ML20126J234
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| ML20126J234 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/29/1992 |
| From: | Kozak T, Louden P, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20126J206 | List: |
| References | |
| 50-295-92-34, 50-304-92-34, NUDOCS 9301060091 | |
| Download: ML20126J234 (7) | |
See also: IR 05000295/1992034
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O.S. NUCLEAR REGULATORY COMMISSION
REGION 111
Reports No. 50-295/92034(DRSS); 50-304/92034(DRSS)
Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48
Licensee: Commonwealth Edison Company
Opus West til
1400 Opus Place
Downers Grove, IL 60515
Facility Name: Zion Nuclear Generating Station, Units I and 2
Inspection At: Zion Station, Zion, Illinois
Inspection Conducted: December 7 through 11, 1992
Inspectors:
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~P. L. Louden Date /
Radiation Specialist
t r.[s /5y
T. J. Koiak Date
Senior Radiation Specialist
Approved By: dbCOO
R[[liam
fl Snell, Chief
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Radiological Controls Section 2
Insoection Summarv
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Inspection on December 7 throuah 11. 1992 (Recort Nos. 50-295/92034(DRSS):
50-304/92034(DRSS))
Areas Inspected: Routine announced inspection of the licensee's radiation
protection (RP) program during a refueling outage (Inspection Procedures (IPs)
83750 and 83729).. Specific areas reviewed included outage planning and
scheduling, internal exposure controls, external exposure controls,
contamination controls, and maintaining exposures as low as reasonably-
achievable (ALARA). Aaditionally, the inspection included a review of '
previously identified inspection findings'and corrective actions to such-
findings, and observations based on tours of the radiologically controlled
area (RCA).
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9301060091 921229
PDR ADOCK 05000295
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' Reallu One violation was identified during the courso of the inspection for
failure to follow radiation protection procedures by an operator who.made an
unauthorized entry into a posted high radiation area that was being controlled
for radiography (Violation 295/92034-01). Exposure goals for higher dose jobs ,
for the Unit 2 refueling outage were on track with pre-outage estimates and
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improvements were noted with the planning and scheduling department.
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., : / DETAILS ,
1. Etn2ns Contacted
Commonwealth Edisoa
*D. Bump, Supervisor, Quality Verification
*R. Boyce, Radiation Protection staff
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*K. Dickerson, Regulatory Assurance
*G. Kassner, Operational Lead Health Physicist
*W. Kurth, Superintendent, Production Services
*R. Pratt, lead Radiation Protection Supervisor
*B. Rendall, Station Training Department
*W. Stone, Diru tor, Performance Improvement
The inspectors also interviewed other licensee personnel in various
departments in the course of the inspection.
Nuclear Reaulatory Commission -
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*J. Smith, Senior Resident inspector
* Denotes those present at the Exit Meeting on December 11, 1992,
2. Licensee Action on Previous inspection findinas (IP 83750)
(Closed) Open Item (50-295/92007-02(DRSS)): Inconsistencies in hot spot
posting program. This item specifically concerned observed
discrepancies between hot spot postings in_the auxiliary building and
those posted in the Unit 1 containment during the spring 1992 refueling. '
outage. Through direct observations and discussions with licensee
staff, several improvements were noted in the methodology csed for the
current Unit 2 refueling outage and prior inspector concerns appeared to
be resolved. This item is closed. ,
No violations of NRC requirements were identified.
3. Contamination Control proaram flP 83750)
The inspectors reviewed the licensee's program for contamination control
and initiativ6s implemented during the current Unit 2 outage.
During previous outages, a common containment entry and exit point was
used. In an attempt to reduce the: number of personnel contamination
events (PCEs), the station modified its containment access point to
provide separate entry and exit paths which has reduced the possibility
of cross contaminations and )rovided more room for workers to remove
protective clothing (PC). Tie Radiation Protection (RP) department also
developed a video tape illustrating proper.PC removal techniques and
providing examples of improper methods and their possible consequences.
The videos are continuously played at the main contractor and station
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employee dressing areas and at the step off pad coming from the Unit 2 .
containment. The inspectors observed several workers exiting i
containment and noted that good contamination control practices were
used by virtually every worker, and noted that their undressing methods
were consistent with what was presented on the video. )
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At the time of the inspection, the station had recorded 435 PCEs for
1992. The licensee averaged about three PCEs per day during the spring
Unit 1 outage, contrasted by a PCE average rate of one to one and one- !
half per day during the current outage. This indicates that the
initiatives implemented to reduce too number of PCEs are working. The
inspectors informed the licensee that while there has been a downward
trend in the number of PCEs, their performance in this area would
continue to be reviewed and tracked under inspection followup Item (Ifl
No. 295/92007-01; 304/92007-01).
No violations of NRC requirements were identified.
4. Outage Plannina and Schedulina (IP 83750 and 83729)
As detailed in a previous inspection report (IR 50-295/92028;50-
304/92028), the station had taken many actions to improve outage
planning and scheduling problems encountered during the spring 1992 Unit
1 outage. The inspectors discussed with licensee management the current
performance of the )lanning and scheduling department for the current
outage. Even thoug1 some inconsistencies in the schedule were noted,
the overall performance of the new programs appeared to be an
improvement from prior outages. The daily planning meetings attended by
the inspectors were well organized. Responsible individuals for each
department provided updates of ongoing work and new work items were
delegated with due dates associated with the assignments. The
inspectors determined that at this point in the outage, the actions
taken to improve the planning and scheduling of outage activities
appeared to be effective.
