IR 05000295/1985034

Insp Repts 50-295/85-34 & 50-304/85-36 on 850917-19 & 26. Violation Noted:Failure to Make Required Rept When 7 Ci Released from Site Via Liquid Radwaste During Third Quarter 1984

ML20138C380
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	10/08/1985
From:	Greger L, Lovendale P, Nicholson N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138C345	List: IR 05000295/1985034 ML20138C340 ML20138C361
References
50-295-85-34, 50-304-85-36, NUDOCS 8510220420
Download: ML20138C380 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-295/85034(DRSS); 50-304/85036(DRSS)

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-Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison _ Company Post Office Box 76 Chicago, Illinois 60690 Facility Name: Zion Nuclear Power Station Inspection At: Zion Site, Zion, IL'

Inspection Conducted: September 17-19 and 26, 1985 i f, k . fk eb1L Inspectors: N.'A. Nicholson N/'7/#f~

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P. C. Lovendale /c/#/# I Date-Approved By: - Chief /0/8MC Facilities. Radiation Protection Date Section l

Inspection Summary i Inspection on September 17-19 and 26, 1985 (Reports No. 50-295/85034(DRSS);

50-304/85036(DRSS))

Areas Inspected: Routine, unannounced inspection of the radwaste and radiation protection programs including: solid radwaste, liquid radwaste, gaseous radwaste, radwaste storage,'and open items. Also, several radiation protection related allegations were reviewed. The inspection involved 43 inspector-hours onsite -by two NRC inspector ~

Results: One violation was identified in one. area (failure to make a required j report - Section 5).

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DETAILS

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' Persons Contacted

• R. Aker, Lead Health Physicist

• J. Ballard,-QC Supervisor

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• R. Cascarano, Technical Staff Supervisor

• E. Fuerst, Superintendent, Production L. Lanes, Lead Rad / Chem Foreman R. Neeley, QA Inspector J. Nykoayko, QC Inspector K. Petowski, Health Physicist

, J. Ramage, ALARA Coordinator i

T. Rieck, Superintendent, Services

• Schultz, Assistant Technical-Staff Supervisor

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Stone, QA Supervisor

• G. Tryzna, Rad / Chem Supervisor Williams, Health Physicist

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'V.P. Zwilling, Lead Chemist

• Holzmer, NRC Senior Resident Inspector

• L. Kanter, NRC Resident Inspector The inspectors also contacted other licensee employees including radiation / chemistry technicians, radiation / chemistry foremen, and members of the engineering and maintenance staffs.

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• Denotes those present at the exit meetin . General This-inspection, which began at 9:00 a.m. on September'17, 1985, was conducted to review the operational radwaste and radiation protection programs, including solid radwaste, liquid radwaste, gaseous radwaste,

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and open -item Also, several allegations related to radiation protection activities, were reviewe The inspectors conducted radiation surveys of selected plant areas using an NRC survey instrument (Xetex 304-B);

readings were-in general agreement with posted licensee data. Area

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< postings were goo No access controls or procedure adherence problems

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were noted. Housekeeping appears to have improved significantl The majority of minor leaks throughout'the plant have been repaire . Licensee Actions on Previous Inspection Findings (Closed) Open Item (295/84-15-01; 304/84-15-01): ~ Install local alarms on high radiation area doors. Forty-three of the needed alarm systems have-been installed. Three more alarms are scheduled for installatio (Closed) Open Item (295/85005-02; 304/85005-02): High frequency of lost

. film badges. Film badges are now being kept with the workers' security badges in the gatehouse. The number of lost film badges has been reduced to nearly zer t

