ML20126J234
| ML20126J234 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/29/1992 |
| From: | Kozak T, Louden P, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20126J206 | List: |
| References | |
| 50-295-92-34, 50-304-92-34, NUDOCS 9301060091 | |
| Download: ML20126J234 (7) | |
See also: IR 05000295/1992034
Text
{{#Wiki_filter:!
O.S. NUCLEAR REGULATORY COMMISSION ' REGION 111 Reports No. 50-295/92034(DRSS); 50-304/92034(DRSS) Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Opus West til 1400 Opus Place Downers Grove, IL 60515 Facility Name: Zion Nuclear Generating Station, Units I and 2 Inspection At: Zion Station, Zion, Illinois Inspection Conducted: December 7 through 11, 1992 Inspectors: d / 8 '/ M " ~P. L. Louden Date / Radiation Specialist t r.[s /5y T. J. Koiak Date Senior Radiation Specialist dbCOO R[[liam Snell, Chief Diite/just Approved By: g fl Radiological Controls Section 2 Insoection Summarv - Inspection on December 7 throuah 11. 1992 (Recort Nos. 50-295/92034(DRSS): 50-304/92034(DRSS)) Areas Inspected: Routine announced inspection of the licensee's radiation protection (RP) program during a refueling outage (Inspection Procedures (IPs) 83750 and 83729).. Specific areas reviewed included outage planning and scheduling, internal exposure controls, external exposure controls, contamination controls, and maintaining exposures as low as reasonably- achievable (ALARA). Aaditionally, the inspection included a review of ' previously identified inspection findings'and corrective actions to such- findings, and observations based on tours of the radiologically controlled area (RCA). l 9301060091 921229 PDR ADOCK 05000295 G PDR
_ _ --____ -_____ -_ _ -___ ___ _ _____ _ ___ _ - ___ _-_______________ - _ _ __-___ _ __ _ _ _ ___ _ -__ __ _ __ se L i Reallu One violation was identified during the courso of the inspection for ' failure to follow radiation protection procedures by an operator who.made an unauthorized entry into a posted high radiation area that was being controlled for radiography (Violation 295/92034-01). Exposure goals for higher dose jobs ', for the Unit 2 refueling outage were on track with pre-outage estimates and improvements were noted with the planning and scheduling department. i f \\ F $ i 9' i k ! I 2 f- ,..g.. ,-w-. e w.w.- , r
_ - _ _ _ _ - - _ - - _ _ _ ___ __-______ __ _ - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . .,
/ DETAILS , 1. Etn2ns Contacted Commonwealth Edisoa
- D. Bump, Supervisor, Quality Verification
- R. Boyce, Radiation Protection staff
- .
- K. Dickerson, Regulatory Assurance
'
- G. Kassner, Operational Lead Health Physicist
- W. Kurth, Superintendent, Production Services
- R. Pratt, lead Radiation Protection Supervisor
- B. Rendall, Station Training Department
- W. Stone, Diru tor, Performance Improvement
The inspectors also interviewed other licensee personnel in various departments in the course of the inspection. Nuclear Reaulatory Commission -
- J. Smith, Senior Resident inspector
'
- Denotes those present at the Exit Meeting on December 11, 1992,
2. Licensee Action on Previous inspection findinas (IP 83750) (Closed) Open Item (50-295/92007-02(DRSS)): Inconsistencies in hot spot posting program. This item specifically concerned observed discrepancies between hot spot postings in_the auxiliary building and those posted in the Unit 1 containment during the spring 1992 refueling. ' outage. Through direct observations and discussions with licensee staff, several improvements were noted in the methodology csed for the current Unit 2 refueling outage and prior inspector concerns appeared to be resolved. This item is closed. , No violations of NRC requirements were identified. 3. Contamination Control proaram flP 83750) The inspectors reviewed the licensee's program for contamination control and initiativ6s implemented during the current Unit 2 outage. During previous outages, a common containment entry and exit point was used. In an attempt to reduce the: number of personnel contamination events (PCEs), the station modified its containment access point to provide separate entry and exit paths which has reduced the possibility of cross contaminations and )rovided more room for workers to remove protective clothing (PC). Tie Radiation Protection (RP) department also developed a video tape illustrating proper.PC removal techniques and providing examples of improper methods and their possible consequences. The videos are continuously played at the main contractor and station 3 . , ._ . _.
