IR 05000295/1988025

Insp Repts 50-295/88-25 & 50-304/88-25 on 881215-890104.No Violations Noted.Major Areas Inspected:Radiation Protection Program,Including Organization & Mgt Controls,Changes in Organization,Personnel,Facilities,Equipment & Procedures

ML20246L598
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/23/1989
From:	Paul R, Slawinski W, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246L596	List: IR 05000295/1988025 ML20246L590
References
50-295-88-25, 50-304-88-25, NUDOCS 8903240230
Download: ML20246L598 (19)

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Rep' orts N'.'50-295/88025(DRSS);

o 50-304/88025(DRSS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2  ;

Inspection At: Zion Site, Zion,' Illinois Inspection Conducted: December 15-16, 19-21, 1988 and January 3-4, 1989 Inspectors:

'(ddI-_G W. 3. Slawinski J * 2./2.3/ Date l W g . Paul M Date L O cY/ '1- $ M Approved By: William Snell, Chief 2/zs/af Emergency Preparedness and Date '

Effluents Section

Inspection Summary i i

Inspection during the period December 15, 1988 through January 4, 1989 (Reports No. 50-295/88025(DRSS); No. 50-304/88025(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection, program (IP 83750) during a refueling / maintenance outage, including:

organization and management controls; changes in organization, personnel, facilities, equipment, and procedures; planning and preparation; training and j qualifications of contractor personnel; external and internal exposure controls; control of radioactive materials and contamination; audits and appraisals; and i Also reviewed were open items (IP 92701) and allegations

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the ALARA progra concerning the radiation protection program (IP 99024).

Results: The licensee's radiation protection program continues to be  !

-generally effective in protecting the health and safety of occupational worker During the Unit 2 refueling / maintenance outage, implementation of the radiological controls program was generally good and improved over the previous (Unit 1) outage. No violations or deviations were identified; however, weaknesses with the Radiological Occurrence Report system and radiological controls over high radiation areas were note %

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DETAILS Persons Contacted

• Budowle, Assistant Superintendent, Technical Services

• L. Gesiakowski, ALARA Engineer D. Johnson, Stores Supervisor

+*P. LeBlond, Rad / Chem Supervisor

+*R. Palatine, Health Physicist'

D. Pecannas, Stockman ,

• Plim1,' Station Manager-

• Principe, ALARA Coordinator

• F. Rescek, Health Physics Director, Nuclear Services

• J. Schrage, Health Physicist, Nuclear Services

• W. Stone, Regulatory Assurance Superviso * Trzyna, Licensing Administrator

• T. Van DeVoort, Quality Assurance Supervisor

• Wepprecht, Health Physicist V. Williams, Lead Health Physicist / RPM

• J. Winston, Quality Control

• P. Zurawski, Quality Assurance Engineer

• Holzmer, NRC Senior Resident Inspector The inspectors also contacted other licensee and contractor employees, including rad / chem technicians and members of the operations and technical staff * Denotes those present at the site exit meeting on January 4, 1989.

+ Denotes those contacted between January 18-26, 198 . General This inspection, which began on December 15, 1988, was conducted to

, review the radiation protection program during a refueling and maintenance outage, including organization and management controls, planning and preparation, qualifications and training, internal.and external exposure controls, control of radioactive material and J contamination, audits and appraisals, and the ALARA program. Also reviewed were open items and allegations concerning the radiation protection program. The Unit 2 refueling / maintenance outage began about October 12, 1988, and was completed the week of December 19, 198 During plant tours, no significant access control, posting, or procedure adherence problems were identified; housekeeping was adequat . Licensee Action on Previous Inspection Findings (IP 92701 and 92702)

(Closed) Open Items (295/88011-01; 304/88012-01): Review calibration of the new "Fastscan" whole-body counter. The calibration was satisfactorily performed by a vendor (Section 9),

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(Closed) Open Items (295/88011-02; 304/88012-02): Clarify and formalize requirements for site-specific respirator training and retraining and verify the apparent discrepancies in instructions on proper respirator and protective clothing removal. Station radiation protection procedure ZRP 1220-2 has been revised to clarify respiratory protection training l requirements; further procedure revision is planned to require annual retraining. Instructional discrepancies have been resolved and NGET

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training videos rectified to eliminate inconsistencies. A separate (apart from NGET) site-specific respiratory protection training course '

is under developmen '

(Closed) Open Items (295/88011-03; 304/88012-03): Review corrective actions taken as a result of the containment evacuation event on April 3, h 1988. The corrective actions taken by the licensee appear adequate and

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include development of guidelines for tool usage, expanded pre-job meetings and more explicit RWP (Closed) Open Items (295/88011-04; 304/88012-04): Review laundry monitor use, calibration and alarm setpoints. Changes to the laundry and monitoring methods are described in Section 11(c).

