IR 05000010/1998002
| ML20248L806 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/18/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248L792 | List: |
| References | |
| 50-010-98-02, 50-10-98-2, NUDOCS 9803240234 | |
| Download: ML20248L806 (21) | |
Text
{{#Wiki_filter:-_ _____-_______-_ -
* .
U.S. NUCLEAR REGULATORY COMMISSION REGIONlil Docket No: 50-10 License No: DPR-2 Report No: 50-10/98002(DNMS) Licensee: Commonwealth Edison Company Facility: Dresden Station Unit 1 Location: 6500 N. Dresden Road Morris,IL 60450
Dates: December 15,1997 - February 26,1998 ; inspector: W. G. Snell, Health Physics Manager i Approved by- Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety l l
i ,
-!
i; i
;
l ;n2g2ggqho G L____________
i
*
l l EXECUTIVE SUMMARY Dresden Station Unit 1 NRC Inspection Report 50-10/98002(DNMS) This routine decommissioning inspection covered aspects of licensee management and control, decommissioning support activities, and radiological safety. Also reviewed were recent incidents involving decommissioning work that resulted in small intakes of radioactive material to several workers and other selected activitie Facility Manaaement and Contro!
* The Decommissioning Projects organization appeared to be organizationally well aligned i
'
and provided with sufficient resources to achieve it's goals while ensuring radiological safety concems were met. No concems were identified with long or short range planning and scheduling. (Section 1.1).
- Controls for identifying and resolving issues that could degrade safety or quality were adequate to ensure safety and quality. Root cause investigation reports were excellent in that they were very broad in scope in both identifying root causes and in implementing corrective actions. Although the PlF system was not being used to the extent it could have in early 1997, management's efforts to encourage a greater use of the PIF on Unit 1 were working. (Section 1.2) j e Decommissioning activities were being conducted in accordance with licensed requirements. Plant tours verified that the materialintegrity of structures, systems, and components necessary for the safe storage of spent fuel and the conduct of safe decommissioning were adequate, as was plant housekeeping. (Section 1.3)
Decommissioning Support Activities e Technical Specification 3/4.10.A.1 regarding maintenance of water level for the Fuel : Storage Pool was being implemented as required. (Section 11.1) l
.
e Adequate actions were being taken ensure safety-related systems were being protected ; against extreme cold weather. (Section 11.2) Radiological Safety e The Radiation Protection program exhibited a number of weaknesses, most of which the Licensee had identified and addressed. Overall, the radiation protection program had , I declined through most of 1997 until controls had become informal, personnel were not well informed or disciplined, and management involvement and assurance of quality were lacking. Although improvements were evident, three examples of violations of requirements were identified, showing that additional improvements are still warrante (Section 111.1) e Effective corrective actions addressed a problem with the control of radioactive material (RAM) by the end of 1997. Poor RAM control, which was the result of poor work practices, was corrected through procedure changes and training. (Section Ill.1.b.1) e The air sampling program was generally adequate, with the exception of a violation for failing to immediately send samples to Chemistry when the initial count showed 0.3 DAC
f l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __-
' .
betalgamma or greater. This practice had been ongoing for many months and was corrected by retraining on procedural requirements. (Section lil.1.b.2) e The use of portable air filtration units was determined to be adequate. (Section Ill.1.b.3) e Concems raised regarding potential inadequate decontamination practices and log keeping were effectively addressed through proceaure changes and retrainin (Section Ill.1.b.4) e Determinations of intemal doses were adequate. (Section Ill.1.b.5) e identification of a failure to lock a high radiation area (HRA) door resulted in a violatio Corrective actions were immediate and included verifying all other HAS were properly posted and locked as required. (Section Ill.1.b.6) e The control of keys for access to HAS was determined to be adequate. (Section Ill.1.b.7) e Postings of NRC Form 3 were less than desirable, but improved after the Inspector raised the issue. (Section lil.1.b.8) e A workers deviation from an RWP during work being performed in the Radwaste Tunnel on October 31,1997, resulted in a violation. This poor work practice was primarily addressed through counseling, retraining and heightening expectation (Section lil.1.b.9) I i
- - _ _ _ _ - - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ __ ._-___-_-__ _______-_______-___ __-__ _ - _ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ -__- ___________ ______ ____-__- -_-__-
*
. Report Details Summary of Plant Activities Dresden Unit 1 was commercially operated from July 1960 until October 31,1978, when it was taken offline to add new equipment and perform a chemical decontamination of the major piping systems. While Unit 1 was shut down, the March 1979 accident at Three Mile Island occurre Due to the additional costs to implement regulatory requirements resulting from the Three Mile Island accident, the decision was made to retire Unit 1. The chemical decontamination was completed in September 1984, and the decision to decommission Unit 1 was made in October 198 The Unit i reactor vessel has been defueled and drained, and all fuel is stored onsite. There are 660 fuel assemblies and 1 fuel rod basket in the Unit 1 Spent Fuel Pool (SFP),23 assemblies in the Unit 1 Spent Fuel Transfer Canal,102 fuel assemblies in the Unit 2 SFP, and 104 fuel assemblies and 1 fuel rod basket in the Unit 3 SF The Licensee intends is to place Dresden Unit 1 in a dormant condition until Units 2 and 3 reach their end of active life. At that time all three units will be decontaminated and dismantled. To date work on Unit 1 has included securing nonessential equipment and systems, draining Sphere systems, cutting and capping system piping, SFP system upgrades, cleaning and waste removal, Dry Cask Storage (DCS) preparation, removal of asbestos, removal of a large volume of contaminated soil, and the removal of a number of radioactive waste tanks. Major activities planned for 1998 include radwaste tank / vault waste removal activities, cutting and capping of radwaste system piping, installation of the independent Spent Fuel Storage Installation (ISFSI) pad, movement of the baskets from the Spent Fuel Transfer Canal to the SFP, characterization of the fuel, and continued asbestos abatemen . Facility Manaaement and Control Organization. Manaaement and Cost Controls Scope (36801) The Inspector reviewed the licensee's systems for overall management and control of the decommissioning process. Specific processes which were selectively examined included the programs foridentification and resolution of safety concems and the commitment tracking programs and procedures. The Inspector also reviewed and evaluated the licensee's organization and staffing to verify licensing commitments were being me Reference was made to the requirements detailed in the Technical Specifications (TS), and the Decommissioning Program Plan. The inspector also selectively examined and evaluated the Licensee's planning and scheduling to determine their effectivenes Observations and Findinas Several significant organizational / management changes were implemented between February 1997 and February 1998. These changes were driven by both the normal movement of individuals within the Dresden organization and in response to the results of an investigation into a radiologicalintake event on September 30,1997, in February 1997, the Commonwealth Edison (Comed) Lead Radiation Protection Supervisor (RPS) for Unit 1 transferred to another position. Due to the lack of resources at that time, the duties of the Lead RPS were given to the Contract Lead RPS, who was
_ _ _ _ _ _
- - - _ _ - _ - - _ - _ - _ _ - _ _ _ _ - _ _ - _ _ _ _ _ _ _ - ' .
