IR 05000010/1985011
| ML20137E231 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/14/1985 |
| From: | Greger L, Miller D, Nicholson N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20137E228 | List: |
| References | |
| 50-010-85-11, 50-10-85-11, 50-237-85-26, 50-249-85-21, NUDOCS 8508230176 | |
| Download: ML20137E231 (10) | |
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i U.S. NUCLEAR REGULATORY COMISSION
REGION III
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Reports No. 50-10/85011(DRSS); 50-237/85026(DRSS); 50-249/85021(DRSS)
Docket Nos. 50-10; 50-237; 50-249 Licenses No. DPR-2; DPR-19; DPR-25 Licensee:
Commonwealth. Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Power Station, Units 1, 2, and 3
' Inspection At: 'Dresden Site, Morris, IL
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Inspection Conducted:
July 15-19 and 30-31, 1985 6. e -nM&o Inspectors:
D. E. Miller-
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N. A. Nicholson T
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Approved By:
.L. R. Greger, Chief Facilities Radiation Date Protection Section Inspection Summary:
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Inspection on July 15-19 and 30-31, 1985 (Reports No. 50-10/85011(DRSS),
No. 50-237/85026(DRSS), No. 50-249/85021(DR55))
Areas Inspected:
Routine, unannounced inspection of.the radwaste management
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program including solid radwaste, training, audits, and transportation l
activities.
Also reviewed was radiation protection technician retraining, progress on repair or replacement of liquid radwaste discharge line, a sampling incident, and radiological aspects of the upcoming Unit 3 recirculating system piping replacecont program. The inspection involved 54 inspector-hours onsite by two NRC inspectors.
~Results:
No violations or deviations.were identified.
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DETAILS
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Persons Contacted
- J. Brunner, Technical Services Assistant Superintendent
- - T. Ciesla, Operating Assistant Superintendent T. Gilman, Project Radiological Protection Coordinator J. Schrage, Lead Health Physicist
- D. Scott, Station Manager D. Sharper, Waste Systems Engineer D. Soccomando, Health Physicist
- S. Mcdonald, Rad / Chem Supervisor L. Oshier, Health Physicist
- R. Stobert, Senior QA Engineer J. Thout, Waste Systems Staff Assistant The inspectors also contacted several other licensee personnel and contractors.
- Denotes those present at the exit meeting.
2.
General The inspection, which began at 8:30 a.m. on July 15, 1985, was conducted to: examine rad / chem technician retraining, and solid radwaste and transportation training for appropriate persons; solid radioactive waste unagement; compliance with solid radwaste transportation requirements; and status of the ruptured Unit 2/3 liquid radwaste discharge line.
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reviewed were radiological aspects of the upcoming Unit 3 recirculating system piping replacement program, and a sampling incident that occurred during the inspection. The inspection included several plant tours, review of posting and labeling, discussions with plant personnel, review of licensee records and reports, and independent inspection effort by the inspectors.
Housekeeping and observable radiological controls appeared good.
3.
Training The inspectors reviewed the continuing RCT retraining program and a radwaste shipping short course recently given to the radwaste engineering staff.
The DNPS training staff developed the continuing RCT training program in response to INP0 and station commitments and presented the first session in mid-July.
Four week-long sessions will be presented to all RCTs quarterly.
Four RCTs are assigned to each weekly session, the session is repeated every week-throughout the quarter to accommodate all 51 RCTs.
These sessions include lectures on topics pertinent to RCT job functions, i.e., dosimetry, procedural changes,-ALARA, etc.; also, some hands-on training for sample collection is conducted.
Training in general operations systems and associated radiological hazards and/or conditions has not specifically been included in this course.
The importance of this training, and its relevance to RCT functions, were discussed at the
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exit meeting; licensee representatives agreed to consider incorporating this training into the continuing program.
Seven RCTs have completed this quarter's training.
Tests given reflected the presented material; all were passing scores (>70%).
Retests would be taken by those with failing scores after the material has been reviewed with an instructor.
No problems were noted.
A contractor conducted a three-day course on radwaste shipments for all DNPS radwaste engineers.
Material addressed included current 00T, NRC, and burial site regulations.
