IR 05000010/1977007
| ML19340A788 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/21/1977 |
| From: | Essig T, Fisher W, Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A785 | List: |
| References | |
| 50-010-77-07, 50-10-77-7, 50-237-77-07, 50-237-77-7, 50-249-77-07, NUDOCS 8009030828 | |
| Download: ML19340A788 (14) | |
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UNITED STATES NUCLEAR RFCULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
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REGION III
Report of Operational Radiation Protection Inspection IE Inspection Report No. 050-010/77-07 IE Inspection Report No. 050-237/77-07 IE Inspection Report No. 050-249/77-07 Licensee:
Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Dresden Nuclear Power Station Licenses No. DPR-2 L.its 1, 2 and 3 No. DPR-19 Morris, IL and No. DPR-25
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Category:
C Type of Licensee:
BWR 200 MWe - Unit 1 BWR 810 MWe - Units 2 and 3
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Type of Inspection:
Routine, Unannounced Dates of Inspection:
March 21-25, 28-30, and April 5 and 7, 1977 D'I 2//77 k~
M Principal Inspector:
T. H. Essig
'(Dale)
Accompanying Inspectors:
None Other Accompanying Personnel:
C.
E. Norclius l//l/[77
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Reviewed By:
W. L. Fisher, Chief Fuel Facility Projects and
(Date)
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Radiation Support Section d'
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SUMMARY OF FINDINCS
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Inspection Summary Operational Radiation Protection Inspection for Units 1,. 2, and 3 on March 21-25, March 28-30, and April 5 and 7, (Unit 1, 77-07),
(Unit 2, 77-07), and (Unit 3, 77-07):
Inspection included review of noncompliance, unresolved item, and commitment follow-ups, review of selected records and procedures related to the radiation protection program, observation of radiation protection work in progress, and independent measurements of radiation fields at selected locations.
Three items of noncompliance, concerning an inedequate evaluation of personal contamination, ft lure to submit termination exposure reports to the Commission, and failure to submit such reports to the individual, were identified for Units 1, 2, and 3.
Enforcement Items
,A.
Infrnetion Contrary to 10 CFR 20.201(b), an inadequate evaluation was made to determine compliance with 10 CFR 20.103 following a personal contamination occurrence on February 19, 1977, which was likely
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to have involved'an inhalation of airborne radioactive material.
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(Paragraph 8.b, Report Details)
B.
Deficiencies 1.
Contrary to 10 CFR 20.408, exposure reports for terminated individuals have not been furnished to the Commission.
(Para-graph 11, Report Details)
2.
Contrary to 10 CFR 20.409(b), exposure reports for terminated individuals have not been furnished to the individual.
(Para-graph 11, Report Details)
Licensee Action on Previously Identified Enforcement Items Calibration of neutron survey instruments, referenced in the enforcement item in the RIII letter of April 23, 1976, was completed on May 6, 1976.
However, this item had been lef t open, pending approval and implemen-tation of a procedure specifying calibration policy.
This procedure has been implemented as of this date.
(Paragraph 6, Report Details)
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- Calibration of the Unit 2/3 liquid radwaste monitor, referenced in en fo rcemen t item A. 3 of the RIII letter of July 8,1976, was completed.
(Paragraph 6, Report Details)
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Other Significant Items A.
Systems and Components None.
B.
Facility Items (Plans and Procedures)
Unresolved Item:
The licensee may not have adequately maintained a radiation exposure history for certain individuals as required by 10 CFR 20.101.
(Paragraph 7, Report Details)
C.
Managerial Items Radiation-Chemistry Department changes included the promotion of a health physicist to lead health physicist, promotion of a
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radiation-chemistry technician to radiation protection foreman, and the transfer of a radiation-chemistry technician to the Training Department.
(Paragraph 2, Report Details)
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D.
Deviations
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None.
E.
Status of Previously Reported Unresolved Items The licensee's bioassay program for contractors has been further defined to specify a quarterly whole body count.
This item, identified in IE Inspection Report No. 050-010/76-05, remains open pending implementation of the revised program.
