ML20206E091
| ML20206E091 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/30/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| IEIN-86-020, IEIN-86-20, NUDOCS 8704130508 | |
| Download: ML20206E091 (5) | |
Text
0 PHILADELPHIA ELECTRIC COMPANY o
2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA, PA.19101 (2158 841 5001 JOSaPH W. G ALLAGHan March 30, 1987
.. 511.".",*.'.*I,"[.
Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/86-21 50-278/86-22 Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I ATTN:
Dccument Control Center Washington, D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station Units 2 and 3 Supplemental Response to Inspection Report Nos. 50-277/86-21; 50-278/86-22
References:
(1)
- Letter, T.
T. Martin, USNRC, to S. L. Daltroff, PECo, dated November 20, 1986 (2)
Letter, M. J. Cooney, PECo, to T. T. Martin, USNRC, dated December 31, 1986
Dear Mr. Martin:
The Reference (1) letter, which forwarded Combined Inspection Report Nos. 50-277/86-21; 50-278/86-22 for Peach Bottom Atomic Power Station, requested Philadelphia Electric Company (PECo) in full compliance with Nuclear Regulatory Commissionto respond to two ite requirements and to review all radwaste shipments from August 1, 1985 through October 23, 1986 to determine if shipments were misclassified under 10 CPR 20.311 and 10 CPR 61.55.
The Reference (2) letter provided PECo's response to the two items of non-compliance with NRC requirements.
The purpose of this letter is to update you as to the resolution of the two items of non-compliance (involving Shipments 45-86 and 119-86) and to provide the results of our review of the radwaste shipments as requested in the Reference (1) letter.
I.
The original shipping papers for Shipment No.
45-86 reported a total activity of 320.12 millicuries (mci).
Based on updated scaling factors received from our vendor 8704130508 B70330 PDR ADOCK 05000277 10 G
PDR T g.- t) \\
Mr. Thomas T. Martin March 30, 1987 Page 2 in January 1987, the activities of two hard-to-identify isotopes should have been listed on the shipping manifest.
These isotopes are Iron-55 (167.71 mCl) and Nickel-63 (6.63 mci).
Therefore, the revised activity for Shipment No. 45-86 is 494.46 mci.
The waste classification for this shipment will remain as Class A - Unstable, as originally reported.
The burial site will be contacted to ensure that the shipping records for Shipment No. 45-86 reflect the additional activity.
As a result of the violation involving failure to report Iron-55 activity in Shipment No. 45-86 (due to our use of an inappropriate scaling factor), a review was made of all resin shipments, dry active waste (DAW) shipments, and solidified oil shipments between January 1, 1984 (date of implementation of 10 CPR 61) and October 13, 1986 (date of the last DAW / Solidified oil shipment) for the purpose of determining any unreported isotopes.
As a result of our review, it has been determined that no changes are necessary for the resin shipment reports; however, changes are required for the DAW and solidified oil shipments.
There were 152 shipments of DAW and solidified oil made between January 1, 1984 and October 13, 1986.
One set of scaling factors was involved with shipments made between January 1, 1984 and June 1, 1984 (14 shipments) and a second, different set of scaling factors was involved with shipments made between June 1, 1984 and October 13, 1986 (138 shipments).
As a result of our review, it was determined that a total of 620.09 mci of Iron-55 activity went unreported in the group of 14 shipments identified above.
Also, a total of 148.05 curies of Iron-55 activity and 5.89 curies of Nickel-63 activity went unreported in the group of 138 shipments identified above.
No changes are required for any other isotopes.
The burial sites will be contacted to ensure that the shipping records reflect the additional activity.
II.
The original shipping papers for Shipment No. 119-86 reported this shipment as being Class B.
The Reference 1 letter identified this shipment's classification as being an item of non-compliance in that the shipment should have been classified as Class C.
PEco's response to this item-of non-compliance (Reference 2 letter) concurred with the finding.
Subsequently, it has been determined that Shipment No. 119-86 should be classified as Class B waste.
