IR 05000010/1974005
| ML19340A713 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/10/1974 |
| From: | Allan J, Fisher W, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A712 | List: |
| References | |
| 50-010-74-05, 50-10-74-5, NUDOCS 8009030723 | |
| Download: ML19340A713 (14) | |
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U. S. ATOMIC ENERGY COMMISSION
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DIREC' ORATE OF REGULATORY OPERATIONS
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REGION III
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'rt of Operational Radwaste Inspection
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RO Inspection Report No. 050-010/74-05 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Drr,sden Nuclear Power Station
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License No. DPR-2
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Unit 1 Category:
C Morris, Illinois Type of Licensee:
GE - BWR - 210 MWe Type of Inspection:
Routine, Unannounced
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Dates of Inspection:
May 21-24, 28, 29, and 31 and June 4, 1974 Dates of Previous Iaupection: May 6, B, 10, and 15, 1974 (Materials)
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7/7[7 V Principal Inspector:
W L F (D'te)
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7 !9/74 Accompanying Inspector:
M. C. Schumacher (Dat'e)
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J. M. Alla A.f(Jue4,1974)
'/(Da't e)
. Jaty 7 F 7f/
Reviewed By:
. M. Allan, Ch f Radiological and Environmental
'(Dite)
Protection Branch
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SUMMARY OF FINDINGS
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Enforcement Action Title 10 CFR Part 71 requires that licensees obtain a specific license for packages used to ship radioactive material, unless exempted from such requiremen'es.
Contrary to the above, solidir > resins and sludge containing greater than Type A quantities have been transported to Sheffield, Illinois, in unlicensed packaging.
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Licensee Action on Previousiv Identified Enforcement Matters None.
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Unusual Occurrences A.
On March 5, 1973, a malfunctioning radwaste flow recorder resulted in an improper radwaste release rate.
(Paragraph 2.f)
B.
On March 17, 1974, a valve and tank failure resulted in the release of 2,000 gallons of radwaste to the ground.
(Paragraph 2.g)
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C.
An unexplained increase in the service water monitor count rate
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occurred on December 5 and 31, 1973.
(Paragraph 2.h)
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D.
On May 23, 1974, a service water line failed inside the containment
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sphere.
(Paragraph 2.1)
Other Significant Findines A.
Current Findings 1.
During 1973, the "B" Seccadary Tank accounted for 29 percent of the volume and 89 percent of the activity in liquid radwaste effluent.
(Paragraph 2.b)
2.
Analysis by the AEC Health Services Laboratory of Waste Neutralizer and "B" Secondary Tank samples taken on February 20, 1973, showed a Waste Neutralis.er Filter decontamination factor of about 1 to 2.
(Paragraph 2.b)
3.
The licensee's semiannual reports for 1973 state that, " Analytical results
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attributable to plant operation." This s;atement is contradicted by data included in the report.
(Paragraph 2.e)
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B.
Unresolved Items:
None.
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C.
Status of Previously Reoorted Unresolved Items
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Modifications to improve the sensitivity and simplify calibration of the service water monitor and other liquid process radiation monitors have not been made.
(Paragraph -2.c)
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Management Interview A management interview was conducted at the conclusion of the inspection on June 4,1974, with Messrs. Pavlick, Roberts, and Stephenson.
The following matters were discussed:
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A.
The inspector noted that information is occasionally.omitted from radwaste batch cards and valve check lists.. (Paragraph 2.a)
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B.
The inspector noted that liquid radwaste records confirm the effluent
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data reported in 1973 semiannual reports.
(Paragraph 2.a)
C.
The inspector asked if it will be possible or necessary to distinguish Unit 1 liquid effluents from Unit 2/3 effluents if Unit I radwaste is sent to the Unit 2/3 radwaste system for processing.
The licensee agreed to review the matter to see if separate identities must be maintained (e.g., for reporting purposes).
(Paragraph 2.b)
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D.
The licensee confirmed that routine surveillance testing of liquid
.rocess monitors will begin when Unit I restarts.
(Paragraph 2.c)
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rhe inspector stated that insensitivity and lack of calibration of liquid process monitors will be considered a violation of 10 CER 20.201(b)
2nless resolved by October 1, 1974, by the study currently underway.
