IR 05000295/1978026
| ML19283B599 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/09/1979 |
| From: | Corcoran M, Fisher W, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19283B596 | List: |
| References | |
| 50-295-78-26, 50-304-78-26, NUDOCS 7903010067 | |
| Download: ML19283B599 (11) | |
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U.S. NUCLEAR REGULATORY COFD!ISSION OFFICE OF INSPECTION AND ENFORCEMENT g
REGION III
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Report No. 295/78-26; 304/78-26
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Docket No. 50-295; 50-304 License No. DPR-38; DPR-48 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility name: Zion Nuclear Power Station, Units 1 and 2 Inspection at: Zion Site, Zion, IL Inspection conducted: November 6-9, 16-17, 21-22, and 29, and December 1, 1978
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Inspectors:
M. C. Schumacher h
I A4L[ss f$1.Corcoran (11/6-9/78 only)
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ikM Approved by:
W. L. Fisher, Chief
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Fuel Facility Projects and Radiation Support Section Summary:
Inspection on November 6-9, 16-17, 21-22, 29 - December 1, 1973 (Report No. 50-295/78-26; 50-304/78-26)
Areas Inspected:
Routine, unannounced inspection of radioactive waste systems, including:
effluent releases; reco ds and reports of effluents; effluent control instrumentation; procedures for controlling releases; air-cleaning systems; reactor coolant water quality; solid radioactive waste; review of noncompliance followup; review of Licensee Event Reports; review of NRC Bulletin and Circular followup; and review of a reported overexposure. The inspection involved 144 inspector-hours onsite by two NRC inspectors.
Results: No items of noncompliance were identified in seven of the eleven areas inspected. Noncompliance (both units) was identified in the areas of personnel exposure (infraction, Paragraph 4), reporting of ef fluents (deficiency, Paragraph 5), ef fluent releases (deficiency, Paragraph 6), and solid radioactive waste (infraction, Paragraph 7); a deviation was identified related to air-cleaning system.
(Paragraph 11)
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DETAILS 1.
Persons Contacted
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Wandke, Station Superintendent
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Leider, As'istant Superintendent s
_y L. Soth, Administrative Assistant
- J. Marianyi, Technical Staff Supervisor S. Miller, Rad / Chem Supervisor
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Koske, Assistant Technical Staff Supervisor
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Rescek, Station Health Physicist
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Curunathan, Station Chemist
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Corwin, Chemist
- G. Tryzina, Engineer (Rad / Chem)
F. Ost, Engineer (Rad / Chem)
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John 5on, Technical Staff Engineer
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Parker, Technical Staff Engineer
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Ward, Operating Engineer
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Kuhner, Quality Assurance F. Tschakert, Instrument Foreman G. Peridikas, Tech Staff Engineer R. Krueger, Rad Waste Foreman G. Harbin, Shift Engineer T. Lehmann, Engineering Assistant (Rad / Chem)
B. Meyer, Engineer (Rad / Chem)
The inspectors also talked with other licensee employees, including control room and radwaste operators ar.d radiation chemistry technicians, during the course of this inspection.
- Denotes those present at the exit interview of December 1, 1978.
2.
General This inspection began at approximately 7:45 a.m. on November 6, 1978.
After initial discussion with station management, the radwaste handling area was visited to observe the results of work done since July (Paragraph 7).
During the inspection, visits were made to:
various radwaste areas to observe cask handling and liquid waste discharges; to the control room on several occasions to note radiation monitor conditions; to the chemical laboratories to observe air flows, ventilation, and performance of chemical analyses; and to various locations within the auxiliary, turbine, and fuel buildings to observe functioning of monitors, air purification equipment, and radiological controls. Housekeeping throughout the station generally was much improved, particularly in view of the recently completed outag.
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Licensee Action on Previous Inspection Findings ti (Closed) Infraction 1 (295/78-08): Unlocked, unattended high e-radiation areasdoor. Corrective action specified in the Licensee's
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letter dated May 19, 1978 was confirmed.
(Closed) Infraction 2 (295/78-08): Missed refresher training of a contractor employee.
Licensee corrective action was confirmed.
4.
