ML17219A555

Responds to Violations Noted in Insp Rept 50-335/87-04 & 50-389/87-04.Corrective Actions:Vendor Onsite Solidification Stopped & Health Physics Procedure HP-40, Shipping of Radioactive Matl, Will Be Revised

ML17219A555
Person / Time
Site:	Saint Lucie
Issue date:	04/27/1987
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
L-87-189, NUDOCS 8705060002
Download: ML17219A555 (8)

See also: IR 05000335/1987004

Text

q I~ccesssow wsa: FAC IL: 50-335 50-38~Au TH.NAME~~DYI C.O.0 CIP.NAWE RE('ULATORY

INFORMATION

DISTRIBUTION.SYSTEN (RIDS)8705060002

DOC.DATE: 87/04/27 NOTARIZED:

NO St.Lucie Plant>Unit ii Florida Potoer Sc Light Co.St.Lucie Plant>Unit 2i Florida Power h Light Co.AUTHOR AFFILIATION

Florida Power 5 Light Co.RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000335 05000389 SUBJECT: Responds to violations

noted in Insp Rept 50-335/87-04

0 50-389'/87-04.

Corrective

actions: vendor onsite solidification

stopped 8r Health Physics Procedure HP-40'Shipping

of Radiactive

Natl'" vill be revised DISTRIBUTION

CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE: TITLE: Qeneral (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: RECIP IENT ID CODE/NANE PD2-2 LA TOUR IQNYi E INTERNAL: AEOD ENF LIEBERNAN NRR/DOEA DIR NRR/DREP/RPB

NRR AN&'B RE('l R FILE 01 EXTERNAL.LPDR NSIC COP IES LTTR ENCL 0 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NANE PD2-2 PD DEDRO NRR ROE>N.L NRR/DREP/EPB

NRR/DRIS DIR OQC/HDS2 RES SPEISi T NRC PDR COP IES LTTR ENCL 1 TOTAL NUMBER OF COPIES REQUIRED'TTR

20 ENCL 19

P.O.BOX 14000.JUNO BEACH, F L 3340B FLORIDA POWER&LIGHT COMPANY IPRlu a7 Igsr L7-I 89 IO CFR 2.20I U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Gentlemen:

Re'.St.Lucie Units I and 2 Docket Nos.50-335 and 50-389 Ins ection Re ort 335/87-04 and 389/87-04 Florida Power 8 Light Company has reviewed the subject inspection

report, and pursuant to the provisions

of 10 CFR 2.20l the response is attached.There is no proprietary

information

in the report.Very truly yours, C.O.W Group e President Nuc I ear Energy COW/GR M/gp Attachment

cc: Dr.J.Nelson Grace, Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, St.Lucie Plant 87050b0002

810427 PDR ADOCK 05000335 9~g,O I i GRM5/P46/I

PEOPLE.~.SERVING PEOPLE

Page I of 4 VIOLATION A(l)A.10 CFR 20.311(d)(l)

requires any generating

licensee who transfers radioactive

waste to a land disposal facility to prepare all wastes so'that the waste is classified

according to 10 CFR 61.55 and meets the waste characteristic

requirements

in 10 CFR 61.56.10 CFR 61.56(b)(l)

states that waste must have structural

stability which will generally maintain its physical dimensions

and its form under expected disposal conditions.

10 CFR 61.56(b)(2)

states that in no case shall the liquid exceed one (I)percent of the volume of the w'aste when the waste is in a disposal container designed to ensure stability, or 0.5 percent of the volume of the waste for waste processed to a stable form.10 CFR 20.311(d)(3)

states that any generating

licensee who transfers radioactive

material to a land disposal facility shall conduct a quality control program to assure compliance

with 10 CFR 61.55 and 61.56 which must include management

evaluation

of audits.Contrary to the above, the licensee failed to adequately

prepare radioactive

waste for disposal as follows: I)The requirements

for structural

stability and minimum volume of liquid in waste were not met in that, on November 24, 1986, Radioactive

Waste Shipment No.86-61 consisting

of sludge solidified

with cement, packaged in two steel liners was improperly

solidified

in that approximately

fifteen percent of the contents of one liner had failed to solidify while the entire contents of the second liner were paste-like

in consistency.

RESPONSE TO VIOLATION A(l)A.I.FPL agrees that the two liners in Radioactive

Waste Shipment No.86-61 were not properly solidified.

FPL does not agree that the requirement

for minimum volume of liquid in waste was not met.The tests conducted by South Carolina Department

of Health and Environmental

Control (SCDHEC), FPL, and Chem Nuclear indicated the criteria for minimum volume of liquids (0.5%)had been met.2.Analysis of the material in the liners indicated that proper solidification

did not take place due to: a)Insufficient

mixing of waste and process chemicals.

b)Generation

of ammonia (due to the waste form)which inhibited solidification.

