ML20056A703

Responds to NRC Re Violations Noted in Insp Repts 50-373/90-13 & 50-374/90-14.Corrective actions:LRP-1250-3 Revised to Include Addl Requirement for Extremity Monitoring

ML20056A703
Person / Time
Site:	LaSalle
Issue date:	07/27/1990
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9008090060
Download: ML20056A703 (3)

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v Hr. A.-Bert Davis l Regional-Administrator

-U.S. Nuclear Regulatory. Commission Region IIIl

-799 Roosevelt Road j Glen Ellyn, IL 60137 i

Subject:

LaSalle County Station O' nits 1 and 2 Response to Inspection Report Hos.

50-373/90013 and 50-374/90014 t EC Docket Nos. 50-373 and 50-374 I

Reference:

(a) C.E. Norellus letter to C. Reed x dated June 28, 1990.

Dear'Mr. Davis:

This ' letter is in response to a meeting held with members of your i

Staff and representatives from Commonwealth Edison's Corporate Office and LaSalle County Station. This meeting was held at Region III offices on June

' 18 ~,' 1990 with the purpose.to discuss the radiological conditions in radwaste i l

' tank rooms at=LaSalle Station.

p 1 Reference (a) indicated that certain activities appeared to be in violation of NRC requirements.

1' The Commonwealth Edison response to the Level IV Notice of Violation i is provided in the following attachment.

If-there are.any questions or comments regarding this matter, please contact-this office.

e Very truly yours, ,

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T.J. ovach Nuc1 ar Licensing Manager 9008090060 900727 r~s g'DR ADOCK 05000373 PDC

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0001Sa Senior Resident Inspector - LSCS b

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, CQHMONHEALTH EDISON RESPONSE TO NOTICE OF VIOLATION

.r y10L& TION: IR 3D/9_0013-01 and 50-374/9Q014d1 10 CFR 20.101(b) requires etsn licensee make or cause to be made such surveys as (1) may be necessary to comply with the regulations in this part.

and (2) are reasonable under the circumstances to evaluate the extent of.

radiation hazards that may be present. 10 CFR 20,201(a) defines a survey as an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions. 10 CFR 20.201(b) specifies the dose limits applicable to individuals in restricted areas.

Contrary to the abovsf during the week of April 22, 1990, the licensee did not conduct an adeluate evaluation to determine radiological conditions associated with floor contamination before allowing worker entry onto the contaminated floor, nor were workers provided with extremity monitoring devices to measure dose to the lower extremities caused by the floor contamination.

DISCUSSLON While a radiological survey was performed to support the work during the week of April 22, 1990, it was not detailed enough to clearly demonstrate the dose gradient between near floor level and general area dose rates.

Because of the high general area dose rates and the fact that the floor was recognized as being a plane source causing the elevated general area dose rates, the procedures in place at the time did not require extremity monitoring. At the time of occurrence, LaSalle County Station's LRP-1250-3,

" Personnel Dosimetry Placement Guidelines" required extremity monitoring if contact dose rates were greater than 1.5 times the whole body dose rate and the whole body dose equivalent was gieater-than 200 mrem. Since contact dose rates in the room did not exceed the i.5 factor, extremity monitoring was not required.

CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED On May 4, 1990, following an evaluation of the radiological hazards in the Radwaste Tank room by the Health Physics Services Supervisor and the-Radiation Protection personnel involved in controlling and monitoring the work in the area, a subsequent entry was made into the room. This entry was made with personnel wearing extremity dosimeters in addition to whole body

. dosimeters. The results of this entry did not indicate an exposure difference between the two locations greater than thirty percent. A survey was performed on July 18, 1990, in the tank room prior to cleaning the floor and indicated a uniform dose rate field. The dose rate measurements between the ankle, knee and chest did not vary. These actions provide assurance that no actual overexposures occurred as a result of the earlier entries.

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, CORRECTIVE ACTION TAKEN TO AVQ1D_fijRitlER ylDIAIJON r

LRPi1250-3 has been revised to include an additional requirement for:

extremity monitoring, :The revised procedure now requires that when' contact dose rates ~ exceed 100 mrem per hour and with the extremity submersed in the source, extremi.ty monitoring will'be required. The Radiation ProtectQn Department was ta11 gated on the event where emphasis was given to the procedure revision, acceptable survey techniques and required documeAW lon.

Radiation. Protection Technician continuing training will include a review of  ;

this event with. emphasis given to documenting survey results, '

DkTE OF FULL COMPLIANCE.

Radiation Protection Technician-continuing training will be completed by.  !

September 28, 1990, y

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