ML20063H316

Responds to NRC Re Violation Noted in Insp Repts 50-254/93-30 & 50-265/93-30.Corrective Actions:Vehicle Returned to Site & Proper Survey Conducted & Interim Procedure Written for Qcap 650-4

ML20063H316
Person / Time
Site:	Quad Cities
Issue date:	02/10/1994
From:	Farrar D COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9402170301
Download: ML20063H316 (3)

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/ ~ k Commonwrith Edisoni 1400 Opus Placo -

~l Downers Grove. Ilknois 60515 Q:

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. February 10,L19941 1...

U. S. Nuclear Regulatory Commission >

Washington, D. C. 20555 4

t Attn: Document Control Desk L

Subject:

Quad Cities Power Station _ Units 1 andI2;'

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.i NRC Docket Number 50-254 and 50-265:

FRC Inspection Report Numbers 50-254265V93030 :

Reference:

Ed vard G. Greenman lett$r to R. Pleniewicz dated January 12, 1994, transmitting Notice.of Violation.

j Inspection; Report 50-254/93030;'50-265/93030; q

Enclosed is Commonwealth Edison's response'to the" Notice of[ Violation ;

(NOV) transmitted with the referenced: letter. The NOV cited cae~ Severity Le' vel IV 3

violation, pertsining to a concern that past corrective actions for a'similar violationi:

O were not effective to prevent recurrence.-

The following commitments are being made by this l'etter:

1.

A permanent procedure revisio'n to QCAP 650-4,1" Disposition of Radioactive '

j Material and Radioactive Waste Shipment Vehicles"_ by February l19,1994

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2.

A task force is being conducted to' perform a Root Cause Investigation'to :

U verify that these corrective actions are~ appropriate. This task force will be. '

completed by March 31,1994 'and the' appropriate recomniended actions will ~

be implemented by July'31,1994.

l If there are any questions or comments concerning this' letter, please refer h

them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-72871 u

- Respec fully, 1500df)

D. L. Farrar, Manager -

Nuclear Regulatory Services.

j Attachment h

cc: J. Martin, Regional Administrator, RIII O. Patel, Project Manager, NRR T. Taylor, Senior Resident Inspector, Quad Cities.

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RESPONSE TO NOTICE OF VIOIATION NRC INSPECTION REPORT.

No. 254(265)/93030 VIOIATIOM 10 CFR 71.5(a) requires that licensees, who transport licensed material outside the confines of their plants or deliver licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Part 170-189.

49 CFR 173.443(c) requires, in part, that each vehicle used for transporting '

radioactive materials as an exclusive use shipment be surveyed with appropriate radiation detection instruments after each use.

Contrary to the above, on November 19,1993, a truck used to transport a pump contaminated with radioactive material as an exclusive use shipment to the licensee was not surveyed with appropriate radiation detection instruments after use.

REASON FOR THE VIOIATION:

CECO acknowledges and agrees with the apparent violation. The causes were procedural inadequacy and a lack of a questioning attitude by the personnel involved with the receipt of the shipment.

1. The security guard at the front desh did not ask if the shipment had radioactive material.

2. When informed by the Electrical Maintenance Department that the material had arrived, stores personnel did not ask if the shipment was radioactive.

3. The crew unloading the material did not question if radiation protection involvement was necessary.

This event is simile to a 1992 event. The corrective actions from the previous violation addressed shipments received inside the protected area and outside the protected area at the warehouse. The corrective actions did not address the scenario of receipt at a location other than the warehouse outside of the protected area.

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. RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT No. 254(265)/93030 1

CORRECTIVE STEPS TAKEN TO ACHIEVE COMPLIANCE:

j The vehicle returned to the site, and the proper survey was conducted. The survey results were within acceptance criteria.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION: -

1.

An interim procedure was written for QCAP 650-4, Disposition of Radioactive Material and Radioactive Waste Shipment Vehicles," adding a note that security shall ask all delivery drivers if they are carrying radioactive material. A permanent procedure revision will be approved by February 19, 1994.

2.

A task force is performing a root cause investigation to verify these corrective actions are appropriate. The task force recommendations.will be reviewed by February 28,1994. The recommendations will be assessed by March 31,1994.

Approved recommendations will be implemented by July 31,1994.

3.

The approved recommendations will be monitored for effectiveness.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

l Full compliance will be achieved by February 19,1994 with the revision of QCAP 650-4, " Disposition of Radioactive Meterial and Radioactive Waste Shipment Vehicles."

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