IR 05000295/1990022

Insp Repts 50-295/90-22 & 50-304/90-24 on 900924-1012. Violations Noted.Major Areas Inspected:Radiation Protection Program

ML20058F473
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/30/1990
From:	Grant W, Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058F469	List: IR 05000295/1990022 ML20058F464 ML20058F471
References
50-295-90-22, 50-304-90-24, NUDOCS 9011080304
Download: ML20058F473 (14)

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I U.S. NUCLEAR REGULATORY COMMISSION Y

REGION III

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Report No. 50 295/90022(DRSS); 50-304/90024(DRSS)

Docket No. 50-295; 50-304 License No. DPR-39; DPR-48

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Licensee:. Commonwealth Edison Company

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Post Office Box 767 Chicago,'IL 60690 FailitMName:

Zion Nuclear Power Station, Units 1 & 2

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. Inspection At:

Zion Station, Zion, Illinois

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InspectionLLorducted: : September 24 through October 12, 1990 g

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l Inspector:

W. B. Grant

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Approved.By: :Wi11famfSnell', Chief'

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Radiological Controls and Date Emergency Preparedness Section

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Inspection Summary

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Inspection on~ Septeniber 24 through October 12,-1990;(Report No.

50-295/90022(DRSS); No.50-304/90024(DRSS))

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' Areas-Inspected:._ Routine unannounced inspection of the radiation protection programs, including ~:. : organization, management controls and training, audits

-and appraisals, external exposure control,. internal exposure control, control

of. radioactive. materials,;. contamination,-and surveys, and maintaining

" joccupational exposures ALARA (IP 83750). Reviewed corrective actiens on

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Lpast violations and ;other' identified concerns-(IP 92701) including releases

'j offgasechs effluents and outstanding items in the area of radiological j

controls and radwaste management.:

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Results

'During this inspection, a-violation associated with.a failure i

to obtain approval for a temporary change to. a procedure was identified-

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'(Sect' ion.4). A violation of contaminated area control' requirements was

identified (Section 11). lA violation and a non-cited violation were

.i identified with a reactor venting / containment purge evolution that occurred -

.on Apr.i.1t10 and 11,-1990 (Section 10). A non-cited violation was identified

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Lfor a1fai' ce to' maintain and preserve exposure records used to-prepare NRC l

Form-4: exposure records (Section 6).

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9011000304 901030

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a PDR ADOCK 05000295;

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IWsiknesses'wereidentifiedin?theareaof' contamination ~ controls (Section8);

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/knogledgefof; plant wide administrative controls,:such;as, _ temporary pro'cedure change;requirementsEand biennial-procedure reviews Section 4); selection and 4.:

Luselof 1 respiratory l protective _ equipment- (Section 7)(;-number of out of service

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portabl.e survey instrumentsL(Section 8)1 and in the material, condition of the

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.i_nstruinent calibration facility and the boric acid storage tank -room (Sections

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LBiand11,frespectively).

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. W "i; i Strengths' were. identified !in the following areas:

information provided to'

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tworkers regarding! radiological. conditions-(Section'4);; continuing progress Lin; housekeeping and material conditionLimprovements (with exceptions) (Section

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8);iefforts to involve' radiation-protection-technicians (Section 4); plans to

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iimprove ~ contamination-controls- (SectionL8); efforts to improve procedures M y,

(Section 4 and:6);' and plans"toLimplement a real time electronic. dosimetry-i N.,:

system:(Section:6).

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-DETAILS

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Persons Contacted

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• G.; Cole, Health Physicist

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PR.. Chrzanowski,TRegulatory Assurance Supervisor

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. # W.3 Demo, Unit 1.0perating Engineer

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1. . P. Geddes,:LER -Coordinator M,

1. 'P; LeBlondD0perating Assistant Superintendent

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'*K.LMcEvoy, Contaminatio' Control Coordinator ~

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*R.; Mika. Health 1 Physics Services. Supervisor R. Palatine, Lead Health Physicist - Technical

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. R.- Pratt, Scheduler / Planner j

L#*T.;Rieck,TechnicalServicesSuperintendent i

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1. • Tl Saksefski, Regulatory Assurance

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sWm u*K. Weaver,zStaff Health Physicist

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i *6.4 Smith,-Senior. Resident Inspector Q'

'#.A. Bongiovanni.iResident Inspector

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iThe. inspectors.also: interviewed ;other licensee and contractor personnel

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O q*: Denotes : those present_ at the Exit-Meeting on September 28,'1990.

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1. Denotes?those present:at the Telephone Exit: Meeting; on October.12,.1990.

