IR 05000010/1997020
| ML20212F754 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 10/30/1997 |
| From: | Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212F732 | List: |
| References | |
| 50-010-97-20, 50-10-97-20, 50-237-97-20, 50-249-97-20, NUDOCS 9711050080 | |
| Download: ML20212F754 (22) | |
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, U.S. NUCLE.AR REGULATORY COMMISSION REGION 111 Docket Nos: 50 10;50-237; 50-249 L "
License Nos: DPR-02; DPR 19; DPR 25 Report Nos: 5010/97020(DRS); 50 237/97020(DRS);
50 249/97020(DRS)
Licensee: Commonwealth Edison (Comed)
Facility: Dresden Nuclear Station, Units 1,2 and 3 o
Location: 6500 N. Dresden Road Morris, IL 60450 Dates: September 1519 and 30, and October 2,1997
Inspectors: R. Paul, Senior Radiation Specialist W. Slawinski, Senior Radiation Specialist S. Orth, Senior Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety
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9711050080 971030 PDR G ADOCK 05000010 PDR
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EXECUTIVE SUMMARY i
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Dresden Generating Station Units 1,2 & 3 {
NRC Inspection Reports 501007020; 50 237/97020; 50 249/97020 '
This inspection consisted of a review of the chemistry and radiological enviror. mental monitoring !
programs and the liquid and gaseous effluent control program. Also reviewed was a recent :
incident involving Unit 1 decommissioning work that resulted in a smallintake of radioactive material to several workers and other selected Unit 1 activities. The inspection resulted in the following conclusions: i
- The radiological environmental rnonitoring program (REMP) was well implemented, t Field performance of the contractor technician was good, and the Individual exhibited a !
thorough knowledge of the sample stations and collection processes. Station involvement and oversight of the program was found to be appropriate (Section R1,1). !
Chemistry technicians and other chemistry staff demonstrated good analytical techniques, radiation protection practices and a working knowledge of systems and ,
processes. Technician performance, however, was mixed and included procedural :
compliance problems caused by the failure to consistently implement the Stop/Think/Act/ Review process. Two exampies of a procedural adherence violation :
were identified during the performance of chemistry sampling activities (Section R4.1).
The overall chemistry organization has remained relatively stable with some exceptions; however, continuity in oversight of certain areas of the program may have been ,
adversely affected by shifting staff assignments (Section R6).
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The station implemented adequate mechanisms to audit and self assess the chemistry and radiological environmental monitoring programs. Audits and assessments were properly focused, relatively thorough and covered a variety of program areas (Section R7.1).
The inspectors observed strengths in the water chemistry control program. The licensee was effective in reduc!ng feedwater iron concentrations, while minimizing the concentration of other corrosive impurities (Section R1.2).
The chemistry staff maintained a good quality control program for the laboratory and in- ,
line instruments. However, the inspectors identified some problems concerning the timeliness of supervisory review of quality control data (Section R2.1).
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A violation was identified concerning the failure to adequately implement the post accident sampling system (PASS) operability procedure by not performing required survelttances (Section R2.2).
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The liquid and gaseous effluent monitoring and control program was effectively 1 implemented. Radioactive releases were well below the regulatory permissible limit ,
Surveillances were performed on Technical Specification (TS) required monitors, and the results satisfied the TS criteria. However, operability problems with certain effluent +
monitors continued (Section R1.4).
The surveillances for the engineered safety feature filtration systems met test ecceptance criteria. The test results were within the TS limits and were performed usirs proper industry standards (Section R2.3).
- The Unit i staff understood the purpose and intent of the problem identification form (PIF) process and acknowledged that the station encourages its use; however, there was some reluctance to issue PlFs for a variety of reasons (Section R7.2).
- Station management stopped all planned work evolutions for Unit i because of degraded work performance related to poor radworker practices (Section R7.2).
- The licensee's immediate response to a Unit 1 intake incident was appropriate and included the suspension of all Unit 1 work, pending a review of work packages that involve radiological activities. The licensee was in the process of conducting a comprehensive evaluation to determine the root cause of the incident, to assess worker dose, and to determine the overall adequacy of radiological controls at the station (Section R1.3).
