ML19209C508

Responds to IE Bulletin 79-19, Packaging of Low Level Radwaste for Transport & Burial. Maintains Radioactive Matls Shipping Manual Containing Applicable Parts of CFR Pertaining to Radioactivve Shipments

ML19209C508
Person / Time
Site:	Cooper
Issue date:	08/31/1979
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
NUDOCS 7910160041
Download: ML19209C508 (3)

Text

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ic t P.O. BOX 98. OROWNVILLE NcBR ASKA 68321 1cteenoNe<4o2,82s.3811 August 31, 1979 Mr. Karl V. Seyfrit, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Suite 1000 Arlington, Texas 76011

Subject:

Response to IE Bulletin No. 79-19

Dear Mr. Seyfrit:

This letter is written in response to IE Bulletin No. 79-19, Packaging of Low-Level Radioactive Waste For Transport and Burial. The following items 1 through 9 address the corresponding actions and answers re-quested in the subject bulletin.

Item 1 Cooper Nuclear Station maintains a Radioactive Materials Shipping Manual containing applicable parts of the Code of Fcderal Regulations pertain-ing to radioactive material shipments. The services of a firm special-izing in radioactive material shipping regulations provides updated copies of these regulations as they become available.

Item 2 A current set of requirements (license) placed on the waste burial firm by the agreement states of Nevada and of Washington were obtained prior to shipping radioactive wastes to these burial sites. Low-level radio-active wastes are not being shipped to the South Carolina facility, but if circumstances should dictate that future shipments to this facility will be mada, a current set of requirements (license) placed on the burial firm will be obtained prior to such shipments.

Item 3 Cooper Nuclear Station r perating procedures delineate responsibilities of and provides instructions to station personnel concerning the trans-1147 117 791016004-/

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Mr. K. V. Seyfrit August 31, 1979 Page 2.

fer, packaging and transport of low-level radioactive wastes. Oper-ations personnel process and package low-level radioactive wastes in accordance with installed equipment design and packaging requirements.

Chemistry and Health Physics personnel monitor the transfer and pack-aging of these low-level radioactive wastes. Shipments, transported by a contract carrier, are inspected prior to leaving the station. The Chemistry and Health Physics Supervisor has the overall responsibility to ensure low-level radioactive wastes are packaged and transported within DOT and NRC regulrements.

Item 4 Management approved detailed operating procedures for transfer, pack-aging and transport of radioactive material have been in use at Cooper Nuclear Station since 1974. Review of these procedures are performed on a scheduled basis. Revisions may be made anytime to ensure procedure adequacy. Instructions and procedures provide controls on the chemical and physical form and packaging integrity of the low-level radioactive waste material.

Item 5 Indicated training for appropriate personnel will be completed by November 16, 1979. Retraining for appropriate personnel involved in the transfer, packaging and transport of radioactive material will be sched-uled periodically. Training records will be available for future in-spection by NRC personnel. ,

Item 6 Indicated training for appropriate personne . tl be completed by November 16, 1979. Retraining for appropriate personnel involved in the processing of low-level radioactive wastes will be scheduled period-ically. Responsible personnel are aware of the need to minimize waste volumes and control the chemical and physical form of the low-level radioactive wastes. Training records will be available for future in-spection by NRC personael.

Item 7 Management controlled audit functions of Cooper Nuclear Station radwaste control have been in effect since 1974. The basis for these management controlled audits is Quality Assurance Plan (QAP)-1200 entitled " Radio-active Waste Treatment and Dicposal". Audits of radwaste control are divided into three levels. One level of audits involves the Safety I147 118

Mr. K. V. Seyfrit Pa . I Review and Audit Board (SRAB). This is a corporate management audit designed to verify that adequate levels of management control over radwaste disposal are being implemented at Cooper Nuclear Station. The next level of audits are conducted by an independent Quality Assurance staff located at Cooper Nuclear Station. This level of audit monitors personnel training; compliance with Technical Specifications; compliance with packaging, handling and shipping requirements for radioactive waste; compliance with station control procedures; and monitors the level and adequacy of station quality control practices. The final level of audits involves CNS management. This level includes the Station Operation and Review Committee (SORC) and provides for direct management and overview of radwaste handling and disposal.

Item 8 Corporate level audits are conducted once every two years. The 1979-80 SRAB audit is currently in progress. The independent QA organization audits are scheduled on a yearly basis, the last audit having been conducted February 28, 1978, with the next audit scheduled for com-pletion by August 31, 1979. CNS management control audits are a con-tinuous process in which CNS management raviews all radwaste packaging, handling and transfer functions as they occur.

Item 9 Responses to the three questions of Item 9 are given below.

162. Sea Cooper Nuclear Station's Semiannual Operating Report - Radio-active Effluents submitted in accordance with Technical Specifi-cations.

3. Yes, low-level liquid radioactive wastes are generated at Cooper Nuclear Station; however, to date these wastes have not been sol-idified. Discharge data is available in the Cooper Nuclear Station's Semiannual Operating Report - Radioactive Effluents submitted in accordance with Technical Specifications.

If you have any questions regarding this response, please contact me.

Sincerely, N

Jay M. Pilant Director of Licensing and Quality Assurance JMP:LCL:cg 1147 iM cc: Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Fuel Facility and Materials Safety Inspection Washington, D.C. 20555

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