ML17194A501

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Forwards IE Insp Rept 50-249/81-30 on 811211,18 & 31 & Notice of Violation.W/O Notice of Violation
ML17194A501
Person / Time
Site: Dresden Constellation icon.png
Issue date: 02/16/1982
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Reed C
COMMONWEALTH EDISON CO.
Shared Package
ML17194A502 List:
References
NUDOCS 8203030383
Download: ML17194A501 (3)


See also: IR 05000249/1981030

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FEB 1 6 1982

Docket No. 50-249

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Commonwealth Edison Company

ATTN:

Mr. Cordell Reed

Vice President

Post Office Box 767

Chicago, IL

60690

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Gentlemen:

This refers to the special safety inspection conducted by Messrs.

R. A. Paul and P. C. Lovendale of this office on December 11, 18 and 31,

1981, of activities at Dresden Nuclear Power Station, Unit 3, authorized

by NRC Operating License No. DPR-25, and an enforcement conference in the

Region III office on January 20, 1982.

The enclosed copy of our inspection report identifies areas examined

during the inspection, which was conducted to examine the circumstances of

a potential personal overexposure.

The inspection consisted of a selective

examination of procedures and representative records, observations, inde-

pendent measurements, and interviews with personnel.

During this inspection, certain of your activities appeared to be in non-

compliance with NRC requirements, as specified in the enclosed Appenqix.

A written response, submitted under oath or affirmation is required.

The inspection showed that workers were unknowingly allowed to work in an

area containing radiation levels exceeding 100 millirem/hour.

Your surveys

and high radiation area controls were ineffective in preventing this occur-

rence.

Additionally, evaluation of the workers' dosimetry devices was

deficient in that the workers were allowed to work in the same area a

second day even though their pencil dosimeters were offscale the first day.

We consider these items to be particularly significant and we considered

classifying them as Severity Level III violations due to the potential for

exceeding the quarterly personal exposure limits.

Only after careful con-

sideration of mitigating circumstances did we conclude that they were more

appropriately classified at Severity Level IV.

However, further similar

occurrences may lead to escalated enforcement action .

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FEB 1 6 1982

Commonwealth Edison Company

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We consider the breakdown in management controls which allowed these un-

planned exposures to occur to represent serious programmatic weaknesses in

your radiation protection program.

These concerns were discussed with you

during an enforcement conference at the Region III office.

Although the

corrective actions you proposed during the enforcement conference generally

represent positive steps to resolve our concerns, additional actions appear

needed to correct the high radiation area control inadequacy which contrib-

uted to the unplanned exposures.

In your response to the noncompliances,

you should address specifically the following matters:

(1) special work

permit (SWP) implementation, (2) expanded self-reading dosimeter use, (3)

routine SWP surveillance by RCTs, (4) unauthorized shielding movement by

workers, and (5) high radiation area controls.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of

this letter and the enclosed inspection report will be placed in the NRC's

Public Document Room.

If this report contains any information that you (or

your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4),

it is necessary that you (a) notify this office by telephone within ten (10)

days from the date of this letter of your intention to file a request for

withholding; and (b) submit within twenty-five (25) days from the date of

this letter a written application to this office to withhold such information.

If your receipt of this letter has been delayed such that less than seven (7)

days are available for your review, please notify this office promptly so that

a new due date may be established.

Consistent with Section 2.790(b)(l), any

such application must be accompanied by an affidavit executed by the owner of

the information which identifies the document or part sought to be withheld,

and which contains a full statement of the reasons which are the bases for the

claim that the information should be withheld from public disclosure.

This

section further requires the statement to address with specificity the con-

siderations listed in 10 CFR 2.790(b)(4).

The information sought to be

withheld shall be incorporated as far as possible into a separate part of the

affidavit.

If we do not hear from you in this regard within the specified

periods noted above, a copy of this letter and the enclosed inspection report

will be placed in the Public Document Room.

The responses directed by this letter (and the accompanying Notice) are not

subject to the clearance procedures of the Office of Management and Budget

as required by the Paperwork Reduction Act of 1980, PL 96-511 .

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Commonwealth Edison Company

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~EEB 1 6 1982

We will gladly discuss any questions you have concerning this inspection.

Enclosures:

1.

Appendix, Notice

of Violation

2.

Inspection Report

No. 50-249/81-30 DETP

cc w/encls:

Louis 0. DelGeorge, Director

of Nuclear Licensing

D. J. Scott, Station

Superintendent

DMB/Document Control Desk (RIDS)

Resident Inspector, RIII

Mary Jo Murray, Office of

Assistant Attorney General

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RIII

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Lovendale

RIII

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Greger

2/3/82

Sincerely,

Original signed by

.James G. Keppler

James G. Keppler

Regional Administrator

RIII I

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Walker

RIII

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