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(Closed) Open-Item (295/85005-04; 204/85005-04): Reduce the number of minor leaks in the auxiliary buildin The majority of these leaks have been repaire (Closed) Open Item (295/85005-03; 304/85005-03); Evaluate causes of increased personal contaminations. This increase is primarily due to poor performance of the laundry. Loosely fixed low level radioactivity was not being removed from the clothing which resulted in numerous minor skin contamination incidents. The old laundry machines have been replaced with more efficient one (Closed) Violation (295/85021-01; 304/85022-01): Failure to perform needed evaluations of radiation hazards. The in5pectors verified that corrective actions outlined in the licensee's response to the violation dated August 15, 1985, had been take No fugher problems were note . Solid Radwaste 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 notifica-tions; and experience concerning identification and correction of programmatic weaknesse The inspectors selectively reviewed solid radwaste production records for 1984 and 198 A decrease of DAW production and number of radwaste shipments was noted in 1984 over 1983. A volume reduction program has recently been implemented. To minimize the material taken into the controlled area, a staffed checkpoint has been established near the 716'

access control. The checkpoint staff assigns plastic suits to workers and verifies that unnecessary items are not taken into the controlled area. By November, 1985, surveying capabilities will be available to segregate potentially clean from potentially contaminated trash removed from the controlled area. The licensee plans to modify the diesel room as a frisking station for this material.

The inspectors reviewed a violation issued by the South Carolina Department of Health and Environmental Control (DHEC) to the license Loose low-level contaminated resins were found in the bottom of a shipping cask, housing solidified resins packaged in a steel liner, received by the Chem-Nuclear Barnwell, SC, burial site on September 13, 1985. This was an apparent violation of Condition 60 of Chem-Nuclear's -

license which prohibits loose radioactive waste in shipping containers.

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According to licensee representatives, this liner was manually filled with clean resin for nonroutine use as a portable demineralize Licensee representatives speculate some resins overflowed and lodged on the liner supports from where they fell into the cask during loadin The cask was apparently loaded and inspected in accordance with station procedures; however, the few resins outside the liner were not identified during this inspection. In response to the violation, the licensee's inspection program has been expanded to specifically include a visual

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check for resins on the liner supports and in the cask. The licensee intends to discontinue the HV-100 for portable demineralizer use when the i current liner is shipped in mid-October. The resins outside of the liner  !

l were contained by the cask, which meets the strong tight package defini- >

tion. No apparent violations of NRC regulations were identifie !

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No. violations or deviations were identifie '

i 3 Liquids and Liquid Radwaste f The inspectors reviewed the licensee's reactor liquids and liquid

radwaste management programs, including: determination whether changes [

< to equipment and procedures were in accordance with 10 CFR 50.59; l determination whether reactor liquids meet chemical and radiochemical  !

f requirements; determination whether liquid radioactive waste effluents  !

i were in accordance with regulatory requirements; adequacy of required i records, reports, and notifications; determination whether process and  ;

effluent monitors are maintained, calibrated, and operated as required;  ;

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and experience concerning self-identification and correction of  :

! programmatic weaknesse !

3 .The inspectors selectiv'ely reviewed records of liquid releases made during ,

1984 and 1985 to date. Continuous liquid release pathways include the turbine building fire sump and steam generator blowdown. The activity  !

4 released via these two pathways is determined by analysis of composite I samples. Liquid batch releases are made from the lake discharge tanks  ;

(LDTs). Before discharge, tank contents are recirculated to ensure a .

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representative sample. A sample is then drawn and analyzed for isotopic,  !

i gross beta, tritium, and gross alpha activities. From this data, a  !

l release authorization is generated based on available dilution flow, i During 1984 and 1985 to date there have been 643 and 315 LDT releases,  !

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respectively. This number of releases represents an increase in 1984 and  !

a decrease in 1985 over previous years. The volume increase in 1984 was  ;

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j primarily due to the cleanup of sodium hydroxide that was inadvertently

dumped from the containment spray system and then flushed to the radwaste j

holdup tanks (HUTS). The sodium hydroxide effectively decontaminated the  !

j radwaste system piping. This liquid was processed through temporary [ charcoal beds and cleanup resins to reduce activity levels. The need to  !

release the liquid in the HUTS significantly increased the number of LDTs

released. Although effectively reducing concentrations within unrestricted  !

j levels by dilution, the radioactivity released to the lake exceeded the '

i technical specification design objective of 5 curies per unit per year; a  ;

i total of 15 curies was released via liquid radwaste in 1984. The  :

l quantity released during the third calendar quarter was 7 curie The l

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licensee did not notify the Director of Licensing regarding the third j calendar quarter releases. This is an apparent violation of Technical l Specification 3.11.8 which requires the licenset to notify the Director  :

of Licensing within 30 days when the release rate of radioactive material [

exceeds 2,5 Ci/ unit during any calendar quarter, identifying the causes l and describing the proposed program to reduce the release rates i (Violation 50-295/85034-01; 50-304/85036-01).  !

