IR 05000010/1977020
| ML19338C975 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/02/1977 |
| From: | Essig T, Fisher W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19338C973 | List: |
| References | |
| 50-010-77-20, 50-10-77-20, 50-237-77-19, 50-249-77-19, NUDOCS 8009120718 | |
| Download: ML19338C975 (2) | |
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U.S. NUCLEAR RECULATORY COMMISSION
0FFICE OF INSPECTION AND ENFORCEMENT
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REGION III
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Report No. 50-010/77-20; 50-237/77-19; 50-249/77-19 Docket No.50-010, 50-237, 50-249 License No. BPR-2, DPR-19, DPR-25
Licensee: Commonwealth-Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power, Units 1, 2 and 3 Inspection At: Dresden Site, Morris, IL
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Inspection Conducted: June 28-29 and July 8, 1977 ld W.$.'O'$,ws; y Inspectors:, T. H. Essig S/2 /7'1 y
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Approved by[:iW. L. Fis er, Chief b/7/'M
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Fuel Facility Projects and Radiation Support Section
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Inspection Summary i
Inspection on June 28-29 and July 8, 1977 (Report No. 50-010/77-20, 50-237/77-19, 50-249/77-19)
Areas Inspected: Special, unannounced inspection of radiation protec-i tion and radwaste activities, including:
radwaste shipments, licensee
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event reports, noncompliance follow-up, unresolved item follow-up, and licensee commitments. The inspection involved 40 inspector-hours on-i site by two NRC inspectors.
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Results: Of the five areas inspected, no items of nsncompliance or
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deviations were identified in three areas; two apparent items of non-compliance were identified in two areas (deficienef, failure to report _ gaseous releases, Paragraph 9; infraction, shipment without authorization, Paragraph 11).
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I DETAILS
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Persons Contacted
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- D. Adam, Radiation and Chemistry Supervisor
- J. Bergan, Chemist
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D. Gamage, Engineer J. Parry, Health Physicist
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G. Remba, Engineer C. Sargent, Supervising Engineer T. Schneider, Chemist
- L.
Scott, Chemist.
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- B.
Shelton, Administrative Assistant
- B.'Stephenson,' Superintendent J. Testa, Assistant Engineer The inspectors also contacted several other licensee employees, including members of the technical and engineering staffs.
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- denotes those attending the exit interview.
2.
f,yneral
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Tbis inspection, which included visual observation of selected licensee work areas, was conducted to examine the licensee's ac tions related to noncompliance items, unresolved items, and
- t commitments identified during previous inspections and to
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review sevetal recent events reported by the licensee.
i 3. ~ Licensee Act.on on Previous Inspection Findings (Closed) Noncompliance (50-010/77-07, 50-237/77-07, 50-249/77-07):
Inadequate evaluation of personal contamination. Corrective action consisted of giving the individual a whole body count and evaluating the exposure. This evaluation indicated that the exposure (assuming'a single event) was less than 40 MPC-hrs. Action taken to prevent recurrence included a reemphasis to Radiation-Chemistry management of the importance of evaluating all events involving personal contamination. The inspectors
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also noted that the licensee had blocked of f several of the
. openings which could have allowed, via ventilation flow reversal,
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airborne radioactivity to be carried from the solid radwaste
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barreling area to'the control panel area,.the latter being a normally noncontaminated area.
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(Closed) Unresolved Item (50-010/7-7-07, 50-237/77-07, 50-249/77-07):
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Possible inadequate maintenance of NRC-4 forms for certain contractor employees. One aspect of this unresolved item involved missing NRC-4s for three contractor employees. The
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Licensee has now located these forms. The other aspect of this
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unresolved item, which was related to the informal arrangement for accounting for contractor. employee time spent at sites other than Dresden, has been modified _to require that a Form-4 be completed when it appears that any individual's quarterly dose will exceed 1250 mrems.
I (0 pen) Noncompliance (50-010/77-10, 50-237/77-11, 50-249/77-11):
Failure to report a release in excess of the technical specifica-tion limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee presently is developing a procedure which permits quantification of iodine and particulate
releases within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This item remains open, pending completion and implementation of this procedure.
(Closed) Noncompliance (50-010/77-10, 50-237/77-11, 50-249/77-11):
Excessive halogen and particulate release rate on April 15 and 16, 1977. The equipment problem which caused the increase in
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the halogen and particulate release rate was corrected. Unit 1
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is. currently out 'of service for refueling. Halogen and particu-
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late release rates are expected to be considerably reduced when Unit I returns to service, due to fuel replacement and the
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anticipated tie-in of the augmented offgas treatment system.
4.
