A97047, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-20 & 50-304/97-20.Corrective Actions:Will Develop, Document & Issue Written Expectations Which Enhance Surveying & Posting Contaminated Areas by 971124

Responds to NRC Re Violations Noted in Insp Repts 50-295/97-20 & 50-304/97-20.Corrective Actions:Will Develop, Document & Issue Written Expectations Which Enhance Surveying & Posting Contaminated Areas by 971124

ML20217F532
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/25/1997
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-97-20, 50-304-97-20, ZRA97047, NUDOCS 9710080272
Download: ML20217F532 (9)

Text

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. ZRA97047 September 25,1997 U S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk Subjeet: RESPONSE TO NOTICE OP VIOLATION NRC Inspection Report No. 50 295/97020(DRS),50 304/97020(DRS);

Zion Generating Station, Units 1 & 2; NRC Docket Numbers 50 295 and 50 304

Reference:

Letter to J.11. Mueller (Comed) from O. E. Grant (USNRC), dated August 26,1997, transmitting "NRC Routine Radiation Protection Inspection Report 50 295/97020(DRS),50 304/97020(DRS)and Notice of Violation" Gentlemen:

Dy letter dated August 26,1997, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. This letter and its attachments constitute Comed's reply to the referenced Notice of Violation in accordance with applicable regulations.

As stated in the above referenced Notice of Violation (page 2), violation item 1 (50-295(304)/9'iO20-01) was adequately addressed in Comed's July 11, 1997 letter from J.11.

Mueller to the NRC, which responded to NRC Inspection Report No. 50 295(304)/97002 (DRP),

and therefore, is not addressed in this response, in regard to previous events tha' have included loss of liigh Radiation Area (llRA) access control, missed radiation monitor surveillances, and improper configuration control of radiation //

monitoring equipment, the inefTectiveness of corrective actions taken to dme was primarily due //

to inadequate program controls, inadequate organizational accountability, ineffective root cause detenninations, and acceptance oflow standards of perfonnance.

7 my in response, the Radiation Protection (RP) department has assigned a senicr individual within that department to maintain single point accountability for llRA access control and strergthen management oversight. This includes limiting IIRA key control issuance to qualified RP technicians and operators, and revising appropriate procedures (as necessary) to clearly define roles and responsibilities of individuals controlling HRA access. Additionally, RP has established clear guidelines and accountability for configuration contial of radiation monitoring equipment.

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4 7.RA97047 Page 2 0f 2 Further, in order to improve root cause evaluations and raise RP department standards, the l Radiation Protection Manager has placed on stafTseveral persons trained in root cause evaluation  !

techniques, and has instituted a self assessment program for the department. Additionally, the RP Manager has created the riew position of Corrective Action Coordinator within the <

department. This indjvidual reports directly to the RP Manager, and is responsible for tracking l and trending radiological performancc, ensuring plant personnel awareness with previous events,  ;

and establishing stet!on performance indicators for senior management review, Should you have any questions concerning this response, please contact Robert Godley, Zion i Station Regulatory Assurance Manager,at(847)746 2084, ext 2900..  ;

Sincerely,

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_ ohn C,13rons  !

I Site Vice President

Zion Generating Station 1

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cc: Regional Adm'nistrator, USNRC - Region 111

Senior Project Manager, USNRC NRR Project Directorate 1112

NRC Senior Resident Inspector. Zion Generating Station j Office ofNudear Facility Safety IDNS 4

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• i ATTACllMENT A to ZRA97047 l' age i of 6 .

ATTACilMENT A RESPONSE TO NOTICE 01: VIOLATION IN l NRC INSPECTION REPORT 50 295/97020(DRS); 50 304/97020(DRS)  ;

t VIOLATION (50-295004)/97020-03.-04):  !

I h chnical Spec @ cation 6.2.1 requires that written procedures be implemented covering  :

the applicable procedures recommended in Appendix A ofRegulatory Guide (RG) 1.33, l

Revision 2.

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a. Appendix A ofRG 1.33 recommends procedures covering contamination control be implemented.

Procedure ZRP 3010-1, " Radiological Posting and Labeling Requirements," '

revision 4, requires that areas, which have removable beta gamma contamination at levels greater than or equal to 1000 disintegrations per minute (dpm) per 100 em', be postea " Caution. Contaminated Area. "

Contrary to the above, on July 30,1997, areas within the Units 1 and 2 containment spraypump rooms, which had removable beta gamma contamination ,

at levels of1000 to 3000 dpm/100 cm', were not posted " Caution, Contaminated  :

Area. " i i

b. Appendix A ofRG 1.33 recommends that c 'ocedures covering equipment control be implemented. _

Procedure ZAP 300-1, "Cominct ofOperations," revision 4, provides instructions concerning equipment control and states that the operations department has the  !

responsibility and authority over allplant systems and equipment, except as  ;

stated in Station Policy 2-11, " Configuration Control. "

Station Policy 2-11, "Cortfiguration Control," dated April 7,1997, states that plant equipment may be operated bypersonnel outside oftheir operational authority if(1) the work was part ofa work request task or Out-Of Service Request Principle or_ (2) the manipulation is controlled by an applicable procedure or work Instruction that requir es or provides a record ofspecified Irtformation including the licensedshift supervisor determination ofthefinal position / state.

