ML20202D744
| ML20202D744 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20202D704 | List: |
| References | |
| 50-295-98-03, 50-295-98-3, 50-304-98-03, 50-304-98-3, NUDOCS 9802170163 | |
| Download: ML20202D744 (17) | |
See also: IR 05000295/1998003
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U. S. NUCLEAR REGULATORY COMMISSION
REGION lli
Docket Nos: 50 295;50-304
Report Nos: 50 295/98003(DRS); 50-304/98003(DRS)
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Licensee: - Commonwealth Edison Company (Comed)
Facility: Zion Generating Station, Units 1 & 2
Location: 101 Shiloh Boulevard
Tu i,IL 60099
Dates: January 20 23,1998
Inspector: S, Orth, Senior Radiation _ Specialist _ _
Approved by: G. Shear, Chief, Plant St.pport Branch 2
Division of Reactor Safety
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PDR ADOCK 03000295
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EXECUTIVE SUMMARY
Zion Generating Station, Units 1 & 2
NRC Inspection Report 50 295/98003; 50 304/98003 ;
This announced inspection included aspects of the licensee's plant support performance and,
specifically, an evaluation of the effectiveness of the radiation protection (RP) program.
Specifically, the inspection focused on the radioactive materia! M waste shipping program and
the redew nf previous inspection findings. The report covers a one week inspection concluding
on January 23,1998, performed by one radiation specialist. Two examples of a vio;ation of
NRC requirements were identified (Sections R4.1 and R4.2).
Plant Supoort
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The licensee properly implemenled the 10 CFR Part 61 waste characterization program,
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The staff sampled waste streams end evaluated the results of the analyses in
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accordance with procedures. However, the inspector observed a large variance
between the gamma isotopic results obtained by the vendor laboratory and by the
licensee's chemistry staff, which had not been communicated to the chemistry staff and
had not been resolved in a timely manner (Section R1.1).
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The RP staff properly packa9ed radioactive materials and wastes for shipment and
completed corrective actions for a previous violation (Section R1.2).
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The RP staff completed a comprehensive review of RP procedures and program
instructions. The staff revised the radioactive msterial and waste shipping procedures
to be consistent with regulatory requirements (Section R3.1).
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One example of a violation was identified concerning the failure to properly adhere to
RP procedures. The licensee identified that an RP technician did not properly follow a
personnel contamination monitor calibration procedure, which contributed to a monitor
having higher than allowed alarrn setpoint (Section R4.1).
.
One example of a violation was identified concerning the inadequate adherence to RP
procedures. On January 18,1990, two security officers removed clipboards from the
radiologically posted area without performing required surveys (Section R4.2).
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Personnel responsible for aspects of the radioactive material transportation program
were current in their training requirements. The licensee had implemented several
program improvements, including position qualification cards and training matrices, to
correct training deficiencies identifi)d in NRC Inspection Report Nos. 50-295/96021
(DRS) and 50-304/96021(DRS)(Section RS.1).
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Beport Details
IV. Plant Sunnart
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R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Activity Determinations of Radioactive Waste ,
s. Insoection Scone (IPs 86750. 92904)
The inspector reviewed the licensee's method for determining the activity of radioactive
waste shipments. The inspectors reviewed the most recent waste stream analyses and
the verifications which were performed to ensure the validity of radionuclide scaling
factors used to detemdne the activity of hard to detect radionuclides. The inspector also
, reviewed the licensee's corrective actions in response to a violation (Examples A and B
of VIO No. 01033 of Enforcement Action (EA) No.97-048) concerning the failure to
perform waste stream sampling in accordance with procedures.
