ML20138G553

Responds to NRC 961121 Ltr Re Violations Noted in Insp Repts 50-295/96-16 & 50-304/96-16.Corrective Actions:Individual Radiation Protection Technician Was Counseled by Health Physics Supervisor

ML20138G553
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	12/20/1996
From:	Mueller J COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9612270075
Download: ML20138G553 (14)

Text

, Commonwraith rAlison Gimpany Zion Generating Station

,' 101 Shiloh Ik>ulevard Zion,11. G NW2797 Tel 8 67-76208 i 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 1 and 2; NRC Docket Numbers 50-295 and 50-304

Reference:

G. E. Grant letter to J. H. Mueller dated November 21,1996

. Attached is the Commonwealth Edison (Comed) respoase 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, failed to notify radiation protection personnel, and removed the contamination. As noted in the subject inspection report, actions taken by Comed were adequate for this event and a response to this violation is not required.

The poor performance of the radiation monitoring system was a major cont'ibuting 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.

I 9612270075 961220 n '

I PDR G

ADOCK 05000295 PDR dh L/

s-I (

I 0?)!)Q l A t nimm o mpan>

[

.- .. 7 If you have any questions or require additional information, please contact Mr. Dennis Farrar, Regulatory Assurance Manager, at (847) 746-2084, extension 3353.  !

g

~

Sincerely.

l\\l j J. H. Mueller Site Vice President

Zion Station  ;

i i

I i

r i

l Attachment A: - Response to the Notice of Violations j Attachment B: Summary of Commitments  !

Attachment C: Radiation Monitor Improvement Plan cc: A. B. Beach, Regional Administrator, Region 111 1 C. Y. Shiraki, Zion Project Manager, NRR Acting Senior Resident Inspector, Zion Station Office of Nuclear Facility Safety - IDNS -

i l 2

_ - - - . . - .-. - . - - . . - . . - - - - - ~ - _ ~ ~ . - - . . - . . _-

1 i

. I

+

l i

i

, ATTACHMENT A i

. Notice of Violation Response  !

l t j VIOLATION: 50-295(304)-96016 03 '

1 j During an NRC inspection conducted from September 23 - October 24,1996, violations of i NRC requirements were identified. In accordance with the " General Statement of Policy and

l Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below

;

I i Technical Specification 3.13.3.C. requires that the radiation monitors which isolate the  !

l containment vent and purge system be operable during core alterations. I j Contrary to the above, on September 24,1995, radiation monitors wHeh isolate

, containment vent and purge system were inoperable during core alterations.

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

, REASONS FOR THE VIOLATION j Comed acknowledges the violation. The reason for the violation was personnel error.

Upon returning the Unit 1 Containment System Particulate lodine and Noble Gas monitcc

{ (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" j flashing beacon. Consequently, the RPT left the Unit 1 Containment SPING in a failed

! condition.

i A contributing cause to this violation was a work practice deficiency during installation of the  !

4 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 sample flow broke the filter paper apart creating the high flow l failure condition.

i 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 e.rm signal be acknowledged by i 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 I 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 room operators were not aware of the SPING failure during this event.

I i

j l 1 1

J l l

l I

ATTACIIMENT A Notice of Violation Response l

1 4

l A final third contributing element in this violation was inadequate control of the purging l process by the relevant effluent release procedure ZRP 6021-33, " Documentation of Containment Radioactive Release." The proceaure did not provide adequate direction to l ensure the requirements for purging are re-verified every time a purge is restarted after a i temporary stoppage (in this event, the purge was stopped temporarily for filter change out).

a CORRECTIVE STEPS TIIAT IIAVE BEEN TAKEN AND RESULTS ACillEVED i.

The individual radiation protection technician was counseled by the IIealth 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 l j particulate filter paper and the potential performance consequences if the filter paper is i damaged.  !

l

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

The effluent release form (from procedure ZRP 6021-33), authorizing and guiding Operations i performance of the containment release, was revised instructing operators to re-verify rad i 3 monitor operability requirements anytime a purge is terminated then restarted.

