IR 05000295/1996021: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot insert)
 
(StriderTol Bot change)
 
Line 1: Line 1:
{{Adams
{{Adams
| number = ML20134P488
| number = ML20148L642
| issue date = 02/11/1997
| issue date = 06/17/1997
| title = Insp Repts 50-295/96-21 & 50-304/96-21 on 961203-970122. Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Radiological Protection & Chemistry Controls
| title = Discusses Insp Repts 50-295/96-21 & 50-304/96-21 on 961203- 970122 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty for $50,000.Insp Included Review of Plant Program for Transportation of Radioactive Matl
| author name =  
| author name = Beach A
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Mueller J
| addressee affiliation =  
| addressee affiliation = COMMONWEALTH EDISON CO.
| docket = 05000295, 05000304
| docket = 05000295, 05000304
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-295-96-21, 50-304-96-21, NUDOCS 9702250491
| document report number = 50-295-96-21, 50-304-96-21, EA-97-048, EA-97-48, NUDOCS 9706190322
| package number = ML20134P485
| package number = ML20148L647
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 16
| page count = 6
}}
}}


Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:.. . - . . . _ _ _ _ - . . _ . . _ . _ _ _ _ .  ..- _ _ _ . _ . _ _ _ __ _ . _ . _ _ _ .
{{#Wiki_filter:_ __ _ _ - . ,_ _ .. _ -_ _ _
_
        ..m.


,
d J* %gg  UNITED STATES
. , -
NUCLEAR REGULATORY COMMISSION (
. Ia o  REGION !!!
801 WARRENVILLE ROAD k,  USLE. ILLINOIS 60532-4351
.
.
l
  .....
  '
I June 17, 1997 EA 97-048 Mr. J. Site Vice President
;  Zion Generating Station    l Commonwealth Edison Company 101 Shiloh Boulevard Zion, IL 60099 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - '
*
  $50.000 (NRC ROUTINE RADIATION PROTECTION INSPECTION REPORT 50-29f(/96021(DRS): 50-304/96021(DRS))
b


U. S. NUCLEAR REGULATORY COMMISSION    -l REGION 111
==Dear Mr. Mueller:==
          ]
!  This refers to the inspection conducted from December 3, 1996, through January 1  22. 1997, at your Zion Generating Station Unit 1 and 2 facilities. This
i Docket Nos:  50-295; 50 304    i Licenses No:  DPR-39; DPR-48 lJ Reports No:   50-295/96021(DRS); 50-304/96021(DRS)  );
;
l Licensee:  Commonwealth Edison Company (Comed)
'  inspection included a review of Zion's program for transportation of  j radioactive material. The written results of this inspection were provided to  1 you on February 11, 1997. A predecisional enforcement conference was conducted on March 19, 1997.
l l
Facility:  Zion Generating Station, Units 1 & 2 I


Location:  105 Shiloh Boulevard    l Zion, IL 60099    j
Based on the information develo provided during the conference, the pedNRCduring hasthe inspection determined and that the information violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty, and the circumstances surrounding them are described in detail in the subject inspection report.
          ,
Dates:  December 3,1996 - January 22,1997  '
          ;
Inspectors:  S. K. Orth, Radiation Specialist  '
i Approved by:  Thomas J. Kozak, Chief, Plant Support Branch 2 Division of Reactor Safety i
          )
          ,
          !
l


l i
The violations involved numerous weaknesses in the transportation of radioactive material program and included: failure to train personnel in accordance with procedures; inadequately maintaining radioactive material shipping procedures: inadequately implementing radiation control procedures:
y 9702250491 970211 PDR ADOCK 05000295 G  PDR
and exceeding the radiation limits of 49 CFR 173.425 for a shipment of radioactive materials. These violations taken collectively demonstrate an overall programmatic deficiency and are described below.
    - _ . - . . . - - . - .  --  _
        .


.
First, two of the seven workers authorized to release and approve shipments of licensed radioactive materials were not adequately trained in accordance with station procedures. While the workers attended the appropriate training, they
.
        ,
EXECUTIVE SUMMARY Zion Generating Station, Units 1 & 2 NRC Inspection Reports 50-295/96021, 50-304/96021 e An apparent violation was identified concerning the shipment of radioactive materials. The external surface of a December 9,1996 limited quantity shipment from Zion exceeded the radiation dose rate limit of 49 CFR 173.425. Problems were also identified concerning the coordination and planning of radioactive material shipping operations. (Section R1.1)
        '
e Access to safety related equipment continued to be radiologically encumbere Pump sealleakage contributed to the high number of contaminated areas within the auxiliary building. Several examples of inadequate radiological housekeeping and control of radiological boundaries were identified. (Section R1.2)
did not pass the associated examination. In addition, the training offered did not address facility instructions or operating procedures. While failing to train authorized personnel was significant, especially since the applicable regulations were substantially revised on April 1-.1996, the radioactive material shipments were reviewed by trained individuals.
e Although the licensee had focussed efforts on resolving operability issues for the


steam generator blowdown and radioactive waste (radwaste) systems, material condition deficiencies, including inoperable chemical drain tank pumps, were not resolved. Radwaste operators continued to work around inoperable equipmen Inconsistencies were identified concerning radwaste system configurations and the Updated Final Safety Analysis Report (UFSAR). (Section R2.1)
l
e Two apparent violations were identified concerning radioactive material shipping procedures. The licensee had not adequately maintained certain procedures to be consistent with the revisions to regulatory requirements. In addition, the licensee had not properly implemented procedures concerning the use of radionuclide scaling factors in determining the activity of radioactive waste. (Section R3.1)
        /lV PJ "%JER FJ L    '%I )
e An apparent violation was identified for not adequately implementing radiation control procedures. Operations personnel removed instruments from a posted contamination area without containing the instrument or having the instrument released by radiation protection personnel. (Section R4.1)
g  pg  l!l1Hll1HlllllllWllllllllllllllIlll.ll
e The licensee demonstrated good communication and coordination during the December 4,1996 medical drill. The licensee was effective in minimizing the spread of simulated radioactive contamination, with some exception (Section R4.2)
      .... , {
e Radioactive material shipping training lesson plans were consistent with the revisions to 10 CFR Part 71 and 49 CFR Parts 172 and 173. An apparent violation was identified concerning the failure to train two operations personnel in accordance with procedures. (Section R5.1)
j
e The licensee's self assessments of the radioactive material transportation program were not thorough and failed to identify fundamental radioactive material shipping problems. (Section 7.1)


