ML20210F812
| ML20210F812 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/28/1987 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8702110168 | |
| Download: ML20210F812 (2) | |
See also: IR 05000277/1986021
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JAN 2 81987
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Docket Nos'.
50-277
50-278
Philadelphia Electric Company
ATTN: Mr. J. W. Gallagher
Vice President
Nucl' ear Operations
a
2301 Market Street
_ Philadelphia, Pennsylvania 19101
Gentlemen:
Subject: Combined Inspection Nos. 277-86-21 and 50-278-86-22
This refers to you"r letter dated December 31, 1986, in response to our letter
dated November 20, 1986.
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 11_ censed program.
Your cooperation with us is appreciated.
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Sincerely,
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Origine1 Sisnot' 37 8
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Thomas T.
Dir
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Division of Radiation Safety
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and Safeguards
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R. S. Fleischmann, Manager, Peach Bottom Atomic Power Station
John S. Kemper, Senior Vice President, Engineering and Production
Troy B. Conner, Jr. , Esquire
W. H. Hirst, Director, Joint Generation Projects Department,
Atlantic El ctric
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G. Leitch, Nuclear Generation Manager
Eugene J. Bradley, Esquire, Assistant GeneraP Counsel (Without Report)
Raymond L. Hovis, Esquire
Thomas Magette, Power Plant Siting, Nuclear Evaluations (Without Report)
W. M. Alden, Engineer in Charge, Licensing Section
Public Document Room (PDR)
local Public Document Room (LPDR)
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Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector
Commonwealth of Pennsylvania
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Region I Docket Room (with concurrences)
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PHILADELPHIA ELECTRIC COMPANY
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2301 MARKET STREET
P.O'. BOX 8699
PHILADELPHIA. PA.191o1
(21518414000
December 31, 1986
Docket Nos. 50-277
50-278
Inspection Report Nos. 50-277/86-21
50-278/86-22
Mr. Thomas T. Martin, Director
Division of Radiation Safety and Safeguards
U.S. Nuclear Regulatory Commission
Region I
631 Park Avenue
King of Prussia, PA
19406
,
Dear Mr. Martin:
Your letter dated November 20, 1986 forwarded combined
Inspection Report Nos. 50-277/86-21, 50-278/86-22 for Peach Bottom
Atomic Powcr Station.
Appendix A of your letter addresses several
items wuich do not appear to be in full compliance with Nuclear
Regulatory Commission requirements.
These items are restated below
followed by our responses.
W. M. Alden, Engineer-In-Charge of our
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Licensing Section, discussed the need for additional time to prepare
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these responses with Mr. Peter Esselgroth of your staff and the delay
was found to be acceptable.
I.
Restatement of Violation
A.
10 CFR 20.311(b) requires, in part, that the manifest
accompanying radioactive waste shipments indicate as
completely as practicable the radionuclide identify and
quantity, and the total radioactivity of the shipment.
10 CFR 20.311(c) requires, in part, that the manifest must
include a certification by the waste generator that the
transported materials are properly described.
Contrary to the above, on February 28, 1986, your Shipment
No. 45-86 of dry active radioactive waste, which contained
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several radionuclides including Iron-55, was sent to a
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Mr. Thomas T. Martin
Drcsmbar 31, 1986
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burial site and was accompanied by a manifest which did not
identify the existence and quantity of the radionuclide
Iron-55 in the shipment.
As a result, the total
radioactivity stated on the manifest was in error.
Further, the certification which accompanied the manifest
was also in error.
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B.
10 CFR 71.5(a)(1)(vi) requires that shipping papers be
prepared in accordance with 49 CFR 172, Subpart C.
49 CFR
172.203(d)(1) requires the name of each radionuclide in the
shipment and 49 CFR 172.203(d)(iii) requires the activity
of each package in the shipment be included in the shipping
papers.
Contrary to the above, on February 28, 1986, your Shipment
No. 45-86 of radioactive waste which contained several
radionuclides including Iron-55, was sent to a burial site
and the shipping papers did not include the identity of
Iron-55 in the shipment and the activity resulting from
that radionuclide.
Violations A and B have been categorized in the aggregate
as a Severity Level IV problem.
(Supplement V)
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Response:
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Admission of Alleged Violations:
Philadelphia Electric Company acknowledges the violations as
stated above.
