ML19254E741
| ML19254E741 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 09/28/1979 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 7911020278 | |
| Download: ML19254E741 (6) | |
Text
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s c-PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF ELECTRCPR CTION September 28, 1979 Re:
Docket Nos.:
50-277 50-278
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fy I[I l
j gp Uglj Q IE Bulletin 79-19
'f r. Boyce H.
Grier, Director Office of Inspection & Enforcecent Region I United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Crier:
This letter is in response to IE - ulletin 79-19, received on August 14, 1979, concerning packaging of low-level radioactive waste for transport and burial.
Responses to your questious are presented sequentially.
Action To 3e Taken 3v Licensees To assure the safe transfer, packaging, and t r e.n s p or t of low-level radioactive waste, each licensee is expected to:
1.
Maintain a current set of DOT and N2C regulations concerning the transfer, packaging and transport of low-level radioactive waste caterial.
Resoonse A set of DOI and NRC regulations is kept current through a subscription to the Federal Register addressed to the Station Superintendent.
To further ensure that our set of regulations are current, the following additional actions have 'oeen taken:
1249 072 h77 7911020 Q
Mr. Boyce H.
Grier Page 2 a)
A purchase order has been issued to obtain the most current copies of 10 CFR parts 0 to 199 and 49 CFR parts 100 to 199 from the U.S.
Printing Office as they are made available.
The addressee for these materials is the person who is Technical Assistant of Health Physics Support Service.
b)
A purchase order has been issued to Datamation Corporation to purchase their subscription service which provides updates of the rules and regulations pertaining to the packaging, handling and shipping of radioactive materials.
The addressee for these materials is the person who is the Engineer Health Physics.
2.
Maintain a current set of requirements (license) placed on the waste burial firm by the Agreenent State of Nevada, South Carolina, or Washington before packaging low-level radioactive waste =aterial for transfer and shipment to the Agreement State licensee.
If a waste collection contractor is used, obtain the appropriate requirenents from the Contractor.
Resoonse Ue do possess a current set of Requirements for the burial sites in South Carolina and Nevada.
At the present time, no shipments are made to the burial site in the state of Vashington.
If shipment to the burial site in the state of Washington is required, we will obtain a current set of their Requirecents and will incorporate them into our procedures prior to shipment.
In order to insure a current set of Requirenents, the Engineer-Chemistry is on the Chem-Nuclear and NECO (operators of the burial sites in South Carolina and Nevada) mailing list which provides updates to the state regule.tions and vendor licenses as changes are made to them.
3.
Designate, in writi:.g, people in your crganization who are responsible for th safe transfer, packaging and transport of low-level radioa'
'e material.
Resnonse We are writing a plant procedure to designate individuals by job title or group responsible for the safe transfer, packaging and transport of low-level radioactive material.
Three individuals (or group of individuals) have responsibility for the safe transfer, packaging and transport of low-level radioactive material at the Peach 3otton Atomic P o.r e r Plant Site.
1249 073
Mr. Boyce H.
Grier Page 3 These three individuals (or group of individuals) and a brief description of their responsibilities are outlined below:
Shift Supervision Shift Supervision is responsible for the operation of systems and processes which generate, transfer and package low-level radioactive waste (dewatered resin, trash, etc.).
A member of this group, the Radwaste Supervisor (or his alternate), is directly responsible for packcging and transport of Radioactive Waste for off-site disposal.
Engineer - Health Physics The Engineer of Health Physics is responsible for the safe handling, 'ransport and storage of radioactive material within the Peach 3cttom Site.
He is also responsible for the transfer, packaging and transport off-site of low-level radioactive material other than radioactive waste.
Radioactive waste is radioactive material which is transported to a burial site for disposal.
Radioactive material includes radioactive sources and contaminated equipment shipped to other sites for re-use.
He is responsible for maintaining the records of radioactive material shipments other than radfoactive waste.
He also acts as a technical advisor to the Radwaste Supervisor.
Engineer - Chemistrv The Engineer of Chemistry is responsible for maintaining the records of radioactive waste shipments.
He provides the audit function on radioactive waste shipments.
He also acts as a technical advisor to the Radwaste Supervisor.
4.
Provide management-approved, detailed instructions and operating procedures to all personnel involved in the transfer, packaging and transport of low-level radioactive material.
