IR 05000295/1997026
| ML20203E529 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203E468 | List: |
| References | |
| 50-295-97-26, 50-304-97-26, NUDOCS 9712170085 | |
| Download: ML20203E529 (17) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-295;50-304 License Nos: DPR 39; DPR-48 Report Nos: 50-295/97026(DRS); 50-304/97026(DRS)
Licensee: Commonwealth Edison Company (Comed)
Facility: Zion Generating Station, Units 1 & 2 Location: 101 Ghiloh Boulevard Zion,IL 60099 Dates: October 27-31,1997 Inspectors: S. Orth, Senior Radiation Specialist N. Shah, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9712170085 971205 PDR ADOCK 05000295 G PDR .
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EXECUTIVE SUMMARY Zion Generating Station, Units 1 & 2 NRC Inspection Reports 50-295/97026; 50-304/97026 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 October 31,1997, performed by two ,
radiation specialists. One violation of NRC requirements was identifie Plant Sucoort
+ One violation was identified concerning the inadequate control of a high radiation area (HRA) within the radioactive waste area. Although the RP staff identified the unlocked area and an additional problem concerning the control of the area, the staff did not perform a thorough review of the additional HRA controlissue. The inspectors identified weaknesses in the communications of expectations and requirements, which contributed to the violation, in addition, corrective actions for two previous HRA access control violations were not effective in preventing this recent violation. (Section R1.1) ,
- The inspectors found radiological hazards in the radio'ogically posted areas to be properly controlled and posted. Although progress was made in the reduction of radioactive contamination in the plant, material condition problems challenged the radiation protection (RP) staff's ability to effectively decontaminate and provide unencumbered access to certain safety related equipment. An auxiliary operator demonstrated good radiation worker practices and knowledge of RP principles. (Section R1.2)
. The respiratory protection program was acceptably implemented, but some weaknesses were identified with station procedural guidance. (Section R2.1)
. Although the RP staff had an ongoing improvement effort, the inspectors observed weaknesses in the documentation of radioactive spills and contamination in and around the facility. (Section R3.1)
= The RP staff continued to implement improvements to the RP program. The RP staff was effectively identifying problems; however, the inspectors observed that corrective
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actions did not always resolve the problems and prevent future occurrences. (Section 7.1)
- One noncited violation was identified concerning the control of radioactive materia The RP staff completed a thorough and comprehensive survey of areas within and outside of the radiologically posted area and identified a significant number of uncontrolled radioactive materials. The staff has taken extensive corrective actions to correct prob' ems in radioactive material control. (Section 8.8)
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Report R91allt IV. PlanLSupoort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 October 17-18.1997 High Radiation Area Control Event Insoection Scone (IP S3750)
The inspectors reviewed an October 17-18,1997, event concerning the loss of positive access control to a posted, locked high radiation area (HRA)in the radioactive waste (radwaste) area. The review consisted of discussions with radiation protection (RP)
personnel, interviews of operations personnel, and a ieview of the RP staff's investigation and subsequent corrective action Observation 3 and Findings On October 16,1997, the licensee completed a transfer of radioactive ion exchange resin to a high integrity container in the radwaste area. The RP staff performed a survey of the area and measured dose rates of about 1500 millirem per hour (millirem /hr) at 30 cm from top of the container. Consequently, the staff posted the area as an HRA and placed a padlock on the door into the area to maintain positive control, as required by Technical Specification (TS) 6.2.2.B. At about 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> on October 18,1997, an RP technician and two other individuals found the required radiological posting for the HRA to be present but found the door to the area unlocked and unattended. The RP technician locked the door and verified that all other HRA doors in the radwaste area were property locked, if applicable. The RP technician reported the incident to RP management and initiated a problem identification form (PIF).
