IR 05000295/1997020
| ML20217R345 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/26/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217R339 | List: |
| References | |
| 50-295-97-20, 50-304-97-20, NUDOCS 9709050078 | |
| Download: ML20217R345 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos:
50-295; 50 304 License Nos:
50 295/97020(DRS); 50-304/97020(DRS)
Licensee:
Commonwealth Edison Company (Comed)
Facility:
Zion Generating Station, Units 1 & 2 Location:
101 Shiloh Boulevard Zion, IL 60099 Dates:
July 28 - August 1,1997 Inspector:
S. Orth, Senior Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9709050078 970826
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PDR ADOCK 05000295 G
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EXECUTIVE SUMMARY Zion Generating Station, Units 1 & 2 NRC Inspection Report 50-295/97020; 50-304/97020 This announced inspection included aspects of the licensee's plant support performance and, specifically, an evaluation of the effectiveness of the radiation protection (RP)
program. The report covers a one week inspection concluding on August 1,1997, performed by a radiation specialist. Four violations of NRC requirements were identified.
Plant Sucoort One violation was identified concerning the inadequate control of a high radiation
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area within the Unit 2 Containment Building. Corrective actions for a previous high radiation area access control violation were not effective in preventing the recent violation. (Section R1.1)
Evaluations concerning the use of respiratory protection were performed based on
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sound radiation protection principles to ensure that the total effective dose equivalent (TEDE) was maintained as-low as-is reasonably-achievable (ALARA).
However, the inspector identified some documentation problems concerning the basis for the evaluations. (Section R1.2)
Commitments contained in the Action Plan to Imorove' Performance of Radiation
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Monitorina System (transmitted in a December 20,1996, letter from J. H. Mueller to the NRC) were met. A March 1997 assessment of the Radiation Monitoring System (RMS) was a thorough evaluation of system performance, indicated positive effects of corrective actions from the improvement plan, and recommended several additional improvement items. However, the inspector noted a decline in routine RMS oversight and monitoring. (Section R2.1)
One violation was identified concerning the failure to identify and post
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contaminated areas within the Units 1 and 2 containment spray pump rooms.
(Section R2.2)
A violation was identified concerning the failure to adhere to the station
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configuration control requirements. RP personnel manipulated plant equipment without required procedures, which resulted in an unexpected containment isolation signal. Corrective actions for a similar event were not effective in preventing the violation. (Section R4.1)
One cited and one non-cited violation were identified concerning compensatory
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measures for inoperable radiation monitors. (Sections R8.1 and R8.2)
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Report Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls
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R1.1 July 1.1997. Hinh Radiation Area Control Event
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inspection Scope (IP 83750)
The inspector reviewed a July 1,1997, event concerning the loss of positive access control to the missile barrier of the Unit 2 Containment Building, a posted locked high radiation area (HRA). The review consisted of discussions with radiation protection (RP) personnel and a review of the staff's investigation and subsequent actions.
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Observations and Findinas On July 1,1997, two insulation installers were performing work within the Unit 2 Containment Building missile barrier, which was posted as a locked HRA. Based on RP surveys, areas within the missilo barrier had radiation levels greater than 1000 millirem per hour (mrom/hr). Consequently, the entrance to the area was posted and controlled as a locked HRA. While the two insulation installers were inside, two contract RP technicians provided coverage of the area and maintained positive control of the missile barrier entrance, in accordance with step H.2 ofstation procedure ZAP 610-2, "High Radiation Area Access Control," revision 3. The RP technicians were briefed on the work activity and had been trained concerning HRA key control. Upon completion of the work activities, the two insulation installers encountered difficulties exiting the missile barrier area but could not locate the RP technicians at the access point. The RP technicians had left the access point to analyze contamination survey results and to perform additional surveys, failing to provide direct surveillance of the access point, in addition, the RP technicians had placed an untatched padlock through the hasp on the access door which should not have prevented the insulation installers' egress from the missile barrier area.
Several minutes later, an RP technician returned to the access point. Based on the survey of the area and electronic dosimetry results, the insulators were in a low dose area at the access point (less than 1 millirem /hr) and received less than 10 millirem for their entire entry. In addition, no unauthorized personnel had entered the area.