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Reoort Details
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IV. PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls i
R1.1 imDlt01entation of the Radioloalcal Environmental ffon[lotng_Emgam [D30ection Scone flP 84750)
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Inspector review of the radiological environmental monitoring program (REMP)
consisted of a physica! examination of several environmental sampling stations; observation of a contractor technician perform!ng sample collection, changeout and a pump flow meter calibration check; interviews with station staff regarding the sampling program; and a review of the annual radiological environmental operating report (AREOR) for 1990. The radiological environmental monitoring contractor's sampling procedure manual and rotameter and sampling pump quality control documents were also selectively reviewed, Observations and Findings All sampling stations examined by the inspectors were properly equipped and in good working order. Data posted at the sampling stations showed that sample pump calibration checks were performed monthly as specified in the contractor's sampling procedure rnanua The inspectors accompanied the contractor samole technician to several sample stations and c,bserved co!!ection and changeout practices to be technicall'
/ sound and in accordance with ths sampling procedure. Sampling techniques were based on good field practices and were repeatable. Sarnples were packaged and uniquely labeled to allow proper identification and prevent cross contam! nation. Required sample flow and leak checks were appropriately conducted, as was the calibration check of a pump flowmeter which the technician demonstrated at the inspectors' reques Review of the AREOR for 1996 revealed that sample collection and analyses were conducted in accordance with the offsite dose calculation manual (ODCM) and Technical Specifications. Deviations in the sampling program were noted in the repor REMP data for 1996 Indicated no significant impact to the environment from plant operation Review of both field and master rotameter calibration records showed these instruments to be calibrated at required intervals. Scheduled sample pump maintenance also appeared to be appropriately completed as evidenced by station record .
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- Conclusions
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The REMP was wellimplemented. Field performance of the contractor technician was !
good, and the Individual exhibited a thorough knowledge of the sample stations end collection processes. Station involvement and oversight of the program was found to be appropriat '
R1.2 Plant Water Chemistry Control Insoection Scooe UP 84750)
The inspectors reviewed the licensee's managernent of water chemistry including the program to mitigate impurilles h the systems. Included was a review of the licensee's trending and analysis of chemistry parameters for the period of September 1996 through September 1997, a review of procedure DCP 2118 01, * Reactor Water," Revision 08, and discussions with the lead chemist regarding planned enhancements to the water chemistry control progra Observations and Findings The licensee's water chemist;y program was well implemented and coincided with industry guidelines for minimizing the concentration of corrosive agents and radiation source term buildup. On Unit 2, the licensee injected both hydrogen and zinc oxide into the reactor coolant system to decrease corrosion and radioactive source term, respectively. The inspectors noted that the staff maintained a steady level of both additives in the reactor coolant, consistent with industry guidance. The lead chemist indicated that the staff planned to initiate the additive injection process on Unit 3 during the fall of 1997. The plant staff continued to use low cross linked lon exchange resins in three of the seven condensate domineralizers to reduce the feedwater iron concentration in addition, the staff had optimized condensate domineralizer operation and ultrasonic resin cleaner operation to minimize the input of contaminants into the reactor coolant when ion exchange resins were returned to service. Consequently, the inspector noted that the concentration of feedwater iron was routinely about 1 to 2 parts per billion (ppb)(Unit 2) and 2 to 3 ppb (Unli 3), which was in the range of the industry median (about 2.7 ppb), The licensee plans to replace the ultrasonic resin cleaner system with a state of the art resin clear er system next yea The licensee effectively maintained control of reactor coolant chemistry in both unit The concentration of chloride in the reactor coolant for both units was maintained between 0.3 to 0.4 ppb, well below the industry median of about 0.6 ppb. In addition, the concentration of sulfate was maintained between 0.5 and 2 ppb, generally below the industry median of about 1.9 ppb. The inspectors noted that the licensee promptly resolved elevated chemistry trends, in addition, the chemistry staff summarized the monthly chemistry parameters and provided a comprehensive analysis of trends.
( The licensee's radiochemistry data did not indicate any fuel integrity problems. The inspectors did not note any increases in the reactor coolant radiolodine activity nor any
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change in the radioiodine ratios. Additionally, the licensee had not detected any gross indications of a failure in fuelintegrity, Conclusions The inspectors observed strengths in the water chemistry contro! program. The liconace was offective in reducing feedwater Iron concentrations, while m'nimizing the concentration of other corrosive impuritie R1.3 Mo!t 1 Intake incident Inspection Scoce flP 83750)
The inspectors conducted a preliminary rev!ew of the circumstances surrounding a sel revealing event in which several workers had a smallintake of radioactive material, while conducting work in the Unit 1 tank vault on September 30,199 OhcIyahos and Fhdings On September 30,1997, severalindividuals including a pipefitter and electrician were working in the Unit 1 radioactive waste (redwaste) tank vault, preparing the area for subsequent decontamination activities in support of the overall Unit i decornmiss!oning project. A Unit 1 radiation protection technician (RPT) was responsible for job coverage in the vault area. The tanks are located in the Unit i underground vaults and were formerly used to store and process wastes generated during Unit 1 operations.