' Paragraph 2.c)
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F.
The licensee agreed to notify RO:III by July 31, 1974, of the temporary and/or permanent course of action to be taken to reduce liquid effluents.
(Paragraph 2.b)
G.
The licensee agread to review and appropriately resolve the commitment to install a 0 to 2 gpm flow measuring device in the radwaste discharge system.
(Paragraph 2.f)
H.
The licensee agreed to notify RO:III before ANEFC0 cuts open any radwaste liners for inspection.
(Paragraph 3.b)
I.
The inspector stated that the shipment of solidified resins and sludge in unlicensed packaging appears to have violated provisions of 10 CFR 71.
(Paragraph 3.c)
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The inspector stated that gaseous release records confirm the effluent
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datS reported in the 1973 semiannual rep'>rts.
(Paragraph 4.a)
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K.
The inspector observed that no iodine or particulate release data were reported for September 19 and 20,1973,. and that no review of possible release had apparently been done.
The licensee stated that this was an oversight and that.cormally a release would have been
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assigned for those days.
(Paragraph 4.b).,
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The inspector stated that he had reviewed the licensee's data relating to the derivation of a calibratign,dactor for off-gas samples and found it satisfactory.
(Paragraoh 4.c)
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M.
The inspector noted that the calibration factors for iodine counting of charcoal cartridges incorporate an efficiency factor provided by the General Electric Company several years ago.
The licensee agreed
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to verify that this factor is still applicable.
(Peragraph 4.c)
.N.
The inspector noted that the licensee appeared to be missing an opportunity to compare his counting results with those of his environmental contractor on occasions when the same samples are analyzed by both parties.
(Paragraph 4.c)
O.
The inspector stated that instrument maintenance. shop records
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suggest that electronic calibrations of chimney and off-gas monitors were done infrequently until recently, and said that it was his
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understanding that they are now being done according to the schedule
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to be required in the expected new technical specifications.
This I
was verified by the licensee.
(Paragraph 4.d)
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P.
The inspector noted that a sharp bend had been removed from the chimney monitor sampling line but observed that a sharp bend in another portion of the line might adversely affect iodine sampling.
The licensee stated that this problem would be corrected before
. Unit I resumes operation.
(Paragraph 4.e)
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REPORT DETAILS
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Persons Co tacted
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Unit 1 G. Abrell, Operating Engineer,?
D. Adam, Engineer
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R. Crandall, Engineer J. Diederich, Administrative Assistant to S tation Superintendent W. Hildy, Instrument Engineer R. Pavlick, Supervisor, Radiation and Chemistry Control A. Roberts, Assistant S tation Superintendent B. Stephenson, Station Superintendent
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R. Thomas, Instrument Foreman S. Gurney (ANEFCO)
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B. Irving (ANEFCO)
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2.
Liquid Radwaste a.
Records Liquid radwaste records for calendar y ar 1973 were reviewed and compared against the data reported in the licensee's semiannual reports for that year.
No discrepancies were
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observed.
Batch cards occasionally lack evidence that tank
1evel was checked two hours af ter a release began.
Occasionally,
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the valve check list attached to batch cards has not been signed or initia11ed by the operator msking the release,
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a t During 1973, the following quantities of liquid radwaste were released:
Laundry - 570,000 gallons containing 580 mil 11 curies
"C" Waste Holdup Tank - 20,000 gallons containing 470 millicuries
,"B" Secondary Tank - 240,000 gallons containing 8,200 millicuries Sampling, analysis, and release records concerning Batch Number 8021, a "B" Laundry Tank release on November 4, 1973, were reviewed.
No
' errors were observed.
However, as described below, the licensee appears to be overestimating radwaste concentrations and, therefore, liquid effluent releases.
Duplicate 2-milliliter radwaste samples are counted for gross gamma activity in a NaI well scintillation system. Activity measured in this manner is conservatively assumed to be all radioiodine, apparentlyinresponsetoaquestionpreviouslyraisedconcergpng the need for measuring radiciodine in Unit I liquid effluent.-
Duplicate 5-milliliter samples are evaporated and counted in a 2-pi
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gas flow proportional system.
