IR 05000219/1985025: Difference between revisions

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{{Adams
{{Adams
| number = ML20135E467
| number = ML20204A376
| issue date = 09/06/1985
| issue date = 05/01/1986
| title = Insp Rept 50-219/85-25 on 850729-0801.Violation Noted: Failure to Conduct QC Program Re Radwaste Transfer to Land Disposal Facility
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/85-25. Corrective Actions Will Be Examined During Future Insp
| author name = Clemons P, Kramaric M, Miller M, Pasciak W
| author name = Martin T
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name = Fiedler P
| addressee affiliation =  
| addressee affiliation = GENERAL PUBLIC UTILITIES CORP.
| docket = 05000219
| docket = 05000219
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-219-85-25, IEB-79-19, NUDOCS 8509160407
| document report number = NUDOCS 8605120139
| package number = ML20135E460
| title reference date = 04-10-1986
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 7
| page count = 2
}}
}}


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=Text=
=Text=
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MAY n 11986 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:
.
Subject: Inspection No. 85-25 We acknowledge receipt of your letter dated April 10, 1986, in response to our letter dated September 11, 1985.
    .
U.S. NUCLEAR REGULATORY COMMISSION


==REGION I==
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 your licensed program.
, Report N /85-25
;
Docket N License No. OPR-11  Priority --
Category C Licensee: GPU Nuclear Cg poration P. O. Box 388 Forked River, New Jersey 08731 i Facility Name: Oyster Creek Nuclear Station    I Inspection At: Forked River, New ' Jersey l
Inspection Conducted: July 29 - August 1, 1985 Inspectors: [ b-m /      _f
  'P. Clemons, Madiation Specialist  d&te f0  M/lY M. Kramaric, Radiation Specialist
      $V A
      '' 'date
'
  ]l.tuA wad $lh.>    E Ji 6 M. ftH ie  4diation Specialist  'date Approved by:  'N L4 ~
bgTciak, Chief d [
        /dat6 W.J(dadiologicalProtectionSection BWR
    '
Inspection Summary:  ,
Inspection on July 29 - August 1, 1985'(Report No. 50-219/85-25)
/ Areas Inspected: Routine, unannounced safety inspection of transportation
, activities including: managemenV controls, training, quality assurance, audits, package selection, shipment of radioactive materials, and low-level
, radioactive waste storage facilit '
Results: One violation was identified:  Failbr'e to conduct a quality control program paragraph i; a
w 8509160407 850911 PDR ADOCK 05000219 G  PDR
      ' >
.
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  ,


  /
Your cooperation with us is appreciated.
-


- , . . . . - . .-- - - -  .. -- - - - -_ -_._- _ _  . -_
Sincerely,
          ,
~
I
    ~
r ido151rre??7~
    '
    '
  #
  '
h .as) . Mar n, irect Ok Division of Radiation fety and Safeguards cc:
M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey C
G 0FFICIAL RECORD COPY RL OYC 85-25 - 0001.0.0 '
04/24/86 -
  .


  .
  .
DETAILS
,
1.0 Persons Contacted a
'
1.1 Licensee Personnel
!  *P. Fiedler,  Vice President and Director, Oyster Creek
.
  * Sullivan Jr. ,  Plant Operations Director
;  * Turner,  Radiological Controls Director
'
  * Fenti,  Quality Assurance (QA) Mod / Ops Manager, Oyster Creek
  * Fuller,  Ops QA Manager
  * Markowski,  QA Program Development / Audit Manager, GPUN
  * Simonetti Jr. , Audit Manager, Oyster Creek
-
  ,
  ,
  *T. Snider, Radwaste Operations Manager
GPU Nuclear Corporation 2 bcc:
  "A. Wacha,  Radwaste Shipping Supervisor
Region I Docket Room (with concurrences)
!  R. Hurley, Group Radwaste Shipping Supervisor B. Schlotens, QA Lead Monitor      t W. Spoulos,  Group Radwaste Packaging Supervisor
Management Assistant, DRMA Section Chief, DRP R SS RI S RI:DRSS MMiller/ms PascFak Bellamy 4/21/86 4/$b/86 f/ \ /86 0FFICIAL RECORD COPY RL OYC 85-25 - 0002.0.0 04/24/86 I
[  *P. Czaya,  Licensing Engineer j  *B. Hohman,  Licensing Engineer i  1.2 Vendor Personnel j  M. O' Kelly,  Waste Management Inc.
 
