ML19351A450
| ML19351A450 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/06/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8912140221 | |
| Download: ML19351A450 (5) | |
Text
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E* J BALTIMORE GAS AND
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ELECTRIC CHARLES CENTER.P.O. BOX 1475 BALTIMORE, MARYLAND 21203 P
GEORCE C CREEL -
December 6,1989 Viet Pntsiotut Noct. an Ektmov -
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U. S. Nuclear! Regulatory Commisslorc
' Washington, DC 20555 L
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ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear ' Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Response to Notice of Violation, Inspection Report Nos. 50-317/89-24, 50-318/89-25
REFERENCES:
(a) Letter from M. R. Knapp (NRC) to G. C. Creel (BG&E), dated November 7,
1989, Notice of Violation (Enforcement Conference
' Report Nos. 50-317/89-24, 50-318/89-25)
(b) Letter from S.
A. Varga (NRC) to G. C. Creel (BG&E), dated May 23,1989, Special Team Inspection 89-200/89-200 (c) Letter from G. C. Creel (BG&n) to Document Control Desk (NRC),
stated June 21, 1989, Response to Inspection Report 89-200/89-200 4
Gentlemen:
As requested in Reference (a), Baltimore G'as & Electric (BG&E) is ' providing the following response-to the Notice of Violation. Two Severity Level IV violations were assessed against our radioactive waste processing and shipping program. Additional information arising from the enforcement conference was also requested.
(1)
Corrective Steps Which Have Been Taken The first violation identified two incorrect radioactive waste shipping manifests. The cause of the incorrect manifests was personnel error-in determining the content of the waste shipments. A contributing factor was that the : procedure used to determine the contents of the waste shipments was not specific enough about the review process for the calculations performed. When the - error in the shipping manifests were discovered, corrected manifests were
- immediately provided to the burial site. It was determined that the waste had been properly packaged for shipment and burial. The individuals involved in the erroneous calculation were retrained concerning the proper review process for radioactive waste shipment calculations. All radioactive waste shipments have been halted until additional controls are in place.
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Document C;ntr:I Desk December 6,1989 v
Page 2 The second. violation concerned the timeliness of the sampling and analysis used to. determine scaling factors for radioactive waste. Since the last inspection, we have continued to. use scaling factors based on samples that were several years old. ' During this' time, the data from the old samples was re-evaluated and slightly revised scaling factors were provided to - the Materials Processing Facility (MPF). Samples of resin and Dry Active Waste (DAW) were sent to a laboratory for analysis in June 1989. The results from these analyses were received at the end of September 1989. The validity of the results was questioned -and, while a re-evaluation was under way, new samples were sent to a different laboratory. An evaluation of the September 1989 laboratory results confirmed that the scaling factors previously provided to the MPF are acceptable.
To ' address the concern of timeliness of sarapling, a revision to the Chemistry procedure was made. Chemistry Procedure 228 was revised in August 1989 to require DAW samples to be analyzed semi-annually and resin samples to be analyzed annually. Both resin and DAW samples were sent to be analyzed in November 1989, in addition, we have changed the laboratory used for sample analysis. It has become clear that the previous laboratory could not provide a satisfactory product on a reasonable schedule.
(2)
Corrective Steps Which Will Be Taken To Avoid Further Violations For the first violation, procedure changes have been processed to clarify the need for an independent review of waste shipment calculations. An additional independent review of waste shipment calculations will be perfornted by a staff health physicist until a detailed review by the line organization is assured.
For the second violation, the procedure changes instituted in August 1989 will correct any further difficulty with timeliness of sampling or providing results to the MPF, In addition, more personnel are being added to the Chemistry Section to help ensure that adequate oversight of the program is maintained.
(3)
Date When Full Compliance Will Be Achieved For the first violation, ~ the procedure changes were completed on December 1,
1989. Continued oversight by a staff health physicist will be provided.
For the scaling factor violation, the procedure change in August 1989, along with j
the change in analytical laboratories which occurred in October 1989 provides resolution to this violation.
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Document Control Desk N
! December 6,1989 Page 3 Additional Concerns The letter which accompanied the Notice of Violation requested some additional information concerning points raised at the enforcement conference on November 1,1989.
(1).
Corrective Action Effectiveness We were asked to describe the actions taken or planned with respect to our
" corrective action" system to ensure that any items requiring resolution or correction, whether identified by the NRC, our staff or contractors, are evaluated, resolved and verified in a timely manner.
