IR 05000295/1996006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-295/96-06 & 50-304/96-06

ML20138J619
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/04/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mueller J COMMONWEALTH EDISON CO.
References
NUDOCS 9702070389
Download: ML20138J619 (2)

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February 4, 1997 Mr. J. Site Vice President Zion Generating Station Commonwealth Edison Company 101 Shiloh Boulevard Zion, IL 60099 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-295/

96016(DRS): 50-304/96016(DRS))

Dear Mr. Mueller:

This will acknowledge receipt of your letter dated December 20,1996, in response to our letter dated November 21,1996, transmitting a Notice of Violation associated with the failure to take required actions for inoperable radiation monitors at the Zion Nuclear Power Station Units 1 and 2. We have reviewed your corrective actions and have no further questions at this time.

These corrective actions will be examined during future inspections.

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Sincerely, Original Signed by Melvyn Leach Geoffrey E. Grant, Director Division of Reactor Safety Docket Nos. 50-295; 50-304 l Licenses No. DPR-39; DPR-48 Enclosure: Ltr 12/20/96 J. Comed (Zion) to USNRC i

Eee Attached Distribution 070047 DOCUMENT NAME:G:DRS\ZIOO1017.DRS To ,eceive a copy of this document, k.dicate in the box: "C" = Copy without ettechment/ enclosure 'E" = Copy with attachment /enclosurs

'N' = No copy 0FFICE lRIII lE RIII , lrJllilK / RIII lv NAME '50rth:jp 6 W TKozak @ ' MDapas X MLeach/GGran M DATE 01/23 /97 01/eA /97 011 / /97 \ ~

03/ og97 0FTICIAL RECORD COPY 7 O\

9702070389 970204 k PDR ADCCK 05000295 G PDR

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J. February 4,1997 cc w/o encl: T. J. Maiman, Senior Vice President, j Nuclear Operations Division l D. A. Sager, Vice President, l Generation Support i i

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H. W. Keiser, Chief Nuclear Operating Officer

. G. K. Schwartz, Station Mana0er W. Stone, Ref,ulatory Assurance

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Supervisor 1 l. Johnson, Acting Nuclear .

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Regulatory Services Manager  !

cc w/ encl: Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General ,

Mayor, City of Zion l State Liaison Officer, Wisconsin i State Liaison Officer l Chairman, Illinois Commerce Commission l Distribution:

Docket File w/ encl SRis, Zion, Braidwood, Enf. Coordinator, Rlli w/o encl PUBLIC IE-01 w/ encl Byron w/o encl R. A. Capra, NRR w/o encl OC/LFDCB w/o encI G. E. Grant, Rlll w/o encl CAA1 (e-mail)

DRP w/o enct LPM, NRR w/o enci W. L. Axelson, Rlll w/o encl i DRS w/o enct A. B. Beach, Rill w/o enci

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December 20,1996 U. S. Nuclear Regulatory Commission

. Washington, D.C. 20555 Attention: Document Control Desk Subject: Commonwealth Edison Reply to Notice of Violations in NRC Inspection Report Number 50-295/304-96016; Zion Nuclear Power Station Units I and 2; NRC Docket Numbers 50-295 and 50-304 Reference: G. E. Grant letter to J. dated November 21,1996 Attached is the Commonwealth Edison (Comed) response to the Notice of Violations (NOV)

transmitted by the referenced letter and discussed in the subject inspection report. The NOV cited four severity level IV violations, with one violation containing two examples. One of

the violations concerned an event where an individual alarmed a radiation detection device, l

failed to notify radiation protection personnel, and removed the contamination. As noted in l

the subject inspection repon, actions taken by Comed were adequate for this event and a l response to this violation is not required.

The poor performance of the radiation monitoring system was a major contributing cause to three of the violations discussed in the subject inspection report. Our goal is to establish a much more reliable system, so as to reduce our risk of missing required surveillances by not requiring the Zion staff to continuously enter LCOs. An action plan to improve the performance of the radiation monitoring system at Zion Station is included in Attachment C of this letter. I feel that the actions described in Attachment C of this letter will improve the long standing problems with the radiation monitoring systems.

