IR 05000295/1998004

Insp Repts 50-295/98-04 & 50-304/98-04 on 980203-0313.No Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20217J372
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/31/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217J350	List: IR 05000295/1998004 ML20217J346
References
50-295-98-04, 50-295-98-4, 50-304-98-04, 50-304-98-4, NUDOCS 9804060279
Download: ML20217J372 (15)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket Nos: 50-295;50-304 License Nos: DPR-39; DPR-48 Report No: 50-295/98004(DRP); 50-304/98004(DRP)

Licensee: Commonwealth Edison Company

. Facility: Zion Nuclear Plant, Units 1 and 2 Location: 101 Shiloh Boulevard Zion,IL 60099 Date: February 3 through March 13,1998 Inspectors: A. Vogel, Senior Resident inspector D. Calhoun, Resident inspector S. Orth, Senior Radiation Specialist J. Yesinowski, Illinois Department of Nuclear Safety inspector Approved by: Kenneth G. O'Brien, Acting Chief Reactor Projects Branch 2 Division of Reactor Projects 9804060279 980331 PDR ADOCK 05000295 G PDR

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EXECUTIVE SUMMARY Zion Nuclear Plant, Units 1 and 2 NRC Inspection Report No. 50-295/98004(DRP); 50-304/98004(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant 3 support. The report covers a six-week period of inspection activities by the resident and I region-based inspectors. Performance during this inspection period was adequate; however,

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there were several instances of deficient personnel performance. Plant management actions to address the deficient performance were effective in re-focusing station personnel's attention on the safe conduct of their duties and, in conjunction with close management oversight and involvement, ensured that Unit 2 defueling activitier were safely accomplishe Operations

. The inspectors concluded that plant management was effective in re-focusing station personnel's attention, after the plant closure announcement, to ensure the Unit 2 defueling evolutions were safely performed (Section 01.1). ]

• Management effectively ensured operators were prepared to conduct the fuel movements through the performance of practice fuel transfers with a " dummy" fuel assembly and the use of infrequent evolution briefings that property emphasized safety, communications, and contingencies. Fuel handlers and operators maintained proper communications throughout the defueling evolution and promptly informed management of abnormal conditions (Section 01.1).

. The licensee identified and took appropriate immediate corrective actions for a failure to notify the NRC within the required four-hour time limit following an inadvertent actuation of the containment ventilation system (Section 04.1).

Maintenance

. The inspectors concluded that the licensee failed to proceduralize the need to perform multiple runs on the No. 2 spent fuel pit pump to ensure proper venting when retuming the pump to service. The inspectors determined that there was good involvement by engineering department personnel in investigating related pump operational problems (Section M1,1).

. The inspectors concluded that the mechanical maintenance department personnel demonstrated good accountability, ownership, and teamwork in safely performing the Unit 2 reactor vessel head and upper intomal lifts. First-line supervisors and senior management were actively involved in and provided close oversight for the defueling evolutions (Section M4.1).

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Plant Support

. The licensee identified and took appropriate immediate correchve actions for deficient radiation protection, mechanical maintenance, and management personnel performance which resulted in a failure to provide a required as-low-as-reasonably-achievable briefing to two maintenance mechanics prior to the breaching of a spent fuel pool cooling system valve (Section R1.1).

. The licensee identified and took appropriate immediate corrective actions for deficient personne! performance involving a mechanic's failure to immediately leave the Unit 1 containment following loss of required dosimetry (Section R1.2).

• The inspectors concluded that diving evolutions, associated with the Unit 2 defueling activities, were completed without ir,cident and with low doses, in part, due to radiation protection department personnel's proper implementation of lessons leamed from industry events involving diving activities (Section R4.1).

