ML20196D151

Ack Receipt of Informing NRC of Corrective & Preventive Actions Taken to Correct Violations Noted in Insp Rept 50-293/87-35.Actions Will Be Examined During Future Insp of Licensed Program

ML20196D151
Person / Time
Site:	Pilgrim
Issue date:	02/10/1988
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Bird R BOSTON EDISON CO.
References
NUDOCS 8802170031
Download: ML20196D151 (2)

See also: IR 05000293/1987035

Text

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FEB 101998

Docket No. 50-293 License No. DPR-35

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Boston Edison Company  ;

ATTN: Ralph G. Bird

Senior Vice President - Nuclear

800 Boylston Street ,

Boston, Massachusetts 02199

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Gentlemen:

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Subject: Inspection 50-293/87-35

This refers to your letter dated December 30, 1987, in response to our letter

dated December 10,'1987.

Thank you for informing us of the corrective and preventive actions documented '

in your letter. These actions will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated.

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Sincerely.

Orcinal Signed By:

henald R. Bellamy

Thomas T. Martin, Director

Division of Radiation Safety

and Safeguards

l CC: i

K. P. Roberts, Nuclear Operations Manager

Paul Levy, Chairman, Department of Public Utilities

Chairman, Board of Selectmen

Plymouth Civil Defense Director

J. D. Keyes, Boston Edison Regulatory Affairs and Programs  ;

E. D. Robinson, Nuclear Information Manager

R. N. Swanson, Nuclear Engineering Department Manager

The Honorable E. J. Markey

Senator Edward P. Kirby

The Honorable Peter V. Forman

l Sharon Pollard, Secretary of Energy Resources .

Peter W. Agnes, Assistant Secretary of Public Safety,  !

j Commonwealth of Massachusetts

Rachel Shimshak, MASSPIRG

Public Document Room (PDR)  ;

Local Public Document Room (LPOR)  !

Nuclear Safety Information Center (NSIC) i

, NRC Resident Inspector 1

Commonwealth of Massachusetts (2)

nerICIAL RECORD COPY PIL REPLY LTR 87-35 - 0001.0.0

8802170031 880210 _ 02/04/88 ' r=

PDR ADOCK 05000293 34

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Boston Edison Company 2

FEB101939

bec:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP

R. Wessman, PM, NRR

PA0 (2) SALP Reports Only

Robert J. Bores, DRSS

S. J. Collins, DRP

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Bicehouse Pasciak Bellamy

2/3 /88 2/d7 /88 2/3 /88

0FFICIAL RECORD COPY PIL REPLY LTR 87-35 - 0001.1.1

02/01/88

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sosawmsaw

Executive Offices

800 Boriston street

Boston, Massachusetts 02199

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Ralph G. Bird

sener vKe President - Nuclear

December 30, 1987

BECo Ltr. #87- 209

U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, DC 20555

License No. OPR-35

Docket No. 50-293

Subject: NRC Inspection Report 50-293/87-35

Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation

, contained in the subject inspection report.

Please do not hesitate to contact me directly if you have any questions.

.

) _-

,

R.G. Bird

RJW/la

Attachment

cc: Regional Administrator

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USNRC - Region I

631 Park Avenue

King of Prussia, PA 19406

Senior Resident Inspecter - Pilgrim Nuclear Power Station

.

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AIIACHMENT

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Boston Edison Company Docket No. 50-293

Pilgrim Nuclear Power Station License No. OPR-35

Notice of Violation J

A. 10CFR20.311 (b) requires, in part, that each shipment of radioactive waste

to a licensed land disposal facility must be accompanied by a shipping

manifest which indicates as completely as practicable the radionuclide

identity and quantity and the total radioactivity of the shipment.

10CFR20.31(c), requires, in part, that the manifest must include a

certification by the waste generator that the transported materials are

properly described.

Contrary to the above, on or about June 27, 1986, licensee's shipment No.

86-44 was accompanied by a shipping manifest which indicated that the

total radioactivity was 0.1 millicurie when the activity was 120.8

millicuries. Further, the certification which accompanied the manifest '

was also in error.

Resconse

1. Corrective Steos Taken and Results Achieved

The cause of this violation was a transcription error in the exponent from

the worksheet to manifest. The manifest received at Barnwell Haste

Hanagement Facility was initially corrected per telephone conversation on

approximately June 29, 1986. The initial corrections were incomplete and

final corrections were made after an additional phone conversation on

approximately October 7, 1987.

2. Corrective Steos Taken to Avoid Future Violations

BECo Haste Hanagement and Nuclear Computer Applications Department (NCAD)

are automating as much as possible the documentation process for the

shipment of radioactive waste. Automation will reduce the likelihood of a

transcription error.

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Rigorous training is being performed on the "Preparation of Shipment '

Documentation" by BECo Waste Management and Nuclear Training Section. In

addition, a copy of the Notice of Violation has been forwarded to the

Training Section for consideration in this training program.

BECo Quality Control Group is now formally included in the review of

shipment documentation prior to the release of any radioactive shipment in

accordance with PNPS Nuclear Operations Procedure 87RC-1. This formal

review was implemented on October 1, 1987 and provides additional

assurance of shipping manifest accuracy.

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, ATTACHMENT (Cont.)

3. Date When Full Como11ance Was Achieved

Full compliance was achieved on October 7,1987 when the shipping manifest

was corrected. . . .

Notice of Violation B '

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B. 10CFR71.5(a)(1)(vi) requires that shipping papers be prepared in

accordance with 49CFR172, Subpart C. 49CFR172.203(d)(1) requires the .1e

of each radionuclide in the shipment and 49CFR172.203(d)(111) requires the

activity of each package in the shipment be included in the shipping

papers. 49CFR172.204(a)(1) requires a statement that the shipment is

properly described in the shipping papers.

Contrary to the above, on or about May 1, 1986, licensee's shipment No.

86-34 was sent to a b'urial site which contained several radionuclides

including Iron-55 and the shipping papers did not include the identity of

Iron-55 and the activity resulting from the radionuclide. In addition,

the shipper's statement was in error.

Resconse

1. Corrective Steos'Taken and Rasults Achieved

The cause of this violation was a judgmental decision, based on industry

standards at that time to not include Febb in 10CFR61 and curie

calculations when Fe55,was known to be constituent of the waste stream.

It was felt that since Fe55 is a beta emitter, its effect outside the

package was negligible, therefore not needed to be included on the

manifest. This decision was reversed in mid 1986 based on internal audit

which recommended including Fe55 on the manifest.

A procedural change was put in place October 2, 1986 which included Fe55

in the calculations and in manifesting.  ;

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2. Conective Steos Taken to Avoid Future Violations ,

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A procedural change, PNPS Procedure No. 6.9-160 was put in place, i

October 2, 1986, which included Fe55 in the calculations and in l

manifesting. '

3. Date When Full Comoliance Was Achieved

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Full compliance was g$ehieved on October 2, 1986 when Procedure 6.9-160 was

issued to require fed be included in the manifest and curie

calculations. There are no plans to backfit manifests prior to September

1986.

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