ML17180B247
| ML17180B247 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/02/1995 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wallace M COMMONWEALTH EDISON CO. |
| References | |
| EA-95-074, EA-95-74, NUDOCS 9506210044 | |
| Download: ML17180B247 (4) | |
See also: IR 05000237/1995005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
EA 95-074
Mr. Michael J. Wallace
Vice President and Chief
Nuclear Officer
Commonwealth Edison Company
Executive Towers West III
1400 Opus Place, Suite 300
Downers Grove, Illinois 60515
REGION Ill
801 WARRENVILLE ROAD
LISLE. ILLINOIS 60532-4351
June 2, 1995
SUBJECT:
DRESDEN STATION - UNITS 2 AND 3
EXERCISE OF ENFORCEMENT DISCRETION
(NRC INSPECTION REPORT NO. 50-237/249-95005(DRP))
Dear Mr. Wallace:
This letter refers to an NRC inspection conducted at the Dresden Nuclear Power
Station, Units 2 and 3, between March 7, 1995, and April 24, 1995.
One of the
issues addressed in the inspection report, which was sent to Mr. T. Joyce on
May 22, 1995, was the identification of a significant contaminated material
control problem. A management meeting was subsequently conducted on May 31,
1995.
The problem involved your discovery of approximately 450 uncontrolled
contaminated items during an extensive site search and survey. These items.
were found outside of radiologically protected areas (RPAs), which is a
violation of your radiation protection procedures. Although you could not
determine how long each item was in the uncontrolled area, this is clearly a
long-standing problem in that the items were uncontrolled for times ranging
from several days to many years.
Of particular concern is your failure to recognize the scope of this problem
earlier when taking corrective actions for contaminated material control
violations identified in 1993 and 1994.
Proper control of potentially
contaminated/radioactive material, including its surveying and handling, is a
fundamental part of a radiation protection program.
The problems with
contaminated material control, as well as in other areas of radiation
protection performance, including perennially high dose expenditure at the
site, are not only problems of the Radiation Protection Department, but are
problems of all site personnel. Without the cooperation of site personnel,
poor performance will most likely persist.
The NRC's concern with the general performance at Dresden has been well
documented.
Most recently, procedural adherence problems resulted in the
April 5, 1995, Notice of Violation and Proposed Imposition of Civil Penalty -
$100,000 (EA 95-030), and this contaminated material control problem also
represents a failure to properly adhere to procedures.
However, in this case,
your thorough response to the initial discovery of four uncontrolled
contaminated items on April 3, 1995, led to your identification of the full
scope of this problem.
-9506210044 6~838~37
ADOCK
G
Michael J. Wallace
2
June 2, 1995
While this problem is of regulatory concern, the NRC acknowledges that the
actual consequence to safety was minimal due to the low contamination levels
on the uncontrolled items.
The NRC also recognizes your corrective actions
taken or planned to correct the process by which you control contaminated
material.
Initial actions included an extensive site survey during which the
movement of material was restricted. The planned actions include, but are not
limited to:
(1) minimizing satellite RPAs; (2) implementing rigid
restrictions on removing material from the power block; and (3) limiting the
background radiation level in which material is unconditionally released. It
now appears that you appre~iate the importance of improving your contaminated
material control program.
With an effective program in place and other recent
improvements in contamination control within the plant, you should be able to
concentrate on more safety significant radiation protection and material
condition problems at the facility.
In accordance with the "General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C,
enforcement action would normally be considered for this problem due to the
repetitive nature of the problem and programmatic concerns based on the high
number of uncontrolled contaminated items.
However, I have been authorized,
after consultation with the Director, Office of Enforcement, and the Deputy
Executive Director for Nuclear Reactor Regulation, Regional Operations and
Research, to exercise enforcement discretion in accordance with the guidance
set forth in Section VII.8.(6) of the Enforcement Policy, and not to issue
enforcement action in this case. The NRC notes that the decision to exercise
enforcement discretion in this case was significantly influenced by your
response to the problem after it was identified by routine surveys.
NRC
.
considers your extensive site-wide survey, undertaken to determine the scope
and magnitude of the problem, and the subsequent actions taken to prevent its
recurrence, to be indicative of your efforts to improve your staff's
responsiveness in the identification and correction of problems.
NRC is
cautiously optimistic that this type of positive response evidences a change
from your previous performance in addressing deficiencies. However, the NRC
emphasizes that any similar violations in the future could result in escalated
enforcement action.
No response to this letter is required.
In accordance with 10 CFR Part 2.790 of the NRC's "Rules of Practice," a copy
of this letter will be placed in
e NRC Public Document Room.
Docket Nos. 50-237; 50-249
Michael J. Wallace
3
cc:
J. S. Perry, Vice President, BWR Operations
T. Joyce, Site Vice President
J. C. Brons, Vice President,
Nuclear Support
T. Nauman, Station Manager Unit 1
E. D. Eenigenburg, Station Manager Unit 3
R. Bax, Station Manager Unit 2
P. Holland, Regulatory Assurance
Supervisor
D. Farrar, Nuclear Regulatory
Services Manager
Richard Hubbard
Nathan Schloss, Economist,
Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
June 2, 1995
)
Michael J. Wallace
4
DISTRIBUTION
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SECY
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JTaylor, EDO
JMilhoan, DEDR
JLieberman, OE
LChandler, OGC
JGoldberg, OGC
WRussell, NRR
RZimmerman, NRR
Enforcement Coordinators
RI, RII, RIV
Licensing Project Manager, NRR
OC/LFDCB
Resident Inspectors LaSalle
Dresden, Quad Cities
Flngram, GPA/PA
DWil 1 i ams, OIG
GCaputo, OI
EJordan, AEOD
OE:EA(2)
MSatorius, OE
Docket File
Public IE-01
NU DOCS
State of Illinois
RAO: RII I
SLO: RII I
PAO: RII I
IMS:RIII