ML20153D410
| ML20153D410 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/04/1988 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Ronald Bellamy NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8805090136 | |
| Download: ML20153D410 (4) | |
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- PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHIL ADELPHI A. PA 19101 3
(21s) s41.soci JOSEPH W. G ALL AGHER Ndy 4, 1900 Docket Nos. 50-277 50-278 I
Mr. Ronald R. Bellamy, Chief l' Facilities Radiological Safety and Safeguards Branch
- Division of Radiation Safety Region I U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
SUBJECT:
Response to Peach Bottom Inspection Report Nos. 50-277/88-05; 50-278/88-05 '
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Dear Mr. Bellamy:
This is in response to your letter dated April 4, 1988 '
which transmitted Peach Bottom Inspection Report Nos. 50-277/88-05; 50-278/88-05. Appendix A of your letter identified two items which did not appear to be in compliance with NRC requirements.
The attachment to this letter provides a restatement of these violations and Philadelphia Electric Company's response.
If you have any questions or require additional 4 information, please do not hesitate to contact us. i r
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l Very truly yours, !
Attachment l cc: Addressee l W. T. Russell, Administrator, Region I, USNRC T. P. Johnson, USNRC Senior Resident Inspector T. C. Magette - State of Maryland
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i 8805090136 880504 PDR ADOCK 05000277
@ DCD_________________________________________.______________________-__
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Attachm2nt Pego 1 of 3 ,
Docket Nos. 50-277 i 50-278 ;
4 1 i' RESTATEMENT OF VIOLATIONS: !
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As a result of the inspection conducted on February 8-12, 1988 -
and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy 1987), the following violations were identified: ;
A. 10 CFR 30.41(c) requires in part, that each licensee i transferring byproduct material verify that the ;
recipient's license authorized the receipt of the type, form and quantity of the byproduct material to be !
- transferred.
i hi Contrary to the above, on or about November 25, 1987, -
your shipment No. 82-87, containing tritium in 52 drums .
of solidified oil was transferred to Quadrex-HPS, Inc.
(An Agreement State licensee) and the Agreement State t license at the time of transfer did not authorize '
receipt of tritium in that form.
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l B. Technical Specification 6.8 requires, in part, that l
, written procedures be implemented. Your procedure No. '
] HPO/CO-17 required, in part, verification of the !
recipient's license prior to transfer of radioactive
- - material. i a ,
i Contrary to the above, on or about November 25, 1987, you failed
- to verify, prior to transfer, titat the recipient's license ,
i allowed receipt of the radioactive material (tritium) in the form (solidified oil) transferred.
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Violations A and B have been categorized in the aggregate as a l 4 Severity Level IV problem. !
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RESPONSE
I Admission or Denial of Alleged Violations:
, i Philadelphia Electric Company (PECo) acknowledges these !
c violations as stated. 1 i
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Attachmsnt Page 2 of 3 i Docket Nos. 50-277 :'
. 50-278
.l Reason for Violations:
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) This violation occurred because a Radioactive Materials Shipping ,.
! Coordinator failed to fully comply with Procedure No,.HPO/CO-17B, "Packaging and Shipm.at of Radioactive Material", which requires ;
verification "that the consignee is licensed to receive the material that is to be shipped." The individual checked the i consignee's license for expiration date but did not verify that the license permitted receipt of the radioactive material to be shipped. Previous frequent shipments of other radioactive ;
material to the same facility caused a complacency with the details of the facility's license. The shipment in which the violation occurred was the first-shipment of a different form (solidified) of material than was previously shipped. This event is considered to be an isolated case. This individual's 1
performance prior to this incident was above average. ,
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Extent or Significance of Violations:
- j This event did not result in an increased risk to the health and safety of the public, even though the shipment was held in a transportation impound yard for several days while a change to the consignee's license was processed. The shipment was not
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received by the consignee until a temporary license amendment was '
, issued by the state of Tennessee authorizing the receipt. The
- waste form of the shipment containing tritium was Environstone, a !
1 cement-based solidification process. This waste form is a stable
) end product acceptable to the burial site (final destination). l q
The waste form was contained in steel drums. The solidified ,
) product and steel container effectively preclude any migration of !
the tritium to the environment for at least several half-lifes. !
In this form there is essentially no pathway for human ingestion. !
The shipment of tritium was in compliance with Dep3rtment of i Transportation regulations and is typical of shipments from l nuclear plants, t I Corrective Actions Taken to Prevent Puture Non-Compliance and I.esults Achieved: '
) A review of a representative sample of previous radioactive materials shipment records, and interviews with all shipping coordinators, confirmed that this was an isolated case. The !
{ Shipping Coordinator who was responsible for the error and the I 4
Shipping Coordinator who approved the entire shipment were j i
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. t Attachmant Pago 3 of-3 Docket Nos. 50-277 50-278
- l counseled on the importance and absolute necessity for strict adherence to procedures. !
On February 9, 1988 (during the inspection), a meeting was held L
between the Senior Engineer-Radwaste and the radwaste shipping group, explaining the violation and the cause of the violation.
Another meeting on the same day was held between the shipping ,
- supervisor and those individuals involved with the shipment.
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- Date When Full Compliance Was Achieved
l On December 8, 1987, Tennessee issued a temporary license amendment permitting receipt of this shipment by the consignee, thereby solving the problem created by these violations.
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