IR 05000277/1986021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-277/86-21 & 50-278/86-22

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)

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JAN 2 81987 s

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.

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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 ectric 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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s Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania

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Philadelphia Electric Company 2

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Region I Docket Room (with concurrences)

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Management Assistant,.DRMA (w/o encl)

Section Chief, DRP Robert J. Bores, DRSS

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PHILADELPHIA ELECTRIC COMPANY 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

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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 i Licensing Section, discussed the need for additional time to prepare i 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

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No. 45-86 of dry active radioactive waste, which contained several radionuclides including Iron-55, was sent to a

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Mr. Thomas Drcsmbar 31, 1986

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Page 2 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)

l r Response:

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Admission of Alleged Violations:

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Philadelphia Electric Company acknowledges the violations as stated above.

Reason for the Violations:

( An incorrect scaling factor was used to determine Iron-55

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activity in Shipment No. 45-86. The use of this incorrect 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

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criteria provided in the procedure specifying the extent to which l scaling factors have to change before it is necessary to update

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Mr. Thomas 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 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:

i As part of the review of this incident, Philadelphia Electric

Company personnel visited the contractor on December 11, 1986 to l 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 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 Dsccmbar 31, 1986

. Page 4 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: 3 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. 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 Dacambar 31, 1986

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certification by the waste generator that the transported 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: 7

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] Admission of Alleged Violation:

Philadelphia Electric Company acknowledges the violation as stated.

Reason for Violation

The violation occurred as a result of personnel error involving l'

failure to properly classify the waste of a non-routine shipment.

Lack of a procedure specifying the need for independent verification of the classification of a non-routine shipment

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contributed to the misclassification.

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

, radwaste computer, requires two independent reviews. Also, a l 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 Daccabar 31, 1986

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Page 6 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:

4 1. Require two independent reviews of documents used to classify waste shipments, and

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2. Require that all vendor radwaste computer programs generate 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, i all Peach Bottom radwaste shipments will be classified using the

PECo computer program.

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Date When Full Compliance Will Be Achieved:

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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Page 7 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.

truly yours, i

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M. . ooney M ager clear Suppcrt Department cc: T. P. Johnson, Resident Site Inspector

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