ML20057F759

Responds to NRC Ltr Re Violations Noted in Insp Rept 50-373/93-19 & 50-374/93-19.Corrective Actions:Generated General Info Notice

ML20057F759
Person / Time
Site:	LaSalle
Issue date:	10/14/1993
From:	Farrar D COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9310190080
Download: ML20057F759 (4)

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, [1 /\\ - Ccmmsnwscith Edison 1400 Opus Place

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Downers Grove, !!!inois 60515 NN.

s October 14, 1993 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Attention: Document ContIol Desk

Subject:

LaSalle County Station Units 1 and 2 Response to 11otice of Violation Inspection Report Nos. 50-373/93019; 50-374/93019 NRC Docket Nuders 50-373 and 50-374

Reference:

E.G.

Greenman letter to L. O. DelGeorge, Dated September 17, 1993, Transmitting NRC Inspection Report 50-373/93019, 50-374/93019 Enclosed is Commonwealth Edison Company's response to Notice of Violations (NOV) which were transmitted with the referenced letter and Inspection Report.

The violation regarded a failure to follow a procedure requiring hoses and electrical cords to be taped down when they breach a i

contaminated area L>oundary, i

If there are any questions or comments concerning this letter, please refer them to JoEllen Burns, Regulatory Performance Administrator at (708)663-7285.

Resp <:tfi11y, h

D. L. Farrar Nuclear Regulatory Services Manager cc:

J.B. Martin, Regional Administrator, RIII J.L. Kennedy, Project Manager, NRR D. Hills, Senior Resident Inspector, LaSalle a

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION URC INSPECTION REPORT 50-373/93019; 50-374/93019

-l VIOLATION: 373(374)/93019-02.

During an NRC inspection conducted on July 13 through August 27, 1993, a violation of NRC requirements was identified.

In accordance with the

" General Statement.of Policy and Procedure for intC Enforcement Action,"

10 CFR Part 2, Appendix C, the violation is listed below:

LaSalle Technical Specification 6.2.B states, in part, " Radiation f

control procedures shall be maintained, made available to all station personnel,-and adhered to".

j LaSalle Radiation Protection Procedure-(LRP)-1490-1, " Construction of-Radiological Control Areas and Step Off Pad Areas", step F.2.d,

states, in part, " hoses, electrical cords,1etc.., that breach contaminated area boundaries.shall be taped to avoid the' spread of contamination from the controlled area".

Contrary to the above, hoses and electrical cords which breached contaminated area boundaries were not t aped as required to avoid the 1

spread of contamination from the contic11ed area.

These conditions were l

observed on August 19, 1993 in the area of the 2D. heater drain room and j

the 1B turbine driven reactor. feed pump (TDRFP) room and on August 26,.

' i 1993 in the 2A TDRFP room.

j This -is a Severity' Level V ' violation (Supplement IV).

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ATTACHMENT-(Continued)

RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93019; 50-374/93C19 REASON FOR VIOLATION:

Commonwealth Edison Company agrees that procedure LRP-1490-1,

' Construction of Radiological Control Areas and Step Off pad Areas", was i

not followed as written.

Procedure LRP-1490-1, " Construction of Radiological Control Areas and Step Off Pad Areas", clearly stated that

. hosec, electrical cords, etc., that breach a contaminated boundary shall be taped to avoid the spread of contamination from the controlled area The purpose of this step was to reduce the i

possibility of spreading contamination by pulling a contaminated hose or cord into a clean area.

The apparent cause for the failure to follow the procedure has been a lack of familiarity with it by personnel who use hosec and cords. The procedure is used by personnel who " set up" i

controlled areas, and is not a " mainstream" procedure for general r

radiation worker use.

i CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED

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A tour of a majority of Unit 1 and Unit 2 7trbine, Reactor and Auxiliary Buildings was conducted on October 5, 1993, to identify and correct l

similar concerns. Those items identified in the violation and any additional problems found have been corrected.

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CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS A General Information Notice (GIN) was generated for all workers and l

l personnel who would enter the Radiologically Controlled Area (RCA) at LaSalle County Station. The GIN reinforced management. expectations in regards to the importance of preventing the spread of contamination in j

the plant, and placed emphasis on the need to secure all materials that pass through a Radiological Boundary so as to preclude the inadvertent j

spread of contamination, An additional GIN was sent to auditing and controlling departments.

l This GIN reinforces management expectations of auditors and controlling departments in regards to verification of plant radiation worker-activities.

I For the remainder of the Unit 2 refuel outage, L2R05, dedicated i

personnel have been assigned by the Station Manager to conduct plant walkdowns, observing radiological practices and resolving problems.

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ATTACHMENT (Continued) r RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93019; 50-374/93019

.LaSalle has also implemented a management overview program (Corrective-

-j Action Manager) for the remainder of the Unit 2 refuel outage, L2R05.

This program, Corrective Actions Manager (CAM), consists of multiple teams of managers in the plant roving, inspecting, interacting, and i

communicating with the workers on expectations and feedback on their concerns. Additionally, a special multi-disciplined repair team will be available to resolve minor maintenance problems.

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I LaSalle will review procedure LRP-1490-1, " Construction of Radiological Control Areas and Step Off Pad Areas", in depth to determine items such as the issue of taping down hoses and electrical cords, that would be better placed in more appropriate procedures or guidelines for radiation worker usage.

The following existing guidelines were reviewed for accuracy:

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Page 13 of the LaSalle County Station Information Handbook j

contained information that states: "Any hose that crosses'a radiological boundary shall be secured at the boundary". A l

similar note was found in the L2R05 Outage Information Book, however, this was not formally in use until the start of L2R05.

These information/ outage books will be revised to.contain information on both electrical cords and hoses as they pertain to radiological controls usage, prior to the Unit 1 spring refuel outage, L1R06.

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LAP-900-8, " Hose Identification Procedure", has been-revised to

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include the appropriate controls on hoses penetrating.

i radiologically controlled areas.

j DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on August 30, 1993 when the hose problems f

identified in this violation were corrected.

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