IR 05000295/1998009
| ML20197C316 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20197C296 | List: |
| References | |
| 50-295-98-09, 50-295-98-9, 50-304-98-09, 50-304-98-9, NUDOCS 9809110101 | |
| Download: ML20197C316 (19) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos:
50-295;50-304 License Nos:
50-295/98009(DNMS); 50-304/98009(0NMS)
Licensee:
Commonwealth Edison Company Facility:
Zion Nuclear Plant, Units 1 and 2 Location:
101 Shiloh Boulevard Zion,IL 60099 Dates:
June 26 - August 13,1998 Inspectors:
J. E. House, Senior Radiation Specialist, DNMS R. J. Leemon, Senior Resident inspector, DNMS R. B. Landsman, Project Engineer, DNMS D. W. Nelson, Radiation Specialist, DNMS W. G. Snell, Health Physics Manager, DNMS S. K. Orth, Senior Radiation Specialist, DRS D. H. Nissen, Radiation Specialist, DRS Approved By:
Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9009110101 990908
PDR ADOCK 05000295 G
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EXECUTIVE SUMMARY Zion Nuclear Plant, Units 1 and 2 NRC Inspection Report 50-295/98009(DNMS); 50-304/98009(DNMS)
This routine decommissioning inspection covered aspects of licensee facility management and control, decommissioning support activities, spent fuel safety, and radiological safety.
j The major decommissioning activities included:
1.
Packaging and shipment of new, non-Irradated, non-contaminated fuel bundles to the fuel vendor.
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Removal of non-irradiated fuel bundles from the spent fuel pool, decontaminating and storing the fuel bundles in the new (dry) fuel vault.
Overall, the licensee performed very well in these activities.
Facility Manaaement and Control Decommissioning activities were in accordance with the schedule.
e The plant's material condition was very good.
- Decommissionina Support Activities
The materialintegrity of structures, systems and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained.
- The Maintenance Rule inspection indicated that the licensee was well prepared for decommissioning and no violations of 10 CFR 50.65 were identified.
- Information was effectively transferred during shift tumovers.
Soent Fue: refety The sp3nt fuel pool was operated safely and spent fuel integrity was maintained.
- Those systems that monitor and cool the spent fuel pool can accommodate those
conditions that would challenge fuel pool level or cooling and thus protect fuel integrity.
Radioloalcal Safety The radiological safety program was very good. As-Low-As-Reasonably-Achievable
reviews were conducted prior to the fuel handling evolutions and radiation protection coverage was very good. Pre-job briefings and training met the radiological challenges of the fuel handling evolution.
Management personnel met the required training and experience requirements.
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e Report Details Summary of Plant Activities During the inspection period, the licensee packaged and shipped new fuel back to the vendor.
New fuel stored in the spent fuel pool (SFP) was removed, decontaminated and stored in the new fuel vault and was awaiting shipmer.t to the vendor. The licensee performed very well during the maintenance rule inspection. SFP systems appeared adequate to maintain water level and temperature within safety margins.
1.0 Facility Management and Control 1.1 General The inspectors conducted frequent reviews of or. going plant activities and attended licensee meetings and reviews addressing these activities, in order to assess overall facility management and controls. Specific events and findings are detailed in the sections below.
1.2 Decommissionina Performance and Status Review at Permanentiv Shut Down Reactors (71801)
1.2.1 General The status of decommissioning and the licensee's conduct of decommissioning activities, in accordance with licensed requirements and commitments, were evaluated. Control and conduct of facility decommissioning were examined to verify the license and Technical Specifications (TS) requirements and commitments described in the Final Safety Analysis Report.
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1.2.2 Monitort,d Decommissionina Activities The inspectors attended licensee meetings where the planning, reviewing, assessing, and scheduling of decommissioning activities were observed. The inspector ascertained that activities were in accordarce with licensed requirements and docketed commitments
as stated in 10 CFR and TSs. Decommissioning activities monitored were:
e Packaging of new dry fuel for shipment
Planning activities for removing new wet fuel from the SFP e
Decontamination of New Fuel Stored in the SFP Downsizing of the Radiation Protection (RP) and Chemistry groups e
1.2.3 Plant Tosrs to Evaluate Material Conditions and Housekeepina a.
Inspection Scope Plant tours were performed to evaluate the materialintegrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning, and to evaluate plant housekeeping.
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Observations and Findinas l
Observations made on plant tours were:
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Rettiining a workforce of sufficient size and with sufficient training and experience to prevent deterioration of systems necessary to maintain the SFP in good operating condition.
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Excellent material condition of the station.
- Fuel removal, decontamination and storage evolution were completed with no major problems. RP planning, job coverage, training and overalljob performance were excellent.
