IR 05000295/1989037

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Insp Repts 50-295/89-37 & 50-304/89-33 on 900206-26. Violations Noted.Major Areas Inspected:Recent Radwaste/ Radioactive Matl Transportation Events & Followup on Allegations Re Nuclear General Employee Training Program
ML20033F308
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 03/12/1990
From: Gill C, Snell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20033F306 List:
References
50-295-89-37, 50-304-89-33, NUDOCS 9003190348
Download: ML20033F308 (12)


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o U. S. NUCLEAR REGULATORY COMMISSION

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REGION III

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Renorts No.- 50-295/89037(DRSS); 50-304/89033(DRSS)

_ Docket No:;. 50-295; 50-304 Licenses No. DPR-39, DPR-48

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Licensee: Commonwealth Edison Company Post Office Box 767

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' Chicago,. IL 60690

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Facility Name:

Zion Nuclear Power Station, Units I and 2

Inspection At:

Zion Station, Zion, Illinois Inspection Conducted:

February 6-26, 1990 In3pector:

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O C. F. Gill Date Approved By:

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William Snell, Chief Date

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Radiological Controls and

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Emergency Preparedness Section

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Inspection Summary.

inspection on February 6-26, 1990 (Reports No. 50-295/89037(DRSSh No. 50-304/89033(DRSS))

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Areas Inspected: Special, announced safety inspection to review the

- circumstances surrounding three recent radwaste/ radioactive material

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transportLtion events (IP 93702) and to followup on allegations regarding the NGET trcining program (IP 99024).

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Results: - Two violations were identified (failure to comp'ly with low-level radioactive waste burial facility requirements and failure to maintain the

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integrity of a radwaste shipping container - Section 3).

l 5003190348 900312 PDR ADOCK 03000293 O

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DETAILS 1.

Persons Contacted R. Budowie, Services Director W.' Cramer, Support Services Training Coordinator

  • G. Geer, Radwaste Cc$rdinator
  • G. Kassner, Lead Health Physicist - Operations /ALARA W. Kurth, Production Superintendent
  • T. Rieck, Technical Superintendent T. Saksefski, Regulatory Assurance NRC Coordinator C. Schultz, Quality Control Supervisor T. Van DeVoort, Quality Assurance Superintendent R. Leemon, NRC Resident Inspector P. Moore, NRC Resident Inspector The above individuals attended the onsite exit meeting on February 9, 1990.
  • Deutes those contacted by telephone during the period February 12-26, 1990.

The inspector also contacted other licensee and contractor employees.

2.

Radioactive Material Shipment Event No. 1 Event Description a.

v On November 2, 1989, the licensee shipped radioactive material-shipment No. NRS P9-068, steam generator sleeving equipment classified as Radioactive Material-LSA, from the Zion Station by exclusive use truck to the Combustion Engineering (CE) Windsor, Connecticut site. On November 7, 1989, CE notified the licensee that upon arrival at the Windsor site the resurvey of the shipment by CE thowed dose rates higher than those indicated in the licensee's shipping papers.

Specifically, the licensee's survey of the trailer showed a maximum contact dose rate of 28-35 mR/hr (on contact) at the front of the trailer compared to the CE values of 40-50 mR/hr (on contact) at the same location. Also, the CE survey of the shipment boxes found one box at the front of the trailer which read 90 mR/hr (on contact) compared to 50 mR/hr (on contact) indicated by the licensee's survey documentation.

In addition, CE measured 3 mR/hr in the cab compared to 1 mR/hr indicated by the licensee's survey documentation.

49 CFR 177.842(g) states that the radiation dose rate must not exce M 2 millirem per hour in any position normally

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occupied in the motor vehicle.-

b.

Investigation Summary On November 8. 1989, telephone conversations between licensee and CE personnel determined that the difference in survey results might be partially explained by the fact that the two surveys were conducted

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x using different types of survey instruments. Because the licensee

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had just source checked the survey instruments used for the trailer and box surveys and found them to be within required tolerances, CE m

E was requested by the licensee to resurvey the shipment for comparison E

using the same type of instrument used by the licensee.

Since the

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shipment had been unloaded, CE personnel could not resurvey the cab and trailer; therefore, they resurveyed the highest dose rate box u

(H-02-146).