(Closed) Open Items (295/88011-06; 304/88012-06): Assess the radiological conditions associated with use and maintenance of the State of Illinois Effluent Monitoring System and communicate applicable '

radiological control requirements to the state. The state was informed of applicable requirements in a letter from the station RPM dated September 7, 1988. Radiological assessments will be performed as part o the normal'RWP proces (Closed) Violations (295/88020-03; 304/88020-03): Failure to include all required information in the semiannual effluent report for the first half of 1988. Commitments made in the licensee's October 25, 1988 notice of violation response letter were reviewed and appear adequat { Closed)OpenItems(295/88020-05;304/88020-05): Review the licensee's ,

evaluation results for gaseous generation during long-term radwaste storage in the interim radwaste storage facility (IRSF). The licensee's (PWRE) evaluation for determining gas generation in the IRSF and for monitoring the area for gas has been completed. A new procedure (S0I-77)

has been developed to address radwaste liner storage in the IRSF and includes consideration for hydrogen gas generation. The procedure was reviewed by the inspectors and appears adequate.

1 (Closed) Open Items (295/88020-06; 304/88020-06): Review IRSF contain ( inspection program procedure. Procedure ZAP 13-52-10," Quarterly Inspection of Drums and Liners Stored in the IRSF," was developed by the licensee and reviewed by the inspectors; no problems were noted with the procedur . Organization and Management Controls (IP 83750 and 92701)

l The inspectors reviewed the licensee's organization and management l controls for the radiation protection and ALARA programs including

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anticipated changes in the organizational structure and staffing,

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effectiveness of. procedures and other management techniques used to ,

Limplement these programs, and experience concerning self-identification and correction of program. implementation weaknesse In early 1989, the licensee plans to permanently assign rad / chem technicians to either radiation protection or chemistry technician positions. This is expected to improve performance in these areas'due to increased specialization. In anticipation of this split, the station has expanded the technician and foreman staffs to 40 and 8 (plus a lead foreman), respectively; additional changes and staff increases are under consideration. Reorganization of the_ remainder of the rad / chem department is also expected to occur in early 1989. Professional health

. physics staff increases are contemplated; an additional health physics engineering assistant was recently hired. This individual has a Bachelor l of University Studies degree in health physics and about nine years radiation protection technician and health physics related experience; no problems were noted with the individuals qualifications. ALARA group staffing is discussed in Section 1 The inspectors discussed tentative long and short-term staffing and organizational plans for the radiation protection group. The changes are expected to benefit the radiation protection and chemistry groups and improve overall program performanc These changes will be reviewed during future inspection '

No violations or deviatiens were identifie ' Changes (IP 83750)

i The inspectors reviewed changes in the station's organization, personnel, facilities, equipment, programs, and procedures that may affect radiation protection during the outage. Changes in organization and personnel are

. discussed in Sections 4 and Fortthe current' Unit 2 outage, use of experienced contract workers and supervisors, including a large percentage of contract technicians with station specific experience, appeared to benefit the radiological control e

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program and reduce the problems that were previously encountered (Inspection Reports No. 295/88011; No, 304/88012). Reactor head work was improved through use of advanced robotic and video technology (Section 12).

During the outage, station rad / chem technicians and foremen typically worked 10-hour days, seven days per wee The health physicists and engineering assistants also worked extended hours (typically 10-hour days, L six days per week) and provided backshift coverage during peak outage activities. Work schedules were developed so as not to exceed Generic Letter 82-12 guideline The station's laundry and respiratory protection cleaning facilities were not used during the outage and replaced with vendor supplied facilities consisting of one wet and two dry-cleaning units, a respirator cleaning /

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drying unit and a large automated laundry monito The physical set-up l of the vendor facilities was similar to that previously described (Inspection Reports No. 295/88011; No. 304/88012). The licensee plans to discontinue routine use of their in-house laundry and utilize an offsite vendor. The station is contemplating upgrades to its in-house laundry facility for use as a backup and for emergency purposes only. An automated laundry monitor has been purchased and is expected to be fully J operational in early 1989. The monitor will be.used primarily to q spot-check. laundered clothing returned from the vendor (Section 11).

No violations or deviations were identifie . Planning and Preparation (IP 83750)

The inspectors reviewed the outage, planning and preparation performed by the licensee, including: additional staffing, special training, increased equipment supplies, and job related health physics consideration ,

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The station's radiation protection group has been augmented with 60 contract radiation protection personnel consisting of 37 senior and 18 junior technicians, four shift supervisors, and a site coordinato Approximately 50% of the contract personnel had previous Zion station experience; this is indicative of a reliable contract staf The inspectors verified that those technicians not meeting ANSI N18.1-1971 selection criteria were not providing radiation protection job coverage without proper supervision. Oversight provided during the outage by rad / chem foremen and health physicists remains as previously described (Inspection Reports No. 295/88011; No. 304/88012).