Contractor Overexposure The inspector reviewed in detail a licensee reported 3070 millirem dose to a contractor employee in the quarter ending October 15, 1978.1/ The man, who has been continuously employed at the station since before 1977, received the bulk of the exposure while working on the Loop 1A RTD flange during the recent Unit 1 outage.
The film badge covering the last two weeks of the quarter indicated 2790 millirems in contrast to the 2200 millirems recorded from self-reading dosimeters by contract health physics technicians who prc71ded continuous coverage for the job. Adding the previous 12-week film badge total af 280 millirems gave a quarterly total of 3070 millirems, which is in noncompliance with 10 CFR 20.101(b)(1).
The total 1978 dose through the third quarter was 3130 millirens.
The inspector determined that the licensee was operating in accordance with approved reasonable procedures at the time of the occurrence. The licensee made an extended investigation but was unable to explain the 25% difference between the film badge and self-reading dosimeter results.
The licensee has amended his procedures to require early badge exchange for estimated badge readings in excess of 1000 millirems or 50% of the unused permissible quarterly exposure, whichever is most limiting.
The licensee's corrective action appeared to be adequate and no further response is required.
5.
Airborne Effluents The inspector reviewed records of airborne releases through November 1978. All releases were well within technical specifica-tion limits of 9600 pCi/sec for noble gases and 2 pCi/sec for iodine plus particulates.
However, the design objective of 1200 pCi/sec for noble gases was exceeded during the third quarter by a factor of about 3.
The licensee is required to notify the NRC if the releases exceed twice the design objective and his failure to do so is 1.sacompliance with Technical Specification 3.12.5.
1/ Licensee Event Report 50-295/78-10.
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-3-Releases along nine pathways are quantified based on continuous iodine and pargiculate samples, changed and analyzed weekly,and by weekly noble gas grab samples. Batch releases from containment, from gas decay; tanks, and reactor head vents are individually
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.,7 quantified by means of grab samples taken in the release volume and analyzed for noble gas, iodines, particulates, and tritium.
These data are reported semiannually.
Noble gases released by the auxiliary building vents are also quantified by integration under the curve described by their common monitor, R14.
These data are supplied as a correction to the semiannual report.
During the third quarter of 1978, the R14 based estimate exceeded that of the grab samples by a factor of about 5 and indicated that the design objective had been exceeded by a factor of about 3.
Monitor background plus uncertainties in calibration owing to changing isotopic mixes makes this method difficult and subject to error.
The licensee uses a conservative calibration cu. ie for R14 and the release estimates are probably conservative but to an unknown extent. Licensee representatives are seeking an improved method of quantifying the auxiliary building noble gas releases, which will avoid both the conservatism of using the R14 monitor trace and the unrepresentativeness of weekly grab samples.
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Owing to a previously noted discrepancy between particulate gross beta and GeLi isotopic data, the licensee changed his method of gross counting composite samples (monthly accumulations of weekly samples).
Both sets of data are reported semiannually.
The data (1978) improved somewhat. However, a spot check of September 1978 data indicated a significant difference between individual release and composite data.
The licensee reevaluated the isotopic data for the third quarter of 1978, using the individual release data; the agreement with gross counting data is much improved.
Licensee representatives stated that reporting procedures would be changed to use individual release data in preference to composite data.
A single gas decay tank of 0.15 curies noble gas and about 2,000 cubic feet was released in 1978.
The possibility of gas leaks in containment or elsewhere accounting for this unexpectedly low release volume was discussed with licensee representatives but the matter was not resolved.
The inspector noted that Unit I containment airborne levels and release levels have both been significantly higher than those for Unit 2.
The matter was discussed at the exit interview.
2/ RIII Inspection Report 50-295/78-0 a
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Liquid Effluents li The liquid release records for 1978 were reviewed, including release n-permits, laboratory analyses, and pre-release surveillance of
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discharge monitors. The inspector also reviewed and discussed with operations personnel present at the radwaste control panel the conditions relating to ongoing discharges on two separate occasions during the inspection. Personnel making the releases appeared knowledgeable and were able to answer questions in detail.
Releases for the period have been well under the limits for individual releases and well under the annual and quarterly objectives.
The very low secondary releases by the fire sump are still being quantified by gross beta and tritium analyses of water from a composite sampler on the discharge pipe.
