ML20053C945

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Responds to NRC Ltr Re Violations Noted in IE Insp Rept 50-293/81-26.Corrective Actions:Supervisory Observation of Waste Packaging Activities Increased
ML20053C945
Person / Time
Site: Pilgrim
Issue date: 02/22/1982
From: Deacon W
BOSTON EDISON CO.
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20053C943 List:
References
82-59, NUDOCS 8206030200
Download: ML20053C945 (2)


Text

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. . 4 EOSYON EDISON COMPANY

= eco Sovterase Senest t BOSTON. MassacHustTTs D2199 February 22, 1982

- BECo. Ltr. #82- 59 Mr. Thomas T. Martin, Director Division of Engineering and Technical Inspection Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 License No. DPR-35 Docket No. 50-293 Response to IE Inspection 81-26 Reference (a): NRC letter of January 22, 1982 from Mr. T. T. Martin to Mr. A. V. Morisi j (BECo Letter #1.82.017)

Dear Sir:

Herein is Boston Edison's response to an item of violatio.1 identified in the reference.

Violation 10 CFR 30.41 prohibits transfer of byproduct material unless it is in a form

, authorized by the recipient's NRC or Agreement State license. South Carolina License No. 097, an Agreement State license issued to Chem-Nuclear Systems, Inc., prohibits the receipt of solidified waste with " detectable free standing liquid" which is defined in the license as liquid in excess of 0.5 percent by waste volume for drums.

]

Contrary to the above, on July. 20,1981, a waste shioment of byoroduct material, >

containing 0.134 curies of solid metallic oxides on gravel and trash, was trans--

! ferred to Chem-Nuclear Systems, Inc., at Barnwell, South Carolina with detectable 1

free standing liquid (from 0.8 to 1.34 percent liquid by waste volume) in each of four drums in the shipment.

1 This is a Severity Level III violation. (Supplement IV.C.6)

Response

Boston Edison concurs that this violation did occur.

We believe, however, that categorizing this as a Level III violation is inappro-priate, because neither 10 CFR 20.303, nor 10 CFR 20.304 are applicable. We believe that this violation should be categorized as one of Severity Level IV (sunnlamant v n 11 8206030200 820527 PDR ADOCK 05000293

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. 'CDDTON E7 EON COMPANY

. fir. Thomas T. Martin, Director 4 - February 22, 1982 Page 2 I Although the total waste shipment did contain 0.134 curies of radioactive waste, the twelve drums contained a total of 0.00576 curies of radioactive waste, with the' remainder of the shipment enclosed in sealed wooden boxes. The analyses of the excessive free standing liquid found in four of the twelve drums was of an exempt nacure in accordance with 10 CFR 30.14 and 10 CFR 30.70, and is believed to have been rainwater intrusion.

! Our immediate corrective action was to institute increased supervisory observa-l tion of waste packaging activities.

A reprimand was given to those individuals involved in this event for their inadequate performance in following existing procedures. In addition, firm verbal reiteration of the requirement for the performance of detailed inspec-tions, to ensure that waste material is free of liquid, was provided to all waste handling supervisors and operators. Full compliance to these manager.ent controls was achieved by August 21, 1981.

Procedural revisions to incorporate these specific instructions have been im-plemented to preclude a recurrence of this type of incident.

We believe this response satisfactorily addresses the violation identified in the reference. Should you require any further information concerning this response, please contact us.

Very truly yours, cc-ecx W. H. Deacon Acting Manager Nuclear Operations Support Commonwealth of liassachusetts)

County of Suffolk )

Then personally appeared before me. William H. Deacon, who, being duly sworn, did state that he is Aumg lianager - Nuclear Operations Support of Boston Edison Compa.ny, t.he applicant herein, and that he is duly authorized to execute and file the.subm'ittal contained herein in the name and on behalf of Boston

. Edison Company.and that the statements in said submittal are true to the best of his knowle ( nd belief.

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