View source for A97025, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-21 & 50-304/97-21.Corrective Actions:Two Operating Personnel Received Remedial Training & Passed Radioactive Matl Shipping Level 1 Training Course & Revised Procedures

{{Adams
| number = ML20196H088
| issue date = 07/17/1997
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-21 & 50-304/97-21.Corrective Actions:Two Operating Personnel Received Remedial Training & Passed Radioactive Matl Shipping Level 1 Training Course & Revised Procedures
| author name = Mueller J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = Lieberman J
| addressee affiliation = NRC OFFICE OF ENFORCEMENT (OE)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = 50-295-97-21, 50-304-97-21, ZRA97025, NUDOCS 9707230324
| title reference date = 06-17-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 16
}}

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       *4             Zion Generating Station o
101 Shiloh Moulevana
                     ' zion, nwmrin                                                                               D /S, i rei a m vans ZRA97025                                                                                                       l July 17,1997                                                                                                   i Mr. James Liebermen, Director, Office Of Enforcement U. S. Nuclear Regulatory Commission Washington, D. C. 20555                                          .
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==Subject:==
Commonwealth Edison Reply to Notices of Violation in NRC Inspection Report No. 50-295/304-96021 Enforcement Action Number 97-048, dated June 17,1997; Zion Nuclear Power Station Units 1 and 2;
                               'NRC Docket Numbers 50-295 and 50-304

==Reference:==
A. B. Beach (USNRC) letter to J. H. Mueller (Comed), dated June 17,1997, "NRC Enforcement Action 97-048 Notice of Violation and Proposed Imposition of
                               $50,000 Civil Penalty.
Gentlemen:                                                                                                    1 This letter provides Comed's response to the Notice of Violation (NOV) as required by the referenced letter. Comed admits to the violation and has therefore enclosed the payment for the civil penalty in the sum of $50,000 to the Treasurer of the United States.
As discussed in the March 19,1997, pre-decisional enforcement conference, the common thread throughout this inspection was a weak work ethic. Individuals felt that they were doing a good job             l and, for the most part, were doing the "right thing". Comed management failed to set the standard of expectations at the appropriate level for this industry's special environment. Management's failure to adequately nurture and reinforce a strong work ethic in every individual is an underlying causal factor for the violations cited in the referenced letter.
This response to the Notice of Violation is organized as follows. Attachment A contains Comed's                ;
responses to the specific violations in the referenced letter. This attachment provides the reasons for each violation, immediate corrective actions taken and results achieved, and dates when full compliance will be achieved. Attachment B provides a description of any commitments made in this correspondence.
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                          ,1 ZRA97025
                    -July 17,1997
                    - page 2 of 3 In addition'to the specific violation responses provided in Attachment A Zion Station is addressing
                    - administrative issues related to the structure of the radiation protection and radwaste organizations.
These issues were summarized at the' March 19,1997, pre-decisional enforcement conference. In order to improve accountability and responsibility for the packaging, storage, and shipment of solid
                    ' radioactive waste, selected responsibilities are being transferred from the operating department to                    ,
the radiation protection department.
                    -I affirm that the content of this transmittal is true and correct to the best of my knowledge,                          f information and belief. In some instances these statements are not based on' my personnel knowledge, but on information furnished by other Comed employees, contract employees and consultants. Such information has been reviewed in accordance with company practices, and I believe it to be correct.
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I ZRA97025                                                                                                    !