(Para-graph 8.a. Report Details)
Management Interview The following items werc discussed on March 30, 1977 with Messrs.
Roberts. Adam, Simpson, Reardanz, and Nash, and subsequently by telephone on April 7, 1977 with Mr. Adam.
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Items of noncompliance related to an inadequate evaluation of
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-personal contamination (Paragraph 8.b, Report Details) and
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failure to report radiation exposures for terminated employees to the NRC and the individual (Paragraph ll, Report Details)
were' identified by the inspector.
B.
17ua need to incorporate the subject of risk of radiation exposure
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in radiation' protection training was discussed.
(Paragraph 4, Report-Details)
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The licensee agreed to include this subject in future training sessions.
r C.
Areas of procedures DRP 1240-9 and DRP 1910-1 needing clari-
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fication were identified by the inspector.
(Paragraph 5, Report Details)
The licensee agreed to revise the procedures within 60 days.
D.
The inspector stated that he had reviewed the licensee's corrective j
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actions relative to items of noncompliance previously identified for an uncalibrated neutron survey instrument and for an uncali-s j
brated liquid effluent monitor and had no further questions. (Para-
graph 6. Report Details)
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I E.
I t was p that _ the Unit 1 ARM recorders were still not printing
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legibly
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The licensee indicated that the problem was likely due to a worn
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printing head. The licensee further indicated that due to the j
age of the Unit 1 equipment, replacement parts may no longer be available, but '_ hey would look into the matter.
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F.
With respect to external dosimetry (Paragraph 7, Report Details):
1.
No overexposures were noted during 1976.
2.
A marked reduction from 3200 man-rems in 1975 to 1600 man-rems in 1976 was noted in the aggregate dose ~for the station.
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The film badge QA program appeared to indicate satisfactory j
performance by the contractor.
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4.
Exposure estimates for the badge period during which new,
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. incoming films were unknowingly given a significant X-ray i
exposure were reviewed.
The estimates appeared sufficiently
. conservative and no problems were noted.
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IE Inspection Report-No. 050-010/76-12.
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IE. Inspection-Report No. 050-010/76-26.
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G.
The inspector stated that he considered the manner in which NRC-4 forms were maintained for contractor personnel an unresolved item.
(Paragraph 7, Report Details)
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The licensee agreed to:
(1) continue the search for several missing NRC-4 forms and (2) determine the adequacy of the exist-ing arrangement for accounting for offsite time spent by " permanent" onsite contractor personnel.
H.
The licensee agreed to review the matter of termination exposure reporting for individuals transferring from Dresden to a CECO non-nuclear site.
(Paragraph 11, Report Details)
1.
With respect to internal dosimetry:
1.
The inspector noted that the personal contamination occurrence on February 19, 1977 clearly indicated a need for the licensee to develop a method to estimate airborne radioactivity exposures in terms of MPC-hrs from whole body counting data.
(Paragraph 8.b, Report Details)
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2.
A previously unresolved item related to contractor bioassay will remain open, pending implementation of a revised procedure which specifies a quarterly bioassay frequency, as well as a termination bioassay, for contractor personnel.
(Paragraph 8.a,
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Report Details)
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It was note'd that the licensee had covered some of the access holes in the shield wall between the control panel and the Unit 2/3 radwaste barrel filling station after the inspector had called the matter of ventilation backflow from the contaminated side to the clean side to the licensee's attention.
The inspector stated that efforts along these lines should be continued.
The licensee acknowledged the comment.
K.
The inspector noted that the licensee had fulfilled a commitment to install an ef fective drum decontamination facility in the Unit 2/3 radwaste basement.
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l REPORT DETAILS
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Persons Contacted
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B. Stephenson, Station Superintendent A. Roberts, Assistant Station Superintendent C. Sargent, Technical Staff Supervisor J. Nash, Resident Engineer (General Electric Company)
G. Reardanz, Quality Assurance Engineer D. Adam, Radiation-Chemistry Supervisor J. Parry, Lead Health Physicist D. Brozik, Health Physicist D. Simpson, Health Physicist D. O'Keefe, Radiation Protection Foreman J. Bowman, Radiation Protection Foreman G. Bergen, Lead Chemist D. Eggett, Chemist T. Schnieder, Chemist J. Testa, Radwaste Supervisor J. Skoryi, Radwaste Foreman
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B. Zank, Assistant Training Supervisor W. Rath, Engineering Assistant (Training)
G. Hast, Engineering Assistant (Radiation-Chemistry)
C. Lawton, Office Supervisor F. Lynch, Argonne National Laboratory
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R. Bruner, Argonne National Laboratory 2.
