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| {{Adams | | {{Adams |
| | number = ML20211M088 | | | number = ML20209C918 |
| | issue date = 02/06/1987 | | | issue date = 04/20/1987 |
| | title = Safety Insp Rept 50-354/87-02 on 870112-16.Violations Noted: Failure to Properly Identify & Quantify Fe-59 & Zr-95 in Shipment 86-04,Details 6.1 & 6.4 & Incorrect Certification for Shipment 86-04,Detail 6.1 | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/87-02. Problem Accurately & Fairly Assessed as Single Severity IV Problem W/Three Violations |
| | author name = Bicehouse H, Davidson B, Pasciak W | | | author name = Martin T |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| | addressee name = | | | addressee name = Mcneill C |
| | addressee affiliation = | | | addressee affiliation = PUBLIC SERVICE ELECTRIC & GAS CO. OF NEW JERSEY |
| | docket = 05000354 | | | docket = 05000354 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-354-87-02, 50-354-87-2, NUDOCS 8702270209 | | | document report number = NUDOCS 8704290112 |
| | package number = ML20211M019 | | | title reference date = 03-13-1987 |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | page count = 11 | | | page count = 2 |
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| U.S. NUCLEAR REGULATORY COMMISSION
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| | APR 2 0 1987 Docket No. 50-354 Public Service Electric & Gas Company ATTN: Mr. C. A. McNeill, J Vice President - Nuclear P.O. Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen: |
| | } Subject: Inspection No. 50-354/87-02 This refers to your letter dated March 13, 1987, in response to our letter j dated February 12, 1987. |
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| ==REGION I==
| | , Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of 1 your licensed program. |
| Report N /87-02 Docket No. 50-354 License No. NPF-50 Priority --
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| Category C Licensee: Public Service Electric & Gas Company 80 Park Plaza - 17C Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancocks Bridge, New Jersey Inspection Conducted: January 12-16, 1987 Inspectors: . ,
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| H. J/ Bicehouse, Radiation Specialist date W. (, awl L z14 In B.S.gavison,RadiationSpecialist dage Approved by: [h Uch ) is W.'J. Fasciak, Chief,' Effluent Radiation idat e /
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| Protection Section Inspection Summary: Inspection on January 12-16, 1987 (Inspection Report No. 50-354/87-02)
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| Areas Inspected: Routine, unannounced inspection of the licensee's solid radio-active waste (radwaste) preparation, packaging and shipping program including previously identified items, management controls; quality assurance and imple-mentation of the program during seven (7) shipments in December 198 Results: Within the areas reviewed, the following violations were noted, ( failure to properly identify and quantify iron-59 and zirconium-95 in Shipment 86-04, Details 6.1 and 6.4; and incorrect certification for Shipment 86-04, Detail 6.1).
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| {DR ADOCK 05000354 PDR | | 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-tion Report No. 50-354/87-02), we recognized the common problem involved and |
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| | treated the violations as a single aggregate problem. However, Public Service 4 Electric and Cas Company has responsibilities under 10 CFR 20.311 as a radio- |
| DETAILS 1. ' Persons Contacted During the course of this routine inspection, the following personnel were contacted or interviewe .1 Licensee Personnel
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| *R. W. Beckwith, Station Licensing Engineer, Hope Creek Generating Station (HCGS)
| | active waste generator and under 10 CFR 71 and Title 49 as a radioactive ma-terials shipper. Although the requirements are similar, separate violations j occurred in preparation of the radioactive waste manifest and certification ' |
| *J. Clancy, Principal Health Physicist, Radiation Protection Services
| | We believe that we have adequately and fairly assessed the problem as a single Severity IV problem with three violation Your cooperation with us is appreciate ' |
| *G. C. Connor, Operations Manager, HCGS
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| *E. J. Dalton, Principal Engineer,- HCGS
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| *E. J. Galbraith, Acting Chemistry Engineer, HCGS | |
| *A. E. Giardino, Manager - Station Quality Assurance (QA), HCGS B. Hunkele, Senior Supervisor, Radioactive Material Control, Salem Nuclear Generating Station (SNGS)
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| *M. J. Kobran, Lead Engineer, HCGS | |
| *J. R. Lovell, Radiation Protection / Chemistry Manager, HCGS D. Mohler, Radiation Protection Engineer, SNGS
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| *J. J. Molner, Senior Radiation Protection Superviso'r, HCGS G. T. Morrill, Radiation Protection Supervisor, Effluents, HCGS
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| *L. M. Piccirelli, QA Engineer, HCGS
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| *L. M. Silvey, Senior Operations Support Supervisor, HCGS J. Trego, Radiation Protection / Chemistry Manager, SNGS Other licensee employees were contacted or interviewed during this inspectio .2 NRC Personnel D. Allsopp, Resident Inspector
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| *R. Borchardt. Senior Resident Inspector
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| * Attended the Exit Interview on January 16, 1987.
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| l Scope of the Inspection l
| | Sincerely, Original Si n d By: |
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| This routine inspection reviewed the licensee's solid radioactive waste (radwaste) preparation, packaging and shipping program as implemented by the licensee for seven (7) shipments (consisting of 16 liners) conducted in December 1986. Those shipments were reviewed relative to the licensee's Technical Specifications, radwaste generator requirements in 10 CFR 20.311 and 10 CFR 61.55-56 and radioactive materials shipper requirements in 10 CFR 71 and 49 CFR 170-189. The inspection completed reviews begun during Inspection 50-354/86-44 by examining implementation of the inter-face agreement between HCGS and SNGS regarding packaging and shipping l activitie In addition, the licensee's actions regarding previously identified items were also reviewe . - _ . ._ _ _ _ _ _ _ _ _
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| | &[Thom/cc as . , i ect ivision of Radiation Sa ty and Safeguards cc: |
| | R. S. Salvesen, General Manager, Hope Creek Operations , |
| | A. E. Giardino, Manager, Station Quality Assurance i |
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| | W. H. Hirst, Manager, Joint Generation Projects Department, Atlantic 1 i Electric Company |
| | , L. A. Reiter, General Manager - Licensing and Reliability ) |
| | ] Rebecca A. Green, Bureau of Radiation Protection |
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| | Public Document Room (PDR) |
| 3. Previously Identified Items 3.1 (0 pen) Followup Item (50-354/85-44-10) Review test results for Solid Radwaste Syste The test program for the licensee's installed solidification /
| | Local Public Document Room (LDDR) p/f |
| dewatering (asphalt) system remained incomplete. Discussions with operations and engineering personnel indicated that testing was being delayed by the licensee's configuration control procedures which made engineering changes to the system difficult and time-consuming. As a result, the licensee had not been able to complete testing by December 1986 as originally planned. This item remains ope .2 (Closed) Followup Item (50-354/85-52-38) Line loss tests for air particulate and radioiodine Contractor reports concerning line loss tests of the North and South Plant Vents were reviewed and appeared to be adequat Contractor evaluations of radiciodine loss also appeared adequate. The licensee had incorporated correction factors based on test results in counting procedures for effluents from the vents. This item is close .3 (Closed) Followup Item (50-354/86-39-02) Semi-Annual Radiological Effluent Report - RE 8817 failure explanatio The licensee's Semi-Annual Radiological Effluent Report provided an explanation for the effluent monitor's failure. This item is close .4 (Closed) Followup Item (50-354/86-39-05) Composite filter analysis for alpha and Sr-89/9 Vendor analyses of composition filters for alpha and strontium-89/90 were reviewed. This item is close .5 (Open) Unresolved Item (50-354/86-44-01) Reorganization of Radiation Protection per 00-1 NRC-NRR had not completed its review of the licensee's requested changes to Technical Specification 6.2 and the Final Safety Analysis Report (FSAR). This item remains ope .6 (0 pen) Followup Item (50-354/86-44-02) Procedures to classify, mark, label and manifes The interface agreement between HCGS and SNGS governing radwaste shipping had not been finalized, (i.e. signed by the representatives of the two sites), at the time of this inspectio Procedures under the agreement had not been develope This item remains ope __ _ _ _ _ _ _ - _ - _ - l
| | : OFFICIAL RECORD COPY RL HC 87-02 - 0001. /14/87 ' I |
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| | 8704290112 870420 |
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| 3.7 (0 pen) Followup Item (50-354/86-44-03) Administrative controls to evoke recharacterization of waste stream Administrative controls had not been developed. This item remains cpe .8 (Closed) Followup Item (50-354/86-44-04) QC Inspection Procedure The licensee's station QA organization developed checklists and 4- implementing procedures for inspecting radwaste shipmente, The checklists were reviewed and appeared to be generally adequate addressing HCGS preparation, packaging and shipping areas. lhis item is close .9 (Closed) Followup Item (50-354/86-44-05) QA Surveillance Procedure The licensee's station QA organization developed surveillance checklists for asphalt drum, LSA Box, radioactive materials and other radioactively contaminated article shipments. Those chek 11sts appeared to be generally adequate addressing key activities of the preparation, packaging and shipping of solid radwaste. This item is close .10 (0 pen) Followup Item (50-354/86-44-06) Develop / Implement Site-Speci-fic Process Control Program (PCP).