b. Observations and Findinos ,
As described in NRC Inspection Report Nos. 50 295/96021(DRS) and 50 304/96021
(DRS), the licensee used scaling Sctors as an indirect method to determine radionuclide
activity in radioactive waste shipments. This is done by inferring the concentration of
hard to detect radionuclides by applying scaling factors to a known enricentration of an
easier to detect radionuclide, provided that there is a reasonable assurance that the
indirect method can be correlated with actual measurements. Procedure ZRP 5600-13
(Revision 2), * Trending for Shifts in Scaling Factors and Waste Stream Sampling,"
, contained the frequencies for sampling each of the licensee's eight waste streams (dry
active waste (DAW), condensa(e damineralizer resin, boric acid demineralizer resin,
portable domineralizer resin, primary system filters, deborating demineralizer resin,
mixed bed domineralizer resin, and spent fuel pool resin), in accordance with NRC
guidance, procedure ZRP 560013 recommended that each waste stream determined to
produce Class B and C wastes be sampled every year and that each waste stream
determined to produce Class A wastes be sampled every two years, The procedure
aim contained requirements to compare vendor and licensee laboratory results and to
ci npare current and historical scaling factor data to ensure that the results were
cla rect.
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The inspector reviewed the licensee's most recent scaling factor evaluations. The
Radiation Protection (RP) staff performed the analyses at the frequencies stated in
procedure ZRP 5600-13; however, the inspector noted large discrepancies between the
vendor and licensee gamma spectro' copy results, which exceeded the criteria
contained in the procedure (i.e., the Lilo of the vendor laboratory's results to the
licensee's results were expected to be in a range of 0.8 to 1.2). In the case of portable -
demineralizer resin (Sample No. 6605), the ratio of resuht, ranged from 0.55 to 1.87, and
for the DAW sample (Sample No. 6784), the ratio ranged from 0.16 to 0.26. Since the
abundances of the isotopes determined by the two laboratories were consistent, the RP
staff was confident l' he resultant scaling factors and partially attributed the difference
to sample sizes a' mple geometries. As required by procedure ZRP 5600-13, the
, onsite and corporate RP staff's were evaluating the discropancies in the gamma
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spectroscopy results. The inspector noted that the e.omparisons had been conducted in
April of 1997, but the evaluation had not been completsd. In addition, the RP staff
Indicated that the licensee's chemistry staff were not mcde aware of the discrepancy in
results. The RP manager acknowledged the inspector's observations and planned to
ensure that the evaluation was completed.
The inspector also noted a minor inconsistency in the sampling frequency of primary
resh 4 as described in procedure ZRP 560013 and as implemented by the staff.
Routinely, the staff did not obtain annual samples of each primary resin waste stream
which were recommended by procedure ZRP 560013. Instead, the staff collected ,
spent lon exchange rosins in the spent resin storage tank, Isolated the spent resin j
storage tank (prior to shipment), and sampled the contents of the tank to determine the
activity of any shipments. Although the inspector did not identify any violation of the
procedures, the licensee acknowledged the discrepancy and planned to revise the
procedure to clearly reflect the RP staff's practices.
The inspector also verified that the licensee had completed the following corrective !
actions for the first two examples of VIO No. 01033 of EA No. 97-048:
+ The RP staff assigned each waste stream a surveillance in the station
surveillance program;
- Attachment Y of procedure ZAP 620-01 (Revision 7), " Shipping and Receiving
Radioactive Material," contained a checklist to verify that the 10 CFR Part 61
data was current; and
. Qualification ceds were developed for the shipper and other members of the RP
staff.
c. Conclus!QDA '
The RP staff was properly implementing the 10 CFR Part 61 waste characterization
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program. The staff sampled waste streams and evaluated the results of the analyses in
accordance with procedures. However, the inspector observed a large variance
between the gamma isotopic results obtained by the vendor laboratory and by the
licensee's chemistry staff, which had not been communicated to the chemistry staff and
had not been resolved in a timely manner.
R1.2 Conduct of Radioactive Material and Waste Shloments
a. Ill1Qcetion Scone (IPs 86750. 92904) .
The inspector reviewed the licensee's corrective actions in response to a vlotation (VIO
No. 01043 of EA No. 97 048) concerning the shipment of a limited quantity package with
j.' surface radiation levels exceeding the requirements of 49 CFR Part 173. The inspector
i also reviewed the shipping documents for the following radioactive shipments, including
l the package classifications, labeling, and shipping papers:
ZRM 97-053 Contaminated Air Conditioning Unit (May 12,1997);
ZRM 97-070 Contaminated Camera (August 5,1997);
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ZRM 97-071 P.adioactive Materials (August 5,1997);
ZRW 97 006 Spent lon Exchange Resins (June 25,1997);
ZRW 97-017 Spent lon Exchange Resins (October 21,1997); and
ZRW 97 023 DAW (December 12,1997).