After conducting plant tours, the inspectors discussed the findings with plant
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management, who were actively monitoring the status of the facility. As issues arose, they were resolved, c.
Conclusion _s The material integrity of structures, systems, and components necessary for the safe storage of spent fuel and conduct of safe decommissioning was being maintained. Plant housekeeping was very good and was monitored by plant management.
1.3 Onsite Followup. Written Reports of Non-routine Events at Power Reactor Facilities (92700)
1.3.1 (Closed) VIO 96-355-01043. 01103. and 02014: Each violation involved the same four modifications with examples of failure to conduct tests and closeout packages in their entirety prior to placing the system back in service. The four modifications were:
Modification M22-0-84-001 provided another control room isolation signal upon
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receipt of an safety injection signal.
Modification M22-1(2)-84-052 installed test switch blocks and jacks on DC
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busses.
Modification M22-1-00-0168 installed environmentally qualified NIS
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instrumentation.
Modification E22-1(2)-93-248 modified the auxiliary feedwater pump steam supply
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steam traps.
All the testing has been satisfactorily completed and three of the systems are no longer required. The fourth system has monthly surveillances performed which ensures its operability. These three violations are closed.
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1.3.2 (Closed) VIO 96-355-01073: Failure to update the monthly material condition data base for the auxiliary power system as required by the Maintenance Rule. The update of the data base has been taken over by the Zion maintenance rule program owner. This violation is closed.
1.3.3 The following violations are being administratively closed:
(Closed) VIO 50-295/304-93009-02, " Design Requirements and Acceptance Criteria Not Documented."
(Closed) IFl 50-295/304-93009-07, " Failure to identify Components Essential to Control the Spread of Contamination."
(Closed) IFl 50-295/304-95016-09, " Instrument Air Deficiencies."
(Closed) URI 50-295/304-97023-02, " Lube Oil Analysis Deficiencies."
(Closed) VIO 50-295/304-97023-03, " inadequate Corrective Actions."
(Closed) VIO 50-295/304-97023-05, " inadequate Training on Electrical Splices."
The inspectors reviewed these open items against the following criteria: (1) the issue is not applicable to a permanently shutdown / decommissioning reactor (2) the issue does not raise potent l ally generic concems (including 50.54(f) commitment), (3) the issue does not involve any pending enforcement action or open investigation, (4) the issue does not involve any indication of willful violations, and (5) the issue does not involve a potential
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non-willful Severity Level lit or higher enforcement action. The licensee's corrective actions for the items listed above were of concem only for power operations and are therefore administratively closed:
2.0 Decommissioning Support Activitics 2.1 Maintenance and Surveillance at Permanently Shut Down Reactors (62801)
2.1.1 General The inspection evaluated maiitenance and surveillance of structures, systems, and components that could affect the safe storage of spent fuel and reliable operation of radiation monitoring equipment. Direct observations, reviews, and interviews of licensee personnel were conducted to assess whether maintenance and surveillance were performed in accordance with regulatory requirements and resulted in the safe storage of spent fuel and reliable operation of radiation monitoring and effluent control equipment.
This included the proper implementation of TSs and 10 CFR 50, Appendix B requirements. Additionally, a Maintenance Rule Inspection (Report 50-295/98008; 50-304/98008 (DRS)) was conducted during this inspection period. The inspection report concluded that the maintenance rule program was well implemented, and was based on the determination that proper monitoring of structures, systems, and components associated with the storage, control, and maintenance of spent fuel was being accomplished. There were no violations of 10 CFR 50.65 identified during the maintenance rule inspection.
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Inspection Gggp.g The inspectors evaluated SFP operations including SFP hut up rate, SFP instrumentation, alarms, and leakage detection, SFP chemistry and criticality controls, b.
Observations and Findinos
The inspectors reviewed SFP surveillance parameters including boron concentration, temperature, water level, radioactivity levels, verified that no leakage was coming from the SFP, and that the SFP area criticality monitor was functioning. Water chemistry and cleanliness controls were excellent. Water chemistry was maintained by keeping a SFP domineralizer train operating at all times. The surface was kept clean by means of a floating skimmer. Weekly chemistry surveillances (ZCP 321-1) were performed with no adverse trends noted.
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Foreign material controls were in use in and around the SFP. The SFP area was a foreign material exclusion area; nothing loose is allowed in the area. This was further assured t:y having a waist-high clear plastic fence around most of the pool area. The SFP heat up rate was reviewed with the system engineer. The estimation of pool heat up time to boiling had many conservative elements in the calculations which resulting in a longer time to boiling than the graphs indicated. Operations used the time obtained from the graphs for time to boil, which would be approximately 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after spent fuel cooling was lost.