'
1.3 NRC Personnel
;
4   *B. Bateman,  Senior Resident Inspector
!  * denotes attendance at the exit interview on August 1, 1985.
 
2.0 Purpose The purpose of this routine inspection was to review the licensee's    .
transportation activities with respect to the following elements:    !
          '
  --
Management Control
  --
Training
  --
Quality Assurance
 
'
  --
Audits
  --
Solid Radioactive Waste System and Processing
  --
Package Selection
  --
Shipment of Radioactive Materials      !
  --
Low-Level Radioactive Waste Storage Facility Status      l
          ,


   - 3.0 Management Control
_   . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______ _______ . -_
;  -
- .
i The responsibility for the administration, technical' direction and imple-    !
,. .
mentation of the licensee's Process Control Program (PCP) for liquid and solid radioactive waste and for shipment of radioactive material is the
. .-
          ,
          ;
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          .
s
 
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_ . . _ .  . . _ _ . _ _ _ ___ _ _ _ _ ._ _ .
  .
  .
'
OPU Nuclear Corporstkm
 
,
d function of the Radwaste Operations Manager. Overall responsibility for radioactive waste management resides with the Plant Operations Director,    ,
,
who reports to the Vice President and Director of Oyster Cree ,
,            t
;
l  The licensee had documented the management control for radioactive waste      :
management in Procedure 101, Revision 15, " Organization and Responsi-      i
'
,
bility." The inspector discussed with the Radwaste Operations Manager      7 and Radwaste Shipping Supervisor the responsibilities and authorities of
;  the individuals designated in the Radwaste Operations organization char !  The inspector noted that vendor support was being used for operations and    .
monitoring of the solidification process, and for classification and char-acterization of radioactive wast All of these activities were governed by procedures which specify methods    ;
,
for handling, processing, sampling, and shipment of radioactive wast '
'
For example, Procedure 101.3, Revision 12, " Shipment of Radioactive      t l  Material" described the requirements for radioactive material and radio-      l active waste shipments. This procedure also detailed the responsibilities    '
of the Radwaste Shipping Supervisor and the responsibilities of other sup-
,
port grou i
            .
Within the scope of this review, no violations were identifie ,
            ,
4.0 Training Personnel training in transportation activities was reviewed against the    i i  criteria contained in IE Bulletin 79-19, " Packaging of Low-Level Radio-t active Waste for Transport and Burial."        .
t i  The licensee's performance relative to this criteria was determined by      l discussions with the Radwaste Operations Manager, Radwaste Shipping      !
Supervisor and other supervisory personnel, and by review of training
,  documentatio :
;  Within the scope of this review no violations were identified. However,
{  the following concern was identified:        ,
  *
On September 24, 1979, in response to Item 5 of IE Bulletin 79-19,    ;
the licensee stated that training and periodic retraining in the DOT    '
and NRC regulatory requirements was being provided to the health    >
i  physics personnel. The inspector discussed with the-licensee, that    !
I  since a new organization was now performing the radwaste packaging    i and shipment function, the licensee's training commitments should be    i
*
revised to define the current training and retraining program. The    '
inspector also noted that during 1984 no formalized training was    i provided to licensee personnel responsible for radioactive waste /    i
;  material shipment. Another letter, clarifying the intent of the    j
            #
i f
i          ,
F
,
A            i
            ,
  . ~ - - , - . - , , ,-i--& w. . e- - . , _ - , ,=,,.,..,y , 3 , ,,w,, ,w- ,c_,erw-.---,,--- ,wp--,,r,-,.- -y
 
_ . . _ - _ _ _ _ _ _ _ _ . .- ._ - ._ ._ _ _ t
-
        !
.-
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        !
t i
licensee's response to IE Bulletin 79-19, should be submitted to the Regional Administrator in the near future. This item will be
'        j reviewed during a subsequent inspection (219/85-25-01).
 
