ML19254E256
| ML19254E256 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/26/1979 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 7910310384 | |
| Download: ML19254E256 (8) | |
Text
TC GENER AL h ELECTRIC NUCLEAR ENERGY PRODUCTS DIVISION WILMINGTON MANUFACTURING CASTLE HAYNE ROAD P.O. BOX 780 e WILMINGTON. N.C. 28401. (919) 343 5000 D ARWEW September 26, 1979 Mr. J. P. O'Reilly, Regional Director U. S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Reference:
NRC License SNM-1097, Docket #70-1113
Subject:
With reference to activities authorized by SNM-1097 at the GE: fuel. - -
fabrication plant in Wilmington, North Carolina, General Electric Q Company hereby submits the response to NRC IE Bulletin No. 7F19,
" Packaging of Low-Level Radioactive Waste.for Transport and Burial,"~,.
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as required by the Bulletin.
y our plan of action and schedule with regard to the eight item's' related to the subject of the Bulletin, and answers to the th~ e questions related to low-level radioactive waste shipments in@the Bulletin, are enci Sed in Attachments 1 and 2, respectively, to this letter.
General Electric Company personnel would be pleased to discuss this matter with your staff a:2 you may deem necessary.
Very truly yours, GENERAL ELECTRIC COMPINY Arthur L. Kap an, Manager Licensing & Compliance Audits M/C J26 ALK:bmw NSD-L+
Attachments 1248 165 7910310 C
GENERALh ELECTRIC
. J. P. O'Reilly
.ptember 26, 1979 tachment 1 - Page 1 ble U#
ATTACHMENT 1 PLAN OF ACTION & SCHEDULE RELATED TO ITEMS 1-9 IN NRC IE BULLETIN NO. 79-19 e following are the plan and the schedule tc implement the actions quired in IE Bulletin No. 79-19, relative to the eight items garding packaging of low-level radioactive waste for transport and urial.
1.
Maintain a current set of DOT nd NRC regulations concerning the transfer, packaging and transport of low-level radioactive waste material.
e e Manager, Licensing & Compliance Audits, is currently responsible r and is presently maintaining a current set of DOT and NRC gulations.
He accomplishes this by subscribing to and reviewing e following government documents:
e Rules and Regulations, Title 10 - Chapter 1, Code of Federal Regulations, U. S. Government Printing Office e
Federal Register, U. S. Government Printing Office e
Hazardous Materials Regulations of the Department of Transportation, R. M.
Graziano, Associaticn of American Railroads, Bureau of Explosives (covers Code of Federal Regulations, Title 49) 2.
Maintain a current set of requirements (license) placed nnel on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level 8
radioactive waste material for transfer and shipment to the ts.
Agreement State licensee. If a waste collection contractor is used, cbtain the apnropriate requirements freci the contracter.
t the present time, low-lu.
radioactiv'e waste is being shipped the burial site in Barnwell, South Carolina, being operated by em-Nuclear Systems. Irc.
Our contract with the vendor stipulates,
.ong other items, that:
.e The vendor takes possession of the waste material at our property boundary and therefore is responsible for shipping the material to his birial site.
e The vendor must supply us with the intest copies of licenses and amendments thereto issued to him by the NRC and the State of South Carolina.
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Mr. J. P. O'Reilly September 26, 1979 - Page 3 our present training program for all* employees working with the processing of uranium for fuel manufacturing, which is administered on an annual basis, includes general information related to safe handling of radioactive materials.
However, there are no specific references to this subject for low-level radioactive waste materials.
Therefore, an appropriate training program will be prepared to cover NRC and DOT regulations requirements, waste burial license require-ments, and related instructions and operating procedures.
This program will be administered to all personnel involved in the handling of radioactive waste material.
A retraining schedule will be established.
Records of training dates, attendees, and subject material will be established and maintained.
These actions will be implemented by December 31, 1979.
6.
Provide training and periodic retraining to those employees who operate the processes which ger:- ate waste to assure that the volume of low-level radioact ve waste is i
minimized and that such waste is processed into acceptable.
chemical and physical form for transfer and shipment to a low-level radioactive waste burial facility, In the same manner as that related to Question 5 above; our present training program for all (mployees working with the processing of uranium for fuel manufacturing, which is administered on an annual basis, includes general information related to minimizing the generation of low-level radioactive waste pinpointed for disposal by burial.
