View source for A97079, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-26 & 50-304/97-26.Corrective Actions:All Other R-key Doors in Building Were Verified Closed & Locked

{{Adams
| number = ML20197G074
| issue date = 12/22/1997
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-26 & 50-304/97-26.Corrective Actions:All Other R-key Doors in Building Were Verified Closed & Locked
| author name = Brons J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = 50-295-97-26, 50-304-97-26, ZRA97079, NUDOCS 9712300368
| title reference date = 12-05-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

=Text=
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                   /k m.11 (hem 2N7 Tel N I" ' in 20M 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 50-295/304-97026(DRS) and Notice of Violation Gentlemen:
i        By {{letter dated|date=December 5, 1997|text=letter dated December 5,1997}}, the NRC cited Commonwealth Edison (Comed) as being in I        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. Attachment B to this letter identifies all colamitments 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, kt  , s
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ohn C, Brons
                           +
ite Vice President Zion Generating Station Attachments                                                         1.1 I.l!Illl,!I,Ill.i ,111.1 t
ec:      Regional Administrator, USNRC - Region III Senior Project Manager, USNRC - NRR Project Directorate III-2 NRC Senior Resident inspector, Zion Generating Station                                  g Oflice of Nuclear Facility Safety - IDNS                                              t 9712300360 971222 PDR      ADOCK 05000295                                                                              .*
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ATTACllMENT A to ZRk97079                                                                                                                                              i l
i IR 50-295/304 97026(DRS)
Page1of3                                                                                                                                                                ,
ATTACllMENT A REPLY TO NOTICE OF VIOLATION IN NRC                                                                                                      ,
INSPECTION REPORT 50-295/97026(DRS); 50-304/97026(DRS) l L
VIOLATION 1 150-295/304-97026-Olh
: l.                           - TechnicalSpecification 6.2.2.B equires areas accessible to persorinel with radiation g-                             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 unauthori:ed entry,                                                                                                                                             ;
:                              Procedure ZAP 610-2, "High Radiation Area Access Control " revision 5, requires that
,                              entrances to accessible high radiation areas, with radiation levels greater than 1000 milliremlhr, he 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 ofthe                                                                                      ,
radioactive waste area, a high radiation area with radiation levels greater than 1000 millirem /hr, was not locked andpersonnel did not have direct oversight ofandpositive control over cuch entry into the area.
I l
This is a Severity Level IV violation (Supplement IV).
Adminion 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 Iligh Radiation Areas (IIRAs) and personnel error. This violation is the third of three events associated with HRA control.
The first and second events occurred on April 1 and July 1,1997, respectively.
Following the April 1 and July 1,1997, events, corrective actions were implemented to provide for continuous manning of unlocked llRA 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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a A1TACllMENT A to ZRA97079 IR 50-295/304-97026(DRS)
Page 2 of 3 There were two deficiencies associated with this violation.
Ineffective Imnlementation of Corrective Actions:
On two separate occasions auxiliary operators (m,:mbers of Operations) responsible for access control of a locked llRA, entered the area to perform a routine inspection and consequently left the llRA access point unattended without the required access control.
This deficiency identified a weakness in a previously committed corrective action that provided Operations with R-key custodial authority. Such authority can easily conflict with other resp (msibilities of Operations personnel or provide an additional burden that is 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 IIRAs.
The common elem-nt of the three llRA events was that personnel involved in llRA access control were performing other duties in conflict with the requirement for an R-key custodian controlling IIRA access as their sole responsibility.
Personnel Error:
An auxiliary operator (a member of Operations) responsible for llRA access control failed to re-lock the llRA after exit. The cause of the failure to re-lock the llRA access door was personnel error in that the individual failed to self-check to ensure that the intended actions were complete.
Corrective Steps Taken and Rcluhs Achieved Following the discovery that the door was ur. locked, it was re-locked. All other R-key doors in the building were verified closed and locked.
To ensure that personnel understand expectations, prior to issuing any R-key to Operations stalT, 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 Manager was issued to all Operations and Radiation Protection personnel concerning the liigh Rad Door Violation. The memorandum specified the following corrective actions:
I

ATTACilMENT A to ZRA97079 IR 50-295/304-97026(DRS) l' age 3 of 3 (1) Locked high Rad doors will be concurrently verified locked upon exiting. This will require the key custodian to remain at the locked ilRA door until it is verified locked.
(2) At least one of the individuals, either locking the door or concurrently verifying the door locked, has to be either a Radiation Protection Technician or RP Supervision.
(3) Locked ilRA doors without a self-closing / locking mechanism (l.c., doors with a hasp and lock) will require at least two individuals for entry. One individual will enter the room. A second individual, who will remain outside of the door and act as the R-key custodian, will mair.tain positive control of the locked llRA access.
(4) In order to ensure positive llRA control, individuals entering a locked ilRA, with 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. lie was electronically locked out of the Auxiliary Building pending further investigation and remained locked out until he was coached on locked ilRA controls, after which his Radiation Protection Area (RPA) access was reinstated.
The individual was counseled in accordance with the Management Associated Results Company (MARC) principles.
Corrective Steps That Will be Taken to Avoid Further Violatheti The Radiation Protection department will evaluate assuming sole responsibility for locked llRA access control (l.c., relieving Operating of R-key custodian responsibilities).
This action will be comp'eted by January 24,1998.
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 ilRAs; i.e., >lRem/llr at 30 cm from the source of radiation. This action will be completed by January 24,1998.
Ilate When Full Compliance Will be Achitted Zion Generating Station is currently in full compliance.

A1TACllMENT 11 to ZRA97079 IR 50 295/304-97026(DRS)
Page1of1 ATTACllMENT 13 COMMITMENTS IDENTIFIED IN Tills REPLY TO NOTICE OF VIOLATION The following table identifies those actions committed to by Comed in this document. Any 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. Robcn Godley, Zion Generating Station Regulatory Assurance Manager, if there are any questions regarding this document or any associated regulatory commitments.
K
                           ~
Commitment:                                                                       Committed Date (or Outage):
The Radiation Protection depanment will evaluate assuming sole January 24,1998 responsit>ility for locked ilRA access control (l.c., 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 individuals for Radiation Protection Area (RPA) non-auto self-locking /scif-closing doors that are locked IIRAs; i.e., >lRem/llr at 30 cm from the source of radiation.
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