IR 05000295/2013011

Third Quarter Inspection Report 05000295-13-011(DNMS);05000304-13-011(DNMS)

ML13319A628
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/14/2013
From:	Robert Orlikowski NRC/RGN-III/DNMS/MCID
To:	Daly P ZionSolutions
Slawinski W
References
"IR 13-011", EA-13-208
Download: ML13319A628 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ber 14, 2013

SUBJECT:

NRC INSPECTION REPORT 05000295/2013011(DNMS); 05000304/2013011(DNMS) -

ZION NUCLEAR POWER STATION

Dear Mr. Daly:

On September 20, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities for the third calendar quarter of 2013 at the permanently shut-down Zion Nuclear Power Station in Zion, Illinois. The inspection continued with in-office review through October 24, 2013. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The enclosed report presents the results of this inspection, which were discussed with Mr. Baker by telephone on October 24, 2013.

During the quarterly inspection period, the NRC inspectors reviewed your program for the control of heavy loads other than spent fuel assemblies; aspects of the occupational radiation protection program; the characterization and manifesting for a planned radioactive waste shipment of irradiated hardware in an NRC approved Type B cask; and implementation of your corrective action program.

The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observation of work activities, independent radiation measurements, and interviews with personnel.

Based on the results of this quarterly inspection, the NRC has determined that a Severity Level IV violation of NRC requirements occurred. The violation was evaluated in accordance with the NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs website at (http://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html). The violation involved the failure to perform an adequate radiological survey to identify the presence of a discrete radioactive particle (DRP) on a worker that was involved in reactor internals segmentation work on July 19, 2013. Reactor internals segmentation activities generate DRPs in the form of metallic chips/fines comprised of cobalt-60 that can deliver significant shallow dose to workers if not adequately controlled and timely identified. Radiation surveys were the means to identify the presence of DRPs should they migrate outside the refueling cavity pools. However, on July 19, 2013, radiological surveys were not adequate to detect DRPs that were present outside the Unit 2 cavity pool including a particle on the skin of a worker that was involved in segmentation work.

Given the potential radioactive content of DRPs, the situation that occurred on July 19, 2013, presented a substantial potential for a worker exposure in excess of applicable regulatory limits, as defined in the NRC Enforcement Policy. Specifically, the radioactive content of the DRP on the worker could have been greater and therefore potentially deliver a dose in excess of regulatory limits. The concern is not the significance of the actual exposure that was incurred but whether adequate controls were in-place to prevent significant radiation exposure to workers. Section 6.7 of the Enforcement Policy provides for a Severity Level III violation for situations that involve a substantial potential for an exposure in excess of regulatory limits.

However, after applying risk insights associated with exposure to DRPs and your generally successful control of DRPs since segmentation activities commenced in 2012, we concluded that a Severity Level IV violation is appropriate.

The violation is cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding it are described in Section 4.2 of the subject inspection report. The violation is being cited in the Notice because the corrective actions taken to date may not be adequate to prevent reoccurrence of similar radiation exposure problems. The corrective actions you had taken following the July 19, 2013 incident focused primarily on radiological survey practices but not mitigation of the particle hazards in the cavity pools.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. If you have additional information that you believe the NRC should consider, you may provide it in your response to the Notice. The NRCs review of your response to the Notice will also determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's

"Rules of Practice," a copy of this letter, its enclosure and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's Agencywide Document Access and Management System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy or proprietary information so that it can be made available to the public without redaction.

We will gladly discuss any questions you may have regarding this inspection.

Sincerely,

/RA/

Robert J. Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Docket Nos. 050-00295; 050-00304 License Nos. DPR-39; DPR-48

Enclosures:

1. Notice of Violation 2. Inspection Report Nos. 05000295/2013011(DNMS);

05000304/2013011(DNMS)

REGION III==

Docket Nos.: 050-00295; 050-00304 License Nos.: DPR-39; DPR-48 Report Nos.: 050-00295/2013-011(DNMS)

050-00304/2013-011(DNMS)

Licensee: ZionSolutions, LLC Facility: Zion Nuclear Power Station (permanently shut-down)

Location: 101 Shiloh Boulevard Zion, IL 60099 Dates: Onsite Inspection July 16 - 19, August 5 - 8, and September 16 - 20, 2013; in-office review through October 24, 2013 NRC Inspectors: Wayne J. Slawinski, Senior Health Physicist Matthew C. Learn, Reactor Engineer Approved by: Robert J. Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Enclosure

EXECUTIVE SUMMARY Zion Nuclear Power Station, Units 1 and 2 NRC Inspection Report 050-00295/2013-011(DNMS); 050-00304/2013-011(DNMS)

The Zion Nuclear Power Station is a permanently shut-down and defueled power reactor facility that was maintained in a SAFSTOR condition with spent fuel in wet storage from 1998 through 2010. In 2011, active decommissioning commenced and continued throughout the current inspection period. This routine safety inspection reviewed the licensees execution of the site decommissioning project focusing on occupational radiation exposure controls including control of discrete radioactive particles, the control of heavy loads, review of a planned radioactive waste shipment in an NRC approved cask and implementation of the corrective action program.

Safety Reviews, Design Changes and Modifications

• The safety review program was implemented in accordance with Technical Specification requirements to ensure changes, tests and modifications are evaluated in accordance with regulatory requirements (Section 1.1).

