IR 05000295/1986025

Insp Repts 50-295/86-25 & 50-304/86-25 on 861117-870130. Violations Identified:Failure to Record Gaseous Effluent Activity Released to Environ During Containment Purges & to Conduct in-place HEPA Filter Testing Following Maint

ML20210U777
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/10/1987
From:	Gill C, Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210U681	List: IR 05000295/1986025 ML20210U675 ML20210U691
References
50-295-86-25, 50-304-86-25, NUDOCS 8702180584
Download: ML20210U777 (27)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-295/86025(DRSS);50-304/86025(DRSS)

Docket Nos. 50-295; 50-304 License Nos. DPR-39; DPR-48

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Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 i

Facility Name: Zion Nuclear Power Station, Units 1 and 2 Inspection At: Zion Site, Zion, Illinois l ,

Inspection Conducted: November 17, 1986 through January 30, 1987

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Inspectors: Wh c9 -/0 -87 Date

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} -/o -S7 Date W. J. Slawinski Approved By: L. , c9 -/O -6 7 Facilities Radiation Protection Date

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Inspection Sunmary,

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!. Inspection en Navember 17, 1986 through January 30, 1987 (Reports No. 50-295/86025(DR55); No. 50-304/86025(DR55))

. Kreas Inspectecf: Routine, unannounced Tnspection of the radwaste management and radiation protection programs during a refueling and maintenance outage

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. including: changes in organization, personnel, facilities, equipment,  :

& , programs, and procedures; audits and appraisals; planning and preparation; )

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- " training and qualifications; internal and external exposure control; control

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? ..of radioactive materials and contamination, surveys, and monitoring; solid

j radwaste; transportation activities; and the ALARA program. Also open items, ;

.certain TMI Action Items, HVAC issues, and selected LERs were reviewe Results: Two violations were identified (failure to record gaseous effluent activity released to the environment during containment purges - Section 20; failure to conduct in place HEPA filter testing after filter housing structural maintenance - Section 25). l

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,, , 8702180584 870211 N, PDR ADOCK 05000295 I G PDR 1

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s DETAILS

, Persons Contacted

• J. Ballard, Quality Control Supervisor

- #*P3 Beinecke, Techr.ical Staff

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S.'8erczynski, HVAC System Engineer

• A.' Bless, Regulatory Assurance Compliance Specialist-R. Boyce, TLD Coordinator T. Boyce, Fire Marshall

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1. D. Budowle, Assistant Superintendent Technical Services E. Campbell, Master Instrument Mechanic J. Carlson, Radwaste System Engineer

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• R. Cascarano, Technical Staff Supervisor

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R. Cole, SNED Engineer D. Dahlen, Radwaste Group Leader D. Dumbacher, Radwaste System Engineer K. Garside, Radwaste Shipper G. Geer, Radwaste Planner L. Holden, Regulatory Assurance Compliance Specialist G. Kassner, Health Physicist

+W. Kurth, Assistant Superintendent, Operating

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• L. Lanes, Lead Rad / Chem Foreman

@P. LeBlond, Nuclear Licensing Administrator F. Lentine, Zion Project Engineer, SNED R. Palatine, Health Physicist

1. G. Plim1, Plant Manager R. Principle, Assistant ALARA Coordinator

1. +*T. Printz, Assistant Technical Staff Supervisor

• J. Ramage, ALARA Coordinator

@#*T. Rieck, Superintendent, Technical Services B. Robinson, Rad / Chem Foreman L. Schaeve, Chemist B. Schramer, Stationman Supervisor

@#*C. Schultz, Regulatory Assurance Supervisor T. Sharp, Technical Analyst C. Sprandel, Quality Assurance Auditor D. Stachon, Instrument Maintenance Foreman

1. • W. Stone, Quality Assurance Supervisor

1. • G. Trzyna, Rad / Chem Supervisor D. Vestal, Health Physicist

• Williams, Lead Health Physicist

1. • J. Winston, Quality Control

+*P. Zwilling, Chemist

1. P. Eng, NRC Resident Inspector

1. M. Holzmer, NRC Senior Resident Inspector L. Kanter, NRC Resident Inspector

1. R. Kazmar, NRC Project Inspector

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The inspectors also contacted other licensee employees and contractors including rad / chem foremen, rad / chem technicians, engineering assistants, and members of the technical and operating staf * Denotes those present at the exit meeting on December 12, 1986.

+ Denotes those contacted by telephone between December 15, 1986 and January 7, 1987

1. Denotes those present at the exit meeting on January 9, 1987.

@ Denotes those contacted by telephone on January 30, 198 . General This inspection which began at 12:10 p.m. on November 17, 1986, was conducted to review selected portions of the radwaste management and the radiation protection programs 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, solid radwaste, transportation activities, the ALARA program, control of radioactive material and contamination, open items, certain TMI Action Items, HVAC issues, and selected LERs. The inspectors conducted radiation and contamination surveys of selected plant areas using NRC survey instruments (Xetex 305-B and Ladlum 14c); readings were in general agreement with posted licensee data. Areas posting and general housekeeping were adequate. Access control frisking problems and the licensee s plans to improve housekeeping in the DAW compactor area are discussed in Section 1 . Licensee Actions on Previous Inspection Findings (Closed) Open Items (295/82020-05; 304/82018-06): A retraining program for Radiation Chemistry Technicians (RCTs) has been established. RCTs are scheduled for two weeks of retraining annually. Records of training for 1986 were selectively reviewed; no problems were identifie (0 pen) Open Items (295/85005-05; 304/85005-05): Prepare compliance and action plan documents for certain NUREG-0737 items. The licensee has completed a draft internal commitment and compliance review document which identifies several action items needed to assure compliance with NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1,,2, and 3). The status of these action items will be reviewed further during a future inspectio (Closed) 0)en Items (295/85005-07; 304/85005-07): Replace / repair degraded auxiliary auilding exhaust ventilation ductwork. During plant tours, the inspectors verified that the degraded ductwork has been adequately replaced / repaire This matter is considered close I

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(Closed) Unresolved Items (295/85005-08; 304/85005-08): Review the adequacy of control room ventilation system repairs and modification See Section 2 (0 pen) Open Items (295/85034-02; 304/85036-02): Established a radiation monitoring program for the interim radwaste storage facility (IRSF).