Radiation Protection Organization The following organizational changes have been recently made:
a.
One of the three health physicists was promoted to the newly created position of Lead Health Physicist, effective March 21, 1977. The selection process for an individual to fill the
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resulting vacancy is nearly complete.
b.
A radiation-chemistry technician was promoted to the position of Radiation Protection Foreman, filling a vacancy created by a transfer during December 1976.
This promotion restored the total number of foremen to three.
c.
A radiation-chemistry technician transferred to the Training Department as an engineering assistant, effective February 20, 1977.
(See also Paragraph 4)
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3.
Licensee - Conducted Audits ('
A review was made of the radiological aspects of onsite and of fsite
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audits conducted during 1976.
Onsite audits were conducted quarterly and offsite audits were conducted semiannually as required by Technical Specifications 6.1.G.l.b and 6.1.C respectively.
s, No significant problems were noted.
4.
Training The licensee's radiation protection training program is described in procedure DRP 1910-1, " Radiation Protection Orientation." The responsibility for conducting the training has recently been transferred from the Radiation-Chemistry Department to the Training Department. At about the same time, a radiation-chemistry tech-nician transferred to the Training Department as an engineering assistant to conduct this training program.
The inspector partici-pated in the first session conducted by the Training Department, and noted that the presentation was reasonably effective; however, it could have been enhanced by the use of additional visual aids.
It
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was also noted during the training session that the subject of risk associated with radiation exposure was not discussed; this item had bgyn noted previously as a shortcoming of the training pro-gram.-
The licensee appeared to have corrected this shortcoming by changing DRP 1910-1; however, this item appears to have become
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lost in the transition to the Training Department.
The licensee's respiratory protection equipment training program is described in procedure DRP 1920-1, " Regulation and Use of Radiological Respiratory Protective Equipment." This training is conducted by the Radiation-Chemistry Department.
No problems were noted during the review of this program.
Retraining in both of the above areas is conducted annually.
Lectures are contained on video tapes. No problems were noted in this area.
A special retraining program was begun February 27, 1977 for radiation-chemistry technicians. This program, which includes a fairly detailed review of radiation protection fundamentals (e.g.,
biological effects of radiation exposure), lasts for one week, but will take about two months to complete because of the limited number of individuals that can be spared during any given week.
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IE Inspection Report No. 050-010/76-05.
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5.
Radiation Protection Procedures
The inspector reviewed the following newly added or revised pro-
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cedures related to radiation protection:
Procedure No.
(DRP - )
Rev. No.
Date Title 1240-6
11/76 Periods of Calibration of Radiation Protection Survey Instruments 1240-8
8/76 Calibration and Operation of the Model 6112 B Teletector 1240-9
1/77 Calibration Check for the Eberline PNR-4 Neutron Detection Instrument 1250-2
8/76 Film Badge Spiking 1280-1
10/76 Blue Diamond Surveys
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1280-2
2/77 Radiation Surveys of Spent Fuel Shipping Cask
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1350-14
1/77 Operation of the RADeCo Air Sampler
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1350-15
3/77 Operation of the Unit 1 Offgas Filter Building Air Sampling }bnifold System 1480-2
12/76 Arrival Survey of Spent Fuel Shipping Casks 1530-1
12/76 Receipt, Inventory and Leak Testing of Radioactive Sources 1910-1
2/77 Radiation Protection Orientation 1920-1
2/77 Regulation and Use of Radiological Respiratory Protective Equipment The only problems noted were found during the review of DRP 1240-9 and DRP 1910-1.
Procedure 1240-9 should have contained a statement regarding its implementation - either by putting such a statement in the procedure or by reference from another procedure.