July 17,1997                                                                                                l
               . page 3 of 3                                                                                                q l
                                                                                                                           -1 Should you have any questions concerning this response, please contact Robert Godley of my staff l
at 847-746-2084 extension 2900.                                                                             ;
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Sincerely, t
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                   . H. Mueller                                                                                              j Site Vice President                                                                                         j Zion Nuclear Station Subscribed and sworn to before me, a Notary Public in and for                                               I the State o       Ojht[ Land County of N1, , this /7                             day of, h           1       , 19 3                       '*
1 p c- -                  -~
                                                          ;ggg3E L; =^)I U8 THERESAI. SLAY Notary Pubhc Notary Public, State ofIllino,is g
               - Attachments                        My Commission Expires 7/13/99 j cc: Regional Administrator, USNRC - Region III
: Senior Project Manager, USNRC - NRR Project Directorate III-2 Senior Resident Inspector, Zion Nuclear Station
                      . Office of Nuclear Facility Safety - IDNS Document Control Desk 1
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A'ITACIIMENT A to ZRA97025                                                                              l Pagje1of12                                                                                              l Reply To Notice of Violation VIOLATION 1: EEI No. 50-295(304)-96021-07:
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Technical Specification 6.1.5 requires that retraining and replacement training ofstation personnel     l shall be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant                 l Personnel," dated March 8,1971.
ANSIN18.1, dated March 8,1971, step 5.1, requires that a continuingprogram oftraining be used for training replacement personnel andfor retraining necessary to ensure that personnel remain           l proficient.                                                                                              l ZAP 200-09, " Training," revision 0, dated September 17,1992, step 3.a.1, requires, in part, that personnel, other than station-men, involved in the transfer, packaging, or transport ofradioactive material shall be trained in accordance with IE Bulletin 79-19, and retrained biennially lE Bulletin 79-19 states that personnel should be trained in the DOT and NRC regulatory requirements, the waste burial license requirements, and in the instructions and operating proceduresfor the transfer, packaging, and transport ofradioactive waste.
Contrary to the above, since April 1992 and April 199-1, two licensee personnel involved in the         \
packaging of radioactive material and authorized by the licensee to release licensed material to carriers were not trained in the DOT and NRC regulatory requirements, the waste burial license requirements, and in the instructions and operating procedures for the transfer, packaging, and transport ofradioactive waste in accordance with ZAP 200-9, revision O.
l ADMISSION OR DENIAL TO THE VIOLATION Comed admits to the violation.
REASONS FOR TIIE VIOLATION I           The reason for this violation was management failed to establish a process for ensuring that l
personnel comply with the training requirements for radioactive materials / waste shipping. There l           was no mechanism in place to ensure that unqualified individuals are identified and restricted from I           performing radioactive materials / waste shipping duties. The results of the radwaste training exams were only being communicated to the trainee. Thus, it was the responsibility of the trainee to restrict himself from his respective duties if he failed an exam.
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ATTACHMENT A to ZRA97025 Page 2 of 12 CORRECTIVE STEPS THAT IIAVE HEEN TAKEN AND RESULTS ACIIIEVED The two operating personnel identified in the violation were immediately removed from radioactive waste shipping duties. Subsequently, the two individuals received remedial training and passed the Radioactive Material shipping Level 1 training course.
The radioactive material / waste shipping training portion of ZAP 200-09 was relocated to ZAP 620-01,
            " Radioactive Materials Shipping and Receiving Guidelines".
In ajoint effort between the station, Corporate Health Physics Support, and Comed's Production 1
Training Center the training process was improved through the following actions:
1
            . Verified that the current training courses adequately qualify personnel for the specific radioactive ;
shipping functions performed.                                                                        '
            . Developed and issued training matrices approved by the appropriate line supervisor and the           ;
Radiation Protection Manager for the purpose of assisting supervision in assigning individuals to    1 specific tasks. The matrices clearly show the status of personnel with regard to their successful completion and expiration date of required radioactive shipping training.                            l
            . Developed and implemented a new Production Training Center policy #30 which requires notification of site personnel in case of training course student failures. The policy requires notification of the trainee, the applicable Department Head, and the Site Training Manager.
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS ZAP 200-09 is in the process of being deleted by the training department. The remaining portions of the procedure are no longer applicable at Zion Station. This will be completed by 08/30/97.
A comprehensive radioactive material / waste shipping job analysis is being performed. From the job analysis a comprehensive task list and task analysis will be developed. This will be completed by 10/01/97.
The Radiation Protection Department will review and implement the results of the job / task analyses.
Comed will also evaluate including the instructions and operating procedures for the transfer, packaging, and transport of radioactive waste into the training programs being evaluated. This will be completed by 02/28/98.

