ML20138N608

Responds to NRC 850911 Ltr Re Violations Noted in Insp Rept 50-320/85-15.Corrective Actions:Temporary Change Notice to Procedure 4214-ADM-4450.01 Implemented Requiring Separate Waste Classification for Each Nonroutine Waste Package

ML20138N608
Person / Time
Site:	Three Mile Island
Issue date:	10/10/1985
From:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
0337A, 337-A, 337A, 4410-85-L-0203, 4410-85-L-203, NUDOCS 8511050252
Download: ML20138N608 (4)

Text

,. .

Gr GPU Nuclear Corporation Nuclear a::,ome:r8os Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

(717) 948-8461 4410-85-L-0203 Docurnent ID 0337A October 10, 1985 Office of Inspection and Enforcement Attn: Dr. T. E. Murley Regional Administrator US Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Inspection Report 85-15 Inspection Report 85-15 dated Septemoer 11, 1985, identified one (1) item of non-compliance. Attacned is the GPU Nuclear response to that citation.

Sincerely,

}

p ^: ,

F. R. Standerfer Vice President / Director, TMI-2 FRS/CJD/eml Attachment cc: Program Director - TMI Program Office, Dr. B. J. Snyder Deputy Program Director - TMI Program Orfice, Dr. W. D. Travers 8511050252 851010 PDR ADOCK 05000320 G PDR GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation }

l jg o/

F ATTACHMENT 1 (4410-85-L-0203)

STATEbENT OF VIOLATION 10 CFR 20.311 requires that any generating licensee who transfers radioactive waste to a licensed land disposal facility prepare all wastes so that the waste is classified according to 10 CFR 61.55.

10 CFR 61.55 allows radioactive wastes containing less than 0.04 curies per cubic meter (C1/m3) strontium-90 (Sr-90) to be classified as Class A waste if requirements for other radionuclides are also met; Dut if tne concentration of Sr-90 exceeds 0.04 Ci/m3 and is less than 150 Ci/m3, the waste is required to be classified as Class B, i,f the requirements for other radionuclides are met.

Contrary to the above, on July 18, 1985, three barrels transferred for disposal in Waste Shipment RS-85-063-II did not meet these requiremen.ts in that three packages, numbered 84-D-II-538, 85-D-II-028, and 85-0-11-030, were classified and packaged as Class A, rather than Class B when they contained concentrations of Sr-90 at 0.052 Ci/m3, 0.059 Ci/m3 and 0.047 Ci/m3 respectively.

This is a Severity Level III Violation (Supplement V).

GPU NUCLEAR RESPONSE GPU Nuclear incorrectly classified three (3) drums in a shipment to the State of Wasnington for disposal. This misclassification was due to an incorrect interpretation of the isotopic content of the drums and a failure to recognize that these particular drums required a different metnod to verify their waste classification due to their Sr-90 concentrations.

As a result of this misclassification, the Washington State Department of Health suspended GPU Nuclear Site Use Permit No. 4580 on August 6, 1985.

In response to the above action, GPU Nuclear letter 4000-85-S-334 dated August 9,1985, notified the State of Washington of the cause of this event, the immediate corrective actions taken, and a request that the burial license be reinstated.

The immediate corrective actions taken included a Temporary Change Notice (TCN) to TMI-2 Procedure 4214-ADM-4450.01, "TMI-2 Radioactive Material Shipment Portfolio Presentation". This TCN was implemented on July 30, 1985. The procedure modification JJnproved the quality control program by requiring a separate waste classification determination of each package that is not within a normal waste stream category.

Additionally, a TCN to TMI Unit Procedure 1501-ADM-4450.01, " Packaging of Radioactive Waste for Disposal at a Commercial Disposal Facility", was implemented on August 9, 1985. This procedure modification improved the quality control program by requiring the use of a Calculation / Curie Estimate Request Form when requesting a curie estimate. This form requires notification when there is a difference between packing methodology /assunptions and calculation methodology / assumptions.

ATTACHIENT 1 (4410-65-L-UZO3) dased on the above corrective actions, the State of Washington reinstated GPU Nuclear's burial privileges on August 16, 1985. This reinstatement was contingent upon the amendment of Procedure 4214-ADM-4450.01, to incorporate the three items of clarification listed in Attachment 2. A TCN to Procedure 4214-ADM-4450.01 incorporated these tnree items of clarification. The TCN was implemented on October 4,1985.

On August 21, 1985, the State of Washington issued a one-time variance to U.S. Ecology to dispose of the three misclassified radioactive waste drums received from GPU Nuclear. The drums were subsequently disposed on August 26, 1985.

1 The long-term corrective actions will include the following:

o A Procedure Change Request (PCR) to 1501-ADM-4450.01 has been submitted to permanently incorporate the corrective actions identified in the TCN dated August 9,1985. This PCR is expected to be approved by Novenber 1, 1985.

o A PCR to 4214-ADM /:450.01 was submitted to permanently incorporate the corrective actions identified in the TCN dated July 30, 1985.

This PCR was jmplemented on September 3,1985.

o A PCR will be submitted to further revise Procedure 4214-ADM-4450.01. This revision will permanently incorporate the three items of clarification identified in the TCN dated Octouer 4, 1985. This PCR is expected to De approved by Decemoer 31, 1985.

GPU Nuclear will be in full compliance once the above discussed PCR's are implemented. Tne expected date for this is December 31, 1985.

J i

y y. , - ._, ,, ..-+ - - - - - , - , , + , - , . - , ~ , - , - . .-----,.--~,w,, -r-3 -+--vv+~ - - - - - - - e-- e,---v ,--w--'e-v-r - = ev--e v-- ~ - e --- -

4 ATTACHMENT 2 (4410-85-L-0203)

ITEMS OF CLARIFICATION  !

f GPLN Procedure 4214-ADM-4450.01 Revision 5, Page 3, Section 3.4.2; i

1. Use the NRC definition of A2 found in 10 CFR 71.4 which does not refer to LSA material as does the Department of Transportation definition in 3 49 CFR 173.403.

GPUN Procedure 4214-ADM-4450.01 Revision 5, Page E4-2, Section 4.1.12:

2. The exemption or variance is for EPICOR Il resin liners as requested in the original GPU Nuclear letter to State of Washington Department of Social and Health Services dated 26 October 1983, GPU Nuclear reference i 4410-83-L-0259.

, GPUN Procedure 4214-ADM-4450.01 Revision 5, Page E4-2, Section 4.1.12.1:

3. References to the msxhnum allowed concentration of Sr-90 as 1 C1/m3 should be amended. For this purpose, 1 C1/m3 is the value assigned for

. Sr-90 in Table 2, column 1 of 10 CFR 61.56 and is to be used as such when 1 applying the sum of f'ractions rule. It does not mean 1 C1/m3 of Sr-90 i regardless of other or additional radionuclides present in the package.

i i

r l

2 1

i

, - , - , - ,,--,..,n., , - - ~ , + ~ - .,,,.,,,,--,,,-n-,--n,,-,..,,.,,,,- . - , , , - - ,. ,n ,, ,.,- -.,- ,- -,- ,,n---,- - , + - -