IR 05000295/1993013
| ML20045A828 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/08/1993 |
| From: | House J, Louden P, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20045A823 | List: |
| References | |
| 50-295-93-13, 50-304-93-13, NUDOCS 9306150039 | |
| Download: ML20045A828 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION L
REGION III
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Reports No. 50-295/93013(DRSS); 50-304/93013(DRSS)
Dockets No. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 300 Downers Grove, IL 60515
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Facility Name:
Zion Nuclear Generating Station, Units 1 and 2 Inspection At: Zion Station, Zion, Illinois Inspection Conducted: May 24 through 28, 1993
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Inspectors:
o P. L. Louden
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Rad'ation Specialist Ad!//k 44V12 p. E. 710use Dste'
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Senior Radiation Specialist Approved By:
(d 8d f,/8/j t William Snell, Chief Date'
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Radiological Controls Section 2
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Insoection Summary Insoection on May 24 throuah 28. 1993 (Recorts No. 50-295/930I3(DRSS):
50-304/930I3(DRSS))
Areas Inspected:
Routine, announced inspection of the licensee's radiation protection (RP) progrcm and radioactive waste processing program (Inspection Procedures (IPs) 83750 a 86750), including changes to the RP department, training and qualifications, audits and appraisals, contamination control, liquid radioactive waste and effluent processing, and the station's performance on the current spent fuel pool re-rack operations. The inspection also included a review of the high radiation sampling system in support of the Zion Review Team.
Results: The following non-cited violation was reviewed during this inspection; the event involved a bag of laundry discovered in the fuel building by a radiation protection technician which exhibited direct radiation readings of up to 5 R/hr (50 mSv/hr). The RP department experienced several staffing changes; however, no negative impact to the normal operations of the department is anticipated.
The spent fuel pool rerack project was progressing as anticipated with respect to exposure goals, but operational problems may 9306150039 930608
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extend the completion date of'the project. The review of the high. radiation i
sampling system indicated no problems or concerns. Overall, the radiation
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protection program at the station is continuing to improve.
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DETAILS
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Persons Contacted Commonwealth Edison
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- G. Beale, Regulatory Assurance
- T. Broccolo, Superintendent, Site Operations
- 0. Fick, Senior Radiation Protection Technician
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- G. Geer, Radioactive Waste Coordinator
- B.
Gulley, Station Quality Verification
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- G. Kassner, Operational Lead Health Physicist
- M. Lohmann, Site Engineering and Construction Manager
- K. McEvoy, Radiation Protection
- G. Ponce, Supervisor, Station Quality Control
't The inspector also interviewed other licensee personnel in various departments in the course of the inspection.
Nuclear Reaulatory Commission
- P. Lougheed, Resident Inspector
- Denotes those present at the Exit Meeting on May 28, 1993.
2.
Licensee Action on Previous Inspection Findinas (IPs 83750 & 84750)
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l (Closed) Inspection Followup Item (295/91016-01: 304/91016-01):
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high radiation sampling system (HRSS) inline dissolved oxygen monitors
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had been incorrectly located below the degassing system and could not measure dissolved oxygen in reactor coolant.
New dissolved oxygen monitors were installed, upstream of the degassing systems in the HRSS panels of both units, and have been declared operable. The inspectors verified that the replacement project had been completed.
This item is
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closed.
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(Closed) Violation (50-295/92034-01(DRSS): 50-304/92034-01(DRSS)):
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Violation involving an auxiliary building operator crossing a posted high radiation barrier established for radiography.
The station
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counseled the operator on his actions and produced a video tape presentation illustrating examples of radiography barriers and other high radiation control devices and the appropriate actions to take when encountering such areas. This video is being presented during Nuclear
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General Employee Training initial and requalification sessions.
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inspectors reviewed this video and found it to be interesting to the viewer and its informational content addressed the earlier problems
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surrounding the violation.
No other occurrences of this type have
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occurred in the last six months. This item is closed.