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ATTACllMENT A to 7.RA97047 Page 2 of 6

. Contrary to the above. on July 14, I997, a member ofthe radiation protection staffmanljndated a radiation monitor (2Rht.PRRI) trilhout an applicable notk request, out of servlee request, procedure, or work instruellon whlehfu0llied the

, requirements ofStation Polley 211.

j This is a Severity Level 18' violation (Suptdement II').

kltidplon or Denial of the Violation

Comed admits the vbaaon.

- VIOI.ATION EXAMPI,E At Reason for the Violation 2

The reason for this violation example is the failure of llealth Physics personnel to

aggressively identify potential sources of contamination. Further, Radiation Protection (RP) management failed to clearly communicate expectations to llealth Physics personnel for identifying potential sources of contamination. Existing RP procedures provide j adequate guidaace for action when contamination is found or suspected. This issue was one of not aggressively seeking out potential sources of contamination, i Corrective Steps Taken and Results Ach_lgnd The contaminated areas within the Units 1 and 2 containment spray pump rooms have been properly posted as a contaminated area. At the time this violation was identified, other areas of the Radiation Protection Area (RPA) were walked down by RP personnel in order to verify compliance with contaminated area posting requirements. The walkdown did not identify any other areas that were not in compliance with the contaminated area posting requirements. Further, Radiation Protection management has clearly communicated to RP personnel the expectations for identifying potential sources ofcontamination.

1 Corrective Steps That Will be Taken to Avoid Further Violations i

Radiation Protection will develop supplemental expectations to enhance surveying and posting contaminated areas, with specific attention to identifying potential sources of contamination; e.g., boron encrusted valves /cyaipment, leaking pumps, seals, valves, etc.

These supplemental written expectations will be deseloped, documented and issued by November 24,1997.

4 Date When Full Compliance Will be Achieved Zion Generating Station is currently in full compliance.

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A1TACilk '.NT A to ZRA97047 l' age 3 of 6 VIOLATION EXAMifI t lilli lienson for the Violathn  :

The reason for this violation example was inadequate standards for co.ifiguration control with respect to troubleshooting radiation monitors, it has been an accepted practice for Radiation Protection personnel to troubleshoot radiation monitors under the direction of Operating personnel without benefit of procedural or work request controls, as these individuals were recognized as Subject hiatter Experts (ShiE) on this system. This practice also contributed to the lack of a fonnal pre Job briefing for th!n work activity.

A contributing cause to this violation example is that l'ait 1 operations personnel did not communicate to Unit 2 operations personnel that er. alarm on Unit 2 would be teceived as a result of troubleshooting being performed on radiation monhor 2RIA PR40. At the time of the event the Unit 1 System Particulate, lodine, and Noble Gas (SPINO) radiation monitor console was in control of the Unit 2 radiation monitor (2RIA PR40). The Unit i Nuclear Station Operator (NSO) was aware of the fact that the llealth Physicist was resetting the radiation monitor process computer by down powering the SPINO, and failed to effectively communicate this evolution to the Unit 2 NSO.

In addition, management expectations for component manipulation and the use of procedures, instructions and/or work requests to maintain control of plant configuration, have not been sufficiently fonnalized and effectively communicated to station personnel.

Corrective Stens Taken and Results Achieved Operations hianagement has counseled the operations personnel involved in this event.

In addition, the Operations hianager has stre; sed to each work group the importance of configuration control and adherence to Configuration Control Policy 2-11. Each work group confinned to the Operations hianager that their people had all been instructed and understood the policy.

Radiation Protection (RP) has issued a policy which clearly defines roles, responsibilities, and standards for RP staffin regard to configuration contial of radiation monitors. The Radiation Protection hianager (RPhi) has distributed copies of this policy to members of the RP staff that could potentially manipulate station equipment. Additionally, the RPhi discussed at department meetings the configuration control expectations for RP personnel manipdating plant equipment. Speci'ically, RP personnel were instructed not to manipulate plant equipment without having an approved procedure, on which they have been trained and are qualified to perform. In addition, this policy was reviewed with the Operations hianager.

4 A1TACllMENT A to ZRA97047 Page 4 of 6 Corrective Stens That Will be Taken to Avoid Further Violationg Zion Generating Dation Configuration Control policy 211 will be revised to include

" Management Expectatioiw for Configuration Control" of components during shutdown i

and other modes, including identifying which departments may manipulate valves or other components, and under what conditions, it will also identify the specific equipment

that Radiation Protection personnel are trained and qualified to operate. This revision will be completed by November 14,1997.

