ML20137P220

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/85-33

ML20137P220
Person / Time
Site:	Oyster Creek
Issue date:	01/30/1986
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8602040398
Download: ML20137P220 (2)

See also: IR 05000219/1985033

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JAN 3 01986

Docket No. 50-219

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GPU Nuclear Corporation

ATTN: Mr. P. B. Fiedler

Vice President and Director

Oyster Creek Nuclear Generating Station

P. O. Box 388

Forked River, NJ 08731

Gentlemen:

Subject:

Inspection No. 50-219/85-33

We acknowledge receipt of your letter dated January 10, 1986, in response to

our letter dated December 4, 1985.

Thank you for informing us of the corrective and preventive actions documented

in your letter. These actions will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated.

Sincerely,

Ori-1:ml O! r'. 't* :

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omas T. Martin, Direc r

vision of Radiation Safety

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and Safeguards

cc:

M. Laggart, BWR Licensing Manager

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Licensing Manager, Oyster Creek

Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

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NRC Resident Inspector

State of New Jersey

8602040390 860130

PDR

ADOCK 05000219

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PDR

OFFICIAL RECORD COPY

RL OYSTER CREEK 85-33 - 0001.0.0g

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GPU Nuclear Corporation

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Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP

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P Clemons, DRSS

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Pasci k'

Bellamy

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0FFICIAL RECORD COPY

RL OYSTER CREEK 85-33 - 0002.0.0

01/24/86

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GPU Nuclear Corporation

U Nuclear

== 388

Forked River, New Jersey 087310388

609 971 4000

Writer's Direct Dial Number:

anuary 10, 1986

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. 85-33

Response to Violation

As requested by the subject inspection report dated December 4,1985,

Attachments I and II to this letter provide our response to the Notice of

Violation.

Should you require further infprmation, please contact Brenda Hohman,

Oyster Creek Licensing Engineer at (609)971-4642.

Very truly yours,

b

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P

ek1 r

Vice President and Director

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Oyster Creek

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PBF/BH/ dam

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Attachments

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(0103A)

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cc Dr. Thomas E. Murley, AdministratoE

(

Region I

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U.S. Nuclear Regulatory Commission

631 Park Avenue

King of Prussia, PA 19406

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Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Comission

7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014

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Mail !bp No. 314

NRC Resident Inspector

Oyster Creek Nuclear Generating Station

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

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ATTACF+ENT I

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Violation

10 CFR 71.5(a) states, in part, that each licensee who delivers licensed

material to a carrier for transport, shall conply with the applicable DOT

regulations appropriate to the mode of transport in 49 CFR Parts 170 through

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189.

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49 CFR 173.44(b) states, in part, that a shipment may be transported as an

exclusive use shipment if the radiation level does not exceed during

transportation in an open transport vehicle 10 millirem per hour at any point

2 meters from the vertical planes projected from the outer edges of the

conveyance.

Contrary to the above, on October 13, 1985, shipment OC 1036-85 containing

radioactive material classified as low specific activity (LSA) was delivered

as an exclusive use shipment to a carrier for transport via an open transport

vehicle, and upon arrival at the Quadrex Corporation in Oak Ridge, Tennessee

on October 15, 1985, the external radiation level of the shipment at the four

survey points 2 meters from the vertical planes projecting from the outer

edges of the conveyance were in excess of 10 millirem per hour with the

highest measurement recorded as 15 millirem per hour.

Response

(FUN concurs with che violation as stated. The attached Operations Critique

regarding this violation provides a detailed description of the incident and

corrective actions taken to preclude a recurrence. The following items are

summarized from information provided in ^:he critique:

1.

Reason for the violation

The package which was delivered to the Quadrex facility contained an

underwater cutter shearer (UCS) which had been used in the fuel pool to

cut control rod blades (CRB) in preparation for disposal.

This USC belongs to a GPUN contractor and was being shipped to Quadrex

for decontamination and repairs. When the package arrived, the receipt

survey revealed a general radietion field increase (over initial

shipment of surveys) of 4-6 mrar at essentially all locations around

the package at two meters.

When the package was opened, it was determined that local shielding,

installed prior to shipment, was intact and had not shifted in transit.

