IR 05000010/1998013
| ML20236L134 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236L119 | List: |
| References | |
| 50-010-98-13, 50-10-98-13, NUDOCS 9807100240 | |
| Download: ML20236L134 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION !!!
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Docket No: 50-010 :
License No: DPR-2 l Report No: 50-010/98013(DNMS) l l
Licensee: Commonwealth Edison Company Facility: Dresden Station Unit 1 Location: 6500 N. Dresden Road Morris,IL 60450 Dates: March 19,1998 - June 30,1998 Intpectors: William G. Snell, Health Physics Manager David W. Nelson, Radiation Specialist Approved By: Bruce L. Jorgensen, Chief '
Decommissioning Branch Division of Nuclear Materials Safety l
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EXECUTIVE SUMMARY Dresden Station Unit 1 NRC Inspection Report 50-10/98013(DNMS)
This routine decommissioning inspection covered aspects of licensee management and control, l spent fuel safety, and radiological safety. Followup inspection was performed on a number of l l previously identified issue Facility Manaaement and Control e A new Decommissioning Plant Manager was named on June 29,1998. Staffing and organization for the Decommissioning of Dresden Unit 1 remains adequate. (Section 1.1).
e The licensee's process for complying with 10 CFR 50.59 was determined to be adequate to ensure that changes to Unit 1 were properly evaluated against appropriate criteria, and evaluations performod were thorough and well documented. (Section 1.2)
e Quality and Safety Assessment (Q&SA) oversight of Unit 1 decommissioning activities was excellent. The 1997 Q&SA Audit of Unit 1 decommissioning activities was broad in scope and range and many deficiencies were identified. However, it lacked assessments of potential programmatic weaknesses. (Section 1.3)
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Soent Fuel Safety l
e The licenseo's planning and preparation for work involving the movement of fuel was excellent. Their work packages and briefings were very thorough, broad in scope, and stressed safety first. Other than some delays in getting started with the movement of the fuel assembly in the Unit 1 SFP, the work was carried out without any problems and with good radiological controls and practices. (Section 11.1)
Radiological Safety e Radiological controls and postings in all areas toured appeared to be in compliance with station procedural requirements. The policy of tagging of clean objects with " Caution Radioactive Materials" tags was seen as a poor practice and the policy did not appear to l be universally implemented. (Section 111.1)
e The licensee continues to make progress in the removal of radioactive waste from the l radwaste vaults and tanks. Radiological controls associated with those activities appeared to be adequate. (Section 111.2)
e The characterization of radioactive waste for packaging and shipment by Dresden Unit 1 l was found to be carried out as required, and documentation and record keeping were up l to date and complete. The training of personnel related to the packaging and shipping of
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radioactive waste appeared acceptable. (Section Ill.3)
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e An issue rernains regarding set up of the Unit 2 and 3 Hot Shop on the Unit 1 Turbine Floor, in that a safety review may not have been performed. The licensing basis for l
future safety reviews was established clearly with the June 29,1998 issuance of the l Defueled Safety Analysis Report. (Section IV)
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Report Details Summary of Plant Activities I
Dreaden Unit 1 was commercially operated from July 1960 until October 31,1978, when it was ,
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taken offline to add new equipment and perform a chemical decontamination of the major piping systems. Wnile 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 l Island accident, the decision was made to retire Unit 1. The chemical decontamination was i completed in September 1984, and the decision to decommission Unit 1 was made in October j l
198 The Unit 1 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 .
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the Unit i 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, j Dry Cask Ctorage (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 that are taking place in 1998 include radwaste tank / vault waste removal activities, cutting and capping of radwaste system piping, characterization of the fuel, and continued asbestos abatemen . Facility Manaaement and Control i Organization. Manaaement and Cost Controls .
