ML20195G303

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Notice of Violation from Insp on 980915-1022.Violation Noted:On 981022,two Individuals Working Under RWP 984014 Removed Outer Rubber Gloves While Replacing Insulation in Containment
ML20195G303
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 11/13/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195G286 List:
References
50-456-98-15, 50-457-98-15, NUDOCS 9811200253
Download: ML20195G303 (3)


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i N'OTICE OF VIOLATION i-Commonwealth Edison Company.

Docket Nos. 50-456; 50-457 Braidwood Station, Units 1 and 2 License Nos. NPF-72; NPF-7 I

During an NRC inspection completed on October 22,1998, two violations of NRC requirements I

were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1.

Technical Specification 6.8.1 requires that procedures be established, implemented and maintained covering activities referenced in the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

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Appendix "A" of Regulatory Guide 1.33, Revisio6 2, February 1978, step 7.e.(1) recommends that procedures be established goveming access control to radiation areas including a radiation work permit system.

j Radiation Protection Procedure BwRP 5000-7 (Revision 2), dated August 2,1996, j

" Unescorted Access To And Conduct in Radiologically Posted Areas," implements the requirements of Technical Specification 6.8.1 and requires in step G.3.f that each I

person entering an RPA (radiologically posted area) follow all applicable job related and safety related procedures and the radiation work permit (RWP).

l Radiation Protection Procedure BwRP 6200-5 (Revision 4), dated March 10,1997,

" Writing Radiation Work Permits," defines class 2 full set as coveralls, cap (optional),

l cloth hood, cotton glove liners, rubber gloves, cloth shoe covers, and rubber shoes.

A.

Radiation work permit 984318 (Revision 0), " Cut out laser templating, machine l

prep, weld RCS and channel head drain piping-SGRP. Include MOB / DEMOB l

PCI equipment," states that protective clothing required for work in dry l

contaminated areas less than 100K dpm/100cm'is class 2 full set. Special instructions included in the work permit include " removal of outer rubber gloves for making adjustments to the small components on the OD welding head is allowed provided loose contamination levels are less than SK, surgeon gloves are worn ender outer gloves, and the RP technician has been notified prior to making the adjustments".

Contrary to the above, on September 29,1998, an individual working under RWP 984318 performed adjustments to the welding head inside of containment, a dry contaminated area, and removed his rubber gloves and cotton liners without RP notification and approval.

B.

Radiation work permit 984014 (Revision 0), " Remove / replace insulation during outage," states that protective clothing required for insulation work in dry 2

contaminated areas less than 100K dpm/100cm is c' ass 2 full set.

4 Contrary to the above, on October 22,1998, two individuals working under RWP 984014 removed their outer rubber gloves while replacing insulation in j

containment, a dry contaminated area.

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l Notice of Violation This is a Severity Level IV violation (Supplement IV).

2.

Technical Specification 6.11 requires, in part, that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR Part 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.

Radiation Protection Procedure BwRP 6210-6 (Revision 3), dated December 15,1993, "Use of X-ray or sealed gamma radiation sources for the purpose of industrial radiopphy," states in step E.5, ensure that all unauthorized personnel are cleared from the posted radiography area prior to exposing the source and that they remain outside the area during the evolution.

Contrary to the above, on October 6,1998, the licensee failed to ensure that two workers, not authorized to be in a posted radiography area, were cleared from the area prior to exposing the source.

This is a Severity Level IV violation (Supplement IV).

For these violations, the NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence and the date when full compliance was acheved is already adequately addressed on the docket in Inspection Report Nos. 50-456/98015(DRS) and 50-457/98015(DRS).

However, you are required to submit a written statement of explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory CcTmission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region ill, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

If you cMose to respond, your response will be placed in the NRC Public Document Room (PDR). Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If j

personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal

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Notice of Violation -

privacy or provide the information required by 10 CFR 2.790(b) to support a request for with-holding confidential commercial or financialinformation). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.

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Dated this 13* day of November 1998 i

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