Subsequent dismantling of the equipment revealed a small piece of a

baron poison tube with a contact radiation level of 25 to 40 R/hr. It

has been determined that the shifting of this boron tube in the

internals of the USC, due to transport stresses, caused the general

two-meter radiation level increase.

2.

Corrective steps which have been taken and results achieved

(a) The shipment was immediately dispositioned and off-loaded by

agreement between GPUN and Quadrex.

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(b) The NRC, transport carrier and the State of Tennessee were notified

of the incident.

(c) An investigation / critique was commenced and the results are attached

(d) The GPUN manager of Radwaste Operations and Radwaste Shipping

Supervisor met with Quadrex and WasteChem personnel at the Quadrex

Oak Ridge Facility to ensure immediate corrective actions were

taken consistent with regulatory requirements and good radiological

control practices.

(e) The contractor owning the USC was informed that the equipment would

not be accepted at Oyster Creek until such time that design

modifications were made to the USC to preclude irradiated scrap

from entering the areas of the machine not readily accessible for

visual inspection.

(f) The baron tube was placed in a secure shielded location at the

Quadrex facility to avoid additional personnel exposure.

(g) The Radiological Controls Department performed a dose assessment to

the population as a result of this shipment. The total

(conservative) estimated dose to the general population was 1,41

Mrem.

The modifications (detailed in attached critique) to the USC have been

conpleted, however, the contract to process CRB's has been indefinitely

postponed. Consequently, future shipments of this equipment are not

planned.

The boron tube segment is presently at Quadrex and plans are being made

to return it to the Oyster Creek fuel pool for storage and ultimate

disposal with other irradiated components.

3.

Corrective steps which will be taken to avoid further violations

(a) This shipment was made with a reasonable assumption that the

radiation levels (1.34 R/hr maximum contact) was from fixed

contamination on the USC surfaces. Our experience with storage

racks and other non-irradiated components, exposed to the fuel pool

water environment (as the USC was), shows these radiation levels to

be normal and not indicative of irradiated hardware. However, this ,

incident clearly indicates the potential for small sources of

irradiated hardware to be inadvertantly mixed with LSA material,

provided ample intrinsic shielding exists to mask the relatively

higher radiation levels. Shipments of LSA material that could be

co-mingled with irradiated hardware are extremely rare and, in

fact, limited to equipment utilized to handle or process the

latter. To preclude a similar recurrence of this nature, the

Oyster Creek general Radwaste Shipping Procedure (0.C. 101.3) will

be revised to include a specific precaution for a prior review of

these types of shipments to determine if irradiated pieces could be

inadvertently included. This review will include a requirement not

to make waste classification determinations when internal surveys

are unavailable for equipment which potentially could contain

irradiated pieces.

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(b) From a broader perspective, this incident instigated a review of

our Radioactive Material Management Program. The procedures

utilized to classify radioactive waste for our normal waste

streams, such as dry activated waste (DAW) and solidified process

waste, specifically address those variables which could preclude

accurate determination of waste classification. The dose to curie

conversion co@ uter program (RADMAN) utilized to classify our

normal waste streams provides ample protection to ensure accurate

classification of waste.

(c) The violation notice expressed a concern because "the radiation

level was only slightly below the limit, yet further

decontamination was not performed." A review was conducted of the

management decision which authorized the administrative limit of 8

mr/hr to be temporarily revised to 9.5 mr/hr. The result of that

review, and specifically the following facts, led us to conclude

that this decision was made with due consideration of the known

circumstances, at the time of shipment, and had no i @ act on the

cause of this violation:

(1) The USC had been hydrolased extensively prior to packaging.

Additional attempts to hydrolase did not reduce the maximum

contact radiation levels.

(2) Shielding requirements were based on the assunption of fixed

contamination rather than a source of irradiated hardware.

Lead shielding was applied to the upper portions of the

equipment with other areas intentionally not shielded because

no dose rate problems were indicated in these areas.

WasteChem personnel verified that when the shipping package

was opened, shielding was found to be intact as originally

installed.

(3) It should be noted that previous experience has shown it is

extremely difficult to appreciably reduce radiation levels (by

1 or 2 mr/hr) of large packages (broad area source) by

installation of additional localized shielding. Likewise,

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significant amounts of shielding applied to general areas are

restricted by container and shipment weight constraints.

