IR 07100017/2011027

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Notice of Violation from Insp on 871017-1127.Violation Noted:Field Initiated Change to PORC Approved Repair Procedure for Emergency Cooling Water Sys Pipe Support 48HB-H58 Made W/O Documented Approval
ML20147C745
Person / Time
Site: Peach Bottom, 07100017  Constellation icon.png
Issue date: 01/11/1988
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20147C734 List:
References
50-277-87-24, 50-278-87-24, NUDOCS 8801190334
Download: ML20147C745 (2)


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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket Nos. 50-277 & ';0-278 Peach Bottom Units 2 & 3 License Nos. DPR-44 & JPR-56 During a routine NRC resident inspection conducted from October 17 to November 27, 1987, and in accordance with the revised "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the following violations were identified: CFR 50, Appendix B, Criterion VI, "Document Control," requires that measures be established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting qualit Section 3, Paragraph 3.1.6 of the PECo Quality Assurance Plan, Volume I, requires the following:

"Design changes to modifications, including field originated changes, shall be subject to design control measures commensurate with those applied to the original design of the modification and shall be approved by the organization approving the original modification design unless PECo documents or procedures specify otherwise. The independent design review of design changes shall include the changed information and an evaluation of the effects of the changes on the overall design."

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Contrary to the above, on October 5, 1987, a field initiated change to the PORC approved repair procedure for emergency cooling water system pipe support 48HB-H58 was made without documented approva This is a Severity Level V Violation (Supplement 1). CFR 20.201, "Surveys," paragraph (a), states that "survey" means an evaluation of the radiation hazards incident to the use, i release, disposal, or presence of radioactive material or other sources of radiation under a specific set of conditions, and where appropriate, may be a physical measurement of levels of radiation or concentrations of radioactive material present; paragraph (b),

requires the licensee to make or cause to be made such surveys as (1) to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radia- ;

tion hazards that may be presen l l

l 8801190334 880111 PDR ADOCK 05000277 Q PDR

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Appendix A -2-

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10 CFR 20.203, "Caution signs, labels, signals and controls,"

paragraph (c)(1), requires that high radiation areas shall be conspicuously posted with a sign or signs with the radiation caution symbol and the words "CAUTION HIGH RADIATION AREA".

Contrary to the above, on October 7,1987, radiation levels in the vicinity of the Unit 2 regenerative heat exchanger room door were 300 mr/hr, constituting a high radiation area, for a period of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />, and the area was not surveyed or poste Contrary to the above, on October 19, 1987, inadequate surveys to [

evaluate changing radiation hazards were conducted in the 2A residual heat removal room resulting_in an unplanned radioactive material intake of 42 maximum permissible concentration-hours for one individua '

Contrary to the above, from August 10, 1987 to October 26, 1987, a radwaste drum manipulator was stored without being surveyed in an unrestricted area near the north substation with radiation levels of 12,000 counts per minute fixed and 1,800 disintegrations per minute per 100 square centimeters smearabl Contrary to the above, on October 30, 1987, fixed contamination levels of 60,000 counts per minute was found in an unrestricted area near the decontamination trailer at the southeast side of the protected area, the area was not surveyed after a spill in 198 This is a Severity Level IV Violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is

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hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement or explanation in reply including for each violation: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved (3) i

the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is j shown, consideration will be given to extending the response tim i I

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