ML20059E827
| ML20059E827 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 10/27/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9311030366 | |
| Download: ML20059E827 (5) | |
Text
.
. [m
, ( _ y C:mm:nwrith Edison.
October 27,1993 1400 Opus Place Downers Grove, llhnois 60515 U.S. Nuclear Regulatory Commission
. Washington, D.C. 20555 Attentic,o.
Document Control Desk
Subject:
LaSalle County Station Units 1 and 2 Response to Notice of Violation NRC Inspection Report 50-373/93021; 50-374/93021 NRC Docket Numbers 50-373 and 50-374
Reference:
W. L. Axelson letter to L. O. DelGeorge, Dated September 27,1993, Transmitting NRC Inspection Report 50-373/93021; 50-374/93021 Enclosed is Commonwealth Edison Company's response to the Notice of Violation (NOV) which was transmitted with the referenced letter and NRC Inspection Report. The violation is addressed in Attachment A and refers to an event which indicated that willful and deliberate acts to bypass radiological control barriers were identified. We view the implications of this event with concern. An event of willful disregard for radiological controls.
can not and will not be tolerated. It is our view that this event was not from malicious intent, but one of apparent careless regard for radiological rules as they relate to job accomplishment. Although we feel this event is singular in occurrence, it nevertheless highlights an unacceptable radiation worker attitude and performance that we are continuing -
to address.
The cover letter to the Inspection Report also requires that the response include the corrective actions we plan to take to ensure there is adequate oversight of the hose control program. Attachment B addresses this requirement.
If there are any questions or comments concerning this letter, please refer them to JoEllen Burns, Regulatory Performance Administrator at (708) 663-7285.
Respe-tfully, 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 L
k:rparinsprh Q.f @ gutropel: 1 9311030366 931027 M i' l'
PDR ADOCK 05000373 G
PDR w:
A ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION RFsPORT 50-373/93021; 50-374/93021 VIOLATION: 373(374)/93021-01 During an NRC inspection conducted on August 11 through 18,1993, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and t
Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification 6.2.B, states, in part, that radiation contr il procedures shall be maintained and adhered to.
LaSalle Radiation Protection Procedure 1130-1, " Radiological Sig is and Labels", Section F.2.f, 2
states, in part, that areas which contain radioactive materials in excess of 1,000 dpm/100cm shall be conspicuously posted with a sign or signs bearing the radiation symbol and the words " Caution Contaminated Arca" or " Danger Contaminated Area".
Contrary to the above, on August 10,1993, the hose storage area on the 754' elevation of the turbine building contained smearable levels of contamination in excess of 1,000 dpm/100cm' and was not posted with a " Caution Contaminated Area" or " Danger Contaminated Area" -
l sign.
l This is a Severity Level IV violation (Supplement IV).
?
O
+
'I
)
k:rpa:inspst:lasalle:cutropel:2
A.
a
+
-.s.-.
in m'
.A.l
_e e
.a+iL.--
ms-4 4
i ATTACHMENT A (Continued)
RESPONSE TO NOTICE OF VIOLATION t
NRC INSPECTION REPORT 50-373/93021; 50-374/93021 REASON FOR VIOLATION:
On August 10,1993, a Radiation Protection Technician (RPT #1) determined by survey that-the hose storage cage on the Turbine Building elevation 754' contained hoses with internal contamination of up to 100K dpm/100cm', and floor contamination of 1-2K dpm/100cm. The 2
cage is a normally " clean" cage which should have no contamination, nor contain hoses with i
internal contamination. RPT #1 posted the cage as " Caution, Contaminated Area, Radioactive materials" by tying a radiation ribbon across the cage door to secure the door and then hanging the sign on the ribbon. RPT #1 then notified an RP supervisor of the situation.