i 5.0 Quality Assurance Program    "
        {
i  The implementation of the licensee's Quality Assurance Program (QAP) for
  .
  .
'
NggIg{      Post Office Box 388 Route 9 South Forked River, New Jetsey 08731-0388 l
transport packages was reviewed against the criteria contained in 10 CFR 71, "Subpart H - Quality Assurance," and 10 CFR 50, Appendix B.
609 971 4000 Writer's Direct Dial Number:
April 10, 1986 Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406


;  The licensee's performance relative to this criteria was determined from  !
==Dear Dr. Marley:==
j  discussions with the QA Mod / Operations Manager, QA Operations Manager,
Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 85-25 dated September 11, 1985 As suggested by the subject inspection report, Attachment I of this letter updates our September 24, 1979 response to I&E Bulletin 79-19,
'
  " Packaging of Low-Level Radioactive Waste for Transport and Burial".
        !
the QA Operations Lead Monitor, and from review of the QA Mod / Operations  j Monitoring Program, Revision 5, and.the QA monitoring reports for 1985  l l  with regard to radioactive waste processing and shipment [
Within the scope of this review, the following violation was identified: f I
        !
{  *
10 CFR 20.311(d)(3), " Transfer. for disposal and manifests" requires  !
1  .a licensee who transfers radioactive waste.to a land disposal facil- !
l  ity to conduct a quality control program to assure compliance with  !
l  -10 CFR 61.55 and 10 CFR 61.5 !
i
!
The licensee has transferred several radioactive waste shipments to  'I a land disposal facility during 1984 and 1985 and the licensee has  !
not conducted a quality control program to assure compliance with 10  [
CFR 61.55 and 10 CFR 61.56, inasmuch as the licensee has not verified  t that spent resin contained less than 1*4 liquid by volume when the !
resin was in a disposal container (high integrity container) designed  j to ensure stability; and neither did the licensee verify that the  ;
:  solidification process was as effective as described in the Topical  !
1  Repor In addition, the licensee QA inspection program did not  i 1  verify that the computer program used in waste classification per-  'i j  formed the required functions,   t
        !
[  Failure to conduct a quality control program to assure compliance  !
.
*
with 10 CFR 61.55 and-10 CFR 61.56 represents a violation of 10 CFR  ,
20.311(d)(3) (219/85-25-02).     -
        (
Within the scope of this review, the following concern requiring  !


licensee attention was also identified:    i
As you are aware, since our original response to I&E Bulletin 79-19, an organizational change altered the department responsible for the radwaste packaging and shipping functions. Previously the responsibility was under the direction and control of the Radiation Protection Department. The present shipping organization is under the control and direction of the Manager of Radwaste Operations. Thus, the commitment to I&E Bulletin 79-19 Item 5 is being revised to reflect current training programs. We understand that this item will be reviewed during a subsequent inspection.
        !
        >
  *
The licensee had identified all structures, systems and compon-


        ;
Should you require any further information, please contact Brenda Honman, Oyster Creek Licensing Engineer at (609)917-4642.
ents to.be covered by the quality assurance program on a docu--  .!
ment designated as a Q List. However, transport packages wer '
not included on this list. Rather, 10 CFR 71 was listed as an  ;
.,  area fnr which the quality Contml Pmgram would be applied. The  !
'
licensee stated that the-Q List was being revised and only owner  .
        ,
'
        ;


1        ?
Very truly yours, P
        ;
Yice President and Director Oyster Creek PBF/BH/ dam (0103A)
*
Attacnment cc: Mr. Jack N. Donohew, Jr.
_ , __  __ _ . _ . _ _ _._ _ _ __ _ . . . - __ _


  - -- _ - _ - -- -. - - - . - - . . - . - - - -- - -. -
* U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue, Phillips Bldg.


  *
Bethesda, MD 20014      ,N,r&j~1 ~3<n/ D ''
  ;
Mail Stop No. 314 NRC Resident Inspector 0/ ster Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
  .
  .
*
  - _ _ _ _ _ _ _ _ _ - _ _ _ _ - _
 
r ATTACHMENT I
  .
  .
* -
. .-
'  Revised Response to NRC 16E Bulletin 79-19 i
Item 1 Maintain a current set of DOT and NRC regulations concerning the transfer, packaging, and t ransport of low-level radioactive waste material .
Response A current set of Department of Transportation (49 CFR) and Nuclear Regulatory Commission (10 CFR) regulations concerning the transfer, packaging, and transport of low-level radioactive waste material is maintained at the Oyster Creek Station in the Radwaste Shipping Department.


