IR 05000295/1985040

Insp Repts 50-295/85-40 & 50-304/85-41 on 851209-13.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program During Maint Outage,Open Items & Responses to IE Info Notices85-042,85-043 & 85-081

ML20137E406
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/09/1986
From:	Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137E336	List: IR 05000295/1985040 ML20137E330
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-295-85-40, 50-304-85-41, IEIN-85-042, IEIN-85-043, IEIN-85-081, IEIN-85-42, IEIN-85-43, IEIN-85-81, NUDOCS 8601170247
Download: ML20137E406 (18)

Text

~

J/ _ , ;:

U.S. NUCLEAR REGULATORY COMISSION

'

REGION III

Reports:No. 50-295/85040(DRSS); 50-304/85041(DRSS)

. Docket Nos. 50-295;'50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion Site, Zion, IL j' Inspection Conducted: December 9-13, 1985-Inspector: C .;4~ /!9/86 Date Approved By: L. R. Greger, Chief [t//f6 Facilities Radiation Protection Date Section Inspection Summary Inspection on December 9-13,' 1985 (Reports No. 50-295/85040(ORSS);

50-304/85041(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection program during a maintenance outage including: changes in organization, personnel, facilities, equipment, programs, and procedures; audits and appraisals; planning and preparation; training and qualifications of new personnel; internal and external exposure control; control of radioactive materials and contamination, surveys and monitoring; and the ALARA progra Also open items and licensee responses to IE Information Notice Nos. 85-42, 85-43, and 85-81 were reviewed. The inspection involved 40 inspector-hours onsite by one NRC inspecto Results: No violations or deviations were identifie %I

on

'

,.

DETAILS Persons Contacted

• R.? Aker,. Lead Health Physicist

• P. Beinecke, Technical Staff A. 81ess, Regulatory Assurance Staff Assistant

.

R. Boyce, Engineering Assistant - Health Physics

• R. Budowle,-Assistant Superintendent - Technical Services

• R. Cascarano, Technical Staff Supervisor D. Dahlen, Radwaste~ Group Leader

• E. Fuerst,~ Superintendent --Production

-

• J. Gilmore, Operation Engineer C. Kuechle, Health Physicist

• P.'LeBlond, Nuclear Licensing Administrator

• D. Outcalt, Regulatory Assurance Staff Assistant

• T.' Printz, Assistant Technical Staff Supervisor

• J. Ramage, ALARA Coordinator J. Reiss, Lead SNED Engineer - Zion Group q *T. Rieck, Superintendent - Technical Services

• W. Stone, Quality Assurance Supervisor

• G. Trzyna, Rad / Chem Supervisor J. Walls, Quality Assurance Lead Auditor D.~Wozencraft, Radwaste Engineer

• J..Yost, Quality Control Inspector

• L.JGreger, NRC/ Region III, Chief, FRPS

• L. Kanter, NRC Resident Inspector

• J.'-Kish, NRC Resident Inspector

-

J. Norris,:NRC/NRR Zion Project Manager The inspector also contacted other licensee and contractor employees including rad /ches foremen, rad /ches technicians, engineering assistants, and members of the technical staf * Denotes those present at the exit meetin . General This inspection, which began at 1:00 p.m. on December 9, 1985, was conducted to review the radiation protection program'during a refueling and maintenance. outage, including organization and management controls, qualifications and training, audits and appraisals, planning and preparation,_ internal and external' exposure controls, ALARA program, control of radioactive material and contamination, open items, and IE Information Notice Nos. 85-42, 85-43, and 85-81. The inspector conducted radiation'and contamination surveys of selected plant areas using an NRC survey instrument (Xetex 305-B) and licensee survey instrument (Eberline RM-14); readings were in general agreement with' posted licensee data with exceptions as discussed in Sections 10 and 16. No access control or

. apparent procedure adherence problems were note The apparent need to

. improve housekeeping is discussed in Section 1 E. , , :C ,

')

~ Licensee' Actions on Previous' Inspection Findings (0 pen) Open. Item'(295/85005-05; 304/85005-05): Prepare compliance and action plan documents for certain NUREG-0737 items. The licensee has completed a handwritten internal commitment and compliance review document

~w hich states that the licensee is in full compliance with NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3). Upon review, the inspector found the document too superficial to justify the claim of full compliance.- This-item remains open pending an adequate response by the-licensee to the inspector concerns. This matter was discussed at the exit meeting.'

