IR 05000423/1985056

Safety Insp Rept 50-423/85-56 on 850930-1004.No Violation Noted.Major Areas Inspected:Preoperational Status of Solid Radwaste Sys & NUREG-0737 Task Items

ML20134A062
Person / Time
Site:	Millstone
Issue date:	10/29/1985
From:	Cioffi J, Shanbaky M, Jason White NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20134A061	List: IR 05000423/1985056 ML20134A059
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-423-85-56, NUDOCS 8511040130
Download: ML20134A062 (17)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N , , Docket N License N CPPR-113 Priority -

Category C Licensee: Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Generating Station, Unit 3 Inspection 4t: Waterford, Connecticut Inspection Conducted: September 30 - October 4, 1985 Inspectors: [ /d & N J. R. White, Senior Rac/'ation Specialist /date

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~.A.Cioffi,Radiat/6nSpecialist J

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Approved by: W. G4 Id M. M. Shanbaky, Chief f WR Radiation

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Safety Section Inspection Summary:

Inspection on September 30 - October 4, 1985 (Report No. 50-423/85-56)

Areas Inspected: Routine, unannounced safety inspection to review the status of previously identified items, the preoperational status of the solid radio-active waste system and the task items identified in NUREG-0737; i.e., the capability for sampling and analyzing reactor coolant and containment atmosphere in post-accident conditions. The inspection involved 74 hours8.564815e-4 days <br />0.0206 hours <br />1.223545e-4 weeks <br />2.8157e-5 months <br /> onsite by two region-based inspector Results: Within the areas inspected, no violations were identifie ,

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DETAILS 1.0 Personnel Contacted D. Burglund, Vice President, Alaron Corporation

• J. Crockett, Millstone Unit 3 Superintendent,~NNECO F. DiLiberto, Engineer, SWEC R. Enoch, Instrument and Control Group Leader, NNECO

• R. Gavensky, Radwaste QC, NNECO

• J. Kangley, Radwaste Services Supervisor, NNEC0 J. Kelly, Senior _ Quality Assurance Engineer, SWEC

• J. LaWare, Engineering Technologist, NUSCO CQA 8. Loweth, Start-up Engineer, NNECO

• D. Miller, Start-up Manager, NNECO D. Moore, Operations Assistant, NNECO

• L. Nadeau, Assistant Project Engineer, NUSCO S. Orefice, Project Engineer, NUSCO

• V. Papadopoli, Supervisor, CQA, NUSCO F. Perry, Health Physics, NNECO

• W. Rose, NNECO QC .

• R. Sachetello, Health Physics, NNECO D. Scase, Start-up Engineer, NNECO

• A. Stengel, Start-up Engineer, NNEC0 R. Stotts, Operator Training Supervisor, NUSCO

• S. Turowski, ALARA Coordinator, NNEC0 J. Waggoner, Training Instructor, HP, NUSCO

• Denotes attendance at the exit meeting.

l 2.0 Purpose The purpose of.this inspection was to review the preoperational status of the solid radioactive waste system, and of the post-accident sampling capability for containment air and reactor coolant, identified in NUREG-0737. Additional effort was expended to determine the status of previously identified items and IE bulletins and circular .0 Status of Previously Identified Items 3.1 (Closed) Circular (76-CI-16). Excessive Radiography Exposures. This

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' circular pertained to holders of radiography licenses. No action was

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required by this applicant.

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3.2 (Closed) Circular (80-CI-25). Radiography Events. This circular pertained to holders of radiography licenses. No action was required by this applicant.

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3.3 (0 pen) Circular (76-CC-03) Radiation Exposure in Reactor Cavitie Details appear in'parigraph 4.0 of this repor .4 (0 pen) Bulletin (78-BU-08). Radiation Levels from Fuel Element Transfer Tubes. A calculation of expected radiation levels during spent fuel transfer was performed by the Architect / Engineer for the applicant, indicating that significant radiation levels were expected f

based on the shielding design provided in the area between the. fuel building and the containment wall. The walkway area adjacent to the Fuel Building / Containment Building interface is scheduled to be equipped with a lock and controlled as an " extreme high" radiation area. This item remains open pending completion of the installation of locked gates in this area and the institution of appropriate aoministrative control .5 (Closed) Circular (81-CI-07). Control of Radioactively Contaminated Material. The licensee established station procedure SHP-4917,