Procedure 1910-1 made reference to identifying " pregnant women" in tne training class for the purpose of supplemental instructions con-cerning prenatal radiation exposure (Regulatory Guide 8.13).
The inspector pointed out that all women (a t least those of child bearing age) should be g'.ven such instruction, not just those who are obviously pregne.nt.
The licensee indicated that both procedures would be clarified.
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6.
Instruments and Equipment The licensee appeared to have an adequate number of instruments on
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hand for performing area and personal contamination surveys; for performing exposure and dose equivalent rate measurements; and for collecting air samples on an intermittent and continuous basis.
All operable portable survey instruments were noted to possess a current calibration sticker.
The licensee is continuing to calibrate all monitoring instrumen-tation onsite, except for neutron survey instruments (calibrated at one of the licensee's other facilities).
Portable survey instru-ments are calibrated quarterly. Hand and shoe counters and portal monitors are calibrated (background and source response checks)
daily. Semi-portabic (AC powered) G-M counters are presently not being calibrated; however, the licensee is formulating a cali-bration program (expected to be operable within approximately one month).
Corrective action taken by the licensee ip response to a neutroa
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survey instrument calibration infraction 1 was reviewed and found to be adequate. Procedure DRP 1240-6 (Paragraph 5) was revised to focus mora attention on the existing calibration requirements.
The revised calibration program includes affixing a calibration sticker which specifies the calibration date and the statement
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"Do Not Use After
." Instruments due to be cali-brated are labelled with an instrument repair tag and the notation
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"To Be Calibrated."
Correctiveactiontakenbythelicenseefnresponsetoaliquid radwaste monitor calibration inf raction5 was reviewed and found to be adequate. The monitor in question is an off-line type which was to replace an origina'.-equipment, on-line monitor which appeared to be insensitive to nornal discharges. The calibration program for the new monitor consisted of determining the monitor response to Co-57, Co-60, and Cs-137 solutions (about 3E-4 pCi/ml) in the detection chamber and then correlating these responses to that obtained f rom the same nuclides contained in small vials (activity ranging from 3E-4 to 3 pC1).
Calibration factors of 3.0 and 6.1 counts /sec per nCi/1 were obtained for Cs-137 and Co-60, respec-tively.
The licensee contractor who performed most of the above calibration work is also developing an ultrasonic transducer which will hopefully prevent the deposition and buildup of activity on the wall of the detection chamber - a problem which is common to most liquid activity monitors.
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IE Inspection Report No. 050-010/76-95.
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IE Inspection Re ort No. 050-010/76-12.
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External Exposure Control (
The licensee's program for measurement and control of external
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exposure utilizes biweekly film badges, pocket dosimeters (read daily), and time-keeping.
Film badge records for 1976 were reviewed; no doses in excess of the 10 CFR 20.101 limits were noted. The aggregate station dose (including contractors) for 1976 was 1600 man-rens, about the same as experienced in 1974 and half of the 1975 total.
A spot check of NRC-4's for twenty contractor personnel who received more than 2 rems during at least one quarter of 1976 revea?.ed two related problem areas:
Tae licensee could not locate NRC-4's for three individuals, a.
but was sure that such forms had been completed because the individuals had received radiation protection training. (A Form-4 is completed for everyone at that time.)
b.
The system for maintaining current NRC-4's for " permanent"
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onsite contractors consists of an informal arrangement in which the contractor foremen inform the licensee when par-ticular individuals have worked at sites other than Dresden.
This arrangement does not appear to provide an adequate
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accounting of a given individur s offsite time.
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These areas are considered unresolved.
The licensee conducts a QA audit of his film badge contractor in accordance with procedure DRP 1250-2, " Film Badge Spiking." During each badge period, five pairs of film badges are exposed to a Cs-137 source, with doses ranging from 150 to 2400 mrads. One pair of film badges is exposed to a natural uranium slab source for about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (220 mrads). The inspector performed a statistical analysis
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of the data and determined the mean and standard deviation of the ratio of measured to calculated film badge doses.
The mean ratio was 1.02, with a two sigma error of 24%, indicating adescate per-formance by the contractor.
