ML20035E985
| ML20035E985 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/29/1993 |
| From: | Nimitz R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20035E972 | List: |
| References | |
| 50-352-93-04-EC, 50-352-93-4-EC, 50-353-93-04, 50-353-93-4, NUDOCS 9304200143 | |
| Download: ML20035E985 (3) | |
See also: IR 05000352/1993004
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U S. NUCLEAR REGULATORY COMMISSION
REGION I
Enforcement Conference Report Nos. 50-352/93-04
50-353/03-04
Docket Nos. 50-352
50W3
)
License Nos. NPR-39
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NPR-85
Licensee:
Philadelphia Electric Comoany
Correspondence Control Desk
P.O. Box 195
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Wayne. PA 19087-0195
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Facility Name: Limerick Nuclear Generatine Station. Units 1 and 2
Enforcement Conference At: Kine of Pnissia. Pennsylvania
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Conference Conducted: March 16.1993
Pn pared by:
RL W
3 dD
R. L. Nimitz,
Senior Radiation Specialist
date
Approved by:
J
3 (O Ct-
3'b M
s
W. Pasciak, Chief, Facilities Radiation
date
Protection Section
Conference Summary: The Enforcement Conference was held to discuss the safety
significance and the licensee's assessment of overall perfonnance in the area of mdiological
controls in light of problems which have occurred over the past year, as well as the
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licensee's assessment of a January 27,1993, contamination event. During the event high
levels of radioactive contamination were unknowingly intmduced into the work area under
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the Unit 2 reactor vessel, possibly creating a substantial potential for an intake by workers of
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radioactive material in excess of NRC limits. Also discussed were the apparent violations
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identified in NRC Combined Inspection Nos. 50-352/93-04; 50-353/93-04, as well as the
licensee's evaluations of the violations, the licensee's generic corrective actions, and the
licensee's perception of the appropriateness of the apparent violations relative to criteria
outlined in the NRC's Enforcement Policy (10 CFR Part 2, Appendix C). The conference
was attended by representatives of Philadelphia Electric Company and members of NRC
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management and staff. The conference was open to the public and members of the public
were in attendance.
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9304200143 930409
ADOCK 0500
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DETAILS
1.0
Licensee and NRC Personnel in Attendance
Attachment I to this conference report identifies licensee and NRC personnel in
attendance.
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2.0
Pumose of Conference
The purpose of the confemnce was to discuss the safety significance and the licensee's
assessment of overall performance in the area of mdiological controls in light of
problems which have occurred over the past year, as well as the licensee's assessment
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of a January 27,1993, contamination event. Also discussed were the appan nt
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violations identified in NRC Combined Inspection Nos. 50-352/93-04; 50-353/93-04,
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as well as the licensee's evaluations of the violations, the licensee's generic corrective
actions, and the licensee's perception of the appropriateness of the apparent violations
relative to criteria outlined in the NRC's Enforcement Policy (10 CFR Pan 2,
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Appendix C). The conference was open to the public and members of the public
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were in attendance.
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3.0
NRC Comments
[
NRC management opened the conference by identifying the purpose of the
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conference, describing the enforcement process, and presenting a summary of the
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January 27,1993, event and the appan nt violations identified during NRC Combined
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Inspection Nos. 50-352/93-04;.50-353/93-04. Attachment 2 to this Enforcement
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Conference Report provides the conference agenda and additional information
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presented at the conference, including identifying the location where the January 27,
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1993, Unit 2 undervessel release of radioactive contamination occurred.
4.0
Licensee Comments
The licensee's representatives presented the status of the radiation protection pmgram,
discussed the independent assessments of the radiation pmtection program conducted
during the outage, discussed the January 27,1993, Unit 2 traversing incore probe
(TIP) tubing contamination event, and discussed the apparent violations identified
during NRC Combined Inspection Nos. 50-352/93-04; 50-353/93-04. Attachment 3
to this Enforcement Conference Repon is a copy of the licensee's presentation made
at the enforcement conference.
Regarding the apparent violations, the licensee indicated that the two apparent
violations associated with the January 27,1993, event occurred, but that the NRC
should evaluate the appropriateness of issuance of the violation associated with.
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training of workers in light of apparent " double jeopardy" (i.e., if there was a failure
to survey, failure to inform the workers of the results of a survey that had not been
done would be an inappropriate violation). The NRC noted that the apparent
violation was based on the failure to apprise the workers of the potential for
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contamination based on results of surveys from an earlier job (May 31,1992) where
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high levels of contamination were identified, and during the job when initial surveys
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of some of the TIP tubes indicated unusually high contamination levels. The licensee
agreed that the apparent radiation protection procedure violation associated with the
May 31,1992, TIP tubing contamination event at Unit 1 occurred, but indicated that
the violation did not have any relevance to deciding on the aggregate severity level of
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the apparent violations identified during the above referenced inspection. The
licensee disagreed with the basis for issuance of the apparent violations associated
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with 1) surveys of material partially removed from the spent fuel pool and 2) air
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sampling during TIP drive mechanism work, and provided the reasons for
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disagreement.
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The licensee indicated that the inspection report provided a factual description of the
January 27,1993, Unit 2 undervessel event. Regarding the characterization as to the
requirements for smveying of material being removed from the spent fuel pool, the
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licensee indicated that the radiation protection technician had misspoken and portrayed
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the survey requirements as consistent with the inspector's understanding of the
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licensee's requirements. The licensee's representatives also indicated that the
technician was apparently somewhat intimidated by the NRC, which may have
prompted the incorrect response.
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5.0
Concluding Remarks
NRC management stated that the apparent violations were subject to change prior to
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any enforcement action and that the statements of views and expressions of opinions
by NRC employees at this conference or the lack thereof were not intended to
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represent final NRC determinations. NRC management expressed concern regarding
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the technician's providing incorrect information to the NRC and indicated this matter
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should be reviewed by the licensee representatives with appropriate staff. NRC
management indicated the alleged intimidation matter would be reviewed with the
staff.
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