IR 05000010/1978031
| ML19289C865 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/29/1978 |
| From: | Greger L, Hiatt J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19289C861 | List: |
| References | |
| 50-010-78-31, 50-10-78-31, 50-237-78-29, 50-249-78-29, NUDOCS 7901250331 | |
| Download: ML19289C865 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-10/78-31; 50-237/78-29; 50-249/78-29 Docket No. 50-10; 50-237; 50-249 License No. DPR-2; DPR-19; DPR-25 Licensee:
Commonwealth Edison Company P. O. Box 707 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3 Inspection At: Dresden Site, Morris, Illinois Inspect.on Conducted:
November 15-17, 21, and 22, 1978
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Inspectors:
L. 'd. Greger r
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I.U.Hiatt Y
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Approved By: W. C. Fisher, Chief M
7d Fuel Facility Projects and Radiation Support Section Inspection Sunn.ary Inspection on November 15-17, 21, and 22, 1978 (Report No. 50-10/ 78-31, 50-237/78-29, 50-249/78-29)
Areas Inspected: Routine, unannounced inspection of radiation protection program for Units 1, 2, and 3, including:
qualifications; training; instruments and equipment; exposure control; posting, labeling, and control; notifications and reports; actions regarding Bulletins and Circulars; and licensee action on previously identified enforcement items and commitments. The inspection involved 90 inspe,ctor-hours onsite by two NRC inspectors.
Results: Of the eight areas inspected, no items of noncompliance or deviations were found in seven areas; one apparent item cf non'compli-ance was found in the remaining area (Infraction - inadequate control of high radiation area access - Paragraph 8).
790125033/
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DETAILS
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1.
Persons Contacted
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- D. Adam, Waste Systems Engineer
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Bergan, Chemist B. Dionne, Health Physicist
- D.
Farrar, Supervising Engineer T. Gilman, Health Physicist
- J.
Parry, Radiation Chemistry Supervisor R. Ralph Engineer
- G.
Reardanz, Quality Assurance Coordinator
- A. Robe rts, Assistant Station Superintendent J. Skoryi, Radwaste Planner The inspectors also contacted several other licensee employees, including members of the technical and engineering staffs.
- Denotes those attending the exit interview.
2.
General This inspection, which began at 12:30 p.m. on November 15, 1976, was conducted to examine certain of the licensee's radiation pro-tection activities for compliance with NRC regulations.
3.
Licensee Action on Previous Inspection Findings (0 pen) Unresolved Item (50-10/78-15, 50-237/78-13, 50-249/78-15):
Evaluation of whole body counts for compliance with 10 CFR 20.103.
The licensee had not completed the required evaluations.
(Closed) Noncompliance (50-10/77-07, 50-237/77-07, 50-249/77-07):
Failure to furnish reports of personal exposures to individuals upon termination of employment. The required personal exposure reports are now being furnished upon termination of employment at the Dresden Nuclear Power Station instead of upon termination of employment with Commonwealth Edison Company.
(Closed) Noncompliance (50-10/77-07, 50-237/77-07, 50-249/77-07):
Failure to submit reports of personal exposures to the NRC upon termination of employment. This item has been. co,rrected as noted above.
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(Closed) Noncompliance (50-137/76-27):
Failure to maintain high radiation areas locked or controlled by an alternate method. The locking mechanisms on high radiation area doors were modified and additional surveillance of high radiation area doors was instituted
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in response to this noncompliance. Further problems with access
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control for high radiation areas are noted in Paragraph 8.
4.
Radiation Protection Organization The basic radiation protection organization remains essentially unchanged from previous inspections.
Individual Unit Health Physicists and Chemists function under a Lead Health Physicist and a Lead Chemist. The Radiation Chemistry Supervisor supervises the activities of the four Chemists and the four Health Physicists as well as the approximately thirty Radmen and three Radmen Foremen.
The former Radiation Chemistry Supervisor was reassigned to the newly created position of Waste Systems Engineer on the plant staf f effective November 20, 1978. The Radiation Chemistry Supervisor position was filled by the former Lead Health Physicist. The Lead Health Physicist position is expected to be filled by the end of 1978. The Waste Systems Engineer will fulfill the Radiation Protection Manager (RPM) requirements per Regulatory Guide 1.8 for approximately six months at which time the new Radiation Chemistry Supervisor will meet the RPM qualification requirements in Regula-tory Guide 1.8.