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Eagggt Details Summary of Plant Status During the inspection period, the licensee maintained Unit 1 in a defueled condition. On February 13,1998, the licensee certified the permanent cessation of operations for both Units 1 and 2.. On February 24 and March g,1998, the licensee completed off-loading the Unit 2 core to the spent fuel pool and certified the permanent removal of fuel from both reactors, respectivel I. Operations 01 Conduct of Operations 0 Unit 2 Defuelina Activities Inspection Scope (71707}

The inspectors reviewed the licensee's actions to eliminate personnel distractions caused by the recent announcement of plant closure. The inspectors also observed the licensee's actions to off-load the Unit 2 reactor core to the spent fuel poo Observations and Findinas Personnel Performance Errors During the inspection period, the licensee determined that plant personnel were, at times, not focused on the proper performance of some work activities due to the plant closure announcement made on January 15,1998. This may have contributed to several human performance errors that occurred in the radiation protection and fire protection areas over a relatively short period of time. Notable examples, involving deficient radiation protection practices which occurred before commencing the Unit 2 defueling evolutions, are described in Sections R1.1 and R1.2. In an effort to re-focus station personnel's attention on the importance of continued safe plant operations and the upcoming Unit 2 core off-load, the licensee conducted sensitivity meetings with all station personnel and developed an " Error Free Plan" for the defueling activities. As a result of these initiatives, personnel performance improved and the defueling evolution was completed without inciden Infrecuent Evolution Briefinas The inspectors observed the infrequent evolution briefings, conducted on February 17 and 19,1997, for the head and upper infomal lifts. The inspectors concluded that the briefings were thorough and property emphasized safsty, evolution objectives, contingencies, communications, and the roles and responsibilities of involved personne The inspectors observed good communications between operations department

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personnel, located in the control room and in the field, during the two evolutions. On February 22,1998, the inspectors attended the infrequent evolution briefings given to the fuel handlers and operators relative to the core off-load activities and concluded that the briefings were adequat Unit 2 Core Off-load Prior to conducting the Unit 2 core off-load activities, the inspectors noted that the licensee proactively ensured the readiness of all the fuel handlers to satisfactorily conduct fuel movements through the performance of practice exercises using a " dummy" fuel assembly. During February 22-24,1998, the inspectors observed the Unit 2 fuel off-load activities. Observations were made in the control room, containment, and fuel handling building. The involved personnel were observed to maintain proper communications during all evolutions. In addition, triple verifications were utilized to ensure the proper completion of fuel movements. Operators and fuel handlers were conscientious in performing the defueling activities and maintained a proper safety focus as demonstrated by the identification and timely notification of management of abnormal conditions and emergent issues that arose during the defueling activities. The licensee safely completed the off-loading and storage, in the spent fuel pool, of Unit 2 fuel assembles on February 24,199 ' Conclusions .

The inspectors concluded that the licensee took appropriate actions to ensure that station personnel were re-focused on the safe performance of work activities following a plant closure announcement. Infrequent evolution briefings, conducted in preparation for the head and upper intemal lifts, were observed to be good. Licensee management proactively ensured that fuel handlers were prepared to perform fuel movements through practice exercises. In addition, fuel handlers and operators maintained proper communications throughout the defueling evolution and promptly informed management of abnormalcondition l 0 Inadvertent Actuation of the Unit 2 Containment Ventilation System Inspection Scope (71707)

The inspectors reviewed the circumstances surrounding the licensee's failure to report the inadvertent engineered safety features actuation of the containment ventilation system. The inspectors reviewed applicable documentation and interviewed operations, radiation protection, and regulatory assurance department personnel, Observations and Findinas On February 23,1998, the onshift control room (CR) personnel placed the containment ventilation purge system in service due to high humidity in the Unit 2 containmen '

Normally, the containment ventilation purge system was not in operation. At approximately 1:30 a.m., a radiation protection technician (RPT) informed the onshift CR personnel that he would be performing filter change outs on several radiation monitors on