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Pre job surveys showed general work area beta / gamma smearable contamination levels ranging between 10,000 and 100,000 disintegrations per minute (dpm)/100 square centimeters, with isolated spots of elevated contamination. Low leve!s of alpha smearable contamination was present up to about 400 dpm. Low levels of airbome ,
radioactivity (about three derived air concentration (3 DAC) beta / gamma and 1.5 DAC aipha) were detected in an air sample collected during the work activities. Protective clothing was worn by the workers; however, respiratory protection was not prcvide After completing the work, a pipefittor and one of the electricians alarmed the personnel -
contamination monitor at the radiation protection control poht, prompting an investigation by the licensee. Whole body counts taken of allinvolved workers on September 30,1997 and Octcber 1,1997, showed a maximum intake of less than 0.1%
of the 10 CFR 20 annual limit of intake (All) for identified gamma emitting radioactive material. Focal samples were collected from severat involved workers and have been sent to the licensee's contractor laboratory for alpha analysis. Followup whole body counts performed several days after the incident were negativ The licensee's initial review of the incident conducted between September 30,1997, and October 1,1997, identified potential problems concerning the pre-job briefing and the engineering controls used to limit the production of airborne radioactivity. A root cause investigation was promptly initiated and was being conducted by a member of the
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licensee's corporate organization. As of the end date of the inspection, the licensee's dose assessment was continuing and will not be completed until fecal sample results l are obtained from the contract laboratory. The laboratory results s's expected in 1 approximately four to six weeks. The licensee's root cause analysis and dose e assesent will be reviewed during a future inspection (Unresolved item No. 50- ;
- 237/97020 03 and 50-249/97020-03).
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As a result of the incident, on October 2,1997, the licensee suspended all Unit 1 work to conduct a re review of all pending work packages and associated radiation work permits. Additionally, on October 3,1997, a radiation protection work control team '
comprised of corporate and Dresden and Zion station personnel w6s assembled and initiated a broad scope review of the radiological controls in place for work at the statio The objective of the assessment, whic:h !s expected to be completed on October 10, 1997, is to determine the adequacy of controls implemented eat the station and to ensure that raolological we.k in each of the units meets regulatory and site expectations, CQoclusions Tne I;censee's immediate response to the incident was appropriate and included the suspension of all Unit 1 work, pending a review of work packages that involve radio'ogicci activ;iles. The licensee is performing a comprehensive evaluation to determine the root causes of the incident, to assess worker dose, and to determine the overall adequacy of the radiological controls at the stat!o R Llauld and Gaseous Radunia InsoectionJcone 84750)
Inspector roview of the liquid and gaseous radwaste program included observations of the operational condition of effluent monitors and controlinst,'uments and review of monitor availability and calibration records, procedures, radwaste discharge permit recorda and procedures, and effluent results. Dose quantification methodology and technical documents used to determine compliance with effluent requirements were also reviewe Seiected documents reviewed included:
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- DRP-2000-04 "Off Gas Radiation Monitor Calibration," Revision 6;
- DRS 2000 03 "Dresden Unit 1 SPING Fuel Storage Fuel Pool Calibration,"
Revision 5;
- DRS 582156 " Unit 1 18M T/S Effluent SPING 4 Calibration," Revelon 0;
DRP o82127 " Unit 2/3 Quarterly T/S GE Plant Chimney Monitor Calibration,"
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- DRS-5830-01 " Unit 2/3 Uquid Discharge Monitor Calibration," Revision 0; and
- DRS-582156 * Unit 2/3 T/S Reactor Building Vent SPING Calibration,"
Revision 1 Obsmyations and Findinas The licensee's liquid and gaseous effluent systems remained as described in the ODCM and the final safety analysis report (FSAR). River discharge releases were prepared in accordance with procedural requiroments, properly quantified, and sufficiently reviewed before releas The inspectors confirmed that the quantification of gaseous releases was completed in accordance with appropdato procedures and that offsite doses and effluent release monitor set points were calculated using ODCM methodolog Calibration and setpoint documents incorporated technically sound guidance to determine proper set points and perform calibrations. Calibration of the TS gaseous erIluent monitors were previously accomplished using National Bureau of Standards (NBS) primary (gas and liquid) sources to establish efficiencies and demonstrate linearity; subsequent calibrations used secondary sources. Calibration of the liquid waste monitors were performed using calibration phantoms containing traceable quantities of radioactivity. No problems were identified with the functional test and calibration data for gaseous and liquid effluent monitoring systems. Calibrations and tests were performed in accordance with approved procedures During walkdowns of the station and the control room, the inspectors verified that area radiation and effluent monitors and associated read out systems were in good operating conditio Operability problems with the Unit 2 service water monitor and the Unit 2/3 main chimney system particulate lodine and noble gas (SPING) monitor continued. Although availability improved in 1997, the Unit 2 service water monitor just recently reached 90 percent availability. Several problem identification forms (PlFs) have been written on the causes of the problems, and the licensee has recently begun corrective actions to improve monitor performance. These actions include the need for an improved sample collection system for the Unit 2 service water monitor, maintaining a dedicated system engineer for the radwaste effluent monitors, and improvement in the maintenance of SPING alarms, seals, and pump During plant walkdowns, the inspectors observed that the material condition of the effluent monitors and associated read out systems was good with few work request j tags. The effluent monitor system's radiation protectiun engineer was knowledgeable of the system and its operating parameter Personnel responsible for generating the annual radioactive effluent reports were knowledgeable of the process and were effectively tracking effluent activity released.