A complete reference manual with course materials and regulations was provided to the attendees.
Attendees interviewed by the inspector stated the course was beneficial to their job functions.
No violations were noted.
4.
Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifica-tions; experience concerning identification and correction of programmatic weaknesses; and training.
Audits and training are discussed in other sections of this report.
Since early March 1985, most solidification has been done onsite by a vendor using portable solidification equipment.
The licensee feeds wet radwaste (resins, evaporator bottoms) to the vendor's system where cement and other solidifiers are mixed with the wet radwaste in a fill head atop a steel liner in a shield cask; mechanical mixing is done in the liner.
Process flows to the liner and curing temperatures are monitored.
Completeness of solidification is observed before shipment.
The vendor has several shield casks onsite in which the liners are filled and stored to cure.
The liners are transferred to shipping casks for transport to a burial site.
The inspector reviewed Special Procedure 85-3-28 " Transfer, Solidification, and Transportation of Floor Drain Surge Sludge and 2/3 Radioactive Waste with CNSI Mobile Solidification." Also reviewed were CNSI operating, process control, and assembly and disassembly procedures.
The station and CNSI procedures had been reviewed and accepted by the Dresden Onsite Review Committee.
A 10 CFR 50.59 review of the special procedure was performed; special mention was made in the review of the use of double wrapped hoses and blocking of local drains.
No significant problems concerning the procedures or the licensee's reviews were noted.
The inspectcr toured the area where the vendor solidification equipment (
is being used; the area is adjacent to the Unit 3 turbine building and
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the radwaste building.
The area was properly posted and access controls appeared adequate.
The feed and decant hoses to the fill head consisted of a hose within a hose; the outer hose was designed to contain leakage of radioactively contaminated materials bein'g supplied to the fill head.
The vendor has placed leak detectors between the two hoses to provide early detection of leakage.
The inspector noted that the storm sewer manhole located in the area is blocked; the licensee stated that any accumulated rainwater is sampled before being released to the storm sewer.
The licensee stated that use of the solidific' tion vendor, and the a
station site, was considered temporary.
If the licensee decides to use vendor solidification long term, a more permanent site will be found.
The licensee has performed a cost / benefit analysis of use of vendor solidification instead of the installed equipment; the analysis does not include the cost of operating and maintaining the installed system.
No ALARA benefit analysis has been performed.
The inspector discussed
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with the licensee the desirability of performance of a thorough cost and dose benefit analysis of use of vendor solidification.
This matter was discussed at the exit meeting.
The licensee is maintaining the installed solidification equipment in readiness for use.
A modification to put television cameras in the-drumming. unit has been delayed pending a decision concerning future use of the solidification equipment.
No violations or deviations were noted.
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Audits and Appraisals The inspector reviewed reports of audits and appraisals conducted by the licensee including audits required by the technical specifications.
Also reviewed were management techniques used to implement the audit program,
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and experience concerning identification and correction of programmatic weaknesses.
The inspectors reviewed the licensee's annual audit of radwaste activities (12-85-20) conducted during May and June 1985.
The audit included compliance with 10 CFR 20, 10 CFR 61, 10 CFR 71, and 49 CFR 173 requirements, and implementation of station procedures.
Audited were shipping manifests, waste characterization and classification documentation, records retention, possession of current regulations and buri'al site requirements, designations of responsible individuals, package surveys and quantity calculations, and cement quality.
Also audited were quality assurance visual inspections and impact tests of vendor. solidified liners.
The auditor was qualified by training and experience to conduct the audit.
There were no audit findings or observations.
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No violations or deviations were noted.
.6.
Transportation Activities The inspector reviewed the licensee's transportation activities, including:
verification that clearly defined management authorities and responsibilities exist; verification that an acceptable training program is in place for persons involved in transport activities; determination whether an NRC approved Quality Assurance program has been implemented; determination whether procurement, selection, preparation and delivery of packages is in compliance with NRC and 00T regulations and the licensee's quality assurance program; determination whether receipt of and periodic maintenance of packages are in compliance with NRC and 00T regulations; adequacy of required records, reports, shipment documentation and notifications; and experience concerning identification and correction of programmatic weakness. Quality assurance and training are discussed in i
other sections of this report.