-(Open) Unresolved Item (295/85005-08; 304/85005-08): Resolve acceptability of the use offsealant and tape in the 1983 modification and repair of the control room emergency air cleaning system. The Diractor, Division of Licensing, NRR, by memorandum dated August 26,-1985 (enclosed), has concluded that the licensee's modifications and repairs at Zion Station are not presently acceptable and that there is a need for some form of corrective action. This matter was discussed at the exit meetin (Closed) Violation (295/85034-01; 304/85036-01): Failure to make a required report after exceeding the quarterly technical' specification liquid radwaste release design objective. Licensee corrective actions outlined in the licensee's response dated November 7, 1985, were reviewe No problems were note (0 pen) Open Item (295/85034-02; 304/85036-02): Establish an air and direct radiation monitoring program for the Interim Radwaste Storage Facility storage area and occupied areas. The licensea expects to complete this

. item by' February 1, 198 (0 pen) Open Item (295/85034-03; 304/85036-03): Monitor Interim Radwaste Storage Facility water runoff collected in the sump The licensee expects to complete this item by February 1, 198 (0 pen) Open Itee (295/85034-04; 304/85036-04): Review the potential of gaseous' generation during long-term storage in the Interim Radwaste Storage

' Facility. The licensee expects to complete this item by February 1, 198 (0 pen) Open Item (295/85034-05; 304/85036-05): Develop a container inspection program to assure container integrity in the Interim Radwaste Storage Facility. The licensee expects to complete this item by February 1, 198 .(0 pen) Open Item (295/85034-06; 304/85034-06): Consider placing the first layer of containers on a metal grating to minimize condensate collection in the Interim Radwaste Storage Facility. The licensee expects to complete this item by February 1, 198 . . _ . - _ .

-

-

,

.  ?

'

,

, " Chances-

,

The inspector reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage

'

tradiation protection. progra ~

During this outage, the station RCTs and RCT ,3remen are working ten-hour days _six days per. week. The Health Physicists are also working ten-hour days to provide continuous coverage except froa. 1:00 a.m. to 6:00 a.m. each  :

- morning; however, a Health Physicist remains on all during these. hour Station rad /ches technicians-(RCTs) are assigned as con ainment rovers on each shift. The containment rover's duties include job coverage for  ;

station. employees and monitoring the performance of contracted technician Three rovers are' assigned during the day shift, two during the ,

afternoon / evening shift, and one during the night shif This scheme, combined.with tours by RCT foremen, health physicists, and the ALARA Coordinator, appears to provide needed oversight of contracted technician activitie These changes appear _to benefit the licensee's outage radiation protection program by providing the needed radiation protection coverage on all shifts and better oversight of contractor activitie No violations or deviations were identifie ,

! Radiation Protection Staff Stability The licensee's radiation protection staff has remained essentially unchanged during the last year and a half. This stability and the increasing experience levels appear to have been partially responsible for the licensee's improved performance in the area of radiological control Previously, excessive turnover of the radiation protection staff appears to have contributed to generally poor performance in the radiological controls are .r Contracted radiation protection supervisors are not utilized except during outages. Contracted radiation protection technicians are normally used only during outages; it appears that a significant number of these technicians return to the plant for each outage.

'

No violations or deviations were identifie '

- 6'. Planning and-Preparation The inspector reviewed the outage planning and preparation performed by the licensee, including: additional staffing, special training, increasec.

equipment supplies, and job related health physics considerations.

e 1 4 L l.

.

y.,, ..

1. .- . . , _ - . ......y_,.,,,%, , . , , , . ,y_w,_,-,_ ,_,,_.y~,..._,,,.__,.,__ , , , , , , , _ . . . _ _ _ . _ , . , , , , _ . ,

.

