ML20198D499
| ML20198D499 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/12/1992 |
| From: | Cooper R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| Shared Package | |
| ML20198D503 | List: |
| References | |
| EA-92-060, EA-92-60, NUDOCS 9205210054 | |
| Download: ML20198D499 (4) | |
See also: IR 05000352/1992014
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MAY 12 m
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Docket Nos.
50-352
50-353
Mr. D. M. Smith
Senior Vice President - Nucimr
Philadelphia Electric Company
Nuclear Group Headquartert
Correspondence Control Desk
P. O. Box 195
Wayne, Pennsylvania 19087-0195
Dear Mr. Smith:
Subject:
NOTICE OF VIOI.ATION
(NRC Combined Inspection Report Nos. 50-352/92-13 and 50-353/92-13; and
Combined inspection Repon Nos. 50-352/92-14 and 50-353/92-14)
This letter refers to the NRC Inspection conducted by S. Sherbini on March 2647,1992, as
well as the followup inspection conducted on April 20-24,1992, at the Limerick Generating
Station. The first inspection (50-352/92-13 and 50-353/92-13) was conducted to review the
circumstances associated with an intake of radioactive material at the facility. The repon for
this inspection was transmitted to you under separate letter dated April 2,1992. During that
inspection, an apparent violation of NRC requirements was identified. At a result, an
enforcement conference was conducted with you and members of your staff on
April 10,1992, to discuss the violation, its cause and your corrective actions subsequent to
the inspection. The second inspection (50-352/92- !4 and 50-353/92-14) was conducted
partly to follow up on your ongoing investigatien of the intake, and panly to review other
aspects of your radiological protection program.
The violation described in the enclosed Notice of Violation involves three workers who
violated the requirements of a Radiation Work Permit. For one worker, the violation
ultimately was a factor which led to the unplanned intake of radioactive material The
occurrence is of concern to the NRC because (1) an unplanned intake of radioactive material
occurred, (2) several workers violated your RWP requirements, (3) there were several
instances of poor health physics practices associated with the job evolution, (4) your health
physics technician covering the job failed to take control of the situation when it was brought
to his attention that a poor health physics practice was taking place, and (5) an adequate
briefing was not conducted prior to the start the job. Therefore, although the violation has
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Philadelphia Electric Company
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been classined at Severity Level IV, the NRC emphasizes that any recurrence of this
violation in the future may result in escalated enforcement.
Regarding the intake incident of March 25,1992, we have reviewed the most recent bioassay
results and we believe that the estimate of intake reported in the initial NRC Inspection
Report of the incident remains substantially correct, with no alpha-emitting radionuclides
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involved. In reference to the Enforcement Conference held at the NRC of6cc in King of
Prussia on April 10,1992 (a summary of which was provided to you with our letter dated
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April 21,1992), the NRC staff has evaluated your presentation and the circumstances
connected with this incident. The possibility of the existence of a substantial potential for
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exceeding the regulatory limit for inhalation of radioactive material was considered.
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However, the staff consensus was that such a conclusion in this particular case would not be
appropriate, but we will review the scope and effectiveness of your corrective actions in
these areas during future inspections. A Notice of Violation issued in connection with this
incident is enclosed as Appendix A to this letter. You are required to respond to this letter
and should follow the instructions specined in the enclosed Notice of Violation when
preparing your response. Details of this violation are presented in NRC Combined Inspection
Report No. 50-352/92-13 and 50-353/92-13.
Regarding the inspection of the Radiological Controls Program conducted on April 20-24,
1992, areas revicwed during this inspection included tours of the radiological controls areas
and observation of ongoing outage work activities, outage planning, scheduling and ALARA
efforts, the surveillance program for alpha contamination, and the selection and quali6 cations
of contractor health physics technicians. Our inspection identified a number of both positive
and negative aspects of your radiological controls program, as summarized below and
described in more detail in the enclosed inspection report (Enclosure 2).
Tours of the facility showed that radiological postings were generally good, as was control of
access into high radiation areas such as the drywell. However, housekeeping was observed
to be marginal in many areas of the plant, particularly in the Turbine Building, but was quite
good on the Refuel Floor. Contamination control practices also were found to be poor in
some areas of the Turbine Building. In addition, weaknesses were identined in the
surveillance program for alpha contamination. While review of the contractor technician
resumes showed tht they all met the minimum qualifications requirements and most had
fairly extensie experience, there were some weaknesses in the procedure implementing the
technician selection program. Problems also appear to have been encountere.1 in planning,
scheduling, and establishing the scope of outage jobs and all of these problems appear to
have been at lea.e partially responsible for exceeding the cumulative dose estimate for the
outage at a relatively early phase of the outage. Dissemination of outage-related exposure
information also was found to be somewhat deficient. However, despite exceeding the dose
estimate, the outage dose to date remains low by current industry standards, and this appears
to be due mainly to your efforts to maintain station dose rates and contamination levels at
relatively low levels.
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Philadelphia Electric Company
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No safety concems or violations of regulatory requirements were identified during the
April 2424,1992 inspection.
You cooperation with us is appreciated.
Sincerely,
Original Signed By:
Jacque Durr
Richard W. Cooper, Director
Division of Radiation Safety
and Safeguards
Enclosures:
1.
- Appendix A, Notice of Violation
2.
Combined Inspection Report 50-352/92-14 and 50-353/92-14
cc w/encls:
R. Charles, Chairman, Nuclear Review Board
G. Leitch, Vice President - Limerick Generating Station
D. Helwig, Vice President of Nuclear Engineering and Services
J. W. Durham, Sr., Senior Vice President and General Counsel
J. Doering, Manap,cr Limerick Generati.ng Station
G. J. Beck, Manager - Licensing Section
G. Hunger, Project Manager V.hne:ick Generating Station
J. O'Rourke, Mankger - Limenck Quality Division
G. Madsen, Regulatory Engineering - Limerick Generating Station
Secretary, Nuclear Committee of the Board
Public Document Room (PDR)
Im < clic Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2)
NRC Resident inspector
Commonwealth of Pennsylvania
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Region I Docket Room (with concurrences)
Management Assisamt, DRMA (w/o encis)
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R. Clark, NRR
J. Lyash, DRP
DRSS SALP Coordinator
M. Banerjee, SLO
R. Lobel, OE"O
J. Lieberman, OH
J. Goldberg, OGC -
J. Partlow, NRR
D. Holody, RI
K. Smith, RC
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