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* ATTACHMENT A to ZRA97025 f age 3 of12 DATE WIIEN FULL COMPLIANCE WILL llE ACIIIEVED Zion Station is currently in full compliance.
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l          ATTACIIMENT A to ZRA97025 "de 4 of12
          ~ VIOLATION 2: EEI No. 50-295004)-96021-04:
i Technical Specification 6.2.2.A requires, in part, that radiation controlprocedures be maintained andshall be consistent with the requirements of10 CFR 20.
10 CFR 20.2006 requires, in part, that each shipment ofradioactive waste intendedfor disposal at a licensed land disposalfacility must be accompanied by a shipment mamfest which includes a certification by the waste generator as specified in Section III ofAppendix F to Part 20.
Section III ofAppendix F to Part 20 requires that the waste generator certify that the transported materials are properly classified, described, packaged, marked and labeled and are in proper condition for transportation according to the applicable regulations of the Department of Transportation and the Commission.
Contrary to the above, since April 1,1996, the licensee failed to maintain ZRP 5600-7 "Of-site shipment ofRadioactive Material," revision 0, to be consistent with the requirements specified in 10 i CFR 20.2006. Specifically, ZRP 5600-7 was not updated to incorporate the April 1,1996, revisions to the Department of Transportation regulations (49 CFR 100-179), and contained inaccurate           l instructions for the classification, description, packaging, marking, and labeling of radioactive    l material.
ADMISSION OR DENIAL TO TliE VIOLATION Comed admits to the violation.                                                                       I REASONS FOR TIIE VIOLATION 1
The reason for this violation was inadequate management oversight. Management failed to establish clear expectations with respect to the proper maintenance, control, and adherence to radioactive material / waste shipping procedures.
The radiation protection shipper allowed outdated procedures to remain active and ava!!able for use.
The individual rationalized that since procedures in use were revised, no immediate actions were needed since existing procedures not in use would be deleted. At no time were outdated procedures used to make radioactive material / waste shipments.
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l ATTACilMENT A to ZRA97025 Pap,e 5 of 12 l
l             CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACIIIEVED L
Radioactive shipments were halted until all shipping procedures were thoroughly reviewed and revised as necessary. As a result, six outdated procedures were deleted. The remaining six procedures were revised to improve quality and ensure programmatic compliance. After a mock shipment of Dry l             Active Waste barrels and a mock shipment involving a High Integrity Container liner, waste l             shipments were resumed on 05/21/97. Each task performed was balanced against procedure adherence and procedural content. Approved software was used to generate and assemble proper shipping paperwork per DOT and NRC requirements. Appropriate waste stream selection was j             verified and vehicle inspections were perfonned to ensure compliance with all station requirements.
Independent review forms were also included to complete the shipment package. The first two l             shipments following resumption of radioactive waste shipping were reviewed and assessed for accuracy by Corporate Radwaste Support, SQV, and QC.
A Radiation Protection Department Conduct-of-Operations standard was implemented and I             communicated to the department. The standard provides concise management expectations and specific guidance on procedure control and adherence.
l The Radiation Protection Manager removed some additional duties performed by the radiation protection shipper, required mock shipments prior to reinstating radioactive waste shipping, and
;             reorganized the radioactive material / radioactive waste program under the Radiological Control Supervisor.
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Radiation Protection Department has undertaken a procedure upgrade project to revise radiation protection procedures as needed by 12/31/97.
DATE WilEN FULL COMPLIANCE WILL BE ACIIIEVED Zion Station is currently in full compliance.
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1 ATTACHMENT A to ZRA97025                                                                            '
Pag;e 6 of12 VIOLATION 3: EEI No. 50-295(304)-96021-05 and eel No. 50-295(304)-96021-06 Technical Specification 6.2.2.A requires, inpart, that radiation controlprocedures be implemented.
ZRP 5610-4, " Preparation and Shipment of Samples for Special Analysis,' revision 0, dated         ;
November 12,1993, step E.3, requires, in part, that primary spent resin and steam generator blowdown resin samples be sent outfor analysisyearly, in accordance with 10 CFR 61 guidelines.