The station's radiation protection group has been augmented with 64 contracted radiation protection technicians, including one site coordinator, two foremen,16 senior technicians, 25 junior technicians, and 20 control point technicians. The inspector verified that those technicians not meeting ANSI N18.1-1971 selection criteria were not providing radiation protection duties without proper supervisio Preoutage special training provided to station and contract workers includes mock-up training for certain high exposure work, ALARA briefings for each work group, and RWP program trainin No problems were noted in this are The supply of portable survey instruments, portable ventilation equipment, and respiratory protection equipment appears adequate for the outag Protective clothing supplies also appear adequate, however, some shortages have been experienced due primarily to unexplained differences between actual warehouse inventories and inventory records. There appears to be no problem obtaining additional needed supplies from other licensee station Evidence that job planning and preparation is influenced by radiation protection includes containment decontamination and shielding prior to allowing outage work to begin, and radiation protection and ALARA participation in all planning and outage meeting No violations or deviations were identifie . Training and Qualifications of New Personnel The inspector reviewed the education and experience qualifications of new plant and contractor radiation protection and chemistry personnel, and training provided to them. Also, radiation protection training provided to other contractor personnel was reviewe Selection of contracted radiation protection technicians includes a review of the technician resumes and a telephone interview with the radiation protection organization of a plant where the technician previously worke After the selected technicians arrive onsite, they receive general employee training and complete a special one-week radiation protection training course emphasizing station radiation protection procedures, use of RWPs, and practical health physics evaluations including shielding calculations. The course was developed and presented by the contractor after the details of the course were reviewed and approved by the license The exam is mostly composed of short answer questions, moderately difficult, and is proctored by the station health physics staf A 70 percent passing grade is normally required; however, exceptions are possible based on the results of an oral exam administered by the Lead Health Physicis No violations or deviations were identifie . -_ _

r-e>

l

,

l Internal Exposure Control Assessment The inspector-reviewed the licensee's internal exposure control and assessment programs, including: changes to procedures affecting internal exposure control-and personal exposure assessment; determination whether e _ engineering controls,; respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and

-

required records,. reports, and notification Whole body counting data, respiratory. protection training and mask fit

. records, MPC-hour determinations, anc air activity surveys for March 1985 to date were selectively reviewed; no , oblems were noted. It appeared o that appropriate air samples were being ollected to support the outage work and that air samples collected were ounted promptly and received timely review of the health physicist No violations or deviations were identifie . External EFDosure Control JThe inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in the dosimetry program to meet outage needs; use of dosimetry; planning and preparation for

maintenance and refueling tasks including ALARA considerations; and i required records reports, and notification ,

Exposure records of plant and contractor personnel for March 1985 to date were selectively reviewed. No exposures greater than 10 CFR 20.101 or administrative limits were noted. Total exposure for 1985 (both Units)-

is estimated to be 1100 person-rems, which is considerably less than the licensee's average over the proceeding five years of about 1400

-

person-ress. There were two extended outages in 1985 with a significant

amount of unscheduled maintenance activities; achieving such a low exposure under these conditions is an indication of an effective ALARA progra The licensee continues to experience a significant rate of lost TLD badges during outages, even though the number of badges lost in the gatehouse has

! been greatly reduced by requiring the TLD badges to be kept with the worker's security badges. This matter is being addressed by the Recurring Station Problems Committee and further reduction in the number of lost TLD l

badges is a 1986 licensee goa No violation or deviations were identified.

,

1 Control of Radioactive Materials and Contamination

+ The inspector reviewed the licensee's program for control of radioactive f materials and contamination, including: adequacy of supply, maintenance,

and calibration of contamination survey and monitoring equipment; effec-l- tiveness of survey methods, practices, equipment, and procedures; adequacy

of review'and' dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.