  .
  .
Report Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 Transoortation of Radioactive Materials Insoection Scone (83750,2515/1331 The inspector reviewed the shipping documents for the following radioactive waste (radwaste) and material shipments and verified the licensee's waste classification, and package classification, labeling, and shipping papers:
.
ZRW 96-02 Dewatered ion Exchange Resin (1/25/96);
J. '
ZRW 96-12 Dewatered lon Exchange Resin (4/24/96);  I
Second. a number of Zion's radioactive waste and material shipping procedures l were not properly maintained to meet the April 1. 1996, revisions to I applicable transportation regulations. Since a computerized software program was used to accomplish the intent of the procedures Zion's staff deemed these procedures to be obsolete without properly deleting these procedures, and without addressing or documenting the known procedural deficiencies. While not adequately implementing the station process for revising procedures was significant, the instructions in the procedures were not necessary for processing radioactive material shi)ments. The instructions in the procedures were for manual determinations of slipment requirements, but manual determinations were no longer being performed.
,
ZRW 96-25 Dewatered lon Exchange Resin (10/24/96); and ZRM 96-131 Radioactive Material (12/9/96).


The inspector also observed the licensee's preparation and packaging of a liner of ion exchange resin (ZRW 97-01) for shipment to a radwaste burial sit Observations and Findinas During the review of the shipping documents, the inspector identified problems concerning the licensee's implementation of shipping and waste classification procedures (also see Section R4.1). With the exception of radioactive material shipment ZRM 96-131, the inspector verified that the licensee's waste  ,
Third, certain of Zion's radiological control procedures were not implemented.
classification and shipping classifications were accurately calculated and that l packaging requirements were met. The inspector also observed that the shipping papers were completed as require The inspector reviewed documentation about a problem concerning the licensee's December 9,1996 shipment of radioactive material (ZRM 96-131) to the Byron Nuclear Station. Although the material was shipped as a limited quantity shipment, the Byron staff identified that the package's contact dose rates of 0.7 mrem /hr exceeded the Department of Transportation's (DOT) contact radiation limit of 0.5 mrem /hr for that type of package. Zion Station's documented survey of the shipment clearly indicated the actual contact dose rate of 0.7 mrem /hr, but personnel incorrectly documented that dose rates were less than 0.2 mrem /hr on the shipping forms. Although four members of the licensee's staff reviewed this information, the problem was not identified until the Byron staff performed an incoming shipment review. Byron personnel made a courtesy notification to NRC to report the problem with the shipmen 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 highway, or who delivers licensed material to a carrier for transport, shall comply with the applicable Department of Transportation regulations in 49 CFR parts 170 through 189 appropriate to the mode of transport. 49 CFR 173.421 requires, in part, that a


I l
On two occasions Zion's staff failed to analyze waste streams annually to determine radionuclide scaling factors as recuired by procedures. In failing to implement these procedures. Zion's staff cid not provide reasonable assurance that the use of scaling factors to determine nuclide activity could ,
.
be accurately correlated with actual measurements. This issue is significant because incorrect information could have been provided to the radioactive waste burial site as a result of inaccurate radioactivity estimations. It is i unlikely that the difference would have changed the waste classification or I would have exceeded the burial site license, but it is important for these activities to be accurate to ensure that waste is properly segregated and is stable. In addition, on January 8, 1997, operations personnel removed a potentially contaminated rod from a posted contaminated area without complying with procedural requirements to contain the rod or to have the rod released by a radiation protection technician. This particular event was not radiologically significant, but improperly removing contaminated items increases the potential of contaminating clean areas and personnel. This event was indicative of the ongoing problems with radiation worker practices at the station.    ,
Class 7 (radioactive) material whose activity per package does not exceed the limits I specified in 49 CFR 173.425 and its packaging are excepted from the specification l
Finally, problems were observed concerning the December 9.1996, limited quantity shipment of radioactive material to the Byron Nuclear Station. The Byron staff identified dose rates in excess of the Department of Transportation's (DOT) contact radiation limits for a limited quantity shipment. The original radiological survey of this shipment. conducted by Zion's staff, clearly indicated that the dose rates exceeded the limit of 0.5 millirem per hour. However, the dose rates were incorrectly documented on the shipping papers. These shipping papers had been reviewed by four members of Zion's staff without this error being identified. This issue is not radiologically significant. due to the low dose rates on the package: however, the issue is of regulatory significance because the classification allowed the shipment to be excepted from additional DOT requirements.
packaging, marking, and labelling, and the shipping paper and certification l requirements, if the radiation level at any point on the external surface of the '
package does not exceed 0.005 millisievert (mSv)/hr (0.5 mrem /hr). The failure of the licensee to properly ship radioactive materialin accordance with 49 CFR 173.425 is an apparent violation (eel No. 50-295/96021-01(DRS) and  )
50-304/96021-01(DRS)). I On January 8,1997, the inspector also observed the packaging of a high integrity container of ion exchange resins (ZRW 97-01) and identified the following problems:
, e Poor planning and coordination between the radiation protection (RP) and l operations staff was noted. The operations staff had unloaded an empty I liner from a carrier's vehicle, had weighed the full liner, and were preparing to move a full liner of ion exchange resins onto the carrier's vehicl However, minutes before the liner was to be loaded on the carrier's truck, i RP personnel notified the operations staff that they did not have a curreret l analysis for the resin. All activities in support of loading of the liner w suspende * While positioning the carrier's truck into the Radwaste Annex, the licensee directed the carrier's truck near a contaminated area boundary. The truck struck and moved the boundary. The truck also brushed against a storage cask (containing a loaded liner) within the contaminated area in the Radwaste Anne Although a violation of NRC requirements was not identified, this evolution could have potentially damaged the storage cask containing the resins and could have potentially contaminated areas outside of the posted are As immediate corrective actions for the problems described above, the licensee suspended all radioactive material shipping on January 10,1997, and bcgan to review, delete, and/or revise a number of shipping procedures to be consistent with the requirement c. Conclusions An apparent violation was identified concerning the shipment of radioactive materials. On December 9,1996, the licensee shipped radioactive material as a limited quantity shipment which exceeded the limits of 49 CFR 173.425. Problems were also identified concerning the coordination and planning of radioactive material shipping operation .
.
R1.2 Plant Radioloaical Conditions Insoection Scoce (83750,86750)
The inspector reviewed the radiological conditions of the plant and assessed the effect of radiological contamination and high radiation levels on access to safety related and radwaste equipment. Specifically, the inspector reviewed the licensee's surveys of the auxiliary building (ABi and the associated posting and control of radiological hazards. In addition, the inspector assessed the radiological housekeeping in the AB and the control of contaminated area boundarie Observations and Findinct The licensee continued to have several radiological impediments encumbering access to safety related equipment, as documented in NRC Inspection Report 50-295/96016(DR S), 50-304/96016(DRS). Extensive pump sealleakage contributed to contamination in several emergency core cooling system (ECCS) pump room Although these areas were properly posted and controlled, the access to safety related equipment was significantly impeded in addition, high radiological source term has resulted in elevated dose rates and numerous hot spots. For example, the licensee posted and controlled all four of the residual heat removal (RHR) pump rooms as high radiation areas (HRAs) and contaminated areas (CAs). The RHR heat exchanger rooms were similarly controlled, with the unit 1 (U1) rooms being locked HRAs as well. Although a small non-contaminated area walkway was maintained in the RHR rooms, the access to equipment remained encumbere The centrifugal charging pump (CCP) rooms were accessible; however, the overall, higher U1 dose rates resulted in the licensee posting and controlling the 1B CCP as an HRA. The inspector also observed that the pumps and pedestals were posted as CAs, owing to pump sealleaks and visible boric acid crystallizatio Similar to the ECCS pump rooms, the inspector observed that the access to areas containing radwaste system components was highly, radiologically encumbere As a result of numerous hot spots and high radiological source tcrm withir: the radwaste tanks, the licensee controlled the AB equipment drain tank (EDT) and chemical drain tank (CDT) as locked HRAs. In general, the inspector noted that pump sealleakage had also resulted in the posting of radwaste tank pumps as contaminated areas, in addition, the inspector observed that the licensee had also restricted access to the crystallizer and evaporator rooms, v5hich had been
'
abandoned in place, with RA and CA postings at the access point and with radiation protection (RP) permission necessary for acces During plant observations on December 3 and 4,1996, the inspector identified problems concerning radiological boundary control and housekeeping in several areas of the AB. For example, the inspector observed several signs of leakage within the U1 and U2 hnrizontal pipe chases, including leakage from the high radiation sampling system waste tank pump. The inspector also identified protective clothing strewn about the area and fulllaundry collection containers improperly stored within CAs. The inspector also identified several radiological housekeeping issues in a work area outside of the U2 volume control tank room


