IR 05000010/1974003
| ML19340A718 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/22/1974 |
| From: | Allan J, Fisher W, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A715 | List: |
| References | |
| 50-010-74-03, 50-10-74-3, 50-237-74-03, 50-237-74-3, 50-249-74-03, NUDOCS 8009030729 | |
| Download: ML19340A718 (14) | |
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s U. S. ATOMIC ENERGY COMMISSION DIRECTORATE OF REGULATORY OPERATIONS
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REGION III
Report of Operational Radiological Protection RO Inspection Report No. 050-010/74-03 R0 Inspection Report No. 050-237/74-03 RO Inspection Report No. 050-249/74-03 Licensee:
Conr.onwealth Edison Company P. O. Eor. 767 Chicago, Illinois 60690 Dresden Nuclear Power Station License No. DPR-2 Units 1, 2, and 3 License No. DPR-19 Morris, Illinois License No. DPR-25 Category:
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Type of Licencee:
GE-BWR - 210 Mwe, 810 Mwe, and 810 Mwe Type of Inspection:
Routine, Unannounced
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Dates of Inspection: March 5-8 and 12-14, 1974 Dates of Previous Inspection: March 5, 6, & 11, 1974 (Construction)
dN!Jf-Principal Inspector:
I.
isher
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Q,('d,gY<.,p c.c c.fl.-
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4//b24)/!/p Accompanying Inspector:
M. C. Schumacher (Date Other Accompanying Personnel:
None
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l Reviewed By:
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.e 5 d. Allan, Chief, adiological and
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nvir nmental Prot etion Branch (I;ateV
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SUMMARY OF FIUDINGS T'
i Enforecment Action
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The following violation is considered to be of Category I severity:
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The Code of Federal Regulations,10 CFR Part 20.101(b) limits quarterly
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personal dose to three rems.
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Contrary to the above, two Commonwealth Edison employees apparently l
received doses greater than three rems during the fourth quarter of r
.endar
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year 1973.
(Paragraph 8.d)
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Licensee Action on Previcusly Identified Enforcenent Matters i
None within the scope of this inspection.
Unusual Occurrences j
None within the scope of this inspection.
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Other Sinnificant Findings
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A.
Current Findines j.
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The licensee bas contracted with NUS Corporation for the services of
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five or si:: radiation protection people to work with contractor personnel during the current outage. The licensee is also considering
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an increase in the Radiation Protectionman staff.
B.
Unresolved Items
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Workers have not been advised, as required by 10 CFR 19.12,
"... as to the radiation exposure reports which workers may request pursuant to Paragraph 19.13."
(Paragraph 4)
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The licensee has not deconstrated compliance with Technical Specification 6.2.B.2.e. regarding approval of respiratory protective devices.
(Paragraph 9.b)
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C.
Status of Pretiously Resorted Unresolved Items t
i Nona.
l Management Interview A management interview was conducted at the conclusion of the inspection on
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March 14 with Messrs. Pavlik, Roberts, Watts, Williams, and Worden; with Mr. Pavlik on March 15; and with Mr. Roberts on March 26.
The following i
matters were discussed:
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A.
The inspector described the scope of the inspection and stated that
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the plant generally appeared to be in good condition from a radiological ' safety standpoir.t.
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i Foremen (2)
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1, Radmen (15)
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Qualifications of Personnel
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Qualifications of Radiation Protection and Chemistry personnel appear
.to be adequate and consistent with recommendations of ANSI 18.1
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" Selection and Training of Nuclear Power Plant Personnel."
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I 4.
Training A Radiation Protection Orientation, outlined.in Dresden Standards
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j Manual, Chapter 37-9-8,is given to new employees and to contractors
'and visitors who may enter controlled areas.
It consists of an
intensive two-hour session covering AEC limits and Dresden's
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own standards.for radiaticn work.
Emphasis is given to requirements i
for entering and leasing controlled areas, including a demonstration of protective clothing use and step-off pad procedure. Methods-
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of keeping doses as low as practicable are -recommended.
The l
classroom session is folloued by a short tour of the plant during which examples of the discussed practices are pointed out.
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j The session attended by one of the inspectors appeared to satisfy the requirements of 10 CFR 19.12 except as regarding advice ".
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as to the radiation exposure reports which workers may request
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pursuant to Paragrar 19.13."
Individuals who may enter an airborne radioactivity area are also
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given a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Respiratory Training class as outlined in the Standards Manual Chapter 37-1-14.
AEC limits as well as Dresden requirements for respirator use are discussed.
In the session
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attended by the inspector, the use of filter respirators was
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emphasized.
