ML20134P488

Insp Repts 50-295/96-21 & 50-304/96-21 on 961203-970122. Apparent Violations Being Considered for Escalated Enforcement Action.Major Areas Inspected:Radiological Protection & Chemistry Controls

ML20134P488
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/11/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134P485	List: ML20134P482 ML20134P488
References
50-295-96-21, 50-304-96-21, NUDOCS 9702250491
Download: ML20134P488 (16)

See also: IR 05000295/1996021

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION 111

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Docket Nos:

50-295; 50 304

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Licenses No:

DPR-39; DPR-48

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Reports No:

50-295/96021(DRS); 50-304/96021(DRS)

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Licensee:

Commonwealth Edison Company (Comed)

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Facility:

Zion Generating Station, Units 1 & 2

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Location:

105 Shiloh Boulevard

Zion, IL 60099

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Dates:

December 3,1996 - January 22,1997

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Inspectors:

S. K. Orth, Radiation Specialist

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Approved by:

Thomas J. Kozak, Chief, Plant Support Branch 2

Division of Reactor Safety

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9702250491 970211

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ADOCK 05000295

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EXECUTIVE SUMMARY

Zion Generating Station, Units 1 & 2

NRC Inspection Reports 50-295/96021, 50-304/96021

An apparent violation was identified concerning the shipment of radioactive

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materials. The external surface of a December 9,1996 limited quantity shipment

from Zion exceeded the radiation dose rate limit of 49 CFR 173.425. Problems

were also identified concerning the coordination and planning of radioactive material

shipping operations. (Section R1.1)

Access to safety related equipment continued to be radiologically encumbered.

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Pump sealleakage contributed to the high number of contaminated areas within the

auxiliary building. Several examples of inadequate radiological housekeeping and

control of radiological boundaries were identified. (Section R1.2)

Although the licensee had focussed efforts on resolving operability issues for the

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steam generator blowdown and radioactive waste (radwaste) systems, material

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condition deficiencies, including inoperable chemical drain tank pumps, were not

resolved. Radwaste operators continued to work around inoperable equipment.

Inconsistencies were identified concerning radwaste system configurations and the

Updated Final Safety Analysis Report (UFSAR). (Section R2.1)

Two apparent violations were identified concerning radioactive material shipping

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procedures. The licensee had not adequately maintained certain procedures to be

consistent with the revisions to regulatory requirements. In addition, the licensee

had not properly implemented procedures concerning the use of radionuclide scaling

factors in determining the activity of radioactive waste. (Section R3.1)

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An apparent violation was identified for not adequately implementing radiation

control procedures. Operations personnel removed instruments from a posted

contamination area without containing the instrument or having the instrument

released by radiation protection personnel. (Section R4.1)

The licensee demonstrated good communication and coordination during the

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December 4,1996 medical drill. The licensee was effective in minimizing the

spread of simulated radioactive contamination, with some exceptions.

(Section R4.2)

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Radioactive material shipping training lesson plans were consistent with the

revisions to 10 CFR Part 71 and 49 CFR Parts 172 and 173. An apparent violation

was identified concerning the failure to train two operations personnel in

accordance with procedures. (Section R5.1)

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The licensee's self assessments of the radioactive material transportation program

were not thorough and failed to identify fundamental radioactive material shipping

problems. (Section 7.1)

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Report Details

IV. Plant Support

R1

Radiological Protection and Chemistry (RP&C) Controls

R 1.1

Transoortation of Radioactive Materials

a.

Insoection Scone (83750,2515/1331

The inspector reviewed the shipping documents for the following radioactive waste

(radwaste) and material shipments and verified the licensee's waste classification,

and package classification, labeling, and shipping papers:

ZRW 96-02 Dewatered ion Exchange Resin (1/25/96);

ZRW 96-12 Dewatered lon Exchange Resin (4/24/96);

ZRW 96-25 Dewatered lon Exchange Resin (10/24/96); and

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ZRM 96-131 Radioactive Material (12/9/96).

The inspector also observed the licensee's preparation and packaging of a liner of

ion exchange resin (ZRW 97-01) for shipment to a radwaste burial site.

b.

