ML19209C471
| ML19209C471 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/21/1979 |
| From: | William Jones OMAHA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 7910150620 | |
| Download: ML19209C471 (7) | |
Text
CENTRAL FILES PDR:HQ R
IISIC
(
Omaha Public Power District 1623 HARNEY a OMAHA. NEURASKA 60102 s T E LEPHON E 536 4000 AREA CODE 402 September 21, 1979 Mr. K. V. Seyfrit, Director U. S. Nuclear Regulatory Comission Office of Inspection and Enforcement Region IV 611 Byan Plaza Drive Suite 1000 Arlington, Texas 76011 Re feren ce : Docket No. 50-285
Dear Mr. Seyfrit :
The Omaha Public Power District received IE Bulletin 79-19, dated Augus t 10, 1979, requesting that certain actions be taken and documented relating to the packaging of low-level radioactive vaste for transport and burial. Acccrdingly, the attached information responds to your reque s t.
Sincerely, flj$' ()G2 l
W. C. Jones Division Manager Production Operations WCJ/KJM/BJH:jmm Attach.
cc:
U. S. Nuclear Regulatory Connission Office of Inspection and Enforcement Division of Fuel Facility & Materials Safety Inspection Washington, D. C.
20555 LeBoeuf, Lamb, Leiby & MacRae 1333 dev Hampshire Avenue, N. W.
Washington, D. C.
20036 1134 2i3 7 910150 b
ATTACH!ENT Ouestion 1.
Maintain a current set of DOT and URC regule. cions concerning the transfer, packaging, and transport of low-level radioactive waste material.
Response
The Omaha Public Power District maintains a current set of the Code of Federal Regulations, specifically Titles 10 and 49 The updated copies of these regulations are kept at the Fort Calhoun Station, as well as at the District's Production Operations headquarters at Jones Street Station.
Question 2.
Maintain a current set of requirements (license) placed on the vaste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive vaste material for transfer and shipment to the Agreement State licensee.
If a vaste collection contractor is used, obtain the appropriate requirements from the contractor.
Response
The Distric is using the services of Chen-Huclear Systems, Inc. of Orchard Park, New York.
All radioactive vaste shipped out by Chem-Huclear Systers, Inc. fron Fort Calhoun Station is buried at Barnwell, South Carolin a.
The District maintains a copy of the procedurea and require-ments placed by Chen-Nuclear Systems, Inc. regarding shipments of radio-active vaste.
Question 3.
Desigante, in writing, people in your organization who are responsible for the safe transfer, packaging, and transport of low-level radioactive cate ri al.
Response
Standing Order T 4, " Waste Solids Shipment", is an administrative procedure of the Fort Calhoun Station Operating Manual.
Persons who are responsible for the safe transfer, packaging, and transport of low-level radioactive material are desigaated, in writing, in Standing Order T-4.
The Plant Health Physicist provides certification that all shipments are authorized for release. The Supervisor - Chemistry and Radiation Pro-tection provides final review and approval prior to release from the site.
In addition, the Radiation Protection Manual, Section 6. 3, " Transportation of Radioactive Materials", and Health Physics Procedure HP-3, " Solid Waste Shipment Procedures", describe the responsibility of the Plant Manager, the Health Physics Technicians, the Shift Supervisor, and the Security Guard during the preparation of each vaste shipment.
I134 2i4 1
e
Question h.
Provide management-approved detailed instructions and operating pro-cedures to all personnel involved in the transfer, packaging, and trans-port of low-IcVel radioactive caterial.
Special attention should be given to centrols on the chemical and physical form of the low-level radioactive material and on the containment integrity of the packaging.
Response
The " Solid Waste Shiptent Procedures", HP-3, delineates all specific requirements for the shipment of the radioactive naterials from the Fort Calhoun Station.
The procedure, HP-3, has been reviewed and approved by the Plant Review Committee and is incorporated in the Fort Calhowa Station Radiation Protection Manual.
The " Solid Waste Shipment Procedures", along with Standing Order T h, have been provided to all personnel involved in the transfer, packaging, and transport of low-level radioactive material.
Question S.
Provide training and periodic retraining in the DOT and NRC regula-tory requirements, the vaste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packagir.g, and transport of radioactive material.
Maintain a record cf training dates, attendees, and subject material for future inspections by :!RC personnel.
Respense All personnel involved in the transfer, packaging, and transport of radioactive material are scheduled for training prior to September 28, 1979 These persons include the General Maintenance and Health Physics Groups.
Training vill include a discussion of items III-l through III-6, excluding III-5, of the attached Lesson Plan.
Retraining vill be con-ducted annually or when changes to any of the present requirements or procedures are issued, whichever is sooner.
Question 6.
Provide training and periodic retraining to those employees who operate the processes which generate vaste to assure that the volume of low-level radioactive vaste is minimized and that such vaste is pro-cessed into acceptable chemical and physical form for transfer and shipment to e low-level radioactive vaste burial facility.