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(Closed) Violation (50-295/92019-01(DRSS): 50-304/92019-01(DRSS)):
Violation involving a shipment of slightly contaminated ta-bine
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intercept valves to an unlicensed refurbishment facility. The station reviewed and enhanced free release procedures to ensure that all system components to be sent off-site are adequately surveyed by the RP department.
The inspectors verified that these procedures were in place and noted no additional occurrences of this type. This item is closed.
No violations of NRC requirements were identified.
3.
Oraanizational Chanaes (IP 83750)
The inspectors reviewed changes to staffing and organization to the RP department which had occurred since the last inspection (IR 50-295/93003(DRSS); 50-304/93003(DRSS)). The more significant changes which have taken place are as follows:
Former Operational Lead HP to Health Physics Services Supervisor Former RP Planner to Operational Lead HP Former Staff HP to Technical Lead HP Former Contamination Control Coordinator to Supervisor of Radiation Protection Shift Supervisors Former Radiation Work Permit Coordinator to ALARA Coordinator Former RP Trainer to Contamination Control Coordinator Other changes included the addition of a staff HP to the operational HP group and the future hiring of two additional staff HPs.
The inspectors discussed these changes with the Health Physics Services Supervisor and verified that the individuals placed in the various S
positions were qualified for the respective re'es. The inspector-determined that the many changes would not adversely effect the current
performance of the RP department.
l Another change in organization which was occurring at the time of the
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inspection was the changing of responsible decontamination personnel and foremen from the control of the RP department to the Station Labor
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department. The inspectors discussed this change with licensee station
management at the exit meeting-(Section 11) to emphasize that the recent j
station performance in recovering many long time contaminated areas
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appeared to be due, in part, to the decontamination crews reporting to the RP department. While the change in the reporting department may not have any negative impact on the decontamination activities, the i
inspectors informed the licensee that this change and subsequent
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- performance in this area would be closely monitored.
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No violations of NRC requirements were identified.
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4.
Trainina and Oualifications (IP 83750)
The inspectors reviewed the continuing training program provided for Radiation Protection Technicians (RPTs), including training modules addressing the Revised 10 CFR Part 20 regulation changes to occur in January 1994.
The current continuing training for station RPIs involves approximately 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of coursework which includes new equipment operation, systems training, and industry events. This year the training curriculum will also include specialized training on the 10 CFR 20 revision.
Industry events to be covered this year included overexposures in reactor cavities, incore detector events, and recent events (within the last year) involving the spread of alpha contamination and intakes which occurred at other utilities. The training sessions are presented by two certified instructors, each of whom were former RPTs and had significant in-the-field experience.
The inspectors attended a training session which covered some of the revised 10 CFR 20 changes. The class was a problem solving session which presented survey data to the RPTs and asked them to calculate external and internal exposures and total effective dose equivalents for scenarios with and without respiratory protection and with and without engineering controls. These comparative calculations were then used to
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determine which method of performing the job would be the most as-low-as-reasonably-achievable (ALARA). An excellent rapport was observed between the students and the instructors who maintained a classroom which was open for questions and comments.
The inspectors reviewed the lesson plans for the above mentioned training and found them to be comprehensive in covering the given subject matter.
No violations of NRC requirements were identified.
5.
Audits and Appraisals (IP 83750_1 l
The inspectors reviewed the results of station quality verification j
field monitoring reports which were recorded for 1993. The field
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monitoring program involves the observance of actual activities in the j
field to identify any adverse trends. Specific areas observed and reported during the timeframe of interest included: area decontamination i
activities; whole body frisking; surveys of Dry Active Waste; i
preparation of radioactive waste shipments; radioactive material control; Radiation Work Permit (RWP) reviews; general surveys; and radiation area postings. Any finding as a result of a field review are passed to the responsible supervisor for action. All identified findings reviewed were acknowledged by the RP department; the corrective actions observed were adequate and had been implemented in a timely manner.
No violations of NRC requirements were identified.
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6.
Contamination Control Proaram (IP 83750)
The station had recorded 92 personnel contamination events (PCEs) for the year at the time of the inspection.
