ML20210A053
| 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: |
| References | |
| NUDOCS 8705050001 | |
| Download: ML20210A053 (6) | |
See also: IR 05000277/1986021
Text
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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this shipment is no longer valid.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
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
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ADOCK 05000277
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Philadelphia Electric Company
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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
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T mas T. Martin,
ecto
[
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
G. Leitch, Nuclear Generation Manager
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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
H. Bicehouse, DRSS
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0FFICIAL RECORD COPY
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PHILADELPHI A ELECTRIC COMPANY
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23o1 M ARKET STREET
P.O. 80X 8699
PHILADELPHIA. PA.19101
(2158 841 5001
JO S E Pe4 W,GALLAGHER
March 30, 1987
- ' ~.".'::,",'...
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
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
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in the Reference (1) letter.
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I.
The original shipping papers for Shipment No. 45-86
reported a total activity of 320.12 millicuries (mC1).
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
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shipment will remain as Class A - Unstable, as originally
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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.
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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
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are required for any other isotopes.
The burial sites will
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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
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of non-compliance (Reference 2 letter) concurred with the
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finding.
Subsequently, it has been determined that
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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
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No. 119-86, it was learned that a Carbon-14 (C-14) value
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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
1987
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Page 3
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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
repaired.his equipment, transmitted the C-14 value for the
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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.
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
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classifications for spent resin between August 1,
1985 and
October 23, 1986.
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Mr. Thomas T.
Martin
' March 30, 1987
Page 4
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There were 59 DAW and solidified oil shipments made during
this same time period.
The activity of Iron-55 and Nickel-
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63 which was previously omitted from the manifests was
added to the total activity for the shipments before the
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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.
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Should you have any questions or require additional
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information, please do not hesitate to contact us.
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Very truly yours,
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Attachments
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Addressee
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T.
P. Johnson, Senior Resident Inspector
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