, GRM3/25/I

Page 2 of 4 3.The liners were returned to St.Lucie, cut open, and the unsolidified

material was removed and reprocessed

and re-packaged.Solidification

was verified by manual soundings (tapping)on the liner and random core boring.The liners were subsequently

transported

to the burial site, re-tested by the SCDHEC, found to be acceptable

and buried.The remaining"solidified" liners containing

the same material were subjected to the same on-site testing.One liner was found to be suspect.The vendor received permission

to ship the liner to his site for further testing and analysis from SCDHEC.When the liner was cut open at the vendor's site, it was found to be a solidified

free-standing

monolith.Subsequently, the liner was re-sealed and buried.The remaining liners containing

this material were also tested successfully

and buried.4.Vendor on-site solidification

has been stopped.No further solidification

will take place until changes take place in the Process Control Program to give assurance of full compliance.

5.Compliance (with respect to the problem material)was achieved by April 7, I987.VIOLATION A(2)2.The licensee's

quality control program to assure appropriate

characterization

of waste was inadequate

in that it contained no requirements

for licensee evaluation

and/or verification

of vendor activities

and as a consequence, on November 24, l986, the contents of the two steel liners described above were not solid as required.RESPONSE TO VIOLATION A(2)I.FPL concurs with the violation.

2.FPL improperly

assumed that the vendor's quality program concurrent

with the process verification

assured an acceptable

product.3.On-site solidification

processes were terminated.

4.Prior to solidification

taking place on-site, FPL will have controls in place which will provide reasonable

assurance that the solidification

is'complete prior to shipment.5.Full compliance

will be achieved prior to on-site solidification

of radioactive

waste for shipment.GR M3/25/2

L

Page 3 of 4 VIOLATION B B.IO CRF 7I.5(a)requires each licensee who transports

licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the applicable

requirements

of the regulations

appropriate

to the mode of transport to the DOT in 49 CFR Parts l70 through I 89.49 CFR I73.475(i)

states that before each shipment of any radioactive

materials package, the shipper shall ensure by examination

or appropriate

tests that external radiation and contamination

levels are within allowable limits.Contrary to the above, the licensee failed to comply with the requirements

of the DOT in that no surveys of the underside of the transport vehicles were performed for radioactive

material shipments:

No.86-46 on September 23, l986;No.86-47 on October 2, l986;No.86-49 on October 9, l986, No.86-52 on October l4, 1986, No.86-53 on October 2 I, I 986;and No.86-54 on October 23, 1986.RESPONSE TO VIOLATION B I.FPL concurs with the violation on the basis that documented

evidence was not available to indicate the underside radiation surveys were performed for these shipments.

However, FPL believes that surveys were performed to insure compliance

with shipping requirements

of the transport vehicle.Additional

surveys taken by the State of Florida, prior to the shipment leaving the site, verified that the radiation limits including the underside of the transfer vehicle were within specification.

2.The cause for the finding was that survey documents did not provide a location for recording dose rates from the underside of the transport vehicle.3.Vehicle survey sheet (HPS-65.l, 2, 3,&4)will be changed to provide for recording dose rates from the underside of the transport vehicles.Appropriate

dose rates were recorded on subsequent

shipments.

4.Health Physics Procedure HP-00, Shipping of Radioactive

Material, will be revised to require recording of dose rates from the underside of the transport vehicle.5.Full compliance

was achieved April I, l987.Procedure changes will be incorporated

by May 30, I 987.GRM3/25/3

Page 4 of 4 VIOLATION C C.10 CFR 20.203(f)(l)

states that, except as provided by IO CFR 20.203(f)(3), licensed material shall bear a durable, clearly visible label identifying

the radioactive

contents.Contrary to the above, containers

of licensed material were not properly labeled in that, on March 3, l987, 28 B-25 metal boxes located in a temporary storage area behind Unit 2 and l2 B-25 metal boxes located adjacent to the Steam Generator Blowdown Treatment Facility did not bear durable, visible labels identifying

the radioactive

contents.The exemptions

of I 0 CFR 20.203(f)(3)

did not apply.FPL RESPONSE TO VIOLATION C I.FPL concurs with the violation.

2.The boxes in question were staged for transportation.

FPL plant procedures

for compacting

waste did not address any additional

labeling requirements.

This oversight was the cause for the finding.3.All packages were properly posted prior to the completion

of the inspection.

4.Health Physics procedures

for waste packaging will be revised to require"RADIOACTIVE

MATERIAL" tagging of all Dry Active Waste (DAW)packages being staged for subsequent

disposal.5.Full compliance

was achieved by March 4, l987.Procedures

will be revised by May 30, l987.GR M3/25/4