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Discusses Insp Rept 50-352/89-14 on 890629 & Forwards Notice of Violation.Insp Reviewed Circumstances Involving Transport of Contaminated Waste from Unit to Quadrex Recycle Ctr in Oak Ridge,Tn on 890620
	ML20245H715
Person / Time
Site:	Limerick
Issue date:	08/09/1989
From:	Russell W; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Corbin McNeil; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20245H719	List: ML20245H715; ML20245H727;
References
	EA-89-145, NUDOCS 8908170255
	Download: ML20245H715 (4)
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August 9, 1989

Docket No. 50-352

License No. NPF-39

EA 89-145

Philadelphia Electric Company

ATTN: Mr. C. A. McNeill, Jr.

Executive Vice President

Nuclear

Correspondence Control Desk

P. O. Box 7520

Philadelphia, PA 19101

Gentlemen:

Subject: NOTICE OF VIOLATION (Inspection Report Number 50-352/89-14)

This letter refers to the special NRC Inspection conducted on June 29, 1989 at j

the Limerick Nuclear Generating Station, Unit 1, Sanatoga, Pennsylvania to

review the circumstances associated with an incident involving the transport of

contaminated waste from Limerick Unit 1 to the Quadrex Recycle Center in Oak

Ridge, Tennessee on June 20, 1989. The shipment arrived at Oak Ridge with

external radiation levels in excess of the regulatory limit at the surface of

the transportation vehicle. The event, which was identified to you by the

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vendor and subsequently reported to the NRC by your staff, constitutes a vio- '

lation of NRC requirements. The report of the inspection was sent to you on

July 11, 1989. On July 17, 1989, an enforcement conference was held with i

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Mr. G. Leitch and other members of your staff to discuss the violation, its

causes, and your corrective actions.

The violation, which is described in the enclosed Notice of Violation, occurred

when a SeaVan was shipped from Limerick to the Quadrex Recycle Center, and upon

receipt of the SeaVan at Quadrex, a radiation level of 250 mR/hr was found on :

the external surface at the bottom of the trailer used to transport the SeaVan.

The SeaVan, which contained bagged radioactive waste and a B-25 container-

holding a Reactor Water Cleanup Pump impeller, was surveyed by your staff prior

to shipment. The survey identified a maximum contact reading on the bottom of <

the trailer of 190 mR/hr, which is within 5% of the regulatory limit. The NRC

is concerned that, even though the instrument used to perform the survey had a

manufacturer's specified linearity of response of + 15%, which raised the

potential for contact readings in excess of regulatory limits, the shipment was

allowed to go forward without adequate assurance that the radiation levels were

within the regulatory limit of 200 mR/hr. Your transportation procedure was

not effective in precluding this shipment of radioactive material with contact

radiation level readings in excess of regulatory limits. The procedure did

not consider instrument error and calibration when measuring the radiation

levels approaching regulatory limits. This matter indicates that there was

inadequate control over shipping of packages.

OFFICIAL RECORD COPY CP PKG LIM /TRANS 8/4 - 0001.0.0

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Philadelphia Electric Company 2

In accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions", 10 CFR Part 2, Appendix C, Fed. Reg. 40019 (October 13,

1988) (Enforcement Policy), the violation in the enclosed Notice has been

categorized as a Severity Level III violation. A civil penalty is normally

considered for Severity Level III violatio :s. However, after consultation with

the Director, Office of Enforcement, and the Deputy Executivc Director for i

Nuclear Materials Safety, Safeguards, and Operations Support, I have decided

that the civil penalty will be mitigated in its entirety due to your past

performance in the area of transportation. The other mitigation and escalation

factors described in the Enforcement. Policy were considered but none warranted

additional adjustment to the civil penalty.

You are required to respond to this letter and the enclosed Notice, and should

follow the instructions specified in the enclosed Notice when preparing your

response. In your response, you should document the specific actions taken and

any additional actions you plan to prevent recurrence. After reviewing your

response to this Notice, including your proposed corrective actions and the f

results of future inspections, the NRC will determine whether further NRC

enforcement action is needed to ensure compliance with regulatory requirements. ]

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC Public Document Room.

The responses directed by thic letter and the enclosed Notice are not subject

to the clearance procedures oi the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, PL No.96-511.

Sincerely,

4

Original Signed By

WILLIAM T. EUSSELL

William T. Russell

Regional Administrator

Enclosure: Notice of Violation

cc w/ encl: See next page

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OFFICIAL RECORD COPY CP PKG LIM /TRANS 8/4 - 0004.0.0

08/07/89

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Philadelphia Electric Company 3

cc w/ encl:

J. S. Kemper, Sr., Senior Vice President - Nuclear Construction

G. M. Leitch, Vice President - Limerich 3enerating Station

S. J. Kowalski, Vice President - Nuclear Engineering

D. R. Helwig, General Manager - Nuclear Servcies

M. J. McCormick, Jr., Manager - Limerick Generating Station .

W. T. Ullrich, Manager - Limerick Unit 2 Startup

A. S. MacAinsh, Manager - Limerick Quality Division

G. A. Hunger, Jr. , Director - Licensing Section

T. B. Conner, Jr. , Esquire

E. J. Bradley, Esquire, Assistant General Counsel

H. D. Honan, Branch Head - Nuclear Engineering Licensing

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

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0FFICIAL RECORD COPY CP PKG LIM /TRANS 8/4 - 0005.0.0

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Philadelphia Electric Company 4

bec w/ enc 1:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o encl)

Section Chief, DRP

J. Dyer, EDO

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HThompson, DEDS

JMTaylor, DEDR

JLieberman, OE

WRussell, RI

JGoldberg, OGC

TMurley, NRR

JPartlow, NRR

Enforcement Directors II-III

Enforcement Officers, RIV-V

Resident Inpsector

FIngram, GPA/PA

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