IR 05000295/1988020

Insp Repts 50-295/88-20 & 50-304/88-20 on 880831-0902. Violations Noted.Major Areas Inspected:Liquid & Solid Radwaste Program,Including Organization & Mgt Controls, Effluent Releases & Records/Repts of Releases

ML20154Q136
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/27/1988
From:	Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154P499	List: IR 05000295/1988020 ML20154P493 ML20154Q123
References
50-295-88-20, 50-304-88-20, NUDOCS 8810030321
Download: ML20154Q136 (10)

Text

.

.--

. .

.

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/88020(ORSS); 50-304/88020(ORSS)

Docket Nos. 50-295; 50-304 Licenses No. OPR-39; DRP-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 Inspection Conducted: A sust 31 through September 2, 1988 Inspector: win 9-A 7-85' ,

Date Approved By: L e hief Facilitiet Radiation Protection k47-86 Date Section

>

Inspection Summary Inspection _on August 31 through September 2, 1988 (Report Nos. 50-295/88020(DRSS)1 50-304/86020(DRSS))

Areas Inspected: Routine, unannounced inspection of gaseous, liquid and solid '.

radwaste management programs, including: organization and management controls (IP 83722); effluent releases and records / reports of effluents (IP 84723 and 84724); calibration and operation of process and effluent control instrumentation (IP 84723 and 84724); solid radwaste generation, processing !

and control (IP 84722); and audits and appraisals (IP 84722, 84723 and l 84724). Also reviewed were open items and circumstances related to elevated '

airborne effluents in Unit I containmen ;

Results: Overall, the licensee's programs for controlling solid radwaste and liquid and gaseous effluents appear effective. However, generic operability '

problems with certain process and effluent control instrumentation continue t One technical specification violation was identified (failure to include all !

required data in a semiannual radioactive release report - Section 8).

.

f I

0810030321 PDR 000927ADOCK 05000295 PNV O [

l

_ - _ _ _ ._ _ ____ ___--____ _ - _ _ - _ _ -

. .

.

.

-

DETAILS .

1. Person Contacted

• A. Bless, Regulatory Assurance

• R. Budowle, Assistant Superintendent, Technical Services

+*G. Geer, Water Management Supervisor

• C. Greaves, Technical Staff Engineer

• P. LeBlond, Rad / Chem Supervisor i R. Palatine, Health Physicist

• T. Rieck, Superintendent, Technical Services  :

T. Saksefski, Regulatory Assurance *

4 +*V. Williams, Lead Health Physicist / RPM

• J. Winsten,' Quality Control

,

i;

• P. Eng, NRC Resident Inspector '

'

The inspector also contacted other licensee employees, including health physicists, chemists and members of the operating staff.

! * Denotes those present at the exit meeting on September 2, 1988.

'

+ Denotes those contacted on September 7-9, 198 . General

,

This inspection was conducted to review the licensee's operational solid, *

liquid and gaseous radwaste management programs, including calibration and operation of process and effluent control instrumentation. Also j reviewed were open items and elevated airborne levels in Unit 1 i containment. Tours of controlled areas were made to observe effluent i

monitors, liquid radwaste process equipment, and follow a planned lake

-

discharge tank effluent release; no significant problems were note Process and effluent control instrument operability problems are ,

described in Section '

i 3. Licensee Action on Previous Inspection Findings (IP 92701) ,

,

(Closed) Ogen Items (295/85034-02; 304/85036-02 and 295/85034-03; 304/8503F03): Establish a radiation monitoring program and monitor sump runoff, respectively, for the interim radwaste storage facility (IRSF).

< Relevant procedures have been developed and are in onsite review. The i

procedures will be reviewed during a future inspection subsequent to '

i licensee approval. Open Items (295/88020-04; 304/88020-04)

(Closed) Open Items (295/85034-04; 304/85036-04)

Review the  !

potential for gaseous generation during long-term radwaste storage in the l IRSF. This matter has been reviewed by SNED. The licensee's evaluation  ;

results will be reviewed during a future inspection. (0 pen Items ,

(295/88020-05; 304/88020-05)  !