The licensee was informed by CE that the resurvey of the

box indicated 70 mR/hr (on contact) rather than the 90 mR/hr (on

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contact) receipt survey reading (with a different type of instrument).

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In late afternoon on November 8, 1989, the licensee decided not to allow any other LSA equipment shipments to leave the Zion site until i

this event and another radioactive material shipment event (see Section 3) had been investigated and resolved, informed the NRC of

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the events, and made plans to send two licensee represercatives to the CE Windsor site.

On November 9,_1989, the two licensee representatives arrived at the

CE Windsor, Connecticut site.

Box H-20-146 contact dose rates

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measured 50 mR/hr with both of the two licensee instruments, 65 mR/hr with the same type of CE instrument and 70 mR/hr with the CE receipt survey instrument of a different design.

CE personnel informed the licensee reprecentatives that the receipt inspection of

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the load found no evidence of load shifting; however, it was possible that an item inside the box may have shifted thus giving rise to the differences in dose rates measured during the various surveys. Upon opening the box, CE and licensee personnel noted that the contents were packed fairly tight but not so tight that they could not be moved with minimal effort.

Licensee representatives-

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informed the inspector that most of the various survey results were o

essentially duplicated by using minimal effort to shift the contents of the box.

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Although the observations and measurements made by CE and licensee

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personnel indicated that shifting contents of the shipping box is a

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credible explanation of the differences between dose rates measured on contact with the box and the front of the trailer, they are not

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sufficient to explain the discrepancy between the cab survey

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results.

It was, however, identified by CE personnel that the cab dose rate measurements were performed by CE personnel after the shipment cab had been disconnected from the shipment trailer and replaced by another cab of a different design. When the original

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shipment cab was returned to the CE Windsor site on November 14, 1989, the difference in distances between the two different cabs and the shipment trailer and the difference in cab wall thicknesses indicated that if CE personnel had measured the cab dose rate with the shipment cab still attached to its trailer, it is credible that the CE survey would not have differed significantly from the licensee's pre-shipment survey results.

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c.

Root Causes The licensee identified two root causes associated with this event.

First, shifting of equipment inside the highest dose rate box is postulated to have caused a change in the dose rate external to the box.

Radiation protection and quality control procedures addressed the proper loading and bracing of the boxes on the trailer, but did not address the proper packing of the boxes.

Second, the subject box was placed at the front end of the trailer.

The licensee concluded that it should have been placed in the center of the trailer to provide more distance between the box and the front of the trailer (and the cab) and to provide shielding by the other boxes, d.

Licensee Corrective Actions The licensee plans to revise the shipping procedures to add precautions on the proper packing of boxes. Also, the licensee

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plans to add procedural precautions to prevent the loading of the highest dose rate boxes near the front or sides of shipment trailers. The procedural revisions are expected to be completed by March 1, 1990.

In addition, the licensee stated that CE plans to revise its survey procedures to ensure that receipt surveys are conducted with the shipment cabs still attached to their trailers.

The inspector independently confirmed the CE plans by discussing the matter with NRC personnel in the regional office which conducts inspections of the CE Windsor, Connecticut site, e.

NRC Conclusions

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The licensee. appeared'to have conducted a prompt, timely, and thorough investigation of this event. The planned corrective actions appear adequate to prevent recurrence.

The licensee's conclusions that the pre-shipment survey was conducted correctly and that no regulatory violations occurred seem credible.

No violations or deviations were identified by the inspector.

3.

Radioactive Material Shipment Event No. 2 a.

Event Description On November 7,1989, the licensee shipped radioactive material shipment No. NRS89-071, steam generator sleeving equipment classified as Radioactive Material-LSA, from the Zion Station by exclusive use truck to the Combustion Engineering (CE) Chattanooga, Tennessee site. On November 8, 1989, CE informed the licensee that upon arrival at the Chattanooga site the resurvey of the' shipment by CE showed a maximum contact reading on the bottom of the trailer of 50 mR/hr, compared to the 6 mR/hr reading of the licensee's pre-shipment survey.

