ML20234D939
| ML20234D939 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/30/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-209, NUDOCS 8801070330 | |
| Download: ML20234D939 (3) | |
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800 Boylston Street Beston, Massachusetts 02199 Ralph G. Bird Senior Vice President - Nuclear December 30, 1987 BECo Ltr. #87-209 U.S. Nuclear. Regulatory Commission Attention: Document Control Desk Hashington, DC 20555 License No. DPR-35 Docket No. 50-293
Subject:
NRC Inspection Report 50-293/87
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.
h -
R.G.
ird RJW/la Attachment cc: Regional Administrator USNRC - Region I 631 Park Avenue King of Prussia, PA 19406 Senior Resident Inspector - Pilgritt Nuclear Power Station 6
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8801070330 871230 ADOCK0500g3 PDR 0
ATTACHMENT Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation A 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 radionuclides 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.
Besoonse 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 Management 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 _Th en to Avoid Future Viola.tioni BECo Haste Management and Nuclear Computer Applications Department (NCAD) l are automating as much as possible the documentation process for the thipment of radioactive waste. Automation will reduce the likelihood of a transcription error.
l Rigorous training is being performed on the " Preparation of Shipment Documentation" by BECo Haste Management and Nuclear Training Section.
In j
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 Comoliance Has Achieved Full compliance was achieved on October 7, 1987 when the shipping manifest rias corrected.
f:otice of Violation B B.
10CFR71.5(a)(1)(vi) requires that shipping papers be prepared in accordance with 49CFR172, Subpart C.
49CFR172.203(d)(i) requires the name of each radionuclides in the shipment and 49CFR172.203(d)(iii) 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 burial 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 radionuclides.
In addition, the shipper's statement was in error.
Resoonse 1.
Corrective Steos Taken and Results Achieved The cause of this violation was a judgmental decision, based on industry standards at that timp to not include Fe55 in 10CFR61 and curie calculations when FeSa,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.
2.
Corrective Staps Taken t0_6y_Qid Future Violations A procedural change, PNPS Procedure No. 6.9-160 was put in place, October 2, 1986, which included Fe55 in the calculations and in manifesting.
3.
Date When Full Comoliance Has Achieved Full compliance was achieved on October 2, 1986 when Procedure 6.9-160 was issued to require Fe55 be included in the manifest and curie calculations.
There are no plans to backfit manifests prior to September 1986.
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