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The Inspector reviewed the licensee's organization and staffing for overall management and control of the decommissioning proces Observations and Findinas In early June 1998, Cliff Howland, Dresden Unit 1 Decommissioning Plant Manager, was moved to the Comed position of Corporate Radiation Protection Manager. Nate Leech, the Dry Cask Storage Project Manager, assumed the additional responsibility of Acting Decommissioning Plant Manager on an interim basis. On June 29,1998, Mr. Leech was permanently assigned to the Decommissioning Plant Manager position, which included the elimination of his previous position as Dry Cask Storage Project Manager. As Plant Manager he will maintain responsibility for both positions. The inspector discussed with Mr. Leech whether he could reasonably assume the responsibilities for both positions and ensure both areas received the attention needed. He stated that it should not be a problem in that the level of work relating the Dry Cask Storage Project Manager position was expected to decrease in the near future. No other significant staffing or organizational changes were made since the last inspectio _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ - - _ _ _ _ _ _ _ _
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c. Conclusions Staffing and organization for the Decommissioning of Dresden Unit i remains adequate Safety Reviews l
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I a. Scooe (37801)
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The inspector reviewed the licensee's program for complying with 10 CFR 50.59. The
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review included an examination of the licensee's administrative procedures to determine if the licensee adequately evaluated proposed changes, tests, and experiments as defined in 10 CFR 50.59. In addition, the inspector reviewed the training requirements and records for those individuals preparing and reviewing these evaluations for Unit b. Observations and Findinas The licensee documented its 10 CFR 50.59 evaluations using Nuclear Station Work j Procedure NSWP-A-04. This procedure was first implemented in March 1997 and was used for screening changes to the plant and specifying preparer / reviewer qualification The inspector reviewed this document and determined that it gave adequate guidance as to when a 10 CFR 50.59 evaluation was required. In addition, the inspector reviewed Dresden Decommissioning Procedure DDP 05," Control of Decommissioned Plant Equipment for Unit 1." This procedure provided methods for the licensee to identify and i evaluate obsolete plant equipment or systems for potential retirement, decommissioning, l or removal. This procedure, in addition to discussions with procedure reviewers, provided the inspector with reasonable assurance that Unit 1 plant equipment would not be removed or abandoned without an appropriate 10 CFR 50.59 safety evaluation first being performe q l
Based on four of the most recent quarterly 10 CFR 50.59 safety evaluation reports i submitted by the licensee, the inspector identified eleven 10 CFR 50.59 evaluations l performed for Unit 1. The inspector reviewed four of these including safety )
evaluation 1998-01-049H which addressed the licensee's cleanup of their radioactive l waste tanks and vault. This was an ongoing work activity at the time of the inspectio l i
The inspector concluded that these evaluations were complete and in compliance with the license's procedures and 10 CFR 50.5 The inspector reviewed the training records of those individuals that were identified by the licensee as being qualified to prepare and review 10 CFR 50.59 evaluations for Unit The records were determined to be complete and current. In addition, the inspector l compared the names of preparers and reviewers on eight Unit 110 CFR 50.59 ,
evaluations and found that they were all qualified to perform these dutie l
c. Conclusions The process that the licensee used to comply with 10 CFR 50.59 was determined to be adequate to ensure that changes to Unit 1 were properly evaluated against appropriate I
criteria. The inspector concluded that the licensee's evaluations were thorough and well documente _ - -- _
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l.3 Self-Assessment. Auditina and Corrective Actions Scope (40801)
The licensee's controls for identifying, resolving and preventing issues that degrade safety or quality were examined, including self-assessments, corrective actions, safety review committees and root cause evaluations. The program was evaluated from the 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 Observations and Findinas i
The inspectors reviewed the Quality and Safety Assessment (Q&SA) 1998 Field Monitor ,
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Reports and the Q&SA 1997 Audit Report of Unit 1 Decommissioning Activities. Reviews l of the 1998 Field Monitor Reports for Unit 1, indicated excellent Q&SA oversight of the Unit 1 decommissioning activities. Q&SA auditors, at a minimum, performed weekly walkdowns of Unit 1, attended pre-job briefings, observed work activities, reviewed l documents and procedures and observed radiation protection technician and worker performance at the RPA egress point and at various job sites. A wide range of adverse findings were identified in the reports and they were either corrected immediately or reported in the appropriate deficiency reporting instrument The 1997 Q&SA audit was broad in scope and range and the auditors identified many deficiencies and adverse trends. The auditors found deficiencies in schedule adherence,
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radioactive material (RAM) control, radiation work practices, radiation worker knowledge and records control. Based on the findings of this audit, work at Unit 1 was stopped by Q&SA to allow Unit 1 management to address the deficiencies identified by the auditors.
l The incpectors noted that the adverse findings had also been reported in the appropriate
! deficiency reporting instruments and improvements in performance had been noted by l the auditors following the work stoppage.