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Conclusi201 The inspectors concluded that the SFP surveillance activities were being performed as required and that a conservative approach was being used by the licensee to determine the time to boil if spent fuel pool cooling was lost.
2.2 Operational Safety Verification
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Inspection Scope (71701)
The insoectors conducted reviews of ongoing decommissioning activities; monitored control. room staffing, interactions between the operations crews, and shift tumovers; and reviewed station logs and procedures. Specific events and findings are detailed below, b.
Observations and Findinos The intipectors observed that the unit shift supervisors maintained command and control of the station, conducting detailed tumovers that included participation of all members of the crew, and shift crew members were requested to provided feedback on the goals and tasks for the shift. Compared to previous tumovers observed by one inspector in the past years there was a significant improvement in the professionalism of the tumovers.
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Conclusions
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Plant status information was transferred effectively and shift tumovers were conducted professionally.
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i 2.3 Physical Security Assessment at Permanently Shut Down Reactors a.
Inspect.on Scope f81700)
The inspectors reviewed an incident involving a security guard discharging his firearm.
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Observations and Findinas i
I On May 17,1998, at approximately 11:25 p.m., a security officer patrolling the Owner Controlled Area (OCA) at the Zion Station reported that he was wounded by an unknown
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subject who had fled the area. The Zion Police Department and the Fire / Rescue
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Department were contacted and arrived at the scene but did not locate the subject. The
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t officer was taken to St. Theresa Hospital in Waukegan where he was treated and released for a gunshot wound to the foot.
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j Further questioning by the Zion Police Department revealed that the gunshot was
self-inflicted and, according to the officer, accidental. The officer confessed to creating the story of an armed intruder to cover up an accidental discharge of his weapon. The
j officer was charged with Disorderly Conduct (Felony) for filing a false police repurt. On
May 19,1998, while being interviewed by the Zicn Security Department the officer retumed to his story of an armed subject. There is no evidence to suppor.' the officer's
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contention that he was attacked by cn unknown assailant. The officer's einployment hat been terminated.
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The Zion Police Department and Site Security Department have determined that the
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officer did not use proper care and safety practices when handling his weapon. The
weapon discharge was a result of a failure to adhere to established policies and
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procedures governing firearms safety.
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The co Tective actions included removing the officer from duty. The event was discussed with Security Department personnel by the Security Admin.!stration and Site Business
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Managers and focused on reinforcing the principles of firearm care end safety when
handling weapons. For a 6 month period, the Security Department will conduct
documented periodic one on one firearm safety training with each armed officer at the Zion Station.
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Conclusions l-The incident happened inside the OCA and no breach of security occurred inside the
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protected area. The licensee's investigation and corrective actions appear appropriate and will be reviewed during future inspections. The safety significancr; of this event was i-minimal. This Security Event Report 98-S02-00 is considered closed.
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l 3.0 Spent Fuel Safety
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3.1 Soent Fuel Pool Safety at Permanently Shut Down Reactors a.
Inspection Scope (60801)
The inspection evaluated the SFP and fuel pool safety. Factors considered in the evaluation included: siphon and drain protection; SFP instrumentation, alarms and l
leakage detection; SFP chemistry and cleanliness control; criticality controls; and SFP
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operation and power supplies.
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Observations and Findinas The SFP is constructed of reinforced concrete and lined with stain less steel. There is no credible failure that could cause a loss of water below the top of the fuel assemblies. The only opening below the normal water surface in the SFP is the weir between the SFP and the fuel transfer canal (the fuel route to the two reactor containments). The bottom of the weir is approximately 2 feet above the fuel. A movable gate with pneumatic seals is in place in the weir. Water in the transfer canal was maintained at the same level as in the SFP. Thus, even if the pneumatic gate seats failed, water would not drain from the SFP.
The cooling suction line is located 4 feet below the normal water level of the pool (approximately 25 feet above the fuel). The cooling retum line terminates approximately 6 feet above the top of the fuel. The retum line contains an anti-siphon hole above the pool surface water to prevent the possibility of draining the pool down. A surveillance of that siphon break has occurred every outage.
There are three independent supplies of makeup water for the pool. Normal makeup comes from the demineralized water system which takes a suction from the condensate storage tank through two flushing pumps powered by normal AC power, Motor Control Center (MCC) 232 and 132. An altemate path for makeup is available from the refueling water storage tanks via cne refueling water purification pump. Suction can be from either unit's tank. This pump is also powered by normal AC power, MCC 133. For a loss-of-offsite power, AOP 8.5 directs the operators to obtain power from an essential safeguards bus to supply power for either the two flushing pumps or the refueling water purification pump. Also, in the event of a loss-of-offsite power, an e.nergency source of makeup water can be obtained from the fire water system through two fire pumps. One is diesel powered, and the other one is powered from an essential safeguards bus (powered by an emergency diesel generator). AOP 6.2 covers spent fuel pool loss of level.
