IR 05000010/1977010

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IE Insp Repts 50-010/77-10,50-237/77-11 & 50-249/77-11 on 770420-22,25,27-29,0506 & 13.Noncompliance Noted:Gaseous Release in Excess of Limit & Failure to Rept Release within 24 Hours
ML19340A780
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 05/26/1977
From: Borst W, Essig T, Fisher W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19340A778 List:
References
50-010-77-10, 50-10-77-10, 50-237-77-11, 50-249-77-11, NUDOCS 8009030823
Download: ML19340A780 (8)


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U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AFD ENFORCEMENT i

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REGION III

Report No. 50-010/77-10; 50-237/77-11; 50-249/77-11 Docket No.50-010; 50-237; 50-249 License No. DPR-2; 19 ; 25

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Licensee: Commonwealth Edison Company

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P.O. Box 767 Chicago, IL 60690 Facility Name: Dresden Units 1, 2, and 3

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Inspection At: Dresden Site, Morris, IL

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' Inspection Conducted: April 20-22, 25, and 27-29, and May 6 and 13, 1977

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T. H. Essig

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N F. J. Borst (date signed)

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W. L. Fisher

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Approved by: W. L. Fisher, Chief d2 7 /~7'7 Fuel Facility Projects and (date signed)

Radiation Support Section

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Inspection Summary Inspection on April 20-22, 25, and 27-29, and May 6 and 13, 1977 (Report No. 50-010/77-10; 50-237/77-11; 50-249/77-11)

_ Areas Inspected: Routine, unannounced inspection of radioactive vaste systems, including : effluent releases; records and reports of effluents ;

effluent control instrumentation; procedures for controlling releases; containment air-cleaning systems ; reactor coolant water quality; solid radioactive waste; licensee event reports ; and licensee action on previously identified enforcement items and commitments. Ihe inspection involved 96 inspector-hours on site by three NRC inspectors.

Results: Of the nine areas inspected, no apparent items of noncompliance or deviations were identified in six areas; three apparent items of non-compliance (infractions) were identified in three areas (gaseous release in excess of limit - Paragraph 3; failure to report release in excess of

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limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of occurrence --Paragraph 6; and failure to perform required monthly operation of SGTS - Paragraph 7).

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DETAILS m

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1.

Persons Contacted

  • Mr. B. Stephenson, Plant Superintendent
    • Mr. A. Roberts, Assistant Plant Superintendent Mr. J. Kolanowski, Operating Engineer, Unit 2
      • Mr. D. Adam, Radiation-Chemistry Supervisor, Tech Staff
    • Mr..J. Parry, Lead Health Physicist, Tech Staff
  • Mr. G. Bergan, Lead Chemist, Tech Staff Ms. L. Scot t, Chemis t, Tech S taf f Mr. G. Romba, Engineer, Tech Staff Mr.

T. Testa, Radwaste Planner Mr. J. Skoryi, Radwaste Foreman Mr. D. Sharper, Radwaste Foreman

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      • Mr.

B. Shelton, Administrative Assistant

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The inspector also had minor contacts with several other licensee employees, including cembers of the Technical Staff and the Operating and Maintainence Engineers' staffs. The individuals noted above (* and **), three other members of the Technical Staff, and one member of the Quality Assurance Department were present during the exit interviews on April 27 and May 13, respectively.

(Attendance at both interviews denoted by ***).

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Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-10/76-12; 50-237/76-15; 50-249/76-13):

Failure to calibrate the Unit 2/3 chimney monitor. The chimney monitor was calibrated during the first quarter of 1977 using a new, improved technique. The new technique involves isolating the moni-tor, injacting a concentrated noble gas sample, recirculating the gas,

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noting the monitor response,'and collecting a sample of recirculated gas for quantitative analysis. The calibration curve appeared slightly nonlinear, however, and probably should have been investi-gated further (additional data points). This item was discussed at the exit interview.

3.