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' General

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. i iThisiinspection was conducted to review aspects:of the licensee's

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tradiation? protection prograni.= Includedln this inspection was a

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4, lfoilow upfofioutstandingfitemslin the' areas 1of' radiation: protection--

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$ P @4" landfra'dioactiveLwaste? management..The inspection 11ncluded -tours of ji e d?fc

radiation controlled areas,1 auxiliary building, radwaste. facilities,-

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observations ofilicensee l activities,z review of representative records'.

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s and.;discussionsiwith licenseeLpersonnel.-

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.a ' ",,13 e Licensee Action:on Prev'

s InspectionLFindinos (IP'92701).

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(Closed) Open Item Nos.:L295/85005-05; 304/85005-05:. Prepare ~

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?. documentation which. identifies required compliance activities for

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NUREG-07371 Items.II.B 3~and'II.F.14(Attachments l', 2 and'3). Since

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r ;g Je mthe licensee has. completed.all NRC. identified actions regarding:this g

r Q,u Tmatter,-this--item is: closed.

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-(Closed) Open: Item No.- 304/86025-06:

Evaluation of ventilation housing m

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drain ; systems to assure conformance with applicable-regulatory require-n

'ments. 4The licensee'slevaluation tresulted fii the initial ~ installation

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of drainline plugs (Temporary Alteration 88-118). The plugs were later replaced byLbubble tight check' valves:(Modification Approval Letter,

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(dated May :31,.1989).

However, because testing. revealed that the

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vinstalled valves did 'not function' properly, Construction ~ Drawing MECN i

1M-22M00003-02;-dated July.9, 1990, was' issued to replace the valves

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with11oop, seals.

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LA Modification Addendum Letter (Subject: Partial Modification

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M22-0-87_-42C,71nstall Loop Seals in HVAC Drain Lines), dated July 20,

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_' -1990, was written to change the affected portions of the original

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= modi fication. approva1L letter.

Housing drain lines are to be installed

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in.the. control room air handling, computer and miscellaneous room air

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. handling.- control room makeup air, hydrogen purge ' auxiliary building

' miscellaneous vents, drumming station, and auxiliary building charcoal

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filter systems. -Since the licensee has completed the subject evaluation V

m and has developed a modification, testing, surveillance and maintenance

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4 program.for implementation of corrective actions that appear appropriate

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1, to ' demonstrate -compliance with regulatory requirements, this item is

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closed.

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.(Closed)0p'en' Item 4 No.'304/86025-07: Administrative controls for-'

'a initiationcof t installed charcoal adsorber delu' e systems.

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211censee's evaluation shoved that only one additional administrative E

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N control-was^ needed and that.one system modification was appropriate.

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Onl April s18,1988, the precaution section of-S01-65, Fire Protection.

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System Operating Instruction,:wae revised to caution operating and fire

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1. g W l brigade personnel?regarding poter.tial radioactive conditions within the

filter: banks and that! radiation protection personnel' were to be contacted

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' prior to: opening 1the filter housings.' The system modification involved-J, ;, ' 7,.

ithe' addition-of loop seals inLthc filter housing drain lines (See closure

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of Open9 Item Nos.c295/U

^ '16; 304;'80025-06:above).- Since the licensee -

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ev at u and, completed / planned. corrective

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~ actions to! resolve idern..,ed i nciencits, this item is closed.

m, I,t f('Clbsed)LUnresolvedItemNo; 304/86025-09:

Review surveillance and-

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l system operation concerns regarding fuel handling exhaust filter bank

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i38fandcdownstreamfcharcoal filter banks (0AV-040 and 041)'.: All three of?these filter banks have successfully passed surveillance and system f

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.< e operabilityLtests,several times since the subject concerns'were

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(Closed)'Open Item'No.'295/89020-01: ; Review; adequacy ofLlicensee's-( > Lt

methods for waste classification-for transuranic.nuclides,to comply,

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with-10 CFR 61.55. Theslicensee'has upgraded waste classif.ication

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' methodologies a~nd procedures.

This itemiis closed.

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0rganizationalp Management Controls-'and Training (IP 83750)

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The' inspectors reviewed the licensee.'s; organization and management..

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4 tcontrols for the radiation protection program,! including: organizational'

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structure, staffing, delineation ofl authority and management techniques'

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. used to ' implement the ' program. and. experience concerning self-identifica-

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tion andicorrection.of program implementation weaknesses..

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[Tra1ningLandQualifications:

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The inspectors reviewed the: training -and-qualification requirements.

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and selected training documentation for radiation protection

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Lperronnel; no problems were noted. ; Discussions with licensee personnel determined that through-the efforts of the RP Training.

