IR 05000295/1999003

Insp Repts 50-295/99-03 & 50-304/99-03 on 990608-0812.No Violations Noted.Major Areas Inspected:Licensee Facility & Control,Decommissioning Support Activities,Sf Safety & Radiological Safety

ML20211L167
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/01/1999
From:	Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211L161	List: IR 05000295/1999003 ML20211L155
References
50-295-99-03, 50-304-99-03, NUDOCS 9909080168
Download: ML20211L167 (12)

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l U.S. NUCLEAR REGULATORY COMMISSION l REGIONlli i

Docket Nos: 50-295; 50-304 License Nos: DPR-39; DPR-48 Report No: 50-295/99003(DNMS); 50-304/99003(DNMS)

Licensee: Commonwealth Edison Company Facility: Zion Nuclear Plant, Units 1 and 2 Location: 101 Shiloh Boulevard Zion,IL 60099 Dates: June 8 - August 12,1999 Inspectors: J. E. House, Senior Radiation Specialist, DNMS R. B. Landsman, Project Engineer, DNMS D. W. Nelson, Radiation Specialist, DNMS W. G. Snell, Health Physics Manager, DNMS Approved By: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9909080168 99090i PDR ADOCK 05000295 G PDR

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EXECUTIVE SUMMARY Zion Nuclear Plant, Units 1 and 2 NRC Inspection Report 50-295/99003(DMNS); 50-304/99003(DMNS)

This routine decommissioning inspection covered aspects of licensee facility management and control, decommissioning support activities, spent fuel safety, and radiological safet Facility Manaaement and Control l

e Eight previously identified issues were reviewed and, based on satisfactory findings, were close e The Action Request System adequately replaced the discontinued Problem Identification Fonn Syste * The Nuclear Oversight Audit and Assessment reviewed during the inspection met the requirements of the Quality Assurance Pla ,

Decommissionina Sucoort Activities e The security plan requirements were effectively implemented. The new security program appears to be on schedule for implementation by October 1,199 Spent Fuel Safety e The safety of spent fuel wac maintained as work progressed on the Nuclear Island Projec Radioloalcal Safety e Station dose was low, which reflected the level of activity within the plant and use of good ALARA practices such as locking many rooms to enhance control of access to these area * The Transportation Program continued to be effectively implemente ,

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. Report Details

Summary of Plarit Activities During the !nspection period, construction of the Spent Fuel Pool (SFP) Island continued. SFP systems appeared adequate to maintain water level and temperature within safety margin LC Facility Management and Control - Onsite Follow uo. Written Reoorts of Non-routine Events at Power Reactor Faci!ities (IP 92701)

1.1.1 General The following violations and ir.spection follow up items were reviewed and are being close l (Closed) IFl 50-295/95018-07: 50-304/95018-07: Welders were not properly filling out the welding forms documenting work performed, raising concems over the quality and traceability of the welding records. Initial actions by the licensee included additional

' training for all welders and taking steps to ensure that information addressing this issue would be included in future contractor training. Documentation was also issued clarifying how welders were to properly initial and date the forms for verification of work completed. This item is close ;

(Closed) eel 50-295/97023-07: 50-304/97023-07: eel 50-295/97023-08:

50-304/97023-08: eel 50-295/97023-09: 50-304/97023-09. These items resulted from an issue raised in Inspection Report 50-295/97018; 50-304/97018, which concemed cross-tying a 125Vdc battery from a unit in mode 5,6 or defueled to a second unit in modes 1 to 4 in order to supply the design basis accident duty cycle for the same division battery. Because Comed has permanently ceased the operation of Zion Station

- Units 1 and 2 and removed all fuel assemblies from the reactor vessels, this issue is no longer relevant. This item is close (Closed) IFl 50-295/9702642: 50-304/97026-02: Minimal documentation existed that identified and characterized past contamination events and spills as required by 10 CFR 50.75(g)(1). Following the permanent shutdown of the Zion Station, Comed developed a series of standardized decommissioning plans (DP), of which DP-1001,