.
Item 2 Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee. If a waste collection contractor is used, obtain the appropriate requi rement s from the contractor.
}.
equipment and components would be on the Q List. Therefore,  ,
transport packages, as well as other non-owner equipment would  i be addressed by QAP procedures or an appropriate vendor lis The inspector stated implementation of the QAP process will be reviewed during a subsequent inspection (219/85-25-03).    ,
6.0 Audits
;
i  The adequacy and affectiveness of the licensee's audit program for trans-    ,
port packages were reviewed against the criteria contained in Criterion    ;
XVIII of Appendix B,10 CFR 50, and with respect to Technical Specifi-    l j  cation 6.5.3.5, " Audits."


!  The licensee's performance relative to these criteria was determined by l  review cf Audit S-0C-84-14, "Radwaste Shipping and Operations," dated
Response A current set of requirements (license) placed on the burial site operators by their respective states are maintained on site in the Radwaste Shipping Department.
;  August 8 through October 8,1984 and discussions with the Audit Manager


and QA Program Development / Audit Manager. The qualifications of the j  auditor were reviewed relative to ANSI N45.2, " Quality Assurance Program
Items 3 Designate, in writing, people in your organization who are responsible for the safe transfer, packaging, and transport of low-level radioactive material.
'
Requirements for Nuclear Facilities."


!
Response Personnel in the Oyster Creek Station organization who are responsible for the safe transfer, packaging, and transport of the low-level radioactive material and those personnel qualified and authorized to sign shipping papers for transportation of radioactive waste have been designated in writing.


Within the scope of this review, no violations were identified. However, the following concern was identified:
,. .-
  '
  . .-
          !
,
   =
Revised Response to NRC I6E   Page 2
The Audit System Plan addressed the 10 CFR 50 Appendix B criteria
-
!  for transport packages. However, the focus of the Radwaste Audit S-0C-84-14 was to determine the adequacy of procedure compliance.
Bulletin 79-19 Item 4 Provide management-approved, detailed inst ructions and operat ing procedures to all personnel involved in the transfer, packaging, and transport of low-level radioacti ve mat erial . Special attention should be given to controls on the chemical and physical fom of the low-level radioactive material and on the containment integrity of the packaging..
Response Management-approved operating procedures which are used in operations and in the transfer, packaging, and transport of radioactive material are provided.


;  The inspector noted that performance against the other designated    ;
Item 5 Provide training and periodic retraining in the DOT and NRC regulatory requi rements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging, and t ransport of radioactive material . Maintain a record of t raining dates, attendees, and subject material for future inspections by NRC personnel.
10 CFR 50, Appendix B criteria was marginally evaluated. The    i
,   licensee stated that subsequent audits would ensure Radwaste Shipping
'
activities would be audited against the applicable criteria. This    ;
;
area will be reviewed during a future inspection (219/85-25-04).    :
i j  7.0 Selection of Packages l
The licensee's program for selection of packages was examined against the   ;
requirements of 10 CFR 71.87 and within the framework of the DOT require-    i ments of 49 CFR Part 17 ;
For dry radioactive waste, the licensee used steel boxes or strong tight    !
containers. Radioactive material shipments requiring the use of an NRC   ;
Certified package (outer ccatainer) were made predominantly in. vendor    l supplied containers.


]  Within the scope of this review, the following issues were identified:    I l
Response Training and periodic retraining in the DOT and NRC regulatory requirements are presently provided to Radwaste Operators, Rad Con Technicians, Station Services, and Radwaste Shipping Supervisors.


