ML20058F603
| ML20058F603 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/03/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312080194 | |
| Download: ML20058F603 (4) | |
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c. Commonwe:lth Edison O'
1400 Opus Place
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Downers Grove. Ilknois 60515 I
December 3,1993 l
U.S. Nuclear Regulatory Commission 1
Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
LaSalle County Station Units 1 and 2 i
Response to Notice of Violation l
Inspection Report Nos. 50-373/93023; 50-374/93023 l
NRC Docket Numbers 50-373 and 50-374 l
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Reference:
B. Clayton letter to Warren P. Murphy,
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Dated November 3,1993, Transmitting l
NRC inspection Report 50-373/93023; 50-374/93023 I
Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which
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was transmitted with the referenced letter and NRC Inspection Report. The violation regarded a failure to follow LaSalle Radiation Control Procedures. Hoses and an electrical cord which breached
.f contaminated area boundaries were not taped as required to avoid the spread of contamination from the r
controlled area.
pg if there are any questions or comments concerning this letter, please refer them to JoEllen Burns, Regulatory Performance Administrator at (708) 663-7285, Respectfully, l
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D.L. Farrar i
Nuclear Regulatory Services Manager
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cc:
J. B. Martin, Regional Administrator, Rlli J. L. Kennedy, Project Manager, NRR D. Hills, Senior Resident inspector, LaSalle i
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PDR ADOCK 05000373 E<
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I ATTACHMENT RESPONSE TO NOTICE OF VIOLATION l
NRC INSPECTION REPORT 50-373/93023; 50-374/93023 f
f VIOLATION: 374/93023-01
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During an NRC inspection conducted on August 27 through October 15,1993, a violation of NRC requirements was identified. In accordance with the
- General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
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LaSailo Technical Specification 6.2.B states, in part,
- Radiation control procedures shall be maintained, made available to all station personnel, and adhered to.*
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LaSalle Radiation Protection Procedure (LRP)-1490-1, ' Construction of Radiological Control Areas and l
Stop Otf Pad. Areas
- step F.2.d. states, in part,
- Tape hoses, electrical cords, etc.., that breach a contaminated boundary to the floor or wall with radiation tape where they exit the area. This will avoid j
the possibility of a contaminated section being pulled into the clean area.*
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Contrary to the above, hoses and an o'ectrical cord which breached contaminated area boundaries were -
not taped as required to avoid the spread of contamination from the controlled area. This condition was j
observed on September 21,1993 in the area of the reactor recirculation low frequency motor generator j
set on 786 foot elevation of the Unit 2 reactor building.
l This is a Severity Level IV violation (Supplement 1).
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' REASON FOR VIOLATION:
Commonwealth Edison Company agrees that procedure LRP-1490-1, ' Construction of Radiologica!
Control Areas and Step Off Pad Areas *, was not followed as written. Procedure LRP-1490-1,
- Construction of Radiological Control Areas and Step Off Pad Areas", states that ' Hoses, electrical
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cords, etc., that breac'h a contaminated boundary shall be taped or tied securely where they exit the j
f area. This will avoid the possibihty of a contaminated section being pulled into the clean area.* The purpose of this step is to reduce the possibility of spreading contamination by pulling a contaminated 7
hose or cord into a clean area. The apparent cause for the failure to follow the procedure has been a i
lack of f amilianty with it by personnel who use hoses and cords. The procedure is used by personnel
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who " set up* controlled areas, and is not a " mainstream
- procedure for general radiation worker use.
j As identified in the inspection Report, a similar condition was noted previously and was the subject of a previous violation (50-373/93019-02). LaSalie was taking correctivo actions in addressing that violation j
at the time the second violation was identified. The time between occurrences of the two violations was not sufficient for LaSalle's previous corrective actions to be effective.
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l CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
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4 A tour of a majonty of Unit 1 and Unit 2 Turbine, Reactor and Auxiliary Buildings was conducted on October _5,1993, to identify and correct similar concerns. The item identified in the violation and any additional problems found have been corrected. No further violations of this kind have been identified.
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The Corrective Actions fhnager (CAM) program, discussed in LaSalle's response to the previous violation (50-373/93019-02) has been effective in reducing some problems in the plant such as poor radworker practices and housekeeping concerns.
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i CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
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LaSailo has surveyed a number of other stations in an effort to identify a better mechanism for j
controlkng the 'Ase of hoses throughout the plant. Based on the results of this survey, LaSalle will l
establish a program by fAarch 4,1994, that will be utilized for controlling the use of hoses in the plant.
In LaSalle's response to the first violation, we provided a number of actions that were being taken to avoid further occurrences of this event. These actions included training of all workers and personnel
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who would enter the Radiologically Controlled Area (RCA) at LaSalle County Station (General
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Information Notice 93-58). This training is expected to be completed by Oecember 31,1993.
Additionally, Generalinformation Notice 93-57 was issued to train auditors and controlling departments j
on management expectations of verification of plant radiation worker activities. Th a training is expected to be completed by December 31,1993, j
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LAP-900-8, ' Hose Identification Procedure *, was revised on October 30,1993, to include the j
appropriate controls on hoses which cross contaminated / clean area boundaries.
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Other corrective actions identified in LaSalle's response to the previous violation (50-373/93019-02) are 4
on schedule for completion.
l DATE WHEN FULL COfAPLIANCE WILL BE ACHIEVED:
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Full compliance was achieved immediately on September 21,1993, when the workers presen! T the job site corrected the problem.
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