. _ _ _ _ _ . . _ _ _ . . _ - _ _ . _ _ _ _ _ . _ - - _ _ _ _ . _ _ _ _ _ _ . - _ _ _. , " , i .. employee dressing areas and at the step off pad coming from the Unit 2 . ' containment. The inspectors observed several workers exiting i containment and noted that good contamination control practices were used by virtually every worker, and noted that their undressing methods were consistent with what was presented on the video. ) i At the time of the inspection, the station had recorded 435 PCEs for 1992. The licensee averaged about three PCEs per day during the spring Unit 1 outage, contrasted by a PCE average rate of one to one and one- ! half per day during the current outage. This indicates that the initiatives implemented to reduce too number of PCEs are working. The inspectors informed the licensee that while there has been a downward trend in the number of PCEs, their performance in this area would continue to be reviewed and tracked under inspection followup Item (Ifl No. 295/92007-01; 304/92007-01). No violations of NRC requirements were identified. 4. Outage Plannina and Schedulina (IP 83750 and 83729) As detailed in a previous inspection report (IR 50-295/92028;50- 304/92028), the station had taken many actions to improve outage planning and scheduling problems encountered during the spring 1992 Unit 1 outage. The inspectors discussed with licensee management the current performance of the )lanning and scheduling department for the current outage. Even thoug1 some inconsistencies in the schedule were noted, the overall performance of the new programs appeared to be an improvement from prior outages. The daily planning meetings attended by the inspectors were well organized. Responsible individuals for each department provided updates of ongoing work and new work items were delegated with due dates associated with the assignments. The inspectors determined that at this point in the outage, the actions taken to improve the planning and scheduling of outage activities appeared to be effective. No violations of NRC requirements were identified. - 5. Internal Exnosure Controls (IP B3750) The inspectors reviewed the results of individuals who had been assessed to determine whether they had received an intake of radioactive materials and noted no problems. The inspectors observed several workers in containment wearing respiratory protection while performing their assigned tasks, and noted that all individuals observed appeared to be properly donning, wearing, and removing their respiratory protection equipment. No violations of NRC requirements were identified. 4 i , , - - . . , - --_-.----,n-------- ,-----,-,n---,,-,. - , - , _ ...-,,.,--,-------.,,--c,
___ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _ - - _ - - _ _ __ _ ___ __ _ ________-_-__-__- , .,
4 6. lxifrnal Exposure Controls flP 83729) l The inspectors reviewed selected Radiation Work Permits (RWPs) for a>propriateness of radiation protection requirements and to ensure that t1ey received supervisory review. No problems were identified. > The station has changed their RWP format in an attempt to better convey 3 relevant information to the workers. Titles, electronic dosimeter alarm settings, and job locations were boldly printed and PC requirements were , presented in terms of a dress class. Specific dress requirements t represented by various classes were itemired at the PC supply area. The inspectors noted that the overall RWP layout and the use of dress classes with associated informational signs were improvements over the old RWP format. Discussions with both station personnel and contractors indicated that the new RWP format and dress classes were easier to read and understand. The inspectors reviewed the circumstances surrounding an unauthorized entry by an operator into an area which was temporarily posted as a high radiation area in anticipation of radiography. The operator had read and signed RWP 92-0006-0 which covered routine operator rounds. Entry into high radiation areas typically encountered during normal rounds was allowed by this RWP. He was performing his rounds in the-auxiliary building when, on the 579 level, he encountered a rope barrier with a