  *
The present Operations t raining program provides training and retraining on minimizing radioactive waste by those processes which
The inspector observed an NRC approved package (Certificate of Compli-  i ance (C of C 9094) labeled as model 14-195 and 00T-7A. The C of C    i i
> generate wastes. A training program is administered for radwaste facility operators which covers Radwaste Operations including transfer, packaging, and shipping of radioactive material in the DOT, NRC, and waste burial requirements thereto. Personnel packaging DAW are bargaining unit personnel who are trained in the operations of the packaging as well as transfer and storage procedures. They are under the direct supervision of the Radwaste Shipping Supervisors who are training in all applicable regulatory criteria.
specifies Model number 14-195 as an approved package. However, the    l 00T-7A. labeling is not permitted by C of C 9094, because it implies  l l  NRC approva ;
i          i
!          [
t
'          i,
          >
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  .. - . .- _ - - .  - .-  . - ... . ~ _ . -  .- -
Item 6 Provide t raining and periodic ret raini ng to Radwaste Operators who operate the processes which generate waste to assure that the volume
  '             i
, of low-level radioactive waste is minimized and that such waste is
: .
'
; e*
processed into acceptable chemical and physical fom for transfer and shipment to a low-level radioactive waste burial facility.


6
l I
;
:  * The inspector noted that the licensee had made radioactive waste i  shipment in an approved package (Certificate of Compliance 9079),
!  but was shipped as package model 14-170. Model 14-170 currently
!  is not approved by C of C 9079.


The licensee stated they would discuss these labeling conflicts with their vendor. The inspector stated these issues would be considered unresolved (219/85-25-05).
r- .
.
,.
. .-
,
Revised Response to NRC I6E  Page 3
* Bulletin 79-19 Response See response to Item 5.


!
Item '
'
Establish and implement a management-controlled andit function of all transfer, packaging, and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory recuirements.
Except as noted above, copies of the Certificate.of Compliance, including the drawings were available for all Type A and Type B l  Casks in us .0 Shipment of Licensed Material for Disposal or Use The transportation of licensed material was reviewed against the criteria contained in 10 CFR 71, " Packaging and Transportation of Radioactive
,
Material," 10 CFR 20.311(d)(3), " Transfer for disposal and manifests," and 10 CFR 61.55, " Waste Classification," and 10 CFR 61.56, " Waste Character-      1 istics."


!
Response A management-controlled audit function for the transfer, packaging, and transport of radioactive materials has been established and has been implemented. This function is provided by the Quality Assurance Department through the QA program development and audit sections.
The licensee's performance relative to these criteria was determined by
;  the following:
j  *
discussion with the Radwaste Shipping Supervisor and his staff;
!
;  *
  - review of shipping manifests and related documents; and
:
;
  *
review of selected program procedures including the following:
!
  *
101.3, Revision 12, " Shipment of Radioactive Materials."


  *
Item 8 Perform, within 60 days of the date of this bulletin, a management-controlled audit of your activities associated with the t ransfer, packaging, and transport of low-level radioactive waste.
351.2, Revision 3, " Absorbing of Low-Level Radioactive Waste Oil for Off-Site Disposal."
:
'
  *
351.37, Revision 1, "Radwaste Processing of Solids and Liquid to the CNSI Cement Solidification System."


i
Maintain a record of all audits for future inspections by NRC or DOT inspections. (Note: If you have an established audit function arx!
  *
have performed such an audit of all activities in items 1-6 within the past six months, this audit requirement is satisfied.)
352.0, Revision 4, " Processing Resins at the large Container l    Filling Station Into a CNSI Enviro Safe High Integrity
!
Container."


t I  Within the scope of this review, no violations were identified.
Response A management controlled audit of Radwaste Operations was conducted on March 7, 1979 (Audit No. 79-04) and have been conducted on an annual basis since the issuance of the 16E bulletin. In addition to annual audits conducted by the QC QA site audit section, routine inspections / monitoring of regular waste shipments are conducted by Operations QA monitors.


l
' .
.
,s- .
..
.
Revised Response to NPC I6E  Page 4
*
Bulletin 79-19 Item 9 Provide answers for 1978 and for the first six months of 1979 to the following questions:
1. How many low-level radioactive waste shipments did you make?
What was the volume of low-level radioactive waste shipped?
  (Power reactor licensees who _ report this information in accordance with Technical Specifications do not need to respond to this question.)


