ML20209C918
| ML20209C918 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 04/20/1987 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Corbin McNeil Public Service Enterprise Group |
| References | |
| NUDOCS 8704290112 | |
| Download: ML20209C918 (2) | |
See also: IR 05000354/1987002
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APR 2 0 1987
Docket No. 50-354
Public Service Electric & Gas Company
ATTN: Mr.
C. A. McNeill, Jr.
Vice President - Nuclear
P.O. Box 236
Hancocks Bridge, New Jersey 08038
Gentlemen:
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Subject:
Inspection No. 50-354/87-02
This refers to your letter dated March 13, 1987, in response to our letter
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dated February 12, 1987.
Thank you for informing us of the corrective and preventive actions documented
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in your letter. These actions will be examined during a future inspection of
your licensed program.
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Your response discussed the issuance of three separate violations for a single
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Severity Level IV problem.
In our Notice of Violation (Appendix A to Inspec-
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tion Report No. 50-354/87-02), we recognized the common problem involved and
treated the violations as a single aggregate problem. However, Public Service
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Electric and Cas Company has responsibilities under 10 CFR 20.311 as a radio-
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active waste generator and under 10 CFR 71 and Title 49 as a radioactive ma-
terials shipper. Although the requirements are similar, separate violations
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occurred in preparation of the radioactive waste manifest and certifications.
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We believe that we have adequately and fairly assessed the problem as a single
Severity IV problem with three violations.
Your cooperation with us is appreciated.
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Sincerely,
Original Si n d By:
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ivision of Radiation Sa ty
and Safeguards
cc:
R. S. Salvesen, General Manager, Hope Creek Operations
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A. E. Giardino, Manager, Station Quality Assurance
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W. H. Hirst, Manager, Joint Generation Projects Department, Atlantic
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Electric Company
L. A. Reiter, General Manager - Licensing and Reliability
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Rebecca A. Green, Bureau of Radiation Protection
]
Public Document Room (PDR)
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Local Public Document Room (LDDR)
p/f
OFFICIAL RECORD COPY
RL HC 87-02 - 0001.0.0
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04/14/87
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8704290112 870420
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Public Service Electric & Gas Co.
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cc: continued
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
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State of New Jersey
bcc:
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Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief
Robert J. Bores, DRSS
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0FFICIAL RECORD COPY
RL HC 87-02 - 0002.0.0
04/14/87
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PuCLc Service
Electr.c and Gas
Company
Cerbin A. McNeill. Jr.
Pub..c Serv ce E'ectoc and Gas Company P O Box 236 Mancocks Br.cge t4.iC8038 609 339 45%
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N uc'ea*
March 13, 1987
NLR-N87046
U.S. Nuclear Regulatory Commission
Attention:
Document Control Desk
20555
Gentlemen:
NRC INSPECTION REPORT #87-02
DOCKET NO. 50-354
HOPE CREEK GENERATING STATION
Public Service Electric and Gas Company (PSE&G) is in receipt of
your letter dated February 12, 1987, which transmitted a Notice
of Violation concerning a failure to comply with the requirements
of 10CFR20.311 and 10CFR71.5 by incompletely identifying and
quantifying all isotopes present in a radwaste shipment...
thereby incorrectly stating the total activity and improperly
certifying the contents of the shipment.
Hope Creek Generating Station is apparently being charged with
three separate violations (354/87-02-01, 02, and 03) for a sincle
Severity Level IV problem that involves redundant requirements
appearing in several regulations.
We submit that the
application of multiple violations for errors that your February
12, 198 7 letter described as " . . .of a minor technical nature. . ."
imposes an inappropriately severe impact on the station's
Systematic Assessment of Licensee Performance record and that
this failure to comply with essentially the same requirements in
several regulations would be more fairly assessed as one
violation.
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WAR 131987
USNRC Document Control Desk
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Amplification of this concern and our response to the Notice of
violation, pursuant to the provisions of 10 CFR 2.201, are
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provided in Attachment 1.