Observations and Findinas

During the review of the shipping documents, the inspector identified problems

concerning the licensee's implementation of shipping and waste classification

procedures (also see Section R4.1). With the exception of radioactive material

shipment ZRM 96-131, the inspector verified that the licensee's waste

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classification and shipping classifications were accurately calculated and that

packaging requirements were met. The inspector also observed that the shipping

papers were completed as required.

The inspector reviewed documentation about a problem concerning the licensee's

December 9,1996 shipment of radioactive material (ZRM 96-131) to the Byron

Nuclear Station. Although the material was shipped as a limited quantity shipment,

the Byron staff identified that the package's contact dose rates of 0.7 mrem /hr

exceeded the Department of Transportation's (DOT) contact radiation limit of

0.5 mrem /hr for that type of package. Zion Station's documented survey of the

shipment clearly indicated the actual contact dose rate of 0.7 mrem /hr, but

personnel incorrectly documented that dose rates were less than 0.2 mrem /hr on

the shipping forms. Although four members of the licensee's staff reviewed this

information, the problem was not identified until the Byron staff performed an

incoming shipment review. Byron personnel made a courtesy notification to NRC to

report the problem with the shipment.

10 CFR 71.5 requires, in part, that each licensee who transports licensed material

outside of the site of usage, or where transport is on public highway, or who

delivers licensed material to a carrier for transport, shall comply with the applicable

Department of Transportation regulations in 49 CFR parts 170 through 189

appropriate to the mode of transport. 49 CFR 173.421 requires, in part, that a

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Class 7 (radioactive) material whose activity per package does not exceed the limits

specified in 49 CFR 173.425 and its packaging are excepted from the specification

packaging, marking, and labelling, and the shipping paper and certification

requirements, if the radiation level at any point on the external surface of the

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package does not exceed 0.005 millisievert (mSv)/hr (0.5 mrem /hr). The failure of

the licensee to properly ship radioactive materialin accordance with 49 CFR

173.425 is an apparent violation (eel No. 50-295/96021-01(DRS) and

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50-304/96021-01(DRS)).

On January 8,1997, the inspector also observed the packaging of a high integrity

container of ion exchange resins (ZRW 97-01) and identified the following

problems:

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Poor planning and coordination between the radiation protection (RP) and

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operations staff was noted. The operations staff had unloaded an empty

liner from a carrier's vehicle, had weighed the full liner, and were preparing

to move a full liner of ion exchange resins onto the carrier's vehicle.

However, minutes before the liner was to be loaded on the carrier's truck,

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RP personnel notified the operations staff that they did not have a curreret

analysis for the resin. All activities in support of loading of the liner we.e

suspended.

While positioning the carrier's truck into the Radwaste Annex, the licensee

directed the carrier's truck near a contaminated area boundary. The truck

struck and moved the boundary. The truck also brushed against a storage

cask (containing a loaded liner) within the contaminated area in the

Radwaste Annex.

Although a violation of NRC requirements was not identified, this evolution

could have potentially damaged the storage cask containing the resins and

could have potentially contaminated areas outside of the posted area.

As immediate corrective actions for the problems described above, the licensee

suspended all radioactive material shipping on January 10,1997, and bcgan to

review, delete, and/or revise a number of shipping procedures to be consistent with

the requirements.

c.

Conclusions

An apparent violation was identified concerning the shipment of radioactive

materials. On December 9,1996, the licensee shipped radioactive material as a

limited quantity shipment which exceeded the limits of 49 CFR 173.425. Problems

were also identified concerning the coordination and planning of radioactive material

shipping operations.

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R1.2 Plant Radioloaical Conditions

a.

Insoection Scoce (83750,86750)

The inspector reviewed the radiological conditions of the plant and assessed the

effect of radiological contamination and high radiation levels on access to safety

related and radwaste equipment. Specifically, the inspector reviewed the licensee's

surveys of the auxiliary building (ABi and the associated posting and control of

radiological hazards. In addition, the inspector assessed the radiological

housekeeping in the AB and the control of contaminated area boundaries.

b.

Observations and Findinct

The licensee continued to have several radiological impediments encumbering

access to safety related equipment, as documented in NRC Inspection Report 50-

295/96016(DR S), 50-304/96016(DRS). Extensive pump sealleakage contributed

to contamination in several emergency core cooling system (ECCS) pump rooms.

