ML20217R341

Notice of Violation from Insp on 970728-0801.Violation Noted:High Radiation Area W/Radiation Levels Greater than 1000 Mrem/Hr Was Not Locked & Personnel Did Not Have Direct Oversight of & Positive Control Over Each Entry Into Area

ML20217R341
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	08/26/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217R339	List: IR 05000295/1997020 ML20217R337 ML20217R341
References
50-295-97-20, 50-304-97-20, NUDOCS 9709050075
Download: ML20217R341 (3)

Text

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NOTICE OF VIOLATION Commonwealth Edison Company Docket Nos. 50 295; 50-304 Zion Generating Station, Units 1 and 2 License Nos. DPR-39; DPR-48 As a result of an inspection conducted July 28 through August 1,1997, four violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

1. Technical Specification 6.2.2.B requires areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 30 cm from the radiation source or from any surf ace which the radiation penetrates shall have locked doors to prevent unauthorized entry.

Procedure ZAP 610-2, "High Radiation Area Access Control," revision 3, requires that entrances to accessible high radiation areas, with radiation levels greater than 1000 mrom/hr, be locked or be controlled by a key custodian who has direct oversight of and positive control over each personnel entry into the area.

Contrary to the above, on July 1,1997, the entrance to the Unit 2 missile barrier of the Containment Building, a high radiation area with radiation levels greater than 1000 mrem /hr, was not locked and personnel did not have direct oversight of and positive control over each entry into the area. (50-295/97020-01; 50-304/97020-01)

This is a Severity Level IV violation (Supplement IV).

2. Technical Specification 6.2.1 requires that written procedures be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.30. Revision 2.

a. Appendix A of RG 1.33 recommends procedures covering contamination control be implernented.

Procedure ZRP 5010-1, " Radiological Posting and Labeling Requirements,"

revision 4, requires that areas, which have removable beta-gamma contamination at levels greater than or equal to 1000 disintegrations per minute (dpm) per 100 cm 2, be posted " Caution, Contaminated Area."

Contrary to the above, on July 30,1997, areas within the Units 1 and 2 containment spray pump rooms, which had removable beta-gamma contamination at levels of 1000 to 5000 dpm/100 cm 2, were not posted

" Caution, Contaminated Area." (50 295/97020-03; 50-304/97020-03)

This is a Severity Level IV violation (Supplement IV).

9709050075 970826 PDR ADOCK 05000295 G FDR

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b. Appendix A of RG 1.33 recommends that procedures covering equipment control be implemented.

Procedure ZAP 3001, " Conduct of Operations," revision 4, provides instructions concerning equipment control and states that the operations department has the responsibility and authority over all plant systems and equipment, except as stated in Station Policy 2-11, " Configuration Control."

Station Policy 2-11, " Configuration Control," dated April 7,1997, states l that plant equipment may be operated by personnel outside of their operational authority if (1) the work was part of a work request task or Out-Of Service Request Principle or (2) the manipulation is controlled by an applicable procedure or work instruction that requires or provides a record of specified information including the licensed shift supervisor determination of the fir.at position / state.

Contrary to the above, on July 14,1997, a member of the radiation

, protection staff manipulated a radiation monitor (2RIA-PR40) without an applicable work request, out of service request, procedure, or work instruction which fulfilled the requirements of Station Policy 2-11.

(50-295/97020-04; 50 304/97020-04)

This is a Severity LevelIV violation (Supplement IV).

3. Technical Specification 3.14 requires that radiation monitoring equipment shown in Table 3.14-1 be operable and, with one or more of the channels inoperable, that the action shown in Table 3.14-1 be implemented.

Table 3.141 requires that area surveys be performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when ORE-0006 has less than one channel operable.

Contrary to the above, between 0450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> on April 4,1997, and 0552 hours0.00639 days <br />0.153 hours <br />9.126984e-4 weeks <br />2.10036e-4 months <br /> on April 6,1997, area radiation surveys were not performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when monitor ORE-0006 was inoperable. (50-295/97020-05; 50-304/97020-05).

This is a Severity Level IV violation (Supplement IV).

With respect to item 1, the NRC has concluded that information regarding the reason for the violation, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance was achieved is already adequately addressed on the docket in a July 11,1997, letter from J. H. Mueller to the US NRC replying to NRC Inspection Report No. 50-295/97002(DRP); 50-304/97002(DRP).

- Consequently, no reply to the violation is required. With respect to items 2 and 3, t

I Notice of Violation 3 pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region 111,801 Warrenville Road, Lisle, Illinois 60532, and a copy to the NRC Resident inspector at the facility which is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This raoly should be clearly marked as a " Reply to a Notice of Violation" and should include for eat.h violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may -

reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, on order or a demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Because your response wi!! be placed in the NRC Public Document room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed la the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please

- provide a bracketed copy of_your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g. explain why the disclosure or information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation), if '

safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 26th day of August 1997 3