ML20034F588
| ML20034F588 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/26/1993 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20034F589 | List: |
| References | |
| NUDOCS 9303040032 | |
| Download: ML20034F588 (5) | |
See also: IR 05000352/1993004
Text
.
..
.
fB 2 61!r33
.
I
Docket Nos. 50-352
50-353
Mr. D. M. Smith
Senior Vice President -
i
Nuclear
Philadelphia Electric Company
Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, PA 19087-0195
'
Dear Mr. Smith:
SUBJECT: NRC Combined Inspection 50-352/93-04; 50-353/93-04
>
An inspection of the radiological controls program was conducted at the Limerick Nuclear
Generating Station by Messrs. R. L. Nimitz and L. L. Eckert of this office during the period
,
r
January 19-22,1993, and February 1-3 and 8-12,1993. The findings of the inspection were
discussed with Mr. J. Doering on January 22, and February 3, 8, and 12,1993.
Areas reviewed during the inspection were important to health and safety and are fully
i
discussed in the enclosed inspection report. The areas reviewed included planning and
preparation for the Unit 2 refueling outage in consideration of the identification of failed
fuel, organization and staffing, external and internal exposure controls, radioactive material
-
controls, and the ALARA program. Also reviewed were the circumstances, evaluations and
corrective actions associated with two events that occurred on May 31,1992, and
January 27,1993. The events involved workers handling traversing incore probe (TIP)
.
.
tubing under the Unit 1 and Unit 2 reactor vessels.
'
!
Overall, the inspector concluded that generally effective planning and preparation for reactor =
refueling, in consideration of failed fuel, was performed. The. inspector also concluded that
-
timely efforts were taken to update radioactive waste shipping data to reflect the potential for
additional radionuclides attributable to the failed fuel. Observations during the outage-
!
identified generally good efforts to maintain radiation exposures as low as reasonably
achievable (ALARA).
9303040032 930226
-
'
ADOCK~05000352'
,
O
'
m
OFFICIAL RECORD COPY
-
b
f'
H
g
.
i.
-
_
s
4
}IB 2 61993
-
Philadelphia Electric Company
2
Regarding the two events involving TIP tubing, although the inspector concluded that no
significant intake of airborne radioactive matedal by, or external exposure of, personnel
occurred dudng either the May 31,1992, or the January 27,1993, events there was the
potential for a significant intake during the January 27,1993 event. Further, apparent
violations of NRC requirements were identified in both events. Regarding the May.31,
1992, event, one apparent violation of the radiation work permit program was identified.
The inspector found that workers failed to inform radiological controls personnel of changes
in their work location, resulting in workers testing TIP tubing under the reactor vessel
without the knowledge of radiological controls personnel.
Regarding the January 27,1993, TIP tubing event, two apparent violations were identified.
.
The inspector found that adequate radiological surveys were not performed and workers were
not provided adequate instructions to minimize their exposure to high levels of radioactive
contamination. We are particularly concerned that lessons learned from the May 31,1992,
event were not appropriately incorporated into program controls in that thorough planning
had not been performed by radiological controls personnel prior to initiation of the work. In
addition, we are concerned that the introduction of high levels of radioactive contamination
into the work area, and the lack of effective radiological oversight of the January 27,1993,
TIP work, resulted in the potential for a significant intake of radioactive material by
personnel.
In addition to the above apparent violations, two additional violations involving failure to -
follow station procedures were identified in association with other work activities.
Specifically, radiation protection personnel failed to adhere to the radiation work permit
(RWP) during fuel inspection activities and to perform required surveys, and failed to
provide adequate air sampling during TIP drive work. One non-cited violation involving
failure of workers performing fuel pool work to sign-in on the proper RWP was also
identified.
Further, in addition to the TIP events discussed above, our review of your performance in -
the area of radiological controls over the past year has identified that a number of
radiological controls problems have occurred which indicate that effective controls over on-
going activities, taking into consideration the increase in the radiological source term at the
station, may not yet be in place. In light of this and because the January 27,1993, event
had the potential to result in a significant personnel exposure, we are concerned about the
effectiveness of your radiological controls program. Accordingly, we have scheduled an
enforcement conference with you at the NRC Region I office for 9:00 a.m. on March 16,
1993. This enforcement conference will.be open to public observation in accordance with
the Commission's trial program as discussed in the enclosed Federal Register notice
(Enclosure 2). The purposes of this conference are to discuss the apparent violations, their
causes and safety significance; to provide you the opportunity to point out any errors in our
inspection report; and to provide an opportunity for you to present your proposed corrective
actions.
gi=
rp
0FFICIN. RECORD COPY
()O
d
.
,
TEB 2 61993
.
Philadelphia Electric Company
3
At this conference, you should be prepared to discuss your overall assessment of the
performance of the radiological controls program over the past year, as a whole, in light of
the above discussed matters, and what actions you have taken to preclude recurrences of
similar problems. You should also be prepared to discuss the above identified apparent
violations. We are particularly interested in your assessment of the January 27,1993, event
and whether this event could have potentially resulted in an intake of radioactive material in
excess of NRC limits. In addition, this is an opportunity for you to provide any information
concerning your perspective on 1) the severity of the issue,2) factors that NRC considers
when it determines the amount of a civil penalty that may be assessed in accordance with
Section VI.B.2 of the Enforcement Policy, and 3) the possible basis for exercising discretion
in accordance with Section VII of the Enforcement Policy.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and
its enclosure will be placed in the NRC Public Document Room. You will be advised by
separate correspondence of the results of our deFSerations on this matter. No response
regarding the apparent violations is required at ais time.
Your cooperation with us is appreciated.
Sincerely,
Odcinal signed pp
Rlthard W. Cooper
Richard W. Cooper, II, Director
Division of Radiation Safety
and Safeguards
Enclosures:
1 NRC Combined Inspection Report No. 50-352/93-04; 50G53/93-04
'
2. Federal Register Notice
,
Ib
e-
nn
i a
w
.jM
0FFICIAL RECORD COPY
.
.
..
FEB 2 61993
-
Philadelphia Electric Company
4
,
cc w/encls:
R. Charles, Chairman, Nuclear Review Board
,
D. R. Helwig, Vice President - Limerick Generating Station
G. J. Beck, Manager - Licensing Section
G. Madsen, Regulatory Engineer - Limerick Generating Station
Secretary, Nuclear Committee of the Board
Public Document Room (PDR)
local Public Document Room (LPDR)
, Nuclear Safety Information Center (NSIC)
K. Abraham, (2)
NRC Resident Inspector
Commonwealth of Pennsylvania
l
..
i
,
a
.
!
C {j
-
L-
. OFFICIAL. RECORD COPY
'
.
.
-
-
-- -
..
FEB 2 61993.
.
Philadelphia Electric Company
5
bec w/encls:
Region I Docket Room (with concurrences)
E. Wenz'mger, DRP
C. Anderson, DRP
DRS/EB SALP Coordinator
V. McCree, OEDO
F. Rinaldi, NRR
J. Lieberman, OE
D. Holody, RI
'
J. Goldberg, OGC
J. Cunningham, NRR ,10 94
W. Hehl, RI
N. Perry, SRI, Yankee Rowe
.
RI:DRSS
RI:DRSS
T :;
RI:DRSS
Eckert
Nimitz
I tes .
"
'
AWf
V
l
,
2/2< /93
29(/93
2 ( 93
2/693
L
RI:
S
RI:DRm .
Cook,
!
man
2/> 93
2[d93
<
Official Record Copy
5
t
!
'
.
,
i
w
Gl1
-
p
'
,