  . --_ .. _ _ -- .. - . . . . -_
While individually each of these issues would not constitute a matter of high safety significance. collectively, these issues are significant because they indicate inadequate implementation and a lack of oversight of the program. We are particularly concerned that problems were identified in virtually every phase of the program. Additionally, an April 1996 audit conducted by Zion's
  .
  -


.
    . . - .- __ - -
including hoses not properly secured crossing CA boundaries, hoses containing fluids not leading to collection devices, and protective clothing strewn about within the C Conclusions
,
.
e J. staff in this area lacked the depth and thoroughness necessary to identify the fundamental program weaknesses. Lack of an effective audit in this area was particularly noteworthy given that a major change to the applicable trans)ortation regulations was made effective April 1,1996. Coupled with the poor listory in radiation protection performance over the past 12 months (violations have been identified concerning inadequate posting of radiol,ogical hazards, inadequate contamination control practices, inadequate procedures to control radiation monitors. and failure to perform compensatory actions for inoperable radiation monitors), these issues indicate a breakdown in this program and weaknesses in the ability to perform adequate self assessments.
Access to safety related equipment continued to be radiologically encumbere Pump sealleakage contributed to the number of contaminated areas within the A Several examples of inadequate radiological housekeeping and control of radiological boundaries were identifie R2 Status of RP&C Facilities and Equipment    l I
R 2.1 Material Condition of Radioactive Waste Processina System  I Scone (86750)
The inspector reviewed the material condition of the radwaste processing syste The inspector compared the current system condition and operation to the licensee's Updated Final Safety Analysis Report (UFSAR) section 11.2, " Liquid Waste Management Systems," and section 11.4, " Solid Waste Management System." The inspector also reviewed the outstanding work orders for the system )
and the licensee's progress in performing system maintenance. The inspector also l discussed system operability and planned corrective maintenance with members of the operations staf Observations and Findinas    ,
i With the exception of the spent resin storage tank (SRST), the inspector verified that the integrity of the radwaste tanks was acceptable and did not identify any indications of leakage. However, as described in Section R1.2, high dose rates impeded access to several radwaste tank rooms. Current radiological conditions (i.e., estimated general area dose rates in excess of 40 rem /hr) made the SRST inaccessible. However, the licensee had decontarninated the tank in July 1996 to perform maintenance on valves. RP personnel, who were involved in the evolution, indicated to the inspector that the integrity of the tank was good and that there were no visible indications of resin leakage from the tan The inspector observed that both CDT pumps were inoperable. The A pump was completely removed from tae pump pedestal and the B pump was wrapped with plastic to contain leakage. Operations personnel indicated that the pumps had been out of service for over ten years and that the pump suction valves had been isolated, in accordance with 801-67D, " Liquid Waste Disposal Chemical Drain Tank," Revision 3, operations personnel directed the unanalyzed CDT contents to the OB AB sump, which was normally pumped to the AB floor drain analysis tan The licensee identified this practice as an operator work around. Although the problem was not documented in a work request and progress in correcting the problem was slow, the system en0ineer had an action plan to correct the deficiencies. The inspector noted that the licensee's process was in conflict with the UFSAR. As described in UFSAR Section 11.2.2.8, the contents of the CDT


_ _    - - .
Therefore, these violations are classified in the aggregate in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, as a Severity Level III problem,  t In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years.1 the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil Senalty assessment process in Section VI.B 2 of the Enforcement Policy. The N1C determined that no credit for Identification was warranted because this problem was identified by the NRC during a routine inspection, and not identified through Commonwealth Edison Company's self assessment process. The NRC determined that credit for Corrective Action was warranted because corrective actions were timely and thorough. Once these issues were brought to the attention of facility management, all shipments of radioactive material were suspended, and the  I assistance of the corporate subject matter expert was obtained. Training was  !
l completed for appropriate personnel, and the training process was enhanced.