' Radioactive Fffluent Releases a.

Gaseous Releases Records of gaseous effluent releases from Units 2 and 3 for the period June 1976 through March 1977 were reviewed.

Release rates are determined by collection and analyses of:

(1) daily grab samples of noble gases collected from the outlet-2-

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of the Unit 2 and 3 augmented offges systems (charcoal beds);

(2) daily cumulative samples of iodine and particulates (half-life greater than 8 days) from the Unit 2/3 chimney; and (3)

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twice-weekly cumulative samples of iodine and particulates from the Unit 2/3 Reactor Building Vent. No items of non-compliance were identified.

Records of gaseous effluent releares from Unit I were reviewed in detail during the last radwaste management inspection;_1./

however, recent iodine and particulate releases required special review at this time. During the periods April 1 at 1325 to April 4 at 1340 and April 9 at 1345 to April 22 at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, the iodine plus particulate (half-life > 8 days)

release rates exceeded 0.48 pCi/sec during a 48-hour period, a point at which the licensee is required to report the release to the NRC as a reportable occurrgnce. During the period April 15 at 0930 to April 16 at 1400, the release rate of iodine

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and particulates (half-life > 8 days) for the station was about 120% of the Technical Specification limit (T.S. 3.8.A.2.b).

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The elevated releases during the first portion of the month were attributed by the licensee to changes in Unit I reactor power level, while the latter (including the release in excess of Technical Specifications) were attributed to steam leaks in a reactor water cleanup loop and primary-to-secondary leakage in the "D" secondary steam generator for Unit 1.

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b.

Liquid Releases Records of liquid redwaste releases from Units 2 and 3 were reviewed for the period June 1976 through March 1977. The review included selective examination of discharge permits, valve lineup sheets, and tank level records. Units 2 and 3 have been operating as a "zero release" facility since December 14, 1976, the date of the last discharge. The "zero release" mode of opgion, initially necessitated by a frozen discharge line appar r.itly was found to be routinely achievable.

r-The only discharge presently being made from the station is the Unit I laundry waste. No items of noncompliance were identified.

4.

' Records and Reports of Effluents Effluent releases reported in the licensee's reports for January-June and July-December 1976 f or Units 2 and 3 were reviewed.

Selected comparisons were made between the data in these reports 1/

IE Inspection Report No. 050-010/76-26.

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Ltr, Stephenson to Keppler, dtd 2/10/77.

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Ltr, Stephenson to Keppler, dtd 3/7/77.

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h and those contained in the licensee's discharge records.

Seven apparent errors (two of which were related to solid radwaste)

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i were noted in the reports by the inspectors. These errors, as

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.well as the report review process, were discussed at the exit interview.

15.

' Effluent Control Instrumentation

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Ideensee records of calibrations and functional tests were examined for the period June 1976 through March 1977. Electronic and radio-nuclide calibrations were performed quarterly. Problems related to calibration of the Unit 2/3 chimney monitor and the Unit 2/3 liquid radwaste monitor, which had resulted in two infractions b/

r appear to have been satisfactorily resolved (paragraph 2 of this report and paragraph 6 of a previous inspection report,5/ respec-tively). No new items of noncompliancs.were identified.

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6.

' Procedures for Controlling Effluent Releases

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The inspectors reviewed new and revised procedures (through March 1977) related to radwaste management. Except as noted belew, no problems related to procedure inadequacy were found.

The release from the station on April 15-16 in excess of the Techni-cal Specifications limit (paragraph 3.a) resulted in a review by

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the inspectors of Procedure DCP 1400-6, which is used to quantify radiciodine and particulate releases.

It was noted that the proce-dure specified only a 7-day decay count for both radioiodine and

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we particulates. A one-week delay was determined by the inspectors to be inadequate, because it did not permit the licenses to undertake timely corrective action to reduce release rates of radioiodine and

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particulates to a level in compliance with Technical Specification 3.8.A.