- The total activity released in 1956 remained low and was well below applicable l regulatory requirements.
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Overall, the liquid and gaseous effluent monitoring program was effectivel/
implemented. Dose to the public from radioactive releases was well below the regulatory permissible limits. Survell!ances were performed on TS required monitors, and the results indicated the TS criteria were mot. However, operability problems with the Unit 2 service water monitor and the Unit 2/3 main chimney monitor continued. The lleensee has init!sted corrective actions to improve performanc l R2 Sta.us of PR&C Facilities and Equipment R Quality Control of Laboratory and in-line Chemistry Instruments InsoectionScooe flP 84750)
The inspectors reviewed the licensee's quality control program for both laboratory and l In line instruments. Implementation of the following procedures was reviewed:
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DCP 1009-02, "In-line Chemistry Instrument Quality Control," Revision 03; e
DCP 1017-01," Laboratory Quality Control," Revision 04; and
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DCP 1017-04," Counting Room Quality Control," Revision The ;nspectors also reviewed the licensee's maintenance of instrument control charts and 1996 and 1997 Interlaboratory program result Observations and Findings The preparation, labeling, and storage of reagents and calibration standards was found to be acceptable. The inspectors did not identify any chemicals which were improperly labeled or which had been used beynnd their expiration date. No instances of incompatible chemicals were observed to be stored in common location Performance tests for the licensee's ana!ytical and radiochemistry laboratory instruments and in-line instruments were appropriately performed. The inspectors observed that the chemistry technicians took the required actions when performance tests did not meet acceptance criteria. The chemistry staff properly maintained instrument control charts, which tracked normal instrument response and statistical distnbution of performance test data. The laboratory chemist reviewed control charts as required and documented any statistical biases noted. Althcugh not required, procedure DCP 1017-01 recommended that the staff perform a monthly statistical analysis of the analyticalinstrument control charts. Due to personnel changes and department priorities, the chemistry staff had discontinusd the monthly analyses. The lead chemist indicated that he planned to reinstate the analysis after the newly assigned individual had completely assumed responsibilities for the area. Although the monthly reviews had not been performed, the inspectors did not observe any problems concerning instrument performance trend .
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The chemistry staff tested in-line instruments as required and took corrective actions for i instruments not meeting the stated acceptance criteria contained in procedure DCP i 1009-02. However, the inspectors noted that several supervisory reviews were not 1 documented in a timely manner. For example, the applicable chemistry supervisor did j not review several of the January 1997 in-line instrument data sheets until Julie of 1937. ,
In addition, the inspectors noted that certain data sheets for June 1997 did not appear to l have been reviewed as of September 17,1997. The lead chemist acknowledged the i inspectors' observations, attributed the problems to changes in chemistry supervisor
assigninents, and planned to ensure that supervisors were knowledgeable of their responsibilities. S!milar review problems were noted with the post accitient sampling system survel!!ances, as described in Section R The licensee performed well in the interlaboratory program for both analytical and radiochemistry analyses. With the exception of gross alpha and beta liquid analysas in the thiro quarter of 1996, the licensee's results wera in excellent agreement with the vendor laboratory and were generally within 10 percent of the vendor's value. The inspectors verified that subsequent analyses for alpha and t; eta activity performed in 1997 were in excellent agreement, Cottclusions The chemJstry staff maintained a good quality control program for the laboratory and in-line instruments. However, the inspectors identified some problems conceming the timeliness of supervisory review of quality control dat R2.2 Post Accident Samolina System Maintenance and Surveillance P.cogram Insoection Scorse (IP 84750)
The inspectors reviewed the licensee's program to ensure the operability of the post accident sampling system (PASS). The inspectors reviewed the licensca's quality control program required by procedurs DSBP 1000-37,"HRSS [high radiation sampling system) Operability Program," Revision 02. In addition, the inspectors observed a chemistry technician conduct a boron performance test of the in line ion chromatograp ObservaliQas.and Findinas The inspectors identified problems concerning both the perfonnance and dccumentation of PASS operability tests required by procedure DSBP 1000 37, which requires quarterly and yearly tests of the system. The chemistry group had difficulty locating several quarterly and yearly survell!ance test records for 1995 and 1996. When test results were located, some showed that tests were incomplete, while others lacked documented supervisory reviews or the reviews were conducted long after the tests were completed As dicussed in section R6, these problems appear to have been caused by a lack of continuity in oversight within the chemistry organizatio .