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the 617' elevation of the auxiliary building. The onshift CR personnel authorized the RPT to perform the work; however, the CR personnel did not ask the RPT which radiation i monitors would be affected by the filter change out activities. Therefore, the CR j personnel could not assess the impact of the activit The RPT performed the filter change-outs using Zion Radiation Procedure (ZRP) 6021-22, " Radiation Monitor Gas Sampling and Particulate Filter and lodine Cartridge Replacement," Revision 2. The procedure did not define a required operational status for the containment ventilation purge system during filter change outs and did not specify that a filter change out could actuate the system, if in operation. When the RPT attempted to perform the filter change out for the Unit 2 containment purge radiation monitor,2RPR09, the radiation monitor shifted to an instrument fail mode, causing the containment ventilation purge system supply and exhaust valves to close. The closure of these valves resulted in an automatic trip of the containment purge fan and several unexpected CR annunciator actuations. The CR operatnrs responded to the annunciators, identified the RPTs filter change out activities as the cause for the equipment repositioning, and took appropriate actions to retum the system to proper operational alignment. In addition, the shift manager (SM) reviewed the station's reportability manual for the unexpected equipment operation. The SM determined that the automatic containment ventilation purge system isolation was not a reportable event because the equipment actuations had not been caused by a valid high radiation signa Later, on the same day, the regulatory assurance manager reviewed the event and questioned the appropriateness of not reporting the event. The licensee decided to review the event in further detail and determined that the automatic isolation of the containment ventilation purge system was a four-hour reportable event. As a result, on February 23,1998, at 12:41 p.m., the SM notiiied the NRC, in accordance with 10 CFR 50.72 requirements, of an inadvertent containment ventilation purge system actuation that occurred at 1:30 a.m., on February 23,199 Subsequently, the licensee determined that the root cause for the untimely report was an error in the station's reportability manual. Specifically, the reportability manual incorrectly stated, "that closure of containment ventilation system isolation valves resulting from invalid radiation monitor signal meets the intent of the ventilation exemptions and should not be reported." In addition to making the notification, the licensee initiated the following corrective actions:

(1) Established administrative controls to ensure that only the criterion in 10 CFR 50.72(b)(2)(ii)(1) and (2) were used for determining the reportability of this type of even (2) Coached the Unit 2 supervisor, nuclear station operator, and other members of the CR crew on the need to ensure that they have a full understanding of the planned in-plant activitie (3) Placed the event in the radiation protection department personnel standing orde (4) Initiated a revision to ZRP 602122 to identify which radiation monitor can cause a system actuatio .

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(5) Enhanced the communications between the operators and radiation protection (RP) department personnel by requiring the RPT to communicate to CR personnel each specific radiation monitor prior to changing its associated filter when performing ZRP 6021-2 Although the licensee made the required notification, the notification was not made within the required four-hour time limit. The licensee reported the event approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> after its occurrence. The licensee's failure to report the event within the four-hour time limit is considered a violation of 10 CFR 50.72 (50-304/98004-01). This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic Conclusion I

The inspectors concluded that a four-hour report to the NRC was not made due, in part, j to some incomplete and inaccurate station procedures. However, active involvement by l the regulatory assurance manager, in reviewing the inadvertent actuation, resulted in the i licensee's recognizing that the event was reportable and the licensee taking timely, l comprehensive corrective action !

i ll. Maintenance j M1 Conduct of Maintenance M1.1 Air Entrained in the #1 Soent Fuel Pit Pumo (62707) Inspection Scope The inspectors reviewed the licensee's troubleshooting activities following the failure of the #1 spent fuel pit (SFP) pump to develop sufficient discharge pressure. The inspectors interviewed system engineering and operations department personnel and reviewed applicable procedures and documentatio Observations and Findinas On January 28,1998, operations department personnel were using Station Operating instruction (SOI)-75A, " Placing A Spent Fuel Pit Cooling Loop in Service," Revision 4, to retum the #1 SFP pump to service following the recent completion of scheduled maintenance. During the performance of sol-75A, a non-licensed operator, stationed at the pump, observed that the pump's discharge pressure was lower than expected and that the oil level dropped in the pump oil sightglass. After the operator informed onshift operations management of the abnormal pump conditions, the shift manager (SM)

generated PIF No. Z1998-00208 and requested an investigation of the proble Engineering department personnel prepared a troubleshooting plan to start and run the pump to assess the problem. The plan directed the staff to maintain the pump's vent ,

valve slightly open to ensure proper and complete venting of the pump. The inspectors l observed portions of the troubleshooting activities and noted that the system and j i