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b Coordinator, alrecently added-management position, employee j

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awareness; and. involvement in the program has increased.- The RP

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.StaffJand technicians (RPT) are required to review new and revised

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procedures and to provide comments on them.

The RP group required u

reading. material has been expanded to include not only the new and

. the revised procedures but also discussions of-significant industry u

events and the minuter ai the weekly radiation protection staff meeting.-1Because these chnges provide more involvement in the y

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program for the HPs and the RPTs they should have a positive effect

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w, on morale, ts Theilicensee-:is developing large. color coded charts that delineate-

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, r'adiological control areas around= the plant.

Current plans include postilig these~-charts at major access control. points and Radiation j

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}p$v Work' Permit;(RWP) sign-in areas, in addition, the licensee has

recently adopted the standardized RWP system that is'being

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implemented throughout the Conanonwealth Edison system. This.

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involved both pr'ocedure and documentatim improvements as well-as i

"retrainin3 of: personnel 'who require 'acs..ss to the radiologically a

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L eontrolledia'rea?(RCA).

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The licenseeLis engaged in en ongoing upgrade of radiation n

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protection department procedures.' The format and-presentation

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The approach taken

'Ww hastbeen toirevise'those proceduresithat are;most urgently.needed-4b

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first Fthen address:other. areas'asi i me allow's. This procedure

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.worknis; presently (supported by a' consultant = engaged by the

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>No. violations--orcdeviations ~were identified.

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ib.; (Ur pprove Tempora'ry? Procedure ' Change

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On May130c 1990,(during' the certification of. qualification of a -

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new TLD: Coordinator, an individual. from;the corporate health -

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?physicsigroupimade pen and in_kl changes to the;TLD-Coordinator (f,' W o ? qualification form that is controlled by Zion Station? procedure

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ZTLDPX1100-3, TLD Qualification Card Completion. 'The. changes.

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(incorpor6tedLreflectedqualificationrequirements'establishedby'

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corporate procedure TSTLD

1100-3. - Approval -of these procedure j

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Jchanges was: not obtained as req'uired by Technical" Specifications, a

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!This cisJ a violation of Technical Specification'Section 6.2.4'.'B -

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and6.2.4.C-(Violation 295/90022-01;-304/90024-01).

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- The corporate procedure was -dated April.1988.x The Zion Station-procedure was dated May 30,11990. JZion Station' administrative.

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iprocedureL5-51-3bProcedure Periodic Review,' requires that clant ~

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' proc' dures receive a. review every.two years to ensure that I

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. procedures (reflect current methods and requirements.

Since the-corporate guidance = that was deemed necessary in procedure TSTLD.

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1100-3 was not1 incorporated into Zion. Station' procedures, it

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appears that an inadequate biennial procedure review contributed

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significantly to: this event,

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The inspector. questioned several members of the radiation protection i

e staff:regarding biennial procedure review and temporary procedure

change requirements.

in.the case of biennial procedure. reviews, i

personnel interviewed had an understanding of the requirements for biennial' procedure reviews. However, these individuals were unable b

to: describe the activities-that constituted a biennial proce&re

. review. With regard to the temporary-procedure requirements,

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personnel interviewed did nct appear to.have an understanding of

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= methods of obtaining approval of a temporary procedure. change nor the need to obtain a temporary procedure change.

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The licensee has experienced a problem in the past with unapproved j

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temporary changes to-a procedure. This was a non-cited violation e'

in Inspection Report 50-295/90015(DR5S);50-304/90017(DRSS).

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Oneiviolation was identified.

5.

L Audits, Surveillances.and Self-Assessments '(IP 83750,84750)

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.The: inspectors reviewed theLresults of Quality Assurance audits and k

surveillances conducted by the licensee since the last inspection.

E-Also reviewed were the scope-and thorouchness of the audits and q

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. sur'veillances.

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1The inspectorsLreviewed three QA audits and six-surveillances of

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Radiation Protection /Radwaste/ Transportation for 1989 and 1990 to

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'date. Thetlicensee's QA audit / surveillance program appears adequate-

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ito assess technical performance, compliance with requirements, and

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personnelEtraining / qualification relating to'the radiation protection /

fradwaste/ transportation. program.. The QA auditors assigned to review i

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ithis functional area -appear to have the:necessary expertise and

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(qualification prerequisites. ; Interviews with; appropriate licensee

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personnel indicated thataresponses<to: audit / surveillance findings are

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generally,etimely; and' technically-scund.

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-.TI LNo violations or' deviations were identified.

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! External Exposuro~ Control (IP 83750)

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UThe" inspector reviewed the-licensee's. external exposure control and

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P persona 11 dos'imetry program, including: changes in the program, use of idosimetry to determine whether requirements were met, planning and

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preparation for maintenance and refueling outage tasks. including

Al. ARA considerations and-required records, reports and notifications.-

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~ a '. - Personnel? Dosimetry Program-

Personnel exposureirecords for current and _past licensee and contractor employees were selectively. reviewed for. completeness

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.and accuracy.