Although these areas were properly posted and controlled, the access to safety

related equipment was significantly impeded in addition, high radiological source

term has resulted in elevated dose rates and numerous hot spots. For example, the

licensee posted and controlled all four of the residual heat removal (RHR) pump

rooms as high radiation areas (HRAs) and contaminated areas (CAs). The RHR heat

exchanger rooms were similarly controlled, with the unit 1 (U1) rooms being locked

HRAs as well. Although a small non-contaminated area walkway was maintained in

the RHR rooms, the access to equipment remained encumbered.

The centrifugal charging pump (CCP) rooms were accessible; however, the overall,

higher U1 dose rates resulted in the licensee posting and controlling the 1B CCP as

an HRA. The inspector also observed that the pumps and pedestals were posted as

CAs, owing to pump sealleaks and visible boric acid crystallization.

Similar to the ECCS pump rooms, the inspector observed that the access to areas

containing radwaste system components was highly, radiologically encumbered.

As a result of numerous hot spots and high radiological source tcrm withir: the

radwaste tanks, the licensee controlled the AB equipment drain tank (EDT) and

chemical drain tank (CDT) as locked HRAs. In general, the inspector noted that

pump sealleakage had also resulted in the posting of radwaste tank pumps as

contaminated areas, in addition, the inspector observed that the licensee had also

restricted access to the crystallizer and evaporator rooms, v5hich had been

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abandoned in place, with RA and CA postings at the access point and with

radiation protection (RP) permission necessary for access.

During plant observations on December 3 and 4,1996, the inspector identified

problems concerning radiological boundary control and housekeeping in several

areas of the AB. For example, the inspector observed several signs of leakage

within the U1 and U2 hnrizontal pipe chases, including leakage from the high

radiation sampling system waste tank pump. The inspector also identified

protective clothing strewn about the area and fulllaundry collection containers

improperly stored within CAs. The inspector also identified several radiological

housekeeping issues in a work area outside of the U2 volume control tank room

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including hoses not properly secured crossing CA boundaries, hoses containing

fluids not leading to collection devices, and protective clothing strewn about within

the CA.

c.

Conclusions

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Access to safety related equipment continued to be radiologically encumbered.

Pump sealleakage contributed to the number of contaminated areas within the AB.

Several examples of inadequate radiological housekeeping and control of

radiological boundaries were identified.

R2

Status of RP&C Facilities and Equipment

R 2.1

Material Condition of Radioactive Waste Processina System

a.

Scone (86750)

The inspector reviewed the material condition of the radwaste processing system.

The inspector compared the current system condition and operation to the

licensee's Updated Final Safety Analysis Report (UFSAR) section 11.2, " Liquid

Waste Management Systems," and section 11.4, " Solid Waste Management

System." The inspector also reviewed the outstanding work orders for the system

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and the licensee's progress in performing system maintenance. The inspector also

discussed system operability and planned corrective maintenance with members of

the operations staff.

b.

Observations and Findinas

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With the exception of the spent resin storage tank (SRST), the inspector verified

that the integrity of the radwaste tanks was acceptable and did not identify any

indications of leakage. However, as described in Section R1.2, high dose rates

impeded access to several radwaste tank rooms. Current radiological conditions

(i.e., estimated general area dose rates in excess of 40 rem /hr) made the SRST

inaccessible. However, the licensee had decontarninated the tank in July 1996 to

perform maintenance on valves. RP personnel, who were involved in the evolution,

indicated to the inspector that the integrity of the tank was good and that there

were no visible indications of resin leakage from the tank.

The inspector observed that both CDT pumps were inoperable. The A pump was

completely removed from tae pump pedestal and the B pump was wrapped with

plastic to contain leakage. Operations personnel indicated that the pumps had been

out of service for over ten years and that the pump suction valves had been

isolated, in accordance with 801-67D, " Liquid Waste Disposal Chemical Drain

Tank," Revision 3, operations personnel directed the unanalyzed CDT contents to

the OB AB sump, which was normally pumped to the AB floor drain analysis tank.

