ML20137E967

Responds to NRC 851209 Ltr Re Violations Noted in Insp Repts 50-277/85-42 & 50-278/85-42.Corrective Actions:Newly Designed Pallet & Lifting Cable Arrangement,To Restrict Cable Movement During Transport,Being Fabricated

ML20137E967
Person / Time
Site:	Peach Bottom
Issue date:	01/07/1986
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8601170375
Download: ML20137E967 (6)

Text

• -' . T O.

.e _...

, a PHILADELPHIA ELECTRIC COMPANY

~

2301 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101

'"$, ,*h,,^M" "

ELECTRIC PRODUCTION Nuary7,1986 Docket Nos. 50-277 50-278 Inspection Report 50-277/85-42 50-278/85-42 Dr. Thomas E. Murley, Administrator

-U.S. Nuclear Regulatory Commission .

Region I

• 631 Park Avenue King of Prussia, PA 19406

Dear Dr. Murley:

Your letter dated December 9, 1985 forwarded combined Inspection Report 50-277/85-42; 50-278/85-42 for Peach Bottom Atomic Power Station, Units 2 and 3. Appendix A of your letter addresses an item which does not appear to be in full compliance with NRC requirements. This item is restated and followed by Philadelphia Electric Company's response.

Restatement of Violation:

On October 18, 1985, an inspection was conducted by a

- representative of the South Carolina Department of Health and Environmental Control (SCDHEC) of a shipment of licensed material sent to the Chem-Nuclear Systems, Inc. , burial site at Barnwell, South Carolina from the Peach Bottom Atomic Power Station in Delta, Pennsylvania, on or about October 16, 1986. During the inspection, a violation of NRC requirements was identified.

In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1985), the violation is set forth below:

10 CFR 71.87 (f) requires that packages are loaded and closed in accordance with written procedures. Philadelphia Electric Company Procedure HPO/CO-71C, Appendix A, dated June 12, 1984, for Peach Bottom Units 2 and 3, " Loading and Closing the HN-100, Series 2 or 3 Radioactive Waste, Shipping Cask,"

requires that the cask loading operator assure easy access to the pallet lifting slings for removal of the pallets at the burial site.

B601170375 860107 PDR ADOCM 05000277 \ oy e PDR p

,i > j' ?p g k .

,~

"1- :N _ ('- .

4.s :N 5 - . .

~

A Dr. Thomat E. Murley ~

Januaryr7, 1986' js Q% ~ Page 2

w J\

. ph~

. Contrary tid the above, on or f about October 16, 1985,

. Philadelphia ? Electric . Company packaged 'and i shipped

,f Radioactive Waste Material Shipment.No. 1085-197-4, Jclassified as-Radioactive Material, LSA,.n.o.s., described as

. centrifuged resin ~,' : packaged in 14 ' palletized PECo, high -

integrity; containers and the cask loading operation did not

-assur'e'. easy _.hecess to the-palletLlifting slings for removal of;the pallets 1at the burial site. As a result, the cask arrived'at-the burial: site and'the lifting slings were not easily acce'ssible. '.

. This is a' Severity' Level III violation. (Supplement V)

~ ~

D -Res'ponse to' Violation: Y Admission or Denial of Alleged Violation:

i Philadelphia-Electric Company acknowledges the violation as stated.-

- Reason for' Violation:

In l'984-revised regulatory requirements resulted in pallets and lif ting , cables being buried .with High Integrity

' Containers . (HICs) .. Previously, the HICs were' dumped off the palletsiat the burial site and the pallets and cables were returnedswith'theseask~to the waste generator. As a result.

of.the' pallet and cable burial, lighter,.less-costly lifting

- cables ~were designed. The lighter cables move around more in -

transport : allowing 'the D-Ring at the end of the cables and

, - the ' cables- to - become entangled with the HICs. or pallet. This was-the cause of the October 16, 1985, problem.