The inspector discussed with the RP staff the adequacy of corrective action for previous HRA controlissues. The licensee acknowledged that the above control event was similar to an April 1,1997, event in which the entrance to tne Unit 1 vertical pipe chase, an HRA with radiation levels greater than 1000 rmrem/hr, was not locked nor adequately control!ed by an individual. That event was the subject of an NRC Notice of Violation and was described in NRC Inspection Report No.
50-295/97002(DRP); 50-304/97002(DRP). In addition, the inspector learned that the contract RP technicians were not informed of the April 1 event and that the RP
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staff had identified other recent problems concerning HRA and other radiological postings, in the licensee's July 11,1997, response to the above Notice of Violation, the licensee described the July 1,1997, event, and consequently, questioned the effectiveness of initial corrective actions for the April 1 event.
Based on the additional event on July 1, the licensee instituted additional corrective actions, including the following:
the two contract RP technicians involved in the July 1 event were removed
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from the site; all contract RP technicians were disqualified from HRA activities and were
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retrained; the events were discussed with all RP staff during immediate stand-down
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meetings and were planned to be further reviewed with RP technicians and supervisors during continuing training; and the licensee planned to revise ZRP 610 2 to explicitly limit the duties of
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personnel assigned to HRA access control.
Technical Specification (TS) 6.2.2.B requires areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 30 cm from the radiation source or from any surface which the radiation penetrates to have locked doors to prevent unauthorized entry. Procedure ZAr-610 2 required that entrances to accessible HRAs with radiation levels greater than 1000 mrem /hr at 30 im be locked or be controlled by a key custodian who has direct oversight of and positive control over each personnel entry into the area. The failure to lock or to maintain positive control over the entry to the Unit 2 missile barrier, a locked HRA, on July 1,1997, is a violation of TS 6.2.2.B (VIO 50-295/97020-01; 50-304/97020-01),
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Conclusions e
The inspector identified one violation concerning the inadequate control of an HRA within the Unit 2 Containment Building. Corrective actions for a previous HRA access control violation were not effective in preventing this violation.
R1.2 Evaluations for the Use of Resoiratorv Protection a.
Insoection Scoce (IP 83750)
The inspector reviewed the RP staff's evaluations of respiratory protection and engineering controls to maintain the total effective dose equivalent (TEDE) as-low-as-is-reasonably-achievable (ALARA). The inspectors reviewed the following radiation work permits (RWPs) to verify that the licensee had performed respiratory protection evaluations as required by ZRP 55001, " Radiological Respiratory Control Program," revision 3, and ZRP 6200-5, " Writing Radiation Work Permits," revision 7:
RWP No. 95-3234-0, "Decon of the cavity area in prep of the RX t.ead disassembly and reassembly," dated September 1,1995;
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RWP No. 95-4234-0, "Decon of the cavity area in prep of the RX head disassembly and reassembly," dated January 9,1995; RWP No. 964234, "Decon of the cavity area in prep of the RX head disassembly and reassembly," revision 0; RWP No. 964501, "Make various repairs to 2FCV-VC0110A, 2FC-VC0110B,2FC-VC0111B, 2MOV VC1128, and 2MOV-VC112C," revision 0;
RWP No. 964502, " Repack 2VC8370A, 2VC8402A, and 2VC8402B,"
revision 0; RWP No. 970141, "Open barrels, check for water and reseal," revision 0; RWP No. 973:r.34, "Decon of the cavity area in prep of the RX head disassembly and reassembly," revision 0; RWP No. 974966, "All Support U 2 Containment Painting," revision 0; RWP No. 974968, " Painting / seal coating containment (scraping / chipping paint, surface prop)," revision 0; and RWP No. 974975, " Accumulator level transmitter MOD #E22 2 97 264,"
revision O.
The inspector also discussed RWP preparation with members of the RP staff.
