ML20137U269: Difference between revisions
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| number = ML20137U269 | | number = ML20137U269 | ||
| issue date = 11/26/1985 | | issue date = 11/26/1985 | ||
| title = Submits Results of Investigation of Constituent R Dobson | | title = Submits Results of Investigation of Constituent R Dobson ,Per 851029 Request.Region I Combined Insp Repts 50-352/85-30 & 50-353/85-07 Re Water Spill Incident Encl | ||
| author name = Dircks W | | author name = Dircks W | ||
| author affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) | | author affiliation = NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) | ||
Line 11: | Line 11: | ||
| contact person = | | contact person = | ||
| document report number = NUDOCS 8512090252 | | document report number = NUDOCS 8512090252 | ||
| title reference date = 10-14-1985 | |||
| package number = ML20137U274 | | package number = ML20137U274 | ||
| document type = CORRESPONDENCE-LETTERS, NRC TO U.S. CONGRESS, OUTGOING CORRESPONDENCE | | document type = CORRESPONDENCE-LETTERS, NRC TO U.S. CONGRESS, OUTGOING CORRESPONDENCE |
Latest revision as of 07:51, 13 December 2021
ML20137U269 | |
Person / Time | |
---|---|
Site: | Limerick |
Issue date: | 11/26/1985 |
From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
To: | Schulze R HOUSE OF REP. |
Shared Package | |
ML20137U274 | List: |
References | |
NUDOCS 8512090252 | |
Download: ML20137U269 (4) | |
See also: IR 05000352/1985030
Text
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/ UNITED STATES
E ^t NUCLEAR REGULATORY COMMISSION
$ ,E WASHINGTON, D. C. 20555
NOV 2 61985
k ..... #
I
The Honorable Richard Schulze
United States House of Representatives
Washington, D.C. 20515
Dear Congressman Schulle:
This refers to your letter to Mr. C. Kammerer, Nuclear Regulatory Commission
(NRC),datedOctober 29, 1985, which included a letter from a Mr. R. Dobson,
Jr., to yourself, dated October 14, 1985. In your letter you requested that
the NRC- review the concerns raised by Mr. Dobson and provide you a report of
our findings. The NRC Region I office was assigned the responsibility to
investigate Mr. Dobson's concerns. Results of that investigation follow.
Prior to receiving your letter, NRC Region I conducted an inspection to deter-
mine the circumstances surrounding the water spill incident, referred to in Mr.
! Dobson's letter, which occurred at Limerick Generating Station, Unit 1, on
August 1,1985. At the request of the NRC Senior Resident Inspector at Limerick,
a Regional specialist inspector was sent to Limerick on August 6,1985 to review
this incident. It was determined that the cause of the water spill was a 3/4-inch
open vent valve on drain piping from the Unit I liquid radwaste system's Equipment
Drain Collection Tank. Details of this inspection were included as a matter of
routine in the monthly NRC Senior Resident Inspector's report, NRC Region I
Combined Inspection Report No. 50-352/85-30; 50-353/85-07 (Enclosure 1).
NRC Region I concluded that this incident was of minimal safety significance
i
and did not constitute a basis that would require the licensee to shut down the
reactor if indeed it had been operating. Furthermore, NRC Region I determined
that this incident was not reportable, that is, it did not meet the notification
criteria of any Emergency Class nor any non-Errergency event category as defined
by the Code of Federal Regulations Title 10, Parts 50.72 and 50.73. However,
the licensee did make a " courtesy call" to the NRC Region I office on August 2
,'
1985 to provide initial notification of the water spill. Dissemination of this
information by Philadelphia Electric Company to the NRC is considered beyond
that required by the Code of Federal Regulations.
InregardtoMr. Dobson'sconcernoverPhiladelphiaElectricCompany's(PEco)
ability to safely operate Limerick, Unit 1, we have evaluated and co'ntinue to
review PEco's performance as an operating licensee. Since granting PECo an
operating license on October 26, 1984, wehavenotidentifiedanyincident(s)
which could be conceived as a basis for concluding thit PEco cannot safely
operate Limerick, Unit 1. On the contrary, in this specific incident PEco's
actions to contain the contaminated water, isolate the source of the leak, ;
investigate additional potential sources and extent of' contamination, process '
the contaminated water and decontaminate the sumps, review generic implications,
I
G512090252 851126
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The Honorable Richard Schulze 2
and implement corrective and preventive actions were determined by NRC Region I to
be timely, thorough and appropriate.