Licensee Internal Audits
' While revieving the licensee's results of investigatiens of
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nonroutine events (Paragraph 5), the inspector noted that the
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licensee had identified two items requiring corrective actions j
per technical. specifications requirements. Corrective action had been completed for both items.
T 5.
Review of Nonroutile Events Reported by the Licensee The inspectors reviewed the licensee's actions with respect to the radiological aspects of the folicwing licensee event reports.
No items of noncompliance or deviations were identified. The
l inspector noted 'that the licensee had identified and initiated
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corrective action, per technical specification, requirements, for two radiation protection related items, i
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Halogen and particulate release rate in excess of 20% of the~
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technical specification limit (LER 50-010/77-7, 50-010/77-8, 50-010/77-18).-
Halogen and particulate release rate in excess of the techni-cal specification limit (LER 50-10/77-10).
Fuel pool' beat exchanger inlet vent line failure (LER 50-10/77-9).
Failure to follow procedures for release of a laundry drain tank (LER 50-10/77-14).-
Steam jet-air ejector-offgas system radiation monitor failure (LER 50-10/7 7-15).
Of fgas system HEPA filter f ailure (LER 50-249/77-14).
Failure to follow procedures for reactor coolant isotopic analysis (LER 50-249/77-18).
The information contained in the LER's reviewed was not complete
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in all cases and was_ misleading in certain cases. Discussions with licensee personnel revealed that the licensee's statement
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in LER 50-249/77-18 that "This surveillance represents less than
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- 1/2% of the total number of surveillances conducted during. the month" did not refer solely to reactor coolant isotopic analyses, the subject of the LER, but included other analyses conducted on reactor coolant samples, including nonradiological analyses.
The reactor coolant isotopic analyses are conducted monthly.
' The reportable occurrence (LER 50-10/77-15) pertaining to the loss of both steam jet-air ejector of fg ts system radiation monitors did not include suf ficient information to fully evaluate the consequences of the. occurrence.
Review of the licensee's records revealed that the Unit 1 steam jet-air ejector offgas system radiation monitors were both out of service for approximately 22 minutes, due to a power failure. The chimney radiation monitors, which were operating during this period, did not
' indicate any significant changes-in the release rate.
The licensee agreed to submit a revised LER for this occurrence.
This matter will be reviewed further during a future inspection.
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The inspectors noted during review of LER 50-249/77-14 that.the licensee had not included the increased gaseous releases associated
with this occurrence in the daily record of gaseous releases.
Licensee personnel had reviewed the strip chart associated with
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the anomalous release but had failed to transcribe the data to
.the daily release records. The gaseous release from the D 2/3 chimney for April 25, 1977 was recorded as 3.7 cu. ries. According to licensee personnel, the gaseous -release associated with the HEPA filter failure, as quantified from the of fgas stack gaseous monitor, was approximately 1200 curies.
Further discussions regarding LER 50-I0/77-9 and 50-10/77-14. are
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contained in Paragraphs 6 and 7.
6.
Fuel Pool Heat Exchancer Inlet Vent Line Failure (LER 50-10/77-9)
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The vent line failure resulted in r spill of about 2000-5000 gallons of Fuel Pool water onto the floor of the adjacent store s
room and the D 1 sphere access corridor. The water was " diked" to prevent further spread and was cleaned ap.
Five radiation surveys were performed the day of the event (April 21, 1977)
and the day af ter.
Generally, these surveys showed little
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s residual surf ace contamination (< 100 cpm g-M). Maximum surface j
contamination levels were 2000-2500 cpm /ft on the warehouse
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floor. This area was then decontaminated.
No radioactivity
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appeared to be released outside of the building.
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No items of noncompliance or deviations were identified.
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T aundry Tank Discharged Without Verification of Release Calculation
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(LER 50-10/77-14)
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On April 26, 1977, about 900 gallons of waste were discharged from the "B" laundry tank without independent verification of the release calculation (as required by Procedure DC? 2000-25).
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In addition, the release rate calculation contained a' factor of i
ten error in the nonconservative direction.
Fortunately, calculations made subsequent to the release showed that the I
technical specification limits had not been exceeded.
(The licensee estimated 66% of the T/S limit and the inspectors estimated 80%; the difference was due to the tank discharge
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time used in the calculation).
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No items of noncompliance or deviations were identified.
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8.
Chimney Caseous Monitor Calibration
The inspectors reviewed the licensee's most recent calibration of the D 2/3 chimney gaseous monitor. The monitor was calibrated-5-t
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by injecting gaseous samples cellected from various points in
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the offgas system. Shortcomings noted in the calibration technique are the use of nonuniform isotopic compositions in te. calibration gases and -the failure to calibrate the monitor a. activities corresponding to the normal release rates.. The licensee indicated that the calibration procedure would be reevaluated before the next scheduled calibration.
