ML20210A053

Ack Receipt of Re Violations Noted in Insp Repts 50-277/86-21 & 50-278/86-22.Violation Re Misclassification of Shipment 119-86 Withdrawn Due to Addl Info.Recommends Addl Mgt Attention to Document Distribution Sys

ML20210A053
Person / Time
Site:	Peach Bottom
Issue date:	04/27/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20210A058	List: ML20210A053
References
NUDOCS 8705050001
Download: ML20210A053 (6)

See also: IR 05000277/1986021

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APR 2 7 1387

Docket Nos. 50-277

50-278

Philadelphia Electric Company

ATTN: Mr. J. W. Gallagher

Vice President

Nuclear Operations

2301 Market Street

Philadelphia, Pennsylvania 19101

Gentlemen:

Subject: Combined Inspection 50-277/86-21 and 50-278/86-22

Your letter dated March 30, 1987 summarized the results of your review of

radwaste shipments as we had requested in our letter dated November 20, 1986.

Thank you for providing the results of that review, the corrective actions

taken regarding activities in your radwaste shipments and your additional

corrective actions taken since your letter dated December 31, 1986. The

actions described in your letters dated December 31, 1986 and March 30, 1987

will be examined during a future inspection of your radwaste program.

In reviewing your letter dated March 30, 1987, we noted that your review had

found additional details concerning the apparent misclassification of your

Shipment No. 119-86. Although your letter dated December 31, 1986 concurred

with the misclassification finding, the new information in your letter dated

March 30, 1987 shows that the 10 CFR 61.55, Table 1 value of 0.8 curies per

cubic meter was not exceeded in the shipment. As a result, classification

based on 10 CFR 61.55, Table 2 was appropriate and the shipment was actually

Class B as you had originally determined. Since the radionuclide data used in

determining the original classification indicated that Shipment No.119-86 was

Class C, it was fortuitous that the waste manifest correctly classified

Shipment No. 119-86 as Class B. In view of this new information uncovered by

you regarding Shipment No.119-86, we have determined that our Violation for

this shipment is no longer valid. We are withdrawing the Violation regarding

misclassification of Shipment No.119-86 (Item C of Appendix A to letter dated

November 20,1986) and will change our records to indicate this.

The process by which your original classification was made was done

incorrectly as you failed to follow Procedure HP0/60-17C. This type of

problem would normally be classified as a violation at the Severity V level

(10 CFR 2, Appendix C). However, since it meets the criteria of 10 CFR 2,

Section V.A for self-identification and correction of problems, we choose to

exercise our discretion and not issue a notice of violation in this case. It

should be emphasized that it was not until you reviewed the history of past

shipping records, as a result of our request, did you find the additional

details. In light of this, you should place additional management attention

on your document distribution system to ensure that the best information is

available for determination of conformance with regulatory requirements,

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8705050001 870427 /

PDR ADOCK 05000277

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Philadelphia Electric Company 2

In view of the corrective and preventive actions documented in your letters

dated December 31, 1986 and March 30, 1987, no reply to this letter is

required.

Your cooperation with us is appreciated.

Sincerely,

Orisi'mlCI TE3

T mas T. Martin,

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ivision of Radiation Safe y

[ and Safeguards

cc:

R. S. Fleischmann, Manager, Peach Bottom Atomic Power Station

John S. Kemper, Senior Vice President, Engineering and Production

W. H. Hirst, Director, Joint Generation Projects Department, Atlantic Electric

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G. Leitch, Nuclear Generation Manager

Troy B. Conner, Jr., Esquire

Eugene J. Bradley, Esquire, Assistant General Counsel

Raymond L. Hovis Esquire

Thomas Magette, Power Plant Siting, Nuclear Evaluations

W. M. Alden, Engineer in Charge, Licensing Section

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

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RegionIDocketRoom(withconcurrences)

DRP Section Chief

Robert J. Bores, DRSS

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PHILADELPHI A ELECTRIC COMPANY '

23o1 M ARKET STREET

P.O. 80X 8699

PHILADELPHIA. PA.19101

(2158 841 5001

JO S E Pe4 W,GALLAGHER

March 30, 1987

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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: Document Control Center

Washington, D.C. 205S5

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 Hos. 50-277/86-21; 50-278/86-22 for Peach  !

Bottom Atomic Power Station, requested Philadelphia Electric

Company (PECo)

to respond to two items which did not appear to be

in full compliance with Nuclear Regulatory Commission

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 i

in the Reference (1) letter. i

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The original shipping papers for Shipment No. 45-86

reported a total activity of 320.12 millicuries (mC1). i

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Based on updated scaling factors received from our vendor

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Mr. Thomas T. Martin March 30, 1987

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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 mci) and Nickel-63 (6.63

mci). Therefore, the revised activity for Shipment No. 45-

86 is 494.46 mci. The waste classification for this

l shipment will remain as Class A - Unstable, as originally

l 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

j are required for any other isotopes. The burial sites will

l be contacted to ensure that the shipping records reflect

the additional activity.

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11. 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

l 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

l No. 119-86, it was learned that a Carbon-14 (C-14) value

l 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

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Mr. Thomas T. Martin' March 30 0 1987

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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

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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

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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.

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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

tactors 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 i

October 23, 1986.

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' March 30, 1987

Mr. Thomas T. Martin

' Page 4

There were 59 DAW and solidified oil shipments made during

i 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-SS 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

(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,

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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

1 information, please do not hesitate to contact us.

!,

Very truly yours,  ;

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Attachments  !

cc: Addressee (

l P. Johnson, Senior Resident Inspector

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