ML20058A890

Discusses Safety Insp Rept 50-374/93-25 on 930908-14. Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $112,500 Encl

ML20058A890
Person / Time
Site:	LaSalle
Issue date:	11/17/1993
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wallace M COMMONWEALTH EDISON CO.
Shared Package
ML20058A893	List: ML20058A890 ML20058A898
References
EA-93-235, NUDOCS 9312010290
Download: ML20058A890 (6)

See also: IR 05000374/1993025

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November 17, 199?

Docket No. 50-374

License No. NPF-18

EA 93-235

Commonwealth Edison Company

ATIN:

Mr. Michael J. Wallace

Vice President,

Chief Nuclear Officer

Executive Towers West 111

1400 Opus Place, Suite 300

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Downers Grove, IL 60515

Dear Mr. Wallace:

SUBJLCl:

LASALLE COUN1Y STATION - UNIT 2

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL

PENALTY - 5112,500

(NRC INSPECTION REPORT NO. 50-374/93025(DRSS))

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This refers to the special safety inspection conducted during the period of

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September 8 through 14, 1993, at LaSalle County Station, Unit 2.

The purpose

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of the inspection was to review a significant radioactive' contamination event

which occurred during reactor vessel disassembly on September 7,.1993.

The

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report documenting this inspection was'sent to you by letter dated September

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27, 1993.

During the inspection, violations of NRC. requirements were

identified.

An enforcement conference was held on October 5,'1993, to discuss the apparent

violations, their causes and your corrective actions.

The report summarizing

the conference was sent to you by letter dated October 13, 1993.

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On September 7, 1993, three crews (eight workers) were assigned to the Unit 2

reactor cavity to disassemble the reactor vessel head with pneumatic tools. A

pre-job meeting which included the maintenance foreman, workers and three

radiation protection technicians (RPIs) assigned to cover the job was. held.

However, the discussion of radiological controls was limited.

Initially, two

RPIs were covering the job from the refueling floor.

The RPIs did not enter

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the cavity and air sampling of the reactor cavity was not performed.

Even

though contamination levels exceeded. 100,000 dpm/100cm2 _in what should have

been considered the work area, the workers were not wearing respirators as

required by procedure for work areas with such. contamination levels.

In

addition.. engineering controls were not used.to limit airborne radioactivity

in the cavity.

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A third RPT relieved one of the RPIs (RPT #1) on the refueling floor, and

noticed that one of two continuous air monitors on the floor was alarming.

About the same time, RPT #1 notified the refueling floor that his face was

contaminated. Operations had previously secured the Unit 2 Reactor Building

ventilation system to perform a scheduled surveillance approximately 15

minutes earlier.

CERTIFIED MAIL

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RETURN RECElf REQUESTED

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The workers were notified and exited the refueling iscor, and the refueling

floor coordinator requested Operations to restart the ventilation system.

Shortly thereafter, contamination was detected in various levels of the Unit 2

reactor building due to air flow through gaps in the refueling floor equipment

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hatch.

In total, 22 workers were contaminated during the event,17 of whom

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received mear.urable intakes of radioactive material .

Three violations were identified as described in the enclosed Notice of

Violation and Proposed Imposition of Civil Penalty (Notice).

The violations

involve: (1) failure to adequately evaluate the job and make necessary surveys

of the reactor cavity while the job was in progress; (2) failure to use

engineering controls to limit airborne radioactivity in the reactor cavity;

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and (3) failure of the workers to wear respirators in accordance with

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radiation protection procedures.

The root causes of the event included inadequate planning which resulted in

the failure to adequately evaluate the radiological hazards associated with

the reactor vessel disassembly.

The ALARA review for the job was cursory and

did not consider the potential changing radiological conditions in the cavity.

There was a clear lack of management and first line supervisory oversight of

the RPTs.

Contributing factors included ineffective training of the RPIs and

radiation workers, the lack of a questioning attitude of RPIs and workers

concerning the work environment, poor communications, a lack of understanding

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of how the reactor building ventilation system's operation affects

radiological conditions, and an inadequate review of Information Notice 92-75.

The root causes of this event are similar to those associated with the failure

to make appropriate surveys which resulted in administrative overexposures on

December 17, 1991 (EA 92-003).

Your corrective actions documented in your.

February 1992 response to the enforcement conference and Notice of Violation-

were ineffective in preventing recurrence, and a lack of management

involvement allowed inconsistent performance of'the radiological controls

program to persist.

I am particularly concerned because I brought to your

attention at the August 20, 1993, public Systematic Assessment of Licensee

Performance (SALP) meeting, clear precursors of poor radiation protection

program performance.

These included the lack of management and supervisory.

oversight illustrated by the station Radiation Protection Manager not entering

-the radiologically controlled area during the first eight months-of 1993,

rece_nt radioactive waste spills, and continued observations'of poor radiation

worker _ performance,

fu thermore, we are concerned'that performance after this event has'~ continued

I poor.- ' Specifically, we continue to seel disturbing radiation protection

wirk practices during our plant tours, including two cases of radiation

workers not following specific' job instructions to contact radiation--

protection before commencing work.

