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Insp Repts 50-295/97-09 & 50-304/97-09 on 970324-0414. Violations Noted.Major Areas Inspected:Licensee Radiation Protection Program
	ML20148B783
Person / Time
Site:	Zion File:ZionSolutions icon.png
Issue date:	05/06/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20148B766	List: ML20148B763; ML20148B775; ML20148B783;
References
	50-295-97-09, 50-295-97-9, 50-304-97-09, 50-304-97-9, NUDOCS 9705130351
	Download: ML20148B783 (11)
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U. S. NUCLEAR REGULATORY COMiAISSION

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Docket Nos: 50-295; 50-304

l Licenses No: DPR-39; DPR-48

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Reports No: 50-295/97009(DRS); 50-304/97009(DRS) l

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Licensee: Commonwealth Edison Company (Comed)

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Facility: Zion Generating Station, Units 1 & 2

Location: 101 Shiloh Boulevard

Zion,IL 60099

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Dates: March 24 - April 14,1997

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Inspector: S. K. Orth, Radiation Specialist

Approved by: Thomas J. Kozak, Chief, Plant Support Branch 2

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Division of Reactor Safety

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i 9705130351 970506

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EXECUTIVE SUMMARY

Zion Generating Station, Units 1 & 2 1

NRC Inspection Report 50-295/97009: 50-304/97009

This inspection included an announced review of the radiation protection program. One

violation with three examples was identified concerning the failure to follow procedures. 1

(Sections R1.1 and R4.1).

Bapt Suonort

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Two examples of a violation for failure to adequately follow radiatiori protection !

procedures were identified. Control of contaminated area boundaries was poor. In ;

addition, problems concerning the posting of potential radiological hazards in the !

Auxiliary Building and Turbine Building were also identified. (Section R1.1)

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One Non-Cited violation was identified concerning the failure to maintain criticality l

alarm setpoints as required by 10 CFR 70.24(a)(2). Although this issue was

identified by the licensee and corrected, a problem was identified concerning the

licensee's operability evaluation. Corrective actions to resolve a discrepancy

between the licensee's Technical Specification basis and radiation monitor alarm

setpoints were not timely. (Section R2.1)

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An additional example of a violation was identified concerning the failure to follow

procedures for the survey of contaminated clothing containers. (Section R4)

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Report Details

! IV. Plant Suonort

R1 Radological Protection and Chemistry (RP&C) Controls

R1.1 Plant Radioloaical Conditions

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l a. insoection Scoon (83750)

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The inspector reviewed the radiological conditions of the plant. The inspector !

assessed the control of contamination boundaries, the posting of radiological '

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hazards, and the implementation of the following procedures:

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l ZRP 5010-1, " Radiological Posti'.g and Labeling Requirements," Revision 3, dated ,

l August 30,1996; and l

l ZRP 5721-6, " Construction of R adiological Posted Contaminated Areas and Step -

l Off Pad Areas," Revision 1, oated August 23,1994.

b. Observations and Findinas

The inspector identified several problems concerning the control of contamination I

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boundaries in the Auxiliary Building (AB) and the Turbine Building (TB). Procedure

ZRP 5721-6 requires that cords and hoses crossing contamination boundaries be

secured to prevent the spread of contamination. On March 24 - 26,1997, the ;

inspector identified unsecured cords and hoses crossing contaminated area (CA)

boundaries at the following locations: (1) AB 617' elevation at the exit from the

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Fuel Building; (2) AB 592' elevation at the barrel compacting area and waste

segregation area; (3) AB 579' elevation at the entrance to the crystallizer; (4) AB

560' elevation near the laundry drain tanks; (5) AB 542' elevation at the

mechanical maintenance department cage; and (6) TB Unit 1 steam tunnel in the

Unit 1 west valve house.

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Techr.ical Specification (TS) 6.2.2.A requires, in part, that radiation control

procedures be prepared and implemented, which are consistent with the

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requirements of 10 CFR 20. The failure to properly secure cords and hoses

l crossing contamination boundaries in accordance with ZRP 5721-6 is a violation of .

TS 6.2.2.A (50-295/97009-01a; 50-304/97009-01a).