L

l

'

F.'

l

-

,

~ Inspctor observation of ingress / egress activity at access control points

-

indicate that workers are properly using step off pads and following frisking procedures. The lack of gatehouse portal monitor alarm actuations' during this outage appears indicative of the effectiveness of

_ the ifcensee's whole body frisk policy for workers exiting contaminated

'

area The inspector performed a radiation and contamination survey of tools, equipment, and floor areas in the auxiliary building and the fuel building. No significant problems were noted. A small spool _ piece which

' had smearable internal contamination was found on a cart just outside a

_ posted, roped-off contamination area on the 617 foot elevation in the cross-town area of the fuel building. The dose rate at contact was measured at 5 mR/hr and a smear taken from inside the spool piece read 1200 cpm (15,000 dpm). This matter was discussed at the exit meeting and will be reviewed further during a future inspection. (295/85040-01; 304/85041-01)

During a tour of the laundry facility on the 617 foot elevation of the auxiliary building, the inspector noted that bags of contaminated laundry were lying on the floor in the general access area, outside the designated storage area and that protective clothing had been hung to dry on electrical junction boxes and switches located just outside the laundry frisking room. The bags of contaminated laundry were not marked as containing contaminated material; however, they measured only slightly above backgroun The protective clothing measured 1200 cpm (15,000 dpm)

.at contact. The inspector was told that the protective clothing had been dry cleaned; the contamination was fixed; and the allowable fixed contamination for issuance was 3000' cpm. As previously noted (Inspection Reports No. 50-295/85005; 50-304/85005), during the last refueling outage an unusually high number of personal contamination incidents were attributed by the licensee to " fixed" contamination leaching from protective clothin In an attempt to eliminate this problem, the

'

licensee acquired two replacement dry cleaning units which increased the capacity by fifty percent; a' third dry cleaning unit is expected in time for the.next refueling outage. Additional licensee efforts to upgrade the laundry facility appears needed based on reports from the station health physics staff that incidents of personal contamination due to leaching from protective clothing are still occasionally occurring and based on the inspectors observation This matter was discussed at the exit meeting and will be reviewed further during a future-inspection. (295/85040-02;

.304/85041-02)

No violations or deviations were identifie '

1 Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling i1tage; worker awareness and

involvement;in the ALARA program; establishmen, of goals and objectives, and effectiveness in meeting them. Also reviewed was management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesse *

. .

3-The licensee has established ALARA goals for 1985 including overall station goals for total dose and contaminated areas, and individual working group goals.for total dos The licensee's station goal for total dose in 1985

- was originally 1000 person-ress, considera11y less than the average over the preceding five years of about 1400 person-rems. On June 30, 1985, this goal was updated and increased to 1350 person-rems to account for unscheduled maintenance and underestimation of exposure for specific tasks which occurred during the Unit 1 outage (January 31 through June 9,1985)

and for a revised estimate of the anticipated exposure for the current Unit 2 outage. The estimate for the total dose for 1985 is currently 1100 person-rems which reflects both cancellation of some planned modifications during*the Unit 2 outage, and dose savings due to of ALARA job preplanning

'and post' job ALARA reviews to implement the lessons learned from each task performe 'In addition to the exposure goals outlined above, it is a station goal that no individual receive more than 5 rems during 198 This goal was met in 1984'and to date in 198 The station's ALARA program includes provisions for dose reduction by minimizing contaminated areas. The licensee's goal for 1985 was to reduce the contaminated auxiliary building area to less than 5000 square feet between outages and to keep this area less than 10,000 square feet during outages; this goal does not include auxiliary building cubicles. This goal was met for 1985 and part of the 1986 goal is to further reduce this area'to 2000 square feet. During the outage, the regular decontamination staff was augmented by 20 additional contracted workers who provided around the clock coverage with four workers and one supervisor per shift under the direction of a site coordinator. In addition to decontamination of the auxiliary building general areas, decontamination workers conduct a monthly surveillance and decontamination of non-high radiation area cubicles and decontaminate equipment and areas after maintenance tasks to keep the smearable contamination below the " Potential Airborne Radioactivity Area" posting level of 22,000 dpm/100 cm2for beta, gamma emitters. New proposals of further reducing contaminated auxiliary building areas include a proposed modification to build partial containments around the station's six charging and four safety injection pumps to keep seal leakage in a confined area so that the remainder of the pump cubicle may be effectively decontaminated. Tools kept in the radiologically controlled area in hot tool boxes are surveyed weekly to assure that they are radiologically acceptable for us The station's ALARA program also includes provisions to reduce the number of potential airborne radioactivity areas. The goal for 1985 was to reduce the number of these areas to eight. Before this last outage the number had been reduced from a high of seventeen to six. During the outage, the number of potential airborne areas has increased to eleven. Most of these areas are auxiliary building cubicles but the two vertical pipe chases contain most of the physical area. The licensee indicated that it