Self-Assessments, Audits and Corrective Actions

• Issues were identified, screened, prioritized and evaluated commensurate with safety significance. The scope and depth of evaluations was adequate in that they addressed the significance of issues and assigned an effective and timely course of corrective action with the exception of certain thermal cutting activities in the auxiliary building (Section 2.1).

Decommissioning Performance and Status

• Radiological barriers and postings satisfied regulatory requirements. Workers followed work plans and were aware of the radiological controls specified in radiation work permits (Section 3.1).

• The heavy loads program was implemented in accordance with recognized industry standards to ensure personnel and radiological safety during movement of heavy loads.

However, slings used to lift loads did not all have markings to indicate when they were last inspected. Also, daily crane inspections did not include the level of rigor delineated in code standards (Section 3.2).

Occupational Radiation Exposure

• Radioactive waste liner transfer operations were executed as provided in planning documents and radiation exposure was maintained as-low-as-is-reasonably-achievable with some exception. The corrective action program was used by the licensee to capture lessons learned resulting in improved future liner transfer performance (Section 4.1).

• Reasonable actions were being taken to curtail low level personnel contamination events which have continued since 2012. However, the licensee failed to perform timely and adequate personnel surveys to identify the presence of discrete radioactive particles to assure compliance with Title 10 of the Code of Federal Regulations (CFR) 20.1201, which limits occupational radiation exposure to specified shallow-dose equivalent limits. As a

result, a substantial potential for an exposure in excess of shallow dose equivalent limits was identified, because it was fortuitous that the exposure to a worker was not greater. One violation of regulatory requirements was identified (Section 4.2).

• An adequate number and type of portable survey instruments and personnel contamination monitors were maintained to support the decommissioning project. Instruments were functionally tested, properly calibrated and alarm setpoints established consistent with industry standards (Section 4.3).

Radioactive Waste Management and Transportation

• A planned radioactive waste shipment of irradiated hardware was classified and characterized appropriately in accordance with 10 CFR 61.55 and 61.66 so as to meet low-level waste burial site criteria (Section 5.1).

• A planned shipment of radioactive waste was prepared and manifested consistent with the licensees procedures to meet the requirements of 10 CFR Part 20 and Part 61, and those of the Department of Transportation in 49 CFR Parts 170-189. However, the shipment was not made because the licensee identified that radiological payload restrictions invoked by a recent amendment to the cask certificate of compliance precluded shipment (Section 5.2).

Report Details Summary of Plant Activities During the quarterly inspection period, active decommissioning work was ongoing at the site and consisted of continued segmentation of the Unit-1 and Unit-2 reactor vessel internals, various waste packaging and shipment preparation activities, and extensive auxiliary building decommissioning work. Preparatory activities associated with the spent fuel dry cask storage campaign also continued.

1.0 Safety Reviews, Design Changes and Modifications (IP 37801)

1.1 Safety Review and Design Change Evaluations a. Inspection Scope The inspectors reviewed documentation and interviewed licensee staff to determine if the licensees safety review committee met as required by Technical Specifications (TS)

and as provided in procedures. Similarly, the inspectors reviewed documentation and performed interviews to verify that design changes, test, experiments, and modifications (CTEMs) were performed in accordance with NRC requirements.

b. Observations and Findings The inspectors reviewed the licensees safety review committee implementation. The safety review committee is responsible for reviewing and advising plant management on matters related to the safe storage of nuclear fuel. The licensee utilizes procedure ZAP-700-16 Station Review Committee, Revision 5 to implement the safety review committee requirements specified in Technical Specifications 5.9.2 Safety Review Committee and 5.9.3 Records. The implementing procedure adequately covered the scope of requirements specified in the TS. The procedure had recently been revised to include provisions for Title 10 of the Code of Federal Regulations (CFR) 72.48 reviews to accommodate spent nuclear fuel loading.

The inspectors reviewed the licensees implementation of the procedure by reviewing the most recent safety review committee meeting records. The records indicated that the licensee followed procedure and evaluated items as required by TS 5.9.2, documenting the outcome of meetings in accordance with TS 5.9.3.

The inspectors reviewed licensee procedures and processes associated with the control and implementation of design CTEMs. Specifically, procedure ZAP 510-02, Fuel Transfer and Dry Fuel Storage Plant Modifications, Revision 15, provided the process for implementing design changes for modifications associated with fuel transfer, transportation of fuel and dry fuel storage operations subject to 10 CFR 50, 10 CFR 71 and 10 CFR 72 regulatory requirements. ZAP-100-06, 10 CFR 50.59 Review Process, Revision 25, established the requirements for preparing, reviewing, approving, and documenting evaluations performed pursuant to the requirements of 10 CFR 50.59, for determining if a facility or procedure change, test, or experiment required NRC approval prior to implementation.

The inspectors selected an example of 10 CFR 50.59 screenings to ensure the licensee performed the screenings in accordance with procedure ZAP 100-06.

No findings of significance were identified.

c. Conclusions The safety review program was implemented in accordance with Technical Specification requirements to ensure changes, tests and modifications are evaluated in accordance with regulatory requirements.