Radiation protection participation in job planning and preparation is evident and includes ALARA and mock-up training, pre-job briefings to station and contract workers, decontamination, extensive use of shielding, use of video and remote welding equipment, and ALARA and health physics participation in planning and daily outage meeting The ALARA program is discussed in Section 1 No violations or deviations were identifie . Training and Qualifications of New Personnel (IP 83750)

The inspectors reviewed the licensee's selection criteria and the education and experience qualifications of contract radiation protection personnel. The training provided to the technicians by the licensee was also reviewe Licensee selection of contractor radiation protection technicians includes a review of resumes to determine conformance to ANSI N18.1-1971 criteri Resume accuracy was licensee verified by contacting previous employers. Selected resumes of contract technicians working at Zion during the current outage were reviewed by the inspectors; no problems were note _ _ - _ _ _ _ _ _ _ - _ _ _ _

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-After selected contract technicians arrive onsite, they are required to complete Nuclear-Gener.al Employee Training (NGET), site specific respiratory training, mathematics refresher training, and Zion radiation i protection administrative and implementing procedures training. The math-and procedures training was developed by the licensee's health physics staff and provided by the contract site coordinator. Comprehension is determined through written examination. To be designated a senior technician, an individual must have the necessary experience and score at least.80% on the mathematics and station procedures exams; junior technicians must score at least 70% on both exams. The exam questions were reviewed by the inspectors; no significant problems were note '

No violations or deviations were identifie . External Exposure Control and Personal Dosimetry (IP 83750)

The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; high radiation area controls; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse General ,

There have been no significant changes in the licensee's external exposure measurement and control program since the previous inspection (Inspection Reports No. 295/88011; No. 304/88012). To date, the licensee's 1988 person-rem total of 1200 person-rem is higher than the original goal of 650 person-rem. According to the licensee, the 1983 Unit 1 refuel outage was responsible for about 700 person-rem, and the Unit 2 refuel outage for 400 person-rem to date; no individual received a whole-body dose in excess of 4 re :

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through December 198 For the aforementioned outages, the licensee established a temporary radiation protection ingress / egress and dosimetry control station in the Auxiliary Building. Personnel needing access to the containment were channeled through this station which is manned by several radiation protection technicians (RPTs) continually. Minimum personal t monitoring requirements for containment access include a TLD and

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self-reading dosimeters (SRDs) and electronic dosimeters for l certain higher dose rate jobs. Technicians manning the control

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station issue the electronic dosimetry and record the exposures j received by containment workers on dose cards. The flow of materials, equipment and personnel to and from the containment is monitored by the technicians manning the station. In addition, other (RPTs) are assigned each shift to cover all RWP work in the containmen !

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The licensee continues to use dose cards for daily dose l accountability / tracking. Each person who receives exposure is '

required to complete an exposure timecard. The timecard information is completed and used for personnel exposure control. Daily exposures are reviewed to ensure dose approvals are not exceeded and have been properly authorized. Whole-body dos'e equivalents in excess of 100 mrems daily and/or 300 mrems weekly require specific rad / chem authorization for each job. Higher levels of authorization are required for exposures in excess of these' administrative I limit A computer program identifies' workers whose exposures (

exceed the predesignated exposure level b, Radiological Controls - High Radiation Areas The inspectors reviewed the licensee's high radiation area access control program for conformance to 10 CFR 20.203 and station procedures. Technical Specifications do not address control for such areas High radiation area (> 100 mrem /hr) access controls are delineated in administrative procedure ZAP 5-51-15. Entry requirements for areas > 15 R/hr are set forth in ZAP 5-15-16 and

' remain essentially as previously described (Inspection Reports No. 295/87022; 304/87023). All entries into designated high radiation areas require shift engineer (SE) or operating unit shift supervisor authorization; high radiation areas other than those temporarily established (30 days or less) are equipped with locking mechanisms and require an R-key for entr R-keys are normally controlled by the SE or designate, non-licensed shift foreman (for radwaste areas), and radiation protection foreman (for rad / chem staff use only). R-Key log books are maintained in accordance with procedural requirement In 1988, five RORs were written for high radiation area access l control' procedural violations. On February 6, 1988, (as documented in ROR No. 88003) multiple R-Key issuance / documentation procedure violations associated with a work group were identified by the licensee. On March 9 and 18, 1988, (as documented in R0Rs No. 88010 and No. 88024) R-key doors were discovered propped-open and the areas unattended. Similarly, on July 13 and September 23,1988,(R0Rs No. 88063 and No. 88068), R-key doors or gates were discovered unlocked and unattended. While one of these instances can be partially attributed to a hardware problem with the locking mechanism, the root cause of these events is failure of workers

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to close and lock the doors to these areas and to fully understand R-key issuance and control procedures. After each event, the licensee has re-emphasized to workers the requirements for these area Also, the licensee has installed audible alarms on about 45 l high radiation area doors that actuate if the doors are open; however,