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Observations and Findinas During RWP preparation, procedure ZRP 6200 5 referred the RWP preparer to ZRP 55001 for guidance in determining respiratory protection requirements. Although the inspector identified some minor problems, procedure ZRP 55001 provided instructions for the evaluation of respirator use based on sound radiation protection
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principles, in accordance with NRC guidance contained in NUREG/CR-6204,
" Questions and Answers Based on Revised 10 CFR Part 20," the licensee established a threshold (i.e., radioactivity concentrations in air of less than 0.3 derived air concentrations (DACs)) for which respiratory protection was not needed and a further evaluation was not required. However, the procedure stated that the application of engineering controls should be evaluated, if the airborne concentration was not less than 0.3 DAC, procedure ZRP 55001 required the licensee to evaluate the use of engineering controls to reduce the airborne concentration, if the airborne concentration could not be reduced below 0.3 DAC using engineering controls, procedure ZRP 55001 required an evaluation to determine if respiratory protection would be issued. Based on worker efficiency studies, a 20 percent increase in efficiency was applied when respirators were not employed. Procedure ZRP 5500-1 contained a flow chart and a graphical representation of dose rates versus airborne concentrations to define cases where respiratory protection would be necessary to maintain the workers' TEDE ALARA.
During a review of RWPs generated from 1995 through 1997, the inspector observed that evaluations were performed as required by licensee procedures.
However, in cases when the airborne concentrations were expected to be less than 0.3 DAC, procedure ZRP 5500-1 was unclear concerning what documentation was required in the RWP package. Consequently, the inspector identified some problems concerning these documents. For example, the documentation did not
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consistently indicate the basis for which the licensee determined that the airborne concentration would be less than 0.3 DAC. Historical survey data was available
which provided a basis for the licensee's evaluations, but the evaluations did not specify what data was used to support the conclusions. The inspector noted that
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the documentation was improved for the more recent RWPs. The RP staff acknowledged the weaknesses in documentation and planned to review and to improve the process. The results of the staff's evaluation will be reviewed in a subsequent inspection (IFl 50 295/97020 02; 50 304/97020-02),
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Conclusions The licensee's evaluations concerning the use of respiratory protection were performed based on sound radiation protection principles to ensure that the TEDE was maintained ALARA. However, some documentation problems were identified concerning the basis for the evaluations.
R2 Status of RP&C Facilities and Equipment R 2.1 Operability of the Radiation Monitorino Svstem a.
Insoection Scooe llPs 83750, 92904)
The inspector reviewed the operability of the radiation monitoring system (RMS).
Specifically, the inspector reviewed the implementation of the Action Plan to Imorove Performance of Radiation Monitorino System _. transmitted in a December 20,1996, letter from J. H. Mueller (Comed) to the U.S. Nuclear Regulatory Commission, b.
Observations and Findinos The system engineer responsible for the RMS was knowledgeable of system function and design. However, the inspector noted some problems concerning program oversight. The inspector noted that the individual was only recently assigned the RMS responsibility, and trends of system operability and availability had not been performed since August of 1996. In eddition, the tumover from the previous system engineer was minimal. For example, the system engineer was not awara of the monthly RMS status reports that had been performed since October of 1994. The radiation monitor task force was also disbanded in the fall of 1996.
The task force had represented the station groups responsible for the RMS system and had been tasked with expediting system improvements. However, the system engineer was aware of the status of current work requests and design changes as discussed below and planned to initiate a trending system.
The inspector reviewed the status of items contained in the RMS action plan with the responsible system and design engineers. In the action plan, the licensee committed to milestones for (a) radiation monitor abandonment; (b) modifications to correct air regulator / sampling system failures; (c) control room ratemeter replacement; (d) system particulate, iodine, noble gas (SPING) console
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modifications; (e) modifications to decrease SPING nuisance alarms; (f) evaluations of check source failure prevention; and (g) an RMS self assessment. The inspector verified that the actions concerned with items (a), (b), (d), (e), (f), and (g) had been completed. The modification of the control room ratemeter (item (c)) was in the planning and desiga stages.
The inspector noted that the review of potential candidates for monitor abandonment (item (a)) was completed in May of 1997. Based on redundancy and other reliable indications, the report identified 2 monitors 1(2)RT-PR27 (Failed Fuel Radiation Monitors) which could reasonably be abandoned. However, the remaining 28 candidates had functions which were linked to design criteria and which provided usefulinformation for accident or abnormal operations. Based on these functions, the review indicated that these monitors should be maintained. The staff identified that 16 of the 28 monitors had performance problems attributable to air regulator / sampling system failures (item (b)) and initiated actions to have the design modifications installed on the monitors.
