ML20198T515
| ML20198T515 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/21/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Kingsley O COMMONWEALTH EDISON CO. |
| References | |
| 50-295-97-26, 50-304-97-26, NUDOCS 9801270079 | |
| Download: ML20198T515 (2) | |
See also: IR 05000295/1997026
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January 21, 1998-
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Mr. Oliver D. Kingsley
. President, Nuclear Generation Group
Commonwealth Edison Company -
ATTN: Regulatory Services
Executive Towers West lil
1400 Opus Place, Suite 500
Downers Grove, IL 60515
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-295/97026(DRS);
50-304/97026(DRS))
Dear Mr. Kingsley:
.
,
This will acknowledge receipt of your letter dated December 22,1997, in response to our
letter dated December 5,1997, transmitting a Notice of Violation associated with the failure to
adequately control access to a high radiation area at the Zion Generating Station, Units 1 and 2.
In your letter, you acknowledged that this violation resulted from ineffective implementation of
corrective actions for previous violations and personnel error. In addition, you described the
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additional controls that your staff has implemonted to prevent future high radiation area conuol
violations. We have reviewed your corrective actions and have no further questions at this time.
These corrective actions will be examined during future inspections.
Sincerely,
original Signed By J. A. Grobe
John A. Grobe, Director
Division of Reactor Safety-
Docket Nos, 50-295; 50 304
Enclosure:
Ltr dtd 12/22/97 O. D. Kingsley
Zion to USNRC
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cc w/o encl:
M. Wallace, Senior Vice President,
Corporate Services
H. G. Stanley, Vice President,
PWR Operations
J. Perry, Vice President,
BWR Operations
Liaison Officer, NOC-BOD
D. A. Sager, Vice President,
Generation Support
D. Farrar, Nuclear Regulatory
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Services Manager
l. Johnson, Licensing Operations Manager
Document Control Desk - Licensing
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R. Starkey, Plant General Manager
R. Godley, Regulatory Assurance
Supervisor
cc w/ encl:
Richard Hubbard
Nathan Schloss, Economist,
Office of the Attomey General
Mayor, City of Zion
State Liaison Officer
State Liaison Officer, Wisconsin
Chairman, Illinois Commerce Commission
Distribution
Docket File w/enci
Rlli PRR w/enci
Rlil Enf. Coordinator w/enci
PUBLICjiiidtw/ encl
SRI, Zion w/enci
TSS w/enci
LPM, NRR w/enci
J. L. Caldwell, Rlli w/enci
R. A. Capra, NRR w/enci
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A. B. Beach, Rlli w/enci
DOCDESK w/enci
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G. E. Grant, Rlll w/ encl
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ZRA97079
December 22,1997
U. S. Nuclear Regulatory Commission
Washington, D.C. 20555
Attention:
Document Control Desk
Subject:
REPLY TO A NOTICE OF VIOLATION
NRC Inspection Report No. 50-295/304-97026(DRS);
Zion Generating Station, Units 1 & 2;
NRC Docket Numbers 50-295 & 50-304
Reference:
Letter to J. Brons (Comed) from G. E. Grant (USNRC), dated
December 5,1997, NRC Routine Radiation Protection
Inspection Report ',0-295/304-97026(DRS) and Notice of Violation
Gentlemen:
By letter dated December 5,1997, the NRC cited Commonwealth Edison (Comed) as being in
Violation of regulatory requirements. This letter and its attachments constitute Comed's reply to
the referenced Notice of Violation in accordance with applicable regulations. Attachment A to
this letter provides the reasons for the violation, the corrective actions taken, and a statement of
full compliance.- 4ttaciunent B to this letter identifies all commitments made by Zion Station in
this response.
Should you have any questions concerning this response, please contact Robert Godley, Zion
Station Regulatory Assurance Manager, at (847)746-2084, extension 2900.
Sincerely,
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hn C. Brons
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ite Vice President
, Zion Generating Station
Attaciunents
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Regional Administrator, USNRC - Region III
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Senior Project Manager, USNRC - NRR Project Directorate III-2
NRC Senior Resident Inspector, Zion Generating Station
Office of Nuclear Facility Safety - IDNS
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DEC I 1
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ATTACHMENT A to ZRA97079
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IR 50 295/304 97026(DRS)
PageIof3
A'ITACHMENT A
REPLY TO NOTICE OF VIOLATION IN NRC
INSPECTION REPORT 50-295/97026(DRS); 50-304/97026(DRS)
VIOLATION 1 (50-295/304-97026-Olh
TechnicalSpec:fication 6.2.2.B requires areas accessible to persorinel with radiation
levels greater than 1000 millirem per hour (millirem!hr) at 30 cmfrom the radiation
source orfrom any surface which the radiation penetrations shall have locked doors to
prevent unauthorized entry.
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Procedure ZAP 610-2 "fligh Radiation Area Access Control," revision 5, requires that
entrances to accessible h gh radiation areas, with radiation levels greater than 1000
millirem /hr, be locked or be controlled by a key custodian who has direct oversight of
andpositive control over each personnel entry into the area.
Contrary to the above, on October 17-18,1997, the entrance to the truck bay cf the
radioactive waste area, a high radiation area with radiation levels greater than 1000
millirem!hr, was not locked cudpersonnel did not have direct oversight ofandpositive
control over each entry into the area.