9.0 Low-Level Radioactive Waste Storage Facility
2. What was the quantity (curies) of low-level radioactive waste shipped? What were the major isotopes in the low-level radioactive waste?
)^
  (Power reactor licensees who report this information in accordance with Technical Specifications do not need to respond to this question.)
The licensee has started construction of a Low-Level Radioactive Waste Storage Facility at the Oyster Creek Site. Projected completion is March


1986. The licensee estimated that 50% has' been completed as of July 31, 198 The Safety Evaluation Report is currently in draft.
3. Did you generate liquid low-level radioactive waste? If the answer is "yes", what process was used to solidify the liquid waste?
Response 1. Reported in Semiannual Reports for the years since 1978,
  " Radioactive Effluent Releases."


i
2. Same as No. I above.
!
I i
.
~,-e- ,-a .w--n- ,a --
  -r--- --+ - --,n-8-- -- , , - - . - , - , , - ,.-a-na+er,--n-r--, ,.----.m,--,-----..-~ -.
          -w ,~~ w,.r.,,- .. , nw - .w m n. , ,


.-
3. Liauld low-level radioactive waste is generated. A process using line and cement is presently used to solidify filter sludge and evaporator bottoms.
*
.


10.0 Exit The inspector met with the Itcensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on August 1, 1985. The inspector summarized the scope of the inspection and finding _
1950W/4
}}
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Latest revision as of 07:18, 7 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-219/85-25. Corrective Actions Will Be Examined During Future Insp
ML20204A376
Person / Time
Site: Oyster Creek
Issue date: 05/01/1986
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8605120139
Download: ML20204A376 (2)
v • d • e


Text

.

.

MAY n 11986 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, NJ 08731 Gentlemen:

Subject: Inspection No. 85-25 We acknowledge receipt of your letter dated April 10, 1986, in response to our letter dated September 11, 1985.

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 your licensed program.

Your cooperation with us is appreciated.

Sincerely,

~

~

r ido151rre??7~

'

'

'

h .as) . Mar n, irect Ok Division of Radiation fety and Safeguards cc:

M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey C

G 0FFICIAL RECORD COPY RL OYC 85-25 - 0001.0.0 '

04/24/86 -

.

.

,

GPU Nuclear Corporation 2 bcc:

Region I Docket Room (with concurrences)

Management Assistant, DRMA Section Chief, DRP R SS RI S RI:DRSS MMiller/ms PascFak Bellamy 4/21/86 4/$b/86 f/ \ /86 0FFICIAL RECORD COPY RL OYC 85-25 - 0002.0.0 04/24/86 I

_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _______ _______ . -_

- .

,. .

. .-

.

OPU Nuclear Corporstkm

.

NggIg{ Post Office Box 388 Route 9 South Forked River, New Jetsey 08731-0388 l

609 971 4000 Writer's Direct Dial Number:

April 10, 1986 Dr. Thomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Marley:

Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 IE Inspection 85-25 dated September 11, 1985 As suggested by the subject inspection report, Attachment I of this letter updates our September 24, 1979 response to I&E Bulletin 79-19,

" Packaging of Low-Level Radioactive Waste for Transport and Burial".

As you are aware, since our original response to I&E Bulletin 79-19, an organizational change altered the department responsible for the radwaste packaging and shipping functions. Previously the responsibility was under the direction and control of the Radiation Protection Department. The present shipping organization is under the control and direction of the Manager of Radwaste Operations. Thus, the commitment to I&E Bulletin 79-19 Item 5 is being revised to reflect current training programs. We understand that this item will be reviewed during a subsequent inspection.

Should you require any further information, please contact Brenda Honman, Oyster Creek Licensing Engineer at (609)917-4642.

Very truly yours, P

Yice President and Director Oyster Creek PBF/BH/ dam (0103A)

Attacnment cc: Mr. Jack N. Donohew, Jr.

  • U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue, Phillips Bldg.

Bethesda, MD 20014 ,N,r&j~1 ~3<n/ D

Mail Stop No. 314 NRC Resident Inspector 0/ ster Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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r ATTACHMENT I

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' Revised Response to NRC 16E Bulletin 79-19 i

Item 1 Maintain a current set of DOT and NRC regulations concerning the transfer, packaging, and t ransport of low-level radioactive waste material .

Response A current set of Department of Transportation (49 CFR) and Nuclear Regulatory Commission (10 CFR) regulations concerning the transfer, packaging, and transport of low-level radioactive waste material is maintained at the Oyster Creek Station in the Radwaste Shipping Department.