Corrective actions to address the specific root causes associated with the violations are discussed in attachment A of this letter. ,

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If you have any questions or require additional information, please contact Mr. Dennis Farrar, _;

Regulatory Assurance Manager, at (847) 746-2084, extension 3353.  ;

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Sincerely,

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J. Site Vice President Zion Station

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i Attachment A: Response to the Notice of Violations Attachment B: Summary of Commitments Attachment C: Radiation Monitor Improvement Plan I

cc: A. B. Beach, Regional Administrator, Region III I

C. Y. Shiraki, Zion Project Manager, NRR l

Acting Senior Resident Inspector, Zion Station J Office of Nuclear Facility Safety - IDNS

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ATI'ACllMENT A Notice of Violation llesponse J

VIOLATION: 50-295(304)-96016-03 During an NRC inspection conducted from September 23 - October 24,1996, violations of NRC requirements were identined. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 3.13.3.C. requires that the radiation monitors which isolate the containment vent and purge system be operable during core alterations.

Contrary to the above, on September 24,1995, radiation monitors which isolate containment vent and purge system were inoperable during core alterations.

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

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REASONS FOlt TIIE VIOLATION Comed acknowledges the violation. The reason for the violation was personnel error.

Upon returning the Unit 1 Containment System Particulate lodine and Noble Gas monitor (SPING) to service after a particulate filter change out, a radiation protection technician (RPT) failed to recognize and respond appropriately to the SPING's local " external fail" I

fiashing beacon. Consequently, the RPT left the Unit 1 Containment SPING in a failed

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condition. '

l A contributing cause to this violation was a work practice deficiency during installation of the l particulate filter paper. The method used to remove the new filter paper from its packaging container most probably creased the center of the new filter paper, thereby weakening the paper. Consequently, the .; ample Eow broke the filter paper apart creating the high flow failure condition.

Another contributing cause to this violation was the method of control room annunciation provided by the control room SPING console. For this type of external fail condition, the control room SPING console does not require that the alarm signal be acknowledged by operating personnel. Control room indication for this type of failure includes a two second audible alarm from the SPING console and a printout on the control room SPING tape. Any subsequent message advances the SPING tape, removing the external fail message from view.

The current audible alarm can actuate and be masked by the normal control room noise.

Consequently, control rcom operators were not aware of the SPING failure during this event.

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ATTACllMENT A Notice of Violation Response A final third contributing element in this violation was inadequate control of the purging process by the relevant effluent release procedure ZRP 6021-33, " Documentation of ,

Containment Radioactive Release." The procedure did not provide adequate direction to ensure the requirements for purging are re-verified every time a purge is restarted after a temporary stoppage (in this event, the purge was stopped temporarily for filter change out).

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACIHEVED The individual radiation protection technician was counseled by the Health Physics Supervisor concerning his performance during this event, and he now understands management expectations for returning the SPINGs to service.

Radiation protection technicians were trained on the proper method of handling SPING particulate filter paper and the potential performance consequences if the filter paper is damaged.

Continuing radiation protection technician training for 1996 included additional training on the SPING radiation monitoring system.

The effluent release form (from procedure ZRP 6021-33), authorizing and guiding Operations performance of the contaimnent release, was revised instructing operators to re-verify rad monitor operability requirements anytime a purge is terminated then restarted.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Design changes (E22-1(2)-96-202) have been issued to modify the Eberline SPING console in the control room to orovide a continuous instrument fail alarm with a push-to-acknowledge function. This ad; .:ature will improve operator awareness of a failed SPING radiation monitor and assure timeliness of operator response. Installation of this change will be completed by August 30,1997, or earlier based on parts availability.

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ATTACilMENT A t j ~

. Notice of Violation Response  !

