ML20010J606
| ML20010J606 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 09/17/1981 |
| From: | Greger L, Lovendale P, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010J605 | List: |
| References | |
| 50-295-81-21, 50-304-81-17, NUDOCS 8110060204 | |
| Download: ML20010J606 (8) | |
See also: IR 05000295/1981021
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U.S. NUCLEAR REGULATLRY COMMISSION
OFFICE OF IhSPECTION AND ENTORCEMENT
REGION III
Reports Ko. 50-295/SI-21; 50-304/81-17
Docket Nos. 50-295; 50-304
Licensee: Commonwealth Edison Company
Post Office Box-767
Chicago, IL 60690
Facility Name: Zion Nuclear Power Station, Units 1 and 2
Inspection At: Zion Site, Zion, IL
Inspection Conducted: August 17-19, 27 and 28, 1981
iller [
FIP/#/
Inspectors:
D. E.
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P. C. Lovendale
937/4/
Approved By:
L.
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8/
Facilities Rr.diation
Protectiou Section
In9pection Summary
Inspection on August 17-19, 27 and 28, 1981 (Report No. 50-295/81<21;
50-304/81-17)
Areas Inspected: Routine, unannounced inspection of licensee actions
taken in response to Health Physics Appraisal findings, past items of
noncompliance, IE Bulletins and Circulars, and radwaste shipping and
transportation activities. The inspection involved 66 inspector-hours
onsite by two h1C inspectors.
Results: No items of noncompliance or deviations were identified.
8110060204 810921
gDRADOCK 05000304!
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DETAILS
1.
Persons Contacted
- K. Craesser, Superintendent
- G. Plim1, Assistant Superintendent, Administrative and
Support Ser4 ices
- E.
Fuerst, Assistant Superintendent, Operations
- J. Marianyi, Radwaste Operating Engineer
- R. Cascarano, Radwaste Group Leader, Technical Staff
- P. LeBlond, Assistant Technical Staff Supervisor
- R. Rescek, Lead Health Physicist
- H. Studtmann, Quality Assurance
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G. Wagner, Technical Services Manager, CECO
R. Aker, Health Physicist
L. Minejevs, Lead Foreman, Rad / Chem
- J. Kohler, Senior Resi/ent Inspector, NRC
- J. Waters, Resident T 2spector, NRC
- D. Hayes, Chief, he .ctor Projects Section IB, NRC
The inspector alse contacted several othar licensee and contractor
employees includin. Rad / Chem Foremen, Rad / Chem Technicians, Rad / Chem
Engineering Assistc.:s, and members of the technical and engineer-
ing staffs.
- Denotes those present at the exit meeting.
2.
General
This inspection, which began at 8:30 a.m on August 17, 1981, was
conducted to examine licensee actions taL.. in response to Health
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Physics Appraisal findings, past items of noncompliance, IE Bulletins
and Circulars, and radwaste shipping activities. The inspectors
performed independent surveys and reviewed radiation controls and
postings during tours of the radiologically controlled areas. House-
keeping and cleanliness appeared good.
3.
Licensee Action on Pre-ious Inspection Findings
(Closed) Noncompliance Item (295/80-05-02; 304/80-04-02): Failure
[
to adequately control access to a high radiation area created by
portable demineralizers. The corrective actions described in the
licensee's response dated July 18, 1980, were reviewed and appear
to be adequate. No additional problems were noted.
(Closed) Noncompliance Item (295/80-05-03; 304/80-04-03): Concern-
'
ing missed calibrations on two ion chamber survey instruments. The
corrective actions described in the licensee's response dated
July 18, 1980, were reviewed and appear to be adequate.
Instrument
calibration records are now being reviewed monthly by the Rad / Chem
Foremen. No additional problems were noted.
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(Closed) Noncompliance Item (295/80-05-04; 304/80-04-04):
Zion
Station emergency trailer did not contain all the items reiaired by
station emergency procedures. The corrective actions described in
the licensee's response dated July 18, 1980, were reviewed and appear
to be adequate. The procedures have been changed and the trailer
cleaned, inventoried, and stocked. The fu pectors have no further
questions at this time.
(Closed) Noncompliance Item (295/80-12-03; 304/80-12-01): A portion
of the contents of gas decay tank 1B was released without being held
for 45 days. The corrective actions described in the licensee's
response dated July 29, 1980, were reviewed and appear to be adequate.
This noncompliance item is not related to the concerns noted in
Section 5 about the ability of the gaseous radwiste system to collect
and retain waste gst activity.
(Closed) Noncompliance Item (295/80-05-01; 304/80-04-01): Concerning
contsainated tools not being controlled in accordance with procedure
RP 1440-1.
The corrective actions described in the licensee's
response dated July 18, 1980, have been implemented and appear to
be adequate.
4.
Rad / Chem Department
a.
Staffing
Since previously reported in IE Inspection Report No. 50-295/81-02,
the following organizational changes have been made:
(1)
T. Jakubaitus, a recent radiological health masters graduate
from Northwestern University, was hired as a Health Physicist.
He has no significant past experience.