" Site Charactenzation - Initial Evaluation of Hazards" addressed the requirements of

10 CFR 50.75(g)(1). This led to the development of a Historical Site Assessment. This

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assessment categorized the site into survey units and then characterized these units with an anticipated classification based on it's likelihood of exceeding the Derived

. Concentration Guideline Level (DCGL) per MARSSIM. In addition, licensee personnel stated that Comed has been interviewing each employee whose employment at Zion is terminated for any knowledge they have of the location of radiological contamination or spills. This item is close l (Closed) IFl 50-295/97029-01: 50-304/97029-01: During an exercise, a communicator failed to follow the available guidance and initially notified the State of Iowa before the States of Illinois.and Wisconsin of an emergency classification. The communicator recognized his error at the time and completed all required notifications within the l

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required 15 minutes. With Zion shut down, there is no postulated accident that results in exceeding the EPA Protective Action Guidelines at the Exclusion Area Boundar Based on the Zion Nuclear Power Station Defueled Station Emergency Plan, notifications to the State of Iowa are not required. In addition, notifications to the States of Illinois and Wisconsin have been extended from 15 to 30 minutes. This item is l close i (C!csed) IFl 50-295/97029-02: 50-304/97029-02: Several problems with the control of i

the scenario and the over-simulation of activities were noted during the exercise. The Zion Nuclear Power Station Defueled Station Emergency Plan specifies that a scenario l will be written for the conduct of exercices and drills, and the scenario will address the level of event simulation. This item is close (Closed) Security URI 50-295/98002-01: 50-304/98002-01(DRS): On January 14,1998, unattended Safeguards Information in the owner-controlled area was not properly protected. The licensee took immediate corrective actions as identified in inspection Reports 50-295/98002 and 50-304/98002. This was determined to meet the criteria of a Severity Level ill violation. By letter dated March 17,1999, in lieu of a pre-decisional enforcement conference the licensee acknowledged the violation and identified all the corrective actions taken to prevent recurrence. The corrective actions were reviewed

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and considered adequate. This item is closed.- Self Assessment. Auditina and Corrective Actions a. Inspection Scope (40801)

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The inspectors reviewed a selection of Action Requests, interviewed station workers and

- interviewed individuals responsible for administering the Action Request system. The inspectors reviewed PIF Z1999-00163, which was generated to address a potential adverse trend in worker performance. The inspectors also reviewed a Nuclear i Oversight Assessment of Radiation Protection Records Control and a Nuclear Oversight I Audit of the station's eifectiveness for previously closed Corrective Actions Records

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b. Observations and Findinas On June 24,1999 the licensee discontinued using the Problem identification Form (PlF) I

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and the PIF tracking process and began identifying and tracking deficiencies using the Action Request (AR) system. The AR system had historically been used to request i specific work activities, not as a deficiency reporting and tracking vehicle. The AR system required that senior manage. is review each AR, the Condition Review Group (CRG) must review each deficiency AR, and each deficiency AR must be assigned a significance level and must be assigned to an appropriate individual designated by the CRG. In addition, Nuclear Oversight would continue to review the deficiency ARs to ,

identify adverse trends and/or programmatic deficiencies. Thus, the AR system mimics l the PIF system. The main advantage to using the AR system is scheduling and l tracking. Unlike the PlF system, all corrective actions within the AR system are included in the station schedule. This aids in tracking the progress of proposed corrective ,

actions and serves as a reminder to the " appropriate individual" assigned a corrective action that the action has a proposed completion date. The inspectors reviewed a number of deficiency ARs and noted that the system had been working as designe ;

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The inspectors questioned whether workers might be confused about the means to report deficiencies because the AR form had no obvious markings to indicate that its intended use was to report deficiencies. The licensee indicated that training on the system had been completed and that worker response to the program had been very positive. Interviews with workers indicated that they were well aware that the AR system should be used to report deficiencies and were, in fact, more comfortable with the AR system as a means to report deficiencies than they had been with the PlF system. The records reflected this. Since the AR system was initiated in June'(replacing the PlF system), the number of reported deficiencies had actually increased.

