ML20133C437

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Discusses Insp on 850506-0722 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Three Events Cited Re Failure to Follow Radiation Protection Procedures
ML20133C437
Person / Time
Site: Byron  Constellation icon.png
Issue date: 10/02/1985
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Oconnor J
COMMONWEALTH EDISON CO.
Shared Package
ML20133C441 List:
References
EA-85-099, EA-85-99, IEIN-84-19, NUDOCS 8510070362
Download: ML20133C437 (4)


See also: IR 05000506/2007022

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October 2, 1985

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Docket No. 50-454

License No. NPF-37

EA 85-99

Commonwealth Edison Company

ATTN: Mr. James J. O'Connor

President

Post Office Box 767

Chicago, IL 60690

Gentlemen:

Subject:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

(NRC INSPECTION REPORTS N0. 50-454/85022(DRSS) AND 50-455/85020(DRSS))

This refers to the inspection conducted during the period May 6 through July 22,

1985 at the Byron Nuclear Station. The inspection disclosed numerous examples

of failures to follow radiation protection procedures, failures of management to

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adequately evaluate radiological conditions, and lack of adequate procedures.

The results of this inspection were discussed on June 27 and July 22, 1985

during Enforcement Conferences held in the Region III office between

Mr. C. Reed and others of your staff and myself and others of the NRC staff.

The violations in the Notice principally involve three separate events.

During

the first event, on April 17, 1985, continual Radiation / Chemistry Technician

(RCT) attendance was not maintained as required by the Radiation Work Permit

for a shift foreman and an equipment attendant entering containment.

As a

result, radiation deses for these two individuals-and the RCT who initially

entered containment exceeded Station limits.

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During the second event, on May 1, 1985, two electrical maintenance workers

entered the incore motor drive area, a high radiation area, without being

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accompanied by an RCT, as-required by Station procedures.

Although the workers

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were provided with dosimetry devices, they were not adequately instructed in

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the use of these devices nor were they informed of the radiation levels in the

work area or that continuous attendance in the area by an RCT was required.

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a result, both individuals received radiation doses that exceeded Station

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administrative limits.

During the third event, on July 1, 1985, a maintenance crew removed contaminated

insulation from a leaking valve without using protective clothing and without

prior contact with the Radiation / Chemistry Department.

As a result, an

individual's hands and clothing were contaminated.

8510070362 851002

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CERTIFIED MAIL-

$DR

ADOCK 05000454

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RETURN RECEIPT REQUESTED

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Commonwealth Edison Company

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October 2, 1985

We are concerned that in all three events, procedures were not followed

and plant personnel were directed to work in areas where there were

significant radiological hazards without adequate supervision or training.

To emphasize the importance of ensuring that supervisory and other personnel

know and follow established radiological safety procedures, personnel are

adequately trained, and that personnel make effective use of the Radiation /

Chemistry Department staff, I have been authorized, after consultation with

the Director, Office of Inspection and Enforcement, to issue the enclosed

Notice of Violation and Proposed Imposition of Civil Penalty in the amount

of Fifty Thousand Dollars ($50,000) for the violations described in the

enclosed Notice.

In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985)

(Enforcement Policy), the violations described in the enclosed Notice have

been categorized as a Severity Level III problem.

Mitigation of the proposed

civil penalty was considered because of your prior good enforcement history;

however, since this plant has only recently received an operating license and

has already experienced three radiological events that indicate a lack of

management attention, no mitigation of the penalty was deemed warranted.

I am ' enclosing for your information a copy of IE Information Notice No. 84-19

which describes two events involving entry into high radiation areas caused

by inadequate understanding of the radiological hazards present and inadequate

access controls.

.I am providing this to further emphasize the significance NRC

places on radiological controls and the consequence of inadequate management

attention in this area.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In your

response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence.

After reviewing your response to this

Notice, including your proposed corrective actions, the NRC will determine

whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its enclosure

will be placed in the NRC's Public Document Room.

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Commonwealth Edison Company

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October 2, 1985

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

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by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely,

Original s1 ped by

J. r:s G. Kepptor

James G. Keppler

Regional Administrator

Enclosures:

1.

Notice of Violation and

Proposed Imposition of Civil Penalty

2.

IE Information Notice No. 84-19

3.

Inspection Reports

No. 50-454/85022(DRSS)

No. 50-455/85020(DRSS)

cc w/ enclosures:

D.

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Farrar, Director of

Nuclear Licensing

R. E. Querto, Plant Manager

See Attached List For Distribution

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Commonwealth Edison Company

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October 2, 1985

Distribution

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JMTaylor, IE

RVollmer, IE

JCollins, IE

JAxelrad, IE

GKlingler,-IE

JKeppler, IE

JLieberman, ELD

Enforcement Coordinators

RI, RII, RIII, RIV, RV

FIngram, PA

,VStello, DED/ROGR

JCrooks, AE00

SConnelly, OIA

BHayes, 0I

EJordan, IE

JPartlow, IE

BGrimes, IE

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HDenton, NRR

RStark, NRR

IE:ES File

IE:EA File

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