The licensee appears
.o have overlooked the requirement cf Technical Specification 4.ll.2(b) for daily alpha analysis of these samples. Befsre the end of the inspection, the inspectors verified that the licensee had changed his procedure to require this analysis, that it was in fact being done, and that, as expected, the results showed no activity above background.
Licensee analyses performed all along on releases from the lake discharge tanks have similiarly shown no alpha activity, nor do weekly samples of the primary coolant.
Corrective action on this matter is adequate and no further response is required.
A continuous monitor has been installed on the fire sump discharge and the calibration has been done for the condition of a full discharge pipe. However, the level of liquid in the pipe during operation of the various discharge pump combinations is not known and the applicability of the monitor calibration is uncertain.
The licensee is pursuing this problem while continuing to do shiftly grab samples.
About October 1, 1978, the fire sump discharge and the heater bay roof drains were rerouted to a newly completed waste water treatment facility in accordance with a commitment to the EPA.
The facility provides about 300,000 gallons per day throughput and is designed to reduce solids in the discharge. After treatment the water is returned to the foreba.
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Solid Radioactive Waste i
Solid waste disposal records for 1978 through October were reviewed with special eQphasis on the topics addressed in IE Circular 78-03, g-
,y dated May 12, 1978.
Solid wastes shipped are principally evaporator bottoms solidified in casks or drums and demineralizer resins solidified in casks. The in-cask solidification is done under the direction of Hittman Nuclear Development Corporation, holder of the NRC issued Certification of Compliance for the casks.
Curie content is determined by station personnel using a combination of direct radiation readings and sample analyses. Analyses for transport groups 1 and 2 are included.
Quantification of high activity resin casks entailed considerable developmental work by the health physics group and involved direct readings on the bed in place, direct readings from samples of the bed, and isotopic analyses. Licensee representatives stated that the method developed would be described in a procedure.
Licensee performance in this area appears satisfactory.
Eleven cask shipments made between March 15 and July 27, 1978, appear to have been in noncompliance with 10 CFR 71.3 because of failure to notify the NRC prior to first use of the cask, failure to have on hand copies of the cask and certificate of compliance and reference documents (10 shipments), and, in the case of shipments made on May 5, 12, June 3 and 10, failure to ship in accordance with Certificate of Compliance 9380A issued for Hittman Cask HN600.
The latter problem was identified by the station after receipt of cask documentation in late June.
Station personnel stated that it was their understanding at the time that Hittman was responsible for 10 CFR 71 compliance because they held the cask licenses and were directing the packaging onsite.
The licensee immediately suspended use of the HN600 casks and by letter dated July 27, 1978, notified the NRC of their use or intent to use Hittman Casks designated HN1005, HN100 Series 1, HN100 Series 2, HN200, and HN600. At that time the licensee was in full compliance with the regulations. The licensee's corrective action appears to have been adequate and no further response is required.
Preparation of a filled HN100 cask for shipment on November 9 and the set-up for direct transfer of a spent resin bed to an HN200 (Type B) cask on November 29 were observed.
Continuous radiation protection surveillance was provided and satisfactory practices with respect to truck surveys and placarding were noted.
The resin transfer used a combination of installed piping and temporary hose leading to the cask, which was secured on a truck outside the radwaste building.
Connections appeared secure and provisions had
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-6-been made for stopping transfer remotely. Licensee representatives indicated plang to minimize use of hoses in favor of additional installed piping.
Sheltering of the casks from weather is also
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being considered.
The status of radwaste modifications and repairs J
described in a previous report 3/ was also examined. Repair of drumming area and shippir-g cranes, of upender and drum capper had been completed. Capper operation has improved somewhat to the extent that the lid and retaining ring are placed on the drum.
The tightening of the bolt must still be done by hand. The station hopes that modified bolts that have been ordered will remedy the problem by allowing for pre-threading into the retaining rings.
It was stated that development of c totally neu drum capper, hoped for in February, continues.
The inspector observed several drums stored in the drumming room and measured 60 mR/hr at the drum capper location. About two weeks later the number of drums had about doubled and the dose rates also.
This backup is said to occur from time to time depending on the problems with truck scheduling.
