ML20247L802

Responds to Violations Noted in Insp Rept 50-293/89-01. Corrective actions:890215 Radioactive Matl Shipments Suspended Pending Resolution,Rev 7 to Procedure 6.9-200 Approved on 890511 & Nonwaste Shipments Allowed to Resume

ML20247L802
Person / Time
Site:	Pilgrim
Issue date:	05/25/1989
From:	Bird R BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-070, 89-70, NUDOCS 8906020258
Download: ML20247L802 (3)

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8057tWiiDiSOM Pilgrim Nuclear Power Station -

Rocky Hill Road '

e Plymouth, Massachusetts 02360

. Ralph G. Bird.

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senior Vice President - Nuclear -

May 25,.1989 BECo Ltr. 89 070-U.S.. Nuclear. Regulatory Commission

. Attn:

Document Control. Desk Washington, D.C.

20555 Docket No. 50-293 License No. DPR-35

Subject:

.NRC Inspection Report 50-293/89-01.

Dear Sir:

Attached is Boston Edison Company's response to the Notice of Violation.

contained in the subject inspection report.

Please do not hesitate to contact me if there are any questions regarding this repor_t.-

R. G. Bird BPL/bal Attachment-cc:

Mr. Hilliam Russell Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Rd.

King of Prussia, PA 19406 i

Sr. NRC Resident Inspector - Pilgrim Station

'M 8906020258 890525 j

ADOCK0500g3 DR

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ATTACHMENT Boston. Edison. Company Docket No. 50-293 Pilgrim Nucleat Power' Station License No. DPR-35 Notice of Violation l

10 CFR 71.5(a) states in part that "Each licensee who... delivers licensable material to a carrier for transport shall comply with the applicable

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requirements of the regulations appropriate to the mode of transport of DOT in 49 CFR Parts 170 through 189." 49 CFR 172.203(d)(1) states in part that "The description for a shipment of radioactive material must include the following-additional entries as appropriate:

(i) The name of each radionuclides in the

_ radioactive material...(iii) The activity contained in each package of the.

shipment...." 49 CFR 172.204(a) states in part that "...each person who offers a hazardous material for transportation shall certify that the material is offered for transportation in.accordance with this subchapter...."

Contrary-to the above, the licensee made seventeen shipments of contaminated laundry between January 1988 and February 1989 which failed to identify the presence of Iron-55 and the activity resulting from the radionuclides on the shipping papers. Consequently, the shipper's certification was also in error.

Response

Cause:

Pilgrim has considered Iron-55 in waste shipments since October 2, 1986. The personnel responsible for upgrading the program to account R

forLinferred nuclides such as Iron-55, failed to revise the non-waste shipment portion of the affected procedures.

It was incorrectly assumed that inferred nuclides were not required for non-waste shipments.

Corrective Steps Taken and Results Achieved:

On February 15, 1989, radioactive material shipments were suspended pending resolution of the discrepancy in curie calculations (failure to include inferred nuclides). Upon review, it was determined that only non-waste shipments (i.e. laundry shipments) were affected, at which time, waste shipments were authorized to resume.

Revision No. 7 to Procedure No. 6.9-200 " DOT Classifications of Radioactive Material" was approved on May 11, 1989, at which time, non-waste shipments were authorized to resume.

The revision added i

scaling factors for inferred nuclides to curie content determination sheets for non-waste shipments.

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' Corrective Steps Taken to: Avoid Future Violations:-

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, c j, A softwa're' package -to. perform curie calculations and to prepare /..

shipping manifests is-being procured.- This wil1~further minimize the; possibility of' personnel' error in the conduct of radioactive material ic shipments..~

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The' personnel l responsible for radioactive shipments have been

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reorganized from the Radiological Section.to_ a newly created Radwaste

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'and Chemistry Section. This consolidates resources to improve-the-

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technical and' managerial oversight of' radioactive material shipments.

,1 Date of Full: Compliance:

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Full compliance was; achieved.on' February 15,i1989 when radioactive:

' material. shipments were suspended pending resolution of the discrepancy..

' Safety Significance:

.n Failure'to include Iron-55 in curie content. determination's and shipping manifest was an administrative oversight having no impact on the public.

health and safety.. Iron-55 does'not constitute an external radiation-hazard.

BPL/bal.

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