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maintenance engineers were actively involved with operators during the troubleshooting efforts. After several pump runs, the pump developed the normal discharge pressure of 65 psig. The maintenance engineer determined that air was entrained in the pump's piping as a result of the piping configuration between the SFP and the pump. The piping configuration necessitated jogging of the pump multiple times to ensure the pump and system were completely vented. The licensee further determined that operators involved i

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in retuming the pump to service lacked specific knowledge with respect to the system configuration and the high potential for air entrainment during maintenance activitie Following retum of the system to service, the licensee initiated the following corrective actions:

(1) Placed the event in the operations Lesson Leamed Database for use during future job brief (2) Added notes to the Electronic Work Control System to ensure the system was completely vente (3) Developed procedure SOI-75R, " Fill and Vent SFP Pump After Draining For Maintenance," Revision 0, to properly vent the pum Conclusions The inspectors concluded that a failure to proceduralize steps needed to completely vent the spent fuel pit pump following maintenance contributed to the pump not reaching the required discharge pressure and the pump's oil level dropping. The failure did not constitute a violation of NRC requirements because safety-related activities were not involved. The inspectors determined that engineering department personnel's active involvement in troubleshooting the system, contributed to a thorough investigation of this event and appropriate corrective action M4 Maintenance Staff Knowledge and Performance M Reactor Vessel Head and Upper Intemal Lifts The inspectors attended the As-Low-As-Reasonably-Achievable (ALARA) briefings for the Unit 2 reactor vessel head and the upper intemal lifts and observed both evolutions. The inspectors noted that the briefings were thorough. Through observation of the lifts, the inspectors concluded that the mechanical maintenance department personnel demonstrated good teamwork and were conscientious in the performance of the lifts. In addition, the inspectors observed that the maintenance supervisor provided good leadership, communications, and supervisory oversight during the activities to ensure the two evolutions were safely performed without inciden .

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IV. Plant Suonort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Maintenance Mechanics Failed to Comply with Radiation Work Permit (RWP)

Reauirements Inspection Scope (71750)

The inspectors reviewed the circumstances surrounding maintenance department personnel's failure to attend a pre-job briefing before beginning wo* on a contaminatad system. The inspectors reviewed applicable documentation and procedures and interviewed maintenance and radiation protection department personnel, Observations and Findinas On February 9,1998, two maintenance mechanics informed the on-duty radiation protection technician (RPT), at the radiation protection control point, that they were performing work on the valve 2SF8762A. The valve was located on the spent fuel pool cooling inlet pipe to the No. 2 heat exchanger. The mechanics planned to breach the valve to repair a body-to-bonnet leak. Based upon the information provided by the mechanics, the RPT obtained RWP No. 98-0101, which had been assigned for the valve work as well as other system work, and the RWP was provided to the mechanics for their review. The mechanics reviewed only the first page of the RWP. As a result, the mechanics were not aware of the RWP requirement specifying that an AMRA briefing must be conducted prior to breaching the valv The RP supervisor assigned an RPT to accompany the mechanics and to perform a survey on the valve. The RP supervisor was not aware of the scope of the wo*

scheduled for the valve. After the RPT performed the survey, the RPT conducted an informal briefing with the mechanics before allowing them to perform woA on the valv !

The mechanics worked on the valve until their lunch break. At that time, the RPT retumed to the RP control point, placed the completed survey in the RWP folder, and identified that a formal ALARA briefing was required for the job. Zion Administrative Procedure (ZAP) 600 3, " Radiation Wo* Permit Program," Revision 7, Step 4.6, specified that prior to working under an RWP, individuals shall familiarize themselves with the requirements of the RWP, including any specialinstructions/ comments, in addition to the mechanics' failure to read and thereby adhere to the requirements of the RWP, the inspectors identified a number of other barriers which failed to prevent this incident. Specifically: (1) the RPT was not familiar with the RWP requirements and the RP personnel did not provide adequate oversight in ensuring that the mechanics had met i I

all the RWP requirements for their specific work assignment prior to authorizing the mechanics to start wo&; (2) the maintenance and ALARA planners did not communicate to their respective departments the AMRA briefing requirement; (3) the RP supervisor I did not fully understand the scope of work before assigning the RPT to the job; and (4) the maintenance supervisor did not ensure that the workers were aware of all the RWP requirements prior to assigning the valve work to the two mechanics. The safety j significance of this incident was minimal as there were no adverse radiological j consequences from the even l l

