IR 05000010/1978015
| ML19340A870 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/28/1978 |
| From: | Fisher W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A866 | List: |
| References | |
| 50-010-78-15, 50-10-78-15, 50-237-78-13, 50-249-78-15, NUDOCS 8009040689 | |
| Download: ML19340A870 (8) | |
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e U.S. NUCLEAR REGLATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-010/78-15, 50-237/78-13, 50-249/78-15 Docket No.50-010, 50-237, 50-249 License No. DPR-2, DPR-19, DPR-25 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, Illinois 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3 Inspection At: Dresden Site, Morris, Illinois Inspection Conducted: April 27 and 28, and May 2-5, 1978 Inspector:
L. R. Greger M 8 Approved By:
W. L. Fisher, Chief
,6 7.F/77
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Y Fuel Facility Projects and Radiation Support Section Inspection Summary Inspection on April 27 and 28, and May 2-5, 1978 (Report No. 50-010/78-15, 50-237/78-13, 50-249/78-15)
Areas Inspected: Routine, unannounced inspection of radiation protection activities, including: audits; procedures; exposure control; posting, labeling, and control; surveys; refueling activities; shipping; and licensee action on previously identified enforcement items and commitments.
The inspection involved 50 inspector-hours onsite by one NRC inspector.
Results: Of the eight areas inspected, no items of noncompliance or deviations were found in six areas; three apparent items of noncompliance were found in the remaining areas (Infraction - inadequate evaluation of airborne exposures - Paragraph 7; Deficiency - failure to maintain shipping records - Paragraph 11; Deficiency - failure to comply with general license requirements for Type B shipments - Paragraph 11).
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DETAILS 1.
Persons Contacted
- D. Adam, Radiation Chemistry Supervisor B. Dionna, Health Physicist
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- G. Myrick, Health Physicist M. Paris, Health Physicist
- J.
Parry, Health Physicist W. Rath, Engineering Assistant
- G. Reardanz, Quality Assurance Coordinator L. Scott, Chemist
- J. Skoryi, Radwaste Foreman The inspector also contacted several other licensee employees, including members of the technical and engineering staf fs.
- Denotes those attendin'g the exit interview.
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2.
General
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This inspection, which began at 3:15 p.m. on April 27, 1978, was conducted to examine the licensee's radiation protection activities for compliance with NRC regulations. Refueling outage activities underway during the inspection were examined in addition to the routine radiation protection activities.
3.
Licensee Action on Previous Inspection Findings
(Closed) Noncompliance (50-010/77-20; 50-237/77-19; 50-249/77-19):
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Unauthorized delivery of Type B quantities of byproduct material to a carrier for transport. The three containers used by the licensee for shipment of Type B quantities of byproduct material are currently authorized for such shipment under certificates of compliance issued by NRC.
(Closed) Noncompliance (50-010/77-07, 50-237/77-07; 50-249/77-07):
Failure to provide termination exposure reports to -individuals.
Review of the licensee's records indicated that these reports are now being made and that the report omissions were corrected.
(Closed) Noncompliance (50-010/77-07; 50-237/77-07; 50-249/77-07):
Failure to submit termination exposure reports to NRC. Review of the licensee's records indicated that these reports are now being made and that the report omissions were corrected.
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(Closed) Unresolved Item (50-010/77-30; 50-237/77-27; 50-249/77-26): Evaluation of the protection afforded by supplied air hoods.
Quantitative testing performed by the licensee during the period October - December 1977 demonstrated the adequacy of the supplied air hoods for use with a protection factor of 1000. The hoods have since been removed from use as 10 CFR 20.103 and Regulatory Guide
8.15 require that specific authorization for use of nonapproved respiratory equipment be received from the NRC before use of such equipment subsequent to December 29, 1977. According to licensee personnel, a request for use of the hoods has been submitted to the NRC.
4.
Licensee Audits Two audits related to radiation protection activities were conducted by the licensee's offsite audit organization during 1977. The audit plans and findings were reviewed by the inspector and found to be rather limited in scope. Additionally, two audit findings were contrary to the inspector's findings. Several
audits conducted by an onsite audit organization during 1977 in-cluded aspects of the radiation protection program. These audits
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were revie.ed; no significant discrepancies were identified.
