ML20151T650

Responds to NRC 880510-20 Ltr Re Violations Noted in Insp Repts 50-254/88-13 & 50-265/88-13.Corrective Actions; Radiation Work Permit Governing Work W/Underwater Cameras Made More Explicit

ML20151T650
Person / Time
Site:	Quad Cities
Issue date:	07/22/1988
From:	Bliss H COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
4872K, NUDOCS 8808160430
Download: ML20151T650 (3)

Text

_ _ _ _ . _ .

- s Commonwealth Edison a-  %

[ One First Natonal Plaza. CNeago. Ipes

\ / Mtess Reply to: Post Offce Box 767 x_/ L::ago, lines 60690 0767 July 22, 1985 Mr. A. Bert Davis Reglonal Administrator U.S. Nuclear Regulatory Co nmi ssl un Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Quad CP,les Station Units 1 and 2 Response to IE Inspection Report Nos. Sr'-254/88013 and 50-265/63013 IIRC_ Rocket Nas. 50-254 and 50-265.

Reference (a): Letter from W.D. Shafer to Cordell Reed dated June 15, 1988.

Dear Mr. Davist This letter is in response to the inspection conducted by your staff during the period May 10 through May 20, 1988 of certain activities at Quad Cities Station. The referenced letter indicated that certain activities appeared to be in noncompliance with NRC requirements and required a written response.

In a telephone conversation between Ms. I.M. Johnson of my staff and your Mr. B. Gregor, a seven (7) day extension for responding to this noncompliance was sought and obtained. The Comrnonwealth Edison Company's response to the Notice of Violation is provided in Attachment A.

If you have any questions regato't g this mattor,. please contact this office.

Very truly yours, H. E. Iss Nuclear Licensing Manager 1m Attachment A k

cet NRC Resident Inspector - Quad Cities 8808160430 FDR 890722 4 f4 DOCK O'y>0 {Ch 4872x JUL 2 51988

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ATIACUMENT_A CCHM')NHL.LTH EDISON COMPANY RESEOtiSE_IO. NOTICE OF VIQLATIOli As a result of the inspection ronducted on May 10-20, 1988, the following violation was idontified ITEM _DI_YIDLAIloti Technical Specification 6.2.B. requires that radiation control proce- dures be maintained, made available to all station personnel, and adhere to.

a. Quad Cities Radiation Protection Procedure QRP 1000-1 requires each individual to read, understand and sign the Radiation Work Permit (RWP) and comply with its regairements in all respects.

Contrary to the above, on October 28, 1987, and May 17, 1988, two licensee workers failed to comply with RWP protective clothing requirements while working on underwater camera equipment removed f rom the fuel pool and reactor cavity, respectively, in that RWP required full-face masks were not worn. One worker handling the equipment was externally contaminated and another was both externally and internally contaminated.

b. Quad Cities Radiation Protection Procedure QRP 1000-1 requires that the Rad / Chem Department be leformed and/or consulted before the fact so that a radiological evaluetion can be made when uncovering contaminated materials or disassembling potentially contaminated equipment where dose rates or airborne radioactivity may be expected to increase significantly.

Contrary to the above, on Octob6i 25, 1987, the Rad / Chem Department was not informed or consulted prior to uncovering (unbagging) conteminated camera equipment and subsequently disassembling portions of it.

COR RECIIYZ .ACT10tLIAKEN_ANILIllE_E E SULTS_ACHIEVID The immediate Corrective Action taken at the time of the May 1988 event includad making the RWP'a governing work with underwater cameras more erplicit. The tasks and the associated protective clothing requirements were broken down into more detail, resulting in lesu confusion.

Additionally, these events, along with RWP awareness, were discussed with Electrical Haintenance personnel in their weekly tailgate safety nieeting.

These corrective actions resulted in no RWP violati7ns by Electrical Maintenance personnel working on underwater cameras during the remainder of the outage.