This is a Severity Level IV vlolation (Supplement IV).
Admission or Denial of the Violation
Comed admits the violation.
Reason for the Violation
The reasons for this violation were ineffective implementation of corrective actions with
regard to previous events involving control of High Radiation Areas (HRAs) and
personnel error. This violation is the third of three events associated with HRA control.
TF , first and second events occurred on April 1 and July 1,1997, respectively.
Following the April 1 and July 1,1997, even, conective actions were implemented to
provide for continuous manning of unlocked HRA access points by a dedicated R-key
custodian and to limit R-key authority to Radiation Protection (RP) and Operations
personnel.
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ATTACHMENT A to ZRA97079
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IR 50 295/304 97026(DRS)
Page 2 of 3 .
There were two deficiencies associated with this violation.
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Incfrective Imnlemenention of Corrective Actigng
On two separate occasions auxiliary operators (members of Operations) responsible for -
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- access control of a locked HRA, entered the area'to perform a routine inspection and.-
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consequently left the HRA access point mattended without the required access control.
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- This deficiency identified a weakness'in a previously'Such authority ca
committed corrective action that'-
.provided Operations with R-key custodial authorit .
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i with other responsibilities of Operations personnel or provide an additional burden that is'
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' secondary to the assigned work task, which is what occurred. The cause of this violation -
was the failure of RP to ensure that Operations personnel. clearly understood.R-key -
custodian authority responsibilities specifically associated with access control of locked
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HRAs.
-The common element of the three HRA events was that personnel involved in HRA
access control were performing other duties in conflict with the requirement for an R-key
custodian controlling HRA access as their scle responsibility.
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Perennnel Frror:
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An auxiliary operator (a member of Operations) responsible for HRA access control
' failed to re lock the HRA after exit.' The cause of the failure to re-lock the HRA access
door was personnel error in that the individual failed to self-check to ensure that the
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intended actions were complete.
- Corrective Stens Taken and Results Acht ved
Following the discovery that the door was unlocked, it was re locked. All other R-key -
. doors in the building _were verified closed and locked.
iTo . ensure l that' personnel un. erstand expectations, prior to issuing any R-key. to
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'_ Operations staff, they are .. briefed by ' Radiation Protection on R-key custodian -
. responsibilities prior to each entry.'
' On October 20,1997, a memorandum from the Radiation Protection ivfanager was issued
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Violation. The memorandum specified the following corrective actions:
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ATTACHMENT A to ZRA97079 --
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IR 50 295/304 97026(DRS)
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L(1) Lock:d high Rad doors will be concurrently verified locked upon exiting.- This
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ill require the key custodian to remain at the locked HRA door until it_ is verified
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locked.
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. (2) At least one of the individuals, either locking the door or concurrently verifying .
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the door locked, has to be either a Radiation Protection Technician or RP. Supervision.
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(3) Locked HRA' doors without a self-closing / locking mechanism (I., , dom with a
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hasp and lock) will require at least two individuals for entry. One individual will
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enter the room. A second individual, who will rernain outside of the door and act as
' the R-key custodian, will maintain positive control of the locked HRA access.
(4) In order to ensure positive HRA control, individuals entering a locked HRA, with
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self-closing / locking mechanism doors, must verify that the door is secure behind
them prior to proceeding into their work area. -
A' review of the R-key logbooks identified the individual who left the door open. - He was
electronically locked out of the Auxiliary Building pending further investigation and
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remained locked out until he was coached on locked HRA controls, after which his
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Radiation Protection Area (RPA) access was reinstated.
The individual.was counseled'in accordance with the Management Associated Results
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Company (MARC) principles.
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Corrective Stens That Will be Taken to Avald Furt8 er Violations
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- The Radiation Protection department will evaluate assuming sole responsibility for
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locked HRA access control (i.e., relieving Operating of R-key custodian responsibilities).
This action will be completed by January 24,1998.
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A plaque will be attached to R-keys and will state that the key requires 2 individuals for
Radiation Protection' Area (RPA) non-auto self-locking /self-closing doors that are locked
HRAs; I.e., >lRem/Hr at 30 cm from the source of radiation? This action will be
- completed by January 24,1998.
Date When Full Comnllance Will be Arkleved
Zion Generating Station is currently in full compliance.
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ATTACHMENT B e ZRA97079
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1R 50 795/304 97025(r)RS)
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ATTACllMENT B
COMM!TMENTS IDENTIFIED IN Tills
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REPLY TO NOTICE OF VIOLATION
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The following table identifies those actions committed to by Comed in this docuraent. Any
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other actions discussed is this submittal represent intended or planned actions by Comed. They
are described to the NRC for the NRC's information, and are not regulatory commitments.
Please contact Mr. Robert Godley, Zion Generating Station Regulatory Assurance Manager, if
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there are any questions regarding this document or any asociated rtgulatory commitments.
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Commitment:
Committed Date
(or Outage)t
The Radiation . Protection department will evaluate ass'uning sole
January 24,1998
responsibility for locked 11RA access control (I.e., relieving Operating
of R key custodian responsibilities).
A plaque will be attached to R keys and will state that the key requires 2
January 24,1998
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individuals for Radiation Protection A. n (RPA) non auto self-
locking /self closing doors that are loci:ed HRAs; I.e., >lRem/Hr at 30
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cm from the source of radiation.
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