IR 05000293/1986010: Difference between revisions

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{{Adams
{{Adams
| number = ML20204A421
| number = ML20212A612
| issue date = 05/01/1986
| issue date = 07/22/1986
| title = Safety Insp Rept 50-293/86-10 on 860324-27.Violations Noted: Failure to Conduct QC of Packages Transferred to Land Disposal Facility & Adhere to Station Approved Procedure
| title = Ack Receipt of 860620 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/86-10. Corrective Actions Will Be Examined During Future Insp
| author name = Miller M, 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 = Harrington W
| addressee affiliation =  
| addressee affiliation = BOSTON EDISON CO.
| docket = 05000293
| docket = 05000293
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-293-86-10, IEB-79-19, NUDOCS 8605120194
| document report number = NUDOCS 8607290082
| package number = ML20204A416
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 8
}}
}}


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=Text=
=Text=
{{#Wiki_filter:.
{{#Wiki_filter:_ _ - _ .
, U.S. NUCLEAR REGULATORY COMMISSION
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JUL 2 21986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Ha rington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199
,
Gentlemen:
Subject: Inspection No. 50-293/86-10 We acknowledge receipt of your letter dated June 20, 1986, in response to our letter dated May 6, 1986.


==REGION I==
i
Report N /86-10 Docket N License N OPR-35 Priority Category Licensee: Boston Edison Company M/C Nuclear 25 Braintree Hill Office Park Braintree, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plymouth, Massachusetts Inspection Conducted: March 24- 27,1986 Inspectors: k aAlv h 42f4A M. Miller, Radfation Specialist yh'[f6 datd Approved by: _
  ! 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 your licensed program.
b o S/< /JC W. Pasciak, Chief, Effluents Radiation 'dite Protection Section Inspection Summary: Inspection on March _24-21 1986 (Report No. 50-293/86-10).


Areas Inspected: Routine, unannounced safety inspection by a regionally based inspector of the licensee's radioactive waste operation, packaging and trans-portation program including, previously identified items, quality assurance /
Your cooperation with us is appreciated.
quality control, package selection, and shipment of radioactive material Results: Two apparent violations were identified: failure to conduct a quality control function, paragraph 4.0, and failure to adhere to a station approved procedure, paragraph e60506 3 PDR ADOCK 0500 G


_ .
Sincerely, B
.
hi inal Sigung 3,,
.
Nb mas T. Martin, Dir %ector Division of Radiation Safety and Safeguards
DETAILS 1.0 Licensee Personnel
- cc:
*J. Seery, Acting Station Manager
L. Oxsen, Vice President, Nuclear Operations A. E. Pedersen, Station Manager Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes Senator Edward P. Kirby
*T. Sowdon, Radiological Section Manager
*B. Eldredge, Acting Chief Radiological Engineer
*F. Famulari, Quality Control Group Leader
*J. Mattia, Quality Assurance Audit Group Leader
*R. Schuler, Assistant Chief Radiological Engineer-Radwaste
*M. Bonnett, RP Supervisor-Shipping & Handling P. Cormier, Senior Nuclear Training Specialist L. Dooley, Technical Training Supervisor
*J. Poorbaugh, Senior QA Engineer T. Sanpere, Senior QC Engineer
*M. Andrews, QC Engineer
*L. Beckwik, Plant Engineer The inspector also contacted other licensee and contractor personne .1 NRC personnel
* Eichenholz, Senior Resident Inspector
* Denotes attendance at the NRC/ licensee exit meeting on [[Exit meeting date::March 27, 1986]].
2.0 Purpose
'
'
The purpose of this routine inspection was to review the licensee's transportation activities with respect to the following elements:
The Honorable Peter V. Forman Sharon Pollard Public Document Room (PDR)
-Status of Previously Identified Items-Quality Assurance / Quality Control-Package Selection-Shipment of Radioactive Materials 3.0 Status of Previously Identified Items (Closed) Violations (50-293/84-13-01): Failure to have three procedures reviewed and approved as required by technical specification The licensee reviewed and approved the three contractor procedures related to waste processing in 1984. Subsequent review by the licensee's QA group and a consultant audit in 1984 and 1985, respectively, identified addi-tional contractor procedures that had not been approved. The inspector noted the licensee's QA process resolved the licensee's internal dispute concerning the requirement to have contractor procedures approval. To date, all radioactive waste processing and transportation procedures have been reviewed and approve .
local Public Document Room (LPDR)
' Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2)
0FFICIAL RECORD COPY RL PILGRIM 86-10 - 0001.0.0 07/18/86 8607290082 e6072223 PDR ADoCK 05    g f@h G  --


