ML20245H715
| 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: |
| References | |
| EA-89-145, NUDOCS 8908170255 | |
| Download: ML20245H715 (4) | |
See also: IR 05000352/1989014
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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
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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-
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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
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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
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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
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Philadelphia Electric Company
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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
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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
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results of future inspections, the NRC will determine whether further NRC
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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,
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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
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Philadelphia Electric Company
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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
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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
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08/04/89
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Philadelphia Electric Company
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Management Assistant, DRMA (w/o encl)
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