ML19253B432
| ML19253B432 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/24/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3--3-A-4, 3-0-3-A-4, NUDOCS 7910150671 | |
| Download: ML19253B432 (4) | |
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ig $[? 28 A8: 4 E Fle-ida Power LO R PO R A is0 N Septen.ber 24, 1979 File:
3-0-3-a-4 Mr. J. P. O'Reilly Director U.S. Nuclear Regulatory Commission Office of Inspection and Enfcrcemen; Suite 3100 101 Marietta Street Atlanta, Ga 30303
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 I.E.Bulletin 79-19
Dear Mr. O'Reilly:
Enclosed is our response to Items 1 thru 9 of I.E.Bulletin 79-19.
Please. contact this office if you require any additional discussion concerning our response.
Very truly yours, FLORIDA POWER CORPORATION]
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.D-dch W. P. Stewart Manager, Nuclear Operations Tibbs (O'Reilly)D88 cc: Division of Fuel Facility and Materials Safety Inspection Office of Inspection and Enforcement U.S. Nuclear Regulatory Com:nission Washington, D.C. 20555 e.
e 1131 013 idocrccoy General Office 32o1 in rty-fourin street soutn. 9 o Box 14o42. st Petersburg Florida 33733 813 - 866-5151 7 91015 0 (7f
v IE BULLETIN 79-19 1.
Maintain a current set cf DOT and NRC regulations concerning the transfer, packaging and transport of low-level radioactive waste material.
Response 1.
A current set of NRC and DOT regulations is maintained by the Chemistry and Radiation Protection Engineer.
2.
Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee.
If a waste collection contractor is used, obtain the approp-iate requirements from the contractor.
Response 2.
Since all CR-3 waste is shipped to South Carolina a copy of the South Carolina agreement State License is maintained by Florida Power Corporation.
3.
Designate, in writing, people in your organization who are responsible for the safe transfer, packaging and transport of low-level radioactive material.
Response 3.
Florida Power Corporation Administrative Instruction AI-200, Organization and Responsiblity, designates 2 Chemistry and Radiation Protection Engineer as being responsible for assuring that radioactive material shipments conforn with applicable NRC, DOT, and State regulations.
4.
Provide management-approved, detailed instructions and operatir.g procedures to all personnel involved in the transfer, packaging and transport of low-level radioactive material.
Special attention should be given to controls on the chemical and physical form of the low-level radioactive material and on the containment integrity of the packaging.
Response 4.
Florida Power Corp. procedure RP-209, Radioactive Waste Shipment Documentation, is being revised to reflect all listed requirements, Plant Review Committee approval is required prior to implementation.
Revised RP-209 procedure will be in effect by November 1, 1979.
Il51 016 Tibbs (O'Reilly)D88
Provide training and periodic retraining in the DOT and NRC regula-tory requirements, the waste burial license requirements, end in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material. Main-tain a record of training dates, attendees, and subject material for future inspections by NRC personnel.
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Response 5.
All personnel involved in the shipp-Ing of radioactive waste will have as a minimum eight (8) hours of class-room training in specified areas.
Training records will be maintained.
6.
Provide training and periodic retraining to those employees who oper-ate the processes which generate waste to assure that the volume of low-level radioactive waste is minimized and that such waste is processed into acceptable chemf cal and physical form for transfer and shipment to a low-level radioactive wacie burial facility.
Response 6: Itaining and periodic retraining is administered to licensed and non-licensed personnel who operate radio-active waste process.
Procedure RP-209, Radioactive Vaste Shipment Documentation, conti,1 packaging and loading for offsite shipment.
7.
Establish and implement a management-controlled audit function of all transfer, packaging and transport activities to provide assurance that personnel, instructions and procedures, and process and trans-port equipment are functioning to ensure safety and compliance with regulatory requirements.
Response 7: Florida Power Corporation will imple-ment its existing Quality Assurance Program (See Response to Item 8) for all transfer, packaging and transport activities to provide assurance that personnel, icstructions and pro-cedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory requirements.
Our existing Quality Assurance Program (submitted as Amendment 52 to the Final Safety Analysis Report for' Crystal River Unit 3, dated 5/9/77, and its Addendum I, dated 5/20/77) satisfies 10 CFR 50 Appendix B and was approved by the Nuclear Regulatory Commission on 5/31/77.
Tibbs(O'Reilly)pB8 1iSi 0i7
f 8.
Perform, within 60 days of the date of this bulletin, a management-controlled audit of your activities associated with the transfer, packaging and transport of low-level radioactive waste.
Maintain a record of all audits for future inspections by NRC or DOT inspectors.
(Note:
If you have an establish d audit function and 9
have performed such an audit of all activities in Items 1-6 within the past six months, this audit requirement is satisfied).
Responsu 8 Audit QP-185 entitled " Rad Waste Tranpc tation" will be conducted and a report issued prior to October 8, 1979.
Audits on this subject will be conducted yearly thereaf ter.
9.
Report, in writing within 45 days, your plan of action and schedule with regard tc the above items.
In addition, provide responses to the three questions below. Reports should be submitted to the Director of the appropriate NRC Regional Office and a copy should be forwarded to the NRC Office of Inspection and Enforcement, Division of Fuel Facility and Materials Safety Inspection, Washington, D.C.
20555.
Provide answers for 1978 and for the first six months of 1979 to the following questions:
1.
How many low-level radioactive waste shipments did you make?
What was the volume of low-level radioactive waste shipped?
(Power reactor licensees who report this information in accordance with Technical Specifications do not need to respond to this question).
Response 9.1: Requested information was reported in the Crystal River Unit 3 Effluent and Waste Disposal Semiannual Report.
2.
What was the quantity (curies) of low-level radioactive waste shipped? What were the major isotopes in the low-level radioactive waste?
(Power reacter licensees who report this information in accordance with Technical Specifications do not need to respond to this question).
Response 9.2: Requested information was reported in the Crystal River Unit 3 Ef fluent and Waste Disposal Semiannual Report.
3.
Did you generate liquid low-level radioactive waste? If the answer is 'yes,' what process was used to solidify the liquid waste?
Response 9.3: ies, low-level radioactive liquid waste was generated. Waste was solidified using a vendor-supplied urea-formaldehyde process and Il5l 018 system.
Tibbs (O'Reilly)D88
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