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the alarms were disconnected due to hardware and other problem )

l Inspector discussions with a SE R-key custodian and review of recent R-key log book entries revealed the following concerns:

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• The specific.high radiation area entered.was infrequently recorded in the log. For example, the auxiliary or containment building was listed instead of the specific area within'each buildin *- -Several individuals were listed together for the issuance ;

of one R-key (group entry) without indicating the primary or responsible key controlle Although the R-key and egress control problems do not appear t represent a.significant programmatic weakness currently, the problems could worsen unless R-key controls are strengthened and procedural requirements more strongly enforced. To improve this area, the licensee committed to strengthen R-key controls including procedural revisions and training by July 1,1989, and is considering the following:

(1) Limit key control and issuance to the Rad / Chem Department onl (Instructions for key and area responsibility would be conveyed'

to the key recipient upon key issuance).

and/or l (2) Require a Type II RWP for all R-key area entries (Type II RWPs require that the RWP be reviewed and signed-off daily; this would reinforce key / area responsibility).

and (3) Designate an R-key controller for group entries.: (The controller would be ultimately responsible for ensuring proper key controls and that doors are closed and locked upon exit).

These matters were discussed with the licensee during the inspection, summarized at the exit meeting, and will be reviewed further during a future inspection (0 pen Item 295/88025-01).

No violations or deviations were identified by the inspectors; however, weaknesses in the high radiation area control program were note . Internal Exposure Controls (IP 83750)

The inspectors reviewed selected aspects of the licensee's internal exposure control and assessment programs including: determination whether engineering controls, respiratory equipment, and assessment of intakes meet regulatory requirements, and planning and preparation for maintenance and refueling tasks including ALARA consideration Portable Ventilation Systems The licensee uses two 1000 cfm portable ventilation units in containment for venting steam generators during outage condition Other portable units are used in the radwaste and decon facilities

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L and other locations as needed. During both outages in 1988, the units were os.ed extensively to maintain proper environmental controls. Procedure ZRP 1120-3, " Radiological Controls for Steam Generator Work," is being revised to ensure portable ventilation '

systems are properly installed.and updated. Based on'a discussion with the ALARA Coordinator about the portable ventilation system-L program, it appeared,the licensee has a good understanding concerning the proper use'and application of tne units, Transfer Canal Air Sampling - Fuel Building '

The inspectors reviewed the circumstances surrounding elevated floor contamination levels and several personal contamination events that occurred in the refuel building. Personal contamination was i identified during worker frisks after completion of refuel floor '

work activities. Personal contamination levels (shoes only) ranged from 2,000-20.'J00 dpm/100 cm2 beta ganm Followup smear surveys showed that several floor areas of the fuel building were contaminated up to 20,000 dpm/100 cm2 Smears of horizontal surfaces indicated no elevated levels. Samples analyzed from a constant non-alarming air sampler on the refuel floor showed no increased activity during the time in which the elevated contamination levels were identifie Whole-body counts of the contaminated workers were not performed because none of the individuals showed positive nasal smear result The elevated contamination levels apparently resulted from sever (

work activities being performed in the fuel building including fuel transfer canal work. No extraordinary measures were taken to prevent personal contamination in the general areas of the fuel building because the licensee did not expect increased contamination levels to evolve. The inspectors review of the events that transpired prior to-and during the personal contamination problems identified the following concerns:

• During work activities in the fuel canal on October 12 and 14, 1988, air samples were taken in and above the cana A non-alarming constant air sampler was located about 40-fect from the top of the canal; however, no alarming real time constant air monitor was operating at the top of the canal ;

while work in the canal was being performed. The use of i alarming constant air monitors located at the top of the canal during work activities in the canal is a good health physics practice and can indicate changing radiological conditions and ,

alert personnel of airborne contaminatio '

• While m M4ure ZRP 1810-5 addresses use of constant air monitors with alarm setpoints during refueling activities in the containment building side of the transfer canal, no procedure addresses similar matters during fuel transfer canal work in the refueling building. The development of such a procedure would strengthen the radiological surveillance progra ;

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These matters were discussed with the licensee during the inspection and at the exit interview. Based on these discussions, it is our understanding that an-alarming constant air monitor will be used 1 during fuel transfer canal work in the fuel building and procedures I will be revised to ensure the use of such alarming constant air '

rnonitors during all future transfer canal work. These matters will ;

be reviewed further during a future inspection. (0 pen  ;

Item 295/88025-02) ,

ALARA concerns with the transfer canal work were also identified in that several seperate (piecemeal) entries were made into the canal within a short time period to repair recurrent problems with the fuel upender and limit switches without fully scoping the problems and !

dcveloping a program / plan for its ultimate resolution. The i desirability of such a plan and decon% mination of the area prior to plan implementation was discussed at the exit meetin I