Fuel pool instrumentation consisted of level, temperature, and radiation alarms. Any significant water loss would be promptly detected by means of a low-level alarm in the control room, while any loss of cooling would be promptly detected by a high temperature alarm, eso located in the control room. The level and temperature are also recorded every shift by localinstrumentation. In addition, an area radiation monitor is located in the pool area which is also alarmed in the control room.
Fuel pool leakage is monitored by leakage channels installed behind the stainless steel liner which are bundled into four pool quadrant site-glasses. They have been checked every 6 months sinco startup with essentially zero leakage.
A variety of site requirements are in place to provide sufficient assurance that spent fuel storage will preclude criticality. With the 76 new Unit 2 fuel assemblies removed from the pool, no fuel will be moved until approved storage casks can be obtained. Acceptable
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geometry is maintained by the newer fuel racks which contain boron for neutron absorption. Coupons of this material are checked every fourth year to determine if there i
are any material losses. There are also heavy load handling limitations over the SFP.
Although the rack system was designed to prevent criticality with pure water in the pool, the water contains boron at a concentration of 2450 ppm or above for additional negative reactivity. There are pool storage location requirements / limitations for low specific fuel bumup bundles.
At present, there are three systems, with three sets of pumps, that are needed to cool the pool (the licensee has considered reducing this to two). The pumps needed for cooling are: (1) the service water system pumps, which take a suction from the lake screen s
house and cool (2) the closed component cooling system. Both of these systems' pumps
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are powered from essential safeguards busses. The component cooling system in turn cools (3) the closed SFP cooling system. The SFP cooling pumps on the other hand are powered from normal AC power, MCC 134 and 234. There are site procedures to
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transfer the power supply from one unit to the other (AOP 6.4) if needed to power the l
other unit's spent fuel pump. For a loss of offsite power, AOP 8.5 directs the operators to obtain power from an essential safeguards bus if needed to supply power for the spent fuel pumps,
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Conclusicrj The systems that monitor and cool the SFP can accommodate those conditions that would challenge fuel pool level or cooling and thus protect fuel integrity.
4.0 Radiological Safety 4.1 Removal of Contaminated Filters from SFP
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Inspection Scope (83750. 83728)
The ir,spectors reviewed the licensee's progress in removing contaminated filters from the SFP. The inspectors also reviewed the radiation work permit (RWP) No. 980169,
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Revision 0, " Transfer filters for shipment / support work," As-Low-As-Is-Reasonably-Achievable (ALARA) Plan (No.98-039,' dated April 23,1998), and radiological surveys and discussed the evolution with a member of the RP staff.
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Observations and Findinas The ALARA Plan and % RWP properly addressed the anticipated radiological conditions, the un of mock-up training, and contamination controlissues. The licensee estimated that 150 filters would be removed from the SFP and established a 0.300 rem dose goal for the evolution. The licensee's controls also addressed RP technician oversight of the evolution. For example, the RWP and ALARA plan required RP technicians to be present during the movement or removal of filters or equipment, which were stored in the SFP, The RP controls also addressed radiological survey requirements and potential problems with associated contingency actions. For example, in the event of a dropped filter, the ALARA plan directed individuals to immediately leave the area and described acceptable response actions. Ire addition, the ALARA plan included information from previous industry events associated with unexpected dose rates from items stored in SFPs.
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As directed by the ALARA plan, the licensee conducted mock-up training for the evolution. Based on the experience gained during this training, the staff adapted the filter removal tool to reduce the potential for the dispersion of highly contaminated filter media into the SFP. The staff also developed and tested an underwater structure which was equipped with survey instrumentation to enable remote, underwater surveys of the filter elements. The ALARA analyst indicated that the training was effective in ensuring that the team was prepared for the evolution.
On April 27 and 28,1998, the licensee removed about 60 filters from the SFP and packaged the filters in a high integrity container. Radiation levels ranged from 0.10 to 18.0 rem por hour at 30 centimeters from the filters. The RP staff indicated that no unexpected radiologicalincidents occurred during the evolution. The total accumulated dose was about 0.185 rem for the first 60 filters. The licensee anticipated that the remaining filters (about 60 to 90) would be removed in the third quarter of 1998. Although the ALARA analyst indicated that the project would probably exceed the initial goal of 0.300 rem, the individual indicated that the goal was very aggressive and that the quantity and activity of filters were not well known at the start of the project.
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Conclusions The RP staff provided effective planning for the removal of contaminated filters from the SFP. The RP planning documents provided good radiological controls and identified radiological hold points and contingencies. The licensee also conducted mock-up training with the staff to ensure that the work crew were familiar with the evolutions and to develop and test a filter lifting tool. Although the RP staff did not expect to meet the initial dose goal for the project, the inspector noted that the dose goal was aggressive and that
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the planning and training were effective in reducing personnel exposures.
