IR 05000010/1999009

Insp Rept 50-010/99-09 on 990325-0506.Non-cited Violations Noted.Major Areas Inspected:Licensee Mgt & Control, Decommissioning Support Activities & Radiological Safety

ML20206P257
Person / Time
Site:	Dresden
Issue date:	05/13/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206P247	List: IR 05000010/1999009 ML20206P243
References
50-010-99-09, 50-10-99-9, NUDOCS 9905180200
Download: ML20206P257 (10)

Text

i U.S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No: 50-10 License No: DPR-2

Report No: 50-10/99009(DNMS)

. Licensee: Commonwealth Edison Company Facility: Dresden Station Unit 1 Location: 6500 N. Dresden Road Morris,IL 60450

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Dates: March 25,1999 - May 6,1999 Inspectors: W. G. Snell, Health Physics Manager D. W. Nelson, Radiation Specialist Approved by: Bruce L. Jorgensen, C Decommissioning Branch Division of Nuclear Materials Safety 9905100200 990513 ?

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EXECUTIVE SUMMARY Dres'den Station Unit 1 -

NRC Inspection Report 50-10/99009(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 two Non-Cited Violation Facilitv Manaaement and Control e Overall management and control of the decommissioning process was adequat Although the staffing for Dresden Unit 1 appeared to be minimal at times, no significant problems were noted as a result. The decommissioning organization shifted its resources as necessary to achieve it's goals while ensuring radiological safety concerns were met. (Section 1.1)

e it was determined that the Year 2000 computer issue was not a concem for Dresden Unit 1. (Section 1.2)

Decommissionino Suooort Activities e The inspector verified that Technical Specification /Offsite Dose Calculation Manual surveillance requirements (Technical Specification Section 6.8.D.4.a Radioactive Effluent Controls Program) pertaining to the Main Chimney SPlNG were being conducted as required. (Section ll.1)

Radiolooical Safety e in general the Radiation Protection Program was effective in carrying out its function of ensuring radiological safety. However, two incidents occurred which resulted in Non-Cited Violations. In each of these cases the licensee identified and investigated the problem and took prompt corrective actions. (Section 111.1)

e A failure to perform adequate surveys prior to and during work in the Radwaste Vault 2 ,

resulted in a worker exceeding his Radiation Work Permit dose limit. This resulted in a l Non-Cited Violation. (Section Ill.1.b.1)

e Four Radiation Protection Technicians failed to perlorm pre-dive source checks of electronic dosimeters as required by procedure. Th's resulted in a Non-Cited Violatio l (Section Ill.1.b.2) )

e The licensee is continuing to make progress in the removal of the radioactive waste from the radwaste vaults and tanks. Radiological concems related to waste water inventory issues appear to be well understood and are being actively monitored by management. (Section Ill.2)

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l Report Details l

Summary of Plant Activities j l

Dresden Unit 1 major activities during 1999 have included radwaste tank / vault waste removal activities, the removal of physical interferences from the Spent Fuel Transfer Canal, and preparations for installation of a new cask handling crane syste j j

l. Facility Manaaement and Control l

! ,  ! ' Oraanization. Manaaement and Cost Controls i L

l g Scooe l'6801) j l- i

!- The inspector reviewed the licensee's systems for overall management and control of the decommissioning process. The inspector reviewed and evaluated the licensee's )

organization and staffing to verify licensing commitments were being met. The

, inspector also selectively examined and evaluated the licensee's planning and

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scheduling to determine their effectivenes Observations and Findinas l One significant organizational / management change was implemente In April 1999, the Unit 1 Decommissioning Plant Manager, Mr. Nate Leech, was replaced by Mr. Paul Planing. Prior to becoming the Unit 1 Plant Manager,

- Mr. Planing was the Programs Supervisor in the Dresden Units 2/3 Engineering Department. Mr. Leech had been both the Unit 1 Plant Manager and the Dry Cask ,