In addition, reporting of exposure information

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l-was reviewed for. timeliness. Several instances were identified

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iniwhichithe' licensee did not maintain and preserve exposure records used to prepare the Form NRC-4 exposure records.

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q the! case of single _ page exposure records provided by other l

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licensees, the form letter with the requisite exposure data and

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certifying-signature was maintained in the individuals exposure i

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file,

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However, in the. case of multiple page exposure. records, the pages

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that contained actual-exposure data were_ maintained but the form-

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letter cover page that contained the certifying (c)gnature was si

disposed. This is a-violation of 10 CFR 20.102 (2). This y, 4 '

-outage.1 This practice was terminated as of_ January 1990. The

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a problem was identified. by the licensee duringL the fall refueling

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' licensee now maintains the entire Form 4 records provided by other

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flicensees. 'Since this event was identified by the licensee,~

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l response was timely, and corrective actions.were adequate, pursuant M

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.to'Section V.G.1 of. Appendix C to 10 CFR Part 2, a_ Notice of

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Violation will not be issued for this Severity Level V violation.

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This matter is. closed. (NCV 295/90022-02; 304/90024-02)

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The licensee currently uses a Panasonic TLD system which is i

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National Voluntary Laboratory Accreditation Program accredited

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in all-eight areas by virtue of actual demonstration cf compliance

with ANSI N13.11 - 1983.through testing. The licensee is in the (f f ' '

processiof implementing a Merlin-Gerint electronic dosimetry system.

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- This1 system, when fully operational, will also serve as ~an automated

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access control andias an administrative. exposure control system.-

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w-lThis: system was tested /used during the spring outages and is

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currently--processing approximately:100 workers per day.

The; inspector reviewed the results of 'the Facilit:y intercomparison r -

Study forLthe period-July 1989 to present. - Th_e,tudy indicated

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l good 1 tolerance. results for gamma-dose and reasonably good results I

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It was noted tolthe: licensee that, while the

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results for beta doseiwere within' the-tolerance limit, the values

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phad been trending toward the upper end of the limit since the

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y latter part of 1989.- A' review:of quality control runs for-photon'

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and_ frequency counters identified no problems.-

The licensee [has recently. implemented -a new computerized radiation

records 1 management system. _In addition,iprocedure upgrades in the-Li

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dosimetry and records keeping areas and improvements in records

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j-ke.eping1 practices are ongoing._ The licensee has become a user of

(the INDEX system. -' This system is an industry data: base that tracks-

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- nuclear contract personnel and' pertinent: training... medical and(

exposure records. This-system promises standardization of records

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and expeditingLof contract. personnel assimilation'into the licensee's;

$m work force.

_- il f L-e-0ne non-cited violation was identified,

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LInternal Exposure' Control-(IP 83750)

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The inspectors reviewed the licensee's internal exposure control and cassessment programs,-including: changes'to facilities, equipment, and

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procedures affecting internal exposure-control'and personal-exposure l

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. assessment; determination whether respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records,

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reports,' and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation _ weaknesses, a.

Whole Body Counting The inspector selectively reviewed the results of the licensee's

whole body counting efforts and the results of the last two calibrations of the whole body counter were reviewed.

No problems

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were noted.

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Apparent Routine Use of Respiratory Protective Equipment The licensee has issued a policy statement directed to all station personntl regarding the revision of radiological posting criteria.

- A Potentia 1' Airborne Radioactivity Area is defined as "all areas in which radioactive materials are present in an uncontained and readily.dispersible form in excess of 2,000 dpm per 100 centimeters squared for alpha emitters and 22,000 dpm per centimeters squared for beta / gamma emitters".

Given the aforementioned criteria for potential airborne radio-

. activity areas, it appears that the licensee has either adopted a policy of routine -respiratory protective equipment usage or has established Ja level for which practicable engineering controls will be ' utilized to maintain contamination levels below the aforementioned criteria to preclude routine respirator usage.

Inspection Report No. 50-304/90-12, NRC Mobile 1.aboratory NDE Inspection atL Zion,-also expressed concern regarding the use of respirators-to' perform nondestructive examinations. This item was discussed at length with -the licensee during the. inspection.

The licensee indicated that this policy is being reevaluated and would provide a_ technical basis for respiratory protective-equipment selection upon completion of their evaluation. (0 pen I tem Nc. 295/90022-03;304/90024-03)

No violations or deviations were identified. One open item was tidentified.

