ML20059H615
| ML20059H615 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/14/1994 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-94-00001, GNRO-94-1, NUDOCS 9401310041 | |
| Download: ML20059H615 (6) | |
Text
__ - __ _ __ - - _ _ __________.
l Entergy Operations,Inc.
e'==~ ENTERGY
- a Pr ct r ;ta : fE $150 b GO I 4]? MKi-C. R. Hutchinson January 14, 1994 w
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,,- m i. s. i.
U.S.
Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C.
20555 Attention: Document Control Desk
Subject:
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Response to Violation for Failure to Comply With State and Disposal Site Requirements for Free Standing Liquid in Resin Shipped to the Disposal-Site Report No. 50-416/93-22, dated 12/15/93 l-(GNRI-93/00218)
GNRO-94/00001
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Gentlemen:
Entergy Operations, Inc. hereby submits the response to the Notice l
of Violation 50-416/93-22-01.
Special attention by management has been given to resolution of this violation.
Corrective actions have been taken to ensure that containers sent to Barnwell Waste Management Facility, Inc.
in Barnwell, South Carolina do not contain liquid in excess of.0.5 percent by waste volume.
Additionally, a
corrective action request has been sent to Pacific Nuclear, Inc.
Entergy Operations feels that the corrective actions taken as a result of this event will prevent the. recurrence of this violation.
Yours truly,
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CRH/WBA/cg attachment cc: (See next page)
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9401710041 940114 PDR ADOCK 0500 4
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January 14, 1994 GNRO-94/00001
.Page 2 of 3 cc:
Mr.
R. H. Bernhard (w/a)
Mr. H. W. Keiser (w/a)
Mr.
R. B. McGehee (w/a)
Mr. N.
S..Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. Stewart D. Ebneter (w/a)
Regional Administrator U.S. Nuclear-Regulatory Commission Region II 101 Marietta St.,
N.W.,
Suite 2900 Atlanta, Georgia 30323 j
- l Mr.
P.
W.
O'Connor, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S.
Nuclear Regulatory Commission Mail Stop 13H3-Washington, D.C.
20555 i
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Attachment to CJRO-94/00001 Page 1 of 4 Notice of Violation 93-22-01 Technical Specification (TS) 6.8.1.g requires the licensee to establish, implement and maintain written procedures covering implementation of the Process Control Program (PCP).
TS 1.32 specifies that the PCP shall contain the current
- formulas, sampling, analyses, test, and determinations to be made to ensure that processing and packaging of solid radioactive wastes based on demonstrated processing of actual or simulated wet solid wastes will be accomplished'in such a way as to assure compliance with 10 CFR Parts 20, 61 and 71, State regulations, burial ground' requirements, and other requirements governing the disposal of solid radioactive waste.
Condition 36 of License No. 097, issued to Chem-Nuclear Systems, Inc.,
Barnwell, South Carolina, by the State of South Carolina, specified that the licensee (Chem-Nuclear) may receive resins and filter media in dewatered form. provided that the free standing liquid requirements of Condition 32 were met.
Condition ' 32.B specified that solidified radioactive waste shall have no detectable free standing liquids in excess of one-half percent (0.5%) by waste volume of non-corrosive liquids per container.
Contrary to the above, on November 8, 1993, the licensee shipped a container of resins to the Chem-Nuclear waste disposal site which was found, by the disposal site operator, to contain 0.7 volume percent of free standing liquid.
I.
MLission or Denial of the A11eced Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation, if Admitted The following describes the sequence of events which resulted in the shipment of a container of dowatered resins with free standing liquid in excess of the allowable limit:
On October 8, 1993, approximately 100 cubic feet (cu. ft.)
of resins were transferred directly from the Floor Drain Domineralizer into a shipping container designed for dewatering bead type resins.
The bead _ resin type container was selected because the Floor Drain Demineralizer normally contained only bead resins.'
An attempt to pump the excess water from the container was not successful due to the internal filter being clogged
4 Attachment to GNRO-94/00001 Page 2 of 4 with powdered resins.
Further investigation revealed that a torn Floor Drain Filter _had allowed powdered resins to enter the Floor Drain Demineralizer.