The self assessment performed in March of 1997 was a comprehensive overview of RMS performance over the previous 24 months. The results of the assessment were consistent with previous system engineering reviews and documented the poor reliability of several of the monitors. in addition, the assessor identified a number of improvement items which the system engineering staff were planning to review and to implement. For example, the assessment identified a number of components for which replacement parts were not available and recommended a major upgrade of system components. As documented above, the licensee was planning such an upgrade, in addition, the self-assessment confirmed that the licensee's actions were consistent with the failure mechanisms that were observed, and the licensee's actions should have a positive effect on system reliability. For
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example, the modification to replace the flow regulatory sampling systems was focused on a significant source of maintenance problems and was expected to significantly reduce the RMS maintenance efforts.
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Conclusions
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The commitments contained in the Action Plan to improve Performance of Radiatiora Monitorino Svstem (transmitted in a December 20,1996, letter from J. H. Mueller
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to the NRC) were met. The licensee's March 1997 assessment of the RMS was a thorough evaluation of system performance, indicated positive effects of corrective actions from the improvement plan, and recommended several additional '
improvement items. However, a decline in routine RMS oversight and monitoring was evident.
R2.2 Radioloaical Conditions in Radioloaically Posted Areas f.P 83750)
On July 30,1997, the inspector reviewed the posting and control of radiological hazards within the Auxiliary Building. High radiation areas and radiation areas were conspicuously posted and controlled. However, the inspector identified some problems concerning the posting of contaminated areas. Procedure ZRP 5010-1,
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" Radiological Posting and Labeling Requirements," revision 4, requires that areas, which have removable beta gamma contamination at levels greater than or equal to 1000 disintegrations per minute (dpm) per 100 cm', be posted " Caution, Contaminated Area." In the Units 1 and 2 containment spray rooms, the inspector identified severalindications of boric acid leakage on pump seals and on instruments within the rooms. However, the leakage was outside of posted
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contamination areas. Following the inspector's observations, an RP technician
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performed surveys of the areas and identified removable, beta-gamma contamina2 ion levels of 1000 to 5000 dpm per 100 cm on seals associated with containment spray pumps 1 A,2A, and 2C, and on an instrument rack in the Unit 1
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containment spray room. Subsequently, contaminated area boundaries and postings were constructed around all of the applicable equipment. Technical a
Specification 6.2.1 requires that written procedures be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33,
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Revision 2. Appendix A of RG 1.33 recommends procedures covering contamination control be implemented. Procedure ZRP 50101 provided instructions for contaminated areas within the plant. The failure to post
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contaminated areas within the Unit 1 and 2 containment spray pump rooms in
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accordance with procedure ZRP 50101 is a violation of TS 6.2.1.
(VIO 50 295/97020-03; 50-304/97020 03)
R4 Staff Knowledge and Performance in RP&C R4.1 Improper Manioulation of a Radiation Monitor a.
inspection Scope (IP 84750)
The inspector reviewed a July 14,1997, event in which a member of the RP staff performed troubleshooting of the Unit 2 containment air radiation monitor (2RIA-PR40), resulting in a Unit 2 containment ventilation isolation signal. This review consisted of interviews with RP and operations personnel and of documents associated with the event.
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Findinas and Observations On July 14,1997, a health physicist on the RP staff investigated a problem with
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the flow to 2RIA PR40 experienced the prior evening during routine tritium sampling. The individual notified the Unit 2 control room staff of his intentions to obtain a tritium sample from 2RIA PR40 and that he would be putting the monitor in the maintenance mode. Since the console for the radiation monitor had been transferred to Unit 1 control, the Unit 2 nuclear station operator (NSO) instructed the health physicist to maintain follow-up communications with the Unit 1 NSO.
The health physicist placed 2RIA-PR40 in the maintenance mode and proceeded to follow the procedure for obtaining a tritium sample. While obtaining the sample,
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the health physicist identified and resolved a minor problem with the position of the sample regulator, which had contributed to the !ow flow condition the previous night. After he completed the evolution, the health physicist placed the monitor in the normal mode; however, the monitor still indicated locally that it was in the
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maintenance mode. The health physicist notified the Unit 1 NSO of the discrepancy in the local indication. However, the NSO indicated that control room indications were showing the monitor in the flush mode and that the rnonitor was still inoperable.
The health physicist questioned other RP and instrument maintenance technicians in
the area regarding possible solutions to.he problem. The technicians suggested
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that the health physicist remove powe' from the monitor and restart the monitor.