Reason for the Violations:
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An incorrect scaling factor was used to determine Iron-55
activity in Shipment No. 45-86.
The use of this incorrect
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scaling factor resulted in failure to report the Iron-55.
These
violations were the result of deficiencies in our program for the
implementation of 10 CFR 61 requirements.
Requirements were not
included in proceduren to clearly specify periodic sampling and
redetermination of scaling factors.
A station procedure for updating scaling factors does exist
(Routine Test RT-7.3.3); however, a frequency for issuing the RT
on a periodic basis is not specified in the procedure, nor are
criteria provided in the procedure specifying the extent to which
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scaling factors have to change before it is necessary to update
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Mr. Thomas T. Martin
Dscamber 31, 1986
Page 3
the radwaste computer.
The procedural inadequacy contributed to
the use of an incorrect scaling factor.
Scaling factors are used to quantify activities of hard-to-
identify radionuclides which are present in the radwaste streams.
The scaling factor relates the concentration of a hard-to-
identify isotope to the concentration of a readily detectable
isotope.- Iron-55 is a hard-to-identify isotope and, as such, its
activity is determined using a scaling factor which relates Iron-
55 activity in a shipment to Cobalt-60 activity in the same
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shipment.
(Cobalt-60 is a readily detectable isotope.)
Our investigation of these violations also determined that other
previously used scaling factors ware inaccurate due to improperly
categorizing samples and data for dry active waste, waste oil,
radwaste resins, and primary resin groupings.
Significance of the Violations:
Shipment No. 45-86 was shipped as Class A waste.
Based upon a
review of the most recent scaling factors supplied by our
contractor (December 1986), the classification of Shipment No.
45-86 will remain as Class A.
This will be confirmed when the
actual scaling factor for Iron-55 in Shipment No. 45-86 is
received from our contractor.
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Corrective Actions Taken and Results Achieved:
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As part of the review of this incident, Philadelphia Electric
Company personnel visited the contractor on December 11, 1986 to
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clarify the categorization of samples used to determine scaling
factors.
Accurate scaling factors developed from samples submitted in
November 1986 were received on December 18, 1986.
These scaling
factors are being used to report Iron-55 in subsequent shipments.
Corrected scaling factors for previous samples submitted to the
vender are being developed and will be used to review past
shipments.
A preliminary determination has been made by
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Philadelphia Electric Company that corrections will need to be
made to include Iron-55 in previous reports.
However, final
determination can not begin until historical sample data is
reanalyzed and the updated scaling factors confirmed.
Corrected
scaling factors for past shipments are expected by the end of
January 1987, and the reassessment of approximately 400 reports
is expected to require approximately 60 days before the results
of these corrective actions can be completed and reports
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Mr. Thomas T. Martin
Dsccmbar 31, 1986
Page 4
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corrected.
The appropriate burial sites will be contacted and
shipping records updated as required.
Priority will be given to
reviewing and correcting the records of shipment No. 45-86.
Corrective Actions Being Taken to Prevent Recurrence:
RT-7.3.3 is being revised to include criteria for updating the
scaling factors stored in the radwaste computer.
A scaling
factor will be updated in the radwaste computer if it changes by
a factor of at least ten.
The procedure revision will also
include a requirement for QC review of the updated scaling
factor (s).
To ensure that the scaling factors in the radwaste computer
reflect current plant conditions, RT-7.3.3 will be changed to a
surveillance test with an annual frequency.
As part of our recent reorganization we have established, under &
Nuclear Support Division, a Radwaste Management Section headed by
a Director.
At each of our nuclear power plant sites, we have
also recently established a position of Senior Engineer for
radioactive waste.
These changes will provided increased
management attention and control in these areas to preclude such
occurrences in the future.
Date When Full Compliance Will be Achieved:
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Current scaling factors were received from our contractor on
December 18, 1986.
As a result, full compliance for current
shipments is now being achieved.
Full compliance for past shipments will be achieved when the
shipment records are updated to include missing Iron-55 activity.
This update is expected to be completed by March 31, 1987.
II.
Restatement of Violation:
10 CFR 20.311(d)(1) requires, in part, that licensees prepare
radioactive wastes so that the waste is classified according to
10 CFR 61.55(a)(3)(ii) requires, in part, that
wastes containing long-lived radionuclides (listed in Table 1 of
that paragraph) exceeding 0.1 times the value in Table 1 be
classified as Class C.