A special evaluation was performed by the licensee to determine personal exposures during the two-week badge period ending March 6, 1977. A package of new films from the contractor was unknowingly given a high exposure by an X-ray package screening device being tested by the licensee. The X-ray unit was being operated at the time for testing purposes without the benefit of an internal iron filter.
(Removal of this filter increased the exposure rate frcm about 1 mR/sec to 200-400 mR/sec).
Fortunately, only the cmr,oyce
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films were irradiated. Film badge results for the period reported
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by the contractor ranged f rom 50 to 4700 mrads, depending on the position of the film within the package. The licensee's evaluation
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utilized pocket dosimeter results and time-keeping for exposure estimates. Where this was not possible (e.g., eight ' nd ividuals had off-scale dosimeters for one or more days), the licensee per-formed a detailed evaluatica of tha individual's work locations and used co-workers' dosimeters for the required estimate.
The analysis appeared sufficiently conservative and no significant concerns were identified with the licensee's evaluation.
8.
Internal Exposure Control a.
Bioassay Records of approximately 990 whcle body counts performed between March 1976 and March 1977 were reviewed.
The f requency of observed radionuclides was Co-58 (4%), Co-60 (80%), Cs-134 (4 3%) and Cs-137 (100%).
Iodine-131 was detected very infrequently (<1%).
Cobalt-60 continues to be
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the limiting radionuclide in terms of percent of applicable limits. The maximum Co-60 burden was 440 nCi (40% of the permissible lung burden); however, the individual was recounted the following day and the apparent lung burden had decreased to 45 nC1.
(Cs-134 and Cs-137 burdens also decreased by a
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factor of 10.)
Low-level external contamination was suspected to be the cause of this anomaly.
The number of whole body counts conducted during the year ending March 1977 represents approximately a 40% increase over the year ending March 1976. While this trend in whole body countin appears to be in the right direction, the matter of bioassay for " permanent" contractors is still considered an unresolved item.
For example, during 1976 a selection of twenty contractor personnel representing 52 man-quarters of onsite time were given only seven whole body counts. The licensee indicated that an increased effort is being made during 1977 to count appropriate contractor indi-viduals quarterly.
The inspector reviewed the results of approximately 330 urinalyses performed during the year ending March 1977.
No anomalies were noted in the data, d*
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b.
Personal Contamination - February 19, 1977 i
On February 19, 1977, an it dividual became contaminated while
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performing operations at the Unit 2/3 radwaste barreling area Several articles control board and in the barrel storage area.
of clothing were contaminated (up to 20,000 cpm, G-M measurement),
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as well as the individual's buttocks, neck, head, and hands (up to about 2000 cpm).
Nasal contamination was apparently detected (1500 cpm) based on a nose blow, but this could have been due, at least in part, to contamination of the hankerchief by the individual's hands. The individual was successfully decontaminated znd was sent home.
No following evaluation was apparently done. Protective clothing and respiratory protection were not worn by the individual, but were normally not required for the areas where he was working.
Because of the evidence suggesting that this individual may have been exposed to a significant airborne radioactivity concentration, the licensee should have determined (e.g., by whole body count) whether the exposure was within the limits and controls contained in 10 CFR 20.103.
Since the expcsure
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was not evaluated, the licensee did not noncomply with 10 CPR 20.201(b).
A whole body count was performed, however, on March 24, 1977, and a calculation performed by the inspector
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showed that the erposure was within the 10 CFR 20.103 control measure. The inspector pointed out that this exposure emphasized
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the need for the licensee to be able to evaluate whole body counting data in terms of MPC-hrs (as opposed to % MFBB),
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particularly for acute exposures.
The source of the contamination could not be definitely identified. In the case of the apparent nasal contami-nation, it is suspecteu that the source was associated with
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a number of penetrations in the barrel filling station shield wall which are thought to permit ventilation air to flow from the contaminated area to the control panel side (clean) when a ventilation system upset (such as opening an outside door)
occurs.
c.
Respiratory Protection Program The licensee's program for using respiratory protective equip-ment is i as inspection report. pssentially as described in a prev cThe program appeared to
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9.