The licensee requested that CE not unload the truck until a licensee representative could investigate the

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Late in the afternoon on November 8, 1989, the licensee decided ~not to allow any other LSA equipment shipments to leave the Zion site until this event and another radioactive material shipment event (see Section 2) had been investigated and

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resolved, informed the NRC of the events, and made plans to send

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i a licensee representative to the CE Chattanooga site.

b.

Investigation Summary On November 13, 1989, one of the two licensee representatives who had investigated the radioactive material shipment event at the CE Windsor, Connecticut site (see Section 2), arrived at the CE Chattanooga site, Surveys of the trailer using two different types of CE instruments showed a 50 mR/hr contact dose rate on the bottom

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of the trailer.

Surveys performed using two licensee instruments (both of the same type as one of the CE instruments) confirmed a 50 mR/hr contact dose rate on the bottom of the trailer in a six-inch by six-inch area.

The inside of the trailer was then inspected and it was determined that the location of the 50 mR/hr contact dose rate was under a box which was labeled as 60 mR/hr contact.

Both CE and licensee instruments indicated 60 mR/hr contact on the bottom of the box.

The shipping papers did not indicate whether the 60 mR/hr contact dose rate had originally been found on tne bottom of the box or on one of the other sides.

Based, in part, on the investigation findings for the radioactive material shipment event at the CE Windsor, Connecticut site, the licensee concluded the most likely reason for the survey discrepancy associated with the CE Chattanooga site event was also shifting of box contents.

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Root Cause The licensee postulated that' shifting of box contents may have caused a change in the dose rate external to the box in a manner which might explain the survey discrepancy.

Radiation protection and quality control procedures addressed the proper loading and bracing of the boxes on the trailer, but did not address the proper packing of the boxes.

d.

Licensee Corrective Actions The licensee plans to revise the shipping procedures to add precautions on the proper packing of boxes.

The procedural revisions are expected to be completed by March 1, 1990.

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NRC Conclusions The licensee appeared to have conducted an adequate investigation of this incident.

The planned corrective actions appear adequate to prevent recurrence if the licensee's supposition concerning the root cause is correct.

Although it may be possible that the box contents could have shif ted enough to explain the difference between the pre-shipment survey data for the bottom of the trailer and the

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corresponding results of the CE receipt survey, the licensee did not substantiate this possible explanation during the onsite investigation. During the inspection, the inspector discussed with appropriate licensee personnel that an inadequate pre-shipment survey of the bottom of the trailer remained a possible explanation of the differences between the licensee and CE survey results.

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Licensee representatives indicated that particular care would be taken to thoroughly survey the bottom of future radioactive shipment trailers. This matter was also discussed with Zion Station management following the inspection (see Section 6). This matter

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will be reviewed further during a future inspection.

(Open Item No. 295/89037-01; 304/89033-01)

No violations or deviations were identified by the inspector.

4.

Radioactive Waste Shipment Event The inspector reviewed the findings from an investigation of a radioactive waste shipment from the Zion Station conducted on January 12, 1990, by representatives of the Department of Health, State of Washington, upon arrival at the Richland, Washington low-level radioactive waste burial facility.

Information regardinE the findings and the licensee's subsequent planned corrective actions was gathered mainly from interviews with licensee representatives, contractors, and vendors; a letter dated January 30, 1990, from the State of Washington, Department of Health to the licensee; and licensee, contractor, and vendor documentation, including correspondence and Process Control Program (PCP) procedures.

a.

Event Description on January 5, 1990, the licensee shipped radioactive waste shipment No.90-001, solidified low-level radioactive ethylene glycol-water mixture, packaged in 62 55-gallon drums, classified as Radioactive Material-LSA, from the Zion Station by exclusive use truck to the Richland, Washington low-level radioactive burial facility. On January 12, 1990, the licensee was notified that upon arrival at the burial facility, free-standing liquid was detected in the shipment

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drums during offloading of the drums from the shipment truck and that the integrity of one drum was found compromised in that a small amount of slightly radioactive liquid had leaked onto the truck bed (without l

exceeding the removable radioactive contamination limit pursuant l

to 10 CFR 20.205(b)(2)), apparently through a damaged lid scal. The l

lids of some of the drums were deformed, apparently from freezing l

and thawing of drum contents during outside storage and transportation.