The overall beta counting efficiency 1/ RO Inspection Report No. 72-03.
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is conservatively assumed to be 25 percent. Th e total concentration in the sampled radwaste is then assumed to be
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the sum of the above gamma and beta concentrations.
This method probably results in concentration estimates high by
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a factor of 2 to 4.
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b.
Waste Treatmeist
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i Unit 1 liquid effluents receive no treatment other than-filtration.
Clean waste is processed through a fine (approximately 1 micron) Waste Filter to the "C" Waste Hc?. dup Tank, from which it is released. On May 5,1972, samples were obtained by the
licensee -for the AEC upstream and downstream of the Waste Filter.
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Decontamination factors determined from isotopic concentrations measured by the AEC Health Services Laboratory showed the filter
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to be ineffective, probably due to the low turbidity of clean j
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waste.
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Plant (all units) laundry waste is processed through a coarse
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from which it is released.
During 1973, laundry waste accounted
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for 69 percent of the volume and 6 percent of the activity in liquid effluents.
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wastewas2.7x10~jheannualaverageconcentrationoflaundry
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microcuries per milliliter.
The highest concentration in a single laundry tank release was 3.4 x 10-3 microcuries per milliliter.
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During 1973, the "B" Secondary Tank accounted for 29 percent of
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, g the volume and 89 percent of the activity released. On February 20, 1973, the licensee obtained for the AEC samples from the Waste-Neutralizer Tank and then, after processing the Waste Neutralizer Tank liquid through the Waste Neutralizer Filter, from the "B" Secondary Tank.
Decontamination factors determined from isotopic concentrations measured by the AEC Health Services Laboratory generally ranged from 1 to 2.
The low decontamination factor was discussed with plant management by telephone on March 19, 1973.
During an earlier inspection, the licensee agreed to determine
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in order to reduce radioactive effluents.2 This determination
has not been made, although the licensee has prepared an Action Item Request for resolution of the problem by September 1975.
Meanwhile, a tie line has been installed to permit routfng Unit I liquid radwaste to the Unit 2/3 radwaste system for additional processing. The extent to which this will be possible is unknown.
2/ Ltr, RO:III to CECO, dtd 6-7-72.
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c.
Process LiqJid Monitors
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During an inspection performed in May 1972, the inspector noted thatliquideffluentmonitorshadnotbe7ncalibratedagainsta liquid of known activity concentration.2 The. licensee was advisedthatcorrectiveactponinthisregardwouldbeexamined dqring future inspections.1 During a later inspection, the
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licensee stated that work on the Unit 1 service water monitor could not begin until sLnilar work on the Unit 2 and 3 monitors had been completed.1/
In February ~1973, this matter was considered an unresolved item. At that time, the licensee agreed to expedite an engineering study of ways to improve the sensitivity and simplify monitors.g of the service water monitor and other process liquid calibrati
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During the current inspection, it was learned that the study had not been performed, but that an Action Iten Request had recently
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been initiated for performance of a study to be completed by October 1, 1974.
Surveillance testing of these monitors has not been performed routinely in the past.
However, the licensee indicated that monthly functional testing using a cesium 137 source will begin when Unit 1 restarts. Once each three months, the functional
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test will be supplemented by ratemeter calibration, discriuinator adjustment, and other electronic tests.
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d.
Unmonitored Release Paths
There appear to be no unmonitored release paths for liquid radwaste to reach the river.
It is possible for surface contamination (e.g., in the Unit 1 Radwaste Area) to be washed through the storm sewer to the discharge canal.
Such a release would be sampled by the discharge canal composite sampler.
e.
' Semiannual Report The licensee's semiannual reports for calendar year 1973 state,
- regarding weekly composite samples taken from Unit 1 inlet and discharge canals, that, " Analytical results
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any measirable radioactivity attributable to plant operation."1 S/
However, the referenced data do not support that statement.
In 43 of 52 weekly samples taken during 1973, the gross beta concentration in the discharge canal exceeded the concentration in the intake
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3/ RO Inspection Report No. 72-02.
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4/ Ltr, RO:III to CECO, dtd 6-7-72.