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Sincerely,
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Attachment
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Dr. Thomas E. Murley, Administrator
USNRC Region I
631 Park Avenue
King of Prussia, PA
19406
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USNRC Resident Inspector
P.O. Box 241
Hancock's Bridge, NJ
08038
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ATTACHMENT 1
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10 CFR 2.201 INFORMATION
PUBLIC SERVICE ELECTRIC AND GAS COMPANY
HOPE CREEK GENERATING STATION
RESPONSE TO NOTICE OF VIOLATION
INSPECTION REPORT NUMBER 50-354/87-02
In your letter dated February 12, 1987, Violation A cited a
failure to comply with the requirements of 10CFR20.311(b) and
(c), which state, in part, that the generator of radioactive
waste must provide, in the manifest accompanying each waste
shipment, the radionuclide identity and quantity and the total
radioactivity of the shipment.
Violation B cited a failure to comply with the requirements of
10CFR71.5(a)(1)(vi) which refers to 49 CFR 172, Subpart C,
shipping paper requirements.
The referenced portions of this
regulation contain basically the same recuirements as those in
Violation A.
1.
PUBLIC SERVICE ELECTRIC AND GAS COMPANY DOES NOT DISPUTE THE
VIOLATIONS.
HOWEVER, IT APPEARS THAT ONE SHIPPING PROBLEM
WHICH LED TO IMPROPER COMPLIANCE WITH SEVERAL PARALLEL
REGULATORY REQUIREMENTS IS, IN THE NOTICE OF VIOLATION, BEING
IDENTIFIED AS TWO VIOLATIONS, " CATEGORIZED IN THE AGGREGATE
AS . . . (ONE ) . . . PROBLEM" , AND IS ADMINISTRATIVELY REING CHARGED
AGAINST THE HOPE CREEK STATION AS THRER VIOLATIONS
(354/87-02-01, 354/87-02-02, AND 354/87-02-03).
WE ARE
CONCERNED THAT THIS ADMINISTRATIVE ASSESSMENT IS OVERLY
SEVERE AND REQUEST THAT THE INCOMPLETE IDENTIFICATION,
OUANTIFICATION AND CERTIFICATION OF THE SUBJECT RADIOACTIVE
WASTE SHIPMENT BE CONSIDERED AS ONE VIOLATION.
2.
THE ROOT CAUSE OF THE VIOLATION WAS PERSONNEL ERROR WHEREIN
THERE WAS INADEOUATE TRANSFER OF INFORMATION BETWEEN THE
WASTE GENERATOR FOR THE SHIPMENT (HOPE CREEK GENERATING
STATION) AND THE SHIPPING STATION (SALEM GENERATING STATION).
SHIPMENT-SPECIFIC ISOTOPIC DATA FROM GAMMA SPECTROSCOPY WAS
GENERATED BY HCGS PERSONNEL.
HOWEVER, THE DATA WAS
TRANSFERRED TO SGS IN A FORMAT THAT WAS UNFAMILIAR TO SGS
PERSONNEL WHO INCORRECTLY ASSUMED THAT THE " DOSE-TO-CURIE"
OPTION OF THE RADMAN COMPUTER PROGRAM, AS USED FOR SGS, WAS
THE ACCEPTABLE METHOD FOR HCGS WASTE CLASSIFICATION AND
MANIFESTING AS WELL.
THE OMISSION OF SHIPMENT GAMMA
SPECTROSCOPY DATA WAS THE RESULT OF POOR COMMUNICATIONS
BETWEEN THE STATIONS REGARDING THE SPECIFICS OF THE EXECUTION
OF THE INTERFACE AGREEMENT.
THE LATE DISCOVERY OF THE ERRORS
(AFTER SHIPMENT) WAS THE RESULT OF A LACK OF PROPER OUALITY
VERIFICATION PRIOR TO SHIPMENT BY RADIATION PROTECTION
PERSONNEL AT BOTH STATIONS.
