ML19345B186
| ML19345B186 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/21/1980 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML19345B187 | List: |
| References | |
| NUDOCS 8011260271 | |
| Download: ML19345B186 (6) | |
See also: IR 05000254/1980020
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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799 ROOSEVELT ROAD
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GLEN ELLYN. ILLINOls So137
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OCT 2 1 1980
Docket No. 50-254
Docket No. 50-265
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Commonwealth Edis m Company
ATTN:
Mr. James J. O'Connor
President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
Subject: Health Physics Appraisal
The h3C has identified a need for licensees to strengthen the health
physics programs at nuclear power plants and has undertaken a signif-
icant effort to ensure that action is taken in this regard. As a
first step in this effort, the Office of Inspection and Enforcement is
conducting special team appraisals of the health physics programs, in-
cluding the health physics aspects of radioactive waste management and
onsite emergency preparedness, at all operating power reactor sites.
The objectives of these appraisals are to evaluate the overall adequacy
and effectiveness of the health physics program at each site and to
identify areas of weakness that need to be strengthened. We will use
the findingt, from these appraisals as a basis not only for requesting
individual licensee action to correct deficiencies and effect improve-
ments but'also to improve h7C requirements and guidance. This effort
was identified to you in a letter dated Jane ry 22, 1980, from
Mr. Victor Stello, Jr., Director, NRC Office of Inspection and Enforcement.
During the period May 5-16, 1980, the hTC conducted the special appraisal
of the health physics program at the Quad-Cities Nudear Power Station.
Areas examined during this appraisal are described in the enclosed report
(50-254/80-20; 50-265/80-22). Within these areas, the appraisal team
reviewed selected procedures and representative records, observed work
practices, interviewed personnel, and performed independent measurements.
We request that you carefully review the findings of this report for
consideration in improving your health physics program.
Findings of this appraisal indicate that several significant weaknesses
exist in your health physics program. These include, among others,
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Commonwealth Edison Company
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training, exposure control, ALARA, access and contamination control,
instruments, and facilities. While we believe the identified weaknesses
require correction to enable you to perform well in normal and abnormal
conditions, your present health physics program is considered adequate
for continued operation while achieving acceptable corrective action.
We recognize that an explicit regulatory requirement pertaining to each
significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for
the health and safety of workers and the public, you are requested to
submit a written statement within twenty (20) days or your receipt of
this letter, describing your corrective action for each significant weak-
ness identified in Appendix A, including:
(1) steps which have been taken;
(2) steps which will be taken; and (3) a schedule for completion of action.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10,
Code of Federal Regulations.
During this appraisal, it was also found that certain of your activities do
not appear to have been conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation enclosed as Appendix B.
The items
of noncompliance in Appendix B have been categorized into the levels of
severity as described in our Criteria for Enforcement Action dated December
13, 1974. Section 2.201 of Part 2, Title 10, Code of Federal Regulations,
requires you to submit to this office, within twenty (20) days of your
receipt of this notice, a written statement or explanation in reply, in-
cluding:
(1) corrective steps which have been taken and the results achieved;
(2) corrective steps which will be taken to avoid further items of non-
compliance; and (3) the date when full compliance will be achieved.
You should be aware that the next step in the NRC effort to strengthen
health physics programs at nuclear power plants will be a requirement
by the Office of Nuclear Reactor Regulation (NRR) that each licensee develop,
submit to the NRC for approval, and implement a Radiation Protection Plan.
Each licensee will be expected to include in the Radiation Protection Plan
sufficient measures to provide lasting corrective action for significant
weaknesses identified during the special appraisal of the current health
physics program. Guidance for the development of this plan will incor-
porate pertinent findings from all special appraisals and will be issued
by NRR in the fall of this year.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and the en-
closures will be placed in the NRC's Public Document Room.
If this material
contains any information that you believe to be proprietary, it is
necessary that you make a written application within 20 days to this
office to withhold such information from public disclosure.
Any such
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Commonwealth Edison Company
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DCT 21 1983
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applicatior: must be acccapanied by an affidavit, executed by the owner
of the in ormation, which identifies the document or part sought to be
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withheld and which contains a statement of reasons which adcresses with
specificity the items which will be considered by the Commission as listed
in Subparagraph (B)(4) of Section 2.790.
The information sought to be with-
held shall be incorporated as far as possible into a separate part of the
If we do not hear from you in this regard within the specif!.ed
period, this letter and the enclosures will be placed in the Public Doct.-
ment Room,
k'e will gladly discuss any questions you have concerning this inspection.