Attendees were given practice in the donning and fitting
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of half and full face models.
Amyl' acetate was used to confirm a fitting (under resting conditions) and to demonstrate the inability.
to obtain a proper fit over a beard. A negative pressure test was
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recommended for routine fitting checks in the field.
New Radiation Protectionmen (Radmen) receive concentrated training in the following areas. This training is generally completed within
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i ninety days.
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Radiation Protection Theory
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Radiation Protection Standards
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Radiation Protection Procedures 10 CFR 20 Chemistry Procedures Laboratory Instruments Radwaste Sampling Procedures Counting Room Instrumentation Dose Rate Instruments and Interpretation of Response Respiratory Protective Equipment Air Sampling Instruments, Calibration, and Interpretation Contamination Sur'ieys Use of Protective Clothing Posting of Radiation Zones First Aid Training GSEP-DESP Exposure Records Liquid Sampling (Other Than Radwaste)
To date, retraining has been provided mainly for employees applying for an operator license.
However, a radiation protection retraining program covering the following areas is being implemented.
CSEP
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Respiratory Protection Equipment Radiation Protection - General Radiation Control Standards 5.
_ Procedures Procedure Manual Chapter 37 cevers radiological aspects of the licensee's operation.
Chapter 37 appears to be comprehensive and adequately maintained.
Thought is currently being given to dividing Chapter 37 into three parts, one containing procedures applicable to all personnel, a second part containing procedures used only by Radiation Pr^tection personnel,and a third containing information for radiation protection management.
Another procedure manual, for use by contractor supervision and foremen, is being cor.aldered.
This manual would comprise those Chapter 37 procedures applicable to contractor personnel.
6.
Records Radiation protection records generally appear to be adequate.
Personal exposure reports are placed on microfiche and are updated biweekly.
Certain other records are presently being microfilmed for storage.
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Radiation Occurrence Reports from January 1973 to the time of tts
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inspection were. reviewed to determine the effectiveness of the ROR
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i system. One hundred and sixteen ROR's were written during 1973.
Of that number, nine concerned personal (skin or clothing)
contamination, eight concerned receipt of exposures greater than
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authorized, twenty-two concerned high. radiation areas found ra be
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unlocked, and seven concerned sources of unnecessary expose..u in l
Unit-1 and Unit 2/3 Radwaste Buildings.
Although the ROR system I
was well used, the Radiation Protection ROR file contained little evidence that ROR's were~being acted upon by management. Discussions
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with management personnel revealed that some of this apparent deficiency involved inadequate documentation rather than inadequate j
response to the ROR. This was recognized by plant managenent before j
the inspection. A system to ensure that ROR's are properly acted j
upon and that such action is properly documented was initiated in early 1974.
7.
Facilities and Ecuipment
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j A general inspection of Unit 1, 2, and 3 reactor and turbine buildings j
revealed no radiological problems.
As has been observed before,
however, the Unit 2/3 Radwaste Building appeared to be very messy, I
the basement floor being covered 01th resins or sludge.
(See Paragraphs 6 and 8.f.)
The Unit 1 Radwaste Building was not
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inspected.
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l Sampling and monitorin.; equipment appeared to be operable and appropriately calibratad.
Calibration records show that portable and fixed monitoring instruments have been calibrated at proper
intervals.
Background radiation levels in certain locations are high enough to interfere with self-nonitoring at GM-equipped checkpoints.
- For example, the background on the Unit 1 trackway hund and shoe
counter, which had a stated reporting level (to Radiation Protection)
l of 100 counts per minute (increase), was 1000 counts per minute.
Two cobalt 60 gamma calibration sources installed in the calibration j
facility were being calibrated against a Victoreen R-Meter during
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performed accurately, and the source drive and position indication the inspeccion.
The recalibration of these sources appeared to be mechanisms appeared to function properly.
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8.
Personal Radiation Protection - External
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a.
Exposure Control External exposure control is described in Procedure Manual Chapter 37-1-12 and in the Radiation Control Stdndards, Chapter 37-1-1.
The system appears to control exposure adequately within exposure limits imposed by the above chapters.
As discussed'in Paragraph 8.f, however, the system might require'more emphasis on reducing exposures to lowest practicable values, b.
Personal Monitoring External dose is measured by beta-gamma-neutron film badges changed biweekly.
Pencil dosimeters are used to estimate gamma dose during the biweekly film badge periods.
For conservatism, pencil results are multiplied by a factor of 1.5.
Except for two recent instances (Paragraph 8.d.), this conservatism has ensured that no personal dose limits have been exceeded.
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c.