Although he did not have a procedure covering the evolution, the health physicist notified the Unit 1 NSO that he intended to restart the monitor and proceeded to take the action. The actions resolved the indications problems, but the loss of power to the monitor resulted in an unexpected low flow failure annunciator alarm and a containment ventilation isolation signal in the Unit 2 control room. The health physicist had anticipated these consequences, but he had not informed the control room staff of his expectations, in addition, the Unit 1 NSO did not inform the Unit 2 NSO of the health physicist's intended actions.
The inspector identified problents concerning the conduct of the evolution. For example, the discussions between the health physicist and Unit 1 NSO did not clearly define the postulated effects of the evolution. Although the health physicist was aware of the potential consequences, he believed that he was not responsible for informing the NSO In addition, the Unit 1 NSO did not communicate to the Unit 2 NSO the intended manipulation of Unit 2 equipment. Procedure ZAP 300-1,
" Conduct of Operations," revision 4, states that the operations department has the responsibility and authority over all plant systems and equipment, except as stated in Station Policy 211, " Configuration Control." Station Policy 2-11, dated April 7, 1997, states that plant equipment may be operated by personnel outside of their operational authority if (1) the work is part of a work request task or Out-Of-Service Request Principle or (2) the manipulation is controlled by an applicable procedure or work instruction that requires or provides a record of specified information including the licensed shift supervisor's determination of the final position / state. However, the health physicist manipulated the equipment without an approved procedure or work instruction containing the specified information.
Technical Specification TS 6.2.1 requires that written procedures be implemented covering the applicable procedures recommended in Appendix A of RG 1.33, Revision 2. Appendix A of RG 1.33 recommends procedures covering equipment control be implemented. Procedure ZAP 300-1 provided instructions for the control and manipulation of plant equipment. The failure to perform the manipulations of 2RIA-PR40 in accordance with procedure ZAP 300-1 is a violation of TS 6.2.1.
(VIO 50-295/97020-04; 50-304/97020-04)
The inspector identified that a similar event had occurred within the last 12 months.
On September 28,1996, an RP technician was troubleshooting radiation monitor 2RIA-PR40. Without a procedure, the RP technician removed power from the monitor which resulted in a trip of an ongoing containment purge. The inspector interviewed members of the 7 end operations staff; however, they were unfamiliar with the event and the corrective actions. Although the event was documented in
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a problem identification form, the licensee could not determirie what actions i
resulted from the event. The inspector concluded that the licensee's corrective actions for the September 28,1996, event were not fully effective, c.
Conclusions The inspectar identified a violation concerning the failun to adhere to the station configuration control requirements. Radiation protection personnel manipulated plant equipment without required procedures, which resulted in an unexpected containment isolation signal. Corrective actions for a similar event were not ef fective in preventing the violation.
R8 Miscellaneous RP&C issues R8.1 LQ1 gad) Licensee Event Report (LER) 97 010-0: On April 6,1997, a unit supervisor (US) of the operations staff identified t* at required area radiation surveys had not been performed for an inoperable area radiation monitor associated with the primary sample room (ORE 0006). On April 4,1997, the monitor failed and was declared inoperable. However, tlee same US incorrectly determined that no compensatory measures were necessary. Table 3.141 of TS 3.14 required that area surveys be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when ORE 0006 was inoperable. Between 0450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> on April 4,1997, and 0552 hours0.00639 days <br />0.153 hours <br />9.126984e-4 weeks <br />2.10036e-4 months <br /> on April 6, 1997, the licensee missed two area surveys, in the LER, the licensee attributed the problem to (1) a cognitive error by the US in his review of the TS, (2) a lack of sufficient reviews, and (3) an error in procedule ZRP 582012, "Out of Service Requirements for Radiation Monitors." Step 3 of procedure ZRP 582012 incorrectly listed ORE 0000 as a monitor which did not require a routine surveillance. As corretive actions, the licensee counseled the control room staff, corrected procedure ~f.' 582012, modified operations procedures to provido additional reviews, tno planned to enhance operations staff training.
