IR 05000295/1983007
| ML20024A658 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/17/1983 |
| From: | Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| References | |
| NUDOCS 8306220026 | |
| Download: ML20024A658 (1) | |
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June 17, 1983 Docket No. 50-295 Docket No. 50-304 Commonwealth Edison Company ATTN:
Mr. Cordell Reed Vice President
' Post Office Box 767 Chicago, IL 60690 Gentlemen:
-Thank you for your letter dated May 25, 1983, informing us of the steps you have taken to correct the noncompliance which we brought to your attention in Inspection Report Nos. 50-295/83-07 and No. 50-304/83-06 forwarded by our letter dated April 27, 1983. We will examine these corrective actions and the corrective actions discussed during the exit meeting on March 23, 1983, during a subsequent inspection.
Your cooperation with us is appreciated.
Sincerely,
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C. J. Paperiello, Chief
~ Emergency Preparedness and Radiological Safety Branch cc: D. L. Farrar, Director of Nuclear Licensing K. L. Graesser, Station Superintendent cc w/ltr dtd 5/25/83:
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division Mayor John B. Spencer City of Zion 8306220026 930617 PDRADOCK05000g G
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- one First National Plaza Chicago. Illinois g.
Address Reply to: Post Office Box 767 Chicago, lilinois 60690 May 25, 1983 Mr. James G. Keppler, Regional Administrator Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Subject:
Zion Station Units 1 and 2 Response to I.E. Inspection Report
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Nos. 50-295/83-07 and 50-304/83-06 NRC Docket Nos-. 50-295-and 50-304-Reference (a):
C. J. Paperiello letter to Cordell Reed dated April 27, 1983.
Dear Mr. Keppler:
Reference (a) provided the results of an inspection conducted by Messrs. P. C. Lovendale and D. E. Miller of your office during the periods of March 11, 14-17, 22-23, and April 17, 1983 of activities et our Zion Station.
During that inspection, certain activities appeared to be in noncompliance with NRC requirements.
The Attachment to this
letter provides the Commonwealth Edison Com of Violation as appended to Reference (a). pany response to the Notice Additionally, our response
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to the Reference (a), Appendix B Notice of Deviation is provided.
To the best of my knowledge and belief, the statements contained in the Attachment are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
Please address any questions that you or your staff may have concerning this matter to this office.
I Very ruly yours,
- w-Dennis L. Farrar EDS/1m
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j Director of Nuclear Licensing
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Attachments cc:
Region III Inspector - Zion bbOM 8 kh33
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ATTACHMENT Response-to Notice of Violation
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Violation
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As a. result of the inspection conducted on March 11, 14-17, 23-24, and
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April 7, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violation was identified.
Technical Specification 6.2.B states that radiation control procedures shall be maintained, made available to all station personnel and adhered
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to.
a.
Procedure ZRP 1470-4, " Decontamination of Personnel," requires documentation of all personal contamination surveys in which internal
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contamination is suspected or a major portion of the bcdy is involved.
Contrary to the above, on March 1, 1983, personal contamination surveys of transfer canal workers who exhibited nasal contamination were not documented.
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b.
Procedure ZRP 1310-11, ' Air Sampling and Posting of Suspected and Known Radioactive Airborne Areas," requires that air samples be
collected in close proximity of the workers to ensure that a repre-sentative sample is-obtained.
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Contrary to the above, on March 1 and 2, 1982, no air samples were collected in the transfer canal before or during performance of work.
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j c.
Procedure ZRP 1310-11
" Air Sampling and Posting of Suspected and
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Known Radioactive Airborne Areas," requires that all air samples be
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counted for gross beta and gross alpha.
Contrary to the above, during the current Unit 2 refueling outage, job specific air samples collected by the contracted technicians have not been counted for gross beta and gross alpha.
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Response to Violation
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Corrective Action'Taken and the Results Achieved
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The event in question was documented on a Radiation Occurrence a.
Report (ROR 83-13).
All the personnel involved were whole-body counted to document any internal contamination.
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b.
This job was completed on March 2, 1983 so air samples durin performance of work in the transfer cana,l could not be taken.g The job for which these air samples refer ended.
c.
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-2-Corrective Action to be Taken to Avoid Further Noncompliance a.
At a weekly department meeting, Radiation-Chemistry personnel were told the importance.of following all radiation protection and chemistry procedures.
A memo has been issued, to be read and signed by all station health physicists, radiation-chemistry foremen, and RCTs, instructing all to adhere to Section F.1.b.
of RP 1470-4, " Decontamination of Personnel," (" Document all surveys in which internal contamination is suspected or a major portion of the body is ' involved.")
b.
The above mentioned memo also instructs all to adhere to Section F.3 of RP 1310-11, " Air Sampling and Posting of Suspected and Known Radioactive Airborne Areas." (" Air Samples should be collected in close proximity of the worker to assure that a
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representative sample is obtained and'that the proper
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respirators are prescribed.")
Personnel have been instructed to take representative air samples of more areas and more specific jobs in the plant.
RP 1310-11 and_RP 1310-12, " Containment Air Sampling During a Refueling Outage," will be revised to require air samples of the transfer canal to be performed and counted for alpha and gross beta-gamma (or isotopic) analyses when work in the transfer canal takes place.
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c.
In addition to the first sentence in a. above, RP 1310-11 will be revised to permit analysis for-particulate contamination to be performed on the station's GeLi or proportional counting
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systems, since the GeLi gives more specific information on airborne activity than the proportional counter and can provide
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l more. rapid results.
Additionally, the procedure will permit less alpha analyses of certain air samples if initial alpha analyses do not show alpha to be a problem or if the air sample i
is taken at an area where alpha contamination would not be expected to be a problem.
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Date When Full Compliance will be Achieved The licensee is in full compliance at this time.
The referenced radiation protection procedures will be revised by September 1, 1983.
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Response to Notice of Deviation
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Deviation
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i Based on the inspection conducted on March 11,14-17, and 22-23, and April 7,1983, it appears that certain of your activities were not in cccordance with commitments which you made in previous correspondence with the Commission.
In a letter to NRC, Region III, dated April 19, 1980, you stated that
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cdditional surveillance for alpha activity would be conducted including, cnalysis of a fuel pool sample quarterly and selected contamination smears semi-annually.
Both analyses were to be performed by a private-laboratory.
Contrary to this, as of March 23, 1982, only one cet of contamination smears have been sent out for analysis (October 1980) and no fuel pool samples have been sent out for analysis.
Response to Deviation Corrective Action Taken or Planned and Estimated Date of-Completion
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Zion Station will send to an offsite contractor for transuranic analysis contamination smears taken just after its 1983 refueling outage from the Unit 2 refueling cavity by the transfer canal flange.
Smears from this area or from the transfer canal will be taken after future refueling outages of each unit.
This requirement will be added to RP 1520-5 (" Preparation of Shipments for Offsite Analysis").
The procedure will be amended by September 1, 1983.
Weekly samples of the fuel pool are analyzed for alpha activity.
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Offsite analysis will be performed if a positive alpha problem is identified by this surveillance.
This will be incorporated into chemistry procedure ZCP-302 by September 1, 1983.
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