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At the exit meeting the inspectors noted, however, that the Audit Report had not included an assessment of Unit 1 programs that may have led to the adverse findings. Specifically the auditors did not identify programmatic weaknesses that may have led to deficiencies in schedule adherence, RAM control, RP practices or radiation worker knowledge. For example, possible weaknesses in the radiation worker training program that could have led to the deficiencies identified by the auditors were not discussed or addressed in the Audit Report. Although programmatic assessments may have been beyond the scope of the Audit, the number of deficiencies identified during the Audit should have warranted the expansion of the Audit to include those programmatic assessment Conclusions Q&SA oversight of Unit i decommissioning activities was excellent. The 1997 Q&SA Audit of Unit 1 decommissioning activities was broad in scope and range and many deficiencies were identified. However, it lacked assessments of potential programmatic weaknesse E .
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l Decommissioning Performance and Status Review a. Scope (71801) l l
Plant tours were conducted to evaluate the materialintegrity of structures, systems, and I
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components necessary for the safe storage of spent fuel and the conduct of safe decommissioning, and to evaluate plant housekeepin b. Observations and Findinas The inspectors toured the Unit 1 Turbine and Containment buildings and the Unit 2 and 3 ,
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Hot Shop. Good housekeeping practices were noted in the Turbine building. Although I i some rooms in the Containment building were cluttered with equipment and debris, the l open walkways were generally clean and well maintained. No problems were noted with l l
the materialintegrity of structures, systems, and components observed that could be {
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c. Conclusions
Good housekeeping practices were observed in the Turbine Building and general I walkways within the Containment building. Housekeeping in some areas of the (
Containment Building, however, needed improvemen l 11. Spent Fuel Safety 11. 1 Fuel Handlina Activities i a. Scope (60710)
i An inspection and evaluation were made of the preparations for and movement of a fuel .
I l bundle in the spent fuel pool to ensure activities were being controlled and conducted as
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l required by Technical Specifications and approved procedure b. Observations and Findinas On April 30,1998, the inspector observed the licensee move a fuel assembly from a j channel storage rack in the fuel pool to a fuel basket carrier in the transfer pool. The movement was conducted as planned, with no problems noted from corrosion that had
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built up over the years between the fuel assembly and channel storage rac l
! On March 19,1998, the inspector attended the licensee's Plant Onsite Review Committee (PORC) meeting, which was conducted to review the plans for moving !
l one fuel assembly in the Unit i fuel pool and transfer canal. The purpose of moving the assembly was to ensure that the corrosion product that had built up over the years between the fuel assembly and the fuel channels holding the assembly would not damage i the assembly when it was moved. In addition to this move, samples of corrosion debris !
l were to be collected for analysis. The inspector also attended a High Level of Activity
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(HLA) meeting on April 29,1998, which discussed all aspects of the fuel assembly move ,
that was to be performed, and pre-job briefings on April 29 and 30,199 ;
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All meetings and briefings were very thorough in detail and addressed all concerns and questions that were raised. The meetings ensured that everyone understood what roles and levels of authority other team members had, what the anticipated radiological conditions were, what actions were to be taken for various scenarios that could occur once work was begun, and that conducting the work in an unrushed and s, i manner was paramount. All personnel involved in the fuel movement were required to be present at the HLA meeting and the pre-job briefing Although the work site had been set up in advance, there were several last minute issues that delayed initiation of work. The first was the decision to install a new monitor with which to view the picture sent from cameras that were being employed to video tape the movement of the fuel assembly. Problems were encountered with the installation of this monitor. A problem was also discovered with the underwater camera, which had to be replaced with a second camera that was initially going to be used elsewhere. The krypton-85 monitor was also alarming spuriously due to the build up of radon because it had been left running over night. This required waiting for a technician to arrive from Unit 2/3 to change out the filter to ensure it would not alarm during the fuel move due to radon buildu ]
Good HP practices were observed throughout the work. The cable and grapple were hosed down and wiped when removed from the pool, and the workers performing the wiping wore double gloves which were changed frequently.
