ML17187B039
| ML17187B039 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/02/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17187B040 | List: |
| References | |
| 50-237-97-10, 50-249-97-10, NUDOCS 9707080052 | |
| Download: ML17187B039 (5) | |
See also: IR 05000237/1997010
Text
...
Mr .. J. S. Perry
Site Vice President
Dresden Station
Commonwealth Edison Company
6500 North Dresden Road
Morris, IL 60450
July 2,
1997
SUBJECT:
NRC INSPECTION REPORT 50-237;249/97010(DRS) AND
Dear Mr. Perry:
Qt..-0
On May 23, 1997, the NRC completed an inspection at your Dresden Generating Station,
Units 2 and 3 facility. The enclosed report presents the results of this inspection.
The inspection* was an examination of activities conducted under your license as they
relate to radiation safety and to compliance with the Commission's rules and regulations
and with the conditions of your license. The inspection consisted of a selective
examination of procedures and representative records, observations, and interviews with
personnel.
Performance in the radiation protection area has continued to improve. During the
refueling outage (D3R14) improved radiological controls, ALARA initiatives, and job
planning were instrumental in reducing station dose. In addition, initiatives such as the
"greeter" program were effective in improving radworker performance.
However, the NRC has determined that violations of NRC requirements occurred. These
violations are cited in the enclosed Notice of Violation (Notice) and the circumstances
surrounding them are described in detail in the subject inspection report. The violations
included: (1) the failure to provide individuals with an exit from a locked high radiation
area; (2) the failure to appropriately evaluate a work activity which resulted in an intake of
radioactive materials; and (3) the failure to follow the requirements of a training procedure.
The violations are of concern because, in these cases, workers were unfamiliar with
station requirements and radiological conditions, and were not provided with adequate
station oversight. The second violation was attributed to poor communications between
personnel, and is of particular concern since it should have been prevented by your
corrective actions for a workers intake due to communications problems during the
refueling outage in 1996.
The NRC has concluded. that information regarding the reason for tt-ie third violation, the
corrective actions taken and planned to correct the violation and prevent recurrence, is
already adequately addressed in the subject inspection report. Therefore, you are not
required to respond to the violation concerning failure to follow the requirements of a
training procedure discussed in this letter unless the description therein does not
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accurately reflect your corrective actions or your position. In that case, or if you choose
,
to provide additional information, you should fo!low the instructions specified in the / ... r: ) {p
enclosed Notice.
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9707080052 970702
ADOCK 05000237
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J. S. Perry
2
July 2, 1997
However, you are required to respond to the other violations discussed in this letter and
should follow the instruction specified in the enclosed Notice when preparing your
response. In your response to the second violation, please describe why your corrective
actions will be more successful in preventing future similar violations than those described
in your letter dated November 13, 1996. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
In accordance with 10 CFR 2. 790 of the Commission's regulations, a copy of this letter,
the enclosures, and your response to this letter will be placed in the NRC Public Document
Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
Original Signed by John A. Grobe
John A. Grobe, Acting Director
Division of Reactor Safety
Docket Nos. 50-237; 50-249
Enclosures:
2. Inspection Report 50-237 /9701 O(DRS); 50-249/9701 O(DRS)
cc w/encls:
T. J. Maiman, Senior Vice President, Nuclear Operations Division
D. A. Sager, Vice President, Generation Support
Distribution:
H. W. Keiser, Chief Nuclear Operating Officer
T. Nauman, Station Manager, Unit 1
M. Heffley, Station Manager, Units 2 and 3
F. Spangenberg, Regulatory Assurance Supervisor
I. Johnson, Acting Nuclear Regulatory Services Manager
Document Control Desk - Licensing
Richard Hubbard
Nathan Schloss, Economist, Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
Docket File w/encls
PUBLIC IE-01 w/encls
OC/LFDCB w/encls
DRP w/encls
SRls, Dre~den, LaSalle,
Quad Cities w/encls
C. Pederson, Riii w/encls
LPM, NRR w/encls
Riii Enf. Coordinator w/encls
R. A. Capra, NRR w/encls
TSS w/encls
CAA 1 w/encls
DRS w/encls
Riii PRR w/encls
DOCUMENT NAME:
OFFICE
NAME
Paul I *
DATE*
6/
197
A. B. Beach, Riii w/encls
J. L. Caldwell, Riii w/encls
G:\\DRS\\DRE9701 O.DRS
(SEE PREVIOUS CONCURRENCE)
Shear
Kro
6/ 197
6/ 197
J. $. Perry
2
However, you are required to respond to the other violations discussed in this letter and
should follow the instruction specified in the enclosed Notice when preparing your
response. The NRC will use your response, in part, to determine whether further
enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter,
the enclosures, and your response to this letter will be placed in the NRC Public Document
Room.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
John Grobe, Acting Director
Division of Reactor Safety
Docket Nos. 50-237; 50-249
Enclosures:
2. Inspection Report Nos.
50-237 /249-9701 O(DRS)
50-249/9701 O(DRS)
cc w/encls:
T. J. Maiman, Senior Vice President, Nuclear Operations Division
D. A. Sager, Vice President, Generation Support
H. W. Keiser, Chief Nuclear Operating Officer
T. Nauman, Station Manager, Unit 1
M. Heffley, Station Manager, Units 2 and 3
F. Spangenberg, Regulatory Assurance Supervisor
I. Johnson, Acting Nuclear Regulatory Services Manager
Document Control Desk - Licensing
Richard Hubbard
Nathan Schloss, Economist, Office of the Attorney General
State Liaison Officer
Chairman, Illinois Commerce Commission
Distribution:
Docket File w/encls
PUBLIC IE-01 w/encls
OC/LFDCB w/encls
DRP w/encls
DRS w/encls
Rll I PRR w /ends
SRls, Dresden, LaSalle,
Quad Cities w /encls
C. Pederson, Riii w/encls
LPM, NRR w/encls
A. B. Beach, Riii w/encls
J. L. Caldwell, Riii w/encls
DOCUMENT NAME: G:\\DRS\\DRE97010.DRS
Riii Enf. Coordinator w/encls
R. A. Capra, NRR w/encls
TSS w/encls
CAA 1 w /encls
To receive a copy of this document, Indicate In the box *c* =Copy w/o attach/encl "E" =Copy w/attach/encl "N" =No copy
II !WE I mi;~i&Viil ii;~!9f
I i~~l197s
II
Commonwealth Edison Company
Dresden Station, Units 2 and 3
Docket Nos. 50-237; 50-249
During an NRC inspection conducted from May 19-23, 1997, violations of NRC
requirements were identified. In accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR 20.1601 (d) requires that the licensee establish the access controls for high
radiation areas in a way that does not prevent individuals from leaving the High
Radiation Area.
Contrary to the above, on April 21, 1997, the licensee failed to provide individuals
an exit from a Locked High Radiation Area in the anteroom of the Unit 2 drywell.
This is a Severity Level IV Violation (Supplement IV).
B.
10 CFR 20.1501 requires each licensee make or cause to be made surveys that
may be necessary for the licensee to comply with the regulations in Part 20 and
that are reasonable under the circumstance to evaluate the extent of radiation
levels, concentrations or quantities of radioactive materials, and the potential
radiological hazards that could be present.
Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological
conditions and potential hazards incident to the production, use, transfer, release,
disposal, or presence of radioactive material or other sources of radiation.
Contrary to the above, as of April 21, 1997, the licensee did not make surveys to
assure compliance with 10 CFR 20.1201 (a)(i), which limits the total effective dose
equivalent to 5 rems per year. Specifically, no evaluation was made to determine
- the radiological conditions before initiating a decontamination of highly
contaminated areas in the Unit 2 torus basement.
This is a Severity Level IV violation (Supplement IV).
C.
Technical Specification 6.2.A required, in part, that written procedures be
established and implemented covering the activities referenced in Regulatory Guide
(RG) 1.33, Appendix A. The activities listed in RG 1.33 include procedure
adherence.
OAP 09-13, Revision 6, "Procedural Adherence," required, in p~rt, that procedures
be adhered to during the course of activities.
OAP 08-01, Revision 6, "Training Department Organization," stated, in part, that
Training Department Instructions are procedures that govern the analysis, design,
development, implementation, evaluation, and administration of training programs,
and that training programs are to be implemented in accordance with approved
Training Department Instructions .
9707080055 970702
ADOCK 05000237
Q
2
Training Department lnstruction-206, Revision 6, "Continuing Radiation Protection
Technician Training" requires in part, that evaluations of task performance must be
conducted in a consistent and objective manner in order to ensure that the required
knowledge and skills have been acquired by the trainees.
Contrary to the above, (from October 1995 through January 1996)the initial
training conducted for the operation of the PASSPORT Personal Alarm, did not
include evaluations of trainee task performance as required by TDl-206.
This is a Severity Level IV violation (Supplement IV).
For Violation Number 3, the NRC has concluded that information regarding the reason for
the violation, the corrective actions taken and planned to correct the violation and prevent
and prevent recurrence and the date when full compliance was achieved is already
adequately addressed on the docket in Inspection Report Nos. 50-237 /97010 and 50-
249/97010. However, you are required to submit a written statement of explanation
pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your
corrective actions or your position. In that case, or if you choose to respond, clearly mark
your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a
copy to the Regional Administrator, Regi~n Ill, and a copy to the NRC Resident Inspector
at the facility that is the subject of this Notice, within 30 days of the date of the letter
transmitting this Notice of Violation (Notice).
For Violation Nos. 1 and 2, 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 Ill, and a copy to the NRC Resident Inspector
at the facility that is the subject of this Notice, within 30 days of the date of the letter
transmitting the 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 results achieved, (3) the corrective steps that will be taken
to avoid further violations, and (4) the date when full compliance will be achieved. If an
adequate reply is not received within the time specified in the Notice, an order may be
issued to show cause why the license should not be modified, suspended, or revoked, or
why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
Because your response will be placed in the NRC Public Document Room (PDR), to the
extent possible, it should not include any personal privacy, proprietary, or safeguards
information so that it can be placed in the PDR without redaction. However, if you find it
necessary to include such information, you should clearly indicate the specific information
that you desire not to be placed in the PDR, and provide the legal basis to support your
request for withholding the information from the public.
Dated at Lisle, IL
this 2nd day of July 1 997