The licensee identified this practice as an operator work around. Although the

problem was not documented in a work request and progress in correcting the

problem was slow, the system en0ineer had an action plan to correct the

deficiencies. The inspector noted that the licensee's process was in conflict with

the UFSAR. As described in UFSAR Section 11.2.2.8, the contents of the CDT

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were to be mixed and sampled, then pumped directly to the applicable radwaste

processing system. In addition, the inspector noted that the AB floor drain analysis

tank and AB sumps (UFSAR Section 11.2.2.2 and 11.2.2.8.2.7, respectively) were

not designed to accept inputs from the CDT nor inputs to the CDT. At the time of

this inspection, the licensee was determining if a safety evaluation had been

completed for the above system configuration. (Unresolved Item No. 50-295/

96021-02(DRS) and 50-304/96021-02(DRS))

In addition to the discrepancy above, the inspector also noted other issues

concerning radwaste operations which were not in conformance with the UFSAR.

The inspector also noted that UFSAR Section 11.2.2.8.5 states that a radwaste

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evaporator was to be used for radwaste processing. However, the licensee did not

have any plans or work requests to repair the non-functioning radwaste evaporator.

The licensee exclusively uses ion exchange demineralization to process the contents

of the liquid radwaste tanks. UFSAR section 11.2.2 also states that the contents

of radwaste tanks were to be mixed and sampled to determine the most effective

processing of the liquids. Specifically, UFSAR Section 11.2.2.8 indicates that the

contents of the following tanks were to be mixed and sampled prior to being

discharged through a treatment process: AB equipment drain analysis tank, AB

floor drain analysis tank, CDT, and laundry and hot shower drain tanks. However,

chemistry and operations personnelindicated that the licensee did not sample the

contents of each tank prior to processing. After processing the tanks' contents,

the licensee sampled the accumulated, processed liquid waste in the evaporator

monitor tanks. Prior to releasing the processed waste to the lake, the licensee also

sampled the contents of the lake discharge tanks (LDTs). At the time of this

inspection, the licensee was determining if a safety evaluation had been completed

for the above difference in radwaste operations. (Unresolved item No. 50-

295/96021-03(DRS) and 50-304/96021-03(DRS))

The inspector noted some progress in the licensee's actions to resolve

longstanding, extensive material condition deficiencies on the steam generator (SG)

blowdown system. Material condition deficiencies in this system (documented in

NRC Inspection Report 50-295/95016(DRP) and 50-304/95016(DRP)) included

severalindications of valve packing and pump sealleakage. Since September

1996, the licensee dedicated an oversight group to improve system operability and

to complete outstanding work orders. As of November 1,1996, the licensee had

resolved issues on the blowdown system which were of high priority to the

operations staff. After complete resolution of the blowdown system maintenance

problems, the licensee planned to focus efforts on the remainder of radwaste

system issues. A radwaste operations supervisor indicated that over 30 work

requests were in the licensee's system for general radwaste corrective

maintenance.

c.

Conclusions

Although the licensee had focussed efforts on resolving operability issues for the

steam generator blowdown and radwaste systems, material condition deficiencies,

including inoperable chemical drain tank pumps, were not resolved. Radwaste

operators continued to work around inoperable equipment. Inconsistencies were

identified concerning radwaste system configurations and the UFSAR.

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R3

RP&C Procedures and Documentation

R 3.1

Radioactive Material Shiocina Procedures

a.

Scoce (86750 -

The inspector reviewed the licensee's procedures providing instruction in the

classification, packaging, transport, and shipping of radioactive materials and

radwaste. The inspector reviewed the following licensee procedures and their

implementation:

ZAP 620-01, " Radioactive Material Shipping and Receiving Guidelines,"

Revision TA-96-973;

ZRP 5600 3, " Classification of Radioactive Waste for Near-Surface Burial Site

Disposal," Revision 0;

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ZRP 5600-4, " Completion of Radioactive Material Shipping Record," Revision 2;

ZRP 5600-7, "Off-Site Shipment of Radioactive Material," Revision 0;

ZRP 5600-11, " Radioactive Shipments (RM) (Other Than Waste)," Revision

TA-96-008;

ZRP 5610-2, " Calculation of Curie Content of Radioactive Shipments," Revision 0;

ZRP 5610-4, " Preparation and Shipment of Samples for Special Analysis,"

Revision 0;

ZRP 5610-6, " Surveying Radioactive Material Shipments," Revision 2; and

ZRP 5610-10, " Radioactive Waste Shipments," Revision O.

b.