!

)

j 2 .

'

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

. .

.

(Closed) Open Items (295/85034-05: 304/8.5036-05): Develop on IRSF container inspection program. A container inspection program procedure has been developed (ZAP 13-52-10) and is undergoing onsite revie The procedure will be reviewed during a future inspection subsequent to licensee approval. Open Items (295/88020-06; 304/88030-06)

(Closed) Open Items 295/86021-01; 304/86019-01): Review turbine building fire sump monitor operability problems. Additional pipe shielding has resolved elevated background radiation problems and electrical ground related spiking problems have been repaired. The monitor has reportedly been operating satisfactorily since September 1987. Operability problems have apparently been resolved; this item is considered close (0 pen) Open Items (295/87022-01; 304/87022-01): Review process and effluent radiation monitor operability problems. The licensee continues to experience operability problems with these monitors. This item will remain open pending further licensee evaluation and ultimate decision regarding the fate of this instrumentation. Section 7(a).

4. Radwaste Organization and Staffing (IP 83722)

The inspector reviewed the licensee's organization and management controls for the radwaste program including responsibilities, staffing, and changes in the organizational structur The station's Radwaste Operations staff reports to an Operating Engineer and is responsible for operating the radwaste processing systems and preparing radwaste shipments including loading, blocking, and bracin The radwaste operations staff has recently undergone a partial reorganization. A Water Management Supervisor, formerly considered a Radwaste Planner, directly supervises four foremen (responsible for various radwaste system operations and shipments) and one radwaste engineering assistant. Stationmen/ Laborers responsible for certain (limited) system operations and DAW collection and shipment preparation, report directly to the shipment foremen. Equipment Attendants operate the radwaste processing systems and report to Shift Foremen (non-licensed).

The Shift Foremen work under the direction of Shift Engineer Since previously reported (Inspection Reports No. 295/87022; No. 304/87023),

the radwaste operations staff has been reduced. Transfers to licensed training have reduced the (non-licensed) shift foremen staff from six to five; another individual is expected to transfer in the near futur In addition, the radwaste engineering assistant is scheduled to retire in September 1988. Although no negative effects have been identified to date, these staff reductions have the potential to negatively impact radwaste operations. This matter was discussed at the exit meetin No violations or deviations were identifie >

. _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-

. .

. Gaseous Radioactive Waste (IP 84724)

The inspector reviewed the licensee's gaseous radwaste management program, including: determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse The licensee's gaseous radwaste system, instrumentation, controls and release pathways are basically unchanged from that described in Inspection Reports No. 295/87022; 304/87023. Calibration and operability of gaseous process and effluent radiation monitors is described in Section The inspector reviewed semiannual effluent reports for the last half of 1987 and the first half of 1988; no significant problems were noted with the gaseous effluent information. The reports generally show a gradual reduction in the total noble gas releases since 1985. Releases were quantified at about 3800 curies annually (both units) in both 1984 and 1985, about 3200 curies in 1986, less than 125 curies in 1987 and about 865 curies in the first half of 1988. The majority (nearly 500 curies) of the noble gas activity released in 1988 was

related to a single turbine building release in May. According to the licensee, on that occasion a routine (weekly) turbine building gas grab sample identified elevated noble gas concentrations which are suspected to have resulted from a containment venting that was drawn into

"

.

the turbine building through nearby turbine building open windows and which was not representative of actual turbine building airborne concentration Subsequent turbine building grab samples did not show similar (elevated) concentrations. Turbine building releases are quantified using the turbine building air sample results and a formula for air exchange to the atmosphere calculated on the basis of the month of the year and reactor unit mode (s). Turbine building air exchange takes place primarily through a varying number of open windows and to a lesser extent through doorways and passages. Small increases in turbine building grab sample results can equate to significant turbine building releases because of the building's large volume. Turbine building release quantification, grab sampling methods and containment venting release pathways will be reviewed further during a future inspectio Open Items 295/88020-01; 304/88020-01 The majority of gaseous effluent releases result from batch type releases made from containments via venting and purging and from waste gas decay tanks. The inspector selectively reviewed records of continuous and batch gaseous releases for 1988 to date. Records showed that technical specification sampling and analysis requirements were met; no instances of a release exceeding technical specification limits were noted.