Whnle Body Counting l RWPs, air activity surveys, MPC-hour determination and whole-body count data for 1988 were selectively reviewed; no significant problems were noted. .RWPs appeared to adequately reflect the respiratory protection requirements for the job. Whole-body count results tabulated in vendor biweekly and quarterly reports were selectively reviewed for 1988 through August. Over 4500 counts vare performed on company and contractor personnel; followup counts were performed on individuals who showed elevated initial counts to verify I that the 40 MPC-hour control measure was not exceede According to !

the licensee, no individual received a body burden greater than 1%

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as a result of station related activities in 1987 or 1988 to date.

l The licensee continues to trend whole-body count data on a quarterly '

basis as an aid to identify potential problematic work groups or individuals and submits the data to the station manage The inspectors reviewed calibration records for the licensee's new j

"Fastscan" whole-body counter. The unit was factory calibrated by the vendor in January 1988 and performance tested at the licensee's )

facility shortly after installation in March 198 According to '

vendor records, the calibration and performance test results were satisfactory. The licensee continues to maintain their lay-down whole-body counter as a backup to the new system. The last full calibration of the lay-down unit was performed by the vendor in '

March 1988. The unit was subsequently relocated and set-up in the warehouse area and performance tested to confirm response l characteristics had not changed; no problems were noted by the

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vendor. The inspectors reviewed records and relevant procedures j for routine operation and quality control checks both whole-body I counters. Daily use response and channel location checks are l l

performed using cobalt-60 and cesium-137 check sources; no problems '

were noted by the inspectors.

f No violations or deviations were identified.

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1 Radiation Occurrence Report (ROR) System The inspectors selectively reviewed RORs generated in 1987 and 1988 to date, including R0Rs provided by an alleger who contended that the ROR system was not being effectively implemented. There were 86 RORs generated in 1988 through mid-December, about twelve remain open pending further licensee investigation. RORs a: 9 typically written by members of the rad / chem staff and assigned to the licensee's health physics staff for followup and corrective action recommendation. After health physics reviews are completed, the R0Rs are routed to. rad / chem department supervision and to station management for review and concurrenc RORs are typically written for failure to follow RWP requirements and for discovery of radiological control practices contrary to procedural requirements or accepted licensee and industry method Over 50% of the RORs generated in 1988 were reviewed by the inspectors for significance, adequacy and timeliness of the licensee's followup and scope of corrective actions; the remainder of those generated in 1988 were reviewed for potential significance and timeliness of licensee review. Inspector review disclosed several problems with implementation of the ROR program. Relevant inspector findings are described below: R0R Review and Closure Timeliness l The inspectors determined that the licensee's review and followup of R0Rs is not always timely. For example, of the 86 R0Rs generated in 1988, about 23% remained open 90 days or more; about 14% exceeded 160 days and about 6% exceeded 240 days. ROR review assignments are normally made expeditiously by the Lead Health Physicist but actual reviews may not commence for several weeks depending on work loa Although RORs are normally cursorily reviewed by the lead and assigned health physicists when received, no mechanism currently exists to establish priorities for R0R reviews, to establish milestones, or to periodically check review / closure statu An ROR written on August 30, 1988 (No. 88065) described a potential safety significant problem that appears not to have been given the necessary attention to determine its cause and to effect corrective action (s). The ROR involved a containment entry at power by two workers who failed to sign the correct RWP or consult rad / chem prior to entry. Licensee review of this matter has been i

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initiated but not completed; the root cause for this event has not been determined by the licensee. As of this inspection, no corrective actions have apparently been taken. The R0R remains open after approximately 120 days. This incident was discussed with the licensee during the inspection and will be reviewed further during a future inspection (Unresolved Item 295/88025-03). Adequacy and Scope of Corrective Actions The adequacy and scope of corrective actions for certain R0Rs is questionabl Approximately 9% of the RORs generated in 1988 involved poor radiation worker practices and radir; ion protection /

administrative procedure violations that appeared to warrant

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'_ disciplinary action. Although the licensee has previously taken disciplinary action, such actions are rare. Stronger enforcement of

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procedural requirements should be considered. Several RORs generated in 1988 for repetitive high. radiation area contro1' problems are described in Section 8.(b). Also, the corrective actions for at least two'other 1988 RORs did not appear to address the root caus Documentation and Filing Numerous ROR documentation and administrative weaknesses were noted and included several misfiled RORs, closed RORs with incomplete or missing closure documentation and difficulties in locating ROR A few RORs apparently missing from the ROR file were later located; all 1988 RORs were eventually located and accounted for. ROR documentation problems were previously identified by the NRC (Inspection Reports No. 295/87037; No. 304/87038). Similar timeliness and documentation problems were identified in a September 1988 station QA surveillance of RORs. Although corrective actions were taken for the specific RORs identified in the QA surveillance, the generic program needs significant improvemen Summary )

l Based on inspector review of RORs generated'in 1987 and 1988 to i date, implementation of the R0R system appears to be:a programmatic weakness. These matters were discussed with the licensee during the inspection and at the exit meeting. To address timeliness concerns, the licensee recently developed an improved ROR tracking system to ,

ensure timely' review and closeout and committed to review the R0R j system and implement mechanisms to strengthen the overall progra ;

The licensee's progress to strengthen the ROR system will be reviewed during a future inspection (0 pen Item 295/88025-04).