- is not feasible to decontaminate the pipe chases; however, efforts are underway to significantly reduce the number of cubicles which are presently designated as potential airborne radioactivity area ,

.

The inspector reviewed the ALARA organization, the qualification and experience of its members, and the effectiveness of the organization in continuing to institute dose saving programs during outages. The professional ALARA staff consists of an ALARA coordinator, an assistant ALARA coordinator, and a radiological engineer; all of whom seem to have the proper qualification, experience, expertise, and dedication to establish and maintain an effective ALARA program. The location of the ALARA group in the station organization, consideration of ALARA principles by other station groups and departments and their working relationship with the ALARA group, management involvement, and the types and number of workers assigned to met ALARA goals also seem conducive to the establishment of an effective ALARA program. A review of the person rems expended during this outage compared to similar tasks during the previous three outage indicates that, except for extenuating circumstances, the licensee has learned well from past experience and has realized significant dose savings by establishing and diligently maintaining an effective ALARA progra No violations or deviations were identifie . Audits and Appraisals The inspector reviewed reports of audits and appraisals conducted for or by the licensee including audits required by technical specifications. Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesses.

.

The licensee's radiation protection / chemistry program receives audits, (

surveillances, and appraisals from several organizations, including: INP0; station quality assurance; and corporate health physics and quality assurance. The last INP0 audit was in June 1984 and the next is scheduled for February 1986. Corporate health physics has an ongoing program involving a number of one-day site oversight reviews each year on specific topics and a trial program for CECO stations baginning next year which will involve more extensive formal audits of the radiation protection programs by several auditors for several days. The station Quality Assurance Department has four formal audits each year and a comprehensive shiftly surveillance program. Corporate quality assurance audits are on an annual basis. The licensee audit, surveillance, and appraisal programs appear adequate to assess technical performance, compliance, and personnel qualification and training in the areas of radiation protection, plant chemistry, radwaste, and transportation. The licensee's responses to audit findings are in general thorough, timely, and technically sound. No problems were noted during the selected review of audit and surveillance reports and the responses to recommendations, findings, observations, and deviation The inspector also reviewed the qualification of the station Quality Assurance (QA) auditors in the areas of radiation protection and chemistr Although the QA auditors in these technical areas seem to have developed adequate audit and surveillance plans to ensure personnel are well qualified and trained and that procedures are adequate and correctly implemented, it appears that the auditors have very little formal training

L

.

f and co'rse work in radiation protection and chemistry. This matter was discussed with the QA supervisor who stated that further training of the auditors in these areas was desirable and such training is being arranged as it becomes available. As an example, he stated that four auditors would be attending a one week course on basic chemistry at the Braidwood training center in the near future. Further training in radiation protection and chemistry is desirable and should be vigorously supported by managemen No violations or deviations were identifie . Facilities and Equipment The inspector toured radiation protection facilities, observed radiation protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staf Newly procured equipment which should enhance the radiation protection program include: (1) bone conduction microphones and headsets to replace poorly functioning throat microphones and headsets; (2) two larger, more efficient protective clothing dry cleaning units to replace ineffective units (a third unit has been ordered); (3) three state-of-the-art portal monitors to replace current less sensitive portal monitors; (4) plastic bag hampers for contaminated protective clothing were replaced by reusable cloth bag hampers to reduce dry active waste; and (5) a Panasonic TLD badging system assessed by station staff which replaced film badges processed by a contracto No violations or deviations were identifie . IE Information Notices and Bulletins The inspector reviewed licensea action taken in response to selected IE Information Notice IE Information Notice No. 85-42: Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Elements. The licensee has purchased and is using this type of TLD. All 6000 new badges were visually inspected before use per station procedure ZTLDP 1400-1; eight TLDs were rejected because of loose phosphor Once in use, TLDs are visually inspected when there is reason to suspect the accuracy of the badge as determined by pre-established criteria, such as a significant difference between the self-reading dosimeter and the TLD. Tests conducted on these suspect badges have not detected a further problem with loose phosphor Some of the licensee's badges have been through 40-50 read-cycles; the frequency of loose phosphors is reported in the information notice to increase substantially after 100-200 read-cycle IE Information Notice No. 85-43: Radiography Events at Power Reactor Health physics personnel were aware of the contents of this notice and stated the necessary administrative control of radiographic activities are required by station procedure ZAP 5-51-10 which outlines control for contractor use of X and gamma ray emitting source ___ _ ______ . _ _ - - . - _ _