2.0 Self-Assessments, Audits and Corrective Actions (IP 40801)

2.1 Identification, Resolution and Prevention of Problems a. Inspection Scope The inspectors reviewed several recently generated corrective action program (CAP)

documents to determine if a sufficiently low threshold for problem identification existed, to determine the quality of follow-up evaluations, and to determine whether the licensee resolved issues timely and appropriately. Corrective action program documents reviewed by the inspectors encompassed a range of issues but focused on radiological and non-radiological safety related to auxiliary building decommissioning activities. The CAP documents reviewed by the inspectors are listed in the attachment to this report.

b. Observations and Findings The inspectors determined that issues were identified at a low threshold within various functional areas of the site and entered into the CAP. Issues were screened, prioritized and evaluated commensurate with safety significance. The scope and depth of evaluations was adequate in that they addressed the significance of issues and assigned an effective and timely course of corrective action with the exception described below.

In July 2013, the licensee initiated work to extract the waste gas decay tanks and safety injection pumps from the auxiliary building. Thermal cutting techniques were used to expedite the removal, as components were cut into manageable pieces for disposal.

Workers involved in cutting activities were supplied with powered air-purifying respirators equipped with high efficiency particulate air (HEPA) filter cartridges to limit intake of non-radiological contaminants. Portable HEPA ventilation units were also used to control airborne contaminants in work areas. The licensees total effective dose equivalent ALARA evaluations demonstrated that respiratory protection equipment was not warranted for radiological purposes, as provided in 10 CFR 20.1701 and 20.1702. Air was routinely monitored for non-radiological hazards within the rooms/areas where torch cutting took place and in general areas outside the immediate work areas. The air monitoring revealed that iron, copper, carbon monoxide and hexavalent chromium off-gases were generated during the cutting operations. On several occasions, air monitoring data revealed that airborne concentrations of gases/vapors in the immediate areas where cutting activities took place reached Occupational Safety and Health Administration (OSHA) exposure limit guidelines, prompting work to stop. Additionally, although airborne levels outside the immediate work areas were determined to be within

industry exposure guidelines, visible smoke and fumes from metal melt caused eye and throat irritation to those working nearby. Following these problems, the licensee made adjustments in an effort to improve ventilation control; however, those actions were not completely effective as similar problems reoccurred when work resumed. Subsequently, the inspectors noted that other actions were being put into place to better control non-radiological airborne conditions while cutting operations continued. Based on the foregoing, the inspectors determined that the extraction work in the auxiliary building was not pre-planned to the extent warranted to ensure fixed and portable ventilation systems were available, configured optimally and other appropriate measures were used to minimize the impact of non-radiological airborne hazards.

No findings of significance were identified.

c. Conclusions Issues were identified, screened, prioritized and evaluated commensurate with safety significance. The scope and depth of evaluations was adequate in that they addressed the significance of issues and assigned an effective and timely course of corrective action with the exception of certain thermal cutting activities in the auxiliary building.

3.0 Decommissioning Performance and Status Review (IP 71801)

3.1 Plant Tours/Walkdowns a. Inspection Scope The inspectors conducted plant tours throughout the inspection period to observe field conditions, discuss job safety with workers, and to assess the impact of work activities on safe decommissioning. During walkdowns, the inspectors evaluated area radiological conditions, work coverage and associated posting/labeling, reviewed the condition of systems, structures and components that support decommissioning and the overall work safety environment. Independent radiation measurements were made by the inspectors in areas toured to determine if those areas were controlled and posted as prescribed in 10 CFR Part 20.

b. Observations and Findings The inspectors found that controls associated with Unit-1 & Unit-2 Containment Building and Auxiliary Building work included those required to prevent unauthorized entry into radiologically posted areas.

During walkdowns, the inspectors found that work coverage provided by the radiation protection staff was adequate for the work observed. The inspectors determined that personnel were aware of job controls specified in work instructions and demonstrated proper radiological awareness. The inspectors found that workers involved in tank/pump extraction activities in the auxiliary building were equipped with appropriate respiratory protection equipment. Supervisors were actively engaged in work oversight and were observed making field adjustments to better control work as it progressed.

No findings of significance were identified.

c. Conclusions Radiological barriers and postings satisfied regulatory requirements. Workers followed work plans and were aware of the radiological controls specified in radiation work permits.

3.2 Control and Movement of Heavy Loads a. Inspection Scope The inspectors reviewed the licensees program for the control of heavy loads to determine whether load lifts at the site were performed safely and in accordance with recognized industry standards. Inspectors focused on non-fuel related loads conducted in the Turbine Building, the Containment Buildings, and those lifts that used the 440-ton mobile lattice boom crane stationed outside of Unit-2 Containment.

b. Observations and Findings Heavy load lift procedure ES-SH-PG-60, Hoisting and Rigging Program, Revision 1, defined the minimum requirements for safe operation of cranes and hoists. Specifically the procedure designated requirements for training and qualification of personnel, inspection and maintenance of cranes or hoists, the safe use of rigging equipment, and documentation for non-standard lifts through supplemental implementing procedures tied to the load lift procedure. Supplemental procedures associated with ES-SH-PG-60 were evaluated by the inspectors and found to be adequately implemented.

The inspectors met with several crane operators and riggers during field operations and confirmed their knowledge of heavy loads operations through visual observation and discussion. The inspectors reviewed license qualification documents which demonstrated that worker qualifications aligned with station procedures and ASME B30 standards.