The inspector also identified problems concerning the construction of several

containment devices used to contain radioactively contaminated leaks. Procedure

ZRP 5010-1 requires that the tygon tubes associated with yellow containments

have radiation tape or radioactive material markings to identify the tubing as t

containing radioactively contaminated liquids. On March 25,1997, the inspector

identified several yellow containments having tygon tubing which was not properly

marked in the following areas: (1) AB 592' elevation near the penetration air

i receiver 1B; (2) AB 560' elevation near the evaporator monitor demineralizer OB,

near the component cooling water pump OA, and outside of the instrument i

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l maintenance hot shop; and (3) AB 542' elevation near the blowdown monitor tank

pump 08.

TS 6.2.2.A requires, in part, that radiation control procedures be prepared and

implemented, which are consistent with the requirements of 10 CFR 20. The

failure to properly identify tygon tubing from yellow containment devices with

radiation tape or radioactive material markings in accordance with ZRP 5710-1 is a

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violation of TS 6.2.2.A (50-295/97009-01b; 50-304/97009-01b). '!

On March 24 and March 26,1997, the inspector also identified problems

j concerning the use of radiological postings. On the 592' elevation of the AB, the l

!- inspector identified that an area posted as an radiation area (RA) did not have

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consistent radiological postings. At one section of the boundary, the posting did

not indicate that the affected area was a RA: the posting only denoted a CA. In the )

l steam tunnel of the TB, the inspector also identified that the ropa used as a CA

l boundary had fallen and that the posting had been obscured, rendering the area

l partially unposted and unbound. Although the licensee had posted these areas as a

precautionary measuie (i.e., the actual radiological conditions did not meet the

[ levels specified in ZRP 5010-1 for a RA or CA, respectively), the licensee did not

provide clear identification of the bounded areas.

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The licensee corrected the problems identified by the inspector and directed a

radiation protection technician (RPT) to conduct a thorough review of all posted

areas in the plant,

c. Conclusions

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l Two examples of a violation for failure to adequately follow RP procedures were

identified concerning the control of contaminated area boundaries and identification

of radiological hazards. In addition, problems concerning the posting of potential

radiological hazards in the AB and TB were also identified.

R2 Status of RP&C Facilities and Equipment

R2.1 Area and Process Radiation Monitors

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a. Insoection Scone (84750)

l The inspector reviewed the status of the liquid and gaseous radiation monitoring

system (RMS). The inspector reviewed the performance trends concerning

operability of monitors and adequacy of monitor setpoints, including problem

identification forms (PlFs) originated in the previous 12 months.

b. Observations and Findinas

The licensee's RMS monitors gaseous and liquid effluents and area radiation levels,

as specified in the licensee's TS, Updated Final Safety Analysis Report (UFSAR),

and Offsite Dose Calculation Manual (ODCM). Liquid radiation monitors were

[ designed as self-contained monitors used to measure radioactivity levels in liquid

l process and effluent streams and consist of either scintillation or Geiger-Mueller

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(GM) detectors. Airborne effluent monitors were designed to detect a certain !

!- combinations of radioactive species (i.e., noble gases, particulate radioactive '

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materials, and radioiodines). For the purposes of postulated accident assessment, '

high-range airbome effluent monitors, consistent with Regulatory Guide 1.97

" Instrumentation For Light-Water-Cooled Nuclear Power Plants To Assess Plant and '

Environs Conditions During and Following An Accident," were designed to be

capable of measuring noble gases released through the Unit 1 and 2 AB vents. The '

radiation monitors on the AB vents have a range of 1E-7 microCuries per cubic

centimeter (uCi/cc) to 1E+ 5 uCi/cc. For a similar accident assessment purpose as

the AB vent monitors, the steam generator atmospheric release path monitors have

a range of 1E-1 to 1E+ 5 milliroentgen /hr, which may be converted to a release in

uCi/cc based on steam flow.