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Inspection Report 50-295/99002(DNMS); 50-304/99002(DNMS) contained a discussion l of a potentici generic problem involving workers not paying attention to detail while i performing work activities. The Nuclear Assessment Supervisor generated l PlF Z1999-00163 to address the potential problem. A review of this PIF indicated that,

! in addition to the corrective actions taken as described in the inspection Report, the l licensee also reviewed and revised the visitor / escort procedures and tasked Radiation Protection to generate a handout for visitor / escorts who are allowed into the Radiologically Posted Areas. A licensee representative indicated that Nuclear Assessment would track ARs and would generate Action Requests to address identified adverse trends. Based on the discussions with Nuclear Assessment and reviews of the I licensee's corrective actions, this issue is considered closed.

l The Nuclear Oversight Audit of the station's Corrective Actions Records (N.O. Audit

, Report 22-99-02) examined eight Corrective Action Records to assess the effectiveness l of the station's Corrective Action Program in implementing prior action items. Based on j the examinations, the auditors concluded that the process for tracking corrective actions l

was effective. The inspectors reviewed the audit and concluded that it had been l conducted within the guidance provided by the Quality Assurance Plan. In addition, l while the scope of the Audit was limited to a relatively small number of CARS, the limited l scope reflected the SAFSTOR status of the plant. With the plant in a permanent shut-down condition, the number of reported deficiencies is significantly smaller, than when the plant was operational.

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The Nuclear Oversight Assessment of Radiation Protection Records Control l (NOA-22-99-001) evaluated the retrievability, accuracy, maintenance and storage of l Radiation Protection records. The auditors found deficiencies in the retrievability and j l maintenance of RP records and concluded that the deficiencies were due, in part, to the I movement of personnel and changes in record index identifiers over time. The auditors also noted that many of the deficiencies identified during the assessment reflected pre-plant-shutdown practices and that more recent improvements should help ensure that l those practices do not recur. The inspectors reviewed the assessment and concluded 1- that althuugh it Was limited in scope, the assessment was well researched and executed.

L c. Conclusions Replacing the PlF system with the AR system to identify and track deficiencies should have little or no adverse effect on the license's corrective action program. Issues raised by the licensee's handling of the generic problem involving workers not paying attention to detail were resolve . .-

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The Nuclear Oversight Audit and Assessment met the requirements of the Quality

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Assurance Plan.- Decommissioning Support Activities 2.1- Security Proaram Review a. Insoection Scooe (81700)

The inspectors reviewed the licensee's decommissioned security program for performance and implementation to assure that security plan requirements are being implemented. In addition, the inspectors reviewed the licensee's July 30,1999, correspondence requesting specific exemptions from certain requirements of 10 CFR Part 73 and the plan to replace their current security plan with the Defueled Physical Security Plan which modifies the existing Zion Nuclear Power Station (ZNPS)

physical security system and security organization. The licensee requested approval of 4 the exemption request by September 21,1999, to support the scheduled i October 1,1999, implementation of the ZNPS Spent Fuel Nuclear Island. The Defueled Physical Security Plan does not appear to result in a decrease in safeguards ,

effectiveness and reflects changes being made pursuant to 10 CFR 50.54(p).  !