-8.

Control of Radioactive Material (IP 83750)

. Th_e _ inspector reviewed the licensee's ' program for control of radioactive,

Lmaterials.and contamination, including: adequacy of. supply, maintenance and calibration of contamination survey and monitoring equipment; effectiveness of. survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of radioactive and contaminated material controls, a.

portable Surver Instruments The inspectors verified by a iaview of records, discussions with licensee personnel, and tours of operatior.a1 areas, that the

l

_

_ _ _

_

_ __ _. - - _ - - -

--- - - -- - - - - - - -

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--_

_ _ _ _ _ _ _........ _...

. _ _..

,

.

,

y supply, maintenance, calibration and performance checks of survey and monitoring instruments were adequate. No significant problems M

were identified.

?

The licensee does, however, appear to have an inordinate number

of portable survey instruments stored in "ie calibration facility C

"

awaiting repair / calibration.

Licensee representatives stated s

,

that the cause.is the prohibition against taking potentially contaminated instruments or instruments with fixed contamination

.,

to the instrument shop, which is not in the radiologically control h.d area (RCA) for repair.

The instrument / maintenance

,

'(IM) technidar,e nast repair the instruments in the calibration

,

facility, which is wi % n the RCA.

This facility appears to

,

be a small, overcro ded and marginal repair facility,

,m

,

The licensee plans to move the RP instrument storage / repair facility to'the former ALARA office which is on-the turbine o,

'

' deck and within the RCA. This should resolve the matter and will be reviewed during a future inspection. There was no

. indication that the number of instruments out of service caused

_,

any operational problems;-however, the inspectors were told by g<

an RPT that some instruments were in short supply during the

n...

recent outage.

4y ib.-

Person'nel Contamination Events-R i-The inspectors reviewed personnel contamination trending reports,

f summaries and analyses for 1988, 1989, and 1990 to date. The 9.*

trend for: personnel contamination events (PCE) is increasing,

,b

,

.

-During 1988, 19G9;and January through September 25, 1990, there

'"

'

were 236,'342 and 497 PCEs, respectively. While a significant

'

number of these events occurred during refueling and maintenance-outages, the causes of -these events' are of concern.

N Random low level shoe contamination / buildup was the attributed cause for 38 PCEs in 1989.and 119'PCEs in 1990 to date. This

'

,

-

' represents 11% and 24% of the total contamination events for

-

1, 1.989 and 1990, respectively.

The levels of contamination dssociated with:these events range from 2,000 dpm to greater

than.30,000 dpm. This is a'significant adverse trend and is

.

indicative of ineffective area decontamination and surveys that

'

"

do -not -appear adequate to evaluate the spread of contamination..

f<%

LHandling contaminated tools, equipment and materials " thought"

-

(surveyed) clean was the cause of 53 PCEs in 1989 and 42 PCEs

4',

in 1990 to date. This represents 15% and 8% of the PCEs for

1989 and 1990 to date, respectively. The levels of contamination

'

Langed from 2,500 dpm to 50,000 dpm. Levels of these magnitudes.

appear to indicate that the implementation of radioactive material release controls and equipment and tool decontamination efforts are weak but improving.

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<?Y, Coming!into-contact with materials previously unidentified as

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contaminated was the cause of 23 PCEs in 1989 and 49 PCEs in

'

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.1990. This -represents 7% and 10% of the PCEs for 1989 and 1990

!

'

to date, respectively.. The. levels of contamination ranged from

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1,875_dpm to'42,500 dpm. These events are associated with

<

P contamination found in unposted areas, recently decontaminated L

areas, air lines crossing contaminated area boundaries and

_ personnel performing work in overhead areas. This is an adverse trend and is representative of ineffective surveys.and poor m

,

'

l radiological-work contro1~.

.

c mM Poor _ radiological work practices, improper protective clothing-

@

worn, improper removal cf respirators, and failure to follow

,y change area. procedures were the cause of 56-PCEs in 1989 and

gl

- 111 PCEs in -1990. iThis represents 16% and 22% of the PCEs in

'

Q*M,

1989 and 1990 to date, respectively. The levels ranged from

_

2,500 dpm to?100,000 dpm.

This is a significant adverse trend

'

-

T;

, and appears ~ to-question' the _ quality of radiological' training

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'

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,

/ and. to question.the level of under. standing by radiological

'

'

workers.of. the -consequences of; exposure to radioactive

,

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contamination.

,

q LExposure to-hot particles was identified in 31 PCEs in 1988, 44 PCEs-

'

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,s-in 1989:and 52 PCEs in.1990 to-date. The trend.for the spread of M

Jhot; particles and their involvement in personnel contaminations.is-

E5

' increasing. _The range.of -hot'. particle activities (associated with k

.