CORRECTIVE STEPS TIIAT WILL HE TAKEN TO AVOID FURTilER VIOLATIONS Design changes (E22-1(2)-96-202) 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. This added feature 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.

2-4

_ . . _ _ _ _ . - . _ _ . _ . ~ . . . . _ . . ......_._ _ _ _ _ . _ . _ _ . . _ . . _ _ _ _ . - . . . _ . _ . . . . _ _ _ _ _ . . _ _ _ _ . _ _ _ _ . . _ _ _ _ ~ _

4

- r 3

I i

ATTACHMENT A Notice of Violation Response  !

1 i

i J .l 1

4  !

i i -l l

j in the interim, the SPING monitor counsel will be checked during operator rounds every 2 i i hours (which is the most limiting action time requirement in the Technical Specifications for. i 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, i i 1997, 1

3 4

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I.

i Zion Station is currently in full compliance.

1

\

l i

i e

i 7

6 i

i i

l 4

4 i

i

. 3 iv.-., -.r= >>---:*?-,< a q - . + - - - ---m--gm---m-t+-s -t- + n--- r -

r- --

. _ _ . . . - - _ _ _ _ _ . . - _ _ _ _ - . - _ _._ _ _-. . - - . - - _ . . ~

l 4

• 1 l ATTACIIMENT A Notice of Violation Response j r

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

l During an NRC inspection conducted from September 23 - October 24,1996, violations of l NRC requirements were identiDed. In accordance with the " General Statement of Policy and i Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below Technical SpeciGcation 3.14 requires that radiation monitoring equipment shown in ,

- Table 3.14-1 be operable and, with one or more of the channels inoperable, that the 1 action shown in Table 3.14-1 be implemented. 1 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.

Contrary to the above, on July 5,1996, grab samples were not obtained and analyzed once per shift when monitor OR-PR07 was inoperable.

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

REASONS FOR THE VIOLATION '

Comed acknowledges the Violation. The reason for the violation is the result of a management denciency. The Operating Department inappropriately delegated LCO monitoring responsibilities to other departments. In addition, Zion Radiation Protection Procedure (ZRP) 5820-12 "Out-of-Service Surveillance for Radiation Monitors," incorrectly applied Technical Speci6 cation (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 />

+ 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) was allowed to -,btain 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 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

4

9 r

ATTACllMENT A r Notice of Violation Response CORRECTIVE STEPS THAT HAVE HEEN TAKEN AND RESULTS ACIIIEVED Procedure ZRP 5820-12, " Out-of-Service Surveillance for Radiation Monitors," was revised l to clarify that Technical Speci6 cation 4.0.2 does not apply to LCO compensatory action i statements. The incident and procedure change were reviewed with station Radiation i Protection personnel.

l It was verined through a review performed on other Radiation Protection and Chemistry I I

procedures that Technical Speci6 cation 4.0.2 was not incorrectly applied to compensatory action statements.

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 Speci6 cation 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 WHEN FULL COMPLIANCE WILL HE ACIIIEVED Zion Station is currently in full compliance. j l

i l

l 5

1

ATTACIIMENT A Notice of Violation Response VIOLATION: 50-295(304)-96016-05A&B During an NRC inspection conducted from September 23 through October 24,1996, violations of NRC requirements were identified. In accordance with the " General Statement l of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 6.2.6.A requires, in part, that a program to control radioactive effluents which conforms to 10 CFR 50.3a) and is contained in the Offsite Dose Calculation Manual (ODCM) shall be imp;emented and maintained.

ODCM 12.2.2 requires that radioactive gaseous effluent monitor equipment shown in Table 12.2-3 be operable and, with one or more of the channels ine:erable, that the l

action shown in Table 12.2-3 be implemented. '

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.