The inspector noted that inadequacies of procedure ZRP 582012 and problems communicating /revlowing actions concerning inoperable radiation inonitors were the subject of previous NRC Notices of Violation (VIO 50 295/96010 09(DRP):
50-304/96010 09(DRP) and 50 295/96016 05b(DRS); 50-304/96016 05b(DRS),
respectively). The similar problems described above indicated that the corrective actions associated with these violations were not fully effective. The failure to perform surveys of the areas associated with the primary sample room area radiation monitor between 0450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> on April 4,1997, and 0552 hours0.00639 days <br />0.153 hours <br />9.126984e-4 weeks <br />2.10036e-4 months <br /> on April 6,1997,is a violaticn of TS 3,14 (VIO 50-295/97020 05; 50 304/97020-05).
R8.2 (Closed) LER 97 014-0:. During corrective actions for LER 97 010 (section R8.1)
and restart reviews, the licensee identified that TS surveillance requirements for radiation monitors 1(2)RT PR15 were not properly reflected in procedure ZRP 5820-12. When 1(2)RT PR15 were inoperable, Table 3.141 of TS 3.14 requires the j
licensee to perform a grab sample analy:,is at least once per shift. Seven radiation
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monitors per unit (1(2)RT PRO 1 thrr agh 1(2)RT PR07) provided inputs into
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112)RT PR15, i.e., the sample blowers for the monitors provided the sample flow l
for 1(2)RT PR15. Historically, the licensee performed grab samples when iadiation monitors 1(2)RT PR07, which were also listed in Table 3.141 were not in service.
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However, the licensee did not take the required compensatory actions for 1(2)RT-PR15 when radiation monitors 1(21RT PR01 through 1(2)RT PR06 were out of service. During the above review, the licensee identified this problem and initiated corrective actions to correct procedures and other licensco documents. This licensee identified and corrected violation is being treated as a Non Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Manual (NCV 50 295/97020 06: 50 304/97020 06).
R8.3 1Clostid) VIO 50 295/96016-03:50-304/96016 03: On September 24,1995, the licensee performed core alterations when radiation monitors required by TS 3.13.3.c, which isolate containment vent and purgo systems, were Inoperable. The inspector noted that the licensoo had completed the following corrective actions:
Technicians were trained on the proper method of handling particulate filter
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paper and continuing training for RP technicians for 1996 addressed the SPING RMS, Procedure ZRP 602133, " Documentation of Contalement Radioactive
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Releases," was revised to require that the radiation monitors be verified operable after a temporary stoppage of a purge, and A modification was completed on July 8,1997, to require an
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acknowledgoment for SPlNG alarms.
The inspector verified that no similar events had been documented in the licensee's corrective action system. This violation is closed.
R8.4 (Closed) VIO 50 295/96016-04: 50-295/96016-04: On July 5,1996, grab samples were not performed at least once per shif t when radiation monitor OR-PR07 had less than one operable channel, as required by TS 3.14. The inspector noted that the licensee had completed the following corrective actions:
Section C of procedure ZRP 582012 was revised to state that a 25 percent
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grace period did not apply to surveillances performed as a result of inoperable monitors, Chemistry personnel were trained on the use of grace periods provided in TS - 4.0.2 in November of 1996, and The RP Manager initiated Radiation Protection Standing Order No. 96 016,
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dated October 30,1996, which stated actions required by RP personnelin response to inoperable radiation monitors whicS require compensatory measUtes.
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The inspector verif>d that no similar events had been documented in the licensee's correctivo action systems. This violation is closed.
I R8.5 IClosed) VIO 50 295/96016 0Bla, bh 50 304/96016 05(a, b): On July 20,1996, and September 22 25,1990, the licenseo failed to perform Offsite Dose Calculation Manual required grab sampling when monitors 1RE 0015 and 2RT PR25, respect}vely, were inoperable. The inspector noted that the licensee had completed the corrective actions transmitted in the December 20,1990, response to the NRC Notice of Violation. Licensee management had (1) counseled the individuals involved in the first event, (2) reviewed the events with applicable RP and operations staff, (3) discussed limiting condition of operation status at the plan of the day meeting, and (4) stressed the need for face to-face communications with operations personnel, in addition, the RMS display system had been corrected, and similar failures had not occurred.
However, the inspector noted that the raissed compensatory surveys described in Section RB.1 of this report shared certain similarities to this violation (example b).
