ML19305C457
| ML19305C457 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/25/1980 |
| From: | Ross D JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19305C453 | List: |
| References | |
| NUDOCS 8003280621 | |
| Download: ML19305C457 (7) | |
Text
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Jersey Central Power & IJght Company
'3/4 Madison Avenue at Punch Bow! Road A
Mornstown, New Jersey 07960 (201)455-8200 February 25, 1980 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch United States Nuclear Regulatory Commission Regicn 1 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Smith:
SUBJECT:
Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 50-219/79-23 This is in reply to your letter of February 5,1980, regarding the inspection conducted by Mr. R. Nimitz on December 9-14, 18-19, 1979 and January 4, 1980 at the Oyster Creek Nuclear Generating Station.
In Appendix A of your letter there are noted several activities which were not conducted in full compliance with NRC regulations.
The specific noncompliances identified, three infractions and one deficiency, and our response to each are given below:
A.
Infraction - 10CFR20.201, " Surveys", states in paragraph (b) that "eacn licensee shall make or cause to be made such surveys as may be necessary for him to comply with the regulations in this part."
Paragraph (a) of 20.201 defines " surveys" as "an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials..."
10CFR20.301, " Waste Disposal", general requirements, specifies that no licensee shall dispose of licensed material except by transfer to an authorized recipient as provided in 10CFR30...
10CFR30.41, " Transfer of byproduct material" requires that no licensee shall transfer byproduct material except as authorized pursuant to this section.
This section permits transfer to persons authorized to receive byproduct material under terms of a licensee issued by an Agreement State.
i Chem Nuclear Systems, Inc.'s Agreement State License for the Barnwell, South Carolina burial site (South Carolina Radioactive Material License No. 097) specifies in license condition 25 that solidified radioactive waste having detectable free standing liquids will not be permitted to be received by the burial site.
South Carolina has defined "no detectable free standing liquid" as less than 1.0% IIquid by volume.
l Contrary to the above, no surveys were performed to determine the l
amount, if any, of free standing liquid in a shipment of dewatered resins (Shipment No. OC-Il48-79) shipped by the licensee to the burial site on December 10, 1979 Notwithstanding, the above shipment, no documentation was available to indicate previous shipments of solidified waste had been surveyed with respect to the above.
Jersey Central Power & Ught Company is a Member of the General Public Utilities System gQD
i IE inspection 50-219/79-23 Page 2 February 25, 1980 Response - Our waste liner supplier was notified of the above non-compliance during the December 9-14, 1979 Inspection.
A design modification which includes a drainage plug at the base of the liner was instituted.
- Also, the internal supports were modified to allow free passage of IIquid.
On January 5, 1980 we received the first load of the modified liners and returned all liners in stock to the supplier for the modifications.
All liners which were filled with process waste as of January 5, 1980, have been drained of free standing liquid, verified by the radwaste supervisor and documented.
In addition, a liner drainage verification procedure, which includes instructions and verification of drainage of free standing liquid has been developed and approved by the PORC and will be used on all future shipments.
A copy of the procedure is included in the shipment document package when the liner is shipped for offsite burial.
A document package for each shipment is kept on file in our document control center.
Full compliance was achieved on January 5, 1980.
In addition to the above actions, equipment modifications are being designed to provide further assurance that the liner contains no free standing liquid.
B.
Infraction - 10CFR71.3, " Requirements for License", requires that no IIcensee subject to the regulations in this part shall (a) deliver any licensed materials to a carrier for transport or (b) transport licensed material except as authorized in a general license or specific license issued by the Commission, or as exempted in this part.
Contrary to the above, on December 10, 1979, and at other times, ship-ments of Ilcensed materials in excess of a Type A quantity were delivered to a carrier for transport without a general por specific IIcense and no exemption in 10CFR71 was applicable.
Response - This non-compliance was the result of shipments made of greater than Type A quantity radioactive material without meeting the require-ments for a general license, that is, not having a copy of the vendor cask drawings referred to in the certification of complience as required by 10CFR71.
12.b,1,2.
After the NRC Inspector notified JCP&L that it was in non-compliance as noted above.