ZAP 610-3, " Unescorted Access to and Conduct in Radiologically Posted Areas," revision f(G),
dated September 12,1996, . step E.5, requires, in part, that personnel are to contain contaminated equipment removed from contaminated areas or have the equipment released by a radiation protection technician.
Contrary to the above:
: a.      Between August 1993 and November 1996, the licensee failed to send out primary spent resin samplesfor analysis, in accordance with ZRP 5610-4.
: b.      Since September 1994, the licensee failed to send out steam generator blowdown resin samplesfor analysis, in accordance whh ZRP 5610-4.
c.. On January 8,1997, operations personnel removed a potentially contaminated rod from a posted contaminated area without containing the rod or having the rod released by a radiation protection technician in accordance with ZAP 610-3.
ADMISSION OR DENIAL TO TIIE VIOLAT(QN Comed admits to the violation.

ATTACllMENT A to ZRA97025 Page 7 of12                                                                                           i REASONS FOR THE VIOLATION EXAMPLE e and b.                                                             l l
The reason for violations 3a and 3b was insufficient management oversight resulting in the shipper being assigned his duties on short notice with marginal turnover, little experience, and inadequate direct supervision to determine readiness to perform shipping activities. The consequence was a deficient 10CFR61 sampling and analysis program. Specifically, the procedure and surveillance         :
program didn't provide ample direction with respect to identification of individual waste streams, waste stream sampling and analysis frequencies, performance / coordination of the sampling process, and the procedure did not specify restrictions for shipping waste that did not have a current Part 61 analysis.
Steam Generator blowdown resin samples sent off-site for 10CFR61 nuclide analysis have historically shown low activity. The values reported by the vendor in many cases are less than        !
detectable. The primary focus of 10CFR61 sampling and analyses is to ascertain waste class (A, B,     I or C) correctly.                                                                                      I l
CORRECTIVE STEPS TIIAT HAVE BEEN TAKEN AND RESULTS ACHIEVED A new procedure, ZRP 5600-13 (Trending for Shifts in Scaling Factors and Waste Stream Sampling),
was implemented. The procedure provides a method for validating 10CFR61 data between analyses,        {
it provides direction on how to sample individual streams, and the procedure provides direction for analyzing and implementing 10CFR61 data.
Each of the individual streams was assigned a separate surveillance in the station surveillance program.                                                                                              1 Five of the eight waste streams have been sampled and analyzed.
l The checklist used by the radiation protection department shipper and independent reviewer to         !
facilitate radwaste shipments was revised to include verification of 10CFR61 data for each waste      i shipment.
The radiation protection shipper was counseled on the requirement for procedural adherence and        i conservative decision making (i.e., all waste shipments should have been stopped until any procedural or 10CFR61 discrepancies were resolved).                                                              l l

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ATTACHMENT A to ZRA97025 Page 8 of12 i
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS.
The remaining three streams are currently unavailable for sampling, but will be sampled / analyzed prior to shipping waste off-site for disposal The Radiation Protection shipper and Radwaste           ,
operations are aware of the requirement to obtain 10CFR61 analysis prior to shipment off-site.       l l
ZRP 5600-13 is being revised to include the required actions if 10CFR61 data is not current and to delineate the individual waste streams. This will be completed by 08/30/97.
The checklist used by radiation protection department shipper and independent reviewer to facilitate  i radwaste shipments will be included in ZAP 620-01, " Radioactive Materials Shipping and Receiving    ]
Guidelines". This will be complete by 08/30/97.
                                                                                                                 ]
I A radioactive material / waste shipping qualification card will be developed by 11/01/97.             '
I In addition, Radiation Protection will evaluate other technical programs for the need to develop      !
qualification cards. Qualification cards will be complete by 12/31/97.
1 DATE WIIEN FULL COMPLIANCE WILL HE ACIIIEVED
                                                                                                                'I Zion Station is currently in full compliance.