N Extent or S'ignificance of Violation: ,!

?. 1 ,

L , i ,

s m ,

s fL - Lifting cab,les'for-the . top pallet in the cask were entangled ,

and not easily accessible. Burial site personnel received '

more'irad(stion exposure- than they woUld have if the cables Lhad been 4asily accessible; however, the off-loading process

- was hnlted to avoid unnecessary exposure to burial site personnel.- j i ,

~~- l l

T

c. . . hn

- . w :. -

-Dr.; Thomas E. Murley, January 7, 1986

.** Page 3 g

.t cg.

1. ,1 hCorrectiveActionsTakenandResultsAchieved:

t

.g "

.IPhiladelphia Electric . Company has worked with the burial site

. operator to-develop a~ temporary modification that will

.. e tprevent entanglement-of the lifting cables. This initial M ;cc G #. bearing:

modification cableconsists which is of a disk placed attached on. to aHICs.

top of the non-load-This

"g 3 'i modification-is effective;-however, it is temporary and will.

be replaced by a design. change to the lifting cable length

{,

. L.,L,jdescribedinthe'nextsection).

fM, ,entitled Additionally,1 LOADINGPeach AND ' Bottom' CLOSINGprocedure HPO/CO-71C, THE HN-100, SERIES 2 ORAppendix 3 A, i RADIOACTIVE ~ WASTE, SHIPPING CASK has been changed to require EA D-Ring ' restr'aint on the sling. The Radwaste Operator and QC inspectoriverify that the' restraint is in place and document'the^ verification by signature.

- Codrective Adtions to be Taken to Avoid Future Non-Compliance:

4 A newly designed pallet and lifting cable arrangement to

. restrict cable movement during' transport is being fabricated.

t

.gThe new design consists of' shortening the three cables 3-- f attached to the~ pallet, and connecting them to a single f Llif ting. cable - through another D-Ring -(See Attachment 1) . A 3:icrossbar will be~ affixed.to each D-Ring, which will then lie

'" on' top of the HICs, thus preventing the cables from becoming y entangled with the HICs or pallet (See Attachment 2) . We

= expect the newly. designed pallet and lifting cables to be n .fready -for 'usei by January 20, 1986.

,/;

' n'y\ r

' Date When FullsCompliance Will be Achieved:

N b ,

wd -

, Thel State of16outh Carolina restored Philadelphia Electric Company?s shipping priviledges on October 30, 1985, after use of the disk an,d non-load-bearing cable was implemented.

.t g v 1 6

s s f

.f j '

B >;

f

/

a w 3' a .

v- ,

- 4 '- t F, . ..

.Dr; Thoza3 E. Murley January 7, 1986

-Page 4 Should you have any questions or-require additional information, do not hesitate to contact'us.

Very truly yours, L. bwj '

Attachments ccs- - T. P. Johnson, Resident Site Inspector

. . . , . s,~ . ~ ' ~ '

' ~

9 Current Design New Design D-Ring

• 0 f HICs (top view)

\ D-Rings i

1 1 -

s h 6 I

)

f i 7 5 i

i

.I .h h a -

,_ L

. - _m __ m

" =

7 above, 7 below, 14 total i

l (Disk and non-load-bearing)

I( cable not shown ) Pallet (crossbars not'shown) mWH>

u fD an 1 03 to n D 'O 'O Q3 NO tD n

• • DD y U1 to n s J

O (D M fD i ** O D

- N Dn

= O, fD o

Ut N O I N *1

1. Mn NN *

• ' '* * ' 99.- ..

, s Attachment 2 Inspection Report Response: 50-277/

85-42;50-278/85-42 a

Current Design New Design I non-load-bearing cable

\

1 l l l V / ) \ '

/ s ,

i D-Rings D-Ring crossbar *

(load-bearing cables not shown) '

0 u *I? -

- - . . . _ , . - . - . . ~_

• *~