IR 05000295/1979004
| ML19225A161 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 05/11/1979 |
| From: | Dubry N, Fisher W, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19225A155 | List: |
| References | |
| 50-295-79-04, 50-295-79-4, 50-304-79-05, 50-304-79-5, NUDOCS 7907180500 | |
| Download: ML19225A161 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-295/79-04; 50-304/79-05 Docket No. 50-295; 50-304 License No-DPR-20; DPR-48 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Zion Station, Units 1 and 2 Inspection At: Zion Site, Zion, IL Inspection Conduct d: March 21-23 and 26-30, 1979 t
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Inspectors:
C. Schumacher b;//./7/9
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N. E. DuBr*
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.C ()Nt3j//,/777 v<
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Approved By.
W. L. Fis er, Chief
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Fuel Facility and Materials J
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Safety Branch Inspection Summar.,
Inspection on March 21-23 and 26-30, 1979 (Report No. 50-295/79-04; 50-334/79-05)
Areas Inspected: Routine, unannounced inspection of radiation protection program, including: qualifications; audits; training; radiation protection procedures; instruments and equipment; exposure control; posting, labeling, and control; surveys; notifications and reports; review of reportable occurrences; and followup of previously identified noncompliance itens and deviations.
It was combir.ad with a Unit 2 refueling outage inspection, which reviewed advanced planning and preparation for the outage in addition to the above-listed topics.
It also included a review of licensee progress with respect to upgrading the solid radwaste treatment system. The inspection involved 140 inspector-hours on site bv two NRC inspectors.
Results: No items of noncompliance were identified in any of the 13 areas inspected.
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DETAILS 1.
Persons Contacted
- N. Wandke, Station Superintendent
- B.
Meyer, Health Physicist
- L.
Soth, Assistant Superintendent (Admin. & Support Se rvice s)
- C.
Schuman, Ascistant Superintendent (Operations)
- S.
Miller, Rad-Cr.am Supervisor
- J.
Marf anyi, Technical Staf f Supervisor
- F.
Rescek, Station Health Physicist
- R.
Ward, Operating Engineer
- T. Hillmer, Radwaste Group Leader
- T.
Lehman, Engr. Asst. (Chemist y)
L. Harl, Quality Assurance Coordinator
- P. Kuhner, Quality Assurance Engineer C. Schultz, Training Supervisor J. Firovid, Engr. Asst. (Chemistry)
G. Trzyna, Health Physicist L. Minejevs, Rad-Chem Foreman R. Boyce, Engr. Asst. (Health Physics)
S. Gurunathan, Station Chemist R. Johnson, Technical Staff Engineer F. Tschakert, Instrument Foreman R. Kruger, Rad-Waste Foreman F. Ost, Health Physicist G. Slobodianuk, Engr. Asst. (Instruments)
M. Davis, Rad-Chem Foreman The inspectors also talked with other licensee employees, including control room and radwaste operators, radiation chemistry technicians, and contractor employees during the course of this inspection.
- Denotes those present during exit interview.
2.
General The inspectors arrived on site at 6 15 p.m.,
March 21, 1979.
Approxicate:.y 30 minutes later clearance through security and escorted entry to a limited portion of the plant were achieved.
Areas visited included entry to Unit 2 containment, radwaste, and selected portions of the auxiliary Duildings. Housekeeping and cleanliness were very good in all areas observed.
Both security and radiation protection were maintaining control of containment access. Protective clothing and respirator supplies were ample.
Radiological conditions appeared satisfactory.
These impressions were reinforced during more extensive tours made later in the inspection when retraining requirements for unescorted access had been satisfied.
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3.
Licensee Action on Previous Inspection Findings (Closed) Deficiency 3 (295/78-26): Failure to notify NRC when quarterly release rate exceeded twice the annual design objective.
Licensee corrective action was confirmed.
(Closed) Deviation (295/78-26): Operation of auxiliary building ventilation system in a degraded mode.
The inspector physically examined the system and verified licensee corrective action.
Orcanization As a result of station reorganization, the radiation chemistry supervisor reports directly to an assistant superintendent.
Also, he no longer attends the morning meeting with the plant superintendent, but meets daily with the assistant superintendent who does.
The radiation chemistry department structure is unchanged. A contractor (NUMANCO) has furnished as many of 13 technicians and a supervisor for the current outage.
The licensee requests the supervisor by name, reviews technician resumes, and right to reject specific individuals.
Their work is reviewed daily by a station health physicist and their use is restricted to coverage of other contractors or CECO management personnel.
Resumes reviewed by the inspector indi ated that for two senior technicians, c
work experience after an assoc.ates degree in health physics was less than two years. However, it was mainly gained during outages et nuclear power plants.
Licensee personnel indicated that performance of these technicians has been generally satisfactory.
No items of noncompliance or deviations were identified.