Resnonce All personnel who operate the processes which generate vaste vill be trained to assure that the volume of low-level radioactive vaste is minimized and that such vaste is processed into acceptable chemical and i134 215
' Resnonce (Continued) physical form for transfer and shipment to a low-level radioactive vaste burial facility.
These nersons vill include Operations and Health Physics personnel.
Training for these personnel vill be completed prior to October 15, 1979, and will include a discussion of items III-l through III-6 of the attached Lesson Plan.
Retraining vill be conducted annually or when changes to any of the present requirements or procedures are issued, whichever is scener, h
UdBQIII'Il Question 7 l
UUll L
Establish and icplement a management-controlled audit function of all transfer, packaging, and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equiptent are functioning to ensure safety and compliance with regula-tory requirements.
Resnonse Quality Assurance Procedure #2, " Audit Plans", and Quality Assurance Procedure #16, " Internal Audit Cycle for QA Program", have been revised to require an annual audit by the Quality Assurance Department of all transfer, packaging, and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equip-ment are fuactioning to ensure safety and compliance with regulatory requiremen ts.
The revised Quality Assurance Procedure #2 specifies that the audit p' - kall verify " maintenance of a current set of DOT and NRC regulaticr.z, and requirements (license) placed on vaste burial firn by the Agreez.ent State; written desicaation of rcoponsible per-scnnel within GPPJ; manscenent-approved, detailed instructions and operating procedures; records of training and periedic retraining for both those involved in transfer, packaging. and transport and those involved in the procetees which generate vaste".
Question 8.
Perform, within 60 days of one date of this bulletin, a management-ccntrolled audit of your activities associated with the transfer, packag-ing, and transport of low-level radioactive vaste.
Maintain a record of.11 audits for future inspections by URC or DOT inspectors.
Re spon se See response to question 7 The audit plan has been issued and the audit is scheduled to be completed by September 28, 1979, by the Quality Assurance Deoartment.
Records of all Quality Assurance audits are main-tained by the Corporate Quality Assurance Engineer.
Question 9 Provide ansvers for 1978 and for the first six months of 1979 to the following questions:
1134 216 3
- Question 9. (Continued) 1.
How many low-level radioactive vaste shipments did you make?
What was the volume of low-level radioactive vaste shipped?
(Power reactor licensees who report this information in ac-cordance with Technical Specifications do not need to res-pond to this question. )
2.
What was the qu1ntity (curies) of low-level radioactive vaste shipped? What were the major isotopes in the low-IcVel radioactive vaste?
(Power reactor licensees who report this information in ac-cordance with Technical Specifications do not need to res-pond to this question. )
3 Did you cencrate liquid low-level radioactive vaste? If the answer is "yes", what process was used to solidify the liquid vaste?
Licensees who do not generate low-level radioactive <aste should so indicate in their responses and do not need to take c,ber : Actions specified in the above items.
Response
1.
This information is reported to the Commission semi-annually in accordance with Section 5 9.h of the Technica.'. Specifi-caticns.
2.
See 1. above.
3 Low-level liquid radioactive waste is generated at the Fort Calhoun Station and cement absorbent is used to solidify the liquid vaste.
0001DUiR 1134 2i7 a
IESSON PIRI I.
Training
Subject:
Packaging of Low-Level Radioactive Waste for Transport and Burial II.
Re ferences :
1 b
1.
URC IE Bulletin 79-19, dated August 10, 1979 E.
DOT Regulations 49 CFR 170-179 3
10 CFR Parts 19 to 71.
h.
5 Chem-Nuclear Systens letter #S-3009, dated July 31, 1979 6.
Chen-Nuclear Systems letter #N00-78-749, "Barnwell Site Dis-pecal Criteria", dated December 15, 1978.
7 Chem-Uuclear Systems letter # SEQ h39, dated September 28, 1978.
8.
Chem-Huclear Systems, Radioactive Material License #097, Amend-ment #22, dated January,1979 9
Chem-Uni.. ear Systems letter M;00-79 487, dated May 29, 1979 10.
Str. air.g Orh r T L, " Waste Solids Release".
11.
Radiation Protection Manual, Sections 6.3 to 6.7, "Transporta-tion of Radioactive Material, Loading, and Shipment of Waste Drums".
12.
EP-3, " Solids Waste Shipment Procedures".
13 OI-WDS-1, 01-WDL-2, OI-WDL-1, " Waste Processing and Solidifi-cation".
III.
Instructions:
1.
Discuss the requirements of reference 1.
2.
Review guidelines and requirements of Barnwell burial site, references 5.,
6.,
7.,
8., and 9 3
Review the applicable sections of references 2., 3., and 4.
pertaining to shipment of low-level radioactive vaste.
h.
Review the requirements of local procedures, references 10.,
- 11., and 12.
1134 218
- 14. _ A I,I I.
Instructions: (Continued) 5 Review reference 13., Operating Instruction.
6.
Dnphasize that no liquida are allowed in vaste drums to be shipped.
IV.
Su rarize and Answer Questions 1134 219
... _