The inspectors discussed the event with members of the RP staff. Based on the recorded entries into the area, the RP staff concluded that the door was previously accessed by a member of the operations staff (i.e., an auxiliary operator) at 1932 hours0.0224 days <br />0.537 hours <br />0.00319 weeks <br />7.35126e-4 months <br /> on October 17,1997, for routine plant inspections and that the individual failed to properly lock the door upon exiting the area. The door remained unlocked for about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. The RP staff reviewed all personnel electronic dosimetry records for the 13 hour1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> period and concluded that no unexpected radiation doses had resulted from the uncontrolled conditio Technical Specification 6.2.2.B requires that areas accessible to pers,,,nnel with radiation levels greater than 1000 millirem /hr at 30 cm from the radiation source or from any surface wh':h the radiation penetrates shall have locked doors to prevent unauthorized entry. Procedure ZAP 610-2 (revisior 5),"High Radiation Area Access Control," required that entrances to accessible HRAs with radiation levels greater than 1000 millirem /hr 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 radwaste area, a locked HRA, on October 17 -18,1997, is a violation of TS 6.2.2.8 (VIO 50-295/97026 01 and 50-304/97026-01).
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During the review of the incident, the RP staff identified an additionalisme conceming the control of the HRA; however, the inspectors identified that the staff did not thoroughly investigate the issue. The staff identified that the auxiliary operator may not have had positive control of the area as required by procedure ZAP 610-2 when he was in the area. To perform a routine inspection, the operator entered the room and verified the operability of a float switch located on the opposite side of the room. During the time that the door was unlocked and the operator was inside of the area, access to the area was not positively controlled. Before the operator could have prevented an unauthorized entry into the area, an individual could have entered the room inrough the unlocked door. Although the liu.nsee had discussed this problem with the above operator, the RP staff had not pursued this issue with another operator who had also entered the area (0845 hours0.00978 days <br />0.235 hours <br />0.0014 weeks <br />3.215225e-4 months <br /> on October 17,1997).
The inspectors interviewed the operator who had accessed the area at 0845 hours0.00978 days <br />0.235 hours <br />0.0014 weeks <br />3.215225e-4 months <br /> on October 17,1997, discussed his actions while in the area, and identified a weakness concerning the communicaCon of RP expectations. While performing inspections of the area, the operator also left the HRA door unlocked and unattended. He indicated that the RP staff had not briefed him before entering the area and had not indicated that an additional individual may have been necessary to control the entrance. With respect to instructions on HRA controls, the operator remembered reviewing reading material supplied to the operations staff after a previous HRA violation but only remembered formal training in the context of general employee training. The operator also indicated that he was not familiar with revision 5 of procedure ZAP 610-2 which contained a note stating that an HRA key custodian was not to perform any other job tasks that would effect his or her responsibilities, including the prevention of unauthorized access to the HRA. Based on this discussion, the inspectors concluded that the RP staff had not effectively communicated its expectations to the operations staff after previous HRA violation The inspectors discussed with the RP staff the immediate corrective actions for the event. For the individual who left the door unlocked, the RP staff restricted the individual's access to the radiologically posted area, provided training to the individual, and planned to re-interview the individual to ensure he understood HRA requirement On October 20,1997, the radiation protection manager issued instructions to the RP i and operations staff for entrance into locked HRAs. For example, individuals were to ensure that locked HRA doors were concurrently verified upon exiting. The key custodian was required to remain at the door until another person verified that it was locked in addition, at least two individuals were required for any entry into a locked HRA which did not have a self closing / locking mechanism. In this case, one individual was required to remain outside of the area to provide a means of positive control. The inspectors discussed with RP management the previous two HRA control violations on April 1 and July 1 of 1997 (NRC Inspection Report Nos. 50-295/97020(DRS) and 50-304/97020(DRS)) and the concern that the associated corrective actions had not prevented this inciden Conclusions One violation was identified concerning the inadequate control of an HRA within the radioactive waste area. Although the RP staff identified the unlocked area and an additional problem concerning the control of the area, the staff did not perform a 4 l