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The licensee's formalinvestigation of the incident was stillin progress at the end of the inspection report period; however, the licensee had initiated the following immediate corrective actions:

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(1) All work on the system was stopped until the required ALARA briefing was conducte (2) An investigation of the incident was initiate (3) All RP department personnel were briefed on the incident and the known performance failure (4) Briefings were planned for the planners and maintenance staff on the performance failures and RWP requirements proces The inspectors reviewed the corrective actions and determined that the corrective actions appeared appropriat The mechanics and radiation protection personnel failed to follow the requirements of RWP No. 98-0101 and to ensure that the special instruction requiring a pre-job ALARA brief before breaching valve 2SF8762A was completed. This is a violation of Technical Specification (TS) 6.2.2.a which requires implementation of radiation control procedures (50-295/304-98004-02). This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy, Conclusion The inspectors concluded that the two mechanics demonstrated deficient radiation protection practices in failing to thoroughly review the assigned radiological work permi In addition, the inspectors determined that the radiation protection and maintenance supervision did not ensure plant personnel were prepared to perform the work and did not provide adequate oversight of the work in progres R1.2 Mechanic Failed to Leave the Containment Followina Dosimetry Loss Inspection Scope (71750)

The inspectors reviewed the licensee's investigation of a maintenance mechanic's failure to leave containment after identifying a loss of required dosimetry. The inspectors interviewed the root cause investigator and reviewed applicable documentation and procedure Observations and Findinas On February 6,1998, the licensee identified that a maintenance mechanic stayed in the radiological protected area without proper dosimetry. The licensee initiated an investigation of the event and documented the incident in PIF No. Z1998-0027 l

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While working in the Unit 1 containment, a maintenance mechanic identified a loss of required personal dosimetry, a thermoluminescent dosimeter (TLD). Instead of immediately leaving containment, the mechanic walked down one flight of stairs and searched for the TLD for approximately five minutes. Failing to locate the TLD, the mechanic exited the containment and reported the lost TLD to radiation protection (RP)

personne Zion Administrative Procedure 610-03," Unescorted Access To And Controlin Radiologically Posted Areas," Revision 4, Step G.2.h, specified that if loss or damage of any personal dosimeter occurs, the involved individual shall immediately leave the work area and report directly to radiation protection. The licensee counseled the mechanic on the radiation protection program requirement to exit the radiological controlled area upon discovering missing personal dosimetry. In addition, the licensee briefed the mechanical maintenance department personnel on the event. The mechanic's failure to immediately leave the containment after discovering missing personal dosimetry, a TLD, is a violation of TS 6.2.2.a (50-295/98004-03). This non-repetitive, licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic Conclusions The inspectors concluded that the mechanic demonstrated deficient radiation protection practices by not immediately leaving the containment following the discovery of missing personal dosimetry. The licensee took appropriate immediate corrective actions to address this example of deficient personnel performaric R Radioloolcal Plannina for Divina in the Fuel Transfer Canal Inspection Scope (IPs 71750. 83750)

The inspectors reviewed the radiological planning for and observed diving operations in the fuel transfer canal to complete inspections and maintenance of the fuel transfer car Documents reviewed included the radiological work permit (RWP), the ALARA Action Review, and the ALARA Plan. In addition, the inspectors verified that the planning documents were consistent with procedure ZRP 6210-1, " Radiological Controls for Contaminated Water Diving Operations," Revision Observations and Findinas The inspectors reviewed the radiological planning for the diving evolutions and determined the licensee's controls were consistent with lessons leamed from previous industry events and information contained in ine following NRC generic communications:

'(1) NRC Information Notice 97-68, " Loss of Control of Diver in a Spent Fuel Storage Pool;"

(2) NRC information Notice 84-61," Overexposure of Diver in a Pressurized Water Reactor (PWR) Refueling Cavity;"

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(3) NRC Information Notice 82-31, " Overexposure of Diver During Work in Fuel l

Storage Pool;" and (4) Regulatory Guide 8.38, " Control of Access to High and Very High Radiation Areas in Nuclear Power Plants, dated June 1993."