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* Boston Edison Company M/C Nuclear 2 e
bec:
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Region I Docket Room (with concurrences)
'
Management Assistant, ORMA (w/o enc 1)
Section Chief, DRP W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR PA0 (2) SALP Reports Only Robert J. Bores, DRSS l
i
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      *
l
!
R  SS RI S Miller /geb Pasci k Bellam
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7/Aa/86-yw ( 1lt'l l ~
  . OFFICIAL RECORD COPY RL PILGRIM 86-10 - 0002.0.0 l . 07/18/86
. - ,
  *,


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i
(Closed) Violation (50-293/84-13-02): Failure to comply with the conditions of C of C 6601 regarding decay heat and gas generation. The licensee provides a radwaste supervisor sign-off for each shipment to ensure the conditions of the C of C are being followed. With regard to decay heat and gas generation, the licensee calculates the decay heat load and/or vents the shipping container, as appropriate to the type and amount of radioactive wast (Closed) Violation (50-293/84-13-03): Failure to identify transport f5 packages as a component of the licensee's quality assurance program. The inspector verified that both transport packages and High Integrity Containers (HICs) were identified as components of the licensee's quality assurance program, Revision E1 (Closed) Deviation (50-293/84-13-04): Failure to fulfill commitment  ;
      -
regarding completion of IE Bulletin 79-19 trainin The inspector noted that the licensee implements a comprehensive radioactive waste training program for all plant staff and contractor personnel, who are involved with waste processing and transportatio (Closed) Inspector Follow-up Item (50-293/85-13-05): Revise procedures checklist to include cask leak tests and cask seal conditions of C uf C 5805, Revision 13. The inspector noted that temporary procedure T 85-39 was revised to ensure the cask was leak tested and seal maintenance had been performe (Closed) Violation (50-293/86-04-01): Failure to meet packaging requirements for low specific activity radioactive material. The inspector determined the licensee painted the Seatrain containers to prevent rusting and to ensure radioactive waste would be packaged in strong tight packages. The licensee also implemented a procedure for loading Seatrain containers which required inspection of the container during receipt and prior to shipmen In addition, the licensee's QC group increased its surveillance of strong tight package waste shipment .0 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 Appendix B to 10 CFR 50 and which is established, maintained and executed with regard to transport packages is acceptable to meet the requirements of 10 CFR 71, Suopart H. The licensee elected to apply their currently established 10 CFR 50, Appendix B, QA program to the packaging and shipment of radioactive material The Itcensee's performance relative to this criteria was determined from
-
discussions with the QC Group Leader, Senior QC Engineer, Senior QA Engineer and the Chief Radiological Engineer-Radwaste; and the QC surveillance reports and QA audit reports for 1985 with regard to radioactive waste processing and shipmen _ _ _ _ _ _ -_  _


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BOSTON EDISON COMPANY B00 BOYLSTON STREET SOSTON.:M ARBACHustTTE O2199 WILLIAM D. HARRlNGTO N K usee nsa posesse m
      '
mete 6saa June 20, 1986 BECo Ltr. :#86- 085


