IR 05000373/1997021
| ML20246H011 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/19/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| 50-373-97-21, 50-374-97-21, NUDOCS 9803250161 | |
| Download: ML20246H011 (3) | |
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March 19, 1998
SUBJECT:
. NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-373/97021(DRS);
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50-374/97021(DRS))
Dear Mr. Kingsley:
This acknowledges receipt of Mr. Dacimo's letter dated February 13,1998, in response to our letter dated January 21,1998, transmitting a Notice of Violation associated with two instances when contract workers failed to contact radiation protection (RP) prior to performing grinding and welding activities at your LaSalle County Station.. In your letter, you indicated that the
. workers involved in the second incident were aware of the requirement to contact radiation protection, and decided on their own to bypass the requirement. Based on a March 13,1998, telephone conversation between Mr. Slawinski of my staff and Mr. Perry Bames of the LaSalle'
Station, we understand that your teview did not disclose the requirement to be intentionally violated by the workers. Specifically, the workers, because of successful completion of prior, similar work activities, had become complacent and failed to focus on the requirement to
. contact RP in their haste to complete the job prior to the end of the work shift. The problem was precipitated, in part, by an approximate two hour delay between weld preparation activities and the actual welding work, while other work was completed in the area. If your understanding.
of this matter differs from ours, please contact this office.
Corrective actions _ included development of a checklist to assure that important information is
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discussed with contract workers during pre-job briefings; expanded RP participation in pre-job meetings and work crew break out sessions; and disciplinary action against the two individuals involved in the second incident. A root cause investigation is also underway to review recent trends in radiation worker practice deficiencies.
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1 March 19, 1998 We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely, Original Signed Harold O' Christensen John A. Grobe, Director Division of Reactor Safety Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18 Enclosure:
Ltr dtd 2/13/98 F. Dacimo LaS:lle to USNRC cc w/o encl:
M. Wallace, Senior Vice President D. Helwig, Senior Vice President G. Stanley, PWR Vice President J. Perry, BWR Vice President D. Farrar, Regulatory Services Manager 1. Johnson, Licensing Director DCD - Licensing F. Dacimo, Site Vice President T. O'Connor, Station Manager P. Barnes, Regulatory Assurance Supervisor cc w/ encl:
Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission i
DOCUMENT NAME: G:DRS\\LAS03118.DRS
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<;e March 19,.1998 O. K.ingsley
Distnbution
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A. Beach w/o enci DRS (2) w/enci l
Deputy RA w/o encl Rlli PRR w/o encl Rill Enf. Coord. w/o enci RAC1 (E-Mail)
SRI LaSalle w/o enct IEO (E-Mail)
Project Mgr., NRR w/o enci DOCDESK (E-Mail).
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February 13,1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Subject:
Notice of Violation; NRC inspection Report 50-373/374-97021 LaSalle County Station, Units 1 and 2 Facility Operating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Reference:
J. A. Grobe letter to O. D. Kingsley, dated January 21,1998, Transmitting NRC Inspection Repoit 50-373/374-97021 The enclosed attachment contains LaSalle County Station's response to the subject Notice of Violation, that was transmitted in the Reference letter.
if there are any questions or comments conceming this letter, please refer them to Ferry Bames, Regulatory Assurance Manager, at (815) 357-6761,
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extension 2383.
Respectfully,
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Fred R. Dacimo Site Vice President LaSalle County Station Enclosure-cc:
B. Beach, NRC Region 111 Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle 2N gs i
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ATTACHMENT s
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RESPONSE TO NOTICE OF VIOLATION g
NRC INSPECTION REPORT 373/374-07021
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l VIOLATidN: 373/374-07021 01
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i As a result of an inspection conducted on December 15 - 17,1997, a violation of NRC requirements was identifed. in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG-1600, the violation is listed below:
Technkal Specihcation No. 6.2(B) requires that radiation control procedures be maintained, made available to station personnel, and adhered to.
l Station Procedure LAP-100-22 (Revision 20), " Radiation Work Permit (RdP)
l Program," requires, in part, that individual workers comply with the requirements of the RWP and any associated documents.
Radiation work permit No. 970325 (Revision 3), " Setup, Remove Old Pumps / Piping, Reinstall New Design Pumps / Pipes and Cleanup of Area,"
requires that workers contact the radiation protection staff before performing welding, cutting or grinding on system components.
Contrary to the above, on November 21 and December 1,1997, contract workers were signed onto RWP No. 970325 and performed cutting / grinding I
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and welding activities on reactor water cleanup system piping, respectively,
and failed to contact radiation protection prior to performing the activities.
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This is a Severity Level IV violation (Supplement IV).
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REASON FOR VIOLATION: 373/374-97021-01
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The November 21,1997 incident was the result of poor work practices on the part of the contract workers. The workers had successfully completed similar work activities earlier, and may have become complacent with the Work.
For the December 1,1997 incident both workers were aware of the requirement to contact Radiation Protection (RP) prior to welding but failed to do so, in apparent haste to complete the job prior to the end of the shift, the workers failed to make the notification to RP staff as required by i
procedure.
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L The corrective actions implemented after the November 21,1997 incident were being followed during the December 1,1997 incident. However, these actions would not prevent individuals, who are aware of the requirement, from deciding on their own, to bypass those requirements.
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CORRECTWE STEPS TAKEN AND RESULTS ACHIEVED:
For the November 21,1997 incident:
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Work on the reactor water cleanup (RWCU) modification and
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work on other contaminated components was stopped. A r
prompt investigation was performed.
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All workers under RWP No. 970325 on elevation 761' were
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gathered together and this incident was discussed with them in'
detail to heighten their awareness and stress communication between work groups.
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Appropriate disciplinary action was implemented for the
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workers involved.
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A checklist was developed for use by the Construction
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Department, as a guideline to assure that important information is discussed with contract workers during pre-job briefings for I
high risk activities. The checklist was incorporated into l
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Maintenance Memo No. 0200-2A.
Radiation Protection participation in pre-job meetings.was
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expanded for the RWCU work, including work crew specific l
breakout sessions with the RP Technicians providing coverage for the pending shift work.
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For the December 21,1997 incident:
Work on the RWCU modificatiori was stopped. A prompt
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investigation was perfomled.
f Appropriate disciplinary action was implemented for the
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workers involved.
This event was discussed and proper radiation worker
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practices were reviewed with the appropriate contract workers L
on December 1 and 2,1997, prior to their admittance to the radiation protection area.
l The Station Communication Topics for the Week of
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December 8,1997, included a review of this event. Each Station Depadment reviewed the Communication Topic during weekly department meetings. The lessons leamed from this event were stressed in this weekly review.
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CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
The Station trends lower level radiation worker practice deficiencies. As a
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. result of recent trends, a root cause investigation has been initiated.
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(NTS 373-230-98-SCAOOOC33.00). The investigation is expected to be completed by March 18,1998. Necessary actions will be taken based on the investigation results.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Fut! compliance was achieved on December 2,1997, following the communication meetings with the contract workers prior to their re-entry to l
the radiation protection area.
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