A98017, Forwards Response to Violations Noted in Insp Repts 50-295/98-03 & 50-304/98-03.Corrective Actions:Monitor in Question Was Correctly Calibrated

Forwards Response to Violations Noted in Insp Repts 50-295/98-03 & 50-304/98-03.Corrective Actions:Monitor in Question Was Correctly Calibrated

ML20216B150
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/06/1998
From:	Brons J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-295-98-03, 50-295-98-3, 50-304-98-03, 50-304-98-3, ZRA98017, NUDOCS 9803120424
Download: ML20216B150 (6)

Text

, Commonwcattli Illnun Compan)

Zion Generating Station 101 Shiloh Ikmlevard Zion, II. WW2797 TelH4?? A 2081 ZRA98017 March 6,1998 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

Subject:

REPLY TO A NOTICE OF VIOLATION NRC Inspection Report No. 50-295/304-96003(DRS);

Zion Generating Station, Units 1 & 2; .

NRC Docket Numbers 50-295 & 50-304

Reference:

Letter to O. D. Kingsley (Comed) from G. E. Grant (USNRC), dated February 6, 1998, NRC Routine Radiation Protection Inspection Report 50-295/304-98003 and Notice of Violation Gentlemen:

By letter dated February 6,1998, 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. Attachment A to this letter provides the reasons for the violations, the corrective actions taken, r.nd a statement of l full compliance. Attachment B to this letter identifies all commitments made by Zion Station in i I

this response.

Should you have any questions conceming this response, please contact Mr. Robert Godley, Zion Station Regulatory Assurance Manager, at (847) 746-2084, extension 2900, i

Sincerely, /

3 lohn C. Brons db l Site Vice President i Zion Generating Station l

l Attachments l

cc: Regional Administrator, USNRC - Region III l Senior Project Manager, USNRC - NRR Project Directorate III-2 NRC Senior Resident Inspector, Zion Generating Station Office of Nuclear Facility Safety - IDNS 9803120424 980306 PDR G

ADOCK 05000295 PDR kggg,,g A 1 nkom company

o- Attachment A to ZRA 98017 Page 1 of 4 i

- . REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/98003(DRS); 50-304/98003(DRS)

VIOLATION 1 (50-295/304-98003-01):

l l 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 Part 20.

Step G.4.dd ofprocedure ZRP 5822-07 (Revision 2), " Calibration of the NE Technology IPAf-8 Whole Body Frisking Afonitor," requires the performer to reset the personnel contamination monitor to the initial settings, prior to performing the instructions containedin Section G.5.

Step E.2.3 of procedure ZRP 5710-02 (Revision 3), " Control of Afaterials For l Conditional or Unconditional Release From Radiologically Posted Areas," requires that j

items unconditionally released from radiologically posted areas 'e surveyed with instrumentation having a detection capability of 5000 disintegration., per minute (dpm) per 100 cm' total contamination and 1000 dpm per 100 cm' removable beta / gamma contamination.

l Contrary to the above: .

l 1 l i

a. On Jimuary 15,1998, a radiation protection technician performed a calibration of an Auxiliary Building exit personnel contamination monitor (NE Technolog l IPAf-8) andfailed to reset the monitor to the initial settings, prior to perfbrming Section G.5 ofprocedure ZRP 5820-07. (50-295/98003-01a and 50-304/98003- l Ola) l b. On January 18,1998, two security officers unconditionally removed two clipboards ~

\ from the radiologically posted area without performing a survey ofthe clipboards.

(50-295/98003-01b and 50-304/98003-01b)

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

l Admission or Denial of the Violation Comed admits the violation, i

l L

\

o- Attachment A to ZRA 98017 Page 2 0f 4

. . REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/98003(DRS); 50-304/98003(DRS) yiolation Example A:

l Reason for the Violation The reason for the violation is the radiation protection technician (RPT) involved in the event chose not to perform the steps in procedure ZRP 5822-7 " Calibration of th, NE Technology IPM-8 Whole Body Frisking Monitor" that required resetting the set points j to their original values.

i

The format for performing IPM-8 whole body frisking monitor calibrations in ZRP. 5822-l 7 requires the RPT to do a series of source tests on the detectors, reset the set points to their original values, and perform various calculations on a calibration sheet to determine l the new calibration set points. The calculations are then reviewed and approved by RP management before the new set points are loaded into the IPM-8.

l The RPT inconectly assumed that RP management would review and approve the new L calculated calibration set points immediately after calibration and therefore chose not to perform the steps that reset the set points to their original values. -Instead he chose to

! follow general RP management expectations for removing an IPM-8 from service by placing a chain across the IPM-8 with an out-of-service tag attached to prevent its use.