The inspectors reviewed the licensees work order packages for the most recent turbine building crane and containment building polar crane periodic (annual) inspection to ensure it met the requirements of the implementing procedures and ASME B30.2 requirements. The inspectors also reviewed the licensees periodic (annual) and monthly inspection of the 440-ton mobile crane to ensure it met the requirements of the implementing procedures and ASME B30.5 requirements. The inspectors reviewed daily overhead crane inspection implementing procedures and met with staff performing the procedure. The inspectors noted that the licensee credited daily inspections to satisfy ASME B30.2 frequent inspection requirements. The inspectors discussed with the licensee that the rigor of the daily inspection may not fulfill the requirements of the frequent inspection as required by ASME B30.2.

The inspectors reviewed the licensees program for annual inspection of slings and discussed expectations with workers about daily sling inspections. The inspectors performed a walkdown of several areas and identified that only a few slings used in the containment and turbine buildings were marked to indicate sling inspection status as provided in ASME B30.9-2003. The inspectors questioned whether site personnel used slings that had not been appropriately tested or inspected. The licensee indicated that

riggers were required to verify a yearly inspection had been performed prior to rigging a load.

The inspectors observed the licensee perform in field heavy loads operations. The inspectors observed the licensee move empty dry fuel storage canisters utilizing the turbine building crane. The inspectors observed the licensee perform a non-standard lift of a Class B/C radioactive waste liner, its over pack and associated transfer bell cask utilizing the containment polar crane and transfer bell hoist. Inspectors planned to watch a lift of the cask with the 440-ton mobile lattice boom crane, however prior to the lift the licensee identified issues with a transducer associated with the lattice boom during daily checks and postponed the lift until repairs could be made.

The inspectors met with structural engineering staff and discussed the licensees ongoing assessment of the heavy haul cart system for moving loads outside the containment buildings.

No findings of significance were identified.

c. Conclusions The heavy loads program was implemented in accordance with recognized industry standards to ensure both personnel safety and radiological safety during movement of heavy loads. However, the inspectors noted that slings used for load lifts did not all have markings to indicate when they were last inspected. Also, the inspectors noted that daily overhead crane inspections did not include the level of rigor delineated in code standards.

4.0 Occupational Radiation Exposure (IP 83750)

4.1 External Exposure Control a. Inspection Scope The inspectors evaluated the safety controls and overall execution associated with radwaste liner transfer operations from Unit-2. The inspectors attended pre-job briefings associated with liner transfers, reviewed radiological surveys, radiation work permits (RWPs) and ALARA documents to determine if the licensee appropriately identified hazards, communicated those hazards to workers and whether controls were established to mitigate potential consequences. Additionally, during plant walkdowns, the inspectors reviewed other work activities to determine whether safety controls aligned with industry standards.

b. Observations and Findings As part of the decommissioning project, containers (metal liners) were loaded with segmented reactor vessel internals inside the containment buildings and moved outside for temporary storage in designated storage vaults. The inspectors observed various phases of liner transfer operations that were conducted during the inspection period.

The inspectors evaluated different aspects of liner transfer operations on separate occasions since liner transfer activities occurred both inside and outside the containment building. The inspectors found overall that work was executed as provided in work

planning documents including rigging and heavy load lift activities, implementation of the physical security plan during liner movements and the control of radiation exposure.

Portions of a liner transfer were suspended due to a potential problem with crane operations, which the inspectors recognized as a conservative decision. The inspectors noted that radiological conditions were appropriately determined and conveyed to workers before work commenced, that ALARA measures were implemented through the use of teledosimetry (remote monitoring) and long handled tooling, through worker positioning relative to the source of radiation and recognizing the importance of minimizing time, increasing distance and taking advantage of the shielding provided by the transfer bell. Despite these controls, during transfer of the hottest liner to date, some workers had unexpected electronic dosimetry alarms because their positioning was not rigorously controlled by the radiation protection staff during certain work steps.

However, actions were taken to address these deficiencies before a subsequent liner transfer. Additionally, during movement of the same hot liner, the licensee recognized that unrestricted area dose limits of 10 CFR 20.1301(a)(2) could be challenged following placement of the liner in the storage vault before the vault lid was secured due to radiation scatter (sky shine). Other inspector and licensee observations associated with liner transfer were captured in the corrective action program and were addressed before additional liners were transferred.

No findings of significance were identified.

c. Conclusions Liner transfer operations were executed as provided in planning documents and overall radiation exposure was maintained ALARA with some exception. The corrective action program was used by the licensee to capture lessons learned resulting in improved future performance.

4.2 Control of Radioactive Material, Contamination and Radiation Surveys a. Inspection Scope The inspectors reviewed the licensees area survey information, job specific survey data and numerous condition reports generated in the months preceding the inspection in an effort to assess the effectiveness of contamination controls at the site. Personnel contamination event (PCE) reports, licensee generated PCE summary data and trending/tracking information, issue reviews, and other pertinent contamination control information were reviewed by the inspectors and discussed with the licensee.