" Unconditional Radiological Release of Material Off-site", to address the concerns raised in this circular. The procedure defines the acceptance criteria that must be met for release of material as non-radioactive, and describes acceptable detection methods and equipment sensitivity to meet the acceptance criteri This item is considered

' close .6 (0 pen) Inspector Follow-Up (85-19-01) Status of RMS Installation and Operability. Attachment I describes the status of installation and operability of the Kaman Radiation Monitoring System as of October 3, 1985. Applicant representatives stated that successful completion of Phase I testing of the RMS is expected to be achieved prior to fuel load. This item will remain open pending successful completion of Phase I testing of the monitors required by the Technical Specification .7 (0 pen) Inspector Follow-up (85-19-02). Status of RMS. procedure development. Attachment 2 describes the status of the development of procedures for the RMS. The applicant stated that approximately 50% of the procedures have been approved by the Plant Operations Review Committee (PORC), with the other 50% in process of review as of October 3,1985. This item will remain open pending approval of the remaining procedure .8 (0 pen) Inspector Follow-up (85-19-03). Training for health physics personnel in RMS operation. A cognizant I&C individual conducted an informal briefing of the RMS system for Health Physics personnel. A formal training program on the RMS system is under current develop-ment with the Training Department, the cognizant I&C individual, and Computer Services to provide classroom training on the RMS system to

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Health Physics personnel at Unit 3. This item will remain open pending successful completion of formal training for the Health Physics personnel, i

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3.9 (0 pen) Inspection Follow-up (85-19-04). Status of the start-up sur-vey procedure. The applicant stated that the procedure for start-up survey is 98% complete. The final form of the procedure and PORC review remain. This item will remain open pending completion of the procedures and review by NR .10 (Closed) Inspection Follow-up (85-19-05). Establish requalification training for HP personnel. The inspector reviewed the 1985 requali-fication course for all station health physics technicians. The three-day course provided detailed instructions for I&E bulletins, circulars, and information notices of interest, current industry event releases, instrumentation, and radiobiological effects of radiation among other general Health Physics topics. Technicians were required to pass an examination with a grade of at least 80%.

This item is considered close .11 (Closed) Inspector Follow-up (85-19-06). Supplies of alpha rate meters per FSAR commitments. The applicant amended Table 12.5-1 of the FSAR to correct the numbers and type of equipment available to Unit 3 and the entire Millstone site. Additionally, the description of supplies on pages 12.5-3 was amended to better reflect the status of equipment for Unit 3. The changes appeared.in Amendment 15, September 1985, to the FSAR. This item is considered close .12 (Closed) Inspector Follow-up (85-19-07). Supplies of Pocket Ion Chambers (PICS) per FSAR commitments. Amendment 15, September 1985, has been submitted by the applicant to correct the numbers of PICS available to the Millstone site and Unit 3 as stated in Table 12.5-1 and 2. This item is considered close .13 (Closed) Inspector Follow-up (85-19-08). Decision to be made by applicant on use of space and facilities for Unit 3 Health Physics technical support. The applicant stated that the Units 1 and 2 Radiation Protection support facilities will be used for Unit 3 as wel These services include dosimetry issue, whole body counting, respiratory protection fit-test and issue, instrument calibrations and the decontamination facilitie This item is considered close .0 Status of High Radiation Area Control and Radiation Exposure in Reactor Cavities The inspector toured areas of containment with the applicant and discussed the areas which would be controlled as high radiation areas. The appli-cant identified all areas of potential high radiation dose rates and the provisions to install locked gates to prevent access to those area The applicant planned to install barriers around all entries into areas of potential radiation dos If these areas prove to be of insignificant radiation hazard during plant operation, the barriers will not be locke _ --