One Unit Health Physicist assumed his position during 1978. His predecessor transferred to another Ceco facility.
No items of noncompliance or deviations were identified.
5.
Training Initial radiation protection orientation consists of a half day combination lecture / videotape presentation. Completion of requalifi-cation training, including radiation protection, is required annually.
Completion of requalification training is a prerequisite for renewal of security badges. Neither written nor oral quizzes are given as part of the initial or requalification training sessions. The inspector attended an initial training course and noted that the topics identified during previous NRC inspections as needing extensive coverage had been included in the training program.p737
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Topics required by 10 CFR 19.12 were covered in adequate detail.
Females working at the site also view a videotype which gives instructions concerning prenatal radiation expossre. Records of initial and requalification training were reviewed for selected individuals; no discrepancies from the licensee's procedural requirements were noted.
1/ IE Inspection Rpt No. 50-010/78-15, 50-237/78-13, 50-249/78-15 2/ IE Inspection Rpt No. 50-010/77-30, 50-237/77-27, 50-249/77-26-
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An abbreviated radiation protection orientation is used in special situations as detailed in procedure DPR 1910-2. A review of records showed that during CY 1978 to date, this training was used for about
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270 individuals. 3pr cedure DRP 1120-1 has been eliminated from the procedure manual.
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Training of new radiation chemistry technicians consists of classroom and inplant instruction. Ten topics are cove ed during the three to four month training period with written tests given at the end of each topic. Each technician receives annual retraining, which includes a more detailed discussion of at least one of the ten topics taught during the initial technician training. Tests are not administered after retraining courses. Training and retraining records, including initial training test results, were reviewed for selected technicians; no problems were noted.
No items of noncompliance or deviations were identified.
6.
Instruments and Equipment Inventories and calibrations of radiation and contamination survey instruments, fixed radiation monitors, and continuous air monitors were selectively reviewed for the period since the preceding radia-tion protection inspection. Calibration and testing frequencies were noted to conform to the licensee's technical specification and procedural requirements.
Although procedure DPR 1240-6, " Periods of Calibration for Radiation Protection Survey Instruments," specifies calibration intervals for survey instruments, several survey instrunents are not included in the procedure. This item will be reviewed further during a subsequent inspection.
No items of noncompliance or devictions were identified.
7.
External Exposure Control The licensee's personal monitoring program, which utilizes film badges, direct and indirect-reading pencil dosimeters, and time-keeping calculations, remains unchanged from the previous radia-tion protection inspection. Dosimetry records for the last two quarters of 1977 and the first three quarters of 1978 were reviewed;
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no doses in excess of 10 CFR 20.101 limits were identified.
Selective review of NRC-4 forms for individuals who received greater than 1.25 rems in a quarter did not identify any reported to be 1635 man-rems.47tation radiation dose for 1977 was discrepancies. The aggregate
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The aggregate radiation dose for
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the Unit 3 refueling outage in 1978 was approximately 500 man-rems.
The licensee's evaluation of neutron personal exposures is generally in agreement with the recommendations of Regulatory Guide 8.14,
" Personal Neutron Dosimeters." Dose calculations, based on time-keeping and neutron surveys (PNR-4), are made for all entrys to known neutroa fields (in excess of two mrem /hr). Neutron film (NTA) badges are also provid ' for all entries. According to the licensee's records, eleven neutron film badges were used during 1977 and 57 have been used through September in 1978. The licensee utilizes the neutron film badge results for determining neutron doses.
According to licensee personnel, no neutron doses have been report d from the film badges to date. Review of neutron survey information and timekeeping records did not reveal any probable neutron doses in excess of 100 mrems in one quarter nor does it appear that the neutron dose ever exceeds 10% of the gamma dose.
The estimated aggregate neutron dose for 1977, based on licensee records, is less than one man-rem.
No independent measurements of neutron dose rates were made during this inspection. It was noted that the licensee did not have a procedure providing guidance on use and evaluation of personal neutron monitoring. This item was discussed in the exit interview.
In response to concerns voiced during a previous inspection,5/ the licensee had:
(1) installed additional film badge storage and modified the storage arrangement, (2) identified and corrected two systematic errors in the film badge spiking technique, and (3)
formalized the pencil dosimeter testing procedures to specify test intervals and record requirements. Review of the licensee's records of film badge spikes, comparisons of film badge and pencil dosimeter doses, and pencil dosimeter testing did not reveal any significant discrepancies.
No items of noncompliance or deviations were identified.
8.
