ML20058N429
| ML20058N429 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/17/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9312210401 | |
| Download: ML20058N429 (8) | |
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Commonwealth Edison e
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1400 Opus Placa Downers Grove, Illinois 60515 December'17,1993
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i U.S. Nuclear Regulatory Commission I
Washington, D.C. 20555 i
Attention:
Document Control Desk i
Subject:
LaSalle County Station Units 1 and 2 Response to Notice of Violation NRC Inspection Report 50-373/93027; 50-374/93027 i
NRC Docket Numbers 50-373 and 50-374 l
Reference:
W. L. Axelson letter to M. J. Wallace, Dated November 18,1993, Transmitting -
NRC Inspection Report 50-373/93027; 50-374/93027 Enclosed is Commonwealth Edison Company's response to the Notice of '
l Violation which was transmitted with the referenced letter and NRC Inspection Report. The violation regarded a failure to follow radiation protection procedures, and perform adequate surveys.
If there are any questions or comments concerning this letter, please refer them to JoEllen Burns, Regulatory Performance Administrator at (708) 663-7285.-
l Respectfully,.
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D..L. Farrar-l Nuclear Regulatory Services Manager cc:
J. B. Martin, Regional Administrator, RIII -
i A. Gody Jr., Project Manager, NRR, MS 13DI, 1
D. Hills, Senior Resident Inspector, LaSalle J. E. Lockwood, Regulatory Assurance Supervisor, LaSalle County Station i
December 17,1993 i
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93027; 50-374/93027 VIOLATION:
During an NRC inspection conducted on September 27 through October 1; October 6 through 8; October 18 through 20; and October 25 through 29,1993 violations of NRC requirements were identified. In accordance with the " General Statement of Pa y and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, c
the violation is listed below:
1.
Technical Specification 6.2.B, states, in part, that radiation control procedures shall be maintained and adhered to.
LaSalle Administrative Procedure 900-26, " Unconditional Release Program",
Step F.1.a.2, states, in part, that all solid materials (not carried on a worker's body) that have been in a controlled area, including all items taken into and out of contaminated areas, must be surveyed for removable and fixed radioactive materials.
LaSalle Administrative Procedure 100-22, " Radiation Work Permit Program", Step F.2.e.4, states, in part, that it is the responsibility of the individual worker to comply with the requirements of the Radiation Work Permit and all associated documents.
Contrary to the above, radiation protection procedures were not adhered to, as evidenced by the following examples:
a.
Radioactive material was discovered outside the radiologically controlled area during the months of July, August, and September 1993 without the appropriate radiation protection survey releases required by LAP-900-26.
b.
Reactor building ventilation filters were transferred from a controlled area to an uncontrolled area on October 14,1993, by mechanical maintenance staff without having the required surveys before transferring the filters as required by LAP-900-26.
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A member of station management became contaminated on October c.
i 13,1993, after removing contaminated material from a contaminated area without having it appropriately surveyed by radiation protection as required by LAP-900-26.
d.
Workers cutting into a process line on October 14,1993, did not comply with the requirements of the radiation work permit under which they were working as required by LAP 100-22. Specifically, the workers did not have radiation protection personnel present to verify dose rates and contamination levels when the process line was breached.
This is a Severity Level IV violation (Supplement IV).
2.
10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of 10 CFR 20 and which are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, during concurrent work activities on the refuel floor and under the reactor vessel on September 29,1993, the licensee failed to perform adequate surveys to evaluate the extent of radiation hazards incident to workers under the reactor vessel.
This is a Severity Level IV violation (Supplement IT9.
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A'ITACHMENT (Continued)
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93027; 50-374/93027 REASON FOR VIOLATION:
1.
- a. We agree we have been experiencing a number ofincidents in which radioactive material was discovered outside the radiologically controlled area (RCA) and this is a violation of radiation protection procedures. These occurrences led us to perform a detailed root cause analysis with the help of a consultant firm expert in root cause analysis. From this evaluation two contributing factors were identified to be the cause (1) the setup of the (RCA) in that there was no single access control point, and (2) management controls of the process were lacking.
- b. We agree that the reactor building ventilation filters were transferred from a controlled area to an uncontrolled area on October 14,1993, by mechanical maintenance staff without having the required surveys. This was a violation of radiation protection procedures. We believe this was due to a break down in the communications between a Radiation Protection Technician (RPT) and the maintenance crew.
- c. We agree a member of station management became contaminated on October 13,1993, after removing contaminated material from a contaminated area without having it appropriately surveyed by Radiation Protection as required by LAP-900-26. This was a violation of radiation protection procedures. We believe the reason for this was the result of poor work practice on the part of the management person.
- d. We agree the workers cutting into a process line on October 14,1993, did not comply with the requirements of the radiation work permit under which they were working. Specifically, the workers did not have radiation protection personnel present to verify dose rates and contamination levels when the process line was breached. This was a violation of radiation protection procedures. We believe this was due to inadequate understanding of the job scope on the worker's part.
