ML20203D201

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Forwards Updated Response to IE Bulletin 79-19, Packaging of Low Level Radwaste for Transport & Burial, Per Insp Rept 50-219/85-25.Response Updated to Reflect Organizational Changes & Current Training Programs
ML20203D201
Person / Time
Site: Oyster Creek
Issue date: 04/10/1986
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To: Murley T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
IEB-79-19, NUDOCS 8604220057
Download: ML20203D201 (5)


Text

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o GPU Nuclear Corporation Nuclear

',m:r388 Forked River. New Jersey o8731-o388 Go9 971-4000 Wnters Direct Dial Number:

April 10,1986 Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Subject:

Oyster Creek Nuclear Generating Station-Docket No. 50-219 IE Inspection 85-25 dated September 11, 1985 As suggested by the subject inspection report, Attachment I of this letter updates our September 24, 1979 response to I&E Bulletin 79-19,

" Packaging of Low-Level Radioactive Waste for Transport and Burial".

As you are aware, since our original response to I$E Bulletin 79-19, an organizational change altered the department responsible for the radwaste packaging and shipping functions.

Previously the responsibility was under the direction and control of the Radiation Protection Department. The present shipping organization is under the control and direction of the Manager of Radwaste Operations. Thus, the comitment to I&E Bulletin 79-19 Item 5 is being revised to reflect current training programs. We understand that this item will be reviewed during a subsequent inspection.

Should you require any further information, please contact Brenda Hohman, Oyster Creek Licensing Engineer at (609)917-4642.

Very truly yours, Pe Vice President and-Director Oyster Creek PBF/BH/ dam (Ol03A)

Attachment cc: Mr. Jack N. Donohew, Jr.

U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 Mail Stop No. 314 gg420057e6041o 0

Dock 05000219 PDR NRC Resident Inspector 0 ster Creck Nuclear Generating Station

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GPU Nudear Corporation is a subwhary of the Ger'eral Pubhc Utdities Corporation I

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g ATTACHMENT-I Revised Response to NRC 16E Bulletin 79-19 Item 1 Maintain a current set of DOT and NRC regulations concerning the transfer, packaging, and t ransport of low-level radioact ive waste material.

Response

A current set of Department of Transportation (49 CFR) and Nuclear Regulatory Commission (10 CFR) regulations concerning the transfer, packaging, and transport of low-level radioactive waste material is maintained at the Oyster Creek Station in the Radwaste Shipping Department.

Item 2 Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee.

If a waste collection contractor is used, obtain the appropriate requi rement s from the contractor.

Response

A current set of requirements (license) placed on the burial site operators by their respective states are maintained on site in the Radwaste Shipping Department.

Items 3 Designate, in

writing, people in your organizat ion who are responsible for the safe transfer, packaging, and t ransport of low-level radioactive material.

Response

Personnel in the Oyster Creek Station organi zat ion who are responsible for the safe transfer, packaging, and transport of the low-level radioacti ve material and those personnel qualified and authorized to sign shipping papers for transportation of radioactive waste have been designated in writing.

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's Revised Response to NRC ISE Page 2 Bulletin 79-19 Iten 4 Provide management-approved, detailed instructions ami opera t ing procedures to all personnel involved in the transfer, packaging, and t ransport of low-IcVel radioacti ve mat eri al.

Special attention should be given to controls on the chemical ami physical form of the low-level radioactive material and on the containment integrity of the packaging.

Response

Management-approved operating procedures which are used in operations and in the transfer, packaging, ani transport of radioactive material are provided.

Item 5 Provide t raining and periMic ret raining in the DOT and NRC regulatory requi rement s, the waste burial license requi rement s, and in your inst ructions and operat ing procedures for all personnel involved in the transfer, packaging, and t ransport of radioactive material.

Maintain a record of t raining dates, attendees, and subject material for future inspections by NRC personnel.

Restonse Training and periodic retraining in the DOT and NRC regulatory requirements are presently provided to Radwaste Operators, Rad Con Technicians, Station Services, and Radwast e Shipping Supervisors.

The present Operations t raining prog ram provides t raining and retraining on minimizing radioactive waste by those processes which generate wastes.

A t raining program is administered for radwa st e facility operators which covers Radwaste Opera t ions incitx!!ng transfer, packaging, and shipping of radioactive material in the DOT, NRC, and waste burial requi rements thereto.

Personnel packaging DAW are bargaining unit personnel who are t rained in t he operations of tie packaging as well as transfer an! storage procedures.

They are under the direct supervision of the Radwaste Shipping Supervisors who are training in all applicable regulatory criteria.

Item 6 Provide t raining and periodic retraining to Radwaste Operators who operate the processes which generate waste to assure that the volume of low-level radioactive waste is minimized and that such waste is processed into acceptable chemical and physical form for t ransfer and shipment to a low-level radioactive waste burial facility.

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's Revised Response to NRC I6E Page 3 Bulletin 79-19

Response

See response to item 5.

s item 7 Establish and implement a management-controlled atxiit function of all t ransf er, packaging, and transport activities to provide assurance that personnel, instructions ami procedures, and process ani t ransport equipment are functioning to ensure safety ani compliance with regulatory requirements.

Response

A management-controlled audit function for the transfer, packaging, and transport of radioactive materials has been established ani has been implemented. This function is provided by the Quality Assurance Department through the QA progran development ani audit sections.

Item 8

Perform, within 60 days of the date of this
bulletin, a

management-controlled audit of your activities associated with the t ransfer, packaging, and t ransport of low-level radioactive waste.

Maintain a record of all audits for future inspections by NRC or DOT inspections.

(Note:

If you have an established anlit function and have performed such an audit of all activitles in items 1-6 within the past six months, this audit requirement is satisfied.)

Response

A management controlled audit of Radwaste Operations was comiucted on March 7, 1979 (Audit No. 79-04) and have been conducted on an annual basis since the issuance of the 16E bulletin.

In addition to annual audits conducted by the OC OA site audit

section, routine inspect ions /moni toring of regular waste shipments are conducted by Operations QA monitors.

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Revised Response to NRC I6E Page 4 Bulletin 79-19 Item 9 Provide answers for 1978 and for the first six months of 1979 to the following questions:

1.

How many low-level radioact ive waste shipments did you make?

What was the volume of low-level radioactive waste shipped?

(Power reactor licensees who report this information in accordance with Technical Specifications do not need to respond to this giestion.)

2.

What was the quantity (curies) of low-level radioactive vaste shipped?

What were the major isotopes in the low-level radioactive waste?

(Power reac tor licensees who report this information in accordance with Technical S,.ecifications do not need to respond to this giestion.)

3.

Did you generate li quid low-l evel radioac t i ve waste?

If the answer is "yes", what process was used to solidify the liquid waste?

Response

1.

Reported in Semiannual Reports for the yea rs since

1978,

" Radioactive Effluent Releases."

2.

Same as No. I above.

3.

Liquid low-le vel radioacti ve waste is gene ra t ed.

A process using lime and cement is present ly used to solidify filter sludge and evaporator bottoms.

1950W/4

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