ML20247N399

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1100/89-01. Actions to Assure B-25 Waste Boxes Sealed to Preclude Possible Spread of Contamination Appear Inadequate

ML20247N399
Person / Time
Site:	07001100
Issue date:	07/25/1989
From:	Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8908020387
Download: ML20247N399 (2)

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JUL 2 51989

) Doc'ketNo. 70-1100.

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Combustion Engineering,;Inc.

' ATTN: .Dr. P. L.'McGill '

Vice' President - Nuclear. Fuel Manufacturing.

. Nuclear Power Systems -

1000 Prospect. Hill Road'

' Windsor,. Connecticut 06095-0500 Gentlemen:

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Subject:

Inspection No.~.70-1100/89-01 This refers to your letter dated April 14, 1989, in response to our letter

dated' March.14, 1989.

Thank .you _for informing .us. of; the corrective and preventive actions documented in your . letter. These actions will be examined during a future inspection of

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your licensed program.

Inlyour, response to' Violation A you contend that the use of type E cup seals meets the intent of-'section 5.1.3 of your NRC-approved facility license application:

since " sealing while'on the waste storage. pad was intended-for the detection of-tampering.": In section VIII-E of the NRC Safety Evaluation Report issued in support of the March 14, 1983. license renewal,.the statement.was made, in part, that low level solid waste packages may be stored outside in a fenced area within 1

.the CE. site; and that all outside storage is sealed and checked four times each L

y year to ensure.that no. radioactive contamination has leaked from.the package.

Through discussions with'NRC licensing personnel, we have confirmed that NRC intended sealing of;the' container to preclude the possible spread of contamination L. .out of:the package into the environment. ~The use of type E cup seals is not

. adequate to. provide .the intended seal for contamination control purposes.

l- Therefore, the violation as issued is-appropriate and will stand.

The actions you described in your response to this violation do not appear adeounte to: assure that B-25 waste boxes are sealed'to preclude the possible

. c < spread of contamination while'in outside storage. Therefore, please provide, l <

'Within 10 days of the date of this letter, a description of yoer actions to L;. correct and prevent recurrence of this item, along wfth the date by which full f'

compliance will be achieved. The response required by this letter is not subfect tof ciearance by the Office of Management and Budget under the Paperwork Reduction cAct~of 1930, PL 96-511.

I I i 0FFICIAL RECORD COPY RL CE 89 0001.0.0 t 06/07/89 1 I

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I989 Combustion Engineering, Inc. 2 Your cooperation with us is appreciated.

Sincerely, Original Signed by:

James H. Joyner c for Ma',.31m R. Knapp, Director Division of Radiation Safety and Safeguards cc:

A. E. Scherer, Director, Nuclear Licensing

'C. B. Brinkman, Manager, Washington Nuclear Operations Public Document Room (PDR)

Local Public Document Room (LPDR) i Nuclear Safety Information Center (NSIC)

State of Connecticut bcc:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

J. Roth, DRSS D. McCaughey, NMSS l

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SOIWBBUSTION ENGINEERING April 14,1989 Docket No. 70-1100 License No. SNM-1067 Dr. Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I 4'75 Allendale Road King of Prussia, Pennsylvania 19406

Subject:

Reply to Notice of Violation

Reference:

Letter, R. R. Bellamy (NRC) to P. L. McGill (C-E),

Inspection Report No. 70-11/89-01, dated March 14, 1989

Dear Dr. Bellamy:

Combustion Engineering has reviewed the Notice of Violation received as Attachment (A) to the reference letter. Combustion Engineering's response to the two (2) violations are submitted herewith.

Please note that based on the additional information provided in the Enclosure, we request that the portion of Violation (A) dealing with low level waste container sealing be reconsidered.

If you have any questions, please do not hesitate to call me or Mr.

A. E. Scherer of my staff at (203) 285-5200.

Very truly yours, COMBUSTION ENGINEERING, INC.

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,P. L. McGil Vice President Nuclern Fuel PLM:jeb [G 2 d /_ l ljf! 69.

Enclosure:

As stated cc: D. McCaughey , _ , , . _ . .

J. Roth (NRC - Regidn4)~ n '2b Power Systems 1000 Prospect Hill Road (203) 688-1911 Combustion Engineering. Inc. Post Office Box 500 Telex: 99297 Windsor, Connecticut 06095-0500

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Enclosure I Page 1 of 4 Combustion Engineering Response to NRC Notice of Violation Violation A:

License Condition 9 of License No. SNM-1067 dated March 14, 1983, incorporates Section 5.1.3, " Low-Level Radioactive Waste," dated April 6,1982, into the NRC-approved license application (Part I -

Criteria) which states, in part, that low-level radioactive wastes will be packaged in accordance with all applicable regulations and stored on an outside storage pad. The maximum residence time of a package will be twelve months and all packages will be sealed, monitored for contamination and labeled as to enrichment and U-235 content.

Contrary to the above, on January 30-31, 1989, five unsealed Model B-25 packages of low-level radioactive waste were observed on the outside waste storage pad and three 55-gallon drums of low-level radioactive

• waste had been stored on the waste storage pad since December 28, 1987, (in excess of thirteen months).