'

,

f

. .

.

Over the last several years, the licensee has not experienced any significant fuel cladding problems and only minor primary to secondary leakage resulting in relatively low total releases of noble gases, iodines and particulates. The licensee has recently, however, identified elevated noble gas activity (primarily the rubidium-88 daughters of krypton-88) in the Unit 1 containment. This matter is discussed further in Section 1 No violations or deviations were identifie . Liquid Radioactive Waste (IP 84723)

The inspector reviewed the licensee's liquid radwaste management programs, including: determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse The licensee's liquid radwaste system and processing methods, including instrumentation, controls and release pathways are basically unchanged from that described in Inspection Reports No. 295/87022; 304/8702 Calibration and operability of liquid process and effluent radiation -

monitors is described in Section The inspector reviewed semiannual effluent reports for the last half of 1987 and the first half of 1988; no problems were noted with the liquid effluent information. Gross activity in liquid releases from the plant has remained fairly stable since 1985, after reaching a peak in 198 In 1985, 1986 and 1987, about 2 curies, 1.6 curies and 1.5 curies, respectively, of gross activity were release For the first half of 1988, about 1.6 curies were release Liquid releases are primarily from the two (30,000 gallon) lake discharge tanks, typically comprised of waste water from the primary system which has been processed through charcoal bed filters and mixed bed demineralizers. The inspector accompanied radwaste operations staff members and observed the performance of valve line-ups and associated documentation for a lake discharge tank release; no problems were note The release was conducted pursuant to relevant system operating procedures. The inspector selectively reviewed records of batch liquid releases for 1988 to date. Pre- and post-batch release sampling and analyses were found to comply with technical specification requirement About 350 lake discharge tank batch releases were made in 1988 through August; no instances of a release exceeding Technical Specification limits were identifie No violations or deviations were identified.

5 I

_- _____ _ _ _ _ _

.

. .

.

. 7. Calibrations and Operational Status of Gaseous and Liquid process and I Effluent Monitors (IP 84723, 84724) General Operability and Calibrations The licensee continues to experience generic operability problems with many of the process and effluent radiation monitors. As previously reported (Inspectinn Reports No. 295/87022; 304/87023),

the problems appear to stem from the age of the equipment (approximately 20 years old) and associated outdated electronic circuitry. The broad scope problems surfaced several years ago and continue to date; however, the magnitude of the problem has been somewhat reduced as a result of licensee efforts to correct certain common mechanical and electronic problem The insoector selectively reviewed PT-14 records "Inoperable Equipment Surveillance Tests" for 1988 to date. These records document completion of technical specification required testing (action statements) for inoperable equipment / systems and document equipment failures where additional testing is not required. The  :'

records revealed that technical specification action statements were met for selected out-of-service monitors. The records also showed repetitive problems with certain gaseous and liquid process and effluent monitors which were inoperable for extended periods or frequently out of service throughout 1988. These included one of the containment vent and purge effluent monitors, and condenser blowdown and gas decay tank monitors.

>

According to the licensee, operability problems peaked in 1986 when it was not uncommon to have upwards of eight or more inoperable '

monitors on a given day. The station currently experiences roughly four out-of-service monitors per day. Two or three instrument

.

l l

maintenance workers are currently devoted to monitor repairs. The '

licensee has completed modifications to numerous monitors to correct problems related to mechanical movement of internal check sources and is currently working on a replacement (prototype) circuitry board that will provide an interim solution for certain electronic i problems. About 70 circuitry boards would be replaced by the

, prototype unit These interim and apparently symptomatic corrections, although generally adequate, have not addressed the overall root cause of the operability problems. To address the source of the problem, the ,

licensee is assembling a broad scope engineering proposal to replace  ;

the antiquated monitoring system with a new state-of-the-art system. This appears to be the proper course of action to resolve the overall problems. This matter was discussed at the exit meeting ,

and will remain open pending the licensee's ultimate decision regarding the fate of the current monitoring syste !