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No items of noncompliance or deviations were identified.
5.
Training Refresher training, including radiation protection activities, is provided annually. Completion of refresher training is required for renewal of security badges. The inspector observed conduct of a refresher training session. Neither written nor oral quizzes were conducted as part of the refresher training. It was noted that the step-off pad procedure described during the refresher training did not correspond to the procedure used by licensee personnel. This item will be reviewed further during a future inspection. No other significant weaknesses were identified.
No items of noncompliance or deviations were identified.
6.
Radiation Protectf,on Procedures The inspector reviewed the revisions to radiation protection procedures effected since April 1917. The revisions do not sig-nificantly diminish the effectiveness of the radiation protection program.
No items of noncompliance or deviations were identified.
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7.
Internal Exposure Control
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The licensee's program for control of internal exposures includes the use of protective clothing and equipment, control / reduction of surface and airborne contamination levels, and utilization of surface and airborne survey information. Station personnel are whole body counted annually or more frequently depending on job assignment and/or suspected airborne exposure.
Contractor per-sonnel are monitored for internal exposure upon termination of work assignment at the station and at intervals during long-term work assignments based on suspected intake potential. The monitoring performed can be either urinalysis or whole body counting. Review of the licensee's records indicated that during the first four months of 1978, approximately 25% of termination monitoring of contractor personnel was by whole body counting. Licensee per-sonnel stated that operational difficulties with the whole body counting equipment due to Unit 1 gaseous releases limit the number of whole body counts which can be performed on departing contractor personnel. This item will be reviewed further after operation of the Unit I augmented offgas system commences.
The onsite whole body counter became operational during late 1977.
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Review of the whole body count data generated subsequent to that time revealed several individuals with internal burdens exceeding
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the long-term lung burden predicted by ICRP Committee 2 for in-halation of 40 MPC-hours of insoluble byproduct material. Although licensee personnel had conducted follow-up evaluations on several ir.dividuals with high whole body counts, twelve individuals with whole body counts indicative of possible excessive airborne ex-posures were not evaluated to determine the significance of the measured body burdens. Such an evaluation is required by 10 CFR 20.201(b) to demonstrate compliance with 10 CFR 20.103. The twelve individuals had measured body burdens which generally ranged from 75 to 125 nCi of cobalt-60 with lesser quantities of manganese-54.
The licensee's evaluations of these individuals' whole body count results will be reviewed during a subsequent inspection. The matter of compliance with the 40 MPC-hours criterion of 10 CFR 20.103 is considered unresolved pending review of the evaluations.
The inspector reviewed the licensee's respiratory protection program for conformance to the requirements of 10 CFR 20.103 and Regulatory Guide 8.15.
Several minor procedural items were discussed with licensee personnel who stated that the administratove procedure governing respiratory equipment usage was presently under revision.
The licensee presently performs qualitative fit-testing of-4-
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respirator facepieces but intends to procure quantitative fit-
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testing equipment in the near future. Half-masks are not irritant smoke tested, before use, each time they are donned. However, the airborne concentrations in which the half-masks are worn are less than one MPC on an isotopic basis.
8.
Posting, Labeling, and Control During inspection of the licensee's facilities, the inspector examined radiation caution sign postings, high radiation area access controls, radiation work permit usage, and survey postings for conformance to regulatory requirements and the licensee's procedures. The poor health physics practices noted during a previous inspection were evident during this inspection also.-j These items included:
(1) unused radiation rope and signs left lying about in work areas, (2) radiation rope used for purposes other than defining radiological hazards, (3) inconsistent step-off pad usage, and (4) failure of radiation protection personnel to require performance of step-off pad monitoring. This area will continue to be reviewed during future inspections.
The inspector selectively reviewed the licensee's radiation work permits, radiation occurrence reports, and radiation protection
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logs for 1978. Usage of the radiation occurrence report system was somewhat improved from the findings during a previous inspection.2/
No items of noncompliance or deviations were identified.
9.
Surveys The licensee's direct radiation, contamination, and airborne survey records were selectively reviewed. No significant discrepancies were identified. Surveys were noted to be conducted at the frequencies specified by the licensee's procedures.