b. Observations and Findinas 1 l

During the inspection period, the inspectors toured the Security Access Facility, Protected Area, Security Alarm Stations, Turbine Building, and evaluated the proposed Defueled Physical Security Plan and Project Plan for the Fuel Island Access Control Area Project for the Fuel Handling Building. The security barrier fence, gates and security doors were adequately maintained and secured. The inspector verified through ;

observation that security personnel were present at required posts and that they were appropriately equipped as required by the security pla The inspector verified through observation that personnel, packages and vehicles entering the facility were adequately searched. The inspector observed employees wearing their picture-badge while within the plant. The inspector observed the contract security personnel perform their routine security duties. All security personnel observed performed weil and were very professiona Due to the decommissioning of the Zion Nuclear Station, Commonwealth Edison will be reducing the scope of the Zion station security program to that required for protection of spent nuclear fuel. This security program reduction will result in a significant reduction of both the nuclear security boundary and the nuclear security staff. The plan is to implement a fuel island access control area that will consist of the spent fuel building and the spent fuel poo The Fuel Island Access Control Area Project involves reducing the nuclear security perimeter to an area that will encompass only the 4 pent fuel building, the spent fuel pool, and the associated security monitoring facilities. During the modification process the existing security plan requirement will remain in effect. The existing security plan has been revised to reflect the proposed changes and has been submitted to the NRC with an exemption request for specific exemptions required by the existing security plan and 10 CFR Part 7 , ..  !

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When the spent fuel island access control facility / area modifications are complete and the NRC approves the exemption request, the new Defueled Physical Security Plan will be implemented, in addition, the Commonwealth Edison security force contracts have gone out for bi The selection of a guard force contractor for all six nuclear sites is expected before the Zion security changes are implemente l c. Conclusions The licensee was effectively implementing security plan requirements. The security force continues to be well managed and effective. The new security program appears to be on schedule for implementation by October 1,1999.

l 3.0 - Spent Fuel Safety 1 Soent Fuel Pool Safety at Permanentiv Shutdown Reactors a. Insoection Scope (60801)

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The inspectors evaluated the new spent fuel pool (SFP) island constructio b. Observations and Findinas The licensee continued its work on converting the SFP to a SFP island. The two new cooling skids along the east side of the truck-bay have been set with all the small and i large bore piping installed. Electrical work for this phase was in process. The new air j conditioning system has been set on the SFP building roof with most of the duct work !

complete through holes in the auxiliary building roof to tie into the existing SFP building duct work. Electrical work for this phase was also in proces All large bore piping inside has been installed except for the final cut-in to the existing heat exchangers. Small bore piping installation along with electrical work for this phase was in proces c. Conclusions l

The safety of the fuel in the SFP was being maintained as work progresses on the islan .0 Radiological Safety i General I The inspectors conducted reviews of ongoing activities in order to assess the overall Radiation Protection Program. Specific findings are detailed in the sections below.

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. Occupational Radiation Exposure Inspection Scope (83750)

The inspectors reviewed the status of on going projects in preparation for SAFSTO Observations and Findinos Activities during the inspection period were limited to waste consolidation, processing spent resin and completing construction of the SFP Nuclear Island. Average daily station dose throughout the period remained low. This reflected the level of work preformed in the RC Conclusions Station dose reflected the reduced scope of work within the RC .3 Solid Radioactive Waste Manacement and Transoortation of Radioactive Materials Insoection Scone (86750)'

The inspectors reviewed the shipping documents associated with the June 24,1999, shipment of spent resin from Zion to the Bamwell Low Level Waste Facility. The inspectors also interviewed the individuals responsible for ensuring that shipments were made in accordance with NRC and Department of Transportation requirement Observations and Findinos On June 24,1999, the licensee shipped approximately 200 cubic feet of spent resin to Bamwell, S.C. for disposal. The shipment arrived at the site without incident and in full compliance with the applicable regulation A review of the records indicated that the shipping documents contained all of the required forms and the forms contained all of the information required by the regulations.~ The 10 CFR 61 analyses of the spent resin were also used in accordance with station procedures and the descriptions of the isotopic contents of the shipping container were accurately portrayed. All of the required notifications were made prior to the shipment and the shipping documents were well organized and maintaine Conclusions The Transportation Program continued to be effectively implemente .4 Tours Insoection Scooe (83750)

The inspectors toured the SFP, turbine and atsCary building _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