Shipments of low specific activity (LSA) waste to licensed burial sites (
are the major transportation activity.
Contaminated solid trash (paper, plastic, wood, metal, discarded clothing, etc.) is either packaged in
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55 gallon steel drums and compacted, or packaged in large metal boxes if the materials are not compactible.
00T Specification 17-H drums are used which meet the 00T 7-A performance specification.
The metal boxes are
supplied by a vendor.
Liquid wastes consisting of resins and evaporator
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bottoms are being solidified onsite by a vendor.
Use of the installed solidification equipment has been suspended pending a decision concerning
. future use of the equipment.
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The inspector reviewed the licensee's procedures for transportation of
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l radioactive material.
The procedures are current with respect to burial
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site criteria and NRC/ DOT regulations. Most cask maintenance is performed by the onsite contractor. The licensee's procedures require confirmation that package maintenance has been completed before shipment.
No problems were noted.
Records of radioactive shipments made during 1985 were selectively reviewed for compliance with 49 CFR 172-173 and 10 CFR 71.
Quality assurance surveillance of these shipments were also reviewed.
No problems were noted.
No violations or deviations were identified.
7.
Liquid Radioactive Waste Discharge Line i
The breached Unit 2/3 liquid radwaste discharge line, and temporary use of soft pipe to connect the Unit 2/3 discharge system to the Unit 1 l
discharge system, is discussed in Inspection Reports No. 50-10/85008; 50-237/85022; 50-249/85018.
The licensee has decided to install a new
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discharge line in a new trench; the new line will be of noncorrosive f
pipe.
The licensee plans to have the line installed and in use before l
winter.
The licensee will discuss disposition of the old line and
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associated contaminated soil with NRR.
This matter will be reviewed
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further during a future inspection.
(0 pen Item 237/85026-01; j
249/85021-01)
l No violations or deviations were noted.
8.
Sampling Incident On July 18, 1985, The Rad / Chem Department discovered that samples had been collected that day from the Unit 1 chemical cleaning system spent resin tank without rad / chem being notified.
The Type I Radiation Work Permit-(RWP) for routine activities in the D-1 chemical cleaning building did not include resin sample collection.
Therefore, a Type II RWP, which requires RCT contact for radiological precautions, should have been completed.
Two 500-milliliter resin san.ples had been collected by a member of the Unit 1 Chemical Cleaning Group at the request of a waste systems staff assistant.
No samples had been collected from the tank for several months; several additions to the tank had since been made.
Therefore, there was no predetermined estimate of radiation dose rates expected during sample collection.
Additionally, the sample collection area was not appropriately posted to alert personnel of the potential radiological hazard or the need for a Type II RWP.
The samples were found to read about 6 millirem per hour.
The licensee informed the inspector of the incident, conducted a thorough investigation, and instituted adequate corrective actions.
This matter is considered licensee identified and corrected.
No inspector identified violations or deviations were noted.
9.
Radiological Aspects of the Unit 3 Recirculation System Piping Replacement (RPR) Program The licensee plans to replace major portions of the Unit 3 recirculating system piping during the next outage, which is scheduled to begin on October 27, 1985.
The outage duration is expected to be about eight m3nths.
Other major tasks to be performed during the outage include replacement of the reactor vessel drain line, and torus cleaning and coating.
Organization, facilities, health physics related equipment and training, and ALARA concerns are discussed below.
Radiation Protection Organization The radiation protection organization being formed is as described in the licensee's Project Radiation. Protection Plan, Revision 5.
The organization chart is presented in the figure attached to this report.
The Project Radiological Protection Group (PRPG) is being formed to provide ALARA engineering support and radiological controls for the RPR project.
The PRPG will be staffed by CECO, Combustion Engineering (Impell Corporation), Chicago Bridge and Iron (CBI)
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Company, and health physics contractor personnel.
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All positions below the Station Project Health Physicist (SPHP)
are, or will be, filled by contractors.
The Project Radiological Protection Coordinator, Operations Health Physics Supervisor, ALARA Supervisor, and CBI ALARA Coordinator positions are currently filled.