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11. Control of; Radioactive Ma a ials and Contamination (IP 83750)

The inspectors reviewed-the licensee's program for control'of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesse ! Tool and Equipment Control The inspectors reviewed the licensee's radiological control program for tools and equipment which are stored, distributed and returned to hot tool storage locations. Numerous tool cabinets and gang boxes are located throughout the auxiliary building as storage places !

for both contaminated (fixed) and non-contaminated tools / equipmen Tools and equipment which are used for work on contaminated systems or in contaminated areas are stored, distributed and returned to these locations. None of the tools / equipment stored in these

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locations are allowed to be used in or transferred to a radiologically uncontrolled area.without required surveys being performe Tools / equipment used on contaminated systems or in contaminated areas are required to be surveyed by rad / chem before return to their storage locatio Rad / Chem routinely surveys the content of tool storage cages and gang boxes to assess adequacy of the tool control progra According to the licensee, the tool control program for gang boxes needs to be enhanced because the gang boxes are not always maintained in the same location, making health physics assessment difficul As a result of a recent QA audit concerning performanc of monthly tool box surveillance, guidelines were given to all departments to formalize gang box inventory and location documentation requirements; the intent of the guidelines ,is to enhance tool control. Records of tool surveillance indicate that loose contamination on tools stored in gang boxes and other tool /

equipment storage locations is not frequent. Although no significant radiological problems were identified, it appears desirable to consolidate the number of tool distribution / return locations and thereby reduce the probability of tool and cor.tamination control problems. This matter was discussed during the inspection and at the exit meetin Personal Contamination Events Personnel contamination event (PCE) reporting criteria, procedures, l and skin dose calculation methodology remain as previously described (Inspection Reports No. 295/87037; 304/87038). The inspectors ,

selectively reviewed personnel contamination incident reports generated from May through November 198 There were 95 PCEs reported during the period and 215 for 1988 through November; 227 were reported for calendar year 1987. Most of the 1988 contamination events occurred during peak outage activities in March, October, and November. Although the total number of PCEs has remained essentially unchanged over the last two years, the licensee continues to reduce the number of events reported during non-outage periods. The licensee tracks and trends PCEs and issues !

monthly reports to plant management; however, PCE review and trending could be enhanced as an aid to better determine potential problem areas. For example, inspector review of October and November PCEs revealed that roughly 15% were apparently due to poor radiation worker practices and 10% to contamination in " clean" areas. This matter was discussed during the inspection and at the exit meetin Thirty-three hot particle events were reported in 1988 through

! December 20; several of these events were reviewed by the inspectors. The majority of hot particles consisted of cobalt or other activation products with activities ranging up to l 0.73 microcuries. Skin dose calculations performed oy the licensee l and reviewed by the inspector showed that no 10 CFR 20 exposure limits were approache _____-_- _

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~ Laundry Facilities-As previously described (Section 5), the station plans to discontinue routine use of theirLin-house laundry facility and has contracted the services.of an'offsite vendor. The licensee has recently purchased an automated laundry monitor primarily to spot-check laundered. items returned from the vendo The new monitor is a Bicron unit featuring 20 (100 cm2) plastic scintillation detectors mounted in two arrays above and below a conveyor assembly and reportedly has the capability to detect minute hot particles in the presence of diffuse contaminatio .The unit was calibrated by the manufacturer in October 1988 and made operational on a trial basis. Alarm setpoints were established pursuant to licensee (corporate) guidance. The inspectors reviewed the manufacturers calibration methods /results and monitor alarm setpoints; no problems were noted. The inspectors also reviewed the calibration records and alarm setpoints for the vendor laundry monitor used during the outage; no problems were identified. The vendor monitor alarms were set at 33 nCi/100 cm2 for canvas items and 100 nCi/100 cm2 for rubber item I No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (IP 83750)

The inspectors reviewed the licensee's program for maintaining  !

occupational exposures ALARA, including: changes in ALARA policy an procedures;.ALARA considerations for maintenance and refueling outages;

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worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation j

