ML20133C703

Responds to Violations Noted in Insp Repts 50-348/85-34 & 50-364/85-34.Corrective actions:84 Drums of Sludge Lance Filters Buried Following Collection & Solidification of All Free Standing Water Approved

ML20133C703
Person / Time
Site:	Farley
Issue date:	09/26/1985
From:	Mcdonald R ALABAMA POWER CO.
To:	Verrelli D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8510070490
Download: ML20133C703 (5)

Text

.

h Mailing Address Alabama Power Company 600 North 18th Street l

['

Post Office Box 2641 Dirmingham, Alabama 35291 Telephone 205 783-6090 I

R. P. Mcdonald G' I8 Senior Vice President 0CT I AlabamaPower Flintridge Building muw e eu m September 26, 1985

. Docket No. 50-348 l

Docket No. 50-364 i

Mr. D. M. Verrelli U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 3100 Atlanta, GA 30323 August 5-9,y Nuclear Plant NRC Inspection of

SUBJECT:

J. M. Farle 1985 RE:

Report Numbers 50-348/85-34 50-364/85-34

Dear Mr. Verrelli:

This letter refers to the violations cited in the subject inspection reports which state:

"The following violations were identified during an inspection conducted on August 5-9, 1985. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

i 1.

10 CFR 30.41(c) required that before transferring byproduct i

material to a specific licensee of an Agreement State, the i-licensee transferring the material shall verify that the i

transferee's -license authorizes 'the receipt of the type, form, and quantity of byproduct material to be transferred. Condition 35 of the State of South Carolina Radioactive Material License No. 097, Amendment No. 41, issued to Chem-f'uclear Systems, Inc., required that regardless of.the waste classification, the licensee shall not receive sludges, or other waste which may contain free standing liquids, unless they are solidified and meet the I

requirements as specified in Condition 32. Condition 32 of the State of South Carolina Radioactive Material License No. 097, Amendment No. 41, issued to Chem-Nuclear Systems, Inc required 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.

8510070490 B g I

u- -

y 90 PDR

m.

t

~

Mr. D. M. Verralli September 26, 1985

. Page-Two l

Contrary to the above, on May 30, 1985, the licensee failed to verify that the byproduct material in radioactive shipment number RWS 85-14 transferred to the Chem-Nuclear disposal site near Barnwell, S.C. was of the type, form and quantity authorized to be received in that-the radioactive waste contained (55-gallon drums) contained detectable free standing liquid in excess of one-half

. percent (0.5%) by waste volume.

This is a Severity Level IV violation (Supplement V).

2.

Technical Specification 6.8.1 required that written procedures be established covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,1978. Regulatory Guide 1.33, Revision 2,1978, Appendix A, paragraph 7.b.(1) recommends procedures for filter sludge handling.

j Contrary to the above, during the period January - May,1985, the licensee failed to adequately establish a procedure for filter L

sludge handling in that licensee procedure FNP-1-ETP-4114 did not l

address processing of sludge lancing filters to ensure there was

.no excess free standing liquid in the packaged waste.

This is a Severity level IV violation (Supplenent IV).

j' 3.

Technical Specification 6.5.3.1 required that procedures required by Technical Specification 6.8 shall be reviewed by an individual / group other than the individual / group which prepared the procedure.

Contrary to the above, the requirement that procedures be reviewed by an individual / group other than the individual / group which prepared the procedure was not met in that ' licensee procedure FNP-1-ETP-4114, used between January i'

and May 1985 for sludge lancing steam generators, was not reviewed by an individual / group other than the individual / group which prepared the procedure.

This is a Severity Level IV violation (Supplement IV)."

Admission or Denial The above violations occurred as described in the subject report.

Reason for Violation 1.

The first violation was caused by procedural inadequacy in that the procedure did not ensure that filters were dewatered. Also, there was a misunderstanding concerning the term " sludge" as used in Barnwell License Condition 35, 4

Y

Mr. D M. V:rralli September 26, 1985 Page Three 2.