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l ATTACHMENT A to ZRA97025 Page 9 of12 VIOLATION EXAMPLE c:
1 ADMISSION OR DENIAL TO TIIE VIOLATION 1
l          Comed admits to the violation.
REASONS FOR THE VIOLATION The reason for this violation a lack of field supervisory oversight. Accountability regarding Radiation i Protection requirements was inconsistent or non-existent. The Operator understood the applicable        I radiologicel requirements. However, the individual rationalized that his actions were acceptable based   j upon his perception that minimal risk existed for the spread of contamination. Furthermore, other        !
Operations personnel had performed this action previously without feedback from supervision. A radiation protection technician surveyed the rod used by the operator and determined that there had been no spread of contamination.
l CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACIIIEVED                                            I To improve radiation protection oversight and radiation worker accountability the following actions were implemented:
l e Zion Station Policy Statement 1-30 titled " Radiation Worker Accountability" was signed by the plant General Manager on April 4,1997. The policy states the expectations for following established radiation worker expectations and the consequences if they are not adhered to.
* The Radiation Protection Department has implemented a program in which RP personnel are radiologically responsible for " zones" within the Auxiliary Building. The RP personnel are a continuous point of contact and oversight and are directly responsible for work occurring in their zone. RP management has provided written expectations of their responsibilities to the RP personnel monitoring the zones. The RP personnel monitoring the Auxiliary Building zones are responsible for the overall condition of their zone and are expected to maintain
                 " ownership" of the zone. Problem Identification Forms are expected to be generated for problems, which are identified.
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l ATTACHMENT A to ZRn97025 l
Page 10 of 12                                                                                          l l
l Operating personnel attended Phoenix training in response to a February 21,1997 reactivity event during a Unit I shutdown. A primary focus of this training was standards and conduct of operations, which would facilitate strict adherence to radiation worker policies.                                  l The area in question was deconned allowing free access by operating personnel.
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Radiation protection performs a quarterly walkdown with operating personnel to identify and resolve    !
any impediments to routine operating activities. This walkdown is included in the station surveillance ,
program.                                                                                                I i
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CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i
!           Radiation protection trainers assessed other department's continuing training programs for radiation
!           worker practice content. Training revision requests (TRRs) were generated for selected work groups (e.g., IMs, ems, Chemistry, Operating, mms, Engineering) to evaluate including radiation protection l           objectives into their training programs. TRR #97-795 was written for operator radiation worker         l training. Operating is evaluating the request and operating trainers are working with radiation protection trainers for inclusion of radiation worker objectives into a 1997 training cycle.
l           DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED                                                           i Zion Station is currently in full compliance.
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O ATTACHMENT A to ZRA97025 Page11of12 VIOLATION 4 EEI No. 50-295(304)-96021-01 10 CFR 71.5 requires, in part, that each licensee who transports licensed material outside of the site of usage, or where transport is on public highways, or who delivers licensed material to a carrierfor transport, shall comply with the applicable Department of Transportation regulations in 49 CFR phrts 170 through 189 appropriate to the mode oftransport.
49 CFR 173.421 requires, in part, that a Class 7 (radioactive) material whose activity per package does not exceed the limits specified in 49 CFR 173.425 and its packaging arc.exceptedfrom the specification packaging, marking, and labeling, and the shipping paper and certification requirements, if the radiation level at any point on the external surface of the package does not exceed 0.005 mSv/hr (0.5 mrem /hr).
Contrary to the above, on December 9,1996, the licensee improperly transported a Class 7 (radioactive) materialpackage as a package expectedfrom the specification packaging, marking, andlabeling requirements, and the shippingpaper and certification requirements. Specifically, this package exceeded the 0.005 mSv/hr maximum radiation limit on the external surface of the package requiredfor expectedpackages in 49 CFR 173.421.
ADMISSION OR DENIAL TO THE VIOLATION Comed admits to the violation.