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The inspector reviewed the shipping documents to determine their compliance with 10
CFR Pad 71 and 49 CFR Pads 172 and 173,
b. Observations and Findings
The inspector verified that the licensee had completed the corrective actions for VIO No.
01043 of EA No.97-048. During 1997 continuing RP technician training, the RP shipper
described the violations documented in NRC EA No.97-048 and the changes to the
program, including the revised procedures. As described in Section R1.2, an
Independent verification checklist was also added to the shipping procedures.
The inspector observed that the RP staff prepared shipments in accordan:e with
procedures ZAP 620-01 (Revision 7), " Shipping and Receiving Radioactive Material,"
and ZRP 5600 04 (Revision 5)," Completion of Radioactive Material Shipping Record "
As allowed by these procedures, the RP staff used a vendor supplied computer progrem
to classify the shipment and prepare the required shipping documents. The inspector
reviewed the classification of materials / wastes shipped as Low Specific Activity ll (LSA-
II) and Limited Quantity packages and noted that the shipments were properly prepared
and packaged.
The inspector observed that the shipping documents and waste manifests contained the
information required by 49 CFR Part 172 and Appendix F of 10 CFR Part 20,
respectively. The RP staff recorded the acdvity of shipments using the International
System of Units (SI). The shipping documentation also included required emergency
response information. Durir'g this review, the inspector identified some minor
documentation errors, which RP management attributed to a lack of attention to detail,
c. Conclustons
The RP staff properly packaged radioactive materials and wastes for shipment and
completed corrective actions for a previous violation.
R3 RP&C Procedures and Documentation
R3.1 Imorovements in RP&C Procedures
a. Insoection Scone (IPs 83750. 86750. 92904)
) The inspector reviewed the RP staff's progress in reviewing and revising RP procedures
to ensure that procedures were consistent with regulatory requirements and to generally
improve the content of procedures. Specifically, the inspector reviewed the following
procedures to ensure that they were consistent with the requirement of 10 CFR Parts
20,61, and 71 and 49 CFR Parts 172 and 173:
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ZAP 300-16 (Revision 2)," Process Control Program Requirements;"
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ZAP 620-01 (Revision 7),'Shlpping and Receiving Radioactive Material;"
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ZRP 5600-03 (Revision 1),' Classification of Radioactive Waste;"
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ZRP 5600-04 (Revision 5), * Completion of Radioactive Material Shipping
Record;"
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ZRP 560013 (Revisions 0,1, and 2), "Trendir;g for Shifts in Scaling Fav>rs and
Waste Stream Sampling;" and
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ZRP 5610-0 (Revision 5)," Surveying Radioactive Materials Shipments."
The inspector also reviewed the licensee's corrective actions in response to a violation
l (VIO No. 01023 of EA No. 97 048) concerning the failure to properly maintain RP
procedures,
b. Qbservations and FindlDg3
The inspector observed an overall improvement in the content of RP procedures.
During 1997, the RP staff reviewed all RP department procedures and the RP series of
the Zion administrative procedures (ZAP 600 series). The inspector reviewed a number
of current procedures and noted good improvements. However, the RP staff
acknowledged that the Zion RP and administrative procedures were not well cross-
referenced, that the staff had not completely reviewed all of the Zion administrative
procedures, and that inconsistencies between Zion RP procedures and Zion
administrative procedures would likely continue to be identified and corrected.
[ The RP staff had also performed a significant restructuring and revision to the
radioactive material and waste shipping procedures. For example, the licensee deleted
several procedures which were not consistent with the current requirements contained
in 49 CFR Parts 172 and 173. In addition, the RP staff improved procedural instructions
concerning the 10 CFR Part 61 waste characterization sampling, calculations, and
trending. The inspector reviewed the above procedures and found them to be
consistent with the regulations and generally correct. However, the inspector identified
some minor errors in procedure ZRP 5610-06 (conceming the contamination limits for a
surface contaminated object package) and in procedure ZAP 620-01 (conceming the
heading in a table used for packaging). The RP staff acknowledged the errors and
planned to make the appropriate revisions.