Additionally, the inspectors reviewed the licensees program for the identification and control of discrete radioactive particles (DRPs) along with CAP documents related to DRPs to determine the scope and breadth of particle problems at the site.

b. Observations and Findings Personnel Contamination Events The site had approximately two-hundred PCEs in 2012 and about one-hundred in 2013 through September 2013. The PCEs in 2012 involved primarily clothing or shoe contamination attributed to poor worker practices. Approximately 25% of those PCEs involved low-level skin contaminations. In 2013, similar percentages of skin

contaminations occurred but were attributed mostly to ventilation system issues and inadequate radiological housekeeping, not worker practices. According to the licensee, worker practices had improved in 2013 reducing the percentage of PCEs attributed to that cause. The inspectors noted that supplemental radworker training provided by the licensee and the experience gained at the site improved worker performance. The inspectors found that none of the PCEs in 2012 or 2013 resulted in more than minor dose consequence with the exception of the DRP incident described below.

Various actions have been taken by the licensee in an effort to reduce the number of PCEs over the last year which focused primarily on actions to improve radworker practices. These efforts have had mixed success because PCEs continued in 2013 at a generation rate similar to 2012, although attributed to different cause(s). The inspectors determined that the licensee continued to take reasonable actions to address vulnerabilities related to radiological housekeeping and fundamental contamination control practices consistent with the hazards. The licensee identified that resources devoted to radiological housekeeping had not been sufficient given the expanding scope of the decommissioning project. To address this shortfall, the licensee recently supplemented the radiation protection staff to bolster radiological housekeeping and contamination control.

Identification and Control of Discrete Radioactive Particles The licensee commenced reactor vessel internals segmentation in early-mid 2012, starting in Unit-2 then transitioning to Unit-1. The segmentation work was performed using mechanical cut and milling equipment designed specifically for the Zion project.

Components were segmented underwater in the refueling cavities, and sized to fit into liners for shipment to low-level waste burial sites. The reactor vessel internals hardware can be highly radioactive depending on core location, material composition and the neutron flux during reactor operations. The activation products of the internals hardware are comprised primarily of Co-60, Ni-59 and Ni-63 in concentrations ranging up to Greater than Class C (GTCC) materials, as defined in 10 CFR 61.55.

Activated metallic chips and fines are radioactive byproducts of the cutting/milling operation and visibly present in the cavity pool, as they typically settle on horizontal surfaces. Small discrete chips/fines with radioactive content greater than one microcurie are defined as hot particles in the licensees procedure ZS-RP-106-002-005, Identification and Control of Discrete Radioactive Particles. These particles can deliver significant worker dose depending on radioactive content and the duration they are present on an individual. To reduce some of these hazards, the licensee routinely processed cavity water using an in-pool filtration and demineralization system. That system was supplemented as the segmentation project progressed with a Tri-Nuke filtering system. These systems, however, were used primarily to remove suspended particles to maintain pool water clarity, not to remove more dense chips/fines which settled on surfaces. A chip collection system was intended to be used during the segmentation project to periodically vacuum metal chips/fines and retrieve larger particulates, but that system was not effective and its use was short-lived.

Given these radioactive byproducts and their accumulation in the cavity pool during the one-year plus extended segmentation project, an increasing potential existed for discrete radioactive particles to be inadvertently extracted or migrate from the cavity pools. In particular, long-handled poles are routinely used by workers to reposition segmentation equipment and particles have clung to the poles as they are removed from the pools.

Although items raised from the pools are power-washed, rinsed or otherwise wiped-down to reduce the probability of particle removal, these methods are not 100%

effective. Recognizing this hazard, radiological surveys were performed by radiation protection staff to identify the presence of contaminants including particles on items extracted from the pool. These surveys had occasionally identified contaminants outside the pool water causing the licensee to adjust its practices and to enhance survey protocols. Particles with radioactive content less than one microcurie had been identified on two previous occasions on the skin of workers but with minimal dose consequence. One of these prior occurrences was documented in Inspection Report No 05000295/12-009(DNMS); 05000304/12-009(DNMS).

On July 19, 2013, a worker involved in Unit-2 segmentation activities and handling long-handled poles alarmed the automated personnel contamination monitors upon attempted egress from the radiologically controlled area (RCA). The worker spent about three hours working in Unit-2 that morning. A metal sliver activated with a 1.56 microcurie Co-60 particle was identified on the workers face and removed by the licensee. Follow-up area surveys by the licensee identified similar levels of contaminants on the cavity walkways surrounding the pool, indicating that contamination control problems were created by the segmentation work that morning and not promptly identified. The licensee conservatively determined that the workers shallow-dose equivalent over the contiguous ten square centimeters of skin receiving the highest exposure was 1980 millirem and the deep dose equivalent was 27 millirem. The inspectors independently verified the accuracy of the licensees calculations using the VARSKIN 2 computer code endorsed in NUREG/CR-5873.

The outcome of the licensees review of the July 19, 2013 incident was non-conclusive but determined that the hot particle was probably present on the long-handled pole, transferred to the workers glove and then to the workers hood and face as the hood was repositioned by the worker. According to the licensee, items being removed from the pool that morning were wiped-down as required and protective clothing dress requirements specified in the RWP were met. The inspectors agreed with the licensees determination that radiological surveys conducted during the segmentation work that day were not adequate to timely identify the particle that was present on the worker and the contamination that had spread into adjacent work areas.

Various measures were put in place by the licensee immediately following the incident to prevent recurrence; however, those actions focused primarily on radiological survey practices and not particle hazard mitigation. Since the incident, surveys were being performed of workers on at least an hourly frequency if items were extracted from the cavity pool. Survey methods were also improved as enhanced particle detection techniques were developed and implemented. Additionally, RWPs were revised to require the use of face shields for cavity pool related segmentation activities. These remedial actions were instituted in the days following the incident and continue to date.