were to be mixed and sampled, then pumped directly to the applicable radwaste processing system. In addition, the inspector noted that the AB floor drain analysis tank and AB sumps (UFSAR Section 11.2.2.2 and 11.2.2.8.2.7, respectively) were not designed to accept inputs from the CDT nor inputs to the CDT. At the time of this inspection, the licensee was determining if a safety evaluation had been completed for the above system configuration. (Unresolved Item No. 50-295/
All outdated procedures were deleted, and procedural rebaselining was initiated. Considerable efforts were implemented to improve the waste stream
96021-02(DRS) and 50-304/96021-02(DRS))
! analysis process through procedural revisions and additional training, and an l emphasis was placed on complying with radiation control procedures. Finally.
In addition to the discrepancy above, the inspector also noted other issues concerning radwaste operations which were not in conformance with the UFSA The inspector also noted that UFSAR Section 11.2.2.8.5 states that a radwaste l evaporator was to be used for radwaste processing. However, the licensee did not have any plans or work requests to repair the non-functioning radwaste evaporato The licensee exclusively uses ion exchange demineralization to process the contents of the liquid radwaste tanks. UFSAR section 11.2.2 also states that the contents of radwaste tanks were to be mixed and sampled to determine the most effective processing of the liquids. Specifically, UFSAR Section 11.2.2.8 indicates that the contents of the following tanks were to be mixed and sampled prior to being discharged through a treatment process: AB equipment drain analysis tank, AB floor drain analysis tank, CDT, and laundry and hot shower drain tanks. However, chemistry and operations personnelindicated that the licensee did not sample the contents of each tank prior to processing. After processing the tanks' contents, the licensee sampled the accumulated, processed liquid waste in the evaporator monitor tanks. Prior to releasing the processed waste to the lake, the licensee also sampled the contents of the lake discharge tanks (LDTs). At the time of this inspection, the licensee was determining if a safety evaluation had been completed for the above difference in radwaste operations. (Unresolved item No. 50-295/96021-03(DRS) and 50-304/96021-03(DRS))
The inspector noted some progress in the licensee's actions to resolve longstanding, extensive material condition deficiencies on the steam generator (SG)
blowdown system. Material condition deficiencies in this system (documented in NRC Inspection Report 50-295/95016(DRP) and 50-304/95016(DRP)) included severalindications of valve packing and pump sealleakage. Since September 1996, the licensee dedicated an oversight group to improve system operability and to complete outstanding work orders. As of November 1,1996, the licensee had resolved issues on the blowdown system which were of high priority to the operations staff. After complete resolution of the blowdown system maintenance problems, the licensee planned to focus efforts on the remainder of radwaste system issues. A radwaste operations supervisor indicated that over 30 work requests were in the licensee's system for general radwaste corrective maintenance. Conclusions Although the licensee had focussed efforts on resolving operability issues for the steam generator blowdown and radwaste systems, material condition deficiencies, including inoperable chemical drain tank pumps, were not resolved. Radwaste operators continued to work around inoperable equipment. Inconsistencies were identified concerning radwaste system configurations and the UFSA l


- - - _ .-  -  . .
l more descriptive guidelines and expectations were created for the approval of, radioactive material shipments.
.
,      ,
R3 RP&C Procedures and Documentation R Radioactive Material Shiocina Procedures Scoce (86750 -
The inspector reviewed the licensee's procedures providing instruction in the classification, packaging, transport, and shipping of radioactive materials and radwaste. The inspector reviewed the following licensee procedures and their implementation:
ZAP 620-01, " Radioactive Material Shipping and Receiving Guidelines,"
Revision TA-96-973; ZRP 5600 3, " Classification of Radioactive Waste for Near-Surface Burial Site
,
Disposal," Revision 0; ZRP 5600-4, " Completion of Radioactive Material Shipping Record," Revision 2; ZRP 5600-7, "Off-Site Shipment of Radioactive Material," Revision 0; ZRP 5600-11, " Radioactive Shipments (RM) (Other Than Waste)," Revision TA-96-008; ZRP 5610-2, " Calculation of Curie Content of Radioactive Shipments," Revision 0; ZRP 5610-4, " Preparation and Shipment of Samples for Special Analysis,"
Revision 0; ZRP 5610-6, " Surveying Radioactive Material Shipments," Revision 2; and ZRP 5610-10, " Radioactive Waste Shipments," Revision Observations and Findinas The inspector observed that the licensee had revised procedure ZAP 620-01 to be consistent with recently implemented revisions to applicable transportation regulations. ZAP 620-01 contained guidance in preparing packages, consistent-with the categories of low specific activity (LSA) and surface contaminated object (SCO). The procedure also contained instructions consistent with the revised packaging requirements. However, ZAP 620-01 often directed the user to refer to applicable regulations instead of providing specific instructions. For example, in determining the type of label for the package, ZAP 620-01 referred the user to 49 CFR 172.403. The licensee indicated that its computer software was used to ensure that the regulatory requirements were me The licensee also used computer software to determine packaging requirements such as activity limits, LSA classification, and SCO classification for transport of radioactive materials. The licensee's procedures properly reflected the use of the computer software which appropriately implemented the applicable regulations. The licensee also had approved procedures which provided instructions for manual determination of the above packaging requirements. The inspector determined that ZRP 5600-7, "Offsite Shipment of Radioactive Material," Revision 0, dated November 2,1993, contained inaccurate instructions for determining packaging requirements (i.e., activity limits, LSA classification, SCO classification, etc.).
Specifically, this procedure contained instructions which complied with the previous regulations and, thus, were outdated. Once this was brought to the licensee's attentior', the licensee deleted the procedur .
.
Technical Specification (TS) 6.2.2.A requires, in part, that radiation control procedures be maintained. The failure to maintain radiation control procedure ZRP 5600-7 is an apparent violation of TS 6.2.2.A (eel No. 50-295/96021-04(DRS)
and 50-304/96021-04(DRS)).
During a review of shipment documents, the inspector identified that the licensee had not adequately implemented its radioactive waste shipping procedures concerning the sampling and analysis of waste streams to determine radionuclide scaling factors. In accordance with 10 CFR 61.55(a)8, scaling factors are used as an indirect method to determine radionuclide activity in radioactive waste shipments. This is done by inferring a concentration of hard to detect radionuclides by applying scaling factors to a known concentration of an easier to detect radionuclide provided there is reasonable assurance that the indirect method can be correlated with actual measurements. Licensee procedures require that sampling and analysis of certain waste streams be done annuall The inspector identified that the steam generator blowdown resin scaling factors had not been analyzed since September 1994. Further, this analysis was not used because it was determined that the sample was not representative of the actual radionuclide content of the resin. No additional sampling was performed and there was no laboratory analysis to support the pre-1994 scaling factors which were in use at the time of the inspection. The significance of this omission is that the slight steam generator tube leakage which had occurred since the last valid sample analysis could have changed the radionuclide content of the blowdown resi Additionally, the sampling and analyses of the primary resin waste stream was not performed from August 1993 through November 1996. Even though the primary resin was sampled in November 1996, a combined average of 1992 and 1993 sample data was in use at the time of the inspectio TS 6.2.2.A requires, in part, that radiation control procedures be implemente Licensee procedure ZRP 5610-4, dated November 12,1993, requires, in part, that spent resin samples be sent out for analysis yearly, in accordance with 10 CFR 61 guidelines. ZRP 5610-4 required that annual samples of SG blowdown resin and primary resin be analyzed in accordance with 10 CFR 61 guidelines and procedure ZRP 5610-10, dated December 12,1994, required that the current shipment be compared to " annual waste stream analyses". The failure to obtain and analyze annual samples of SG blowdown resin and primary resin is an apparent violation of TS 6.2.2.A (eel No. 50-295/96021-05b(DRS) and 50-304/96021-05(DRS)).
c. Conclusion Two apparent violations were identified concerning radioactive material shipping procedures. In the first violation, the licensee did not adequately maintain certain procedures consistent with the revisions to regulatory requirements. The second violation concerned the failure to have samples of various waste streams analyzed to establish acceptable scaling factors within the procedurally-specified timefram ..
:      1 1      I l
:
i .
R4 Staff Knowledge and Performance in RP&C l
,. R4.1 - Radiation Worker Practices L During the inspector's observations of radwaste shipment ZRW 97-01 (Section i R1.1), the inspector identified an apparent violation of procedure ZAP 610-03,
" Unescorted Access To and Conduct in Radiologically Posted Areas," Revision 1(G),
; dated September 12,1996. This procedure states that personnel are to contain
)
contaminated equipment removed from contaminated areas or have the equipment released by a radiation protection technician. On January 8,1997, the inspector j observed an operations individual pick up a rod in a clean area, use the rod .to j manipulate potentially contaminated equipment in a posted contaminated area, and 1 . remove the rod from the posted contaminated area without containing the rod or j having the rod released by a radiation protection technician. In utilizing the rod to manipulate equipment within the posted contaminated area, the individual potentially contaminated the rod. Following the observation, the inspector alerted a
,
radiation protection technician (RPT) in the area, who took control of the rod and
: performed a contamination survey.