As a result of the findings contained in NRC Inspection Report No. 50 295/96021(DRS)
and 50-304/96021(DRS), RP management implemented and communicated clear
expectat!ons to the RP staff concerning procedure control and adherence. On
March 17,1997, RP management implemented Radiation Protection Standing Order
No. 97-03, *RP Conduct of Operations." Section 3.17 of the standing order stated that
verbatim procedure compliance was expected and that an activity was to be halted if a
procedure could not be implemented. Further instructions also addressed performing
periodic procedure reviews and revising procedures. On September 5,1997, the RP
staff deleted the standing order and moved the contents into RP policles and plant
procedures. The inspector discussed procedure adherence and the procedure revision
process with members of the RP staff, who were familiar with the above expectations.
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c. Conclusions
The RP staff completed a comprehensive review of RP procedures and progrLm
instructions. The staff revised the radioactive material and waste shipping procedures
to be consistent with regulatory requirements.
R4 Staff Knowledge and Performance in RP&C
R4.1 Inadeaunte Calibration of Personnel Contamination Monitor (PCM)
a. IDipaction Scoce (IP 83750)
The inspector reviewed the licensee's investigation of a personnel contamination
monitor (PCM) at the Auxiliary Building exit, which did not have the required alarm
setpoints. The inspector also discussed the incident and associated corrective actions
with members of the RP staff,
b. Observations and Findhgs
On January 17,1998, on RP technician (RPT)ident;fied that a PCM at the Auxiliary
Building exit to the radiologically posted area (RPA) dkl not respond properly to the daily
alarm functional test. The RPT recalled that the PCM had been out-of service the
previous day but could not locate a current calibration sticker on the instrument. In
addition, the RPT noted that the alarm settings were significantly higher than the
ellowable limits contained in the calibration procedure. Subsequently, the RPT placed a
chain across the ingress point of the PCM, placed an out-of-service card on the PCM,
and initiated a problem identification form (PIF No. Z1998-0049).
The licensee reviewed the incident and identifiec' that an RPT had performed a
calibrttion of the monitor on January 15,1998, but had not performed all of the required
steps of the calibration proe . dure (ZRP 5822-07 (Revision 2)," Calibration of the NE
Technology IPM 8 Whole Body Frisking Monitor'). Before calculating and reviewing the
calibration data, Step G.4.dd required the performer to reset the PCM setpoints to the
original values (prior to calibration). However, the RPT decided to place a chain across
the PCM's ingress point and complete the steps of the procedure but not to reset the
monitor's setpoints. During its review, the licensee determined that the chain had been
removed from the monitor during the early mom ng of January 16,1998, and that the
monitor had been in service for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During this time period, the incorrectly
calibrated PCM was one-of-two PCMs available to personnel. Based on the RP staff's
calculations, the PCM's detectors had been set to alarm at contamination levels which
were 3 to 5 times greater than the level specified in the procedure (5,000 disintegrations
per minute (dpm)).
Technical Specification (TS) 6.2.2.A requires, in part, that radiation control procedures
be prepared and implemented, which are consistent with the requirements of 10 CFR
Part 20. Procedurc ZRP 5822-07 provides instructions for the testing and calibration of
PCMs. As described above, the failure to reset the PCM (Step G.4.dd) prior to
continuing in the calibration (Section G.5)is an example of a violation of TS 6.2.2.A (VIO
Nos. 50-295/98003-01a and 50 304/98003-01a).
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As documented in NRC inspection Report Nos. 50-295/97026(DRS) and 50 304/970 '
l (DRS), the RP staff had previously identified numerous radioactive materials outside oi
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the RPA, which were attributed to poor historical controls at RPA exits and to poor
j radiation worker practices. Since the material was identified by the licensee and the
i licensee had implemented broad corrective actions, the NRC exercised enforcement
, discretion and issued a noncited violation (NCV). Although the licensee had
implemented corrective actions to improve this program area, the inadequate calibration
of the PCM, as described above, Indicated that additional corrective actions were
warranted. Since this incident is similar to the fundamental root cause of the NCV (i.e.,
I.1 adequate implementation of the survey program at the RPA exit), enforcement
discretion I.as not been exercised for the above violation.