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weaknesses. Special attention was given to the high station exposures for 198 The ALARA group is currently staffed with an ALARA supervisor and two ALARA engineers. Before and during the outage, a contractor health physicist was assigned to the staff. The ALARA staff appears to have the necessary qualifications and dedication to implement an effective ALARA progra In addition to their responsibility for implementing )

the ALARA program, the staff is also responsible for the tool / equipment decontamination program. The ALARA group performs daily reviews of all RWPs, attends all planning meetings, supervises the decontamination crew, administers the shiciding program, performs pre and post job meetings, and collates and tracks the station's person-rem performance. The ALARA coordinator. reports directly to an Assistant Superintendent who apparently provides adequate support to the staff. The licensee has i recently discussed reorganizing this reporting structure so that the i ALARA group would report to the radiation protection staff. This matter l was discussed with the licensee during the inspection and at the exit meetin i

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The station sets annual person rem goals each yea For 1988, the initial goals were set at about 700 person-rem, but revised after the Unit 1 outage (late February through early May 1988) to the current projected dose of about 1300 person rem to reflect the increased scope of work for both outages. The initial goals were established partly by corporate guidelines but primarily upon historical dose information from five previous outages. The higher than initially projected station dose was primarily due to the larger than work scope expected during two major refueling outage (Inspection Reports No. 295/88011; No. 304/88012).

For the 1988 outages, the licensee achieved dose savings through extensive use of lead shielding, use of mockups during pre-job training, and expanded use of video equipment and their photo-librar The licensee realized considerable dose savings for Unit 2 reactor head control rod drive housing work by employing weld overlay methods (rather than cutting / capping techniques) and robotic technology, use of experienced workers and supervisors, and by implementing improvements for certain tasks as a result of lessons learned from previous outage ,

l The license expended only 10 person-rem for the Unit 2 job. Compared to

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about 125 person-rem on the Unit 1 reactor head job compared The Unit 1 job involved cutting / capping canopy seal welds or, three control rod drive mechanisms; Unit 2 involved weld overlay on one drive mechanism. The licensee estimates that altogether about 500 person-rem was saved in 198 As a result of the unanticipated dose received during the Unit 1 refueling outage in the spring of 1988, a corporate review of the station's ALARA program was performed to identify major causes of the exposures and to formulate recommendations to aid the station in reducing the magnitude of exposures for the Unit 2 outage. The audit identified both ALARA program strengths and weaknesses, with the latter including inexperienced workers performing specialized tasks as part of the integrated work package, inexperienced field engineers (PAC), lack of involvement by PAC field engineers in the pre-job ALARA reviews, the need for a PAC organization ALARA specialist, and the need for improved dose budgeting and for an improved incentive program. The auditors concluded that the station has a strong ALARA program and that much of the dose from unplanned jobs during the outage could not have been avoided. They further concluded that some unplanned work could have been done better and that future outage work be performed by more experienced and qualified workers. The licensee adequately responded to i the audit concerns by implementing recommended corrective actions for the Unit 2 outage; the station dose for the Unit 2 outage was about 450 person-rem. Although the licensee attributes much of the 1988 exposure to major work activities and a large number of unanticipated tasks, they recognize improvements in the ALARA program are necessary and stated they will be made. Steps to improve the program include increased corporate ALARA involvement / participation in the stations ALARA program, increased PAC ALARA staff, improvement in contractor performance, and increased utilization of lessons learned. The inspectors agreed that although some weaknesses were identified in the program, it appeared the licensee had taken extensive measures to implement generally sound ALARA '

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No violations or deviations were identifie i 1 Audits and Appraisals (IP 83750)

The inspectors reviewed the quality assurance (QA) organization and records of audits and appraisals of radiation protection program activities conducted since April 1988 to date and discussed the findings and related issues with members of the QA and rad / chem departments. Extent and scope of audits / surveillance and adequacy and timeliness of corrective actions taken or proposed were reviewe The station's quality assurance group remains essentially as previously described (Inspection Reports No. 295/87037; No. 304/87038) except that a newly hired auditor with about six years naval experience but little commercial power plant experience was added. The licensee expects the new auditor to eventually assume or share radiation protection QA audit responsibility. An inspector discussed with the QA Superintendent the desirability for this individual to attend a radiation protection / health physics training course (s).

As discussed in Section 12, a corporate audit of the ALARA program was conducted shortly after completion of the spring (Unit 1) 1988 refueling outag Audit observations were adequately addressed and corrective actions implemented during the current Unit 2 outage. A station QA audit of the radiation protection program was conducted on September 20-26, 1988 and focused on activities and documentation associated with inventories, surveys, and bioassays. The audit did not identify any significant problems; however, four observations and one open item were identifie The observations dealt primarily with record and documentation problems and have been adequately addressed and correcte The open item concerns lack of radioactive sealed source inventory and leak test record The inspectors also reviewed radiation protection related QA surveillance ,

performed in 1988 to date and discussed the surveillance approach and i results with QA department personnel. Approximately ten radiation protection access control, RWP and related activity surveillance were performed during the review perio The audit and surveillance program appears to be adequately developed and continues to be implemented satisfactorily. No problems were noted with :

the scope, frequency and thoroughness of the audits and surveillanc '

No violations or deviations were identifie . Allegation Followup Discussed below are allegations relating to the radiation protection program at the Zion Station which were evaluated during this inspectio ;

The evaluations consisted of record and procedure review, interviews l with licensee personnel, and observations of plant egress practice Concerns expressed in Allegation No. 88-A-0143 were clarified in a telecon with the alleger on December 14, 198 J

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• The Zion NRC Resident Inspectors' Office received a telecon which expressed a concern regarding use of personnel dosimetry at the Zion Station. The concern and inspectors' finding are discussed below (Allegation No. RIII-88-A-0143 (Closed)).