Storage Project Manager, and would continue in his capacity as the Dry Cask Storage 1

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Project Manage At the staff level, Dresden has been reducing the overall size of the Unit 1 work forc Although four full time Commonwealth Edison (Comed) Dresden employees had been moved from Unit 2/3 to Unit 1 as permanent Unit 1 workers, the contractor workforce l

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- was being steadily reduced. It was expected that all the contractor Radiation Protection Technicians (RPTs) would be let go by the end of July 1999. An additional Dresden Comed RPT was expected to be moved to Unit 1 in the futur While attending planning meetings the inspector noted that there were occasions when ,

an insufficient number of workers were available to support the planned work. When j these situations developed, work was prioritized and only the work that could be handled 'i while ensuring radiological and worker safety was conducted. At no time was work .

observed to be conducted without sufficient personnel to safely and correctly conduct the }ob.

t Conclusions (. Overall management and control of the decommissioning process was adequate.

l' Although the staffing for Dresden Unit 1 appeared to be minimal at times, no significant problems were noted as a resul '

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. i l Year 2000 (Y2K) Issue Scooe (71801)

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The inspector evaluated the licensee's actions to address the potential for Y2K problems to affect plant equipment for Dresden Unit b. - Observations and Findinas

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The inspector discussed the potential for Y2K problems associated with the licensee's activities with licensee personnel. The licensee provided a document dated February 24,1998, that addressed this issue. Three Unit 1 components were identified as having the potential of being affected by the Y2K issue: Unit 1 Fuel Building SPING, Unit 1 Chimney SPINC. and the Unit 1 Fuel Pool Recorder, in the event that any of .

these systems fallec, on' the SPINGs would be an issue, and then only the Main .

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Chimney SPING is t, ' .o the Technical Specifications (TS) through the Offsite Dose Calculation Manual (UDCM). In the event the Main Chimney SPING becomes inoperable, the only requirement is to attach a sample pump to the sample stream from tne Main Chimne Conclusions l l The inspector determined that the Y2K issue was not a concern for Dresden Unit . Decommissionino Suncort Activities

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11. 1 Maintenance and Surveillance Scooe (62801)

The inspector verified that TS/ODCM surveillance requirements pertaining to the Main Chimney SPING were being conducted as required, Observations end Findinas The Unit 1 TS Section 6.8.D.4.a. Radioactive Effluent Controls Program, states that the program shall include: " Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM." The ODCM provides the Unit 1 Main Chimney SPING surveillance and operability requirements and sampling frequencie The inspector reviewed the calibration results from February 1997 and June 1998, the results of quarterly tests from October 1997 to March 1999, and the grab sample results from April 28,1999. All the information reviewed showed that the surveillances and samples were conducted as required by the ODCM. No problems were note Conclusions TS Section 6.8.D.4.a, Radioactive Effluent Controls Program, was being implemented as require W '

ill. Radioloalcal Safety 111. 1 Occuoational Radiation Exoosure Scooe (83750) 4 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 Observations and Findinas b.1 Radiation Worker Exceeded Radiation Work Permit Dose Limit On February 25,1999, a contract robotics worker entered the Unit 1 Radwaste Vault The purpose of the entry was to move a robot from one area of the vault around an interference to another area, remove debris and other materials from the robot's path, and measure and inspect a sump. The entry was expected to take 15 to 30 minute The RWP specified an accumulated dose limit for the work of 100 mrem with an ED alarm set point of 80 mrem, and a dose rate alarm set point of 500 mrem per hour (mrem / hour).

The worker spent 24 minutes working in the vault, and was subsequently determined to have received a dose of 107 mrem. It was also determined that the dose rate alarm set point had been exceeded when a field of 756 mrem / hour was entered. The licensee documented this incident on a Problem Identification Form (P!F #D1999-01097) and followed up with an investigation and written report (Report No. 010-200-99-00100).

