ML20133H691
| ML20133H691 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/09/1997 |
| From: | Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20133H694 | List: |
| References | |
| NUDOCS 9701170260 | |
| Download: ML20133H691 (3) | |
See also: IR 05000352/1996009
Text
I
l
o
,
>o
s
January 9, 1997
Mr. D. M. Smith, President
PECO Nuclear
Nuclear Group Headquarters
Correspondence Control Desk
P. O. Box 195
Wayne, PA 19087-0195
SUBJECT:
NRC INTEGRATED INSPECTION REPORT 50-352/96-09,
50-353/96-09; NOTICE OF VIOLATION
Dear Mr. Smitl..
On October 22,1996, through December 16,1996, the NRC completed an inspection at
your Limerick 1 & 2 reactor facilities. The enclosed report presents the results of that
inspection.
During the 8-week period covered by this inspection period, your conduct of activities at
the Limerick 1 & 2 facilities was generally characterized by safe and conservative
operations. Operators responded appropriately to several plant transients. We noted that
the material condition of the emergency diesel generators was significantly improved during
this inspection period; however, it required the NRC pointing out the poor overall material
condition to plant management before action was taken to correct this situation.
Our review of selected procedures and records and personnel ".erviews found the
emergency preparedness prog'am, overall, to be directed tow 1 public health and safety.
Noted strengths were management involvement, relationships with offsite agencies, and a
well-defined self-assessment program.
The inspectors reviewed the applied radiological controls program including planning and
preparation for the Unit 2 outage. The inspectors found that applied radiological controls
were good including planning and preparation for the outage. However, weaknesses were
identified in the control of radioactive sources.
Also reviewed was the disposal of radioactive material at the new 10 CFR 20.2002
disposal area. The area proposed for disposal of slightly contaminated flowable solids
(soils, sediment, sludge) was found to be generally consistent with information provided to
the NRC, but not in all material respects. Consequently, a violation involving failure to
provide a complete description of the disposal area, as required by 10 CFR 50.9 and 10 CFR 20.2002, was identified. The violation is cited in the enclosed Notice of Violation
j
(Notice) and the circumstances surrounding it are described in detail in the subject
/
/
inspection report. The violation is of concern because complete and accurate information
was not provided prior to the NRC's approval of disposal of radioactive materialin the
environment. You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
9701170260 970109
'
ADOCK 05000352
G
.
..
.
..
r
NORTH AMERICAN INSPECTION, INC.
,
MEMO
December 12, 1996
TO:
Robert K.
Shumway, President
,.
FROM:
Don B.
Shumway, RSO
1
As discussed during our meeting this date, you will assume all
duties of the Radiation Safety Officer, during my absence.
This
will include my current medical leave, vacations, and regular
scheduled days off.
.
-
,.
North American Inspection, Inc.
Page #3
Joel Guthrie - Operations Manager; manages lab services and
schedules all work for NAII's radiographers.
Also covers over
90% of all in-house radiography, with a small percentage of
field-site radiography in emergency cases.
Now, the communication problem, as we see it.
On August 7,
1996
NAII's RSO went on medical leave expecting to be out four to six
weeks.
Detailed instructions were given to the Assistant RSO by
the RSO, as to when field audits were to be done, sources to be
leak tested, and projectors needing quarterly maintenance to be
administered, during his absence.
Everything directed by the RSO
was completed as instructed, but unfortunately the RSO developed
complications, which extended his medical leave for cuer four
months.
On November 12 and 13, 1996, Sheri A. Arredondo and Eric
Reber of your office conducted a routine safety inspection.
The
two radiographers not named on their " Notice of Violation" were
the Assistant RSO and Operations Manager.
Needless to say, as
President of NAII I have asked myself many times, how could this
have happened?
During the absence of the RSO, his directives
were reviewed with the Assistant RSO by me on a regular basis to
assure all inspections were done as instructed.
These two
individuals' names were not on the original directive from the
RSO.
When the Assistant RSO was questioned as to why the
Operations Manager was not picked up for a field audit, it was
explained that the Operations Manager's work was mostly confined
to the in-house lab service with most of this work being with X-
ray machines, and that from a previous routine inspection
conducted by the NRC's Kathleen Dolce on September 1,
1995, the
RSO and Assistant RSO for NAII were told that in-house
inspections and/or staged inspections outside the laboratory in
the field were not acceptable.
Also, on the day the Operations
Manager was working in the field, which is the day picked up in
this noted violation, the Assistant RSO was also working in the
field and was unaware of the Operations Manager being out.
The
duties performed in the field by the operations Manager on the
day in question were to process film for the radiographer in
charge of his project.
The Operations Manager did not work with
nor was he near the source of radiation during exposures on this
day.
The missed inspection on the Assistant RSO, during this
same day, was due to the RSO not being back from his medical
leave.
The Assistant RSO assumed, that since he was the acting
RSO and no one was over him at the time, that he would be
exempted from a field inspection.
ACTION TAKEN TO PREVENT RECURRENCE
A subsequent meeting was held with the RSO, Assistant RSO,
Operations Manager and myself on December 12, 1996.
The above
was discussed in detail and decided that until the RSO returns on
a full-time basis, that the President will assume all duties as
1