IR 05000293/1986010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/86-10. Corrective Actions Will Be Examined During Future Insp

ML20212A612
Person / Time
Site:	Pilgrim
Issue date:	07/22/1986
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Harrington W BOSTON EDISON CO.
References
NUDOCS 8607290082
Download: ML20212A612 (2)

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JUL 2 21986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Ha rington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199

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Gentlemen:

Subject: Inspection No. 50-293/86-10 We acknowledge receipt of your letter dated June 20, 1986, in response to our letter dated May 6, 1986.

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! 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 licensed program.

Your cooperation with us is appreciated.

Sincerely, B

hi inal Sigung 3,,

Nb mas T. Martin, Dir %ector Division of Radiation Safety and Safeguards

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L. Oxsen, Vice President, Nuclear Operations A. E. Pedersen, Station Manager Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes Senator Edward P. Kirby

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The Honorable Peter V. Forman Sharon Pollard Public Document Room (PDR)

local Public Document Room (LPDR)

' Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

0FFICIAL RECORD COPY RL PILGRIM 86-10 - 0001.0.0 07/18/86 8607290082 e6072223 PDR ADoCK 05 g f@h G --

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• Boston Edison Company M/C Nuclear 2 e

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Region I Docket Room (with concurrences)

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Management Assistant, ORMA (w/o enc 1)

Section Chief, DRP W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR PA0 (2) SALP Reports Only Robert J. Bores, DRSS l

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R SS RI S Miller /geb Pasci k Bellam

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7/Aa/86-yw ( 1lt'l l ~

. OFFICIAL RECORD COPY RL PILGRIM 86-10 - 0002.0.0 l . 07/18/86

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BOSTON EDISON COMPANY B00 BOYLSTON STREET SOSTON.:M ARBACHustTTE O2199 WILLIAM D. HARRlNGTO N K usee nsa posesse m

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mete 6saa June 20, 1986 BECo Ltr. :#86- 085

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Mr. Thomas T. Martin, Director -

Division of Radiation Safety and Safeguards

U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406

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Subject: BECO Response to Notice of Violation as Contained in NRC Inspection Report 86-10, dated May 6, 1986 I

Dear Mr. Martin:

This letter is in response to the notice of violation as contained in the subject letter. The violations and Boston Edison's responses are enclosed as an attachment to this letter. ,

Please note that this response is being sent in accordance with an extension of the response due date to June 20, 1986 as agreed to in a telecon to Ms.

Marie Miller of your staff on June 4, 1986.

Should you have any further questions regarding this issue, please do not hesitate to contact me.

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Very truly yours,

W. D. Harrington M

Attachment '+

JC/vep-ffbC131(3i3fiCNde-

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, ATTACHMENT

NRC NOTICE OF VIOLATION (86-10-04)

Technical Specification 6.8 requires that written procedures and administrative policies be established, implemented and maintained, that l

meet or exceed the requirements and recommendations of Appendix ' A' of

. Regulatory Guide 1.33, 1972. Station approved Procedure 1.3.4,

" Procedures", requires in Section III.A that approved written procedures i be adhered to by all station personnel. Procedure PNPS-6.9-160, Revision

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20 specifies in part, (1) to survey material to be packaged and to document the survey results on appropriate radiation level at the surface

of the package, and the total activity within the package on the shipping manifest.

Contrary to the above, on January 23, 1985, July 9, 1985, and August 2,

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1985, radiation surveys of packaged irradiated reactor components were not documented on appropriate radiation survey forms and maps; the maximum '

radiation level at the surface of the package was incorrect for shipment numbers 85-06 and 85-66' and the total radioactivity contained within shipment number 85-79 was incorrectly listed during transport.

BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective action to correct the condition, the incorrect entry associated with shipment number 85-79 (being a self-identified deficiency) was corrected on August 5, 1986.

As corrective action to preclude recurrence, an increased emphasis has ,

been placed on the quality of surveys (as discussed and reinforced at the

daily meetings with technicians). It is planned to use this particular

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violation as a " lesson learned" example in the training which we provide

! to health physics technicians.

l As further corrective action to preclude recurrence, technicians are now assigned to shipment-related functions for a longer period of time. This longer assignment will result in an increased familiarity with the procedures and paperwork involved in the radwaste shipping process.

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The combination of the above actions has already, and will continue, to result in higher quality records from both a content and a consistency 1 viewpoint.

Full compliance was achieved on August 5, 1985, the date upon which the paperwork related to shipment number 85-79 was corrected.

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As an added note, we would like to correct part of the basis of the subject violation which states that ...

" procedure PNPS-6.9-160, Revision 20 specifies in part, (1)

to survey material to be packaged and to document the survey results on appropriate radiation survey forms and maps, and (2) to document the maximum radiation level at the surface of the package, and the total activity within the package on the shipping manifest."

Procedure 6.9-160 does not contain the above statement, although it is our policy to document survey results in an appropriate manner.

NRC NOTICE OF VIOLATION (86-10-01)

10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires licensees who transfer radioactive waste to a land disposal facility to conduct a quality control program to assure compliance with 10 CFR 61.56.

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l Contrary to the above, the licensee had transferred Several radioactive waste shipments composed of dewatered resins and diatomaceous earth absorbers to a land disposal facility during 1984 and 1985 and the licensee had not conducted a quality control program to assure that the packages did not contain free standing liquid greater than 1% of the waste volume, and that the waste was structurally stable for compliance with 10 CFR 61.56.

BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective step: to correct the condition and to preclude recurrence, we have taken the following actions. First, the Quality Control Instruction (QCI 19.01) has been revised to require a yearly surveillance inspection of the dewatering processes used at PNPS. The revised instruction was issued on May 1, 1986. Secondly, the on-site Q.C. Group will now conduct surveillance inspections of container loading, dewatering, and shipping preparation activities.

The above corrective steps will ensure that Boston Edison's radioactive waste handling activities are done in compliance with 10 CFR 61.56. Full compliance was reached on May 1, 1986, the date upon which the yearly surveillance inspection requirement was incorporated.

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