IR 05000254/1997003
| ML20140D183 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 04/16/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kraft E COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 9704230039 | |
| Download: ML20140D183 (2) | |
Text
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97003(DRS);
'
!
.
50-265/97003(DRS))
i
ll
Dear Mr. Kraft:
$y -
l This will acknowledge receipt of your letter dated April 7,1997, in response to our letter dated March 7,1997, transmitting a Notice of Violation for two examples where the i
requirements of station procedures for radiological postings and labeling were not
[
followed, in your response, you indicated that the affected postings /labelings were
replaced and that the procedure would be revised to clarify the posting / labeling
!
requirements. We have reviewed your corrective actions for the violations and have no further questions at this time. These corrective actions will be examined during future
,
inspections.
,
l
Sincerely,
/s/ Melvyn Leach (for)
i Geoffrey E. Grant, Director j
Division of Reactor Safety
Docket Nos. 50-254; 50-265
}
Enclosure: Ltr dtd 4/7/97 f
'
Ouad Cities to USNRC w/enct
\\
j See Attached Distribution
)
j
e recef ve a ce nt of this deciment. indicate to the boa
"C" = Co w w/o attach /enci *E*
= Gony w/ attach /enel
"W" = No e 9y DOCUMENT NAME: G:DRS\\QUA041k7.DRS 0FFICE RIII:DRS l&
RIII:DRS c,
RIII:DRP f lM RIII:DRS
.#
,
i NAME NShah:jp 48 TKozak:#' M-WKropp f MLeach/GGra r
!
DATE 04/;t, /97 04/ w-/97 04/ % /97 04/ /6 /97
'
OFFIC"AL RECORD COPY
.B,,0009 lyi.ngjpyl;ggig
,
'
9704230039 970416
,
,.
PDR ADOCK 05000254 G
PDR g,
..
.
.. -..
- - ~. - _ _.
..
. _ -._ -
_
-.
. - - - -
.- -
.. _ _ - - _.
.
,
.
.
- April 16, 1997 (
cc w/o encl: T. J. Maiman, Senior Vice President,
Nuclear Operations Division
D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear l
Operating Officer L. W. Pearce, Station Manager
,
C. C. Peterson, Regulatory Affairs
!
Manager i
1. Johnson, Acting Nuclear
i Regulatory Services Manager l
cc w/ encl:
Document Control Desk - Licensing Richard Hubbard
Nathan Schloss, Economist, i
Office of the Attorney General State Liaison Officer j
Chairman, Illinois Commerce Commission
J. R. Bull, Vice President, General &
Transmission, MidAmerican Energy Company
'
Distribution:
Docket File w/ encl Rlli PRR w/ encl A. B. Beach, Rill w/enct PUBLIC IE-01 w/ encl SRis, Quad Cities, Rlli Enf. Coordinator w/enci OC/LFDCB w/enci Dresden, LaSalle w/enct R. A. Capra, NRR w/enci DRP w/ encl TSS w/enci C. D. Pederson, Rill w/enci DRS w/enci LPM, NRR w/ encl CAA1 w/enci l
,
)
l J
. _ -. _. _
_
_._~__
commmmeahn niivm compan>
(Juatl Citic% Gencr.uing $tation
22*10 20Nh Asenue North Corglin a. II. 612123r io k
Tel.409M s 22 e i ESK-97-075 April 7,1997 I
l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk Subject:
Quad Cities Station Units 1 and 2; NRC Docket Numbers 50-254 and 50-265:
NRC Inspection Report Numbers 50-254/97003 and 50-265/97003.
.
Reference:
M. Leach to E. S. Kraft, Jr. Letter dated March 7,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning Inadequate Radiological Posting with two examples in accordance with 10 CFR 20.
'
This letter contains the following commitments:
QCRP 5010 1, " Radiological Posting & Labeling Requirement", will be revised to add clarification on posting and labeling of radioactive material. This action will be completed by 7-15-97.