Allegation: X-Ray technicians working at the Zion Station wore contaminated film badges at a local restauran !

l The alleger reported observing two contract radiographer whom he '

recalled from his previous Zion employment, each wearing a film  ;

badge while at a restaurant located near the Zion Station. The alleger assumed the radiographer were working at Zion at the time and that the film badges might be contaminated because these individuals may work in radiologically controlled and contaminated areas. The alleger did not know the names of the radiographer or company they represented. The alleger stated that the radiographer wore film badges and not TLDs. TLDs are provided by Zion station to monitor personnel exposure Discussion: According to licensee representatives, it is common practice for contract radiographer to use their company issued dosimetry (e.g., film badges) in addition to that provided by a utility while providing radiographic services at the utility facilit This practice is not contrary to regulatory requirements or Zion procedures. Contractor film badges are worn together with Zion issued TLDs and both are required by Zion procedures to be checked (frisked) for contamination upon exiting contaminated area Workers that leave a contaminated area are required to frisk their dosimetry after removing their PCs and before crossing the

. step-off pad; hand-held friskers are provided for this purpos Workers are then required to clear the automated whole-body contamination monitors after donning their street clothes and before leaving the RCA. The automated monitors serve as an additional check for potential worker and dosimetry contamination. Workers that have not crossed a contamination boundary must also clear the contamination 3 monitors prior to leaving the RCA. TLDs provided by the Zion Station '

are collected by security guards at the guard house as the worker i leaves the statio This practice reduces the possibility of lost or misused dosimetr Non-Zion dosimetry is allowed to be removed offsit Finding: While the individuals observed by the alleger likely were working at the Zion Station, the individuals apparently were contract radiographer wearing company provided dosimetry (film badges) and not Zion issued dosimetry (TLDs). This practice is not prohibited by regulation or Zion procedures. Also, the licensee (Zion Station)

has adequate mechanisms to assure dosimetry worn in potentially contaminated areas is checked for contamination prior to leaving the contaminated area and again during whole-body frisks prior to leaving the RCA. No problems were identified with the licensee's dosimetry issuance, return, or frisking policies and practices, t' . The Zion NRC Resident Inspectors' office received information regarding concerns with the implementation of the Radiological i

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Occurrence Report (R0R) system at Zion Statio The concerns and inspectors' findings are discussed below (Allegation No. RIII-88-A-0161 (Closed)).

Allegation: The Radiological Occurrence Report (ROR) system is not effectively implemented, problem resolution is slow, corrective actions are incomplete, documentation errors exist, and some reports are missing. Specific examples to support the allegation were provide Discussion: The inspectors reviewed numerous R0Rs generated primarily in 1988, including examples provided by the alleger. As a result.of this review, several problems were identified and are described in Section 1 Finding: The allegation was partially substantiated in that ROR resolution and closecut is not always timely, corrective actions may warrant stronger worker sanctions and do not always appear to address the root cause, and documentation errors are prevalent. The concern regarding missing R0Rs was not substantiated; although some 1988 RORs were initially difficult to locate, all were accounted fo Inasmuch as no regulatory requirements exist for RORs other than those existing in licensee internal procedures, and no specific violations of those procedures were identified, no regulatory violations are applicable in this matter. However, the licensee has committed to review and make improvements to their ROR system; future NRC inspections will review the licensce's progress. (See Section 1 for further details.)

1 Exit Meeting (IP 30703)

One of the inspectors met with licensee representatives (denoted in '

Section 1) at the conclusion of the site inspection on January 4, 1989, to summarize the scope and findings of the inspection; an additional discussion concerning corrective action schedules for identified weaknesses in the area of high radiation area access controls and radiation occurrence reporting was held with Mr. Joyce on February 16, 1989.. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify  !

any such documents / processes as proprietary. The following matters were

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-discussed specifically by the inspecto Necessity to improve radiological controls over high radiation areas. The licensee committed to implement an improvement program by July 1, 1989. (Section 8) Radiological control and ALARA concerns associated with work in the fuel transfer canal. (Section 9) Radiological Occurrence Report System weaknesses. The licensee committed to implement an improvement program by July 1, 198 (Section 10)

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