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The inspector discussed control of high radiation areas with the applicant. A station procedure will be implemented, Procedure ACP 7.04, Revision 0, " Station Lock and Key Control," to control access to the keys for "high" radiation and " extreme high" radiation areas. Additionally, Operations and Health Physics personnel are currently working together to develop a specific Unit 3 procedure to control the moveable incore detec-tors (MIDS), stressing health physics concurrence and oversight when such activities take plac The inspector discussed training of Health Physics technicians on the previous industry exposures incurred with the moveable incore detectors (MIDS). The Health Physics Supervisor circulated a document acknowledgment sheet (DAS) with a package of material containing a description of Unit 3's MID system and additional NRC IE circulars and notices which discussed previous industry experience of overexposures with this plant system. All Unit 3 health physics technicians signed the DAS. Additionally, the training department covered the Reactor Cavity overexposures in detail during the 1985 Health Physics technician requalification training to ensure that all health physics technicians at the Millstone Station were aware of the past history of problems with the MIDS and reactor cavity entrie The inspector discussed the training of operations personnel on the exposure of personnel during MID activities and entry ir,to reactor cavities. The applicant representative stated that all operations person-nel were instructed on potential exposures during their Health Physics training, but that no specific issue was made of the industry experience of overexposures during MID activities and reactor cavity entrie Circular 76-03 will remain open pending final development and approval of the operations procedure for the MIDS a1d reactor cavity entries and more detailed instruction of operations personnel on pa;t industry experience with this plant syste .0 Post-Accident Sampling System The applicant has installed a General Dynamics designed post-accident sampling system (PASS) to support accident sampling requirements pursuant to NUREG-0737, Item II.B.3. Testing of'the system is currently being performed in accordance with T3311C, " Post-Accident Analysis Sampling."

In view of engineering design control and construction deficiencies pre-viously identified in this area relative to other Northeast Utilities nuclear operating units, the applicant appears to have developed a com-prehensive test program to verify and validate that the PASS will perform as intended. An Emergency Operating Procedure currently exists for the PASS but will'be modified as necessary to be commensurate wit' the oper-ating parameters and characteristics determined from the preo rational test progra .

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While no in-depth review was performed of this system, it was noted that the ventilation fan incorporated in the sampling module to exhaust poten-

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tially contaminated air from the module during operation, was running in

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the PASS, a comprehensive inspection to validate PASS performance will be

' conducted, including corrective measures relative to the items identified during this effor (50-423/85-56-01)

6.0 Radioactive Waste Solidification System The applicant's radioactive waste solidification system was reviewed against descriptions and documentation identified in Attachment III to this repor The FSAR and SER issued in'1984 describe a waste solidification process that is different than the method and equipment configuration actually intended by the applican Amendment,8 to the FSAR, dated 1984, describes spent resin dewatering and liquid waste solidification processes that were eliminated from serious consideration in 1982. Reference is made to Figure 11.4-1 which was derived from the Stone and Webster Drawing No. 12179-EM-1108-2A. This drawing depicts a system which is described in the FSAR as able to solidify waste such as evaporator concentrates by connecting a portable solidifi-cation system to the installed binder transfer line, promoter and catalyst components which simultaneously blend the process chemicals into the shipping containe Though such a binder system has been constructed as part of the solidt-fication system, the applicant does not intend to use or maintain the system, and essentially retired the components in place in 1982. Instead, solidification of evaporator concentrates is expected to be performed by a conventional cement process which has not yet been described in the FSAR or any documentation submitted to the NRC relative to the license appli-cation. The latest SER supplement dated July 1984 still references the intent to use the original solidification proces Additionally, on May 16, 1985, during the preoperational Phase I test program, it was identified that the installed spent resin dewatering system was incapable of dewatering to an acceptable level for shipment to a disposal sit Several Design Deficiency Reports were fiied in this period which indicated that certain key components such as the Evaporator Forwarding Pump,'P4, and Spent Resin Dewatering Pump, P1, were unable to function as intended by design. As a result, these components were removed from service and efforts were made to determine if the components

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were essential to the dewatering process. The Test Procedure T3338-P was developed to support this effort but relied on vendor supplied equipment, i.e., NUPAC, for actual dewatering. To this end, t,e Phase 2 preopera-tional tests were conducted in an effort to demonstrate that the P4 and P1 pumps were not necessary, and that the NUPAC supplied portable dewater-ing system could be applied successfully. Such test performance, however, '

required major modification of the FSAR described system by physically removing the P4 and P1 pumps and the associated interlocks, reconfigu-ration of piping systems, and the application of the NUPAC procedure OM-38 which actually effect dewatering. Though such system modification was implemented by August 1985, and an FSAR change initiated internally, no information or notice of the change was ever made available for NRC review in preparation for licensing. At the time of this inspection, an FSAR change had yet to be processe In response to this finding, the applicant indicated that action would be initiated to update the FSAR relative to actual system configuration and processes for waste solidification and resin dewatering. This item will be reviewed in a subsequent inspectio (50-423/85-56-02)