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j in the interim, the SPING monitor counsel will be checked during operator rounds every 2

hours (which is the most limiting action time requirement in the Technical Specifications for

SPING monitor inoperability) to ensure that the monitors are in an operable status. The -

i required procedure changes and training to accomplish this will be completed by January 17,

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l DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED '

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i Zion Station is currently in full compliance. '

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. ATTACHMENT A Notice of Violation Response i

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VIOLATION: 50-295(304)-96016-04

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During an NRC inspection conducted from September 23 - October 24.1996, violations of

NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

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Technical' Specification 3.14 requires that radiation monitoring equipment shown in i

Table 3.14-1 be operable and, with one or more of the channels inoperable, that the  ;

j action shown in Table 3.14-1 be implemented. I

Action 26 of Table 3.14-1 requires that a grab sample analysis be performed at least once per shift when radiation monitor OR-PR07 has less than 1 operable channel.

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Contrary to the above, on July 5,1996, grab samples were not obtained and analyzed

once per shift when monitor OR-PR07 was inoperable.

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

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i l REASONS FOR THE VIOLATION

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j' Comed acknowledges the Violation. The reason for the violation is the result of a management deficiency. The Operating Department inappropriately delegated LCO monitoring responsibilities to other departments. In addition, Zion Radiation Protection '

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Procedure (ZRP) 5820-12 "Out-of-Service Surveillance for Radiation Monitors," incorrectly j

applied Technical Specification (TS) 4.0.2 (the 25% grace period) to compensatory action

statements. Consequently, Chemistry personnel believed that the LCO of 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> i + 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />)'was allowed to obtain and analyze the samples. However, this did not meet the

once per shift TS action statement requirement which at Zion is considered to be once per 12

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ATTACilMENT A Notice of Violation Response l

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CORRECTIVE STEPS TIIAT llAVE HEEN TAKEN AND RESULTS ACI.llEVED Procedure ZRP 5820-12, " Out-of-Service Surveillance for Radiation Monitors," was revised to clarify that Technical Specification 4.0.2 does not apply to LCO compensatory action statements. The incident and procedure change were reviewed with station Radiation Protection personnel.

It was verified through a review performed on other Radiation Protection and Chemistry procedures that Technical Specification 4.0.2 was not incorrectly applied to compensatory

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Station Chemistry personnel were trained on the revised procedure ZRP 5820-12 during the continuing training cycle completed in November of 1996. The fact that Technical Specification 4.0.2, which covers surveillance grace periods, is not applicable to action statements was also discussed.

To ensure LCO time clocks are being met on radiation monitors, the Radiation Protection Department issued a standing order (96-016) to notify the respective Operations Unit

Supervisor after completion of any required compensatory action requirements on radiation '

monitors.

DATE WiiEN FULL COMPLIANCE WILL BE ACIIIEVED Zion Station is currently in full compliance.

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ATTACllMENT A Notice of Violation Response

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VIOLATION: 50-295(304)-96016-05A&B

l J I During an NRC inspection conducted from September 23 through Octcber 24,1996, j j

. violations of NRC requirements were identified. In accordance with the " General Statement

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of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed

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j Technical Specification 6.2.6.A requires, in part, that a program to control radioactive j

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effluents which conforus to 10 CFR 50.36(a) and is contained in the Offsite Dose -

Calculation Manual (OL'CM) shall be implemented and maintained.

, ODCM 12.2.2 requires that radioactive gaseous effluent monitor equipment shown in j

Table 12.2-3 be operable and, with one or more of the channels inoperable, that the action shown in Table 12.2-3 be implemented.

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i Action 6 of Table 12.2-3 requires, in part, that grab samples be obtained at least once

per shift and analyzed for gross activity within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when radiation monitor 1RE-0015 or radiation monitor 2RT-PR25 have less than 1 operable channel.

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j Contrary to the above, the licensee failed to obtain required samples at least once per

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shift and analyze for gross activity as evidenced by the following examples: l

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a. On July 26,1996, grab samples were not obtained and analyzed as required,

when monitor 1RE-0015 was inoperable.