Consequently, our shipping procedure provides for relief from

the 8 mr/hr requirement up to 9.5 mr/hr maximum at two meters

with prior approval of the Manager of Radwaste Operations.

These situations are very infrequent, however, they do recur

with large equipment packages such as control rod drives and

fuel storage racks. This waiver has been applied for no more

than 10 shipments out of approximately 225 in the last three

(3) years and there has never been a similar incident, i.e.

increased two-meter dose rates.

(4) The package was placed on the shipping trailer, surveyed and

found to be reading

8 mr/hr at two-meter in one location.

To add additional shielding would have required additional

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personnel exposure while returning the equipment to the

Reactor Building, opening the package and applying more

shielding.

4.

Date when full compliance will be achieved

Full compliance was achieved on 10/15/85 when agreement was reached

between GPUN and Quadrex for the package to be received, off-loaded and

processed by the Quadrex Decontamination Facility.

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Attachment II

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Memorandum

December 24, 1985

Subject: Operation Critique -

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O. C. Radioactive Material

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Shipment Number 1036-85

From:

T. W. Snider

Location:

Oyster Creek

Manager, Radwaste Operations

To:

Operations Critique File

This operatons critique was initated to review the events, determine cause,

and corrective action to preclude a recurrence of radwaste shipping

discrepencies which occurred with 0. C. shipment number 1036-85 on October 15,

1985. The following format is utilized:

I.

Brief Description of the Incident.

II. Detailed Sequence of Events.

III. Determination of Cause.

IV. Corrective Action to Prevent Recurrence.

I.

Brief Description of the Incident

WasteChem Corporation was awarded the contract to volume reduce misc.

Irradiated hardware,

i.e., control rod blades (CRB), flow channels.

Volume reduction of the hardware was performed by utilizing an underwater

shearer crusher (U$C). Control rod blades were selected as the first

item to be volume reduced. Five (5) CRB's were volume reduced with no

apparent problems with the USC. The sixth CRB was placed in the USC and

was being volume reduced when WasteChem noticed a drop in hydraulic

pressure. The process was stopped and was technically evaluated by

WasteChem to determine the reason for the loss of hydraulic pressure. It

was determined that there was a damaged seal around one of two hydraulic

pistons which are physically located inside the USC.

To insure personnel exposure was minimized, it was determined that the

USC should be sent to Quadrex Corp. in Oakridge, TN for decontamination

and repair. The equipment was decontaminated, as much as possible

without disassembly, by hydrolazing. Removable external apparatus, such

as filters and cutting blades, with highest radiation levels were removed

and stored. The equipment was packaged and shipped from Oyster Creek on

10/13/85. It arrived at Quadrex Corporation, Oak Ridge, TN, on

10/15/85. The receipt survey determined that the external radiation

limit of 10 millirem per hour at two meters wss exceeded at four survey

points ranging from 11 to 15 millirem per hour. This violated the

specific requirements of 49 CFR 173.441(b). As such, it is also deemed a

violation of 10 CFR 71.5(a).

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Operatlon Critique

12/24/85

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II.

Detailed Sequence of Events

A.

Specific Preparations for Shipment

To meet the requirements for packaging and shipment, the Radwaste

Shipping Section gave hasteChem the following instructions to be

implemented prior tr ,ackaging:

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1.

The USC shall be hydrolaseo to reduce smearable contamination

levels and contact radiation. levels. Hydrolasing will cease when

there is no further reduction in radiation / contamination levels.

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2.

The USC shall be inspected to insure that there are no pieces of

irradiated hardware on or within the USC.

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The filter shall be removed from the filtration system.

4.

Any and all shielding used shall be installed, banded, and

secured to insure that it does not shift during transportation.

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A one square inch scraping shall De taken from the area with the

highest direct radiation level on the USC in order to determine

the total specific activity on all surface areas.

6.

All equipment shall be wrapped in plastic prior to being placed

into the shipping container.

The items listed above were contained in plant specific procedures with

supervisory signoffs, for verification of completion, with the exception

of Item #5 which was a requirement listed in the Radiological Engineering

Request (RER). The RER was listed as a prerequisite in the procedure

which made it part of the procedure.

