ML20058C966
| ML20058C966 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/22/1993 |
| From: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9312030002 | |
| Download: ML20058C966 (2) | |
See also: IR 05000352/1993022
Text
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NOV 2 2 993
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Docket Nos. Si)-352
50-353
Mr. D. R. Helwig, Vice President
Limerick Generating Station
Philadelphia Electric Company
P. O. Box 2300 Mail Code SMB 1-1
Sanatoga, PA 19464-2300
Dear Mr. Helwig:
SUBJECT:
INSPECTION NOS. 50-352/93-22; 50-353,,. 72
This refers to your letter of November 1" 1993, in response to our letter dated October 15,
1993.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
O'"SI."Il SIGNED BY
ED?iARD C. WENZINGER
Edward C. Wenzinger, Chief
Projects Branch 2
Division of Reactor Projects
Enclosure: Licensee letter
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ADOCK 05000352
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Mr. D. Helwig
2
cc:
D. M. Smith, Senior Vice President - Nuclear
J. Doering, Chairman, Nuclear Review Board
G. A. Hunger, Jr., Manager Licensing Section
J. L. Kantner, Regulatory Engineer - Limerick Generating Station
cc w/cy of licensee letter:
Secretary, Nuclear Committee of the Board
Nuclear Safety Information Center (NSIC)
Public Document Room (PDR)
Local Public Document Room (LPDR)
NRC Resident Inspector
Commonwealth of Pennsylvania
bec w/cy of licensea biter:
Region I Docket Rt.om
E. Wenzinger, DRP
C. Anderson, DRP
F. Rinaldi, Project Manager, PDI-2, NRR
L. Nicholson, Acting PDI-2, NRR
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E enzinger
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OFFICIAL RECORD COPY
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10 Q_FR 2.201
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PHILADELPHIA ELECTRIC COMPANY
a? 9EAICis GENERATING STATION
P. O. BOX 2300
SANATOGA, PA 19464-2300
GM) 327-1200, EXT. 3000
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DAVID R. HELWIG
November 15, 1993
VICE PRESIDENT
UMERICK GENERATING STATION
Docket ?!os. 50-352
50-353
License Nos. NPF-39
NPF-85
U.S.
Nuclear Regulatory Commission
Attn: Document Control Desk
20555
SUBJECT:
Limerick Generating Station, Units 1 and 2
Reply to a Notice of Violation
NRC Combined Inspection Report Nos. 50-352/93-22
and 50-353/93-22
Attached is Philadelphia Electric Company's reply to a Notice
of Violation for Limerick Generating Station (LGS), Units 1 and 2,
which was contained in your letter dated October 15, 1993.
The
cited violation involved the failure of a Radwaste technician to
properly frisk
for contamination when exiting a Radiological
Controlled Area.
The attachment to
this
letter provides a
restatement of the violation followed by our reply.
If you have any questions or require additional information,
please contact us.
Very truly yours,
GHS:cah
i1
Attachment
cc:
T.
T.
Martin, Administrator, Region I,
w/ attachment
N.
S.
Perry, USNRC Senior Resident Inspector, LGS
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U.S. Nuclear Regulatory Commission.
November 15, 1993
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Commitment Coordinator - CB, 62A-1
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Correspondence Release Point - SMB1-2
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. Docket Nos. 50-352
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At_tachment
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50-353
Page 1 of 3
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Restatement of the Violation
During an N.RL inspection conducted on August 17 t o,
September 25,
1993,
a
violation
of
NRC
requirceents
as
ident fied.
1c
.
accordance with the " General Statement of Policy and Procedure for
NRC Enforcement Actions," 10 CFR Part 2,
Appendix C,
the violation
is listed below:
Technical Specifications
(TS),
Section
6.11,
states that
procedures
for
personnel
radiation
protection
shall
be
prepared consistent with the requirements of 10 CFR Part 20
and shall be approved, maintained, and adhered to for all
operations involving personnel radiation exposure.
Administrative Procedure A-C-107, Revision 14, " Radiation Work
Permit
Program
and
Radiological
Controlled
Area
Access
Requirements," Step
5.4,
written to comply with TS 6.11,
states, in part, that it is all worker's responsibility to
comply with
established
postings
in
the
RCA.
Posted
requirements for personnel exiting the RCA are that all
personnel shall pass through a portal monitor before stepping
across a stepoff pad.
l
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Contrary to the above, on August 23,
1993, the inspectors
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identified that a radwaste technician had exited the RCA
without properly frisking through a portal monitor.
This is a Severity Level IV Violation (Supplement IV).