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lL On August 9,1996, the licensee determined that the alarm setpoints for criticality !

i accident radiation monitors in the Fuel Building (OR-AP03 and OR-0005) did not

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meet the rewirements of 10 CFR 70.24(a)(2). In 1980 and 1983, the setpoints for ,

OR-0005 and OR AR03 had been changed from 20 mrem /hr to 100 and

30 mrern/hr, respectively, to accommodate the storage or radioactive materials in

the area. However, the setpoints had not been reset when the materials were

removed from the area.10 CFR 70.24(a)(2) requires a monitoring system be

capable of detecting a criticality which generates radiation levels of 300 rem /hr at

1 foot from the source and be set at an alarm level between 5 and 20 mram/hr. On '

August 16,1996, the licensee initiated a work request to reset the alarm points to

within the levels required by 10 CFR 70.24(a)(2), which was completed and tested

on September 9,1996. The licensee's evaluation of the problem identified

potential programmatic issues concerning alarm setpoints which were planned to be

evaluated and resolved.

The failure to have setpoints between 5 and 20 mrem /hr for radiation monitors OR-

AR03 and OR-0005 is a violation of 10 CFR 70.24(a)(2). However, this licensee !

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identified and corrected violation is being treated as a Non-Cited Violation,

consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-295/97009-02;

50-304/97009-02).

The inspector identified that the licensee did not adequately assess the operability

of the monitors. Although the alarm setpoint of the monitors was incorrect, the

licensee considerert the monitors operable, i.e., the monitors would trip at a value

above the preset st;tpoint. On April 14,1997, the inspector discussed the ist.ue

with licensee personnel and indicated that the failure to have the correct alarcn

setpoint had affected the monitors' ability to meet their design function as r9 quired

by 10 CFR 70.24(a)(2), i.e., detect and wam of a criticality event and, therefore,

had rendered the monitors inoperable. The inspector discussed this with the HP

supervisor, who indicated that he planned to ensure that licensee management

further evaluated the question of monitor operability.

On October 3,1996, the licensee also identified a problem concerning the alarm

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setpoints for Unit 1 and 2 steam jet air ejector (SJAE) radiation monitors and the

l Unit 1 and 2. steam generator (SG) blowdown radiation monitors. The bases for

l TS 4.18 indicates that the monitors will have an alarm setpoint of 1E-5 uCi/cc to

l identify when the surveillance in TS 4.18 need be commenced. When the

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secondary iodine concentrations exceed 25 percent of the limits specified in

l- ' TS 3.18 (i.e., 5.48 Ci of lodine-131 per SG), TS 4.18 requires that the licensee

obtain wookly samples from the air ejector. Even though the iodine levels in the

i SGs were well below 25 percent of the TS limit, the licensee routinely performed

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weekly isotopic analyses of the SJAE as directed by chemistry procedure

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ZCP 921-3, " Primary to Secondary Leak Rate Determination," . Revision 5. During

the investigation, the licensee determined that an alarm setpoint of 1E-5 uCi/cc for

the radiation monitors would be indistinguishable from the background radiation

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levels and monitor fluctuations and would result in spurious, inconsequential

alarms. At the time of the inspection, the monitor biarm setpoints were about 5 to

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20 times higher than those in the TS basis but were sufficient to provide early

l indication of primary-to-secondary leakage and were commensurate with the

j methodology of the ODCM. At the time of this inspection, the licensee had not

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i taken actions to correct the discrepancy between the TS basis and the radiation

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monitor alarm setpoints. Since the licensee planned to implement improved TS

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basis. The licensee acknowledged the lack of timely resolution of the discrepancy

i and planned to ensure that either the basis was revised or the improved TS were

j implemented in the immediate future. The resolution will be reviewed in

i subsequent inspections (50-295/97009-03; 50-304/97009-03).

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l c. Conclusions

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i One Non-Cited violation was identified concerning the failure to maintain criticality I

i alarm setpoints as required by 10 CFR 70.24(a)(2). Although this issue was

identified by the licensee and corrected, a problem was identified concerning the

j licensee's operability evaluation. Corrective actions to resolve a discrepancy

between the licensee's TS basis and radiation monitor alarm setpoints were not

timely.