After consulting with the vendor's technical. support personnel (Pacific Nuclear Inc.), a decision was made to dewater the mixture of bead and powdered resins with a powdered resin type shipping container.
Approximately 95 cu. ft. of the mixed resins were transferred from the Floor Drain Domineralizer into the powdered resin type container.
On October 11, 1993, the mixed resins in the bead resin type container were transferred to the powdered resin type container.
On October 12, 1993, approximately 15 cu. ft. of bead type resins were transferred from the Spent Resin Storage Tank into the powdered resin type container and dewatering of that container was commenced.
The drying process continued until October 14, 1993, when the relative humidity critorion was achieved, and on October 18, 1993, the container was placed in a shipping cask.
During preparation for shipment, the container was tested and found to be generating methane.
The container was removed from the cask and the resins were treated with biocide.
The resins were redried to meet the relative humidity criterion and then shipped to the disposal facility on November 8, 1993.
On November 12, 1993,_the. licensee was informed by the
=
disposal facility operator that the container had been randomly selected for testing to verify compliance with the limit for free standing liquid.
The container was punctured and 6.15 gallons of liquid drained from the container.
On November 15, 1993, the opposite side of the container was punctured and an additional 3.27. gallons of liquid drained from the container.
The total volume of resins in the container was 180 cu. ft.; therefore, the 9.42 gallons (1.26 cu. ft.) of liquid collected from the container represented 0.7 percent of the waste volume.
As indicated above, the allowable-limit for free standing _ liquid was 0.5 percent by waste volume per container._ Upon notification of the results from the first penetration test, shipment of containers bearing the same mixture of resins was suspended and an investigation into the cause of this event was initiated.
Attachment to GNRO-94/00001 Page 3 of 4 An apparent cause for the_ creation of this liner that exceeded the free standing liquid requirement'of the State and burial. site is improper selection of the container for the waste media based on the GGNS Waste Characterization form.
III. Corrective Steps Which Have Been Taken and Results Attained Quality Deficiency Report 0279-93 was issued to document the preliminary results of the investigation and the initial corrective actions taken to preclude recurrence.
Corrective Action Report 93-106 was issued to the vendor which includes the following corrective actions:
- The vendor issued a memorandum to their site representatives to assure _that no bead resins are introduced into the bottom of any container equipped wt,th tubing and filters designed specifically for dr. watering. powdered resins.
That memorandum also indicated that bead resins or mixtures of bead and pewdered resins may be allowed into the top portions for the above type of containers only if the bottom portion of the container is filled with pure powdered resins and only if prior approval has been obtained from the vendor's Engineering and Operations department.
- The vendor has enhanced the operating procedures for the dewatering process to ensure proper container is selected.
- The vendor was requested to validate the accuracy of the calibration for.the instrumentation used for the dewatering process.
The vendor is investigating why all parameters indicated within acceptable limits, yet the liner yielded greater than 0.5%-free standing liquid.
Initiated monitoring of the Floor-Drain Effluent for suspended solids as an indicator of the integrity of the Floor Drain Filter and to provide an alert that powdered resin may have been introduced into the Floor Drain Demineralizer.
GGNS Radiation Protection Procedure 08-S-01-25 has been revised to provide verification of PCP and container suitability for all medias.
Health Physics Form HP-616 has been revised to ensure documentation of correct _ container suitability for both waste classification and PCP requirements.
Attachment to GNRO-94/00001 Page 4 of 4 Corrgetive Steps to be Trken to Preclude EuJther Violations I
IV.
a GGNS Radwaste Instruction 08-S-06-11 is being enhanced to minimize the potential for recurrence.
If there are any waste streams created that are questionable, all' precautions will be taken to ensure the proper container is selected and utilized.
Containers that provide test leg verification will be used in questionable situations.
No deviation will be allowed in this matter concerning any mixture of medias in resin containers.
As part of the Corrective Action Report disposition, long term training of vendor personnel under the Vendcr's Qualification Program will be performed.
Upon disposition of the Quality documents further evaluation will be performed to determine if other enhancements are warranted.
V.
pate When Full Compliance Will Be Achieved These actions are scheduled to be completed by March 31, 1994.
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