IR 05000010/1985017
| ML17199F629 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/07/1986 |
| From: | Greger L, Miller D, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199F628 | List: |
| References | |
| 50-010-85-17, 50-10-85-17, 50-237-85-41, 50-249-85-35, IEIN-85-042, IEIN-85-043, IEIN-85-42, IEIN-85-43, NUDOCS 8602130073 | |
| Download: ML17199F629 (11) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-10/85017(DRSS); 50-237/8504l(DRSS); 50-249/85035(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 Inspection Conducted:
December 11-13, and 16-18, 1985 and January 7-10, 1986 Inspectors:
,{
&
-;_'vt::,
1',** G., //~
D. E. Miller
- ).. /~ (
- <;/::_ i\\ i _/a~
R. A. Paul
. -r/' /l
.? /') '
Approved By: "*!7~
l. R. Greger, Chief Facilities Radiation Protection Section Inspection Summary
-*ft/?t Date '
- )1/R&
Date Inspection on December 11-13 and 16-18, 1985, and January 7-10, 1986 (Report Nos. 50-10/85017(DRSS); 50-237/8504l(DRSS); 50-249/85035(DRSS))
Areas Inspected:
Routine, unannounced inspection of radiation protection aspects of the Unit 3 recirculating system piping replacement progra Also reviewed were past open items, skin doses to discrete particles, radiological aspects of a Unit 3 torus incident, and licensee actions taken in response to selected IE Information Notice The inspection involved 141 inspector-hours on site by two NRC inspector Results:
No violations or deviations were identifie ~130073 36020]
~ ~oocK 0 5000010
,....
PIH7!
G
- .
- *
Persons Contacted
- D. Adam, Compliance Coordinator
- D. Brown, QA Supervisor, RPR Project
- J. Brunner, Assistant Superintendent, Technical Services C. Engel, Project Radiological Protection Coordinator (Combustion Engineering, Inc.)
- R. Flessner, Services Superintendent
- T. Gilman, Project Radiological Protection Coordinator
- S. McDonald, Radiation Chemistry Supervisor J. Schrage, Lead Health Physicist D. Soccomando, Health Physicist
- J. Williams, Sr. QA Inspector
- J. Wujciga, Production Superintendent The inspectors also contacted several other licensee and contractor personne *Denotes those present at the exit meetin General This inspection, which began at 8:30 a.m. on December 11, 1985, was conducted to examine radiation protection aspects of the Unit 3 recirculating system piping replacement progra Also reviewed were past open items, skin doses to discrete radioactive particles, radiological aspects of a Unit 3 torus incident, and licensee actions taken in response to selected IE Information Notice Several tours of access control and wo~k areas were made to observe and evaluate operational radiological control Licensee Actions on Previous Inspection Findings (Open) Open Item (010/83-11-02; 237/83-19-02; 249/83-17-02):
Procedure for disposal of waste oi Formal procedure is being developed; implementation projected to be by February 1, 198 (Open) Open Item (010/84017-02):
Post decontamination surveys of Unit The surveys have been complete The written final report has not been received by the license (Closed) Open Item (010/85002-01; 237/85005-01; 249/85004-01):
Commitment to not reuse respirators without contamination chec Licensee has developed policy/procedure to require a contamination check on respirators before being reused during jobs in high contamination areas and when cutting and grindin (Closed) Open Item (010/85002-02; 237/85005-02; 249/85004-02):
Adequacy of High Radiation Area barrier Barriers that are less than five fee high are being raised to a minimum height of five fee Several barriers have been raised, and work orders have been written to raise the remainder.
(Closed) Open Item (237/85005-03; 249/85004-03):
Progress in isocondenser decontaminatio The secondary side of the Unit 3 isocondenser is being hydrolazed during this extended outag Also, the licensee has reviewed the isocondenser operational modes to determine if alternate modes could preclude periodic atmospheric effluent releases; the review indicated that emergency power does not feed the bus which powers the clean demineralized water system and therefore, clean demineralized water cannot be fed to the isocondenser when offsite power is los The licensee stated that a change to the emergency power system feed system may involve an unreviewed safety question and that an extensive evaluation would be required to determine if a change is possibl (Open) Open Item (237/85005-04; 249/85004-04):
Procedure for alternate methods of effluent tritium quantificatio The licensee has developed a revised method of effluent tritium quantificatio The licensee is now collecting moisture samples on silica gel in gaseous effluent pathways, determining relative humidity, analyzing tritium content of collected moisture, and calculating quantity of tritium in the effluen Formal procedures are being developed as the techniques are being refine The licensee plans to complete and implement the procedures by April 1, 198.