4.2 Plannina and Preparation for the Removal of New Fuel from the SFP a.
Inspection Scope (83750)
The inspectors reviewed the licensee's planning for the removal and decontemination of
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new fuel assemblies that were stored in the SFP, discussed radiological controls for the fuel handling operation with the ALARA analyst, and observed both mock-up training and the fuel removal / decontamination operation.
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Observations and Findinos In preparation for SAFSTOR, the licensee removed and decontaminated 76 new fuel assemblies that were stored in the SFP. These bundles were then transferred to the new fuel vault while arrangements were being made for shipment of the fuel bundles to the licensee's fuel vendor. Originally, the fuel had been loaded into the Unit 2 reactor vessel i
during the fall of 1996 (i.e., Unit 2 refueling outage). However, the licensee did not re-start the unit following the refueling outage. Because the assemblies had been in the transfer canal, the transfer cart, the reactor vessel and the SFP, the licensee indicated that radioactive contamination and potential hot particle control would be the greatest radiological concems.
The inspectors reviewed an Al. ARA plan and an RWP for the fuel move evolution that the licensee was developing. The RP staff modeled the plan and RWP on the documents developed for the filter removal evolution (Section 4.1). The ALARA analyst indicated that the staff was addressing specific controls for contamination control and airbome
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monitoring. In addition, the analyst was including controls for hot particle detection and control.
The licensee constructed a device to perform a decontamination of the fuel assemblies.
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The device consisted of eight spray nozzles arranged into a 18 X 18 inch square, so that there was a 2 inch overlap of spray from each nozzle. This spray system was attached to the new fuel elevator. During the decontamination process, the fuel assemblies were moved up the new fuel elevator and through this device. As the assemblies passed through the device, demineralized water was sprayed from the nozzles and decontaminated the fuel assemblies. The inspectors noted that the device was designed to be operated remotely to minimize personnel exposure.
The licensee conducted mock-up training for the fuel removal project. The inspectors noted that the RP staff provided a thorough briefing prior to each training session to ensure that all of the crew understood the purpose and scope of the evolutions. The RP
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staff stressed the radiological conditions and the RWP requirements. During the mock-up training, the licensee tested the decontamination device and evaluated the spray that was
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emitted. The inspectors observed that the crew communicated well and evaluated the effect of the spray device on the potential for spreading of contamination and creating
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airbome radioactive contamination.
During removal, each fuel bundle was visually inspected, surveyed, cleaned, resurveyed and wrapped in plastic. The first fuel bundle was processed on July 10,1998 and the last on August 1,1998. During removal, the inspectors attended daily pre-job briefings,
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interviewed participants and observed the removal and processing of several fuel j
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The project initial briefing and daily pro-job briefings were well planned and presented.
The material covered during the briefings included, but was not limited to, RWP
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requirements, tools, contingencies, dose goals, work goals and access and work control.
l During the briefings, the inspectors noted that the workers actively participated in the
question and answer period that followed the briefing.
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During the fuel move evolution, the inspectors also noted good performance while observing the processing of several of the fuel bundles. All of the participants appeared
to be familiar with their assigned roles and responsibilities and all activities appeared to be well choreographed. Dose rates in the work areas were closely monitored and the
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participants were seen leaving the work areas to enter adjacent marked low dose areas when their tasks were completed. Contamination control was also excellent. Potentially con %minated surfaces and objects were cleaned immediately after each activity or when bundles had been placed in the new fuel storage vault. All of the observations indicated that the planning for the project had been excellent.
During one of the daily briefings several workers indicated that the ambient air temperatures in the fuel pool area were high and it was uncomfortable to work in the area for long periods of time. The ALARA Coordinator indicated that high ambient air temperatures in the work area had been considered during the planning for the project.
The workers were given frequent short breaks and drinking water was available in the SFP area. Neither the workers or the inspectors, however, observed temperatures being
measured in the work areas during the early stages of the project. When asked about
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this, the attemate Safety Officer indicated that although the facility was committed to complying with OSHA guidance on controlling work in adverse environments,
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temperatures had not been routinely measured during the early stages of the project.
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l Immediately following the conservations with the altemate Safety Officer, temperatures in i
the SFP area were measured and it was determined that the facility was in compliance with the OSHA guidance. The altemate Safety Officer did acknowledge that not j
measuring the temperatures had been a poor practice and the facility had taken steps to ensure that work area temperatures would be measured in the future.