(2) Two Rad / Chem Technicians (RCTs) have been promoted to
Engineering Assistant (EA) positions within the department,
and one RCT has transferred to Quality Control.
(3) Former Rad / Chem Foreman, M. Davis, has transferred to the
Station's planning group.
The department now has one EA assigned to chemistry and three
EAs assigned to bealth physics. There are 22 RCTs including
four who have recently completed training and are on the job.
The licensee is presently interviewing applicants for additional
RCT positions. There are four Rad / Chem Foreman, one on extended
sick leave.
b.
Management and Management Support
During the Health Physics Appraisal, it was no;ed that management
and management support of the health physics program needs streng-
thening (295/80-05-05; 304/80-04-05). Several corrective actions
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were described in 7E Inspection Report No. 50-295/81-15; 50-304/
81-11.
The following actions remain to be implemented:
(1) The workload placed on Rad / Chem Foremen remains excessive,.
making it difficult for them to directly supervise RCfs
and review protective measures for work in prograus in
radiclogically important areas. According to licensee
representatives, the newly appointed EAs are to relieve
the foremen of some of their workload. This matter was
dir, cussed at the exit meeting.
(2) In accordance with na Immediate Action Letter (IAL), Jated
May 14, 1980, the licensee had agreed to have a consultant
review possible separation of the health physics and
chemistry RCT job function. The inspector reviewed a
report, dated July 9, 1981, titled " Suggested Radiation
Protection Responsibilities and a Proposed Program for
Indoctrination, Training, and Career Development for
a
Radiation Protection Personnel" which was prepared by SAI
under contract to Commonwealth Edison. This report dis-
cusses several personnel matters but does not include
separation of the health physics and chemistry job func-
tions. During later discussions with the CECO Technical
Services Manager, it was learned that the subject of
possible separation of the health physics and chemistry
job functions may not have been included in the scope of
the consultant contract. The study does not appear to
have been performed. The completion date for the study
listed in the IAL was January 31, 1981. This matter was
discussed at the exit meeting.
(7.95/81-21-01; 304/81-17-01)
5; q Gaseous Radwaste Management
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During the Health Physics Appraisal, it was noted that there appears
araple reason to suspect leakage from the gaseous radwaste system
(295/80-05-05; 304/80-04-05). This suspected leakage was also dis-
cussed in IE Inspection Report No. 50-295/80-12; 50-304/80-12.
In the licensee's response, dated August 19, 1980, to the Health
Physics Appraisal significant findings, the licensee described
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several measures designed to improve their capability of assessing
the gaseous radwaste system integrity. Several measures have been
completed, and some are in progtess. Portions of the gas decay
tank system have been leak tested, with no evidence of leakage
found.
During this inspection, it was learned that a radioactive noble gas
release via the auxiliary building vent occurs when the Unit 1 VCT
is vented to the gaseous radwaste vent header; the licensee is
gathering information on this and other previous.f identified or
suspected similar events to help identify possible leakage paths.
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Because there are ample reasons to doubt the integrity of the
gaseous radwaste collection and retention system, the inspectors
are concerned that excessive gaseour releases to the envircament
might occur during adverse operating conditions, an eccident, or
post-accident recovery. This matter was discussed with plant mana-
gers during the inspection and at the exit meeting.
In response
to the inspector's concerns, the licensee stated that they would
evaluate this matt;r, advise Region III of the results of the
evaluation, and update this response to the Health Physics Appraisal
significant finding concerning suspected leakage from the gaseous
radwaste system.
(295/81-21-02; 304/81-17-02).
6.
Emergency Response Capabilities
During the Health Physics Appraisal, it was noted that the Rad /them
Department's emergency response capabilities need_significant im-
provement. Since then, a more comprehensive appraisal of the same
subjects has been performed <
Therefore, the licensee's response to
the first appraisal was only cursorily reviewed. No significant
problems concerning the licensee's response dated August 19, 1980
were noted.
(295/80-05-05; 304/80-04-05)
No significant problems were noted
7.
Portable Demineralizers
During the Health Physics Appraisal, it was noted that the temporary
portable demineralizers, being used for processing liquid radwaste,
could cause radiological problems following a major reactor accident.
The Appraisal Team urged prompt correction, including completion of
additional radwaste treatment facilities.
(295/80-05-05; 304/80-04-05)
Included in the licensee's response dated August 19, 1980, were the
results of a 10 CFR 50.59 review concerning continued temporary use
of the demineralizers and a schedule for completion of a Radwaste
Anne >. Since that time, the use of portable demineralizers within
the Auxiliary Building has been terminated and the Rad"cate Annex
is nearly complete.
Some hard piping to the Annex remains to be
installed. According to a licensee representative, this haid piping
will be installed in the near future.
The actions listed above appear to have improved the situation.
8.
Alpha Activity Surveillance
During the Health Physics Appraisal, it was noted that the ability to
sample, detect, and measure alpha activity should be improved, and
that surveillance should be increased.