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| In November 1986, the licensee submitted a topical report on Class B and C wastes to support a request for approval of the process control program to process those waste classes. However, the PCP had not been approved and implementing procedures had not been complete This item remains ope . Management Controls
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| The licensee's management controls for the seven (7) shipments were reviewed to determine if clear designations of responsibilities and controlled instructions were provided for processing, packaging and shipping activities. Criteria provided in the licensee's Technical Specifications, Final Safety Analysis Report and 10 CFR 50, Appendix B were used in this revie .1 Responsibilities Sixteen liners containing startup resins, (i.e., reactor water cleanup, condensate demineralizer and " filter sludge" resins) were shipped in December 1986. Each liner was dewatered by a contracted dewatering servicer using the modifications to the solid radwaste system described in Inspection Report No. 50-354/86-44. Dewatering i to less than 1% standing water was verified by quality control
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| | Public Service Electric & Gas C l cc: continued Nuclear Safety Information Center (NSIC) |
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| | NRC Resident Inspector State of New Jersey bcc: |
| | ! Region I Docket Room (with concurrences) |
| | : Management Assistant, DRMA (w/o encl) |
| | DRP Section Chief Robert J. Bores, DRSS |
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| inspections at the completion of dewatering and just prior to ship-men Each batch of resin was sampled and analyzed by gamma spectro-scopy by the HCGS chemistry staff. Radioactive shipping and radwaste manifest documents were prepared by SNGS Radiation Protection person-Inel using the RADMAN computer program described in Inspection Report
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| }No.50-354/86-44. Certification under 10 CFR 20.311(c) that the jshipmentswereproperlyclassified, described, packaged,markedand glabeled and were in proper condition for transport were made by HCGS Sadiation Protection personnel. All other preparation, packaging and lhipping activities were conducted by HCGS personnel with the advice a,d oversight of SNGS personne .2 Procedures The following procedures (used in the preparation, packaging, classi-fication and shipping of the 16 liners) were reviewed relative to criteria in 10 CFR 20.311,10 CFR 71.5,10 CFR 71.12, Technical Specification 6.8 and 10 CFR 50, Appendix B, Criterion V:
| | RI:DRSS RI:0 SS RI:DRSS |
| * Vendor Operating Procedure (V0P)-SO.HC-101(R), " Chem-Nuclear System, Inc. F0-0P-032-Setup and Operating Procedure For the RDS-1000 Unit," Revision 0 (June 20,1986);
| | : Bicehouse Pasciak Bellamy 4/Jt/87 4/ls/87 4/)'l/87 0FFICIAL RECORD COPY RL HC 87-02 - 0002.0.0 |
| * RP-RW.ZZ-004(Q), " Shipment of Radioactive Material,"
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| Revision 2 (June 24, 1986);
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| RP-ST.ZZ-001(Q), " Radioactive Material Shipment Surveillance,"
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| Revision 0 (June 7, 1985);
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| * VRP-TE.ZZ-001(Q), " Shipment of Radioactive Waste For Burial,"
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| Revision 0 (December 16,1986);
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| VRP-TE.ZZ-002(Q), "Use of The NUPAC 14/210 Radioactive Shipping l Package, " Revision 0 (December 16, 1986); and
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| * VRP-TE.ZZ-003(Q), "Use of The Chem Nuclear 21-300 Radioactive l Shipping Package," Revision 0 (December 16,1986).
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| The three (3) "VRP" procedures were SNGS Radiation Protection proce-
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| , dures reviewed, approved and adopted for use as temporary HCGS pro-l cedures. The inspectors noted that none of the procedures required I review of the accuracy of the RADMAN program regarding the identities and activities of the radionuclides in each liner provided in the ( computer generated radioactive shipping and radwaste manifest i records. Determining the identities of the radionuclides and i their respective activities is important since the identities and l activities affect the determination of the acceptability of rad-waste for disposal in shallow land burial sites under 10 CFR 20.311 and 10 CFR 61 and the packaging and handling of radwaste shipments l under 10 CFR 7 Since the licensee used the computer for those | | e i PuCLc Service |
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| | ; Electr.c and Gas Company Cerbin A. McNeill. J 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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| | March 13, 1987 NLR-N87046 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 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 shipmen 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 regulation 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 violatio On~ l # |
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| | WAR 131987 USNRC Document Control Desk 2 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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| determinations, a quality verification of the input data and the results of the computer's computations was an important step in ensuring the accuracy of the licensee's determinations regarding 10 CFR 20.311; 10 CFR 61.55-56 requirements and 10 CFR 71 package selection. Failure to ensure the accuracy of the computer generated radioactive shipping and radwaste manifest records is a weakness of the licensee's program, and contributed to the problems noted in Detail 6.
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| . Quality Assurance / Quality Control The provisions of 10 CFR 71, Subpart H require the establishment of a QA program for the packaging and transportation of radioactive materials. A Commission-approved QA program which satisfies the applicable criteria of
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| , 10 CFR 50, Appendix B and which is established, maintained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Subpart H. The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and ship-ment of radioactive material Specific quality control (QC) requirements to assure compliance with 10 CFR 61.55 and 61.56 are mandated by 10 CFR 20.311 in addition to the general QC requirements required by 10 CFR 50, Appendix B. A process control program for waste dewatering (and solidification) is required by Technical Specifications 3/4.11.3, " Solid Radioactive Waste Treatment," | | ' |
| 6.8.1.h, " Process Control Program Implementation," and-6.13, " Process Control Program (PCP)." The implementation of QA/QC activities to the preparation, packaging and shipment of the 16 liners was reviewe .1 Radwaste Generator QC Program The licensee's performance in providing a QC program under 10 CFR 20.311(d)(3) was determined by review of dewatering procedures and records related to the 16 liners above and independent determination of waste classification for the 7 shipments under 10 CFR 61.55.
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| | i Attachment C Dr. Thomas E. Murley, Administrator USNRC Region I |
| | : 631 Park Avenue |
| | : King of Prussia, PA 19406 |
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| | USNRC Resident Inspector Box 241 Hancock's Bridge, NJ 08038 |
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| Within the scope of this review, no violations were noted. The l Vendor's Process Control Program for dewatering the resins was reviewed, incorporated into licensee's procedures and implemented.
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| l Specific inspection holdpoints related to dewatering were provided l and implemented. All seven (7) shipments appeared to be adequately classified as Class A under 10 CFR 61.55 and to meet waste form requirements under 10 CFR 61.56(a).
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| l 5.2 Audits l
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| Under the licensee's QA program, an audit of radwaste preparation, packaging and shipping activities was planned for February 1987. The inspectors noted that the licensee's QA procedures called for i management evaluation of audits as required by 10 CFR 20.311(d)(3).