Regarding Mr. Dobson's concern that the plant was allowed to continue operation
while contaminated water had not yet been cleaned up, we have determined that
Limerick Unit I was shutdown at the time. However, had Unit I been operating,
the licensee would not have been required to shut down the reactor as no license
condition was exceeded, no regulation was violated, and nothing of safety
significance was involved. The spilled water, which contained very low levels
of contamination, was collected from the sumps and processed through the
radwaste system. All water had been transferred to the radwaste system by the
end of August 2, 1985. All sumps were then decontaminated. Although not required,
the licensee posted the areas as Radiation Areas in order to minimize possible
spreading of contamination. (See Enclosure 1 for further details.)
In regard to Mr. Dobson's concern over metal particles in the reactor coolant
which would pick up and transfer excessive radiation to the cooling system and
possibly the environment the only " particles" that could be construed as such
are normally-occurring metal corrosion products in the reactor coolant. These
are continuously removed by filtration and ion exchange systems in order to
maintain the purity of the reactor coolant.
Whenever there are piping interfaces (for example, in a heat exchanger) involving
the reactor coolant system and a secondary system whose discharge is to the
environment, there exists the potential for leakage between the systems and
into the environment. However, various design features have been built into
Limerick, as well as all nuclear power plants, such that the potential for
leakage into the environment is minimal and within regulatory requirements.
These features include 1) secondary system isolation capability (both automatic
and manual), 2) maintenance of a differential pressure such that leakage will
be from the secondary system into the reactor coolant, 3) continuous-reading
radiation monitors on the secondary system discharge lines which can annunciate
- alarms and initiate automatic actions and 4) leak testing of the reactor coolant
pressure boundary to ensure a leak-tight system. These examples are not all-
inclusive, and the specific design details can vary from plant to plant.
However, the purpose of each remains the same -- to prevent the radioactive
reactor coolant from reaching the environment.
Regarding Mr. Dobson's final concern, the NRC has been mandated the responsibi-
lity for protecting the radiological health and safety of the public and the
environment, and assuring nuclear industry conformance to regulatory requirements.
To accomplish this goal, we engage in major inspection efforts on a daily basis
by assigning Resident Inspectors to each nuclear site and supplementing that
effort with Regional Inspectors.
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- The Honorable Richard Schulze 4
!
. Any finding resulting from an inspection is evaluated in the context of the
NRC enforcement policy (Ccoa of Federal Regulations, Title 10, Part 2, Appendix
C). This enforcement policy authorizes the NRC to issue notices of violations,
. civil penalties, and orders to. those licensees who do not achieve the necessary
,
attention to detail-and the high standard of ccmpliance which the NRC expects.
l However, each enforcement action is dependent on the circumstances of the case.
- The NRC has taken such enforcement action in the past and will continue to do
i so when necessary and within the bounds of our lawful authority.
!
,
I trust you will find this report sufficient for answering the concerns of
your constituent.
Sincerely,
i
, y (Sinned) T. A, Rehm
'
William J. Dircks
Executive Director
for Operations
! Enclosure:
NRC Region I Combined Inspection Report No. 50-352/85-30;
, 50-353/85-07, excerpt
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RI:DRP DRP DRSS DRP REG ATTNY DEP RA
j Gallo/jc Collins T. Martin Starostecki Gutierrez Allan
!- 11/21/85 11/21/85 11/21/85 11/21/85 . 11/01/85 11/21/85
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The Honorable Richard Schulze 5
Distribution
EDO 1156
E00 Reading File
Docket No. 50-352
Public Document Room
Local Public Document Room
Commonwealth of Pennsylvania
W. Dircks
J. Roe
T. Rehm
V. Stello
C.-Kammerer
J. Taylor
H. Denton
G. Cunningham
T. Murley
J. Allan
R. Starostecki
S. Collins
R. Gallo
E. Kelly
K. Abraham
P. Lohaus
J. Gutierrez
T. Martin
R. Bores
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UNITE 3 STATES
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C'UCLEAR RE!ULATORY COMMISSION '
[ REGION I
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mine or caussia.esansvi.vansa e4ee
Docket Nos. 50-352--- - --- OCT 211985
50-353
Philadelphia Electric Company
ATTN: Mr. Shields L. Daltroff
Vice President
Electric Production
2301 Market Street
Philadelphia, Pennsylvania 19101
Gentlemen:
-
Subject: Combined Inspection 50-352/85-30; 50-353/85-07
.