Although the licensed shif t supervisor was aware of the inoperable monitor (2RT-PR25), he incorrectly assumed that the failure was a previously Identified problem and failed to initiate required compensatory measures. Similar to the failure to correctly review the requirements for monitor ORE-006 (Section R8.1), the operations staff did not adequately review the requirements for the inoperable monitor 2RT PR25. Corrective actions wlli be reviewed for tbs violation (VIO 50 295/97020 05; 50 304/97020-05) described in Section R8.1. This violation is t
closed.
V. Manaoement Meetinos X1 Exit Meeting Summary n
n August 1,1997, the inspector presented the inspection results to licensee management. The licensee aC.mowledged the findlags presented.
The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. This licensee identified none.
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PARTIAL LIST OF PERSONS CONTACTED D. Beutel, Regulatory Assurance R. Godley, Regulatory Assurance Manager E. Katzman, Radiation Protection Manager J. Mueller, Site Vice President M. Phalen, Radiation Protection R. Starkey, Plant General Manager INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure IP 84750:
Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904:
Followup - Plant Support ITEMS OPENED, CLOSED, AND DISCUSSED OPENED 50-295/304 97020-01 VIO Failure to maintain adequate control of entrances to an HRA.
50-295/304 97020 02 IFl Licensoo planned to review documentation required for respiratory protection evaluations.
50 295/304-97020 03 VIO Failure to post contaminated areas in accordance with RP procedures.
50-295/304 97020-04 VIO Failure to manipulate plant equipment with required procedures.
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50-295/304 97020-05 VIO Failure to perform required area surveys when monitor ORE 006 was inoperable.
50 295/304 97020-06 NCV inadequate procedure requirements concerning the compensatory measure for 1(2)RT PR15.
CLOSED 50-295/304-97010-00 LER Failure to perform required area surveys when monitor ORE-000 was inoperable.
50-295/304 97014-00 LER Inadequate procedure requirements concerning the compensatory measure for 1(2)RT-PR15.
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50 295/304 96016 03 VIO Failure to meet the requirements of TS 3.13.3.c while performing core alterations.
50 295/304 96010 04 VIO Failure to perform TS required grab samples
'
when monitor OR PR07 was inoperable.
50 295/304 96016-05(a,b) VIO Failure to perform ODCM required compensatory measures when radiation monitors were inoperable.
_ _ _ _ _
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LIST OF ACRONYMS USED ALARA As Low As-is Reasonably Achievable
!
DAC Derived Air Concentration (
DPM Disintegrations Por Minute l
IFI Inspection Follow up ltern l
LER Licensee Event Report j
LSS Licensed Shif t Supervisor l
MREM Millirem
'
NCV Non Cited Violation
.
NSO Nuclear Station Operator PlF Problem Identification Form RG Regulatory Gulde RMS Radiation Monitoring System RP Radiation Protection RP&C Radiation Protection and Chemistry RWP Radiation Work Permit SPING System Particulate, lodine, Noble Gas TEDE Total Effective Dose Equivalent TS Technical Specification VIO Violation
_
_ _ _
._
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.
PARTIAL tlST OF DOCUMENTS REVIEWED Comed Memorandum to M. Schimmel, dated July E22 2 97 263, " Replace Radiation Monitor Blowers with24 PR, Exempt Change No.:
'
s em:
,
centrifugal oil less blowers."
Radiation Monitoring System Self Assessment." Comed Memorand of
,
Review of System Engineering Proposal to Abandon A
,
Units 1 and 2."
at Zion Problem identification Forms (PlFs) No.:
00670, Z1997 00763, Z1997 00847, Z1997-0087096 2827, Z1997 00493, Z1997 00662, Z1 PT-0, Appendix D, Revision 11. " Operating Surveillance Checksheets "
.
Operating for LCO Surveillances." Radiation Protection Standing Order N on to
,
007o7, dated July 8,1997.SPING Console Sealin Alarm Acknowledgement Pus
,
Radiation Protection Survey Nos. 971409,97-1476, 971486, and 971500.
Zion Radiation Protection Procedures; ZRP 50101, " Radiological Posting and Labeling Requirements," Revision 5
.
ZRP 602133, " Documentation of Containment Radioactive Releases " Revision 3
,
.
ZRP 6200 5, " Writing Radiation Work Permits," Revision 7.
i