IR 05000010/1976008
| ML19340A809 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/04/1976 |
| From: | Gibson G, Oestmann M, Pagliaro J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A806 | List: |
| References | |
| 50-010-76-08, 50-10-76-8, 50-237-76-08, 50-237-76-8, 50-249-76-08, NUDOCS 8009040634 | |
| Download: ML19340A809 (10) | |
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UNITED STATES NUCLEAR REGULATORY COMMTSSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report of Operational Environmental Program Inspection IE Inspection Report No. 050-010/76-08 IE Inspection Report No. 050-237/76-08 IE Inspection Report No. 050-249/76-08 Licensee: Commonwealth Edison Company P.O. Box 767 Chicago, Illinois 60690 Dresden Nuclear Power Station Licenses No. DPR-2 Units 1, 2 and 3 No. DPR-19 Morris, Illinois and No. DPR-25 Category:
C Type of License _.
BWR (GE) Unit 1 - 700 MWt Unit 2 - 2527 MWt
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Unit 3 - 2527 MWt Type of Inspection:
Routine, Unannounced
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Dates of Inspection: May 5-6, 10-11 and 18, 1976 (F. _ - -
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Principal Inspector:
M.
. Oestmann
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Accompanying Inspector:
G. T. Gibson b '3' 7 b (Date)
Other Accompanying Personnel: None s
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Reviewed By: iJ. A. Pagliaro, Chief
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Environmental and Special (Date)
Projects Section
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SUMMARY OF FINDINGS Inspection Summary
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Unannounced routine operational environmental program inspection conducted on May 5 -6, May 10-11, and May 18, (76-08, Unit 1; 76-08, Unit 2; and 76-08, Unit 3): Reviewed environmental program cenduct and mana;cment; examined ptogtam tusults; discussed and reviewed programs for quality control in sample collection and laboratory analysis; reviewed status of preparation of Appendix B Technical Specifications; reviewed the meteorological monituring program;angjollowedupitemsfromthepreviousenvironmental f
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Enforcement Item Deficiency Contrary to Appendix A, Technical Specification 6.6.C.2.a. (10),
the licensee did not provide any explanation in the July-December, 1975 Semi-Annual Report of the unusual results reported for the onsite thermoluminescent dosimetry (TLD) station No. 2.
(Paragraph 5.a.(3), Report Details)
Licensee Action on Previously Identified Enforcement Items
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No previously identified enforcement items within the scope of this inspection.
Other Significant Items A.
Systems and Components The licensee plans to display meteorological data taken from the 400-foot meteorological tower on recording instrumentation in the plant control room in the near future.
(Paragraph 5.c, Report Details)
B.
Facility Items (Plans and Procedures)
The licensee plans to submit a revised proposed Appendix B Technical Specifications to the Office of Nuclear Reactor Regulation by June, 1976. (Paragraphs 2 and 5.b, Report Details)
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IE Inspection Rpts No. 050-010/75-08, No. 050-237/75-13, and No. 050-249/75-11.
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Managerial Items
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None.
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Noncompliance Identified and Corrected by Licensee None.
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Deviations None.
F.
Status of Previously Reported Unresolved Items No previously reported unresolved items within the scope of this inspection.
Management In te rview A.
A management interview was held with the following licensee personnel on May 11, 1976.
B. B. Stephenson, Station Superintendent, Dresden J. Abel, Administrative Assistant to Station Superintendent, Dresden
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D. Adam, Radiation Chemistry Supervisor, Dresden D. Simpson, Radiation Protection Engineer, Dresden F. Wi'_leford, Quality Assurance Engineer, Commonwealth Edison Coupany Headquarters B.
The following items were discussed with the licensee representa-tives.
1.
The NRC inspector discussed the scope and intent of this inspection.
(Paragraph 2, Report Details)
2.
The inspector noted that there was no major change in management controls for the environmen program since the previous inspection.gpl protection (Paragraph 3, Report Details)
3.
The inspector reviewed the results of the radiological environmental program, including discussion of observations of various monitoring stations.
(Paragraph 5.a, Report Details)
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The' status of the proposed Appendix B Technical Specifications was discussed.
(Paragraph 5.b, Report Details)
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The inspector noted the review of the quality assurance and* quality control of sample collection and radioanalysis of various environri.cntal media.
(Paragraph 4, Report Details)
6.
The installation of recording instrumentation from the 400-foot meteorological tower into the plant control room was discussed.
(Partgraph 5.c, Report Details)
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REPORT Et ' AILS
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Persons Contacted
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The following persons, in addition to those identified under the Management Interview section of this report, were contacted during the inspection.
