ML20064C804

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Responds to NRC Re Violations Noted in IE Insp Repts 50-277/82-13 & 50-278/82-13.Corrective Actions: Electric Production Dept QA Div Increased Monitoring of Radioactive Matl Shipments & Procedures Will Be Upgraded
ML20064C804
Person / Time
Site: Peach Bottom  
Issue date: 12/08/1982
From: Daltroff S
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20064C760 List:
References
NUDOCS 8301040483
Download: ML20064C804 (4)


Text

r PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215) 848-5001 SHIELDS L. DALTROFF ELecipic en c som December 8, 1982 Re: Docket Nos. 50-277 50-278 l

Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs 1

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

Dear Mr. Martin:

Your letter of November 9, 1982, forwarded combined Inspection reports 50-277/82-13 and 50-278/82-13.

Appendix A addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.

This item is restated below along with our response.

10 CFR 30.41(b) (5) states, that,

. any licensee may transfer byproduct material to any person authorized to receive such byproduct material under l

terms of a specific license issued by.

. an Agreement State."

Section 1.2 of Regulation No. 61-83, " Transportation of Radioactive Waste Into or Within South Carolina",

issued by the South Carolina Department of Health and Environmental Control, an Agreement State, states that,

- 8301040483 821229 PDR ADOCK 05000277 i

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J Mr. T. Martin Page 2 "All persons subject to the provisions of this regulation shall comply with... any disposal facility radioactive material license requirements regarding the packaging, transportation, disposal, i

storage, or delivery of radioactive materials."

i Condition 50 of South Carolina License No. 097, an Agreement State license issued to Chem-Nuclear Systems, Inc., states, "The licensee shall not receive shipments of radioactive materials unless appropriate lifting i

devices

. have been provided and securely attached to containers.

. within a cask."

i Contrary to the above, on March 19, 1982, the Philadelphia Electric Company transferred 1.74 Curies of byproduct material to Chem-Nuclear Systems, Inc., at i

Barnwell, South Carolina, in a container (cask liner) which was not provided with appropriate lifting devices.

1 This is a Severity Level IV violation (Supplement V),

Response

Radioactive waste shipment No. 0382-255, containing feedwater spargers, was shipped on March 17, 1982, to l

Barnwell, South Carolina without any lifting slings attached l

to the liner as a result of two occurrences.

l t

First, the Philadelphia Electric Company issued a purchase order to Chem-Nuclear to provide two liners, and transportation for the shipment of feedwater spargers to their Barnwell, South Carolina site for burial.

The liners were received at Peach Bottom without any lifting slings.

l Philadelphia Electric Company craftsmen loaded the first liner into the cask with slings provided by Peach Bottom Atomic Power Station.

When the operation was complete, the craftsmen removed the slings since they were not provided with the liners.

'Mr. T. Martin Page 3 Second, the cask loading procedure, HPO/CO-71C Appendix H, did not specifically state that the lifting slings were to remain with the liner.

Thus, the check-off-list for the operation did not include a verification that the slings were on the liner.

These two discrepancies resulted in the liner being shipped without any lifting slings.

This particular shipment was unique which undoubtedly contributed to the procedure failing to specifically state that lifting slings were to remain with the liner.

Corrective action included leaving Peach Bottom slings on the second liner when it was loaded into the cask for a later shipment to Barnwell, South Carolina.

Also, the procedure was revised to show that lifting devices must remain with any future liner shipments.

In addition, the radioactive material coordinator will devote more time in observing that subsequent shipments are conducted in accordance with regulatory requirements and that procedures fully implement the regulations.

(

The conference call referenced in the cover letter to l

this inspection report took place one day after the March 17, 1982, cask shipment was made, and prior to its arrival j

at Barnwell where the violation was discovered.

Consequently, corrective measures taken as a result of this call were not in place at the time of this shipment.

In response to the conference call and our commitment to an effective radioactive waste preparation and transportation program, further corrective actions have been taken.

The Electric Production Department Quality Assurance Division, has increased its monitoring on radioactive material shipments from the Peach Bottom site.

A one week

" Regulatory Awareness" seminar was conducted by a Chem Nuclear consultant at the Peach Bottom site and attended by twenty (20) Philadelphia Electric personnel involved in radioactive waste material shipments.

The Peach Bottom Radwaste Handling and Shipping procedures were also reviewed by the consultant and a report was received which is being used to further upgrade the procedures.

~

Mr. T. Martin Page 4 The assignment period of Health Physics technicians and Health Physics Quality Control personnel to radioactive waste shipping activities has been significantly increased.

These personnel are now assigned for six month intervals.

This extended assignment period should increase these individuals' familiarity with preparation and shipping procedures, improving overall performance in this area.

Additionally, a procedure change has been made to require the presence of the radioactive material coordinator or shift supervision during all appropriate radioactive waste shipping activities.

Philadelphia Electric Company believes that these improvements will preclude an event of this nature from recurring and assure compliance with the regulatory requirements.

Very truly yours,

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cc:

R. A.

Blough, Site Inspector Peach Bottom i

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