View source for BSEP-86-1459, Forwards Response to Violation Noted in Insp Repts 50-324/86-21 & 50-325/86-20.Corrective Actions:Processing of Radwaste Resins Containing More than 1% Oil to Assure Representative Sampling Underway & Verification Implemented

{{Adams
| number = ML20215N195
| issue date = 10/23/1986
| title = Forwards Response to Violation Noted in Insp Repts 50-324/86-21 & 50-325/86-20.Corrective Actions:Processing of Radwaste Resins Containing More than 1% Oil to Assure Representative Sampling Underway & Verification Implemented
| author name = Dietz C
| author affiliation = CAROLINA POWER &amp; LIGHT CO.
| addressee name = Grace J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION II)
| docket = 05000324, 05000325
| license number = 
| contact person = 
| document report number = BSEP-86-1459, NUDOCS 8611040423
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

=Text=
{{#Wiki_filter:r                                                                                          l I                                                                          bed Cp&L 6+
BrunswickSheamElectricPlant P. O. Box'10429 Southport, NC 28461-0429 October 23, 1986 FILE: B09-13510C SERIAL: BSEP/86-1459 Dr. J. Nelson Grace, Administrator U.S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street hV Atlanta, GA 30323 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS

==Dear Dr. Grace:==
The Brunswick Steam Electric Plant (BSEP) has received I&E Inspection Report 50-325/86-20 and 50-324/86-21 and finds that it does not contain information of a proprietary nature.
This report identified one item that appeared to be in noncompliance with NRC requirements. Enclosed is Carolina Power & Light (CP&L) Company's response to this violation.
The notice of violation and inspection report discussed an oral commitment concerning CP&L's intent to contract a consultant to further audit its program for compliance with 10CFR61.55 and 61.56.      While use of a consultant is being considered, the decision on the need for a consultant to perform the audit has not been finalized. The intent of the discussion was to indicate that                  <
per'sonnel highly knowledgeable in this specific area of the regulations would
                                ~
I be sought for the audit and not to imply thr- t, consultant was the only method'  -
to obtain this objective.                                                              l i
h r- . :uly yours ,
8611040423 861023                            y @ m./n  i                           .
PDR   ADOCK 05000324                                                               l o                  PDR
                                                    . R..Dietz, General Manager Brunswick' Steam Electric Plant MJP/jo Enclosure cc: NRC Document Control Desk
                                                                                )
9

VIOLATION A 10CFR30.'41(c) requires that before transferring by product material to a specific licensee of the Commission or an Agreement State or to a general licensee who is required'to register with the Commission or with an Agreement State prior to receipt of the by product material, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of by product material to be transferred.
The State of South Carolina Radioactive Material License No. 97, Amendment No. 41 for Chem-Nuclear Systems, Inc., Barnwell Waste Management Facility, License Condition No. 52, requires that the licensee not receive or bury oil or lubricants in any physical form. This license condition does not prohibit the receipt and disposal of waste containing incidental or trace amounts of oil which have been absorbed, provided that the amount of absorbed oil does not exceed 1 percent by waste volume in a container.
10CFR20'.311(d)(1) requires that any generating licensee who transfers radioactive waste to a land disposal facility or a licensed waste collector, shall prepare all waste so that the waste is classified according to 10CFR61.55 and meets the waste characteristic requirements in -10CFR61.56.
10CFR61.56(a)(3) requires that solid waste containing liquid shall contain as little freestanding and noncorrosive liquid as is. reasonably achievable, but in no case shall the liquid exceed 1 percent of the volume.
Contrary to the above, the requirement that waste shipped to a land disposal facility contains no unabsorbed oil or freestanding liquids in excess of 1 percent of the volume of waste was not met in that on June 13, 1986, high integrity container (HIC) No. 414319-317, shipped as radioactive materials Shipment No. 0683-082A, when inspected by a State of South Carolina inspector at the Barnwell burial site, was found to contain 36 gallons (3.2 percent of waste volume) of freestanding liquid and 2 quarts of unabsorbed oil.
This is a Severity Level IV violation (Supplement V).

===RESPONSE===
I. Admission or Denial of the Alleged Violation CP&L acknowledges that on June 13, 1986, high integrity container l           No. 414319-317, when inspected by a State of South Carolina inspector, did contain greater than 1 percent freestanding liquid as well as unabsorbed oil.
l l
{
l L

1 II. Reason for the Violation The source of the waste bead resin in the liner was the spent resin tank. The entire remaining tank contents were transferred to this liner. Apparently, oil existed at the top of the liquid in the spent resin tank and was transferred to the liner without being detected. Since some of the bead resin in the tank had been used to process floor drains, oil in the floor drains system accumulated in the spent resin tank. The spent resin mixing process apparently is not sufficient to cause the presence of oil to be identified during sampling and analysis. During processing of liner contents, the presence of oil was not identified, although some difficulty in dewatering the liner occurred.
The accumulation of oil in the resin apparently caused pockets of-water to be formed within the resin. During the dewatering process, water was drawn around these pockets and out of the liner, indicating to the operator that all water had been removed. During transport to the burial
                 . site, the water / oil pockets became dislodged and accumulated in the liner bottom, where it' was subsequently found upon inspection by liner punching.
The absence of an accurate method of identifying the oil content in resin wastes is the direct cause of this violation.
III. Corrective Steps Which Have Been Taken Radioactive waste resins which are possibly exposed to oil which could cause volume to be greater than 1 percent during service or processing are being processed to assure representative sampling. Representative samples are being analyzed for oil content to determine disposition in accordance with applicable regulations regarding oil content.
As of October 9, 1986,~seven liners of bead resin have been processed with oil content analyzed and found to meet Barnwell Site criteria.
The liners were solidified in accordance with Chem-Nuclear and CP&L procedures to ensure compliance with freestanding water criteria.
A verification procedure has been implemented for the process control program and is referenced in loading dock transfer procedures to ensure performance during waste resin transfers. .This procedure assures identification of the proper' disposition process based upon resin source and sample analysis.
          .IV. . Corrective Action to Avoid Further Violations Action to correct the problem and prevent a recurrence has.been taken.
V. Date When Full Compliance Will Be Achieved Full compliance has been achieved.
f l
i l
l l}}