R4 Staff Knowledge and Performance in RP&C

On March 25,1997, the inspector observed licensee personnel removing protective

l clothing (PC) collection bags from a CA exit from the Fuel Building (FB). Temporary i

Change TA-96-489 (dated August 20,1996) to procedure ZRP 5721-5, i

! " Collecting, Laundering, Surveying, and Reissue Protective Clothing," Revision 1,

l dated January 12,1994, requires that personnel removing PC containers from a job

] site use a calibrated survey instrument to survey each bag of contaminated

j clothing. If the bag has a contact dose rate of less than 10 mrem /hr, the procedure

then directs personnel to transfer the clothing to a shipping container. If the dose

i rate exceeds 10 mrem /hr, the procedure requires that RP personnel be immediately

l notified. The inspector observed that the individual did not have a survey

l instrument and, thus, did not perform a survey prior to transferring the clothing to a

j shipping container. The individual indicated that he felt a survey was only

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necessary once the shipping container was loaded. The inspector discussed the

! event with RP management who indicated that the individual's actions were

unacceptable, counseled the individuel, and provided additional training and

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discussion with the entire work crew. In addition, the licensee performed a survey

of all clothing bags within the transport container and did not identify any bags

having a contact dose rate greater than 10 mrem /hr.

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TS 6.2.2.A requires, in part, that radiation control procedures be prepared and

implemented, which are consistent with the requirements of 10 CFR 20. The

failure to conduct a radiological survey of each bag of protective clothing removed

from a work area in accordance with ZRP 5721-5 is a violation (50-295/97009-

01c: 50-304/97009-01c).

R6 Quality Assurance in RP&C Activities

The inspector assessed the effectiveness of the licensee's identification and

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resolution of RP problems. Specifically, the inspector reviewed the licensee's

Problem identification Form (PIF) database for the previous 12 months, reviewed

the licensee's corrective actions for PIFs, and reviewed the RP department's

evaluation and trending of common problems. The licensee had documented

several PIFs related to RP and the RMS. The inspector reviewed the licensee's .

corrective actions for a selection of PlFs and found them to be adequate, with the

exception of the PIFs concerning the RMS (Section R2.1). However, the inspector

noted that the PlFs did not always provide detailed descriptions of corrective

actions. The RP staff had begun trending PlFs to better identify more significant

problems. The inspector concluded that the PlF system was adequately used to

document radiological problems; however, some weaknesses were identified

concerning the resolution of PIFs and the documentation of corrective actions.

R8 Miscellaneous RP&C lasues

R8.1 (Onen) Violation 50-295/96006-11: 50-304/96006-11: The licensee failed to

properly post a radiation area in accordance with 10 CFR 20.1902(a). As

corrective actions, the licensee communicated the incidents to members of the RP

staff. In addition, the licensee implemented two additional measures to prevent

recurrence: (1) daily posting verifications were impiamented and (2) RP Standing

Order No. 96-07 was issued requiring that ail posting placements and changes be

verified by a second RPT or RP supervisor. The licensee indicated that they had

been performing the verifications and reviews but had not documented the

verifications and had not assessed the effectiveness of the actions. Based on the

problems concerning postings and control of boundaries identified by the inspector

(Section R1.1), the licensee's corrective actions did not appear to be effective. .The

licensee planned to expand the above corrective actions and ensure that

management expectations regarding the corrective actions was well understood by

the RP staff. The results of the licensee's actions will be reviewed in future NRC

inspections.

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R8.2 (Closed) Violation 50-295/96008-09: 50-295/96008-09: Chemistry technicians

(cts) failed to perform a contamination survey when removing items from the

primary sample room (a posted, CA) as required by station RP procedures. The

inspector verified that the licensee had implemented its planned corrective actions. ]

The inspector noted that chemistry procedure ZCP 600-1, " General Sampling i

Procedure," was revised on September 22,1996 to include direction for properly

removing samples from CAs. The inspector reviewed a CT performing routine

sampling in the primary sample room and observed the CT removing items from the

room as instructed by licensee procedures. The CT contained the items in a plastic

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bag, then transported them to the chemistry laboratory for required contamination

surveys. This item is closed.

R8.3 (Closed) Followuo item 50-295/96016-01: 50-304/96016-01: The licensee

planned to upgrade its analytical equipment by January 1997 to fully meet the

environmental lower limit of detection (LLD) for the unconditional release of liquids.