Response

Combustion Engineering concurs that the five B-25 low-level waste packages were not secured with metal clips. They were, however, sealed with Type E cup seals, thus meeting our license requirement that they 'oe " sealed". (Sealing while on the waste storage pad was intended for the detection of tampering). If shipped off-site, the B-25 shipping containers would be secured with metal clips to fasten the cover in place during shipment for disposal. The B-25's in question were not secured with the metal clips because it was anticipated that these containers '

would have to be brought back into the Building 17 pelJet shop where they would be reopened and the contents reprocessed. Based on the above, Combustion Engineering believes that we were and are in compliance with the license and its intent. As such. Combustion Engineering would intend to continue to use tamper indicating seals for those occasions where containers are being temporarily held on the waste storage pad. The language in Section 5.1.3 of the license application will, however, be clarified as part of our overall license upgrade / renewal process to more explicitly define our sealing procedures.  !

i In regard to the three 55-gallon drums of radioactive waste showing an l apparent waste storage pad residence tirre in excess of the twelve month i limit; these drums contain contandnated oil which was encapsulated in i concrete for subsequent shipment to the Hanford site for burial. The drums were being held on the waste storage pad until arrangement could be mado for shipment to the Hanford burial site. During the course of this holding period our Hematite facility indicated that they would also be making a shipment of material to the Hanford burial site. The three drums in question were shipped to Hematite where they were to be l

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' Enclosure I

, Page 2 of 4 combined with the Hematite shipment and forwarded to Hanford. After several months, however, Hematite decided that they did not need to make a shipment to the Hanford site, and the three drums were returned to Windsor and placed back on the waste storage pad.

The shipment to Hematite was made prior to the expiration of the twelve month waste storage pad residence time limit, thereby complying with the license requirement. When the drums were returned from Hematite, however, we failed to place new dates on the drum labels to indicate that they had in fact not been resident on the Windsor waste storage pad for greater than twelve months. These drums have since been re-dated to reflect their new arrival time on the waste storage pad. Since the inspection, these drums were shipped to Hanford.

While technically in conformance with our license, Combustion Engineering recognizes that labeling on the containers were not updated upon their return from Hematite. While we believe the specific instance cited came about because of a unique sat of circumstances which is not representative of normal waste handling operations, we will, nevertheless, revie- our facility procedures to see if any explicit changes are warranted to help prevent a similar re-occurrence. This review will be accomplished as part of our Waste Management Program review which is currently scheduled for completion by July,1989.

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. Enclosure I

. Page 3 of 4 Violation B:

Amendment No. 9 to License No. SNM-1067, dated . April 8,1987, incorporates Section 2.3, " Nuclear Safety Committee", dated October 22, 1986, into the NRC-approved license application (Part I - Criteria) which states, in part, that it is a function of the Nuclear Safety Committee to review and approve applications for SNM license renewals and amendments  ;

affecting nuclear criticality safety prior to submittal to the NRC.

1 Contrary to the above, as of February 1,1989, there were no records available which indicated that the Nuclear Safety Committee, other than its Chairman, reviewed and approved applications for SNM license amendments affecting nuclear criticality safety prior to submittal to the NRC.

Response

As part of our upgrade effort, and in response to this violation, Combustion Engineering is following a revised and more disciplined process to secure Nuclear Safety Committee review and approval of license amendments which affect nuclear criticality safety.

1Lfore an amendment is transmitted to the Nuclear Regulatory Commission, it is sent to the Chairman of the Nuclear Safety Committee. The Chairman, or his designee, may determine that the draft amendment does not affect nuclear criticality safety and, l therefore, that Nuclear Safety Committee review is not required. If this is the case, the Chairman, or his designee, signs off on the amendment and no further Nuclear Safety Committee review is required.

On the other hand, if nuclear criticality safety may be affected, review of the draft amendment is normally performed by the members of the Committee on a notice and comment basis. That is, the Chairman, or his designee, distributes copies of the draft amendment to Committee members. (The Chairman, or his designee, may also elect to hold a formal committee meeting for that purpose or add it to the agenda of a previously schedule meeting.) The comments and concern of the Committee members, if any, are collected by the Chairman, or his designee, who then forwards them on to Nuclear Licensing. The revised amendment package is again provided to the Chairman of the Nuclear Safety Committee, or his designee, to confirm that all Committee concerns have been addressed in an acceptable manner. Concurrence is provided by the signature of the Chairman, or his designee.

Records of Nuclear Safety Committee reviews were and are available in the offices of the Chairman of the Nuclear Safety Committee. Records of Nuclear Safety Committee approvals (or that nuclear criticality safety is not involved) is documented by the signature of its Chairman, or his designee, and is available in Nuclear Licensing.

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' Enclosure I

~ . Page ' 4 of 4 with the process described above, Combustion Engineering believes that it is in compliance with our license requirement.for Nuclear Safety Committee reviews and approvals of license amendments affecting nuclear criticality safety prior to their submittal to the NRC, and will be able to provide adequate documentation to that effect at future audits.

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