ML20094L496
| ML20094L496 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 03/19/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203250322 | |
| Download: ML20094L496 (3) | |
Text
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C:mmonwe:lth Edis:n 1400 Opus Place t
Downers Grove. Illinois 60515 March 19, 1992 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn:
Document Control Desk
Subject:
Quad Cities Nuclear Power Station Units 1 and 2 Response to Notice of Violation J.nspection Report Nos. 50-254/92005; 50-265/92005 NRC_DockeLNos,,_50:25LanL50-265
Reference:
L. R. Greger letter to Cordell Reed dated February 21, 1992 transmitting NRC Inspection Report 50-254/92005; 50-265/92005 Enclosed is Commonwealth Edison company's (Ceco) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report.
The NOV cited one Severity level IV violation requiring a written response.
The violation concerned the failure of earlier corrective actions to effectively correcc problems associated with the control of high radiation areas to prevent unauthorized entry.
CECO's response is provided in the attachment.
i If your staff has any questions or comments concerning this transmittal, please refer them to James Hatson, Compliance Engineer at (70(D 515-7205.
Sincerely,
[
$7 l
T.J. Kovach L
Nuclear Licensing Manager crn.
s, J v u.4.a Attachments
'cc:
A.B. Davis, Regional Administre, tor - Region III f '0(
L.N. 01shan, Project Manager, NRR T. Taylor, Senior Resident Inspector
/
9203250322 920319
)
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_PDR ADOCK 0500 4
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ATTACHliENT A RESPONSE 10 N9TICL Of V10LA110N HRC INSP!Cil0N REPOR1 50-254/92005; 50-265/92005
-VIOLATION 10 CFR 20,203(c)(2)(iii) requires in part that, in the absence of certain specified control M ices, each entrance or access point to a high radiation area be mM.#tained locted except during periods when access to the area is required with positive control over each individual entry.
Contrary to the above, on several occasions in 1991, in the absence of the specified control devices, doors to high radlaiton areas were not locked or controlled to prevent unauthorized entry.
BEA50tlCOLTHE,VIOLMI'i
.The door control problems, as discussed in the inspection report, arc attributed to personrel ialling to secure doors or ieturn
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high radiation area keys as required oy :tatbn procedures.
CORRECIIVE_SIERS.REMED RESULIS ActilEVED s
Rad!' tion Occurrence Reports were initiated and investigations a
completed for each identified incident.
In each case where the specific personnel involved could be identified, these individuals r
were interviewed by a panel of senior station management personnel and follow-up actions including discipline,.were asd gned.
As noted in the NRC inspection report, the station has initiated a number of actions in an attempt to improve performance of properly controlling high radiation areas. Most of these actions were designed to i
heighten the level.of awareness of personnel to the importance of properly controlling high radiation areas.
This approach was taken because_the station high radiation area control program relied on the 4
individuals-signing out the key to ensure.that all procedural requirements were followed.
The statton acknowledget that these actions have not produced satisfactory performance.
During the present outage (Q2R11), personnel wre placed at frequently used high radiation area entrances to control-access.
These personnel were effective in reducing high radiation area control problems until the station was able to make a complete revision to the'high radiation area. control program.
In January 1992, the station. received an amendment-to the plant Technical Specifications (section 6.12) which allows control.cf high radiation areas in the manner described in generic Technical Specifications.
The present control program will be modified under the terms of the lechnical Specifications to provide controls on the area based on the radiation hazard'of the area.
The new control program will reduce the number of locked high radiation areas from 140 to below 60.
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The control of lotted high radiation areas will be assumed solely
'by the Radiation Protection department which will enhance program accountability.
This transfer of control was made on March 9, 1992.
CORREC11VE STEPS JALEli 10 AV010 IURTHER VIOLAlloti To ensure near term effectiveness, focussed management oversight of the program implementation will be provided through the end of 1992.
Progiam adjustments will be made as necessary.
DATE WHER [VLL COMPLI ANCE HILL DE_ ACHIEVED full compliance was achieved upon implementation of the revised high radiation area control program on March 9, 1992.
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