assigned to report to the Lead Comed RPS for Units 2/3. In June 1997 the Unit 1 ALARA Engineer changed companies (although he continued to work at Dresden), which resulted in a new ALARA Engineer picking up those duties along with the continued responsibility for site coordination of the contract radiation protection (RP) personnel. Because the new ALARA Engineer devoted most of his time to the coordination of the contract RP personnel, the Contract Lead RPS for Unit 1 started performing duties of the Al. ARA Enginee On September 30,1997, several contract workers were intemally contaminated while working in the Unit 1 Radwaste Vault #1. Following an in-depth investigation the Licensee concluded that this event was caused in part by a management deficienc Specifically, management had failed to adequately evaluate the impact of the supervisory changes implemented in February and June 1997, which in combination " allowed the radiation protection program (both operations and worker practices) to deteriorate."
These findings resulted in the collateral duties of the ALARA Engineer position being reassigned, leaving that position responsible only for ALARA duties. Changes were also made in personnel filling various supervisory positions, as well as adding an additional RPS to provide oversight for the RP Technician In addition to these changes, effective on February 15,1998, the Unit 1 Decommissioning Plant Manager, Mr. Tom Nauman, was replaced by Mr. Cliff Howland i due to Mr. Nauman's departure from Comed. Mr. Howland was previously the Dresden j Station Radiation Protection Manager (RPM).
The organizational structure of Dresden Unit 1 was compared against Amendment No. 39 of the Unit 1 Technical Specifications, Sections 6.1 and 6.2.A. The organization was found to be as described in the Technical Specification , A review was made of the planning and scheduling process for Unit 1. The Licensee has developed a SAFSTOR Operations document that provides a list of the minimum i endpoint requirements for SAFSTOR Dormancy. They have also developed a detailed matrix of all work tasks scheduled for 1998. These tasks are selected based on the Unit 1 Manager's prioritization of the endpoint work requirements in conjunction with the available funding for 1998 and input from his management staff. Safety-related items have the highest priority when planning and scheduling work. These tasks are then broken down into an integrated 12-week and 5-week schedule of planned work activitie This appeared to be an effective system and no problems were noted with it's implementatio Conclusions The Decommissioning Projects organization for Dresden Unit 1 appeared to be organizationally well aligned and provided with sufficient resources to achieve it's goals while ensuring radiological safety concems were met. The past degradation in the area of radiation safety has been recognized and the organizational changes and emphasis on increasing expectations and level of performance appear adequate to resolve this issue.
l Mr. Howland's radiation protection background should have a positive influence in - ! improving the radiation protection program for Unit 1. No concems were identified with long or short range planning and schedulin *
. Self-Assessment. Auditha and Corrective Actions
' a. Scope (40801)
!
The Licensee's controls for identifying, resolving and preventing issues that degrade i safety or quality were examined, including self-assessments, corrective actions, safety I review committees and root cause evaluations. The program was evaluated from the l perspective of its adequacy to accomplish the objective of assuring that management and staff were knowledgeable of plant / activity performance and contributed effectively to safety and quality in the conduct of important activitie b. Observations and Findinas Four significant Root Cause investigations conducted on Unit 1 by the Ucensee between September 1997 and February 1998 were reviewed. ~ Two of the investigations were I carried out in response to radiological events that resulted in several workers receiving intakes of radioactive contamination, one on September 30,1997, and the other on j October 30,1997. Additionally, an investigation was carried out to investigate concems ; raised by a worker in conjunction with a personnel action involving that worker, and an ! investigation was conducted to look at the integration of radiological practices into the work control process. A review of each of the reports from these investigations found them to be very thorough in their determination of the events and the root causes, and the responses to be aggressive and timely. For example, following the September 30 event, immediate actions included stopping all werk on the Radiation Work Permit (RWP) ' under which the work was being performed, a subsequent stoppage of all radiological work activities on Unit 1, conducting whole body counts of all personnel in the area where the event occurred, and developing a formal evaluation process for all radiological work processes with a job-by-Job approval from the Unit 1 Station Manager and the Dresden l Station Radiation Protection Manger (RPM) required to restart work. In addition, actions i taken to prevent recurrence appeared to be broad in scope and comprehensive. The only 1 negative finding regarding these investigations was that the conclusions of the investigation into the personnel actions surrounding a worker were twice rejected when 4 reviewed by the Corrective Action Review Board (CARB) because they had not ; adequately captured the root causes. The first rejection was in part based on the fact that the investigation had not met several of the basic checklist requirements of the CARB, On the positive side, it showed that the CARB effectively carried out it's responsibilities and as a result a much better product was produced with more clearly defined root cause The inspector reviewed the Problem identification Form (PlF) system, which is employed l for the documentation, tracking and resolution of problems and concems. The system is l computerized so that a worker can document a conoom from any computer terminal. In 1997 the Licensee identified that the number of PlFs being written on Unit 1 was low : ' compared to Unit 2/3. This led to efforts to promote a higher use of the PlF system, ! which have been effective. The number of PlFs written since February 1997 has been steadily increasing. For example, the total number of PlFs written for the three month ; l period of February, March and April 1997 was about 55, while for the three month period ; including November and December 1997 and January 1998 it was about 100. This increase was in spite of the fact that staffing and field work were reduced during November and Decembe A general review of the PlFs written on Unit i found them to be problems or concems that met the threshold for being placed on the system, and their resolution appeared to be
_ _ . _ _
* .