Radiological Aspects of the Unit 3 Recirculating System Piping Replacement (RPR) Program The radiation protection organization and facilities remain essentially as described in Inspection Report Nos. 50-1085011; 50-237/85026; 50-249/8502 Other aspects reviewed during this inspection are discussed belo *
Radiation Protection Orientation Training The inspectors reviewed the implementation and content of the licensee 1s radiation protection orientation trainin This training is presented to all workers associated with the RPR projec The training is conducted by the station and Chicago Bridge and Iron (CBI).
General orientation training consists of lectures and tapes covering security, quality assurance, radiation and fire protection, and emergency preparedness requirement The training includes practical factor requirements such as frisking, donning and removal of protective clothing, and controlled area entry (step-off-pad) procedure Successful completion of a written examination is require Workers requiring access to the controlled areas of the RPR project received additional instruction which included mock-up training and ALAR Contract radiation chemistry technicians also received additional instructions which included station and CBI procedures and requirement These technicians were then selected for specific job functions based on their work experience, previous performance, and completion of training program *
The inspectors selectively reviewed training records, lesson plans, and examination It appears that the extent of training was commensurate with potential radiological health problems associated with the RPR project, as required by 10 CFR 19.1 No problems were note *
.Exposure Controls - Internal The program to control internal exposures during the RPR project includes engineering controls, airborne sampling and contamination surveillance, and use of approved respiratory devices and protective clothin Whole body counting is used to supplement the monitoring program to ensure its effectiveness; The engineering controls include use of portable ventilation units with HEPA filters to exhaust and clean air from areas where welding, cutting and grinding is being performe Also, the licensee is using containment tents and/or glove bags during certain pipe welding, cutting and grinding operation Entry to containment tents usually requires the use of respiratory protective equipment; the type of equipment depends on the work performe *
All persons associated with the RPR who work in controlled areas receive a base line (incoming) whole body count (WBC) and a termination WB Other WBCs may be required at the discretion of the heaith physics staff and as required by station procedure The inspectors reviewed the licens~e 1 s evaluations of followup WBCs performed on workers who were found to have facial contamination upon exit from the drywell access control are Several immediate WBCs on such individuals detected elevated quantities of radiosotopes; all detected quantities were reduced, to less than the quantities that would result from inhalation of 40 MPC-Hours, when recounting was performed over a two to four day perio The licensee believes that the elevated counts were caused by external contamination or ingested radiosotope Further evaluations are being conducted by the license The licensee is inv~stigating to determine the cause of an increased frequency of facial contaminatio Also, the licensee is performing additional training of craft personnel to inform them of the increased number of contamination incidents and to reinstruct them concerning good health physics practices in radiologically controlled area *
Exposure Control - External The external exposure measurement and control program for the RPR project consists of whole body monitoring using thermoluminescent dosimeters (TLDs), extremity monitoring using film ring badges, self-reading dosimeters (SRDs), direct radiation surveys, radiation work permits, administrative dose limits, and a radiation dose recording syste The number of TLDs and extremity badges worn and their positioning, the number and range of SRDs, and the frequency of conduct of surveys are established for each task work package and radiation work permi According to the licensee, drifting problems are being experienced
with SRDs purchased from one vendor; the licensee is attempting to acquire sufficient SRDs from other vendors so that suspect SRDs can be taken out of servic The inspectors selectively reviewed Forms NRC-4 and licensee administrative dose limit extensions for persons who exceeded 1250 millirem per calendar quarter during the fourth calendar quarter of 198 No problems were note *
Task Work Packages Task Work Packages (TWPs) are initiated by the Chicago Bridge and Iron, Inc. (CBI) ALARA Coordinato Generally, a TWP is initiated for each recirculating system piping segment to be removed or installe The TWP includes work procedures, person-hour and person-rem estimates, training requirements, checklists, ALARA related requirements, and other job related requirement Health physics and QC hold points are included in the work procedure The TWPs are forwarded to Combustion Engineering ALARA representatives for further ALARA review; comments and recommendations are worked out between ALARA representatives and coordinator A Radiation Work Permit (RWP) is written for each TWP, and is assigned the same number as the TW Dose accountability, therefore, is simplified and accuracy is enhanced.
