ML19256G399

Responds to IE Bulletin 79-19, Packaging of Low Level Radwaste for Transport & Burial. Sixteen Shipments Made in Jan 1978-June 1979

ML19256G399
Person / Time
Site:	North Carolina State University
Issue date:	12/06/1979
From:	Morgan D North Carolina State University, RALEIGH, NC
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
IEB-79-19, NUDOCS 7912310223
Download: ML19256G399 (3)

Text

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.7 NORTH CAROLINA STATE UNIVERSITY AT RALEIGH

~[ 'W .; : 00 Reunow Paoncnow Orner 6 December 1979 Box 5344 Zaxxay; 27650 Mr. James P. Reilly, Director U.S. Nuclear Regulatory Commission Region II 101 Marietta Street NW Atlanta, GA 30303

Dear Sir:

This constitutes North Carolina State University's response to I.E. Bulletin No. 79-19 entitled " Packaging Low-Level Radioactive Waste for Transport and Burial." We have responded to each of the appropriate action items and re-quests for information as was stated in the bulletin. In this connection, our responses relate to all NCSU low-level radioactive waste which includes material covered under our Agreement States License and our Reactor Facility License. The waste generated in relation to the operction of the PULSTAR Reactor consists only of solid waste and represented only 7.5% of the waste on a total volume basis during the reporting period. In our estimation, this value is an accurate assessment of the portion of our waste which will result from the operation of the reactor in the future.

ACTION ITEMS

1. Maintain a current set of DOT and NRC regulations concerning the transfer, packaging, and transport of low-level radioactive waste material.

Both the NCSU Radiation Protection Office and the PULSTAR Reactor Health Physics Office maintain complete and up-to-date copies of the DOT and NRC regulations regarding the packaging and transport of low-level radioactive vaste caterial.

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 appropriate requirements from the contractor.

NCSU maintains a current set of license requirements as placed on both Chem-Nuclear Systems, Inc. and Nuclear Engineering Co.,

Inc. by the Agreement States of South Carolina and Washington

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respectively. These license doc ~ments were supplied directly by these two vaste disposal firms since they also transport our waste to the disposal sites.

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3. Designate, in writing, people in your organization who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

a) L. T. Caruthers, Radiation Protection Officer b) D. W. Morgan, Associate Radiation Protection Officer c) R. O. Mangum, Radiation Survey Supervisor d) R. D. Cross, Reactor Health Physicist 4 Provide management-approved, detailed instructions and operating pro-cedures to all personnel involved in the transfer, packaging and trans-port 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.

Staff members of the NCSU Radiation Protection Office perform all of the final steps in the packaging of low-level radioactive vaste material including controls on the physical form and the sealing of the shipping containers. In this regard, detailed instructions are provided both through written procedures and checklists and through direct supervision by the Radiation Survey Supervisor.

Controls on the chemical make-up of the waste material are effected through instructions which are issued to the various users on campus.

5. Provide training and periodic retraining in the DOT and NRC regulatory requirements, the vaste burial license requirements, and in your in-structions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material, Maintain a record of training dates, attendees, and subject material for future inspections by NRC personnel.

The Radiation Survey Supervisor serves as the individual responsible for the training of personnel of the Radiation Protection Office in the applicable provisions of the DOT and NRC regulations. New em-ployees will be trained as appropriate and retraining of all employees will take place every six months. Records of such training will be maintained.

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 waste is minimized and that such vaste is processed into acceptable chemical and physical form for transfer and shipment to a low-level radioactive vaste burial facility.

Training and periodic retraining of those users on campus who generate waste to assure that the volume of low-level radioactive vaste is minimized and that such vaste is processed into acceptable chemical and physical form is managed through instructions in the NCSU Radiation Protection Handbook and additional appropriate and timely written instructions Snxn the Radiation Protection Office. This is also effected by periodic in-laboratory radiological surveillance inspections.

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7 Establish and Onplement a management-controlled audit function of all transfer, packaging and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equip-ment are functioning to ensure safety and compliance with regulatory requirements.

Management-controlled audit of all waste disposal operations will be maintained through a systen where all instructions, procedures, checklists and shipping documents will be reviewed by the Associate Radiation Protection Officer and/or the Radiation Protection Of .cer.

In addition, periodic direct inspections of disposal operations will be conducted by the Associate Radiation Protection Officer and/or the Radiation Protection Officer; such inspections will be documented.

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 established audit function and have performed such an audit of all activities in Items 1-6 within the past six months, this audit requirement is satisfied.)

This function is continuously being performed as per Item 7 above.

INFORMATION ITEMS Answers are provided for 1978 and for the first six months of 1979 as follows:

1. How many low-level radioactive waste shipments did you make? What was the volume of low-level radioactive waste shipped?

NCSU made a total of 16 shipments of low-level radioactive waste during the reporting period. The total volume of this vaste amounted to 757.5 cubic feet.

2. What was the quantity (curies) of low-level radioactive waste shipped?

What were the major isotopes i- the low-level radioactive waste?

The total quantity of radioactive vaste shipped during this period amounted to 0.642 Curies. The major radionuclides involved were 14C , 3 H, 32p, 125 7, 51Cr, and 59 pe,

3. Did you generate liquid low-level radioactive waste? If the answer is

'yes,' what process was used to solidify the liquid waste?

Liquid wastes were generated during the reporting period. They were absorbed in grade-4 vermiculite, ectfully su

• ted, if9ey. -

. . organ A iate Radiation P ote' ion Officer cc: Nuclear Regulatory Commission Office of Inspection & Enforcement

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