Observations and Findinas

The inspector observed that the licensee had revised procedure ZAP 620-01 to be

consistent with recently implemented revisions to applicable transportation

regulations. ZAP 620-01 contained guidance in preparing packages, consistent-

with the categories of low specific activity (LSA) and surface contaminated object

(SCO). The procedure also contained instructions consistent with the revised

packaging requirements. However, ZAP 620-01 often directed the user to refer to

applicable regulations instead of providing specific instructions. For example, in

determining the type of label for the package, ZAP 620-01 referred the user to 49

CFR 172.403. The licensee indicated that its computer software was used to

ensure that the regulatory requirements were met.

The licensee also used computer software to determine packaging requirements

such as activity limits, LSA classification, and SCO classification for transport of

radioactive materials. The licensee's procedures properly reflected the use of the

computer software which appropriately implemented the applicable regulations. The

licensee also had approved procedures which provided instructions for manual

determination of the above packaging requirements. The inspector determined that

ZRP 5600-7, "Offsite Shipment of Radioactive Material," Revision 0, dated

November 2,1993, contained inaccurate instructions for determining packaging

requirements (i.e., activity limits, LSA classification, SCO classification, etc.).

Specifically, this procedure contained instructions which complied with the previous

regulations and, thus, were outdated. Once this was brought to the licensee's

attentior', the licensee deleted the procedure.

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Technical Specification (TS) 6.2.2.A requires, in part, that radiation control

procedures be maintained. The failure to maintain radiation control procedure

ZRP 5600-7 is an apparent violation of TS 6.2.2.A (eel No. 50-295/96021-04(DRS)

and 50-304/96021-04(DRS)).

During a review of shipment documents, the inspector identified that the licensee

had not adequately implemented its radioactive waste shipping procedures

concerning the sampling and analysis of waste streams to determine radionuclide

scaling factors. In accordance with 10 CFR 61.55(a)8, scaling factors are used as

an indirect method to determine radionuclide activity in radioactive waste

shipments. This is done by inferring a concentration of hard to detect radionuclides

by applying scaling factors to a known concentration of an easier to detect

radionuclide provided there is reasonable assurance that the indirect method can be

correlated with actual measurements. Licensee procedures require that sampling

and analysis of certain waste streams be done annually.

The inspector identified that the steam generator blowdown resin scaling factors

had not been analyzed since September 1994. Further, this analysis was not used

because it was determined that the sample was not representative of the actual

radionuclide content of the resin. No additional sampling was performed and there

was no laboratory analysis to support the pre-1994 scaling factors which were in

use at the time of the inspection. The significance of this omission is that the slight

steam generator tube leakage which had occurred since the last valid sample

analysis could have changed the radionuclide content of the blowdown resin.

Additionally, the sampling and analyses of the primary resin waste stream was not

performed from August 1993 through November 1996. Even though the primary

resin was sampled in November 1996, a combined average of 1992 and 1993

sample data was in use at the time of the inspection.

TS 6.2.2.A requires, in part, that radiation control procedures be implemented.

Licensee procedure ZRP 5610-4, dated November 12,1993, requires, in part, that

spent resin samples be sent out for analysis yearly, in accordance with 10 CFR 61

guidelines. ZRP 5610-4 required that annual samples of SG blowdown resin and

primary resin be analyzed in accordance with 10 CFR 61 guidelines and procedure

ZRP 5610-10, dated December 12,1994, required that the current shipment be

compared to " annual waste stream analyses". The failure to obtain and analyze

annual samples of SG blowdown resin and primary resin is an apparent violation of

TS 6.2.2.A (eel No. 50-295/96021-05b(DRS) and 50-304/96021-05(DRS)).

c.

Conclusion

Two apparent violations were identified concerning radioactive material shipping

procedures. In the first violation, the licensee did not adequately maintain certain

procedures consistent with the revisions to regulatory requirements. The second

violation concerned the failure to have samples of various waste streams analyzed

to establish acceptable scaling factors within the procedurally-specified timeframe.

