ML20059N673
| ML20059N673 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/09/1990 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9010170125 | |
| Download: ML20059N673 (3) | |
Text
.
Commonwootth Edison
) 1400 Opus Pl:ce ac owners artve, unn:Is 60515 i
x t
i October 9, 1990 l
l Mr. A. Bert Davis Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road i
Glen Ellyn, Il 60137 i
Subject:
Zion Station Units 1 and 2 j!
Response to Inspection Report Nos. 50-295/90015 and 50-304/90017-l O nchet Nos. 50-295 and 50-304
Reference:
(a) L.R. Greger letter to Cordell Reed dated September 6, 1990
Dear Mr. Davis:
i The letter of reference (a) provided the results of a routine safety, inspection of the activities at Zion Station Units 1 and 2 during the period of July 16 through August 8, 1990. The letter indicated that certain activities appeared to be in violation of NRC requirements..The Commonwealth Edison c
Company response to the Notice of Violation is provided:in the-enclosure.
If you have any questions regarding this' response, please direct them to this office, i
Respectfully, x
i
.J.
vach t
L Nuclear Li nsing Manager
)
Enclosure a
cc: ' NRC' Document Control Desk C. Patel-NRR NRC Resident Inspector-Zion l
/scl:ID336:1 C(134 9010170125 900909 PDR ADOCK 05000295:
((4 / -
O PNV
l O
4 EHCLOSURE (XBOUNEALTN EDISON CENAIN'S RESPONSE TO VIOLATION l
[
NO. 295/90015-06; 304/90017-06 l
\\
VIOLATION:
i As a result of the inspection conducted during the period July 16 j
i l
through August 6, 1990, and in accordance with the " General Statement of Policy l
l and Procedure for NRC Enforcement Actions," 10 CFR Part 2,' Appendix C, (1989)
(Enforcement Policy) the following violation was identified:
Technical Specification 6.2.1 requires adherence to Zion Station.
I procedures.
Zion Station' Administrative Procedure, ZAP 5-51-15 High Radiation Area Access Control, requires that-high radiation access doors be closed and i
locked at all times unless a worker is posted outside the area to prohibit-unauthorized entries.
ZAP 5-51-15 also requires positive control over keys to l
1 locked high-radiation areas.
i Contrary to the above, during the period from December 7, 1989 to-i May 10, 1990, there were eleven incidents'in which access to high radiation i
areas was not controlled as required by ZAP 5-51-15.
Five of these incidents 1
involved the radwaste annex door ~.
a This is a Severity Level IV violation (Supplement IV).
t RESPONSE TO THE VIOLATION:
i Zion Station acknowledges this-violation.
l CoggECUVE ACTION TAKEN Als prun TS ACHIEVED
- The Radwaste Annex door mentioned.in the Notice Of Violation has been Upgraded with a stronger door closure mechanism and a'new latch. : These repairs should reduce the probability'of future incidents with this door, f
A blanket nuclear work request has'been issued to the Maintenance.
department to expedite-the necessary repairs to High Radiation Area (HRA) i doors. Previously, a nuclear work request was issued for each door. repair.
Radiation. Protection personnel; check all.HRA doors weekly and. submit requests for repair to the Maintenance department.
During the recent unit. outages a HRA." rover" was utilized on all i
shifts to assist in controlling access to HRAs and'to verify that these doors l
were closed.
Station personnel have been retrained'by their department supervision on the'HRA access procedure.
l L
1 1
' t.
./sc1:ID336:2
.,v r.,,
e,
e t.
O' s'k 2
A Zion Performance Improvement Plan (PIP #00505) was. developed on August l
e 31, 1990 to improve control of HRA's.
The following describes the actions of
.j PIP #00505 that have been completed:
The HRA's were previously controlled by a master R-key' lock system in I
which one key would fit every R-key lock., The master R-key locks were replaced on September 26, 1990 with room specific R-key locks.
This i
means each.of the HRA's has a unique lock and key.
This will-Increase accountability and limit access to individuals or groups which have been specifically approved access to one specific HRA.. Master keys are available, but.use.will be limited to special. situations' authorized by 1
the Radiation Protection Department such as emergencies, l
i The HRA access procedure ZAP 5-51-15 was' revised to incorporate the l
change to room specific R-key locks. This procedure change was completed by September 26. 1990.
i CORRECTIVE ACTION.TO.BE..TAKEN TO.PREVFAT_FURTHER. VIOLATION:
?
TheCorporateNuclearServicesRadiailonProtection'Departmenthas formed a committee to study HRA control.
The Zion Lead Health-Physicist-Operations /ALARA is a member of this-committee.
The committee will issue recommendations through Senior Corporate Managers to improve HRA access control (over and above that detailed above) by December 31, 1990.
Zion-station l
will develop additional PIP #00505 action steps by January'31, 1991 to comply t
with the recommendations of this committee.
Note: Although the following action-is unnecessary to prevent further i
violation, it is likely to improve control of HRAs by reducing the total number of doors / areas unnecessarily considered a HRA.
l Current Zion Technical Specifications require HRA controls that-differ from Standardized Technical Specifications.
Zion Station will submit a i
technical specification change to update the current Technical Specification to i
current industry practices by December 31,.1990.
tl DATE MEN FULL GBrLIAufT WILL BE= AdifEVED:
j Any additional actions to improve HRA. access control'and their schedule l
for completion will be summarized and communicated to the NRC by'
/
l February 8, 1991.
l ul l
/ sci:ID336:3 i
?
{
.