ML20236U124
| ML20236U124 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/25/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8712020296 | |
| Download: ML20236U124 (5) | |
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w TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 374o1 SN 157B Lookout Place N00/ 251987 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l
Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 I
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50-296 l
BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/87-34, 50-260/87-34, AND 50-296/87-34, - RESPONSE TO NRC CONCERNS This letter is to provide TVA's response to your letter from G. G. Zech to S.
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A. White dated October 16, 1987 which transmitted the subject report. This l
1etter transmitted a severity level IV violation for liquid found in a radioactive waste shipment. provides TVA's response to the violation. A list of commitments i
l is provided in enclosure 2.
We do not recognize any other items described I
herein as commitments.
In regard to your cover letter reference to an oral commitment, TVA did not intend to make an oral commitment concerning a formal management development program for the newly appointed Technical Section Supervisor within the site Radiological Control Group. Actions are being taken to orient a new manager and while these actions are definitely in the area of management development, there was no formal specific management program corcmitment intended. This was discussed with T. Collins of Region II on November 6, 1987.
l An extension of this response submittal due date until November 29, 1987 was agreed to in a conference call with Al Ignatonis of your staff on November 12, 1987. Please refer any questions to C. S. Hsieh at (205) 729-2048.
To the best of my knowledge, I delcare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
-R.
- ridley, irector Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 8712O20296 h9
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DR ADOCK PDR An Equal Opportunity Employer
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. U.S. Nuclear Regulatory Commission f40 '
51987 cc (Enclosures):
Mr. G. G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Coramission Region Il 101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects l
U.S. Nuclear Regulatory Commission 4350 East-West Highway EWW 322 Bethesda, Maryland 20814 l
Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 2, P.O. Box 311 i
Athens, Alabama 35611 i
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ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/87-34, 50-260/87-34, 50-296/87-34 LETTER FROM G. C. ZECH TO S. A. WHITE DATED OCTOBER 16, 1987 Violation 50-259, 50-260. 50-296/87-34-02 10 CFR 30.41(c) requires that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring-the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of the byproduct material to be transferred.
l License Condition 32A, Radioactive Material License 097, Amendment 41, issued to the low level radioactive waste disposal facility operator, Chem-Nuclear Systems, Inc. by the State of South Carolina, Department of Health and Environmental Control requires that the licensee shall not receive any liquid radioactive waste regardless of the chemical or physical form.
License Condition 34. Radioactive Material License 097, Amendment 41, requires that the licensee shall not accept liquid radioactive waste packaged in absorbent materials, or where absorbent materials have been used to absorb liquids rather than properly solidified with an approved media.
Contrary to the above, on August 5,1987, the licensee failed to comply with' a disposal site's license conditions in that a drum within Radioactive Waste Shipment No. 0787-052-S was found upon its arrival at the disposal cite to contain free liquid. The licensee had also used absorbent material to absorb liquids rather than properly solidifying the waste with an approved media.
This is a Severity Level IV violation (Supplement V).
1.
Admission or Denial of the Alleged Violation (or Finding)
TVA admits the violation occurred.
2.
Reasons For the Violations (or Finding) if Admitted i
The root cause for the presence of excess liquid in radioactive waste shipment No. 0787-053-S is attributed to deficiencies in the current method for j
processing' wet and damp material' resulting from our misinterpretation of i
license condition 32A.
(please note the correct shipment No is 0787-053-S instead of 0787-052-S as stated in the Notice of Violation.) License condition 32A allows the use of approved absorb'ent material in packages of dry solid waste to absorb unintentional and incidental amounts of liquids. Before this 1
infraction, it was TVA's position that liquid, retained within solid materials after initial processing, was considered " incidental" to the waste.
Accordingly, when processing wet and damp solid material, the method then in l
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.. i use required the addition of "Celite," a form of diatomejeous earth, to absorb any residual liquids.
Subsequent lab tests have' revealed that Celite, when mixed with liquids to the point of saturation and subjected to agitation, will release a portion of the liquid. The current procedure has no provisions to prevent saturation of the Celite.
Obviously, all materials prepared by this method will be agitated during shipment.
Therefore, the two conditions for release of free liquids within the radwaste packages could be present.
After a review and evaluation of this infraction TVA recognized that it misinterpreted license condition 32A with regard to the definition of unintentional and incidental liquids.
Based on the corrective action, which requires complete drying of'the material or special processing, we
'do not expect a need for further interpretation of condition 32A.
3.
Corrective Steps Which Have Been Taken and Results Achieved Special tests have been performed to establish optimum drying periods for various wet and damp materials. Portland cement is being used as a i
generic absorbent for incidental liquids.
1 4.
Corrective Sters Which Will Be Taken To Avoid Further Violations We have concluded from our investigation that the most significant_
improvement in our method for processing wet and damp material will be I
gained by placing a major emphasis on the complete drying of wet and damp materials such as mops, rags, and filters before packcging. However, specific cases may arise when the complete drying of wet and damp material is not practical or feasible.
In those cases, special processing techniques will be utilized. Special tests will continue in order to establish optimum drying periods.
An internal radwaste section quality assurance program focusing on verifying radwaste packaging procedural compliance and processing effectiveness will be developed. Boyss and drums of dry, solid waste will be randomly inspected before being released for shipment. Test data will be gathered and evaluated on a variety of disposal site approved absorbents to be used as alternates or backups for Portland cement.
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Date When Full Compliance Will Be Achieved TVA will b'e in full compliance by January 1, 1988.
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ENCLOSURE 2 LIST OF COMMITMENTS l
1.
Complete drying where feasible of wet and damp materials such as mops,
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rags, and filters before packaging.
2.
An internal radwaste section quality assurance program on verifying l
procedural compliance and processing effectiveness will be developed.
This vill include random inspection of boxes and drums of dry, solid waste before being released for shipment.
3.
Test data will be gathered and evaluated on a variety of disposal site
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approved absorbents to be used as alternates or backups for Portland I
cement.
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