ML20133C437
| ML20133C437 | |
| Person / Time | |
|---|---|
| Site: | Byron |
| 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
Text
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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.
As
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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.
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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09/30/85
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Commonwealth Edison Company
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October 2, 1985
Distribution
PDR.
LPDR
'SECY
CA
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
'
HDenton, NRR
RStark, NRR
IE:ES File
IE:EA File
EDO Rdg File
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