timely and adequate. A detailed review was made of 8-10 of the items that had been placed in the PlF system. In all cases reviewed the problem or concem was well documented, assigned to appropriate personnel for followup, and the resolution adequate In NRC Inspection Reports 50-10/97020(DRS); 50-237/97020(DRS) dated October 30, 1997, a possible reluctance to write PIFs had been identified. The report stated that there was "a reluctance to issue PlFs because it was perceived as a negative process used to reprimand workers for insignificant issues." However, after further discussion, i the Report also stated that "it appeared that there was little apprehension about issuing a PlF for fear of management repercussion." In November 1997 the Licensee sent out a questionnaire to all personnel working on Unit 1 to assess the use of the PlF system. Of i the over 70 questionnaires distributed,100 percent response was achieved, and only a few respondents indicated a reluctance to write PlFs. The response also indicated that
'
all but a few respondents had either used the PIF system or some other means (e.g., discussion with their supervisor) to express their concems or identify a problem. Based on the small number of negative responses, this was perceived by the Licensee as an indication that overall the PIF system was being used. However, to further encourage the use of the PlF system, subsequent to the Questionnaire and as additional training, the Licensee discussed the threshold for writing PlFs in Tailgate Session In mid-1997 Dresden investigated an employee concem that was raised for Units 2/3 regarding both a husband and wife working at Dresden with one being a manager and the l other a worker. The concem was that if an individual wrote a PIF that involved the worker i spouse, the manager spouse could retaliate against the individual who wrote the Pl The Licensee's investigation determined that Dresden had several cases where both the husband and wife worked at the site and one was a supervisor. Discussions with the Licensee indicated that this resulted in an organizational change in which a Unit 2/3 employee was moved to Unit 1. Current examples of these situations that existed at i Dresden that were mentioned by the Licensee included a contractor supervisor on Unit 2/3 whose spouse was a contractor on Unit 1, and a Comed supervisor on Unit 2/3 whose spouse was a contractor on Unit ! Discussions with the Licensee indicated that it has been Comed's policy that they will not l hire both a husband and wife. However, Comed has not prevented a contractor from hiring both a husband and wife or the spouse of a Comed employee. It has also been Comed's policy that if two individuals marry while employed by Comed, they could both ! continue to be employed by Comed. In those cases where both a husband and wife have worked at Dresden and one of them was a supervisor, Comed has ensured that the supervisor has no supervisory responsibility over their spouse. If a worker identifies a concem regarding a supervisor's spouse, the concem should be documented in the PlF system. Since the PIF is reviewed by an independent group, concem over a manager , . spouse should not be of sufficient concem to prevent raising a safety issue. If a supervisor did try to retaliate via a workers performance appraisal, the worker has the opportunity to provide a written response to the appraisal which is reviewed by upper ; management. Essentially, Comed has tried to avoid this situation to the extent l practicable, and still ensure the rights of all the individuals involve : Another issue related to writing PlFs was examined which involved whether there was a lower threshold for terminating contract workers than Comed workers. The concem was that if a contract worker started writing numerous PlFs, they could be perceived as a
" trouble maker" and terminated with little justification, which could not happen to a Comed worker. Organizationally, the majority of the Dresden Unit 1 work force are r
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
* .
contractors. As such, each contract organization has its own rules goveming personnel actions for its workers. To determine if there was a lower threshold for terminating contract workers than Comed workers, the inspector reviewed the Ucensee's investigation Report dated January 29,1998, involving circumstances surrounding a contract worker whose employment at the Dresden Station was terminated in mid-November 1997. Prior to this concems raised by the worker regarding perceived improper radiation protection practices, were not addressed to the worker's satisfaction by either contract management or Comed. The situation eventually resulted in the suspension of the worker pending the results of an investigation into the matte However, upon leaving the site under suspension, the worker apparently believed they had been terminated. Subsequent attempts by Comed and the contractor to persuade the worker to retum failed, and the worker's employment was eventually terminate The Licensee's subsequent investigation into this sequence of actions determined three root causes, one of which was " ineffective managerial methods." In effect, management had been generally unaware of the requirements of DAP 1-04, Station Contractor Control, regarding a contract employee's rights and protection. DAP 1-04 requires that a contractor " provide written notice to Station Manager / designee at least five days before terminating any on-site employee or taking other significant adverse employment action which the contractor has reason to believe may result in a claim of discrimination . . . ." As a result of Comed's root cause finding, training was instituted for Station and contract management on the content of DAP 1-04. During the inspection the content of DAP 1-04 was also discussed by the Inspector with a number of Unit 1 workers, and none of them was aware of this procedure. All contract individuals with whom this issue was discussed believed that they could be terminated immediately if management chose to do so, without Comed management having any input into the decision. (However, it was also noted that each of these individuals indicated that even presuming they could be terminated immediately, they would still raise safety issues if they felt strongly about : them.) The lack of knowledge of DAP 1-04 by the contract workers was discussed with Unit 1 management, who subsequently expanded their training of DAP 1-04 to the include the work force as well as management. This was carried out by discussing the content of DAP 1-04 during a March 4,1998, Unit 1 Tailgate meetin There were two additional important (root cause) issues that were raised as a result of this incident and the Licensee's subsequent investigation. The first was that a supervisor failed to recognize the significance of potential safety-related comments made by a worker (even though they were informally stated). This was identified by the Licensee as a key root cause of the entire incident leading to the eventual suspension and termination of the worker. The supervisor should have responded to the concems at the time and either entered the concems into the PIF system for later followup or directed the worker to do so. However, the second root cause was that the worker failed to 4 adequately communicate his concems regarding the perceived inappropriate work practices to the individuals involved, his supervisor, or Station management. Had the worker better communicated his concems, the supervisor may have grasped the significance of the issues and responded correctly. This was also identified as a root cause of the incident.
l l Conclusions Overall the licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were determined to be adequate to ensure safety and quality in the conduct of important activities. The root cause investigation reports were excellent in that they were very broad in scope in both identifying the root causes and in the
u ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ -_ ._ . - _ _ _ . - . - _ _ _ _ __
__ _ _ _ _ _________ _. - .- ..
.. .