*
While your corrective actions were thorough, the initial audit of the l
TS 6.2.2.A requires, in part, that radiation control procedures be implemented. The failure to adhere to ZAP 610-3 is an apparent violation of TS 6.2.2.A (eel No.50-
radioactive material program was superficial and identified none of the above
[ 295/96021-06(DRS) and 50-304/96021-06(DRS)).  !
i
:
R4.2 Onsite Emeroency Medical Drill l
.      1 Insoection Scone (83750,82301)
l The inspector observed the licensee's December 4,1996 onsite emergency medical ,
l drill. The drill scenario included a simulated contaminated, injured person (CIP) who j had fallen in the 1B CCP room. The inspector reviewed the licensee's response to
; the scenario events, including the licensee's first aid response, evaluation and !
'
'
communication of radiological hazards, and contamination control.
weaknesses. It is imperative that Commonwealth Edison Company can rely on self assessments to identify program deficiencies, and not depend solely on
;
personnel rationalizations to supersede inadequate procedures to ensure the program is adequately implemented. The administrative barriers l
l i


l Observations and Findinas
A severity Level 111 Problem with a $100,000 Civil Penalty was issued on March 12,1997 (EA 96-355); a severity Level Ill Violation with a $50,000 Civil Penalty was issued on August 23,1996 (EA 96-216); a
!
-
} The inspector observed good communications and coordination with offsite i responders and between onsite personnel. With the exception of a simulation problem, the onsite personnel responded to the CIP in a timely manner. The initial responders (security, operations, and RP personnel) ensured that appropriate first
severity Level til Violation with a $50,000 Civil Penalty was issued on February 21,1996 (EA 95-283); a severity Level !!! Violation with a $50,000 Civil Penalty was issued on November 28,1995 (EA 95-144); and a !
; aid was administered and that information was properly communicated with offsite fire protection personnel. The RPTs monitored the CIP's vital signs and ensured L that the individual remained conscious and aware of what was occurring. The status of the CIP was appropriately relayed to the offsite fire protection personnel responding to the scenario event Contamination control practices were good, with some minor exceptions. The RP personnel established a boundary around the CIP to control the potential spread of contamination and limit personnelin the area. The RPTs also prepared a " clean area runway" to reduce the potential for contaminating offsite emergency responders and their equipment. Although the RPTs did not perform extensive
severity level Ill Violation with no Civil Penalty was issued on september 22,1995 (EA 95-118).


_ _ _ . _ _ . _ . . _ _ _ -
.
.
.
.
i J. l to prevent this type of problem eroded to the point that the transportation program was significantly degraded. Poor oversight of the radioactive  l material shipping program is significant since this program controls  !
contamination surveys of the CIP, the RPTs indicated that their main concern was to assess the CIP's medical condition and to stabilize his condition. As a result, they treated the CIP as potentially contaminated, communicated this to all other medical responders, and performed further surveys when the CIP was in a stable condition. The RPTs demonstrated good use of contamination control practices while treating the CIP. The RPTs donned gloves while working on the CIP and removing his protective clothing, but the inspector observed that the RPTs did not always change gloves while moving from more to less potentially contaminated articles of protective clothing. Potentially, this practice could have spread contamination to the CIP. In addition, the inspector identified that a security officer, initially responding to the event, potentially contaminated himself when he approached the CIP and assessed the casualty. Since the security officer did not identify that he had been near the CIP, RP personnel did not control or survey this person to ensure that he did not spread contamination at the accident sit The inspector also identified a problem concerning the control of the medical dril As the CIP was removed from the radiologically posted area (RPA), a drill controller indicated to the RPTs and RP supervisor that the individual was not to be removed from the stretcher to enter the personnel contamination monitors (PCMs) (the rout;ne, automated method of personnel survey) but that he was to be surveyed on the stretcher in his medically dressed position. Although the RPTs and RP supervisor were hesitant, they performed a manual survey of the CIP and the stretcher, then accompanied the CIP to the hospital for additional survey Although allowed by licensee procedures, the inspector indicated to the licensee that this was a nonconservative decision. For an actual medical situation, a partial survey and RPT accompaniment would have been appropriate. However, since a medical situation did not exist, not entering a PCM prior to exiting the RPA could have potentially resulted in the unnecessary spread of contamination. The licensee representatives indicated that their original intent was to have the CIP survey through the PCMs and planned to review RPA access and egress requirements for future drill Conclusion    )
radioactive material entering the public domain.   !
The licensee demonstrated good communication and coordination during the December 4,1996 medical ornl. The licensee was effective in minimizing the spread of simulated radioactive contamination, with some exception R5 Staff Training and Qualification in RP&C R 5.1 Radioactive Material and Waste Shloment Trainina l
Therefore. to emphasize the importance of procedural compliance, ai.tention to detail, compliance with technical specifications, compliance with radiation limits, and prompt identification of violations. I have been authorized, -
      ' Scoce (86750. Tl 2515/133)
after consultation with the Director. Office of Enforcement. 'to issue the ,
The inspector reviewed the licensee's training program for personnel involved in the radioactive waste and radioactive material shipping program to ensure personnel involved in the shipping program were adequately instructed in the revisions to 1 10 CFR Part 71 and 49 CFR Parts 172 and 173. The inspector reviewed the following procedures and training lesson plans:
enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice)'  '
in the base amount of $50.000 for the Severity Level III problem.


