ML20203N524
| ML20203N524 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/26/1986 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 0065P, 4410-86-L-0159, 4410-86-L-159, 65P, NUDOCS 8610090225 | |
| Download: ML20203N524 (3) | |
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jo GPU Nuclear Corporation g
gf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84-2386 Writer's Direct Dial Number:
(717) 948-8461 4410-86-L-0159 Document ID 0065P September 26, 1986 Office of Inspection and Enforcement Attn: Dr. T. E. Murley Regional Administrator US Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Dr. Murley:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report 86-06, Supplemental Response Inspection Report 50-320/86-06 dated July 11, 1986 identified two (2) items of non-compliance. GPU Nuclear letter 4410-86-L-0135 dated August 8,1986 provided the GPU Nuclear response to those items. Based on further discussion with members of your staff, the attached information supplements the response provided by GPU Nuclear to one of the items of non-compliance.
Sincerely,
/
T
. Standerfe Vice President / Director, TMI-2 FRS/CJD/eml Attachment cc: Director - TMI-2 Cleanup Project Directorate, Dr. W. D. Travers 8610090225 860926 PDR ADOCK 05000320 G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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t a s-NRC NOTICE OF VIOLATION l
10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires that a licensee who transfers radioactive waste to a land disposal facility conduct a quality control program to assure compliance with 10 CFR 61.56.10 CFR 61.56 requires, in part, that free-standing and non-corrosive liquids not exceed one percent of the volume of solid wastes.
Contrary to the above, during 1985, the licensee transferred several radioactive waste shipments of dewatered resin to a land disposal facility in the State of Washington and the licensee did not conduct a quality control program to assure that the packages contained less than one percent by volume free-standing liquid.
4 This is a Severity Level IV violation (Supplement V).
GPU NUCLEAR SUPPLEMENT RESPONSE 1
In the initial response to this item GPU Nuclear contended that the quality control requirements of 10 CFR Part 20.311 were fulfilled by implementation of a Process Control Program for dewatering EPICOR II Liners which ensured compliance with 10 CFR Part 61.56. Based on further discussion with members of your staff, we understand that two specific concerns remain.
1.
The EPICOR II Liner Dewatering Procedures did not provide for an independent verification of the dewatering process.
2.
The NRC did not have enough information to determine whether the EPICOR II supplemental dewatering process was adequate.
With respect to the first issue, independent verification of the dewatering process, as of July 24, 1986, the following procedures have been modified to include a prerequisite that the Quality Assurance Department be notified prior to the dewatering of EPICOR II liners:
o 4215-OPS-3233.08 EPICOR II 4x4 and 6x6 Liner Supplemental Dewatering i
o 4215-OPS-3526.07 Auxiliary Building Emergency Cleanup System (EPICOR II or ALC) Prefilter and Demineralizer Removal o 4215-0PS-3526.18 Dewatering of EPICOR Liners at EPICOR II These procedural changes will further assure that the dewatering process receives an appropriate level of Quality Assurance / Quality Control overview consistent with the NRC approved " Recovery Quality Assurance Plan for Three Mile Island Nuclear Station Unit 2."
With respect to the second issue, adequacy of the supplemental de-atering process the following information is provided. This information should allay any concerns relative to the adequacy of this procrss.
s Supplemental dewatering is a process used at TMI-2 if the normal EPICOR II liner dewatering process is not sufficient, that is completion of normal EPICOR II dewatering is a prerequisite to supplemental dewatering.
During
re f-supplemental deratering a 5/8 hole is drilled 13/16" to about 1" above the~
8 bottom liner plate. The liner is then tilted by placing an 82x8" block under the edge of the liner opposite the drain hole. The liner is then allowed to drain through this hole. The draining operation continues for at least one (1) hour after visible drainage ceases or until a leakrate specified by engineering has been achieved. Then, the hole is resealed.
In May 1981, a calculation war performed to determine the amount of free water that could be lef t in an EPICOR 6x6 af ter performing the supplemental dewatering process outlined above. This calculation assumed a square 6'x6' vessel, tilted 8" with the bottom of the drain hole 1/2" above the bottom liner plate. Based on those assumptions, the liner would retain no more than 0.35 gallons of free-standing liquid remaining after supplemental dewatering.
As this volume of liquid is less than the one percent by volume free standing liquid requirement of 10 CFR 61.56, GPU Nuclear believes that this process is adequate.
Additionally, GPU Nuclear reviewed the supplemental dewatering procedures This review performed subsequent to the implementation of 10 CFR 20.311.
revealed that a majority of the steps were signed by a Radwaste Foreman.
Because of normal union / supervisor work distribution, it can be inferred that the steps were performed by one person and then verified and signed by the supervisor. Discussions with affected supervisory personnel indicated that, because of the increased complexity of the supplemental dewatering process, the inferred independent verification did occur. GPU Nuclear believes that this practice provides adequate independent verification of the supplemental dewatering process to comply with 10 CFR 20.311(d)(3).
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