ML17180B046
| ML17180B046 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/09/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17180B045 | List: |
| References | |
| 50-237-94-18, 50-249-94-18, NUDOCS 9412230091 | |
| Download: ML17180B046 (3) | |
Text
Commonwealth Edison Company Dresden Station Units 2 and 3 NOTICE OF VIOLATION Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 During an NRC inspection conducted on October 6 to November 21, 1994, a violation of NRC requirements was identified.
In accordance ~ith the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed qelow:
Technical Specification 6.2.A.l stated written procedures shall be established, implemented and maintained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which included procedures for abnormal conditions and the control of radioactivity.
A.
Dresden Operations Abnormal Procedure 0010-10, "Fire/Explosion,"
Revision 3, stated that if a fire is located inside the protected area, the location is to be announced twice on the public address system.
Contrary to the above, on October 24, 1994, operators failed to announce over the public address system a trash fire inside the protected area west of the Unit 2/3 cribhouse building.
B.
Dresden Administrative Procedure 12-33, "Control of Radioactive
- Material, 11 Revision 2, stated that all radioactive material moved from a posted area shall be escorted by a qualified radiation protection department member unless the movement is otherwise authorized and controlled by other special written instructions, such as a procedure or radiation work permit.
Contrary to the above, on October 27, 1994, radioactive material as contamination on an instrument for measuring equipment vibration was moved from a posted area and was not escorted or otherwise authorized and contra 11 ed.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region III, and a copy to the NRC Resident Inspector at Dresden, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the l o
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used as a hot tool and machine shop, resulted in contamination control problems.
The area was decont~minated and an airlock was erected around the access door to control airflow.
However, problems with controlling vJorker access to the tool storage room and improper return and storage of contaminated tools indicated that additional management attention to this area was necessary.
For the reactor buildings, a project to assess and optimize the ventilatiun system was ongoing.
This included cleaning and repair of local dampers and air registers, walkdown of pitot traverses to ensure adequacy of location, and fan blada pitch adjustment.
Once the repairs were done, a full system balancing was planned, and consideration was being given to installing chillers on the supply side of the system to reduce the number of contaminations caused by workers sweating profusely and leaching contamination through protective clothing.
4.1.3 Internal Contamination Events The inspectors reviewed the internal contamination events of August 2, October 8, 12, 13, and November 10.
Although the resultant doses from the intakes were well below regulatory limits, the intakes were unplanned and indicated a weakness in internal exposure control.
The predominant cause appeared to be poor. communications between departments resulting in poor control of work activities.
As a result of the events in October, the radiation protection department conducted several internal discussion sessions on the contribution of the radiation department group to these problems and a task group was.established with personnel from operations, RP, and maintenance to review the coordination of work and reactor operations activities; 4.1.4 Control of Radioactive Material The inspectors reviewed corrective actions for a Levei II investigation concerning problems with contaminated items inadvertently leaving radiologically posted areas (RPAs) as documented in Inspection Report 50-237/249-93032(DRSS).
Although some corrective actions were completed, the licensee's ability to prevent the inadvertent release of contaminated items from RPAs was still poor.
In 1994 the licensee identified 38 occasions where contaminated items were taken out of RPAs with inadequate or no surveys.
The corrective actions taken in late 1993 and early 1994 were ineffective.
In addition, on October 27 a contaminated instrument for measuring equipment vibration was found outside an RPA.
Dresden Administrative Procedure (OAP) 12-33, "Control of Radioactive Material," Revision 2, stated that all radioactive material moved from a posted area shall be escorted by a qualified RP department member unless the movement is otherwise authorized and controlled by other special written instructions, such as a procedure or radiation work permit.
Failure to take proper measures to control contaminated material in accordance with an approved procedure is a Violation of Technical Specification 6.2.A.l (50-237/249-94018-0lb(DRSS)).
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e.~ e The corrective actions taken to date included: the use of a tool monitor for consistent surveys of hand-held items leaving the main RPA, limitation on the items (including tools) that could be taken in and out of the main RPA, reduction of the number of egress points from the main RPA, and a plant cleanup day in which 14 dumpsters were filled with trash and disposed of offsite. However, the licensee had not completed several corrective action~ including reduction in the number of satellite RPAs, full use of the hot tool shop, a complete search of owner controlled area for contaminated items.
Incomplete corrective actions, a recent industry-group audit finding with the station RP procedure on surveying contaminated items and site quality verification personnel observations on egress point tool and personnel monitoring indicated comprehensive management attention was warranted.
Related to the control of radioactive material, during a walkdown of the Unit 1 radwaste storage area (an outdoor, fenced area) the inspectors observed a large number of "Sea-vans" (waterway shipment containers commonly used at nuclear power plants for storage of material). A contact dose rate measurement on one of the Sea-vans indicated 20 millirem/hour (0.2 millisievert/hour). The Sea-van was not labeled as containing radioactive material, but did bear a piece of duct tape that indicated the contents were scaffolding, large hand tools, and shelving.
A preliminary search did not locate a survey record of the contents or records for the other Sea-vans. This is considered a Unresolved Item (50-237/249-94018-06(DRSS)) pending review of the licensee's evaluations.
In addition, around November 10, heavy rains resulted in water pooling in the storage area around many of the Sea-vans. A subsequent survey by the licensee identified low-level contamination in the area suggesting that the rain may be washing contamination out of some of the Sea-vans.
Furthermore, discussions with plant personnel indicated a lack of ownership with the storage of materials in the Sea-vans.
Previous plans to inventory and consolidate the contents of the Sea-van apparently were postponed indefinitely because of scheduling constraints. Overall, control of radioactive material in this area was poor.
4.1.5 Change in Radiation Protection 'Manager Positions As discussed in Inspection Report 50-010/237/249-94015(DRP), the licensee appointed one Radiation Protection Manager (RPM) for Unit 3 and radwaste activities and one RPM for Units 1 and 2, with both RPMs functioning as head of the department.
In addition, the former RPM was assigned to a position of administrative RPM.
On October 24 the licensee reverted to having a single RPM for all three units and radwaste.
In addition, the role of the administrative RPM was more clearly defined for conducting root cause analyses of problems and reviewing procedure changes prior to signature by the department head.
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