The licensee determined that the root cause of the event was "an inadequate work practice due to human error." Contributing causes included: not wearing a wireless radiation monitor which would have allowed remote monitoring of the workers dose; placing the workers dosimetry where he couldn't check it visually, and; working in a high ambient noise area while wearing a headset and with the ED under the protective clothing, which together prevented the worker from hearing the ED alarm Numerous errors were made in both the planning and carrying out of this job. Pre-job planning for this work was based on genal area dose rates only, which were reported to be 100 to 400 mrem / hour. Based on the known dose rates and the projected stay times, it should have been expected that the RWP limits would have been challenge No detailed survey data was obtained for the robot or debris in the vault even though it was known the robotics worker was to manually pick up and move the robot. Surveys from previous entries to work on the robot had shown levels of greater than 1000 mrem / hour on contact on the robot. During the work the RPT informed the robotics worker that the dose rates on the robot were 200 to 250 mrem / hour. Followup surveys for this incident showed contact readings on the bottom of the robot of 2000 mrem / hour and on the hoses of 500 to 1300 mrem / hour on contact. Post event surveys showed that the lowest dose rate that should have been seen in the area of the robot was 1000 mrem / hour, and the debris that was moved was measured to be 700 to 1500 mrem / hour on contac The lack of good survey data had been recognized during the job planning, pre-job brief, and high risk brief, with the decision made to compensate by having the RPT covering

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i the job conducting surveys of each item before the robotics worker handled it. However, the RPT stayed on a platform above the vault floor and took readings with a teletector (telescoping dose rate meter). This was an inappropriate place from which to perform adequate surveys. The licensee estimated that the RPT reported dose rates by a factor of 2 to 10 lower than what actually existed. The licensee concluded that had the initial surveys provided the actual dose rates, the job planning would have been significantly different. Further, had the RPT conducted proper surveys during the work and identified

the higher dose rates, and responded appropriately, the job would have been halted in l it's early stages.

l The licensee initiated numerous corrective actions in response to this event, including the termination of the RPT involved in this event. Other actions included the tailgating of this event with Radiation Protection (RP) Department personnel, evaluating the l contingencies for working in high noise areas and areas where they may not easily be

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able to read their dosimetry, adding this event into the RPT Continuing Training Program, and disciplining the RP Supervisor and As-Low-As-Reasonably-Achievable Enginee The failure to perform adequate surveys in conjunction with this job was contrary to

, 10 CFR Part 20.1501(a) which states: "Each licensee shall make or cause to be made, surveys that - (1) May be necessary for the licensee to comply with the regulations in this part; and (2) Are reasonable under the circumstances to evaluate - (i) The extent of radiation levels; and (ii) Concentrations or quantities of radioactive material; and (iii) The potential radiological hazards that could be present." This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC

Enforcement Policy. This violation was addressed in the licensee's corrective action

! program and adequate corrective actions were implemented, b.2 Failure to Source Check Remote Dosimetry On March 5,1999, it was discovered that RP personnel had not been completing a required step in a procedure involving water diving in the Unit 1 fuel / transfer pool Attachment C of NSP-RP-6202, Radiological Controls for Contaminated Water Diving

< Operations, Revision 0, dated May 13,1998, contained a Pre-dive and Post Dive Checklist that was to be completed by RP personnel. One of the checklist items stated:

" Verify diver's alarming dosimeters / remote dosimetry have the batteries changed and source checked the day of the dive." Although the RPTs verified that the batteries were changed each day when dives were performed, the dosimeters were never source

. checked. A total of four different RPTs had initialed that they had completed this checklist item on 28 separate days covering 43 dives during January and February 199 Upon discovery, this issue was documented as PiF #D1999-01199 and subsequently addressed under an Apparent Cause Evaluation (NTS #0102609920201) that was approved on March 25,1999. The licensee concluded that this procedural noncompliance was a human error caused by a lack of attention to detail, and that the RPTs had not fully read or understood the requirements of the procedure. The immediate corrective action was to source check the dosimeters that had been used, which showed that all the dosimeters were working properly and were within their calibration dates. Additional corrective actions included the termination of all four RPTs and the tailgating of the importance of paying attention to the details of the procedure y .