PCEs are trending about as expected for the year, and improvements have been noted in the frequency of events as compared to 1992.
i Certain areas of the auxiliary building have been designated
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contaminated for preparatory work for the dual unit service water outage. Overall, the cleanliness of the auxiliary building has
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continued to improve.
Discussions with auxiliary operators indicated L
that the number of minimal dressouts was currently about three to
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perform shiftly rounds.
Six dressouts were required last year for the same tour. The RP department has continued to be sensitive to operator rounds and has assisted in making access to these areas as easy as
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possible.
No violations of NRC requirements were identified.
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7.
Hiah Radiation Samplina System The licensee's HRSS was reviewed to determine the status of instrument operability that was identified in Region III Inspection Report 295/92016(DRSS); 304/92016(DRSS). The dissolved oxygen monitor replacement project has been completed (Section 2). The problem with the Unit 2 HRSS in line gas chromatograph (GC) still persists and is caused by the failure of an air actuated sampling valve. The instrument has been repaired several times at the vendor's facility but has failed
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to operate when reinstalled. A licensee representative stated that a vendor representative wculd service and test the GC at the licensee's facility.
Routine analyses of hydrogen in reactor coolant are performed on a GC in the laboratory.
Progress in this area will be reviewed in
future inspections.
The inspectors observed licensee personnel obtain samples from the HRSS and reviewed sample analysis data.
Reactor coolant was obtained from three separate parts of the system, including a grab sample from the sink (unshielded), an undiluted sample (shielded), and a diluted sample
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(shielded). One minor difficulty was noted during collection of the diluted sample. Only 8 milliliters (ml) of deionized water was drawn into the sample bottle instead of the 24 ml required for a 1:1000
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dilution.
The most likely cause of this was loss of vacuum in the j
sample bottle. A licensee representative stated that this was unusual
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and that 24 mis were normally obtained.
Since the volume delivered was
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known, the actual dilution factor could be determined for radioactivity J
calculations.
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An independent audit of the HRSS had questioned the integrity of the valve used to obtain the diluted sample.
This valve delivers a known volume (bite) of reactor coolant to an evacuated shielded sample bottle.
Deionized water is then drawn'into the bottle to dilute the sample.
Licensee representatives stated that the valves on both HRSS units had
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leaked in the past but the problem had been resolved.
The cause was attributed to a valve packing modification by the HRSS vendor which increased the pressure rating of the valve.
The licensee had installed identical valves obtained from the valve manufacturer which leaked
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because they did not receive the packing adjustment for pressure rating enhancement.
The licensee then installed modified valves obtained from the HRSS vendor which appeared to solve this problem.
However, a licensee representative stated that the valve in the Unit 1 HRSS panel was exhibiting some leakage and would be replaced.
It should be noted that these valves wear with use and leakage is not uncommon.
Based on this review, the inspectors determined that the HRSS panel was operable and met the requirements for obtaining reactor coolant samples.
HRSS operability will be reviewed in future inspections.
No violations of NRC requirements were identified.
8.
Liouid Radioactive Waste (IP 86750)
The inspectors reviewed the licensee's liquid radioactive waste management program, including liquid waste releases and the water inventory management program.
Selected liquid release packages were reviewed for compliance with regulatory requirements.
Release procedures were followed, sample radioactivity had been determined, and the calculations were correct.
The Water Inventory Management Program, defined by. ZAP 300-13A Revision 1, March 11, 1993, is intended to reduce the volume of water processed and curie content released via liquid discharge.
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significant reduction in water processing occurred in March 1993, when the on-site laundry facility was closed and laundry was sent to an off-site vendor. Although water volume reduction was not the primary reason for removal of the laundry facility, trend charts for the February through April 1993 period indicated that the volume of water released had dropped by approximately 200,000 gallons (30%) and that the curies released had dropped approximately 0.075 curie (75%) during the same period.
Discussions with licensee representatives indicated that there was cooperation among the groups responsible for the Water Inventory Management Program and that the program continues to improve.
The volume of buried radioactive waste for the first 4 months of 1992 was 2375 cubic feet and for the same period of 1993 was 2073 cubic feet, which represents a decrease of approximately 13%.