,

T IE Information Notice No. 85-81: Problems Resulting in Erroneously High Reading with Panasonic 800 Series Thermoluminescent Dosimeters. The licensee has purchased and is using this type of TLD. Health physics personnel were aware of the content of this notice and stated that a review was conducted of their TLDs and the environment to which they are subjected; no problems were note . Interim Radwaste Storage Facility (IRSF)

Representatives of Brookhaven National Laboratory (BNL), under contract to the NRC, conducted a technical review of the Zion IRSF on October 8 and 22-23, 1985. The BNL report dated November 19, 1985 identified concerns with IRSF dose calculations and associated assumptions including:

(1) omission from the calculations of the gamma streaming effect from duct penetrations in the IRSF vertical wall; (2) modeling uncertainties regarding the skyshine phenomenon; and (3) dispute regarding the exact location of maximally exposed individual. The inspector verified the licensee is recalculating the dose projection to reflect the BNL finding These calculations are expected to be completed by March 1, 1986, and will be reviewed during a future inspection. (295/85040-03; 304/85041-03)

The BNL report also concluded some unreviewed safety questions may not have been addressed in the 10 CFR 50.59 review; this will be reviewed during a future inspection. (295/85040-04; 304/85041-04)

No violations or deviations were identifie . Auxiliary Building and Fuel Building Tour On December 11, 1985, the inspector accompanied a station health physicist on a general tour of the auxiliary building and the fuel buildin The following observations were made during the tour and discussed at the exit meetin * Approximately one dozen incidents of various articles of protective clothing were found abandoned throughout the auxiliary building and the fuel building. Although the items which the inspector surveyed were not significantly contaminated, the presence of such items is an indication of a need for improvement in general housekeepin * During the tour of the laundry facility on the 617 foot elevation of the auxiliary building, the inspector noted that bags of contaminated laundry were lying on the floor in the general access area and protective clothing had been hung to dry on electrical junction boxes and switches located just outside the laundry frisking room. These appear to be examples of poor housekeeping and an indication of a need to improve the operation of the laundry facilit This matter is discussed further in Section 1 * A small spool piece which had smearable internal contamination was found on a cart just ot.tside a posted, roped-off contamination area on the 617 foot elevation in the cross-town area of the fuel buildin This matter is discussed further in Section 1 _ . _ _ _ _ _ _ _ _ _ _ -

w

,i

] ,

.

n

• -Lfrisker booth on the 592 foot elevation of the auxiliary building

,

was'without AC power.

, - * 0n_the 579 foot elevation of the auxiliary building, water was on the floor outside the Domin Tank Room; there was no apparent contaminatio Also, the room lights were non-functional. This item and the previous

'ites may represent. problems with-the maintenance or surveillance program *' "Also'on the 579 foot' elevation of the auxiliary building, a valve was

leaking ingthe sampling area between 1A and 18 charging pump cubicle This valve was connected by a plastic tube to a floor drai The contact dose rate on the tube measured 25 mR/hr in a background of less:than 1 mR/hr. .No labelling _was on the tube or posting of the

. surrounding area to indicate the location and dose rate of this hot spot. Other unlabelled hot spots were also found by NRC inspectors during a previous inspection (Inspection Reports No. 50-295/85005;-

50-304/85005). This matter was discussed at the exit meeting and will be reviewed further during a future inspection (295/85040-05; 304/85041-05).

