ML19225A229

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IE Insp Repts 50-295/79-07 & 50-304/79-08 on 790410-12,16 & 18.Noncompliance Noted:Failure to Collect & Analyze Fish Semiannually
ML19225A229
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 05/18/1979
From: Essig T, Oestmann M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19225A206 List:
References
50-295-79-07, 50-295-79-7, 50-304-79-08, 50-304-79-8, NUDOCS 7907180587
Download: ML19225A229 (8)


See also: IR 05000295/1979007

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMEh7

REGION III

Report No. 50-295/79-07; 50-304/79-08

Docket No. 50-295; 50-304

License No. DPR-39; DPR-48

Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name:

Zion Nuclear Power Station, Units 1 and 2

Inspection At:

Zion Site, Zion, Illinois and Corporate Office,

Chicago, Illinois

Inspection Conducted: April 10-12, 16 and 18, 1979

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Inspector:

M. J. De tmann

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Approved By:

T. H. EWig, Chief

% nvironmental and Special

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Projects Section

Inspection Summary

Inspection on April 10-12, 16 and 18, 1979 (Report No. 50-295/79-07

50-304/79-08)

Areas Inspected: Routine, unannounced inspection of environmental

protection of Units 1 and 2 including:

administrative and procedural

controls; licensee internal audits; implementation and results of the

radiological and nonradiological environmental monitoring program;

review of meteorological program; review of corrective actions for

enforcement items from a previous inspection; review of licensee

environmental event reports; and sample collection for the confir-

matory measurements program.

The inspection involved 30 inspector-

hours on site by one NRC inspector.

Results: Of the nine areas inspected, no items of noncompliance or

deviations were found in eight areas; one apparent item of noncompli-

ance was identified in one area (infraction - failure to collect and

analyze fish semiannually - Paragraph 5.a) and a deviation in the same

(failure to place the TLDs at two onsite stations adequately for

area

air exposure - Paragraph 5.b).

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DETAILS

1.

Persons Contacted

  • J. Golden, Administrator, Radiological Environmental Monitoring

Program, Production Systems Analysis Department (PSA), CECO

P. Howe, Supervisor in Biology, Environmental Aff airs

Department (EAD), CECO

R. Kunshek, Staff Biologist, (EAD), CECO

G. Abrell, Manager, Quality Assurance Department (QAD), CECO

A. Saller, Quality Assurance Engineer, (QAD), CECO

    • L. Soth, Administrative Assistant , Zion Station

T. Parker, Assistant Technical Staff Supervisor, Zion Station

    • S. Miller, Rad / Chem Supervisor, Zion Station
    • F. Rescek, Lead Health Physicist, Zion Station
    • G. Tryzina, Health Physics Engineer, Zion Station
    • S. Gurunathan, Lead Chemist, Zion Station

T. Lehmann, Chemist, Zion Station

T. Prince, Operations Engineer, Zion Station

  • denotes phone contact on April 19, 1979.
    • denotes those present at the exit interview on April 18, 1979.

The inspector also interviewed 14 other licensee employees during

the course of the inspection, including health physics and chemistry

technicians, members of the security force, and general office

personnel.

Other Personnel

F. Magliery, Associate Administrator, Director of General Services

Division, Victory Memorial Hospital, Waukegan, Illinois

2.

Licensee Action on Previous Inspection Findings

(Open) Deficiency (50-295/77-10 and 78-12; 50-304/77-13 and

78-14): Excess annual boric acid use.

The licensee continues to

operate the Station using more boric acid than provided for by

Appendix B, Technical Specification 1.3.B.

Request for a Technical

Specifications amendment dated September 23, 19'/u, has not yet

been approved.

The licensee exceeded Section 1.3.B using 122,700

pounds in 1977, and 3000 pounds as of January 16, 1978. This

item will remain open pending action by the Office of Nuclear

Reactor Regulation on the request for the amendment.

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(Closed) Infraction (50-295/78-12; 50-304/78-14):

Prompt noti-

fication and subsequent 10-day written report of the excess boric

acid usage. Review of licensee event reports, LER Nos. 78-51, 78-76

and 79-17 indicated that the licensee has submitted the required

prompt and 10-day written reports in a timely manner in accordance

with Section 3.4 of Appendix B, Technical Specifications.

(Closed) !afraction (50-295/78-12; 50-304/78-14): The rate of

temperature change of 8 F per hour limit was exceeded on June

17, 1977. Examination of selective temperature recordings for

1978 indicated no other instances of this rate of temperature

change being exceeded in accordance with Section 1.1B of Appendix

B, Technica Specifications.

(Open) Unresolved Item (50-295/79-03; 50-304/79-03):

Inadequate

familarization training provided for the emergency staff at the

Victory Memorial Hospital and poor condition of the decontami-

nation treatment room at the hospital.