This1refers
July to the22,
- September rout'ne
1985 resident safety inspection by Mr. E. M. Kelly on .
Pennsylvania. at the Limerick Generating Station, Limerick,
The inspection consisted of document reviews, interviews, and
observation
Leitch of your of staff.
activities, and the results have been discussed with Mr. G. M.
No violations of NRC requirements were identified and no response is require .
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
will be placed in the Public Document Room. -
Your cooperation is appreciated.
Sincerely,
muel .C ns, Chief
Projects Branch No. 2
Division of Reactor
Projects
Enclosure: NRC Region I Combined Report 50-352/85-30; 50-353/85-07
cc w/ encl:
V. S. Boyer, Senior Vice President, Nuclear Power John
S. Kemper, Vicq President, Engineering and Research
G. Leitch, Station Superintendent
Troy B. Conner, Jr. , Esquire
Eugene J. Bradley, Esquire, Assistant General Counsel
Limerick Hearing Service List
Public Document Room (POR)
Local Public Document Roo'm (LPOR) -
Nuclear Safety Information Center (flSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
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U. S. NUCLEAR REGULATORY COMISSION
REGION I
Report Nos. 85-30; 85-07
Docket Nos. 50-352; 50-353
License Nos. NPF-39; CPPR-107 Priority -- Category C;A
Licensee: Philadelphia Electric Company -
2301 Market Street
Philadelphia, Pennsylvania 19101
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Facility Nane: Limerick Generating Station, Unit 1 & 2
Inspection Conducted: July 1 - September 22, 1985
Inspectors: E. M. Kelly, Senior Resident Inspector
J. E. Beall, Project Engineer
R. J. Bores, Technical Assistant
.
D. J. Florek, Lead Reactor Engineer
T. 8. Silko, Reactor Engineer
Reviewed by: Am
J. E. Beall, Project Engi'neir }Oh14 BT
datt
Approved by:
R. M. Gallo,~ Chief, (7
dats
Reactor Projects Section 2A
ORP ,
Inspection Summary: Combined Inspection Report for Inspection
Conducted July 1 - September 22, 1985 (Report Nos. 50-352/85-30;
50-353/85-07)
Areas Inspected: Routine and backshift inspections by the resident inspector
and region-based inspectors of: activities associated with issuance of the
full power operating license on August 8, 1985 and subsequent power ascension;
followup on outstanding items and license conditions; plant tours; observation
of startup testing and review of test procedures and results, maintenance and
surveillance observations, and review of periodic reports. Also addressed are
events that occurred dur,ing the reporting period which include: corrective
action for cable tray penetration fire seal voids, contaminated water spill on
August
11.
1, a RWCU resin spill on Sept' ember 7, and a reactor scram on September
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Result: Three unresolved items were identified associated with: the potential
third offsite 33 kV power source (Detail 2.3); overtime guidelines for shift
personnel (Detail 3.4.3); and drywell temperature control (Detail 7.0). No
violations were identified.
This inspection involved 274 hours0.00317 days <br />0.0761 hours <br />4.530423e-4 weeks <br />1.04257e-4 months <br /> of onsite inspection by the Senior Resident
Inspector, the Limerick Project Engineer and other region-based inspectors.
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The inspector observed both tests at the remote shutdown panel. The
inspector monitored the pre-test briefings, operator communications,
adherence to approved test procedures, and plant response to the
imposed transients. Additional details are provided in Inspection
Report No. 50-352/85-37.
No violations were identified.
5.4 Loss' of Offsite Power Test
,
The licensee successfully completed the loss of offsite power test
(STP 31.1) on September 16, 1985. The test was initiated from about
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20% power and the unit scrammed about one minute later on low reactor
water level. The level drop was caused by the loss of power to the
~ condensate pumps which tripped the feed pumps on low suction pressure
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and caused a loss of feedwater flow to the reactor. All four unit
diesel generators automatically started and powered vital loads as
designed. HPCI initiated automatically 23 minutes into the test as
reactor level continued to decrease. As level began to increase.
HPCI was manually secured to prevent excessive reactor vessel cooldown,
and the smaller RCIC turbine pump was manually started and used to
restore level. The test was terminated as planned after 30 minutes
with the reactor shutdown, vital loaos on the diesels, and vessel
{ 1evel being controlled by RCIC.