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thorough review of the additional HRA controlissue. The inspectors identified weaknesses in the communications of expectations and requirements, which contributed to the violation. In addition, corrective actions for two previous HRA access control violations were not effective in preventing this recent violatio R1.2 Plant Radiological Conditions Insoection Scoce (83750)
The inspectors reviewed the radiological conditions of the plant. The inspectors assessed the control of contaminetion area boundaries, the posting of radiological hazards, and the control of locked HRAs. In addition, the inspectors accompanied a member of the operations staff on routine inspections within tne radiologically posted area (RPA). Observations and Findings During inspections of the Auxiliary Building and Fuel Handling Building, the inspectors found tnat contamination, radiation, and high radiation areas were properly posted and controlled. The inspectors noted progress in the reduction of contaminated areas of the plant. For example, the licensee had decontaminated significant portions of the crystallizer and evaporator rooms. In addition, the staff had decontaminated significant portions of the horizontal and vertical pipe chases. However, significant portions of the residual heat removal pump and heat exchanger rooms remained coniaminated. In these areas, uncontaminated walk-ways were maintained so that operations personnel could enter the areas without donning protective clothing; however, access to the equipment remained encumbered, in the case of other safety related equipment, the staff had decontaminated the areas or had confined the contamination to the pumps and/or leak collection trays. The radiation protection manager indicated that further initiatwee were ongoing but acknowledged that the material condition of plant equipment challenged progress in some area The insoectors accompanied an auxiliary operator during routine plant inspections. The operator demonstrated good radiation worker practices and a good understanding of basic RP principles. During the inspection, the operator was observed to adhere to RP requirements for accessing HRAs and contaminated areas. However, the inspectors obsented that the leak collection trays for a number of contam!nated pumps contained measurable, standing amounts of fluids. The inspectors were concerned that the condition may challengo contamination control and the identification of existing leakag For example, if the drain in the collection tray becomes blocked, the level of fluid may exceed the volume of the tray and may spread into uncontaminated areas. The licensee acknowledged the inspectors' observation Conclusions The inspectors found radiological hazards in the RPA to be properly controlled and posted. Although progress was made in the reduction of radioactive contamination in the plant, material condition problems challenged the RP staff's ability to effectively decontaminate and provide unencumberai access to certain safety related equipmen . . .- .- -. - . . . -- .-
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An auxiliary operator demonstrated good radiation worker practices and knowledge'of RP principle R2 Status of RP&C Facilities and Equipment R2.1 Resolratorv Protection Prooram Insoection Scope The inspectors reviewed the implementation of the respiratory protection program as defined in 10 CFR Part 20, Subpart H. The inspection consisted of interviews with workers, a walkdown of the respirator storage and issuance areas, and a review of training records and the following procedures:
.- ZRP 5500-1 (revision 4) " Radiological Respiratory Control Program,"
- ZRP 5500-2 (revision 1)" Maintenance of Respiratory Protection Equipment," and
. ZRP 5510-1 (revision 3)" Issuance and Retum of Respiratory Protection Equipment." Observations and Findinas The RP staff was responsible for all respirators except for self-contained breathing apparatuses (SCBAs), which were the responsibility of the operations group through the fire brigade. Through interviews, the inspectors verified that those RP staff overseeing the respirator program were knowledgeable of applicable procedural and 10 CFR Part 20 requirements and that workers who had received respiratory protection training were knowledgeable of specific respirator use requirements and limitations.