A chip collection/pool desludge system is being explored by the licensee as a means to clean the cavity pools and reduce the inventory of DRPs. Deployment of that system is expected in November 2013.

The July 19, 2013 incident presented a substantial potential for an exposure in excess of shallow dose equivalent limits of 10 CFR 20.1201 because it was fortuitous that the source strength (radioactive content of the particle) was not substantially greater.

Metallic chips/fines of unknown and varied radioactive content are generated during internals segmentation and are present in the reactor cavity pools. Tooling that is routinely used during segmentation activities such as the long-handled poles used on July 19, 2013, have the potential for transferring DRPs onto workers and areas. Had a particle with a Co-60 content of approximately 40 microcurie or greater been transferred onto the workers skin on July 19, an exposure in excess of regulatory limits could have occurred. The licensees work controls did not effectively prevent the accumulation of DRPs in the cavity pool and radiological surveys were not adequate to detect their presence on a worker in a timely manner to preclude a potential exposure in excess of regulatory limits.

Title 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive material, and the potential radiological hazards that could be present. As defined in 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal or presence of radioactive material or other sources of radiation.

Contrary to the above, on July 19, 2013, the licensee did not perform adequate surveys to assure compliance with 10 CFR 20.1201, which limits occupational radiation exposure to specified shallow-dose equivalent limits. Specifically, adequate and timely radiological surveys were not made to identify the presence of a discrete radioactive particle on a workers face which caused unnecessary radiation exposure. Moreover, the situation presented a substantial potential for an exposure in excess of shallow-dose equivalent limits because the radioactive content of the particle could have been greater.

The self-revealed violation is of more than minor safety significance because it resulted in unnecessary radiation exposure to a worker which could have been greater. The violation examples in Section 6.7 of the Enforcement Policy provide for a Severity Level III violation should a substantial potential for an exposure exist that could be in excess of applicable limits in 10 CFR 20.1001 - 20.2401. However, applying risk insights associated with exposure to DRPs, a Severity Level IV violation is appropriate for this incident. The basis for this determination is that shallow dose from DRPs does not have significant actual (biological) consequence. Therefore, the violation is dispositioned at Severity Level IV consistent with Sections 2.2 and 6.7 of the Enforcement Policy. The violation is being cited because the licensees corrective actions may not be sufficient to prevent recurrence (VIO 05000295/2013-11-01; 05000304/2013-11-01). The segmentation project continued shortly after the incident even though particle hazard in the cavity pools were not mitigated. Corrective actions implemented through October 24, 2013 did not address the ongoing potential for DRPs that are likely present in the cavity pools to be extracted or otherwise migrate from the pools and potentially deliver a shallow dose in excess of regulatory limits.

No findings of significance were identified; however, a Severity Level IV violation was disclosed through a self-revealing incident.

b. Conclusions Reasonable actions were being taken by the licensee to curtail low level personnel contamination events which have continued since 2012. However, the licensee failed to perform surveys of a worker that were necessary to identify discrete radioactive particles to assure compliance with 10 CFR 20.1201, which limits occupational radiation exposure to specified shallow-dose equivalent limits. As a result, a substantial potential for an exposure in excess of shallow dose equivalent limits was identified.

4.3 Radiological Instrumentation a. Inspection Scope The inspectors reviewed the licensees radiological survey instrumentation to determine if a sufficient number and type of instruments was available to support the decommissioning project. The review included portable instruments used for job coverage to determine area radiological conditions, instruments used to monitor workers for contamination and the device used for calibration of portable radiation survey instruments. The inspectors evaluated the licensees procedures and practices for functional testing these instruments to demonstrate instrument readiness.

b. Observations and Findings Radiation protection staff used appropriate radiation sources and methods to functionally test portable survey instruments prior to use each day. Procedures developed for functional testing instruments were adequate to ensure that the instruments were operationally checked on all appropriate scales. Adequate methods were used to log-out and return instruments back to storage or tag them out-of-service should an instrument fail the functional check.

The inspectors observed that radiation protection staff used the portable survey instrument calibration unit as specified by procedure and were cognizant of backscatter issues that could impact measured results. The inspectors selectively compared calibrator exposed readings with calculated values to validate results. The inspectors also found that staff were knowledgeable in functional test protocols, as radiation protection technicians demonstrated the methods for performing source checks of portable survey instruments and operational checks of personnel contamination and portal monitors.

Gamma sensitive portal monitors and beta radiation sensitive personnel contamination monitors located at the main RCA egress and at alternate locations were determined to be set to alarm at sufficiently low levels and functionally checked daily consistent with operating reactor standards. The portal monitors were demonstrated to satisfy the monitoring requirements of 10 CFR 20.1502(b) for use as passive monitors to identify the presence of internally deposited radioactive material. Records revealed that instrumentation was calibrated as required by the licensees procedures, consistent with industry and regulatory standards. Instruments found to be significantly out of tolerance during the calibration process were evaluated to determine possible consequences during prior instrument use, as is the industry norm.

No findings of significance were identified.

b. Conclusions An adequate number and type of portable survey instruments and personnel contamination monitors were maintained to support the decommissioning project.

Instruments were functionally tested, calibrated and alarm setpoints were established consistent with industry standards.