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. Observations and Findinos The inspectors noted during the tours that housekeeping in the buildings continued to be excellent. The buildings were generally very clean, and debris that had been observed on the floors during previous tours in the auxiliary building had been removed. The inspectors observed that most, if not all, materials had been properly stored or had been placed in the appropriate waste containers. Radiological signs were posted in accordance with station procedures and containers were properly labele During the tours the inspectors also noticed that many rooms in the buildings had been locked. The Radiation Protection Manager indicated that as a good ALARA practice, most, if not all, of the rooms would be locked prior to SAFSTOR and access to the rooms would be controlled by Radiation Protectio Conclusions The buildings toured were clean and well maintained. Labels on containers and radiological postings were appropriate and in accordance with station procedures. The locking of rooms within the RCA was seen as a very good practic .0 Exit Meeting Summary inspection findings were presented to members of licensee management at the conclusion of the inspection on August 12,1999. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietar .

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PARTIAL LIST OF PERSONS CONTACTED j

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D. Combs, Administrator, Security '  !

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R. Starkey, Station Manager J. Waters, Regulatory Assurance 1

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J. Zeszutek, Regulatory Assurance INSPECTION PROCEDURES USED IP 40801: Self-Assessment, Auditing and Corrective Action at Permanently Shutdown Reactors IP 60801: Spent Fuel Pool Safety at Permanently Shut Down Reactors IP 81700: Physical Security Program for Power Reactors IP 83750; Occupational Radiation Exposure IP 86750: Solid Redwaste Management and Tonsportation of Radioactive Materials 1 IP 92701: Onsite Follow up, Written Reports or Non-routine Events at Power Reactor Facilities

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ITEMS OPENED, CLOSED AND DISCUSSED Ooened None Closed IFl 50-295/95018-07; 50-304/95018-07 Welders were not properly filling out the welding forms documenting work performed, raising concems over the quality and traceability of the welding record eel 50-295/97023-07; 50-304/97023-07 - These items resulted from an issue raised in eel 50-295/97023-08; 50-304/97023-08 Inspection Report 50-295/97018; 50-304/97018, 1 eel 50-295/97023-09; 50-304/97023-09 which concemed cross-tying a 125 Vdc battery from a unit in mode 5,6 or defueled to a second unit in modes 1 to 4 in order to supply the design basis accident duty cycle for the same division batter IFl 50-295/97026-02; 50-304/97026-02 Minimal documentation existed that identified and '

characterized past contamination events and spills as required by 10 CFR 50.75(g)(1).

IFl 50-295/97029-01; 50-304/97029-01 During an exercise, a communicator failed to follow the available guidance and initially notified the State of Iowa before the States of Illinois and Wisconsin of an emergency classificatio IFl 50-295/97029-02; 50-304/97029-02 Several problems with the control of the scenario and the over-simulation of activities were noted during the exercis !

URI 50-295/98002-01; 50-304/98002-01 On January 14,1998, unattended Safeguards Information in the owner-controlled area was not properly protecte Discussed None

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable AR' Action Request BPO Bulk Power Operations CAR Corrective Action Record DCGL Dose Concentration Guideline DG Diesel Generator DNMS Division of Nuclear Materials Safety -

. dpm ' disintegration per minute -

DRP Division of Reactor Projects DRS Division of Reactor Safety DSAR Defueled Safety Analysis Report EMS Electrical Maintenance Surveillance Procedure IFl Inspection Follow up Item -

ITDC Important to the Defueled Condition MARSSIM Multi-Agency Radiation Survey and Site Investigation Manual NARS Nuclear Accident Reporting System NCTL Nuclear Component Transfer List NRC Nuclear Regulatory Commission PlF Problem identification Form RCA' Radiologically Controlled Area RPA Radiologically Posted Area RPT Radiation Protection Technician SAFSTOR Safe Storage SFP Spent Fuel Pool

! USAR Updated Final Safety Analysis Report

URI Unresolved item

Vdc Volts, direct current ZNPS Zion Nuclear Power Station 12