5.
Licensee Audits QA audit records for April 1978 through February 1979 were reviewed.
Five onsite and two offsite audits dealt partly with radiation protection topics.
The onsite audits identified problems with instrument calibrations and solid radwaste shipments that were subsequently corrected. Another audit noted that one of two radiation / chemistry foremen at the time of his appointment in early 1978 had less than the four years experience specified in ANSI N18.1-1971 for nonlicensed supervisors.
Station management has taken the position that this foreman, who works with another foreman, is regarded as a supervisor in training and is qualified in this role by meeting crrft requirements.
Licensee representatives indicated that the matter has been referred to the corporate manager of quality assurance.
No items of noncompliance or deviations were identified.
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6.
Training Selected records of radiation protection initial training and retraining for CY 1978 and for the current outage were examined.
The inspectors attended the 4-hour General and Radiation Protection Training session on March 22, 1979.
One inspector also attended the respirator training session held during the afternoon. Oral presentations were supplemented by videotapes and demonstrations.
Areas which appeared to need more emphasis in the training included respirator fitting and radiation dose effects.
These matters were discussed with the training supervisor.
No items of noncompliance were identified.
7.
Radiation Protection Procedurec The following radiation protection procedures, changed or new since March 1978, were reviewed.
1210-1 (6-26-78)
Determination of Personnel Radiation Exposure 1210-2 (12-29-78)
Film Badge Program 1210 c ul-13-78)
Expor tre Control 1240-2 (9-13-78)
Calibration of the Eberline Model 6112 Teletector 1240-15 (4-11-78)
Calibration of the Eberline RO-2, RO-2A Portable Survey Instrument 1240-19 (8-28-78)
Operation of the Eberline R0-3A " Cutie Pie" 1240-21 (9-25-78)
Calibration of the Xetex Model 302A High Level Probe 1280-1 (5-15-78)
Radiation Surveys 1280-3 (4-28-78)
Radiological Surveillance of Plant Demineralizers 1310-1 (10-16-78)
Maintenance and Care of Respiratory Protective Equipment 1310-2 (9/78)
Issuance and Selection of Respiratory Protective Equipment 1310-3 (6-14-78)
Operation and Use of the Respiratory Fitting Test System 1310-11 (9-25-78)
Air Sampling and Posting of Suspected and Known Radioactive Airborne Areas 1310-12 (9-25-78)
Containment Air Sampling during, Refueling Outage 1340-3 (7-5-78)
Instructions for the Use of the Whole Body Counter 1340-4 (4-28-78)
Supervisors Procedure for Whole & dy Counting 1350-37 (5-22-78)
High Radiation Monitor Alarm 1480-1 (6-16-78)
Inventory and Leak Test of Radioactive Sources 1610-7 (10-16-78)
Containment Radioactive Gas Sampling for Determining Post Accident Sample System Performance 1620-1 (9-25-78)
Radiological Controls for Eddy Current Testing of Steam Generators-4-347 i83
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No significant problems were identified in this review.
Procedures 1210-2 and 1340-3 will be revised to reflect changes in iork group classifications.
Procedure 1620-1 will be modified to reflect the licensee's practice of requirin; supplied air during steam generator opening.
Problems with the licensee's new method of recording procedure changes were discussed.
Each procedure is assigned an index wherein the dates of the current pages are recorded. However, the overall index of the entire procedure set is not dated and does not carry the date of the latest revision of the individual procedures. Thus the accurney of any procedure cannot be determined without detailed comparison with the naster set of procedures.
This matter was discussed in the exit interview.
No items of noncompliance or deviations were identified.
8.
Instruments and Equipment A review of calibration records for portable survey instruments, portal monitors, hand and foot monitors, air samplers and area radiation monitors for the period of February 1978 to March 1979 was pe-formed.
The inspectors visited the control room twice for monitor operation and setpoint observations.
No items of noncompliance or deviations were noted.
9.
External Exposure Control The inspector reviewed records related to personal exposure for CY 1978 and 1979 through March.
Included were NRC-4, vendor fil-badge reports, bad e and pocket dosimeter assignment sheets, l
a previously described daily exposure update, and a microfiche system that fulfills the NRC-5 requirements. No overexposures were noted except a previously reported 2/ third quarter 1970 exposure of 3.07 rems to a contractor employee. Total station dosa in 1978 was about 1000 man-rens with the highest individual at 5.C1 rems.
The inspector found it difficult to make a detailed audit of contractor exposures, because the computer geneiated microfiche system combines the entire Commonwealth Edison system into a common alphabetical file. The station did not have a readily available, conveniently arranged list of names of all contractors who had been assigned badges at this station.
Previously the microfiche system was simpler, consisting of one page per indivi-dual, and contractors were segregated according to the station at which badges had been assigned. A fairly detailed review of contractor exposures was then possible.