The shipment drums measured less than 1 mR/hr contact dose rate, contained less than 0.5 nanocuries per drum, and contained up to about one foot of free-standing liquid on top of solidified material.

49 CFR 173.425(b)(1) states that LSA materials must be packaged in strong, tight packages so that there will be no leakage of radioactive l

material. State of Washington Radioactive Materials License l

No. WN-IO19-2, issued to US Ecology (operator of the Richland, l

Washington low-level radioactive waste burial facility), Condition No. 21 prohibito radwaste packages containing free-standing liquid.

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Investigation Summary The licensee sent two representatives to the burial facility to investigate this event.

Because the drums had been processed at the Zion Station by US Ecology using the Aguaset II process supplied by Fluid Tech, representatives from U.S. Ecology and Fluid Tech aided in the investigation.

Laboratory experiments by Fluid Tech showed that if the drums had been through at least two freeze-thaw cycles, free-standing liquid would occur in the drums.

A method of solidifying the shipment drums in-situ at the burial site was developed, the method was approved by the State of Washington, and the drums were subsequently solidified and buried at the Richland, Washington facility.

c.

Root Cause Licensee representatives, contractors, and vendors identified the root cause of this event to be inadequate PCP procedures.

Zion Station Procedures No. PCP-BFT-1-0P-1, Process Control Program for Solidification of Radwaste in Fluid Tech Media, and No. PCP-BFT-1-01-1, Batch Solidification of Radwaste in Fluid Tech Media, both Revision 0 dated December 7, 1989, were determined to contain inadequate instructions regarding the determination of the proper choice of Fluid Tech Media and solidification methodology.

The Zion Station procedures are based on US Ecology procedures which, in turn, are based on Fluid Tech procedures, d.

Licensee Corrective Actions The licensee plans to revise the Zion Station PCP procedures regarding this process, based on US Ecology procedural revisions which, in turn,.will be based on revisions to the Fluid Tech procedures. The inspector reviewed the proposed revisions to the PCP procedures and discussed them with appropriate licensee employees and contractor / vendor representatives. The proposed corrective actions appear adequate to prevent recurrence, e.

Regulatory Conclusions Failure to meet the requirements of 49 CFR 173.425(b)(1), which states that LSA materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material, is a violation of 10 CFR 71.5(a), which requires the licensee to comply with 49 CFR Parts 170 through 189.

(Violation No. 295/89037-02; No. 304/89033-02)

Failure to meet the Richland, Washington low-level radiation waste burial site licensee condition which prohibits radwaste packages containing free-standing liquid is contrary to Zion Station Administrative Procedure No. ZAP 13-52-8, Preparation and Shipment of Radioactive Material.

Failure to meet the

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requirements of Procedure No. ZAP 13-52-8 is a violation of Techhical Specification 6.2.1, which states that written procedures shall be implemented.

(Violation No. 295/89037-03; No. 304/89033-03)

Two violations were identified.

5.

Allegation Followup (IP 99024, AMS No. RIII-89-A-123)

Discussed below are several specific allegations relating to the Nuclear General Employee Training (NGET) program at the Zion Nuclear Power Station which were evaluated during this inspection. The evaluation consisted of record and procedure review and interviews with licensee and contractor personnel.

Allegation:

There is not sufficient time allotted in the eight-hour NGET training to adequately teach about Radiation Work Permits (RWPs)

and other important topics.

Discussion:

The first day of NGET (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) consists of fitness for duty training followed by a 25 question exam (70% passing criterion)

and radiation protection training followed by a 50 question exam (70%

passing criterion). The first half of the second day (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) concludes NGET training with contamination control and protective clothing (PC)

training, including the requirement to pass a practical examination involving proper donning and removal of PCs to demonstrate the student's ability to avoid self-contamination and to prevent the spread of contamination. The inspector reviewed the NGET lesson plan, instructors manual, procedures, training standard, sample examination questions,.

students examination records, selected training tapes, and material handed out to students during the class.

Also, several NGET instructors and several recent NGET graduates were interviewed regarding course contents and the classroom interface between instructors and students.

The documentation and the interviews showed that the licensee's NGET program contains the appropriate subjects for a radiation protection training program as recommended in Table 1 of Regulatory Guide 8.27, Radiation Protection Training for Personnel at Light-Water-Cooled Nuclear Power Plants.