The licensee expects to complete this item, including appropriate procedures, by June 1987. This matter will be reviewed further during a future inspectio (0 pen) Open Items (295/85034-03; 304/85036-03): Monitor IRSF sump runof The licensee expects to complete this item, including' appropriate procedures, by June 1987. This matter will be reviewed further during a future inspectio (0 pen)OpenItems(295/85034-04;304/85036-04): Review the potential for gaseous generation during long term radwaste storage in the IRSF. The licensee expects to complete this item, including appropriate evaluations and procedures, by June 1987. This matter will be reviewed further during a future inspectio (0 pen) Open Items (295/85034-05; 304/85036-05): Develo) an IRSF container inspection program. The licensee expects to complete t1is item,_ including appropriate procedures, by June 1987. This matter will be reviewed further during a future inspectio (Closed) Open Items (295/85034-06; 304/85036-06): Evaluate placing the first layer of IRSF containers on metal grating to minimize condensate accumulation. The inspectors reviewed the licensee's decision that the use of metal gratings was inadvisable; no problems were noted. This matter is considered close (Closed) Open Item (295/85040-03; 304/85041-03): Reassess the interim radwaste storage facility dose calculation. The licensee responded to this matter in a letter to the NRC Regional Administrator dated November 20, 198 The inspectors reviewed this response and interviewed appropriate licensee representatives; no problems were noted. This matter is considered close (0 pen)UnresolvedItems(295/86028-01;304/86028-01): Control room and TSC ventilation systems not able to meet design requirements. See Sections 22 and 2 . Organization and Management Controls  !

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The inspectors reviewed the licensee's organization and management controls for the radiation protection program including: changes in l the organizational structure and staffing, effectiveness of procedures I and other management techniques used to implement these programs, and :

experience concerning self-identification and correction of program !

implementation weaknesses. Audits are discussed in Section 1 l

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Currently there are 36 rad / chem technicians (RCTs). All but one have greater than two years of applicable experience and meet the selection criteria stated in ANSI N18.1-1971 for technicians in responsible positions. The exception is a recent. transfer to the rad / chem staff with approximately six years of station operations experienc Technical support ~for the radiation protection group is provided by six-engineering assistants, technicians, or technical analysts and four degreed health physicists (HP), including the lead HP. Three of the: health physicists have B.S. degrees in health physics, including the lead HP, and one has'an M.S. degree in a related discipline.. Two health physicist have, on the average, only six months of related plant experience. According to the lic<!nsee, a health physicist from their corporate office ~will be transfe ring to the station early in 1987 to supplement.the permanent staff; 1.his individual has a Ph.D. in chemistry but'no plant operational experienc The Lead Health Physicist reports to the' Rad / Chem Supervisor and is responsible for supervising radiation protection group activitie The Lead HP meets ANSI N18.1-1971 requirements for supervisors not requiring AEC Licenses. The Rad / Chem Supervisor is designated as the station's Radiation Protection Manager (RPM), meets ANSI N18.1-1971 requirements for RPM, and appears to have direct access to the Station Manager for resolution of matters related to radiation safety. The RPM also has-periodic meetings with appropriate plant management to discuss the radiation protection program; these meetings are documente No violations or deviations were identifie . Radiation Protection Staff Stability The station's RCT staff has remained essentially unchanged during the last year; or.e RCT position was added in 198 However, as a result of promotions and terminations, the professional health physics staff has changed considerably in the last year; only two of the five health physicists at the station in 1985 remain on the current staff. The two health physicists appointed in 1986 and the one anticipated for early 1987 have no previous operational plant experience. Past improvements in radiation protection staff stability appeared at least partly responsible for the increase in the licensee's overall radiation protection arogram performance over the last ,

two year During future inspections, t1e potential negative effect associated with the recent reduction in professional health physics staff stability on this positive trend will be followe ,

d No violations or deviations were identifie . Changes The inspectors reviewed changes in the organization, personnel, facilities,.

equipment, and programs that could affect the outage radiation protection progra _ .

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During the current Unit 1 outage,-which' began in early September 1986, the station RCTs and foremen are typically working ten-hour days, six days per week. The health physicists are also working ten-hour days and provide continuous coverage except from 2:00 a.m. to 6:00 a.m.; however, a health physicist remains on call during these off-hours. To provide additional support, an experienced corporate health physicist,-familiar with the-station, was assigned to the station for this outage through November 198 Both station and contractor RCTs are assigned as containment rovers on

.each-shift. Station containment rover duties include job coverage for station employees and monitoring the activities of contracted technician '

-Two or three station rovers are assigned during the day shift and typically two are assigned during the other shifts. This, combined with tours by RCT foremen, health physicists, and the ALARA Coordinator, appears to provide needed oversight of outage activitie The station laundry facilities have been augmented with two vendor dry cleaning units; one unit is currently operable. The vendor laundry trailer is located in the Unit No. 2 turbine buildin These changes appear to benefit the station outage radiation protection

)rogram by providing the needed shiftily radiation protection coverage and 3etter oversight of outage activitie No violations or deviations were identifie . Planning and Preparation The inspectors reviewed the outage, planning and preparation performed by the licensee, including: additional staffing,-training, increased equipment and supplies, and job related health physics consideration The station radiation protection group has been augmented with 49 contracted radiation protection personnel, including one site coordinator, three field techniciansupervisors,22seniortechnicians,16juniortechnicians,and seven control point technicians. At the time of this inspection, approximately 25 radiation protection contractor personnel remained at the station. The inspectors verified that those technicians not meeting ANSI N18.1-1971 selection criteria were not^providing radiation protection duties without proper supervisio Radiationprotectioninfluence/participationinjobplanningand preparation incudes mock-up training for high exposure work decontaminationandinstallationofshieldingpriortoinitiationof work, and radiation protection and ALARA participation in planning and outage meeting No violations or deviations were identifie l i

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8. Training and Qualifications The inspectors 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 station and 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 the plant where the technician previously worked. After selected technicians arrive on-site, they are required to receive nuclear general employee training (NGET) and complete a required reading list which includes radiation protection procedures and other documents related to the outage radiation protection program. Following this, each contracted technician must pass two written examinations. The exams are a combination of multiple choice and essay questions on radiation protection procedures and polices and practicable radiation protection shielding and dose problems; the exams appeared to be moderately difficul If a minimum exam grade of 70% is not achieved, technicians may be downgraded to a lower technician position or removed from the program entirel According to the licensee, no senior or junior contractor technicians failed the exams. The technicians also receive respiratory training and associated mask fitting, as appropriat The inspectors reviewed the Rad / Chem (RCT) retraining progra During 1985, the licensee formed a continuing training committee to establish and implement a continuing training program for RCTs. Each RCT was scheduled for two weeks of continuing training during 1986. Records reviewed indicate this training, which includes training on the High Range Sampling System (HRSS), has been completed. After completion oftrainingineachsubjectarea,writtentestingisperformedandthe students must demonstrate acceptable task performanc rovided to The inspectors stationmen, also reviewed especially relatingportions of the to radiation training p/ decontamination protection activities. Stationmen training requirements are outlined in Zion Administrative Procedure ZAP No. 2-52-1 and consist of a general orientation program (approximately 17-days duration) and specific stationman training (approximately two to three days); the latter is provided by the Stationmen Superviso Orientation training includes the following:

• NGET

• Use/ familiarization of survey instrumentation

• Segregation of laundry and DAW

• PC laundering

• Area and material decontamination

• Fire protection

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Stationmen training includes the following:

• Safe work practices

• Radiation )rotection and monitoring techniques

• Radwaste slipments Stationmen are required to perform various tasks on a rotational basi Stationmen perform decontamination work as directed by the Rad / Chem Department, under the supervision of their foreme No violations or deviations were identifie . Externai Exposure Control The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification Exposure records of plant and contractor personnel for 1986 to date were reviewe No exposures greater than 10 CFR 20.101 or station administrative limits were note The inspectors reviewed the licensee's dosimetry program to verify compliance with NRC requirements (Form NRC-5) which specify that whole body doses be determined using a maximum absorber thickness of 1000 mg/cm2 when e 2 maximum of 300 mg/ye cm2 withoutprotection eye (y>rotection.700 The licensee'smg/cm ) is provided dosimetry stem; one chip with a tissue program employsthickness equivalent absorber the useofofseven a 4-chip mg TLD sy/cm2, two with 300 mg/cm2, a one chip at 1000 mg/cm2 . Currently, the station's official record of whole body exposures are determined through a tissue equivalent absorber of seven mg/cm 2 ; eye protection is not routinely required. A recent computer error resulted in whole body doses for December 1986 and part of January 1987 to be recorded through 1000 mg/cm2; however, this caused only one individual's exposure to increase by one millirem. The licensee is evaluating whether to modif exposures through 300 mg/cm Skin ydoses their have dosimetry and willprogram continuereport to be whole body determined through a tissue equivalent absorber of seven mg/cm2 ,

No violations or deviations were identifie . Internal Exposure Control The inspectors reviewed the licensee's internal exposure control and assessment program, including: changes to procedures affecting internal exposure control and personal exposure assessment; determination whether

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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 records, MPC-hour determinations, mask fit records, medical qualification, and air activity surveys for 1986 to date were reviewed; no problems were noted. About 1900 whole body counts for company and contractor personnel were selectively reviewed. Several follow-up counts were performed on persons who showed elevated initial counts. Follow-up counting was adequate to verify that the 40 MPC-hour control measure was not exceede No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment, and procedures; adequacy of. review and disseminations of survey data; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section 1 Whole Body Frisking In late August 1986 the licensee installed seven Nuclear Enterprises ModelNo.IPM-7wholebodyfriskers;fourarecurrentlylocatedin the auxiliary building near Unit 1 containment egress and three are located at the auxiliary building exit at the 617' level. Workers are required to frisk shortly after removing their protective clothing and again while in their street clothes prior to leaving the auxiliary building. Frisker alarm setpoints are established using Cs-137 calibration sources and currently are set at 10,000 d)m (4.5 nCi) for whole body and feet and 5,000 dpm (2.25 nCi) for the lands. In addition, hand-held friskers and lead-lined frisking booths are located at various levels of the auxiliary building for use by personnel upon exiting contaminated area The inspectors observed workers exiting containment during several shift changes to ascertain the degree of procedure adherence regarding removal of protective clothing, use of step-off pads, and frisking requirement Although overall procedural adherence was fair, several incidents were noted of improper use of the new whole body friskers; see Section 1 _. _

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Personnel alarming either of the two guardhouse portal monitors are required to clear the same monitor two out of three times before leaving the sit If this-fails the individual frisks his feet and hands and returns to the rad / chem office for whole body frisk Based on )reliminary data and comparison to previous outages, it appears tlat the new whole body friskers have been at least partially responsible for a reduction in the number of gatehouse portal monitor alarm b. Personal Contamination Incidents StationRadiationProtection(RP)ProcedureNo.1470-1requiresa Personnel External Contamination Record (PECR) form be prepared for any detectable personnel and/or clothing contamination event. During the period January through November 1986, 176 personnel contamination incidents occurred. The peak month was October when 72 incidents were recorded. A significant number of incidents also occurred in September (31) and January / November (19 each). Increased incidences ccrrespond to outage periods; those in September and October 1986 correspond to the current Unit 1 outage and can partially be attributed to the increased monitoring sensitivity of the new Nuclear Enterprise IPM-7 whole body frisker The 72 incidents in October occurred dueing peak outage work when eddy current testing, steam generator tube sleeving and split pin work was performed; 32 percent of the 72 contamination events were related to these major jobs, the majority of contamination involved contractor personnel. Approximately 40 percent of the personal contamination incidents for October were attributed to carelessness and improper working techniques while nearly 20 percent were attributed to leaching of " fixed" contamination from protective clothing. Personal contamination incidents are trended and a monthly report is issued to station management. The reports describe the contamination event, probable cause and corrective actions taken or planned. Lists of contractor personnel-contaminated during a,given month are distributed to the respective contract group supervisor; repeat offenders are counseled or reprimanded, as appropriat Station RP Procedure No. 1190-1 requires Radiation Occurrence Reports (RORs)bepreparedwhenpersonnelcontaminationoftheskin or clothing yields radiation levels greater than 1 mR/hr above background, as measured with an appropriate beta / gamma instrumen R0R trending for 1985 through the third quarter of 1986 showed a decrease of approximately 40 percent in the number of R0Rs initiated for personnel contaminations in 1986. The reduction in these

"significant" personnel contamination events indicates a positive trend in the station contamination control progra . ,- . . -

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The licensee possesses three (55 pound capacity) dry cleaning' units; two of which were added in 1986.- During this inspection, only one

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unit was operational, the others have burned-out motors.~ A vendor-lalso has two dry cleaning units onsite, one currently operational ~.

According to the licensee, an adequate supply of " clean PCs was available during the current outage. Plans for the upcoming Unit 2-i outage, scheduled to begin February 1987, include continuing the use of an.onsite laundry vendor-and/or shipping protective clothing i offsite. Licensee representatives stated that the turn-around time j for an offsite vendor would be about two day : The licensee attributed many personal contamination incidents to-

" fixed" contamination: leaching from PCs. Protective clothing

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release criteria for reissuance is 1 mR/hr at one inch, measured with-an RM-14 rate meter coupled to an Eberline HP 260 probe, approximately 3000.dpm/100'cm2 The licensee believes'the apparent-excessive number-of personal contamination incidents attributed to leaching could partially be due to the fact that the " Personnel-

External Contamination Record" form defaults to this reason when other general categories do not apply. The licensee plans o modifying the report forms to include more comprehensive cause for personal contamination incidents.

