ML20096E363

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Responds to Noncompliance Noted in Insp Repts 50-277/84-15 & 50-278/84-13.Corrective Actions:Health Physics Personnel Instructed That Fire Barrier Seal Matl May Accumulate Contamination & Should Be Considered Potential Problem
ML20096E363
Person / Time
Site: Peach Bottom  Constellation icon.png
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,

Page 2,

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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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