We are concerned that this continuing' poor

performance may stem from your underestimating the depth and breadth of the

underlying problems as illustrated by what appeared to be an overly optimistic

portrayal of the present situation at the enforcement conference.

It appears

that-the continuing problems are due, in part, to. poor individual performance

by RPTs and other radiation workers; these problems raise fundamental

questions about the attitude of station workers'towards radiation hazards.

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Commonwealth Edison Company

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November 17, 1993

This situation requires sustained and intensive management oversight and

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involvement in radiation work activities.

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We acknowledge your corrective actions for the violations, which included but

were not limited to: implementation of the lead technician program for the

refuel floor by a qualified manager, ensuring continuity is provided when new

programs are implemented, conducting one-on-one discussions with the RPTs to

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review the event and management expectations, developing an administrative

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controls guide for the refuel floor, reconsidering the need for localized

ventilation units during reactor vessel disassembly, and extensive actions to

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address programmatic and radiation orotection attitude issues.

However, we

are concerned that you apparently underestimated the scope of the problems

that you face, your training initiatives were not sufficiently comprehensive

in that no feedback mechanism was included to assess effectiveness, and you

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did not address improvements for reviewing NRC information notices.

We recognize that the radiation doses received by the workers during the event

were within regulatory limits.

Nevertheless, based on the concerns discussed

above, the violations are classified in the aggregate as a Severity Level Ill

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problem in accordance with the " General Statement of Policy and Procedure for

NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C.

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To emphasize the need for management involvement an' - ersight of the

radiation safety program, I have been authorized I". . consultation with the

Director, Office of_ Enforcement, to issue the enclosed Notice of Violation and

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Proposed Imposition of Civil Penalty (Notice) in the amount of $112,500 for

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the three violations that constitute a Severity Level Ill problem. . The base

value of a civil penalty for a Severity Level III problem is $50,000. Tho

civil penalty adjustment factors in the Enforcement Policy were considered,

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-The base civil penalty was mitigated 25 percent because.your staff

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demonstrated initiative in identifying the root causes of the violations

resulting in. this self-disclosing event.

In particular, the immediate actions

of the involved radiation protection personnel in pursuing the initial

indications of the problem demonstrated a questioning attitude.

The base

civil. penalty was not~ mitigated for your corrective actions because we had

concerns in this area, as discussed above,

lhe base civil penalty was escalated 50' percent for your poor past

. performance. A number of problems ~ have been identified in the last two years

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including a. contaminated area posting being cut down and discarded (8/93),

three liquid radioactive waste spills which~ resulted in the signif.icant spread

of contamination (6/93 and 8/93), a violation'for workers not adhering.to a

radiation work permit'(11/92), and the administrative overexposures discussed

above (12/91),

The base civil penalty was escalated 100' percent for prior opportunity to-

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identify. - NRC Information Notice' 92-75 was issued in November 1992 and .

alerted licensees to enplanned personnel intakes of radioactive materials

because of inadequate radiological, engineering, and procedural controls for

contaminated areas.

The Information. Notice emphasized the need for vigilance

.in conducting maintenance activities that could significantly increase

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November 17, 1993

airborne radioactive material.

Furthermore, as noted earlier, clear

precursors of poor radiation protection program performance were brought to

your attention at the SALP meeting.

The other adjustment factors in the Policy were considered and 60 further

adjustment to the base civil penalty is considered appropriate.

Therefore,

based on the above, the base civil penalty has been increased by 125 percent.

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You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In your

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response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence.

After reviewing your response to this

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Notice, including your proposed corrective actions and the results of future

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inspections, the NRC will determine whether further NRC enforcement action is

nece.ssary to ensure compliance with NRC regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of

this letter, its enclosure, and your responses will be placed in the NRC

Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

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to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, Public Law No.96-511.

Sincerely,

Original Signed By

John B. Martin

Regional Administrator

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Enclosure:

Notice of Violation and Proposed

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Imposition of Civil Penalty

See Attached Distribution

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November _17, 1993

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Distribution:

cc w/.,iclosure:

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L. DelGeorge, Vice President,

Nuclear Oversight and Regulatory

Services

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W. Murphy, Site Vice President

J. Schmeltz, Acting Station Manager

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J. Lockwood, Regulatory Assurance

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Supervisor

D. ~ f arrar, Nuclear Regulatory

Services Manager

OC/LFDCB

Resident inspectors, LaSalle,

Clinton, Dresden, Quad Cities

R. Hubbard

J. .W.

McCaffrey, Chief, Public

Utilities Division

Licensing Project Manager, NRR

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R. Newmann, Of fice of Public Counsel-

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State liaison Officer

Chairman, Illinois Commerce

Commission

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