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The chemistry staff could not locate records or analysis results for certain yearly reactor coolant comparison samples obtained at the PASS and those obtained at the routine sampling panels, as required by DSBP 1000-37. For Unit 2 no records or data was available to demonstrate that sample panel comparisons were performed in 1995 and
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1996. In addition, records indicated that the January 22,1996, isotopic analysis for the Unit 2 shutdown cooling sample point was accredited for both the 1995 and 1996 yearly surveillance. Also, certain Unit 2 yearly surveillance data generated in early 1995 and early 1996 and Unit 3 data generated in early 1000 did not have documented supervisory reviews performed until September 1997. Although not required by the surveillance procedure, chemistry supervision's normal practice was to expeditiously review tho results of the surveillance tests and document completion of that review at a pre-designated location on the surveillance record. During the inspection, the licensee performed the comparison of samples obtained from the Unit 2 PASS and the routine sample panel, the results were within the cr!!eria specified in DSBP 1000-3 Technical Specification 6.8.D.3 requires the licensee to implement a PASS program, which ensures the capability to obtain and analyze reactor coolant, radioactive lodines and particulates in plant gaseous effluents, and primary contalnment atmosphere samples under accident conditions and which includes procedures for sampling and analysis. Procedure DSBP 1000-3/ requires the licensee to perform and document yearly surveillances, which include the comparison of grab samples obtained from the reactor water filter inlet and reactor recirculation loop B at the post accident sampling system panel and routine sample panel. The failure to complete the yearly surveillance; for Unit 2 in 1995 and 1996 as required by DSBP 100-37 is a violation of Technical Specification 6.8.D.3. (Violation Nos. 50 237/97020-02 and 50-249/97020-02).
On September 17,1997, the inspectors observed a chemistry technician perform a performance test of the PASS in-line ion chromatograph. The technician demonstrated good procedure adherence and was knowledgeablo of the PASS and associated i..strumentation. However, the pump on the ion chromatograph developed a leak, which resulted in an unacceptable test. The technician properly identified the problem and notified chemistry supervision. On the following day, the staff repaired the instrument and performed an additional test, which was within acceptance criteria. The inspectors noted that the technician's response was appropriate, c. Conclusions A violation was identified conceming the failure to complete the yearly surveillances required by the PASS operability procedure. The inspectors also identified PASS surveillance record review and niaintenance problems. Chemistry technicians demonstrated good performance in resolving a problem with the PASS in line ion chromatograp .
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R2.3 Enaineered-Safetv-Fa=' ore Filtration Systems ! Insoection Scoce (84750) ,
The inspectors reviewed the latest test results of the TS and non-TS requ' red engineered safety featured atmosphere cleanup filtration and absorption unit l Walkdowns of the systems were also performed, Obtervations and Findinas The tests included in-place charcoal adsort>er leak tests, charcoal canister lodine adsorption tests, and in place high efficiency particulate air (HEPA) filter tests. Charcoal ,
and HEPA filters for the technical support center and the high range sampling system building were tested to the same standards as those for the TS control room and standby gas systems. Test acceptance criteria was met for the inplace leakage testing (DOP testing of HEPA filters and freon testing of charcoal adsorbers) and for the ;
laboratory test criterion for carbon 6, ample removal efficiency for methyl lodid During plant walkdowns, the inspectors noted that the above systems were maintained in good material conditio Conclusions Surveillances for the engineered safety feature filtration systems were completed as '
required and met test acceptance criteria. Test results were within the Technical '
Specification lim lts and were performed using proper industry standards, R4 Staff Knowledge and Performance in RPAC R Worker Performance and Practiefts Insoection Scope (IP 84750)
The inspectors accornpanied two station chemistry technicians (cts) and the contractor environmental monitoring techn;cian during the collection and processing of various samples. The inspectors observed the individuals conduct these routine sampling activities and evaluated their knowledge of the program and adherence to procedures and good practice Observations and Findines As discussed in Section R1, performance of the contract technician responsible for collecting environmental samp!es and for maintenance and quality control of the monitoring stations was good. The individual was knowledgable, displayed a sense of ownership of the program, and exhibited good sample collection technique .