l On June 9,1998, the inspector attended the licensee's pre-job brief and HLA meeting associated with the characterization of Unit 1 fuelin the Unit 2 and 3 fuel pools. Although these meetings were rather long, they were thorough in their coverage of the work to be accomplished and appeared of benefit in clarifying some worker concems. On June 18, 1998, the inspector observed some of the fuel characterization being performed in the Unit 3 spent fuel pool. No concems were noted with the radiological controls that were established or radiological practices that were observe Conclusions The licensee's planning and preparation for work involving the movement of fuel was excellent. Their work packages and briefings were very thorough, broad in scope, and ,
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stressed safety first. Other than some delays in getting started with the movemcnt of the fuel assembly in the Unit 1 fuel pool, the work itself was carried out without any problems and with good radiological controls and practice Ill. Radioloalcal Controls 111. 1 Occupational Radiation Exoosure Scope (83750)
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 area (..
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D b. Observations and Findinas During tours of the Unit 1 Turbine and Containment buildings the inspectors noted that all areas within both buildings appeared to be properly controlled and appropriately poste Survey maps for both buildings were posted at the Unit 1 access point and surveys 3 appeared to have been performed within the time constraints specified in station procedures. Each survey map appeared to have sufficient information to accurately convey the radiological conditions in the areas surveye During a tour of the Containment and Turbine buildings the inspectors noted that all of the containers and many of the items in the Containment and Turbine buildings had been i tagged with " Caution Radioactive Materials" tags. The inspectors noted, however, that in many cases that containers and items had been tagged even though they were not contaminated and/or did not house items that were contaminated or radioactive, as evidenced by the "NCF" for No Contamination Found, and "<1mR/hr" for less than 1 milliroentgen per hour exposure rate, written on the tag. When asked about this, the licensee indicated that in the past many contaminated and/or radioactive objects had been found outside the RPA and the facility had adopted the practice of tagging all containers to partially correct this deficienc The inspectors indicated at the exit meeting that they considered the policy to be a poor radiological practice. Since radiological tags and postings were meant to convey information regarding the radiological condition of the object or area tagged or posted, i identifying clean objects as radioactive could cause confusion and lead to a disregard of other tags or postings. While this over posting practice was not considered a violation of NRC regulatory requirements, the practice was discussed at the exit meetin The inspectors also noted during a tour of the Unit 2 and 3 Hot Shop located on the Unit 1 turbine deck that the tagging practice did not appear to be uniformly applied. During l the tour the inspectors observed several containers that had not been tagged as l
radioactive even though the Hot Shop was located in the Radiologically Protected Area (RPA). A discussion with the licensee indicated that the containers had just recently been moved to the Hot Sho The inspector also reviewed the asbestos removal procedures, training records, medical surveillance records, air sampling results, and required asbestos removal licenses for asbestos workers at Dresden. Overall, records and procedures were acceptabl c. Conclusions l
Radiological controls and postings in all areas toured appeared to be in compliance with
! station procedural requirements. The policy of tagging of clean objects with " Caution Radioactive Materials" tags was seen as a poor practice and the policy did not appear to h La universally implemented. Asbestos abatement practices appeared adequate.