However, there is no specific formal tr'aining of employees who operate the specific processes which generate this kind of waste, other than the on-the-job training they receive.
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Therefore, an appropriate training program will be prepared to cover the two points stipulated:
e Minimizing volume of low-level radioactive waste scheduled for disposal by burial.,
o Processing cf 2"Th w:Ite into acceptable chemical and physical form for transfer and shipment to a low-level radioactive waste burial facility.
f j
Also, in addition to preparing the training program, provision will be made for training and retraining the foreman of the employees involved in operating the specific processes of concern.
This foreman will, 4
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Mr. J. P. O'Reilly September 26, 1979 - Page 4 in turn, arrange for training and pe,giodic retraining of these employees utilizing the training program specifically prepared for this forer.an.
These actions will be implemented by December 31, 1979.
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 transport quipment are function-e ing to ensure safety and compliance with regulatory require-
=snts.
There is presently an internal, management-controlled audit function established within the General Electric Wilmington Manufacturing Department, which was established to assure, among other things, compliance of Department operations with appropriate NRC, DOT and State regulatory and license requirements.
This audit function, currently assigned to the Manager, Licensing & Compliance Audits, is therefore responsible for auditing transfer, packaging and transport activities related to low-level radioactive waste scheduled for disposal by burial, to provide the cequired assurances as stated above.
8.
Perform, within 60 days of the date of this bulletin, a managenent-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 established audit function and have performed such an audit of all activities in Iters 1-6 within the past six months, this audit requirement is satisfied.)
An audit of our activities related to packaging and transportation of radioactive materials, was conducted on August 27 - September 7, 1979.
Part of this audit was concerned with the activities described
- above, Therefore, we conclude that the audit requirement stipulated above has been satisfied.
O e,
F T
1248 168 e
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Mr. J. P. O'Reilly September 26, 1979 - Page 5 a
9.
Report, in writing *within 45 days, your plan of action and schedule with regard to 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 Cffice of Inspection and Enforcement, Division of Ftiel Facility and Materials Safety Inspection, Washington, D. C.
20555.
This letter, along with its two attachments, mailed by September 26, 1979, (within 45 days from the documented date of our receipt on August 27, 1979, of IE Bulletin No. 79-19) constitutes our compliance with this requirement.
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g A. L. Kaplan
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- 4. J. P. O'Reilly September 26, 1979 - Page 1 ATTACHMENT 2 ANSWERS TO QUESTIONS RELATED TO LOW-LEVEL RADIOACTIVE WASTE IN NRC IE BULLETIN NO. 79-19 Answers to the three questions relative to low-level radioactive waste generation and shipment, which were raised in NRC IE Bulletin No. 79-19, are given below.
1.
How many low-level radioactive waste shipments did you make? What was the volu=e of low-level radioactive waste shipped?
The number of low-level radioactive waste shipments made for e
disposal by burial are as follows:
1978 (entire year)
- 15 shipments 1979 (January 1 to June 30) - 22 shipments The volume of low-level radioactive waste shipped for disposal e
by burial is as follows:
1978 (entire year)
- 34,620 cubic feet ( 980.3 cubic meters) 1979 (January 1 to June 30) - 50,776 cubic feet (1437.8 cubic meters) 2.
What was the quantity (curies) of l'ow-level radio-active waste shipped? What were the major isotopes in the low-level radioactive waste?
e Quantity (curies) of low level radioactive waste shipped for disposal by burial is as follows:
1978 (entire year)
- 0.316 curie 1979 (January 1 to June 30) - 0.532 curie 1248 170
Mr. J. P. O'Reilly September 26, 1979 - Page 2 (Question #2 - continued) t e Major isotopes in the low level radioactive waste are as follows:
Activity, curie's 1979 (First Isotope 1978 6 months)
U-234 0.196 0.331 U-235 0.013 0.022 U-236 0.003 0.005 U-238 0.087 0.144 3.
Did you generate liquid low-level radioactive waste?
If the answer is "yes", what process was used to solidify the liquid waste?
Yes, we have accumulated oil which contains low levels of uranium.
At the present time, we are storing this oil pending our decision on final disposition.
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A. L. Kaplan
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