IR 05000010/1980008
| ML19318A436 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/06/1980 |
| From: | Fisher W, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19318A434 | List: |
| References | |
| 50-010-80-08, 50-10-80-8, NUDOCS 8006230024 | |
| Download: ML19318A436 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-10/80-08
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Docket No. 50-10 License No. DPR-2 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Station, Unit 1 Inspection At: Dresden Site, Morris, IL Inspection Conducted: March 3-5, 7, 13-14, and April 8, 9, 1980 Inspector:.. A$
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Approved By:
W. L. Fisher, Chief cs 6, NPC Fuel Facility Projects and i/
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Radiation Support Section Inspection Summ.ety Inspection on March 3-5, 7, 13-14, and April 8, 9, 1980 Areas Inspected: Routine, announced inspection of radiation protection program for the Unit I decontamination, including: audits; training; ALARA; monitoring equipment and procedures; exposure control (external and internal); posting, labeling, and control; and notification of re-ports. The inspection involved 73 inspector-hours on site by one NRC inspector.
Results: Of the seven areas inspected, two items of noncompliance were found in one area:
Infraction - failure to make an adequate evaluation to determine compliance with 10 CFR 20.106 - (Paragraph 13) and Infrac-tion - concentrations in excess of T.S. 3.8.C.2. limits were found in the discharge canal (Paragraph 13).
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- DETAILS 1.
Persons Contacted ~
- J. Almer, Operations
- J. Barker, USNRC
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- T. Gillman, Health Physicist-
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- J. Harrison, Engineer
- F. Jones, Health Physicist
- R.-Ragan, Operating Assistant Superintendent
- C. Sargent, Operations, Unit 1
- B. Stephenson, Station Supervisor The inspector also contacted other licensee employees.
- Denotes those present at the exit interview.
2.
General This inspection, which began at 8:00 a.m. on March 3, 1980, was conducted to examine the licensee's radiation protection and rad-waste management progran for the chemical decontamination of Unit 1.
During the inspection, several tours were made in Unit 1 and the Unit 1 Chemical Cleaning Building (CCB). The inspector attended an initial radiation protection orientation class and informational meetings concerning the Unit I decontamination.
3.
Training All contractor personnel involved in the Unit I decontamination pro-
' gram have attended the licensee's radiation protection orientation class. The instruction consists of lectures, video tape presenta-tions, and demonstrations of mask fitting techniques. All topics required by 10 CFR 19 were covered in detail. Any additional train-ing given to radiation workers involved in the program was given by contractor supervisory personnel or the licensee's radiation pro-tection staff.
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ALARA The licensee's program in keeping occupational exposures ALARA con-i sisted of adding temporary shielding where needed, draining and flushing of the primary system prior to installation of the inter-face piping and instrumentation, and backia. ling the primary system with water to provide additional.self shielaing. Because of these precautions, with'over 90% of the pre-decontamination installations
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completed, the occupational exposure received to date has been approximately_275 man-rems. The original exposure estimate before installation was 400 man-rems. The reduction is primarily due to preoperational testing, monitoring,. engineering, and training.
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.High Radiation Areas The controls for high. radiation areas in the CCB are written and established in accordance with DAP 12-4, " Control of High Radiation Areas." nThe controls for high radiation areas in the sphere will
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be implemented in accordance.with DAP 12-4 during the decontamina-
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tion. These procedures were reviewed and appear adequate for proper control.
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6.
Radiation Monitoring Equipment and Procedures i
Radiation and effluent monitoring during the' decontamination in Unit i
1 will be accomplished using the presently installed equipment.
It is the licensee's intent to maintain effluent releases below Dresden 1 technical specifications. The existing monitoring equipment at Unit 1 that can be'used for the decontamination project is described in Section 11.2 of the Chemical Cleaning Licensing Update dated August 30, 1977. The radiation and effluent monitoring procedures and equipment for the Chemical Cleaning Facility are outlined in a system description entitled " Radiation Monitoring in a Chemical Cleaning Facility." The monitoring systems are designed to detect
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and alarm when radiation fields or airborne concentrations exceed predetermined levels. The facility will use area radiation monitors, airborne radioactivity monitors, effluent monitors of liquid and j
gaseous discharges, process monitors, and personnel monitors.
j During this inspection some detectors had not yet been installed
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because they had not been received from the vendor. All monitors will-be operable before the mock run.