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As immediate corrective actions, the RP staff performed the following:
. An RPT placed the chain across the monitor and placed an out of service card
on the chain;
- The RP staff conducted surveys at the RPA exit point and did not detect any
contem' nation at or beyond the RPA boundary; and ,
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The RP staff were evaluating the personnel who may have monitored through
- he PCM to determine the need for any additional follow up surveys.
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Based on the initial survey results, the licensee was confident that the potential for the
release of radioactive material was minimal. At the RPA exit point, personnel were also
required to process through an additional PCM (gamma sensitive monitor), which
provided additional assurance that no significant contamination had been released. At
the time of this inspection, the licencee was completing its investigation and developing
additional cc>rrective actions,
c. Conclusions
One example of a violation was identified conceming the failure to properly adhere to
RP procedures. The licensee identified that an RPT did not properly follow a PCM
calibration procedure, which contributed to e PCM having higher than allowed alarm
setpoint.
R4.2 1padeauate Survev of Matterials Exitina the Radioloalcally Posted Area
j_ a. Insoection Scoca (IP 83'ljQ)
The inspector reviewed an incident in which two security personnel improperly removed
two clipboards from the RPA. The inspector also reelewed the licensee's preliminary
report, interviewed members of the RP and security aaffs, and reviewed the RP staff's
, immediate corrective actions
b. Observations and Findinas
At about 6:00 a.m. on January 18,1998, an RPT identified that two contaminated
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clipboards had been improperly removed from the RPA. As security personnel
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attempted to enter the RPA, the RPT questioned the Iridividuals concerning one of the
individual's clipboards, which had a radioactive materials label affixed to it. Although the
RPT did not detect any contamination on the clipboard, the RPT detected fixed
contamination (about 62,000 dpm) on another clipboard which security personnel were
also bringing into the RPA. Following this discovery, the RP staff surveyed the
remaining security clipboards which were not within the RPA and measured fixed
contamination levels of about 10,200 dpm on an additional clipboard.
Durh J the course of the initialinvestigation, the RP staff determined that the security
officers on the previous shift had removed the clipboards without performing the
required radiological surveys. Near the RPA exit, these officers presented the oncoming
shift with the clipboards so that they could use the clipboards for the next routine
rounds.
The inspector reviewed the PIF associated with the event (PlF No. Z1998-0053) and
interviewed one of the security officers who had improperly removed the clipboards.
According to the individual, he had been onsite since about October of 1997 and had
only performed the rounds a couple of times. When the Individual completed his rounds
on January 18,1998, he was not certain of the RP requirements concerning the removal
of the clipboards. Another security officer indicated to him that the previous night he
had placed tht, clipboards on the counter, processed through the PCMs, retrieved the
clipboards, and exited. Although the officer Indicated to the inspector that he had some
reservations, the security officer followed the instructions of his associato (i.e., he
removed the clipboard from the RPA without performing a survey of the clipboard).
Technical Specification 6.2.2.A requires, in part, that radiation control procedures be
prepared and Implemented, which are consistent with the requirements of 10 CFR Part
20. Step E.2.3 of procedure ZRP 5710-02 (Revision 3)," Control of Materials For
Conditional or Unconditional Release From Radiologically Posted Areas," requires that
items unconditionally released from RPAs be surveyed with Instrumentation having a
detection capability of 5000 dpm por 100 cm2 total contamination and 1000 dpm per 100
cm' removable beta / gamma contamination. As described above, the failure to perform
a survey of the clipboards before removing the items from the RPA i. an example of a
violation of TS 6.2.2.A (VIO Nos. 50-295/98003-01b and 50 304/98003-01b).
As documented in NRC Inspection Report Nos. 50 295/97026(DRS) and 50-304/97026
(DRS), the RP staff had previously identified numerous radioactive materials outside of
the RPA. The staff had attributed this problem to poor historical controls at RPA exits
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and to poor radiation worker practices. Since the above incident concerning the security
( officers is similar to the fundamental root cause of the radioactive material control
problem (i.e., inadequate implementation of the survey program at the RPA exit),
enforcement discretion has not been exercised for the above violation.