During this inspection effort, Phase 2 testing of the system was observe While some equipment and performance deficiencies were noted, the test demonstrated that the modified system installation, in conjunction with vendor supplied portable equipment, was able to accomplish dewatering satisfactoril However, the tested configuration did not provide for ventilation of the fill head during resin loading, and verification that the vacuum exhaust from the NUPAC equipment could be satisfactorily handled by the plant's vent system. Additionally, the vendor procedure for dewatering, OM-38, did not provide sufficient prerequisites to assure that all alarms and system interlocks were functioning, nor did the pro-cedure provide adequate instruction relative to alarm respons The applicant initiated action to resolve these deficiencies by perform-ance of system modifications as necessary for venting the fill head, arranging for verification of the ability of the vent system to accommo-date the exhaust from the NUPAC system, the revision of procedure OM-38 to address prerequisites that verify system readiness (including interlocks and alarms), and the incorporation of alarm response procedures into the body of OM-38. These actions will be reviewed in a subsequent inspection (50-42385-56-03).

As part of the test program, resin dewatering was verified by removing the resin from the High Integrity Container (HIC) to qualify the presence of free-standing water. The results demonstrated that the process effectively eliminated any free-standing water. While some saturated resin remained in the bottom 2 inches of the HIC, it was apparent that the dewatering criteria of not more than 0.5% of the resin volume could be me :

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Review of the Radioactive Waste Operating Procedures, which are currently implemented for Units 1 and 2, indicated that certain of the procedures will require modification or the development of additional procedures in order to reflect actual dewatering and solidification activities intended for Unit 3. ' For example, the ~ procedures currently refer to a solidif f-cation method different than the cementing process intended for Unit This item will be reviewed in a subsequent inspection. (50-423/85-56-04)

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l 7. Exit Interview l

The inspector met with applicant representatives (denoted in Section 1)

on October 4, 1985. The inspector summarized the purpose, scope, and findings of the inspection. At no time during this inspection was written i material;provided to the applicant by the inspector.

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ATTACHMENT I RADIATION MONITORING SYSTEM STATUS-Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Ventilation / Gas Monitors-3HVRRE10A/B* 3-4 weeks before testing

.3HVRRE19A/B* 3-4 weeks before testing 3HVRRE11A/B X X X-3HVRRE12A/B X X X 3HVRRE13A/B X X X 3HVRRE14A/B X X X 3HVRRE15A/B' X X X 3HVRRE16A/B X- X X 3HVRRE17A/B X X X 3HVRRE18A/B X X X 3HVCRE91A/B X X X 3CMSRE22A/B* X X .X 3HVZRE09A/B* X X X Temporary mounting plates installed. "Unsat" -

monitor A is reading 3 decades hig l 3HVQRE49A/B X X X 3HVCRE16A/B* X X X

• Category IE Monitors .

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ATTACHMENT I - Page 2 RADIATION MONITORING SYSTEM STATUS Instrumentt Turned Field Communications Number (Mark No.) Over Tested Loop Established C_omments Liquid Process Monitors 3CHSRE69 X X X Setpoints must be establishe CCPRE31 X X X 3CNARE47 X X X-30ASRE50

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X X X 3LWSRE70 X- X X Skid mounted equipment test incomplet LWCRE65 X X X Skid mounted equipment test incomplet CNDRE07 X X X 3SSRRE08 X X X 35WPRE60A/B*- X X X 3GWSRE48 X X X 3ARCRE21 X X X "Unsat," Noise proble HSSRE75 X X X Communications problem '3MSSRE76 X X X Connector failed, to be-replace MSSRE77 X X X 3MSSRE78 X X X

3MSSRE79 .s X X X

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ATTACHMENT I - Page 3 RADIATION MONITORING SYSTEM STATUS Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Area Monitors