COPJtECTIVILACIIOtiS__IQJ1E_TAKEN IN ORDER TO AYQID FURTiiER VIOLAI1QtiS A review contamination of the two occurrences ars events indicate that the root cause of the subsequen* Radiation Occurrence Report, was the failure to follow radinle,gical proteition instructions on the RWP. A contributing factor was the complexity of the RWP and the apparent confusion regbrding the proper handling of contaminated materials. To address these issues, the following steps will be undertaken:

1. The responsibility for adherence to the reque oments of the RWP rest with each individual.

the entiro contents of the RWP.This includes responsibility for understanding The station will re-emphasize that the responsibility for strict adherence to the RWP program lies with all Individuals at the station. Additionally, the need for individuals to contact this Radiation Protection Department in the event that radiological will conditions have changed or are suspected to have changed be re-emphasised.

This instruction will be incorporated in the Station Annual Retraining in 1988.

2.

A review of the existing RWP's will be conducted in order to identify any deficiencies, including excessive detall, lack of specific guidance or redundancy. Lessons learned so a result of this process will be incorporated into the aptropriate guidance to ensure future RWP's are accurately written.

3.

As part of the RLdlation Occurrence Report Investigation, a committee was formed material to look at the broader issue of control of small radioactive containments.

The committee recorser.dations have been reviewed by station management and will be incorporated into station procedures as appropriate.

Specific controls that will be taken includet requiring Radihtion Protection notification prior to opening any bags, gang boxes, etc.

containing cavities.

tools or equipment used la the fuel pools or reactor In addition, the Radlation Work Permit will require Radiation Protection to label all such small containments, which contain highly smearable items, to opening. with the caution to notify Radletion Protection prio-labeling as required. Protection will develop specific criteria on such Radiation D ATE _ NiiEM_ WLLCOM EL I ANCE_NI L L .D E_ACilI EYE D 1988. TheThe specific procedure re .slons will be completed by October 1, R.W.P.

January 1, 1989. system will refl ct these specific procedure revisions by The training will be completed by October 1988.

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. CfdBICIIVE ACTIONS TO BE TAKEN IN ORDER TO AVOID FURTHER VIOLATIQt{S A review of the tro events indicate that the root cause of the contamination occurrences and subsequent Radiation Occurrence Report, was the failure to follow radiological protection instructions on the RWP. A contributing factor was the complexity of the RWP and the apparent confusion regarding the proper handling of contaminated materials. To address these issues, the following steps will be undertakon:

1. The responsibility for adherence to the requiremenus of the RWP rest with each individual. This includes responsibility for understanding the entire contents of the RWP. The station will re-emphasize that the responsibility for strict adherence to the RWP program lies with all ledividuals at the station. Additionally, the need for individuals to contact the Radiation Protection Department in the event that radiological conditions have changed or are suspected to have changed will be re-emphasized. This instruction will be incorporated in the Station Annual Retraining in 1988.

2. A review of the existing RWP's will be conducted in order to identify any deficiencies, including excessive detail, lack of specific guidance or redundancy. Lessons learned as a result of this process will be incorporated into the appropriate guidance to ensure future RWP's are accurately written.

3. As part of the Radiation Occurrence Report Investigation, a committee was formed to look at the broader issue of control of small radioactive material containments. The committee recommendations have been reviewed by station management and will be incorporated into station procedures as appropriate.

Specific controls that will be taken includes requiring Radiation Protection notification prior to opening any bags, gang boxes, etc.

containing tools or equipment used in the fuel pools or reactor cavities. In addition, the Radiation Work Permit will require Ra01ation Protection to label all such small containments, which contain highly smearable items, with the caution to notify Radiation Protection prior to opening. Rhdiation Protection will develop specific criteria on such labeling as required.

DATLNHrJLTULL_CCHELIMICEJf1LL_BLACli1IVID The specific procedure revisions will be completed by October 1, 1988. The R.W.P. system will reflect these specific procedure revisions by January 1, 1989. The training will be completed by October 1988.

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