ML20128C339

Responds to NRC Re Violations Noted in Insp Rept 50-295/92-34 & 50-304/92-34.Corrective Actions:Instructional Video Tape Being Produced on Personnel Procedures for High Radiation Access Control & Containment Access Control

ML20128C339
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/28/1993
From:	Farrar D COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302030395
Download: ML20128C339 (3)

Text

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• ' Commenwealth Edison A,a 1400 Opus Place Downers Grove, Illinois 60515 January 28,1992 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Attn: Document Control Desk

Subject:

Zion Nuclear Power Station Unit 1 and 2 Response to inspection Report 50-295(304)/92034 NRC DocketNumber 50-295_a0_d1040_4

Reference:

Cynthia Pederson letter to Cordell Reed dated December 29,1992, transmitting Inspection Report 50-295(304)/92034.

Enclosed is Commonwealth Edison Company's (CECO) response to the subject violation which was transmitted with the referenced letter.

The violation concerns f ailure of an Operator to review, sign and comply with a radiation work permit prior to entering into a temporary high radiation area.

If there are any questions or comments regarding th's response, please contact Sara Reece Koenig, Compliance Engineer, at 708/515-7250.

Very truly yours, g

D. Farrar Nuclear Regulatory Services Manager Attachments cc: A. Bert Dav!s, Regional Administrator - Region 111 Clyae Shiraki, Project Manager, NRR J. D. Smith, Senior Resident inspector, Zion 010049 -

9302030395 930128 A gDR ADOCK 030o 5 Vj ZNLD/2482/1 l\

. AUACHMENI REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT _

295/92034;304/92034 i

ylOLATLQN; Technical Specification 6.2.2 requirec that radiation control procedures be prepared, implemented and maintained.

Zion Administrative Procedure, ZAP 610-02, High Radiation Area Access Control, requires personnel to review, sign and comply with the appropriate -l radiation work permit prior to entering a high radiation area. )

Contrary to the above, on December 9,1992, an Operator failed to review, sign and comply with the appropriate radiation work permit prior to~ entering a high radiation area in which radiography was about to commence.

d This is a Severity Level IV violation (Supplement IV), _

l ElEASON.EQELIHE VIOLATION Commonwealth Edison Company (CECO) acknowledges the violation.- On L December 9,1992, an operator read and signed Radiation Work Permit (RWP) 92-0006-0 which covered routine operator rounds. Entry into high . ,

radiation areas typically encountered during normal rounds was allowed by

this RWP.

While performing his rounds on the 579' level of theA' uxiliary Buildin , the operator encountered a waist high rope barrier with a sign stating "H h l Radiation Area, Radiography in Progress, Exclusion Area, Do Not E er". The operator did not heed the posting and rope barrier. He believed erroneously that he could enter the area based on his previous experience that there was ~

! nothing in that area of the building that would cause a high radiation area to exist.

This event occurred as a result of this individual operator's inadequate understanding of the significance of temporarily posted High Radiation Areas and the radiological conditions which can be present during radiography. Zion .

Administrative Procedure, ZAP 600-03, Radiation Work Permit Program, requires a RWP to be prepared for radiography operations. RWP 92-2295-0 was prepared for radiography of the Unit 2 Auxiliary Feedwater Pum as. The operator had.not read or signed this RWF' and therefore was not aut aorized to enter the area in which radiography was taking place.

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- AIIACHMENI-REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT 295/92034;304/92034 (continued)

1 CORRECTIVE ACTION _TAKEN AND.RESULTS_ ACHIEVED The radiographer immediately halted operations upon discovery of the _-

operator in the exclusion area. He then notified Radiation Protection -

department personnel assisting with the radiography operation of the incident.

The Radiation Protection department reviewed the incident with the operator and his supervisor to ensure a clear understanding of the violation of station radiation protection practices and procedures. ,

The operator had successfully completed annual Nuclear General Employe o Requalification training in February of 1992, included in this training were the topics of Radiation Work Permits and High Radiation Area Controls. A review of the training showed it to be adequate in the topic areas discussed.

A Lessons Learned initial Notification (LLIN 92-188) was issued on December 18,'1992. This notification was sent to all other CECO Nuclear Stations to -

- share information on this event.

An article was printed in the Zion Station daily newsletter to heighten the awareness of station personnel to the potential hazards of radio the proper procedures to follow regarding radiography postings. graphy and The operator received appropriate disciplinary action.

COBBEGIIVE.ACIJOfLIOJE TAKEN IQAV_QlR_EUBIHERMOLATION To enhance training on High Radiation Controls, Zion Station is producing an instructional video tape on personnel procedures for High Radiation Access Control, Containment Access Control, and Radiography. The tape will be incorporated into Zion Nuclear General Employe Training classes no later than July 1,1993.

DATEEHEN_EULLCOMELIANCE.WILL.BEACHIEVED Zion Station was in full compliance on December 9,1992, upon completion of the Radiation Protection department review of the' event with the operator.

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