Records Radiation exposure reports are received biweekly froq the
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film badge processor. Dose and othcr information required by i
AEC Form 5 are recorded on microfiche, copies of which are maintained at each of the licensee's nuclear stations.
As described in Procedure Manual Chapter 37-9-5, an AEC Form 4 is prepared for every person for whom this form is required by 10'CFR 20.102.
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Notification and Reporting
- The licensee is prepared to advise workers of annual radiation exposure, as required by 10 CFR 19.13(b), but to date has had-no such requests.
The licensee provides exposure reports to workers formerly engaged in licensed activities, as required by 10 CFR 19.13(c).
The licensee reports overexposures to the Commission as required by 10_CFR 20.405 and to affected workers as required by 10 CFR 19.13(d).
Records and reports 1/ concerning'two
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apparent overexposures were reviewed and found to be adequate.
The licensee's evaluation of these exposures indicates anomalous data reported by the film badge processor.
Being unable to-prove this, however, the licensee has recorded
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the apparent overexposures in the two employees' records.
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Two letters, CE to R0:III, dtd 2-1-74.
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The licensee provides termination reports, as required by 10 CFR 20.408 and 10 CFR 19.13(d), for all terminating
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employees and for all contractor personnel who received more
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than 300 millirem in any quarter.
The licensee provides the Commission with an annual exposure report, as required by 10 CFR 20.407.
The report for the year 1973 is expected to be submitted by the May 6,1974, deadline.
c.
Dose Trends Since the startup of Unit 1 in 1959, total and per capita dose to station e=ployees have increased as shown in the accompanying tabic.
The singularly low doses during calendar 1970 occurred because Unit 1 experienced no significant outage and Units 2 and 3 were not yet operating.
Beginning in 1971, doses to both station and contractor personnel increased markedly.
CECO rers
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Year Total Per Capita
' Contractor rems Total rems 1953
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1960
- 64 1961 110
110 1962
- 140 1963
- 120 210 1964
- 90 1965 100
130 1966 110 1.1
150 1967 170 1.3
~190 360 1968 190 1.2 110 300 1969 220 1.1
290 1970 130 0.6
140 1971 320 1.4 400 720 1972 370 1.4 360 730 1973 550**
1.8**
300**
850**
- Not available
- Approximate.
Not yet officially reported.
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i Examination of 1973 film badge records revealed that 6 work
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groups of station personnel have incurred the most significant
per capita exposures..
I Number in Dose (rem)
Group Work Group Description Group Average-Range Ibn-rem
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Fuel Handlers
5.2 2.9-6.6
Radiation - Pro tection
3.7 2.4-4.4
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Mechanical Maintenance
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3.0 0.5-5.1 180 Fuel Handler Foreman
3.0 3.0-3.0
B Operators
2.4 0.05-4.4 110 Shift Foreman
2.4 0.7-5.3
Tctals 144 437 The fuel handler group was created in 1970.
From the outset,.
i it was expected to receive higher than average exposures.
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In 1970, the average dose-to the group was 1.4 rem (also the station average), a factor of 3 louer than in 1973.
The licensee believes doses to this group result from chronic
exposures to low dose rates - mainly from the surface of the
fuel storaga pools.
Overall, this group is young (median age 31)
i with 4 members under 24 year's of age.
Annual doses appear
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well balanced within the group and no individual has exceeded the 5 (N-18) limit.
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The 3 operator group is the youngest of the plant exposure
groups (median age about 26).
Among uembers of the group,
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i dose incurred during periods of radcaste facility work appears to be somewhat higher (147 vs. 114 mrea/2 week period) than during non-radwaste assignments.
More significantly, work in
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the radwaste barrelling area leads to greater exposure
(180 vs. 115 mrem /2 week period) than does work in the raduaste control room.
Exposures appear to be reasonably well balanced
i within this grcup and no individual has excceded the 5 (N-18)
limit.
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i Dose to Dresden contractor personnel has increased since the startup of Units 2'and 3.
Examination of licensee records
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j (January-February 1974) reveals frequent requests (in accordance with Dresden Standards) to permit specified individuals ~to receive doses up to 600 millirem in a day or 1000 millirem in.a week.
The licensee said that most of these involve-individuals hired by a contractor to do work associated with in-service inspection.
A sampling of film badge records (January-February 1974) revealed no exposures in excess of AEC' limits.
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f.
"As Low As Practicable"
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The matter of maintaining in-plant radiacion exposure to
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"as low as practicable" values was discussed at length with I
licensee personnel.
It is apparent that considerable effort is made to. conduct operations in a radiologically safe i
manner and to minimize total personal exposure.
This is most evident in the planning and conduct of high dose rate work.