[ b. On September 22-25,1996, grab samples were not obtained and analyzed as j required, when monitor 2RT-PR25 was inoperable.

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

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ATTACilMENT A Notice of Violation Response REASONS FOR TIIE VIOLATION

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Violation Example A: .

Comed acknowledges the violation. The reason for the violation was personnel error. A Radiation Protection Technician and Radiation Protection Supervisor failed to ensure that all of the required samples for out-of-service (OOS) radiation monitors had been obtained.

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. Violation Example B: '

. Comed acknowledges the violation. The reason for the violation was personnel error.

The weekly surveillance procedure, PT-0 Appendix Y, indicated that radiation monitor 2RT-PR25's belt had come off and that an AR had been written. Upon review of the PT-0 the Licensed Shift Supervisor (LSS) did not initiate a PT-14 or notify Radiation Protection to obtain shiftly grab samples because the LSS made an erroneous assumption that the AR represented a previously identified problem.

A contributing cause to this violation is that no verbal communication occurred between the Equip' ment Attendant (EA) that performed the surveillance and the LSS. The EA noted in the margin of the checklist for PT-0 that the monitor pump belt was disconnected and that he generated an AR, but did not note that information in the comments section of PT-0 and did not verbally communicate that information to the LSS.

A second contributing cause to this violation was the failure of the Radiation Monitor Display System (RMDS) annunciator to alarm despite zero flow through the monitor. The RMDS display system is the primary method Operating uses to identify radiation monitor failures.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Violation Example A:

The Radiation Protection Technician and Radiation Protection Supervisor were individually counseled by the Lead Operational Health Physicist concerning their performance during this event so as to ensure they understand enanagement expectations for obtaining grab samples as

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ATTACllMENT A Notice of Violation Response l

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j required by the ODCM.

.! The circumstances surrounding this event were reviewed with Radiation Protection Department -

i personnel to emphasize the importance of the self check philosophy and the potential j consequences if insufficient attention to detail is applied.

Violation Example B

f A work request was written (960095088) to repair the RMDS annunciator for radiation monitor i

2RT-PR25. This repair was completed on October 19,1996.

This event was reviewed with the LSS and EA involved in the event to reinforce management expectations for face-to-face communication and proper review of pts to verify all applicable acceptance criteria have been met. In addition, the Operations Manager covered this event with all operations personnel and stressed his expectations for face to face communications when-equipment deficiencies are identified.

The Operations Manager removed the Shift Engineers and Licensed Shift Supervisors involved in the event from shift duties until they could investigate and determine appropriate corrective actions to prevent recurrence. As a result, the following corrective actions were determined:

LCO status is now discussed at the plan of the day meeting, a letter was issued to the Shift Engineers to reiterate the face to face communication expectations when out-of-spec conditions are discovered, and requirements were reinforced with the Nuclear Station Operators in regards to logging LCO's in effect.

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I DATE WHEN FULL COMPLIANCE WILL BE ACil:EVED Zion Station is currently in full compliance. l

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ATTACilMENT 11 Summary of Commitments identified in this Violation Response:

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The SPING monitor counsel will be checked during operator rounds every 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (which is the l

most limiting action time requirement in the Technical SpeciGcations for SPING monitor '

inoperability) to ensure that the monitors are in an operable status. The required procedure changes and training to accomplish this will be completed by January 17.1997.

See Attachment C for commitments identi6ed in the Radiation Monitoring System Improvement Action Plan. l

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ATTACIIMENT C a

j Action Plan to improve Performance of Radiation Monitorine System:

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The following action plan provides details of the actions taken to date and those in progress.