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      -
4.1 Radwaste Generator QC Program The licensee's performance in the conduct of a QC program under 10 CFR 20.311(d)(3) was determined by review of procedures for preparing radwaste shipments, examination of radwaste and QC sign-offs related to shipments of dewatered resins and review of QA audits which performed independent determinations of waste classification under 10 CFR 61.5 Within the scope of this review, the following violation was iden-tified:
      ..
10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires a licensee who transfers radioactive waste to a land disposal facility to conduct a quality control program to assure compliance with 10 CFR 61.5 The licensee had transferred several dewatered radioactive waste shipments to a land disposal facility during 1984 and 1985 and the licensee had not conducted a quality control program to assure compliance with 10 CFR 61.56, inasmuch as the licensee had not verified that spent resin contained less than 1% liquid by volume when the resin was in a disposal container (high integrity container) ,
Mr. Thomas T. Martin, Director  -
designed to ensure stabilit The inspector noted as of April, 1985, the licensee did institute a QC check-off that ensured the acceptance criteria was documented for the applicable radwaste shipments, however, QC verification of the dewatering process by QC staff or QC designated radwaste staff had not been performe Failure to conduct a quality control program to assure compliance with 10 CFR 61.56 represents a violation of 10 CFR 20.311(d)(3).
Division of Radiation Safety and Safeguards
      *
U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406
    .
Subject: BECO Response to Notice of Violation as Contained in NRC Inspection Report 86-10, dated May 6, 1986 I


This item will be reviewed during a subsequent inspection (293/86-10-01).
==Dear Mr. Martin:==
This letter is in response to the notice of violation as contained in the subject letter. The violations and Boston Edison's responses are enclosed as an attachment to this letter.  ,
Please note that this response is being sent in accordance with an extension of the response due date to June 20, 1986 as agreed to in a telecon to Ms.


4.2 QC Surveillance Activities The site QC organization provides inspections of radwaste prepara-tin , packaging and shipping activities as well as receipt inspection of *..ansport packages. The licensee conducts 100 percent surveil-lance of radioactive waste snipments made in NRC approved cask The following QC instructions and supporting reports were reviewed:
Marie Miller of your staff on June 4, 1986.
* QCI 19.01, Revision 4, " Inspection of Low Level Radioactive W. o r Packaging and Shipping Activities"
*
QCI 19.02, Revision 0 and Revision 1 (Draf t), " Receipt Inspec-tion of High Integrity Containers"


.
Should you have any further questions regarding this issue, please do not hesitate to contact me.


.
~ . .
*
Very truly yours,
Selected surveillance reports for 198 Within the scope of this review, the following was noted:
      *
The inspector noted that the QC organization generally verified the completeness of the shipping papers and adherence to packaging requirements and related procedures. However, the inspector noted that the QC representative did not independently verify the accuracy of the shipping papers. The inspector also noted that peer review by qualified members of the Waste Management group to ensure accurate information was not routinely completed. Problems related to this lack of review are discussed in paragraph 6.0 of this repor .3 Audits The licensee's program for audits of radwaste preparation, classi-fication, transport packages and shipping activities was reviewe Audits were conducted by a qualified QA auditor and supported by qualified technical specialist, as necessary. The inspector reviewed the following audits and surveillances for 1984, 1985 and 198 *
W. D. Harrington M
Audits 84-9 (April,1984), and 85-6 (March,1985)
Attachment  '+
*
JC/vep-ffbC131(3i3fiCNde-
Surveillances 85-9.5-13 (September, 1985), and 86-2.1-3 (March,1986).


The audits and surveillances were performed to verify the station's implementation of 10 CFR 20, 61, 71 and 49 CFR requirements and to applicable criteria of 10 CFR 50, Appendix B were being implemente Within the scope of this review, the following concern was noted:
      .
The inspector noted that audit deficiencies had been reviewed and evaluated by licensee management. However, one finding was repeti-tious and had not been resolved. Audit 85-6, DR 1376 identified that transport packages and services were being procured and utilized from a vendor without a current purchase orde The revised purchase order was issued on July 25, 1985, to expire on December 31, 198 Surveillance 86-2.1-3, DR 1509, conducted March 11, 1986, identified the same violation of 10 CFR 71.10 The licensee stated they had instituted a document control system to prevent this problem as well as ensuring site personnel expedite the purchase order process. The licensee stated this deficiency would be resolved. In addition, the licensee stated they would determine if other services requiring adequate quality were being provided without a current purchase order. This item will be reviewed during a subsequent inspection (293/86-10-02).