Specifically, RWPs are very well covered in NGET by almost 10 minutes of video tapes, considerable classroom discussion, and effective handout material. All of the recent NGET graduates interviewed demonstrated that they understood the RWP process and believed the course covered the topic well. The review of the radiation protection examination questions for tests given in 1989 and to date in 1990 showed that approximately 10-20% of the questions were to directly test the students'

understanding the RWP process and their ability to understand a sample RWP.

ihe alleger expressed a concern that the NGET supervisor may be more concerned with getting personnel through the NGET program rather than with the program's adequacy.

The inspector interviewed the NGET supervisor, several NGET instructors, and the licensee's Corporate NGET Coordinator concerning this matter.

Recent NGET graduates were also asked if they had the perception that the course was taught in a manner that seemed too fast or if they believed there may be a problem with

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program adequacy.

The training staff members all indicated that quality e

of the NGET program is of prime importance to the instructors and their supervision. The recent NGET graduates praised the thoroughness / clarity of the course and the high quality and conscientiousness of their

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instructors. As stated above, the inspector's independent review of the NGET program did not identify any inadequacies.

The alleger expressed a concern that there may be inadequate review of

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I incorrect answers to questions missed on the NGET tests.

Inspector interviews with the NGET training staff and recent NGET graduates indicated that sufficient time is allotted to review incorrect answers to missed NGET questions.

In addition, each student is required to sign a statement on the examination answer sheet that acknowledges that the student, upon request, has had the opportunity to review ~the entire examination with the instructor to ensure the student's complete understanding of the material presented and of the potential hazards of working with ionizing radiation.

All NGET instructors and recent graduates interviewed stated that the instructors review frequently missed questions with the entire class and make significant efforts to solicit additional questions from members of the class. The recent NGET graduates also stated that their instructors explained all missed questions to the students' satisfaction and informed them not to sign the acknowledgement statement unless they were sure they agreed with the statement and understood the correct answers to their missed examination questions.

The alleger expressed the concern that the NGET instructors may lack adequate inplant experience.

The inspector reviewed the resumes of current and recent NGET instructors. Although mary of these persons have significant applicable inplant experience before being assigned as NGET instructors, some do not.

Interviews with the NGET staff showed that the position of NGET instructor is usually an entry-level position such that it is not always possible to hire and keep NGET instructors with significant inplant experience.

To assure that NGET instructors maintain a minimum level of current inplant experience, the licensee requires instructors to obtain at least 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of applicable inplant experience per year (nominally, at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per quarter).

The inspector reviewed documentation of inplant experience for current and recent NGET instructors. All instructor records reviewed showed that the required inplant experience had been obtained and that many instructors significantly exceeded the required inplant experience.

Interviews with recent NGET graduates indicated that their instructors had the necessary inplant experience to adequately address student questions relating to potential inplant situations.

In summary, it appears that current and recent NGET instructors have the necessary inplant experience to teach the NGET course.

Finding:

This allegation was not substantiated.

The licensee's NGET program appears to meet all the regulatory guidance regarding radiation protection training. The inspector did not identify any programmatic problems.

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Allegation:

Personnel are allowed to attend respiratory training without medical certificate in hand which violates the licensee's procedure.

Discussion: The inspector and licensee personnel contacted were unable to identify a procedure which states that personnel must have a medical certificate in hand to be allowed to attend respiratory training. However, the Support Group Instructor Information compiled for the respiratory training course states that each trainee must have a medical qualification in hand to complete the course and the course instructors are required to sign a statement on the student answer sheet which verifies that the student is medically qualified to wear a respirator by means of an attached sheet (copy of medical certification) or by checking radiation protection medical records.

Interviews with the NGET training staff indicated that before each respiratory training class begins, the instructor collects a copy of. medical certificates from each trainee with the exception of licensee personnel who have their medical certificates on file with the Zion radiation protection group. The instructor attaches the medical certificate to the examination answer sheet for those trainees who brought copies with them and signs the associated medically qualified verification statement.

For those trainees with medical qualifications on file, the instructor confirms by telephone that a valid certification is in each person's file before signing the verification statement. Each of the instructors interviewed stated that trainees who did not have appropriate medical certification are removed from the classroom before the training session begins.

