ML20207S472

Responds to NRC Re Violations Noted in Insp Rept 50-354/87-02.Corrective Actions:Shipment of HCGS Radwaste Suspended Until Remedial Action Taken.Rev 0 to Ltr of Agreement Between Hope Creek & Salem Nuclear Stations Encl

ML20207S472
Person / Time
Site:	Salem, Hope Creek, 05000000
Issue date:	03/13/1987
From:	Corbin McNeil Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLR-N87046, NUDOCS 8703190512
Download: ML20207S472 (12)

Text

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..,4 Pubhc Service Electric and Gas Company Corbin A. McNeill, Jr.

Public Service Electnc and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609 339-4800 Vice President -

Nuclear March 13, 1987 NLR-N87046 U. S. Nuclear Regulatory Commission i

Attention:

Document Control Desk Washington, DC 20555 Gentlemen:

NRC INSPECTION REPORT #87-02 DOCKET NO. 50-354 HOPE CR,EEK 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 shipment.

Hope Creek Generating Station is apparently being charged with three separate violations (354/87-02-01, 02, and 03) for a single Severity Level IV problem that involves redundant requirements appearing in several regulations.

We submit that the application of multiple violations for errors that your February 12, 1987 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 violation.

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NAR 13137 USNRC Document Control Desk 2

Amplification of this concern and our response to the Notice of Violation, pursuant to the provisions of 10 CPR 2.201, are provided in Attachment 1.

Sincerely, N

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Attachment C

Dr. Thomas E. Murley, Administrator USNRC Region I 631 Park Avenue King of Prussia, PA 19406 USNRC Resident Inspector P.O. Box 241 Hancock's Bridge, NJ 08038

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~ ATTACHMENT 1 l

'10-CFR 2.201 INFORMATION-PUBLIC. SERVICE ELECTRIC AND. GAS COMPANY

-HOPE CREEK' GENERATING STATION 1

RESPONSE TO NOTICE OF VIOLATION

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INSPECTION--REPORT NUMBER 50-354/87-02 4

In your' letter dated February 12, 1987, Violat' ion A cited 1m failure to comply with the requirements of 10CFR20.311(b) and

'(c), which state, in part,'that the generator of' radioactive

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waste must-provide, in the manifest accompanying each. waste-shipment, the radionuclide identity and quantity and the total radioactivity of the shipment.

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 4

regulation contain basically the same requirements as those in Violation A.

1.

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 L

IDENTIFIED AS TWO VIOLATIONS, " CATEGORIZED IN THE AGGREGATE i-

.AS...(ONE)... PROBLEM", AND IS ADMINISTRATIVELY BEING CHARGED L

AGAINST THE HOPE CREEK STATION AS THREE VIOLATIONS

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.(354/87-02-01, 354/87-02-02, AND 354/87-02-03).

WE ARE L

CONCERNED THAT THIG ADMINISTRATIVE ASSESSMENT IS OVERLY SEVERE AND REQUEST THAT THE INCOMPLETE IDENTIFICATION,

-QUANTIFICATION AND CERTIFICATION OF THE SUBJECT RADIOACTIVE WASTE SHIPMENT BE CONSIDERED AS ONE VIOLATION.

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2.

THE ROOT CAUSE OF THE VIOLATION WAS PERSONNEL-ERROR WHEREIN

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THERE WAS INADEQUATE TRANSFER OF INFORMATION BETWEEN THE f

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 PERSONNEL.

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 QUALITY 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 PROGRESS.

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-ATTACHMENT'l 3.

IMMEDIATS CORRECTIVE ACTIONS-i Upon diccohery of the errors in the sh'iptcencs, shipment of HCGS 'radwaste was immediat'ely_ suspJnded _ by/ the Radiation Protection /Ch'emistry Mannser!until allinecestary remedial #

action was taken to permit. proper classification and manifesting.

A comprehensive review was made of all seven shipments to diagnose the interface mechanics that;_-

contributed to the errors.

A thorough database review was accomplished incorporating gancaa spectroscopy data from

'!t several months of radwaste information.

Based on this

.. e review, an updated' database analysis report was generated using site-specific gamma spectr scopy data.

Aitssk team was assembled to correct the interf ee mechanics.

06 January 30, 1987, the radwaste shipping interface aqreament 1otween HCGS and SGS (copy attached) was fully executed.

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CORRECTIVE ACTIONS IN PROGRESS A transfer flow chart matrix was developed to assist in the preparation of new procedures covering all? interface mechanics.