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!
,  ATTACHMENT
; NRC NOTICE OF VIOLATION (86-10-04)
:
Technical Specification 6.8 requires that written procedures and administrative policies be established, implemented and maintained, that l
meet or exceed the requirements and recommendations of Appendix ' A' of
. Regulatory Guide 1.33, 1972. Station approved Procedure 1.3.4,
  " Procedures", requires in Section III.A that approved written procedures i  be adhered to by all station personnel. Procedure PNPS-6.9-160, Revision
'
20 specifies in part, (1) to survey material to be packaged and to document the survey results on appropriate radiation level at the surface
;  of the package, and the total activity within the package on the shipping manifest.


.
Contrary to the above, on January 23, 1985, July 9, 1985, and August 2,
5.0 Package Selection The licensee's program for selection of packages was examined against the requirements of 10 CFR 71.87 and within the framework of the D0T require-ments of 49 CFR Part 17 For dry radioactive waste, the licensee used steel boxes or Seatrain containers, as strong tight containers. Dewatered resins and radioactive material shipments, such as irradiated reactor components, requiring the use of an NRC Certified package (outer container) were made in vendor supplied casks. Copies of the Certificate of Compliance including draw-ings were available for all Type A and Type B casks in us Within the scope of this review, the following issue was identified:
'
* The inspector noted that the licensee had made radicactive waste shipments in an approved package (Certificate of Compliance 9079),
1985, radiation surveys of packaged irradiated reactor components were not documented on appropriate radiation survey forms and maps; the maximum  '
but was shipped as package model 14-170. Model 14-170 currently is not approved by C of C 907 The licensee stated they would discuss this labeling conflict with their vendo The inspector stated this item would be reviewed during a sub-sequent inspection, and any subsequent shipment as package model would be considered an apparent violation of a condition of the C of C until Cask 14-170 is approved by the NRC (293/86-10-03).
radiation level at the surface of the package was incorrect for shipment numbers 85-06 and 85-66' and the total radioactivity contained within shipment number 85-79 was incorrectly listed during transport.


6.0 Shipment of Radioactive Materials The transportation of licensed material was reviewed against the criteria contained in 10 CFR 71, " Packaging and Transportation of Radioactive Material, " 10 CFR 20.311(d)(3), " Transfer for disposal and manifests,"
BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective action to correct the condition, the incorrect entry associated with shipment number 85-79 (being a self-identified deficiency) was corrected on August 5, 1986.
and 10 CFR 61.55, " Waste Classification," and 10 CFR 61.56, " Waste Char-acteristics "
The licensee's performance relative to these criteria was determined by the following a
discussion with the Assistant CRE-Radwaste and his staff;
*
review of fifteen shipping manifests and related documents from 1985 and 1986;
*
review of selected program procedures including the following:
*
6.9-160, Revision 20, " Shipment of Radioactive Material"
*
6.9-165, Revision 4, " Handling & Loading Procedure LL-50-100 Shipping Cask"
*
6.9-184, Revision, " Handling & Loading CNSI 1-13G"
*
6.9-188, Revision 0, '' Dewatering Bead Resin in 14-195 or Small Liners"
*
6.9-190, Revision 0, " Dewatering 14-195 or Smaller Liners Containing Powder Resin, Precoat Material or D.E."


.
As corrective action to preclude recurrence, an increased emphasis has  ,
I
been placed on the quality of surveys (as discussed and reinforced at the
;
daily meetings with technicians). It is planned to use this particular
'
violation as a " lesson learned" example in the training which we provide
!  to health physics technicians.


