IR 05000352/1985021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-352/85-21

ML20126G678
Person / Time
Site:	Limerick
Issue date:	06/12/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
CON-#285-470 NUDOCS 8506180129
Download: ML20126G678 (4)

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Docket No. 50-352 License No. NPF-27 Philadelphia Electric Company ATTN: Mr. S. L. Daltroff Vice President, Electric Production 2301 Market Street Philadelphia, PA 19101 Gentlemen:

Subject: Inspection Report No. 50-352/85-21 We acknowledge, receipt of your letter dated May 23, 1985, in response to our letter dated May 2,1985.

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, ykt kg} (  %

Th6'm"as T. Martin, Director Division of Radiation Safety and Safeguards cc:

V. S. Boyer, Senior Vice President, Nuclear Power John S. Kemper, Vice President, Engineering and Research G. Leitch, Station Superintendent Troy B. Conner, Jr. , Esquire Eugene J. Bradley, Esquire, Assistant General Counsel Limerick Hearing Service List PublicDocumentRoom(PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Pennsylvania 0FFICIAL RECORD COPY 8506180129 850 $52 i PDR ADOCK O PDR g\

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Philadelphia Electric Company 2 bcc:

Region I Docket Room (with concurrences)

S-- b. Operar. ions Officer--

Section Chief, DRP P. Eselgroth, Shoreham, SRI Section Chief, TPS, DRS

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R::DRSS. 'RI SS alBiller/djh vzBasciak Bellamy Ma in-6/G/85 6/[./85 0 64/85 6/ 85 0FFICIAL RECORD COPY ~ LIMERICK 85-21 - 0001.1.0 06/04/85

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Limerick Hearina Service List 1 Judge Helen F. Hoyt '

Mr. Marvin I. Lewis A.:mic Safety and Licensing 6504 Bradford Terrace Ecard Philadelphia, PA 19149 U.S. Nuclear Regulatory Cc= mission Washington, D.C. 20555 Judge Richard F. Cole Phyllis Zitner At:mic Safety and Licensing LEA Ecard P. O. Box 761 U.S. Nuclear Regulatory Pottstown,

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PA 19464 '

Commission Washir.gton, D.C. 20555 Judge Jerry Harbour Docketing and Service Station Atomic Safety and Licensing Office of the Secretary Ecard U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission W shington, D.C. 20555 Mr. Frank R. Rcmano Counsel for NRC Staff 61 Forest Avenue Office of the Executive Legal Director

. Ambler, Pennsylvania 19002 U. S. Nuclear Regulatory Ccemissicn Washington, D.C. 20555 Mr. Robert L. Anthony Philadelphia Electric Ccmpany P. O. Box 186 ATTN: Edward G. Bauer, Jr.

103 Vernon Lane Vice President and Moylan, Pennsylvania 19065 General Counsel 2301 Market Street Philadelphia, PA 19101 David Wersan, Esq. Charles W. Elliott, Esquire Assistant Consumer Advocate Brose and Postwistilo Office of Consumer Advocate 1101 Building 1 25 Strawberry Square lith and Northamp in Streets Harrisburg, PA 17120 Easton, PA 18042 Steven P. Hershey, Esquire Zori G. Ferkin Community Legal Services, Inc. Governor's Energy Council Law Center West P. O. Box 8010 5219 Chestnut Street Harrisburg, PA 17105 Philadelphia, PA 19139 Martha W. Bush, Esquire Troy B. Conner, Jr. , Esquire

_ Kathryn S. Lewis, Esquire Mark J. Wetterhahn, Esquire l Municipal Services Bldg. Conner & Wetterhahn 15th and JFK Blvd. 1747 Pennsylvania Avenue

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. Philadelphia, PA 19107 Washington, D. C. 20006 t

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Angus Love, Esquire Robert J. Sugarman, Esq.

101 East Main Street -

Sugarman, Denworth & Hellegers

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16th Floor Center Plaza

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'~ 101 North Broad Street Philadelphia, PA 19107 Spence W. Perry, Esquire Mr. Joseph H. White, III Associate General Counsel- 15 Ardmore Avenue Federal Emergency Management Agency Ardmore, PA 19003 500 C Street, S.W. Room 840 Washington, DC 20472 Thomas Y. Au, Esquire Assistant Counsel - '

Commonwealth of Pennsylvania DER 505 Executive House P. O. Box 2357 Harrisburg, PA 17120 Thomas Gerusky, Director Bureau of Raciation Protection Department of Environmental -

Resources 5th Floor, Fulton Bank Bldg.

Third and Locust Streets H.arrisburg, PA 17120

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. i PHILADELPHIA ELECTRIC COMPANY l

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2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.191o1 (2 51 e415020

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. o c , .Ic"*So"o" c'".. . "o' .'! .' ,- . -, May 23, 1985 Docket No. 50-352 Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

Your letter dated May 2, 1985, forwarded Inspection Report 50-352/85-21 for Limerick Generating Station Unit 1 in which no violations were identified. However, you requested that we describe in writing our readiness plans concerning our radioactive waste management program and state that no radioactive waste shipments will be made until the radioactive waste management program is in place and meets the requirements of IE Bulletin 79-19.

We are in the process of finalizing our radioactive waste management program. Until such time that this program is in place and meets the requirements of IE Bulletin 79-19, no radioactive waste shipments will be made from the Limerick Generating Station. Restated below are the requirements set forth in IE Bulletin 79-19 followed by our response.

Action to Be Taken by Licensees To assure the safe transfer, packaging, and transport of low-level radioactive waste, each licensee is expected to: 1 1. Maintain a current set of DOT and NRC regulations concerning the transfer, packaging and transport of low-level radioactive waste material.