The four procedures developed to support radwaste shipment activities are:

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RP 902 Radioactive Waste Sampling And Classification i

r RP 903 Operating Inctructions for RADMAN RP 904 Dose / Curie C'onversion falculations RP 905 Transfer of Radioactivt Wante To SGS

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These procedurca will be fully'implenented prior to commencement ct fradwaste shipments from-HCGS.

The procedures

'1 and the attached agreement should clv;se Inspection Open Item 354/86-44-02.

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WE WILL BE IN FULL COMPLIANCE BY MARCH 30, 1987 OR PRIOR TO RESUMPTION OF RADWASTE SHIPMENTS PROM HOPE CREEK GENERATING STATION, WHICH EVER IS EARLIER.

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LETTER OF AGREEMENT 7

BETWEEN HOPE CREEK j

GENERATING STATION i

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SALEM NUCLEAR GENERATING STATION

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RADIOACTIVE MATERIALS SHIPMENTS j'

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January 30, 1987 i

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RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEM b

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's PURPOSE 1

As agreed in the. fall of 1985 Salem Nuclear Generatingwill a Station (SNGS)

SNGS will then be Hope Creek Generating Station.(HCGS).

In addition SNGS responsible to ship and bury the waste.

will provide for radioactive material shipments of otherThis document de than waste as needed by McGS.

Station responsibilities for both SNGS, the HCGS and the Site Services Department tc' support radioactive material shipments from a single Nuclear Department program.

SCOPE The guidelines set forth in this document are applicable to all radioactive material shipments originating from HCGS unles's specific instances require exemptions as agreed to by the Radiation Protection / Chemistry Managers of SNGS and Irradiated fuel in any form is specifically not HCGS.

included in this agreement.

PHILOSGPHY Shipments of radioactive materials originating'from the chances of making errors common to the complexity;of Regulatory requirements.

To this end, all shipments of radioactive materials from Artificial-Island will' be consigned from SNGS.

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Rev. 0 Page 2 of 8

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RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREEMENT i

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-RESPONSIBILITIES General i

1.

Possession of radioactive materials will transfer to SNGS for shipment.

Ownership of the material will remain with HCGS.

2.

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 SNGS.

3.

Materials will be packaged in shipping containers by HCGS at their facility.

4.

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 must be performed by HCGS to properly select containers.

5.

All external communications from the Stations in regard to radioactive shipments will be performed by SNGS.

i HCGS will be involved with external communications only when requested by SNGS, with the exception of Limited Quantity L

Shipments made by HCGS.

6.

Radiation surveys of packages will be performed by HCGS at_ contact and'at one meter from the surface of the p

package, using a calibrated ion chamber instrument.

Additional readings, as required by Regulations, will be performed by HCGS while packages remain at HCGS.

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 j

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 t

to transfer to SNGS.

7.

Packages which do not meet the site release limits will be decontaminated to the maximum extent practical by HCGS.

If release limits cannot be met, but contamination is within regulatory limits, the material may be transferred to SNGS at their concurrence.

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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 Pase 3 of 8 Rev. O

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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 SNGS.

SNGS will provide personnel to accept packages when scheduled with HCGS.

Site Services will assist with the i'

transfer of materials from HCGS to SNGS.

They will also assist SNGS with shipments off site.

e HCGS will assure that packages are undamaged prior to 9.

i transfer.

Minor damages incurred during transport to SNGS will be corrected by SNGS.

Packages damaged, or otherwise rendered unshippable, after transfer to SNGS will be restored to a shippable configuration by SNGS.

10.

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 shipment.

11.

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 requirements.

Materials transferred to SNGS will be loaded onto the 12.

final shipping vehicle by SNGS in accordance with their In the event that materials to be shipped have procedures.

I 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 procedures.

HCGS will perform waste stream sampling and analysis 13.

j to meet waste classification requirements.

This will be performed in accordance with the HCGS Process Control 4

All data Program and SNGS approved procedure requirements.

concerning waste types shall be gathered by and approved by l

The applicable forms (Radman computer loading forms)

HCGS.

shall be completed by HCGS and forwarded to SNGS to be All computer generated entered into the computer data base.

data base reports shall be reviewed and approved by HCGS and SNGS prior to use.

The Manifesting shipments will be performed by SNGS.

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computer generated manifest is produced using the data supplied and approved by HCGS.

(This includes Radman data base information as well as survey data).

Updated survey data may be used due to radioactive decay considerations.

15.