On September 12, 1986, two individuals working in the licensee' laundry facility were taken to an area hospital as a result of-Freon

, gas leakage; the individuals were later released. This problem, coupled with motor burnout of the dry cleaning units and PC " fixed"

contamination leaching problems, appear to indicate that additional

efforts to upgrade the laundry facility, including additional' training and reinforcement of procedural adherence, are needed. -This matter was discussed at the exit meeting and will be reviewed further during a future inspection (295/86025-01; 304/86025-01). Contamination Surveys

, Routine auxiliary building surveys are conducted by members of the~

rad / chem staff and include smears and direct measurements. Rad / Chem t Technicians (RCTs) survey one floor of the auxiliary building per day, thus the entire building is surveyed each week. Auxiliary building cubicles routinely entered are'also surveyed as described above; those cubicles not routinely frequented are surveyed prior to entry or as needed. The inspectors selectively reviewed auxiliary building-

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survey results for the third and fourth quarters of 1986 to date; no problems were noted. Areas exhibiting high radiation levels or

removable contamination greater than 1000 dpm/100cm2 are identified on the survey forms. Areas exhibiting greater than 22,000 dpm/100cm2 removable are posted as " Potential Airborne Radioactivity Areas."

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The licensee plans on initiating on auxiliary building cubicle contamination control program in early 198 Proposed plans call for identifying then isolating the source (s) of contamination with partial barriers (plexiglas or other containments around pumps, andothermajorsourcesofcontamination),deconningsurrounding aceas, tracking / trending contamination levels, and use of smaller step-off pads moved inside the cubicles. The advantages of such a program were discussed at the exit meeting and will be reviewed further during a future inspection (295/86025-02; 304/86025-02).

No violations or deviations were identifie . Radiation Occurrence Reports The inspectors reviewed Radiation Occurrence Reports (R0Rs) for 1986 through December 5, 1986; there were 44 R0Rs written during this perio RORs were typically for personnel contamination incidents failure to followRWPrequirements,andfailuretoadequatelycontrolaccesstohigh radiation areas. The RORs were selectively reviewed for significance, corrective action adequacy, and timeliness of corrective actions. The reports appeared to have adequate and timely corrective action Disciplinary action was taken when deemed warrante No violations or deviations were identifie . Maintaining Occupational Exposures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outages; wor (er awareness and involvementintheALARAprogram;establishmentofgoalsandobjectives, and effectiveness in meeting them. Also reviewed was management technigues use to implement the program and experience concerning self-identification and correction of implementation weaknesse Total exposure for 1985 was approximately 550 person-rems per reactor, matching the stations ALARA goal. This is about 20 percent less than the station's average over the previous five years but 35 percent higher than the 1985 average for U. S. pressurized water reactors. Much of the station's 1985 exposure was accumulated during a 140-day Unit 1 outage early in the year and a 151-day Unit 2 outage which began September 198 The licensee has established ALARA goals for 1986 including overall station goals for total dose and contaminated areas, and individual working group goals for total dose. The licensee's station goal for total dose in 1986 is 651 person-rems. The current estimate for the total dose for 1986 is about 500 person-rems. This indicates a significant dose savings considering the Unit 1 outage activities

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i performed during the year including: steam generator edd testing, valve maintenance work, and snubber inspection, y currentrepair, and testing.

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In addition to the exposure goals outlined above, it is a station goal that no individual receive more than 5 rems a year. This goal was met in 1985 and to date in 1986.

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The station's ALARA program includes provisions for dose reduction by minimizing contaminated areas. The licensee's goal for 1986 was to reduce

, the contaminated auxiliary building areas, excluding cubicles, to less-than 2000 square feet during non outage periods and less than 7500 square-feet during outages. This' goal was met for 1986 thereby reducing the

, 1985 goals of 5000 and 10,000 square feet by 60%,during non-outages and 25% during outages, respectively. Preliminary plans for 1987 call for a further reduction during outages to 6000. square fee During non-outage periods routine decontamination work is performed by the Stationmenstaff,currentlycomprisedof31 individuals,withassistance

, from four contractor personnel assigned to the ALARA group. The number of

, stationmen assigned to decontamination work varies depending on work assignment priorities. For the current outage the regular decontamination staff is augmented by 19 additional contracted, workers who provide around-the-clock coverage. Thirteen of these 19 contractors work primarily in general auxiliary building access areas; the remainder, a five-man crew plus foreman, provide continuous coverage for containment decontamination wor the station has been a photo library A

of useful ALARA auxiliary tool building utilized by/ equipment and scale mock-ups of various cubicles equipment / components. Thephotofileisusedinconjunctionwith radiologicalsurveydataduringpre-jobmeetingswithworkcrews. The licensee is developing a computer program to index the ALARA photo library by equipment description. Mock-ups include split pin replacement seals, steam generators, and reactor coolant filtration system The inspectors 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

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the ) roper qualification, experience, expertise, and dedication to esta)lish and maintain an effective ALARA program. In addition, a fuel handler has frequently arovided assistance to the ALARA grou over the last four years. T1e location of the ALARA group in the station-organization, consideration of ALARA princi)les by other station groups

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and departments and their working relations 1i) with the ALARA group, t

management involvement, and the types and num)er of workers assigned to j

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met ALARA goals also seem conducive to the establishment of an effective ALARA progra A review of the person-rems expended during this outage compared to similar tasks during the previous outages indicate that the licensee has learned well from past experience and has realized significant dose savings by maintaining an effective ALARA progra No violations or deviations were identifie . Solid Radicactive Waste The inspectors reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality

] assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits are discussed in Section 1 The licensee's Radwaste Operations staff is responsible for operating the radwaste processing systems and loading, blocking, and bracing of radwaste shipments. The staff consists of a Radwaste Shipper, a Radwaste Planner, six Radwaste Foreman working under the direction of a Shift Engineer, six

, Radwaste system operators and six contractor personnel. The contractors j compaction, and shipment have iciding,various blocking,duties including and bracin TheDAW segregation,s Rad / Chem licensee Departme performs all radiological surveys for radwaste shipments and maintains the shipping record ,

Records of solid radioactive waste shipments made from July through l November 1986 were selectively reviewed. Fourteen shipments containing nearly 191 curies in 4240 cubic feet of solid wastes were shipped during this period. For 1986 through November, the licensee generated a total of 10,642 cubic feet of solid radwaste; another 800 cubic feet is expected to be generated by the end of the year. This represents a significant reduction in solid waste production over 1985 when nearly 24,000 cubic l feet were generate This reduction is due, in part, to the licensee's conscientious efforts to minimize solid radwaste volume by use of radwaste process equipment, waste segregation, and DAW compactio The licensee formed a DAW Reduction Committee chaired by the Technical Services Superintendent; the committee implements programs to reduce the amount of solid radwastes generated. The licensee has ordered a small solid waste shredder and a mop head dryer which are expected to reduce DAW by about 10%. The licensee employs a vendor supplied super-compactor to further reduce the generaction of DAW filled drums (compaction ratio about 2.4); the resulting " pucks" are placed in new drums for shipment and burial. The licensee is considering upgrading their DAW compacter to