Response j l

A set of DOT and NRC regulations is kept current through a 1 subscription to the Federal Register addressed to the N nager Limerick Generating Station.

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Mr. Thomac May 23, 1985 Page 2 To further ensure that our set of regulations are current, the following actions have been or will be taken prior to any radioactive waste. shipment from Limerick Generating Station.

a) A current copy of 10 CFR and all revisions are sent to the Plant Manager through a subscription service and are available in the Health Physics office.

b) A purchase order will be issued by 06/15/85 for a subscription service for other documents, i.e. 49 CFR which will provide up-dates of the rules and regulations pertaining to the packaging, handling and transport of radioactive waste.

2. Maintain a current set of requirements (license) placed on the waste burial firm by the Agreement State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste material for transfer and shipment to the Agreement State licensee. If a waste collection contractor is used, obtain the appropriate requirements from the contractor.

Response To ensure that the requirements and licenses are kept current, Philadelphia Electric Company's Director of Radiation Protection in the corporate office is on the mailing lists of the burial sites in South Carolina and Washington which provide updates to the state regulations and vendor licenses as changes are made to them. Copies of these are maintained both at Headquarters and at the Limerick Generating Station in the Health Physics office. Prior to the shipment of radioactive waste, verification will be made to assure that we possess current requirements and licenses.

If a waste collection contractor is used, its requirements will be incorporated into our procedures.

3. Designate, in writing, people in your organization who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

Response We have developed written position descriptions to designate individuals by job title who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

A management organization has been developed to provide safe l transfer, packaging, and transport of radioactive materials.

The Operations Engineer has overall responsibility for directing the safe transfer, packaging and transport of low-level radioactive material. The senior plant staff members

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Mr. Thomas May 23, 1985

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l Those people who will play a lesser roll, i.e. the .

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i collection, sorting and gathering, and temporary storage of low-level radioactive material attend a formal classroom training initially and for annual requalification with

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i special emphasis given on the controls of chemical and

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physical forms.

l All plant employees as part of their normal training (General

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Employee Training and job specific training) are instructed

in methods to minimize the volume of radioactive waste produced. Retraining is performed on an annual basis.

A record of attendees, training dates and subject material discussed is maintained for inspection by NRC personnel.

6. Provide training and periodic retraining to those employees who operate the processes Which. generate waste to assure that

' the volume of low-level radioactive waste is minimized and ,

that such waste is processed into acceptable chemical and

! physical form for transfer and shipment to a 16w-level radioactive waste burial facility.

i i Response

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Plant employees, as part of their normal training (General ~

Employee Training and job specific training) are instructed to minimize the volume of radioactive waste produced. System

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training is currently being developed for Operators as to the l specific operations of three general areas.

? Plant personnel in Solid Radwaste, Offgas, and Liqu'A

! Radwaste operations have been trained and the formalized

requalification programs for these areas will be completed i and implemented by September 1, 1985.

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To stress the importance of radwaste volume reduction and of

,' acceptable chemical and physical form for transfer and shipment of low-level radioactive ~ waste, specific personnel

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whose. job encompasses the collection, transfer and packaging of radioactive waste will receive additional training in

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Establish and implement a management-controlled audit

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function of all transfer,-packaging and transport activities to provide assurance that personnel, instructions and

' procedures, and process and transport equipment are functioning'to. ensure safety and compliance with regulatory i ' requirements.-

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Mr. Tho;ac May 23, 1985 Page 5

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Response A management-controlled audit function has been developed as an integral part of the overall Quality Assurance program.

The audit function performed by the PECo Quality Assurance Organization assures and documents that personnel, instructions, procedures and process are in compliance with current Regulatory requirements.

To ensure the independence of the audit and the auditor, the Quality Assurance organization does not report to the Plant Operations organization.

8. Perform, within 60 days of the date of this bulletin, a management-controlled audit of your activities associated with the transfer, packaging and transport of low-level radioactive waste. Maintain a record of all audits for future inspections by NRC or DOT inspectors. (Note: If you have an established audit function and have performed such an audit of all activities in items 1-6 within the past six months, this audit requirement is satisfied.)

Response The requirements of IE Bulletin 79-19 were not applicable to Limerick Generating Station during the 60 day time period following the date of the Bulletin. However, a management-controlled audit will be performed prior to the first waste shipment from Limerick Generating Station. Audit records will be on file for review by NRC or DOT inspectors.

Additional questions asked in IE Bulletin 79-19:

1. How many low-level radioactive waste shipments did you make?

What was the volume of low-level radioactive waste shipped?

Response No low-level radioactive waste shipments have been made.

Low-level radioactive material generated, (spent resins, DAW), are being stored on site pending completion of the Radioactive Waste Management program.

2. What was the quantity (curies) of low-level radioactive waste shipped? What were the major isotopes in the low-level radioactive waste?

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Mr . Thomas May 23, 1985 Page 6 Response

, Not applicable.

3. Did you generate liquid low-level radioactive waste? If the answer is 'yes', what process was used to solidify the liquid waste?

Response No low-level radioactive liquid waste has been generated to date.

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Should you have need for any further information, please feel free to contact us.

Very truly yours,

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i cc: J. T. Wiggins, Resident Site Inspector q See Service List

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c: Judge Helen F. Hoyt Judge Jerry Harbour Judge Richard F. Cole Troy B. Conner, Jr., Esq.

Ann P. Hodgdon, Esq.

Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Phyllis Zitner i Charles W. Elliott, Esq.

Zori G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna g Emergency Management Agency Angus Love, Esq.

David Wersan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bush, Esq.

Spence W. Perry, Esq.

Jay M. Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel Docket & Service Section (3 Copies)

James Wiggins Timothy R. S. Campbell

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i January 16, 1985 l

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