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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 shipmen 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 . 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 VIOLATIO . 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). |
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| | SHIPMENT-SPECIFIC ISOTOPIC DATA FROM GAMMA SPECTROSCOPY WAS GENERATED BY HCGS PERSONNE 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 PROGRES . ._ |
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| | ATTACHMENT 1 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 manifestin A comprehensive review was made of all seven shipments to diagnose the interface mechanics that contributed to the error 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 execute . |
| | CORRECTIVE ACTIONS IN PROGRESS A transfer flow chart matrix was developed to assist in the preparation of new procedures covering all interface mechanic 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 HCG The procedures and the attached agreement should close Inspection Open Item 354/86-44-0 , WE WILL BE IN FULL COMPLIANCE BY MARCH 30, 1987 OR PRIOR TO RESUMPTION STATION, OF RADWASTE WHICH SHIPMENTS FROM HOPS CREEK GENERATING EVER IS EARLIE . |
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| 5.3 QA/QC Matrix The licensee had developed a matrix to ensure that each aspect of the preparation, packaging and shipping activities interfaces between HCGS and SNGS were addressed by the licensee's QA organizations, (i.e, SNGS QA/QC, HCGS QA/QC and Corporate QA). However, quality verification of the waste stream sampling program, (including com-puter inputs / outputs for the RADMAN Program), were the responsibility of the SNGS Radiation Protection group under the matrix. As imple-mented during the seven (7) shipments reviewed, quality verification of computer inputs / outputs by the SNGS Radiation Protection group was a significant weakness of the overall QA/QC matrix which contributed to the problems noted with radioisotopic identification and activity determinatio . Implementation During December 1986, the licensee made seven (7) shipments (comprising 16 liners containing dewatered startup resins). Those radwaste shipments were reviewed against criteria provided in:
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| * 10 CFR 20.311, 61.55 and 61.56;
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| * 20 CFR 71;
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| * 49 CFR 170-189; and
| | LETTER OF AGREEMENT BETWEEN HOPE CREEK GENERATING STATION AND |
| * Station Technical Specifications and Procedure The licensee reported that the Agreement State in which the radwaste shipments were buried had not issued any violations or warnings for tte seven (7) radwaste shipments receive .1 Waste Generator Requirements l The following waste generator requirements were reviewed and j discussed with the licensee:
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| * Waste Manifests under 10 CFR 20.311(d)(4) and 20.311(b) and (c);
| | SALEM NUCLEAR GENERATING STATION |
| * Waste Classification under 10 CFR 20.311(d)(1) and 10 CFR 61.55;
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| l Waste Form and Characterization under 10 CFR 20.311(d)(1) and 10 CFR 61.56; l * Waste shipment labeling under 10 CFR 20.311(d)(2) and
| | ON RADIOACTIVE MATERIALS SHIPMENTS January 30, 1987 Revision 0 |
| ; 10 CFR 61.55;
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| l * Tracking of waste shipments unde.r 10 CFR 20.311(d), (e), (f) and l (h); and
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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 Station (SNGS) |
| | will accept packaged radioactive waste from Hope Creek Generating Station (HCGS). SNGS will then be In addition SNGS responsible to ship and bury the wast will provide for radioactive material shipments of otherThis document de than waste as needed by NCG the HCGS and the Station responsibilities for both SNGS, Site Services Department to support radioactive material shipments from a single Nuclear Department progra SCOPE The guidelines set forth in this document are applicable to all radioactive material shipments originating from HCGS unless specific instances require exemptions as agreed to by the Radiation Protection / Chemistry Managers of SNGS and HCG Irradiated fuel in any form is specifically not included in this agreemen 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 requirement To this end, all shipments of radioactive materials from Artificial Island will be consigned from SNGS. |
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| * Disposal site license conditions (South Carolina Radioactive , | | ' |
| Material License No. 97 for the Barnwell site.) 4 Within the scope of this review, the following items were noted:
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| * 10 CFR 20.311(b) requires, in part, that the manifest accompany-ing radwaste shipments indicate as completely as practicable the radionuclide identity and quantity and the total radioactivity of the shipmen Contrary to this requirement, the manifest accompanying licen-see's shipment No. 86-04 failed to identify the radionuclides fron-59 and zirconium-95 and their activities. Although the presence of both radionuclides was clearly shown on the gamma ,
| | RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMENT RESPONSIBILITIES General Possession of radioactive materials will transfer to SNGS for shipmen Ownership of the material will remain with HCG . 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 SNG . Materials will be packaged in shipping containers by HCGS at their facilit . 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 container . All external communications from the Stations in regard to radioactive shipments will be performed by SNG HCGS will be involved with external communications only when requested by SNGS, with the exception of Limited Quantity Shipments made by HCG . Radiation surveys of packages will be performed by HCGS at contact and at one meter from the surface of the package, using a calibrated ion chamber instrumen Additional readings, as required by Regulations, will be performed by HCGS while packages remain at HCG Contamination surveys will be performed by HCGS, employing i 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 $NG . Packages which do not meet the site release limits will be decontaminated to the maximum extent practical by HCG If release limits cannot be met, but contamination is within regulatory limits, the material may be transferred to SNGS at their concurrenc l Materials to be shipped will be transferred by HCGS to ; |
| isotopic analyses provided by the licensee's chemistry group, both radionuclides and their activities were omitted from the manifest sent with shipment on December 17, 1986. Calculations of the activities of these radionuclides (decay corrected from the date of gamma isotopic analysis to December 17,_1986 showed that iron-59 contributed approximately 3% and zirconium-95 approximately 2% of the corrected total activity of the shipmen In addition, evaluations by the licensee (reviewed and confirmed by the inspectors) indicated that tSe total activity of the shipment was in error by a factor cf approximately 6. The manifest indicated approximately six (6) times more activity than was actually present. Failure to include iron-59 and zirconium-95 and their activities in the manifest accompanying shipment No. 86-04 constitutes a violation of 10 CFR 20.311(b)
| | 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 I |
| 50-354/87-02-0 * 10 CFR 20.311(c) requires, in part, certification by the waste generator that the transported materials are properly describe Contrary to this requirement, the licensee certified that ship- i-ment No. 86-04 was properly described when the identities of two radionuclides were missing and the activities due to those radionuclides were not identified and included in the total activity of the transported material Certification that Shipment No. 86-04 was properly described when it was not constitutes a violation of 10 CFR 20.311(c), 50-354/87-02-02.
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| * The RADMAN computer program used by the licensee' selects l scaling factors to compute the activities of "hard-to-identify" | | * |
| , radionuclides from various libraries based on the input waste source information provided by its user. SNGS Radiation Protection personnel entered incorrect waste types for five (5) | | , |
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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 SNG SNGS will provide personnel to accept packages when scheduled with HCG Site Services will assist with the They will also transfer of materials from HCGS to SNG assist SNGS with shipments off sit . HCGS will assure that packages are undamaged prior to transfer. Minor damages incurred during transport to SNGS will be corrected by SNG Packages damaged, or otherwise rendered unshippable, after transfer to SNGS will be restored to a shippable configuration by SNG . 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 shipmen . 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 requirement . Materials transferred to SNGS will be loaded onto the final shipping vehicle by SNGS in accordance with their |
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| of six (6) shipments. The following table summarizes these data input errors: | |
| Shipment N Input Waste Type Actual Waste Type
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| > 86-01 cleanup resin filter sludge t ( 86-02 cleanup resin filter sludge cleanup resin
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| 86-03 condensate resin 86-04 condensate resin condensate resin 86-05 cleanup resin filter sludge and condensate resin 86-06 cleanup resin filter sludge i
| | procedures. In the event that materials to be shipped have 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 procedure . HCGS will perform waste stream sampling and analysis to meet waste classification requirement This will be performed in accordance with the HCGS Process Control i |
| These errors were discovered by the licensee during a systematic reevaluation of computer data conducted during the inspectio * SNGS Radiation Protection personnel did not enter the gamma isotopic data (provided by HCGS Chemistry) into the RADMAN
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| - - | | program and SNGS approved procedure requirements. All data concerning waste types shall be gathered by and approved by HCG The applicable forms (Radman computer loading forms) |
| computer program. As a result, the computer program used
| | 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 us . Manifesting shipments will be performed by SNGS. The 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 consideration . 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 produc omn. 4 of a Rev. 0 |
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| " default" values to print the radionuclides present and to calculate their activitie The " default" values used "gencric" isotopic mixes and dose-rate-to-curie conversion factors to identify and quantify the activities. This omission of gamma isotopic data from the resins and the incorrect choices of waste source contributed to the errors noted in the activities and isotopic mixes noted in the manifests.
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| l 6.2 Procurement-and Selection of Packages The licensee's selection of packages for the seven (7) shipments was reviewed relative to requirements in 49 CFR 173, " Shippers-General Requirements for Shipments and Packaging," and 10 CFR 71.12,
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| " General License: NRC Approved Package." The licensee's performance
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| ; relative to the criteria was determined by interviews with HCGS and i SNGS Radiation Protection personnel, discussions with Quality l Control personnel and review of documents, procedures and shipping
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| [ record Within the scope of this review, no items were noted.
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| i j 6.3 Preparation of Packages for Shipment l
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| The licensee's preparation of the packages for shipment was reviewed
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| relative to the requirements of 49 CFR Parts 172 and 173, 10 CFR 71.87 and Technical Specifications. The licensee's performance
| | 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 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 This will include, but is not limited to, each containe performing surveys ofthe trash prior totocompaction, container the maximum equalizing extent dose rates throughout practical and placing high dose items in the center of i theSNGS container where possible.this activity, and make recommendations HCGS will meet regulatory and/or burial site requirements for materials shipped in boxe Solidified Wastes (drums) |
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| | I Drums with contact dose rates greater than 400 mrem /hr will be stored at ECGS until transferredfor suitable On-site Storage Container (OSCI) |
| | totransfer SNGS in to aa shipping cas . Drums with less than 40t mrem /hr at contact will be HCGS will load palletized on 3- or 6-drum pallets by HCG and band drums on pallets such that drums with greater than 200 mrem /hr dose rates are in the center or at one en |
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| | HCGS will serialize each drum with a unique number which can be traced to the source of the solidified will be provided by HCGS at SNGS reques Rev. 0 Page 5 of g |
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| *f relative to the criteria was determined by interviews of the HCGS
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| , Radiation Protection staff and examination of procedures, shipping records and other document Within the' scope of the review, no items were note .4 Delivery of Packages to Carriers The licensee's delivery of the packages to carriers was reviewed relative to criteria provided in:
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| 10 CFR 71.5(a)(1)(iii), " Placarding;"
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| 10 CFR 71.5(a)(1)(vi), " Shipping Manifests;"
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| 10 CFR 71.5(a)(1)(iv), "Public Highway - 49 CFR Part 177;" and
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| * applicable Technical Specifications and procedure The licensee's performance relative to the criteria was determined by ' | | . |
| review of shipping records and discussion with cognizant licensee personne !
| | HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMEN Limited Quantity Shipments HCGS will perform all requirements (with for Limited the exception Quantity shipments originating from NCGS of waste shipments for burial) in accordance with 49CFR173.42 . |
| Within the scope of this review, the following violation was noted:
| | SNGS will provide technical expertise if requested for these shipment BURIAL SITE ALLOCATIONS Any waste allocation assigned to PSE&GHowever, will be considered administrative anlimits Artificial will Island be assigned allotmen to each Station upon receipt of the allocatio . Each Stations' administrative portion of the 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: |
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| 10 CFR 71.5(a)(1)(vi) requires preparation of shipping papers in accordance with 49 CFR 172, Subpart C. 49 CFR 172.203(d)
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| (i) requires the name of each radionuclide in the shipment and 49 CFR 172.203 (d)(iii) requires the activity of each package in the shipment be included in the shipping papers. | |
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| T l Contrary to the requirements, the licensee failed to include
| | Waste Volume Allocation (ft ) |
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| | 1987 1988 1989 Total Year 1986 14,655 12,000 56,615 SNGS 16,960 13,000 20,000 24,740 77,727 2987 30,000 HCGS 34,655 36,740 134,342 43,000 Totals 19,947 Note: Any overage in 1986 must be subtracted from the remaining totals for 1987 through 198 . If a Station will require a larger waste volume than its administrative portion, that Station may request a larger portion of the allocatio . To most effectively utiltre burial allocations, wastes with higher dose rates will be given preferential treatment when preparing for shipment Rev. O Page 6 of 8 |
| ' iron-59 and zirconium-95 and the activities resulting from those radionuclides in the shipping papers associated with Shipment No. 86-04. Failure to name iron-59 and zirconium-95 and include their activities constitutes a violation of 10 CFR 71.5 (a)(1) | | _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _- |
| vi),50-354/87-02-0 . Exit Interview The inspectors met with the licensee's representatives (denoted in Detati 1)
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| at the conclusion of the inspection on January 16, 1987. The inspectors summarized the scope of the inspection and findings as described in this repor The licensee's representatives indicated that radwaste shipments had been suspended pending completion of a review of preparation, packaging and i shipping procedures. The inspectors discussed the importance of the
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| | * Charges and Cost Acccunting |
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| | - for NCGS agrees to be invoiced directly, or charged, g reasonable costs incurrea by SNGS under this agreemen These costs include time a.d m*+erials for the transfer, |
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| | loading, documentation and subsequent shipment of the materials. Any costs due to SNGS inspections (such as repackaging required due to an inspection), delays due to SNGS equipment or procedural deficiencies and other costs within SNGS control but outside of HCGS' control will be borne by SNG . HCGS shall budget each subsequent year for costs associated with transportation and burial of radioactive materia . NCGS shall cut a Department Order to SNGS to allow This will charges incurred by SNGS to be charged to NCGS.also this service provided by SNG . Invoices sent to NCGS for signature approval should be processed within three working days of receip . Any extra fees which may be incurred for exceeding the total Artificial Island allocation will be chargeable to the station (s) exceeding its administrative portion in an |
| activities reviewed and the need for close attention to detail to avoid more serious problems, (e.g., misclassification of waste).
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| | equivalent proportion to its exces . |
| | PROCEDURIS Each Station will implement this program through written procedure . Procedures or revisions which address shipment of radioactive materials will be reviewed by both Station Rev. O Page 7 of 8 e |
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| At no time during this inspection was written material provided to the
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| licensee by the inspectors. .No information exempt from disclosure under 10 CFR 2.790 is discussed in this report.
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| | * HCGS RADIOACTIVE MATERIALS SHIPMENTS REVIEWE_D G! b Y |
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| | Willian Hunkele, Supervisor 1. ,' |
| | fary/Morrill, Supervisor Radiation Protection Radiation Protection Hope Creek Generating Station Salem Generating Station RECOMMENDED: |
| | $ E I , <A.A' 'A t { t.1l f3 |
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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: |
| | //yfl}f $^ //Lt/r7 k ', Y} Roger Salvesen, General Manager John papko, Ge6eral Mar.ager Hope Creek Generating Station Salem Generating Station Alton Thompson /, General Manager |
| | //k/11 $6h &jrp Charles John # , General Manager Nuclear Qua Rty Assurance Nuclear Services l |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M7571999-10-22022 October 1999 Advises That Attachment 1 to ,Marked as Proprietary,Re Safety Limit MCPR & Fuel Vendor Change Will Be Withheld from Public Disclosure Per 10CFR2.790(b)(5) ML20217M2101999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates ML20217H8471999-10-18018 October 1999 Discusses Completion of Licensing Action for GL 98-01 & Suppl 1, Yr 2000 Readiness of Computer Sys at Npps, to All Holders of Operating Licenses for NPPs ML20217K8441999-10-15015 October 1999 Submits Revised Commitment to NRC Bulletin 90-01,Suppl 1 for Hope Creek Generating Station ML20217H9771999-10-13013 October 1999 Forwards SRO & RO Initial Exam Rept 50-354/98-302,suppl Rept on 990125-29,mtg Meeting on 990322,990429-30 & 0617-18 in-office Review & 990720 Telcon on Appeal Results.Overall, 11 of 16 Applicants Received NRC Licenses ML18107A5561999-10-0707 October 1999 Requests Relief Associated with Containment Examinations at Hope Creek & Salem Generating Stations.Attachment 1 Includes Proposed Alternatives & Supporting Justification for Relief Requests ML20217C4391999-10-0606 October 1999 Informs That Util Authorized to Administer Initial NRC Retake Written Exam to Applicant Listed,During Week of 991011 ML18107A5521999-10-0505 October 1999 Encourages NRC to Support Abb Combustion Engineering Nuclear Power Request for Priority Review of Generic TR Re Crossflow Ultrasonic Flow Measurement Sys ML18107A5501999-10-0505 October 1999 Provides Current Status of Pse&G Actions Re GL 98-01, Y2K Readiness of Computer Sys at Npps, for Salem Nuclear Generating Station,Units 1 & 2 & Hope Creek Nuclear Generating Station ML20217A9601999-10-0404 October 1999 Forwards Errata Redressing Deficiencies & Correcting Two Typos to Ufsar,Rev 10.Incorporate Attached Pages/Figures Into Controlled Copies of UFSAR ML20217A6861999-10-0101 October 1999 Forwards Insp Rept 50-354/99-05 on 990711-0829.Four Violations Occurred Re Areas of Fire Protection,Operation at Reduced Feedwater Inlet Temp & safety-related Battery Charging Operation & Being Treated as NCVs LR-N990430, Forwards Rev 10 to Hope Creek Generating Station Ufsar,Iaw 10CFR50.71(e).Details Re Each Change Also Attached to Facilitate NRC Review1999-09-28028 September 1999 Forwards Rev 10 to Hope Creek Generating Station Ufsar,Iaw 10CFR50.71(e).Details Re Each Change Also Attached to Facilitate NRC Review ML18107A5341999-09-22022 September 1999 Provides Data Re Operator Licensing Exam for Salem & Hope Creek Station,In Response to NRC Form 536 (7-1999) 05000354/LER-1999-009, Forwards LER 99-009-00, License Condition Violation - Min FW Temp Limits. Commitments Made by Util Encl1999-09-20020 September 1999 Forwards LER 99-009-00, License Condition Violation - Min FW Temp Limits. Commitments Made by Util Encl ML20217K7781999-09-16016 September 1999 Forwards Discharge Monitoring Rept for Hope Creek Generating Station for Month of Aug 1999. Rept Is Required by & Prepared Specifically for EPA & Nj Dept of Environ Protection ML20212B3631999-09-14014 September 1999 Forwards Rev 13 to Salem - Hope Creek Security Plan,Iaw 10CFR50.54(p).Summary of Proposed Changes to Plan,Encl. Encl Withheld ML20212B4021999-09-13013 September 1999 Submits Supplemental Info Related to Hope Creek License