Item 2 Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee. If a waste collection contractor is used, obtain the appropriate requi rement s from the contractor.

Response A current set of requirements (license) placed on the burial site operators by their respective states are maintained on site in the Radwaste Shipping Department.

Items 3 Designate, in writing, people in your organization who are responsible for the safe transfer, packaging, and transport of low-level radioactive material.

Response Personnel in the Oyster Creek Station organization who are responsible for the safe transfer, packaging, and transport of the low-level radioactive material and those personnel qualified and authorized to sign shipping papers for transportation of radioactive waste have been designated in writing.

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Revised Response to NRC I6E Page 2

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Bulletin 79-19 Item 4 Provide management-approved, detailed inst ructions and operat ing procedures to all personnel involved in the transfer, packaging, and transport of low-level radioacti ve mat erial . Special attention should be given to controls on the chemical and physical fom of the low-level radioactive material and on the containment integrity of the packaging..

Response Management-approved operating procedures which are used in operations and in the transfer, packaging, and transport of radioactive material are provided.

Item 5 Provide training and periodic retraining in the DOT and NRC regulatory requi rements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging, and t ransport of radioactive material . Maintain a record of t raining dates, attendees, and subject material for future inspections by NRC personnel.

Response Training and periodic retraining in the DOT and NRC regulatory requirements are presently provided to Radwaste Operators, Rad Con Technicians, Station Services, and Radwaste Shipping Supervisors.

The present Operations t raining program provides training and retraining on minimizing radioactive waste by those processes which

> generate wastes. A training program is administered for radwaste facility operators which covers Radwaste Operations including transfer, packaging, and shipping of radioactive material in the DOT, NRC, and waste burial requirements thereto. Personnel packaging DAW are bargaining unit personnel who are trained in the operations of the packaging as well as transfer and storage procedures. They are under the direct supervision of the Radwaste Shipping Supervisors who are training in all applicable regulatory criteria.

Item 6 Provide t raining and periodic ret raini ng to Radwaste Operators who operate the processes which generate waste to assure that the volume

, of low-level radioactive waste is minimized and that such waste is

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processed into acceptable chemical and physical fom for transfer and shipment to a low-level radioactive waste burial facility.

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Revised Response to NRC I6E Page 3

Item '

Establish and implement a management-controlled andit function of all transfer, packaging, and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory recuirements.

Response A management-controlled audit function for the transfer, packaging, and transport of radioactive materials has been established and has been implemented. This function is provided by the Quality Assurance Department through the QA program development and audit sections.

Item 8 Perform, within 60 days of the date of this bulletin, a management-controlled audit of your activities associated with the t ransfer, packaging, and transport of low-level radioactive waste.

Maintain a record of all audits for future inspections by NRC or DOT inspections. (Note: If you have an established audit function arx!

have performed such an audit of all activities in items 1-6 within the past six months, this audit requirement is satisfied.)

Response A management controlled audit of Radwaste Operations was conducted on March 7, 1979 (Audit No. 79-04) and have been conducted on an annual basis since the issuance of the 16E bulletin. In addition to annual audits conducted by the QC QA site audit section, routine inspections / monitoring of regular waste shipments are conducted by Operations QA monitors.

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Revised Response to NPC I6E Page 4

Bulletin 79-19 Item 9 Provide answers for 1978 and for the first six months of 1979 to the following questions:

1. How many low-level radioactive waste shipments did you make?

What was the volume of low-level radioactive waste shipped?

(Power reactor licensees who _ report this information in accordance with Technical Specifications do not need to respond to this question.)

2. What was the quantity (curies) of low-level radioactive waste shipped? What were the major isotopes in the low-level radioactive waste?

(Power reactor licensees who report this information in accordance with Technical Specifications do not need to respond to this question.)

3. Did you generate liquid low-level radioactive waste? If the answer is "yes", what process was used to solidify the liquid waste?

Response 1. Reported in Semiannual Reports for the years since 1978,

" Radioactive Effluent Releases."

2. Same as No. I above.

3. Liauld low-level radioactive waste is generated. A process using line and cement is presently used to solidify filter sludge and evaporator bottoms.

1950W/4

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