Licensee representatives stated that the Dry Active Waste (DAW) sorting table was in use and that approximately 90% of the green (clean) barrels in the radiation controlled area (RCA) were clean. A licensee representative dlso stated that there appeared to be no advantage in sorting the yellow barrel (contaminated) trash due to cross contamination. The licensee has removed all of the yellow (contaminated) containers in the RCA except at step off pad areas to further reduce the volume of DAW.
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inspectors noted that the licensee has made good progress in the volume reduction of radioactive waste.
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No violations of NRC requirements were identified 9.
Unit 1 and 2 Soent Fuel Pool Rerackina
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Background: The licensee received approval for the rerack operation from the NRC Office of Nuclear Reactor Regulation on January 15, 1993.
Operations commenced in March of 1993 and were approximately 45 percent complete at the time of the inspection. The new spent fuel racks will increase the storage capacity from 2,112 assembly cells to 3,012 assembly cells which will allow for full core off-loading through the year 2005.
The projected exposure for the rerack job was 6 to 12 person-rem (60 to 120 mSv).
Review: The inspectors reviewed updated dose information for the job, ALARA considerations for the job, and observed rerack operations in progress. About 6.5 person-rem (65 mSv) had been expended for the job at the time of the inspection and was on track with a modified dose goal of 14 person-rem (140 mSv) for the entire job. ALARA reviews included briefings on possible problems with hot particles and the need for all workers to be attentive of changing radiological conditions when items are removed from the pool.
No significant hot particle events had occurred for the job to date.
The inspectors noted, through direct observation of the work activities, that the job was being adequately covered by experienced RPTs and some consistency was attempted through detailing RPTs for two week periods to the rerack job. Wherein exposures were progressing as planned, some operational problems had been encountered specifically with the moving and uprighting of new and decontaminated old spent fuel racks. These problems have slightly lengthened the completion date for the job.
Through reviews of radiological events for the rerack operations, the inspectors discussed with licensee management one particular event which involved the discovery of a bag of laundry which exhibited direct '
radiation readings of up to 5 rem /hr (50 mSv/hr) contact. The bag was not labeled to indicate its contents nor was it controlled within a posted high radiation area. The bag was discovered by an RPT performing surveillances of material around the fuel building.
In addition to laundry, the bag contained a masslin rag contaminated with a hot particle.
It could not be determined how the contaminated rag had gotten into the laundry bag. Licensee representatives did not know if any exposures had resulted from the bag, but felt that exposure potential was limited since the bag was found in a corner area and personnel access to the fuel building is being tightly controlled.
The station discussed the event with personnel on the rerack job and further discussed the importance to decontamination personnel to have all accumulations of trash surveyed by RP.
During this inspection, certain activities, as described above, appeared to be in violation of NRC requirements.
However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.1 of the " General Statement of Policy and
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Procedures for NRC Enforcement Actions" (Enforcement Policy, 10 CFR Part 2, Appendix C) were satisfied.
One non-cited violation was identified.
10.
General Station Tours The inspectors performed walkdowns of the auxiliary and fuel buildings and of the out buildings within the restricted area. All postings were in order and radioactive material and bags were appropriately labeled or marked. The inspectors also performed independent radiation and contamination surveys of areas within the auxiliary building. All radiation measurements were consistent with documented surveys and no contamination was discovered outside of designated contaminated zones.
All instrumentation (meters, air monitors, etc.) observed during the tours were in good working order and in current calibration.
11.
Exit Meetina The scope and findings of the inspection were discussed with licensee representatives (Section 1) at the conclusion of the inspection on May 28, 1993.
Specific items discussed during the exit meeting are summarized below.
Licensee representatives did not identify any documents or processes reviewed during the inspection as proprietary.
The results of the review of the operability of the high radiation
sampling system.
The improved performance of the water management program and
subsequent reduction in water columes and activity released.
The non-cited violation involving the laundry bag found in the
fuel building by a radiation protection technician which measured 5 rem /hr (50 mSv/hr) on contact.
The continued good performance of the station quality verification
group in reviewing RP operations.
The closure of the items detailed in Section 2.
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