Significant personal exposures will probably not be incurred there as the licensee continues to do little drumming in favor of cask solidification.
The drumming room is used for temporary storage because of lack of space.
The designed storage area is virtually useless, owing to a large accumulation of drums, jammed conveyor belts, tight spacing between storage lines, etc.
These problems were discussed at the exit interv12w.
The radwaste evaporators were chemically cleaned in November, 1978, with disappointing results.
The AQUA-CHEM evaporator readings were reduced by about a factor of 2 rather than a factor of 10 hoped for.
For this reason the radwaste outage scheduled to start in late November was held up, as the licensee considered the exposure problem.
8.
Records and Reports of Effluents The licensee's effluent report for January to June 1978 was reviewed. The data appeared generally consistent with the primary records generated at the site, except for auxiliary building noble gas releases which the licensee intends to submit as errata with the next semiannual report.
The data in the report appeared to be internally consistent and the report was submitted on time.
3/ Rill Inspection Report No. 295/78-1.
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Effluent Control Instrumentation U
Routine calibration of ef fluent and process monitors and ef fluent n-monitor set polnt changes were reviewed for the period December
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1977 through mid-November 1978.
Calibrations by the instrument maintenance group were timely in accordance with approved procedures. Set point changes involve a 50.59 type review by the health physics group. The most recent setting of IE-3 pCi/per el for the lake discharge monitors was reviewed against the require-ment of Technical Specification 3.11.4.d that the alarm occur prior to exceeding 10 CFR 20 Appendix B, Table 2 limits.
Licensee representatives indicated that it is met by requiring cessation of discharge for any change in dilution conditions on which the authorized discharge flow is based.
Examination of the monitor readout in the control room indicated satisfactory operation ;
alarm settings were verified.
The inspector also reviewed effluent gas monitor calibration curves being developed by the health physics group based on a comparison of grab samples with monitor readings.
Reasonable data appear to have been obtained except Containment Monitors 1/2 PR09A and Auxiliary Building Monitor 2RTPR25 for which the data are widely scattered.
The data for the Auxiliary Building Monitor R14 suggest that the vendor's calibration curve for xenon 133, which is used for release calculations, is somewhat conservative.
Licensee representatives stated that this work would continue.
Real time iodine monitors are installed on the containment purge exhuasts, auxiliary building system 2 exhaust, and at several locations within the plant. Possible false positive alarms from noble gases captured on the charcoal cartridge were discussed with licensee personnel. The automatic action for a high alarm on these mor_itors is to either terminate discharge or divert it through charcoal filters. Subsequent actions include verification of alarm authenticity by radiation protection.
The licensee representatives described a five-year monitor plan on which the station has embarked with the intent of upgrading performance of the monitoring system.
Daily surveillance is done on the monitors and samplers and the health physics group is
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keeping a log on the performance of each device.
No items of noncompliance were identifie.
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Radwaste Release Procedures li The following procedures covering quantification of airborne
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releases were seviewed in detail:
i-ZCP304, Revision 9, 3/30/78, " Containment Venting and Purging Analyses Procedure" ZCP305, Revision 5, 7/28/78, " Periodic Gas Discharge-Gas Decay Tank" ZCP306, Revision 4, 5/6/77, " Continuous Gas Release Calculation" The technical details of these procedures were found to be accurate and thus acceptable.
However, they are unnecessarily detailed, cumbersome, and difficult to follow.
Licensee representatives stated that these procedures are being revised and simplified.
No items of noncompliance were identified, 11.
Air Cleaning Systems In-place leakage tests of HEPA and charcoal filters were performed in February - March 1978. Samples of charcoal for laboratory analyses were also taken. All test results met technical specification requirements. The report of the testing contractor noted that the south blower on the chemical laboratory filter system had a 10-inch tear in the flexible suction connector.
A work request for repair was written on !by 30 and closed out on June 9, 1978 with a notation that the problem had evidently been fixed on a previous work request. The inspector and a licensee representative examined the blower in question and found a tear approximately 10 inches long on the inlet connector.
The contractor's letter also noted that the doors that penetrate the filter wall in each of the six auxiliary building HEPA filter rooms required duct tape in order to pass the leakage test.
