ML20134P163
| ML20134P163 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/15/1985 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 0499K, 499K, NUDOCS 8509060157 | |
| Download: ML20134P163 (3) | |
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f'~N Commonwealth Edison
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J Address Reply to: Post Office Box 767 Chicago. Illinois 60690 August 15, 1985 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Zion Nuclear Power Station Units 1 and 2 I.E.-Inspection Report Nos. 50-295/85-21 and 50-304/85-22
Reference:
July 19, 1985 letter from W. D. Shafer to Cordell Reed.
Dear Mr. Keppler:
This letter concerns the routine safety inspection of activities at Zion Station conducted on June 17-21, 1985 by P. C. Lovendale and G. M.
France,d to be in noncompliance with NRC requirements.
III. The referenced letter indicated that certain activities appeare Commonwealth Edison Company's response to the Notice of Violation is provided in the Attachment to this letter.
If.you have any questions regarding this matter, please direct them to this office.
Very truly yours, f
Ye N
[w D. L. Farrar Director of Nuclear Licensing im U
-gD Attachment cc: Resident Inspector - Zion AUG 161969 -
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ATTACH 4ENT ZION NUCLEAR POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF VIOLATION ITEM OF-NONCOW LIANCE:
As a. result of the inspection conducted on June 17-21, 1985, and in accordance with the General Policy and Procedures for MlC Enforcement Actions, (10 CFR Part 2, Appendix C), the following violation was identified:
10 CFR 20,201(b) states that each licensee shall make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations of this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that'may be present.
As used in the regulations in this part, " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other source of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and.
equipment, and measurements of levels of radiation or concentrations of radioactive material present.
Contrary to the above, on February 12, 1985, and again.on April 22, 1985, during work on the reactor head, the licensee failed to properly evaluate the dose rates of areas entered by workers for the purposes of determining. stay times and proper dosimetry placement. This resulted in
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seven wcrkers exceeding their authorized daily exposures of 300 mrems.
CORRECTIVE ACTION TAKEN ABO RESULTS ACHIEVED Subsequent.to each of these events, radiation occurrence reports (Report Nos. 85-31 and 85-52) were written. For each of these reports health physics staff researched the event to determine root cause and corrective actions to prevent reoccurrence. Both of these events resulted in the need to make corrections to personnel exposures.
However, the root causes were different for each. The first event was-due to poor communication between the maintenance personnel working on the reactor head and.the rad / chem department. The second event was due-to inadequate timekeeping..
-The initial corrective actions were to discuss the events with the
. personnel involved, make necessary dose calculations and corrections to
. the. personnel involved and to discuss the events with other personnel in maintenance and rad / chem. Additionally,.a letter dated March 19, 1985 was sent to the Alara Group to add a notation to the "Special Instructions".section of specific varying dose Radiation Work Permits for future outages to ensure an RCT or contractor technician is in attendance at the start.of the specific job to verify dosimetry placement.
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< CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOWLIANCE 1.
Thirty-five recurring outage Radiation Work Permits which will
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involve varying dose rates will be reviewed and if applicable will have the following statement added in the "Special Instructions" section.
An RCT or contractor HP technician must be in attendance at the start of the job to ensure proper replacement of dosimetry.
This review and addition to applicable RhP's will be completed by September 5, 1985.
2.
A listing of all recurring outage _ jobs developed by the station planning department will be reviewed and if applicable will have the following statement added as a comment to the outage schedule printout:
Contact Rad /Cnem prior to starting job This review and applicable additions to the outage schedule will be completed by Septe t er 5, 1985.
3.
Discussions will be held between the Station Health Physicist, j
Master Mechanic, Maintenance Assistant Superintendent, Maintenance Staff Head, and Outage Planner on the necessity of proper i
communications between maintenance personnel (CECO and contractor) and Rad / Chem personnel. These discussions will be completed by September 5, 1985.
4.
The Radiation Occurrence Reports, the Notice of Violation, and this response will be reviewed by Health Physics Staff, radiation
. chemistry technicians and contractor Health Physics Technicians.
This review will be complete by September 5, 1985.
5.
A training package will be assembled to provide guidance to station RCT's relative to work performed on the reactor head. The package will include historical data on reactor head work, i.e., past.
surveys, photos, guidelines, for dosimetry placement, timekeeping i
concerns, etc All of this information is intended to identify problem areas unique.to reactor head work. The package will be completed by September 5,1985. The package will be implemented i
for use during this outage and reviewed by RCT's following reactor head work prior to their assignment to the job.
1 DATE WHEN FULL COWLIANCE WILL BE ACHIEVED 0
Full compliance on this item of noncompliance will be met by September 5, 1985.
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