5.0 Solid Radioactive Waste Management and Transportation (IP 86750)

5.1 Waste Classification and Characterization a. Inspection Scope The inspectors reviewed the licensees method to classify and characterize a planned waste shipment of irradiated hardware to determine if the radionuclide mix and content was accurate. The use of scaling factors was reviewed to determine if hard-to-detect radioactive materials (e.g., pure alpha or beta emitting radionuclides) were included in the characterization. The review was performed to determine whether the licensee characterized and classified the proposed radioactive waste shipment in compliance with 10 CFR 61.55 and 10 CFR 61.66, as required by Appendix G of 10 CFR Part 20 so as to meet low-level waste burial site criteria.

b. Observations and Findings The inspectors found that the licensees method for determining the radionuclide content of a planned September 17, 2013 shipment of segmented unit-1 reactor internals was technically sound. Shipment content was based on unit-1 historical neutron flux profiles and corresponding activation analyses, and verified for conformity with component dose rate information. Characterization assumptions and the activation analysis results were reviewed by the inspectors to verify the accuracy of the licensees characterization and waste classification calculations.

No findings of significance were identified.

c. Conclusions A planned radioactive waste shipment of irradiated hardware was classified and characterized appropriately in accordance with 10 CFR 61.55 and 61.66 so as to meet low-level waste burial site criteria.

5.2 Shipment Preparation and Manifesting a. Inspection Scope The inspectors observed shipment preparations and selectively reviewed documentation of shipment packaging, package/vehicle radiation surveys and placarding, package labeling and marking, carrier instruction and the licensees draft manifesting of a shipment planned for September 17, 2013. For this planned shipment, the inspectors determined if the requirements of 10 CFR Parts 20 and 61, the requirements of the Department of Transportation (DOT) in 49 CFR 170-189 and the conditions of the cask certificate of compliance were met.

b. Observations and Findings The inspectors observed various preparatory activities conducted on September 16 and 17, 2013, associated with the loading of a liner with Unit-1 segmented components which consisted primarily of upper core plate sections. The liner was loaded into an overpack, a secondary container and ultimately into a Type B (U) package. The package was to be used by the licensee under the general license provisions of 10 CFR 71.17.

The inspectors evaluated the radiological controls during the loading process, observed cask preparatory activities including lid and vent port leak testing, plus reviewed documentation to verify that the licensee satisfied selected criteria of the certificate of compliance (COC) for the package. Additionally, for this shipment, the inspectors determined if the requirements of 10 CFR Parts 20 and 61 and those of the DOT were met. The inspectors validated that the package was labeled and marked properly, that package and transport vehicle surveys were performed with appropriate instrumentation and that results satisfied DOT criteria. The inspectors also determined that the draft shipment manifest was completed in accordance with NRC and DOT requirements and included the required emergency response information.

Shortly before shipment departure, the licensee identified that gamma emitter payload restrictions invoked by Revision 19 to the cask COC (effective September 1, 2013)

precluded the shipment because the Co-60 content exceeded limitations. The restrictions were enacted in the cask COC as a conservative measure to ensure cask dose rates were met for non-homogeneous payloads under all conditions incident to transport. The shipment was not made as planned and future similar shipments were postponed. These issues were documented in the licensees corrective action program and being resolved by the cask license holder.

No findings of significance were identified.

c. Conclusions A planned radioactive waste shipment was prepared and manifested consistent with the licensees procedures to meet the requirements of 10 CFR Part 20 and Part 61, and those of the DOT in 49 CFR Parts 170-189. However, the shipment was not made because the licensee identified that radiological payload restrictions invoked by a recent amendment to the cask certificate of compliance precluded shipment.

6.0 Exit Meeting One of the inspectors presented the results of the inspection to Mr. Baker during a telephone call on October 24, 2013. The licensee acknowledged the results presented and did not identify any of the documents reviewed by the inspectors as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED P. Daly, Senior Vice President and General Manager G. Bouchard, Vice President, Engineering, Operations & Nuclear Security

• S. Chris Baker, Vice President, Environmental Health & Safety P. Thurman, Vice President, Regulatory Affairs D. Brown, Vice President, D&D and Construction R. C. Keene, Director, Radiation Protection M. Wiskerchen, Waste Operations Manager L. Edinger, Industrial Health & Safety Specialist M. Manninen, Radiation Protection Technical Manager

• Participated in the October 24, 2013 telephone call.

INSPECTION PROCEDURES (IPs) USED IP 37801 Safety Reviews, Design Changes and Modifications IP 40801 Self-Assessment, Auditing and Corrective Actions IP 71801 Decommissioning Performance and Status Review IP 83750 Occupational Radiation Exposure IP 86750 Solid Radioactive Waste Management and Transportation ITEMS OPENED, CLOSED, AND DISCUSSED Opened Type Summary 05000295/13-11-01 VIO Failure to perform adequate radiological surveys to 05000304/13-11-01 identify the presence of discrete radioactive particles PARTIAL LIST OF DOCUMENTS REVIEWED CR-2013-000811; Reported Schedule Pressure; dated July 31, 2013 CR-2013-000813; Carbon Monoxide Symptoms; dated July 31, 2013 CR-2013-000814; Elevated Carbon Monoxide Levels; dated July 31, 2013 CR-2013-000815; Elevated Airborne Metal Fume Concentrations; dated July 31, 2013 CR-2013-000927; Hexavalent Chromium Medical Surveillance Required; dated August 28, 2013 RWP 2013-2-0002; Waste Operations, Security, Radiation Protection & Crane Support for Transfer of Liners from Unit 2 for Shipment or Transport to South Yard for Storage; Revision 3 ALARA Review for RWP 2013-2-002; Revision 2 Attachment