The required documents for full compliance with the regulations were received and in place on December 11, '979 In addition to the above on February 7, 1980 JCP&L received a complete set of our cask suppliers Rad Service manuals.
Each volume contains the cask handling procedures, description, safety analysis, and the certification of compilance with all associated drawings and support documents for a specific type cask.
Additionally, in order to assure full coverage, a new set of shipping procedures are presently being complied.
An individual procedure will exist for l
l m
e
4 IE Inspection 50-219/79-23 Page 3 February 25, 1980 each type cask.
Upon completion the procedures will be reviewed against the requirements set forth in 10CFR71, 49 CFR 170-189 and the individual burial site requirements by a qualified independent consultant.
C.
Infraction - 10CFR50, Domestic Licensing of Production and Utill-zation Facilities, Section 50.59, Changes, Tests and Experiments, specifies in paragraph (a) that the holder of a license authorizing operation of a utilization facility may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
Additionally, 10CFR50.59(c) specifies that the holder of a license authorizing operation of a utilization facility who desires to make a change in technical specification or a change in the facility as described in the safety analysis report shall submit an appilcation for amend-ment of his license.
Contrary to the above, as of December 10, 1979, no application for amendment to the facility license had been made with addressed changes to the facility technical specifications in order to include radioactive effluent releases from the new Radwaste Building.
This building, constructed and placed into operatic:. by the licensee constituted a change in the facility as described in the safety analysis report.
The IIcensee had submitted a safety analysis report pursuant to 10CFR50.59(b) and proposed technical specifications for building settlement in soll.
However, since initial Introduction of radio-active material into this building in October 1978, no submittal has been made addressing the above releases.
Response - Licensing activities for the New Radwaste Facility were undertaken by the General Public Utilities Service Corporation.
Their recommend-ation to the safety committees was that the only Technical Specification required was one for building settling.
The safety committees apparently did not recog-nize or overlooked the fact that a technical specification was required for ventilation releases from the new radwaste facility.
(1)
The corrective step which has been taken was to commit on December 21, 1979 to Mr. J. M. Allan of NRC Region 1 to submit technical spect-fications by March 1, 1980 covering vent releases from both the New Radwaste Facility and the Augmented Offgas System Building.
Technical Specification Change Request No. 79 was submitted February 15, 1980.
The change was made to assure the gaseous effluent releases from the Oyster Creek Station are kept as low as is reasonably achievable, as defined by 10CFR50 Appendix 1.
This change covers releases of noble gases, radiolodines and radioactive materials in particulate form from all release points at the facility.
l (2)
The corrective step that will be taken to prevent further non-l compliances of this type is the use of a Comprehensive System / Equipment Turn-over Sheet which is attached.
This turnover sheet is currently being informally used on a trial basis. When this process is deemed to be working properly it will be formalized by incorporating it into the plant administrative procedures.
This formalization will occur no later than January 1, 1981.
IE inspection 50-219/79-23 Page 4 February 25, 1980 (3)
Full compliance will be met after March 1, 1980 upon receipt from NRC of the approved Technical Specifications.
D.
Deficiency - 10CFR71.62, " Records", requires in part that the licensee shall maintain for a period of 2 years after its generation, a record of each shipment of more than a Type A quantity of radioactive material as defined in 71.4(g) in a single package, showing where applicable, the results of the determinations required by 71.54, " Routine Determinations." These determina-tions include determinations that:
(a) the packaging has not been significantly damaged... (c) the closure of the package and any sealing gaskets are present and are free from defects... and (i) the package has been loaded and closed in accordance with written procedures.
Additionally, 71.62 requires records to be maintained of the results of determinations made pursuant to 10CFR71.53 including:
determinations that there are no cracks, voids or other defects which could reduce the effectiveness of the packaging prior to its first use.
Contrary to the above, the following shipments contained greater than a Type A quantity of radioactive material in a single package and were shipped l
from the 1icensee's facility without record of the above determinations being
)
performed:
Shipment N.
Curie Content
- Date Shipped 3
OC-1018-79 17.78 1/30/79 j
OC-1025-79 8.65 2/21/79 OC-1009-79 77.56 2/14/79 OC-1073-79 35.34 7/23/79
- Transport Group 111 Type A Limit 3 Curles Response - This deficiency resulted from the lack of appropriate records to determine compliance with 10CFR71.53 and 10CFR71.54.
