ML20035E978
| ML20035E978 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/09/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035E972 | List: |
| References | |
| 50-352-93-04, 50-352-93-4, 50-353-93-04, 50-353-93-4, NUDOCS 9304200137 | |
| Download: ML20035E978 (2) | |
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APPENDIX A NOTICE OF VIOLATION Philadelphia Electric Company Docket Nos. 50-352, 50-353 Limerick Nuclear Generating Station License Nos. NPR-39, NPR-85 Units 1 and 2 As a result of the inspection conducted on January 19-22, 1993, February 1-3 and 8-12, 1993, and March 17,1993, and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix (C)), the following violations were identified. Violations A and B are associated with an event that occurred on January 27,1993, and Violation C is associated with an event that occurred on May 31,1992.
A.
10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of 10 CFR Pan 20 and which are reasonable under the circumstances to evaluate the radiation hazards that may be present. As defined in 10 CFR 20.201(a) a " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of material and equipment, and l
measurements of levels of radiation or concentrations of radioactive material present.
1 Contrary to the above, the licensee did not make surveys to determine that individuals were not exposed to airborne concentrations exceeding the limits specified in 10 CFR 20.103. Specifically, at about 2:00 a.m. on January 27,1993, during removal of traversing incore probe (TIP) tubes, the licensee failed to detect the introduction of high levels of radioactive contamination (subsequently measured to be as high as 320 2
millirad /hr per 100 cm removable) into the work area as the Unit 2 TIP tubes were removed. As a result, there was a potential for workers, performing the task without benefit of respiratory protective equipment, to sustain a significant intake of radioactive material.
This is a Severity Ixvel IV Violation (Supplement IV).
B.
10 CFR 19.12 requires that the licensee inform workers of the storage, transfer, or use of radioactive material and in precautions or procedures to minimize exposure.
Contrary to the above, on January 27,1993, the licensee did not adequately inform workers as to the presence of high levels of radioactive contamination or of means to minimize their exposure to such contamination. Specifically, at about 2:00 a.m. on January 27, workers were not informed either during the pre-job briefing or after OFFICIALRECORD COPY 9304200137 930409 PDR ADOCK 05000352 o
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surveys during the early stages of the job of the presence of high levels of radioactive contamination contained within traversing incore probe tubes.
l This is a Severity level IV Violation (Supplement IV).
C.
Technical Specification 6.11 requires adherence to radiation protection procedures.
Radiation Protection Procedure A-C-107, Radiation Work Permit Program and l
Radiological Controlled Area Access, states in Section 7.1.2 that all personnel entering the radiological controlled area shall employ proper radiological work practices as presented in Exhibit A-C-107.5 of Procedure A-C-107. Exhibit A-C-107.5 provided examples of proper radiological work practices, which include the need to prepare and plan for all mdiological controlled area work sufficiently in l
advance to allow proper health physics review.
Contrary to the above, on May 31,1992, workers did not adequately prepare for the undervessel work at Unit I sufficiently in advance to allow health physics review in that,1) radiation protection personnel were not included in a pre-job briefing to discuss testing of TIP tubes under the reactor vessel, and 2) workers entering to perform actual TIP testing under the vessel did not inform radiation protection personnel at the drywell control point that they would be performing the testing under the reactor vessel. As a result, workers handled a highly contaminated TIP cable and j
dummy probe without the benefit of radiation protection review. The TIP tube and
- cable exhibited removable radioactive contamination levels up to 40 millirad /hr per 2
100 cm This is a Severity Izvel IV Violation (Supplement IV).
No response to Violation C is required.
Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby ~
required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, A'ITN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for violations A and B: (1) the reason for the violation, or, if l
contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
OFFICIAL RECORD COPY
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