Date When Full Comollance Will be Achieved l

- Zion Generating Station is currently in full compliance.

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ATTACitMENT A to ZRA97047 l' age 5 of 6 VIOLATION (50 295(304)/97020-05):

Technical Specification 3,14 requires that radiation monitoring equipment shown in Table 3.141 be operable and, with one or more of the channels Inoperable, that the action shown in Table 3.141 he implemented.

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? Table 3.14-1 requires that area sun eys be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when ORE-0006 has less than one channel operable.

Contrary to the above, between 0430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br /> on April 4,1997, and 0352 hours0.00407 days <br />0.0978 hours <br />5.820106e-4 weeks <br />1.33936e-4 months <br /> on April 6, 1997, area radiation surveys were notperformedevery 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when monitor ORE.

0006 was inoperable.

This Is a Severity Level IV violation (Supplement IV).

Adal.sions or Denial of the Violatio.n Comed admits the violation.

Reason for the Violation The reasons for this violation are: (1) a cognitive error by the Unit Supervisor (US) in his review of the Technical Specifications (TS) in that he failed to adequately review the TS to detennine and implement the correct surveillance requirements for monitor ORE-0006; (2) no confinning review r: quired or perfonned by either the Shill hianager (Sht) or Nuclear Station Operator (NS0) of the monitor surveillance requirements incorrectly detennined by the US: and (3) less than an adequate questioning attitude by any st.bsequent reviewers of the NSO/US/SE turnover sheets, PT 0 (" Surveillance Check Lists and Periodic Tests"), Appendix N, or PT-14 (" Inoperable Equipment Surveillance Tests").

A contributing cause to this event was an error in step 3 of RP procedure ZRP 582012

(" Surveillance Requirements for inoperable Radiation hionitors"), that inappropriately listed ORE 0006 as not requiring a routine surveillance when inoperable.

Corrective Stens Taken and Results Achieved The Nuclear Station Operator, Unit Supervisor, and Shill hianager were counseled by Operations Management to reinforce expectations for thorough independent reviews of surveillance requiremmts for out-of service equipment.

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ATTACllMENT A to ZRA97047 I i l'agc 6 of 6 t l

The Unit Supenisor has presented this event at a Licensed Shill Supervisor meeting in  !

order to ensure operator awareness and emphasize Ic"ons learned.

ZRP $82012 (" Surveillance Requirements for in, perable Radiation Monitors") has been  !

revised so that ORE-0006 has been deleted from monitors not requiring routine  :

surveillance in step 3.

A comprehensive review was performed on all radiation monitors in order to verify that t the Inoperability action requirements of Technical Speelrications, Offsite Dose  !

Calculation Manual (ODCM), and Updated Final Safety Analysis Report (UFSAR) were

addressed and captured in ZRP $82012. Thh review lead to the discovery of the l 2-inadequate com~nsatory actions being taken when radiation moritors that provide input ,

to radiation nr.naor 1(2)RT PR15 are declared inoperable, as discussed in LER 97 014

) (docket no. 50 295). The surveillance requirements, as implemen::d by procedure ZRP 582012, non conservatively required a grab sample selectively, such that grab samples j wr. eld be taken only for certain input failures (radiation monitors), instead of any

radiation monitor input failure.

• Appendix A to PT 14 has been revised to include a snond verification of the required  :

actions for inoperable / degraded equipment. PT-14 (" Inoperable Equipment Surveillance r 4 Tests") and PT 14E (" Degraded Equipment Status") have been combined into one PT 14  :

(" Inoperable / Degraded Equipment Surveillance Tests"),

i Corrective Stens That Will he Taken to Avoid Further Violations i No additional actions required.

1 Date When Full Comnilance Will he Achieved Zion Generating Station is currently in full compliance.

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A'JACilhti:N T !! to ZRA97047 6ageIofI ATTACilh1ENT 11 COhihilThf ENTS IDENTIFIED IN Tills RESPONSE TO NOTICE OF VIOLATION 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 included here for the NRC's infonnation only, and are not regulatory commitments. Please contact hir. Robert Godley, Zion Generating Stmion Regulatory Assurance hianager, if there are c.ny questions regarding this document or any associated regulatory commitments.

Commitment: Committed Date (or Outage):

The Radiation Protection will develop supplemental expectations to Nov. 24,1997 enhance surveying and posting contaminated areas, with specific attention to identifying potential sources of contamination; e.gm boron encrusted valves / equipment, leaking pumps, seals, valves, etc.

Zion Generating Station Configuration Control Policy 2-11 will be Nov.14,1997 revised to include "hianagement Ex) ectations for Configuration Control" of components during shutdown and other modes, including identifying which departments may manipulate valves or other components, and under what conditions, it will also identify the specific equipment that Radiation Protection personnel aie trained and qualified to operate.