DCL-87-121, Forwards Addl Info Re Application for State of Nv Site User Permit for Beatty,Nv Low Level Waste Disposal Site, Including Clarification Re Util Radwaste Processing, Indemnification Agreement & Procedures

Forwards Addl Info Re Application for State of Nv Site User Permit for Beatty,Nv Low Level Waste Disposal Site, Including Clarification Re Util Radwaste Processing, Indemnification Agreement & Procedures

ML20214Q232
Person / Time
Site:	Diablo Canyon
Issue date:	05/28/1987
From:	Shiffer J PACIFIC GAS & ELECTRIC CO.
To:	Marshall S NEVADA, STATE OF
Shared Package
ML16341E263	List: DCL-87-121, Forwards Addl Info Re Application for State of Nv Site User Permit for Beatty,Nv Low Level Waste Disposal Site, Including Clarification Re Util Radwaste Processing, Indemnification Agreement & Procedures
References
DCL-87-121, NUDOCS 8706040305
Download: ML20214Q232 (9)

Text

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May 28, 1987 m /.*E"'.5.S.'.., c PGandE Letter No.: DCL-87-121 Mr. Stan Marshall State of Nevada Department of Human Resources

[p + pfI Radiological Health Section 505 East King Street, Room 202 Carson City, NV 89710 Re: Application for a Nevada Department of Human Resources (DHR) " Site User" Permit, Beatty, Nevada Low Level Haste Disposal Site

Dear Mr. Marshall:

Enclosed for your review and approval is the additional information you requested in your letter to J. D. Shiffer dated August 11, 1986, responding to Pacific Gas and Electric Company's (PGandE) permit application submitted to you on July 18, 1986. The enclosure consists of the following:

1. Additional information/ clarification concerning PGandE radwaste processing

2. Indeminification Agreement (2 copies)

3. DCPP Procedures, Radiological Control Procedure (RCP) RH-1, RCP RH-4, RCP RW-5, and RCP RW-7 Based on information supplied by you in a phone conversation on May 15, 1987, PGandE understands that the fee for a " Site User" Permit was revised to

$3,396.00 on March 9, 1987. Since PGandE submitted $3,126.00 with its permit application dated July 18, 1986, the balance of $270.00 for this permit is attached.

PGandE intends to ship LLH to Beatty at the end of DCPP Unit 2 current refur 'g outage (July 1987). Your review and approval of the referenced appi tion would be appreciated.

If you need further information, please call Thomas de Uriarte at (415) 768-3057.

h Sincerely, ,k Enclosure L i

cc: L. J. Chandler B. Norton l[g g(D

,V Y J. B. Martin M. M. Mendonca C. M. Trammell.'

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1378S/0050K/BJB/138 .

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r PGandE Letter No.: DCL-87-121 ENCLOSURE The following additional information/ clarification concerning Pacific Gas and Electric Company (PGandE) procedures for processing and packaging radwaste at its Diablo Canyon Power Plant (DCPP) is being provided in response to Mr. Stan Marshall's information request' dated August 11, 1986.

DHR CONCERN:

1. Your letter and the application for a license submitted July 18, 1986, did not contain an agreement to indemnify the State of Nevada as required by Nevada Administrative Code (NAC) 459.870. Enclosed is sample language for the indemnification statement. The indemnification statement should include the language concerning the third-party inspection until the review is completed of your waiver request.

PGandE CLARIFICATION:

Attachment 1 is an indemnification agreement signed by an authorized PGandE officer. Although the enclosed indemnification agreement includes language concerning a third-party inspection service, PGandE believes that the additional documentation provided in this letter to support its third party inspection waiver application will make use of this service unnecessary.

DHR CONCERN:

2. Review of NPAP D-10, Quality Control Program for Shipment of Radioactive Haste to Land Disposal Facilities, revealed that Paragraph 5.0 References did not include a reference to the Beatty Facility Radioactive Material License issued by the State of Nevada to U.S. Ecology.

NPAP D-506 Radioactive Waste Shipment in Sections 4.2.5 a.1 and 4.2.7 d.1 Indicates that liquid radioactive waste may be shipped. You should be aware the receipt of waste containing liquids is prohibited by conditions of the license for the Beatty site.

Further, Section 4.2.5 a.4 indicated a package cannot contain more than 15 grams of U-235 and Section 4.2.9 a.1 states a fissile exempt quantity is not more than 15 grams of fissile radionuclides in a package, however, there is no requirement in the procedures that the total quantity of fissile radionuclides or special nuclear material in a shipment of radioactive waste cannot exceed a critical mass. A condition of the site license requires that only subtritical quantities of SNM may be received.