.PCEs)'was from 5,000.dpm-to 1,250,000 dpm. The potential for.

(

.

significant. radiation: exposure due to hot particles is a significant J

-

m concern. : As with random shoe buildup PCEs, the spread d hot

'

particle contamination represents a potential loss.of co strol of

-

_

'

radioactive material. -

Finally,; confidence in the licensee's ability to: perform effective

.

,

surveys :is-~ questioned when a radiation' protection techniciannis

i

,

l observed performing. a." direct frisk".of floor areas-by dragging:the

4 probe on.the floor by.itsi. connecting cable.

Licen'see performance

~~

.

a

in;this tarea: appears to ~ b'e weak.

'

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Contamination Control Initiatives y,

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'

As;noted.in Inspection Report'50-295/90015; 50-304/90017, the.

licensee 'has staffed a full time Contamination Coordinator

. position.,.This ' individual is responsible for trending,; follow up, identifying corrective actions and implementation. Continuing

- g progress-(with noted exceptions,in'Sectionill) is;being made to

-

a

-

m improve the1 material' conditions and' plant appearance. These-

'i

%

'

x efforts are1 characterized?by general cleaning, decontamination of

'

M contaminated areas and painting-the' floors, walls and ceilings

~

,

w withlan epoxy based paint.

L 3The licensee Lplans to implement a contaminated tool crib in the

-

>

-

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, > containment during outages. -As reported, tools with less than

?

22,000 dpm/100; centimeters (cm) squared would be returned for

{m ireuse. Tool! with contami' nation levels' greater than~ 22,000

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1. i j 151

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,dpm/100 cm squared:but less than 100,000 dpm/cm squared would

..

'-

be'de' contaminated in the-containment.- Tools and equipment t

contaminated. n excess of 100,000 dpm/100 would be removed from

[.

the containment for decontamination activities.

-

,

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"

'

_ The -licensee plans' to implement a large area smear (LAS) survey

..

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prog ram. This type of survey would be used during for release

,

of decontaminated areas and routine surveys. As reported, if a y

release survey indicated greater than 1,000 dpm/LAS, then the

(%

area would.be resurveyed with LAS.

If the results from this survey indicated greater than 1,000 dpm/LAS, then the area 3~

'would be decontaminated again.

During routine surveys, if LAS results indicated greater 1,000_ dpm/LAS, then the area would be y

a resurveyed with LAS If the results from-this survey indicated

>

y greater than l',000 dpm/LAS, then the area would resurveyed with

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100 cm squared smears ~ and dispositioned in accordance with the

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>

results of:this; survey.

'

,

,

-No violations orJdeviations were identified. A programmatic weakness

' ~

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was identified'in. the area of contamination controls.

.'

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,

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,9.

Maintaining' Occupational Exposures ALARA (IP' 83750)

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The ' inspector reviewed Ithe licensee's program for maintaining '

.

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ge occupational < exposures ALARA,? including:- ALARA group staffing and

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= qualification;; changes? in ' ALARA policy andLprocedures, and their-C cimplementation; ALARA! considerations for-planned, maintenance and-d refueling outages; worker ' awareness andLinvolvement in the ALARA-t Zg

.

- program; establishment of goals and objectives, and effectiveness in

-

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"' meetin'gLthem. - Also reviewed were management: techniques, program

'

h, g. '. experience' and< correction'of self identified program weaknesses.

-

"

- T The LARA/OperationstSection' consists ;of a lead health physicist (HP),

"M fourihealth physicists, an:RWP coordinator / work analyst, an ALARA

.

coordinatorLa contamination' control coordinator,' and two HP

,

( ' assistants..

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lInih dition to I, heir responsibility for implementing the ALARA program,

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7the' group is also responsible for, the= tool / equipment decontamination

-

'

' program. A member'ofLthe group,:usua_11y the ALARA coordinator, attends

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all, planning-. meetings,

and-tracks the station' pre and post job ALARALmeetings and collates l s perean-rem performance; ; The ALAR.Voperations; i

staff appears to have ~the necessary qualifications and dedication to'

_;

'

,

'

iimplement'an effective ALARA program.

,

'

,

,

[r During the Unit'l forced outage, which lasted 104' days-(3/1/90-6/13/90),

.!

m the= radiation protection' group reviewed 117 radiation work permits (RWP)

E

'for ALARA' considerationb An. ALARA review was-completed on approximately

,5

- 23' job; tasks. Omporary shielding was used ' extensively as an ALARA'

'

tool. -TheLshielding accounted:for 112 person-rem saved. A total ofz

,

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_1515 person-rem was expended during the -Unit 1 forced outage all of whichi

.

was unplanned.