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Conclusions The RP staff's initial planning for the removal of new fuel from the SFP addressed radiological hazards, including the potential for airbome contamination. The maintenance and RP staffs also devised a decontamination device which could be remotely implemented to reduce worker exposures. During mock-up training, the ciew demonstrated effective communications and RP controls. Dailyjob briefings were thorough and the planning and execution of the fuel removal project were excellent.
4.3 Packaaina of New Fuel from the New Fuel Vault a.
Inspection Scope,(83750)
e The inspectors observed the removal and packaging of new fuel bundles for shipment back to the vendor.
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Observations and Findinas Seventy two bundles of new fuel had been stored in the new fuel vault (dry) in preparation for Unit i refueling. As this fuel had not been irradiated and had never been in the reactor vessel or the SFP, no radiation or contaraination problems were expected. This fuel was repackaged and shipped to tlie vendor. Each bundle was hoisted from the vault, the plastic bag around the bundle was removed and the bundle was surveyed and smeared. The bundles were then rebagged, lowered and secured in the shipping containers. Work coordination between the radiction workers and the health physics (HP)
technicians was very good and the repacking operation, which occurred over approximately 3 working weeks went smoothly. The foreign material exclusion zone practices were enforced. All loose item such as TLD's, badges, and pens were taped to workers and observers clothing.
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Conclusions Work planning and radiation work practices for tNs operation were very good. No problems were noted.
4.4 Staff Trainina and Qualification in RP&C 4.4.1 Asslanment of Radiation Protection Manaaer(RPM)(83750)
The inspectors reviewed the licensee's RP and chemistry organization and the qualifications of individuals assigned to this organization. TS 6.1.4, requires, in part, that station personnel be qualified in accordance with ANSI 18.1, " Selection and Training of Nuclear Power Plant Personnel," dated March 8,1971. In addition, TS 6.1.4 requires that either the HP supervisor or lead health physicist meet the qualifications of RPM, as recommended in Regulatory Guide 1.8, dated September 1975. Following the licensee's decision to cease operations, ths licenseo combined the RP, chemistry, and maintenance
groups and appo5ted a new manager fer the organization. The inspectors reviewed the
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manager's qualifications and verified that the individual met the qualifications of a technical manager in accordance with ANSI N18.1; however, the individual did not meet the qualifications for the RPM, as defined in Regulatory Guide 1.8. The licensee had assigned the RPM responsibility to the lead health physicist, who reported to the new manager. The inspectors reviewed the lead HP's (RPM) qualifications and verified that this individual met the RPM qualifications recommended in Regulatory Guide 1.8. The
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licensee hsd also assigned two individuals, who also held the RPM qualifications in accordance with Regulatory Guide 1.8, as back-up RPMs. The inspectors noted that licensee management had issued written instructions for the RPM to communicate
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radiological concems directly to senior plant management. No concems were noted with a
the organizational structure of the HPs and Chemistry groups.
4.5 Miscellaneous RP&C lssues 4.5.1 (Closed) VIO 50-295/97048-01033 and 50-304/97048-01033: Failure to Adhere to RP Procedures - three examples. In example C of this violation, operations personnel had improperty removed a potentially contaminated rod, which had been used to manipulate a switch within a contaminated area, from a posted contaminated area. This item was reviewed in NRC Inspection Report 050-295/98003; 050-304/98003. At that time during l
Ont inspections the inspector noted a rod similar to the one utilized in the subject violation outside of a contamination area and the item remained open pending completion
of operator training and future inspections.
The inspectors accompanied an operator on routine rounds in the Auxiliary Building and i
noted that there were no such rods left near any posted contaminated areas. The
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operator used good radworker practices and had no problems manipulating any equipment. In addition, the inspectors reviewed the lesson plans for training that was provided to the operators. Training included reviews of specific procedures as well as lessons leamed from industry events, including this violation. This item is closed.
4.5.2 (Closed) VIO 50-295/97020-03 and 50-304/97020-03: Failure to Post Contaminated Areas. The inspectors reviewed the effectiveness of the licensee's corrective actions for a violation conceming the failure to post a contamination area. Corrective actions
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included performing radiological surveys and verifying that the area was appropriately posted. Additionally, the licensee developed supplemental expectations to enhance the survey program. RP-OPS-01, Revision 1, " Radiation Protection Guideline Surveys," was
reviewed, and the inspectors observed a Radiation Protection Technician (RPT) perform
routine surveys in the Auxiliary Building. No additional examples were identified. This item is closed.
