ML20214K293
| ML20214K293 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/08/1986 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 0065P, 4410-86-0135, 4410-86-135, 65P, NUDOCS 8608210019 | |
| Download: ML20214K293 (6) | |
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GPU Nuclear Corporation Nuclear
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e Middletown, Pennsylvania 17057-0191 717 944-7621 TELEX 84 2386 Writer's Direct Dial Number:
l (717) 948-8461 4410-86-0135 Document ID 0065P August 8,1986 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 Inspection Report 50-320/86-06 dated July 11, 1986 identified two (2) items of non-compliance. Attached are the GPU Nuclear responses to those items.
Sincerely, b
Q hG.R.Standerfer Vice President / Director, TMI-2 1
FRS/CJD/eml l
cc: Director - TMI-2 Cleanup Project Directorate, Dr. W. D. Travers 8608210019 860300 PDR ADOCK 00000320 G
PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
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@ C Notica of Viol 5 tion:
l' 110 CFR 20.311(d)(3),- " Transfer for disposal and manifests" required 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 freestanding 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. freestanding liquid.
LThis is a Severity Level IV violation (Supplement V).
GPU Nuclear Response:
Based on the information presented in the above Notice of Violation, Section 3.b of. Inspection Report 50-320/86-06, and available reference material on Radioactive Waste Management Systems, GPU Nuclear disagrees with this finding. The finding is based on the premise that neither Quality Assurance or Waste Management personnel responsible for operations performed quality control functions during dewatering i
evolutions. According to the Inspection Report, this is a failure to-conduct a quality control program. GPU Nuclear contends that the quality
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control requirements of 10 CFR Part 20 were fulfilled by the implementation of a Process Control Program for dewatering EPICOR II Liners which ensures compliance with 10 CFR Part 61.
10 CFR 20.311(d)(3) states in part that: "Any generating licensee who transfers radioactive waste to a land disposal facility or a licensed waste collector shall... Conduct a quality control program to assure compliance with Paragraphs 61.55 and 61.56 of this chapter; the program must. include management evaluation of audits." 10 CFR 61.56(a)(3) requires solid waste to "contain as little freestanding and non-corrosive liquid as is reasonably achievable, t*ut in no case shall the liquid exceed 1% of the volume."'
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The NRC correspondence to all Licensees dated December 22, 1983, entitled i
" Additional Guidance on the Implementation of 10 CFR 61", provides guidance for implementation of a recommended quality control program.
Section 2.c of Enclosure 1 nf the above referenced correspondence states that: " Activities related to implementation of 10 CFR Part 61 and 10 CFR 20.311 are not required to be included unoar the nuclear power plant
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licensee's corporate level quality assurance program for " nuclear safety related" items which pertain to the safe operation of a nuclear power j
plant. For nuclear power plant licensees quality control programs should be consistent with the quality assurance recommendations for radioactive j
waste treatment systems in Regulatory Guide 1.143."
A review of Regulatory Guide 1.143 does not clarify the requirements for an acceptable quality control program. Regulatory Guide 1.143 provides Quality Assurance guidelines only for the design, construction and i
testing of Radioactive Waste Management Systems. The operational aspect j
of a Radioactive Waste Management System is not addressed.
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. PRC.guidanca for _the operation of a Radioactivi W.tsta Management System is provided by Branch Technical Position (BTP), ETSB 11-3, " Design 4_
L Guidance for. Solid Radioactive Waste Management ~ Systems Installed in Light-Water-Cooled Nuclear Power Reactor. Plants."_ This BTP provides-acceptable design solutions to assure that radioactive waste shipments meet the receiving burial site free liquid restrictions at the time of receipt _at the burial site. Section_B.III of the BTP, " Assurance of~
_ Complete Solidification or Dewatering," states that " complete' _
solidification or dewatering of wet wastes should be assured by the' j
implementation of a process control program or by methods to detect free liquids within container contents prior to shipment."
GPU Nuclear has chosen to implement the' guidance provided by the BTP through the use of a Process Control Program. - Section B.II.l.b of.the BTP states that " Dewatering procedures, equipment, and potential waste constituents should be tested and a set of process parameters-(settling 7
time, drain time, drying time, etc.) be established which-provide boundary conditions.within which reasonable assurance can be given that 4
U dewatering will be complete,'with essentially.zero free liquid." Section i
B.II.l.d of the BTP further states, in regard to the Process Control
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Program, that "The plant operator should provide assurance that the i
process is run within the parameters established under items B.II.1.a i
and/or B.II.l.b,. above. Appropriate records should be maintained for-individual batches showing conformance with the established parameters."
i GPU Nuclear has, developed a Process Control Program for dewatering EPICOR i-II liners which satisfies the guidelines of the BTP. This Process-l Control Program is based on the results of the Resin Liner Dewatering Study which was performed after the 1979 accident. The objective of-this.
study was twofold:
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To understand the mechanism by which water exists in a resin bed.
and confidently determine the amount of water present.
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To perform various tests of removing water from the bed so as to determine the most efficient process.
i Based on the results of the various tests performed, process parameters-were established for dewatering EPICOR II Liners to ensure compliance with burial agreements. It should be emphasized that the resin liner dewatering study was performed in 1979 when the regulatory requirement for freestanding water was less than 0.5% of the container volume or one gallon, which ever was less. Since performance of that test, the l
freestanding water criteria, as specified'in 10 CFR 61, has been relaxed to no more than 1% of the container volume.
