ML20203E341

Notice of Violation from Insp on 860216-0404

ML20203E341
Person / Time
Site:	Peach Bottom
Issue date:	07/17/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203E338	List: IR 05000277/1986005 ML20203E333 ML20203E341
References
50-278-86-05, 50-278-86-5, NUDOCS 8607240131
Download: ML20203E341 (2)

Text

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l APPENDIX A NOTICE OF VIOLATION i

{ Philadelphia Electric Company Docket No. 50-278 i Peach Bottom Atomic Power Station License No. OPR-56 i Unit 3 1

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, During an NRC inspection conducted from February 16 to April 4,1986, in ,

response to an event identified by the licensee and reported to the NRC,  ;

multiple examples of three violations of NRC requirements were identified and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the particular violations are set forth bclow:

I 4 A. 10 CFR 20.201(b) requires that each licensee make surveys to evaluate the i radiation hazards incident to the release of radioactive materials.10 CFR

! 20.106(d) requires that the concentration limits for effluents released to i unrestricted areas shall be in accordance with 10 CFR 20, Appendix B, l Table II, at the restricted area boundary.

Contrary to the above, from the time of the unplanned release to the unrestricted area at approximately 4:00 p.m. on February 16 until j approximately 2:30 a.m. on February 17, effective surveys were not made to 4

measure concentrations of radioactive material present at the restricted i area boundary, in that, no samples were taken from the actual outfall of j the potentially contaminated storm drain system.

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- Contrary to the above, during the analysis of samples taken throughout the event the radiation hazard was not effectively evaluated in that, no i determination was made of the radiation hazard due to radionuclides in the

. release other than those that emit gamma radiation.

I i These examples constitute a severity level IV violation (Supplement IV). ,

B. Technical Specification section 6.8.1 requires that written procedures be

< established, implemented and maintained that meet the requirements of ,

j sections 5.1 and 5.3 of ANSI N18.7-1972, and Appendix A of Regulatory

Guide 1.33 (November 1972).

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ANSI N18.7-1972, section 5.3.8.2 requires procedures for coping

, with excessive release of radioactive liquids. Regulatory Guide 1.33

! (November 1972) Appendix A, section F, requires procedures for combating abnormal releases of radioactivity.

! Contrary to the above, as of February 16, 1986, no procedure existed to i combat unplanned liquid radioactive releases via potential pathways other j than the discharge canal. ,

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This is a Severity Level IV violation (Supplement IV).

f 0FFICIAL RECORD COPY CIR PB 86 0003.0.0 07/11/86 8607240131 860717 PDR ADOCK 05000277 G PDR

Appendix A 2-C. 10 CFR 50.59(a) allows the licensee to make changes in the facility as described in the FSAR without prior Commission approval if the change does not involve a change in Technical Specifications or an unreviewed safety question. 10 CFR 50.59(b) requires the licensee to maintain records of changes in the facility which shall include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.

FSAR section 2.4.3.3 indicates that release to the environment of a large quantity of radwaste, such as emptying of a tank, is improbable because all outdoor tanks containing radioactive liquids are contained in watertight structures. The maximum expected radioactivity concentration in the condensate storage tank (CST) is given as 3N3 uCi/ml in the updated FSAR Table 9.2-7.

Contrary to the above, the increased probability and consequences of a CST release were not evaluated in that Unit 3 operated from January 1984 to February 1986 with the condensate storage tank dike not watertight and the radioactivity levels of up to IN2 uCi/ml, a factor of three times the value in the FSAR. No safety evaluation was performed for these changes in the facility as described in the FSAR.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Philadelphia Electric Company is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violation,; and (3) the date when full compliance will be achieved. Where good-cause is shown, consideration will be given to extending this response time.

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0FFICIAL RECORD COPY CIR PB 86 0004.0.0 07/10/86