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increase its pressure and packing efficiency and are establishing a new DAW sorter program to segregate clean" DAW. Sorter procedures have been approved and activities are scheduled to commence in early 1987. Also, the licensee plans on modifying their DAW compaction area by enclosing it in a booth or cell-type structure. Currently, the DAW compactar is located in a general access area of the auxiliary building, segregated by a plastic retaining wall about three to four feet high. The insaectors noted numerous barrels of contaminated oil stored just outside tie DAW compactor the physicalbarrier; general modifications housekeeping are complete see(in this area Section 18). should improve once No violations or deviations were identifie . Transportation of Radioactive Materials The inspectors reviewed the licensee's transportation of radioactive materials procedures program, including:tained are adequate, main current, properly approved, anddetermina acceptably implemented; determination whether shipments are in compliance with NRC or 00T regulations and the licensee's guality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of re documentation, and notifications; quired records, reports, shipmentand experi and correction of programmatic weaknesse The inspectors selectively reviewed portions of the solid radwaste shipment records for 1985 and to date in 1986. The information on the shipping papers appears to satisfy NRC, D0T, and burial site requirement The licensee had 75 solid radwaste shipments in 1985 and 39 shipments in 1986 through November totaling 23,748 and 10,642 cubic feet, respectivel The majority of 1986 shipments were to the Barnwell, South Carolina sit The inspectors observed a loaded flat-bed trailer containing solidified labeling, or oil liners; no placarding problems were noted. related to blocking, There were bracing, incidents noted no transportation in the last yea No violations or deviations were identifie . Audits and Appraisals The ins)ectors reviewed reports of audits and appraisals conducted for or by tie licensee including audits required by technical specification Also reviewed were management technicues used to implement the audit program, and experience concerning icentification and correction of programmatic weaknesse The licensee's radiation protection / chemistry program undergoes audits, surveillances, and appraisals from several organizations, including:

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INP0, station quality assurance, and corporate health physics and quality assuranc Findings of the 1986 INP0 audit were previously described in Inspection Reports No. 50-295/86004; 50-304/8600 In 1986 the licensee implemented an expanded guality assurance surveillance program emphasizing direct observation of activities and com>1iace with implementing procedures. The expanded program consists of sliftly surveillances in categories including rad / chem instrument calibration chemical sampling and analysis, radiation area access controls, radiation occurrence report followup, radiation protection and radwaste activities, -

and general housekeeping. This appears to be an effective method for continually assessing technical performance, procedural compliance, and the general quality of the radiation protection progra Approximately one hundred QA surveillances were performed of the rad / chem program in 1986. Findings are summarized in wee (ly reports; most observed inconsistencies are quickly corrected. The licensee's response to audit findings are in general thorough, timely, and technically sound. No problems were noted during selected review of audit and surveillance reports and the responses to recommendations, findings, observations and deviations. Theinspectorsalsoreviewedthestations1986and1987 QA audit and surveillance schedules. No problems were noted; shiftly surveillances are scheduled to continue in 1987.

The licensee initiated a program in 1986 to provide additional training for

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auditors. For example, all auditors are required to attend a two-week

" Quality Assurance Inspector Chemistry Course" conducted at the licensee's production training center. Although the licensee is gradually improving theknowledgeoftheauditorswithregardtogeneralchemistry,little im)rovement was noted in the auditors knowledge of radiation arotection (R)) practices. The number of auditors qualified to conduct R) audits i

was recently reduced from five to two due to terminations and transfer Although it appears that two auditors are'close to meeting the minimum requirements to qualify as RP auditors, the expertise in this technical area has decreased in the last year. The inspectors discussed with the QA Supervisor the desirability of obtaining an individual with a strong rad / chem background for one of the open QA auditor position No violations or deviations were identifie . Facilities and Equipment The inspectors toured radiation protection facilities observed radiation protectionequipmentinuse,anddiscussedplansforImprovingfacilities and equipment with a Rad / Chem forema Equipment procured in 1986 which should enhance the radiation protection (1) two larger more efficient dry cleaning units p(rograminclude: licensee currently has three units total); (2) seven state-of-th

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whole body friskers to replace less sensitive units; (3) a. respiratory ' ,

protection mask drying unit; and (4) canvas hamper bags for unlaundered protection clothin According to the licensee, adequate supplies of PC's, respiratory equipment, j and survey instrumentation is available to accommodate routine and outage l activities.

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It appears that facilities and equipment for radiation protection activities are adequate to support the radiation protection program.

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No violations or deviations were identified.

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18. Auxiliary Building Tour During tours of the auxiliary building, radioactive material controls and housekeeping appeared adeguat Inspector observation of egress activity at access control points indicate that most workers are properly using step-off pads and adhering to frisking procedures;-however, the '

following exceptions were noted:

• Some workers leaving containment did not frisk their personal

, dosimetry for contamination; the lead rad / chem foreman indicated

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a sign would be placed in this area to remind workers of this requiremen * Some workers were observed not properly using the whole body friskers even though directions are affixed to each unit; workers pro)erly used the friskers after being reminded of the required tec1nique by the lead rad / cham forema .

The inspectors performed radiation and contamination surveys of equipment- !

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and floor areas in the auxiliary building; no problems were note The licensee plans on modifying the DAW compactor area located in the auxiliary building by isolating it from surrounding areas. Plans call for enclosing the area with plexiglass ~or other structural material and improving the area exhaust system. This should improve contamination control and overall housekeeping in the area. This matter was discussed 1 at the exit meeting and will be reviewed during future inspections.~ '

(295/86025-03;304/86025-03)

No violations or deviations were identifie . Missed Surveillances on Radiation Monitors On October 5 1986, the licensee identified missed surveillances ontheTechnIcalSupportCenter(TSC)arearadiationmonitor. This monitor is not used for normal operating area monitoring but is

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maintained in the TSC for emergency program activities. : The current surveillance requirements, effective September 24, 1986, call for daily channel and monthly source checks in addition to previously required quarterly functional tests. The monitor has been functionally tested on a quarterly basis; however,.the daily and monthly surveillances were not previously performed or required-by procedur This matter was identified and reported by the licensee in LER No. 295/86-038-00 dated November 3, 1986; corrective actions are i

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currently in progress and include development of_ procedures to implement the revised surveillance requirements. Until procedures are developed, the monitor. daily / monthly surveillances are being i

tracked by the Rad / Chem department to insure' technical specification requirements are me On October 7, 1986, the licensee identified missed Technical l

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S)ecification required calibrations on channel three of a containment i S)ING radiation monitor (2RIA-PR40). When discovered, the channel:was declared inoperable. The surveillance requirements became effective

, on September 24, 1986, the date of implementation for the revised l Radiological Effluent Technical Specifications (RETS). Since September 24, 1986, the RETS allow containment venting for u) to 30 days 4 with Channel 3 inoperable if shiftly samples are obtained. -)rior to

the revised RETS, Channel 3 had not been required for containment

, releases or other operating functions; therefore, until recently, calibrations were not required to be performed on this channe '

l As reported by the licensee, Unit 2 containment was vented on six occasions between September 24 and October 7, 1986, during this time, l only daily samples were obtained from containment prior to each venting.