. Through interviews with fire brigade personnel and a selective review of the fire brigade plan and operations department procedures, the inspectors verified that SCBAs were
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properly maintained. Since all plant operators were assigned to the fire brigade, the licensee required all operators to be clean-shaven and to have current medical evaluations. During plant walkdowns, the inspectors interviewed several operators and determined that those requirements were understoo During a review of procedures, the inspectors identified some minor problems Lnd inconsistencies. For example, the procedures did not provide clear direction for the
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ev~uation of engineering controls and for the frequency of medical evaluations. The licensee acknowledged that the procedures contained some inconsistencies and lacked clarity in certain areas. The RP staff indicated that a corporate review of the respiratory program was ongoing, including a planned procedural revision addressing the
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inspectors finding The inspectors walked down the designated storage cnd issuance areas and found respirators to be in good condition and to be operable. Prior to issuance, an RP technician verified that the respirator user had received training and that the assigned respirator was in good condition. During interviews with the inspectors, the RP
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- - Conclusions The respiratory protection program was acceptably implemented, but some weaknesses were identfied with station procedural guidanc R3 RP&C Procedures and Documentation R3.1 Qocumentation of Soills and Contamination (IP 83750)
The inspectors reviewed the licensee's documentation of spills or other unusual occurrences involving the spread of radioactive contamination in and around the facility, equipment, or site, as required by 10 CFR 50.75(g). As stated in the requirements, these records may be limited to instances when significant contamination remains after decontamination or when contamination may have spread to inaccessible areas. Prior to this inspection, the inspectors had discussed this issue with members of the RP staff, who were not aware of any documentation and were uncertain if such events had occurred. Consequently, the RP staff was reviewing various plant records and corrective action systems to determine if spills or other occurrences had taken place in the past which should have been characterized and documented in addition, the staff was planning to develop a program and procedures to ensure that these types of
occurrences were properly documented and that the required records were properly maintained. At the time of this inspection, the RP staff had not comp!sted the aforementioned activities, Members of RP management acknowledged the weaknesses in this area and the potential for unknown, undocumented contamination to be present in and around the facility. In future inspections, the inspectors will review the RP staff's progress in identifying, characterizing, and documenting past contamination events and the development of a program ano procedures to document future events
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(IFl 50-295/97026-02 and 50-304/97026-02).
R7 Q:'ality Assurance in RP&C Activities R7.1 RP Imorovement Program Progress and Assessments of the RP Proaram Insoect;on Scoce (IP 83750)
The inspectors reviewed the RP staff's progress in improving program performanc The inspectors discussed improvement plans with the RP staff and reviewed the results
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of program assessments.
' Observations and Findings The inspectors obsewed that the RP staff had identified weaknesses in the as-low-as-is-reasonably-achievable (ALARA) program and was revisingicreating procedures and guides to better defin9 the ALARA program at the site. The lead health physicist-operations had begun a project to provide instructions for routine ALARA program components, including outage pieparation, shielding planning, and source term reduction. The individualindicated that these procedures and guides were planned to provide clear expectations of the sandards of ALARA program products. In addition, the licensee planned to strengthen the role of the ALARA review board and the department ALARA coordinator _ _ - _ _ - .. .. .. . _ _ _ .
