IR 05000295/1996002

Insp Repts 50-295/96-02 & 50-304/96-02 on 961203-970122.No Violations Noted.Major Areas Discussed:Shipment of Radioactive Matls Exceeding Limits of 49CFR173.425 & Inadequately Training Personnel IAW Procedure

ML20137M865
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/01/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137M827	List: IR 05000295/1996002 ML20137M822
References
50-295-96-02-01, 50-295-96-2-1, 50-304-96-02, 50-304-96-2, NUDOCS 9704080193
Download: ML20137M865 (37)

Text

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U. S. NUCLEAR REGULATORY COMMISSION {

REGION lil i l

Docket Nos: 50-295; 50-304 Licenses No: DPR-39; DPR-48

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Licensee: Commonwealth Edison Company j Facility: Zion Generating Station -1 Dates: March 19,1997 l

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Meeting Location: Region 111 Office 1 801 Warrenville Road )

Lisle, IL 60532-4351

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Type of Meeting: Predecisional Enforcement Conference inspection: Zion Station j

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December 3,1996 - January 22,1997 i l

inspector: S. K. Orth, Radiation Specialist Approved by: Thomas J. Kozak, Chief, Plant Support Branch 2 Division of Reactor Safety Meetino Summarv

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Predecisional Enforcement Conference on March 19.1997  !

Areas Discussed: Apparent violations identified during the inspection were discussed, along with the corrective actions taken or planned by the licensee. The apparent violations involved: (1) a shipment of radioactive materials exceeding the limits of 49 CFR 173.425; (2) inadequately maintaining radioactive material shipping procedures; (3) inadequately i implementing radioactive material shipping procedures; (4) inadequately implementing l radiation control procedures; and (5) inadequately training personnel in accordance with procedures, in addition,' the licensee discussed planned actions to improve overall station ,

radiation protection performanc l

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l 9704000193 970401 PDR ADOCK 05000295 l 0 PDR

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Report Details Persons Present at Conference Commonwealth Edison Comoany (Comed)

T. Maiman, Senior Vice President J. Mueller, Site Vice President R. Starkey, Plant General Manager W. Strodi, Health Physics Supervisor F. Rescek, Corporate Health Physics Support Director M. Pavey, Licensing R. Laburn, Lead Health Physicist T. Bergner, Training Manager R. Godley, Regulatory Assurance Manager U. S. Nuclear Reaulatory Commission A. B. Beach, Regional Administrator, Rill G. Grant, Director, Division of Reactor Safety, Rlli J. Caldwell, Director, Division of Reactor Projects, Rlli R. Capra, Director, Projects Division 111, NRR T. Kozak, Chief, Plant Support Branch 2, Rlli M. Dapas, Chief, Reactor Projects Branch 2, Rlli H. B. Clayton, Enforcement Officer, Rlli S. Orth, Radiation Specialist, Rlll T. Vogel, Senior Resident inspector, Zion Station, Rlli C. Shiraki, Project Manager, Zion, NRR 1 Predecisional Enforcement Conference A Predecisional Enforcement Conference was held in the NRC Region lli Office on March 19,1997. This conference was conducted as a result of the findings of an inspection conducted December 3,1996, through January 22,1997, in which five apparent violations of NRC regulations were identified. The inspection findings were documented in inspection Reports No. 50-295/96021(DRS): 50-304/96021(DRS) transmitted to the licensee by letter dated February 11,199 The purpose of this conference was to discuss the apparent violations, root causes, contributing factors, and the licensee's corrective actions, in addition, the licensee discussed circumstances that contributed to the lack of attention to and oversight of the radioactive material transportation program and the planned actions to improve overall performance in radiation protectio ~

During the Predecisional Enforcement Conference, the licensee acknowledged the apparent violations. The licensee's presentation included a synopsis of the apparent violations, investigation results, safety significance, and corrective actions. A copy of the licensee's handout is attached to this repor Attachment: As stated