A description of the events which led to this conclusion follows.
In our review of the apparent misclassification of Shipment No. 119-86, it was learned that a Carbon-14 (C-14) value provided by our vendor in May 1985 was not specific for the Peach Bottom samples sent to the vendor at that time, but was in fact a generic value derived by a correlation factor
Mr. Thomas T. Martin March 30, 1987 Page 3 generated from the vendor's computer data base system due to the inoperability of his C-14 counting system.
The transmittal letter from the vendor did indicate that the C-14 value was a generic value.
The vendor, after having repaired his equipment, transmitted the C-14 value for the actual Peach Bottom samples in June 1985.
However, because this transmittal letter was misdirected, the revised value did not reach the Peach Bottom personnel involved with classifying Shipment No. 119-86, resulting in the use of the generic value.
The C-14 values reported in the two vendor reports are significantly different (Generic Value 1.9E00; Peach Bottom Specific Value 9.7E-4).
The difference is attributed to the fact that the generic value was based on routine shipments; however, Shipment No. 119-86 was a special shipment involving fuel pool filters.
The generic value was incorrectly used during the apparent misclassification of Shipment No. 119-86.
Use of the generic value for C-14 would indeed make the shipment Class C waste; however, as stated previously, the unavailable Peach Bottom specific C-14 value should have been used.
Using the Peach Bottom specific C-14 value, Shipment No.
119-86 can be properly classified as Class B waste.
The burial site will be contacted to ensure that the shipment records for Shipment No. 119-86 indicate Class B waste.
To prevent recurrence of the transmittal error, the vendor has been notified that all sample analysis reports are to be sent to the Senior Engineer-Radwaste, a new position established in December 1986 to strengthen our Radwaste Program.
This will ensure that the reports are distributed to the correct personnel in the newly organized Radwaste Group.
III.
In the Reference 1 letter, Philadelphia Electric Company was requested to review all radioactive waste shipments from August 1, 1985 through October 23, 1986 to determine if other shipments were misclassified under 10 CFR 20.311 and 10 CFR 61.55.
The purpose of this section is to provide the results of this review.
There were 358 radioactive waste shipments made between August 1, 1985 and October 23, 1986.
Of the 358 shipments, 299 were spent resin shipments.
A review of scaling factors used during this time period reveals that the factors had remained within an order of magnitude of all previously used scaling factors.
For this reason (based on guidance provided in I.E.
Information Notice 86-20), use of the revised scaling factors does not change the waste classifications for spent resin between August 1, 1985 and October 23, 1986.
Mr. Thomas T. Martin March 30, 1987 Pago 4
.~
There were 59 DAW and solidified oil shipments made during this same time period.
The activity of Iron-55 and Nickel-63 which was previously omitted from the manifests was added to the total activity for the shipments before the classification review was performed.
The concentration of Iron-55 was, in all cases, found to be insignificant for classification purposes (i.e., less than 0.01 times the concentration of that nuclide listed in Table 1 of 10 CFR 61.55 (a)(3)(iv) or 0.01-times the smallest concentration of that nuclide listed in Table 2 of 10 CFR 61.55 i
(a)(4)(v)) based on guidance provided in the NRC's Branch Technical Position on Radioactive Waste Classification.
In the case of Nickel-63, 49 of the 59 shipments were also found to contain concentrations of Nickel-63 in less than significant quantities.
Ten shipments were found to have at least one package that contained concentrations of Nickel-63 that were considered significant for waste classification purposes.
The Nickel-63 Table 2, Class A fraction determined by using the correct scaling factor for the time period between August 1,
1985 and October 23, 1986 was added to the previously calculated Table 2, Class A fraction and in all cases the result was less than unity using the " sum of the fractions rule".
As a result of these calculations, we have determined that all 59 DAW and solidified oil shipments made between August 1, 1985 and October 23, 1986 were properly classified as Class A - Unstable.
Should you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, WY W Attachments cc:
Addressee T.
P. Johnson, Senior Resident Inspector I
i
_