'3RMSRE16 X X X Switch to be replace RMSRE17 X X X 3RMSRE18- X X X

.3RMSRE19 X X X 3RMSRE20 X X X

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3RMSRE21 X X X 3RMSRE22 X X X Temporary fix, part on orde RMSRE24 X X X 3RMSRE25 X X X 3RMSRE28 X X X 3RMSRE29 X X X 3RMSRE31 X X X 3RMSRE32 X X X 3RMSRE33 X X X Missing par RMSRE34 X X X 3RMSRE35 X X X 3RMSRE36 X X X 3RMSRE37 X X X 3RMSRE04* X X X Detector and cable not installe RMSRE05* X X X Detector and cable not installe RMSRE41* X X X Detector and cable not installe RMSRE42* X X X Detector and cable not installe RMSRE01 X X X 3RMSRE02 ( X X-3RMSRE03 ( X X 3RMSRE06 X X X 3RMSRE07 X X X 3RMSRE08 X X X 3RMSRE09 X X X 3RMSRE10 X X X

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ATTACHMENT I - Page 4

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RADIATION MONITORING SYSTEM STATUS Instrument Turned Field Communications Number (Mark No.) Over Tested Loop Established Comments Area Monitors 3RMSRE11 X X X 3RMSRE12 X X X 3RMSRE13 X X X 3RMSRE14 X X X 3RMSRE15 X X X 3RMSRE38 X X X 3RMSRE52 X X X

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ATTACHMENT II RMS SURVEILLANCE PROCEDURE SUMMARY Procedure Number Monitor Identification Status / Comment 3449801 3HVR-RE19A/B SLCRS Part/ Gas Cal. Pro Draft 3450F01 3CND-RE07 Waste Neut. Sump Rad. Monitor Ca PORC approved, Rev. 0 3450J01 3LWC-RE65 Regen. Evap. Rad. Monitor Ca PORC approved, Rev. 0 3450K01- 3SSR-RE08 S/G Blowdown Rad. Monitor Ca PORC approved, Rev. 0

,3449J01 3HVQ-RE49 ESF Part & Gas Rad. Monitor Ca Draft 344'JH01 3RMS-RE04/05 Cont. HR Inter. 51'4" CTMT. Ca Pro Draft 3449G01 3HVC-RE16A/B Control Bldg. Inlet. Cal. Pro Draft 3449A11 3HVR-RE10A/B Vent Part/ Gas 66'6" Aux. Bld Oper. Test Draft 3449811 3HVR-RE19A/B SLCRS Part/ Gas Oper. Test Draft 3449D11 35WP-RE60A/B Cont. Recirc. Cool Outlet Ope Test Cancelled 3449E11 3RMS-RE41/42 Fuel Orop Monitor 51'4" Ope Test Draft 3449G11 3HVC-RE16A/B Control Bldg. Inlet Oper. Test PORC approved, Rev 0 3449H11 3RMS-L '05 Cont. HR Inter. 51'4" CTM Oper. test PORC approved, Rev. 0 3450F11 3CND-RE07 Waste Neut. Sump Rad. Monitor Ope Test PORC approved, Rev 0 3450G11 30AS-RE50 Turb. Weldg. Floor Drains Ra Monitor Oper. Test . PORC approved, Rev. 0 3450H11 3LWS-RE70 Liquid Waste Rad. Monitor Ope Test PORC approved, Rev. 0 3450J11 3LWC-RE65 Regen. Evap. Rad. Monitor Ope Test PORC approved, Rev. 0 3450K11 3SSR-RE08 S/G Blowdown Rad. Monitor Ope Test Draft 3449A01 3HVR-RE10A/B Vent Part/ Gas 66'6" Aux. Bld Cal. Pro Draft 3449C01 3 CMS-RE22A/B CTMT Atmos. Part/ Gas Cal. Pro Oraft 3449C11 3 CMS-RE22A/B CTMT Atmos. Part/ Gas Oper. Test Draft 3449001 3SWP-RE60A/B TM Recirc. Cool Outlet Ca Pro Cancelled 3449E01 3RMS-RE41/42 Fuel Orop Monitor 51'4" Ca Pro Draft 3449E21- Fuel Pool Storage Criticality Monitor PORC approved, Rev. 1 3449E31 Fuel Pool Storage Crit. Monitor Oper. Test PORC approved, Rev. 0 3449F01 3HVZ-RE09A/B Recom. Cub. A/B Exh. 7'6" Ca Pro Cancelled 3449F11 3HVZ-RE09A/B Recom. Cub. A/B Exh. 7'6" Ope Test Cancelled