This item will be. reviewed-further during a subsequent inspection
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9.
Radioactive Caseous Releases (D 2/3)
The licensee quantifies gaseous releases from Units 2 and 3 on-the basis of daily grab samples collected at the outlet of the individual augmented of fgas-treatment systems. The chimney gaseous monitor is utilized to quantify ancmalous gaseous releases. Reactor building ventilation system gaseous releases and gaseous releases via the chimney, other than the of fgas treatment s stems, apparently are not quantified. At the inspector's reques t, gaseous grab samples were collected from.
the reactor building ventilation stack and the chimney. Analyses
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of'these samples (by the licensee) resulted in calculated release rates which were approximately a factor of ten greater
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than the release rates quantified by the daily of fgas treatment -
system samples. - Although the majority of the activity is released from the chimney, reactor building ventilation stack releases appear to be about 100 pci/sec.
j The additional gaseous releases identified ari well within the
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technical specification release limits, but the licensee apparently has not been adequately quantifying and reporting gaseous releases as required by Technical Specification 6.6.C.I.
Isotopic. analyses of the chimney grab samples indicates that the additional gaseous releases have a significantly shorter average half-life than the of fgas treatment system gases.
Part, if not the majority, of the additional gaseous releases may be gland seal exhrust system ef fluent, which bypasses the offgas treatment system. Those effluents which bypass the offgas treatment system have become proportionately more significant since the augmented of fgas system became operational and are not quantified by the licensee's current method for determining gaseous relenec3.
The liernsee has agreed to thoroughly investigate the gaseous release sources and to institute a program for accurately
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quantifying those releasec. This item will be reviewed further s
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during a subsequent inspection.
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- 10.
Follow-up on Licensee Commitments
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The in,spectors noted fulfillment of the following commitments i
by the licensee:
a.
Procedure DRP 1240-10, " Operation of the Eberline Survey
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Meter, Model PNR-4," was written to indicate when procedure
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DRP 1240-9 " Calibration check of...." should be used.
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b.
A portion of procedure DRP 1910-1, " Radiation Protection f
Orientation," was rewritten to include instructions on prenatal exposure for all women, not just those who a;re obviously pregnant at the time of the radiation protection orientation.
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Termination exposure reports (10 CFR 20.408 and 20.409)
are now being sent to individuals who terminate their assignment at the Dresden station, but remain Commonwealth Edison employees.
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11.
Radioactive Was te Shipments
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j The inspectors reviewed the licensee's solid radioactive vaste j
shipment records for January through March 1977. During the three-month period, 83 shipments of waste were recorded as Group III, LSA. Of these, 66 shipments exceeded the Croup III,
Type A quantity limit (3 curies). Authorization by way of a general or specific license -issued by the NRC or an exemption
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pursuant to 10 CFR 71 is required to either deliver licensed
materials to a carrier for transport or transport licensed material'(10 CFR 71.3).
The licensee apparently does not possess a specific license pursuant-- to 10 CFR 71, nor does it
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appear that the licensee is exempted from the requirement to
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possess a license. The general license defined in 10 CFR 71.12 authorizes shipment of Type B quantities in either DOT
Type B specification containers or packages for which a license,
ce--ificate of compliance, or other cpproval has been issued by the NRC. The licensee shipped the solidified radioactive waste -in DOT specification 7A containers, which are not DOT Type B containers, par have the containers been approved by the NRC for Type B qunatities.
It appears, therefore, that the licensee did not comply with the requirements of 10 CFR 71.3 for the 66 shipments-of Type B quantity, Croup III solid radioactive waste -delivered for transport during the period Jtnuary through Nbrch 1977.
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Exit Interview
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The. inspector met with licensee representatives (denoted in Para-graph 1)-' a t the conclusion of the inspection on July 8,1977 and
. further discussed the inspection findings with Mr. Stephenson w
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telephone on July 21, 1977. The inspectors' summarized the scope
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and findings of.the inspection. - The licensee made the following remarks in response,to certain items discussed by the inspector:
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i a.
Stated that LEP. 5010/7715 would be resubmitted in order j
to' clarify the original report.
(Paragraph 5)
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Stated that future LER's would receive additional review before submission in order to uprove their clarity.
(Paragraph 5)
c.
Stated that the failure to add the increased gaseous 4,
releases associated with the April 25, 1977 HEPA filter failure to the gaseous release record for that day repre-
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sented an isolated omission.
(Paragraph 5)
d.
' Stated that the chimney monitor calibration technique
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would be reviewed and discussed with the regional NRC
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office before the next required calibrations.
(Para-
graph 8)
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Stated that.an investigation into the gaseous activity e.
released from the D 2/3 himney and the reactor building ventilation stack would be initiated immediately.
(Para-graph 9)
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