ML20082A088
| ML20082A088 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/19/1983 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20082A081 | List: |
| References | |
| NUDOCS 8311180041 | |
| Download: ML20082A088 (3) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET
[ P.O. BOX 8699 v,,
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~ PHILADELPHIA. PA.19101 SHIELDS L. DALTROFF October 19, 1983
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Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/83-19 50-278/83-19 Mr. Thomas T. Martin-Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631' Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter dated September 22, 1983, forwarded combined Inspection Report 50-277/83-19 and 50-278/83-19.
Appendix A addresses two items which do not appear to be in full. compliance with Nuclear Regulatory Commission requirements..These items are restated below along with our response.
A.
Technical Specification 6.4 requires a retraining and replacement training program for.the facility staff meeting the requirements of Section 5.5 of ANSI Kl8.1-1971.
Section 5.5 of ANSI N18-1971 states that means should be provided in the training program for appropriate evaluation of its effectiveness.
Contrary to the above, as of July 22, 1983, means were not provided in the training program for the appropriate evaluation of its effectiveness in that the technical performance of entry level Assistant Technicians is routinely evaluated and documer ted by "C" Level Technicians, who are not qualified in accordance with ANSI N18.1-1971 and are
.f themselves entry level personnel in training.
In such cases the evaluation of training effectiveness afforded to Assistant Technicians is not appropriate.
This is a Severity Level V Violation (Supplement IV).
8311180041 D31109 PDR ADOCK 05000277 G
f Mr. Thomas T. Martin Page 2
Response
This occurrence resulted because the qualification manual did not specifically require that the evaluation of practical factors be completed by an individual with a minimum of Technician "B" qualifications.
The Level "C" Technicians who evaluated and documented the technical performance of the Assistant Technicians were qualified by an internal company qualification program to perform the task they evaluated.
However, they were not qualified under the ANSI N18.1-1971 standard due only to the lack of 2-years experience.
A review of the practical factors will be conducted on those individuals now qualified as Assistant Technicians to ensure that their qualifications have been evaluated by at least a
- "B" level technician.
Where evidence is found that the original training was not verified by Technician "B"
or better qualified. individuals, the affected individuals will be required to re-perform the practical factors and the evaluation of their performance will be by at least a "B"
level technician.
To prevent future occurrences, the qualification manual for 4
Assistant Technicians will be revised to require evaluation by Technician "B" or better~ qualified individuals.
The revision of the qualification manuals and review of Assistant Technicians will be completed by October 31, 1983.
4 B.
10 CFR 50.59, " Changes Tests and Experiments", requires that a licensee perform a written safety evaluation of changes in i
procedures as described in the Final Safety Analysis Report 7
(FSAR).
Chapters 9.2, " Liquid Radwaste System", and 9.3, l.
" Solid Radwaste System", of the FSAR described certain systems and procedures for handling liquid and solid radioactive waste.
l Contrary to the above, since March, 1983, the licensee has processed certain liquid radioactive waste filter sludge and wet solid material having radiation levels as high as 11 rem l
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per hour by a cement solidification and processing procedure thct is not described in the FSAR, without a written safety evaluation providing the bases that the change in the procedure did not involve an unreviewed safety question.
This is a Severity Level IV violation (Supplement IV).
Mr. Thomas T. Martin Page 3
Response
Because of the simplicity of this solidification process and because of an oversight in not reviewing the Final Safety Analysis Report, a safety evaluation was not performed.
Until the safety evaluation is completed, this method of solidification has been terminated.
The cement solidification process is an accepted means of disposing of radioactive waste and this process has been used by others in the industry.
Because of its effectiveness, Philadelphia Electric Company plans to resume this process as a normal solidification method for disposal of radioactive waste.
Should you require additional information, please do not hesitate to contact us.
Very truly yours, y.f
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itL LL~l f cc: A. R. Blough, Site Inspector i
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