In the event that long-term storage (e.g., greater is than the time required to accumulate a full shipment) required due to the inability to ship the material, HCGS will store radioactive material that they produce.

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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTE I

l Compacted Waste (Boxes)

Boxes will be marked by HCGS with unique numbers, I

which relate to the documentation relevant to each box,The num 1.

I 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 2.

This will include, but is not limited to, performing surveys of trash prior to compaction, equalizing each container.

dose rates throughout the container to the maximum extent practical and placing high dose items in the center of theSNGS container where possible.this activity, and make recommendations i

HCGS will meet regulatory and/or burial site requirements for materials shipped in boxes.

3.

Solidified Wastes (drums)

Drums with contact dose rates greater than 400 mrem /hr will be stored at HCGS until transferred to SNGS in a l.

for transfer to a l

suitable On-site Storage Container (OSCI) shipping cask.

Drums with less than 400 mrem /hr at contact will beH palletized on 3-or 6-drum pallets by HCGS.

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and band drums on pallets such that drums with greater than 200 mrem /hr dose rates are in the center or at one j

the pallet.

HCGS will serialize each drum with a unique number which can be traced to the source of the solidifie 3.

f will be provided by HCGS at SNGS request.

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HCGS RADIOACTIVE MATERIALS SHIPMENTS - LETTER OF AGREE Limited Quantity Shipments HCGS will perform all requirements for Limited (with.the exception 1.

Quantity shipments originating from HCGSin accordance with of waste shipments for burial) 49CFR173.421.

SNGS will provide technical expertise if requested for 2.

these shipments.

BURIAL SITE ALLOCATIONS Any waste allocation assigned to PSEEG will be 1.

However, considered an Artificial Island allotment.

administrative limits will be assigned to each Station upon receipt of the allocation.

Each Stations' administrative portion of the allocation will be determined in accordance with the system 2.

adopted in The Low Level Radioactive Waste Policy Amendments for SNGS The following breakdown is the result Act of 1985.

and HCGS:

Waste Volume Allocation (ft )

3 Total Year 1986 1987_

1988 1989 SNGS 16,960 13,000 14,655 12,000 56,615 HCGS 2987 30,000 20,000 24,740 77,727_

Totals 19,947 43,000 34,655 36,740 134,342 Any overage in 1986 must be subtracted from the remaining Note:

totals for 1987 through 1989.

If a Station will require a larger waste volume than 3.its administrative portion, that Station may request a larger portion of the allocation.

To most effectively utilize burial allocations, wastes with higher dose rates will be given preferential treatment 4.

when preparing for shipments.

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Charges and Cost Accounting HCGS agrees to be invoiced directly, or charged, for 1.

'g reasonable costs incurred by SNGS under this agreement.

These costs include time and materials for the transfer, loading, documentation and subsequent shipment of the 4

Any costs due to SNGS inspections (such as materials.

delays due to repackaging required due to an inspection), procedural deficienc SNGS equipment or within SNGS control but outside of HCGS' control will be borne by SNGS.

HCGS shall budget each subsequent year for costs associated with transportation and burial of radioactive 2.

4 material.

HCGS shall cut a Department order to SNGS to allow l

This will 3.

charges incurred by SNGS to be charged to HCGS.also all l

this service provided by SNGS.

Invoices sent to HCGS for signature approval should be 4.processed within three working days of receipt.

L Any extra fees which may be incurred for exceeding the total Artificial Island allocation will be chargeable to the 5.

exceeding its administrative portion in an station (s) equivalent proportion to its excess.

PROCEDURES Each Station will implement this program through 1.

written procedures.

l Procedures or revisions which address shipment of radioactive materials will be reviewed by both Stations.

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HCGS RADIOACTIVE MATERIALS SHIPMENTS _

REVIEWED _:

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1.,' G-fary/Morrill, Supervisor William Hunkele, Supervisor Radiation Protection Radiation Protection Hope Creek Generating Station Salem Generating Station RECOMMENDED:

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A. Russell Lovell, Manager

'Jadiation Protection / Chemistry Jopf Trejo, Mp agerReiation Prdection/ Chemistry Hope Creek Generating Station Salem Generating Station APPROVED _:

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//?flN John p'ipko, Gestral Marfager

' Roger Salvesen, General Manager Hope Creek Generating Station Salem Generating Station

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'/k/f1 Charles John

, General Manager

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Alton Thompson /, General Manager Nuclear Qua ty Assurance Nuclear Services l

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Page 8 of 8

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