A review of the monitoring procedures and equipment that will be used during the decontamination project was made during this in-spection.
Based on the review, it appears the licensee has ade-quate procedures and equipment to identify potential.and real radiation safety problems.
7.
Radiation Protection Program Health physics coverage has been and will continue to be provided for.the entire decontamination project. During the actual decon-tamination phase of this project, Health Physics will continually monitor the operation. Most Health Physics procedures used during this operation are written in the licensee's existing procedures; some are still to be developed and others are not documented.
The Health Physicist assigned to the decontamination project had identified some 25 radiation concerns of Unit I chemical cleaning i
equipment arrangements and operating requirements in the building and sphere which could impede proper operation and maintenance.
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These concerns and the licensee's response to them were reviewed-during the inspection. Although some of the identified concerns-are still under review for action, the great majority of them were acknowledged and positive action was taken.
8.
Exposure Control - External
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All personnel working in the preoperational phase of this project wore film badges and pocket dosimeterm. As of April 1, 1980, about 275' Lan-rem (about 75% of the original estimate before installation)
was_ received by workers, with over 90% of the predecontamination installation completed. Approximately 75% of the 275 man-rem was measured using film badges, and the remaining exposure was assigned on the basis of worker's stay time in known radiation fields. This method of assigning dose is considered conservative and probably tends to overestimate dose because, for most cases, pocket dosi-meter-readings were considerably less than estimated doses.
Radiation Safety Rad / Chem technicians instruct workers to place the whole body film badges at that part of the anatomy where the highest exposure to the whole body is most likely.
Extremity monitoring devices were not used during the preoverational phase of this project. A licensee representative stated that although monitors were not worn, an evaluation is made to ensure compliance with 10 CFR 20.102. requirements by knowing the worker's specific job function and the estimated exposure time to perform the job. Using this method of evaluation, the licensee determined that no extremity exposures exceeded 25% of the Part 20.101 applicable limits.
9.
Surveys-Radiation area and contamination surveys were made in the Unit I sphere on a nonroutine basis during the' construction phase of the decontamination project.
The radiation surveys identified radiation fields and were used to assess permissible stay times for workers. The contamination sur-veys are made to identify areas with significant loose contamination, one criterion used to determine the need for half-face particulate respirators. Survey records, reviewed for the first three months of 1980, indicate the surveys were performed at irregular, although-adequate, frequencies.
10.
Exposure Control - Internal Whole body counts were taken on all workers involved in the Unit I decontamination project during the construction phase before and after their work assignment. Records of the results of these counts I
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were not made during this-inspection;'however, a licensee representa-
- ti_ve stated that no.radionuclide uptakes, as' determined by the whole body counts,'were observed. These records will be revie. sed at the next inspection.
A review of the licensee's air samples taken from January through
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March'1980 in.the Unit I sphere indicates that sufficient samples were taken to ensure compliance with 10 CFR 20.103 requirements and-the licensee's respirator use criteria. -No problems were noted.
11.
Sampling and Analysis Requirements for Spent Solvent,-Evaporator Bottoms, and Resins The licensee's sampling requirements and sampling schedule for the
. Unit I decontamination follows:
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Spent Solvent 1.
Transuranic analysis and istopic - before evaporator ratio determination 2.
Strontium 89and9gjpalysis
- before solidification
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Isotopic analysis -
- before solidification 4.
- before demineralizer transfer to station b.
Evaporator Bottoms Isotopic for each 115 tank _/
- before solidification
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and after tank isolation 2.
Isotopjesasnecessaryfor
- at the start of the curie content'vs. dose rate solidification process correlation
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Isotopic if tank does not
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remain isolated c.
Resins 1.
Isotopic
- before resin solidification *
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Strontium 89 and 90 analysis _/ - before resin solidification *
. *These requirements may possibly be relaxeo efter analysis of evaporator bottoms and spent solvent samples.
1/ Analysis performed by: Nuclear Enviornmental Servicee 2_/~ Analysis performed _by: Station 3/ Analysis performed by: Radiation Management Corporation
{/ Analysis performed'by: Dow Chemical Company
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12. ' Posting,. Labeling, and Control During-Unif.1 plant tours, the inspector noted that controlled area Epostings and control;of high radiation areas complied with regulatory requirements.