If there are any questions or comments concerning this letter, please refer them to Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, extension 3609.
Respectfully, b /b E. S. Krafi J)t, Io
.
Site Vice President Quad Cities Station Attachment (A), " Response to Notice of Violation" cc:
A. B. Beach, NRC Regional Administrator, RIII R. M. Pulsifer, NRC Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities D. C. Tubbs, MidAmerican Energy Company W. D. Leech, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden M. E. Wagner, Comed Licensing DCD - License (Both electronic and hard copy)
QtgQ Srq/yfcom < omp.ms Apg i i 1997
_
.. _
_
.
_
_
.
_
_
_ _ _ _ _ _ _ _
,
.
.
,.
ATTACHMENT A,
" Response to Notice of Violation"
-
ESK-97-075 Page 1 of 2 l
STATEMENT OF VIOLATION (NRC IR 97-003-01):
NOTICE OF VIOLATION Technical Specification 6.11 requires that procedures for personne! radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
a) Quad Cities Radiation Protection Procedure (QCRP) 5010-01," Radiological Posting &
Labeling Requirement," Revision 4, dated September 27,1996, Step G.2.f(l) required that i
areas having removable (smearable) contamination greater than or equal to 1000 l
disintegrations per minute (dpm) beta-gamma or 20 dpm alpha utilizing the survey methods established in QCRP 6020-03, " Radiological Surveys," be posted using " CAUTION, CONTAMINATED AREA" signs.
l b) QCRP 5010-01, " Radiological Posting & Labeling Requirement," Revision 4, dated l
September 27,1996, Step G.3.b(2) required that " CAUTION-RADIOACTIVE MATERIAL" pre-printed labels / stickers be used to indicate licensed material or containers oflicensed
material and that these labels indicate dose rates, contamination levels, signature / initials of
surveyor, and a description of the material / contents, as practical.
Contrary to the above:
,
I a) In the Unit 2 "A" Residual Heat Removal (RHR) room, a drainage trough having removable (smearable) contamination greater than or equal to 1000 dpm beta-gamma was not posted with a " CAUTION, CONTAMINATED AREA" sign; and b) The labels used for check sources for the service water and the radioactive waste effluent l
radiation monitors, which contained licensed material, did not clearly indicate dose rates, contamination levels, signature / initials of surveyor, and a description of the material / contents.
'
This is a Severity Level IV violation (Supplement IV).
I a
't
.
__
. -.
.
_.._
,.
.
'
$
ATTACHMENT A,
" Response to Notice of Violation"
-
ESK-97-075 Page 2 of 2 REASON FOR VIOLATION:
QCRP 5010-01, " Radiological Posting & Labeling Requirement," does not provide adequate guidance for the posting and labeling of radioactive material. The procedure for posting of contaminated areas does not define inaccessible and allows interpretation. This led to the drainage trough in the RHR to be considered inaccessible and not posted as an contaminated area.
The term "as practical" for labeling radioactive material was not defined and allowed inconsistent practices. The sources were labeled but did not include all the peninent information.
ACTIONS TAKEN:
Unit 2 "A" Residual Heat Removal (RHR) room drainage trough was posted as contaminated.
The 2B, I A and the IB RHR rooms' drainage troughs were also posted as contaminated.
The service water and the radioactive waste efIluent radiation monitors' sources were labeled as radioactive material with the pertinent information. A review of other similar monitors with sources was performed and those requiring radioactive material labels, were labeled with the pertinent information.
ACTIONS TO PREVENT FURTHER OCCURRENCE:
QCRP 5010-1, " Radiological Posting & Labeling Requirement", will be revised to add clarification on posting and labeling of radioactive material.
NTS# 2541009700301.01 DATE WHEN FULL COMPLIANCE WILL BE MET:
Unit 2 "A" Residual Heat Removal (RHR) room drainage trough was posted as contaminated and the service water and the radioactive waste effluent radiation monitors' sources were labeled as radioactive material with the pertinent information. Full compliance was met on 3-20-97.