The licensee's method of verifying medical qualification before allowing personnel to don resplictnrs appears adequate.

The alleger expressed the concern that the licensee may not be properly reviewing medical certificates which could result in personnel injury from work being performed beyond physical limitations. The inspector confirmed that the mask fit area contained a sign which required the technician on duty to verify that each worker had successfully completed

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The inspector also confirmed that the licensee had proceduralized this requirement.

Finding: This allegation was not substantiated.

The licensee has developed administrative control which appears adequete to preclude the donning of respirators without proper training and medical certification.

Allegation:

Test accountability and control procedures are poor. A health physics test was missing for two or three days. Also, when a new test was written, the question book did not contain enough questions to ensure minimal repeat questions.

Discussion:

Although the specific incident of the missing test could not be verified by the inspector, the licensee's training staff confirmed that there had once been occasional problems in the distant past regarding test accountability and control. The licensee currently obtains two examinations of 60 questions each for the radiation protection portion of NGET each quarter from INPO. The licensee selects 50 of these questions (or

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licensee substituted questions) for examination, A and B for that quarter.

In the past, when an examination's bank of qutstions has apparently been compromised, the licensee has changed some r,( the questions by using the i

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10 unused questions supplied by INPO and D, extracting questions from previous quarters' examinations.

Although many of the examination questions

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thoroughly mixed the order of the questions to preclude the use of an answer key from the original version of the examination from being used to cheat on the revised test.

The licensee's reasoning appears valid and the revised examination would appear to be a valid test of the trainees'

knowledge of radiation protection. The training staff indicated that no test has been compromised since 1988 when the licensee improved test accountability and control by numbering the examinations and accounting for each copy of the test before any trainee left the classroom.

Beginning the first quarter of 1990, INP0 will no longer be supplying prepared examinations.

Instead INPO will supply the licensee with their entire bank of questions and require the licensee to prepare its own examinations. Members of the training staff informed the inspector that any future compromised examination will be replaced by a new examination from the large INP0 question bank.

Finding:

This allegation was partially substantiated in that past test accountability and control practices were acknowledged by the licensee to have resulted in occasional problems.

Presently the licensee appears to have a valid NGET testing program even if an examination's bank of questions becomes compromised. No regulatory requirements were identified as having been violated.

Allegation:

Unqualified personnel are allowed to teach courses because ANSI N18.1 requirements are weak.

Discussion; ANSI N18.1 - 1971, Selection and Training of Nuclear Power Plant Personnel, is specified by Zion Station Administrative Procedure No. ZAP 2-52-1, Training.

Since ANSI N18.1-1971 is not explicit on the qualification of training instructors, the training department has developed its own requirements which appear to assure that unqualified personnel do not teach courses. A selected review of the qualification records of current and recent NGET instructors did not

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identify any instructor who was not qualified to teach NGET.

Finding: This allegation was not substantiated.

Allegation: Contractor personnel screening qualifications are too low.

They frequently fail the NGET test, which requires requalification training and retesting.

Discussion: The purpose of NGET is to instruct workers pursuant to 10 CFR 19.12 before granting unescorted site access.

If a contractor employee fails the initial NGET course, that person must retake and pass the course to be eligible for further consideration for unescorted site access. This policy is consistent with the intent of 10 CFR 19.12 and represents the licensee's effort to ensure adequate understanding by the workers of the instructions specified by 10 CFR 19.12.

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Finding: The allegation is not' relevant. The licensee's NGET program is designed to instruct workers in accordance with the requirements of 10 CFR 19.12. This may require additional insu >ction of some workers.

No violations or deviations were identified.

6.

Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the onsite inspection on February 9,1990, and by telephone through February 26, 1990.

The inspector summarized the scope and findings of tne inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.

The licensee did not identify any such documents or processes as proprietary.

The following matters were discussed specifically by the inspector, The violations associated with a radioactive waste shipment.

a.

(Section4)

b.

The potential of an inadequate survey regarding a radioactive material shipment.

On February 26, 1990, the licensee informed the inspector that additional corrective actions would be taken

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to prevent potential inadequate surveys of future radioactive shipments.

(Section 3)

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