implementation of corrective actions. Although the PlF system was not being used to the extent it could have in early 1997, management's efforts to encourage a greater use of the PlF on Unit 1 were working, and it appeared that the system was being effectively implemented to identify and respond to problems and concem Decommissioning Performance and Status Review a. Scope (71801) The inspector evaluated the status of decommissioning to verify the Licensee and the contracted workforce were conducting decommissioning activities in accordance with licensed requirements. Plant tours were conducted to evaluate ths materialintegrity of l structures, systems, and components necessary for the safe storage of spent fuel and I the conduct of safe decommissioning, and to evaluate plant housekeepin b. Observations and Findinas The Unit 1 Plant Manager met with various levels of his management staff at 7:40 each moming to discuss the status of work activities. The inspector attended nine of l these meetings. The inspector also attended a Unit 1 Tailgate meeting and a Unit 1 Performance Review Board meeting. The meetings were all well attended and appeared l to benefit those in attendance. Management had a high level of involvement at these ! meetings, which included a strong focus on safety, quality of work, communication, and encouragement to use a questioning attit'.:de in all work activitie A number of plant tours were conducted, which included two tours in the Unit 1 Sphere, two tours of the Fuel Handling Building, and a tour of outdoor areas. The general material condition of facilities, systems and equipment, as well as general housekeeping j were examined. The overall material condition of the Unit 1 facilities and systems was ; very good. Housekeeping was generally very good, with the Fuel Handling Building being , kept in excellent condition. Work areas were noted to generally be maintained in an orderly manner, with required barriers and postinga in place. Although some areas within the Sphere had not yet been cleaned up, those areas where asbestos abatement had occurred as well as other areas where loose equipment had been removed were found to be overallin good conditio c. Conclusions The Ucensee's decommissioning activities reviewed were being conducted in accordance with licensed requirements. Plant tours verified that the material integrity of structures, systems, and components necessary for the safe storage of spent fuel and the conduct of safe decommissioning were adequate, as was plant housekeeping.
' 11. Decommissioning Support Activities 11. 1 Maintenance and Surveillance , s. Scope (62801) The inspector verified that Technical Specification (TS) surveillance requirements pertaining to water level in the Fuel Storage Pool were being conducted as require _ _ _ _ _ _ _ _ _ _ _ - _ _ _ .__-____ _ _ _ _ _ _ _ _ _-____ _ __________-_ _ _ _
* . Observations and Findings The Unit 1 TS Sections 3/4.10.A.1 require the water level in the Fuel Storage Pool to be maintained at a level of at least 18 feet, and the level verified at least once per 24 hour It was verified that the Appendix 1 Unit 1 Equipment Attendant Logsheet, Operator Tumover Sheet, which was the log to be filled out by operators on their rounds, contained a line item for checking the level of water in the Fuel Storage Pool. A review of a printout .
of the Logsheet showed that the water level was being verified at least once every 24 hour period (in fact it was being verified shiftly). Conclusions Tech Spec 3/4.10.A.1 was being implemented as require . 2 Cold Weather Preparations Scope (71714) The inspector reviewed Licensee procedures and conducted several plant tours to verify l the implementation and effectiveness of actions to protect safety-related systems against I extreme cold weather, Observations and Findinas TS 6.8.A.8 requires that the Licensee establish, implement and maintain procedures for a < Winterization Program applicable to the safe storage and handling of irradiated fuel. The i Licensee had three procedures pertaining to cold weather activities for Unit 1. Two of I these procedures (DOS 0010-19, Preparation fbr Cokf Weathertbr Unit 1, and DOS 0010-20, initiation of Coki Weather Operations for Unit 1) addressed preparing Unit i for cold weather, while the third procedure (DOS 0010-21, Securing From Cold Weather Operations on Unit 1) addressed the removal of plant equipment from operation that was used for protecting Unit i from cold weather. DOS 0010-19 was required to be initiated in September and completed by October 15, and DOS-0010-20 was required to be initiated on or about November 1 and completed by November 15. Checklist A of required actions for each of these procedures was reviewed for 1995,1996 and 1997. The actions were all completed as required and within the time frames specified. DOS 0010-21 was to be completed around April 1. A review of the Checklist for DOS 0010-21 for 1997 indicated it was implemented in early May, which was considered to be acceptabl Three heators are maintained in the Unit 1 Sphere, with remote read out at the entrance to the Sphere. These heaters are located in the A and B Reactor Enclosure Drain Tank (REDT) Rooms and the Subpile Room, and are manually controlled. When the temperature ir. any of the rooms where the heaters are located falls into the 40*F range, they are tumed on until the room heats up, and then tumed off. The temperatures in these three rooms are recorded daily. A review of the temperature logs for January 1-February 25,1998, showed the temperatures varied from a low of 41.5'F to a high of l 110*F. On January 14,1998, the inspector was touring Unit 1 with the Plant Manage During the tour the Plant Manager determined that a heater in the A REDT Room was inoperable, which was promptly replaced by the License j
!
l l l
- _ _ _ - _ _ _ _ _ - _ . _ _ - - - - - - _ _
' , Conclusions The Licensee was taking adequate actions to ensure safety-related systems were being protected against extreme cold weathe l Pl RadiolonicalControla i 111. 1 Occupational RadiationExposure Scone (83750) !
l An inspection and evaluation were made of the radiation safety program to ensure that ! procedures and controls were adequate to minimize occupational exposure to radiological ; materials and to identify potential problem areas, Observations and Findenns b.1 Housekeeping and Control of Radioactive Materials Examination of housekeeping during a number of tours of Unit 1 showed areas to be generally clean and clutter free. A review of the PIF system identified numerous PlFs j
'
that were related to poor radioactive material (RAM) control in Unit 1. Most of the issues identified involved finding bags of untagged RAM. The causes provided included failures - to follow procedures and inattention to detail. Corrective actions included training and procedure modifications, in 19g7 there were nine PlFs written on this issue in l September, one in October, one in November, and none in December. During the tours no improperiy tagged bags or other problems regarding an inappropriate control of RAM were identified. Based on these findings, it appears that the corrective actions taken have adequately addressed the probioms with RAM contro b.2 Air Sampling Program A review was made of the air sampling program for Unit 1. Procedure DRP 6020-02, Radiological Air Sampling Program, specifies how air samples are to be counted following , collection. The procedure states that following a field check of a sample, it should be i transported "to the appropriate analytical area for analysis." For Unit 1, the practice has !