!

i

.

_ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _

.

,

.

.

The inspector reviewed relevant procedures and records of the latest calibration for a monitor on the radioactive liquid system (one of the lake discharge tank monitors) and monitors on the rddioactive gaseous system (Unit 2 containment purge / vent and gas decay tank monitors). Calibration methods appeared appropriate and met technical specification frequency requirements; no significant problems were noted, b. Lake Discharge Tank Monitor Operation The station has two lake discharge tanks (LDTs) and a single radiation monitor on each discharge line (ORT-PR04 and PROS) to continuously monitor all releases from the tanks prior to discharge to the Unit 1 or ? canals. The monitors have alarm and isolation capabilities as required by technical specifications and initiate automatic closure of the lake discharge valve located downstream of the monitor In late 1985, the licensee installed and made operational a new LDT radiation monitor for the Unit 1 canal (ORT-PR05) to correct high background contamination problems which reduced the sensitivity of the original monito This monitor, unlike its sister monitor (PR04) for the Unit 2 discharge canal, does not have the "alarm seal-in" feature which maintains isolation of the lake discharge valve (and termination of the release) until the monitor alarm is acknowledged and reset by operator action. Specifically, if the cause of the PROS monitor alarm clears the monitor the lake discharge valve will automatically reopen and resume the release, without necessarily allowing the operator to determine the cause of the monitor alarm before resumption of the discharge. (The 11guld effluent monitored by PROS is not released to the environment and recirculates back to the LDT.) Although this operability trait is not desirable, it does not violate technical specification requirements, FSAR commitments, or affect the licensee's ability to adequately control the release of liquid effluent Licensee operating procedures require verification that high alarm automatic actions have occurred to terminate the release or are otherwise manually or locally performed, and that radiation protection is notified for evaluation of alarm authenticity including col'ection and analyses of additional LDT sample To enhance controls over liquid effluent releases and (should a monitor alarm occur) 2ssure that a representative LOT mix exists by subsequent resampling and analyses, the licensee has taken interim corrective actions and is proposing additional long-term action As an interim measure, the licensee revised system operating procedures (501-67) governing LDT releases to require continuous radwaste operator presence at the radwaste panel during releases to isolate the air supply to the lake discharge valve (and maintain isolation of the release) should the monitor alarm. As a long-term

-

. ,

e

.

-

corrective action, the licensee is developing a modification package submittal to install the "seal-in" function on PR05. These matters were discusses at the exit meeting. The status of the proposed modification package will be reviewed during a future inspection (0 pen Item 295/88020-02; 304/88020-02).

No violations or deviations were identifie . Solid Radwaste (IP 84722)

The inspector reviewed selected arnects of the licensee's solid radioactive waste management program, including: 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 weaknesse The licensee's solid radwaste consists of dry active waste (DAW)