Ilowever, he failed to place the out-of-service tag on the chain. The chain was L subsequently removed (it cannot be determined who removed it) and the monitor was in l service for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to discovery by another RPT when the daily L alarm functional test failed on the IPM-8.

t Corrective Steps Taken and Results Achieved The monitor in question was correctly calibrated.

l The RPT involved in the event was disciplined via the MARC process for failure to follow the procedure.

Radiation Protection staff conducted surveys in and around the RPA ex'it area and did not detect any contamination at or beyond the RPA boundary.

Parameter set points on other RPA IPM-8 monitors were re-verified and found to be correct.

The RP staffinterviewed other RPTs to determine if this inadequate work practice was common. Results of the interviews indicated that the other RPTs are following the procedural requirements, i

J

.. Attachment A to ZRA 98017 Page 3 of 4

. REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/98003(DRS); 50-304/98003(DRS)

Radiation Protection staff reviewed RPA entry logs to determine the personnel that were likely to have made contamination area entries during the time the PCM was in use out of calibration. Interviews with these personnel revealed that they had followed proper radiological practices and had monitored themselvc- in the field prior to re-monitoring themse!ves at the RPA exit. In addition, a search of tne problem identification form (PIF) database on the dates surrounding this event did not reveal any PIFs written on contamination monitor alarms at the guard house.

As part of the RP pocedure upgrade program, ZRP 5822-7 was enhanced by adding sign offs for each step of the calibration process.

Corrective Steps That Will be Taken to Ay ,d Further Violatlons No further corrective actions t Jeemed nece: sary.

Violation Example H:

c JLeason for the Violation The reason for the violation was an inadequate understanding of how hand carried materials are authorized and released from the radiological posted area (RPA) by the security officers involved in the event. The Security officers did not consider the cMpboards as equipment needing to be surveyed prior to exiting the RPA. The officer's mind sn was directed towards tools exiting the RPA, rather than paperwork and clipboards.

3 Discussion:

Both officers were newly hired and this was their iirst time posted in the RPA. The otficers exited with tre clipboards because they thought their post instructions and maps  ;

of the areas, attached to the clipboards, were not to be left in plain view for other  !

personnel to see. They did not think that the clipboards were considered material that needed to be surveyed. They were under the impression that only hand carried tools /equipm:nt needed to be surveyed. They did not call a radiation protection technician (RPT) for assistance.

When they arrived at the IPM-8 whole body inonitors one of the officers set the clipboard on the plexiglass divider that separates the RPA from the non-radiological area. The

-w._ - -

.- Attachment A to ZRA 98017 Page 4 of 4

. . REPLY TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT 50-295/98003(DRS); 50-304/98003(DRS)

I other of6cer put the clipboard between his knees and proceeded into the monitor. Both ofncers cycled through the IPM-8 monitors and exited the auxiliary building.

The officers' reliefs returned to the auxiliary building by way of the RPT at the RPA access control point. The RPT questioned the of0cers about their clipboards and found one clipboard to have a low level of 6xed radioactive contamination on it.

Corrective Steps Taken and Results Achieved The security ofDeers involved in the event were counseled and reprimanded for their failure to follow the rules and requirements on how materials are authorized and released frons the radiological posted area (RPA).

The Radiation Protection Department collected twenty (20) clipboards from Security and surseyed them and found one (1) other with a low level of fixed contamination on it. The ,

I contaminated clipboard was found inside a Security vehicle within the PA. The vehicle was surveyed and no other contaminationwas found.

Radiation Protection has provided security department personnel with Comed Radiation Protection liandbooks that depict requirements of the radiation protection program and specincally the control of radioactive material.

Security tailgated and documented this event. The tailgate included reviewing the Comed Radiation Protection 11andbook a'.,' the PIF that was generated. The review process is to ensure tSat security personnel are aware of their expected actions concerning hand carried items when entering / exiting a radiological protected area.

'tr.diation Protection has installed a gate just prior to entering the whole body monitors.

This gate has a large sign on it directing personnel to seek assistance from a RPT to survey any hand carried items before entering the IPM-8 monitor. (NOTE: you physically have to push this gate open in order to pass through.)

1 Corrective Steps That Will be Taken to Avoid Further Violations No further corrective actions are deemed necessary.

Date When Full Compliance Will be Achieved 3

)

Zion Station is currently in full compliance.

~

Attachment B to ZRA 98008 Page1of1 REPLY TO NOTICE OF V'OLATION IN NRC

. , INSPECTION REPORT 50-295/98003(DRS); 50-304/98003(DRS)

COMMITMENTS IDENTIFli!D IN Tills REPLY TO NOTICE OF VIOLATION The following table identifies those actions committed to by Comed in this document.

Any other actions discussed in 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 contact Mr. Robert Godley, Zion Generating Station Regulatory Assurance Manager, if there are any questions recarding this document or any associated regulatory commitments.

Commitment: Committed Date (or Outage):

None N/A l

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i f