  .
;
,
l As further corrective action to preclude recurrence, technicians are now assigned to shipment-related functions for a longer period of time. This longer assignment will result in an increased familiarity with the procedures and paperwork involved in the radwaste shipping process.


y .
i
,
* 6.9-193, " Classification of Radwaste 10 CFR 61"
* 6.9-195, " Completion of Radioactive Waste Shipping Papers" 6.9-200, " DOT Classification of Radioactive Material"
'
'
*
The combination of the above actions has already, and will continue, to result in higher quality records from both a content and a consistency 1  viewpoint.
* TP 85-39, Revision 1, " Handling and Lo, ling Procedure for CNIS 3-55 Cask."


Within the scope of this review, one violation was identified, i Technical Specification 6.8 requires that written procedures and admi-
Full compliance was achieved on August 5, 1985, the date upon which the paperwork related to shipment number 85-79 was corrected.
! nistrative policies be established, implemented and maintained, that meet or exceed the requirements and recommendations of Appendix A of Regulatory Guide 1.33, 1972. Station approved procedure 1.3.4, " Procedures,"
;- requires in Section III.A that approved written procedures be adhered to
. by all station personne Procedure 6.9-160, Revision 20 specifies in i
part, (1) to survey material to be packaged and to document the survey results on i appropriate radiation survey forms, and (2) to enter the maximum radiation
'
level at the surface of the package, and the total activity within the package on the shipping manifest.


'
;
Contrary to the above, on January 23, 1985, July 9, 1985, and August 2, 1985, radiation surveys in support of radioactive waste
! shipments of packaged irradiated reactor components were not docu-l mented on appropriate radiation survey forms and maps or facsimile j with the same information, and the maximum radiation level at the surface of the package containing dewatered bead resin or other dry radioactive j waste was incorrect; and the total isotopic activity of an irradiated i reactor component shipment was incorrectly listed, as 279 Curies instead l of 379 Curies during transport. These shipments were identified as 85-06, 85-66 and 85-79, and were made on January 23, 1985, July 9, 1985, and August 2, 1985, respectivel The inspector stated that failure to adhere to a station approved proce-
,
,
dure with regard to radiation surveys and indicating total isotopic i activity represents a violations of Technical Specification (293/86-10-04).
Page 1 of 2
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i The inspector also expressed concern to the licensee that (1) a waste classifitation error for shipment 86-16 occurrgd (identified by the
      - - -___ _ _ _ _
,
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licensee's QC representative during transit); and (2) the licensee misrepre-
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>
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sented the waste form and quantity on the Massachusetts State Notification Form for shipment 85-66 (indicated fiter media with activity of 200 Curies
As an added note, we would like to correct part of the basis of the subject violation which states that ...
,
  " procedure PNPS-6.9-160, Revision 20 specifies in part, (1)
instead of irradiated reactor components with activity of 15,900 Curies).
to survey material to be packaged and to document the survey results on appropriate radiation survey forms and maps, and (2) to document the maximum radiation level at the surface of the package, and the total activity within the package on the shipping manifest."
: These were additional examples of either inaccurate or incomplete shipping q paper documentation.
 
Procedure 6.9-160 does not contain the above statement, although it is our policy to document survey results in an appropriate manner.
 
NRC NOTICE OF VIOLATION (86-10-01)
10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires licensees who transfer radioactive waste to a land disposal facility to conduct a quality control program to assure compliance with 10 CFR 61.56.


b The licensee stated that three or four RP technicians would selectively u rotate through the Waste Management Group to enhance implementation and adherence to procedures. In addition, the licensee would consider the use
'
; of computers for some aspects of manifest preparation and related docu-
l Contrary to the above, the licensee had transferred Several radioactive waste shipments composed of dewatered resins and diatomaceous earth absorbers to a land disposal facility during 1984 and 1985 and the licensee had not conducted a quality control program to assure that the packages did not contain free standing liquid greater than 1% of the waste volume, and that the waste was structurally stable for compliance with 10 CFR 61.56.
,
mentation.