Our inability to ensure timely and effective corrective actions was identified in the Special Team Inspection ' conducted from February 27 March 31, 1989 l'
(Reference (b)).
Our response to the inspection report (Reference (c))
identifies actions needed to improve our NCR program. The implementation of i
these corrective actions addresses this concern. These actions are schedeled to l
be completed as part of our Performance Improvement Program.
(2)
Independent Review l
We were requested
'o address the actions ' planned to ensure that appropriate independent reviews of procedures, activities, and corrective actions in the radioactive waste processing, shipping, and transportation areas are corapleted.
A comprehensive review of the radwaste packaging and shipping procedures will be performed - to ensure that all aspects of the regulations are adequately addressed.
In addition, as part of the Procedure Upgrade Program, the procedures will be reformatted und expanded to provide additional guidance. Procedures involving radwaste packaging and shipping will be reviewed by February 1990. The
- procedures will be upgraded on a schedule consistent with our Procedure Upgrade Program.
'(3)
Iron-55 Scaling Factors We were requested to provide the iron-55 scaling factors used prior to November
'1989 and compare those results with the factor determined from the June 1989 samples. In addition, we are to provide an analysis of the effect of the new scaling factor on radwaste shipments made in 1988 and
- 1989, including transportation and waste classification.
For radwaste disposal shipments made during the first part of 1988, the values of the Fe-55/Co-60 scaling factors used for the waste and shipment classifications were 0.29 for resin shipments and 2.9 for DAW shipments, in May of 1988, the resin Fe-55/Co-60 ratio was increased to a value of 0.5 based on CCNPP waste I
stream specific data. The DAW correlation remained at 2.9; the CCNPP specific DAW sample data supported the in-use correlation.
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Page 4 In 1989, the Fe-55/Co-60 scaling factors were revised based on the independent contractor's ' review of the CCNPP 10 CFR 61 waste classification program. The Fe-55/Co-60 correlation for resin shipment was revised to a value of 1.0. The DAW correlation remained at a value of 2.9.
The Fe-55/Co correlation for a waste filter shipment conducted in 1989 was 2.66.
This value was based on past filter sample analyses, that included a December 1988 CVCS filter sample.
The June 1989 sample results yielded the following sample specific Fe-55/Co-60 correlations:
Samnle Tvoc Fe-55/Co-60 Palin resin 6.0 resin 15 DAW 5.8 DAW l.8 The DAW results (with an average value of 3.8) were in good agreement with past CCNPP sample data and-the 1988 and 1989 scaling factor value of 2.9.
The results of the June 1989 resin sample correction for Fe-55/Co-60 were considered suspect. The values were not consistent 'with the previous - CCNPP resin sample results. in keeping with the NRC guidance provided in NRC Information Notice No. 86-20, an additional resin sample was sent in October 1989 for complete 10 CFR 61 radionuclide analyses. Also, the vendor performing the analyses was changed. The analytical results of this resin sample yielded a Fe-55/Co-60 correction ' of 1.1, confirming the June resin samples for the Fe-55 analysis were questionable and supporting the validity of the previous value for the Fe-55/Co-60 scaling factor of 1.0.
The changes in the Fe-55/Co-60 scaling factors for the years 1988 and 1989 have been minor; all revisions have been within the factor of 10 accuracy in accordances with the guidelines presented in the NRC Division of Waste
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- r Document Cdntrol Desk i December 6,1989 Page 5 Management Branch Technical Position on Waste Classification (May 11, 1983).
Additionally, no waste shipments have been mis-classified or mis-labeled as a result of these minor changes in the correlations.
Very truly yours,
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STATE OF MARYLAND hAllh 4 bl11h[
I hereby cet ify that on the day of
,19,[Y, before me, the subjeriberj,/n Notary Public of the State of Maryland in and for f's In u f' ri4> u
, personally appeared George C. Creel, being duly sworn, and states that he is (Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, e
information, and belief; and - that' he was authorized to provide the response on behalf of said Corporation.
My WrrNESS my lland and Notarial Seal:
Notary Pubfic f
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l My Commission Expires:
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V ODa(e GCC/ PSF /bjd I
cc:
D. A. Brune, Esquire l
J. E.
Silberg, Esquire L
R. A.Capra, NRC S. A. McNeil, NRC
' W. T. Russell, NRC V. L. Pritchett, NRC T. Magette, DNR l
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