PRIOR TO NRC INSPECTION
354/87-02, HCGS REVIEWED SHIPMENT MANIFEST AND GAMMA
SPECTROSCOPY DATA AND CONCLUDED THAT A PROBLEM EXISTED IN THE
EXECUTION OF THE SHIPMENT INTERFACE AGREEMENT AND AN
INVESTIGATION WAS IN PROGRESS.
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ATTACHMENT 1
3.
IMMEDIATE CORRECTIVE ACTIONS
Upon discovery of the errors in the shipments, shipment of
HCGS radwaste was immediately suspended by the Radiation
Protection / Chemistry Manager until all necessary remedial
action was taken to permit proper classification and
manifesting.
A comprehensive review was made of all seven
shipments to diagnose the interface mechanics that
contributed to the errors.
A thorough database review was
accomplished incorporating gamma spectroscopy data from
several months of radwaste information.
Based on this
review, an updated database analysis report was generated
using site-specific gamma spectroscopy data.
A task team was
assembled to correct the interface mechanics.
On January 30,
1987, the radwaste shipping interface agreement between HCGS
and SGS (copy attached) was fully executed.
4.
CORRECTIVE ACTIONS IN PROGRESS
A transfer flow chart matrix was developed to assist in the
preparation of new procedures covering all interface
mechanics.
The four procedures developed to support radwaste
shipment activities are
RP 902
Radioactive Waste Sampling And Classification
RP 903
Operating Instructions for RADMAN
RP 904
Dose / Curie Conversion Calculations
RP 905
Transfer of Radioactive Waste To SGS
These procedures will be fully implemented prioc to
commencement of radwaste shipments from HCGS.
The procedures
and the attached agreement should close Inspection Open Item
354/86-44-02.
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5.
WE WILL BE IN FULL COMPLIANCE BY MARCH 30, 1987 OR PRIOR TO
RESUMPTION OF RADWASTE SHIPMENTS FROM HOPS CREEK GENERATING
STATION, WHICH EVER IS EARLIER.
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LETTER OF AGREEMENT
BETWEEN
HOPE CREEK
GENERATING STATION
AND
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SALEM NUCLEAR
GENERATING STATION
ON
RADIOACTIVE MATERIALS SHIPMENTS
January 30, 1987
Revision 0
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RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEHENT
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PURPOSE
As agreed in the fall of 1985 Salem Nuclear Generating
will accept packaged radioactive waste from
Station (SNGS)
SNGS will then be
Hope Creek Generating Station (HCGS).
In addition SNGS
responsible to ship and bury the waste.
will provide for radioactive material shipments of otherThis document de
than waste as needed by NCGS.
the HCGS and the
Station responsibilities for both SNGS,
Site Services Department to support radioactive material
shipments from a single Nuclear Department program.
SCOPE
forth in this document are applicable to
The guidelines set
all radioactive material shipments originating from HCGS
unless specific instances require exemptions as agreed to by
the Radiation Protection / Chemistry Managers of SNGS and
Irradiated fuel in any form is specifically not
HCGS.
included in this agreement.
PHILOSOPHY
Shipments of radioactive materials originating from HCGS
will rely on the expertise and experiences of SNGS to reduce
the chances of making errors common to the complexity of
Regulatory requirements.
To this end, all shipments of radioactive materials from
Artificial Island will be consigned from SNGS.
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RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMENT
RESPONSIBILITIES
General
1.
Possession of radioactive materials will transfer to
SNGS for shipment.
Ownership of the material will remain
with HCGS.
2.
Selection of specification shipping containers will be
performed by HCGS with SNGS concurrence.
Where prior
concurrence has been granted, that agreement shall remain
until specifically revoked by SNGS.
3.
Materials will be packaged in shipping containers by
HCGS at their facility.
4.
Documentation sufficient to properly classify, mark,
label , and manifest the material will be provided by HCGS
to SNGS in the format specified by SNGS procedures.