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Il RadWaste Treatment. and Effluent and Environmental Monitorina Scope (84750)
An inspection and evaluation were made of the radioactive waste treatment systems and activitie Observations and Findinas The inspectors toured the radwaste yard and facilities to evaluate activities involving the removal of sludge / water from the radwaste vaults and tanks. Waste was being processed by being pumped into a system for drying the material and depositing it into a shipping container. Radiological controls for the operations observed appeared adequate. During the inspection the licensee was investigating several minor incidents that had occurred regarding radwaste operations. These included the mistagging of a drum of waste and a worker who crossed over into a high radiation area to assist with work when his role was to stay outside of the high rad area. The preliminary indication was there were no adverse health or safety consequences from either of these occurrences, but the licensee was actively looking why these incidents occurred in the first plac Conclusions The licensee continues to make progress in the removal of radioactive waste from the radwaste vaults and tanks. Radiological controls associated with activities appeared to be adequat Il Solid Radwaste Manaaement and Transportation of Radioactive Materials Scope (86750)
An inspection and evaluation were made of the procedures and documentation for the packaging and shipment of radioactive materials, and of the training records for the Unit 1 management and laborers responsible for packaging Unit i radioactive material or waste in hazardous materials shipping container Observations and Findinas The inspector reviewed DRP 5600-04, Completion of Radioactive Material Shipping Record, DRP 5600-07, Shipment of Radioactive Matenals, DRP 5610-06, Surveying Radioactive Material Shipments, along with the records from several shipments of radioactive material from Dresden Unit 1. The records included completed Uniform Low-Level Radioactive Waste Manifests, as well as numerous forms from the above procedures. In all cases the procedures and documentation were found to be adequate to ensure radioactive waste was being property characterized and packaged prior to shipment. No problems were noted with any of the records of calculations or of the surveys performe _ _ _ _
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The shipment of radioactive waste is handled as a joint effort for all three Units, with Units 2 and 3 maintaining primary responsibility. The training records of the Unit 1 key manager responsible for this area were reviewed and were found to be acceptable with training up to date and as required. Discussions with the cognizant manager indicated that he was knowledgeable of his duties and responsibilities. The training records for the Unit i laborers responsible for packaging Unit i radioactive material or waste in hazardous materials shipping containers indicated that they had received training on the Department of Transportation (DOT) requirements on April 7,1998. The training appeared to have met DOT requirements Conclusions The characterization of radioactive waste for packaging and shipment by Dresden Unit 1 was found to be carried out as required, and documentation and record keeping were up to date and complete. The cognizant Unit manager had been adequately trained on his responsibilities for shipping of radioactive waste, and the laborers had received the proper DOT training and the training was performed within the time constraints of the DOT regulations IV. Previousiv identified Issues (92701)
(Closed) IFl 50-010/94009-06: Spent Fuel Pool (SFP) gate between SFP and Transfer Cana This item had been partially addressed in Inspection Reports 50-010/94019 and 50-010/95008, leaving only the replacement of the lower gate gasket as an issue requiring followup. In August 1995 a new bottom seal for the SPF gate was installed under Work Request No. 94098373-0 The Work Request package was reviewed, which indicated the installation was completed without any problems. It has been in place for almost three years now, and no problems with the gate seats have been note (Closed) IFl 50-010/94019-05: Heating requirements related to presence of "A7" steel in various components in containment. A review was made of the licensee's closure package for this issue under NTS #0101009401905. The package showed that the A7 steel was evaluated in August 1995 by testing three coupons of 6"x17"x3/4." The testing confirmed the presence of A7 steel, and stated it would be addressed by limiting loads on various platforms and cranes at low temperatures. The package also contained the results of an evaluation by Sargent & Lundy dated January 20,1995, that stated that the localized heating conducted in the sphere as part of the winterization actions was sufficient to ensure that an adequate margin of safety existed for site personnel and the publi (Closed) IFl 50-010/95008-04: A corroded steel beam was attached to the fuel rack in the Unit 1 SFP. A review was made of the licensee's closure package for this issue under NTS #0101009500804. The package stated that the results of an evaluation by Sargent & Lundy determined that the beam performed no structural function and had no impact on the structural adequacy of the spent fuel rack (Closed) URI 50-010/95015-06: Evaluations were unavailable that could address discrepancies between licensing documents and operating practices related to operation of the Unit i ventilation systems. The ventilation system for Unit 1, with the exception of the Fuel Building, had been shut down for a number of years. This raised questions regarding whether, 1) all potential releases would pass through Unit 1 chimney as a monitored release pathway,
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2) an unmonitored release path could exist from the Units 2 and 3 Hot Machine Shop that had been erected in the Unit 1 Turbine Building, and 3) the Sphere and Turbine Building asbestos removal could result in an increase in the migration of byproduct material. In addition, the Unit i Decommissioning Plan had not been updated to accurately reflect the licensing basis.