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On September 16,1997, the inspectors accompanied a CT during the performance of routine Reactor Building vent sampling. The inspectors witnessed the collection of the Reactor Building vent SPING sample and non SPING particulate and lodine filter collection and changeout. The CT demoristrated good analytical techniques, radiation protection practices and knowledge of the system; however, the individual did not follow each step of the sampling procedure in the seouence specified. While retuming the Unit 3 Reactor Building vent non SPING monitoring system to service after filter changcout, J the CT misaligned the valves on the two sample pumps and started the pump moto Specifically, contrary to the Reactor Building vent sampling procedure, the inspectors observed the CT start the sample pump motor prior to closing the inlet valve of the previously operating sample pump and opening the inlet valve of the pump to be placed in service. After questioned by the inspectors and no air flow was evident through the system, the CT realized the mistake and manipulated the eppropriate valve On September 18,1997, the inspectors acccmpanied another CT during the collection of a reactor water sample from the Reactor Building sample panel. Like the CT accompanied earlier during the inspection, the individual demonstrated pood analytical techniques and knowledge of the sample panel system, including knowledge of procedure requirements and expected concentrations found in the coolant sample. The individual also demonstrated good contamination control and radiation protection practices, including use of a radiation detection instrument to monitor tne sample panel and withdrawn sample. However, contrary to the sampling procedure, both the CT and inspectors noted that the sample panel drain valve was open while the technician was preparing the panel for sample collection. The panel drain valve drains to the Reactor Building equipment drain tank and is required to be closed after sample withdrawal to prevent drain backup and panel sink contamination. The inspectors later leamed that a different CT collected a samp!e from the panel during the night shift earlier that day or during the evening of September 17,199 Although the fa:!ure to close the sample panel drain valve could have potentially produced a radiological problem, neither the temporarily misaligned Reactor Building vent sample pump valves or the open panel drain valve problems resulted in a significant problem. A PIF generated in April 1997, dealing with the collection of Reactor Building vont samples was also an example of a chemistry technician procedure adherence proble Technical Specification 6.S.A requires, in part, that v;ritten procedures be established and implemented covering the activities recomrnended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978. Appendix A of RG 1.33 recommends that procedures be implemented which address procedural adherence and that addiess radiochemical controls which prescribe the nature and frequency of sampling and analyse DAP 09-13, Revision 6 " Procedural Adherence," requires, jn part, that procedures be adhered to during the course of activities and that each step of the procedure be performed exactly as written and in the sequence specified in the procedur *
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DCP 1019-01, Revision 10," Sampling,' requires, in part, that after an aqueous sample is obtained from the reactor building sample panel, the sample panel drain valve be closed to prevent drain back up and panel sink contaminatio DCP 2218-01, Revision 4, " Reactor Building Vent," requires, in part, that if switch'
ng sample pumps after particulate ar; ,odine filter changeout on the non-SPING system and prig; to starting the pump motor of the pump to be placed in service, the sample pump valve lineup be performed in a specified sequenc The failure to: (1) close the Reactor Building sample panel drain valve after sample collection on or about September 18,1997; and (2) properly allpa the Unit 3 reactor building vont sample pumps on September 10,1997, prior to starting the sample pump motor are examnles of a violation of Technical Specification 6.8.A (Violation Nos. 50-237/97020-01 and 50 249/97020-01), Conclusions Worker knowledge of the chemistry program was good. Technicians demonstrated appropriate analytical techniques, radiation protection practices and a working knowledge of the systems and processes for which they were responsible. Technician performance, however, was mixed and included procedural compliance problems caused by the failure to consistently implement the Stop/Think/Act/ Review process important to station operations. Two examples of a procedural adherence violation were identified during the performance of chemistry samplin R4.2 Followuo en Licensee Investigation of Loitering Conecm Insoection Scoos (IP 837E0)
The inspectors 'eviewed the results of an investigation performed by the licensee at the NRC's request, into a concern which was forwarded to the station by the Region lli office in a letter dated June 23,1997. The concern involved station laborers sleeping within the radiologically protected are Observations and Findings The licensee's investigation was conducted by a corporate security investi0 ator, an individual with no reporting relationship to mangement at Dresden Station. The investigation covered the first half of 1997, as requested by the NRC. The investigation substantiated the concern and identified one Instance when a station laborer vias discovered sleeping in a radiologic ally protected area (RPA). The sleeping incident
, occurred on April 30,1997, and was initially identified by a member of the station's plant engineering staff, and a PlF was generated that same da The laborer was found sleeping on the floor of the Unit 3 turbine pipeway, just outsice the Unit 3 south conder,ses waterbox, a posted radiation area. Although a rcdiation area, the radio;ogical conditions in the immediate region, where the laborer was fcund
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resting, did not result in a significant dose to the individual, because no smearable contamination was present and direct radiation levels were appioximately 2 mrenVhou DAP 09-15, " Procedural Adherence," requires tnat procedures be adhered to during the course of activities. DAP 12 27, * Radiation Protection Guide!ines for RPA Access,"