!
l been to send samples to the Unit 1 Count Room for initial counting and determination of the Derived Air Concentration (DAC). Procedure DRP 6020-02 specifies that air samples at or above 0.3 DAC beta / gamma will be immediately counted using a high purity ;
'
germanium detector (HPG). Samples meeting this threshold must be taken to Unit 2/3 Chemistry for counting. Because Unit i has had known areas of high redon, air samples , that initially equal or exceed 0.3 DAC were allowed to decay for up to five days to lower l the redon levels. If subsequent to allowing for the decay an air sample counted less than ! 0.3 DAC, that air sample was not forwarded to Chemistry for further analysis. This : practice was not as directed by DRP 6020-02. The failure to adhere to DAP 6020-02 l was a violation of the Dresden Unit 1 Technical Specifications, Section 6.11, Radiation ! Protection Program, which states in part that " Procedures for personnel radiation i protection shall be . . . adhered to for all operations involving personnel radiation ! exposure." (Violation 50-010/98002-01, Example No.1) -{ On November 21,1997, the Licensee generated a PIF in regards to delaying the' couming of air samples with a DAC greater than 0.3 prior to forwarding the sample to l Chemistry. Th9 investigation into this matter determined that this practice had been i
I 1 i
* .
initiated about a year and a half earlier under the direction of the previous Radiation ProtectH>n Supervisor. The reason for doing this was to minimize the number of air samples being forwarded to Chemistry.. The Licensee's corrective action was to retrain all contract Radiation Protection Technicians (RPTs) on DRP 6020-02, and the need to forward all samples in excess of 0.3 DAC to Chemistry without delaying for decay. This was accomplished during a Tailgate session on December 3,199 While evaluating the air sampling program, the Inspector requested the calibration data for a particular air sampler (RADeCO A/S H809-7085). An initial search by the Licensee was unable to locate calibration records for this particular sampler. The Licensee wrote a PlF and initiated an investigation. The issue was resolved when it was identified that the serial number that had been hand written on the air sampler had the numbers transposed. Workers had subsequently used this transposed number when documenting the calibration and use of this air sampler, b.3 Portable Air Filtration Units The use of portable air filtration units for radiological activities was examined. Procedure DRP 6210-16, Set-up and Operation of Portable AirFiltratiorWentilation Equipment, addressed the use of high efficiency particulate air (HEPA) filters. Procedurally, personnel charged with the set up and operation of the HEPA units are required to be familiar with the proper use and operation of the equipment. Although the RPTs are assigned this responsibility, it was noted that there was no formal training provided on this matter. However, discussions with several RPTs about the set up, use and maintenance of the HEPAs indicated they were knowledgeable concoming the equipment. A review of the most recent calibration records (Data Sheet 1 of DRP 5821-07, Operation and Calibration of the RADeCO Model AVS-60A Portable Constant Flow Air Sariipler) indicated the instruments were being property maintained. A review was also made of the DRP 6210-16 HEPA Checklist (Checklist A), HEPA Unit issuance Log (Attachment B) and the Portable Ventilation Unit inspection Log Sheet (Attachment D) pertaining to HEPA Unit # H039. Only one minor item was noted,' and that was that the ' Checklist tasks were being " checked off' as completed even though the Checklist states to " initial each blank as check satisfactory." During plant tours the inspector examined j several HEPA units. In each case they appeared to be property set up end were being l adequately inspected with results documented on the Portable Ventilation Unit inspection l Log Shee ' b.4 Personnel Contaminations
;
l A review was made of what actions were taken when personnel contaminations are identified on Unit 1. Procedurally, routine decontamination of extemally contaminated I individuals were addressed in DRP 5720-04, Routine PersonnelDecontamination. Per DRP 5720-04, personnel contaminations are recorded on a Contamination Event Log. A r review of this Log for the period September 24 through November 3,1997, identified i contamination events from less than 100 cpm up to one event at 10,000 cpm and another l at 20,000 cpm. Of the 75 events recorded, only three were in excess of 500 cpm. The majority were at less than 100 cpm and were shoe contaminations. Although no discrepancies were noted with the information provided on the Log, discussions with various workers indicated that the Lcg had not in all cases been filled out when minor contaminations were identifie The practice at Dresden Unit 1 has been to provide the RPTs the latitude to use professional judgement when handling personnel contaminations. For minor
L
_ , _ - _ _ _ _ _ - .
., ' .- l contaminations, the RPTs were allowed to decontaminate individuals on the Unit 1 sid Otherwise, contaminated individuals were taken to the Unit 2/3 side for decontaminatio (The Unit 2/3 side has facilities and equipment for decontaminating workers that are not available on the Unit 1 side.) However, as a result of a concem being raised in the Fall of 1997 regarding decontamination practices on the Unit 1 side, the Licensee reviewed this issue and changed their policy. During Tailgate Sessions in early November 1997, it was !
stated that all identified personnel contaminations would be decontaminated on the Unit 2/3 side. Subsequently, after further review, the policy was modified again in a memorandum issued on February 6,1998, stating that shoe contaminations of less that 1,000 cpm from a direct frisk could be decontaminated on the Unit i side if it was done , with tape or masslin. All other decontamination were to be performed on the Unit 2/3 ! sid b.5 Intemal Dose Calculation An review was made of the methodology and calculations used to determine the intemal doses received by workers during the September 30,1997, and October 31,1997, events. The infomal doses (committed effective dose equivalent (CEDE)) were derived based on focal sample analysis and whole body count results. No problems were noted with the procedures or analytical results for the derived doses, which were all less than 5 millire b.6 Locked Hioh Rad Doors l During a January 14,1998, tour of the Unit 1 Sphere with the Unit 1 Plant Manager, a ; door to the Subpile Room was found unlocked. Uncertain as to whether this was l appropriate or not, the Plant Manager requested his staff to verify if that door should have j been locked, or whether it was acceptable as found. A followup survey the same day identified a 1.2 rem / hour dose rate at a distance of one foot within the room. This rem / hour dose was located on the carousel under the Unit i reactor bottom head, which was accessible by climbing up a ladder. This was a violation of Technical Specification 6.12.B. which requires that for " areas accessible to personnel with radiation levels greater than 1000 mrom/hr at 30 cm (12 in.) . . . Doors shall be locked to prevent unauthorized entry." (Violation 50-010/98002-02). Upon identification of this condition the Licensen took immediate and extensive corrective actions. The RPT who identified the condition controlled the area until it was posted as a Locked High Radiation Area (HRA) and the Subpile Room door was locked. All other unlocked HAS were then surveyed to determine if this condition existed elsewhere. No other doors were found unlocked that should have been locked. In examining the reason why this door was unlocked, the Licensee j determined that it had been unlocked based on a 1997 change in the Unit 1 Technical l
'
Specification that allowed HAS to be unlocked. To the extent practicable, the decision to unlock doors was based on a review of existing survey data. New surveys of all the areas were not conducted as an ALARA action. The survey data showed the Subpile Room to be less than 1 rem /hr, but there had been no survey data for the carousel are j The lack of data for the carousel area went unnoticed at the time the door was unlocke j i b.7 Hiah Radiation Area Kev Control J A review was made of the key controls for High Radiation Areas. Access is for HAS procedurally controlled under DAP 12-04, Control of Access to High Radiation Areas, I while Section E.5 addresses Key Control. Dresden Unit 1 has eight areas that qualify as ( HAS that are required to be locked per Technical Specification 6.12.B. which requires that for " areas accessible to personnel with radiation levels greater than 1000 mrem /hr at 30 l 13
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ . -A
i
~ ..