Sincerely,
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James G. Keppler
Director
Enclo uses:
1.
Appendix A, Significant
Appraisal Findings
2.
Appendix B, Notice of
Violation
3.
IE Inspection Report
No. 50-254/80-20 and
No. 50-265/80-22
cc w/encls:
Mr. J. S. Abel, Director
of Nuclear Licensing
Mr. N. Kalivianakis,
Plant Superintendent
Central Files
Reproduction Unit NRC 20b
Resident Inspector, RIII
Local PDR
Mr. Dean Hansell, Office of
Assistant Attorney General
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Appendix A
SIGNIFICANT APPRAISAL FINDINGS
Cocoonwealth Edison Company
Docket Nos. 50-254; 50-265
Based on the Health Physics Appraisal performed May 5-16, 1980, the following
items appear to require corrective action.
(Section references are to the
details portion of the enclosed appraisal report.)
1.
Training
a.
By failing to establish the relationship between low-level radia-
tion effects and the various health physics practices for radi. tion
and contamination control, insufficient motivation to follow these
procedures is provided in general employee training. A contribut-
ing factor appears to be overemphasis of acute radiation effects
relative to low-level effects. Related weaknesses appear to exist
in protective clothing training for contractors and in contamination
control training for maintenance personnel.
(Sectior- 3.4, 3.5, 3.6,
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5.6, and 9.7).
b.
Recent (1979) Radi. :ca Chemistry Technician (RCT) training was
allowed to slip to three days for some RCT's, indicating insuffi-
cient priority given to this program. Retraining also shoald
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emphasize better understanding of basic health physics concepts
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and practices.
(Section 3.5)
RCT's were not traine.d in interim emergency procedures, because
c.
these procedures would be performed by Radiation Chemistry (R/C)
management during accident conditions. The assumption that R/C
management would always be able to respond promptly may be un-
realistic.
(Section 11.2)
2.
Exposure Control and ALARA
Inadequate control over respirator issuance on the backshifts permits
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unauthorized respirator use. Failure to require their return and the
entering of duration-of-wear information undermines exposure control
based on MPC-hours.
(Section 4.4 and 5.5)
b.
Approximately 5000 man-rems are projected for the year 1980. Signif-
icant dose savings should be achievable by a strong, comprehensive
ALARA program.
(Section 10)
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Appendix A
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3.
Access Controls
High radiation area (HRA) access controls do not ensure that entries
are made with adequate knowledge of dose rate or that overlong entries
will be promptly recognized. Controls on contractor work in the torus
may be insufficient to prevent unexpected exposures, because of field
variations between different creas of this extensive high radiation area.
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(Sections 5.3 and 6.2)
4.
Contamination Controls
Several weaknesses were noted with respect to contamination control:
a.
Movement of contaainated tools and equipment from the controlled
area for maintensuce work or surveys.
(Sections 5.6 and 9.7)
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b.
Reduced surveillance in the maintenance shop and laundry.
(Sections 5.6 and 9.8)
c.
Questionable protective clothing requirements in portions of
radwaste.
(Sections 5.6 and 8.4)
d.
Proliferation and prolonged duration of temporary decontamination
sites.
(d etion 9.7)
e.
Widespread occurrence of contaminated trash.
(Section 5.6)
f.
Inappropriate contamination control practices in the laundry and
elsewhere.
(Sections 5.6 and 9.8)
5.
Instruments
a.
There is an insufficient supply of portable survey instruments with
adequate range (1000 R/hr or greater) for use during a serious
accident. There is also inadequate assurance of ready availability
of portable survey instruments, owing to lack of secure storage space
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and weak instrument accountability.
(Sections 7.2, 7.3, and 9.6)
b.
Area monitor charts are not legible enough to permit after-the-fact
unraveling of an event with any confidence. Date and time annota-
tions made by operator and reviewers are also frequently deficient.
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(Section 7.6)
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c.
Excessive chimney sample line fittings makes representative sampling
questionable.
It also indicates piping changes made without know-
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ledgeable review and approval.
/Section 7.7)
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Appendix A
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6.
Facilities
High activity sample handling capabilities in the hot laboratory
a.
are suspect, owing to lack of shielded work space in hoods and
on bench tops.
(Section 9.2)
b.
The combined. personal decontamination and medical treatment facility
is too small and inadequately equipped, and it inappropriately shares-
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space with the whole body counter.
(Section 9.3)
Background fluctuations in the current whole body counter location
c.
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are excessive. Its location in the same room with the personal
decontamination facility is inappropriate.
(Section 9.4)
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