prohibits loitering in radiaticn fields and casual or other non work related exposure such as loitering in or around RPAs. Since the laborer attended nuclear general ernployee training and fitness for duty training which address unacceptable practicco during working hours and stetion radiatiori protection procedures prohlbliloitering in RPAs, the laborer's empbyment was terminate Two other examples of laborers sleeping while at work were also identified by the
- iceni,ea !n 1997; however, these other ir,cHents occurred outside the RPA. Corrective actions taken b/ the licensee for these other instances included the issuance of letters
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of revJuand to the workers involved and tailgate meetings with staff to alert them of theco unacceptable pracuce Wonrical Specification 0.8.A requirec, in part, that written procedures be established MhmWemented covering the activities recommended in Appendix A of Regulatory G.dce (RG) 1.33, Revision 2 February 1976 Appendix A of RC 1.33 recommends that adminiAirative procedures addressing procedural adharence and radiation protection procedures be implemented. As discussed above, on April 30,1997, the licensee identified a vlotation of station procedures involving 6 laborer found sleeping (loitering) in an RPA. The violation was isolated and was identified and corrected by the licensee prior to the NRC forwarding the concem to the station. Consequently, this non-repetitive, licensecs'dentified and corrected violation % being treated as a Non-Cited Violation, consistent with Section V!l B.1 of the NRC Enforcement Policy (Non Cited Vioiran No. 50 237/97020-04 and 50-249/97020-04),
' Conclusions The licenseo conducted an appropriate investigation into the concern and substantiated that a station laborer was sleeping in the RPA. Corrective action taken by the licensee for the substantiated concern and for other exarr.ples of individuals sleeping during the work shift were also appropriate. One Non-Cited Violation was identifie R6 RP&C Organi:::ation and Administration a. lasanction Scone (IP 84750)
The inspectors reviewed the chcmistry organization and staffing, and evaluated supervisory involvement and oversight of the progra b. Observa11ons and Findinos The overall chemistry organization has rsemained relatively stable since about 199 However, in June 1957, a new chemistry supervisor was appchted, and over the last
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couple years, responsibility for various areas of the chemistry program have boen shifted among the staff chemists and chemistry technician supervisors. These changes ,
may have caused a lack of continuity in oversight, as evidenced by the problems identified with PASS surveillances and associated records, as discussed in Gection R Conclusions Although the overall organit.ation has remained rebtively stable with some exception, supervisory oversight of certain areas of the program may have been adversely affected by shifting staff assignmJnt R7 Quality Assurance in RP&C Activities R Proaram Audits and Self Assessments Insoection Scone (IP 84750)
The inspectors reviewed audits and self assessments performed of the chemistry, radiolo0i cal environmental monitoring and liquid and gaseous effluent programs in 1996 to the date of the inspection. The review included audits conducted by the station's quality venfication organization and self assessments by station and corporate chemistry personnel. PiFs related to the chemistry program and generated since mi were also reviewe Qbietvations and Findings In lete 1995, the chemistry group initiated a self assessment program that included performance based field observations of chemistry activities by chemistry managemen The self assessment program was developed in response to a 1995 audit by the station quality verification (SOV) organization, which identified several deficiencies with the chemis,try program and overaliinconsistent leadership and management oversight of the chemistry progra Several chemistry pro 0 ram self assessments were performed in 1996 and 1907. These assessments were reviewed by the inspectors and found to be of adequate depth and covering a range of program areas. The assessments found program implementation to be adequate; although, interdepetment communications and management oversight of daily activities were areas in need of improvemen In March 1996, a comprehansive audit of the REMP, ODCM and gaseous and liquid effluent rwams was performed by SQV. The audit included performance based
...weetions of sampling activities conducted by the environmental monitoring contract technician and station chemistry technicians. The audit found these programs to be well implemented.
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Assessments and audits appeared to be properly focused, performed by knowledgable individuals and identified weaknesses were addressed in u timely manner, Conclusions Adequate mechanisms have been implemented to audit and self assess the chemistry and radiological environmental monitoring programs. Audits and assessments were properly focused, relatively thorough and coveled a variety of program area R7.2 Unit 1 Work Shutdown Jaspection Scone (IP 83750)
The inspe', tors reviewed the circumstances which led to the shutdown of work activities at Unit 1. The review included interviews of several Unit 1 staff and manageme,it and a selective review of PlF Observations and Findings On September 15,1997, station management stopped all planned work evolutions for Unit 1 after they identified that recent radiological and non-radiological work performance had degraded, that station expectations were not being mot, and that the work standards had diminished for both management and workers, The radiological Indicators written in PIFs and tiie observations leading to this decision included examples of problems with the use of electronic dosimeters, tagging of contaminated
