ML19344A512
| ML19344A512 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 07/18/1980 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML19344A479 | List: |
| References | |
| NUDOCS 8008200538 | |
| Download: ML19344A512 (6) | |
Text
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l 'W TN Commonwealth Edison
[Opj - ona First N;tional Plata. Chic"go. Illinois O
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Address Reply to: Post Office Box 767 Q
Chicago, lihnois 60690 July 18, 1980 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Zion Station Units 1 and 2 Response to Health Physics Appraisal IE Inspection Report Nos. 50-295/80-05 and 50-304/80-04 NRC Docket Nos. 50-295 and 50-304 References (a):
June 27, 1980 letter from J. G. Keppler to J. J. O'Connor (b):
May 14, 1980 letter from J. G. Keppler to C. Reed
Dear Mr. Keppler:
Reference (a) transmitted an inspection report regarding an NRC conducted special appraisal of the health physics program at Zion Station during the period March 10 through March 21, 1980.
That report identified four apparent items of noncompliance with NRC requirements.
Commonwealth Edison Company's response to these items are contained in the enclosure to this letter.
Per Appendix A of Reference (a), the NRC Staff also delineated several apparent significant weaknesses in our health physics program and requested Commonwealth Edison to provide the corrective steps taken or to be taken, including completion schedules.
These weaknesses were discussed at meetings between members of our respective staffs on April 11 and 28, 1980.
As indicated in Reference (a), the results of these meetings and the actions to be taken by Commonwealth Edison to correct the apparent weaknesses were documented in an April 15, 1980 letter from J. G.
Keppler to J. J. O'Connor and in the Immediate Action Letter of Reference (b).
8008200 538 NL221980
Commonwo:lth Edison Mr. James G. Keppler, Director July 18, 1980 Page 2 Currently, Commonwealth Edison has accomplished or is on schedule for accomplishing all of the corrective actions delineated in the Immediate Action Letter of Reference (b).
In order to adequately and thoroughly address in detail each specific item of the "Significant Appraisal Findings" contained in Appendix A of Reference (a), Commonwealth Edi',n requests an extension to August 20, 1980 for respo.. Jing to ther' items.
This extension was discussed and tentatively agreed to in a July 18, 1980 phone conversation between Dr.
W.
F. Naughton of our of fice and Mr. A. B.
Davis of your office.
Approval of this extension should be granted based on the NRC Staff's assessment in Reference (a) that to date Commonwealth Edison has appeared to be responsive to NRC concerns on these findings and that the present health physics program at Zion Station is considered adequate for continued operation while achieving acceptable corrective action.
Please address any additional questions that you might have concerning this matter to this office.
Very truly yours, 9_o_
Cordell Reed Vice President of Nuclear Operations CR:WFN: rap Enclosure l
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NRC Docket Nos. 50-295 50-304 Enclosure Response to Notice of Violation The items of apparent noncompliance identified in Appendix B of the NRC letter dated June 27, 1980 are responded to in the following paragraphs:
Item 1 (Infraction)
Technical Specification 6.2.B requires adherence to radiation control procedures.
Procedure RP 1440-1, " Hot Tool Procedure,"
requires:
that beta-gamma activity on tools stored in an unshielded a.
container in the auxiliary building not exceed a direct reading of 6000 counts per minute at one inch; and b.
that all contaminated tools and equipment be marked with purple paint for identification purposes.
Contrary to the above, tools found in unshielded contractor tool boxes in the auxiliary building on March 19, 1980, were unmarked although contalminated to 15,000 counts per minute, and tools left on the auxiliary building floor between March 14 and March 19, 1980, were unmarked, unwrapped, and unshielded, although reading up to 30,000 counts per minute.
Corrective Action Taken and The Results Achieved:
Contractor tools found contaminated in excess of 6000 cpm 0 1" are now being kept in a separate gang box set off in a low traffic area of the Auxiliary Building.
The exposure rate at contact with the box will be kept to less than 2.5 mR/h.
Commonwealth Edison Company I
maintenance tools are kept in a designated hot tool room which is less than 2.5 mR/h at the door.