Change Request (LCR) H98-08,submitted to NRC on 981230, Re Flood Protection TS Changes ML18107A5221999-09-0808 September 1999 Requests Approval to Use ASME Code Case N546,which Provides Alternative Qualification Requirements That Allow Personnel Most Familiar with Walkdown of Plant Sys,Like License Operators to Perform VT-2 Examinations ML20211N5421999-09-0808 September 1999 Forwards Amend 121 to License NPF-57 & Safety Evaluation. Amend Revises TSs by Relocating Procedural Details of RETS to Offsite Dose Calculation Manual LR-N990395, Provides Comments on NRC Ltr Dtd 990714, Closure of TAC Number MA1194 - Response to RAIs to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity, for Hope Creek Generating Sation. Revised GE Report Encl Also1999-09-0101 September 1999 Provides Comments on NRC Ltr Dtd 990714, Closure of TAC Number MA1194 - Response to RAIs to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity, for Hope Creek Generating Sation. Revised GE Report Encl Also ML18107A4911999-08-20020 August 1999 Forwards Revised Plant Attribute Libraries for Salem & Hope Creek Generating Stations,Iaw 10CFR50,App E,Vi, Emergency Response Data Sys, 3.b.Changes Are Identified by Rev Bars ML20211B5341999-08-20020 August 1999 Forwards RAI Re 2nd 10-yr ISI Interval Relief Requests Re Plant.Info Requested to Be Provided within 60 Days of Receipt of Ltr ML18107A4801999-08-13013 August 1999 Requests That Pse&Gs Contact in NUREG-0383, Directory of Compliance for Radioactive Matl Packages, Be Changed ML20210R4911999-08-11011 August 1999 Forwards Insp Rept 50-354/99-04 on 990530-0711.No Violations Noted.Inspectors Reviewed Performance Indicators Submitted as Part of Pilot Program for New Regulatory Oversight Process & Verified Data ML18107A4751999-08-0505 August 1999 Forwards Fitness for Duty Performance Data Rept for Six Month Period Ending 990630 ML20210H9241999-07-26026 July 1999 Informs That State of Nj Dept of Environ Protection Has No Comments on Licensee 990517 Request for Amend to TS by Adding TS 3.3.10, Instrumentation of OPRM Sys ML20210F3271999-07-22022 July 1999 Forwards SE Granting Relief Requests RR-B1,RR-C1,RR-D1 & RR-B3 Re First 10-year Interval for ISI Program at Hope Creek ML20210D3971999-07-16016 July 1999 Forwards Discharge Monitoring Rept for Hope Creek Generating Station, for June 1999.Rept Is Required by & Prepared for EPA & Nj Dept of Environ Protection ML20209G2831999-07-14014 July 1999 Disclosure Closure of TAC MA1194 Re Licensee Response to RAI to GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, for Plant 05000354/LER-1999-007, Forwards LER 99-007-00,re License Condition Violation - Class-1E Battery Charging Operation.Commitments Made by Util Encl1999-07-14014 July 1999 Forwards LER 99-007-00,re License Condition Violation - Class-1E Battery Charging Operation.Commitments Made by Util Encl LR-N990250, Provides Proposed Alternative & Supporting Justification for Relief from Augmented Inservice Requirements of 10CFR50.55a(g) for Volumetric Exam of RPV Circumferential Welds1999-07-0909 July 1999 Provides Proposed Alternative & Supporting Justification for Relief from Augmented Inservice Requirements of 10CFR50.55a(g) for Volumetric Exam of RPV Circumferential Welds ML20196J4421999-07-0101 July 1999 Forwards Request for Addl Info Re Increase of Allowable Main Steam Isolation Valve (MSIV) Leak Rate & Deletion of MSIV Sealing Sys for Plant LR-N990316, Responds to NRC Request for Info Re Y2K Readiness at Npps, Per GL 98-01,suppl 1.Disclosure Encl1999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Npps, Per GL 98-01,suppl 1.Disclosure Encl ML18107A4131999-06-25025 June 1999 Provides Further Clarification of Licensing & Design Basis for 125 Vdc Battery Margins for Sgs & HCGS for Meeting Station SBO & Loca/Loop Loading Requirements,Per Util 990426 Ltr & Discussion with NRC ML20209B6441999-06-21021 June 1999 Offers No Comments on Licensee 990529 Request for Revs to Plant Radiological Effluent Ts,Per GL 89-01 ML20196F9441999-06-21021 June 1999 Forwards Insp Rept 50-354/99-03 on 990419-0529.Violations Noted.Two Violations of NRC Requirements Occurred Re Reactor Bldg Ventilation Setpoints & Control Rod Drop Analyses ML20196E6471999-06-21021 June 1999 Forwards Revised marked-up TS Page for HCGS License Change Requests H99-02 & H99-05,dtd 990329 & 0524,respectively. Revised Pages Do Not Alter Conclusions Reached in 10CFR50.92 No Significant Hazards Analysis Previously Submitted ML20209C0621999-06-21021 June 1999 Forwards NPDES Discharge Monitoring Rept,May 1999, for Hcgs.Rept Prepared Specifically for EPA & Nj Dept of Environ Protection ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First ML20196E9631999-06-17017 June 1999 Informs That Util Has Made Change to Commitment Stated in NRC Ser,Suppl 5.Commitment That Has Been Changed Is Item Number 1 of First Paragraph on Page 9-3 of Ser,Suppl 5 LR-N990295, Submits Change 1 to Relief Request RR-A4,which Clarifies Requirements Re Snubber Visual Insps.Request Was Submitted as Part of Plant Second Interval ISI Program on 9905111999-06-16016 June 1999 Submits Change 1 to Relief Request RR-A4,which Clarifies Requirements Re Snubber Visual Insps.Request Was Submitted as Part of Plant Second Interval ISI Program on 990511 05000354/LER-1999-006, Forwards LER 99-006-00 Re Esfa B Channel Primary Containment Isolation Signal Actuation.Attachment a Lists Commitments Util Making to NRC Re LER1999-06-15015 June 1999 Forwards LER 99-006-00 Re Esfa B Channel Primary Containment Isolation Signal Actuation.Attachment a Lists Commitments Util Making to NRC Re LER ML20195J1101999-06-0707 June 1999 Informs of Completion of Review of Providing Updated Status on Implementation of Commitments Made in Response to GL 89-13.Confirms Revs Made to Previous Commitments to Resolve Monitoring Pressure Drop Problem ML20195J1051999-06-0707 June 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Jw Clifford Will Be Section Chief for Hope Creek Generating Station ML20207F2681999-06-0303 June 1999 Responds to by Forwarding Gfes & NRC Written Exam Grades for List of Hope Creek Operators Submitted by DE Jackson.Absence of Gfes Grade Indicates That Operator Previously Issued RO or SRO License.Without Encl ML18107A3611999-05-27027 May 1999 Forwards Responses to NRC 990301 & 990323 RAIs for Salem & Hope Creek Generating Stations Relating to GL 96-05 ML20207D0201999-05-27027 May 1999 Discusses 990512 Meeting to Identify Insp Activities at Hope Creek Facility Over Next Six Months & Informs of Planned Insps in Order for Licensee to Have Opportunity to Prepare & Provide Region I with Feedback on Schedule Conflicts ML20195B9931999-05-20020 May 1999 Forwards NPDES Discharge Monitoring Rept,Apr 1999, for Hgcs.Rept Prepared Specifically for EPA & Nj Dept of Environ Protection ML20207A3451999-05-20020 May 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECCS Strainers by Debris in Bwrs ML20206Q6211999-05-14014 May 1999 Informs That on 990119 Licensee Provided NRC with Several Revised TS Bases Pages for Plant.Ts Bases Pages B 3/4 6-1 & B 3/4 6-2 Were Revised 1999-09-08
[Table view] Category:NRC TO UTILITY
MONTHYEARML20062E7751990-11-15015 November 1990 Discusses Util 900910 Submittal of Addl Info Re Reliability of Bailey Solid State Logic Modules ML20197H7051990-11-0808 November 1990 Forwards Exam Rept 50-354/90-17OL Administered During Wks of 900827,0924 & 1001 ML20058H0461990-11-0606 November 1990 Forwards List of Unimplemented Gsis,Per Generic Ltr 90-04 ML20058H0531990-11-0606 November 1990 Informs That Dembek Replaced C Shiraki as Staff Project Manager for Plant ML20062B6611990-10-12012 October 1990 Extends Invitation to Attend 910220-21 Workshop in King of Prussia,Pa Re Engineering Role in Plant Support ML20059P0031990-10-0505 October 1990 Grants 900928 Request for Regional Waiver of Compliance Re Safety Auxiliaries Cooling Sys ML20058N8261990-08-13013 August 1990 Advises That Request for Relief from ASME Code Requirements for Svc Water Piping,Granted Until Next Scheduled Outage Per 10CFR50.55a(g)(6)(i) & Guidance of Generic Ltr 90-05 ML20058M4371990-08-0101 August 1990 Forwards Safety Insp Rept 50-354/90-13 on 900618-22.No Violations Noted ML20058L7541990-07-23023 July 1990 Forwards Radiological Controls Insp Rept 50-354/90-15 on 900625-29.No Violations Noted ML20059M9281990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20055C6241990-05-22022 May 1990 Forwards Exam Rept 50-354/90-06OL Administered During Wk of 900319 ML20248G5531989-09-26026 September 1989 Forwards Exam Rept 50-354/89-08OL Administered During Wk of 890717 IR 05000354/19890141989-09-19019 September 1989 Forwards Safety Insp Rept 50-354/89-14 on 890620-0814.No Violations Noted.Inspectors Noted Addl Attention to Detail