As immediate corrective actions, the licensee performed the following actions:
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. Security management held a stand-down with security personnel, described the
event, and indicated the correct process for removing articles from the RPA;
- The RP staff restricted the RPA access for the individuals involved and planned
to provide additional training to the individuals; and
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The RP staff placed an additional posting at the RPA exit to inform workers of
the survey requirements and placed an individual at the exit point to ensure that
personnel were properly following the requirements.
At the time of this inspection, the staff was completing its Investigation of the incident
and developing additionallong term corrective actions. The RP manager also planned
to review training modules to ensure that personnel were properly instructed in the
survey requirements,
c. Conclusions
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One example of a violation was identified concerning the inadequate adherence to RP .
procedures. On January 18,1998, two security officers removed clipboards from the
RPA without performing required surveys.
R5 Staff Training and Qualification in RP&C
RS.1 Trainina of Personnel Resoonsible for Radioactive Material and Waste Shloments
a. insoection Scoos (IPs 86750. 92904)
The inspector reviewed the training and qualification of Individuals responsible for
packaging and shipping radioactive material and wastes. Specifically, the inspector
reviewed the licensee's corrective actions in response to a violation (VIO No. 01013 of
EA No.97-048) concerning the failure to properly train two individuals,
b. Qbservations and Findinos
The inspector noted that the licensee had improved the structure of the training
requirements. For example, the licensee had deleted procedure ZAP 200-9 (Revision
0), " Training," and incorporated the appI! cable requirements into procedure ZAP 620-01
(Revision 7)," Shipping and Receiving Radioactive Material." The inspector noted that
Section E.8 of procedure ZAP 620-01 contained the applicable requirements, which
were consistent with 49 CFR Part 172 Subpart H (i.e., initial training and rctraining
requirements), in addition, the RP staff developed training matrices for each position,
which identified the persons tralned and the respective training dates. The inspector
noted that the matrices clearly defined the training courses for each position and verified
that all of the indMduals assigned to perform radioactive material shipping duties were
currently tralned. However, the inspector identified an error in one of the training dates
recorded on a matrix. The RP staff acknowledged the error and planned to revise the
document.
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The training department had implemented a policy to provide immediate notification of
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training class failures. Production Training Department General Policy No. 30 (Revision
1) required training personnel to notify a trainee's department head and the trainee's site
training manager of a course failure. Members of the training staff Indicated that these
provisions should ensure that plant departments were made aware of any personnel
who failed a training course and enable the departments to take immediate actions, if
applicable. As described above, the inspector did not identify any personnel who were
not current in the training requirements.
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The RP staff was also developing a job / task analysis for each of the positions in the
radioactive material / waste shipping organization. The inspectors observed that this
analysis remained under development. In the interim, the RP staff had developed
qualification guides for each radicactive waste / material packaging and solpping position
and for select RP professional c uties. Based on the final results of the analysis, the
lleensee planned to review and revise the existing qualification guides, if necessary.
The inspector reviewed the guides and noted that the guides contained requirements for
both technical training and on the job performance evaluations. The RP staff indicated
that the qualification guides would t'e implemented to qualify new Individuals in the
positions,
c. Conclusions
Personnel responsible for aspects of the radioactive material transportation program
were current in their training requirements. The licensee had implumented several
program improvements, including position qualification cards and training matrices, to
correct training deficiencies identified in NRC Inspection Report Nos. 50-295/96021
(CRS) and 50-304/06021(D9S).
R8 Miscellaneouc RP&C lasues
R8.1 (Closed) Insoection Follow-uo item flFl) No. 50-295/97020-02 and 50-304/97020-02:
The licensee planned to evaluate the documentation of respiratory protection
evaluations. The RP staff determined that additionalinformation needed to be recorded
on Attachment A of procedure ZRP 5500-01 (Revision 3)," Radiological Respiratory
Control Program." to clearly indicate the basis for a respiratory protection decision. In
addition, the RP staff identified that survey documents which satisfied seve al radiation
work permits (RWPs) and respirator evaluations needed to be better organized and
cross referenced. Based on these issues, the RP staff had implemented some
enhancements to the process. During this inspection, the inspector reviewed a number
of RWPs which had been activated in 1997 and 1998 and noted a good improvement in
this documentation. Within the RWP, the RP staff had documented on Attachment A of
ZRP 5500-01 the projected airbome concentration and the basis for that estimate. This
item is closed.