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The RP staff had also taken action to correct problems identified in a quality assurance audit of the radioactive waste program. The audit was performed to monitor the staffs progress in resolving previously identified deficiencies in the radioactive waste and transportation program. The inspectors found the audit to be well performed and to properly identify issues in the program. For example, the auditor identified some minor problems concerning the procedures and identified that certain commitments were not proper!'? tracked. The staff acted appropriately to correct those items ider.tified in the audi The inspectors acknowledged the RP staffs initiatives in the self assessment and program improvement areas; he ;,ever, the inspectors were concemed about the adequacy of RP corrective actions. Although the RP staff was identifying problems, the corrective actions did not always prevent subsequent issues. For example,15e RP staff implemented corrective actions for HRA control violations in April and July of 1997, but the licensee identified an additional HRA control violation in October of 1997 (Section R1.1). In addition, problems concerning the calibration of portable instrumentaticn were identified by the RP staff in July of 1997 and again during this inspection, indicating that corrective actions needed improvement. The RP manager cknowledged the inspectors' concerns e.nd indicateo that the staff had maoi 1ress but still had room for improvemen Conclusions The RP staff continued to implement improvements to the RP program. The RP staff was effectively identifying problems; however, the inspectors observed that corrective actions did not always resolve the problems and prevent future occurrence R8 Miscellaneous RP&C lssues R (Closed) Violation (VIO) Nos. 50-295/96006-11 and 50-304/96006-11: The licensee failed to properly post a radiation area in the Auxiliary Building. As documented in NRC Inspection Report Nos. 50-295/97009(DRS) and 50-304/97009(DRS), the RP staff had not documented or tracked the results of daily radiological posting reviews, and the inspectors had identified some problems concerning radiological posting and boundaries. Subsequently, the RP staff maintained better documentation of the daily posting verifications. The inspectors found that the verifications were properly performed r "I that problems were properly resolved. In addition, a member of the RP staff was reviewing the results of the verifications to ensure that performance trends were properly documented and that applicable items were properly documented in PlF Overall, the daily verifications indicated that the frequency of radiological posting and boun ary problems was significantly reduced and that identified problems were minor in nature. In addition, the RP staff assessed the skills of RP technicians and provided training to correct any deficiencies. The inspectors reviews of the RPA (Section R1.2)
did not identify any radiation areas that were not properly posted. This violation is close R8.2 [ Closed) Unresolved l' am (URI) Nos. 50-295/96016-02 an< 50-304/96016-02: The inspectors identified P i anomaly in the air flow from the primary sample room on the 592' elevation of the Auxiliary Building, i.e. air was flowing from a contaminated area to a uncontaminated area. This airflow conflicted with Section 9.3.2.1.2.2.3 of the Updated 8 l
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Final Safety Analysis Report (UFSAR). During an evaluation of the ventilation system, the engineering staff identified that a panel was missing from the dumbwaiter system that operates between the chemistry laboratory on the 617' elevation and the primary sample room, which provided an alternate ventilation path. As designed and as described in plant drawings, the dumbwaiter shaft was suppued to be a sealed syste In October of 1996, the staff performed an operability assoson.9nt, found the system to be operable, and initiated an engineering request to install a ner panel and to re-seal the shaft. In January of 1997, the staff completed the modification, and no subsequent problems were identified. In addition, the licensee decontaminated the primary sample room, which eliminated the potential for any further airflow anomalies. The inspectors concluded that the licensee performed the required actions when this item was identified. This item is close R8.3 (Ocen) URI Nos. 50 295/96021-02 and 50-304/96021-02: As the chemical drain tank pumps were inoperable, the licensee was processing the chemical drain tank contents in a manner contrary to UFSAR sections 11.2.2.2 and 11.2.2.8. The licensee determined that a safety evaluation had not been performed for the system configuration described in NRC Inspection Report Nos. 50-295/96021(DRS) and 50-304/96021(DRS). The engineering staff initiated a PlF (No. 97-0096) to track the resolution of the discrepancies. At the time of this inspection, the engineering staff had not performed an evaluation to determine the safety impact of the change. This issue will remain open pending the completion of the licensee's evaluatio R8.4 (Ocen) URI Nos. 50-295/96021-03 and 50-304/96021-03: The inspectors identified discrepancies between the Section 11.2 of the UFSAR and the manner