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The process of dewatering EPICOR II Liners is performed in accordance l
with approved TMI-2 Operating Procedures 4215-0PS-3526.07, Revision 1,
" Auxiliary Building Emergency Liquid Cleanup System (EPICOR II or ALC) f
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Prefilter and Demineralizer Removal," 4215-0PS-3526.18, Revision 1,
" Dewatering of EPICOR Liners at EPICOR II," and 4215-OPS-3233.08, "EPICOR j
II 4x4 and 6x6 Liner Supplemental Dewatering." These procedures were developed based on the process parameters that were established during l
the 1979 dewatering study. To ensure compliance with each of the above 1
procedures, plant operators are required to initial each step of the l -.
procedure. The completed procedure is then maintained as part of the plant history.
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GPU Nuci:*r belicy:s that the operations performed in accordanca t:ith the above procedures satisfy the BTP for acceptable dewatering programs.
Further, the requirement for operators _to initial each procedure step and
=the eventual retention of the completed procedure verifies that the parameters established by the Process Control Program are being met. GPU Nuclear considers the above actions are more than a'dequate to satisfy the quality control requirements of 10 CFR 20.311(d)(3).
In the context of the above discussion, GPU Nuclear disagrees with the notice of violation. GPU Nuclear considers its activities to be well within the regulatcry guidance'for assuring that solid waste shipments contain as 1.ittle freestanding liquid as is reasonably achievable.
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NRC Notica ' f Violation:.
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. Technical Specification:6.8, " Procedures'," requires ~thatfwritten F
procedures be established,' implemented and maintained.1 4
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Procedure No. 4000-ADM-1218.02, Revision No. 6-00, Section 4.6.6.2,- dated
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- July 22,~1985, required,:in part,:that' procedures classified as Important-
- to Safety, pertaining to. final preparation for: shipment of radioactive
. materials, including those.for dewatering, be reviewed.and concurred.in i
by Quality Assurance as a part of the. approval process.
t (Contrary to the above, Procedure'No. 4215-OPS-3526.18, " Dewatering'of EPICOR Liners at EPICOR II," Revision No. 1-00,-dated August 6,.1985 and-Procedure No. 4215-OPS-3233.08,."EPICOR II 4x4 and 6x6 Liner Supplemental-Dewatering," Revision 1-00, dated February 3, 1986, classified Important
.to Safety, did not receive Quality Assurance review as part of the j.
approval process.
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.This is a Severity Level IV violation (Supplement V).
1 GPU Nuclear Response i
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As detailed in IRC Inspection Report 50-320/86-06, TMI-2 Operating i-Procedures 4215-0PS-3526.18,". Dewatering of EPICOR Liners at EPICOR II,"
1 Revision 1, dated August 6,- 1985 and 4215-OPS-3233.08 "EPICOR II 4x4 and -
6x6 Liner Supplemental Dewatering," Revision 1, dated February 3, 1986 e
did not receive the required review and approval. Specifically, thel.
Quality Assurance Department-(QA) did not review or concur with the above-procedures as required.
This violation resulted from of an oversight during the procedure change process. In both cases, cognizant personnel were not knowledgable of a change to TMI-2 Administrative Procedure 4000-ADM-1218.02, "TMI-2 Document Evaluation Review and Approval." ' This procedure establishes the evaluation, review and approval process for TMI-2 documents. On July 22, i
1985, Procedure 4000-ADM-1218.02, Revision 6, was issued for use. This revision included the addition of Section 4.6.6.2 which requires QA to F
concur on all procedures classified as Important to Safety that deal with final preparation for shipment of radioactive materials, including
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dewatering.
On January 7, 1986, a Procedure Change Request (PCR) was initiated for l
' Procedure 4215-0PS-3233.08, "EPICOR II 4x4 and 6x6 Liner Supplemental Dewatering." Upon submittal of the PCR, the originator did not signify that QA review and concurrence was required. This oversight was not detected by any of the procedure reviewers / approvers. The procedure was
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subsequently issued on February 5, 1986 without QA concurrence, u
In regard to Procedure 4215-0PS-3526.18, " Dewatering of EPICOR Liners at i
EPICOR II", a PCR was initiated on June 21, 1985.
Thus, the procedure i.
was already in the review cycle when the requirement for QA review and i
concurrence was established on July 22, 1985. The lack of QA review and concurrence for the procedure was not detected by any of the i
reviewers / approvers. This procedure was issued on August 6, 1985 without j
QA concurrence.
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Upon identific tion of the tbova deficiencits, the procedures ware revised to include QA review and concurrence. Procedure 4315-OPS-3233.08, Revision 1-01 was issued on July 3,'1986 and Procedure 4215-0PS-3526.18, Revision 1-01 was issued on July 15, 1986. In addition, all Radioactive Waste Operation Procedures were reviewed to
-verify the required QA review and approval. Also, a memorandum from the Manager, Plant Operations dated July 25, 1986 was sent to applicable Section Managers to ensure that reviewers / approvers would be cognizant of this incident and the QA review / concurrence requirement..
GPU Nuclear considers that all necessary corrective actions have been completed and that full compliance has been achieved.
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