R8.2 (Closed) VIO Nos. 50-295/97048-01013 and 50-304f97048-01013: The licensee failed
to adequately train two personnelinvolved in the packaging of radioactive material and
authorized to release radioactive material to carriers. As described in Section RS.1, the
licensee had completed corrective actions for this violation, and all personnel were
currently trained. This item is closed.
R8.3 (Closed) VIO Nos. 50 295/97048-01023 and 50-304/97048-01023: The licensee failed
to properly maintain RP procedures current with the requirements of 49 C R 100179.
As des;,ibed in Section R3.1, the licensee had completed corrective act ' 'or this
violation. The inspector also found that the licensee's radioactive material = nipping
procedures were current with the regulations. Although the inspector identified some
minor procedure inconsistencies, the licensee's procedure upgrade efforts had achieved
positive results. This item is closed,
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R8.4 (Ocen) VIO Nos. 50 295/97048-01033 and 50-304/97048-01033: The licensee failed to
properly implement RP procedures concerning radioactive waste activity determinations
and contamination control.
In examples A and B of this violation, the licensee had not e operly sampled its
radioactive waste streams at the frequency required by procedures. As documented in
Section R1.1, tha licensee had improved this program and had completed corrective
actions for this violation. The Inspectors observed that waste stream samples were
current and that the RP staff had implemented measures to prevent future violations.
Examples A and B of this violation are c.losed.
In example C of this violation, operations personnel had improperly removed a
potentially contaminated rod, which had been used to manipulate a switch within the
contaminated area, from a posted contaminated area (i.e., the rod was not contained or
surveyed). As corrective actions for this violation, the licensee had completed the
iollowing:
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The Zion General Manager approved Z;on Station Policy No.130, " Radiation
Worker Ac.vuntability," to ensure that station personnel understood their
responsibilities as radiation workers;
- The RP department implemented zone coverage of the Auxiliary Building to
provide better support to workers and to provide better oversight of work
activities; and
. The staff decontaminated and released the area, described in the subject
violation, to provida better access for operations personnel,
i The training department had also evaluated the staff's training for radiation worker
content. However, the inspector noted that the operator radiation worker training
remained under development. The training staff Indicated that the training would be
conducted in 1998.
During plant inspections, the inspector also noted a configuration in the Auxiliary
, Building equipment collection tank OB and pump room (542' elevation of the Auxiliary
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Building) which was similar to the area in the subject violation. Within the room, the staff
had established a posted contaminated area around a sump, The inspector and the RP
manager both noted a long rod just outside of the contaminated area, Although the RP
staff removed the rod from the area and found the rod to be free of contamination, the
RP manager and the inspector were concerned about the rod's intended use. In
addition, the RP staff had identified recent inadequate contamination control practices in
the security organization (Section R1.2), which indicated that additional corrective
actions were warranted.
The completion of the operator training and additional observations of operator radiation
worker practices will be reviewed in future inspections.
R8.5 LChied) VIO Nos. 50-295/97048-01043 and 50-304/97048-01043: The licensee
shipped a limited quantity package which had contact radiation levels exceeding the
requirements of 49 CFR Part 173. As described in Section R1.2, the licensee had
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completed corrective actions for the violation, in addition, the inspector found
subsequent shipments of radioactive materials and wastes to be prepared and
packaged in accordance with the regulations. This item is closed.
V. u=a== ment Meetings l
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X1 Exit Meeting Summary
On January 23,1998, the inspector presented the inspection results to licensee management.