Completion of this plan will ensure improved performance of Zion's radiation monitoring  ;

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Problems Experienced:

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Zion's radiation monitoring system has experienced excessive failures which have directly or indirectly resulted in a high number of radiation monitor equipment unavailability, missed surveillances and Licensee Event Reports. Radiation monitor problems include, but are not limited to; broken blower belts, leaking oil from blowers, failed check source mechanisms, failed electronics, inadequate alarming capabilities, obsolete parts and radiation detector failures. These problems can be categorized into four major areas:

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• Air regulation / sampling system failures

• Check source failures

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• Failure of aging or obsolete equipment

• SPING alarm deficiencies l

A. Radiation Monitor Abandonment An overall review of the radiation monitoring system has been initiated to abandon unnecessary radiation manitors. Prior to this year, Zion Station had approximately thirty area radiation monitors and sixty-nine process radiation monitors supplied by four different vendors. The original design of the Zion Station radiation monitoring system resulted in radiation monitoring capability in excess of what is required today. Specifically, several monitors are redundant to existing monitors, serve equipment / areas which are no longer considered a radiation source, and may not be required.

To date, six monitors have been abandoned. Titree additional monitors have been reviewed and approved for abandonment after implementation of the Improved Technical Specifications.

Approximately thiny additional monitors are being reviewed as candidates for abandonment. An engineering analysis of these thirty monitors will be completed by June 1,1997.

B. Air Regulation / Sampling System Failures Gaseous radiation monitors manufactured by Nuclear Measurement Corporation (NMC)

esperience a high failure rate. These monitors sample via an air regulation system consisting of a blower, belt, motor, magnehelic flow switch, motor operated valve and a flow control circuit i

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[ ATTACilMENT C

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b'oard, all of which have experienced a high failure rate.

! Of these 26 NMC monitors,16 are candidates for abandonment and will be addressed through actions of item A. For the remaining ten process monitors, design changes have been issued to

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[' replace the air regulation system with a simpler system consisting of more reliable components.

This design change has been performed for one Unit I monitor. The Unit 2 monitors (total of l i 4) were modified during the current refueling outage (Z2R14). The remaining five Unit 1 '

! monitors will be completed prior to startup from the next Unit I refueling outage (ZlRIS,

, currently scheduled for April 5,1997 thru May 24,1997).

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1 l C. Control Room Ratemeter Module Replacement s

! The electronics in the NMC control room ratemeter modules have a high failure rate and some

of the internal parts, such as transistors, are obsolete.

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A replacement module supplied by NMC was recently successfully installed for one monitor at i Zion. We are currently evaluating long term performance of this module. In addition, a second j

vendor has also been contacted regarding possible replacement modules. We expect to complete

] our evaluation for the selection of appropriate replacement modules and initiate design changes j for installation prior to startup from the 1998 refueling outages.

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j D. SPING Push to Acknowledge Capability i.

Operator awareness of a failed SPING radiation monitor along with positive action in response to an alarm is needed.

Design changes have been issued to modify the Eberline SPING console in the control room to provide a continuous instrument fail alarm with a push-to-acknowledge function. Installation of this change will be completed by August 30,1997.

E. SPING Nuisance Alarms

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The current radiation monitor sample period is sufficiently short such that normal minimal counts seen by an operating monitor is frequently flagged as an instrument fait condition. These are nuisance alarms in the main control room.

Design changes have been issued to increase the sample period for the " low counts" input from each SPING monitor to the instrument fail alarm in the main control room SPING console.

Along with Item D above, this change will focus operator attention on actual problems il

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NITACilMENT C associated with the SPING radiation monitors. The design change is scheduled to be installed by !

March 31,1997.

F. Check Source Failure Prevention Excessive use of the check source mechanisms associated with the radiation monitors have contributed to their failure.

l A daily check source test is currentiy performed on radiation monitors. System Engineering will l evaluate the check source testing frequencies to determine if the interval of testing can be increased. This evaluation will be completed by March 1,1997. If it is determined that the frequencies can be incrcased, the applicable pr ,: dure changes will be implemented by March 31,1997.

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Additional Corrective Actions Planned:

A self assessment of the radiation monitoring systern will be performed in 1997 to evaluate the

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effectiveness of the corrective actions :. ten and determine additional actions necessary to further improve the overall system performa.:ce. This self assessment will be completed by April 5, {

1997.

Conclusion:

These corrective actions will improve the material condition of the radiation monitor syrtem.

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