A radiation protection technician is assigned to follow specific TWPs that are being worked during his shif The technicians follow progress of the task and assure that RWP requirements are complied with, and performs the tasks required by procedural health physics hold point These hold point tasks can include:
performance of job specific direct radiation, contamination, and airborne surveys; changes in work area isolation requirements; and changes in requirements for respiratory protectio The inspectors reviewed selected TWPs, their Associated RWPs, and the job specific direct radiation, contamination, and airborne surveys conducted during performance of the task No significant problems were note *
A LARA In preparation for the RPR, the contamination within recirculating system piping was reduced using a vendor operated decontamination process, and smearable contamination levels within the drywell were reduced by hydrolazin The recirculating system piping decontamination resulted in an average overall decontamination factor of about 1 Decontamination was least effective at the nozzles, where little or no decontamination resulte When estimating person-rem for the RPR project prior to this decontamination, the licensee used a projected decontamination factor of fiv Total dose for the project as of December 31, 1985,
was estimated to be 435 person-re For work packages that have been completed, the total dose received is slightly below the projected estimate The drywell was hydrolazed to reduce contamination levels before the first recirculating system pipe cut was mad The decontamination goal was to reduce loose surface contamination levels in general work areas to less than 10,000 disintegrations per minute per 100 square centimeters; this goal was me No respiratory protective devices are required for entry to any area where the goal was met unless work that may alter the contamination levels is, or soon will be, performe Most work involving opening a contaminated system, or work on an open system, is done within a containment tent; respiratory devices are worn inside the tent Open systems are capped when no work is being performe The RPR project ALARA Committee meets at least weekl The committee members include representatives of CECo, Impell/Combustion Engineering, and Chicago Bridge and Iro The committee reviews the ALARA aspects of ongoing and future work, current radiological problems, and progress in meeting ALARA goal An inspector attended an ALARA subcommittee meeting held to review cutting of a core spray nozzl The subcommittee appeared to be effective in performance of its intended purpos *
Radiation Protection Procedures The inspectors reviewed selected radiation protection procedures related to RPR project health physics activities to determine if they were consistent with regulatory requirements and good health physics practice No problems were note *
Tour of Unit 3 Drywell An inspection tour was conducted in the Unit 3 drywell to examine RPR project activitie The inspection included review of worker preparation for specific job functions, worker use of protective clothing, worker adherence to radiological control procedures and good health physics practices, use of installed and portable equipment to achieve ALA~A, radiation protection job coverage, and the drywell exhaust system. * No significant problems were note *
Audits The licensee assembled a combined Quality Assurance (QA) audit and Quality Control (QC) inspection group to implement the QA/QC program for the RPR project; the QA/QC program was operational before any physical work was done on the recirculating system pipin The following radiation protection and radwaste related audits have been performed by the RPR project QA group.
