ML20198C521
| ML20198C521 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/05/1985 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8511120109 | |
| Download: ML20198C521 (1) | |
See also: IR 05000219/1985025
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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KING OF PRUS$1 A, PENNSYLVANI A 19406
NOV 0 51985
Docket No. 50-219
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. 85-25
We acknowledge receipt of your letter dated October 17, 1985, in response to
our letter dated September 11, 1985.
Thank ycu 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,
Sa
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homas T. Martin, Dir ctor
Division of Radiation Safety
and Safeguards
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cc:
M. Laggart, BWR Licensing Manager
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Licensing Manager, Oyster Creek
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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
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Route 9 South
Forked River. New Jersey 08731 -0388
609 971-4000
Wnter's Direct Dial Number:
October 17, 1985
Thomas T. Martin, Director
Division of Radiation Safety and Safeguards
Region I
U.S. Nuclear Regulatory Commission
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.
Yht guly yours
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Pe
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edler
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P esident and Director
0y
e Creek
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Enclosures
(0103A)
cc:
Dr. Thomas E. Murley, Administrator
Region I
U.S. Nuclear Regulatory Commission
631 Park Avenue
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
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GPU Nuclear Corporation is a subsidiary of the General Pubhc Utikties Corporation
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ATTACHMENT I
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VIOLATION
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10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires a
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licensee who transfers radioactive waste to a land disposal facility to
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conduct a quality control program to assure compliance with 10 CFR 61.55 a:..
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Contrary to the above, the licensee has transferred several radioactive
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waste shipments to a land disp'osal facility during 1984 and 1985 and the
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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
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that spent resin contained less than 1% liquid by volume wnen the resin was
in a disposal container (high integrity container) designed to ensure
stability, and neither did the licensee verify tnat 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.
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This is a Severity Level IV violation.
DISCUSSION
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GPUN has maintained and continues to maintain an extensive QA Monitoring
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Program to verify that various programs are implemented and meet established
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requirements. Radioactive Material Shipping and Handling is one of
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approximately 30 programs under the scope of QA Monitoring.
Through periodic planning and scheduling activities, Operations QA
determines how their current resources can be most effectively utilized.
These detenninations consider the need for achieving broad scope coverage in
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each program that is monitored as well as the need to address significant
areas of concern.
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During 1984, approximately 80 monitorings were performed on radioactive
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material shipping.
In 1985, to date, over 170 monitorings have been
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performed in that area. This number is greater than that for any otner
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program monitored during the same time period. A sufficient portion of the
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total radioactive material shipping and handling program was monitored to
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provide confidence that the program in general is properly implemented and
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meets established requirements.
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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
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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
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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
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the violation.
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Further, it should be noted that Operations QA reviewec all procedures'
relat d 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.
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RESPONSE
Corrective Steps Which Have Been Taken and the Results Achieved:
Changes to the Operations QA (0ps/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 notification 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 /cciculations used in
verifying that the acceptance criteria have been met will be reviewed.
Computer Program: Ops /QA will periodically review RADMAN (the computer
program used to detennine waste classification) to ensure:
1.
Reccrds are maintained 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.
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Solidification Verification: The following activities will be
periodically monitored to verify that the solidification process is as
effective as described in the Topical Report.
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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
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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 of CNSI 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 the 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.
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