The USC was hydrolased until the radiation levels coulo not be reouced

any further. Radiation surveys indicated there was a maximum 1.34 R/hr

hot spot. This rad level was appreciaole below the original levels

(approximately 4 R/hr maximum) on the unit when Oyster Creek received it

from another licensee.

In adoition, it is consistent with hot spots,

remaining after hydrolasing, on the non-irradiated equipment removed from

the fuel pool. Consequently, the source was assumed to be from fixed

contamination. This assumption was reinforced by the fact that WasteChem

had not founo significant, mobile radioactive material in this or similar

equipment in eleven years of operation.

This incident and subsequent

investigations would prove this to be a wrong assumption, as the 1.3 R/hr

was in the area where the boron tube piece was ultimately found.

The Radwaste Shipping Supervisor (RSS) was called at home for his

approval to shield the hot spot. The RSS reiterated the requirements of

the proceoure regaroing snieloing, specifically it was to be installed in

a manner so as not to shift in transit, ano approved application of the

shieloing.

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Operation Critique

12/24/85

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WasteChem supervisors completed the stipulated requirements to insure

shipping compliance of the USC. The USC was wrapped in plastic and

transfered to its designed shipping container which was located on Elev.

23' in the Reactor Bldg. Localized lead shielding was installed under

tne direction of WasteChem supervisors to reduce contact radiation

levels. After installation of the lead shielding, the USC container was

closed and loaded on the trailer. The trailer was removed from the

Reactor Bldg. to a lower background area in the RCA yard and surveys were

performed on the containers. The box containing the USC was reading 9.5

mr/hr at two meters which was 1.5 mr/hr above allowable adninistrative

limits. The contact rad levels were well below the administrative limit

of 180 mr/hr.

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The Radwaste Slipping Supervisor was contacted at nome ano advised of the

radiation levels. He reported to work to evaluate the need for further

shielding or make the necessary procedure changes. WasteChem Supervisors

were questioned about the lead shielding and the manner in which it was

installed. The Raowaste S7ipping Supervisor was told that the shielding

was properly installed and secured.

NOTE:

It should be noted that previous experience has shown it is

extremely difficult to appreciably reduce radiation levels (by 1

or 2 mr/hr) of large packages (broad area source) by

installation of additional localized shielding. Likewise,

significant amounts of shielding applied to general areas are

restrictec by container and shipnent weight constraints.

Consequently, our shipping procedure provides for relief from

the 8 mr/hr requirement up to 9.5 mr/hr maximum at twc meters

with prior approval of the Manager of Radwaste Operations.

These situations are very infrequent, however, they do recur

with large equipaent packages such as control rod drives and

fuel storage racks. This waiver has been applied for no more

than 10 shipments out of approximately 225 in the last three

years and there has never been a similar incident, i.e.,

increased two meter dose rates.

To reouce personnel exposure, the oecision was maoe not to return

the container to the Reactor Building and open the container to

install more shielding, but rather make a one time procedure change

to authorize shipment at these radiation levels. The Manager,

Raowaste Operations was called at home for his approval to make a

one time change to the procedure which would allow the

acministration limit of 8 mr/hr at two meters to be waived and

increased to 9.5 mr/hr for this shipment. His instructions were to

survey the area in question utilizing two survey instruments to

verify readings. This was performed and both instruments read 9.5

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mr/hr. The Radwaste Operations Manager then questioneo the adequacy

of the lead shielding and its installation. With the assurance that

the shielding was properly installed, he authorized the procedure

change. The shipping papers were completed and the shipment made

from the site on 10/13/85 as LSA material in an open flatbed

designated as exclusive use.

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Operation Critique

12/24/85

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B.

Receipt of shipment at Quadrex Corp. Oakridge, TN.

.The shipment arrived at Quadrex Corp. OEkridge, TN. on 10/15/85 s.t.

7:10 a.m.

