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| * / \ C mm:nw alth Edis:n i _. / ' 1400 Opus Placs
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| \V) Downers Grove, Illinois 60515 April 11,1994 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk
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| ==Subject:==
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| Quad Cities Power Station Units 1 and 2; NRC Docket Number 50-254 and 50-265; NRC Inspection Report Numbers 50-254(265)/94002
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| ==Reference:==
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| Edward G. Greenman letter to R. Pleniewicz dated March 11,1994, transmitting Notice of Violation.
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| Inspection Report 50-254/94002; 50-265/94002 Enclosed is Commonwealth Edison's response to the Notice of Violations concerning failure to control high radiation area boundaries and contaminated material and equipment.
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| The following commitments are being made by this letter:
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| : 1) The station will establish a centralized toolissue and storage facility inside the RPA by December 31,1994.
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| If there are any questions or comments concerning this letter, please refer .
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| them to Marcia Jackson, Regulatory Performance Administrator at (708) 663-7287 Respectfully, m
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| z[ &! N 'h: . WhWI)C* .
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| D. L. Farrar, Manager 3/ Nuclear Regulatory Services !
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| Attachment \ j cc: J. Martin, Regional Administrator, RIII
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| - C. Patel, Project Manager, NRR C. Miller, Senior Resident Inspector, Quad Cities K:rpatinreprts: quad:vio9400211 940414o3o3 940411 l1 PDR ADOCK 05000254 I Q PDR l i
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| i QUAD CITIES STATION l RESPONSE TO NOV 50-254(265)/94002 i
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| VIOLATIONS:
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| Technical Specification 6.12.1.a requires that high radiation areas greater than 100 millirem /hr (1 millisievert/hr) (mSv) but less than 1000 millirem /hr (10 mSV/hr) -
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| be barricaded and conspicuously posted as a high radiation area and areas greater than 1000 mrem /hr be provided with locked doors and controlled to prevent unauthorized entry. !
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| Contrary to the above, a high radiation area greater than 100 mrem /hr but les's than 1000~ mrem /hr was not barricaded and conspicuously posted as a high radiation area and an area greater than 1000 mrem /hr was not provided with a:
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| locked door and controlled to prevent unauthorized entry. Specifically: -
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| a) on August 14,1993, an access door to an area greater than 1000 mrem /hr, near the main condenser tube pull pit area was unlocked, and b) on November 25,1993, a door leading into the backwash receiving tank room, an area greater than 100 mrem /hr but less than 1000 mrem /hr, was propped open.
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| This is a Severity Level IV violation.
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| REASON FOR THE VIOIATION:
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| CECO acknowledges and agrees with the violation. The cause of the events were due- )
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| to inattention to detail by the station workers.
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| * CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED: ,
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| a) The subject door was immediately locked and all other doors in the Turbine building were verified. Additionally, the station performed a daily verification I of all doors for a period of 10 days, b) The backwash receiving tank room door was closed and an additional barrier ,
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| was erected.
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| f kirpa:Insprts: quad:vio94002:2
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| QUAD CITIES STATION RESPONSE TO NOV 50-254(265)/94002 1
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| CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:
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| The station has revised procedure QCAP 620-1, "High Radiation Area Access" which requires dual verification oflocked doors upon exit. -.
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| Warning signs were posted on the inside of the subject doors instructing workers to .
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| verify door is locked.
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| The station is evaluating the use of additional swing gates as a dual barrier.
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| The Health Physics department will develop and provide a training package to the d department heads for presentation to all department personnel for reinforcing-station / management expectations for the control of High Rad doors.
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| The station is having Corporate HP perform a Root Cause analysis of the Hi-Rad !
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| door event trends. Additional corrective actions (if any) will be reviewed and implemented as required upon completion of the analysis.
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| Note: Since the issue of this NOV, the station h'as experienced two additional Hi- ,
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| Rad door events. One of the events was due to mechanical failure (sticking) of the q swing gate and not due to any human error / inattention.' The station is investigatmg i the cause and solution to this problem. The second event was attributed to 'I inattention, however the use of dual barriers will prevent this from occurring. The !
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| individual involved in the second event immediately identified the problem and j notified the station of the problem. The station is currently conducting an.
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| investigation of the event through the station's Problern Identification process (PIF- )
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| 94-0789). !
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| DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:- g Full compliance was achieved when the doors were locked and verified.'
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| 4 kirpa:insprts: quad:vio94002t3
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| QUAD CITIES STATION .;
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| RESPONSE TO NOV j '
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| 50-254(265)/94002 V!OLATIONS:
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| Technical Specification 6.3. requires that radiation protection procedures be' established, maintained, and adhered to.
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| Quad Cities Radiation Protection Procedure (QRP) 1000 requires, in part, that :
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| material leaving the radiologically controlled area be surveyed before release to ensure that radioactive material is not being released. ,
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| Contrary to the above, on January 7,1994, and on several other occasions in .
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| 1993, contaminated tools and equipment were not surveyed before release from-the radiologically controlled area. ,
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| This is a Severity Level IV violation.
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| R.EASON FOR THE VIOLATION:
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| CECO acknowledges and agrees with the violation. The cause of tho' events were due -
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| to inattention to detail by the station workers.
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| CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED: !
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| The material was transferred to the appropriate storage areas. Additional surveys of the affected areas were performed. ',
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| CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION: l The station is in the process of establishing a centralized tool issue and storage facility inside the radiological posted area (RPA). This will be in-place by December 31,1994. Until the facility is established the station will implement an interim procedure on tool control inside the RPA, The interim ;
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| procedure will be implemented by April 30,1994.
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| The station has erected a LTD (Laundry / Tool Decon) building designed to handle hotshops and laundry inside the radiological posted area (RPA). l k:rpasinsprtsiquadivio94002:4 a
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| QUAD CITIES STATION RESPONSE TO NOV-50-254(265)/94002 The Health Physics department will develop and provide a training package to the department heads for presentation to all department personnel for reinforcing station / management expectations for the control of material leaving a Radiological Posted Area (RPA)..
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| DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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| -Full compliance was achieved when the subject tools / materials were transferred to the appropriate storage areas.
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