A97005, Forwards Response to Violations Noted in Insp Repts 50-295/97-09 & 50-304/97-09.Corrective Actions:Unsecured Hoses & Cords of Concern Secured According to Station Procedures

Forwards Response to Violations Noted in Insp Repts 50-295/97-09 & 50-304/97-09.Corrective Actions:Unsecured Hoses & Cords of Concern Secured According to Station Procedures

ML20140E100
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/05/1997
From:	Mueller J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-97-09, 50-295-97-9, 50-304-97-09, 50-304-97-9, ZRA97005, NUDOCS 9706110236
Download: ML20140E100 (7)

Text

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, rci a co a.20s i ZRA97005 l June 5,1997 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Attention: Document Control Desk- -- - - - - - - - -

Subject:

Commonwealth Edison Reply to Notice of Violation in NRC Inspection Report Number 50-295/304-97009; Zion Nuclear Power Station Units 1 and 2; ,

NRC Docket Numbers 50-295 and 50-304 l

Reference:

Letter to J. II. Mueller (Comed) from G. E. Grant (USNRC) dated May 6,1997, NRC Inspection Report 50-295/97009,50-304/97009 and Notice of Violation Gentlemen: )

By letter dated May 6,1997, the NRC cited Commonwealth Edison (Comed) as being in ]

violation of regulatory requirements. This letter and its attachment constitute omEd's reply to the referenced Notice of Violation in accordance with applicable regulations.

Comed acknowledges that problems concerning radiological work practices have not been effectively resolved at Zion Station. In that regard, efforts are being tmdertaken to increase oversight of radiation workers and intensify enforcement of accountability for poor radiological  !

work practices. Other efforts being taken are further described in Attachment A to this letter which provides the reasons for the violation, the corrective actions taken, and the date when full compliance was achieved.

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• ZRAd7005 Page 2 of 2 .

I Should you have any questions concerning this response, please contact. Robert Godley.of my ~

staff at 847-746-2084 extension 2900. i l

Sincerely, -

) , //.)) 1 2 .

l J.' H. Mueller

• Site Vice President Zion Nuclear Station I l

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Attachments cc: Regional Administrator, USNRC - Region 111 Senior Project Manager, USNRC - NRR Project Directorate 111-2 Senior Resident Inspector, Zion Nuclear Station j

- Office of Nuclear Facility Safety - IDNS  ;

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ATTACllMENT A to ZRA97005 Pageiof4 Reply To Notice Of Violation VIOLATION: 50-295(304)/97009-01 Zion Technical Specification 6.2.2.A requires, in part, that radiation control procedures be prepared and implemented, which are consistent with the requirements of10 CFR 20.

1. . Procedure ZRP 5721-6, " Construction of Radiological Posted Contaminated Areas and Step OffPad Areas," Revision 1, dated August 23,1994, requires, inpart, that cords and hoses - crossing contamination -boundaries -be -secured to prevent -the -spread of i contamination.

Contrary to the above, on March 24 - 26,1997, cords and hoses crossing contamination boundaries were not properly secured on the Auxiliary Building (AB) 617' elevation at the exitfrom the Fuel Building, the AB 592' elevation at the barrel compacting area and waste segregation area, the AB 579' elevation at the entrance to the crystalli:er, the AB 560' elevation near the laundry drain tanks, the AB 542' elevation at the mechanical maintenance department cage, and the Turbine Building Unit 1 steam tunnelin the Unit l 1 west valve house. (50-295/97009-01a; 50-304/97009-01a) l l

l 2. Procedure ZRP 5010-1, " Radiological Posting and Labeling Requirements," Revision 3, l dated August 30,1996, requires, in part, that the Tygon tubes associated with yellow containments have radiation tape or radioactive material markings to identify them as containing radioactively contaminated liquids.

Contrary to the above, on March 25, 1997, lygon tubing associated with yellow containments did not have radiation tape or radioactive material markings in the AB 592' elevation near the penetration air receiver IB: the AB 560' elevation near the evaporator l monitor deminerali:er OB, near the component cooling water pump OA, and outside of the instrument maintenance hot shop; and the AB 542' elevation near the blowdown -

monitor tankpump OB. (50-295/97009-01b; 50-304/97009-Olb)

3. Temporary Change TA-96-489 (dated August 20, 1996) to procedure ZRP 5721-5,

" Collecting, Laundering, Surveying, and Reissue Protective Clothing," Revision 1, dated January 12,1994, requires that personnel removing protective clothing containersfrom a l

job site use a calibrated survey instrument to survey each bag ofcontaminated clothing. ,

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l Contrary to the above, on March 25,1997, an individual removing protective clothing containersfrom the Fuel Building did not use a survey instrument to survey each bag of contaminated clothing. (50-295/97009-01c; 50-304/97009-01c)

This is a Severity LevelIV violation (Supplement IV).

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ATTACHMENT A to ZRA97005 Page 2 of 4

ADMISSION OR DENI AL TO TIIE VIOLATION Comed admits the violation.