- On October samples were 7, initiated.1986, Channel Since Channel3 3was hasdeclared inoperable no control and shiftly function and the containment atmosphere was manually sampled daily, it does not appear that the inoperability of this channel constituted a i significant health or safety hazar This matter was identified and reported by the licensee in LER No. 304/86-022-00, corrective actions are i currently in progress and include calibratdated November 6, 1986; ion of calibration procedural revisions, and post-implementation review of the revised RET ,

Pending further review during a future inspection, these missed surveillances are considered to be Unresolved Items (295/86025-04; 304/86025-04).

j No violations or deviations were identified by the inspectors.

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20. Out of Service Radiation Monitor Recorders Overview On three occasions in 1985, the licensee identified that chart recorders for technical specification required gaseous effluent activity monitors were out-of-service during containment purges.

. Technical Specification 3.12.1.c.4 requires that, during releases, the gross and particulate activity of all gaseous wastes' released to the environment be monitored and recorded. The initial event occurred May 22, 1985, while Unit 1 was in cold shutdown and a containment purge was in progress. The condition existed fo a) proximately five minutes before the problem was identified and

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t1e purge secured. The second occurrence on October 4, 1985, went undetected for approximately three and one half hours, coincident with a Unit 2 containment purge. The third occurrence on October 5, 1985, lasted approximately 50 minutes before the problem was noticed and a Unit 2 purge was secured.

, Initial Event During a Unit 1 containment purge on Ma 22, 1985, an Instrument MaintenanceControlSystemTechnician(yCST) deenergized a chart recorder from two technical specification required gaseous effluent radiation monitors, Unit 1 auxiliary building ventilation exhaust (IRT-PR25) and service building ventilation stack (ORT-PR22). Contrary to administrative 3rocedures and Instrument Maintenance policy, the CST failed to inform tie Shift Engineer or Shift Foreman and obtain authorization to deenergize the recorder. The recorder was disconnected i in order to investigate a guide arm which was found on the floor in the

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vicinity. Approximately five minutes elapsed before an operato noticed the recorder was out-of-service and terminated the purge. It j took the CST approximately 30 minutes to identify the problem and repair the chart recorder. The licensee reported that an abnormal effluent release did not occur while the recorder was out-of-service because it would have been detected by redundant monitors and control room alarms. The monitor and recorder were verified as operable before

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initiating the purge; the guide arm is not necessary for proper operation of this recorder and the recorder was operational until it

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was deenergized.,

This event was identified by the licensee and reported to the NRC in LER No. 29E,85-020-00, dated June 21, 1985. Corrective action consisted of discussions concerning the incident during an Instrument Maintenance group meeting on June 21, 198 During the meeting, a memorandum was circulated and reviewed by all CSTs and foremen to reinforce the procedural requirement to inform the Shift Engineers and obtain authorization prior to rendering, equipment out-of-service. Also, the technician involved in this incident was reprimande i

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This event appeared to satisfy the criteria for.self identification and correction: delineated in 10 CFR Part 2, Appendix C, " General Statement of Policy and Procedure for Enforcement-Actions." Second and Third Events During a Unit 2 containment purge on October 4, 1985, Instrument Maintenance personnel'deenergized the recorder (0RR-PR20) for the failed fuel letdown monitor (IRT-PR29) in order to repair the pens'

servo motor. This time Instrument Maintenance personnel followed

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procedure and-informed the Operations staff and obtained approval to disconnect the pen for this monitor. However, Instrument j Maintenance did not inform the Operations staff, nor apparently did the Operations staff realize, that this recorder was linked 4<

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to another monitor. Recorder ORR-PR20 is a two pen recorder for both the failed fuel letdown monitor and miscellaneous vent' stack

i effluent gas monitor (ORT-PR188). Additionally, the slide wire contact for the miscellaneous. vent stack recorder pen was periodically interrupted during the maintenance to gain access to the failed fuel letdown monitors recorder pen. This condition existed for about 3 1/2 hours until the recorder was returned to service.

i This was not identified until the next day when the problem was

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repeated. On October 5, 1985, again coincident with a containment '

purge, the same dual monitor recorder was deenergized by Instrument Maintenance for additional repairs. Similar to the previous day,

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Instrument Maintenance obtained shift authorization to work on'the recorder, but failed to indicate that this would effect the

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miscellaneous ventilation stack effluent monitors recording capability. After ap3roximately 50 minutes, operations personnel discovered that the clart recorder miscellaneous for the vent stack monitor was inoperable and secured the purg For both the October events, station computer data later showed that no abnormal gaseous effluent releases occurred during the time the recorders were out-of-service. The miscellaneous vent stack gas monitor does not monitor a primary release path but detects exhaust from the cold lab, decontamination room, and battery room. The miscellaneous vent stack is not a containment purge effluent release pathway. This monitor and its annunciators were not compromised by l its inoperable chart recorder.

1 The latter two events were identified by the licensee and reported to the NRC in LER No. 295/85-036-00, dated November 4, 1985. Corrective actions included additional discussions with Instrument Maintenance personnel concerning the need to thoroughly inform Operating Shift Supervision of other equipment which will be affected by maintenance or surveillance activities on instrument loops. Discussions were also

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held with Operations personnel to heighten their awareness of equipment which has input from unrelated sources. As additional corrective action, sometime after the October events, a system modification was proposed and approved to rearrange effluent release related recorders so they are not linked with non-release recorders; when completed, the modifications should prevent the recurrence of a similar proble Thus far, engineering work is complete for Unit 1 and the ptyysical modifications are in progress; Unit 2 engineering modification work is'pendin NRC Conclusion The May and October 1985 events involved different effluent monitors and recorders; however, the causes and the work groups involved were similar in all three instances. Although the events were identified by the licensee, it appears that the corrective actions for the initial event were not adequate to prevent the subsequent event Instrument Maintenance personnel should have been more thorough in communicating to the Operations staff. The latter two events should reasonably have been prevented by the licensee's corrective action for the initial event, had it been adequate. The latter occurrences do not satisfy all the criteria for self identification and correction described in 10 CFR Part 2, Appendix C, " General Policy and Procedures for Enforcement Action."