Posting, Labeling, acd Control
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l Posting and labeling requirements were reviewed against the require-ments of 10 CFR 19.11 and 20.203.
No problems were noted.
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IE Inspection Report No. 050-249/76-21.
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liigh radiation area controls were reviewed; no instances of non-
compliance were noted. This appears to represent an improvem
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anareawhichpreviouslyhasresultedinseveralinfractions.725/h710/
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liigh radiation' arca controls were also recently (December 1976)
reviewed.by the licensee in response to IE Circular. No. 76-03.
A total for the station of approximately 150 high radiation area
- entrances (either locked' doors, gates, or other similar barricades)
were identified. No problems were noted with posting.
The licen-i see's existing radiation protection training and retraining programs j
were found to be adequate with respect _to high radiation areas.
- Additional retraining efforts specific to this area have been
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precipitated as a result of the infractions mentioned above.
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Surveys
- Selected exposure rate and contamination survey records for the l
period April 1976 through March 1977 were reviewed.
Surveillance l
appeared adequate both in terms of frequency and depth of the
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survey. Air particulate samples are generally either collected
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with CAMS (Unit 2 and 3 drywells, Unit 2/3 refueling floor, Unit 1 i
529' elevation) or with high flow rate (30-40 cfm) air movers
(grab samples).
Radioiodine concentrations are determined
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. routinely for the CAMS mentioned previously as well as on an as-needed basis with low flow rate samplers. 'No significant problems
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were noted with these data.
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The inspect'or also reviewed the licensee's records related to leal
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testing and inventory of sealed sources.
The licensee has 20 sources of Co-60, Sr-90, and Cs-137 having activity levels in
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excess of 100 uCi.
The largest source, which contains 11.8 Ci of Cs-137, is used in conjunction with 2.0 and 7.0 Ci sources for
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instrument calibrations. No problems were noted with the semi-
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annual leak tests, quarterly inventories, or possession limits.
11.
Notification and' Reports
- A review of termination exposure reports indicated that the licensee j
had not been submitting such reports to the NRC and to the
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IE Inspection Report No. 050-237/75-25.
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IE Inspection. Report No. 050-237/76-05.
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- IE Inspection Report No. 050-237/76-25.
10/ IE Inspection Report No. 050-237/76-27.
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individual for persons terminating during April, May, July, August, and September 1976, and February 1977, as required by 10 CFR 20.408 and 20.409.
Dresden personnel believed that such reports were
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being generated at corporate headquarters, but this was found not to be the case. Termination reports for individuals transferring to other facilities operated by the licensee (e.g., a coal-fired
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station) do not appear to be required by 10 CFR 20.408 and 10 CFR 20.409; however, an adequate basis exists for generating them:
(1) the mechanism for producing such reports already exists, (')
the chance of missing a report due to the long period of time (e.g., 20 years) af ter the individual's 1ast work assigarent at
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the nuclear station would be minimized; and (3) the report is of more use to the individual if received in a timely manner af ter the individual's nuclear work assingment.
12.
Inspection of Facilities The inspector made several tours of the plant to observe radio-logical conditions and ongoing radiation protection work.
Licensee-furnished portable survey instruments were used to independently
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verify radiation levels.
No significant discrepancies were noted.
Preparation work for inspection of the Unit 1 fuel transfer dolly was observed. The fuel transfer pool water level had been lowered
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from 40 feet to 11 feet.
Pool walls had been decontaminated and
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the licensee was in the process of removing highly radioactive
crud (containing an estimated 20-3G Ci of activity) from the bottom of the pool. The crud was going to be removed by placing the suction line from an underwater pump on the pool bottom and utilizing the pump's cartridge filters.
The licensee had planned to use a pre-filter, but the pump did not work adequately with the pre-filter in place. The first cleanup run lasting about 10 minutes) was accomplished on March 30, 1977.
The radiation level adjacent to the filter cartridge was about 30 R/hr.
The licensee appeared to have adequately prepared to cope with the radiation levels encountered.
Surveys also appeared adequate.
The filters were to be disposed as solid waste.
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