ML19262C568

Forwards Revised Response to IE Bulletin 79-19, Packaging of Low Level Radwaste for Transport & Burial. DOT & NRC Regulations Re Transfer Packaging & Transport of Radwaste Revised Continually as Changes Are Proposed & Implemented

ML19262C568
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/30/1979
From:	Trimble D ARKANSAS POWER & LIGHT CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
IEB-79-19, NUDOCS 8002140513
Download: ML19262C568 (5)

Text

bec to DAC *

CENTRAL p1LES 3

POR$Q i LPOR MSIC ARKANSAS POWER & LIGHT COMPANY bTATE POST OFFICE BOX 551 UTTLE PCCK. ARKANSAS 72203 (501) 371-4000 November 30, 1979 -

1-119-21 2-119-14 Mr. K. V. Seyfrit, Director Office of Inspection & Enforcement U. S. Nuc l e ar Regul a t ory Comm.

Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Subject:

Arkansas Nuclear One-Units 1 & 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Revised Response to I . E. Bulletin 79-19 (File: 1510.1 and 2-1510.1)

Genticmen:

By letter dated September 28, 1979, we provided our initial reponse to the subject bulletin. As a result of the review of the waste management audit required by the subject bulle-tin, attached is a revised response to the bulletin. The ve r t i c al lines indicate which responses have been changed.

Very truly yours ,

b OAkN 0. V David C. Trimble Manager, Licensing DCT / MAS /ew Attachment cc: Mr. W. D. Johnson-U. S. Nuclear Regulatory Comm.

P. O. Box 2090 Russellville, Ark. 72801 Mr. James A. Sniezek, Director Division of Fuel Facilities and Materials Safety Inspection NRC Office of Inspection and Enf gement Washington, D. C. 20555 8002,140

Attachment A Response to IE Bulletin 79-19 Iten 1. Maintain a current set of DOT and NRC regulations concerning the transfer, packaging and transport of low-level radioactive waste material.

Response: ANO's current set of DOT and NRC regulations concern-ing transfer, packaging and transport are revised con-tinually as changes are proposed and implemented by DOT and NRC.

Item 2. Maintain a current set of requirements (license) placed on the waste burial f i rm by t he Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste ma-terial for transfer and shipment to the Agreement State licensee. If a we.ste collection contractor is used, obtain the appropriate requirements from the contractor.

Response: Current burial site regulations and license re-quirements are maintained at ANO for the Barnwell burial site. Site and license regulations for Nevada and Washington will be available before any radwaste shipments are initiated to these sites but no later than January, 1980. These burial site regulations are updated when changes are identified and implemented by the subject states or burial site operation.

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

Response: Although no individual has previously been desig-nated in writing, the Heal t h Phys ics Supervisor at Arkansas Nuclear One has been responsible in the past for the safe transfer, packaging and transport of low-level radioactive material. An individual now has been designated in writing to perform these tasks.

Item 4. Provide management approved, detailed instruc-tions and operating procedures to all personnel involved in the transfer, packaging and transport of low-level radioactive materi=1 Special atten-tion should be given to contro:- on the chemical and physical for of the low-level radioactive material and on che containment integrity of the packaging.

Response: Pursuant to the audit performed in response to item 8 of IE Bulletin 79-19, revised pro-cedures relating to NRC, DOT, and state waste burial license requirements are being prepared.

These procedures will be c omp t e t ed in January. 1980 and will be approved for implementation by Feb-ruary, 1980.

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

Response: Consistent with the audit referenced in Item 4, above, and the implementation of revised procedures relating to DOT and NRC requirements and waste burial license requirements, training of responsible ANO personnel will commence in Feb-ruary, 198 0, on implementation of these revised proedures. Training and retraining will be per-formed on a regular basis consistent with ANO's needs and the overall radwaste training program.

Item 6. Provide training and periodic retraining to those employees who operate the processes which generate waste to assure that the volume of low-level radioactive waste is minimized and that such aste is processed into acceptable chemical and physical f o rm for transfer and shipment to a low-level radioactive wa s t e bur i a l facility.

Response: The radwaste operations, including operating procedures, are currently being reviewed and will be revised as required. This radwaste operational review will be completed by April, 1980. Based upon this review, a training progren will be devel-oped and implemented by June, 1980 and initial training of all ANO personnel responsible for

-adwaste process operation will be c omp l e t ed b y July, 1980. A retraining program including rad-waste processing and radwaste packaging and trans-port will be in place upon completion of initial training. Retraining will occur as necessary to reflect changes in operating procedures and govern-ing regulations. Such retraining will occur at least annually.

I t en 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 equipment are functioning to ensure safety and co=pliance with regulatory requirements.

Response: A management-Controlled audit will be performed as necessary, but a minimum of once a year, of all transfer, packaging and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory requirements.

Item 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 in-spections by NRC or DOT inspectors. (Note: If you have an established audit function and have per-formed such an audit of all activities in Items 1-6 within the past six months, this audit requirement is s a t i s f i ed.)

Response: A r.anagement-controlled audit of our activities associated with the transfer, packaging and trans-port of low-level radioactive waste has been per-formed. A record of all audits will be maintained for future inspection by NRC or DOT inspectors.

The following is provided to answer the questions asked on page 3 of IE Bulle tin 79-19 for 1978 and the first six months of 1979:

1. For Ic73, 26 shipments of low-level radioactive wastes were made. This consisted of approximately 7850 cubic feet. For the first six months of 1979. 10 shipments of low-level radioactive waste were made. This con-s i s t ed o f approxima t el y 5041 cubic feet.

2. For 1c73, approximat ely 4 6 0 curies of low-level radio-active va s t e we re shipped. For the first six months of 1979, approximately 750 curies of low-level radioactive waste were shipped. The major isotopes in the low-level radioactive waste included:

Cr - 51 Nb - 95 Sb - 125 Mn - 54 I- 131 Sr - Yu Mn - 56 Cs - 134 Fe - 59 Cs - 137 Co - 58 Cs - 138 Co -

60 H- 3 Co - 57 Ag - 110m Zr - 95 Sb - 122

3. Liquid radioactive waste was generated. No liquid radioactive waste was solidified or shipped, but was processed, treated, and released in accordance with Technical Specification limits.

_4