ML17329A553
| ML17329A553 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/26/1992 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Davis A NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207150024 | |
| Download: ML17329A553 (10) | |
Text
ACCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9207150024 DOC.DATE: 92/06/26 NOTARIZED: NO DOCKET FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan power Co. (formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION DAVIS,A.B.
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 920529 ltr re violations noted in Insp Repts 50-315/92-10
& 50-316/92-10 on 920421-24
& 0513-20.
Corrective actions:waste container returned to licensee radiation measurements performed on contents.
DISTRIBUTION CODE:
IE06D COPIES RECEIVED:LTR J ENCL 2 SIZE:
TITLE: Environ
& Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES:
RECIPIENT ID CODE/NAME PD3-1 LA STANG,J INTERNAL: AEOD/ANDERSONPR COLLINS,D RGN 2
NRR/DLPQ/LPEB10 NRR/PMAS/ILRB12 OE D
G FILE 02 RGN3 DRSS/RPB RGN4 MURRAYEB EXTERNAL: EG&G SIMPSONEF NSIC COPIES LTTR ENCL 1
0 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 2
2 1
1 RECIPIENT ID CODE/NAME PD3-1 PD AEOD/DSP NMSS/SGTB 4E4 NRR/DREP/PRPB10 NUDOCS-ABSTRACT OGC/HDS2 RES RGN3 FILE 01 NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LINIS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 23 ENCL 22
614 223 1CC"
"-RNAH H.ECTRSC PAN%8 AEP NRC:1175A Donald C. Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC ZNSPECTZON REPORT NOS. 50-315/92010 (DRSS)
AND 50-316/92010 (DRSS)i REPLY TO A NOTZCE OF VZOLATZON U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20005 ATTN:
A. B. Davis June 26, 1992
Dear Mr. Davis:
This letter is in response to Ms. Cynthia D. Pederson's letter dated May 29,
- 1992, which forwarded a Notice of Violation that resulted from the inspection conducted April 21 through April 24 and May 13 through May 20, 1992 by members of your staff.
The Notice of Violation attached to Ms. Pederson's letter identified two severity level ZV violations associated with a condition involving the transfer of hazardous solvent waste contaminated with byproduct material to four analytical laboratories and an incinerator vendor,'acilities which did not possess the appropriate license to receive the byproduct material.
Our response to the Notice of Violation is provided in the attachment to this letter.
Sincerely, E. E. Fitzpatrick Vice President eh Attachment 9207150024 920626 PDR ADOCK 05000315 8
Mr. A. B. Davis AEP:NRC:1175A ceo D. H. Williams, Jr.
A. A. Blind - Bridgman J.
R. Padgett G. Charnoff NRC Resident Inspector
- Bridgman NFEM Section Chief A. B. Davis - Region III
Attachment to AEP:NRC:1175A
Response
Attachment 1 to AEP:NRC:1175A Page 1
A.
"Technical Specification 6.8.1.a requires adherence to the applicable procedures recommended in Appendix A
of Regulatory Guide 1.33, February 1978.
Section 7.e.2 of Appendix A requires procedures, for radiation surveys.
Procedure 12 PMP 6010 RPP.301, "Control of Equipment and Material in a
Restricted Area,"
requires surveys be performed on material leaving the restricted control area for unconditional release.
Contrary to the above, prior to March 30, 1992, a barrel of hazardous waste containing radioactive material was released from the restricted control area without the required survey being performed.
This is a Severity Level IV violation (Supplement IV).
(1)
Reason for Violatio The licensee has concluded that the container or its contents (in the form of individual samples) must have been brought out of the restricted area without an unconditional release survey as required by Procedure 12 PMP 6010 RPP.301.
However, at the time of this submittal, no root cause has been determined.
The investigation into the above condition is still in progress.
(2)
Cor ective ctions Take and Results Ach eyed On April 3, 1992, the licensee informed the NRC of the March 30, 1992, notification from a vendor in Arkansas that a barrel labeled as hazardous waste (liquid solvent) received for incineration contained radioactive material.
On April 4, 1992, the waste container was returned to the licensee
- and, subsequently, a
radioactivity analysis was performed on the contents.
Direct radiation measurements confirmed the contents of the barrel contained radioactive material; later analysis showed the barrel contained about 40 microcuries of mixed isotopes (cesium-137 and 134, and cobalt-60).
Surveys of the outside of the barrel and truck bed
Attachment 1 to AEP:NRC:1175A Page 2
indicated no detectable contamination.
No violations of Department of Transportation (DOT) requirements occurred because the radioactivity levels were below the DOT definition of radioactive material.
In addition, radioactivity surveys were performed immediately on any containers of waste of unsure origin in storage outside of the protected area.
A program to analyze the remaining identified waste containers has been established and willbe completed by July 17, 1992.
To date, three additional waste containers in storage outside of the protected area have indicated radioactive contamination.
(3)
Preventive Actions Taken to Avoid Further V olations Preventive actions taken to prevent recurrence of this event include strengthening the unconditional release and chemical control programs to require specific and detailed labeling of waste containers and associated sample containers.
Radiological analyses will be performed on all hazardous waste containers leaving the protected area and site area.