L From a health and safety standpoint, the failure to source check the dosimeters was not a significant concern. Attachment A, initial Pre-job Prerequisite / Set-up Checklist, of NSP-RP-6202, required the EDs to be response checked before they were used the first time, which was done. The EDs are also on a quarterly calibration schedule. Industry experience is that it is very rare to have a malfunctioning ED. In this situation the divers l wore four EDs which were continuously monitored remotely by an RPT while the dive l

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was in progress, in addition, the divers carried two underwater high range ion chambers, which were also remotely monitored. These ion chambers were used by the divers under instructions from the RPTs so the RPTs could continuously monitor and

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verify the dose rates in the areas and on objects where the divers were working. The l

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failure to conduct the required source checks notwithstanding, dose rate coverage and monitoring for the dives was extremely thoroug However, the failures to perform the source checks that were required by Attachment C of Procedure NSP-RP-6202, Radiological Controls for Contaminated Water Diving Operations, is contrary to TS 6.11 which states in part: " Procedures for personnel RP shall be . . . adhered to for all operations involving personnel radiation exposure." This Severity Level IV violation is being treated as a Non-Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This violation was addressed in the

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licensee's corrective action program and adequate corrective actions were implemented, b.3 Fuel Buildina Pier Installation Activities During the inspection the inspectors observed the loading of concrete blocks from the Unit i spent fuel pool into a radioactive waste shipping container. The concrete blocks were sections of the spent fuel pool building concrete floor that had been cut and removed to provide for the installation of forms and piers for the new spent fuel pool l building crane. Because of the potential for creating contaminated dust during the cutting of the floor, the inspectors reviewed the project airbome monitoring progra The spent fuel building is ventilated and the building's air is discharged through the Ur.it 1 stack. Particulates in the stack discharge are monitored continuously and filters from the stack monitor are collected and analyzed weekl The surface of the fuel pool building concrete floor has fixed contamination and to minimize the creation of contaminated dust during the cutting of the concrete floor the cutting blades were sprayed with water. To determine the levels of fixed contamination 4 the spray water was periodically collected and analyzed. Breathing zone air samples were also collected during cutting and soil samples are collected after the concrete blocks have been removed. All of the these measures were intended to protect the-workers inside the spent fuel pool buliding and to prevent the spread of contaminatio The inspectors' review of the program indicated that the measures had been effective in accomplishing the licensee's goals, Conclusions in most situations reviewed, the RP Program was determined to be effective in carrying out its function of ensuring radiological safety. However, two incidents occurred which resulted in Non-Cited Violations. In each of these cases the licensee identified and

investigated the problem and took prompt corrective actions.

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111. 2 RadWaste Treatment. and Effluent and Environmental Monitorina l Scooe (84750)

An in_spection and evaluation were made of the radioactive waste treatment system and associated water inventory activitie Observations and Findinas

