ML20092J151
| ML20092J151 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/30/1984 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20092J130 | List: |
| References | |
| NUDOCS 8406260369 | |
| Download: ML20092J151 (4) | |
Text
PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A PA.19101 SHIELDS L. DALTROFF
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May 30, 1984 Docket Nos. 50-277 50-278 Inspection No. 50-277/84-09 50-278 /84-09 Mr. Thomas T. Martin, Director Division of Project and Resident Programs U.S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Martin:
Your letter of A 30, 1984, f orwarded combined Inspection Report 50-277 /pril 84-09 and 50-278 /84-09.
The report cited three apparent violations of NRC requirements.
Thi s 1 et t er will restate the violations and provide our responses.
A.
10 CPR 61. 57, " Labeling", states "Each package of waste must be clearly labeled to identify whether it is Class A waste, Class B waste, or Class C waste in accordance with paragraph 61.55."
Contrary to the above, on March 5, 1984, and March 6f 1984, the licensee made two shipments of licensed waste material to
- Barnwell, South Carolina and twenty-three packages containing the waste were improperly classified as Class A waste.
The isotopic analysis of the was t e mat eri al indi cat ed that the waste should have been identified as Class B waste.
Thi s i s a S everi ty Level IV violati on ' (Suppl ement V).
8406260369 840618 PDR ADOCK 05000277 G
Mr. Thomas T. Marti n May 30, 1984 Page 2 of 4 Respons e 10 CF R. 61. 55 r equi res c las s A was te t o have a C esi um-137 concentration of less than 1 curie per cubic meter.
The
-isotopic analysis data f or the March 5 and March 6 waste shipments indicated that the Cesius 137 concentration was 0.13 curies per cubic meter above that limit.
Although this information was correctly presented on the data sheets, the individual perf orming the review f ailed to note that the Cesium 137 concentration was above the level used as the cutof f cri teria f or Class A waste.
When notified by the Barnwell Waste Management Facility that the March 6 shipment had been mislabeled, Philadelphia Electric Company immediately re-evaluated recent isotopic analysis data and informed Barnwell t. hat the March 5 ahipment was also improperly classified.
Subsequently, two other shipme nts, one on March 19 and one on March 20, were found to be similarly mislabled.
Notifications were also made of these violations.
This violation was primarily caused by personnel error.
To avoid f urther violations, the individual has been ' counseled on the importance of the classification process and the need for caref ul review of the data sheets.
In addi tion, a major revision to procedure "C.O.L. HPO/00 71F-1 Burial S ite Criteria for Barnwell, South Carolina", has been canpleted to provide more precise shipping information.
Prior to the revision, this procedure did not present an adequate explanation of the data review process.
The procedure was revised to provide step by step guidance on the review of the isotopic analysis sheets to properly classif y and label a waste shipment.
Addi tionally, the procedure now requires review by 2 qualified individuals bef ore a waste shipment can be r eleased.
The' procedural deficiencies were identified and the corrective actions described in this response were completed pri or t o t he i ns pe ct or' s revi ew of thi s ar ea.
B.
10 CFR 71.105(d ) s tates "....The program shall provide f or indactrination and training of personnel performing activities af f ecting quality as necessary to assure that suitable proficiency is achieved and maintained."
Mr. Thom as T. Mar ti n May 30, 1984 Page 3 of 4 Centrary to the.above, the Radioactive Material Coordinator involved in the two shipments of licensed waste material made on March 5, ~ 1984, and March 6, 1984, had not received any docusented indoctrination and training in the Nuclear Regulatory Commission or the Department of Transportation Regulations to assure that suitable proficiency was achieved and maintained.
This is a Severity Level IV violation (Supplement V).
Respons a
'The Radioactive Material Coordinator involved in the March 5 and March 6 radwaste shipments attended a Regulatory Awareness Training Course held at Peach Bottom Atomic Power Station on October 18 - 19, 1982.
Attendance at this training was documented in the Health Physics and Chemistry training records.
This course did not, however, discuss the requirements of 10 CPR Part 61.
Philadelphia Electric Company realized this prior;to the inspector's review of this area and had arranged f or a training session by Hittman -
Wes tinghouse, which was held on March 27, 1984.
This training was attended by the personnel involved in the f our mislabeled shipments including the Radioactive Materials Coordinator.
This training emphasized the special burial site criteria for Barnwell, S.C. and the requiremenH of 10 CFR Part 61.
The Radioactive Material Coordinator also attended a -course on Regulatory Awareness Training given by Chem-Nuclear Sys tem s, Inc. f rom May 21 thru May 24, 1984,' at Peach Bottom Atomic Power Station.
This course covered radwaste and radioactive material preparation, handling and shipping.
-To prevent recurrence and to maintain the proficiency of the Radioactive Material Coordinator, a training session will be repeated once per year.
'C.
10 CFR.2 0. 311( c ) s tat es, "Each manif est must include a certification by the waste generator that the transported materials are properly classified, described, packaged, marked, and labeled and as are 'in proper-condition for transportation..."
O Mr. T$naas T. Marti n May 30, 1984 Page 4 of 4 Ccntrary to the above, on March 5, 1984, and on March 6, 1984, the shipment manif est of the two waste shipments made on these days were signed by a shif t supervisor certifying that the twenty-three containers in the shipments were properly classified, when in f act the contalners were not properly classified.
Thi s i s a S everi ty L evel V violati on (Supplement V).
Res pons e Thi s vi ol ati on w as ca us ed be caus e pro cedur e, " C.O. L.
HP O/ CO
.71F-1, Burial Site Criteria for Barnwell, South Carolina",
did not provide the Shif t Supervisor with enough detail about
~
the isotopic analysis data to immediately identif y a 10 CFR Part 61 Class A waste discrepancy.
As a result, the C esi um-137 concentration, which slightly exceeded the Class A waste cri teria, was not identified during his review.
To prevent recurrence, the procedure has been revised as described in the response to Violation A.
This revision should ensure that the waste classifications are correctly reviewed and specified for f uture waste shipments.
If you need any additional inf ormation, please do not hesitate to contact us.
Very truly yours,
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