Energy Solutions Procedure TR-TP-002; Air Pressure Drop Test for Model 8-120B Cask Certificate of Compliance 9168; Revision 19 Energy Solutions Procedure TR-OP-035; Handling Procedure for Transport Cask Model 8-120B Certificate of Compliance 9168; Revision 23 DW James Consulting Document DAC-0032; Flux Profiles; Revision 2; Document DAC-0033; Activation Analysis for Internals Regions of U-1/U-2; Revision 2; and Document DAC 0035; Project Packaging Plan for Unit-1; Revision 3 DW James Consulting Document DAC-0166; Final Packaging Plan for Liner 619188-17; Revision 0 Certificate of Compliance No. 9168 for the Model No. CNS 8-120B; Amendments 17, 18 and 19 Safety Evaluation Report for Certificate of Compliance No. 9168, Revision 19 Energy Solutions Cask Book for Model 8-120B USA/9168/B(U); Revision 39 Gamma Irradiator Service Report and Source Characterization for Model 89-400 Calibrator; dated April 3, 2013 Focused Area Self-Assessment Report; Radiation Protection Portable Instruments; dated January 4, 2012 Focused Area Self-Assessment Report; Radioactive Source Handling and Control; dated December 4, 2012 ZRP 5822-10; Calibration of the Eberline PM-7 Portal Monitors; Revision 13 ZS-RP-108-000-001; Instrument Issue and Operational Testing; Revision 2 ZRP 5822-7; Source Check and Calibration of the NE Technology IPM-8 Whole Body Frisking Monitor; Revision 13 Certificate of Calibration for Ludlum Measurements Model 12-4 (SN 294866); dated June 15, 2013 Calibration Record for SAM-11, No. 524; dated July 5, 2013 Calibration Record for AMP-100, No. 5010-032; dated April 11, 2013; and AMP-200, No. 7711-004; dated April 16, 2013 Calibration Record for Telepole, No 6611-172; dated August 21, 2012; and No. 6611-089; dated February 19, 2013 Draft Shipment Manifest and Waste Characterization Information, Radiological Surveys and Associated Documentation for Shipment No. RW-13-058; Shipment of Activated Metal in Type B(U) Package; Planned for Shipment September 17, 2013 Calibration Record for Eberline RO-2, No 1580; dated May 23, 2013

Calibration Record for Eberline Model-3, No. 283057; dated October 23, 2012 Certificate of Calibration for RO-20, No. 11853; dated December 13, 2012 Calibration Record for IPM-8, Various Instruments and Dates in 2013 Calibration Record for PM-7, Various Instruments and Dates in 2013 ZS-RP-106-002-005; Identification and Control of Discrete Radioactive Particles; Revision 1 CR-2013-000764; Personnel Contamination Event in Unit 2 Containment; dated July 22, 2013 Issue Review for CR-2013-000764; dated August 25, 2013 Personnel Contamination Event Report and External Dose Assessment for July 19, 2013 Incident; dated July 22, 2013 RWP 2013-2-2005; Operate, Maintain, Repair and Modify Segmentation Equipment In or Over the Cavity Pool or in the Maintenance Stand; Revision 4 RP-AA-250; External Dose Assessment from Contamination; Revision 4 Personnel Contamination Event Summary Data and Trending Information; Undated Siempelkamp Nuclear Services, Inc., Work Instruction for the Segmentation of Zion Generating Stations Unit-1 Reactor Vessel Internals; Revision 2 50.59 Screening 2013-045; Service Water Isolation to the Unit 0 and 2 CC Heat Exchangers to Prevent Flooding of the Auxiliary Building During Decommissioning; Revision 0, 50.59 Screening 2013-056; Re-Power Auxiliary Building Fire Sirens from 617 Elevation; Revision 0 50.59 Screening 2013-070; DSAR Control Room Ventilation System Update DSAR Change #

2013-05; Revision 0 Certificate of Unit Test and/or Examination of Crane and Derricks Used for Lifting Service -

Manitowoc Lattice Boom Crane; May 1, 2013 CR-2012-001284; Concern with the Establishments of the B/C Water Storage Area; December 5, 2012 ES-SH-PG-60; Hoisting and Rigging Program; Revision 1 Work Order 01541678; Perform Unit 2 Polar Crane Inspection; January 23, 2013 Work Order 01541679; Perform Annual Unit-1 Polar Crane Inspection; January 15, 2013 Work Order 01544678; Unit-1 Turbine Building Overhead Crane Mechanical and Electrical PM; March 20, 2013

Work Order 01547169; Unit 2 Turbine Building Overhead Crane Mechanical and Electrical PM; March 22, 2013 ZAP 510-02; Fuel Transfer and Dry Fuel Storage Plant Modifications; Revision 15 ZAP-100-06; 10 CFR 50.59 Review Process; Revision 25 ZAP-700-16; Station Review Committee; Revision 5 ZS-WC-100; Decommissioning Work Control Process, Initiating and Screening Work Requests; Revision 6 4