ML19296B738
| ML19296B738 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/11/1980 |
| From: | Schneider F Public Service Enterprise Group |
| To: | Grier B 4 NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8002210440 | |
| Download: ML19296B738 (5) | |
Text
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Freoerick W. Schneider Public Service Electric and Gas Company 80 Park Place Newark, NJ. 07101 201/430-7373 Vice Pressdent Production February 11, 1980 Mr. Boyce H. Grier, Director Office of Inspection and Enforcement Region 1 U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Mr. Grier:
NRC INSPECTION 50-272/79-31 INSPECTION DATED NOVEMBER 13-15, 1979 SALEM UNIT 1 We have reviewed the report of the inspection conducted by Mr. L.H. Thonus and Mr.
R.L. Nimitz of your office on Novem-ber 13-15, 1979, which was transmitted to us with a letter from Mr. George Smith dated January 21, 1980 and received January 25, 1980.
Our response to the item of noncompliance in Appendix A of that report is as follows:
Item A, Violation 10CFR 50, Appendix B, C; 'erion VI, Document Control states, " Measures shall established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized per-sonnel and are distributed to and used at the location where the prescribed activity is performed."
Quality Assurance Manual Instruction QAI 6-1,
" Document Control" and Salem Operational QA Program Administrative Proceduro (. P) 17 Section 6.0 " Document Control" imple-A ment the requirements of 10CFR 50 Appendix B Criteria VI at the Salem Nuclear Generating Station.
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B.H. Grier 2-11-80 1.
Quality Assurance Manual Instruction QAI 6-1,
" Document Control", states in part, "all PSE&G organizations conducting quality-related activi-ties shall document measures to control docu-ments...
These measures shall provide for the following:
... control of obsolete and super-seded documents, availability of documents at locations where the activity is being performed and use of latest revision documents."
Addition-ally, AP-17, Section 6.5, " Requirements" states in part, " document control measures shall include provisions for means of ascertaining that proper documents are being used."
Contrary to the above, the following was noted in a review of document maintenance on November 13, 1979:
As of November 13, 1979, no current copy of 49CFR Part 100 to 199, " Transportation" was on site.
These regulations provide rules and regulations for shipment of radioactive materials.
Approximately two year old copies of 10CFR 20 and 49CFR 100 to 199 were in use at the field location where radioactive waste activities were being performed.
The two year old copies of 49CFR 100 to 199 were being used to provide guidance for revisions of procedures detailing packaging, handling, and shipping of radioactive material.
No formalized method of document control was in place to assure appropriate dis-tribution and use of current revision burial license and package certification of compliance documentation including packaging, drawings, and regulations.
Additionally, one controlled copy of 10CFR 20 was on site, however, it and its changes and revisions were not being dis-tributed to location of use, i.e. Health Physics.
2.
Quality Assurance Manual Instruction QAI 6-1,
" Document Control" requires in Section 4 "Im-plementation", that measures shall be provided for coordination of interfacing documents to preclude conflicts and omissions.
N B.H. Grier 2-11-80 Contrary to the above, a review of documents on November 14, 1979, indicated that inter-facing documents, used by the Maintenance and Health Physics Departments were not coordinated to preclude omissions.
Specifically, Mainten-ance Procedure M7E, Revision 2, " Radioactive Solid Waste Shipment" and Radiation Protection Instruction No. PD-15.7,004, Revision 3,
" Ship-ment of Radioactive Material," established by the licensee to ensure compliance with NRC, DOT and burial site requirements for radioactive waste shipping and disposal, were not coordinated to preclude the following omissions:
a.
Burial site limitations includlag:
limits on free standing water limits for transuranics limits for toxic chemicals limits on absorbed oil methods to determine above b.
Compliance with Applicable Shipping Cask Certificate of Compliance including:
total weight heat loading wood shoring (where necessary) securing of drain lines and access plugs c.
Provisions to provide carriers of exclusive use LSA shipments specific instructions for maintenance of sP'-pment.
d.
Loading instructions for LL-50-100 shipping package.
B.H. Grier 2-11-80 Reply to Item A 1.
In regard to failure to provide and control proper documents:
The cause was a failure to specify the responsi-bility for completing this action in any station Administrative Procedure.
This resulted in vari-aus personnel involved with radioactive waste as-suming the requirement was satisfied.
To correct the situation, a new Administrative Procedure, " Radioactive Waste Program", shall be written to assign responsibilities concern-ing radioactive waste.
The Senior Performance Supervisor-RP (Radioactive Waste Coordinhtor) shall assume the following responsibilities:
a.
Maintain a current copy of all the appli-cable federal regulations relating to radioactive waste.
b.
Review of all procedures pertaining to radioactive waste.
To prevent future items of noncompliance, the Senior Performance Supervisor-RP shall utilize his current copies of federal regulations in reviewing all radioactive waste procedures to ensure that all the requirements are addressed.
Date for full compliance is March 30, 1980.
2.
The identified discrepancies are recognized and the following corrective action shall be initiated:
The cause was a failure to specify the responsi-bility for ensuring that various radioactive waste procedures are reviewed to preclude con-flicts and omissions.
t 1
B.H. Grier 2-11-80 To correct the situation, a new Administrative Procedure, " Radioactive Waste Program", shall require that all procedures pertaining to radio-active waste are reviewed by the Senior Perform-ance Supervisor-RP.
Radiation Protection In-struction PD-15.7.004 shall be revised to refer-ence the use of the applicable burial site limits relative to the items mentioned in Subsection 2a and provide the instructions identified in Sub-section 2c.
Limits on free standing water are addressed in Radiation Prot ~ction Instruction PD-15.7.016, " Securing Demineralizer Operations and Dewatering."
Additional procedures have been developed for each cask utilized at Salem.
These individual procedures reference the requirements of the applicable shipping cask Certificate of Compliance with respect to those items stated in Subsection 2b.
Radiation Protection Instruction PD-15.7.015, "Use of LL-50-100 Shipping Cask",
shall specify the loading instructions for the LL-50-100 shipping cask as identified in Sub-section 2d.
To prevent future items of compliance, the Senior Performance Supervisor-RP shall review all radio-active waste procedures to ensure that all the ap-plicable requirements are properly addressed.
In addition, this review shall include a check for conflicts and duplications.
Date for full compliance is March 30, 1980.
If you require additional information, we will be pleased to discuss it with you.
Sincerely,
/ /
L CC:
Director, Office of Inspection & Enforcement USNRC Washington, D.C. 20555 George H.
Smith, Chief Fuel Facility & Materials Safety Branch Region 1 USNRC 631 Park Avenue King of Prussia, Pennsylvania 19406