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JThe statiords' initial ALARA. goal for 1990 was 600 person-rem.

The

,5 igoal was revised after the Unit-1 forced outage to 690 person-rem.

-The current'(9/27/90); person-rem dose is 650.

f a x;g No violotions-or deviations were identified.

M W L 10. - Containment Purge Events of April =1990 (IP 93702)

y On Apr.il110,J1990,Ethe reactor. head was vented from 0115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> to

'

s0630 hours0.00729 days <br />0.175 hours <br />0.00104 weeks <br />2.39715e-4 months <br /> into the containment purge system while the 1R-PR09A j

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,

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fra.diation' moni_ tor was inoperable.

On April 11, 1990, the reactor J

-

head was again vented from'0355 hours0.00411 days <br />0.0986 hours <br />5.869709e-4 weeks <br />1.350775e-4 months <br /> to 0710 hours0.00822 days <br />0.197 hours <br />0.00117 weeks <br />2.70155e-4 months <br /> into the containment purge system;while'the 1R-PR09A and IR-PR09C were-Ea

. inoperable. This configuration utilized a tygon hose that routed

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the hydrogen"and fission product gases from the reactor head to'the a

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purge;exhaus't: system. This method of reactor head venting was

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established by.a procedure change to Zion.procedurc MI-1,-Draining

,

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. the~ Reactor Coolant: System. At that time, the Zion Technical m'h

Specifications required that the 1R-PR09 radiation monitor, channels'

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' A','_B and C,. be: operable during containment purge evolutions.

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3ubsec,dentfto'this procedure change, another radiation monitor was

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Tinstalled to monitor the containment purge exhaust system. This lMg

' monitor.o1R-PR40, channels A, B, and C,lprovided redundant monitoring jt Lof containment purge evolutions... During the implementation of the

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' Radiological Ef fluent LTechnical Specifications.n the Zion Technical

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lSpecificati6ns.were revised _to require :that with the number of channels

i operable 11essethan Lthe minimum number required and

no redundant monitor l

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in this flow path. purging (of the: containment shall be. suspended via J

t gd sthis; pathway.

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However, the pathway established by the licensee.to conduct. reactor:

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head ventingLvi'a tygon: hose?to the purge exhaust 1 system did not have

'7

"a: redundant radiation monitor.. ; Th.e tygon hose was piped:into the.

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purge exhaust system at-a locction tlat was between the 1R-PR09 and:

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.1R-PR40 radiation' monitors.

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Thisiresulted in the complete bypass ofL

.

the11R;PR40 monitor., As such, the IR-PR09 radiation. monitor wasithe

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L onlyLeadiation r.aniter with control functions-in the reactor head j

g, sventtpg/ purge flow path.

'

ng By'failing totrecognize ;the implications of this flow path configuration y

F and the inoperable channels;of_. the 1R-PR09 radiation monitor, operations

, @"

personn'el failedLto immediately suspend purging of radioactive effluents

<

on. April 10 and 11,;1990,;as required by Technical Specifications Section'

13.12h Table 3.12-1, Action 7. : These 'are violations. Apparent weaknesses

"

,

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inithe safety evaluation for' this

cenfigurationrand Technical ~ Specification-

'

changes'were contributing causes to this event. The licensee informed the :

'

NRC via red phone, retracted the notification, and after much discussion

'with NRC regional management reinstated the red l phone notification.

>

,

,

m,

,Regarding corrective actions, the licensee will redse the system

.:

ioperating instruction, S01-9, a_nd-procedure ZCP-3L, Documentation of j

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Containment Radioactive Releas6s, to include the ' requirements:for the-

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1R-PR09 radiation monitor-to be operable to perform reactor head vent,

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L releases /purg,es.f This' Severity Level IV violation is.not being cited

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% M, Jbecausesthe criteria specified in Section V.G. of-the Enforcement Policy

were satisfied.l(NCV-295/90022-04; 304/90024-04)

'

.

J Since th'e licensee perfonned react 9rL head vent reletses/ containment '

,,

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1. purges"on April 10 and 11,1990, without the minimum number of operable t.

A

+ - channels and }nn redundant monitor ir thisiflow-path, the plant was x

" operated (in-a: condition: that was prohibited by the' Zion Technical j

f Y" Specif.ications./ Technical Specifications Sectinn 6.6.2.B requires i

N that a? Licensee Event Report;(LER) to be submitted within.30 days l

'

M af ter discovery of any operation'or condition prohibited by Technical

%

Specificationsk The licensee submitted a," voluntary" LER to the NRC.