A visit by the inspector

to the hospital on April 16, 1979, indicated the licensee's

medical procedures were found. However, the hospital staff had

not straightened out the emergency treatment room in that the

shipping boxes containing footlockers and plastic bags of medical

supplies had not been removed nor placed properly. The hospital

staff stated that these items would be remaved promptly so that

the treatment room would be available to handle a contaminated

victim from the plant.

3.

General

The licensee's 1978 radiological and 1977 - 78 nonradiological

environmental monitoring programs, including implementation,

sampling equipment and locations, and program results, were

reviewed during this inspection.

Corrective actions performed by

the licensee for items of noncompliance from a previous inspection 77

were reviewed. Environmental event reports were also reviewed.

Radioactive samples for the Confirmatory Measurements inspection

program were obtained from the licensee. The licensee was als

provided spiked samples as discussed in a previous inspection.gj

1/

IE Inspection Reports No. 50-295/78-12 and No. 50-304/78-14.

2/

IE Inspection Reports No. 50-295/79-03 and No. 50-304/79-03.

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066

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4.

Administrative and Procedural Controls

The licensee's administrative and procedural controls for imple-

mentation of the radiological and the nonradiological environ-

mental monitoring program were reviewed with the licensee. The

radiological and the meteorological program remains under the

program management of Dr. J. Golden. Eberline Instrument Company

is the licensee's radiological environmental monitoring contractor

and Murray and Trettle, Inc. the meteorological contractor.

R. Kunshek is the Staff Biologist in Environmental Affairs Depart-

ment responsible for the overall direction of the biological

monitoring program. The biological program was completed on

September 30, 1978, and the final report for the five year program

is under preparation. Hazelton Laboratory, who purchased Nalco

Environmental Sciences on November 1, 1978, is the licensee's

contractor for this program.

No items of noncompliance or deviations were identified.

5.

Implementation of the Radiological Environmental Monitoring

Program

The inspector examined the ?icensee's radiological environmental

monitoring program results for calendar year 1978 for compliance

with monitoring and reporting requirements. This included exami-

nation of the annual report submitted to the NRC and detailed

monthly reports containing specific analytical data.

Examination

of the operability, maintenance and calibration of selected

radiological environmental monitoring stations was also conducted

during a tour of site and environs.

a.

Environmental Monitoring Program

The 1978 monitoring results were examined for compliance

with the requirements in Table 4.16-1 of the Appendix A,

Technical Specifications. The examination revealed that

fish samples had not been collected for the second half of

1978 for the semiannual requirement.

The gamma isotopic

analysis of the fish, therefore, was not conducted as

required. This omission constitutes an item of noncom-

pliance and will be examined during a subsequent inspection.

The samgjitem was also discussed in a previous inspection

report.-

The licensee stated that steps will be taken to

assure that fish will be collected as required.

3/

IE Inspection Reports No. 50-295/78-12 and No. 50-304/78-14.

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Review of the results indicate the licensee discharged

elevated tritium concentrations in its cooling water on May

29 - June 4 and July 3 - 9, 1978. A licensee representative

stated that these results were probably a function of the

sampling techniques. The sampler is located in the discharge

pipe where only a small volume of liquid may be available

for dilution when the other unit is shut down. The remaining

samples may yield tritium results which do not accurately

reflect " environmental" concentrations. An analysis by the

licensee to establish a representative " environmental"

sampling system will be required.

This matter will be

examined further in future inspections.

The licensee also reported elevated radioactivity concen-

trations found in milk, air particulate filters, and

charcoal adsorbers due to atmos,aneric weapons testing by the

Republic of China during the fall of 1977 and spring of

1978. The licearee utilizes indicator radionuclides to

discriminate wt pons fallout from plant effluent effects and

provides for a referenced analysis for each determination

where quantifiable levels of radioactivity were observed in

environmental media.

Other than these items discussed above, review af the results

indicated no unusual results or trends ascribable to plant

operations were observed.

The licensee also submitted the Environmental Dose Pathway

Study in accordance with Section 3.16 of Appendix A, of the

Technical Specifications. The report is being evaluated by

the Office of Nuclear Reactor Regulation.

b.

Sample Collection Stations

The inspector toured selected radiological environmental

monitoring stations and observed that thenmoluminescent

dosimeters (TLDs) at Onsite Stations #1 and 3 were located

in the steel air sampler housing, thereby precluding exposure

to the 81-kev gamma radiation from Xe-133.

As a result, the

licensee has not adequately measured any changes in the

levels of environmental radioactivity due to plant effluents

as required in the Objectives of Section 4.16 of Appendix A,

Technical Specification. This item is a deviation and will

be examined during a subsequent inspection. The air sampling

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stations containing air particulate filters and charcoal

adsorbers were operating properly. Municipal water intakes,

fish, and cooling water sampling stations were also observed.