• - In the mechanical maintenance area on the 542 foot elevation of the auxiliary building, a 50-foot rubber hose and several ladders were measured with a contact dose rate of 5 mR/hr which was about ten times background.' ' Smears taken from these objects indicate that the contamination was fixed. The importance of taking smears from this type'of equipment during routine surveys was discussed with members of the health physics staf No violations or deviations were identifie . Exit Meeting The' inspector met with licensee representatives (denoted in Section 1) at the conclusion of_the inspection on December 13, 1985. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.- The licensee did not identify any such documents / processes as proprietary. In response to certain items discussed by the inspector, the licensee: Acknowledged that the licensee prepared commitment and compliance documentation for NUREG-0737, Items II.B.3 and II.F.1 (Attachments 1, 2, and 3) does'not satisfy the definition of these documents as described in Section 15 of Inspection Reports No. 50-295/85005; 50-304/85005. (Section 3) In response to the NRR conclusion that the use of tape and sealant in the 1983 modification and repair of the control room emergency air cleaning system is not acceptable and that there is a need for corrective action, stated that further discussion with Region III and NRR would be needed to resolve the issu (Section 3)

c. .

-+-

c. Acknowledged the inspector's concerns regarding the apparent need to more carefully survey for and label objects with internal contamination and stated that the adequacy of appropriate procedures would be reviewe (Section 10)

d. Acknowledged the inspector's concerns regarding the apparent need to improve general housekeeping and the operation of the laundry facil.it ,

(Sections 10 and 16)

i e. Agreed to review their procedures to ascertain if formal criteria for hot spot surveillance and labelling should be included. (Section 16)

,

Attachment: -Ltr dtd 08/26/85 from H. L. Thompson, J to J.A. Hind

,

'

C ,. ..

'

'

nee 8 y UNITED STATES NUCLEAR REGULATORY COMMISSION Gy d. kro W .; wAspecTow. o. c. 20sss %g

• \,...../ August 26, 1985 +

W]

i t/1 -

Inu MEMORANDUM FOR: John A. Hind Director Division of Radiation Safety and Safeguards, RIII )

FROM: Hugh L. Thompson, Jr. , Director Division of Licensing, NRR SUBJECT: ADEQUACY OF ZION CONTROL ROOM EMERGENCY AIR CLEANING SYSTEM MODIFICATION AND REPAIR (AITS F03018285)

This is in response to your request of April 9,1985 for technical assistance with respect to the use of temporary sealants in the modifications and repairs of the Control Room Air Cleaning System at the Zion facility, a practice that is contrary to regulatory guidance (Regulatory Guide 1.52). You also noted that the Zion Station may not be committed to Regulatory Guide 1.52 due to its earlier licensing timefram With respect to the question of applicability of Regulatory Guide 1.52 for the Zion Station, the licensee's submittal in response to item III.D.3.4 of NUREG-0737 references use of Regulatory Guide 1.52 with regard to iodine removal efficiencies. Regulatory Guide 1.52 specifies iodine removal efficiencies for systems designed in accordance with the regulatory guide. It is not clear that the licensee's reference constitutes a commitment that encompasses the exclusion of temporary sealants and patching materials from such systems. Nevertheless, it is clear that the intent of item III.D.3.4 was to provide for the protection of the control room operators by providing, among other things, an air cleaning system whose long-term integrity could be assured. It is also clear that the need for long-tenn integrity was a basis for the statement in Regulatory Cuide 1.52 excluding the use of temporary sealants in air cleaning system In the case of Zion Station, there are several factors which compound our concern about the use of temporary scalants and patching materials in the Control Room Emergency Air Cleaning System. The system operates at a negative pressure, it is'mostly located outside of the control room envelope, and there is little _information available on the characteristics or identity of the i

sealent material. It also appears that a relatively small amount of inleakage l

could result in the failure of the system to comply with GDC-19. Experience with silicone sealants in general applications would indicate some degradation may exist today. We presently have no assurance that the sealants have not degraded already, or will not degrade further in the future. Thus, we conclude that the licensee's modifications and repairs at Zion Station are not presently

,

!

l acceptable and that there is a need for some form of corrective action, l

l su , ,

l l

l t

'

e, -

,

- .