Overall the above violations indicate a weakness in procedure adherence.
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i ATTACHMENT (Continued)
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RESPONSE TO NOTICE OF VIOLATION l
NRC INSPECTION REPORT-50-373/93027; 50-374/93027.'
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We agree that on September 29,1993, during concurrent work activities on :
l the refuel floor and under the reactor vessel we failed to perform adequate j
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surveys to evaluate the extent of radiation hazards incident to workers under the reactor vessel.
We believe that both Radiation Protection (RP) and Fuel Handlers (FH) were lacking in knowledge of each others job activities. They were not aware of how each others actions could and did effect the results of the -
worker's environment. There were some communication problems between fuel handlers and Radiation Protection Technicians (RPTs).
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ATTACHMENT (Continued)
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93027; 50-374/93027 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:
1.
On each occasion that radioactive material was discovered outside the radiologically controlled area without the appropriate radiation protection
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survey releases required the condition was rectified immediately.
We have had disciplinary discussions with those involved with the reactor building filter transfer, as a positive retribution measure we will be assigning the maintenance personnel to the Radiation Protection (RP)
Department for a week, and the Radiation Protection Technician (RPT) to the Maintenance Department for a week. The maintenance crew was required to attend initial NGET training.
A letter was placed in the station management person's file. The station management person was required to repeat the protective clothing section of NGET training prior to entering the RCA. In addition the person wrote a letter which was published in the station's daily STAR newsletter. The letter indicated the error that was made and what the correct actions should have been.
The workers involved with the process line were instructed at a safety meeting on October 22,1993, on the importance of having a RPT in attendance when cutting into an unknown radiological condition and to clearly communicate to the RPTs what activity is to take place.
2.
We immediately performed an adequate survey under the reactor vessel.
l We reviewed the procedure with the fuel handlers during the pre-job l
briefing and established the drywell RPT as the focal point for any drywell 1
activities or activities with i he potential to effect the drywell.
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ATTACHMENT (Continued)
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93027; 50-374/93027 l
CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER j
VIOLATIONS:
I 1.
We commissioned a Business Development Team to review overall station performance, including the Radiation Protection (RP) area, using a methodology that was patterned after the NRC's Diagnostic Evaluation module. The team was made up of 27 individuals with 16 members coming i
l from offsite organizations. Several of the Team members had also participated in the Quad Cities Business Development Team which -
interfaced directly with the NRC DET during that inspection. The Team t
assessed station performance from October 25 through November 12,1993 ~
and issued a report to the Site Vice President on November 29,1993.
l The Team identified several deficient performance areas, found the-l l
existence of common themes throughout, and cited several. root causes underlying performance deficiencies including: (1) the lack of a process to increase standards of performance, (2) weak communication of management l
expectations and sustained accountability for their implementation, and (3) j low success at quickly identifying and correcting areas of deteriorating-l performance. The Team's findings were shared with the station staff during l
information meetings held on December 6 & 7,1993.
By the end of January,1994, a comprehensive action plan will be developed to respond to the Team report findings. Accountability for identification of appropriate corrective actions, their implementation, and an effectiveness review will be assigned to senior station managers and will be overseen by the Site Vice President.
We have developed an issues management priority setting process that will 2.
be used as a bias for action. Currently radiation worker performance is a top issue. At this point we are choosing an owner and sponsor for the program who will develop success criteria and a timeline for objectives to be accomplished and communicated to the station.
3.
Management expectations on radiological performance were discussed with station personnel during a special stand down session on September.16, 1993. The meeting focused on radiation worker practices. We obtained significant information and concerns from workers and a multi-disciplinary l
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ATTACHMENT (Continued)
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/93027; 50-374/93027 l
team was established to address the input. The team identified approximately 50 items in the following areas: (1) procedure ineffectiveness, (2) procedure adherence, (3) training methods and knowledge, and (4) i l
supervisory issues. The items have been assigned to department heads for resolution. Currently we are implementing and tracking the effectiveness of these items.
1 4.
We have implemented the Corrective Action Manager (CAM) Program which consists of a senior station manager (Site Engineering and Construction Manager) designated as the lead of a team focused on monitoring and correcting problems in the plant. Radiation worker practices, housekeeping issues, procedure compliance, and material condition are the areas of primary attention. Senior staff will review l
worker identified issues with the Corrective Action Manager for resolution.
l With this method, getting supervisors in the plant to rectify the problems on the spot will lead to elevated expectations throughout the station.
5.
LaSalle Fuel Handling Procedure, LFP-600-2, Replacement of LPRM Assemblies without the Use of Spring Reel, will be revised to include guidance on notification to the drywell control point for any activities which have the potential to effect the environment of the drywell. This procedure will be revised prior to March 7,1994.
6.
We have included plant systems training and the related radiological conditions which could be potential hazards from system alterations into the RPT continuing training program and the Fuel Handlers training.
l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved immediately on the dates of the various violations, however, total compliance to procedure adherence is an ongoing effort for us and will continue to be addressed through our management improvement programs.
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