    -   _ _
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part. to determine whether further enforcement action is  -
^
necessary to ensure compliance with regulatory requirements.


1 ZAP 200-9, " Training," Revision 0; l
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your res' 'se will be placed in the NRC Public Document Room (PDR).
Radioactive Material Shipping, Initial Training, Revision 1;  I Level 11 Radioactive Materials Shipping Training, Fuel Handler / Station Laborer Personnel, Revision 2; and Level 11 Radioactive Materials Shipping Training, Quality Control Personnel, l Revision l I
The inspector also reviewed the training history of those persons who were authorized by the licensee's procedures to release radioactive material shipments.
:
b. Observations and Findinag The inspector observed that the lesson plans for the licensee's Radioactive Material Shipping training was consistent with the April 1996 revisions to 10 CFR 71,49 CFR 172, and 49 CFR 173. The lesson plans contained appropriate instructions concerning the classification of waste for burial and the requirements for packaging and shipping radioactive materials, including the LSA and SCO classification In reviewing the licensee's training records, the inspector identified that two of the seven persons authorized to release / approve shipments of licensed materials were not trained in accordance with ZAP 200-9, which requires biennial radioactive materials shipment training in accordance with NRC IE Bulletin 79-19. IE 79-19 states that individuals are expected to be trained and retrained in the following:
  (1) DOT and NRC regulatory requirements, (2) Waste burial license requirements, and (3) Licensee instructions and operating procedure The inspector verified that the two members of the operations staff were involved in the shipping program and were authorized to release radioactive shipments. In April 1996, the individuals attended the Radioactive Material Shipping training but did not successfully pass the associated exam and had not successfully completed this training since April 1992 and April 1994, respectively. In July 1996, those persons successfully completed the task specific training (Level 11 Radioactive i Materials Shipping Training, Quality Control Personnel) which was limited to instruction on vehicle cnd package inspections and limited regulatory requirements (i.e., radiation levels and placarding). This training did not fully meet the requirements of ZAP 200-9. Neither training course appeared to review the licensee's instructions and operating procedures. Although these individuals were authorized, the licensee indicated that the two operations personnel had not released any shipment TS 6.1.5 requires that retraining and replacement training of station personnel shall be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant Personnel," dated March 8,1971. ANSI N18.1, dated March 8,1971, requires that a continuing program of training be used for training replacement personnel and for retraining necessary to ensure that personnel remain proficient. ZAP 200-09, dated September 17,1992, requires, in part, that personnel, other than stationmen, involved in the transfer, packaging, or transport of radioactive material shall be trained in accordance with IE Bulletin 79-19, and retrained biennially. IE Bulletin


. - - - _ - _ _ - _ ~ - . - . - . - . - - - - - - _ - - . ._ . - . - ~ . - - .
Sincerely
.
.
        !
me.
 
A. Bill Beach Regional Administrator Docket Nos. 50-295: 50-304    i License Nos. DPR-39: DPR-48 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty    I l
l i
l i
See attached distribution l
l
l
'
      :
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 procedures for the transfer, packaging, and transport of radioactive waste. The failure to adequately train personnel in accordance with ZAP 2000-9 is an apparent violation (eel No. 50-295/96021-07(DRS) and 50-304/96021-i 07(DRS)). Conclusion Radioactive material shipping training lesson plans were consistent with the revisions to 10 CFR Part 71 and 49 CFR Parts 172 and 173. An apparent violation was identified concerning the failure to train two operations personnel in '
      !
accordance with procedure R7 Quality Assurance in RP&C Activities R7.1 Self Assessments of Radioactive Material Shionino Activities The inspector reviewed quality assurance audit QAA 22-96-04 " Zion Site Quality Verification Audit of REMP/ODCM/PCP/RW Shipping" conducted on April 15-19, 1996. The site quality verification (SOV) staff reviewed the status of the radiological environmental monitoring program, the liquid and gaseous' effluents program, and the radioactive materials transportation program. The audit concluded that the radioactive shipping program was sound and that radioactive shipments were being performed by qualified personnel using approved procedure Given the fundamental problems identified during this NRC inspection, which  j ranged from worker training and procedural adherence to the shipment of material  l'
      ;
above applical;le limits, the inspector concluded that this audit was not thorough and failed to identify basic problems which existed at the time of the audit. The Quality Assurance Manager indicated that considering a major change to radioactive  i
        '
material transportation regulations had been implemented two weeks prior to the audit, an in-depth review of this program to ensure proper implementation of the new requirements should have been conducte V.- Manaaement Meetinas X1 Exit Meeting Summary      .
On January 22,1997, the inspectors presented the inspection results to licensee management. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie . - . . - - . - - . _- - - - . - . _ - - . - _.