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equipment and area posting. During the work stoppage, management personnel listened to workers concems, provided re training to all Unit i rcdiation protection and craft personnel, and re-established standards and expectation The inspectors reviewed several PIFs that identified the nature of the problems on which the work stoppage was based and interviewed reveral RPTs, some craft workers and management about their understanding and use of the process. Based on the inspectors revien, it was noted that, although sor PlFs were written by RPTs and the SQV organization, a large fraction of the PIFs we <ritten by RPT supervisors and managemen Those ir terviewed indicated that, in gener'll, it was understood that the purpose of the PIF process was to identify and document observed radioiogical/ safety problems or Known material and process problems that could negatively impact station performanc However, many expressed a reluctance to issue PlFs because it was perceived as a negative process used to reprimand workers for insignificant issues, rather than a mechanism to correct significant safety related or generic problems. They also indicated that computer terminals (currently the only mechanism to initiate a PlF) wore not readily available, and not all workers had been trained on the use of the compute Some workers indicated that after they corrected the observed problem on the spot, they were more comfortable with discussing their observations with their supervisors and allowing them to initiate the PlF, as deemed necessary by the supervisor. All
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workers interviewed agreed that the station encourages the use rif ine PlF process and ;
that, in gone,al, it appeared that there was little apprehension :.oout issuing a PlF for l fear of management repercussio ' Conclusions l The inspectors concluded that although the workers understood the purpose and intent of the PlF process and acknowleded that the station encouraged its use, there was some reluctance to issue PlF R8 Miscellaneous RP&C lssues R8.1 (Closed) IFl Nos. 50-237/96006-06: 50 249/96006-06: Weakness in the PASS operability procedure. The inspectors reviewed Dresden Sample Building Procedure (DSBP) 1000 37. Revision 2 dated June 26,1996 "HRSS Operability Program," and found it contained adequate surveillance acceptance criteria and included actions to be taken if a surveillance test fails. This item is close V. Management Meetings X1 Exit Meallagjummary On September 19,1997, the inspectors presented the preliminary inspection results to licensee management. On October 9,1997, a teleconference was conducted with Mr. Cliff Howland, the Radiation Protection Manager, to discuss the results of inspection activities conducted on September 30 and October 2,1997. During the telecon, the licensee was informed that the Unit 1 Intake incident would be reviewed further during a future inspection, after the results of the licensee's assessment was provided to Region Ill. The licensee acknowledged the findings presented at the exit meeting and during the teleco The licensee did not identify any information discussed as proprietary, a-
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PARTIAL LIST OF PERSONS CONTACTED comu L. Aldrich, Assistant Radiation Protection Manager R. Burke, Unit 1 Lead Radiation Protection Supervisor M. Friedman, Lead Health Physicist M. Heffley, Station Manager J. Hill, Lead Radiation Protection Supervisor C. Howland, Radiation Protection Manager P. Moore, Effluent Health Physicist J. Moser, ALARA Coordinator T. Neuman, Unit 1 Plant Manager J. Perry, Site Vice President P. Queasy, Unit 1 Decommissioning Health Physics Supervisor -
B. Scott, Chemistry Supervisor F. Spangenburg, Regulatory Assurance Manager J. Strmee, Lead Chemist OlllE A. Lewis, Technician, Teledyne Brown Engineering Environmental Services INSPECTION PHOCEDURES USED IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 83750 Occupational Radiation Exposure IP 92904 Followup - Plant Support ITEMS OPENED AND CLOSED Opened 50 237/249 97020-01 VIO Failure to follow procedure requirements during reactor building vent sample chanyout and reactor building aqueous samplo collection, /249 97020-02 VIO Failure to complete yearly sutveillances of the high radiation sampling syste URI Evaluate a Unit 1 intake incident and the licensee's dose assessment and root cause analysi .
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50 237/249-96006 06 IFl Adequacy of High Radiation Samp!ing System procedur /249-97020-04 NCV Lollering in the Radiologically ProtJeted Area,
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l LIST OF ACRONYMS USED
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AREOR Annual Radiological Environmental Oporating Report CFR Code of FederalRegulations
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CT Chemistry Technician DAC- Derived Air Concontration DPM- Disintegrations per Minute HEPA High Efficiency Particulate Air HRSS/ PASS High Radiation Sampling System / Post Accident Sampling System :
ODCM Offsite Dose Calculation Manual PIF Problem idenficiation Form REMP Radiolog! cal Environmental Monitoring Program i RPA Radiologicsily" Protected Area RPT- Radiation Protection Technician RWP Radiation Work Permit SPING System Ptrticula'e lodine & Noble Gas SOV Station Quality Verification TS Technical Specification PARTIAL LIST OF DOCUMENTS REVIEWED DCP 4212-01 " Liquid Scintillation Counter," Revision 0 DAP 0913, Revision 6, " Procedural Adherence,"
DCP 1019-01, Revision 10. " Sampling."
DCP 2218-01, Revision 4, " Reactor Building Vent."
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Dresden Station Annual Radiological Environmental Operating Report for 1996 DSBP 1000-37 "HRSS Operability Program," Revision 02, Attachment B performed in the 1st, 2nd, and 3rd Quarters of 1997 for Units 2 and 3 ard in the 1st,2nd,3rd, and 4th Quarters of 1997 for Unit DSBP 1000-37 "HRSS Operability Program," Revislen 02, Attachment C performed in 1995 and
, 1996 for Units 2 and "Dresden Chemistry, Environmental, and Radwaste Monthly Report," dated March 1997 and
July 1997.-
DOP 2000-110 (Rev 15) River discharge batch nos.97-024 and 97-02 DRP 2000-04 (Rev 6)"Off Oas Radiation Monitor Calibration."
DRS-2000 03 (Rev 5)"Dresden Unit 1 SPING Fuel Storage Fuel Pool Calibration."
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. DRS 582156 (Rev 0)" Unit 1 18M T/S Emuent SPING 4 Calibration."
DRP-582127 (Rev 02)" Unit 2/3 Quarterly T/S GE Plant Chimney Monitor Calibration."
Di'S 5830 01 (Rev 0)" Unit 2/3 Liquid Discharge Monitor Calibration," [
RS-5821 56 (Rev 01) ' Unit 2/3 T/S Reactor Building Vent SPING Calibration."
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