in which radioactive waste tanks were sampled and the manner in which the radioactive waste evaporator was maintained. The engineering staff initiated a PIF (No. 97-0096) to track the resolution of the discrepancies. On March 18,1997, the engineering staff had performed safety evaluation no.97-034 to evaluate the current manner in which radioactive waste tanks were sampled and processed and did not identify any unresolved safety questions. Subsequently, the engineering staff had identified some concerns with that evaluation and were performing a review of the evaluation. In addition, the staff had not performed an evaluation for the operation of the radioactive waste evaporator but planned to complete an evaluation in the future. This issue will remain open pending the completion of the licensee's review of safety evaluation 97-034 and the completion of an evaluation of the radioactive waste evaporato R8.5 (Closed) VIO 50-295/97002-10 and 50-304/97002-10: On April 1,1997, the entrance to the Unit 1 vertical pipe chase, a high radiation area having radiation levels of approximately 1,500 millirem /hr, was not controlled as required by procedure ZAP 610-02. As documented in NRC inspection Report No. 50-295/97020(DRS) and 50-304/97020(DRS), the licensee experienced an additional violation of ZAP 610-2 on July 1,1997, and questioned the effectiveness of the initial corrective actions for the April 1,1997, violation. Consequently, the licensee implemented additional corrective actions documented in the above inspection report. At the time of this inspection, the RP staff had completed all of the corrective actions including a revision to ZAP 610-2 (revision 5) which explicitly limited the duties of persons assigned to control an HRA ke Based on the similar violation described in Section R1.1, these additional corrective actions did not appear fully effective. This item is closed, and the licensee additional corrective actions will be followed as VIO No. 50-295/97026-01 and 50-304/97026-0 I _ - ________-_-
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R8.6 - fClosed) VIO 50-295/97009-01 and 50-304/9700E01: A violation with three examples was identified concerning the failure to adequately follow RP procedure in the case of Example 1, NRC inspectors identified that cords and hoses crossing contaminated area boundaries were not secured as required by procedure ZRP 5721-6 (revision 1)," Construction of Radiological Posted Contaminated Areas and Step Off Areas." After the examples wore identified, the RP staff performed inspections of the RPA and identified and corrected unsecured cords and hoses. The licensee attributed the violation to weaknesses in radiation worker standards and RP oversight of radiation workers. -To prevent future occurrences, the RP staff communicated expectations to
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personnel via Zion Station Policy Statement 1-30 'Radiatior. Worker Accountability,"-
which indicated the consequences for radiation worker practice problems. As documented in NRC Inspection Peport Nos. 50-295/97015(DRS) and 50-304/97015 (DRS), the RP staff assigned RP technicians to zones within the Auxiliary Building to provide better assistance to radiation workers ad to provide better oversight of -
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radiation worker practices. The licensee planned to review this coverage process by December 31,1997, to determine if future changes to the process were necessar During this inspection, the inspectors reviewed the control of contaminated area boundaries and did not identify any problems. This example is closed.
in the case of Example 2, NRC inspectors identified that catch containment drain tubing was not labeled in accordance with the requirements of procedure ZRP 5010-01 (revision 3)" Radiological Posting and Labeling Requirements." Similar to Exarnple 1, the licensee attributed the violation to inadequate communication of expectations for Wper set-up of catch containments and insufficient RP oversight. To correct the problem, the licensee implemented the corrective actions discussed in Example 1 and
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established a catch containment program via RP standing order no. SO 97-17 (July 30, 1997)" Catch Containment Maintenance (Rev.1)." The standing order established a -
program to set-up and track catch containments and to provide a surveillance of existing catch containments. The inspectors compared the most recent catch containment log to the field conoitions and did not identify any problems. Catch containments were properly labeled and numbered. This exarnple is closed, in the case of Examplo 3, NRC inspectors identified that personnel removing protective clothing containers fwm a contaminated area failed to survey each bag of clothing in -