A receipt survey was performed and the radiation levels

at two meters were found to be in excess of 49 CFR 173.441(B) for

the container which housed the USC. At the time of receipt,

WasteChem Supervisors were at Quadrex to repair the equipment. CPU

Nuclear was notified and copies of the surveys were sent via

telecopy to Oyster Creek. Quadrex accepted receipt of the equipment

and it was offloaded for decontamination and repair. WasteChem and

Quadrex were asked to apprise the as found condition of the

shielding and any other conditions that would have caused the

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increase in the two meter radiation levels. WasteChem personnel'

verified the shielding integrity as shipped and the equipment was

unpackaged for repair.

The Oyster Creek Manager, Radwaste Operations had numerous telephone

conversations with the Quadrex Facility representatives to determine

the extent of the problem and immediate corrective action.

Subsequently, the EC Region I and Tri-State Corp., (the carrier)

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were notified and appraised of the situation. The State of

Tennessee was notified by Quadrex and the Manager, Radwaste

Operations had a numoer of telelphone conversations with Tennessee

officials to explain the event and offered to mect with them to

review the cause and corrective action. They determined a meeting

unnecessary.

tpon disassemoly of the equipment, a segment of a coron tube from a

CRB was discovered below the hydraulic processing cylinder internal

to the USC in the area shown on Figure 1 (attached). Tne tube was

approximately 2 1/2 inches long, 3/16 inch outside diameter, with a

contact raoiation level of 25 to 40 R/hr. GPUN was notified of the

finding and Quadrex agreed to place the piece of boron tube in a

secure area for evaluation and subsequent dispositioning.

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On October 21, 1985, the Manager, Radwaste Operations and the

Raowaste Slipping Supervisor went to Quadrex to investigate the

situation. The radiation survey instrument used for the outgoing

shipment at Oyster Creek was taken along for a comparison with the

survey instrument used by Quadrex for receipt surveys. It was

preliminarily determined tne movement of the boron tube in transit

within the USC was the cause for the increase in the two meter

raoiation levels.

Tne radiation survey instruments were compared using a Cobalt 60

source. Both instruments read the same on contact and at three and

one half inches from the source (160 mr/hr and 15 mr/hr

respectively).

C.

Investigation Meeting at Oyster Creek

A critique was held at Oyster Creek on October 24, 1985 with all

responsiole parties involveo with the packaging and shipment of

WasteChem's volume reduction equipment.

The purpose of the meeting

was two fold to determine; (1) whether the shielding used was

installed adequately and secured in such a manner that it would not

shift during transport and (2) how a piece of boron tube got inside

the pressure piston area of the USC.

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Opers: tion Critique

12/24/85

Page 5

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1.

Shielding:

Shielding requirements were based on the assumption of fixed

contamination rather than a source of irradiated hardware. Lead

shielding was applied to the upper portions of the equipment

with other areas intentionally not shielded because no dose rate

problems were indicated in these areas. WasteChem personnel

verified that when the shipping package was opened, shielding

was found to be intact as originally installed.

Based on a review of the incoming survey of the USC container at

the Quadrex facility, it was concluded that the general increase

of 4-6 mr/hr at essentially all locations around the box

(shielded and unshielded) at two meters is the result of the

unexpected movement, due to transport stresses, of the CRB baron

tube piece previously assumed to be fixed contamination, to an

area with less internal shielding. This conclusion is given

additional credence by the fact that a piece of loose scrap in

this area of the machine has mobility, i.e., it can move within

a space with dimensions of 16 inches x 19 inches x 0.60 inches.

Within this location, there is an absolute minimum inherent

shield thickness of one inch of steel.

In most other areas of

the USC, it is two inches or greater.

2.

Baron Tube:

It was determined after extensive discussion that the only

possible method of entry for the boron tube segment was to fall

from a control rod being processed, with the control rod being

simultaneously raised as the press jaw was being retracted. The

boron tube would then have entered the space where it was found

by falling behind the jaw to the area below the cylinders. This

space is inaccessible except when the jaw is partly open. Such

an occurrence was believed so improbable that this space had

been left open in design. It is now being modified to seal it

and preclude recurrence.

III. Determination of Cause

The determination of cause regarding this incident has been made

considering all information reviewed during the investigation, and

more specifically, the following:

(1) Portions of the upper area of the equipment were shielded with

lead blankets while others were intentionally not shielded

because no dose rate problem was indicated in this area when the

machine left the Oyster Creek site (dose rates less than 10

mr/hr). Shielding requirements were considered to be local for

fixed contamination, not general. When the box was opened, no

shielding was found to be hanging askew or to be lying on the

floor of the box. Therefore, the ropes and ties affixed at the

top of the USC remained stable.