5/ RO Inspection Report No. 72-03.
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6/ RO Inspection Report No. 73-01.
7/ "Dresden Nuclear Power Station Radioactive Waste And Environmental Monitoring - January through June 1973."
8/ "Dresden Nuclear Power Station Radioactive Waste And Environmental Monitoring - July through December 1973."
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canal.
The measured, net, annual average discharge canal gross beta concentration appears to have been about 5 picocuries per
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liter.
The semiannual reports also show that 9 curies (excluding tritium)
was released into 3 x 10ll liters of dilution (circulating) water for an annual average efflu'ent concentration of 30 picoeuries per liter. The discrepancy probably results partly from the conservative error discussed in paragraph 2.a.
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f.
"B" Secondary Release The licensee reported in early 1973 that a malfunctioning radwar*_
flow recorder had resulted in an improper radwaste release rate.9/
A review of records during the current inspection confirmed that no ILnits were exceeded.
However, discussion with licensee personnel revealed that, contrary to corrective action described in the April 13, 1973, letter, the O to 5 gpm flow metering instrument was not replaced by a 0 to 2 g;m instrument.
g.
"B" Was te Holdup Tank Leak On March 17, 1974, a valve and tank failure resulted in the release of 2,000 gallons of radwaste to the ground.10/ Review of the incident
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during the current inspection revealed that:
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(1) At some time in the past, the original tank vents were removed and the overflow lines were modified to act as vents.
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(2) The c:ack in the top of the "B" Holdup Tank occurred in the past, probably as a result of pressurization some time af ter the vent and overflow line modification.
(3) Valve V-8 malfunctioned to initiate the release.
Foll'owing the release, approximately 2,000 cubic feet of contaminated soil and gravel removed from the area surrounding the tank was placed into steel boxes for eventual disposal.
Measurements made during removal indicated that essentially all of the contamination was placed into the boxes.
Filtered vents have been reinstalled on the tanks, and the crack and faulty valve have bee.n repaired.
9/ Ltr, CECO to L, dtd 4-13-73.
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10/ Ltr, CECO to L, dtd 3-26-74.
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h.
Service Water Monitor Increase
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On December 5, 1973, the service water monitor count rate increased from 5 to 35 percent full scale.for about six hours.
Service water samples taken during and following this period showed slight contamination, which disappeared by the following day. A similar increase. occurred on December 31, 1973.
Both increases occurred during an outage when the vessel and. canal were empty. To date,
.the increases are unexplained.
The licensee is still investigating.
1.
Service Water Line Failure
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On May 27, 1974, the licensee notified RO:III that a reactor enclosure drain tank cooling line had failed inside the containment sphere on May 23, 1974. About 25,000 gallons of service (river)
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water flowed into the containment sump and was pumped into the enciesure drain tanks, which then overflowed back to the containment sump. By.May 28, the processing of this waste through the Unit 1 radwaste system was essentially completed.
The leak resulted in no release of radioactivity from the plant.
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Radwaste Facility
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A tour of the Unit 1 radwaste facility revealed significant house-keeping improvements.
The radwaste basement was reasonably dry
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and clean. Exposure rates were generally in the range of 10 to 100 milliroentgens per hour.
The radwaste ventilation system was found
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Also,~ ventilation system filter
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. compartment doors were found incompletely latched.
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Solid Radwaste
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Records
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Solid radwaute records for calendar year 1973 were being micrafiched and thus were not available for review. Records for 1974 were reviewed.
" Radioactive Materials Shipment
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Reccrd" forms have generally not been signed by the storekeeper to certify that the material.has been packaged and labeled properly. Frequently, the form contains no description of the shipping container.
b.
Resin and Sludge Solidification
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R.* tin and sludge are being solidified by ANEFCO..
Resin and
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j sludge are mixed with urea formaldehyde, and sodium bisulphate
is added as a catalyst as the mixture is pumped into an 89-cubic-1-
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foot, cylindrical (approximately 4' diameter by 7' high)
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polyethylene liner.