The licensee received its upgraded detector in October of 1996; however, the .

licensee had operation difficulties with the new equipment. The licensee returned I

l the equipment to the vendor and suspended the survey of liquids for free release

l from the station. While the detector was out of service, the licensee utilized other. ;

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facilities detectors to release liquids. On March 18,1997, the licensee received a

new detector that satisfied the licensee's performance requirements. On March 24,

1997, the licensee calibrated the detector and placed it into service. The inspector

reviewed the LLD for the licensee's liquid geometry and observed that the LLD was

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consistent with the environmental LLD for liquids. This item is closed.

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l V. Manaaement Meetinas

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X1 Exit Meeting Summary

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On March 27,1997, the inspector presented the inspection results to licensee

management. On April 14,1997, the inspector conducted additional discussions with

! Mr. W. Strodl to discuss the findings documented in Section R2.1. The licensee 1

acknowledged the findings presented. l

The inspectors asked the licensee whether any materials examined during the inspection-

l should be considered proprietary. No proprietary information was identified. i

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PARTIAL LIST OF PERSONS CONTACTED

, C. Allen, Regulatory Assurance

D. Beutel, Regulatory Assurance

B. Giffin, Engineering

R. Godley, Regulatory Assurance

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R. Laburn, Health Physics

J. Lewis, Radiation Protection improvement Manager

F. Rescek, Corporate Health Physics Director

R. Starkey, Plant General Manager

W. Stone, Regulatory Assurance

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W. Strodi, Health Physics Supervisor

INSPECTION PROCEDURES USED

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IP 83750: Occupational Radiation Exposure

IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring j

IP 92904: Follow-up - Plant Support

ITEMS OPENED, CLOSED, AND DISCUSSED

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50-295/304-97009-01(a-c) VIO Failure to adequately implement procedures.

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50-295/304-97009-03 IFl Resolution of inconsistencies between the basis

for Technical Specification 4.18 and plant

conditions.

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CLOSED

50-295/304-96008-09 VIO Failure to follow procedures in removing

chemistry samples from contaminated areas.

, 50-295/304-96016-01 IFl Use of environmental LLD for unconditional

release of liquids.

50-295/304-97009-02 NCV Failure to meet 10 CFR 70.24(a)(2).

DISCUSSED

50-295/304-96006-11 VIO Failure to post a radiation area in accordance

with 10 CFR 20.

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LIST OF ACRONYMS USED

AB Auxiliary Building

ALARA As-Low-As-is-Rea s ona bly-Achie va ble

CA Contaminated Area

CFR Code of Federal Regulations

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CT Chemistry Technician

FB Fuel Building

IFl Inspection Follow-up Item

LLD Lower Limit of Detection

MREM /HR Millirem per Hour

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ODCM Off-site Dose Calculation Manual

OOS Out of-Service

NCV Non-Cited Violation '

PC Protective Clothing

PlF Problem identification Form

RMS Radiation Monitoring System

RP Radiation Protection

RPA Radiologically Posted Area

RPT Radiation Protection Technician

RP&C Radiation Protection and Chemistry

RWP Radiation Work Permit

SG Steam Generator

SJAE Steam Jet Air Ejector

TS Technical Specification

UCl/CC Microcuries Per Cubic Centimeter

UFSAR Updated Final Safety Analysis Report

VIO Violation

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PARTIAL LIST OF DOCUMENTS REVIEWED

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Problem identification Forms (PlF) Nos. 96-1801, 96-3037, 96-3637, 96-3911, 96-3933,

96 4150,96-4488, and 96-4620.

Radiation Protection Standing Order No. 96-07, "Second Verification of All Posting

Changes," dated June 5,1997.

Zion Administrative Procedure (ZAP) 620-05, Revision 6, " Unconditional Release of Liquids

from the RPA"

Zion Radiation Protection Procedure (ZRP) ZRP 5710-2, Revision 2, " Control of Materials

for Conditional or Unconditional Release for Radiologically Posted Areas"

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ZRP 5821-50, Revision 1, " Documentation and Control of Radiation Monitor Setpoints"

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ML20148B783

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