compacted /supercompacted in 55- and 83 gallon drums, bead resins, sludges and activated carbons dewatered by a vendor, and certain Class B and C resins and filters cement solidified by a vendor and placed in liners or high integrity container The licensee does not currently segregate clean from potentially contaminated DAW. All DAW is assumed contaminated and disposed of as such. Compatible DAW is shipped offsite to a vendor for supercompaction prior to disposal at a licensed burial site. The licensee attempts to reduce OAW generation by limiting the amount of material taken into radiologically controlled area The inspector reviewed the licensee's process control program (PCP) and vendor solidification and dewatering procedures and discussed their implementa'eion with the licensee; no significant problems were note The procedures appeared to be consistent with 10 CFR 61 and burial site requirements. All vendor PCP related procedures undergo onsite review prior to implementatio The licensee continues to minimize solid radwaste volume by use of radwaste process equipment, administrative controls and DAW compaction /supercompaction. A DAW Reduction Committee continues to meet routinely to discuss / implement programs to reduce the amount of solid radwastes generated. The station plans to continue their current DAW disposal practices and forego DAW segregation pending corporate guidance concerning acceptable segregation and monitoring methods. The licensee's volume of solid radwaste has been considerably reduced since 1985 when nearly 24,000 cubic feet were generated. In 1986, the station generated a total of about 11,675 cubic feet of solid radwast In 1987, obout 1;,500 cubic feet were generated, primarily resulting from dual unit refueling / maintenance outage activities conducted that year. In 1988 through August, about 4,750 cubic feet have been generate m

.

,

.

-

The inspector reviewed semiannual effluent release reports for the last half of 1987 and first half of 1988. No problems were noted in the 1987 report. However, contrary to Technical Specification 6.6.1.0, the semiannual effluent report for the first half of 1988 did not include information regarding solid radioactive waste shipped offsite. According to the licensee, several offsite radioactive waste shipments were made during the reporting period and not included in the report because of an administrative oversight. Failure to include the required data is a violation of Technical Specification 6.6.1.0 (Violations 295/68020-03; 304/88020-03).

One violation was idontifie . Audits and Appraisals (IP 84722, 84723, 84724) ,

The inspector reviewed reports of radwaste activity and related audits ccnducted by the licensee and discussed the audit program with members of the QA staf Annual audits of the radwaste program are conducted by the station's QA Department. The last audit was conducted in March and April 1987 and was previously described in Inspection Reports No. 295/87022; 304/87023. The next annual audit is scheduled for late 1988. The finding from a previous station QA audit (described in Inspection Reports No. 295/87022; 304/87023) concerning functional test frequency for certain instruments has been close Corrective actions for this finding consisted of a technical specification change request submittal for instrument logic check frequency and included interim corrective actions pending technical specification change approva A station QA audit was performed from February 29 to March 18, 1988, to evaluate the station's generic onsite/offsite review programs and procedures. One finding was identified concerning failure to perform reviews of vendor PCP implementing procedures. Adequate corrective actions have been taken and the finding close No violations or deviations were identifie . Review of Elevated Gaseous Concentrations in Unit 1 Containment I The licensee began experiencing elevated noble gas / noble gas daughter !

particulate activity (primarily rubidium-88) in Unit I containment shortly af ter Unit 1 operations resumed in May 1988 subsequent to '

refuelin The containment concentrations identified by the licensee !

to date are not significant (approximately one-MPC maximum) and show no significant increasing trend. The problem was identified by the licensee [

i after frequent containment SPING alert and occasional high alarm indication I

.

,SY

, .- . . .

,

.

l -

The licensee attributes the problem to a known leaking fuel element and small primary system leakage, which has been exacerbated by increased frequency of load following cperation. Although no significant radiological concerns currently exist, escalation of the problem could restrict containment entries and containment venting / purging. The NRC resident inspector office is aware of the problem and is monitoring the situation. These matters will be reviewed further during future ir.spection No viciations or deviations were identifie . Exit Meeting (IP 30703)

_

The inspector met with licensee representatives (denoted in Section 1) at

, the conclusion of the inspection on Septerber 2, 1988, and further discussed issues related to the operability of LDT monitors (Section 7(b))

in telecens on September 7 and 8, 1988, and content of semiannual effluent reports on September 23, 1988. The inspector also discussed the likely informational content of the inspection repcrt with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents / processes as proprietar The inspector Specifically discussed the following matters, The potential for radwaste operation problems associated with staff i reductions. (Section 4)

i-' Continued concerns associated with proccss radiation and effluent monitor uperability problems and noted that the matter will continue

tc be reviewed. (Section 7(a))

$

k

!

e

10 m