The second violation was also caused by procedural inadequacy in that the governing procedure did not have sufficient controls to ensure adequate dewatering prior to placement in shipping drums.

3.

The notice of this violation states that " Technical Specification 6.5.3.1 required that procedures required by Technical Specification 6.8 shall be reviewed by an individual / group other than the individual / group which prepared the procedure." Actually the Technical Specification continues with "but who may be from the same organization as the individual / group which prepared the procedure or procedure change." This requirement is interpreted to mean that the personnel involved in preparing a procedure, be it an individual or several individuals (a group), shall not be the same personnel (singular or plural) reviewing the procedure. As long as this requirement is met then the reviewing personnel may or may not be from the same organization. The word " group" in this particular Technical Specification speaks of "more than one individual" instead of a formal organization (i.e., Operations Group, Systems Performance Group, etc.)

This interpretation was not used only for FNP-1-ETP-4114 but has been used for all types of procedures prepared by all the different plant groups.

At the Exit Conference the Inspector stated that the procedure had not been properly reviewed in accordance with Technical Specifications.

The licensee stated that the procedure had been reviewed in accordance with Technical Specifications (as discussed above) and that if anything was in error, it was the decision not to have a cross disciplinary review performed.

Technical Specification 6.5.3.1.e states that "Each such (procedure) review shall include c determination of whether or not additional, cross disciplinary review is necessary, If deemed necessary, such review shall be performed by the review personnel of the appropriate discipline." At the time FNP-1-ETP-4114 was reviewed it was in-fact determined that a cross-disciplinary review was not necessary.

In retrospect, this was not a good decision.

This event was caused by personnel error in that a decision was made incorrectly that a cross-disciplinary review was not necessary on FNP-1-ETP-4114 Corrective Action Taken and Results Achieved 1.

The burial of the 84 drums of sludge lance filters following collection and solidification of all free standing water was approved by the South Carolina Department of Health and Environmental Control (SC DHEC).

2.

Free-standing water was drained from the drums to allow for proper disposal.

F Mr. D.ber. Verre11126, 1985 M

Septem Page Four Corrective Steps Taken to Avoid Further Violations la. The shipment of bag type filters used for sludge lancing will be suspended until a suitable process control procedure can be developed to ensure that such filters are dewatered adequately.

b.

A variance request has been submitted to Chem-Nuclear to support future shipments of sludge and sludge lance filters without solidification.

2.

Procedural controls will be added to the governing procedure to insure that filter elements are properly prepared before sludge from the steam generators is shipped again at FNP.

3.

FNP-1-ETP-4114 will be cross-disciplinary reviewed by the Radwaste Supervisor prior to further use of the procedure.

The personnel involved will be cautioned about possible consequences of incorrect determination of cross-disciplinary reviews.

Date of Full Compliance 1.

4-1-86 (First Violation) 2.

4-1-86 (Second Violation) 3.

4-1-86 (Third Violation)

Objections Although the above violations are correct, Alabama Power Company objects to double jeopardy in that the NRC duplicated a violation previously imposed by SC DHEC. Restatement of this violation serves no useful purpose since SC DHEC (not NRC) exercises control over the Barnwell burial site.

Further complicating the issue is the fact that Alabama Power Company and SC DHEC have not resolved whether or not solidification of sludge lance filters is required.

Alabama Power Company objects to receiving three separate violations for different aspects of a single problem, i.e. mishandling sludge lance filters.

Alabama Power Company objects to being cited for inadequate procedure review and approval when, in fact, the problem was inadequate cross-disciplinary review.

This was pointed out to the inspector at tha exit interview.

Affirmation I affinn that this response is true and complete to the best of my knowledge, information and belief.

. Mr. D. M. Verralli

' September 26,- 1985 Page Five The-information contained in this letter is not considered to be of a proprietary nature.

Yours very trul

/

R. P. Mcdonald RPM /KWM: sam cc: File-

-