i 4.5.3 (Closed) VIO 50-295/97020-04 and 50-304/97020-04: Manipulation of plant equipment l
without a procedure. The inspectors reviewed the corrective actions for a violation concoming the improper manipulation of a radiation monitor. Corrective actions included, counseling operations personnel on the importance of configuration control. Radiation
Protection issued a policy, " Configuration Control of The Installed Plant Radiation
Monitoring System," dated August 15,1997. In response to other configuration control Issues the licensee had recently implemented Procedure ZAP-300-20, Revision 0,
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" Configuration Control," April 28,1998, which included equipment that RP personnel were
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approved and trained to operate. The violation resulted from problems with the
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procedure as well as communications problems between RP and Operations Department personnel. The initial corrective actions were not fully effective with regards to i
communications. On February 23,1998, while changing out filters on 2PR-09 radiation monitor, the monitor spiked high causing a high radiation alarm which resulted in the i
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isolation of the Ur'it 2 containment purge system. However, no additional examples of configuration control problems with radiation monitors had been noted after the February 23,1998, event. The implementation of the above corrective actions as well as
the corrective actions for that event were effective in correcting both procedure and
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communication problems in this area. This item is closed.
i 4.5.4 {Qosed) VIO 50-295/97020-05 and 50-304/97020-05: Failure to take required actions for
inoperable radiation monitor. The inspectors reviewed the corrective actions taken for a
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violation conceming the failure to perform compensatory surveys, when a radiation monitor was inoperable, as required by TSs 3.14-1. Corrective actions included
counseling the control room staff, providing additional training to the operating staff, and
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correcting Proceder:: 2RP 5820-12, " Surveillance Requirements For Inoperable Radiation Monitors." The inspectors reviewed the procedure to ensure that the radiation monitor ORE-0006 was documented as requiring compensatory surveys when inoperable. This item is closed.
4.5.5 (Closed) VIO 50-295/97026-01 and 50-304/97026-01: Failure to maintain adequate control of entrances to a high radiation area. The inspectors reviewed the corrective actions taken regarding the failure to lock and maintain direct oversight of and positive control over entry to a locked high radiation area. On October 20,1997 a memo was issued regarding locked high radiation area (HRA) control. Standing Order 97-23,
"'R' Key issuar,ce & Corrective Actions From 10/17/97 HRA Event," was implemented on December 19,1997. The standing order provides guidance for issuance of R-keys, as well as individual responsibilities, and verification that doors are properly secured after entry to an area. The inspectors observed the implementation of this standing order when an R-key was issued to an operator for routine rounds, and for entry into a locked HRA. The entry and use of the key was performed in accordance with the standing order, no additional examples of this violation had occurred, this item is closod.
4.5.6 (Closed) VIO 50-295/98003-01 and 50-304/98003-01: Failure to properly implement radiation protection procedures - two parts. Example A involved the failure to properly calibrate a personnel contamination monitor (PCM) which resulted to the PCM having higher than allowed alarm set points. Corrective actions included the following:
The monitor was correctly calibrated
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Surveys were conducted in and around the Radiologically Protected Area (RPA)
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exit, no contamination was identified Interviews with other Radiation Protection Technician (RPT)s to determine that
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the procedure was followed correctly A search of the problem identification form database, for this time period, revealed
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no alarms of the portal monitors at the security gate house, indicating that no personnel left the site with contamination on them ZRP 5822-7, " Source Check, Display Test and Calibration of the NE Technology
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- lPM-8 Whole Body Frisking Monitor," was revised to include sign off spaces for each step of the calibration process No additional examples of this violation had occurred. The inspectors reviewed the most recent calibrations and identified no discrepancies.
Example B concemed a failure to properly survey material prior to release from the RPA.
Corrective actions included a tailgate session with the Security Department which reviewed the Comed Radiation Protection Handbooh. Also the RP Department installed a gate with a sign on it at the Auxiliary Building exit directing personnel to have RP survey
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any items prior to entering the IPM-8 monitor. No additional examples of this violation had occurred. This item is closed.
5.0 Exit Meeting Summary The lead inspector presented the inspection results to members of licensee management at the conclusion of the inspection on August 13,1998. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietary.
