ML20213G720
| ML20213G720 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/30/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20213G717 | List: |
| References | |
| NUDOCS 8611180286 | |
| Download: ML20213G720 (3) | |
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October 30, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368
Dear Sir:
TROJAN NUCLEAR PLANT Responses to Notices of Violation Your letter of October 1, 1986 forwarded Inspection Report 86-30 and two Notices of Violation. These Notices of Violation concerned the transfer to a shipping container (July 24, 1986) and shipment (August 5, 1986) of Type B radioactive waste. Our responses to these Notices of Violation are attached.
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Bart D. Withers Vice President Nuclear Attachment c:
Mr. Lynn Frank, Director State of Oregon Department of Energy 8611180286 861112 PDR ADOCK 05000344 o
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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 October 30, 1986 License NPF-1 Attae.hment Page 1 of 2 RESPONSE TO NOTICE OF VIOLATION Violation A.
10 CFR 71.12(c)(2): requires that any licensee of the Commission who transports, or delivers to a carrier for transport, licensed material in a package, under a general license pursuant to 10 CFR 71.12(a) shall comply with the terms and conditions of the approved certificate of compliance (COC) for that package. Condition 5(b)(1) of NRC COC No. 9208, limits the content type and form for a Model No.10-142 shipping package to:
"(i)
Dewatered, solids, or solidified waste in secondary containers; or (ii) Activated solid components in secondary containers."
Contrary to the above requirements, on August 5, 1986, the licensee delivered for transport a Model No.10-142 shipping package which contained approximately 30 gallons of freestanding radioactive water between the inner liner (dewatered resins) and the shipping cask.
This is a Severity Level IV violation (Supplement V).
Response
The root cause of the violation was procedural inadequacy. The Plant and vendor procedures did not contain sufficient detail to ensure the inner liner was not overfilled. The lack of sufficient management attention to this task was a contributing cause.
The following procedural changes have been made to preclude recurrence of this problem.
1.
The vendor procedure has been revised to clearly define the sequence of steps for equipment setup and testing. The procedure now requires testing of the level alarms and automatic shutoff
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i switch after placing the fillhead on the inner liner.
2.
The cask handling procedure has been revised to include pulling the cask drain plus prior to shipment if the inner liner has been filled in the cask with material that requires dewatering.
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3.
The vendor procedure has been revised to include the use of hold-down straps to ensure the fillhead does not move during the resin transfer.
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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 October 30, 1986 License NPF-1 Attachment Page 2 of 2 4.
The use of the vendor equipment was modified to provide improved visual observation of the level of the resin / water mixture in the inner liner. The fillhead camera now has an unobstructed view of the inner liner internals. The vendor procedure has also been modified to include the addition of level marks on the inner liner to allow more precise visual observations.
5.
NSRD Radiological Safety Branch personnel have reviewed the packaging and shipping procedures for these types of radioactive shipments.
In addition to the above actions, the Manager of the Radiological Safety Branch has been assigned to complete a programmatic review of the expected actions for the preparation, packaging, and shipment of Type B radioactive wastes from the Trojan Nuclear Plant. This review may show the need for additional actions. Until this review and any resulting corrective actions are completed (expected by December 31, 1986), there will be no Type B shipments of radioactive wastes from the Trojan Nuclear Plant.
Violation B.
10 CFR 20.401(b) requires, in part, that each licensee shall maintain records showing the results of surveys required by 10 CFR 20.201(b),
" Surveys".
10 CFR 20.201(b) requires that each licensee make or cause to be made surveys as:
(1) may be necessary for the licensee to comply with the regulations in 10 CFR 20, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
Contrary to the above, as of August 26, 1986, the licensee failed to maintain records of surveys made of the apent resin storage tank pump room and adjacent areas on July 24, 1986, following the transfer of radioactive resins.
This is a Severity Level V Violation (Supplement IV).
Response
As stated in Inspection Report 86-30, the survey in question was performed and the survey data were documented but these records were lost. The root cause of the loss of survey data was a lack of attention in the documentation and filing of survey results by Radiation Protection personnel. The need and importance for documentation and filing of all survey data was reviewed prior to October 1, 1986 with the appropriate Radiation Protection personnel.
NCD/kal 1057W.1086