The licensee had conducted extensive preparation for this test,
including several hours of scenarios run on the site simulator with
those shif t and test personnel taking part in the test. The scenarios
were not limited to the expected course of events, but included
sequences of events containing failures of key components such as one
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or more diesels failing to auto start. The inspector monitored the
i pre-test briefings in the Control Room and noted that they were
thorough and of high quality. The briefings were interdisciplinary
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in nature, included potential "what-if" scenario variants, and clearly
outlined the announcements which would be made to abort the test
prematurely and the major restorative actions. The importance of
good communications was stressed, and exhibited, throughout the test.
Additional details are provided in Inspection Report 50-352/85-37.
No violations were identified.
6.0 Event Followup
6.1 Contaminated Water Leak into Unit 2
l 6.1.1 Description'of Event
'
On August 1, 1985, at about 10:00 p.m., a security guard
reported to Itcensee management the accumulation of water
in a pit (Unit 2 Pipe Tunnel and Access Room) near the Unit
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2 offgas holdup piping. The water level in the pit rose
from about 1/2 inch to about 18 inches on August 2. Health
physics personnel analyzed this water and found low levels
of radioactive contamination. Approximately 4 E-6 micro-
curies /cc of CO-58, and lesser levels of Co-60 and Cr-51 in
some samples were found in water sampled from the Unit 2
Pipe Tunnel and Access Room, the location where the water
accumulation was first noted. The highest concentrations
were about 4% of the 10 CFR 20, Appendix B limits for
unrestricted areas.
The licensee's investigation identified the source of the
,
water as an open 3/4 inch manual vent valve on drain piping
from the Unit 1 liquid radwaste system Equipment Drain
Collection Tank. Liquid waste was being transferred from
_ the Equipment Drain Collection Tank to the larger Equipment
Drain Surge Tank to provide additional available tank
capacity in the former. With the 3/4 inch manual vent
valve V-2104 open, liquid was apparently siphoned from the
Unit 1 Equipment Drain Surge Tank (through the piping) to
the Unit 2 Pipe Tunnel and Access Room. The source was
identified and isolated on August 2, 1985. Confirmation
that the open valve and the Equipment Drain Surge T,ank were
the cause of the leakage was based on:
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the Itcensee's review of drawings;
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cessation of leakage after valve isolation;
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activity concentrations of comparable levels, and
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a slight downward trending in the Equipment Drain
Surge Tank level after the completion of the transfer
from the* Equipment Drain Collection Tank.
6.1.2 Clean-up Activities
The licensee initiated timely actions to identify and
isolate the source of the leakage, to sample all Unit 2
sumps (several others were found to contain low levels of
contamination), and to begin the processing of the water
(estimated at 10 to 20,000 gallons) through the radwaste
processing system. The contamination in the other sumps
was traced to either pumping from the Unit 2 Pipe Tunnel
and Access Room or gravity flow from that area. No other -
sources were identified.
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All Unit 2 sump water had been transferred to the radwaste
system by the end of August 2, 1985. The sump walls and
floors were monitored for contamination. The highest level
of contamination was about 5000 dpa per 100 square centimeters
in the Pipe Tunnel and Access Room. Most of the other
sumps were about 300 dpm per 100 square centimeters. Since
these are normally " Clean" sumps, all were being decontami-
nated. Although the contamination levels were low, the
licensee posted the areas as Radioactivity Areas to
minimize possible spreading of contamination.
. The licensee's sampling program included all Unit 2 sumps,
the settling pond (last hold-up point on site before
discharge) and a low point in the discharge hose from the
Unit 2 Reactor Enclosure Floor Drain Sump. This sump has
an automatic level control and therefore would automatically
pump to the settling pond when the level rose past the trip
point. No detectable activity was found in water samples
taken from the discharge hose, nor from the settling pond.
This would indicate that no contaminated water had been
discharged to the settling pond. The licensee lifted the
pump electrical leadslof the Unit 2 Reactor Enclosure Floor
Drain Sump to assure no discharge of slightly contaminated
water from the sump could recur without appropriate
processing.
6.1.3 Corrective / Preventive Activities
The licensee closed, locked and tagged valve V-2104, although
it was not determined how or when this valve had been opened.