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l PARTIAL LIST OF PERSONS CONTACTED M. Beaumont, Chemistry Supervisor D. Bump, Maintenance and Rad / Chem Manager R. Godley, Manager, Regulatory Assurance R. LaBum, Radiation Protection Manager R. Schuster, Rad / Chem Supervisor R. Starkey, Station Manager J. Waters, Regulatory Assurance J. Zeszutek, Regulatory Assurance INSPECTION PROCEDURES USED IP 36801:
Organization, Management, and Cost Controls at Permanently Shut Down Reactors IP 37801:
Safety Review, Design Changes, and Modifications at Permanently Shut Down Reactors IP 60801:
Spent Fuel Pool Safety at Permanently Shut Down Reactors IP 62801:
Maintenance and Surveillance at Permanently Shut Down Reactors IP 71707:
Operational Safety Verification
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IP 71801:
Decommissioning Performance and Status Review at Permanently Shut Down
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Reactors IP 81700:
Physical Security IP 83728:
Maintaining Occupational Exposures ALARA IP 83750:
Occupational Radiation Exposure IP 84750:
Radwaste Treatment, Effluent and Environmental Monitoring IP 86750:
Solid Radwaste Management and Transportation of Radioactive Materials IP 92700:
Onsite Followup, Written Reports or Non-routine Events at Power Reactor Facilities
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ITEMS OPENED, CLOSED AND DISCUSSED
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Opened None l
Closed 50-295/304-96355-01043 VIO Failure to follow procedures according to ZAP 510-02 50-295/304-96355-01103 VIO Operating plant with installed SR modifications not previously tested 50-295/304-96355-02014 VIO Safety-related modification did not contain measures to status tests 50-295/304-96355-01073 VIO Failure to perform monthly updates of material conditions 50-295/304-97048-01033 VIO Failure to adhere to radiation procedures 50-295/304-97020-03 VIO Failure to post contaminated areas j
50-295/304-97020-04 VIO Manipulation of plant equipment without a procedure-50-295/304-97020-05 VIO Failure to take required actions for inoperable radiation monitor 50-295/304-97026-01 VIO Failure to maintain adequate control of entrances to a high radiation area 50-295/304-98003-01 VIO Failure to properly implement radiation procedures -
two parts 50-295/98-S02-00 SER Self-inflicted gunshot wound to security officer 50-295/304-93009-02 VIO Design Requirements and Acceptance Criteria not Documented 50-295/304-93009-07 IFl Failure to identify Components Essential to Control the
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Spread of Contamination 50-295/304-95016-09 IFl Instrument Air Deficiencies
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50-295/304-97023-02 URI Lube Oil Analysis Deficiencies 50-295/304-97023-03-VIO Inadequate Corrective Actions 50-295/304-97023-05 VIO Inadequate Training on Electrical Splices Discussed None
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LIST OF ACRONYMS USED i
ALARA As-Low-As-Reasonably-Achievable
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AOP Abnormal Operating Procedure DRP Division of Reactor Projects
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HP Health Physics HRA High Radiation Area i
IP inspection Procedure LER Licensee Event Report
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MCC Motor Control Center
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i NRC Nuclear Regulatory Commission PCM Personnel Contamination Monitor RP Radiation Protection RPA Radiologically Protected Area RPM Radiation Protection Manager
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RPT Radiation Protection Technician RWP Radiation Work Permit
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SFP Spent Fuel Pool TLD Thermo-Luminescent Dosimeter TS Technical Specification VIO Violation i
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DOCUMENTS REVIEWED
ALARA Plan No.98-039, dated April 23,1998
Radiological Surveys Nos. 98-0481 and 98-0490 i
RWP No. 980169 (Revision 0) " Transfer Filters for Shipment / Support Work"
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ZAP 500-09, Attachment A," Certification of Participants to ANSI-Recognized Requirements,"
j dated September 15,1995; May 19,1998; and May 28,1998
ZRP 5820-12, Revision 10, " Surveillance Requirements for inoperable Radiation Monitors,"
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May 29,1998 a-ZRP 5822-7, Revision 5, " Source Check, Display Test and Calibration of the NE Technology
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IPM-8 Whole Body Frisking Monitor, " March 24,1998
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ZAP 300-20, Revision 0, " Configuration Control," April 28,1998 RP-OPS-01, Revision 0, " Radiation Protection Guideline Surveys" RP-ADM-02, Revision 2, " Radiation Protection Guideline RP Verification Program" Standing Order 97-23, "'R' Key issuance & Corrective Actions From 10/17/97 HRA Event,"
December 19,1997 Standing Order 98-02, " Communication Expectations From RP to Operations Prior to Manipulation of installed Plant Equipment," February 23,1998 Calibration Records:
IPM-8 Monitor Nos. AR-25, February 17,1998, AR-30, April 3,1998, AR-38, May 7,1998, AR-40, April 9,1998, AR-49, January 16,1998, AR-50, February 25,1998 PM-7 Monitor Nos.1) May 11,1998,2) May 7,1998, 3) March 11,1998,4) August 25,1997 and February 20,1998, 5) February 12,1998, 6) February 18,1998 AOP 6.2, Revision 9, " Refueling Cavity / Spent Fuel Pit / Transfer Canal Uncontrolled Loss of Level," June 5,1997 AOP 6.4, Revision 3, " Loss of Spent Fuel Pit Cooling," September 5,1997 AOP 8.5, Revision 1, " Loss of Off Site Power or System Auxiliary Transformer," February 10, 1998 ZCP 321-1, Revision 6, " Auxiliary System Surveillance Requirements," April 20,1998
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