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Operation Critique

12/24/85

Page 6

(2) The Quadrex survey dose rates went up in a general fashion

around the USC container, approximately 4-6 mr/hr at all

locations, including shielded and unshielded areas of the

machine, indicating that a general source increase had

occurred.

The addition of more shielding (reasonable amounts

within size and weight contraints) where it already existed and

at unshielded areas to reduce the two meter dose rates to less

than the administrative limit (8 mr/hr) would not have prevented

this more general dose increase above 10 mr/hr.

(3) Movement of the tube segment to the position in which it was

found resulted in a change in shield geometry, with only une

inch of steel between the tube and outside surface of the

machine as opposed to two inches for most other machine sections,

in conclusion, it was determined that the unknown piece of boron

tube segment moving freely within the USC during transit, caused the

increase in the two meter radiation levels which exceeded the

permissable limits specified in 173.441(B)(3).

IV. Corrective Action to Prevent Recurrence

A.

Specific

To prevent the entrance of contaminated or irradiated hardware into

the USC internals, and to enhance the effectiveness of

decontamination of internal surfaces, WasteChem Corporation has made

the following physical changes to the USC.

1.

Introduction of barriers to seal the entrances of areas

difficult to flush clean and prevent the entrance of foreign

material.

2.

Addition of a " Sweep" to push scrap, which could potentially

settle on the moving knives, into the collection bucket.

3.

. Twenty four access holes will be drilled in the side plates for

the introduction of a hydrolaser lance. The hole pattern

provides excellent coverage to machine internals to dislodge

foreign material and contamination. These holes will also

permit introduction of a survey instrument for accurate

detection of radioactive material.

4.

Addition of a pump interlock to insure that the USC cannot be

operated without the filtration cleanup system in service.

5.

Use of a compacting jaw set to " crimp" the work piece and thus

retaining the boron tubes in the control rod blade sheath.

The above changes preclude a similar event. These changes will also

provide more effective decontamination of other internal machine

surfaces as well as the detection of any internal radioactive

material.

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Operction Critique

12/24/85

Page 7

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B.

General.

This shipment was made with a reasonable assumption that the

radiation levels (1.34 R/hr maximum contact) was from fixed

contamination on the USC surfaces. Our experience with storage

racks and other non-Irradiated conponents, exposed to the fuel pool

water environment (as the USC was), shows these raolation levels to

be normal and not indicative of irradiated hardware. However, this

incident clearly indicates the potential for small sources of

irradiated hardware to be inadvertantly mixeo with LSA material,

provided ample intrinsic shielding exists to mask the relatively

higher radiation levels. Shipments of LSA material that could be

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comingleo with irraolatea hardware are extremely rare and, in fact,

limited to equipment utilized to handle or process the latter. To

preclude a similar recurrence of this nature, our general Radwaste

Shipping procedure (0.C. 101.3) will be revised to include a

specific precaution for a prior review of these types of shipments

to determine if irradiated pieces could be inadvertently included.

Tnis review will incluoe a requirement not to make waste

classification determinations when internal surveys are unavailable

for equipment which potentially could contain irradiated pieces. .

From a broader perspective, this incident instigated a review of our

Radioactive Material Management Program. The procedures utilized to

classify radioactive waste for our normal waste streams, such as DAW and

solidified process waste, specifically address those variables which

could preclude accurate determination of waste classification. The dose

to curie conversion computer program (Radman) utilized to classify our

normal waste streams provides anple protection to ensure accurate

classification of waste.

In conclusion, I believe this incident was not indicative of a

programmatic problem but rather a unique situation which is limited to

the area of classifying LSA material which had the potential to be

comingled with irradiated hardware. This waste type is classified on a

case-by-case basis ano the potential for recurrence with the

irtplementation of the above corrective actions is minimal for this waste

type and highly improbaole for all other waste types.

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Submitted by:

T. W. Snider

Manager, Radwaste Operations

' Yh$5

Approved by:

. L.

Su

van, Jr.

lant Operations Director

Attachments

TWS/mee

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