Errors by Facility Personnel Similar to Ones Described in Most Recent SALP Rept 50-354/88-99 ML20246E7631989-08-22022 August 1989 Informs of Maint Program Team Insp Scheduled for 891002-13 to Focus on Maint Performance & Whether Components,Sys & Structures Adequately Maintained & Repaired to Perform Intended Safety Function.Encl Ref Matl Requested ML20246J4371989-08-18018 August 1989 Clarifies NRC Position Re Definition of Extremity for Purpose of Setting Occupational Exposure Limits.Procedures Should Incorporate Applicable Dose Limits of 10CFR20 ML20246C3941989-08-15015 August 1989 Forwards Safeguards Insp Repts 50-272/89-19,50-311/89-17 & 50-354/89-15 on 890710-14.No Violations Noted ML20247J2841989-07-24024 July 1989 Forwards SER & EGG-NTA-8341 Re Generic Ltr 83-28,Item 4.5.3, Reactor Trip Reliability-On-Line Functional Testing of Reactor Trip Sys ML20247N4481989-07-24024 July 1989 Forwards Insp Rept 50-354/89-13 on 890626-30.No Violations Noted ML20246J8671989-07-12012 July 1989 Forwards Safety Insp Rept 50-354/89-11 on 890501-0619.No Violations Noted ML20246F7291989-07-0606 July 1989 Forwards to Ecology Ctr of Southern California Re Petition to Fix or Close Reactors Designed by Ge.Ltr States That Petition Being Treated Under 10CFR2.206 ML20245J8061989-06-27027 June 1989 Grants Util 871211 Relief Requests 3.1.1.1,3.1.1.2 & 3.1.1.3 Re Inservice Insp Plan Category B-A Reactor Vessel Welds,Per 871211 SER ML20247M8211989-05-25025 May 1989 Forwards Director'S Decision,Ltr of Transmittal & Fr Notice Re Denial of Ocre 10CFR2.206 Petition on BWR Stability. Request to Reopen Rulemaking on Anticipated Transients W/O Scram Being Considered as Petition Under 10CFR2.802 ML20246N3441989-05-11011 May 1989 Forwards Safety Insp Rept 50-354/89-09 on 890314-0430.No Violations Noted ML20247A0611989-05-0404 May 1989 Forwards SER Accepting Util Response to Generic Ltr 83-28, Item 4.5.2, Reactor Trip Sys Reliability,On-Line Testing. Technical Evaluation Rept Also Encl ML20247A7781989-05-0303 May 1989 Extends Invitation to Power Reactor Operator Licensing Seminar on 890531 in King of Prussia,Pa.Meeting Agenda Encl ML20245B6681989-04-10010 April 1989 Forwards Safety Insp Rept 50-354/89-06 on 890227-0303.No Violations Noted ML20244B5961989-04-0707 April 1989 Forwards Exam Rept 50-354/89-04OL Administered During Wk of 890214 ML20248J3851989-04-0404 April 1989 Advises That Reactor Operator & Senior Reactor Operator Licensing Exams Scheduled for Wk of 890717.Encl Ref Matl Requested by 890515 to Meet Schedule ML20248J1761989-03-31031 March 1989 Forwards Safety Insp Rept 50-354/89-02 on 890124-0313 & Notice of Violation.Concludes That Uncontrolled Installation of Electrical Jumpers in Controls of Drywell Equipment Drain Pumps Represented Violation of NRC Requirements ML20247M9521989-03-27027 March 1989 Forwards Insp Rept 50-354/89-05 on 890227-0303.No Violations Noted.Apparent Violation of Radiation Protection Procedures Identified by NRC Reviewed for Nonissuance of Notice of Violation ML20247E2771989-03-24024 March 1989 Requests Addl Info Re IGSCC Problems in BWR Austenitic Stainless Steel Piping,Per Generic Ltr 88-01.Response Should Be Provided within 60 Days ML20247D3561989-03-23023 March 1989 Confirms Requalification Program Evaluation Scheduled for Wk of 890619,per Telcon.Util Should Furnish Approved Items Listed in Encl 1 ML20247C2371989-03-20020 March 1989 Forwards Eg&G Idaho Evaluation Accepting Rev 10 to ODCM for Plant.Number of Points Remain Open Re Eg&G Suggestions That Could Make ODCM More Useful & Complete ML20236B6061989-03-0606 March 1989 Forwards Safety Insp Rept 50-354/89-03 on 890206-10.No Violations Noted ML20206M2131988-11-23023 November 1988 Informs That Recent Insp of Records Indicated That Util May Have Purchased Class 1E Components from Planned Maint Sys, Inc.Util Should Review Records for Period from Jan 1985 to Present ML20195H6571988-11-22022 November 1988 Accepts Util Response to Part 2 of Item 2.1 to Generic Ltr 83-28 Re Establishing Interface W/Either NSSS or Vendors of Each of Components of Util Reactor Trip Sys.Ser Encl ML20195J1321988-11-22022 November 1988 Advises That 880331 Response to NRC Bulletin 88-001, Defects in Westinghouse Circuit Breakers Satisfactory. Response Confirmed That Westinghouse Ds Series Circuit Breakers Not Used in safety-related Applications IR 05000354/19882001988-11-11011 November 1988 Forwards Emergency Operating Procedures Insp Rept 50-354/88-200 on 880906-16.No Violations Noted.Weaknesses Involving Development & Implementation of Emergency Operating Procedures Identified ML20206C5261988-11-0303 November 1988 Forwards Safety Insp Rept 50-354/88-23 on 880823-1011. Unresolved Area Re Operation at Powers Marginally Above Rated Thermal Power Specified in License Will Be Evaluated for Potential Enforcement Based on Review of Evaluation ML20195E3011988-11-0101 November 1988 Requests Remittance of Fee for 880715 Application for Extension of Time to Submit 90-day Inservice Insp Rept ML20205Q7821988-10-28028 October 1988 Requests Ref Matls Listed in Encl Be Provided for Licensing Exam Scheduled for 890214-17 by 881219.Encls 1 & 3 Describe Requirements for Conducting Exams & Lists Rules & Guidelines in Effect During Administration of Exams,Respectively ML20204B5781988-10-17017 October 1988 Forwards Technical Evaluation Supporting VRS-002, 10CFR61 Waste Form Conformance Program for Solidified Process Waste Chem Corp Vol Reduction & Solidification Sys for Util Use as Ref Document ML20155F5651988-10-0707 October 1988 Forwards Grading & Answer Sheets for 880921 Generic Fundamentals Pilot Exam.W/O Encls ML20154N2221988-09-22022 September 1988 Forwards NRR to Ohio Citizens for Responsible Energy Ack Receipt of Petition Per 10CFR2.206.Request for Immediate Relief Denied Since Allegations Did Not Reveal Any New Operational Safety Issues Posing Safety Concern ML20154M3671988-09-16016 September 1988 Forwards Safety Insp Rept 50-354/88-22 on 880712-0829 & Notice of Violation.Previously Identified Items Re Scaffolding Should Be Promptly & Properly Corrected ML20154N4841988-09-0909 September 1988 Requests Rev to Util Pump Valve Inservice Testing Program, within 90 Days to Reflect Changes Discussed at 880629-30 Meetings & to Address Three Open Items.Questions That Served as Agenda for Meeting & Responses to Questions Encl ML20151Z2391988-08-25025 August 1988 Forwards Request for Addl Info Re 880227 Request for Exemptions to Allow Util to Take Credit for Respirators Fitted W/Sorbent Cartridges for Protection Against Airborne Radioidine.Response Requested within 30 Days IR 05000354/19880191988-08-0303 August 1988 Forwards Insp Rept 50-354/88-19 on 880613-17.No Violations Noted ML20151L2061988-07-27027 July 1988 Forwards Revised Notice of Violation Sent on 880714 Re Finding of Discrimination by Util Contractors Against Contractor Employees ML20151J4801988-07-27027 July 1988 Forwards Safety Insp Rept 50-354/88-18 on 880601-0711.No Violations Noted 1990-08-13
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217M7571999-10-22022 October 1999 Advises That Attachment 1 to ,Marked as Proprietary,Re Safety Limit MCPR & Fuel Vendor Change Will Be Withheld from Public Disclosure Per 10CFR2.790(b)(5) ML20217M2101999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates ML20217H8471999-10-18018 October 1999 Discusses Completion of Licensing Action for GL 98-01 & Suppl 1, Yr 2000 Readiness of Computer Sys at Npps, to All Holders of Operating Licenses for NPPs ML20217H9771999-10-13013 October 1999 Forwards SRO & RO Initial Exam Rept 50-354/98-302,suppl Rept on 990125-29,mtg Meeting on 990322,990429-30 & 0617-18 in-office Review & 990720 Telcon on Appeal Results.Overall, 11 of 16 Applicants Received NRC Licenses ML20217C4391999-10-0606 October 1999 Informs That Util Authorized to Administer Initial NRC Retake Written Exam to Applicant Listed,During Week of 991011 ML20217A6861999-10-0101 October 1999 Forwards Insp Rept 50-354/99-05 on 990711-0829.Four Violations Occurred Re Areas of Fire Protection,Operation at Reduced Feedwater Inlet Temp & safety-related Battery Charging Operation & Being Treated as NCVs ML20211N5421999-09-0808 September 1999 Forwards Amend 121 to License NPF-57 & Safety Evaluation. Amend Revises TSs by Relocating Procedural Details of RETS to Offsite Dose Calculation Manual ML20211B5341999-08-20020 August 1999 Forwards RAI Re 2nd 10-yr ISI Interval Relief Requests Re Plant.Info Requested to Be Provided within 60 Days of Receipt of Ltr ML20210R4911999-08-11011 August 1999 Forwards Insp Rept 50-354/99-04 on 990530-0711.No Violations Noted.Inspectors Reviewed Performance Indicators Submitted as Part of Pilot Program for New Regulatory Oversight Process & Verified Data ML20210F3271999-07-22022 July 