ML20077F616
| ML20077F616 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 06/14/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9106190418 | |
| Download: ML20077F616 (4) | |
Text
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C mm:nw:alth Edlssn 2
C 1400 opus Place O
Downers Grove, Illinois 60515 Ame 14,1991 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
LaSalle County Station Units 1 and 2 Responso to Notice of Violation Inspection 50-373/91008; 50-374/91007 NBC_Dochet Nesm50-373_and50 3Z_4 neference:
C.E. Nolallus letter to Cordell Reed dated May 16,1991 transmitting NRC Inspection Report 50 373/91008; 50 374/91007 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Notice of Violation (NOV). The NOV cited two Severity Level IV violations. The first violation concerned the failure to conduct adequate evaluations of radiological conditions. The second violation Identified examples of workers falling to contact Radiation Protection when they undertook work beyond the scope of their respective Radiation Work Permits (RWPs). In the examples cited, the workers involved were contaminated and received low level radioactive intakes.
CECO understands the significance of these events as well as the need for effective corrective actions to prevent recurrence. These have been considered in developing actions in response to the cited violations. CECO's response is provided in the following attachment.
If your staff has any questions or comments concerning this letter, please refer them to Annette Denenberg, Compliance Engineer at (708) 515-7352.
Very truly yours, f_s
.J j<ovach f
Nuclear L9snsing Manager GAD /TJK/GMP Enclosure I
cc:
A.B. Davis, Regional Administrator - Rlli B. Siegel, Project Manager - NRR T. Tongue, Senior Resident inspector ZNLD996/1 9106190418 910614 ADOCK oSoo' j3 g pf g
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VIOLATION: IR 50 373/91008 01; 50-374/91007 01 10 CFR 20.201(b) requires that each licensee makes or causes to be made such surveys as (1) may be necessary to comply with the regulations in this part, (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.10 CFR 20.201(a) defines a survey as an evaluatiors 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, on February 19, March 25 and 26,1991, the licensee did not conduct an adequate evaluation to determine radiological conditions ascociated with contaminated floors / equipment which resulted in personalintakes of radioactive material.
REASON FOR THE VIOLATION:
Commonwealth Edison (CECO) acknowledges the violation. The violation involved the failure to conduct adequate evaluations of radiologica! conditions.
The violation occurred as a direct result of inadequate commurocations between the workers involved and the Radiation Protection Department, in the three events cited, the workers did not recognize the need to notify Radiation Protection of their work activities.
These missed communications ranged from not communicating work activities prior to the commencement of the work itself to not communicating radiologically significar. changes which occurred during the course of the work. Had these communications taken place, LaSalle Station believes that adequate evaluations I
would have been performed. Therefore, due to the inadequate communications, Radiation Protection was not able to provide an adequate evaluation to prescribe controls specific to the work or to make necessary evaluations to reflect the changes in radiological conditions at the work site.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The workers involved in these three events were counselled on the necessity to provide the required information to Radiation Protection. The events specific to the Fuel Handlers and contractor personnel were tailgated with the respective work groups involved.
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l 50RRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
Trainir.g addressing these three events will be provided for all on site personnel via the General Information Notification (GIN) system. The training will highlight the necessity of ensuring that Radiation Protection is adequately informed prior to commencement of work activities. Hence, Radiation Protection will be able to provide a proper evaluation of radiological controls specific to the work scope.
The training will also stress the importance of communicating changes that occur during a job which may require additional evaluation and/or a change in radiological controls.
A Trainin g Feedback Form will be submitted to the Training Supervisor to include similar iniormation in the General Employee Training Program and the Annual Retraining Program to maintain continuing awareness in this area.
Finally, a communications reminder will be alaced at the access control points reminding all workers to ensure that Radiat on Protection is kept informed of their work activities in order to provide for adequate evaluations and controls.
DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED:
Full compliance will be achieved by August 31,1991. The actions to be completed by this date include training via the GIN system, submission of the Training Feedback Form, and placement of the communications reminder.
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VIOLATION:
IR 50-373/91008 02 50 374/91007 02 Technical Specification 6.2.B rec ulres that radiation control procedures be maintained, made available to al personnel, and adhered to.
LaSalle Administrative Procedure LAP-100 22, requires that Individuals comply with the requirements of applicable RWPs.
Contrary to the above, Individuals involved in refueling floor work on March 25, 1991, and individuals involved in housekeeping in the outboard MSlV room on March 26,1991, did not contact Radiation Protection when they undertook work that was beyond the scope of their respective RWP's.
REASON FOR THE VIOLATION:
CECO acknowledges the violation. In the two events cited, the workers performed work outside of the RWP due to an inadequate understanding of the scope and limitations associated with the RWP.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED:
The individuals involved were counselled on the necessity to remain within the specific scope of the RWP and to ensure that the limitations associated with the work are understood prior to performing the work. Both work groups involved in these events were tailgated on these requirements.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
A General information Notice (GIN) will be issued to all Station personnel discussing these two events. This GIN will stress the necessity to review the task listings associated with the RWP prior to performing work to ensure that the intended work was considered by Radiation Protection during the preparation of the RWP and thereby falls within the scope of the RWP.
The current RWP portions of the General Employee Training and Annual Retraining programs (l.a. NGET) will be reviewed to ensure that adequate emphasis is placed upon performing this verification of intended work versus scope.
The Station will convene a working level group to review the Station's implementation of the new RWP program. The working level group will ensure that the Station is getting the maximum benefit from the program revision and that the new RWP package minimizes problems associated with worker adherence, DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED:
Full compliance will be achieved by August 31,1991. The actions to be completed by this date include distribution of the GIN, review of the RWP cortion of the NGET programs, and formation of a group to review mplementation of the new RWP program.
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