!
PARTIAL LIST OF PERSONS CONTACTED G. Geer, Radioactive Waste Operations M. Hagen, Health Physics R. Krueger, Radioactive Waste Operations
: R. Laburn, Health Physics W. Lacey, Plant General Manager M. Madigan, Site Quality Verification
! L. Menejevs, Site Quality Verification T. Patterson, Operations F. Rescek, Health Physics Support Director G. Schwartz, Site Quality Verification W. Stone, Regulatory Assurance
#
W. Strodi, Health Physics Supervisor
<        ,
INSPECTION PROCEDURES USED lP 83750: Occupational Radiation Exposure IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92904: Followup - Plant Support Tl 2515/133: Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-295/304-96021-01  eel Shipment in excess of 49 CFR 173.425 limits 50-295/304-96021-02  URI Discrepancies between radioactive waste system configuration and UFSAR 50-295/304-96021-03  URI Discrepancies between radioactive waste system operation and UF.SAR 50-295/304-96021-04  eel Failure to maintain radiation control procedures 50-295/304-96021-05(a,b) eel Failure to implement radiation control procedures 50-295/304-96021-06  eel Failure tn irnpfement radiation control procedures 50-295/304-96021-07  eel Failure to train personnei in accordance with ZAP 200-9 Closed Non Discussed Non . _ _ . -
_ _ . _ _ _ . . .,. . . __. _.._ ... _ . . . . _ _ _ _ _ ..
.
.
.
-
LIST OF ACRONYMS USED a
AB Auxiliary Building CA Contaminated Area CCP Centrifugal Charging Pump
'
CDT Chemical Drain Tank CFR Code of Federal Regulations
'
CIP Simulated Contaminated injured Person
! DOT Department of Transportation
!
ECCS Emergency Core Cooling System    l EDT Equipment Drain Tank    )
1 HRA High Radiation Area    '
LDT Lake Discharge Tank
,
LSA Low Specific Activity 1 MREM /HR Millirem per hour l MSV/HR Millisievert per hour PCM Personnel Contamination Monitor PlF Problem identification Form
. RA Radiation Area
'
Radwaste Radioactive Waste RHR Residual Heat Removel I RP Radiation Protectior, l RPA Radiologically Posted Area RPT Radiation Protection Technician RP&C Radiation Protection and Chemistry    !
'
SCO Surface Contaminated Object
-
SG Steam Generator l
        !
        '
St Safety injection
,
SOV Site Quality Verification
+
SRST Spent Resin Storage Tank TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation
      -.
. ~ - - . - . - . - = . . - - -.  -.. - - ... .-.- - .. .- . _ - . . . - - . - . . - . - - - . ~ .
i
*
;
l'
l -
l .
PARTIAL LIST OF DOCUMENTS REVIEWED Engineering Request, "Dumbwalter Shaft Ventilation Barrier" Initial Operability Assessment No. ER9605838 Problem Identification Form (PlF) 96-4677, " Exceeding Dept. of Transportation (DOT)
Limited Quantity Limit"
        ,
PlF 96-4998, " Hot and Cold Lab Vent Delta P" SOI-67D, " Liquid Waste Disposal: Chemical Drain Tank," Revision 3 Temporary Alteration Log Sheet, Attachment A and B, TA-96-075 l-
.
.
!
J. cc w/ encl: T. J. Maiman Senior Vice President Nuclear Operations Division D. A. Sager. Vice President.
s
        ,


Generation Support H. W. Keiser. Chief Nuclear Operating Officer R. Starkey. Plant General Manager R. Godley. Regulatory Assurance Supervisor  ,
I. Johnson. Acting Nuclear Regulatory Services Manager Richard Hubbard Nathan Schloss. Economist '
Office of the Attorney General Mayor. City of Zion State Liaison Officer. Wisconsin State Liaison Officer Chairman. Illinois Commerce >
Commission Document Control Desk-Licensing i
l
    :
i
i
          )
        :


i I
.
I i
.
:
J. DISTRIBUTION:
        !
PUBLIC M SECY CA LCallan. EDO EJordan. DEDO LChandler. OGC JGoldberg. OGC SCollins, NRR RZimmerman. NRR Enforcement Coordinators RI. RII and RIV Resident Inspectors-Zion. Braidwood, and Byron RCapra. NRR CShiraki, NRR JGilliland OPA HBell. OIG GCaputo. 01 LTremper. OC Dross. AE00 OE:ES OE:EA (2)
l    16
GJohnson. OC/DAF RAO:RIII SLO:RIII PAO:RIII OC/LFDCB DRP Docket File
,
}}
}}

Latest revision as of 06:16, 23 June 2020

Discusses Insp Repts 50-295/96-21 & 50-304/96-21 on 961203- 970122 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty for $50,000.Insp Included Review of Plant Program for Transportation of Radioactive Matl
ML20148L642
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 06/17/1997
From: Beach A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Mueller J
COMMONWEALTH EDISON CO.
Shared Package
ML20148L647 List:
References
50-295-96-21, 50-304-96-21, EA-97-048, EA-97-48, NUDOCS 9706190322
Download: ML20148L642 (6)
v • d • e


Text

_ __ _ _ - . ,_ _ .. _ -_ _ _

,

d J* %gg UNITED STATES

. , -

NUCLEAR REGULATORY COMMISSION (

. Ia o REGION !!!

801 WARRENVILLE ROAD k, USLE. ILLINOIS 60532-4351

.

.....

I June 17, 1997 EA 97-048 Mr. J. Site Vice President

Zion Generating Station l Commonwealth Edison Company 101 Shiloh Boulevard Zion, IL 60099 SUBJECT
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - '

$50.000 (NRC ROUTINE RADIATION PROTECTION INSPECTION REPORT 50-29f(/96021(DRS): 50-304/96021(DRS))

b

Dear Mr. Mueller:

! This refers to the inspection conducted from December 3, 1996, through January 1 22. 1997, at your Zion Generating Station Unit 1 and 2 facilities. This

' inspection included a review of Zion's program for transportation of j radioactive material. The written results of this inspection were provided to 1 you on February 11, 1997. A predecisional enforcement conference was conducted on March 19, 1997.

Based on the information develo provided during the conference, the pedNRCduring hasthe inspection determined and that the information violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty, and the circumstances surrounding them are described in detail in the subject inspection report.

The violations involved numerous weaknesses in the transportation of radioactive material program and included: failure to train personnel in accordance with procedures; inadequately maintaining radioactive material shipping procedures: inadequately implementing radiation control procedures:

and exceeding the radiation limits of 49 CFR 173.425 for a shipment of radioactive materials. These violations taken collectively demonstrate an overall programmatic deficiency and are described below.

First, two of the seven workers authorized to release and approve shipments of licensed radioactive materials were not adequately trained in accordance with station procedures. While the workers attended the appropriate training, they

,

'

did not pass the associated examination. In addition, the training offered did not address facility instructions or operating procedures. While failing to train authorized personnel was significant, especially since the applicable regulations were substantially revised on April 1-.1996, the radioactive material shipments were reviewed by trained individuals.

l

/lV PJ "%JER FJ L '%I )

g pg l!l1Hll1HlllllllWllllllllllllllIlll.ll

.... , {

j

.

.

J. '

Second. a number of Zion's radioactive waste and material shipping procedures l were not properly maintained to meet the April 1. 1996, revisions to I applicable transportation regulations. Since a computerized software program was used to accomplish the intent of the procedures Zion's staff deemed these procedures to be obsolete without properly deleting these procedures, and without addressing or documenting the known procedural deficiencies. While not adequately implementing the station process for revising procedures was significant, the instructions in the procedures were not necessary for processing radioactive material shi)ments. The instructions in the procedures were for manual determinations of slipment requirements, but manual determinations were no longer being performed.