Posting, Labeling, and Control During inspection of the licensee's facilities, the inspectors examined radiation caution sign postings, high radiation area access controls, radiation work pe:mit usage, and survey postings 4/ Ltr, Stephenson to Keppler, dtd 2/14/78.
5/ lE Inspection Rpt. No. 50-10/77-30, 50-237/77-27, 50-249/77-26.
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for conformance to regulatory requirements and the licensee's procedures. Although a significant improvementg -- was evident, contaminationcontrolsoverpreviousinspectionspyyadiationand
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several items requiring further attention were identified; (1)
unauthorized radiation rope usage, (2) local radiation area post-
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ings within the turbine and reactor buildings, and (3) controlled area clothing cintrol. These items will be reviewed further durin; future inspee
.ons.
The licensee's method of control over high radiation area (HRA)
entries was modified in early November 1978. Under the new procedures, high radiation area keys and key-control logs are maintained in ten dif ferent locations. The keys are to be signed out in one of the key-control logs; the respective control room is to be notified upon actual entry and exit from the high radiation areas. The inspectors reviewed the four control room HRA entry logs and the ten key control logs for November 17, 1978, in an attempt to determine the effectiveness of the procedure for ensuring positive control over individual HRA entries.
There were forty-four entries in the HRA key-control logs for November 17.
For fifteen of the forty-four key issuances, no corresponding entry record existed in the control room or local entry logs. Not all of these omissions necessarily represent failure to control individual entries into HRA's as some keys may have been issued but not used. The licensee did verify, however, that in some of the cases llRA entries were made without notifying the appropriate control room operator. In these instances, the licensee failed to comply with the requirements of 10 CFR 20.203(c)(2)
for controlling access to nRA's.
In addition to the lack of con-trol over individual entries, the inspectors discovered the entrance to the Unit 3 shutdown cooling area open during inspection of the licensee's facilities on November 16, 1978. The area was postad as a HRA; recent surveys showed general area radiation levels of 150-200 mR/hr in the room. This also represents noncompliance with 10 CFR 20.203(c)(2).
9.
Notifications and Reports Reports to employees and the NRC appear to have conformed to the requirements of 10 CFR 19, 10 CFR 20, and the technical specifica-tions. The licensee had corrected the discrepancies identified during a previous inspection regarding exposure reports for termi-nated workers. The reports are now automaticalfy;s.ent out for workers who do not renew their biweekly film badges.
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No items of noncompliance or deviations were identified.
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1/lEInspectionRpt. No. 50-10/78-15, 50-237/78-13, 50-249/78-15.
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10.
Review of Bulletins and Circulars The inspector reviewed the licensee's actions regarding the
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following Bulletins and Circulars.
- IEB 78-08 Radiation Levels from Fuel Element Transfer Tubes IEC 78-03 Packaging Greater than Type A Quantities of Low Specific Activity Radioactive Material for Transport IEC 77-14 Separation of Contaminated Water Systems from Noncon-taminated Plant Systems The specified action for IEB 78-08 had been completed. This Bulletin is applicable only to Unit 1.
IEC 78-03 was discussed with licensee personnel, who were aware of the requirements for packaging and shipping greater than Type A quantities of radioactive material. The licensee's procedures reflect these requirements.
The licensee's review of contaminated and noncontaminated water system interconnections, performed in response to IEC 77-14, was examined. The procedural changes recommended as a result of the licensee's review had been completed.
No items of noncompliance or deviations were identified.
11.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on November 22, 197c. The inspector summarized the scope and findings of the inspection.
In response to certain items discussed by the inspector the licensee:
a.
Stated that the Waste Systems Engineer (former Radiation Chemistry Supervisor) would assist the new Radiation Chemistry Supervisor as required for tne six months until tl.e new Radiation Chemistry Supervisor meets the experience recommen-daticns of Regulatory Guide 1.8.
(Paragraph 4)
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Stated that procedure DRP 1240-6 would be revised to specify calibration frequencies for additional instrumentation.
(Paragraph 6)
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b Acknowledged t:o inspector's comments regarding personal neutron monitoring and stated that a procedure for evaluating c.
rsonal neutron exposures would be initiated.
(Paragraph 7)
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Acknowledged the inspector's comments regarding controlled d.
area housekeeping conditions and stated that efforts towards (Paragraph 8)
improving these conditions would continue.
Acknowledged the noncompliance with high radiation area access e.
control requirements. (Paragraph 8)
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