Nor did it permit the licensee to report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (of the event) that an LCO had been exceeded.

(The licensee learned on April 22 that Technical Specification 3.8.A.2.b. had been exceeded on April 15-16.) This was discussed at the exit interview.

7.

Containment Air-Cleaning Systems Records of particulate (DOP) and halide (Freon) penetration tests of the standby gas treatment system (SGTS) were reviewed for the period June 1976 through March 1977. Penetration tests were per-formed on the HEPA and charcoal filters on September 4 and September 7, 1976, respectively. Collection efficiency tests for methyl iodide were performed on SGTS test cartridges on June 22, 1976. No items of noncompliance were noted regarding these tests.

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IE Inspection Report No. 050-237/76-15, 5/

IE Inspection Report No. 050-237/77-07.

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i A change 'in Technical Specification 4.7.B.1, which became ef fective December 31, 1976, requires that SGTS fans and heaters be operated

10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month at rated power to remove any accumulated mois-ture from the charcoal. The licensee performed the required

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operation ot; January 31, 1977, but failed to do so during February and March, because this test hati not been entered in the comput-erized surveillance schedule. After the requirements were entered in the surveillance schedule on April 20, the required test was performed on April 27, 1977.

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Monitoring of Radioactivity in Reactor Coolant Reactor coolant surveillance for Units 2 and 3 was reviewed for the

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period June 1976 through March 1977. Radioiodine concentrations were noted to be < 0.01% of the Technical Specification 3.6.C.1 limit of 20 pC1/ml. No items of noncompliance were noted.

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9.

' Solid Radioactive Wastes

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Solid radwaste shipment records for the periods June through December 1976 and March 1977 were reviewed. The licensee divides all solid radwaste into two types:

(1) solidified - includes spent resins,

evaporator bottoms, and similar wastas which are mixed with concrete; and (2) dry active waste (DAW) - includes filters, paper, rags, etc. The quantity of radioactivity shipped per month has shown a marked increase:

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Solidified Waste DAW

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3 m /mo.

Ci/mo, m /mo.

Period Ci/mo, Jan-June 76

248 3.6 265

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July-Dec 76 620 117 1.9 548 March 77 1500

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This ine ease is attributed by the licensee to a special effort which involved emptying and solidifying the contents of the Unit 2/3 15,000 gallon spent resin tank, a tank which, according to the licensee, had not been empty since plant startup.

Solidified wastes are categorized as Transport Group III (10 CFR 71)

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by the licensee, based on a gamma spectral analysis of a resin sample.

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This analysis showed that essentially all of the gamma activity was due to Co-60 (38%), Cs-134 (21%) and Cs-137 (41%). Although the presence of only these nuclides would classify the solidified waste shipment as Transport Group III, analyses for Sr-90 (a beta emitter and one of the Group II radionuclides most likely to be present) need to be performed to confirm the present classification of ti.ese wastes.

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The inspectors also examined methods used by the licensee to quantify

radioactivity contained in solidified spent resins before their ship-ment to a licensed disposal site. Although the mathematical model used by the licensee appeared adequate, the inspectors questioned

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the buildup factor used by the licensee in the computation. Until adequate justification is available to support the use of a buildup

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factor greater than 1.0 (i.e., in a non-conservative direction), this item is considered unresolved.

10.

Review of Licensee Event Reports a.

'LER'10/77-1: Resin Mix Tank Overflow (January 8,1977)

The inspector reviewed the radiological aspects of this spill, which involved approximately 3600 gallons of water having an activity concentration of about lE-4 pCi/ml. Based on inter-views with selected personnel, it appears that the licensee's

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assessment of this release was very conservative. That is, the volume spilled on the ground was probably less than 1000

gallons (the remainder ending up in the radwaste basement)

and no activity reached the river, since it was confined to a gravel-covered area south of the radwaste facility (i.e.,

a direction away from the river) and was well within the radwaste area fence. A radiation survey of the affected

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area revealed no activity levels above background.