REASONS FOR THE VIOLATION The reason for this violation was inadequate review and oversight. In addition, management failed to establish clear expectations for review and data validation in regards to radioactive material / waste shipping documentation. ZAP 620-01," Radioactive Materials Shipping and Receiving Guidelines",
did not delineate specific expectations for the independent reviewer.

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!          ATTACHMENT.A to ZRA97025                                                                                      l l
* Page 12 of 12 -                                                                                               l l
The subject shipment was accurately surveyed and a contact dose rate of 0.7 mrem /hr was recorded by a Radiation Protection Technician (RPT) on the pictorial survey form. A second RPT erroneously transcribed the 0.7 mrem /hr highest contact dose reading to a tabular data sheet as <0.2 mrem /hr. The original technician validated the transcribed data on the tabular form with his initials failing to identify the transcription error. Upon preparing and reviewing the shipping documentation package, the radiation protection shipper and independent reviewer erroneously classified the shipment as " Limited Quantity" based on the contact dose rate of <0.2 mrem /hr list'ed on the tabular data sheet. Both individuals failed to identify the dose rate discrepancy between the original survey and the incorrect tabular data sheet.
CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACHIEVED Shipments of Radioactive Waste were halted until the following corrective actions were implemented.
During Radiation Protection first quarter RP Technician continuing training classes, the RP shipper reviewed shipping regulations and discussed the specifics of this event. The RP shipper stressed the importance of attention to detail.
ZAP 620-01 was revised to provide specific expectations for the i$ dependent reviewer.
The Lead Technical Health Physicist communicated expectations for thorough and independent document review and data validation with the RP shipper and reviewer involved.
A radiation protection department " Conduct of Operation" standard was implemented. The standard provides clear and concise expectations for the scrutiny and rigor required when personnel sign for the review or validation of official documentation.
CORRECTIVE STEPS TIIAT WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS Refer to previous violation 50-295/304-96021-07 for corrective steps that will taken to avoid further        .
Violations.                                                                                                   l l
DATE WIIEN FULL COMPLIANCE WILL BE ACIIIEVED Zion Station is currently in full compliance.

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M     ATTACHMENT E to ZRA97025 Page1 of1 List of Commitments Identified in the Violation Respmg a 4 The following table identifies those actions committed to by Comed in this document.
Any other actions discussed in 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 notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.
Commitment                                                                     Committed Date or Outage ZAP 200-09 is in the process of being deleted by the training department. 08/30/97 The remaining portions of the procedure are no longer applicable at Zion Station.
A comprehensive radioactive material / waste shippingjob analysis is being    10/01/97 performed. From thejob analysis a comprehensive task list and task analysis will be developed.                                                                       ,
The Radiation Protection Department will review and implement the             02/28/98            l results of the job / task analyses. Comed will also evaluate including the instructions and operating procedures for the transfer, packaging, and transport of radioactive waste into the training programs being evaluated.                        i The Radiation Protection Department has undertaken a procedure                12/31/97            I upgrade project to revise radiation protection procedures a. needed.
ZRP 5600-13 is being revised to include the required actions if 10CFR61       08/30/97 data is not current and to delineate the individual waste streams.
The checklist used by radiation protection depanment shipper and              08/30/97 independent reviewer to facilitate radwaste shipments will be included in ZAP 620-01," Radioactive Materials Shipping and Receiving Guidelines".
A radioactive material / waste shipping qualification card will be developed. I1/01/97 Radiation Protection will evaluate other technical programs for the need to   12/31/97 develop qualification cards.
Training revision requests (TRRs) were generated for selected work groups     1997 training cycle (e.g., IMs. ems, Chemistry, Operating, mms, Engineering) to evaluate including radiation protection objectives into their training programs.
TRR #97-795 was written for operator radiation worker training.
Operating is evaluating the request and operating trainers are working with radiation protection trainers for inclusion of radiation worker objectives into a 1997 training cycle.
The remaining three streams are currently unavailable for sampling, but       None will be sampled / analyzed prior to shipping waste off-site for disposal The Radiation Protection shipper and Radwaste operations are aware of the requirement to obtain 10CFR61 analysis prior to shipment off-site.}}