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R4

Staff Knowledge and Performance in RP&C

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R4.1 - Radiation Worker Practices

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During the inspector's observations of radwaste shipment ZRW 97-01 (Section

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R1.1), the inspector identified an apparent violation of procedure ZAP 610-03,

" Unescorted Access To and Conduct in Radiologically Posted Areas," Revision 1(G),

dated September 12,1996. This procedure states that personnel are to contain

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contaminated equipment removed from contaminated areas or have the equipment

released by a radiation protection technician. On January 8,1997, the inspector

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observed an operations individual pick up a rod in a clean area, use the rod .to

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manipulate potentially contaminated equipment in a posted contaminated area, and

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. remove the rod from the posted contaminated area without containing the rod or

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having the rod released by a radiation protection technician. In utilizing the rod to

manipulate equipment within the posted contaminated area, the individual

potentially contaminated the rod. Following the observation, the inspector alerted a

radiation protection technician (RPT) in the area, who took control of the rod and

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performed a contamination survey.

TS 6.2.2.A requires, in part, that radiation control procedures be implemented. The

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failure to adhere to ZAP 610-3 is an apparent violation of TS 6.2.2.A (eel No.50-

295/96021-06(DRS) and 50-304/96021-06(DRS)).

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R4.2 Onsite Emeroency Medical Drill

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a.

Insoection Scone (83750,82301)

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The inspector observed the licensee's December 4,1996 onsite emergency medical

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drill. The drill scenario included a simulated contaminated, injured person (CIP) who

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had fallen in the 1B CCP room. The inspector reviewed the licensee's response to

the scenario events, including the licensee's first aid response, evaluation and

communication of radiological hazards, and contamination control.

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b.

Observations and Findinas

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The inspector observed good communications and coordination with offsite

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responders and between onsite personnel. With the exception of a simulation

problem, the onsite personnel responded to the CIP in a timely manner. The initial

responders (security, operations, and RP personnel) ensured that appropriate first

aid was administered and that information was properly communicated with offsite

fire protection personnel. The RPTs monitored the CIP's vital signs and ensured

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that the individual remained conscious and aware of what was occurring. The

status of the CIP was appropriately relayed to the offsite fire protection personnel

responding to the scenario events.

Contamination control practices were good, with some minor exceptions. The RP

personnel established a boundary around the CIP to control the potential spread of

contamination and limit personnelin the area. The RPTs also prepared a " clean

area runway" to reduce the potential for contaminating offsite emergency

responders and their equipment. Although the RPTs did not perform extensive

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contamination surveys of the CIP, the RPTs indicated that their main concern was

to assess the CIP's medical condition and to stabilize his condition. As a result,

they treated the CIP as potentially contaminated, communicated this to all other

medical responders, and performed further surveys when the CIP was in a stable

condition. The RPTs demonstrated good use of contamination control practices

while treating the CIP. The RPTs donned gloves while working on the CIP and

removing his protective clothing, but the inspector observed that the RPTs did not

always change gloves while moving from more to less potentially contaminated

articles of protective clothing. Potentially, this practice could have spread

contamination to the CIP. In addition, the inspector identified that a security

officer, initially responding to the event, potentially contaminated himself when he

approached the CIP and assessed the casualty. Since the security officer did not

identify that he had been near the CIP, RP personnel did not control or survey this

person to ensure that he did not spread contamination at the accident site.

The inspector also identified a problem concerning the control of the medical drill.

As the CIP was removed from the radiologically posted area (RPA), a drill controller

indicated to the RPTs and RP supervisor that the individual was not to be removed

from the stretcher to enter the personnel contamination monitors (PCMs) (the

rout;ne, automated method of personnel survey) but that he was to be surveyed on

the stretcher in his medically dressed position. Although the RPTs and RP

supervisor were hesitant, they performed a manual survey of the CIP and the

stretcher, then accompanied the CIP to the hospital for additional surveys.

Although allowed by licensee procedures, the inspector indicated to the licensee

that this was a nonconservative decision. For an actual medical situation, a partial

survey and RPT accompaniment would have been appropriate. However, since a

medical situation did not exist, not entering a PCM prior to exiting the RPA could

have potentially resulted in the unnecessary spread of contamination. The licensee

representatives indicated that their original intent was to have the CIP survey

through the PCMs and planned to review RPA access and egress requirements for

future drills.

c.

