ML19345B659
| ML19345B659 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/30/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19345B657 | List: |
| References | |
| NUDOCS 8012020312 | |
| Download: ML19345B659 (3) | |
Text
-s Commonwealth Edison one First Nabonal Plaza Chicago Illino s 4
Address Reply to-Post Office Box 767 Chicago. lilinois 60690 October 30, 1980 Mr. James G.
Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Dresden Station Units 1, 2, and 3 Response to IE Inspection Report Nos. 50-10/80-14, 50-237/80-17, and 50-249/80-21 NRC Docket Nos. 50-10/237/249 Peference (a):
R.
F.
Heishman letter to C. Reed dated October 8, 1980.
Dear Mr. Keppler:
The following is in response to an inspection conducted by Messrs.
J.
L.
Barker, T.
M.
- Tongue, M.
Jordan, and F. Reimann conducted from August 3 to September 6, 1980, of activities at Dresden Nuclear Power Station.
Reference (a) indicated that one item appeared to be in noncompliance with NRC requirements.
Attachment A to this letter contains Commonwealth Edison Company's response to the identified item of noricompliance.
Please address any questions concerning this matter to this office.
Very tru.'y yours, a
M S. Abel Director of Nuclear Licensing Attachment cc:
RIII Inspector, Dresden 8012020 M b
.](Qy 11980
1 e
f NRC Docket Nos. 50-10/237/249 j
ATTACHMENT A i
Commonwealth Edison Attachment j
Response To Notice Of Violation 1
The item of non-compliance identified in Appendix A of the NRC letter dated October 8, 1980, is responded to in the following paragraphs:
1 1.
Te.hnical Specification 6.2.8 states, " Radiation control procedures shall be maintained, made available to all station i
personnel, ano adhered to.
These procedures shall show l
permissible radiation exposure and shall be consistent with the J
requirements of 10 CFR 20.
This radiation protection program shall be organized to meet the requirements of 10 CFR 20."
The Dresden Radiation Protection Manual states, in part, "When radiation work involves raising radioactive materials in the 4
pools above established radiation levels, uncovering contaminated material, valving or opening process lines, or i
disassembling _ radioactive equipment, Radiation Protection shall be informed before the fact so that a proper evaluation of the radiological consequences may be made.
Contrary to the above, on August 12, 1980, the resident inspectors observed several licensee personnel working on a contaminated CRD pump without wearing adeouate protective clothing and without the work area being properly posted.
Aoditionally, the inspectors determined that Radiation i
Protection had not been notified to perform an evaluation of the j
radiological consequences associated with this job.
Further i
review by the inspectors disclosed that the Dresden outage or l
work request forms do not contain a requirement for workers to obtain Radiation Protection concurrence, when required, for a l
specific job.
Corrective Action Taken and Results Achieved The immediate action was an evaluation of the potential radiological consequences to workers who were performing maintenance on the CRD pump.
In our judgment the levels of contamination would j
4 have involved insignificant exposure; therefore, no further immediate corrective measures were taken.
To prevent recurrence of this type of deviation, operating and maintenance practices have been evaluated to determine proper requirements for notification of Radiation Protection.
On the basis of this evaluation it is our judgement that only the mechanical maintenance work _ request practices are subject to this type of i
1
e deviation.
Therefore, we have developed specific corrective i
measures to prevent future deviation of this type associated with mechanicrl maintenancc.
We have now developed a new stamp with a caution which is 3
prominently displayed on appropriate work requests by an experienced I
mechanical maintenance department work analyst.
The work analyst stamps this caution on all appropriate work requests as the work j
request is being logged into the mechanical department files and i
prior to the work request being released to a foreman.
The 2" X 3" J
stamp states, " Radioactive Equipment
-Contact Radiation Protection j
Prior to Disassembly or Opening Process Line to Arrange for Survey.
Currently we have decided to have only the Mechanical Maintenance Group stamp their work requests since the major portion of the work done by the instrument and electrical maintenance groups does not involve opening of potentially contaminated systems or components.
Date When Full Compliar.(e Will Be Achieved The use of the caution stamp has begun, and we feel that full cortoliance has been achieved.
To further emphasize these corrective measures, they will be discussed at the next meeting of the mechanical maintenance management staff.
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