RESPONSE
,
Admission of Violation
I
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Philadelphia Electric Company acknowledges the violation.
)
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Reason for the Violation
I
The cause of the violation was personnel error on the part of
)
the vendor Radwaste technician.
The technician ignored posted
J
requirements
to
use
a
portal
monitor
(i.e.,
to
frisk
for
contamination) when exiting the Radiological Controlled Area (RCA) .
This incident occurred outside the east entrance to the Main
Control Room (MCR) adjacent to a building that was previously used
as an office for issuing Maintenance Request Forms (MRFs).
There
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_ Docket Nos. 50-352
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Attachment
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50-353
Page 2 of 3
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,
is a
.eaP in . % RC's . ;ur.
a n ..
c,
pad at
us
ation
,
primarily for con' :.nienw to pr ovida a pathway for opc it ions
personnel exiting the MCn to enter the RCA.
The stepoff pad ac
read from the RCA states that "All personnel shall pass through a
portal monitor before stepping
here."
However,
ti .c re
is no
contamination monitoring equipment at this .' ecation cince .it in not
an established RCA exit point.
The contaminatiin monitoring
eqcipment is located at t i . c.
opposite end of the old MRF office
outside the west entrance to tne MCR.
This area is the estohlished
RCA exit point.
In addition, there is a stantion located by the break in the
RCA boundary at the east end of the old MRF office with a notice on
it which directs all personnel to use the portal nonitors at the
opposite
side
(i.e.,
the west end)
of
the
old MRF office.
Regardless of the posting and notice,
the Radwaste technician
crossed the RCA boundary outside the east entrance to the MCR
without performing the required frisk.
Sufficient procedural
controls and management expectations exist to prohibit exiting the
RCA without first frisking for contamination.
A review of previously recorded incidents was performed to
determine if this incident was representative of a generic concern
relative to radiation workers exiting the RCA without performing
any type of frisk for contamination.
No discrepancies were
identified.
Therefore, this incident is considered to be an
isolated occurrence.
As identified in the Inspection Report, a contributing factor
to this incident may have been the physical
arrangement for
attaining access to the MCR.
As stated previously, the established
location for exiting the RCA is outside the west entrance to the
MCR.
Therefore,
this is the only location where monitoring
equipment exists to perform the required frisk for contamination
prior to exiting the RCA.
However, this arrangement does not
provide for convenient access to the east entrance of the MCR.
This arrangement, in combination with the fact that the turbine
building in this area typically is not contaminated, may have led
the Radwasta technician to cross the RCIs boundary at the east end
of the MCR /ather than use the established RCA exit point at the
other side.
Corrective Actions Taken and Results Achieved
Upon
immediate
investigation
of
this
event,
the vendor
Radwaste technician was released from employment by the Radwaste
vendor, and was denied access to the protected area on August 23,
1993.
On August 24, 1993, Redwaste vendor information notice ARC-93-
014 was circulated throughout the population of Radwaste vendor
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. Docket Nos. 50-352
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At.tachment
50-353
Page 3 of 3
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employees onsite t.
zera.
.1 . vt:w
,.) u
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_m<
ner
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of good radworker pract; .es.
Th
inica.u; ion notice
z.
cliled the
responsibility of vendor Rad **asto per-om ol to monito" t.ncmselves
and personal items for contamination when exiting the RCm
The
information notice also reminded the vendor Radwaste p .rsonnel that
prior to entering a designated eatii.<j and drinking area, personnel
and personal items must be monitored tec contamination. No rimile:
incidents have been identified since August 23, 1993.
Corrective Actions to Avoid F'utur e Non -cpnnlic cce
Subsequent to this event, articles have been publirhed in the
site daily news publication on a weekly basis throughout the month
of October 1993 to remind all station personnel of the importance
of frisking prior to exiting the RCA.
Additionally,
the
importance
of
adhering
to
exit
contamination monitoring and control requirements will be discussed
with
the
plant
staff
during
the
upcoming
training
for
implementation of the revised 10CFR20 requirements.
This training
is scheduled to be completed by December 31, 1993.
To enhance control
of the RCA boundary at
the MCR,
a
renovation of the entrance / exit to the RCA at this loca* ion is
currently underway.
This renovation provides for one entrar.ce and
exit point to and from the RCA, as well as a clear delineation of
the RCA boundary.
This renovation will be complete by January 1,
1994.
Date When Full Comoliance was Achieved
Full compliance was achieved on August
23,
1993 when the
Radwaste technician was released from employment by the Radwaste
vendor, and was denied access to the site.
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