The mixture is adjusted to obtain ' inst solidification in order to prevent settling of the res'.nt, and
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sludge. After filling, a cap layer of urea formaldehyde and j
catalyst is poured into the liner. The liner neck is then j
capped with a nonremovable polyethylene cap. ANEFC0 personnel believe that little, if any, liquid remains unsolidified. Tc t'est
i this, however, ANEFCO plans to cut open several liners containing
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low activity waste within a few months.
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Exposure rates within the solidification building are generally about 1 milliroentgen per hour, but are much higher near the
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solidification equipment. The operator typically receives about 30 milliroentgens per day while filling 10 liners. Filled liners
are stored out-of-doors surrounded by temporary shielding while awaiting shipment.
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c.
Resin and Sludge Shipment
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For shipment to Sheffield, Illinois for burial, a liner is placed
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into a concrete and steel cask on a flatbed truck. The curie
. content of the liner is then estimated from exposure rates measured outside of the cask. The accuracy of this method has not been verified by sampling or other means.
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Discussion with the Department of Transportation indicates that the shipments to Sheffield are considered interstate and are thus covered by 10 CFRg 9.
i Radioactivity contained-in the solidified resin and sludge is assumed by the licensee to be in Transport Group III. However, j
the licensee offered no measured evidence of the absence of
- j strontium 90 or that the radionuclides should not be considered
" mixed fission products."
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Title 10 CFR Part 71 requires that licensees obtain a specific
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license for packages used to ship radioactive material, unless
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exempted from such requirements.
The resin liners and shipping cask are not so licensed, and do not appear to be exempted from the licensing requirement except for shipment of Type A quantities.
On 17 occasions in January and February 1974, re' sin shipments greater than Type A quantities (assuming Transport Group III)
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were made, as follows, according to the licensee's shipping records:
Date
_Ci Date C1 1/17/74 3.5 2/6 3.5
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1/28 9.2 2/7'
5.3 2/1 8.4 2/8 6.6 2/4 5.3 2/12 3.5 2/4 4.0 2/14 4.5
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2/4 6.6 2/ L5 4.4
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2/5 3.5 2/20 5.7 2/5 3.3 2/21 3.5 2/5 5.3 4.
Gaseous Radwaste
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a.
Release Records
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Unit 1 gaseous effluents (air ejector off-gas, reactor building ventilation and turbine building ventilation) are released through the 300-foot Unit 1 chimney. The off-gas fraction is
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given approximately 20 minutes of holdup.and is passed through high efficiency filters before entering the chimney.
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Noble gas releases are based on the analysis of a daily grab sample of off-gas from the air ejector.
It is assumed that release parameters at that time hold for the entire 24-hour period.
Particulate and iodine releases are based on the evalu-ation of integrated (24-hour) filter and charcoal cartridge sarnles taken from the chimney.
The licensee's release records for 1973 were examined and selected sample analyses were reviewed in detail.
No.significant errors were observed in either the daily release records or in the summed releases reported semiannually to the Commission.
The records examined included a daily graph of chimney discharge that has been kept pursuant to an abnormal occurrence recorded on January 3, 1971.11/ 12/
Except on this occasion when the iodine plus particulate release 11/ Ltr, CE to L, dtd January 18, 1973.
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12/ RO Inspection Report No. 050-010/73-01.
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exceeded 0.48 uCi/second over 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, no reportable release took
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place during 1973. The maximum releases recorded in 1973 together with applicable technical specification limits are tabulated below:
Dresden 1 Limits and Maximum Release Rates for 1973
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Limits (uCi/sec)
Release Rates (uCi/sec)
Quarterly 48-hour Quarterly Daily *
Average Average **
Daily Average
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Noble Gas 560,000 56,000 112,000 62,000(4/11)
40,000 (3rd)
Iodine &
Particulate 2.4 0.24 0.48 0.7 (1/3)
0.06 (1st)
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- Station limit based on release via Unit 1 chimney.
- Abnormal Occurrence if exceeded for consecutive 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, b.
Missing Data of September 19 and 20, 1973 An anomaluous event was noted in that no iodine or particulate release,was recorded for September 19 or September 20, 1973, the days following the year's highest (0.12 uCi/sec) ree ded particulate
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release and approaimately coinciding with a reported _gg/ airborne
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condition in the sphere. Apparently no evaluation of potential release
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was made by the licensee.