Section 4.2.9.2b states that the maximum mass of fissile radionuclides in a package is 500 grams. In addition to exceeding the subcritical cmount of SNH set by license condition, this quantity also exceeds the amount of SNM allowed in one package as specified in the license for the site.

1378S/0050K .

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You should refer to the license for the Beatty site in NPAP D-10, and inform personnel of the restriction in the conditions of the license so that unacceptable waste will not be shipped to Beatty.

PGandE CLARIFICATION:

Diablo Canyon Power Plant utilizes a number of plant-specific procedures for preparation packaging, and shipment of wastes for disposal at licensed burial sites. Included in, but not limited to these procedures are RCP RH-1, RCP RN-4, RCP RN-5, and RCP RN-7. These procedures include appropriate references to the Beatty Facility Radioactive Material License issued by the State of Nevada to U.S. Ecology.

NPAP D-10 is a corporate office non-plant specific procedure which will be revised to reflect current waste management practices at PGandE nuclear plants.

RCP RH-7, Paragraph 1(d) specifically states that "all waste forms must meet free standing liquid criteria. .Only-dry solid, solidified or absorbed waste are acceptable." The paragraph and subsequent ones further discuss processing requirements to ensure that the resulting waste form meets the federal, state, and burial sites (including Beatty) requirements.

RCP RN-7 Paragraph 1(c) states that "Only subcritical quantities of special nuclear material are acceptable (at the burial site)." Generally, the following criteria will be used in determining subcriticality:

a. Each accumulation of packages shall not contain more than 350 grams of Uranium 235, or 200 grams of Uranium 233 or combinations thereof such that the sum of the ratios of the quantity of each special nuclear material to the quantities specified herein does not exceed unity, as determined by the following formula:

l Grams Contained U235 , Grams Contained U233 < 1 350 200 l

j b. No single package shall contain more than 100 grams of Uranium 235

or 60 grams of Uranium 233 or any combination thereof such that the sum of the ratios of the quantity of each special nuclear material

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i to the quantities specified herein does not exceed unity, as determined by the following formula.

Grams Contained U235 , Grams Contained U233 < 1 l 100 60

c. No single package shall contain more than 15 grams of any combined Uranium 235 and Uranium 233 per cubic foot of total volume.

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! 1378S/0050K a

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RCP RH-4 Paragraph 4(g) discusses the' nature of documentation that must accompany shipments containing special nuclear material.

DHR CONCERN:

3. It appears that QC approval for container inspection . loading of containers and closing of containers only applies to shipments of radioactive materials in licensed containers as described in Section 4.2.8 of NPAP D-506. Missing from the. procedures is a requirement.that all containers for shipping radioactivs waste will be visually inspected before use for manufacturing defects of damages from handling during delivery. '

Please advise regarding the rationale for not having QC inspections of all radioactive waste packaging and of containers after packaging and of the loading of containers on the transport vehicle.

PGandE CLARIFICATION:

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RCP RH-1 contains a solid radioactive waste package inventory form. This form includes a waste container quality checklist used by radwaste handlers for evaluating container integrity prior to packaging, during packaging and closure, and prior to shipment of radwaste. '

DHR CONCERN:

4. The procedures appear to provide for labeling of packages of radioactive waste only in accordance with DOT regulations. He found no provision'for determining whether the waste was Class A, B, or C for applying labels to containers specifying Class A, B, or C waste as required in 10 CFR 61 and NAC 459.825, and 459.827 through 459.829.

Please address the labeling requirements of the additional applicable regulations.

PGandE CLARIFICATION:

A section of RCP RH-7, which was not included in the initial application discusses classification of radwaste. Please refer to attached RCP RH-1 and RN-7 for radwaste labeling and classification requirements and RCP RN-5 for verification at DCPP. All radioactive waste packages leaving DCPP. are classified and labeled appropriately in conformance with Department of Transportation (DOT) and Nuclear Regulatory Commission (NRC) requirements.

DHR CONCERN:

5. The radioactive material shipment record form enclosed with the QA procedures is not adequate for shipment of radioactive waste. It does not include columns for recording volume of packages, agent used in 1378S/0050K _.- - - -- - --. -- - - - .

solidification,' percent of chelating agents in waste, classification of waste as Class A, B, or Class C and the total quantity of_the radionuclides, H-3, C-14, Tc-99, and I-129.