It is
recognized that some preliminary classification of materials
cust be performed by HCGS to properly select containers.
5.
All external communications from the Stations in
regard to radioactive shipments will be performed by SNGS.
HCGS will be involved with external communications only when
requested by SNGS, with the exception of Limited Quantity
Shipments made by HCGS.
6.
Radiation surveys of packages will be performed by
at contact and at one meter from the surface of the
package, using a calibrated ion chamber instrument.
Additional readings, as required by Regulations, will be
performed by HCGS while packages remain at HCGS.
Contamination surveys will be performed by HCGS, employing
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methods capable of detecting HCGS site
release limits
(1000 dpm/100 sq cm beta gamma or 20 dpm/100 sq cm alpha
loose contamination, and less than 80% of Federal radiation
limits for shipment).
Results of these surveys will be
included in the documents accompanying the materials prior
to transfer to $NGS.
7.
Packages which do not meet the site release limits
will be decontaminated to the maximum extent practical by
HCGS.
If release limits cannot be met, but contamination is
within regulatory limits, the material may be transferred to
SNGS at their concurrence.
8.
Materials to be shipped will be transferred by HCGS to
SNGS on an as-generated basis under normal conditions.
SNGS
will continue to accept materials from HCGS, provided that
the materials can be shipped offsite.
Packages will only be
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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMENT
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transferred to SNGS during normal work hours (0900 to 1530,
Monday through Friday) unless specifically agreed to by
SNGS.
SNGS will provide personnel to accept packages when
scheduled with HCGS.
Site Services will assist with the
transfer of materials from HCGS to SNGS.
They will also
assist SNGS with shipments off site.
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HCGS will assure that packages are undamaged prior to
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transfer.
Minor damages incurred during transport to SNGS
will be corrected by SNGS.
Packages damaged, or otherwise
rendered unshippable, after transfer to SNGS will be
restored to a shippable configuration by SNGS.
10.
SNGS reserves the right to inspect, refuse acceptance,
and/or to return to HCGS, any package or material which is
not in a form acceptable for shipment.
11.
HCGS will perform specification marking and labeling
of packages for routine shipments.
In specific instances,
SNGS may change the markings or labeling of a package in
order to meet regulatory requirements.
12.
Materials transferred to SNGS will be loaded onto the
final shipping vehicle by SNGS in accordance with their
procedures.
In the event that materials to be shipped have
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been stored at HCGS (e.g., a large accrual due to burial
site closure) and shipment of those materials is to occur,
HCGS personnel will load the shipment under the direction
of SNGS using SNGS approved procedures.
13.
HCGS will perform waste stream sampling and analysis
to meet waste classification requirements.
This will be
performed in accordance with the HCGS Process Control
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All data
program and SNGS approved procedure requirements.
concerning waste types shall be gathered by and approved by
HCGS.
The applicable forms (Radman computer loading forms)
shall be completed by HCGS and foruarded to SNGS to be
entered into the computer data base.
All computer generated
data base reports shall be reviewed and approved by HCGS and
SNGS prior to use.
The
14.
Manifesting shipments will be performed by SNGS.
computer generated manifest is produced using the data
supplied and approved by HCGS.
(This includes Radman data
base information as well as survey datal.
Updated survey
data may be used due to radioactive decay considerations.
15.
In the event that long-term storage (e.g., greater
than the time required to accumulate a full shipment) is
required due to the inability to ship the material, HCGS
will store radioactive .naterial that they produce.
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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER O
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compacted Waste (Boxes)
Boxes will be marked by RCGS with unique numbers,
which relate to the documentation relevant to each box,The nu
1.
prior to transfer.two digit year followed by a sequential four digit numbe
(YY-XXXX).
HCGS will make every reasonable attempt to maintain
contact dose rates ALARA while optimizing the Volume within
2.
This will include, but is not limited to,
performing surveys of trash prior to compaction, equalizing
each container.
the container to the maximum extent
dose rates throughout
practical and placing high dose items in the center of theSNGS
container where possible.this activity, and make recommendations
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HCGS will meet regulatory and/or burial site
3.requirements for materials shipped in boxes.