. . . ,

k John A. Hind -2- August 26,1985 Enclosure 1 addresses the use of temporary sealants and patching materials in ESF and non-ESF air cleaning systems and suggested alternative corrective actions. Our staff is available for more detailed discussion on this subject should there be a need.

'

ine NRR technical contacts on this matter is Jack Hayes (FTS 492-7632).

.

D Hugh L. Thompso ,

-

rector Division of Licensing Office of Nuclear Reactor Regulation Enclosure: As stated -

<. ,

' 't ,

L b

%

h-k

,

i e

d

,;

. . . -. .

. '.

ENCLOSURE 1 GENERAL GUIDANCE ON THE USE OF TEMPORARY SEALANTS AND PATCHING MATERIALS IN AIR CLEANING SYSTEMS It has recently become apparent that the use of sealants and tape to control

,

leakage is .a common pructice on ESF and non-ESF air cleaning systems in nuclear power plant This practice is contrary to guidance provided in Regulatory Guides 1.52 and 1.140. Specifically, the Regulatory Guides state that "The use of silicone sealants or any other temporary patching material on filters, housing, mounting frames or ducts should not be used." A problem arises as a result of the licensees' classification of these materials as permanent rather than temporary. While the quality of some of these sealants has improved, the NRR staff has not yet accepted such materials as being good for the life of the plant. Thus, it is the staff's position that these materials can be expected to degrade over a period of years and may result in unacceptability high leakage in ductwork or filter housing The use of temporary sealants or patching materials in control room emergency air cleaning systems is of particular concern to the staff since degradation of these materials could lead to the inability of the system to meet General Design Criterion 19. There is the additional concern over the ability of the

_ _ _ - -. _ .

,

-

.

-

i system to adertuately protect the operators from accidental releases of toxic

'

gases. These systems typically operate at' a negative pressure resulting in the potential for inleakage of contaminated air which would subsequently be discharged into the control room without filtration. Nominal leakage in sections of ductwork or filter housings located within the control room envelope is usually.of no concern to the staff. However, those systems or

.

sections of systems which operate at a negative pressure and are located outside of the control room envelope may fail to protect the control room operators from a radiological or toxic gas hazard. Such systems should be !

'

evaluated to determine the need for corrective actio Several alternatives are available in the event a need for corrective action is indicated. Replacement of the system with all welded construction is an expensive action which may not be justified. An exception may be where only a short section of duct is outside of the control room envelope. Similarly, replacement of sealant with welded joints in the entire system may be impractica Frequently, the ductwork is of too small a gauge to pemit welding and is not easily accessible. However, replacement welding should be considered on problem areas of filter housings. The most practical corrective action may be a leakage testing program which would establish the long-tenn

'

integrity of the sealant or patching materials used and the total system.

.

Since rapid deterioration of the sealants would not be expected, a testing period on the order of 18 months should be adequate. This approach will require an analysis to detenni.ne the rate of inleakage which could be tolerated without exceeding the GDC-19 dose criteria, and taking into consideration any

-_ . _.- -- ._ _ - - -

-. .

-

,

. . ,

'

potential toxic gas hazard. This number will be the basis for establishing an acceptance'value for the periodic test, and the magnitude of the acceptance value will probably determine the method of leakage testing which should be used to demonstrate system integrit .

Other ESF and non-ESF air cleaning systems vary so much in design that little ,

guidance can be provided with respect to use of temporary sealants. Leakage in most of_ these systems is not expected to be as critical as for control room systens. However, one should not jump to the conclusion that leakage in such systems is unimportant without first considering the likely magnitude of the leakage, whether the system operates et a negative or positive pressure or both, whether increased leakage has the potential for degrading the system to the point that it could not fulfill its intended air cleaning or ventilation functions, for creating a pathway for unmonitored releases, etc. Therefore, such systems should be evaluated on a case-by-case basi .

>