Failure to record the activity of all gaseous effluents released to the environment during containment purges is a violation of Technical Specification 3.12.1.c.4. The system modification to rearrange effluent related and non-effluent related recorders, proposed after the third occurrence, appears adequate to prevent a similar recurrenc (295/86025005;304/8625005).

One vio'ation was identifie . HVAC Filtration Systems The inspectors reviewed the adequacy of the ESF and non-ESF HVAC filtration systems to prevent (1) potential fire protection system leakage from damaging air cleaning filters, (2) filter bypass via filter housing drain systems, and (3) inadvertently flooded control room HVAC ductwork leaking water onto an ESF control panel (incident similar to that described in the Hatch Plant LER No. 85-018-00).

According to the Fire Marshall, the station has automatic fire protection HVAC charcoal absorber deluge systems which have not had leakage problem No apparent water damage was noted in several filter housings which were entered by inspectors during plant tour The inspectors discussed with licensee representatives the incident at Hatch Unit 1 (LER 85-018-00) where inadvertently flooded control room HVAC ductwork leaked water onto an Analog Transmitter Trip (ATTS)

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pane This introduced moisture into the ATTS panel, which in turn, resulted in the malfunction of a safety relief valve and the High PressureCoolantInjectionSystem. This incident is also described in INP0 SER 34-85 and IE Information Notice No. 85-85; the inspectors reviewed the licensee's internal response to these documents and discussed the matter with licensee representatives. Because the control room is located approximately 25 feet above the control room HVAC filter housing deluge system, the licensee concluded an event similar to that at Hatch does not seem plausibl Inspection Reports No. 50-295/86013; 50-304/86012 state that the licensee identified a potential leakage path from the auxiliary building to the control room ventilation system via the charcoal absorber filter housing drain lines. The licensee has partially corrected the problem by plugging one of the two interconnected drain lines; further licensee action is apparently necessary to conform to aaplicable regulatory guidance. Re Position 3.h)gulatory Guide 1.52, and Regulatory GuideRevision 2, March 1.140, Revision 1978 1978, 0, March (Regulatory and Revision 1, October 1979, (Regulatory Position 3.e) state that the filter housing water drains should be designed and constructed in accordance

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with the recommendations of Section 4.5.8 of ERDA 76-21 and Section of ANSI N509-1976, respectively. These recommendations include individually valving, sealing, or otherwise protecting drain lines from individual chambers of the housing to )revent bypassing of contaminated air around filters er absorbers throug1 the drain system. Although station plumbing diagrams apparently indicate loop seals for filter housing drain lines, plant tours failed to confirm their existence for the six filters housing drain systems inspected. If individual drain line loop seals have not been installed and properly maintained, it may be necessary for this licensee to install isolation valves, water check valves, or other appropriate devices. The licensee should review all appropriate plant ventilation filter housing drain systems to assure conformance with applicable regulatory guidanc This matter was discussed at the exit meeting and will be reviewed further during a future inspection. (295/86025-06; 304/86025-06)

Although licensee representatives stated the installed charcoal absorber deluge systems are unlikely to inadvertently activate, it appears that the licensee has not instituted administrative controls beyond those needed for the initiation of the deluge, systems. The administrative controls which are apparently lacking, include: (1) assurance that the filter housing will not overfill to the extent that water backs up into theductwork,housingintegrityisjeopardized,orseismicandstatic loading become concerns; (2) training or procedural cautions to warn the fire brigade that the water in the housing is contaminated and radwaste (or radiation protection) personnel should be notified; (3) assurance that the housing will be drained in a timely manner without overloading l the radwaste system, with procedural steps to ensure that the proper -

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isolation valves are correctly manipulated; (4) addition of the filte housing drain line isolation valves to the valve check list of the ventilation system startup procedure, and (5) assurance that the filter housing drain line isolation valves are verified closed as part of the (monthly) fire protection surveillance program. This matter was discussed at the exit meeting and will be reviewed further during a future inspection. (295/86025-07; 304/86025-07)

No violations or deviations were identifie . Control Room Emergency Air Cleaning System Modification and Repair During March 1985, discussion with licensee representatives on the status of the licensee's commitments to NUREG-0737, Item III.D.3.4, the inspectors were informed that in 1983, as part of the control room emergency air cleaning system modification and repair program, the mechanical lock longitudinal internal duct seams were sealed with tape and an overlay of sealant. Also, the filter housings were partially caulked. These sealing methods appeared to be contrary to accepted industry standards and practice and to Regulatory Guide 1.52, Regulatory Position 5.c which states, in part, that the use of silicone sealant or any other temporary patching material on housings or ducts should not be allowed. Region III contacted NRR concerning the technical adequacy of these sealing methods. In June 1985, three representatives from NRR toured the plant to observe the control room ventilation duct sealant use and discussed the matter with licensee representatives. The Director, Division of Licensing, NRR,'by memorandum dated August 26, 1985, 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 memorandum was attached to Inspection Reports No. 50-295/85040; 50-304/8504 On February,4, 1986, a conference call was conducted to discuss this matter with participation by NRR, Region III, and licensee representative During that conference call, the licensee agreed to conduct a quantitative leakage test of the control room emergency air filtration system to verify the validity of the licensee's NUREG-0737, III.D.3.4 safety evaluation assumptions, to demonstrate that the 1983 repairs and modifications (involvin material)ghave the application of silicone not significantly sealant degraded, and and to other temporary determine the need patching for and frequency of any required periodic retests based on the quantitative test results. On March 6, 1986, Region III sent a letter to the licensee to confirm the licensee's commitments, state the NRC's intention to witness the leakage tests, request that Region III and NRR be notified of the licensee's test schedule at least 30 days before the tests are to begin, and request that the licensee's test procedures be made available to Region III and NRR personnel in sufficient time to allow their review prior to conduct of the tests. The licensee, by letter dated July 25,

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1986, transmitted the test procedure to the NRC for review. During the review of the licensee's test procedure, certain NRC concerns were identified regarding the ability to obtain the necessary quantitative leakage data. Before these concerns could be resolved with the licensee, an incident took place at the station which raised other control room habitability concerns not directly related to application of silicone sealant and other temporary patching material during the 1983 control room emergency air filtration system repairs and modifications. This incident, which took place on September 11, 1986, involved the intrusion of radioactive noble gas into the control room while the control room ventilation system was in the accident mode. Because the licensee's corrective actions regarding this event may include modification of the test procedure, the previous control room habitability concerns (Unresolved Items No 295/85005008; 304/85005008) will be tracked with the additional concerns raised by the September 11, 1986 incident (See Section24).