1999 Forwards SE Granting Relief Requests RR-B1,RR-C1,RR-D1 & RR-B3 Re First 10-year Interval for ISI Program at Hope Creek ML20209G2831999-07-14014 July 1999 Disclosure Closure of TAC MA1194 Re Licensee Response to RAI to GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, for Plant ML20196J4421999-07-0101 July 1999 Forwards Request for Addl Info Re Increase of Allowable Main Steam Isolation Valve (MSIV) Leak Rate & Deletion of MSIV Sealing Sys for Plant ML20196F9441999-06-21021 June 1999 Forwards Insp Rept 50-354/99-03 on 990419-0529.Violations Noted.Two Violations of NRC Requirements Occurred Re Reactor Bldg Ventilation Setpoints & Control Rod Drop Analyses ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First ML20195J1051999-06-0707 June 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Jw Clifford Will Be Section Chief for Hope Creek Generating Station ML20195J1101999-06-0707 June 1999 Informs of Completion of Review of Providing Updated Status on Implementation of Commitments Made in Response to GL 89-13.Confirms Revs Made to Previous Commitments to Resolve Monitoring Pressure Drop Problem ML20207F2681999-06-0303 June 1999 Responds to by Forwarding Gfes & NRC Written Exam Grades for List of Hope Creek Operators Submitted by DE Jackson.Absence of Gfes Grade Indicates That Operator Previously Issued RO or SRO License.Without Encl ML20207D0201999-05-27027 May 1999 Discusses 990512 Meeting to Identify Insp Activities at Hope Creek Facility Over Next Six Months & Informs of Planned Insps in Order for Licensee to Have Opportunity to Prepare & Provide Region I with Feedback on Schedule Conflicts ML20207A3451999-05-20020 May 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECCS Strainers by Debris in Bwrs ML20206Q6211999-05-14014 May 1999 Informs That on 990119 Licensee Provided NRC with Several Revised TS Bases Pages for Plant.Ts Bases Pages B 3/4 6-1 & B 3/4 6-2 Were Revised ML20206Q4461999-05-14014 May 1999 Forwards SE Accepting GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves, for Plant ML20206U8451999-05-14014 May 1999 Forwards Insp Rept 50-354/99-02 on 990308-0418.Violations Re Fuel Handling Errors & Missed Temp Monitoring During Reactor Vessel Head Tensioning Occurred & Being Treated as non-cited Violation ML20206R2691999-05-12012 May 1999 Informs That During 990504 Telcon Between J Caruso & H Hanson,Arrangements Were Made for Administration of Licensing Written Retake Exam at Hope Creek Nuclear Generating Station During Week of 990927 ML20206C8431999-04-22022 April 1999 Forwards SER Authorizing Util 980728 Submitted Relief Requests Associated with Changes Made to Repair Plan for Core Spray Nozzle Weld N5B ML20205S7911999-04-19019 April 1999 Forwards Insp Rept 50-354/99-01 on 990124-0307.Violations Noted.Some Human Performance Errors Occurred During Numerous Outage Activities,Util Appropriately Reacted to Each of Errors & Initiated Corrective Actions ML20205R0461999-04-14014 April 1999 Forwards Associated Page with Correction Marked in Margin of PPR of Salem Issued 990409.During Final Review of Hard Copy, Error Was Noted.Without Encl ML20205R0861999-04-14014 April 1999 Informs That Final Review of Hard Copy of PPR Re Hope Creek, Issued 990409 Had Error.Electronic Version e-mailed Was Not Effected.Forwards Pp with Correction in Margin.Without Encl ML20205N2111999-04-0909 April 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/98-302 Issued on 990226.Response Indicates That Licensee Corrected Violation & Initiated Measures to Prevent Recurrence ML20205N2481999-04-0909 April 1999 Discusses Hope Creek Generating Station Plant Performance Review Conducted for Period April 1998 Through Jan 1999 & Informs of NRC Planned Insp Effort Resulting from Ppr. Historial Listing & Insp Plans for Next Few Months Encl ML20205G5961999-03-19019 March 1999 Forwards Safety Evaluation of Relief Request Re ASME Code Case N-567, Alternate Requirements for Class 1,2 & 3 Replacement Components Section Xi,Div 1. Request Acceptable ML20205F8771999-03-18018 March 1999 Forwards SE Authorizing Licensee 971222 Relief Requests Re Second 10-year Interval for Pumps & Valves IST Program for Hope Creek Generating Station ML20207D5741999-03-0101 March 1999 Discusses Pse&G 980604 Updated Response to GL 96-05 Indicating Intent to Implement Provisions of JOG Program on MOV Periodic Verification at Hope Creek Generating Station. Forwards RAI Re GL 96-05 Program at Hope Creek ML20198H6211998-12-24024 December 1998 Forwards Notice of Withdrawal of 970826,as Suppl 980424 & 0924 Amend Request for FOL NPF-57.Proposed Change Would Have Modified Facility TSs Pertaining to Filtration,Recirculation & Ventilation Sys Surveillance Testing Requirements ML20198L3571998-12-22022 December 1998 Forwards Insp Rept 50-354/98-11 on 981101-1212.No Violations Noted.Insp Generally Characterized by safety-conscious Operations,Effective Engineering & Maint Practices & Careful Radiological Work Controls ML20198H6661998-12-17017 December 1998 Informs That Attachment 1 to Ltr LR-N98404,dtd 980825 Marked as Proprietary,Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act of 1954,as Amended ML20196K1371998-12-0909 December 1998 Advises of Planned Insp Effort Resulting from Hope Creek Insp Review Planning Meeting Conducted on 981110.Details of Insp Plan for Next 6 Months Encl ML20197H3841998-12-0707 December 1998 Informs That Licensee Authorized to Administer Initial Written Exams to Listed Applicants on 981222.NRC Region I Operator Licensing Staff Will Administer Operating Tests ML20196H0301998-12-0101 December 1998 Informs That NEDC-32511P,rev 1,dtd Oct 1998 Marked as Proprietary,Will Be Withheld from Public Disclosure Pursuant to 10CFR2.790(b)(5) & Section 103(b) of Atomic Energy Act of 1954,as Amended ML20196F7991998-11-30030 November 1998 Forwards Rept Representing Results of 981026-29 Audit of Year 2000 Pragram at Hope Creek Generating Station.Audit Conducted as Followup to NRC GL 98-01, Year 2000 Readiness of Computer Sys at Npps, Issued 980511 ML20196D0711998-11-23023 November 1998 Forwards Insp Rept 50-354/98-10 on 980920-1031 & Notice of Violation Re Preforming Single Cell Charge on safety-related Battery Cell in Configuration Prohibited by Station Procedures ML20154Q7071998-10-16016 October 1998 Forwards Exam Rept 50-354/98-03OL Conducted by NRC During Periods of 980304-12,0519-21,22-28 & 0629.All Five Reactor Operator Applicants & Four of Five Senior Reactor Applicants Passed Exams IA-98-323, First Final Response to FOIA Request for Records.Records in App a Available in Pdr.Records in App B Partially Withheld (Ref FOIA Exemption 3)1998-10-0909 October 1998 First Final Response to FOIA Request for Records.Records in App a Available in Pdr.Records in App B Partially Withheld (Ref FOIA Exemption 3) ML20154J8501998-10-0909 October 1998 Forwards Insp Rept 50-354/98-08 on 980809-0919 & Notice of Violation Re Inadequate Corrective Actions to Resolve Steam Leaks from Piping Located in Torus Room ML20154P4011998-10-0909 October 1998 First Final Response to FOIA Request for Records.Records in App a Available in Pdr.Records in App B Partially Withheld (Ref FOIA Exemption 3) ML20154F1121998-10-0202 October 1998 Forwards Insp Rept 50-354/98-09 on 980817-26 & 0908.No Violations Identified.Major Areas Inspected:Maint, Engineering & Mgt Meeting ML20154B3341998-09-29029 September 1998 Requests That Encl Info on GE Rept NEDC-32511P Be Reviewed & Revised Proprietary Version of Subj Rept Be Submitted.Some Info in Rept Should Not Be Exempt from Public Disclosure & Should Be Released & Placed in PDR ML20154B3781998-09-25025 September 1998 Informs That Facility Scheduled to Administer NRC Generic Fundamentals Exam on 981007.Sonalysts,Inc Authorized Under Contract to Support NRC in Administration of Activities. Ltr & Encls Provide Instructions & Guidelines ML20151Z1111998-09-11011 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/98-06 Issued on 980721 ML20151Z5941998-09-11011 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-354/98-02 on 980423.Response Indicated Violations Corrected & Measures Initiated to Prevent Recurrence ML20151W9711998-09-10010 September 1998 Informs That as Part of NRC PRA Implementation Plan, Commission Has Assigned Two Senior Reactor Analysts (Sras) to Each Regional Ofc.T Shedlosky & J Trapp Have Been Assigned as SRAs in Region I 1999-09-08
[Table view] |
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APR 2 0 1987 Docket No. 50-354 Public Service Electric & Gas Company ATTN: Mr. C. A. McNeill, J Vice President - Nuclear P.O. Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:
} Subject: Inspection No. 50-354/87-02 This refers to your letter dated March 13, 1987, in response to our letter j dated February 12, 1987.
, Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of 1 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-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 4 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 j occurred in preparation of the radioactive waste manifest and certification '
We believe that we have adequately and fairly assessed the problem as a single Severity IV problem with three violation Your cooperation with us is appreciate '
Sincerely, Original Si n d By:
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&[Thom/cc as . , i ect ivision of Radiation Sa ty and Safeguards cc:
R. S. Salvesen, General Manager, Hope Creek Operations ,
A. E. Giardino, Manager, Station Quality Assurance i
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W. H. Hirst, Manager, Joint Generation Projects Department, Atlantic 1 i Electric Company
, L. A. Reiter, General Manager - Licensing and Reliability )
] Rebecca A. Green, Bureau of Radiation Protection
Public Document Room (PDR)
Local Public Document Room (LDDR) p/f
- OFFICIAL RECORD COPY RL HC 87-02 - 0001. /14/87 ' I
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Public Service Electric & Gas C l cc: continued Nuclear Safety Information Center (NSIC)
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NRC Resident Inspector State of New Jersey bcc:
! Region I Docket Room (with concurrences)
- Management Assistant, DRMA (w/o encl)
DRP Section Chief Robert J. Bores, DRSS
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March 13, 1987 NLR-N87046 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 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 shipmen 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 regulation 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 violatio On~ l #
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WAR 131987 USNRC Document Control Desk 2 Amplification of this concern and our response to the Notice of violation, pursuant to the provisions of 10 CFR 2.201, are
! provided in Attachment 1.
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Sincerely,
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i Attachment C Dr. Thomas E. Murley, Administrator USNRC Region I
- 631 Park Avenue
- King of Prussia, PA 19406
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USNRC Resident Inspector 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 shipmen 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 . 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 VIOLATIO . 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 PERSONNE 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 PROGRES . ._
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ATTACHMENT 1 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 manifestin A comprehensive review was made of all seven shipments to diagnose the interface mechanics that contributed to the error 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 execute .
CORRECTIVE ACTIONS IN PROGRESS A transfer flow chart matrix was developed to assist in the preparation of new procedures covering all interface mechanic 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 HCG The procedures and the attached agreement should close Inspection Open Item 354/86-44-0 , WE WILL BE IN FULL COMPLIANCE BY MARCH 30, 1987 OR PRIOR TO RESUMPTION STATION, OF RADWASTE WHICH SHIPMENTS FROM HOPS CREEK GENERATING EVER IS EARLIE .
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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 Station (SNGS)
will accept packaged radioactive waste from Hope Creek Generating Station (HCGS). SNGS will then be In addition SNGS responsible to ship and bury the wast will provide for radioactive material shipments of otherThis document de than waste as needed by NCG the HCGS and the Station responsibilities for both SNGS, Site Services Department to support radioactive material shipments from a single Nuclear Department progra SCOPE The guidelines set forth in this document are applicable to all radioactive material shipments originating from HCGS unless specific instances require exemptions as agreed to by the Radiation Protection / Chemistry Managers of SNGS and HCG Irradiated fuel in any form is specifically not included in this agreemen 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 requirement 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 Possession of radioactive materials will transfer to SNGS for shipmen Ownership of the material will remain with HCG . 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 SNG . Materials will be packaged in shipping containers by HCGS at their facilit . 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 container . All external communications from the Stations in regard to radioactive shipments will be performed by SNG HCGS will be involved with external communications only when requested by SNGS, with the exception of Limited Quantity Shipments made by HCG . Radiation surveys of packages will be performed by HCGS at contact and at one meter from the surface of the package, using a calibrated ion chamber instrumen Additional readings, as required by Regulations, will be performed by HCGS while packages remain at HCG Contamination surveys will be performed by HCGS, employing i 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 $NG . Packages which do not meet the site release limits will be decontaminated to the maximum extent practical by HCG If release limits cannot be met, but contamination is within regulatory limits, the material may be transferred to SNGS at their concurrenc l 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 I
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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMENT (
transferred to SNGS during normal work hours (0900 to 1530, Monday through Friday) unless specifically agreed to by SNG SNGS will provide personnel to accept packages when scheduled with HCG Site Services will assist with the They will also transfer of materials from HCGS to SNG assist SNGS with shipments off sit . HCGS will assure that packages are undamaged prior to transfer. Minor damages incurred during transport to SNGS will be corrected by SNG Packages damaged, or otherwise rendered unshippable, after transfer to SNGS will be restored to a shippable configuration by SNG . 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 shipmen . 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 requirement . Materials transferred to SNGS will be loaded onto the final shipping vehicle by SNGS in accordance with their
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procedures. In the event that materials to be shipped have 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 procedure . HCGS will perform waste stream sampling and analysis to meet waste classification requirement This will be performed in accordance with the HCGS Process Control i
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program and SNGS approved procedure requirements. All data concerning waste types shall be gathered by and approved by HCG 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 us . Manifesting shipments will be performed by SNGS. The 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 consideration . 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 produc omn. 4 of a Rev. 0
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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 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 This will include, but is not limited to, each containe performing surveys ofthe trash prior totocompaction, container the maximum equalizing extent dose rates throughout practical and placing high dose items in the center of i theSNGS container where possible.this activity, and make recommendations HCGS will meet regulatory and/or burial site requirements for materials shipped in boxe Solidified Wastes (drums)
I Drums with contact dose rates greater than 400 mrem /hr will be stored at ECGS until transferredfor suitable On-site Storage Container (OSCI)
totransfer SNGS in to aa shipping cas . Drums with less than 40t mrem /hr at contact will be HCGS will load palletized on 3- or 6-drum pallets by HCG and band drums on pallets such that drums with greater than 200 mrem /hr dose rates are in the center or at one en
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HCGS will serialize each drum with a unique number which can be traced to the source of the solidified will be provided by HCGS at SNGS reques Rev. 0 Page 5 of g
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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMEN Limited Quantity Shipments HCGS will perform all requirements (with for Limited the exception Quantity shipments originating from NCGS of waste shipments for burial) in accordance with 49CFR173.42 .
SNGS will provide technical expertise if requested for these shipment BURIAL SITE ALLOCATIONS Any waste allocation assigned to PSE&GHowever, will be considered administrative anlimits Artificial will Island be assigned allotmen to each Station upon receipt of the allocatio . Each Stations' administrative portion of the 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 )
1987 1988 1989 Total Year 1986 14,655 12,000 56,615 SNGS 16,960 13,000 20,000 24,740 77,727 2987 30,000 HCGS 34,655 36,740 134,342 43,000 Totals 19,947 Note: Any overage in 1986 must be subtracted from the remaining totals for 1987 through 198 . If a Station will require a larger waste volume than its administrative portion, that Station may request a larger portion of the allocatio . To most effectively utiltre burial allocations, wastes with higher dose rates will be given preferential treatment when preparing for shipment Rev. O Page 6 of 8
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- Charges and Cost Acccunting
- for NCGS agrees to be invoiced directly, or charged, g reasonable costs incurrea by SNGS under this agreemen These costs include time a.d m*+erials for the transfer,
loading, documentation and subsequent shipment of the materials. Any costs due to SNGS inspections (such as repackaging required due to an inspection), delays due to SNGS equipment or procedural deficiencies and other costs within SNGS control but outside of HCGS' control will be borne by SNG . HCGS shall budget each subsequent year for costs associated with transportation and burial of radioactive materia . NCGS shall cut a Department Order to SNGS to allow This will charges incurred by SNGS to be charged to NCGS.also this service provided by SNG . Invoices sent to NCGS for signature approval should be processed within three working days of receip . Any extra fees which may be incurred for exceeding the total Artificial Island allocation will be chargeable to the station (s) exceeding its administrative portion in an
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equivalent proportion to its exces .
PROCEDURIS Each Station will implement this program through written procedure . Procedures or revisions which address shipment of radioactive materials will be reviewed by both Station Rev. O Page 7 of 8 e
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- HCGS RADIOACTIVE MATERIALS SHIPMENTS REVIEWE_D G! b Y
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Willian Hunkele, Supervisor 1. ,'
fary/Morrill, Supervisor 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:
//yfl}f $^ //Lt/r7 k ', Y} Roger Salvesen, General Manager John papko, Ge6eral Mar.ager Hope Creek Generating Station Salem Generating Station Alton Thompson /, General Manager
//k/11 $6h &jrp Charles John # , General Manager Nuclear Qua Rty Assurance Nuclear Services l
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