Special attention should be given to controls on the chemical and physical form of the low-level radioactive material and on the containment integrity of the packaging.
Resoonse All plant operating p rocedures which involve the transfer, packaging and transport of low-level radioactive waste have been reviewed and revised as necessary in order to insure compliance with NRC, DOT, and Surial site requirements.
Special attention is given to the chemical and physical forms of the low-level material and to the containment integrity of the packaging.
These revisions have been approved by the Plant Operation Revieu 1249 074
Mr. Boyce H.
Grier Page 4 Committee.
In response to the recent industry concern over proper handling of low-level radioactive material, the Operation and Safety Review Committee is being requested to also revieu and approve the applicable procedures.
5.
Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material.
Maintain a record of training dates, attendees, and subject material for future inspections by NRC personnel.
Resoonse Plant personnel directly responsible for transfer, packaging and transport of radioactive warte have been trained in DOT, NRC and Burial Site requirenents and the operating procedures which enforce these requirenents.
The remainder of shift supervision and the plant operating force which transfer, package and transport radioactive material vill be trained in DOT, NRC and Burial Site requirements and the operating procedures to the depth necessary for the j ob they perform.
This training vill be completed by January 1,
1980.
2etraining will be performed on an annual basis.
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 mininized and that such vaste is processed into acceptable chemical and physical f orn for transfer and shipment to a low-level radioactive waste burial facility.
Resoonse All plant personnel as part of their normal training (General Employee Training and j ob specific training) are instructed to mininize the volume of radioactive vaste produced.
In order to stress the importance of minimizing radioactive vaste, and of acceptable chemical and physical f orm f or transfer and shipment of low-level radioactive waste, all plant operators who transfer and package radioactive waste will receive additional training in these areas by January 1,
1930.
P.etrainin3 will be performed on an annual basis.
7.
Establish and inplement a nanagement-controlled audit function of all transfer, packaging and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are 1249 075
Mr. Boyce H.
Grier Page 5 functioning to ensure safety and compliance with regulatory requirements.
Resoonse A management-controlled audit 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 requirements was established and implemented in accordance with the April 1978 revision to the Peach 3otton quality Assurance Plan (PBQAP) Operations Phase.
This revision of the P3QAP incorporated the applicable criteria contained in 10 CFR 71 Appendix E " Quality Assurance Criteria for Shipping Packages for Radioactive Material".
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 "RC 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.)
Resnonse An audit covering all areas except training was conducted in January 1979 In keeping with your "within the past 6 months" requirement for performance of an audit covering all activities in Items 1-6, a Quality Assurance Division audit is in progress and will be completed by Oc t ob e r 10, 1979.
Additional questions 1.
How many low-level radioactive vaste shipments did you make?
What was the volume of low-level radioactive uaste shipped?
Resnonse In accordance with the instructions in Bulletin 79-19, no r es p ons e to this question is necessary since the number of vaste shipments and the volume of vaste is reported in accordance with Technical Specifications in our Semi-Annual Effluent 2eleases Report.
2.
'4h a t was the quantity (curies) of low-level radioactive waste shipped?
What vere the major isotopes in the low-level radioactive waste?
1249 076
Mr. Boyce H.
Grier Page 6
Response
In accordance with the instructions in Bulletin 79-19, no report of the quantity (curies) of radioactive waste is included since it is reported in accordance with the Technics 1 Specifications in our Semi-Annual Effluent Releases Report.
The major is ot op es in the low-level radioactive waste from Peach 3ottou Atomic Power Station are:
Na-24, P-32, Fe-55, Cr-51, Mn-54, Co-58, Co-60, Zn-65, Sr-89, Sr-90, Zr-95, Nb-95, Tc-99m, Mo-99, I-131, I-133, Cs-134, Cs-137, Ba-140, La-140.
3.
Did you generate liquid low-level radioactive waste' If the answer is
'yes',
what process was used to solidify the liquid waste?
R e s n ort s e Ue do generate liquid low-level radioactive waste in the form of contaminated oils.
These oils are solidified using the Delaware Custom Material process which uses cement with additives.
Should you have need for any further information, please feel free to contact us.
Very truly yours,
/
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cc:
United States Nuclear Regulatory Commission Office of Inspection and Enforcement Division of Reactor Operations Inspection Washington, DC 20555 1249 077