l The licensee had limited historical records on Unit 1. Because of the age of the Unit, (it began commercial operation in 1960), it had no Final Safety Analysis Report as a licensing basis. As a result, determining what was done in the past and the basis for those decisions has been difficult. For example, it appears that the ventilation system was shut down in 1988 or 1989, but no document was readily available to provide a specific date. Additionally, no safety analysis related to shutting the system off was available from when the system was shut down. Therefore, subsequent to and in response to this issue being raised in Inspection Report 50-010/95015, the licensee conducted an evaluation in early 1996 to determine whether there were any safety issues resulting from not running the ventilation systems for the Unit 1 Off-Gas Building, Turbine Building, Maintenance Shops, and Sphere. The evaluation was
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conducted in part using Form 10-2C,10 CFR 50.59 Safety Evaluation, from Dresden Administrative Procedure (DAP) 10-02, Revision 13. The conclusion of the safety review was that an unreviewed safety question did not exist. This was based on the fact that those portions of the facility where the ventilation systems had been tuned off no longer contained operational systems from which appreciable airborne releases could result. In addition, work that was conducted on a contaminated system was/would be controlled by a Radiation Work Permit (RWP). The Offsite Dose Calculation Manual (ODCM) also conservatively accounted for the unventilated areas by computationally multiplying any radioactivity measured in the Unit 1 Main Chimney monitor by the assumed cumulative air flows for all area This issue was further researched by the licensee during this inspection. The licensee reviewed over 900 work requests since the beginning of 1996 through late June of 1998, and identified 25 that contained significant radiological work. For these 25 cases they reviewed the air sample data. In each case they determined that adequate air sampling had been conducted to ensure the protection of the workers. Their review also concluded that the sampling conducted was adequate to ensure that an unmonitored release of radioactive material could not have occurred undetecte However, to address concems by the inspector regarding conducting sampling for the purpose of ensuring an unmonitored release would not occur undetected, not just for the purpose of protecting the worker, the licensee began conducting additional area monitoring. As of June 30,1998, area air sampling was being conducted in the Sphere, on the Turbine Floor, and in the Radwaste Building. Sampling was to continue as long as work was being performed or it could be established that no radiological effluents exist. Samples are to be counted weekly, and as appropriate, the results included in the ODC These actions were considered adequate to address most concems related to this unresolved item. However, it still wasn't clear if a safety review had been conducted when the Unit 2 and 3 Hot Shop had been set up on the Unit 1 Turbine Floor. The licensee was still researching this issue. This issue will be tracked under a new item, 50-010/98013-01 and reviewed during a future inspectio The issue related to the licensing basis for Unit 1 has been addressed in that the licensee issued their Defueled Safety Analysis Report on June 29,1998. This document is now the licensing basis to be used for Unit _ _ _ _
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l (Closed) URI 50-010/97013-06: 250 vde battery loading calculation. This item was opened regarding Units 2 and 3, and was inadvertently entered into the tracking system for Unit 1. This
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item is not pertinent to Unit 1.
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V. Previousiv Identified Violations and Deviations (92702)
(Closed) VIO EA 50-010/94044-01013: Notice of Violation and Civil Penalty associated with the 1994 Unit 1 Service Water Pipe Freeze Event. The Service Water Pipe Freeze resulted in two violations: 50-010/94001-09A,098, and 09C, and 50-010/94001-10. These items were addressed and closed in NRC Inspection Reports 50-010/94014(DRP) and 50-010/94019(DRP).
