ML17194A501
| ML17194A501 | |
| Person / Time | |
|---|---|
| Site: | Dresden |
| 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
Text
..
-
-~ "J*
FEB 1 6 1982
Docket No. 50-249
\\
Commonwealth Edison Company
ATTN:
Mr. Cordell Reed
Vice President
Post Office Box 767
Chicago, IL
60690
P.: c;'. :~~ :. */ /,*:: ;:;,
~rnR* ~
\\. _,
. '.1.lii
~':;;
190?:::-. 1*--.-*
[*'"'"
O~ ""'~
~" Jtit-.1.a._J f':" ~-wr
' ..... _
lJC!1t
1I~D1tr~ ~~:.:}. ;/? plr~~:*:,:;*~~/~; !! *~"'
\\,->
ii'[;(:'-"'" I: ~:i /<;fj
')'),....
/\\ .. '.
1,~ ,.___/
I _____.*( \\ f~-'
\\)
'
I
\\
.
I~
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 .
'1:>1-10:
TEo(,
s 0
I
'
FEB 1 6 1982
Commonwealth Edison Company
- 2 -
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
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 .
..
Commonwealth Edison Company
- 3 -
~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
RIIL/
~/so
RIII
fV"r.
Lovendale
RIII
'-f~~
Greger
2/3/82
Sincerely,
Original signed by
.James G. Keppler
James G. Keppler
Regional Administrator
RIII I
~(t'ltr
Walker
RIII
\\..u~ r~
Warnick
'l. ~ 1\\-"b 'L