>

on'0ctober 4, 1990, cThis is a violation. (Violation No. 295/90022-05;

-d

J304/90024-05)

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, ;0ne, violation" arid one ' non-cited violation were identified. -

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P 111.'. Plant Tours?(IP.83750,84750)

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--Th/ inspectors" performed several tours of radiologically controlled

N, i Eareas.GThese; included walkdowns of fuel,' auxiliary, turbine and

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'radwaste buildings. RThe inspectors observed the following:

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=Ra'diation'.sorkers'. access 7and egress from the RCA, and personnel.

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'use of friskingtstations, portal monitors;and electronic dosimetry s

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_were; acceptable.

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1, FContaminations onitori h,; portable survey.. area radiation m

monit' r,ing 7 instrumentation.in'use throughout the plant, and

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' instrumentation ' observed had been recently source checked -

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and had current calibrations, as appropriate.

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b 4 J 'osting ahd 11ats11ng :forf radiation, high-radiation.- contaminated :

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M and; radioactivk material; storage areas, with the exceptionJnoted f

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Jbelow iwere in 'acc6rdance with regulatory re41rements and approveu f

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< station procedures.

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Q W H Housekeeping and(material:honditions; with the exception -noted

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below, were, good and improving, e

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diowever,9 housekeeping and materi,1: conditions in the boric acid storage

.

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tankiroom were poor.: Lin,the boric: acid storage tank roon6 largc amounts.

H

,

Toflboricfacid;< dirt.and(debris were observed spread across the floor

-

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with boric acid piled deep;under_the chemicalc addition mixing tank.

m

.Sur'veys indicated /thatilow -level ' contamination existed in this area.

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. Since this area is; routinely accessed, it1 appears that the control-ofi j

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the

spread ofccontamination-from this area is a-concern.

Other: concerns'

"

iwith respect to storage of mixed waste,: equipment and. materials were i]

"

'

af i identified toithe licensee. The'licenseeccommenced investigations and.-

,

,*

h, 1 E ? corrective actions to resolve these: concerns dur1ng the inspection.-

1. '

LThe" inspectors identified'an unposted and -unbarricaded' contaminated

area lat/near3the-0B lake discharge; pump.

Con' taminated water had run

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off the: pump pedestal, ^beyond the contaminated area boundary and out-

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naceral:ar6a walkways.

This condition had apparently existed

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. for 1 :

B since. there was a large amount of dried residue on the sf t punip s.aeu.el and on the floor. The inspectors also identified three j

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Econtaminated areas that were barricaded as required; however, these j-areas were not pested as contaminated areas. These three areas-included

-

'.

the IB and 1C xharging pump rooms and the 2B safety injection pump room.

^

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. Decontamination affarts were ongoing in the 18 and IC charging pump

'%

-rooms and the 2BisafeP/ injection pump room was awaiting a release survey for the-general area within the room.

These are violations of m,,

j

, Technical; Specification 6.2.2 which requires procedure adherence and

,

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'theLrequirements of procedure ZRP 1101-12, Radiological Postings, Labels,

/Q ilndicators and Their Use. This procedure requires that contaminated

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. areas be barricaded with radiation rope or radiation -tape and be posted

• as contaminated areas. The licensee was notified of these situations-l

-

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.and responded.by surveying the areas in question and posting and

!

barricading the. areas. as contaminated areas. (Violation No. 295/90022-06; j

>>nh-

-304/90024-06)'

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,

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'Thellicensee/has experienced a problem in the past with posting and-M l barricading c'ontaminated areas.

This was a non-cited violation in yf

',

ginspection Report g

-

50-295/90015(DRSS);50-304/90017(DRSS).

s is 0neiviolation'was identified.

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$s w[, $12h Exib Interview"(IP 30703)

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TheC nspectors met with licensee representatives [(denoted in Section 1)

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'following the inspectionLon September 28, 1990, and reexited by telephone i

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,on October 12,)1990, to discuss the scopefand findings of the inspection.

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' ;During{the exit' interview, 'the; inspectors discussed the likely informational

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icontent of 'thel inspection reportLwith; regard Ltoj documents-or processes:

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creviewed by the inspectors during the inspection'.: : Licensee representatives.

.

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fdidanotiidentify any.such' documents or' processes as. proprietary. The

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following matters were specifically discussed.by.the inspectors:

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,

s a.,1 T'he-appdrent l violations (Sections 4.b, '6.a, '10. andL11).

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xbE : Inspector concerns-regardingL the-apparent routine use of respiratory

" protective e uipment. (Section 7.b, 0 pen. Item Nos. 295/90022-03;

1304/90024-03)

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Inspector concerns regarding the apparent weaknes's of the j

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-contamination control-program,-(Section~8.b)'

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