10 CFR 20.311(c) requires, in part, that
the manifest accompanying radioactive waste shipments include a
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Mr. Thomas T. Martin
Dacambar 31, 1986
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certification by the waste generator that the transported
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materials are properly classified.
Contrary to the above, on May 15, 1986, your Shipment No. 119-86
of radioactive waste contained a concentration of Carbon-14 (a
long-lived radionuclide) of approximately 1.82 curies per cubic
meter which exceeded 0.1 times the Table 1 value of 8 curies per
cubic meter for that radionuclide and was classified as Class B.
Further, the certification that the shipment was properly
classified was also in error.
This violation has been categorized as a Severity Level IV
problem.
(Supplement IV)
Response:
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Admission of Alleged Violation:
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Philadelphia Electric Company acknowledges the violation as
stated.
Reason for Violation:
The violation occurred as a result of personnel error involving
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failure to properly classify the waste of a non-routine shipment.
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Lack of a procedure specifying the need for independent
verification of the classification of a non-routine shipment
contributed to the misclassification.
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Shipment classifications are determined by reviewing a computer-
generated form which lists the isotopes and activities of the
waste shipment.
This form, when generated through the PECo
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radwaste computer, requires two independent reviews.
Also, a
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classification is identified on the PECo radwaste computer form
based on 10 CFR 61 data.
However, because Shipment No. 119-86
was a non-routine shipment, the computer forms generated for
review of this shipment were completed using a vendor's computer
program.
Due to the inadequacy of the vendor computer program,
the shipment classification was not identified on the vendor
computer form and further, a procedural inadequacy existed in
that the vendor computer form was not required to be
independently verified.
With no shipment classification
identified on the computer form, the individual responsible for
classifying waste shipments had to analyze the isotopes and
activities indicated on the form in order to determine the
shipment's classification.
The classification error occurred
during the course of this analysis.
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Mr. Thomas T. Martin
Daccabar 31, 1986
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Significance of Violation:
The significance of this violation is considered to be minimal
since both Class B and Class C wastes are placed in the same
trench at the burial site.
Consequently, no adverse consequences
to the health and safety of the public are expected.
Corrective Actions Taken and Results Achieved:
Immediate corrective action involved notifying the burial site of
the misclassification and requesting the burial site personnel to
check the burial location.
The shipping record for Shipment No.
119-86 has been corrected to resolve the classification
discrepancy.
Corrective Actions Taken to Avoid Future Non-Compliance:
To prevent recurrence of this violation, procedures are being
prepared to:
1.
Require two independent reviews of documents used to
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classify waste shipments, and
2.
Require that all vendor radwaste computer programs generate
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forms which specify the need for two independent reviews
and which recommend a shipment classification based on 10 CFR 61 data, and
3.
Require PECo approval of all radwaste computer programs
prior to their use.
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These procedures are expected to be prepared and approved by
January 31, 1987.
In the interim, until the vendor radwaste
computer program is upgraded in accordance with these procedures,
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all Peach Bottom radwaste shipments will be classified using the
PECo computer program.
Date When Full Compliance Will Be Achieved:
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Full compliance was achieved on December 31, 1986 when the
Shipment No. 119-86 records were updated to correct the
classification discrepancy.
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Mr. Thomac T. Martin
D3cambar 31, 1986
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Your letter also requested that Philadelphia Electric
Company review all radioactive waste shipments from August 1, 1985
through October 23, 1986 to determine if other shipments were
misclassified under 10 CFR 20.311 and 10 CFR 61.55 and that the
results of this review be provided to you by January 19, 1987 (60 dagli
from the date of your letter).
Our contractor's review to determine
updated scaling factors is not expected to be completed until January
30, 1987.
Due to the large number of waste shipments which have to be
reviewed (approximately 400), we anticipate that our review will be
completed by March 31, 1987 (60 days from receipt of the updated
scaling factors).
We hope that this unavoidable delay will not
present an inconvenience to you or your staff.
Should you have any questions or require additional
information, please do not hesitate to contact us.
fer
truly yours,
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M.
ooney
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M
ager
clear Suppcrt Department
cc:
T. P. Johnson, Resident Site Inspector
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