The licensee representatives expressed a need to accompany

the Eberline sample collector during sample collections to

be better acquainted with the location and status of the

sampling stations.

This item will be examined during a

future inspection.

One apparent item of noncompliance and one deviation were

identified.

6.

Implementation of the Meteorological Monitoring Program

Review of the CY 1978 meteorological monitoring reports prepared

by the licensee's meteorological consultants showed an overall

data recovery rate of 98.0%.

This inspection revealed that the

contractor had maintained and calibrated the meteorological

recording equipment on a bimonthly basis. The inspector toured

the meteorological tower and observed the monitoring equipment.

All equipment was found to be operable and in good order.

No items of noncompliance or devations were identified.

7.

Implementation of the Nonradiological Monitoring Program

The inspector selectively reviewed the results of the nonradio-

logical environmental monitoring program for the second half of

1977 through March 1979 for compliance with monitoring and

reporting requirements of Appendix B, Technical Specifications.

a.

Boric Acid Usage

Reportable occurrences LER Nos. 78-51, 78-76 and 79-17 for

excessiv; usage of boric acid greater than twice the 1000

pounds per year in accordance with Section 1.3.B, Table B.4

of Appendix B, Technical Specifications were reviewed.

The

records revealed a total usage of boric acid of 85,500

pounds during CY 1978 and 2,100 pounds as of March 22, 1979.

As stated in Paragraph 2, the licensee has requested relief

from Table B.4 requirement from NRR. This item will be

examined during a subsequent inspection.

These licensee event reports were submitted in a timely

manner in accordance with the reporting requirements of

Section 3.4 of Appendix B, Technical Specification. This

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item was discussed in a previous inspection report. /

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The

inspector has no further questions concerning this matter.

b.

The rmal

The inspector noted that the licensee received a technical

specification change, effective April 25, 1978, del. ting the

requirement of reporting the instances of exceeding.

(1)

the maximum temperature differential of 20 F and (2) the

maximum winter discharge temperature of 55 F.

The inspector selectively reviewed the recordings of rate of

temperature change of 8 F /hr during CY 1978 and found no

instances were recorded that exceeded this limit.

c.

Biological Monitoring Program

The licensee completed the 5-year biological monitoring

program on June 30, 1978 and is in process of writing up a

final report for the program. The inspector reviewed

selected data in the four-volume report covering data from

July 1977 to June 1978, for the fifth year of this program.

The data presented included lake current measurements, field

chemistry, adult fish, phytaplankton, zooplankton populations,

and benthic faunal collections. The requirements for sampling

locations and frequencies presented in 2.C of Appendix B,

Technical Specifications, have been satisfied by the licensee's

contractor.

The inspector also reviewed the licensee's supplemental

reports on the environmental monitoring program which

extended the program through September 30, 1978. This

extension resulted ftom the technical specification change

issued by the NRC oa April 25, 1978 deleting the thermal

discharge limits. The extended program confirmed the pre-

diction that no mersurable effects on the lake biota occurred

from station operation.

No items of noncompliance or deviations were identified.

8.

Licensee's Internal Audit

The inspector reviewed the licensee internal audits of the

environmental monitoring program. The audit conducted by the

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Ibid.

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Quality Assurance Department in April 26, 1978 of the 1977

results identified the omission of collection of fish the second

half of 1977.

An audit of the 1978 program had not been con-

ducted at the time of this inspection but is scheduled for later

on in the spring of 1979.

The licensee also conducted an audit on July 27, 1978, of the

1977 results by the licensee's radiological environmental moni-

toring contractor. The audit traced the paperwork for 30

randomly selected samples from all Ccmmonwealth Edison plants.

The audit also reviewed logbooks and calibration procedures. No

significant problems were identified.

No items of noncompliance or deivations were identified.

9.

Confirmatory Measurements Program

Effluent samples consisting of particulate filter, charcoal

adsorber, waste gas and liquid waste were collected from the

licensee for the Confirmatory Measurements inspection program.

They will be analyzed by the NRC Reference Laboratory and the

results compared with the licensee's. -In addition, two spiked

liquids, two charcoal adsorbers and a particulate filter were

provided the licensee for analysis as a further test of the

licensee's analytical capability.

The results of the comparisons

will be reported in a subsequent inspection report.

10.

Exit Inte rview

The inspector met with licensee representatives (denoted in

Paragraph 1) at the conclusion of this inspection on April 18,

1979. The inspector summarized the purpose and scope of this

inspection and its findings. The licensee acknowledged that:

(1) Fish should have been collected semiannually (Paragraph 5.a);(2)

the TLDs will be properly mounted for complete air exposure

(Paragraph 5.b); (3) the plant personnel will accompany the

contractor personnel on her rounds to collect environmental

samples (Paragraph 5.b).

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