, cm (12 in.) . . . Doors shall be locked to prevent unauthorized entry." Seven of these areas are controlled by a locked door while the eighth is a shield banded in place. Keys to these areas are controlled by the Radiation Protection Department, with a daily key inventory documented on Form 12-048, Daily HRAILHRANHRA Key Master Checklis Multiple keys for each lock are allowed, as is a master key. 'A duplicate of the keys is maintained on the Unit 2/3 side, in addition, a monthly verification is made that these ; doors are locked, the keys work, and the area is correctly posted. This monthly I verification is documented on DRS 5600-01, Checklist A, High and Very High Radiation Area Boundary and Posting Checklist. When keys are si0ned out, their use is documented on Form 12-04A, LHRANHRA Key Control Log. Radiation Protection will provide a briefing on key control responsibilities to any worker checking out a HRA ke The control of and procedural requirements surrounding the use of HRA keys were discussed with the Unit 1 Lead Contract RPT Supervisor. In addition files of each of the above forms / checklists for Unit i for September-December 1997 wera reviewed by the inspector. No discrepancies or problems were identifie Post ng of NRC Form 3 During a tour of Unit 1, it was noted that a copy of NRC Form 3, Notice to Employees, was not posted in the Unit 1 Radiation Protection Trailer. A copy of Form 3 was found to be posted in the adjoining Unit Production Trailer. According to the Licensee the walls in the Radiation Protection Trailer had been remodeled several months eariier and the Form 3 was removed and not reposted at the conclusion of the wxk. The NRC Form 3 is required to be prominently posted. The Form 3 was noted to be posted by the next day after the inspector raised the issue, b.9 Contamination Event on October 31.1997 On October 31,1997, two Pipe Fitters were identified as extemally contaminated following cutting and capping operations in the Unit 1 Radwaste Tunnel. The Licensee's investigation of this incident determined that one Pipe Fitter received an infomal dose (CEDE) of 4 millirem (mrom). This same individual also received an extemal dose of 20 mrom during the even The work that was being conducted involved the cutting out of a 4 foot section of an old 3 inch stainless steel Service Water line. The line was cut with a band saw by one Pipe Fitter while the other Pipe Fitter held onto the pipe. Followin0 removal of the section of pipe, the ends were to be capped. RPT coverege was provided for the wor The job was set up on the moming of October 31, with the first cut completed before lunch. The RPT assigned this job was not the same RPT who had attended the pre-job ; brief several days earlier. However, for this job a pre-job brief had not been procedurally 1 l required, but had been conducted as a conservative decision. An air sample was l collected during the first cut, which was taken for analysis when work was stopped for lunch. Following lunch the second (and final) cut was made. During both cuts a HEPA unit was employed and misting was performed as engineering controls to minimize contamination and pirt>ome activity, but an air sample was not collected during the second cut. Although the air sample was not procedurally required, Dresden Radiological Procedure (DRP) 6020-02, states that " air samples should l'e obtained while work is in l
'
progress and in close proximity to the worker, ideally within the breathing zone."
After the second cut was completed, the Pipe Fitter holding the pipe saw that there was debris inside the pipe. He asked the RPT for permission to dump the debris into the l
J
!
-. _ _ _ _ _ _ _ . . _ _ _ . _ _ . . _ _ j
_____. _ _ _ _
* .
bucket of water that was there. The bucket of water had been brought in for rinsing and cleaning drip funnels and for refilling the spray bottles used for misting. The RPT gave permission to dump the debris into the bucket, which when carried out, created a localized airbome event, which resulted in the intake by one of the Pipe Fitters. Allowing i the Pipe Fitter to dump the debris into the bucket of water was not only a poor radiological I decision by the RPT, but was beyond the scope of the Radiation Work Permit (RWP 971012). This was also a failure to follow DAP 12-25, Radiation Work Permit Program, Section F.1.f.(4), which states that it is the responsibility of personnel performing a job under a RWP to follow the requirements of the RWP The failure to adhere to DAP 12-25 was a violation of the Dresden Unit 1 Technical Specifications, Section 6.11, Radiation Protection Program, which states in part that " Procedures for personnel radiation protection shall be . . . adhered to for all operations involving personnel radiation exposure." (Violation 50-010/98002-01, Example 2) Subsequent to the completion of their work, the two Pipe Fitters alarmed the PCMs when exiting the Radiologically Posted Area (RPA). Whole body counts were taken of all workers involved, and subsequently confirmed with the whole body counts and fecal sample analysis the intake to one of the Pipe Fitters. Because the intake had not been planned, all work on RWP 971012 was ha".ed and an investigation was initiated by the Licensee. Three primary root causes were identified as follows: 1) an error by the RPT in allowing work outside the scope of the RWP, 2) an error by the RPT in not recognizing that dumping the debris into the bucket could cause an airbome problem, and, 3) the failure of the RPT to attend the pre-job brief, recognizing it had not been procedurally required and the RPT who had attended had been reassigned to other wor Actions taken by the Licensee in response to this event included: 1) halting work on RWP 971012 on November 4,1997, and then halting all radiological work in Dresden Unit i until a restart work plan could be developed, which was subsequently issued on November 12,1997, 2) counseling the RPT on his performance, 3) implementing an organizational change on December 1,1997, ("which delineates an RP General Supervisor who is responsible for RP on Units 1,2, and 3, with the Unit 1 Lead RP Supervisor reporting directly to the RP General Supervisor") to ensure the standards and expectations for radiological work on Unit 1 are the same as for Units 2/3, 4) adding training on this and previous intake events to the in-processing training for contract RPTs, and, 5) heightening the awareness of RP managers and RPTs assigned to Unit 1 on the expectation to stay within the scope of the RW c. Conclusions The Radiation Protection program exhibited a number of weaknesses, most of which the Licensee had identified and addressed. Overall, the radiation protection program had declined through most of 1997 until controls had become informal, personnel were not well informed or disciplined, and management involvement and assurance of quality were lacking. Although improvements were evident, three examples of violations of requirements were identified, showing that additional improvements are still warrante i
*
\
l IV. Previously identified issues 192701) l (Closed) URI 50-010/97020-03: Unit 1 Radweste Vault #1 intake event. On September 30, l- - 1997, several contract workers were unexpectedly intemally contaminated while working in the Unit 1 Radweste Vault #1. An RPT, Pipefitter and an Electrician received intemal doses (CEDE) of 3,2 and 1 mrom, respectively. These same individuals received extemal doses of 28,19 and 6 mrom respectively, during the event. Because Vault #1 was posted " Dangerous High Radiation Area," the extemal doses for the work were not unexpected. Although the primary cause of the workers unexpected intake of radiological contamination was a failure to obtain a radiation survey of the work area prior to conducting the work, numerous failures to follow procedures and poor radiological work practices were identified by the Licensee as a result of their investigation into this event.