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ATTACHMENT II - Page 2 RMS SURVEILLANCE PROCEDURE SUMMARY Procedure Number Monitor Identification Status / Comment 3449J11 3HVQ-RE49 ESF Part & Gas Rad. Monitor Ope Test Draft 3450001 3 MSS-RE75, 76, 77, 78 Main Stm. Rel. Line A-D Cal. Pro Draft 3450011 3 MSS-RE75, 76, 77, 78 Main Stm. Rel . Line A-D Oper. Test PORC approved, Rev. 0 3450E01 3 MMS-RE79 Turb. Drv. Aux. Fdw. Pump Dsch. Ca Pro Draft 3450E11 3 MMS-RE79 Turb. Drv. Aux. Fdw. Pump Dsc Oper. Test PORC approved, Rev. 0 3450G01 3DAS-RE50 Turb. Bldg. Floor Drains Ra Monitor Ca PORC approved, Rev. 0 3450H01 3LWS-RE70 Liquid Waste Rad. Monitor Ca PORC approved, Rev. O

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ATTACHMENT III RMS GENERIC PROCEDURE SUMMARY I&C Gineric Procedure Monitor No. (GPIC) N Identification Status / Comment

,20.01 3490B01 Kaman Science (KMG-HRN) Radiation Monitor Approved,* Rev. 0 20.02- 3490B02 Kaman Science (KMG-HRH) Radiation Monitor Draft 20.03- 3490B03 Kaman Science (KMPG) Radiation Monitor Approved,* Rev. 0

.20.04 3490B04 Kaman Science (KML) Radiation Monitor Approved,* Rev. 1 20.05 3490B05 Kaman Science (KMG) Radiation Monitor Draft 20.06 3490B06 Kaman Science Hydrogen Vent Monitor Draft 20.07 3490B07 Kaman Science Hydrogen Recombiner Monitor Deleted 20.08 3490B08 Kaman Science (KMA-HR) Radiation Monitor Approved,* Rev. 0 20.09 3490809 Kaman Science (KMA-MR) Radiation Monitor Deleted 20.10 3490816 Kaman Science'(KMA) Radiation Monitor Approved,* Rev. 0 20.11 3490811 Kaman Science Fuel Failure Monitor In Review 20.12 3490812 Kaman Science Service Water Effluent Monitor In Review 20.13 ECl-4 Eberline Radiation Monitor In Development

• Approval of these procedures is by the I&C Department Supervisor and the Startup Manage I

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Radioactive Waste Operating Procedures Number Title Re Date RW 6001/26001/36001 Waste Classification Implementation Program 1 8/1/85 RW 6002/26002/36002 Determination of the Waste Classification for Radioactive Waste Offered for Shallow Land Burial 3 .10/1/85 RW 6003/26003/36003 Radioactive Materials Shipping Compliance 1 8'1/85 RW 6004/26004/36004 Shipment of Radwastes 2 8/1/85 RW 6005/26005/36005 General Radioactive Materials Shipment 1 8/1/85 RW 6006/26006/36006 Receipt of Radioactive

,' Material 1 5/31/85 RW 6007/26007/36007 Container Control and Accountability 1 8/1/85 RW 6008/26008/36008 Drum Compacting Procedure 2 8/1/85 RW'6009/26009/36009 'Radwaste Shipment Survey

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Procedure 1 8/1/85 RW 6010/26010/36010 Loading of Chem-Nuc Shipment Cask 1 8/1/85 RW 6011/26011/36011 Operating the Mobile Shield Assembly (Atcor Cask) 1 8/1/85 RW 6012/26012/36012 Packing Noncompactable LSA Containers 2 8/1/85

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ATTACHMENT III

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MNPS-3 Final ' Safety An'alyses Report (FSAR), Section 11.4, Solid Waste Management, Amendment 8, dated May 1984 Safety Evaluation Report (SER) Supplement dated July 1984 Operating Procedure OP3338A, Revision 0, " Radioactive Solid Waste," dated September 19, 1985 Test Procedure T3338-P, Revision 0, " Radioactive Solid Waste System," dated August 15, 1985 Vendor Procedure OM-38, " Nuclear Packaging Dewatering System," Revision 1, dated September 26, 1985 Stone and Webster Orawing No.12179-EM-1108-2A, " Piping and Instrument Diagram -

Radioactive Solid Waste," dated September 17, 1982 Licensee Response to NRC Interrogatory No. Q460.17 NRC Standard Review Plan 11.4, Solid Waste Management Systems