ML20133P584
| ML20133P584 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/17/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8511010073 | |
| Download: ML20133P584 (4) | |
Text
-
..s l
GPU Nuclear Corporation
- r Nuclear
- ==388 Forked River, New Jersey 08731-o388 609 971-4000 Writer's Direct Dial Number:
October 17, 1985 Thomas T. Martin, Director Division of Radiation Safety and Safeguards Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report No. 85-25 As requested by the subject inspection report dated September 11, 1985, Attachment I to this letter provides our response to the Notice of Violation.
Should you require further information, please contact Brenda Hohman, Oyster Creek Licensing Engineer at (609)971-4642.
Yhr tquly yours j
W Pe ar edler Vi P esident and Director 0y e Creek PBF/8H/ dam Enclosures (0103A) cc:
Dr. Thomas E. Murley, Administrator Regior I U.S. f:uclear Regulatory Commission 631 Park Avenua f
King of Prussia, PA 19406 Mr. Jack N. Donohew, Jr.
U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 Resident Inspector Oyster Creek Nuclear Generating Station 8511010073 851017 DR ADOCK 050 9
GPU Nuclear Corporation is a subsidinry of the General Public Utilities Corporation Ok,
m
~
ATTACHMENT I VIOLATION-10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires a licensee who transfers radioactive waste to a land disposal facility to conduct-a ' quality control program to assure compliance with 10 CFR 61.55 and L10 CFR '61.56.
Contrary to the above, the licensee has transferred several radioactive i
waste shipments to a land disposal facility during 1984 and 1985 and the licensee has not conducted a quality control program to assure compliance with 10 CFR.61.55 and 10 ~CFR 61.56 inasmuch as the licensee has not verified that spent resin contained less than 1% liquid by volume when the resin was Lin ~a disposal container (high integrity container) designed to ensure stability, and neither did the licensee verify that the solidification process was as effective as described in the Topical Report.
In addition, the licensee did not verify that the' computer program used in waste classification performed the required functions.
This is a Severity Level IV violation.
. DISCUSSION GPUN has maintained and continues to maintain an extensive QA Monitoring Program to verify that various programs are implemented and meet established requirements.
Radioactive Material Shipping and Handling is one of approximately 30 programs under the scope of QA Monitoring.
Through period'ic planning and scheduling activities, Operations QA determines how their current resources can'be most effectively utilized.
These determinations consider the need for achieving broad scope coverage in each program that is monitored as well as the need to address significant
. areas of concern.
During 1984, approximately 80 monitorings were performed on radioactive material shipping.
In 1985, to 'date, over 170 monitorings have been performed in that area. This number is greater than that for any other program monitored during the same time period. A sufficient portion of the total radioactive material shipping and-handling program was monitored to provide confidence that the program in general is properly implemented and meets established requirements.
It was determined in late 1984 and for more than half of 1985 that, in the area of radioactive material shipping, our monitoring resources would be best spent addressing the highly sensitive project of returning spent fuel from West Valley, NY to Oyster Creek. Now that this project is complete we have resumed progress toward broader scope coverage in radioactive materials handling and shipping, specifically: waste solidification, resin dewatering, and waste classification as outlined below in our response to
.the violation.
Further, it 'should be nct:d that Operations QA rsviewed all procedures' related to dewatering, solidifcation and shipping prior to implementation to assure that proper controls would be in place to satisfy requirements of 10CFR61.55 and 10CFR61.56.
RESPONSE
Corrective Steps Which Have Been Taken and the Results Achieved:
Changes to the Operations QA (Ops /QA) Monitoring Program are currently underway'in order to fully comply with 10 CFR 20,311(d)(3) and to assure full compliance with 10 CFR 61.55 and 61.56.
In order to properly conduct this program, Ops /QA will have prior noti _fication for:
1.
All PCPs to be performed 2.
All solidifications 3.
All resin dewaterings 4.
All oil absorptions The necessary procedures are being revised. to incorporate these notification requirements. Temporary changes to these procedures were in effect as of September 23, 1985.
- Corrective Steps to Avoid Further Violations:
Resin Dewatering: The resin dewatering process will be periodically monitored during the process and/or at final verification of less than 1% free standing water. All documentation / calculations used in verifying that the acceptance criteria have been met will be reviewed.
Computer Program: Ops /QA wi.. periodically review RADMAN (the computer program used to determine waste classification) to ensure:
)
Records are maintain'ed of changes to waste sample data, deletion of sample data, or addition of data for a new waste type.
2.
Records are maintained of changes to the characteristic files maintained for the various waste types.
Included in this review will be the current RADMAN data book.
Ops /QA will verify that hardcopy sample data were input correctly into the waste characteristic file for wastes being shipped. o
Solidification Verificatien: Tha following activities will be periodically monitored to verify that the solidification process is as effective as described in the Topical Report.
1.
Sample solidification of various waste forms to be solidified. CNSI document SD-0P-003, " Process Control Program for CNSI Cement Solidification Units", requires a sample solidification prior to full scale solidification. Ops /QA will: monitor CNSI operator's performance of this-test at least
- once every third shipment for each type of waste form.
2.
Completion ofJCNSI Solidification Worksheets and full scale calculations. These documents are used to determine tne volume of waste material to be received and the amounts of solidifying agents that will be added.
3.-
Addition of waste and solidfying agents to ensure the amounts added are those determined in the full scale calculations.
4.
' Visual inspection of the end product to ensure a uniform product with no free standing water.
5.
After solidification has been completed and prior to capping the liner, visual inspection of th? end product will be conducted to ensure it resists penetration when probed with a rod, approximately 1 inch in diameter.
Full compliance was achieved as of September 23, 1985 when temporary changes to procedures went into effect.
The monitoring program is now in effect.