ML20247B427
| ML20247B427 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/08/1989 |
| From: | Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8909130028 | |
| Download: ML20247B427 (6) | |
Text
<
W.
l 10 CFR 2.201 3
+..
PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING STATION ij P. O. BOX A.
j SAN ATOG A, PENNSY LV ANI A 19464 i
i tzis) sznizoo sxt zooo September 8, 1989 I
M. J. McCO RMIC K. Jn., P E.
5..... 7 '".I,.".*f4 ".'".,....,,
Docket Nos. 50-352 t
License Nos. NPF-39 l
U.S. Nuclear Regulatory Commission j
Attn: Document Control Desk Washington, DC-20555
SUBJECT:
Limerick Generating Station, Unit 1 Reply to a Notice of Violation-NRC
-Inspection Report No. 50-352/89-14
Dear Sir:
Attached is Philadelphia Electric Company's (PECo's) response to the " Notice of Violation (NRC Inspection Report No. 50-352/89-14)" for Limerick Generating Station (LGS) Unit I regarding the transport of radioactive waste.from LGS Unit 1 to the Quadrex Recycle Center in Oak Ridge, Tennessee, on June 20, 1989.
The' August 9, 1989, NRC " Notice of Violation" letter refers to the June'29, 1989, NRC inspection at LGS.
During the inspection the NRC identified a violation of NRC requirements, described in NRC Inspection Report No. 50-352/89-14, transmitted by NRC letter dated July 11, 1989.
On July 17, 1989, an Enforcement Conference was held at the NRC Region I office between PECo and NRC representatives, at which time the identified violation, the root cause of the event, and the corrective actions were discussed.
The attachment to this letter provides a restatement of the violation and our response.
If you have any questions, or require additional information, please contact us.
Very truly yours, t
DRS:sc
'Q"I Attachment cc:
W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS
\\
8909130028 890908 PDR ADOCK 05000352 O
- e.
bec:
C. A. McNeill, Jr., - 52C-3 J. S. Kemper - S25-1 S. J. Kowalski - S25-1 J. W. Durham - S23-1 J. M. Madara - 53A-1 G. M. Leitch - LGS M. J. McCormick,-Jr. - LGS C. R. Endriss - LGS A. S. MacAinsh - LGS E. P. Fogarty - 51A-1 D. R. Helwig - 51A-11 G. A. Hunger, Jr. - 52A-5 R. M. Krich - 52A-5 Limerick ISEG Supervisor Commitment Coordinator Correspondence Release Point - T2-4 DAC PA DERBRP Inspector LGS.
I
--__m__.. _. - _ _ _ _ _ _ _ _ _ _. _ _ _
' Attachment Page 1.ofLe
.4 Inspection No. 50-352/89-14 Reply to a Notice of Violation Restatement of the Violation During an NRC inspection conducted on June 29, 1989, to review the circumstances associated with the shipment of radioactive waste, a. violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, 55 Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10m CFR 2.205.
The particular violation is' set forth below.
10LCFR 71.5(a) states, in part, that each licensee who transports licensed material outside of the confines of its plant.or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode'of transport of the Department of Transportation (DOT) in-49 CFR Parts 170 through 189.
49 CFR 173.441(b)(2) states, in'part, that a package which exceeds the radiation level limits specified in paragraph (a) of that section shall be transported by exclusive use shipment only and the radiation levels for such shipment must not exceed 200 millirem per hour at any point on the outer surface of the vehicle, including the top and underside of the vehicle.
Contrary to the above, on June 20, 1989, the licensee shipped a SeaVan containing 736.64 millicuries of licensed material (in the form of bagged trash and contamination on a pump
-impeller' blade), by exclusive use shipment on a trailer to the Quadrex Recycle Center in Oak Ridge Tennessee.
Upon receipt by the Quadrex Recycle Center on June 21, 1989, a survey determined that maximum surface reading on the underside of the trailer was 250 millirem per hour.
This is a Severity Level III violation.
(Supplement V)
RESPONSE
Admission of Alleged Violation i
Philadelphia Electric Company acknowledges the violation.
l 1
r, te i
Attachment' 2
Page 2 of 4 c,-
Inspection No. 50-352/89-14
' Reason for the Violation
'This violation has been attributed to:
1) differences in the response capabilities of the survey meters used at Limerick Generating Station (LGS) and the radwaste receiver (i.e., Quadrex: Recycle Center),-.and'
'2)_
a failure to incorporate a + 15% instrument error factor, as specified by the instrument vendor, in'the LGS. procedures governing radwaste shipments.
'The Health Physics (HP) technician performing the' June 20,
'1989, SeaVan release survey using an Eberline Model E-520 survey meter with an HP-270 external-probe,.obtLined a-contact dose rate reading on the underside of the SeaVan of 190' milliroentgen per hour (mR/hr).