Several Unit 1 waste tanks contained contaminated water that presented unique problems for the Dresden Unit i radioactive waste group. At the time of the inspection Unit 1 Tanks T-102 A and B, T-26A and B and T-117 all held rinse solution from the chemical decontamination of Unit 1 in 1983. The licensee wanted to drain the tanks by transferring the rinse to the Unit 2/3 radioactive waste system. However, the concentrates in Tank T-102 A and B contained slightly elevated levels of transuranics and if the concentrates were processed and concentrated further the licensee would potentially be prevented from disposing of the concentrates at a licensed burial site. In addition, the water quality (pH, conductivity, etc.) of the rinse did not meet the standards set by the Unit 2/3 radioactive waste program and the Unit 2/3 radioactive waste group had refused to accept the rinse. Therefore, Unit 1 had to process the rinse before it could be transferred to Unit 2/3 and the processing would have to be closely monitored to prevent the transuranic levels in the waste generated from exceeding the license requirements of the waste disposal site. After discussing the issue with individuals involved in the tank draining project, the inspectors concluded that management war well aware of the problem and the transuranic levels in the processing medium would be closely monitored during the processing of the rins Cleanup of the Unit 1 Resin Burial Tank (T-113) storage vault was continuing. Most of the sediment in the vault had been removed with approximately one half inch of sludge remaining. Cleanup of T-113 Tank was also continuing, with most of the resin having been removed and approximately 8 to 10 inches of resin remaining in the tank. The cleanup of Unit 1 Sludge Burial Tank (T-113) storage vault was about 75 percent complete. The cleanup of Tank T-113 had been delayed, however, pending resolution of a number of technicalissues involving attemate cleanup technologies. As of the inspection, approximately 1-3 feet of hardened sediment remained in the tank, Conclusions The licensee was continuing to make progress in the removal of the radioactive waste from the radwaste vaults and tanks. Radiological concems related to waste water inventory issues appear to be well understood and were being actively monitored by managemen V. Manaaement Meetina

' The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on May 6,1999. 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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PARTIAL LIST OF PERSONS CONTACTED Licensee

• Ken Alnger, Licensing Director, Zion /Dresden Unit 1 Nate Leech, Dry Cask Storage Project Manager

• Jim Limes, Licensing / Compliance Engineer

• C. McDonough, Unit 1 Maintenance & Construction ,

• Bob Norris, Lead HP Supervisor, Unit 1 1

• Paul Planing, Plant Manager Unit 1

• Bob Speck, Nuclear Oversight

• Denotes those attending the exit meeting on May 6,199 The inspector also interviewed other licensee personnel in various departments in the course of the inspectio '

lNSPECTION PROCEDURES USED IP 36801: Organization, Management & Cost Controls at Permanently Shut Down Reactors IP 62801: Maintenance and Surveillance ct Permanently Shut Down Reactors IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 83750: Occupational Radiation Exposure j IP 84750: Radwaste Treatment, and Effluent & Environmental Monitoring j

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable

' Comed Commonwealth Edison ED Electronic Dosimeter NCV Non-Cited Violation NRC Nuclear Regulatory Commission ODCM Offsite Dose Calculation Manual PIF Problem identification Form RP Radiation Protection RPT Radiation Protection Technician RWP- Radiation Work Permit TS Technical Specification l

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DOCUMENTS REVIEWED Apparent Cause Evaluation (NTS #010-260-99-20201), Unit 1 RPT Failed Daily Source Check of Remote Dosimetry, March 25,199 Apparent Cause Evaluation (NTS # 010-200-99-00100), Unit 1 Radiation Worker Exceeds RWP Dose Limi Comed Correspondence from Sigwerth to Marchi, Year 2000 /ssue, dated February 24,199 DAP 12-09, Dresden Station ALARA Program, Rev.16, Pre-job Briefing Checklist for RWP 991013, dated 2/23/9 DRP 5500-01, Radiological Respiratory Control Program, Rev. 5, TEDE ALARA Evaluation

' Worksheet for RWP 991013, dated 2/18/9 NSP-RP-6202, Radiological Controls for Contaminated Water Diving Operations, Revision 0, dated May 13,199 Offsite Dose Calculation Manual, Revision 1.8,' July 199 Problem identification Forms:

1. D1999-01199 Unit 1 RPT Failed Daily Scurce Check of Remote Dosimetry

1. D1999-C 197 Unit 1 Radiation WorkerExceeds RWP Dose Limit RWP 991C . Rev 1., Unit 1 Redweste Vault Cleanup Project Activitie Unit 1, Fact )perating License No. DRP-2, Amendment No. 39, Appendix A, Technical Specifications isued July 8,199 ,