Survey results were posted at the radiation protection office.
The licensee's records of sealed source leak tests and inventories conducted since April 1977 vere reviewed. Leak tests were con-ducted semiannually and inventories quarterly. No leaking sources were identified.
No items of noncompliance or deviations were identified.
10. Outage Activities Unit 3 began a refueling outage on March 5, 1978. At the time of this inspection, the fuel handling operations had been completed.
The inspector observed ongoing work and radiation protection 1/ IE Inspection Rpts. No. 50-010/77-30, 50-237/77-27, 50-249/77-26.
2/ Ibid.
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activities at various locations in the reactor building, drywell,
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and turbine building. All major jobs of radiological significance were under continuous radiation protection coverage, either by licensee personnel or contract radiation protection personnel. The inspector selectively reviewed radiation work permits, radiation protection logs, respiratory equipment usage records, personnel dosimetry records, and the results of airborne, smear, and direct radiation surveys related to outage activities. External radiation measurements were made by the inspect'or to verify licensee meas-urements. Except as noted elsewhere in this report no significant problems were noted.
Dose expenditures are expected to total about 700 man-rems over the 10-week outage. The major contributorc to the exposures were drywell instrumentation modifications, inservice inspections, CRD nozzle modifications, and feedwater sparger work.
No items of noncompliance or deviations were identified.
11.
Radioactive Waste Shipment The inspector reviewed the licensee's records of shipments of greater than Type A quantities of byproduct material. The containers
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used for the shipments were noted to be authorized for low specific activity byproduct material (including Type 3 quantities) and for use under the general license provisions of Paragraph 71.12(b) of 10 CFR Part 71.
It was noted however that the licensee had not fully complied with the requirements of 10 CFR 71.12(b), in that:
(1) NRC (NMSS) was not notified before first use of one of the three generally licensed shipping containers, and (2) all documents referred to in the applicable certificates of compliance were not possessed by the li-censee. It was further noted that the licensee's records did not contain all of the information specified by 10 CFR 71.62.
Specific omissions included:
(1) package identification by model number (2) shipping / transferee address, and (3) results of the determina-tions regarding container damage, closure and sealing condition, and loading and closing procedures required by 10 CFR 71.54.
12.
Review of Nonroutine Events The inspector reviewed the licensee's actions with respect to the radiological aspects of the following licensee event reports. No items of noncompliance or deviations were identified.
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D, LER 50-10/78-12:
Failure to Conduct Sampling
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Following High Air Sample (Nbrch 1,1978)
Ltr. Reed to Keppler:
Structural Failure of Trailer (dtd 2/28/78)
Carying Spent Fuel (Februery 9, 1978)
Discussions.with licensee personnel and/or review of the licensee's records did not reveal any significant discrepancies in the reports.
Neither event had significant radiological consequences.
13. Unresolved Items Unresolved items are matters about which more information is re-quired in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved item dis-closed during the inspection is discussed in Paragraph 7.
14.
Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the cenclusion of the inspection on May-5,1978, and further discussed the inspection findings with Mr. Stephenson by
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l telephone on May 23, 1978. The inspector summarized the scope and findings of the inspection. In response to certain items discussed by the inspector, the licensee:
a.
Acknowledged the inspector's comments regarding the audits conducted by the licensee's oftsite audit organization.
(Paragraph 4)
b.
Stated that the radiation protection orientation training would be reviewed regarding step-off pad procedures and quizzes.
(Paragraph 5)
c.
Stated that the controlled area housekeeping problems noted by the inspector would be investigated and corrective action initiated.
(Paragraph 8)
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Acknowledged the inspector's comments regarding the items of noncompliance.
(Paragraphs 7 and 11)
e.
Stated that problems encountered with the whole body counter due to fluctuating background radiation levels were being pursued. A higher percentage of contractor personnel could be
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whole body counted if the background radiation problems were
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reduced.
(Paragraph 7)
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Agreed to perform periodic isotopic evaluations of airborne concentrations of radioactive material to confirm that half masks are not worn in airborne concentrations greater than one MPC (isotopic) or, if worn, that irritant smoke qualitative testing is performed, before use, each time they are worn.
(Paragraph 7)
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