13. Notificatio'n and Reports
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In'accordanceLwith 10 CFR 50.72 requirements, the licensee notified the NRC Operations Center. on April 5,1980, of an unplanned release of radioactivity. The release occurred from Unit 1 during the period April 3-5, 1980, from the service water system, which was released via the discharge canal to the river. The following information was found by~the inspector on April 8 and 9, 1980, during a review of the cir-cumstances surrounding the unplanned release.
The release was caused by a tube failure in the IB unloading heat exchanger that was being used to heat up the primary system by use of. steam from the auxiliary boiler. During April 3 and 4, 1980, the licensee became aware they were losing water and assumed the water was being lost either to the Unit 1 floor drain system or into a cross tie in the DOW system.
Stored demineralized water from the waste storage tank was the source of the water used in the system. The discharge from the system was closed off at 3:26 p.m. on April 5, 1980.
The release of the radioactivity into the discharge canal was dis-covered at 1:00 p.m., April 5, 1980, when the results of the routine, 24-hour composite-sample of the canal effluent indicated a concentra-tion of 1800 picocuries per liter, gross be+a.
The results of the samples for the two previous days were 63 a<d 75 picocuries per liter. Two grab samples collected at 3:00 p.m. on April 5, 1980, one.at the same location as the composite sample and another down-stream, indicated 890 and 30 picocuries per liter, respectively.
On the basis of these results, the licensee assumed that an estimated one millicurie had been released to the river.
The licensee used the results of a sample taken from the Rad Waste Storage Tank to determine the total activity' discharged into the river. On April 6, 1980,,the licensee speculated that a more ap-propriate sampling location for determining total quantity of radio-activity released would be the heat exchanger which contained the leaking tubes. Based on the results of a sample taken at that loca-tion, the licensee concluded 620 millicuries had been released into
'the discharge canal, which was pumped into the river during the
'af ternoon of April 6,1980.
During the period April 3-5, 1980, the licensee assumed the water was being lost into the Unit 1 'radwaste system and did not determine-6-
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whether any of the water flowed into the discharge canal.
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tion, no water samples were taken upstream of the canal composite sampler on April 5, 1980, after identifying the release, to determine whether contaminated water remained in the canal. This failure to make a timely evaluation to ensure compliance with 10 CFR 20.106(a)
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is in noncompliance with-10 CFR 20.201(b).
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The 24-hour routine composite sample taken between April 5 and 6, 1980, counted at 9:00 a.m. on April 6, indicated 3100 pCi/1. At 3:10 p.m.'two grab samples, one downstream and one upstream of the composite sampler, showed 3400 and 750 pCi/1, respectively. At
'6:00 p.m., two more samples taken upstream of the composite sample showed-150 and 430 pCi/1. On the basis of these results, the li-
-censee concluded that most of the radioactivity had been in the dis-charge canal for the period April 3 through April 5, 1980, and had not, as assumed on April 5, been released to the river.
Grab samples taken on April 5 and 6, 1980, indicated 1800 and 3700 pCi/1, respec-tively.
An isotopic analysis of the composite sample taken for the period April 5 through April 6,1980, indicated the results to be 22% of the Part 20 limits.
Technical Specification 3.8.C.2 states thct the concentration of gross beta activity...in the condenser cooling water discharge shall not exceed IE-7 pCi/ml (100 pCi/1) unless discharge is controlled on a radionuclide basis and in accordance with Part 20 concentration limits. Since an uncontrolled release into the discharge canal oc-curred from April 3 to 3:26 p.m. on April 5, 1980, and since the discharge from the canal to the river was not controlled, and since several grab and composite samples showed concentrations :xceeding IE-7 pCi/ml, the licensee appears to have violated the above tech-nical specification.
'To ensure that water will not be discharged into the canal in case of further' tube leaks, water from the tube side of the Unit I heat exchanger will go to the Rad Waste Storage area during the Unit I decontamination. The. licensee is also considering blocking the dis-cha.ge line.
14.
Exi. Intersiew The inspector met with licensee representatives at the conclusion of the inspection on April 9 and 18, 1980.
The following matters were discussed:
a.
The purpose and scope of the inspection.
b.
The items of noncompliance.
(Paragraph 13)
c.
_The incorporation of isotopic sampling to correlate dose rate and curie content and strontium 89 and 90 sampling into the analysis requirements for spent solvent evaporator bottoms and resins.
(Paragraph 11)
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