Numerous previous waste water transfers from the Unit 1
Equipment Drain Collection Tank to the Equipment Drain
Surge Tank had taken place with no identified leakage.
Routine surveillance of all noncontaminated sumps and
systems in response to IE Bulletin 80-10 was conducted as
recently as July 18, 1985. No contamination had been found
previously. The licensee indicated that V-2104 may have
been overlooked in the valve lineup procedures because it
was thought to be a Unit I valve, yet it does have a Unit 2
coding on the P & ID. Consequently, it was apparently
omitted from the surveillance procedures from both units.
Valve V 2104 was incorporated into the valve lineup checkoff
list on August 6 and also 16corporated in the monthly
surveillance procedure. In addition, the licensee has
directed that, in the future, all Unit 2 sumps will be
, sampled and analyzed prior to transfer to Unit I for
l . appropriate processing. Finally, the licensee has initiated
a third independent review of all the Unit 1/ Unit 2 inter-
faces in radwaste piping; this had been underway by the ,
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Limerick Radwaste Coordinator, and was scheduled for
completion by August 8, 1985. Two previous reviews of
these interfaces had been conducted of this area; one by
Bechtel and the other by PEco.
6.1.4 Summary
PECo Upset Report UR-012 dated. August 2, 1985 was reviewed.
The inspector noted that the actual radiological consequences
of this event were insignificant, although the potential
for more serious concerns existed. The licensee's actions
to (1) contain the contaminated water, (2) isolate the
'
source of the leak, (3) investigate additional sources and
.
the extent of contamination, (4) process the contaminated
water and decontaminate the sumps, (5) review generic
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implications and (6) implement corrective and preventive
actions were timely, thorough and appropriate. The inspector
had no further questions.
No violations were identified.
6.2 Contaminated Spill at 'Jnit 1 Reactor Building, Elevation 313
On September 7, 1985, the licensee experienced a spill of a highly
contaminated resin water mixture at elevation 313 of the Unit 1
Reactor Building. The spill was caused by the failure of a RWCU
demineralizer vent valve to close while valving the system on line.
An area about 20 feet by 30 feet was contaminated to levels of about
800,000 dpm per 100 square centimeters; no personnel contamination
occurred,
The inspector reviewed tNe radiological protection measures imple-
mented by the licensee to cleanup the spill while limiting the poten-
tial for airborne contamination and personnel exposure. The initial
steps by the licensee included tenting off the corridor surrounding
the spill, frequent air sampling and use of respirators by cleanup
personnel. The inspector reviewed the radiation work permit (RWP) .
and verified that the personnel involved in survey and cleanup activ-
ities were following RWP requirements. The Ifcensee's approach was
consistently conservative with respect to radiation protection measures
from the discovery of the spill until the corridor area was released
for general access. Additional review of this incident is provided
in Inspection Report 50-352/85-28.
.
No violations were identified.
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EDO PRINCIPAL CORRESPONDENCE CONTROL
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- FROM
- DUE: 11/90/85 EDO CONTROL: 001156
i DOC DT: 10/29/85
i REP. DICK SCHULZE FINAL REPLY:
i'
TO:
CARLTON KAMMERER
i FOR SIGNATURE OF: ** GRFEN ** SECY NO: 85-932
EXECUTIVE DIRECTOR
DESC: ROUTING.
i I
/ ENCLOSES LETTER FROM ROBERT G. DOBSON RE INCIDENT DENTON
AT LIMERICK PLAN ON 8/1/85 TAYLOR
> OCUNNINGHAM
j DATE: 11/05/85
j ASSIGNED TO: RI CONTACT: MURLEY
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l SPECIAL INSTRUCTIONS OR REMARKS: '
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Rep Dick Schulze
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CORRESPONDENCE CONTROL TICKET
,
SdCYNUMBER: 85-932 LOGGING DATE "
0FFICE OF THE SECRETARY
ACTION OFFICE: E00
AUTHOR:
- Rep Dick Schulze--Const Ref
AFFILIATION: Robert Dobson
LETTER DATE: 10/29/85 FILE CODE inAR-s timerick
ADDRESSEE: OCA
SUBJECT:
August 1st incident at the Lirnerick plant
ACTION:
Direct Reply... Suspense: Nov 14
DISTRIBUTION: OCA to Ack
SPECIAL HANDLING: None
SIGNATURE DATE: FOR THE COPMISSION
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