The supervisor who was touring the plant at the time included an inspection of the posted cage as part of the tour, but upon arrival within 40 minutes of being notified of the situation I
by RPT #1, found no radiation ribbon or sign on the cage or door. After contacting RPT #1 to I
confirm the correct cage, the supervisor found the radiation ribbon and sign in a nearby grey cart. The radiation ribbon had been cut down, and the knots of the ribbon remained on the cage. Security was notified and secured possession of the ribbon and sign. Initially upon arrival to the cage area, the RP supervisor had observed a worker (worker #1) leaving with a hose. Worker #1 was contacted for interview, the hose was surveyed and found to be clean.
l t
Worker #1 stated that he found the hose he needed in a grey cart (the same cart in which the sign was found) located just outside the door to the hose cage, and doesn't remember the specifics of whether he actually entered the cage or not. He stated that no radiation ribbon or sign was on the cage or door. The hose was procured after the cage was posted, and before the RP supervisor arrived. A broader scale investigation was conducted. A list of all individuals who were logged into the radiological controlled area of the plant svas compiled and reviewed. Individuals who's jobs could have resulted in the need for a hose from the cage of concern or could have been in the cage area during the time of the event were interviewed. Approximately 75 individuals were interviewed. The seriousness of the situation was explained to each individual and management expectations were re-emphasized. From the interviews, no other individuals could be positively identified as j
having entered the Turbine Building 754' elevation during the time frame ofinterest. The RPTs were also questioned concerning which radiological areas,if any that they released or down-posted during the time frame of concern. According to these interviews, no RPT released or down-posted this cage. The sign was " finger printed" by a professionallaboratory to determine if the responsible individual could be identified. The results were inconclusive.
The reason for the violation is that a person or persons unknown removed a properly posted i
and required sign, karpa:inspSt:lasalle:cutropel:3
i' ATTACHMENT A (Continued)
RESPONSE TO NOTICE OF VIOLATION.
?
NRC INSPECTION REPORT 50-373/93021; 50-374/93021 CORRECTIVE ACTIONS TAKEN AND RESULTS AC.HIEVED i
Upon finding the cage not posted, the RP supervisor remained in attendance and called for an RPI'. The hose cage was immediately posted as required by the RPT upon arrival.
I CORRECTIVE ACTIONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS The hose storage cage has been returned to " clean" status by surveying and deconning the floor, and cleaning or removing' internally contaminated hoses as necessary.
All personnel who had jobs that could have been involved in this event were interviewed.
The seriousness of the situation was explained to each individual and management expectations were re-emphasized.
A Station Manager letter was issued on Augutt 27,1993 to Department Heads for review and communication with their personnel concernirg the seriousness of this event. It emphasized that "..this type of blatant disregard for station procedures will result in immediate discipline, up to, and including termination."
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when the cage was properly posted on August 10,1993.
i kzrpatinspst:lasalle:cutropel:4 I
ATTACHMENT B -
CORRECTIVE ACTIONS FOR HOSE CONTROL PROGRAM NRC INSPECTION REPORT 50-373/93021; 50-374/93021 CORRECTIVE ACTIONS FOR HOSE CONTROL PROGRAM:
Procedure LAP-240-6, " Temporary System Changes," contains direction to ensure adequate protection against using a hose or pipe of the wrong rating. However, this procedure is for special use and is not applicable if the transfer is performed in accordance with an other approved procedure.
LAP-900-8, " Hose Identification and Control," w as also reviewed, and it was identified to not contain guidance that would direct the hose user to evaluate the hose against the pressure and temperature for which it is to be used. LAP-900-8 will be revised to direct the user to select a hose which meets the expected pressure and temperature conditions for use.
We are soliciting information on hose control fmm other CECO sites and other utilities. A review performed for controls at the responding plants have shown no improvements to the current LAP-900-8. We will continue to review other utility programs and incorporate those ideas considered to be improvements.
Recently implemented activities at LaSalle to address management attention and aggressiveness in identifying and resolving problems includes the assignment of a Corrective Actions Manager (CAM) for the duration of the present refuel outage, which was described in the response to the Notice of Violation in NRC Inspection Report 50-373/93019; 50-374/93019.
General compliance with the hose control program through field observations of hose usage
-]
and in field questioning of personnel using hoses as to correct application have been included as part of this function.
l i
l l
~
1 k:rpa:inspstilasalle:cutropel:5
]
m