Solidified Wastes (drums)
Drums with contact dose rates greater than 400 mrem /hr
will be stored at ECGS until transferred to SNGS in a
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for transfer to a
suitable On-site Storage Container (OSCI)
shipping cask.
mrem /hr at contact will be
Drums with less than 40t
HCGS will load
palletized on 3- or 6-drum pallets by HCGS.
2.
and band drums on pallets such that drums with greater than
200 mrem /hr dose rates are in the center or at one en
the pallet.
HCGS will serialize each drum with a unique number
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which can be traced to the source of the solidifie
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will be provided by HCGS at SNGS request.
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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMEN
Limited Quantity Shipments
HCGS will perform all requirements for Limited
(with the exception
1.Quantity shipments originating from NCGS
of waste shipments for burial) in accordance with
49CFR173.421.
SNGS will provide technical expertise if requested for
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these shipments.
BURIAL SITE ALLOCATIONS
Any waste allocation assigned to PSE&G will be
1.
However,
considered an Artificial Island allotment.
administrative limits will be assigned to each Station upon
receipt of the allocation.
Each Stations' administrative portion of the
2.allocation will be determined in accordance with the system
adopted in The Low Level Radioactive Waste Policy Amendments
for SNGS
Act of 1985.
The following breakdown is the result
and HCGS:
Waste Volume Allocation (ft )
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Year
1986
1987
1988
1989
Total
SNGS
16,960
13,000
14,655
12,000
56,615
2987
30,000
20,000
24,740
77,727
Totals
19,947
43,000
34,655
36,740
134,342
Any overage in 1986 must be subtracted from the remaining
Note:
totals for 1987 through 1989.
If a Station will require a larger waste volume than
3.its administrative portion, that Station may request a
larger portion of the allocation.
To most effectively utiltre burial allocations, wastes
with higher dose rates will be given preferential treatment
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when preparing for shipments.
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Charges and Cost Acccunting
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for
NCGS agrees to be invoiced directly, or charged,
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1.reasonable costs incurrea by SNGS under this agreement.
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These costs include time a.d m*+erials for the transfer,
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loading, documentation and subsequent shipment of the
Any costs due to SNGS inspections (such as
materials.
repackaging required due to an inspection), delays due to
procedural deficiencies and other costs
SNGS equipment or
within SNGS control but outside of HCGS' control will be
borne by SNGS.
HCGS shall budget each subsequent year for costs
associated with transportation and burial of radioactive
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material.
NCGS shall cut a Department Order to SNGS to allow
This will
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charges incurred by SNGS to be charged to NCGS.also
this service provided by SNGS.
Invoices sent to NCGS for signature approval should be
4.processed within three working days of receipt.
Any extra fees which may be incurred for exceeding the
total Artificial Island allocation will be chargeable to the
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exceeding its administrative portion in an
station (s)
equivalent proportion to its excess.
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PROCEDURIS
Each Station will implement this program through
1.written procedures.
Procedures or revisions which address shipment of
2.radioactive materials will be reviewed by both Stations.
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HCGS RADIOACTIVE MATERIALS SHIPMENTS
REVIEWE_D
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Willian Hunkele, Supervisor
fary/Morrill, Supervisor
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Radiation Protection
Radiation Protection
Hope Creek Generating Station
Salem Generating Station
RECOMMENDED:
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A. Russell Lovell, Manager
Johf Trejo, Manager
Utadiation Protection / Chemistry
Ra'ciation Prdiection/ Chemistry
Hope Creek Generating Station
Salem Generating Station
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APPROVED:
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//yfl}f Roger Salvesen, General Manager
John papko, Ge6eral Mar.ager
Hope Creek Generating Station
Salem Generating Station
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Charles John # , General Manager
Alton Thompson /, General Manager
Nuclear Qua Rty Assurance
Nuclear Services
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