(Closed) VIO 50-010/97013-01: Appendix B, to 10 CFR Part 50 item conceming issues adverse to quality. This item was opened regarding Units 2 and 3, and was inadvertently entered into the tracking system for Unit 1. This item is not pertinent to Unit (Closed) VIO 50-010/97024-01: Both trains of Stand-by Liquid Control subsystems were inoperable, and the plar.t was not brought to at least a hot shut down condition. This item was apened regarding Units 2 and 3, and was inadvertently entered into the tracking system for Unit 1. This item is not pertinent to Unit VI. Manaaement Meetina The inspectors presented the inspection results to members of licensee management at the conclusion of the onsite portion of the inspection on June 18,1998, and during telephone calls on June 25 and 30,1998. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspectors as proprietar _ _ _ _ _ _ _ _ - - - _ -
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I PARTIAL LIST OF PERSONS CONTACTED
l Licensee
- K. Ainger, Decommissioning Services Licensing Manager
- R. J. Christensen, Operations Manger i L. Ferrell, Procedure Writer
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J. C. Howland, Corporate Radiation Protection Manager
- B. Kobel, Compliance Engineer
- J. N. Leech, Decommissioning Plant Manager Unit 1
- J. Limes, Licensing / Compliance Engineer
- Denotes those attending the exit meeting on June 18,199 ' Denotes those participating in telephone calls on June 25 and 30,1998.
l l The inspector also interviewed other licensee personnel in various departments in the course of i
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 Roactors IP 40801: Self-Assessment, Auditing, Corrective Action IP 60710: Refueling Activities IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down I Reactors l lP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive ;
Materials IP 92701: Followup l IP 92702: Followup on Corrective Actions for Violations and Deviations 1
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ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-010/98013-01 Safety review documentation regarding placement of Unit 2/3 Hot Shop on the Unit 1 Turbine Floor Closed l I
010/94009-06 IFl Replacement of the lower gasket for the Spent Fuel Pool (SFP) gate between SFP and Transfer Cana /94019-05 IFl Heating requirements related to presence of "A7" steel in various components in containmen /95008-04 IFl A corroded steel beam was attached to the fuel rack in the Unit 1 SF l 010/97013-06 URI 250 vde battery loading calculatio l 010/95015-06 URI Evaluations were unavailable that could address discrepancies between licensing documents and operating practices related to operation of the Unit 1 ventilation syste /97013-01 VIO Appendix 8 to 10 CFR Part 50 item conceming issues adverse to qualit /97024-01 VIO Both trains of Stand-by Liquid Control subsystems were inoperabl /94044-01013 VIO EA Notice of Violation and Civil Penalty associated with the 1994 Unit 1 Service Water Pipe Freeze Even ,
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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable Comed Commonwealth Edison DAP Dresden Administrative Procedure DCS Dry Cask Storage DOT Department of Transportation DRP Dresden Radiological Procedure HLA High Level of Awareness HRA High Radiation Area NOV Notice of Violation NRC Nuclear Regulatory Commission NSWP Nuclear Station Work Procedure ODCM Offsite Dose Calculation Manual PORC Plant Onsite Review Committee Q&SA Quality & Safety Assessment RAM Radioactive Material RP Radiation Protection RPA Radiologically Protected Area RWP Radiation Work Permit SFP Spent Fuel Pool TS Technical Specification VIO Violation i
DOCUMENTS REVIEWED NSWP-A-04,10 CFR 50.59 Safety Evaluation Process, Revision 1,11/6/97 DDP 05, Contml of Decommissioning Plant Equipment for Unit 1, Revision 1 DDP 10, Decommissioning Impact Evaluations, Revision 1 Decommissioning Program Plan, Revision No. 5, December 1996 Dresden Unit 1 Annual Report on Decommissioning,1997 Dresden Nuclear Power Station Post-Shutdown Decommissioning Activities Report, May 199 Unit 1, Facility Operating License No. DRP-2, Amendment No. 39, Appendix A, Technical Specifications, Issued July 8,1997 DRP 5600-04, Completion of Radioactive Material Shipping Reconi, Revision 03 DRP 5600-07, Shipment of Radioactive Materials, Revision 0 DRP 5610-06, Surveying Radioactive Material Shipments, Revision 04
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