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However, efforts are being made to reduce sources of exposure throughout the plant.
For example:.
l (1) The possibility of decontaminating Unit 1 to reduce exposure during in-service inspections is being investigated.
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I (2) Ways to reduce the exposure rate from a decontamination pad drain line (near EHC units) are being studied.
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(3)
The possibility of relocating Unit 1 fuel pool heat exchangers and installing fuel pool demineralizers to reduce Fuel Handler dose is being studied.
(4) Ways to reduce the exposure rate from the
"C" Instrument i
Room are being studied.
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(5) The removal and reinstallation of insulation for in-service
inspection is being simplified.
Although progress is being made in reducing personal exposure, i
as described above, there appear to be other areas, notably j
the Unit 1 and Unit 2/3 raduaste areas, in which personal
exposures could be reduced significantly.
This problem seems
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to have been recognized, in that seven Radiation Occurrence Reports in 1973 concerned sources of unnecessary exposure in these areas.
However, no evidence of corrective action was found.
(See Paragraph 7)
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Personal Radiation Protection - Internal a.
Exposure Control Internal exposure control is described in Procedure Manual Chapter 37-1-14 and in the Radiation Control Standards,
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Chapter 37-1-1.
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During the inspection, whole body counting records were being
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microfilmed and were thus unavailable, except for records of
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whole body counts made during the period November 6-14, 1973.
Measurable radionuclides (excluding K-40) are compared below with those measured during May 1971.
Measured in Subjects (%)*
Maximum Measured (nC1)
>TBB Radionuclide May 1971 November 1973 1971 1973 (nci)
Co-58
31
980 2,900(L)**
Co-60 100
100 590 1,100(L)**
Cs-134
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40 20,000(TB)
95
105 30,000(TB)
- Approximately 180 and 220 subjects counted in May 1971 and November 1973, respectively.
- Permissible lung burdens calculated by the whole body counting contractor.
Due to the unavailability of records, it was not possible to determine the significance o'f the inr.reased " Maximum Measured" burdens or to determine the sourcen and extent of internal exposure within the plant.
This will be reviewed during ~ a
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future inspection.
b.
Respiratory Protection Respiratory protection is provided as described in Procedure Manual Chapter 37-1-8.
Technical Specification Section 6.2.B.
appears to be satisfied, except that an MSA GMA-H cc=bination (filter and sorbent) cartridge has not been approved by the U.S.
Bureau of Mines as required by Section 6.2.B.2.e.
According to the licensee, USA is asking the National Institute for Occupational Safety and Health (NIOSh) to consider approval of this cartridge.
The licensee does not use the above combination cartridge when a protection factor is needed for radioiodine.
In such cases, supplied air is used rather than the combination cartridge.
10.
Posting of Notices Notices were found to ba posted in accordance with 10 CFR 19.11.
11.
Monitoring of Trash
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The licensee has had some difficulty keeping contaminated gloves and other slightly contaminated items out of the " clean" trash.
To improve the monitoring and segregation of trash, the licensee is constructing a fenced trash collection pad having an area outside the locked fence for temporary collection and monitoring.
After being
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monitored, trash uill be placed inside the locked fence to await
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pickup by the disposal contractor.
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's, UNITED STATES hj ATOMIC ENERGY COMMISSION
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>s DIRECTORATC OF REGULATORY OPCRATH3NS
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,f f t 8' j DEGhDN 111
799 ROOSEVELT ROAD rnaygong
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. GLEN ELLYN, ILLINOIS 60137 (312) 858-2660
A.
RO Inspection Report No.
050-010/74-03, No. 050-237/74-03 and No. U3U-Z49//4-03 Transmittal Date
April 24, 1974 Distribution:
Distribution:
RO Chief, FS&EB R0 Chief, FS&EB RO:HQ (5)
RO:HQ (4)
DR Central Files L:D/D for Fuels & Materials Regulatory Standards (3)
DR Central Files Licensing (13)
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B.
RO Inquiry Report No.
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Transmittal Date
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Distribution:
Distribution:
R0 Chief, FS&EB R0 Chief, FS&EB
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RO:HQ (5)
RO:HQ DR Central Files DR Central Files
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Regulatory Standards (3)
RO Files Licensing (13)
RO Files
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Incident Notification From:
(Licensee & Docke,t No. (or License No.)
Transmittal Date
Distribution:
DistributL)n:
RO Chief, FS&EB R0 Chief, FS&EB RO:HQ (4)
RO:HQ (4)
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Licensing (4)
L:D/D for Fuels & Materials DR Central Files DR Central Files RO Files RO Files
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