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accordance with temporary change TA-96-489 to procedure ZRP 5721-5 (revision 1),
" Collecting, Laundering, Surveying, and Reissue Protective Clothing." The inspectors verified that the licensee had completed corrective actions associated with this viciation:
. On June 2,1997, the staff implemented revision 3 of ZRP 5721-5 to clearly define the requirements for handling contaminated protective clothing;
- The RP staff revised radiation work permit (RWP) No. 97003," Routine work performed by the Station Labor and Contractor Labor Dept." to state that a survey of the laundry was required; and
. The staff implemented a training program for decontamination technicians to ensure that individuals had the proper instructions for performing their assigned work activities and to raise the standards of these individual <-
The inspectors accompanied two individuals performing routine laundry rounds, The individuals demonstrated a good knowledge of the requirements and performed the evolutions in accordance with the RWP and procedure. This example is close RB.7 (Closed) Ifl No. 50-295/91DQ9.-Q3.and 50-304/97009-03_: The licensee planned to resolve a discrepancy between the basis for TS 4.18 and the alarm setpoints of the Unit 1 and 2 steam jet air ejector and steam generator blowdown radiation monitors. The RP staff indicated that the licensee's improved TS will remove this inconsistency. The '
inspectors reviewed the applicable section of the improved TS and its basis and verified that there were no references to either radiation monitor or alarrn setpoints. The licensee planned to implement the improved TS prior to the startup of either unit. The inspectors also verified that the licensee had reviewed and updated (as applicable) the Offsite Dose Calculation Manual and the UFSAR. This item is close R8.8 (Closed) Insoection Follow-uo itemBos. 50-296/97015-01 and 50-204/97015-Q.1%
Results of licensee's site-wide survey for radioactive material inside or outside the RP The RP staff completed the survey on October 15,1997, and identified a total of 1434 improperly controlled items (264 found outside the RPA) having measurable fixed and/or removable contamination, ranging from 1,000-25,000 disintegrations per minute over 100 cmr . After identifying the items, all items found outside the RPA were retumed to appropriate radioactive material storage areas. The inspectors noted that the level of contarnination did not pose a radiological dose hazard to the public. However, the RP staff identified that a significant number (about 19 percent) of those items found were in proximity to the corporate visitor center. Through staff interviews and direct inspection, the licensee venfied that no radioactive material was located in the visitor cente As documented in NRC inspection Report Nos. 50-295/97015(DRS) and 50-304/97015(DRS), the RP staff had identified several weaknesses in the radioactive material control program and had implemented immediate corrective actions. In particular, the staff identified weaknesses in worker accountability and in ownetuip and maintenance of designated storage areas (such as tool storage areas). Immediate correctivo actions included designating only one RPA ingress / egress point, requiring that all items leaving the RPA be surveyed by RP staff, and placing all designated satellite RPAs under RP control. The licensee planned to revise station procedures for radioactive material control and satellite RPAs, designate a new tool storage area, and develop a program for routine site-wide searches of areas inside!outside the RP The failure to control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage is a violation of 10 CFR 20.1802. The inspectors recognized the extensive corrective actions completed by the licensee and the corrective actions planned to improve the overall radioactive material control program. As the violation was licensee identified and corrected, it is being treated as a Non-Cited Violation consistent with section Vll.B.1 of the NRC Enforcement Pohev (NCV 50-296/97026-03 and 50-304/97026-03).
The inspectors observed activities at the RPA access point and performed a walkdown of the following satellite RPAs: the West Warehouse; miscellaneous railroad cars and sea-land containers; the east Dry Active Waste building; radioactive waste outside storage area; waste water treatment drying beds; '.hermoluminescent dosimeter irradiator room; instrument maintenance calibrated tooi storage and repair facilities; and