No violations of NRC requirements were identified. -
5. Internal Exnosure Controls (IP B3750)
The inspectors reviewed the results of individuals who had been assessed
to determine whether they had received an intake of radioactive
materials and noted no problems. The inspectors observed several
workers in containment wearing respiratory protection while performing
their assigned tasks, and noted that all individuals observed appeared
to be properly donning, wearing, and removing their respiratory
protection equipment.
No violations of NRC requirements were identified.
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The inspectors reviewed selected Radiation Work Permits (RWPs) for
a>propriateness of radiation protection requirements and to ensure that
t1ey received supervisory review. No problems were identified. >
The station has changed their RWP format in an attempt to better convey
relevant information to the workers. Titles, electronic dosimeter alarm
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settings, and job locations were boldly printed and PC requirements were ,
presented in terms of a dress class. Specific dress requirements t
represented by various classes were itemired at the PC supply area. The
inspectors noted that the overall RWP layout and the use of dress
classes with associated informational signs were improvements over the
old RWP format. Discussions with both station personnel and contractors
indicated that the new RWP format and dress classes were easier to read
and understand.
The inspectors reviewed the circumstances surrounding an unauthorized
entry by an operator into an area which was temporarily posted as a high
radiation area in anticipation of radiography. The operator had read
and signed RWP 92-0006-0 which covered routine operator rounds. Entry
into high radiation areas typically encountered during normal rounds was
allowed by this RWP. He was performing his rounds in the-auxiliary
building when, on the 579 level, he encountered a rope barrier with a
sign on which was written, *High Radiation Area, Radiography in
Progress, Exclusi::n Area, Do Not Enter". The operator was not aware of
the radiological conditions which are present during radiography and was
under the impression that he could enter the area. He decided to enter
the area and seek radiation protection personnel to find out what had
changed in the area and if he could continue his rounds. At this time,
the radiographer had just completed setting up his equipment and was
doing a final boundary check prior to exposing the source. He
encountered the operator and allowed him to obtain the few readings he
needed and then notified station radiation protection personnel about '
the incident.
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Zion Technical Specification 6.2.2 requires that radiation control
procedures be prepared, implemented and maintained. Zion Administrative
Procedure 610-02, High Radiation Area Access Control, requires personnel
to review, sign, and comply with the appropriate radiation work permit
prior to entry into a high radiation area. Zion Administrative
Procedure 600-03, Radiation Work Permit Program, requires an RWP to be
prepared for radiography operations. RWP 92-2295-0 was prepared for
radiography of the Unit 2 auxiliary _feedwater pumps. The operator had
not read or signed this RWP and therefore was not authorized to enter
the area in which radiography was taking place, further, the operator
was not aware of the radiological conditions present in areas near.to a
radiography source. This-is a violation of Technical Specification
6.2.2 (Violation 295/92034-01).
One violation of NRC requirements was identified. No deviations were
identifled.
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! 7. MaintainingAgnational Exposures ALARA (if_SJ1U11
The inspectors reviewed ALARA initiatives for the outage, and reviewed
the performance of higher dose jobs against their respective pre-outage
estimates.
The station once again performed early boration while shutting down the
reactor. The procedure appeared to be successful as indicated by good
chemistry control trends and overall dose rates for many areas within
containment being about twenty-five percent less than in previous Unit 2
outages.
Steam generator tube sheet and center-line channel head dose rates were
significantly lower than in previous Unit 2 outages. Current dose rates
for steam generators were between 2.5 and 6 R/hr in contrast to dose
rates during the previous octages being 9 to 15 R/hr. One improvement
of note was the development and use of a containment for the eddy
current probe pusher. This containment has been effective in reducing
the spread of contamination into the steam generator work area.
Based on interviews with cognizant licensee staff, exposures for higher
dose jobs were trending as planned for this stage of the outage.
Exposure goals for higher dose jobs were as follows:
Steam Generators: 88 person-rem
Misc. Valves: 59 person-rem ,
Inservice inspection: 55 person-rem i
Reactor llead: 49 person-rem
The inspectors noted that a significant contributor to exposures meeting
goals was the assigning of responsible individuals to follow job
exposures daily and review these exposures against the percentage of
work completed. The RP department has also established set points which
flag jobs which may be deviating from anticipated exposures. The
current flag points are at 50 and 80 percent of the established exposure
goal for a specific job. -
No violations of NRC requirer.ents were identified. ,
8. Auxiliary Buildinn and Containment Tours
The inspectors performed several tours of the auxiliary building and the
Unit 2 containment. The inspectors noted that all monitoring
instrumentation was in good working order and in current calibration.
All. minor concerns identified by the inspectors were promptly corrected
by on shift RP foremen. The inspectors noted that information hot spot
posting in containment had improved significantly from earlier outages.-
Workers observed in containment were following good RP 3ractices and
were observed being queried by radiation protection tecinicians as to
where they were working and if they were cognizant of their current
dose.
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No violations of NRC requirements were identified.
9. 12it Meetino
lhe scope and findings of the inspection were discussed with licensee
representatives (Section 1) at the conclusion of the inspection on
December 11, 1992. Specific items discussed during the exit meeting are
summarized below. Licensee representatives did not identify any
documents or processes reviewed during the inspection as proprietary,
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* The violation involving an operator crossing a high radiation area
boundary which was being controlled under a job specific RWP for
radiography.
* The improved hot spot posting program, especially those areas within
containment.
* The good performance in the outage with respect to doses meeting :
estimated goals.
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