The licensee acknowledged the findings presented,
The inspector asked the licensee whether any materials examined during the inspection should
be considered proprietary. No proprietary informationwas identified,
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PARTIAL LIST OF PERSONS CONTACTED
J. Baxter, Radiation Protection
J. Brons, Site Vice President
>
A. Christensen, Quality and Safety Assessment
F. Jones, Regulatory Assurance
E. Katzman, Radiation Protection Manager
R. LaBurn, Radiation Protection
C. Oshler, Radiation Protection
M. Phalen, Radiation Protection
B. Robinson, Radiation Protection
R. Starkey, Plant General Manager
W. Stone, Regulatory Assurance
R. Zyduck, Quality and Safety Assessment
INSPECTION PROCEDURES USED
0 83750: Occupational Radiation Exposure
IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive
Materials
IP 92904: Followup - Plant Support
ITEMS OPENED, CLOSE.D, AND DISCUSSED
OPENED
50-295/98003-01(a b) VIO Failure to properly implement RP procedures concerning
50 304/98003-01(a b) the calibration of PCMs and contamination control
(Sections R4.1 and R4.2).
CLOSED
50 295/97020-02 IFl Documen*/Jon of respiratory protection evaluations
50 304/97020-02 (Section R8.1).
50-295/97048-01013 VIO _ Fallure to adequately train two individuals involved in
50-304/97048-01013 shipping radioactive materials (Section R8.2).
50 295/97048-01023 VIO Failure to adequately maintain RP procedures used to
50-304/97048-01023 prepare radioactive material shipments (Section R8.3).
50-295/97048-01043 VIO Package containing radioactive material exceeded
50-304/97048-01043 the radiation limits of 49 CFR Part 173 (Section R8.5).
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Dhculled
50 295/97048-01033 VIO Failure to edequately implement RP procedures used to
50 304/97048-01033 determine radioactive waste activities and to control the
spread of contamination (Section R8.4).
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LIST OF ACRONYMS USED
EA Enforcement Action
DAW Dry Active Waste
IFl inspection Foliow up llem
IP Inspection Procedure
l.SA low Specific Activity
NCV Non Cited Violation
PCM Personnel Contamination Moniter
PIF Problem Identification Form -
RP Radiation Protection
RPA Radiologier.ily Posted Area
RP&C Radiation Protection and Chemistry
RPT Radiation Protection Technician
RWP Radiation Work Permit
St International System of Units
TS Technical Specification
VIO Violation
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PAMTIAL LIST OF DOCUMENTS REVIEWED
Problem identif! cation Forms Nos. Z1998-0049 and Z1998 0053.
Radiation Work Permits Nos. 970015 (Revision 0) h23 (Revision 0),970027 (Revisic 0),
970040 (Revision 0),970042 (Revision 0),973218 (r vision 0),980008 (Revision 0),980i1 4
(Revision 0),980029 (Revision 0),983283 (Revision O. and 984707 (Revision 0).
Radioactive Material / Waste Shloolna Trainina Matrices:
- Fuel Handler RMS Training Matrix," dated January 9,1998;
"QC RMS Training Matrix," dated March 18,1997;
- Radwaste Packagers RMS Training Matrix," dated March 17,1997;
"Radwaste Packagers RMS Training Matrix," dated March 18,1997;
- Station Laborers RMS Training Matrix," dated March 18,1997; and
" Stores RMS Training Matrix," dated March 18,1997,
Zion Radiation Protection Procedures:
ZAP 300-16 (Revision 2), " Process Control Progrem Requirements;"
ZAP 600-03 (Revision 7), " Radiation Work Permit Program;"
ZAP 610-03 (Revision 4), " Unescorted Access To and Conduct in Radiologically Posted
Areas;"
ZAP 620 01 (Revision 7), " Shipping and Receiving Radioactive Material;"
ZRP 5500-01 (Revision 3), " Radiological Respiratory Control Program;"
ZRP 5600-03 (Revision 1), " Classification of Radioactive Waste;"
ZRP 5600-04 (Revision 5),' Completion of Radioactive Material Shipping Record;"
ZRP 5600-13 (Revisions 0,1, and 2)," Trending for Shifts in Scaling Factors and
Waste Stream Sampling;"
ZRP 5610-6 (Revision 5), " Surveying Radioactive Materials Shipments."
ZRP 5710-02 (Revis!on 3), * Control of Materials For Conditional or Unconditional
Release From Radiologically Posted Areas;" rnd
ZRP 5822-07 (Revision 2), " Calibration of the NE Technology IPM-8 Whole Body
Frisking Monitor."
Zion Station (Revision 0), " Radiation Protection Professional Duties Qualification Card," dated
December 10,1997.
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