Sampling difficulties were blamed for the
~ bsence of camples and lack of evaluation was described as an over-a
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sight. Normally, the release rates are plotted each day and the up-to-date graph is placed on the radiation protection supervisor's desk each morning with anomalies noted.
If data are missing, a release would ordinarily be assigned after a review of related information.
It was noted by the licensee that off-gas release remained steady during this period. However, this information is of doubtful value, since off-gas is determined from a grab sample
~ taken once daily.
A review of air samples taken in the sphere showed that activity on the 529' level was up 1 to 2 orders of magnitute on September 18.
- No iodine samples were recorded.
The inspector estimated that the reported September release (0.06 curies) may therefore have been low by 20%. The difference is :.ot regarded as significant at the level (.02 uCi/sec) of release involved.
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'13/ Ltr, CE to L, dtd 9-27-73.
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c.
Reliability of Release Calculations
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The reliability of gaseous release calculations depends on the validity of calibration of laboratory instruments on which the samples are counted. The inspector r.eviewed data relating to the calibration of the Dresden well counters used for gross counting oO the 'off-gas vials.
The calibration is based on the isotopic analysis of off-gas using a sod'ium iodide analyzer (in one case a GeLi analyzer) and is limited by the accuracy of that procedure.
The calibration appears to be satisfactory.
Calibrations relating to the calculation of iodine and particulate
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releases incorporate efficiency factors obtained from the General Electric Company at some time in the past.
The licensee did not have at hand information on the origin of these factors.
Periodically, the licensee's environmental contractor analyzes routinely collected charcoal cartridges. The licensee stated that he has not compared these results with his own for the same cartridges.
The inspector made the comparison for three cartridges and found them to agree within a factor of two.
d.
Process Monitors Process monitors (chimney and off-gas) used for surveillance of
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gaseous effluent streams are electronically maintained by the instrument maintenance shop.
Records suggest that functional tests
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and calibrations (electronic) were infrequently done before 1973.
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, j A licensee representative said the calibrations were not frequently done but were done more frequently than.the examined records show.
New detailed procedures for calibration and functional testing have been written and have been followed since December 1973.
These tests will be required quarterly under the expected version of the new Unit 1 technical specifications.
The current technical spe.cifications are silent on this matter. A comparison of the response of these monitors as a function of off-gas release rate is made daily by the Radiation Protection Department.
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e.
Chimney Monitor Modificatiou The licensee has removed a 90-degree bend from the sampling line ahead of the particulate filter in the Unit 1 chimney monitor.
However, a flexible hose connection between the filter and the following charcoal cartridge was bent even more than 900, raising the question of iodine sample loos.
The licensee recognized the problem and said it would be solved by a pending modification which will bring the particulate filter and charcoal cartridge together.
This modification will be completed before Unit 1-returns to operation..
14/ RO Inspection Report No. 050-010/73-01.
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k UNITED STATES
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l ATOMIC ENERGY COMMISSION
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DIRECTORATE OF REGULATORY OPERATIONS
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REGION III
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GLEN ELLYN ILLINOIS Gol37 (312) 858 2660
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RO Inspection R=; ort No.
050-010/74-05 July 15, 1974 Transmittal Date
Distribution:
Distribution:
R0 Chief, FS&EB RO Chief, FS&EB RO:HQ (5)
, RO:HQ (4)
_DR Central Files L:D/D for Fuels & Materials
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Regulatory Standards (3)
DR Central Files Licensing (13)
RO Inquiry Report No.
Transmittal Date
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r Distribution:
Distribution:
RO Chief, FS&EB RO Chief, FS&EB RO:HQ (5)
RO:HQ
-
i DR Central Files DR Central Files Regulatory Standards (3)
RO Files Licensing (13)
RO Files C.
Incident Notification From:
(Licensee & Docke,t No. (or License No.)
Transmittal Date
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Distribution:
Distribution:
RO Chief, FS&EB RO Chief, FS&EB RO:HQ (4)
RO:HQ (4)
Licensing (4)
L:D/D for Fuels & Materials DR Central Files DR Central Files RO Files RO Files
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