EXAMPLES 1 and 2 REASON FOR TIIE VIOLATION The reason for these violation examples was the historical practice of Radiation Protection Department (RP) personnel correcting- radiological work practice problems-in -a manner that would not prevent recurrence. For example, Radiation Protection personnel would secure cords and hoses crossing contaminated areas boundaries that were found unsecured without contacting the applicable work group to correct the deficiency or establish accountability. As a result, radiation workers were not held accountable regarding strict adherence to the established radiation worker procedure requirements that they were trained on during Enhanced Radiation Worker Training prior to the 7.2R14 refueling outage.

A contributing cause to these violation examples was insufficient RP personnel oversight of radiation workets in the field. In addition, there was a failure to establish clear standards and expectations for proper set-up of catch containments.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACIIIEVED The unsecured hoses and cords of concern were secured according to station procedures.

The unlabeled catch containment drain tubing of concern was labeled according to the requirements of ZRP 5010-01.  ;

Walkdowns of the RPA were performed by multiple RP personnel. Radiological problems or l discrepancies identified during these walkdowns were corrected. l l

RP personnel were informed of a new Zion Station Policy Statement 1-30 " Radiation Worker I Accountability" and RP Department expectations for implementing the policy. Expectations  !

were communicated to make an effort to identify violators of significant station radiation worker j expectations, correct the problem, and restrict RPA access for the violators. I The Radiation Protection Department has implemented a program in which RP personnel are radiologically responsible for " zones" within the Auxiliary Building. The RP personnel are know a continuous point of contact and oversight and are directly responsible for work occurring i in their zone. Written expectations of their responsibilities have 1een provided by RP l management to the RP personnel monitoring the zones. The RP personnel monitoring the Auxiliary Building zones are responsible for the overall condition of their zone and expected to maintain " ownership" of the zone. Problem Identification Forms are expected to be generated for problems which are identified.

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NITACHMENT A to ZRA97005 Page 3 of 4

• 1 CORRECTIVE ACTIONS TO BICfAKEN TO AVOID FURTIIER VIOLATIONS I Radiation Protection Department will establish a program to set-up and control catch containments and enhance tracking and trending of catch containments. The establishment of this 4

program will be completed by June 29,1997.

, The Radiation Protection Department will perform an assessment of the effectiveness of the

" zone" coverage process described above for future enhancements and to determine if the 4

process needs to remain in eC r This assessment will be completed by December 31,1997. i DATE WilEN FULL COMPLIANCE WILL HE ACillEVED l l

Zion Station is currently in full compliance.

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l EXAMPLE 3 l

REASON FOR TIIE VIOLATION 1

The reason for this violation example was inadequate training for the Decontamination Technicians (DTs) with respect to the requirements of procedure ZRP 5721-5, " Collecting, Laundering, Surveying, and Reissue Protective Clothing." Specifically, on-the-job training provided for Decon Techs did not adequately include the radiological requirements of surveying each bag oflaundry at the job site prior to transfer when performing laundry collection tasks.

As a result, a DT inappropriately transferred a bag oflaundry from the Auxiliary Building (AB) elevation 617' to the transfer cart on AB 592' prior to performing a dose-rate survey. However, upon reaching the transfer cart on AB 592', the DT did perform a dose-rate survey of the laundry bag away from the job site within a few minutes of collecting the bag. The DTs were also using electronic dosimetry with audible dose-rate alarms to warn them of unexpected dose rates. ,

l CDERECTIVE ACTIONS TAKEN AND RESULTS ACIllEVED l Tailgate meetings were held with all shifts of Decon Techs. The meetings reviewed the circumstances surrounding this violation and the expectation for properly removing laundry from )

a contaminated area per the requirements of ZRP 5721-5.

An RP Technician performed a review of the laundry collection process and procedure with i I

Decon Techs in the field and revised procedure ZRP 5721-5 to enhance the process.

Radiation Protection Department revised the Radiation Work Permit (RWP) used by Decon Techs for laundry collection to include appropriate written expectations for laundry duties. The expectations were reviewed by Decon Supervisors in meetings with Decon Techs. Decon Techs j are also required to read and acknowledge the RWP revision prior to using the revised RWP. l

4 ATTACilMENT A to ZRA97005 Page 4 of 4 COikRECTIVE ACTIONS TO HE TAKEN TO AVOID FURTIIER VIOLATIONS To enhance the current on-the-job training process for Decon Techs, a structured task specific training program for Decon Techs will be developed. This task specific training program will be developed and implemented by July 15,1997.

DATE WIIEN FULL COMPLIANCE WILL BE ACHIEVED Zion Station is currently in full compliance.

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.o ATTACliMENT B to ZRA97005 PageiofI List of Commitments Identified in this Violation Response The following table identifies those actions committed to by Comed in this document.

Any other actions discussed is this submittal represent intended or planned actions by Comed. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.

Commitment Committed Date or Outage Radiation Protection Department will establish a program to set-up and June 29,1997 control catch containments and enhance tracking and trending of catch containments.

l The Radiation Protection Department will perform an assessment of the December 31,1997 effectiveness of the " zone" coverage process described in the corrective actions taken section of violation examples 1 and 2 for future enhancements and to determine if the process needs to remain in effect.

To enhance the current on-the-job training process for Decon Techs, a July 15,1997 structured task specific training program for Decon Techs will be developed and implemented.

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