ML20203C258
| ML20203C258 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/13/1998 |
| From: | Dacimo F COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-97-21, 50-374-97-21, NUDOCS 9802250127 | |
| Download: ML20203C258 (4) | |
Text
_.
O,moninw r.mh I divin < ompany lealle (.rneratmg station
{
.n.oi sonn ns: m.aa u.,rse,nn n <, n,i.rs-n i y n m<n.i February 13,1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Notice of Violation; NRC Inspection Report 50-373/374-97021 LaSalle County Statior Units 1 and 2 Facility O[.erating License NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Reference:
J. A. Grobe letter to O. D. Kingsley, dated January 21,1998, Transmitting NRC Inspection Report 50-373/374-97021 The enclosed attachment contains LaSalle County Station's response to the subject Notice of Violation, that was transmitted in the Reference letter, if there are any questions or comments conceming this letter, please refer them to Perry Bames, Regulatory Assurance Manager, at (815) 357 6761, extension 2383.
Respectfully,
/
j Q V Fred R. Dacimo
' Site Vice President LaSalle County Station
/
5 Enclosure
,/10 cc:
A. B. Beau., NRC Region 111 Administrator M. P. Huber, NRC Senior Resident Inspector - LaSalle D. M. Skay, Project Manager - NRR - LaSalle
$0
$DN
[3
\\\\I. \\b\\,!I\\,
ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-97021 VIOLATION: 373/374-97021-01 As a result of an inspection conducted on December 15 - 17,1997, a violation of NRC requirements was identified. in accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG-1600, the violation is listed below:
Technical Specification No. 6.2(B) requires that radiation control procedures be maintained, made avaitchis to station personnel, and adhered to.
Station Procedure LAP 100-?2 (Revision 20)," Radiation Work Permit (RWP)
Program," requires, in puA that individual workers comply with the requirements of the RWP and any associated documents.
Radiation work permit No. 070325 (Revision 3), " Setup, Remove Ovi Pumps / Piping, Reinstall New Design Pumps / Pipes and Cleanup of Area,"
requires that workers contact the radiation protection staff before performing welding, cutting or grinding on system components.
Contrary to the above, on November 21 and December 1,1997, contract workers were signed onto RWP No. 970325 and performed cutting / grinding and welding activities on reactor water cleanup system piping, respectively, and failed to contact radiation protection prior to performing the activities.
This is a Severity Level IV violation (Supplement IV).
REASON FOR VIOLATION: 373/374-97021-01 The November 21,1997 incident was the result of poor work practices on the part of the contract workers. The workers had successfully completed similar work activities earlier, and may have become complacent with the work.
For the December 1,1997 incident both workers were aware of the requirement to contact Radiation Protection (RP) prior to welding but failed to do so. In apparent haste to complete the job prior to the end of the shift, the workers failed to make the notification to RP staff as required by procedure.
The corrective actions implemented after the November 21,1997 incident were being followed during the December 1,1997 incident. However, these actions would not prevent individuals, who are aware of the requirement, from deciding on their own, to bypass those requirements.
1
~
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
For the November 21,1997 incident:
Work on the reactor water cleanup (RWCU) modification and work on other contaminated components was stopped. A prompt inveatigation was performed.
All workers under RWP No. 970325 on elevation 761' were gathered together and this incident was discussed with them in detail to heighten their awareness and stress communication between work groups.
Appropriate disciplinary action was implemented for the workers involved.
A checklist was developed for use by the Construction Department, as a guideline to assure that important information is discussed with contract workers during pre-job briefings for high risk activities. The checklist was incorporated into Maintenance Memo No. 0200-2A.
Radiation Protection participation in pre-job meetings was expanded for the RWCU work, including work crew specific breakout sessions with the RP Technicians providing coverage for the pending shift work.
For the December 21,1997 incident:
Work on the RWCU modification was stopped. A prompt investigation was performed.
Appropriate disciplinary action was implemented for the workers involved.
This event 'was discussed and proper radiation worker practices were reviewed with the appropriate contract workers on December 1 and 2,1997, prior to their admi+tance to the radiation protection area.
The Station Communication Topics for the Week of December 8,1997, included a review of this event. Each Station Department reviewed the Communication Topic during weekly department meetings. The lessons leamed from this event were stressed in this weekly review.
l j
2
~
CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
The Station trenc'c lower level radiation worker practice deficiencies. As a result of recent trends, a root cause investigation has been initiated.
(NTS 373-230-98 SCA000003.00). The investigation is expected to be completed by March 18,1998. Necessary actions will be taken based on the investigation results.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on December 2,1997, following the communication meetings with the contract workers prior to their re-entry to the radiation protection area.
a 3
..