F He suggest that you contact the Beatty site operator, U.S. Ecology, (702) 553-2203.

'PGandE CLARIFICATION:

The radioactive material shipment record form enclosed with the Quality Assurance (QA) procedures is not a plant-specific form for shipment of radioactive waste. Attachment I of RCP RN-4 is a radioactive waste shipment and disposal manifest form for shipment of radwaste from DCPP. This form includes columns for recording volume of packages, agent used in solidification, percent of chelating agents in waste, classification of waste as Class A, B, or Class C and the total quantity of the radionuclides, H-3, C-14 Tc-99, and I-129.

DHR CONCERN:

6. There was no statement in the procedures that carriers must receive a certificate from the Nevada Public Service Commission, (702) 885-4117,.

and notify the Nevada Highway Patrol before entering Nevada. These requirements are the responsibility of the carrier but we believe that PGandE in its role as overseer of the contract should include this information_ for the benefit of QC inspectors.

PGandE CLARIFICATION:

RCP RW-4 Paragraph 3(a) states the advance notification requirements for shipment of radwaste to the Beatty facility. These requirements include (1) certifying that the carrier has a certificate from Nevada Public Service Commission to transport radwaste, (2) ensuring that the carrier's route avoid Clark County, and (3) certifying that the carrier notifies the Nevada Highway Patrol prior to entering Nevada.

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i 1378S/0050K . - - - . . . - , - - . . . _ . - . . . - , . . - . . . - . - . . . . - - . . _ , _ . - . _.-

ATTACHMENT 1 INDEMNIFICATION AGREEMENT (2 Copies) 1378S/0050K

INDEMNIFICATION AGREEMENT Pacific Gas and Electric Company hereby covenants to the State of Nevada and agrees hereby to comply with the following conditions in consideration of the issuance of a Permit to ship radioactive waste to the Beatty, Nevada disposal site:

1. Contract with Nevada Inspection Services, Inc., to carry out the functions of the third party inspection system and to pay for such services directly to Nevada Inspection Services, Inc.; and

2. Indemnify and hold the Health Division of the Department of Human Resources and the State of Nevada harmless for any liability or consequential damages arising from out of the transportation of any radioactive material or waste to the Beatty site regardless of any prior inspection by Nevada Inspection Services, Inc.; and

3. Comply with all Federal and State Regulations relating to the transportation of radioactive waste. This company understands that an Nevada Inspection Services, Inc., inspection is not a guarantee of suitability for shipment and the ultimate responsibility for compliance with Federal and State Regulations and safe transportation is upon this company (or institution).

s Date ' / 'b JafneVD. Shiffer nc( President -

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Nuclear Power Generation Pacific Gas and Electric Company 1378S/0050K

INDEMNIFICATION AGREEMENT Pacific Gas and Electric Company hereby covenants to the State of Nevada and agrees hereby to comply with the following conditions in consideration of the issuance of a Permit to ship radioactive waste to the Beatty, Nevada disposal site:

1. Contract with Nevada Inspection Services, Inc., to carry out the functions of the third party inspection system and to pay for such services directly to Nevada Inspection Services, Inc.; and

2. Indemnify and hold the Health Division of the Department of Human Resources and the State of Nevada harmless for any liability or consequential damages arising from out of the transportation of any radioactive material or waste to the Beatty site regardless of any prior inspection by Nevada Inspection Services, Inc.; and

3. Comply with all Federal and State Regulations relating to the transportation of radioactive waste. This company understands that an Nevada Inspection Services, Inc., inspection is not a guarantee of suitability for shipment and the ultimate responsibility for compliance with Federal and State Regulations and safe transportation is upon this company (or institution).

Date N, 7 Japfes 6. Shiffer vin President - "[

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Nuclear Power Generation Pacific Gas and Electric Company 1378S/0050K

ATTACHHENT 2 DCPP RADIOLOGICAL CONTROL PROCEDURES (RCP)

• RCP RW-1 " Collection, Packaging, Storage, and Accountability of Radioactive Haste," Revision 4

• RCP RH-4 " Solid Radioactive Haste Shipment," Revision 4

• RCP RH-5 " Receiving, Loading, and Releasing of Transport Vehicle for Radioactive Haste Shipment," Revision 1 e RCP RH-7 " Burial Site Disposal Criteria and Classification of Radwaste," Revision 2 1378S/0050K