Contrary to the above, the licensee failed to obtain required samples at least once per shift and analyze for gross activity as evidenced by the following examples- I l'

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 l required, when monitor 2RT-PR25 was inoperable.

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

l l

6

ATTACIIMENT A Notice of Violation Response

?

1 )

REASONS FOR TIIE VIOLATION  ;

i 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.

Viobion 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 l

obtain shiftly grab samples because the LSS made an erroneous assumption that the AR 1 represented a previously identified problem.

A contributing cause to this violation is that no verbal communication occurred between the Equipment 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 TIIAT IIAVE HEEN TAKEN AND RESULTS ACIIIEVED

~

Violation Example A:

i The Radiation Protection Technician and Radiation Protection Supervisor were individually counseled by the Lead Operational llealth Physicist concerning their performance during this

event so as to ensure they understand management expectations for obtaining grab samples as 7

. - _ - . . . . ~ - . .. .-. -. . . . - - . . _ - - - - . - _ . . - . - .

. f ATI'ACHMENT A Notice of Violation Response '

i i

l required by the ODCM.

The circumstaces surrounding this event were reviewed with Radiation Protection Department . ,

personnel to e nphasize the importance of the self check philosophy and the potential  :

consequences finsufficient attention to detail is applied.

Violation Example B:

A work request was written (960095088) to repair the RMDS annunciator for radiation monitor 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 cr'teria 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 stams is, now discussed at the plan of the day meeting, a letter was issued to the Shift Engineers to reiterat,: 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.

I DATE WHEN FULL COMPLIANCE WILL HE ACHIEVED Zion Station is currently in full compliance.

l i

8 I

1

. 1 l

l l

ATTACHMENT B l l

Summary of Commitments identified in this Violation Response: l l

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 j most limiting action time requirement in the Technical Specifications for SPING monitor 1 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.  ;

i See Attachment C for commitments identified in the Radiation Monitoring System Improvement i Action Plan.

1

- t ATTACIIMENT C Action Plan to Improve Performance of Radiation Monitorine System:

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 system.

Problems Experienced: )

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:

• Air regulation / sampling system failures

• Check source failures

• Failure of aging or obsolete equipment l

• SPING alarm deficiencies A. Radiation Monitor Abandonment An overall review of the radiation monitoring system has been initiated to abandon unnecessary radiation monitors. 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 l may not be required.

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

Approximately thirty additional monitors are b:ing 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) experience 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

i ATTACHMENT C board, 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 ofitem A. For the remaining ten process monitors, design changes have been issued to replace the air regulation system with a simpler system consisting of more reliable components.

This design change has been performed for one Unit 1 monitor. The Unit 2 monitors (total of

4) were modified during the current refueling outage (Z2R14). The remaining five Unit 1 l monitors will be completed prior to startup from the next Unit I refueling outage (ZlR15, currently scheduled for April 5,1997 thru May 24,1997).

C. Control Room Ratemeter Module Replacement 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.

A replacement module supplied by NMC was recently successfully installed for one monitor at Zion. We are currently evaluating long term performance of this module. In addition, a second 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 for installation prior to startup from the 1998 refueling outages. l l

D. SPING Push to Acknowledge Capability 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 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 fail condition. These are nuisance alarms in the main control room.

1 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 2

ATTACIIMENT C associated with the SPING radiation monitors. The design change is scheduled to be installed by March 31,1997.

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

J A daily check source test is currently performed on radiation monitors. System Engineering will 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. Ifit is determined that the ,

frequencies can be increased, the applicable procedure changes will be implemented by March l

.51, 1997.

1 Additional Corrective Actions Planned: 1 A self assessment of the radiation monitoring system will be performed in 1997 to evaluate the effectiveness of the corrective actions taken and determine additional actions necessary to further !

improve the overall system performance. This self assessment will be completed by April 5, l 1997.

I

Conclusion:

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

l i

l l

3 i