Corrective Action to be Taken to Avoid Further Noncompliance:
Periodic inspections of contractor gang boxes are being conducted to identify tools which require purple painting for contamination marking.
In addition, tools which are found contaminated during release surveys are either deconned or painted.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved at this time.
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a Item 2 (Infraction) 10 CFR 20.203(c)(2) lists three alternative requirements for each entrance or access point to a high radiation area.
Contrary to the requirements specified, the entrance to a high radiation area created by portable demineralizers on March 17, 1980, was not locked or equipped with an audible alarm system or equipped with a device to reduce the radiation level.
Corrective Action Taken and The Results Achieved:
The high radiation area created by portable demineralizers is and has been controlled through the use of 7' high water shields.
These shields extend around the demin in a manner which precludes possible access or entrance to the demin other than via the use of a ladder.
This type of rad control is analagous to other plant demins located behind shielded walls.
The portable demin area is also properly posted as a high radiation area.
During the NRC inspection, a ladder was found unattended beside the water shields.
As corrective action, the ladder was removed from the area.
Corrective Action to be Taken to Avoid Further Noncompliance:
The Rad / Chem Technicians and Radwaste Foremen have been reinstructed that the use of a ladder requires the establishment of positive control for each individual entry into the demin are'a.
At the conclusion of each entry the ladder will be removed from the area.
Date When Full Compliance Will be Achieved:
The station is in full compliance with 10 CFR 20.203 at this time.
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O 1 Item 3 (Infraction)
Technical Specification 6.2.B requires adherence to radiation control procedures.
Procedure RP 1280-5, " Instrumentation Maintenance and Control," specifies quarterly calibration for portable survey instruments.
Contrary to the above requirement, calibration was missed on two ion-chamber survey instruments (S/N 630 and S/N 632) in the third quarter and on one instrument (S/N 370) in the fourth quarter of 1979.
Corrective Action Taken and the Results Achieved:
The radiation protection foremen are responsible for ensuring that all instruments are calibrated as required by procedures.
Each Rad / Chem Tech is assigned an ion chamber survey meter with the understanding that the instruments are to be calibrated by each owner.
Two of the instruments were being stored by the Techs in their lockers and were not being used.
The instruments were removed from service.
Subsequently they were calibrated and returned to use.
The technicians involved were reinstructed regarding the requirements for timely instrument calibrations.
Corrective Action to be Taken to Avoid Further Noncompliance:
To prevent future occurrences, instrument calibration records will be reviewed on a monthly basis.
Date When Compliance Will Be Achieved:
Full compliance has been achieved at this time.
Item 4 (Infraction)
Technical Specification 6.2.A.4 requiles adherence to written procedures covering emergency conditions.
Appendix B of the Zion Emergency Plan Implementing Procedures requires that the Zion Station Emergency Trailer supplies include a pulse integrator, five 100 R self-reading pocket dosimeters, an air sampler tripod, a set of keys to the environmental monitoring stations, and a large waste container.
Contrary to this requirement, all of the above items were missing from the Zion Station Emergency Trailer when it was inventoried during the week of March 17, 1980.
Corrective Action Taken and The Results Achieved:
The type of equipment and supplies kept in the emergency monitoring facility has been reviewed in light of our expected needs during an emergency involving significant plant releases.
Subsequently, the station has deleted a number of supplies which were on the inventory list including most of the items which were found missing during the audit.
The trailer has been cleaned, labeled and inventoried to include supplies consistent with environmental sampling.
In addition, appropriate changes have been made to EPIP Appendix 8.
The purpose of this facility is to provide the station with the capability to perform limited environmental monitoring during an alert, site emergency or general emergency until relieved by monitoring teams from the State of Illinois or other Edison sites.
Corrective Action to Be Taken to Avoid Further Noncompliance:
The lock on this facility will be changed and the keys will be under the control of the Rad Protection Foreman to ensure that equipment and supplies are not lost or removed for other uses.
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inspection and inventories will be performed.
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Date When Full Compliance Will be Achieved:
Full compliance has been achieved at this time.
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