1/ IE Inspection Report No. 295 / ~/ T-08.
2/ Ibid.
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Licensee Technical Specification 6.5.B.8 requires that records of rcliation exposure be recorded in a manner convenient for review.
The question of whether these records meet this require-ment is considered an unresolved item and will be examined further.
NTA film has been used until recently in all regular badges for monitoring neutron dose equivalent. Licensee representatives indicated no special processin,was done and no positive results were ever recorded. NTA film is no longer used in regular badges. Instead, each person on jobs with potential neutron exposure (containment entries at power and neutron calibration source use) exchanges the regulai badge for one that includes NTA film. This special badge is processed soon after use to reduce latent image fading. To date, these special badges have shown no positive results.
Licensee representatives stated that all such work requires prior neutron surveys with a " rem meter" and that a new procedure is being developed to use these survey data with the timekeeping to estimate neutron dose.
Extensive neutron dose measurements were recently made in containment by licensee and Battelle Northwest personnel. The results indicated gamma / neutron dose equivalent ratios are about 100 where neutron level was high (40-80 mrem /hr) and about 2 where neutror. level was low (< 5 mrem /hr). Licensee representatives believe that these data and the infrequent entries made show that neutron dose equivalent is relatively insignificant (< 10%) when compared to gamma dose.
The new procedure described above should resolve this question.
No items of noncompliance or deviations were identified.
10. Internal Exposure Control a.
Respiratory Protection The respiratory protection program was reviewed against the requirements of 10 CFR 20.103.
Improvements to the previously reported program include quantitative fit testing, improved mask use accountab!11ty through unique identification of each mask, and use of irritant smoke tests for-half masks.
Tests were observed and test data for May 1978 to March 1979 were reviewed.
Also reviewed were procedures (Paragraph 7), medical approvals, and the use of air line respirators and hoods pursuant to IE Bulletin 78-07.
This use was as described in the licensee's letter dated August 3, 1978.
No items of noncompliance or deviations were noted.
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b.
Bioassay Bioassay records for the period Marca 21, 1978, to Nbrch 23, 1979, were reviewed. Approximately 1340 counts on 900 individuals were made.
Followup on questionable results usually revealed low-level surface cantamination.
Elevated levels of the short-lived noble gas Xe-133 were detected in whole body counts (WBC) of several individuals following drywell entries.
Subsequent WBC showed the expected rapid decrease in activity to about 5% of initial activity within twenty-four hours.
The bioassay contractor's evaluation indicated liver dose co=mitment of about 60 millirem in the most significant case.
Review of records and discussion with licensee personnel indicated that whole lady counter availability has been about 50% for several months owing to a variety of problems.
As a result, the licensee has had to rely on urinalysis to meet his bioassay commitment. The station has brought the matter to the attention of the vendor, Radiation Management Corporation, and it has also been referred to the licensee's Corporate Office of Industrial Relations.
No items of noncompliance or deviations were identified.
c.
Air Sampling Selected records of iodine, particulate, and gaseous air sampling for 1978 through March 1979 were reviewed, with particular attention given to the ongoing Unit 2 outage.
Procedures and practices were also reviewed and discussed with various licensee personnel. The licensee has acquired portable units suitable for sampling radioiodines and particulates.
A marked increase in the frequency of such samples for specific jobs has been achieved.
The licensee appears now to have an adequate air sampling program.
No items of noncompliance or deviations were identified.
11.
Posting, Labelin g, and Control a.
Posting and Labeling The inspectors noted no discrepancies in licensee posting or labeling pursuant to 10 CFR 19.11 or 10 CFR 20.203.
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b.
Control Exposure control techniques for the outage have been changed to reduce radiation chemistry technician (RCT)
exposures and still achieve satisfactory job coverage.
Workers who may exceed 100 millirems per day are issued self reading dosimeters at a control point at containment entry.
The scheme places more responsibility on maintenance personnel and involves less one-on-one coverage and fewer special work permits.
Certain jobs, such as process line breaking, still require presence of an RCT.
Licensee representatives stated the method is still under evaluation but believe it has been effective.
No items of noncompliance or deviations were identified.
12.
Su rveys Selected records of direct radiation and contamination surveys for the period April 1978 through March 1979 were reviewed.
Satisfactory survey practices were indicated.
Compliance with source leak test requirements was verified for the same period.
Approximately fifty sources were discarded to waste and removed from inventory in December 1978.
No items of noncompliance or deviations were identified.
13.
Notification and Reports The inspectors noted no discrepancies with regard to notifications and reports required pursuant to 10 CFR 20.402, 20.403, 20.405 and 20.408.
The inspectors also reviewed the station's semiannual effluent report for the period July to December 1978. No internal discrepancies were noted.
No items of noncompliance or deviations were identified.
14.