R. Pavlick, Staff Assistant on Radiation Protection and Environmental Programs, Production Systems Analysis Dep'rtment, Commonwealth Edison Company (CECO) Headquarters J. Golden', Staff Radioecologist and Administrator for Radiological Environmental Monitoring Programs, Prrduction Systems Analysis Department, CECO Headquarters P. Hayes, Radiochemist, Production Systems Analysi, Department, CECO Headquarters D. Scott, Director of Quality Assurance (Operatiot.s), CECO Headquarters J. McCluskey, Director, Environmental Affairs Department, CECO Headquarters A. Courtney, Assistant to the Director of the Environmental Affairs Department, CECO Headqu,rters B. Barichman. Director of Biology Programs, Environmental Affairs Department, CECO Headquarters H. Bernhard, Staff Biologist, Environ.' ental I.ffairs Department,
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CECO Headquarters S. Walters, Staff Biologist, Environmental Affairs Department, CCCo Headquarters T. Hiebert, Staff Biologist, Environmental Affairs Department, CECO Headquarters L. Duchek, Staff Assistant, Dresden R. Monzingo, Staff Assistant, CECO Headquarters G.
Bergan, Plant Chemist, Dresden 2.
General This environmental program inspection consisted of examination of the licensee's radiological and non-radiological monitoring programs, including sampling techniques and procedures, measurement equipment, operability and location of monitoring equipment, examination of the intake and discharge structure systems, and program results. Management control aspects, including organizational structure, assignments of responsibilities and authorities, provisions for audits, and criteria -ad-5-
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instructions for conduct of program activities, were reviewed and discussed with the licensee. The licensee's Technical
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Specifications, Appendix A, were utilized as the primary
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inspection criteria.
Although the licensee has conducted a non-radiological monitoring program since 1968, the Technical Specifications do not contain non-radiological tequirements. The licensee plans to submit revised proposed Appendix B Technical Specifications to the Office of Nuclear Reactor Regulation by June, 1976.
Such specifications are expected to be finalized later this year. The non-radiological portion of the environmental monitoring program will be examined subsequent to the issuance of the Appendix B Technical Specifications.
3.
Management Controls The licensee's administrative and procedural controls for implementation of the environmental monitoring and mett rological programs were examined. This examination included a review of assignments, responsibilities and authorities for program environmentalprograminspectiongyncethetimeoftheprevious management and implementation.
, the licensee has maintained the same management and audit functions relating to the conduct of the radiological environmental anc meteorological
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monitoring programs. However, the licensee has established an independent Quality Assurance Department which has prepared a Quality Assurance Program for Nuclear Generating Stations.
This program has been reviewed, evaluated and approved by NRC on December 29, 1975.
The inspector reviewed records of audits of the radiological environmental monitoring program conducted by the Onsite and Offsite Audit Function Boards in accordance with Technical Specifications, Section 6.1.
The results of the February 24-28, March 7, and September 22-26, 1975, audits conducted by the Offsite Audit Function Board were examined.
The Onsite Audit Function Board carried out audits on June 19, and December 16, 1975. The audita reviewed sampling frequency and missed samples, reporting requirements of measurement and analytical procedures, and requirements of specific NRC tegulatory guides which have been included in the Technical Specificat ions. The audits have been performed in accordance with the Technical Specifications.
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Informal auditing of contracto'r activities has been carried out by the Administrator for Environmental Monitoring Programs
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in the case of the radiological environmental monitoring and meteorological programs. A licensee represamtative reported
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that the audit functions and responnioilities for the contractors'
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activities are beine transferred to the corporate Quality Assurance Department.
Independent audits of the environmental programs are scheduled to be carried out by this department later this year.
In addition, the licensee's contractors carry out their own internal audits to assure compliance with contract requirements. The reports of these audits will be reviewed during a subsequent inspection.
4.
Quality-Control of Analytical Measurements The inspector examined documentation developed by the licensee's contractors to implement the environmental and meteorological monitoring programs.
The Administrator for Environmental Monitoring Programs has approved the Field Sampling and Analytical Pcocedures documents and the Quality Assurance Manual submitted by Eberline Instrument Corporation to carry out the radiological environmental monitoring program. A summary of the analytical procedures used to determine the radiation levels in environmental samples was presented in the semi-annual report on radioactive
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effluents for the January-June 1975 period.
'he licensee utilizes a 6-month schedule to assure samples re collected in accordance with the frequency established in Table 4.8.1 of the Technical Specifications.