(295/80-05-05; 304/80-04-05)
Since the appraisal, the licensee has received, tested, and calibruted
three new gas flow proportional counters. An independent review of
the station's alpha analytical techniques and capabilities was then
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performed by Commonwealth Edison offsite personnel who concluded that
no further significant deficiencies exist. Also, the licensee is
participating in an independent offsite interlaboratory comparison
program. The licensee's response, dated August 19, 1980, includes
a listing of plant system samples and facility smears curt ntly being
routinely collected and analyzed onsite and offsite for cipha activity
detection and measurement.
The actions listed above appear to have sign > ficantly iniproved the
licensee's alpha activity surveillance progrom.
9.
Contaminated 1cols
The inspectors reviewed the results of corrective actions taken to
improve the control tf contaminated tools. 295/81-15-01; 304/81-11-01.
All corrective actions had been taken except that many tools were not
being surveyed before being returned to the tool boxes. During the
inspection, the licensee reinstructed workers about tool survey
tequirerents.
10.
,IE Fulletins and Circulars
a.
The licensee's actions in response to IE Bulletin No. 80-10,
" Contamination of Nonradioactive System and Resulting Potential
for Unmonitored, Uncontrolled Release of Radioactivity to the
Environment," were reviewed. All systems identified as systems
which could become contaminated through interfaces with radio-
active systems are monitored or routinely sampled. No problems
were identified,
b.
This circular concerns malfunctions of SurvivAir Mark I self-
contained breathing apparatus. The licensee does not use these
devices; therefore, no licensee action was necessary.
c.
IE Circular No. 80-14
The licensee's actions in response to IE Circular 80-14, " Radio-
active Contamination of Plant Demineralized Water System and
Resultant Internal Contamination of Personnel," were reviewed.
The licensee generally does not permit temporary demineralized
water hose connections. Demineralized water s. unections have
been posted with signs stating " Prohibited for human Consump-
tion," and samples are routinely collected and analyzed. No
problems were noted.
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IE Cirenlar No; 80-18
Tha licensee's actions in response to IE. Circular No. 80-18,
"10'CFR 50.59 Safety Evaluations for Changes to Radioactive
Waste Treatment Systems," were reviewed. The licensee deter-
mined that procedures exist which adequately, address the
requirements of 10 CFR 50.59.
Also, the appropriate people
have been reinstructed on 10 CFR 50.59 requirements. No
problems were noted.
e.
IS Circular *No. 81-07
The licensee's actions in response to IE Circular No. 81-07,
" Control of Radioactively Contaminated Material," were re-
viewed. The licensee determined that plant practices meet the
release requirements listed in the circular. However, the
permissible release limp:s stated in the Radiological Control
Standards need to be altered. These standards are union
negotiated, and this matter is to be inclc3ed in negotiations
currently being conducted. No other problems were noted.
11.
Transportation Activities
The inspector reviewed the licensee's program for receipt, packaging,
and transport of radioactive materials. Written procedures are used
which specify all necessary documentation, notification, survey, and
package preparation requirements for each type of shipment. Each
step of the procedure requires a sign-off by the cognizant individual.
Records of shipments for 1981 to date were reviewed for compliance
with 49 CFR Parts 170-180 and 10 CFR 71.
No problems were noted.
No items of noncompliance were identified.
12.
Independent Inspection
The inspector response checked several of the licensee's portable
contamin, tion friskers using an NRC Cs-137 beta source set. The
licensee's Eberline PRM-4s response was fcund to be nonlinear, the
efficiencies varied from about 12 percent near the low end of the
bottom range and the high nd of the top range to about 50 percent
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in the middle rante. The cause of this problem was not readily
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apparent. The licensee agreed to investigate the problem and remove
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these instruments from service as necessary.
(295/81-12-03;
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304/81-17-03) No other problems were noted.
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13.
Immediate Action Letter (IAL)
The matters. listed in the IAL, dated May 14, 1980, stating our
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understanding of the planned actions discussed in the' management
meeting held on April 28,1980, were reviewed during this inspection,
and past inspections conducted since the IAL date. All the~ matters
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discussed in the IAL have been, or are being, implemented except
for the two management items described in S-ction 4.b, the gaseous
radwaste concerns described in Section 5, ano followup of the con-
taminated tool corrective actions described in Section 9 of this
report.
14.
Exit Meeting
The inspector met with licensee representatives (denoted in Section
1) at the conclusion of the inspection on August 28, 1981. The
inspector sammarized the scope and findings of the inspection.
In responte to certain matters discussed by the inspector, the
licensee stated that;
a.
They would evaluate the possible radiological consequences
associated with gaseous waste system leakage under adverse
operating conditions such as a leaky fuel element, during
an accident, and during post-accident recovery, and submit
the results of the review to Region III within twenty-five
days.
(Section 5)
b.
They woula update their response, dated August 19, 1980, to the
Health Physics Appraisal significant finding concerning suspected
leakage from the gaseous waste system.
(Section 5)
2.
They would advise Region III in writing, within taenty-five days,
why the commitment to have a consultant conduct a review of
possible separation of the health physics and chemistry job
functions was not performed (Immediate Action Letter dated
May 14, 1980, J. Keppler to C. Reed), and that an expected
completion date or alternate plan would be included.
(Section 4.6)~
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