ML20096E363
| ML20096E363 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom |
| Issue date: | 08/10/1984 |
| From: | Cooney M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8409070030 | |
| Download: ML20096E363 (2) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA,19101 (21s) 841 5020 M. J. COON E Y vC o."P.!'o" C,,O,.
August 10, 1984
. ELECTW4C PRODUCT 6CN DEPARTMENT Docket Nos. 50-277 50-278 Mr. Richard W. Starostecki, Director Division of Project and Resident _ Programs U.S. Nuclear. Regulatory Commission
- Region I 631 Park ~ Avenue King.of Prussia, PA 19406
Dear Mr. Starostecki:
Your letter dated July 2, 1984, forwarded Combined.
Inspection Report 50-277/84-15 and 50-278/84-13.
Appendix.A of
-your letter addresses one item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.
This item is restated below along with our response.
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l Technical Specification'6.8 and Regulatory Guide.l.33
-(November 1972) require implementation _of-procedures for L
control of radioactivity.
Procedure HPO/CO-100, Revision 13, April 25,1983, _ Health Physics Guides Used. in the Control of Exposure to Radioactive Material, requires posting, with l
" Contaminated Area"' signs or a radiation tape barrier line, of-areas.having removable surface contamination above 1000 i
disintegrations per minute per 100 square centimeters l
(apm/100 cm2).
Contrary to the above, on May 16, 1984, three fire barrier-
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seals in the ReactorLBuilding 165-foot elevation had t
removable surf ace contamination of 1700 to 23,000 dpm/100 cm2 l
and were not. posted with " Contaminated Area" signs or a radiation tape barrier-line.
This'is a Severity Level IV Violation (Supplement IV) applicaole to DPR-44.
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Mr. Richard W. Starostecki August 10, l'9'84,
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. Response.
Investigation determined _that this violation apparently ~T occurred because Health Physics. personnel, performing aif,
. general area survey, neglected to smear several fire barrier seals..
' Representative smears of. surfaces are-necessarily used to.
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' monitor. areas and equipment for loose surface contamination..
-During general' area. surveys, these representative smears are normally taken from areas where plant personnel are inclined to walk or touch. ~ Consequently, the representative smear area' is 'relatively small.in comparison to-the large surfaces.
Because of this large surface area to smear area ratio, and because: personnel-would not normally access the seals in
' question, Health Physics personnel did not smear sample theseEparticular' seals during their general area survey.
HealthPhysicspersonnelhavenowbeenmabeawarethatthe fire" barrier-seal material.may accumulate contamination and that the seals should be considered potential contamination problems. 'On May 23, 1984," Health Physics personnel were instructed'during a weekly meeting to increase their surveillance of fire barrier seals and.other'relatively
. inaccessible areas.during general area surveys.
Fire barrier seal surveys have been re-emphasized during weekly meetings
'since then_as a reminder to prevent the recurrence of a similar violation.
The ten-day delay of this response.was discussed with
- Robert:M..Gallo of your staff and found acceptable.- We regret any-inconvenience this late submittal may have~ caused.
t-1 If you require additional information, do not-hesitate
.to contact us.
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Ver.truly yours,
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cc:. Mr '. A. R. Blough, Site Inpsector
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