Q.A.A No. RPR-12-85009, performed October 23-25, 1985, was a programmatic audit of the Combustion Engineering (CE) RPR radiation protection grou The audit included a review of qualifications and training of radiation protection professionals and selected technician The audit was based on ANSI/ANS 3.1 and utility selection and qualification criteri The audit resulted in three open items; one concerned failure of CE to provide certification of the accuracy of individual resume 1 s, one concerned an administrative matter, and one concerned lack of a defined work scope for junior health physics technician These open items have since been responded to, and have been closed as acceptabl *
Q.A.A. No. RPR-12-85009, performed on November 22 through December 2, 1985, was a programmatic audit of London Nuclear Services, Inc., who performed the recirculatin system decontaminatio The audit included radiation protection, radwaste, and contamination control There were no audit finding In addition to audits, the RPR Project QA group performs surveillances of selected ongoing work including housekeeping and observable radiological work practices; these surveillances are aimed mainly at procedural complianc The QA group also performs surveillances of radioactive materials shipments; these surveillances are performed in accordance with the CECo Quality Assurance Manua The inspector reviewed the qualifications of QA auditors assigned to the RPR project QA grou Several auditors have received training in radwaste packaging and shipping procedures and regulatory requirements; these auditors are 11certified 11 by CECo to perform such audit None of the auditors are 11 certified 11 in health physic According to the RPR QA Supervisor, technical reviews and surveillances of ongoing RPR health physics work is routinely done by the station and corporate health physics staffs; however, none of these reviews and surveillances are documented as QA audits or surveillance The inspector discussed with the licensee the desireability of documenting these technical reviews and surveillance No violations or deviations were identifie.
Radiological Aspects of an Accident in the Unit 3 Torus Area At about 7:30 p.m. on December 14, 1985, the lifeless body of a contractor Quality Control (QC) employee was found in the Unit 3 torus basemen He apparently died as a result of a fall while decending a ladder from the 517-foot elevation to the top of the toru The QC employee had been logged into the area at 1:45 p.m. by another contractor employee who was assigned to implement High Radiation Area (HRA) access controls for torus entrie The QC employee was apparently alone when he descended the vertical ladder leading to the torus top; he was not seen again until 7:30 p.m. when his body was found in the torus
basemen The QC employee had been logged out of the area at 2:30 p.m.,
per the log shee During interviews, the individual who logged the QC employee out of the area stated that he did not actually see the QC employee exit the area, but made the log-out entry based on hearsay information from other contractor employee The inspector discussed with the licensee the apparent need to provide better HRA surveillance for personnel accountability purpose Since then, additional instructions have been provided to the contractor employees who implement torus access control procedure Also, the identification badges of the contractors about to enter the torus are collected and displayed on a board as an additional accountability too After the dead QC employee was removed from the contaminated torus basement, his anti-contamination clothing was removed and the body was surveyed for contaminatio About 2,000 disintegrations per minute per 100 square centimeters was detected on the back of the hea The contamination was removed before the body was removed from the statio Subsequent to this incident, NRC Region III radiation protection representatives were contacted by a licensee representative who asked what the proper procedure would be if a deceased person was contaminated and it was impractical to remove the contamination before autops The licensee was advised that if adequate radiological controls were implemented, the autopsy could be performed before decontaminating the individua Such controls would require coordination with the facility containing the autopsy roo No violations or deviations were identifie.
Plant Tours (other than RPR Project) Several tours of radiologically significant areas were made to review postings, access controls, contamination controls, and housekeepin During the tours, the inspectors observed a 11 gang 11 box containing tools stored in yellow and clear plastic bags; the box was not labelled as containing radioactive materia When asked, the licensee stated that routine surveys of 11gang 11 boxes to determine if they contain radioactive materials are* not performe The inspectors discussed with the licensee the desireability of performing contamination surveys of 11 gang 11 boxes to determine if proper labelling is provided, and if contaminated tools are properly store This matter was discussed with the licensee during the inspection and at the exit meetin The licensee stated that contamination surveys of 11 gang 11 boxes would be performed weekly when such boxes are in us (Open Item 237/85041-01; 249/85035-01).