Examination of these rooms revealed that tape had been removed from four of the doors (Filters OAV29, 31, 32, and 34) and in one case (OAV32) the door was held ajar by a latching dog.
Operation of the aux 1111ary building ventilation system in this manner, so as to bypass the filters, is a deviation from generally accepted industry practic.
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Reactor Coolant Water Quality
.I Records of radioactivity measurements in primary and secondary coolant were rev)ewed for 1978 through October. Regulatory
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It requirements for surveillance appear to have been satisfied.
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was confirmed that a second I determination was made in
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December 1977 and that two E determinations were made in 1978.
No items of noncompliance were identified.
13.
Review of Licensee Event Reports The following licensee event reports (LER's) were reviewed onsite during this inspection:
295/78-25, 41, 49, 50, 54, 60, 61, 62, 63, 67, 69, 73, 82, 83, 85, 95, and 100; 304/78-42, 54, 57, and 60.
Most of these reports dealt with monitor failures and the inspector confirmed that appropriate grab samples had been taken during the period of failure. Two of the reports (295/76-25 and 50) identified failure to take grab samples following r.onitor failure; corrective action to prevent recurrence was confirmed.
No items of noncompliance were identified regarding the matters addressed in the above report.
An overexposure identified in LER 295/78-103 is discussed in Paragraph 4.
Problems with several radwaste shipments identified in LER 295/78-115 are discussed in Paragraph 7.
14.
Review of IE Bulletins and Circulars 1EB 78-08 " Radiation Levels f rom Fuel Element Transf er Tubes" Station measured radiation levels around the Unit I transfer tube during the recent Unit I refueling outage. Maximum dose rate of 4.3 R/hr in the small, not easily accessible, area at the junction of the transfer tube and the inside containment wall.
The measurements were made with an element stationary in the center of the tube. A film badge at that location during the transfer of a 135 elements recorded a total of 6.5 R.
Drawings indicate Unit 2 construction to be similar. Licensee personnel stated that this will be confirmed during the upcoming Unit 2 outage.
IEC 77-14 " Separation of Contaminated Water Systems from Noncontaminated Plant Systems"
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The licensee's review revealed no problems.
Domestic water and sanitary sewage treatment is provided by the Village of Zion.
Licensee representatives stated that precautionary surveillance on clean water % systems will be done periodically.
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IEC 78-03 " Pac aging Greater Than Type A Quantities of Low Specific Activity Material for Transport"
This circular was reviewed in conjunction with review of solid waste radwaste shipments (Paragraph 7).
15.
Exit Interview The inspection results were discussed with the station superintendent and others (Paragraph 1) on December 1, 1978.
Four apparent items of noncompliance (Paragraphs 4, 5, 6, and 7) were reviewed. The inspector acknowledged adequate corrective action cnd stated that no response would be required for all but the failure to report to the NRC of exceeding twice the gaseous effluent design objective.
Ventilation problems, including the deviation from acceptable practices of operating the auxiliary building filter with a bypass, were discussed. The need for better system surveillance and better followup on work requests where the reported problem is not found was acknowledged.
The licensee stated that the ventilation defects were being repaired and that the other matters would also be addressed promptly. By telephone on December 8, the inspector was informed that they bypass doors had been retaped and that an order bad been placed for new gaskets that would be installed upon receipt (about two weeks), and that a surveillance procedure to ensure proper operation of the ventilation systems betwecn leak tests was being prepared.
The tendency of Unit 1 containment gas concentrations and releases to greatly exceed those from Unit 2 and the low number of gas decay tanks discharge uas discussed.
The licensee personnel stated that since return to power in November, Unit I levels have been lower, possibly owing to repair of a pressurizer leak.
The inspector acknowledged improvements made in solid waste handling but observed that drums are still being stored in the drumming room because the basement drum storage area is not available. The licensee representatives stated that this problem is recognized and discussed some plans under consideration for reclaiming the storage facility. No timetable was offered but
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licensee representatives stated that it depended upon availability c( material and equipment and their ability to schedule in concert with other work going on in the area.
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inspector statAd tnat this would be a significant step in the
,J-improvement of radwaste management.
The inspector stated that his brief review of radiation occurrence reports indicated much improved management followup.