ML20036A939

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-320/93-04.C/As:util Has Not Used Fluid Tech Media for Solidification Since 921216 Waste Shipment & Will Not Use Vendor Until Testing for Cause of Degradation Completed

ML20036A939
Person / Time
Site:	Crane
Issue date:	05/07/1993
From:	Long R GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C-93-2090, C000-93-2090, C312-93-2035, NUDOCS 9305170317
Download: ML20036A939 (3)

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GPU Nuclear Corporation

1. 1 S Nuclear

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Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

(717) 948-8400 l

May 7,1993 C312-93-2035 C000-93-2090 US Nuclear Regulatory Commission l

Attn: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station Unit 2 L

Operating License No. DPR-73 Docket No. 50-320 i

Inspection Report No. 50-320/93-04 Response to a Notice of Violation

Dear Sir:

The subject Inspection Report identified a violation of the NRC requirements of 10 l

CFR 30.41(b)(5) and 10 CFR 61.56(a)(3) as they relate to the allowable amount of f

free-standingliquid in solidified waste. Pursuant to the provisions of 10 CFR 2.201, provides the GPU Nuclear response to the NRC Notice of Violation.

Sincerely, t

R. L. Long Director, Service Division l

JSS/dlb l'

Attachment cc:

T. T. Martin - Regional Administrator, Region I M. T. Masnik - Project Manager, PDNP Directorate l

L. H. Thonus - Project Manager, TMI

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F. I. Young - Senior Resident Inspector, TMI

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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

ATTACIIMENT 1 Response to a Notice of Violation i

Inspection Report 93-04 i

NOTICE OF VIOLATION "A violation of NRC requirements was identified as a result of the inspection i

conducted on February 8,1993 by a representative of the Washington Department of Health. The inspection involved a shipment of licensed material sent from Three Mile Island Unit 2 on December 16, 1992 to the US Ecology commercial low-level radioactive disposal site. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions",10 CFR Part 2, Appendix C (1992), the violation is listed below.

(A) 10 CFR 30.41(b)(5) states in part that "any licensee may transfer byproduct material...to any person authorized to receive such byproduct material under terms of a specific license issued by...the Commission or an agreement state." License Condition 30 of the US l

Ecology Radioactive Material License, State of Washington WN-IO19-2, l

requires that a waste stream, solidified in accordance with a process control program using an approved solidification medium, contain no detectable free standing liquid, which is defined as no more than 0.5%

(by volume) of liquid per container.

(B) 10 CFR 61.56(a)(3) states in part that " Solid waste containing liquid i

shall contain as little free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 1% of the volume."

l Contrary to (A) and (B) above, on December 16, 1992, the licensee shipped eight drums containing waste processed to a stable form, which upon receipt at the US Ecology site near Richland, Washington, were determined to contain a measured amount of liquid that was in excess of 1.0% by volume. Specifically, the containers i

2 were determined to contain 1.4% to 2.6% free standing liquid by volume.

This is a Severity Level IV viclation (Supplement V)."

GPU NUCLEAR RESPONSE i

GPU Nuclear concurs that the event identified in the above Notice of Violation did occur as described and is a violation of 10 CFR 30.41(b)(5) and 10 CFR 61.56(a)(3).

GPU Nuclear responded to the initial Notice of Violation reported in Inspection Report 93-02 (R. L. Long to NRC, March 17, 1993). The NRC determined that the l

GPU Nuclear response was not complete in that it did not describe the actions taken to prevent recurrence in the period prior to receipt of the results of vendor testing i

to identify the root cause of the degradation of the solidification media and prior to the implementation of those results. Therefore, Inspection Report 93-04 requested an additional response deceribing the interim actions taken to prevent recurrence 4

of the event prior to the identification of the root cause.

GPU Nuclear has not used Fluid Tech Media for solidification since the December 16, 1992 waste shipment. Further, as a practical matter, GPU Nuclear does not plan to

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use this media in the future. Although the Fluid Tech Media is approved for j

solidification of waste shipped to the Richland, WA disposal facility, which is located l

in the Northwest Compact region, the site is not accepting waste from generators j

in the Appalachian Compact region. To the contrary, the Barnwell, SC disposal site, which is accepting GPU Nuclear radioactive waste, has not approved the Fluid Tech Media for solidification.

As a matter of technical prudence, GPU Nuclear has no intention to use the Fluid Tech Media for radioactive waste solidification until the vendor testing for determination of the root cause of the degradation of the media is completed and the corrective actions indicated by the results of the testing have been implemented.

GPU Nuclear believes that the above corrective actions and those described in our March 17,1993 letter will provide reasonable assurance that a similar event will not occur and full compliance will be achieved.

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