sign on which was written, *High Radiation Area, Radiography in Progress, Exclusi::n Area, Do Not Enter". The operator was not aware of the radiological conditions which are present during radiography and was under the impression that he could enter the area. He decided to enter the area and seek radiation protection personnel to find out what had changed in the area and if he could continue his rounds. At this time, the radiographer had just completed setting up his equipment and was doing a final boundary check prior to exposing the source. He encountered the operator and allowed him to obtain the few readings he needed and then notified station radiation protection personnel about ' the incident. - Zion Technical Specification 6.2.2 requires that radiation control procedures be prepared, implemented and maintained. Zion Administrative Procedure 610-02, High Radiation Area Access Control, requires personnel to review, sign, and comply with the appropriate radiation work permit prior to entry into a high radiation area. Zion Administrative Procedure 600-03, Radiation Work Permit Program, requires an RWP to be prepared for radiography operations. RWP 92-2295-0 was prepared for radiography of the Unit 2 auxiliary _feedwater pumps. The operator had not read or signed this RWP and therefore was not authorized to enter the area in which radiography was taking place, further, the operator was not aware of the radiological conditions present in areas near.to a radiography source. This-is a violation of Technical Specification 6.2.2 (Violation 295/92034-01). One violation of NRC requirements was identified. No deviations were identifled. 5 . ,. . , , , , , . - ,, -,w%p._., 3 - - . , _e_.-.wy%. ,. y --.-w .m.w, mvm eu.~-.w w, ,-- y,- -..-..#--+ ,#-.-,w.-,%. ,,,-...+.,,-.--# ,-,,,,y
_ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _. .__ _ ___ - _ _ _ _ _ - . . , ! 7. MaintainingAgnational Exposures ALARA (if_SJ1U11 The inspectors reviewed ALARA initiatives for the outage, and reviewed the performance of higher dose jobs against their respective pre-outage estimates. The station once again performed early boration while shutting down the reactor. The procedure appeared to be successful as indicated by good chemistry control trends and overall dose rates for many areas within containment being about twenty-five percent less than in previous Unit 2 outages. Steam generator tube sheet and center-line channel head dose rates were significantly lower than in previous Unit 2 outages. Current dose rates for steam generators were between 2.5 and 6 R/hr in contrast to dose rates during the previous octages being 9 to 15 R/hr. One improvement of note was the development and use of a containment for the eddy current probe pusher. This containment has been effective in reducing the spread of contamination into the steam generator work area. Based on interviews with cognizant licensee staff, exposures for higher dose jobs were trending as planned for this stage of the outage. Exposure goals for higher dose jobs were as follows: Steam Generators: 88 person-rem Misc. Valves: 59 person-rem , Inservice inspection: 55 person-rem i Reactor llead: 49 person-rem The inspectors noted that a significant contributor to exposures meeting goals was the assigning of responsible individuals to follow job exposures daily and review these exposures against the percentage of work completed. The RP department has also established set points which flag jobs which may be deviating from anticipated exposures. The current flag points are at 50 and 80 percent of the established exposure goal for a specific job. - No violations of NRC requirer.ents were identified. , 8. Auxiliary Buildinn and Containment Tours The inspectors performed several tours of the auxiliary building and the Unit 2 containment. The inspectors noted that all monitoring instrumentation was in good working order and in current calibration. All. minor concerns identified by the inspectors were promptly corrected by on shift RP foremen. The inspectors noted that information hot spot posting in containment had improved significantly from earlier outages.- Workers observed in containment were following good RP 3ractices and were observed being queried by radiation protection tecinicians as to where they were working and if they were cognizant of their current dose. 6
.. No violations of NRC requirements were identified.
9. 12it Meetino lhe scope and findings of the inspection were discussed with licensee representatives (Section 1) at the conclusion of the inspection on December 11, 1992. Specific items discussed during the exit meeting are summarized below. Licensee representatives did not identify any documents or processes reviewed during the inspection as proprietary, t The violation involving an operator crossing a high radiation area
boundary which was being controlled under a job specific RWP for radiography. The improved hot spot posting program, especially those areas within
containment. The good performance in the outage with respect to doses meeting
estimated goals. 1 P* 7 .- - w -M+r
- g
m }}