! On May 7,1997, an initial entry was made into the Unit 1 Radwaste Vault #1, which contained four radwaste tanks. The purpose of the entry was to evaluate the radiological conditions for eventual work activities involving the processing of sludge and water contained within the Vault
#1 tanks. The floor of Vault #1 also contained 4-6 inches of sludge which would be remove Removal of sludge from within the tanks would be achieved by opening the manways on top of the tanks. Surveys were primarily taken around the floor of the Vault and around the bottom and sides of the tanks. Dose rates, smears and an air sample were collected. Six dose rates were taken on top of the tanks (the highest being 100 mrom per hour (mrom/hr)), and these were obtained by removing plugs from the floor above the Vault, and dropping a radiation detector probe down through the plug opening On August 20 and September 24,1997, ALARA briefings were conducted, which included discussions of the planned work in Vault #1. Both of these briefings included the May 7 survey data. The September 24 briefing addressed the need for an entry into Vault #1 to in part, determine if the radiological conditions had changed. On September 26, a Lead RPS for Unit i entered Vault #1 to verify that radiological conditions had not changed since the May 7 surveys were taken. A new updated survey sheet was not generated as a result of this entry. This was a failure to follow DAP 12-25, Radiation Work Permit Program, Section F.1.c.(2), which requires that surveys used to generate RWPs be verified to ensure they reasonably reflect the I current radiological conditions in the work area, and, that they provide adequate job specific j information to determine exposures. The only available documented survey data was from the May 7 survey, and this was inadequate in that it did not sufficiently identify the radiological conditions on the top of the tanks where work was to be performed. A Pipe Fitter Foreman and Pipe Fitter General Foreman also entered the Vault with the Lead RPS to evaluate the work area. No surveys for loose contamination had been conducted and the dose rates collected had been insufficient to fully characterize the existing radiological conditions. This was also a j failure to follow DAP 12-25 F.1.d.(6), because the RPS, acting as the RPT for the entry, failed
, to perform surveys during the job as required and as deemed necessary to verify radiological l conditions were as expected. The Pipe Fitter General Foreman also failed to adhere to DAP 12-04 E.7, Control of Access to High Radiation Areas, when he descended to the top of the tanks. Specifically, he failed to be briefed on the dose, dose rate, and low dose areas by Radiation Protection before entering a High Radiation Are The failure to follow these above procedures were a violation of the Dresden Unit 1 Technical Specifications, Section 6.11, Radiation Protection Program, which states in part that
* Procedures for personnel radiation protection shall be . . . adhered to for all operations involving personnel radiation exposure." (Violation 50-010/98002-01, Examples 3,4 and 5) l On September 30, work began in Vault #1. Based on the results of the September 26 entry, it was determined that all work could be performed from the top of the tanks, which could be
I '
. - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _
. l .
accessed directly from the ladder extending into the vault. This would eliminate the need to climb to the bottom of the Vault and then back up to the top of the tanks via another ladder, which had been the initial plan. Work included obtaining an initial radiation survey, stringing lights, opening the manways on all four tanks, and estimating what it would take to clean the Vault. A total of nine workers entered the Vault during the approximately 1% hours of work. At the initiation of the entries, the RPT identified a white sandy substance on top of the tank, a 150 millirem per hour (mrom/hr) pipe, and a 1 Roantgen per hour (R/hr) hot spot, but chose not to halt the work. His reasoning was that because it was a High Radiation Area, the identification of high radiation levels was not unexpected. Smears and an air sample were collected, but were not counted until after the work had ende Following the entries, an Electrician and Pipe Fitter were found contaminated upon exiting the Radiologically Protected Area (RPA). Nasal smears identified potential intemal contaminatio Follow up whole body counts of all nine individuals who entered the Vault identified three workers who had been intemally contaminated: the RPT, Pipe Fitter and Elect ician. Because these intakes had not been planned, all work was halted and an investigation was initiated by the Licensee. Two primary root causes were identified as a result of the investigation, as follows: 1) personnel errors, which included numerous instances of failing to adhere to radiation procedures, as well as numerous instances of inappropriate worker actions, and, 2) management deficiency in that management attention to the radiation protection program on Unit 1 following organizational changes in February and June 1997, were insufficient to identify and prevent the program from deterioratin Corrective actions taken by the Licensee in response to this event included: 1) halting work on the Unit 1 Radweste Vaults, 2) - developing a formal evaluation process to ensure compliance with all radiological work processes, 3) evaluating personnel associated with the Radwaste Vault work to ensure they understood task requirements and expectations, 4) disciplining the Comed Health Physics Supervisor for Unit 1 and selected contract craft personnel, 5) . reviewing and subsequently changing the organizational structure for radiation protection on Unit 1,
- 6) upgrading the Unit i self-assessment program in the area of radiation protection, l 7) counseling the contractor Radiation Protection Supervisor, 8) having the contractors involved evaluate the qualification and experience of all their I
'
workers, which resulted in organizational changes, and, 9) briefings of Unit 1 personnel on procedural requirement ! , in addition to the above actions, the Licensee evaluated the worst case total dose scenario that ! could have occurred during this event. Since these tanks were no longer in use, the worst case source term that could have existed was what in fact did exist. The Licensee's worst case ALARA evaluation determined that a worst case dose was 24 millirem TED Considering the RPT received a TEDE from this entry of 31 millirem, the worst case calculated dose was clearty low. The Inspector reviewed the Licensee's calculations and determined that the assumptions were not necessarily unreasonable, and that even with major changes in the assumptions, the potential for a significantly higher dose would have been very small. It i appears that the doses received were in fact probably close to the worst cas The Unresolved item has resulted in a Violatio L_____________ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
* .