Documentation of field and office procedures for the meteorological data aquisition, reduction and reporting was also examined.
Implementing procedures for equipment servicing, calibration, and checking the operability of meteorolgical instrumentation have been developed by the meteorological monitoring contractor and approved by the licensee. A licensee representative stated that procedures for audit of the meteorological program have yet to be prepared. This item will be examined during a subsequent inspection.
The licensee possesses a quality control manual of the contractor responsible for carrying out the non-radiological environmental monitoring program. This document will be examined during a subsequent inspection, when the conduct of this program has been incorporated into the Appendix B Technical Specifications.
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Implementation of the Environmental Monitoring Program
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Radiological Environmental Monitoring Program
Only the radiological program is addressed in the current Technical Specifications. The results of the licensee's radiological program for calendar year 1975 were examined for compliance with the me-itoring and reporting requirements in the Technical Specx ications.
The installation and operability of selected radiological environmental stations at specified locations were also examined.
(1) Environmental Monitoring Reports The inspector reviewed selected monitoring results in the semi-annual reports on radioactive effluents against the monitoring requirements established in Table 4.8.1 of the Appendix A Technical Specifications.
No monitoring omissions or deviations were noted for the period of inspection. The inspector examined an operating procedure which documents each sample collection and specific environmental and operating conditions of the monitoring equipment and idenuifies missed samples, including the reasons for missing i
samples. Such information is provided in the semi-
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annual reports. Special sampling and analyses performed during accidental releases of radioactivity from the plants and the corrective action taken were found to be reported to NRC in a timely manner and also described in the semi-annual reports.
(2) Air Monitoring Stations Selected radiological air sampling stations were examined ano found to be operable and located as specified in steel-walled shelters. Meters were in operation to indicate air flow through the particulate filter and the charcoal adsorber.
The licensee reported that the contractor services the monitoring equipment and checks on a weekly basis that the equipment is operable.
(3) TLD Monitoring The lithium fluoride (LiF) TLD gamma radiation monitoring system was reviewed and selective sites
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were examined. The inspector noted that the, plastic
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vial containing the TLD included a 300 mg/cm'
aluminum shield.
In addition the TLD material was
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placed inside the air sampler shelter.
Since this shelter is constructed of steel, placement inside the shelter housing provides additional shielding of effluent gamma radiation.
Specifically this shielding would preclude monitoring of gemma radiation with an energy of less than 100 Kev (Xe-133).
After discussions with licensee ps sonnel concerning the shielding of the TLD material, the licensee removed the aluminum shields and placed the TLDs outside the shelter.
The inspector reviewed results of the TLD program for July-December 1075 as presented in the semi-annual report. Tha inspector noted the results for onsite TLD station No. 2 were significantly higher than the remaining two onsite locations. Contrary to Appendix A, Technical Specification 6.6.C.2.a. (10),
the licensee did not provide any explanation in the July-December semi-annual report of the unusual results reported for TLD station No.
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This failure constitutes an item of noncompliance with the referenced Technical Specification.
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Non-Radiological Environmental Monitoring Program The results of the licensee's non-radiological environmental monitoring programs for 1973 were selectively examined.
The non-radiological program includes thermal plume survey, water chemistry and bacteriology, phytoplankton, zooplankton, periphyton, benthos and fish studies.
This program has been conducted since 1968 and is described in the licensee's responses to staff questions on the Environmental Report, dated October 17, 1972. The licensee will submit a modified non-radiological monitoring program in the revised proposed Appendix B Technical Specifications by June 1976. This program including non-radiological effluent limits will be examined during a subsequent inspection, once the Appendix B, Technical Specifications have been finalized and approved.
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Meteorological Monitoring Program The inspector noted that the meteorological monitoring
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results during 1975, showed a data recovery overall of
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96.47%. The licensee reported that the contractor has been able to improve data recovery by improvements since the previous year in equipment maintenance and. servicing.
The contractor carries out weekly checks of all equipment and instruments and bimonthly calibrations.
Replacement parts are available in case the equipment is not operable. A licensee representative stated that
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remote recording instrumentation from the 400-foot meteorological tower will be installed in the plant control room.
The inspector also reviewed the semi-annual meteorological reports from the contractor and found that this contractor carries out all dose calculations for the licensee, the results of which are presented 'n the semi-annual reports on radioactive effluents sub2itted to the NRC.
The inspector also noted that all recceding instrumentation from the 400-foot meteorological tower during a tour of the meteorological facility was in good order.
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