10CFR71.53 address pre-liminary determinations that the radioactive waste shipping container integrity has been ascertained to be effective for use.
10CFR71.54 addresses routine deter-minations that the radwaste shipping container effectiveness has not been reduced.
l The shipping cask supplier has been contacted to ascertain the Informa-tion reon! red by 10CFR71.53 and he has stated that all casks presently being used l
by our 'ac*lity are in compliance with the requirements.
A written statement from l
the cask supplier to that effect is forthcoming.
In addition to the above, JCP&L Quality' Asscance Department will be conducting an audit of our cask suppliers documentation.
The audit results will serve as documentary evidence which will assure full compliance with 10CFR71.53 and 10CFR71.62.
It is planned to complete this audit by April 22, 1980.
The procedure used for packaging radioactive process waste for shipment to offsite burial sites contains a shipment checkoff sheet.
The shipment checkoff i
j IE inspection 50-219/79-23 Page 5 February 25, 1980 sheet has been modified to include specified items which address the routine determinations set forth in 10CFR71.54.
Upon completion of the checkoff sh-et a copy is placed in the shipment document package which is maintained in our document center.
The corrective actions which have been taken have achieved full com-pliance with regard to the nr n-:ompliances listed above.
Jersey Central Power & Light is in the process of upgrading its Quality Assurance program in the area of radioactive waste.
This upgrading is being done in accordance with our commitments to 10CFR71 Appendix E.
In part this includes a significant increase in the surveillance and audit function performed by the QA organization.
This increased effort should address your concern about the Jersey Central Quality Assurance program.
Very truly yours, T
W a
Donald A. Ross, Manager Generating Stations-Nuclear ck L_
't V
SYSTEM / EQUIPMENT 1UR2XNER SHEE.T SystenyTquipment Engineering Task No.
(Nre/ Function) 1.
The purpose cf this turnover sheet is to docununt the turnover systems or equipent from the responsible supervising agency (usually Generation Engineering acting as Project Management) to plant operations. Since a formal procedure does not exist as yet, the turnover sheet should be considered as a guide to turnover.
Items which don't apply should be marked "not applicable"
" (NA) ". The follcwing items, as applicable, could be mnsidered by operations when detennining when to accept a system or equipent:
A.
Specification available and reviewed. (Usually in project package)
B.
Pre-operational System test ccmpleted. Date Reviewed Yes C No Attached Yes No O
Notes:
C.
Q.A. non-conformances in project package.
Reviewed Yes No C Resolved Yes O no O
Notes:
D.
Revisions Subnitted for:
C N/A [
System Prints Yes System Operating procedures Yes C N/A ' C O
n/^ D System Valve lineups Ye's System Electrical lineups Yes O N/A O System Instrument lineups Yes O N/A C Surveillance procedures Yes C N/A C ISI weld & hanger program Yes C N/A ]
ISI pump & valve program Yes C N/A C Electrical PM program Yes [
N/A C
[ N/A [
Mechanical PM program Yes Note: prints include P & ID, Iscrnetric, weld, instrument racks, I
pcwer supplies, valve list, and specific wwnents.
E.
System description available. (May be Generation Engineering or Plant Engineering responsibility, if applicable)
F.
System walked down by plant personnel with latest prints.
G.
Training required ccrnpleted/scFaduled.
' V. ',
,,' ac SYSTEN/rTJUIRE2TP 'IUR?XNER SID7f (cont.)
H.
Spare parts requircrents defined & lists subnitted to appropriate traintenance supervisors I.
Valve line-up verified in accordance with procedure, valves tagged.
J.
Technical Specifications (if required) Approved.
K.
Instrument Calibration Cmpleted.
L.
Procedures revised and' approved.
M.
Job Order ccrrpleted.
N.
Equipment Manuals furnishcd/ processed - To Document Control -
Copy to Maintenance Supervisor.
I accept responsibility / operation control of above name systerry' equiprent without condition or with the following conditions:
List and/or attach schedule e.nd ccmnit:nents, if required.
Review by Supervisor-Station Operation Unit Superintendent Distribution:
PORC Secretary e
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