Text

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
	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: ML20137U269; ML20137U295;
References
	NUDOCS 8512090252
	Download: ML20137U269 (4)
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/ UNITED STATES

E ^t NUCLEAR REGULATORY COMMISSION

$ ,E WASHINGTON, D. C. 20555

NOV 2 61985

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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

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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

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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,

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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

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. 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

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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.

!

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I trust you will find this report sufficient for answering the concerns of

your constituent.

Sincerely,

i

, y (Sinned) T. A, Rehm

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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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Distribution

EDO 1156

E00 Reading File

SECY 85-932

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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C'UCLEAR RE!ULATORY COMMISSION '

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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:

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Subject: Combined Inspection 50-352/85-30; 50-353/85-07

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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

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D. J. Florek, Lead Reactor Engineer

T. 8. Silko, Reactor Engineer

Reviewed by: Am

J. E. Beall, Project Engi'neir }Oh14 BT

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Approved by:

R. M. Gallo,~ Chief, (7

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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

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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

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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

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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

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source of the leak, (3) investigate additional sources and

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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

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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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ML20137U269

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