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$ One-apparent violation was identifie }

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. Gaseous Radwaste The inspectors reviewed the licensee's gaseous radwaste program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were in accordance with regulatory require-ments; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated in accordance with requirements; and esperience concerning self-identification and correction of program implementation weaknesse The inspectors selectively reviewed records of waste gas releases made during 1984 and 1985 to date. Gaseous releases are made from waste gas decay tanks (WGDTs), and containments via venting and purging. No instances of a release exceeding technical specification design objectives were note Ten WGDTs have been released in 1985 to date. Sixteen WGDTs were released in 1984. This relatively large number of WGDT releases is due primarily to the large water inventory caused by the sodium hydroxide addition to the radwaste system. The large water inventory increase caused the cover gas normally occupying space within the large tanks, such as the HUTS, to be compressed, collected and released. The licensee continues to keep a close watch over waste gas inventory so that system leakage can be readily detecte Records of HEPA filter and charcoal adsorber tests conducted during 1984 and 1985 to date were selectively reviewed. All tests were conducted in accordance with the technical specifications and yielded satisfactory result No violations or deviations were identifie . Allegations On August 19, 1985, an anonymous former contracted radiation protection technician telephoned Region III and related several concerns regarding radiation protection activities during the Unit 1 refueling and mainten-ance outag The inspectors discussed these allegations with station and contractor personnel, reviewed records of surveys and radiation work permits, and reviewed radiation occurrence reports generated during this perio No violations or deviations related to the allegations were identifie Allegation: Radiation work permits (RWPs) were inadequate or disregarded during the outag Discussion: The alleger claimed that the RWP for entry below the steam generators did not specify respiratory protection and that he entered the area beneath the steam generator loops (560-foot elevation) with only a beta shield and without a respirato L

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The inspectors' review of radiation work _ permits for entry into the 560-foot elevation areas under the steam generators revealed that each permit included the requirement for respiratory protection. In addition, surveys of these areas revealed that the area was highly contaminated and posted as airborne radioactivity areas. According r to personnel interviewed, respiratory protection devices were routinely worn for entries beneath the steam generators. If the alleger did enter these areas without respiratory protection, it appears that he did so in violation'of the applicable RWP and the

. area postin The allegation was not substantiate No violations or regulatory concerns were identifie !

Allegation: Radwaste bags measuring in excess of 75 mR/hr were not

' escorted to the compactor by radiation protection technicians as required by station radiation protection procedure Discussion: The alleger stated that radwaste bags measuring as high as 300 mR/hr were not escorted. The inspectors could not identify any such procedural requirement, but radiation protection personnel stated that radiation protection technicians normally escort such waste to ensure that it is properly stored near the compactor thereby preventing the creation of uncontrolled radiation hazards. A review of radiation occurrence reports and surveys of the compactor area did not reveal any problems with the movement of radwaste bag Although the allegation was not substantiated, it appears that no '

regulatory violation would have existed had it been substantiate , Allegation: A vacuum cleaner fell two levels and spilled dust everywher Discussion: The alleger stated that during April 1985 a plant employee reached over a " radiation rope" and pushed a vacuum cleaner which fell two levels and spilled dust (assumed to be radioactive)

everywhere. The alleger contended that this was an example of poor radiation safety practices at Zio l A review of radiation occurrence reports and discussions with plant and contractor personnel did not reveal any such incident. Although I Zion Station has been cited for poor radiation safety practices in ;

the past, recent NRC inspection have not revealed a continuation of !

poor practices. The licensee's performance in the radiological controls area has steadily improved over the last two and one-half year This allegation was not substantiate ;

e Allegation: Poor laundry practices for cleaning protective clothin t i

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Discussion: The alleger stated that Zion Station utilized poor laundry practices.for cleaning protective clothing. The caller stated that the laundry did not remove contamination and only fixed it to the protective clothin The licensee and the NRC have been aware of the laundry problems at Zion for some time. It appears that the old and inefficient laundry equipment does not always remove all the loose contamination from the clothing; this has resulted in many minor skin contaminations