b i
BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective step: to correct the condition and to preclude recurrence, we have taken the following actions. First, the Quality Control Instruction (QCI 19.01) has been revised to require a yearly surveillance inspection of the dewatering processes used at PNPS. The revised instruction was issued on May 1, 1986. Secondly, the on-site Q.C. Group will now conduct surveillance inspections of container loading, dewatering, and shipping preparation activities.
l


.
The above corrective steps will ensure that Boston Edison's radioactive waste handling activities are done in compliance with 10 CFR 61.56. Full compliance was reached on May 1, 1986, the date upon which the yearly surveillance inspection requirement was incorporated.


e 7.0 Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 27, 1986. The inspector summarized the scope of the inspection and finding At no time during this inspection was written material provided to the license .
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Revision as of 21:20, 21 January 2021

Ack Receipt of 860620 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-293/86-10. Corrective Actions Will Be Examined During Future Insp
ML20212A612
Person / Time
Site: Pilgrim
Issue date: 07/22/1986
From: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Harrington W
BOSTON EDISON CO.
References
NUDOCS 8607290082
Download: ML20212A612 (2)
v • d • e


Text

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JUL 2 21986 Docket No. 50-293 Boston Edison Company M/C Nuclear ATTN: Mr. William D. Ha rington Senior Vice President, Nuclear 800 Boylston Street Boston, Massachusetts 02199

,

Gentlemen:

Subject: Inspection No. 50-293/86-10 We acknowledge receipt of your letter dated June 20, 1986, in response to our letter dated May 6, 1986.

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 your licensed program.

Your cooperation with us is appreciated.

Sincerely, B

hi inal Sigung 3,,

Nb mas T. Martin, Dir %ector Division of Radiation Safety and Safeguards

- cc:

L. Oxsen, Vice President, Nuclear Operations A. E. Pedersen, Station Manager Paul Levy, Chairman, Department of Public Utilities Edward R. MacCormack, Senior Regulatory Affairs and Program Engineer Chairman, Board of Selectmen Plymouth Civil Defense Director J. D. Keyes Senator Edward P. Kirby

'

The Honorable Peter V. Forman Sharon Pollard Public Document Room (PDR)

local Public Document Room (LPDR)

' Nuclear Safety Information Center (NSIC)

NRC Resident Inspector Commonwealth of Massachusetts (2)

0FFICIAL RECORD COPY RL PILGRIM 86-10 - 0001.0.0 07/18/86 8607290082 e6072223 PDR ADoCK 05 g f@h G --

- _ _

.

  • Boston Edison Company M/C Nuclear 2 e

bec:

.

Region I Docket Room (with concurrences)

'

Management Assistant, ORMA (w/o enc 1)

Section Chief, DRP W. Raymond, SRI, Vermont Yankee T. Shedlosky, SRI, Millstone 1&2 H. Eichenholz, SRI, Yankee P. Leech, LPM, NRR PA0 (2) SALP Reports Only Robert J. Bores, DRSS l

i

!

l

!

R SS RI S Miller /geb Pasci k Bellam

'

7/Aa/86-yw ( 1lt'l l ~

. OFFICIAL RECORD COPY RL PILGRIM 86-10 - 0002.0.0 l . 07/18/86

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  • ,

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x 6 . =

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BOSTON EDISON COMPANY B00 BOYLSTON STREET SOSTON.:M ARBACHustTTE O2199 WILLIAM D. HARRlNGTO N K usee nsa posesse m

'

mete 6saa June 20, 1986 BECo Ltr. :#86- 085

-

..

Mr. Thomas T. Martin, Director -

Division of Radiation Safety and Safeguards

U. S. Nuclear Regulatory Commission Region 1 - 631 Park Avenue King of Prussia, PA 19406

.

Subject: BECO Response to Notice of Violation as Contained in NRC Inspection Report 86-10, dated May 6, 1986 I

Dear Mr. Martin:

This letter is in response to the notice of violation as contained in the subject letter. The violations and Boston Edison's responses are enclosed as an attachment to this letter. ,

Please note that this response is being sent in accordance with an extension of the response due date to June 20, 1986 as agreed to in a telecon to Ms.