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Radwaste Enforcement Conference  ;

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Zion Station March 19,1997

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Agenda e Enforcement Conference Methodology e Programmatic Issues / Actions /Results e Specific Violations issues / Actions e Regulatory Considerations e Closing Remarks

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Presentation Methodology e Appropriate Focus is on Programmatic Implications of Specific Violation Issues

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Specific Issues are Symptoms of Broader Considerations e Failed to Provide Proper Oversight for Radiation Protection Programs

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Programmatic Issues Frank Rescek Radiation Protection Director l Corporate l

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Programmatic Issues

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e Organizational Breakdown e Organization-To-Program Interface e Vague or Unclear Management Expectations i

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Programmatic Issues

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e Effects of Programmatic Issues:

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Fragmented Radwaste Processing and Shipping Program Organization

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Inadequate Resource Priority

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Poorly Defined and Administered Radwaste

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Shipping Training Requirements Inadequate Procedure Update Timeliness

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Inadequate Process for Comparing the

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UFSAR to Radwaste Activities

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Programmatic Actions

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Organization

e Single Person Responsibility / Accountability

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Reorganization Decision Made ,

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e RadWaste Laborers Report to Radiation Protection e Protective Clothing Program Transferred to Radiation Protection e Engineering Support

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Rebaseline UFSAR j -

Materiel Condition Action Plan for RadWaste

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Process Rad Monitor Action Plan initiated l

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Programmatic Actions

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Program / Process e Management Emphasis on Understanding Importance of Compliance and Performance-Based Standards

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Address Personnel Regulatory Ethic

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RP Dept. Conduct of operations issued

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Developing Quals for RP Management Positions

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Procedure and UFSAR Adherence e Use/ Monitor Surveillance System

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Programmatic Actions Program / Process (cont.)

e Management Focus on Identifying and Utilizing Lessons Learned From Other Comed Sites, Industry 1 i

e Self-Assessment Program for Performance '

Monitoring e Improving Tracking, Accountability Regarding Personnel Training

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Programmatic Actions

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RP Department Improvement

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e Organization / Staffing e Procecure/ Process

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e Self-Assessment e Performance Indicators

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Station RP Performance .

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e Source Term Reduction e ALARA Processes .

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e Radiation Worker Practices

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Specific Violations .

Rick LaBurn Lead Health Physicist

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1. Radioactive Materials Shipment in Excess of 40CFR173.425 2. Radiation Control Procedures -

3. Required Annual Samples and Analysis of Waste Streams 4. Control of Potentially Contaminated Rod '

5. Radwaste Shipper Training

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49 CFR 173.425 Shipping Failure to satisfy 49 C.F.R.173.421, which requires, in part, that a Class 7 radioactive material whose activity per package does not exceed the limits specified in 49 CFR 173.425 and its packaging, are excepted from the specification for packaging, marking, and labeling, and the shipping paper and certification requirements if the radiation level at any l point on the external surface of the package does not exceed 0.5 mrem /h _ - - _

49 CFR 173.425 Shipping causes

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e Inadequate Supervisory Review and Oversight e Inadequate Regulatory Ethic

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Inattention to Detail e Inadequate Procedure Guiding Independent Review Activities

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49 CFR 173.425

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Shipping Violation-Continued Corrective Actions e included Independent Review Expectations in Shipping Procedure e Event Included in Ongoing Continuing Training l e implemented Department Conduct of

Operations Standard

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Maintenance of RP Procedures

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The NRC determined that ZRP 5600-7, "Offsite Shipment of Radioactive Material," Revision 0, dated November 2,1993, contained inaccurate instructions for determining packaging requirements (i.e., activity limits, LSA classification, SCO classification, etc.).

Specifically, this procedure contained instructions which complied with the previous regulations and, thus, were outdate .