No violations or deviations were identifie . Licensee Event Reports (LER) Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specification UNIT 1 i

LER N DESCRIPTION i i

86035-00 Minor Radioactive Release into Control Room Due to Control Room Relief Damper Installation Deficiency 86038-00 Missed surveillances on Technical Support Center portable area radiation monito Fuel Building Ventilation HEPA Filter Bypass UNIT 2

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LER N Unit 2 containment vents without shiftly containment atmosphere iodine sample '

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LER 295/86038-00 and 304/86022-00 are discussed in Section 19; LER 295/86035-00 is discussed in Section 24; LER 295/86039-00 is discussed in Section 25, 24. Minor Radioactive Release into the TSC and the Control Room On September 11, 1986, while personnel were lowering the level in the Spent Resin Storage Tank (SRST), a vent path was established into the

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auxiliary building from the waste gas system; the licensee estimates that 4500 cubic feet of waste gas were vented. The licensee reported that approximately 8.2 curies of noble gas were released during the even the licensee was 2.4 percent The maximum of Technical stack release rate Specification reported Due.to designby / installation deficiencies in ventilation systems, the airborne radioactivity entered the Technical Support Center (TSC) and the control room. There were no contaminations of plant personnel or building evacuations due to this incident. A release of this magnitude does not represent a significant health or safety hazard. The licensee's immediate corrective actions regarding this

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incident are discussed in Inspection Reports No. 50-295/86028(DRP);

50-304/86028 (DRP).

ThismatterisconsideredtobeUnresolved(295/C6028-01;304/86028-01)

pending completion of NRC inspection into the potential design control

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deficiencies and the ability of the control room and TSC ventilation systems to meet their design requirement No violations or deviations were identified by the inspector . Fuel Building Ventilation HEPA Filter Bypass On October 16, 1986, Ventilation Test," the access door to the fuel building fiwhile performing Proc found open (normal position closed) causing the ventilation flow to bypass the pre-filter and the HEPA filter in Exhaust Filter Bank 38. The licensee concluded that the door had opened because the door gasket had fallen off thus leaving the door latches loose, and then since the door opens in the direction of flow, the force of the ventilation flow eventually opened the door. Although the licensee did not conduct an in place filter test, it was assumed by the licensee that the bypass through the 2 foot-by-3 foot open door would result in greater than the one percent bypass of the Fuel Building HEPA filters allowable per Technical Specifications Table 4.1 The licensee reported that the door latch spacings were reduced to allow the door to be closed tightly without the gasket being replaced. The HEPA bank was then returned to service without conducting an in place filter l test. Corrective action included revising PT-19 to include a requirement i to verify access door closur l l

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ThegasketwasreplacedandthedoorlatchesadjustedonNovember17, 1986, per Work Request No. Z5391 A selected review of the PT-19 check sheets indicate that Fuel Handling (FH) Exhaust Filter Bank 38 was in service, 198 TheatFuel least, intermittently, Building Ventilationbetween October System has two 10016 and November percent capaci 17,ty HEPA exhaust filter banks, 38 and 39. Licensee representatives stated that l the access door problem only effected FH Exhaust Filter Bank 38. According to licensee representatives, due to NRC concerns expressed during the week of November 17, 1986, the licensee requested a consultant to conduct an in place HEPA filter test on FH Exhaust Filter Bank 38. That test was successfully passed on November 25, 198 The adjustment of the filter plenum access door latches and the closure of the door without gasket replacement is considered to be structural maintenance. The basis for Technical Specification 4.13 states that the test requirements on the ventilation filter systems will generally conform to the recommendations of ANSI N510-1975. ANSI N510-1975 states that in place HEPA tests are to be performed after any maintenance l activity in the filter housing to verify that the system contains no l bypassing which could compromise the function of the filter Because l resents a

! the filterreclosure of the accessdifferent housing configuration door without gasket than the replacement rep (access configuration l door closed with gasket in place) that existed during the last in place l HEPA test, the previous test results were invalid the licensee should l haveperformedaninplaceHEPAtesttoensurefilterbypasswaswithin the technical specification limit before FH Exhaust Filter Bank 38 was placed into service. Failure to conduct in place HEPA filter testing on FH Exhaust Filter Bank 38 after filter housing structural maintenance is a violation of Technical Specification 4.13.2.b. The corrective actions l noted above appear adequate to prevent recurrenc (295/86025-08; 304/86025-08)

On January 30, 1987, the inspectors discussed with licensee representatives (denotedinSection1)additionalsurveillance,QA,and system operability concerns regarding this matter. Surveillance concerns include the potential need to test the downstream charcoal filter banks (OAV040 and 41) to assure that they have not been degraded due to pre-filter and HEPA filter bypass during the operation of FH Exhaust Filter Bank 3 QA concerns include the performance of structural maintenance on the HEPA filter housing apparently without a work request. Further review appears l necessary to ascertain the ability of FH Exhaust Filter Bank 38 to meet ( its design requirements, both during the period when the access door may l' have been open before discovered in that configuration on October 16, 1986, and during system operation before the access door gasket was replacedandthedoorlatchesadjustedonNovember 17, 198 Pending these additional concerns completionofNRCinspectionregardinf295/86025-09;304/86025-09}this matter is considered an Unresolve One violation was identified by the inspector i i

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r 26. Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the site inspection on December 12, 1986 and January 9, 1987. The apparent violations were discussed in a telephone conversation with licensee representatives (denoted Section 1) on January 30, 1987. The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary. In response to certain matters discussed by the inspectors, the licensee: Acknowledged the inspectors' concerns regarding the apparent need to improve operation of the laundry facility (Section 11). Confirmedtheirplanstoimplementanauxiliarybuildingcubicle decontamination program and acknowledged the inspectors statements concerning the desirability of tracking / trending cubicle contaminationdata(Section11), Confirmed their plans to modify the DAW compactor area (Sections 14 and 18). Acknowledged the unresolved item concerning missed surveillance on Technical Specification required radiation monitors (Section 19). Acknowledged the apparent violation of Technical Specification 3.12.1.c.4 concerning repetitive occurrences of out-of-service radiation monitor recorders during containment purges (Section 20). Acknowledge inspectors' concerns regarding the apparent need to review ventilation filter housing drain systems to assure regulatory compliance (Section21). Acknowledge inspectors' concerns regarding the apparent need to review administrative controls over filter housing fire protection deluge systems (Section 21). Acknowledged inspectors' concerns regarding the adequacy of the licensee's proposed control room ventilation system test procedure (Section22), Acknowledge the apparent violation of Technical Specification 4.13. concerning failure to perform in-maintenance on a filter housing (place HEPA filter testing after Section25).

I Acknowledgeinspectors'concernsregardingsurveillance,QAand 4 operabilityofthefuelbuildingventilationsystem(Section25). l

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