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the RP digital dosimeter calibration facility. Radioactive material was properly controlled at the access point, and no proolems were identified with those specific areas inspectr:d. A walkdown was also performed at public accessible areas of the visitor centar; no problems were identifie RS.9 [C103ed) VIO_50-295/RQ20;_Q1L.50-304197020-01: On July 1,1997, the entrance to the Unit 1 Containment Building rnissile barrier, a high radiation area with a radiation dose rate of greater than 1000 millirem /hr, was not controlled as required by procedure ZAP 610-02. As described in Section R8.4, the staff completed corrective actions for the violation; however, a similar violation (Section R1,1) occurred after the corrective actions were in place which question the effectiveness of the corrective actions. This item is closed, and the licensee additional corrective actions will be followed as VIO No. 50-295/97026-01 and 50-304/97026-0 V Management Meelln91 X1 Exit Meeting Summary On October 31,1997, the inspectors presented the inspection results to licensee managemen Trie licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie i
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- PARTIAL LISY OF PERSONS CONTACTED J. Baxter. Radiation Protection
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A. Christensen, Quality and Safety Assessment R. Davey, Engineering R. Godley, Regulatory Assurance Manager
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F. Jones, Regulatory Assurance E. Katzman, Radiation Protection Manager M. Phalen, Radiation Protection
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B. Robinson, Radiation Protection R. Starkey, Plant General Manager R. Zydur k. Quality and Safety.? ssecsment INSPECTION PROCEDURES USED IP 33750: Occupational Radiation Exposure IP 92904: Followup - Plant Support t
ITEMS OPENED, CLOSED, AND DISCUSSED
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OPENEQ 50-295/97026-01 VIO Failure to maintain adequate control of entrances to an 50 304/97026-01 HRA. (Section R1.1)
50-295/97026-02 IFl Licensec planned to implement program and procedures 50-295/97026 02 to document radioactive material spills and abnormal occurrences and to investigate past incidents. (Section R3.1)
-CLOSED 50-295/96006-11 VIO FaHure to adequately post a radiation area. (Section R8.1)
50-304/96006-11 50 295/96016-02 URI Ventilation flow from primary sample room inconsistent
- 50 304/96016-02- with statements in UFSAR. (Section R8.2)
50-295/37002-10 VIO Failure to adequately control the entrance to an HR /97002 10 (Section R8.5)
50-295/97009-01 VIO Three examples of failure to adequately adhere to RP
,
50 304/97009-0 procedures. (Section R8.6)
50-295/97009 03 'Fl Resolution of inconsistencies between TS basis 4.18 and 50-304/97009-03 the plant systems. (Section R8.7)
50-295/97015-01 IFI Control of Radioactive Material. - (Section R8.8)
50-304/97015-01-13
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50 295/97020 01- VIO Failure to adequately control the entra' m to an HR /97020-01 (Section R8.9)
50-295/97026-03 NCV Failure to adequately control radioactive materia /97026-03 (Section RC.8)
Discussed 50 295/06021-02 URI inconsistencies between Section 11.2 of the UFSAR and 50-304/96021-02 the processing of liquid from the chemical drain tan (Section M.3)
50-295/96021-03 URI Inconsistencies between Section 11.2 of the UFSAR and 50-304/96021-03 the sampling of radioactive waste tanks and the operation of the radioactive waste evaporator. (Section R8.4)
.
l a
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LIST OF ACRONYMS USED ALARA As-Low As Is-Reasonably-Achievable HRA High Radiation Area <
IFl inspection Follow-up Item NCV Non Cited Violation PIF Problem identification Form RP Radiation Protection RPA Radiologically Posted Area RP&C Radiation Protection and Chemistry RWP Radiation Work Permit SCBA Self Contained Breathing Apparatus TS Technical Specificulon UFSAR Updated Final Safety Analysis Report URI Unreso'ved item VIO Violation j 15
- _ _ _ _ _ _ _ _ _ _- _-
_ _ _ _ - ._.._._ ..__._ _ _ _ _. _ . _ _ _ . _ _ _ _ _ _ _ _.-
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i PARTIAL LIST OF DOCUMENTS REVIEWED >
'
Attachment A of ZAP 610-02 (revision 5)"High Radiation Area Access Control," for the 592'
-
elevation of the radioactive waste area dated OMober 1718,1997.
Nuclear General Employee Training (N-GET) Module RESP, " Level 1 Respiratory Training,"
revision 2,
'
Problem identification Forms Nos. Z1997-00980, Z1997-02309, and Z1997-02465.
.,
Radiation Protection Technician B Initial Training Process Module RTPI PE52, " Respirator
'
Inspection and Repair," revision 0.
- Radiological Survey Nos. 97 2346 and 97 236 Zion Radiation Protection Procedures
ZRP 50101 (revision 6)" Radiological Posting and Labeling Requirements" l
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ZRP 5800-6 (revision 0)" Administrative Controts for Portable Health Physics Instrumentation"
.
l Zion Station Radwaste/ Rad Material Handling, Packaging and Transportation Audit Report 22-
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97 08, dated October 16,1997, s
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