The inspectors concluded the planning documents were comprehensive and clearly identified the conditions for terminating the evolution. The inspectors observed tnat RWP No. 984452 and ALARA plan No. 980002 property reflected the requirements contained in ZRP 6210-1. For example, the RWP and the ALARA plan directed the licensee to maintain voice communications with the diver and to continuously monitor the diver's pcsition and remote dosimetry. The procedure also provided for a positive means of control to ensure that the diver did not inadvertently access unauthorized areas, including areas with dose rates exceeding 10 rem per hour. The inspectors concluded that the documents provided a good level of instruction and radiological controls for the diver, RP and support personne Prior to the diving evolution, the RP personnel performed underwater radiological surveys of the transfer canal. Although the general area dose rates were reduced via decontamination efforts, the RP personnel measured a significant area dose rate (about 150 rad /hr) at a location about eight to ten feet behind the expected work location. In accordance with the requirements contained in ZRP 6210-1, the RP staff shielded the area (reducing the area dose rate to about 0.5 rad /hr) and posted the area with a beacon to alert the dive On February 17 and 18,1998, the licensee successfully completed the diving operations in the fuel transfer canal and the repair of the Unit 2 transfer cart. The licensee did not experience any notable malfunctions of equipment or any work control problems. The total dose for the evolution was approximately 120 millirem, which was below the licensee's goal. The diver's total dose was measured (via electronic dosimetry) to be about 57 millirem, and the highest measured dose rate to the diver was about 200 millirem /h , Conclusions Radiation protection personnel provided sound planning and good oversight of the diving operations in the fuel transfer canal. Radiological planning personnel properly implemented lessons leamed from industry events and the diving evolution was completed without inciden V. Manaaement Meetina X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 13,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie _-

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A PARTIAL LIST OF PERSONS CONTACTED Commonwealth Edison

- J. Brons, Sito Vice President R. Starkey, Plant General Manager K Dickerson, Executive Assistant to Site Vice President )

T. Saksefski, Executive Assistant to Site Vice President j

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D. Bump, Restart Manager R. Zyduck, Site Quality Verification Manager E. Katzman, Radiat:on Protection Manager R. Landrum, Operations Manager l

L Schmeling, Training Manager  ;

R. Godley, Regulatory Assurance Supervisor i D. Beutel, Regulatory Assurance U.S. Nuclear Reaulatory Commission I

K O' Brien, Acting Chief, Reactor Projects Branch 2 A. Vogel, Senior Resident inspector D. Calhoun, Resident inspector Illinois Department of Nuclear Safety e

J. Yesinowski

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LIST OF INSPECTION PROCEDURES USED lP 62707 Maintenance Observation IP 71707 Plant Operations IP 71750 . Plant Support IP 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-304/98004-01 NCV The licensee failed to report the inadvertent actuation of the containment ventilation purge system within the 4-hour time limi /304-98004-02 NCV Two mechanics failed to ensure that they received an ALARA briefing as required by their assigned RWP before performing work on 2SF8762A .

50-295/98004-03 NCV A mechanic failed to immediately leave containment after discovering that her TLD was missin Closed 50-304/98004-01 NCV The licensee failed to report the inadvertent actuation of the containment ventilation purge system within the 4-hour time limi /304-98004-02 NCV Two mechanics failed to ensure that they received an

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ALARA briefing as required by their assigned RWP before performing work on 2SF8762A .

i 50-295/98004-03 NCV A mechanic failed to immediately leave containment after discovering that her TLD was missing.

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LIST OF ACRONYMS USED l (

ALARA As Low As Reasonably Achievable <

CR Control Room l lP inspection Procedure NCV Non-Cited Violation

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NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation Pl Problem Identification Form RP Radiation Protection RP&C Radiological Protection and Chemistry RPT Radiation Protection Technician RWP Radiation Work Permit SFP Spent Fuel Pit SM Shift Manager sol Station Operating Instruction TLD Thermoluminescent dosimeter TS Technical Specifications ZAP Zion Administrative Procedure ZRP Zion Radiation Procedure l

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