Conclusion

The licensee demonstrated good communication and coordination during the

December 4,1996 medical ornl. The licensee was effective in minimizing the

spread of simulated radioactive contamination, with some exceptions.

R5

Staff Training and Qualification in RP&C

R 5.1

Radioactive Material and Waste Shloment Trainina

a.

Scoce (86750. Tl 2515/133)

The inspector reviewed the licensee's training program for personnel involved in the

radioactive waste and radioactive material shipping program to ensure personnel

involved in the shipping program were adequately instructed in the revisions to

10 CFR Part 71 and 49 CFR Parts 172 and 173. The inspector reviewed the

following procedures and training lesson plans:

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ZAP 200-9, " Training," Revision 0;

Radioactive Material Shipping, Initial Training, Revision 1;

Level 11 Radioactive Materials Shipping Training, Fuel Handler / Station Laborer

Personnel, Revision 2; and

Level 11 Radioactive Materials Shipping Training, Quality Control Personnel,

Revision 2.

The inspector also reviewed the training history of those persons who were

authorized by the licensee's procedures to release radioactive material shipments.

b.

Observations and Findinag

The inspector observed that the lesson plans for the licensee's Radioactive Material

Shipping training was consistent with the April 1996 revisions to 10 CFR 71,49

CFR 172, and 49 CFR 173. The lesson plans contained appropriate instructions

concerning the classification of waste for burial and the requirements for packaging

and shipping radioactive materials, including the LSA and SCO classifications.

In reviewing the licensee's training records, the inspector identified that two of the

seven persons authorized to release / approve shipments of licensed materials were

not trained in accordance with ZAP 200-9, which requires biennial radioactive

materials shipment training in accordance with NRC IE Bulletin 79-19. IE 79-19

states that individuals are expected to be trained and retrained in the following:

(1)

DOT and NRC regulatory requirements,

(2)

Waste burial license requirements, and

(3)

Licensee instructions and operating procedures.

The inspector verified that the two members of the operations staff were involved

in the shipping program and were authorized to release radioactive shipments. In

April 1996, the individuals attended the Radioactive Material Shipping training but

did not successfully pass the associated exam and had not successfully completed

this training since April 1992 and April 1994, respectively. In July 1996, those

persons successfully completed the task specific training (Level 11 Radioactive

Materials Shipping Training, Quality Control Personnel) which was limited to

instruction on vehicle cnd package inspections and limited regulatory requirements

(i.e., radiation levels and placarding). This training did not fully meet the

requirements of ZAP 200-9. Neither training course appeared to review the

licensee's instructions and operating procedures. Although these individuals were

authorized, the licensee indicated that the two operations personnel had not

released any shipments.

TS 6.1.5 requires that retraining and replacement training of station personnel shall

be in accordance with ANSI N18.1, " Selection and Training of Nuclear Power Plant

Personnel," dated March 8,1971. ANSI N18.1, dated March 8,1971, requires

that a continuing program of training be used for training replacement personnel and

for retraining necessary to ensure that personnel remain proficient. ZAP 200-09,

dated September 17,1992, requires, in part, that personnel, other than stationmen,

involved in the transfer, packaging, or transport of radioactive material shall be

trained in accordance with IE Bulletin 79-19, and retrained biennially. IE Bulletin

12

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79-19 states that personnel should be trained in the DOT and NRC regulatory

requirements, the waste burial license requirements, and in the instructions and

operating procedures for the transfer, packaging, and transport of radioactive

waste. The failure to adequately train personnel in accordance with ZAP 2000-9 is

an apparent violation (eel No. 50-295/96021-07(DRS) and 50-304/96021-

i

07(DRS)).

c.

Conclusion

Radioactive material shipping training lesson plans were consistent with the

revisions to 10 CFR Part 71 and 49 CFR Parts 172 and 173. An apparent violation

was identified concerning the failure to train two operations personnel in

'

accordance with procedures.