1 \ l l l V. Manaoement Meetina j The inspectors presented the inspection results to members of Licensee management at the ! conclusion of the inspection on February 26,1998. The Licensee acknowledged the findings ) presented. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietar I
i l l l ! t
- _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
* .
PARTIAL LIST OF PERSONS CONTACTED Licensee j
*T. Nauman, former Plant Manager Unit 1 *J. C. Howland, Plant Manager Unit 1 l *B. Zank, Operations Manger l *P. Holland, Decommissioning Regulatory Manager l K. Ainger, Decommissioning Services Licensing Manager ! 'J. Limes, Licensing / Compliance Engineer , *J. Hill, General Supervisor !
R. Burke, ALARA Manager i
'
H. Anagnostopoulos, Corrective Actions Supervisor T. Cockream, CRPT Supervisor
*R. Grant, NUKEM RP Supervisor l *C. McDonough, Unit 1 Decommissioning Financial and Planning Manager * Denotes those attending the exit meeting on February 26,199 The Inspector also interviewed other licensee personnel in various departments in the course of the inspectio ]
INSPECTION PROCEDURES USED IP 36801: Organization, Management & Cost Controls at Permanently Shut Down Reactors ; IP 37801: Safety Reviews, Design Changes, and Mods at Permanently Shut Down Reactors IP 40801: Self-Assessment, Auditing, Corrective Action IP 60801: Spent Fuel Pool Safety at Permanently Shut Down Reactors IP 62801: Maintenance and Surveillance at Permanently Shut Down Reactors IP 71714: Cold Weather Preparations IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 83750: Occupational Radiation Exposure IP 92701: Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Openid 010/98002-01 VIO Multiple examples of failures to follow radiation protection procedures as required by the Technical Specification /98002-02 VIO Failure to lock a high radiation area door to prevent unauthorized entry to an area with a dose rate in excess of 1000 mrem / hour at 30 cm.
I l Closed ! 010/97020-03 URI Additional information obtained supported a violation, which was cited under 010/98002-01 due to multiple examples of failure to follow procedures, some which were the result of other event _ - _ _ _ _ _ _ _- _
* ;,
010/98002-01 VIO Root cause investigation and corrective actions already taken were considered sufficient to close this item in the same report it was opene /98002-02 VIO Root cause investigation and corrective actions already taken were considered sufficient to close this item in the same report it was opene DOCUMENTS REVIEWED ADM-11, Radiation Protection Policy Memo, Revision 01 DAP 01-04, Station Contractor Control, Revision 08 DAP 12-04, Control of Access to High Radiation Areas, Revision 28 DAP 12-09, Dresden Station ALARA Program, Revision 13 DAP 12-25, Radiation Work Permit Program. Revision 06 DAP 12-27. Radiation Protection Guidelines forRPA Access, Revision 08 DAP 15-06, Preparation, Approval, and Control of Work Packages and Work Requests. Rev. 20 DDP 12, Unit 1 Winterization Program, Revision 0 Decommissioning Program Plan, Revision No. 5, December 1996 DOS 0010-19, Preparation for Cold Weather for Unit 1, Revision 07 DOS 0010-20, Initiation of Cold Weather Operations for Unit 1, Revision 04 DOS 0010-21, Securing from Cold Weather Operations on Unit 1, Revision 03 Dresden Unit 1 Annual Report on Decommissioning,1997 DRP 5720-04, Routine Personnel Contaminations, Revision 07 j DRP 6020-02, Radiological Air Sampling Program, Revision 04 DRP 6020-03, Radiological Surveys, Revision 05 DRP 6210-16, Set-up and Operation of Portable AirFiltrationNentilation Equipment, Revision 0 NSWP-A-15, Comed Nuclear Division Integrated Reporting Program, Revision 1,5/5/97 Problem Identification Forms: D1997-06764 Q&SA identi6es Unit 1 radiologicalconcems D1997-06838 Q&SA identi6es tagging discrepancies in Unit 1 D1997-06884 Unit 1 selfidenti6ed negative human performance tren D1997-07924 Redpractice de6ciency on Unit 1 D1997-08221 Unit 1 airsamples not tumedin to Chemistryin a timely fashion D1997-08546 Supervisorputting down questioning attitude D1998-00217 Unlocked are > 1 RenVhridentified D1998-00712 ~ Inability to 6nd calibration documentation for air sampler i 20 !
.
,
i l l Root Cause Investigation Report, OrganizationalBreakdowns and Supervisory , Misjudgment Result in Employment Action and Notification of NRC Personnel, Report i NTS No. 010-200-97-00400, Revision 0 i Root Cause Investigation Report, Radiation Protection Integration into Dresden Station's Work Contro/ Process, P.eport NTS No. 237-251-97-04700, Approved 12/10/97 Root Cause Investigation Report, Unit 1 Contract PersonnelIntemally Contaminated During Work in Unit 1 Radweste Tunnel Caused by Personnel Errors, Report No. 010-200-97-00300, Revision 0 Root Cause Investigation Report, Unit 1 Contract PersonnelIntemally Contaminated During Work in Unit 1 Radweste Vault #1 Caused by Personnel Errors and Management Dcficiency, Report No. 010-200-97-00200, Revision 0 Unit 1. Facility Operating License No. DRP-2, Amendment No. 39, Appendix A, Technical Specifications, issued July 8,1997
!
UST OF ACRONYMS USED l ALARA As Low As Reasonably Achievable ; CARB Corrective Action Review Board Comed Commonwealth Edison DCS Dry Cast Storage HEPA High Efficiency Particulate Air HRA High Radiation Area ISFSI Independent Spent Fuel Storage Installation NOV Notice of Violation NRC Nuclear Regulatory Commission PlF Problem identification Form RP Radiation Protection RPA Radiological!y Protected Area RPM Radiation Protection Manager RPS Radiation Protection Supervisor RPT Radiation Protection Technician RWP Radiation Work Permit SFP Spent Fuel Pool TS Technical Specification VIO Violation i I l
21 ' l l
- - - _ - _ - _ - - - - - . -- - - o
}}