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Maintenance of RP Procedures Causes

e Inadequate Regulatory Ethic

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Failure to Address Known Procedure Deficiencies

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Failure to Document Known Procedural Deficiencies e Lack of Experience / Knowledgeable with Respect to Shipping Process / Program

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Maintenance of Procedures

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Corrective Actions e Suspended Radioactive Material Shipping e Deleted Outdated Procedures e Implemented Department Conduct of Operations Standard e Initiated Rebaseline of All Radiation Protection i Procedures

Technical Specification 6.2. Sampling Zion did not obtain and analyze annual samples of SG blowdown resin and primary resin as required by Technical Specification 6.2.2.A and ZRP 5610-4, " Preparation and Shipment of Samples for Special Analysis",

dated November 12,1993, and ZRP 5610-10,

" Radioactive Waste Shipments" dated December 12,199 _ _ - - - -

Technical Specification 6.2. Sampling Causes e Inadequate Regulatory Ethic -

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Failure to Utilize Corrective Action Progra'm e Inadecuate Procedural / Process Requirements I e Inadequate Organizational Infrastructure e Inadequate Management Oversight

Technical Specification 6.2. Sampling Corrective Actions l

e Individual Waste Streams included in Station Surveillance Procedure e Performed Appropriate 10CFR61 Analyses e implemented New Analyses / Trending Procedure e Developing Personnel Qualification / Training Guideline e Expectation Establishment, Communication, and Feedback

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Technical Specification 6.2. Contamination Practices Zion failed to follow Technical Specification 6.2.2.A and ZAP 610-03, " Unescorted Access To and Conduct in Radiolically Posted Areas," Revision 1, dated September 12,1996 which requires that personnel are to contain contaminated equipment removed from contaminated areas or have the equipment released by a Radiation Protection technicia ,

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Technical Specification 6.2. Contamination Practices cause e Inadequate Regulatory Ethic -

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Inconsistent / Absent Accountability Regarding Radiation Protection

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Requirements

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Inadequate Su aervisory Oversight

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Technical Specification 6.2. Contamination Practices Corrective Actions e Technician Surveyed and Controlled the Tool e Communicate and Establish Expectations Through Enhanced Training Interface e Implemented Radiation Protection In-Fieid Observation Program i

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Radwaste Shipping Personnel

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Training Ted Bergner Training Manager

Radwaste Shipping Personnel

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Training Two members of the Operations Staff were involved in the shipping program and were authorized to release radioactive shipments,

! but had not satisfied the requirements of Technical Specification 6.1.5 and ZAP 200-09,

" Training," dated September 17,199 _ - _ - - - _

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Radwaste Shipping Personnel Training Cause.

l e Inadequate Regulatory Ethic -

e Inadequate Coorcination Between Training and Radwaste Department Requirements

Radwaste Shipping Personnel Training

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Corrective Actions e Short Term -

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Operators' Training Completed

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Evaluated Potential Extent of Condition ~

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IdentificationNalidation of Appropriate Training Procedures

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Evaluated / Revised Training Matrixes

Radwaste Shipping Personnel Training Corrective Actions (cont)

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Development and Implementation of Course Failure Notification Policy

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Interface Established Between Training I and Radwaste Shipping Assignments

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c Radwaste Shipping Personnel  ;

Training

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e Long-Term

- Validate / Update Qualification Requirements

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Re-Visit Effectiveness of Actions and Adjust as Necessary

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Regulatory Considerations Robert Godley Regulatory Assurance Manager

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Regulatory Considerations e No Actual Safety Consequences e Minimal Potential Safety Consequences e Regulatory Significance

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Duration of Deficiencies

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Extended Knowledge of Deficiencies

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Programmatic Issues /Causes

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Management / Supervisory Oversight

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Regulatory Considerations e Zion has Accepted that Significant

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Program Improvements are Necessary 1

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e Self-Assessment Abilities are Improving

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Recent Self-Assessment was Intrusive and Critical of Radwaste Program

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Plans

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Closing Rem. arks .

Rob Starkey l General Manager

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