When a container of liquid or sludge is sampled, the waste container will be isolated and a unique seal applied to ensure that the container contents are henceforth unaltered.
Subsequent to isotopic analysis of the sample, another unique seal will be applied to the waste container verifying its disposition and fulfillment of administrative requirements.
Procurement of a unique seal for waste containers is expected early in July, 1992 '
top tier procedure, specifying general chemical waste management requirements, is complete and willbe approved by July 1, 1992.
Full implementation of the chemical waste management program will occur by July 1, 1993.
This will include completion of lower tier procedures associated with specific chemical waste management requirements, and completion of training for all personnel who may have to handle hazardous waste while executing those procedures.
However, in the interim, personnel currently trained
Attachment 1 to AEP:NRC:1175A Page 3
to handle hazardous waste will provide assistance to ensure that radiological analyses willbe performed on all hazardous waste containers leaving the protected area and site area.
(4)
Date When Full Com liance Wi Be Ac eyed Full compliance was achieved when the
- barrel, containing the radioactive material, was received back into the restricted area at Cook Nuclear Plant on April 4, 1992.
B.
10 CFR 30.41(a) and (b)(5)
- require, i'n part, that no licensee. transfer byproduct material except to a person authorized to receive such byproduct material under the terms of a specific or general license issued by the Commission or Agreement State.
Contrary to the'above, on July 29 and 30, October 29, and December 18,
- 1991, the licensee transferred hazardous solvent waste contaminated with byproduct material to four analytical laboratories and an incinerator vendor, persons who were not authorized to possess the byproduct material under the terms of a specific or general license issued by the Commission or Agreement state.
This is a Severity Level IV violation (Supplement IV)."
(1)
Reason for V olatio The licensee has concluded that, prior to the shipment of the hazardous solvent waste, it was unknown that the waste contained byproduct material.
The failure to perform an unconditional release survey of the waste led to the transfer of the radioactive solvent to unlicensed facilities.
2)
Co rect ve ct ons Take and Results Ac ieved On April 3, 1992, the licensee informed the NRC of the March 30, 1992, notification from a vendor in Arkansas that a barrel labeled as hazardous waste (liquid solvent) received for incineration contained
Attachment 1 to AEP 'NRC: 1175A Page 4
radioactive material.
The vendor did not have a
license to receive or possess radioactive material.
On April 4, 1992, the waste container was returned to the licensee
- and, subsequently, a
radioactivity analysis was performed on the contents.
Direct radiation measurements confirmed the contents of the barrel contained radioactive material; later analysis showed the barrel contained about 40 microcuries of mixed isotopes (cesium-137 and 134, and cobalt-60).
Surveys of the outside of the barrel and truck bed indicated no detectable contamination.
No violations of Department of Transportation (DOT) requirements occurred because the radioactivity levels were below the DOT definition of radioactive material.
In addition, radioactivity surveys were performed immediately on any containers of waste of unsure origin in storage outside of the protected area.
A program to analyze the remaining identified waste containers has been established and willbe completed by July 17, 1992.
The licensee issued a
condition report and a
subsequent investigation discovered that samples of the barrel had been sent to several unlicensed laboratories prior to shipment.
These laboratories were also not authorized to receive radioactive material.
Surveys of the laboratories on April 8 and 9, 1992, indicated that no detectable contamination was found.
The licensee's investigation also revealed that on September 14,
- 1991, a spill involving the solvent had occurred in the hazardous waste storage building, but surveys were not performed because the licensee was unaware that the solvent contained radioactive material.
Follow-up surveys (April 4, 1992) indicated fixed contamination levels on sections of the floor up to 40,000 dpm/100 cm~,
and contaminated soil immediately outside the building.
No other equipment or barrels were found contaminated during these surveys'he soil apparently became contaminated from periodic floor sweepings which had been swept outside a
door of the building during the time the'pill occurred and its subsequent discovery.
The
Attachment 1 to AEP:NRC:1175A Page 5
contaminated soil was recovered for disposal and the inspectors verified that the building has been appropriately posted and controlled.
Analysis by an independent laboratory has since determined that the contents of the waste container of issue can be categorized as non-hazardous.
(3)
Prevent ve ction Take to Avo d Further Violations To preclude the possibility of inadvertently shipping a
waste container to an inappropriately licensed facility, administrative guidance willbe in place to ensure that a waste container must have the unique seal indicating an acceptable radiological survey prior to initiation of the manifest.
A top tier procedure, specifying general chemical waste management requirements, is complete and willbe approved by July 1, 1992.
Full implementation of the chemical waste management program will occur by July 1, 1993.
This will include completion of lower tier procedures associated with specific chemical waste management requirements, and completion of training for all personnel who may have to handle hazardous waste while executing those procedures.
However, in the interim, personnel currently trained to handle hazardous waste will provide assistance to ensure that radiological analyses willbe performed on all hazardous waste containers leaving the protected area and site area.
(4) ate Fu Com 1
a ce W 1 Be Ach eyed Full compliance was achieved when the barrel, returned on April 4,
- 1992, and all unprocessed samples were received back into the restricted area at Cook Nuclear Plant.