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b.

LER 10/77-4: Contamination of House Heating Boiler

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February 13, 1977)

This event involved contamination of the Unic 1 house heating

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boiler (oil-fired) via leaks in the heating coil of a radwaste.

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tank and an opeh valve (normally closed) in the condensate return line. Radioactivity concentrations in the boiler increased from a normal 2E+2 to IE+7 pCi/1 during the period

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from February 9 to February 13.

(The Fcoruary 9 date was based on tank liquid level records.) The concentration in the con-densate was approximately a factor of ten less. The inspector reviewed the licensee's quantification of release to the environs (via normal system leakage paths) and su veys per-forma" *o determine if there was any increase in tidiation levels in various offices and other locations whi~n receive heating steam from this boiler. No increase above background

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radiation levels was revealed by the survey.

The licensee had blown down the boiler on numerous occasions to reduce the radioac:ivity coner * ration (to 1.4E+5 pCi/l on April 22),

and on April 23 tat boiler was chemically cleaned. The cleaning process furtlier reduced the concentration by a factor of about 25 to SE+3 pCi/1. Corrective action included installation of a blank flange in the condensate return line. The licensee also decided to install electric heaters in this and other similar radwaste tanks.

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LER 237/1977-12: Floor Drain Surge Tank Sump Overflow

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March 21, 1977)

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The failure of a sump high level alarm resulted in approximately one liter of liquid seeping beneath the door of the Unit 2/3 Floor Drain Surge Tank Building and onto the ground (the esti-mate of volume was based upon thg size of the area contaminated).

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The area involved was about 1 ft Radiation levels (G-M

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measurement) of soil samples as a function of depth were:

sur-face (20,000 cpm), 4 in. (2000 cpm), and 10 in. (< 100 cpm). All

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contaminated soil was removed and disposed of as solid radwaste.

Alarm electr1 cal contacts were cleaned as part of the licensee's corrective action.

No items of ncncompliance were identified as a result of reviewing these Licensee Event Reports.

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11. Unresolved ~ Items

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Unresolved items cre matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item disclosed during the inspection is discussed in Paragraph 9.

12.

Exit Interview

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The inspectors met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on April 28, 1977,

subsequently by telephone with Mr. Stephenson on April 29 and May 6, 1977. A second management interview was held on May 13, 1977. The

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inspectors summarized the -cope and findings of the inspection. The

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inspectors noted fulfi'

.it of previous commitments by the licensee

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to:

(1) initiate a formal program for review of the chimney monitor charts to ensure that daily grab samples of noble gases are represen-tative and (2) issue an errata sheet for the January through' June 1976 effluent report. In response to certain items discussed by the inspe-tors, the licensee:

a.

Acknowledged statements made by the inspectors regarding the item of noncompliance related to a release in excess of Technical Specification limits.

(Paragraph 3.a)

b.

Indicated that errata sheets for the January-June (second sheet)

and July-December 1976 effluent reports would be issued, as appropriate, within 60 days to address apparent errors iden-tified by the inspectors. Also indicated that the review procedure for such reports before their issuance would be examined and upgraded as appropriate.

(Paragraph 4)

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Will include four to five data points in the next Unit 2/3

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chimney monitor calibration (instead of three) to better define the monitor calibration curve; 1.e., to determine if

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thel response (somewhat nonlinear) is substantiated.

(Para-graph 2)

d.

Indicated, in response to the item of noncompliance related to timeliness of iodine and particulate release of quantification, that a method for counting charcoal cartridges within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of collection would be investigated.

(Paragraph 6)

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Acknowledged the item of noncompliance related to the Standby Gas Treatment System.

(Paragraph 7)

f.

Will analyze spent resin samples for Sr-90 to determine whether such resins should be regarded as * Transport Group II (10 CFR 71)

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during shipment.

(Paragraph 9)

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