ML20080A911

Forwards Response to Violations Noted in Insp Repts 50-254/94-21 & 50-265/94-21.Corrective Actions:Initiated Security Investigation & All Sr-90 Check Sources Removed from Unrestricted Use

ML20080A911
Person / Time
Site:	Quad Cities, 05000365
Issue date:	11/16/1994
From:	Kraft E COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF ENFORCEMENT (OE)
References
ESK-94-084, ESK-94-84, NUDOCS 9411230125
Download: ML20080A911 (5)

Text

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' . Commonwealth Edison Quad Cities Nuclear Power Station 22710 206 Avenue North Cordova. lilinois 61242

. Telephone 309/654-2241 ESK-94-084 November 16,1994 Director, Office of Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk

Subject:

Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/94021

Reference:

John B. Martin letter to M. Wallace dated October 18, 1994, transmitting Notice of Violation and Proposed Imposition of Civil Penalty - $100,000 (Severity Ixvel II)

Enclosed is Commonwealth Edison's (. Comed) response to the Notice of Violation transmitted with the referenced letter. The NOV cited two violations, involving: 1) the failure to ensure that byproduct material was controlled, used and possessed in accordance with the terms of the license (Civil Penalty, Severity Level II) and 2) the failure to perform a proper survey in accordance with 10 CFR 20.1003 (NOV, Severity Level IV).

These violations have been classified in the aggregate as a Severity Level II problem and a 12 vel IV NOV, and assessed a civil penalty of $100,000. Comed's response and payment of the civil penalty is attached.

We appreciate the NRC's acknowledgement of Quad Cities corrective actions for these violations.

If there are any questions or comments concerning this letter, please refer them to Nick Chrissotimos, Regulatory Assurance at (309) 654-2241 ext 3100.

Respectfully, Y.bxt$)e E. S. Kraft J .

Site Vice P sident Quad Cities Station

" O~ () C n3 .

Attachment cc: J. Martin, Regional Administrator, Rill R. Pulsifer, Project Manager, NRR C. Miller, Senior Resident Inspector, Quad Cities 5j '

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9411230125 941116 PDR ADOCK 05000254 i O PDR

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VIbLATION 50-254/265-94021 I During an NRC inspection conducted from August 15 through August 25,1994, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

1. Violation Assessed a Civil Penalty License Condition 2.D authorizes the licensee, in part, to receive, possess, and use at any time any byproduct, source and special nuclear materials as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts required.

Contrary to the above, the licensee failed to ensure that byproduct material was controlled and was possessed and used in accordance with the terms of the license. Specifically, on August 8,1994, a sealed radiation check source of strontium-90 was deliberately removed from its holder mounted in the Unit 1 Turbine Building and placed in an individual's clothing, a use not authorized by the license condition.  ;

I This is a Severity Ixvel II violation. Civil Penalty - $100,000.

REASONS FOR THE VIOLATION:

Comed acknowledges the violation. The apparent root cause for the event was a deliberate act performed by an individual. Contributing to the event was the design configuration and location of the source holder.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The station has taken the following actions in response to the above event:

1) Initiated security investigation and FBI involvement.

2) All Sr-90 check sources removed from unrestricted use in the plant.

3) Sources were inventoried and evaluated.

4) Article in station newspaper on expectations for employee training. j i

5) Contractor Orientation and New Station Employee Training has been revised to include this j event.

CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION: l l

4 The station is planning on taking or has taken the following actions:

1) Site-wide evaluation of radiological hazards.

2) General Employee Training (GET) enhancements. (complete)

3) Upgraded controls for sources. (complete)

4) Lessons-learned from Quad Cities will be provided to all Comed sites, and system-wide enhancements will be undertaken for source control. (complete)

5) Site VP's at all Comed sites will issue letters reinforcing expectations concerning radiation work practices, respect for radiation, employee conduct, and respect for co-workers. (complete)

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was met with the actions taken by upgrading the controls for source materials.

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1 VIOLATION 50-254/265-94021-2:  !

. l During an NRC inspection conducted from August 15 through August i 25, 1994, violations of NRC requirements were identified. In i accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),

42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalty are set forth below:

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2. Violation Not Assessed a Civil Penalty 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with l the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

Contrary to the above, on August 8, 1994, the licensee did not make adequate surveys to assure compliance with 10 CFR 20.1201 which limits, in part, the annual shallow-dose equivalent to the skin to 50 rems (0.50 Sv). Specifically, a hand-held frisker survey of a radiation worker by a radiation protection technician was limited to the radiation worker's front side and was not performed on the radiation worker's back side, although the radiation worker had set off whole body alarms. The radiation protection technician did not locate a radiation source which was in the worker's back pants pocket.

This is a Severity Level IV violation.

REASONS FOR THE VIOLATION:

Comed acknowledges the violation. The apparent root cause of the event was an inappropriate assumption by the RPT which led to an ineffective initial survey.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The station has taken the following actions:

1) RPTs were briefed on the guidelines for response to a contamination event.

2) The contamination response guidance was incorporated into a procedure.

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1 CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:

The station will take the following actions:

1) Lessons learned from Quad Cities will be provided to all Comed sites and system-wide enhancements will be undertaken for surveys by RPTs and training for RPT personnel, including contractors who perform work involving response to a contractor event.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance will be met with the completion of the enhancements to the performance of surveys and training for RPTs.