Licensee Event Reports The following licensee event reports (LER's) were reviewed onsite during this inspection:
295/78-122, 133, 138, 79-2, 8, and 304/79-4.
Licensee actions related to these events (tanitor failures) were in accord with technical specification requirements.
No items of noncompliance or deviations were identified.
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Solid Radwaste System Status Station progress in upgrading the solid radwaste system was discussed with various licensee employees.
Rehabilitation work on one of two radwaste evaporators was described as virtually complete.
The other requires replacement of the tube bundle and will be done af ter the outage. Waste water was still being treated by portable demineralizers which were placed just inside the radwaste loading door.
Drumming station performance was still inadequate with upender performance considered acceptable but not optimum and capper performance was still a failure as the hoped for solution of longer retaining ring bolts failed.
These problems have not been of much radiological significance because bulk solidification has been used with little or no drumming. However, an attempt to resume drumming for at least some of the wastes was expected in April. A contract has been let to NUMANCO, Inc. to assist in the unloading of the drum storage area.
Restoration of this portion of the drumming system to design use should alleviate the unfavorabic conditions now
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associated with drumming.
Modification request No. 22- -78-16 submitted in the 3rd quarter of 1978 would enclose and shield from weather the area just outside the radwaste loading doct where bulk solidification takes place.
It would also provide a locatica for the portable demineralizers.
A separate modification has been written to install permanent piping for transfer of wastes to bulk solidification casks.
On May 3, 1979, the inspectors were brought up-to-date on further station progress. Use of portable demineralizers continued and no drumming was being done.
The new capper was onsite and being prepared for assembly with installation expected by June.
Approximately cne third of an estimated 350 drums had oeen removed from the underground storage vaults and sF1pped.
The mcdification for construction of an addition to radwaste had been approved and bid specifications were in preparation.
Station personnel were aiming at December 1979 completion.
No items of noncompliance or deviations were identified.
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16.
Radwaste Spill, February 1, 1979 Licensee representatives described a spill that occurred during the filling of a resin cask for solidific._ ion and shipment.
An estimated 25 gallons of line flush water containing some resins overflowed the cask, contaminating it, the trailer, and the concrete pad outside of radwaste where the transfe: took place.
The occurrence was blamed on failure of a high liquid Iceel alarm together with a frozen overflow line designed to handle such an occurrence. Temperature at the time of this transfer was said to be 10-150F.
A rather extensive cleanup was required.
The tractor was cleaned and released; the trailer was moved to the fuel building loading area, where it awaits final disposition.
This occurrence points out the need to expedite changes, discussed above, which would install permanent transfer piping and shelter the entire cask filling operation from the weather. The problem is exacerbated by the temporary use of a demineralizer in place of the evaporator for treating liquid radwaste.
This darineralizer with its shielding partially blocks the radwaste outside door through which the resin transfer is made.
These problems were discussed at the exit interview.
No items of noncompliance or deviations were identified.
17.
Advance Planning The inspectors discussed outage advance planning with licensee representatives.
The licensee described.Tethods being used to control radiation / chemistry technician doses (Paragraph 10)
as well as the increased use of shielding to reduce general area exposures in containment, particularly on the 560 and 592 levels.
Both of these methods were observed during facility tours.
No items of noncompliance or deviations were identified.
18.
Unresolved Items,
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An unresolved item disclosed during the inspection is discussed in Paragraph 9.
19.
Exit Interview The inspectors findings were discussed in an exit interview with Mr. Wandke and members of his staff (Paragraph 1) on March 20, 1979, and by telephone on May 3, 1979.
No items of noncompliance were identified and the inspectors indicated that radiological matters were generally improved.
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Among the tiems discussed were the following:
a.
Weakening of the bioassay program because of the limited availability of the whole body counter and the resulting reliance on urinalysis.
(Paragraph 10)
Licensee representatives indicated that the matter had been referred to his corporate headquarters and was being pursued with the vendor.
b.
Difficulty encountered by the inspectors in making a detailed audit of contractor exposures via the microfiche file which is designated as the official record.
(Paragraph 9)
Licensee representatives agreed to request periodic generation from the computerized record system of a list of persons assigned badges at Zion during the year.
On May 3, the inspectors were informed that the request, made to the corporate office, had been denied. The inspectors stated that this matter was considered an unresolved item.
c.
The resin spill of February 1, 1979, and the need to proceed with modifications to better accommodate bulk solidification and portable demineralizer use.
(Paragraphs 15 and 16)
Licensee representatives stated that modification requests for a building addition and other improvements had becn submitted. The inspectors learned by telecon on May 3 that the building addition had been approved and that bid specifications were being prepared.
d.
The need for an improved procedure index to termit a reasonable determination of individual procedure currency.
(Paragraph 7)
The licensee stated that a method for makinc an individual procedure book self auditable would be addressed.
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