The Eberline.E-520 isLthe survey meter most commonly used by the nuclear industry for measuring radioactive shipments.
After careful re-verification of the 190 mR/hr reading by the HP. technician, the Radwaste (RW) shipping group allowed'the SeaVan to be released for shipment.
The SeaVan arrivedLat the Quadrex Recycle Center on June 21, 1989, and was surveyed by their technician using a Ludlum Model-14C survey meter with a'Model 44-6 external probe.. The.Quadrex technician.
recorded a contact' dose rate of 250 mR/hr at the same_ location where the 190 mR/hr reading was taken prior to shipment.
After follow-up. investigation by LGS personnel at the Quadrex Recycle Center, the possibility of the radioactive material shifting during transport was ruled out.
Further investigation by LGS personnel revealed that differences existed between the response capabilities'of the meters used at LGS and the Quadrex Recycle Center.
LGS personnel' determined that the Eberline E-520 survey meter with the HP-270 probe significantly under-responds at radiation levels greater than 150 mR/hr when set on a range setting' corresponding to a multiplication factor of 10.
The
-Eberline'E-520 meter utilizes a " Linear" scale for each multiplication factor range setting of the instrument.
As a result, if the instrument is used with the'HP-270 probe to determine radiation levels, and is set on the high range scale, j
the meter under-responds due to increasing meter dead time or meter saturation.
As for the Ludlum 14C meter, it utilizes a "Non-linear" upper range scale which compensates for the tendency of the meter to under-respond at high radiation levels.
In addition, the. vendor manual for the Eberline E-520 did not specify that the meter would under-respond at radiation levels greater than 150 mR/hr, however, it did specify that the meter has an instrument' error factor of + 15%.
The LGS HP and RW procedures.that control RW shipments described below, did not incorporate the vendor's instrument error factor of + 15% for determining radiation levels.
l 1
P Attachment Page 3 of 4 Inspection No. 50-352/89-14 Procedure HP-715, " Vehicle Surveys in Support of Radioactive Material and Radioactive Waste Shipments."
Procedure RW-222, " Shipment of Radioactive Waste to Barnwell."
Procedure RW-223, " Shipment of Radioactive Waste to Richland."
Procedure RW-224, " Shipment of Radioactive Material to a Location Other than a Burial Site."
Had the instrument error of + 15% been incorporated into the HP and RW shipping procedures, the SeaVon measured dose rate of 190 mR/hr would have fallen within the range of 162 to.219 mR/hr.
Therefore, additional investigation on the part of.the RW shipping group would have been called for which may have prevented the shipment of the radioactive material above the 200 mR/hr regulatory limit.
Corrective Actionc Taken and Results Achieved
.P and RW shipping procedures HP-715, RW-222, RW-223, 1.
H and RW-224 have been revised and now incorporate the +
15% instrument error factor for the Eberline E-520.
The LGS site limits for shipping radioactive material, without authorized approval, have now been reduced to below the regulatory limits, and are identified below.
Previously, the LGS site limits were identical to that of the regulatory limits.
The dose rate limit on contact of the vehicle has been reduced from 200 mR/hr to 150 mR/hr.
The dose rate limit at 2 meters distance from the vehicle has been reduced from 10 mR/hr to 8 mR/hr.
The dose rate limit in any normally occupied area of the vehicle limit has been reduced from 2 mR/hr to 1.6 mR/hr.
A procedural step, which instructs the technician performing a RW shipment survey to inform appropriate LGS station supervision when a contact dose rate greater than 150 mR/hr is
)
obtained with the Eberline E-520 meter, has also been j
incorporated into the RW ar d HP procedures identified above.
I 2.
The training for HP technicians now includes this event and its cause, and also includes information on the response characteristics of the Eberline E-520, to
)
preclude a recurrence of this incident.
Attachm:nt c.-
Page 4 of 4 Inspection No. 50-352/89-14 3.
A HP group information notice dated August 14, 1989, has been sent to the HP staff discussing this incident and the response characteristics the Eberline E-520 survey meter.
4.
Operating experience (OE) document No. OE 3462, describing this event, has been disseminated via the Institute of Nuclear Power Operations (INPO) Nuclear Network on July 17, 1989.
Corrective Actions Taken to Avoid Future Non-Compliance Recurrence of this violation will be precluded as a result of lowering the LGS site radioactive waste shipping limits,
)
incorporating the + 15% instrument error factor into the HP and RW procedures, and incorporating the response characteristics of the Eberline E-520 survey meter into the HP training.
Date When Full Compliance Will be Achieved All of the corrective actions identified in this response have been completed and implemented as of August 11, 1989.
_ _ - ~ _ _ - _ _ _ _ _ _