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when workers sweat while wearing the clothing. In response to this problem, the licensee has installed new laundry equipment which should be in operation during the upcoming outage. No clothing monituring problems were identifie Although the allegation was substantiated in that a problem with the laundry existed, the licensee's corrective actions for the problem is acceptabl . Interim Radwaste Storage Facility The licensee is constructing an interim radwaste storage facility (IRSF)

for solidified radwaste for use should commercial burial sites restrict burial allocations January 1,1986. Other alternatives for dry active waste (DAW) storage and handling are being evaluate The IRSF is a generic CECO design; similar structures are being constructed at the LaSalle and Quad Cities st'ations. An inspector reviewed blueprints of and toured the IRSF; the base layer of the roof has been poured. The IRSF is to be completed during 198 The licensee has conducted a 10 CFR 50.59 evaluation of IRSF safety issues. This evaluation was briefly reviewed; it will be reviewed further pending additional generic guidance from I&E on 10 CFR 50.59 evaluations for storage facilitie The licensee is currently developing operational and radiological moni-toring programs for the IRSF. As an ALARA measure, no personnel access doors to the storage area have been designed. Containers are manipulated by a crane operated remotely. In response to the inspectors' comments, the licensee agreed to: (1) establish an air and direct radiation monitoring program for the storage area and occupied areas (0 pen Item 295/85034-02; 304/85036-02); (2) monitor water runoff collected in the !

sumps (0 pen Item 295/85034-03; 304/85036-03); (3) review the potential of gaseous generation during long-term storage (0 pen Item 295/85034-04; 304/85036-04); (4) develop a container inspection program to assure container integrity (0 pen Item 295/85034-05; 304/85036-05); and (5) consider placing the first layer of containers on a metal grating to minimize condensate collection (0 pen Item 295/85034-06; 304/85036-06).

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The IRSF is. located outside t.he protected area, but within the owner

controlled area. The licensee plans to maintain the facility- )

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continuously locke No apparent violations or dev.iations were identifie . ' Auxiliary Building Tour On September 19, 1985, an inspector accompanied the ALARA Coordinator on

, .a general tour of the auxiliary buildin The following observations

were mad * Contaminated components stored in the fuel building trackway had

. 'been decontaminated and removed; the trackway had been cleaned and i released from contaminated area status.

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j Reduced number of steam leaks throughout the auxiliary buildin *

The ALARA coordinator is following leak repair work activities (See ]

Section 3).

• Significant improvement'in general housekeeping.

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• Installation of local alarms on High Radiation Area doors (See l Section 3).

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• Placement of designated trash containers throughout the auxiliary

i building as part of the proposed volume reduction program.

l Currently, all trash from the controlled area is treated as

! contaminated waste. Under the volume reduction program, separate t

containers would be designated for potentially contaminated versus 1 potentially clean trash. All material would be surveyed after.

leaving the controlled area.

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• Independent measurements made with an NRC survey instrument were in general agreement with posted licensee data.

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• Elevated readings with the NRC instrument were detected from i settlement buildup along the lake discharge pipe on the 560' and

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542 levels. Contact readings on the vertical run pipe on the 560'

level were approximately 75-80 iR/hr; this pipe section is readily accessible to personnel. A hot spot of 120 mR/hr was found in an

inaccessible pipe run area on the 542' level. In response, the 4 ALARA Coordinator (1) made arrangements to have both sections of pipe wrapped with lead sheets to reduce exposure, and (2) is j evaluating the possibility of replacing this pipe section with j stainless steel piping.

1 No apparent violations or deviations were identified.

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10. ' Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on June 21, 1985. The inspectors summarized the scope and findings of the inspection. The inspectors also discussed the likely information 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 the inspectors' comments, the licensee: Acknowledged the violation (Section 5). Stated that the following items would be incorporated into the IRSF construction program (Section 8)

• establish a radiological monitoring program for the IRSF

• monitor the IRSF sump collections

• review the potential for gaseous generation in packages during long-term storage

• develop a container inspection program

• consider a first layer grating to minimize condensate contact with long-term stored packages

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