ML20059M306

Responds to NRC Re Violations Noted in Insp Rept 50-352/93-22 & 50-353/93-22 on 930817-0925.Corrective Actions:Released Vendor Radwaste Technician

ML20059M306
Person / Time
Site:	Limerick
Issue date:	11/15/1993
From:	Helwig D PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9311190023
Download: ML20059M306 (5)

Text

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c . 1 lo CFR'2.201' PHILADELPHIA ELECTRIC COMPANY

'l LIMERICK GENERATING STATION j P. O. BOX 2300 l 1

SANATOGA, PA 19464-2300 j (215) 327-1200, EXT. 3000 DAVID R. HELWIG November 15, 1993 VICE PRESIDENT UMERICK GENERATING STAHON Docket Nos. 50-352 50-353 I License Nos. NPF-39  :

NPF-85 'l U.S. Nuclear Regulatory Commission Attn: Document Control Desk ,

Washington, DC 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 P 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 (

Attachment .]

cc: T. T. Martin, Administrator, Regia). I, USNRC w/ attachment N. S. Perry, USNRC Senior Resident Inspector, LGS "'

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9311190023 931115 PDR ADOCK 05000352 @O, '- 1 3

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p-EU.S. Nuclear Regulatory Commission November 15, 1993  ;

Document Control Desk Page 2 of.2 i t

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bec: D. M. Smith - CB, 63C-3 w/ attachment 1

G. R. Rainey - CB, 62C-3 R. W. Boyce-- GML5-1 J. L. Kantner - SMB2-4 J. B. Cotton - CB, 53A-1 J. G. Hufnagel - SMB3-1  :

C. A. Mengers - SSB4-3 -

G. A. Hunger, Jr. - CB, 62A-1  ;

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G. W. Murphy - HPO1-1 .

K. J. Cenci - SSB2-2 l J. Doering, Jr. - CB,-63C-5 Secretary, NCB - CB, 63C-7 PA DER BRP Inspector - SMB2-4 f Commitment Coordinator - CB, 62A-1 "  !

Correspondence Release Point - SMB1-2 "

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' Docket Nos. 50-352- Attachment 50-353 Page l'of'3 Reply to a Notice of Violation

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Restatement of the Violation During an NRC inspection conducted on August 17 to September 25, 1993, a violation of NRC requirements was identified. In 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 i 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 pe7onnel radiation exposure.

l 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 Contrary to the above, on August 23, 1993, the inspectors 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 Philadelphia Electric Company acknowledges the violation.

Reason for the Violation ,

t The cause of the violation was personnel error on the part of  ;

the vendor Radwaste technician. The technician ignored posted 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 i

Docket Nos. 50-352 Attachment 50-353 Page 2 of 3 is a break in the RCA boundary with a stepoff pad at this location  !

primarily for convenience to provide a pathway for operations  !

personnel exiting the MCR to enter the RCA. The stepoff pad as  ;

read from the RCA states that "All personnel shall pass through a ,

portal monitor before stopping here." However, there is no  !

contamination monitoring equipment at this location since it is not i an established RCA exit point. The contamination monitoring {

equipment is located at the opposite end of the old MRF office i outside the west entrance to the MCR. This area is the established 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 monitors 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 I 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 Radwaste technician to cross the RCA boundary at the east end l of the MCR rather than use the established RCA exit point at the other side.

l Corrective Actions Taken and Results Achieve _d Upon immediate investigation of this event, the vendor ,

Radwaste technician was released from employment by the Radwaste i i

vendor, and was denied access to the protected area on August 23, 1993. l On August 24, 1993, Radwaste vendor information notice ARC 014 was circulated throughout the population of Radwaste vendor ,

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Docket Nos. 50-352 Attachment 50-353 Page 3 of 3 employees onsite to remind all vendor personnel of the importance of good radworker practices. The information notice identified the  !

responsibility of vendor Radwaste personnel to monitor themselves l and personal items for contamination when exiting the RCA. The I information notice also reminded the vendor Radwaste personnel that prior to entering a designated eating and drinking area, personnel l

and personal items must be monitored for contamination. No similar incidents have been identified since August 23, 1993. -

l Corrective Actions to Avoid Future Non-compliance l

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Subt a ent to this event, articles have been published in the l site dail. r as publication on a weekly basis throughout the month l of October 1393 to remind all station personnel of the importance of frisking prior to exiting the RCA.

Additionally, the importance of adhering to RCA e':it .

I 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 i t, 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 location is currently underway. This renovation provides for one entrance 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 Compliance 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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