Third, certain of Zion's radiological control procedures were not implemented.

On two occasions Zion's staff failed to analyze waste streams annually to determine radionuclide scaling factors as recuired by procedures. In failing to implement these procedures. Zion's staff cid not provide reasonable assurance that the use of scaling factors to determine nuclide activity could ,

be accurately correlated with actual measurements. This issue is significant because incorrect information could have been provided to the radioactive waste burial site as a result of inaccurate radioactivity estimations. It is i unlikely that the difference would have changed the waste classification or I would have exceeded the burial site license, but it is important for these activities to be accurate to ensure that waste is properly segregated and is stable. In addition, on January 8, 1997, operations personnel removed a potentially contaminated rod from a posted contaminated area without complying with procedural requirements to contain the rod or to have the rod released by a radiation protection technician. This particular event was not radiologically significant, but improperly removing contaminated items increases the potential of contaminating clean areas and personnel. This event was indicative of the ongoing problems with radiation worker practices at the station. ,

Finally, problems were observed concerning the December 9.1996, limited quantity shipment of radioactive material to the Byron Nuclear Station. The Byron staff identified dose rates in excess of the Department of Transportation's (DOT) contact radiation limits for a limited quantity shipment. The original radiological survey of this shipment. conducted by Zion's staff, clearly indicated that the dose rates exceeded the limit of 0.5 millirem per hour. However, the dose rates were incorrectly documented on the shipping papers. These shipping papers had been reviewed by four members of Zion's staff without this error being identified. This issue is not radiologically significant. due to the low dose rates on the package: however, the issue is of regulatory significance because the classification allowed the shipment to be excepted from additional DOT requirements.

While individually each of these issues would not constitute a matter of high safety significance. collectively, these issues are significant because they indicate inadequate implementation and a lack of oversight of the program. We are particularly concerned that problems were identified in virtually every phase of the program. Additionally, an April 1996 audit conducted by Zion's

-

. . - .- __ - -

,

e J. staff in this area lacked the depth and thoroughness necessary to identify the fundamental program weaknesses. Lack of an effective audit in this area was particularly noteworthy given that a major change to the applicable trans)ortation regulations was made effective April 1,1996. Coupled with the poor listory in radiation protection performance over the past 12 months (violations have been identified concerning inadequate posting of radiol,ogical hazards, inadequate contamination control practices, inadequate procedures to control radiation monitors. and failure to perform compensatory actions for inoperable radiation monitors), these issues indicate a breakdown in this program and weaknesses in the ability to perform adequate self assessments.

Therefore, these violations are classified in the aggregate in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy). NUREG-1600, as a Severity Level III problem, t In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem. Because your facility has been the subject of escalated enforcement actions within the last 2 years.1 the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil Senalty assessment process in Section VI.B 2 of the Enforcement Policy. The N1C determined that no credit for Identification was warranted because this problem was identified by the NRC during a routine inspection, and not identified through Commonwealth Edison Company's self assessment process. The NRC determined that credit for Corrective Action was warranted because corrective actions were timely and thorough. Once these issues were brought to the attention of facility management, all shipments of radioactive material were suspended, and the I assistance of the corporate subject matter expert was obtained. Training was  !

l completed for appropriate personnel, and the training process was enhanced.

All outdated procedures were deleted, and procedural rebaselining was initiated. Considerable efforts were implemented to improve the waste stream

! analysis process through procedural revisions and additional training, and an l emphasis was placed on complying with radiation control procedures. Finally.

l more descriptive guidelines and expectations were created for the approval of, radioactive material shipments.

While your corrective actions were thorough, the initial audit of the l

radioactive material program was superficial and identified none of the above

'

weaknesses. It is imperative that Commonwealth Edison Company can rely on self assessments to identify program deficiencies, and not depend solely on

personnel rationalizations to supersede inadequate procedures to ensure the program is adequately implemented. The administrative barriers l

l i

A severity Level 111 Problem with a $100,000 Civil Penalty was issued on March 12,1997 (EA 96-355); a severity Level Ill Violation with a $50,000 Civil Penalty was issued on August 23,1996 (EA 96-216); a

-

severity Level til Violation with a $50,000 Civil Penalty was issued on February 21,1996 (EA 95-283); a severity Level !!! Violation with a $50,000 Civil Penalty was issued on November 28,1995 (EA 95-144); and a !

severity level Ill Violation with no Civil Penalty was issued on september 22,1995 (EA 95-118).

_ _ _ . _ _ . _ . . _ _ _ -

.

.

i J. l to prevent this type of problem eroded to the point that the transportation program was significantly degraded. Poor oversight of the radioactive l material shipping program is significant since this program controls  !

radioactive material entering the public domain.  !

Therefore. to emphasize the importance of procedural compliance, ai.tention to detail, compliance with technical specifications, compliance with radiation limits, and prompt identification of violations. I have been authorized, -

after consultation with the Director. Office of Enforcement. 'to issue the ,

enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice)' '

in the base amount of $50.000 for the Severity Level III problem.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part. to determine whether further enforcement action is -

necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your res' 'se will be placed in the NRC Public Document Room (PDR).

Sincerely

.

me.

A. Bill Beach Regional Administrator Docket Nos. 50-295: 50-304 i License Nos. DPR-39: DPR-48 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty I l

l i

See attached distribution l

l

!

.

J. cc w/ encl: T. J. Maiman Senior Vice President Nuclear Operations Division D. A. Sager. Vice President.

Generation Support H. W. Keiser. Chief Nuclear Operating Officer R. Starkey. Plant General Manager R. Godley. Regulatory Assurance Supervisor ,

I. Johnson. Acting Nuclear Regulatory Services Manager Richard Hubbard Nathan Schloss. Economist '

Office of the Attorney General Mayor. City of Zion State Liaison Officer. Wisconsin State Liaison Officer Chairman. Illinois Commerce >

Commission Document Control Desk-Licensing i

l

i

.

.

J. DISTRIBUTION:

PUBLIC M SECY CA LCallan. EDO EJordan. DEDO LChandler. OGC JGoldberg. OGC SCollins, NRR RZimmerman. NRR Enforcement Coordinators RI. RII and RIV Resident Inspectors-Zion. Braidwood, and Byron RCapra. NRR CShiraki, NRR JGilliland OPA HBell. OIG GCaputo. 01 LTremper. OC Dross. AE00 OE:ES OE:EA (2)

GJohnson. OC/DAF RAO:RIII SLO:RIII PAO:RIII OC/LFDCB DRP Docket File

,

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000295/1996021&oldid=2846011"