No other significant problems were note Housekeeping appeared adequat No violations or deviations were identifie Skin Exposures by 11 Hot Particles
The inspectors reviewed the licensee 1s investigations of two incidents in which minute discrete radioactive particles were found; one on a contractor 1 s skin and one on a CECo substation employee 1 s undershir *
In one incident, the particle was found on the skin of the individual's
-,
abdomen on January 4, 198 After removal, the particle was analyzed and found to contain 64 nanocuries of cobalt 60 and one nanocurie of cesium 13 The licensee conducted an investigation of the individual's activities during the period January 2-4, 198 Prior to this time, the individual had been working only in clean area The investigation included interviews with the individual and his supervisor, review of the individual's work activities, his entries and exits from controlled areas, and his use of hand held frisker As a result of information obtained, the licensee performed radiological surveys of the individual's vehicle and residence; no activity was foun In an effort to find the source of the particle, the licensee performed surveys of selected laundered protective clothing and all areas in which the individual had worked during the period in questio During the licensee's investigation, they performed instrument response checks on PCM whole body friskers, portal monitors, and laundry monitors using the collected particl The licensee concluded that the particle was probably transferred from protective clothing onto the individual's ski During interviews with licensee representatives the individual admitted that he routinely omitted frisking after removing his protective clothing at step-off pad The particle was detected by a PCM-lA whole body frisker on the morning of January 4, 198 The individual had apparently passed through either whole body frisker booths or portal monitors approximately thirteen times on January 2 and 3, without detectio The licensee located the particle by a whole body survey with a pancake probe subsequent to the monitor alar The particle was removed and retaine The licensee placed the particle near its original location on the individual's body and had him pass through whole body friskers several times; an alarm was received about 50 percent of the tim Based on the individual's work activities and the paths he took when exiting and traversing the plant during the January 2-4 period, the licensee estimated that the maximum probable time the particle could have been on the individual's skin was sixteen hour The licensee calculated the beta-gamma dose to the skin of the whole body, averaged over one square centimeter, was less than five rem In the other incident, a particle was found near the abdomen area on the outside of the ind1vidual's undershirt on December 11, 198 After removal, the particle was analyzed and found to contain 110 nanocuries of
- cobalt 6 The licensee investigated this matter by conducting a review similar to that described abov As a result of this investigation, the licensee concluded that the particle was most likely transferred from protective clothing to his undershir The contamination was initially detected by an IRT portal monito After surveys were performed by RCTs, the particle was found and remove Based on the individuals work activities, the licensee estimated the exposure occurred for approximately seven hours and the dose to skin to was less than 1 re The inspector's review of the dose calculations indicate they were computed using acceptable dose equations, methodology and assumption Although the licensee has concluded the contaminated particles were transferred to the workers from protective clothing, they do not believe these occurrences constitute a major proble However, actions have been taken to prevent recurrence, including:
a more aggressive laundry monitoring and
surveillance program is being developed; the contractor, for whom the first individual worked, initiated a radiation surveillance support program designed to observe worker adherence to radiological controls and report violations; and discussions with contractor and supervisory personnel emphasizing the need for worker compliance with radiological control It appears that the licensee made a timely and thorough review of the incident No violations or deviations were identifie.
Station Decontamination (Reclamation) Program In May 1984, the licensee initiated a contamination control program as part of the station ALARA Program (Inspection Report Nos. 10/84017; 237/84022; 249/84020).
The purpose of the program was to decontaminate floors, walls and horizontal surfaces in the reactor, turbine and radwaste buildings to reduce the square footage in the plant designated and controlled as contamination area This program was under the direction of the ALARA coordinator, who was assigned a decontamination crew foreman and professional health physicis During this inspection, it was noted that this program had, in effect, been discontinued due to manpower and economic constraint This matter was discussed at the exit meetin (237/85041-02; 249/85035-02) IE Information Notices 1 The inspectors reviewed licensee action in response to the following selected Information Notice The actions are considered adequat No. 85042:
Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Element The licensee has recently purchased and is currently using this type of TLD; most TLDs have been read less than five time The licensee visually inspected and response checked each TLD before first us Any TLD which responds unexpectedly after use is again visually inspected and response checked; suspect badges are replace Any long term reinspection program will be based on experience gained through operational us No. 85043:
Radiography Events at Power Reactor Rad/chem personnel are
- aware of the contents of this notic A representative stated that procedure DRP 1610-3 11 Use of X-ray or Sealed Gamma Radiation Sources by Contractors
, addresses licensee actions required to oversee contractor operated radiation sources at the statio Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on January 10, 198 The inspectors summarized the scope and findings of the inspectio The inspectors also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee identified no such documents/processes as proprietar In response to certain items discussed by the inspectors, the licensee stated that:
..,
' Contamination surveys of 11 gang 11 boxes would be performed weekly if the 11 gang 11 boxes had been used since the last weekly surve (Section 6). A plan is being developed to reactivate the station contamination reclamation program (Section 8).
13