R7

Quality Assurance in RP&C Activities

R7.1 Self Assessments of Radioactive Material Shionino Activities

The inspector reviewed quality assurance audit QAA 22-96-04 " Zion Site Quality

Verification Audit of REMP/ODCM/PCP/RW Shipping" conducted on April 15-19,

1996. The site quality verification (SOV) staff reviewed the status of the

radiological environmental monitoring program, the liquid and gaseous' effluents

program, and the radioactive materials transportation program. The audit

concluded that the radioactive shipping program was sound and that radioactive

shipments were being performed by qualified personnel using approved procedures.

1

Given the fundamental problems identified during this NRC inspection, which

j

ranged from worker training and procedural adherence to the shipment of material

above applical;le limits, the inspector concluded that this audit was not thorough

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and failed to identify basic problems which existed at the time of the audit. The

Quality Assurance Manager indicated that considering a major change to radioactive

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material transportation regulations had been implemented two weeks prior to the

audit, an in-depth review of this program to ensure proper implementation of the

new requirements should have been conducted.

V.- Manaaement Meetinas

X1

Exit Meeting Summary

.

On January 22,1997, the inspectors presented the inspection results to licensee

management. The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

13

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PARTIAL LIST OF PERSONS CONTACTED

G. Geer, Radioactive Waste Operations

M. Hagen, Health Physics

R. Krueger, Radioactive Waste Operations

R. Laburn, Health Physics

W. Lacey, Plant General Manager

M. Madigan, Site Quality Verification

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L. Menejevs, Site Quality Verification

T. Patterson, Operations

F. Rescek, Health Physics Support Director

G. Schwartz, Site Quality Verification

W. Stone, Regulatory Assurance

W. Strodi, Health Physics Supervisor

<

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INSPECTION PROCEDURES USED

lP 83750:

Occupational Radiation Exposure

IP 86750:

Solid Radioactive Waste Management and Transportation of Radioactive

Materials

IP 92904:

Followup - Plant Support

Tl 2515/133: Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

ITEMS OPENED, CLOSED, AND DISCUSSED

Ooened

50-295/304-96021-01

eel

Shipment in excess of 49 CFR 173.425 limits

50-295/304-96021-02

URI Discrepancies between radioactive waste system

configuration and UFSAR

50-295/304-96021-03

URI Discrepancies between radioactive waste system

operation and UF.SAR

50-295/304-96021-04

eel

Failure to maintain radiation control procedures

50-295/304-96021-05(a,b) eel Failure to implement radiation control procedures

50-295/304-96021-06

eel

Failure tn irnpfement radiation control procedures

50-295/304-96021-07

eel

Failure to train personnei in accordance with ZAP 200-9

Closed

None.

Discussed

None.

14

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LIST OF ACRONYMS USED

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a

AB

Auxiliary Building

CA

Contaminated Area

CCP

Centrifugal Charging Pump

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CDT

Chemical Drain Tank

CFR

Code of Federal Regulations

CIP

Simulated Contaminated injured Person

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DOT

Department of Transportation

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ECCS

Emergency Core Cooling System

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EDT

Equipment Drain Tank

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HRA

High Radiation Area

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LDT

Lake Discharge Tank

LSA

Low Specific Activity

,

MREM /HR

Millirem per hour

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MSV/HR

Millisievert per hour

PCM

Personnel Contamination Monitor

PlF

Problem identification Form

RA

Radiation Area

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Radwaste

Radioactive Waste

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RHR

Residual Heat Removel

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RP

Radiation Protectior,

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RPA

Radiologically Posted Area

RPT

Radiation Protection Technician

RP&C

Radiation Protection and Chemistry

SCO

Surface Contaminated Object

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SG

Steam Generator

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St

Safety injection

4

SOV

Site Quality Verification

,

+

SRST

Spent Resin Storage Tank

TS

Technical Specification

UFSAR

Updated Final Safety Analysis Report

URI

Unresolved item

VIO

Violation

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PARTIAL LIST OF DOCUMENTS REVIEWED

Engineering Request, "Dumbwalter Shaft Ventilation Barrier"

Initial Operability Assessment No. ER9605838

Problem Identification Form (PlF) 96-4677, " Exceeding Dept. of Transportation (DOT)

Limited Quantity Limit"

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PlF 96-4998, " Hot and Cold Lab Vent Delta P"

SOI-67D, " Liquid Waste Disposal: Chemical Drain Tank," Revision 3

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Temporary Alteration Log Sheet, Attachment A and B, TA-96-075

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