Marie Miller of your staff on June 4, 1986.

Should you have any further questions regarding this issue, please do not hesitate to contact me.

~ . .

Very truly yours,

W. D. Harrington M

Attachment '+

JC/vep-ffbC131(3i3fiCNde-

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,

!

, ATTACHMENT

NRC NOTICE OF VIOLATION (86-10-04)

Technical Specification 6.8 requires that written procedures and administrative policies be established, implemented and maintained, that l

meet or exceed the requirements and recommendations of Appendix ' A' of

. Regulatory Guide 1.33, 1972. Station approved Procedure 1.3.4,

" Procedures", requires in Section III.A that approved written procedures i be adhered to by all station personnel. Procedure PNPS-6.9-160, Revision

'

20 specifies in part, (1) to survey material to be packaged and to document the survey results on appropriate radiation level at the surface

of the package, and the total activity within the package on the shipping manifest.

Contrary to the above, on January 23, 1985, July 9, 1985, and August 2,

'

1985, radiation surveys of packaged irradiated reactor components were not documented on appropriate radiation survey forms and maps; the maximum '

radiation level at the surface of the package was incorrect for shipment numbers 85-06 and 85-66' and the total radioactivity contained within shipment number 85-79 was incorrectly listed during transport.

BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective action to correct the condition, the incorrect entry associated with shipment number 85-79 (being a self-identified deficiency) was corrected on August 5, 1986.

As corrective action to preclude recurrence, an increased emphasis has ,

been placed on the quality of surveys (as discussed and reinforced at the

daily meetings with technicians). It is planned to use this particular

'

violation as a " lesson learned" example in the training which we provide

! to health physics technicians.

l As further corrective action to preclude recurrence, technicians are now assigned to shipment-related functions for a longer period of time. This longer assignment will result in an increased familiarity with the procedures and paperwork involved in the radwaste shipping process.

i

'

The combination of the above actions has already, and will continue, to result in higher quality records from both a content and a consistency 1 viewpoint.

Full compliance was achieved on August 5, 1985, the date upon which the paperwork related to shipment number 85-79 was corrected.

,

Page 1 of 2

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As an added note, we would like to correct part of the basis of the subject violation which states that ...

" procedure PNPS-6.9-160, Revision 20 specifies in part, (1)

to survey material to be packaged and to document the survey results on appropriate radiation survey forms and maps, and (2) to document the maximum radiation level at the surface of the package, and the total activity within the package on the shipping manifest."

Procedure 6.9-160 does not contain the above statement, although it is our policy to document survey results in an appropriate manner.

NRC NOTICE OF VIOLATION (86-10-01)

10 CFR 20.311(d)(3), " Transfer for disposal and manifests" requires licensees who transfer radioactive waste to a land disposal facility to conduct a quality control program to assure compliance with 10 CFR 61.56.

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l Contrary to the above, the licensee had transferred Several radioactive waste shipments composed of dewatered resins and diatomaceous earth absorbers to a land disposal facility during 1984 and 1985 and the licensee had not conducted a quality control program to assure that the packages did not contain free standing liquid greater than 1% of the waste volume, and that the waste was structurally stable for compliance with 10 CFR 61.56.

BOSTON EDISON COMPANY RESPONSE Boston Edison agrees with the violation. As corrective step: to correct the condition and to preclude recurrence, we have taken the following actions. First, the Quality Control Instruction (QCI 19.01) has been revised to require a yearly surveillance inspection of the dewatering processes used at PNPS. The revised instruction was issued on May 1, 1986. Secondly, the on-site Q.C. Group will now conduct surveillance inspections of container loading, dewatering, and shipping preparation activities.

The above corrective steps will ensure that Boston Edison's radioactive waste handling activities are done in compliance with 10 CFR 61.56. Full compliance was reached on May 1, 1986, the date upon which the yearly surveillance inspection requirement was incorporated.

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