The persons who occupy the above positions appear qualified to hold the positions; they are employed by Combustion Engineering or Impell Corporations.
The contractor who will provide / perform the operational radiation protection function is yet to be selected; the licensee is requiring that half of the senior radiation protection technicians have previous RPR experience.
The licensee estimates that 75 technicians plus several supervisors will be needed.
The licensee has not determined which contractor will perform the record keeping function.
Training Introductory Nuclear General Employee Training for all workers and supervisors is being provided by the station training department.
Supplemental training for radiation protection technicians and supervisors is to be provided; a training outline has been developed and the training manual is being written.
Supplemental training for crafts persons is being planned; it will be reviewed during a future inspection.
Facilities Two permanent and one temporary buildings are being constructed, and an access / egress facility composed of trailers will be put in place and equipped; these buildings / facilities are to be used in support of the RPR project.
A two-story Process Building is being built outside the security fence.
This building is to house an NGET classroom, mask fit facility, security classroom and offices, dosimetry irradiation room, TLD office, and a welder's qualification area.
This building is designed for continued use after completion of the RPR project.
A two-story Construction and Pipe Fabrication Building is being
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built inside the security fence about 150 feet from the Unit 3 reactor building.
The building is to house CECO, contractor, and subcontractor offices for those involved in the project. The majority of the building space is a pipe fabrication area.
This building is also designed for continued use after the RPR project.
A temporary airlock access building is being built at a Unit 3 reactor building equipment access door.
This building will be used to maintain secondary containment integrity while taking piping, materials, and equipment into and out of the reactor building.
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o An access / egress facility is planned to be placed at the Unit 3 reactor building personnel access door. The facility will consist of one double-wide and four single-wide trailers.
The double-wide trailer will be the access / egress point with RWP and health physics offices, a. respirator issue booth, a personal decontamination /
monitoring room, and exit personal monitoring equipment.
The licensee plans to install five Eberline PCM-1A portal monitors and a frisker station.
Primary frisking will be done in the reactor building before arrival at the access / egress facility.
The four single-wide trailers are for a walkway with storage, and clothing change areas.
ALARA The ALARA program management will be performed by contractors using station / utility procedures. The ALARA group will be mainly independent of the stations ALARA group.
The licensee plans to perform recirculating system piping chemical decontamination and drywell decontamination before the RPR begins.
The licensee hopes to reduce general contamination levels in the drywell low enough that respiratory protective devices will not be required except during performance of certain tasks.
To aid in monitoring / observation without acceptance of unnecessary dose to radiation protection technicians and craft worker supervision, the licensee has:
Obtained six television cameras and associated monitors and
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recorders for remote observation of work.
Purchased 30 telemetric dosimeters for remote indication of
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accumulated dose.
Specific use is yet to be determined.
Staffing of unfilled ALARA positions, interfaces between ALARA related organizational positions / functions, and programmatic details will be reviewed when the program becomes functional.
Dosimetry The licensee plans to implement a TLD whole body dosimetry program j
before beginning the operational RPR programs; TLDs will replace the l
currently used film badges.
During discussions with licensee personnel, the inspector was informed that several details and decisions concerning TLD program implementation were yet to be developed / determined before the program is ready for implementation.
These details / decisions include administrative, technical, hardware, and facility subjects.
Licensee representatives stated that higher priority operational health physics tasks have reduced the time available for appropriate technical persons to finalize these aspects of the TLD program to date.
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.The inspector discussed with the licensee during the inspection and at the exit meeting the need to expedite preparations for TLD program implementation to ensure adequate program quality.
No violations or deviations were identified.
10.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
on July 19, 1985, and at the conclusion of the inspection on July 31, 1985.
The inspectors summarized the scope and findings of the inspection.
The inspectors also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee identified no such documents / processes as proprietary.
In response to certain items discussed by the inspectors, the licensee:
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Acknowledged the inspectors' comment-concerning the desirability of performing a thorough cost / benefit and ALARA benefit analysis of using vendor solidification services instead of the installed solidification equipment (Section 4).
b.
Acknowledged the inspectors' comment concerning the need to expedite TLD program implementation preparations (Section 9).
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