IR 05000010/1999013

Insp Rept 50-010/99-13 on 990702-27.No Violations Noted. Major Areas Inspected:Aspects of Facility Management & Control & Radiological Safety

ML20210L137
Person / Time
Site:	Dresden
Issue date:	08/02/1999
From:	Jorgensen B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210L111	List: IR 05000010/1999013 ML20210L106
References
50-010-99-13, NUDOCS 9908090044
Download: ML20210L137 (9)

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U.S. NUCLEAR REGULATORY COMMISSION i REGION lli

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Docket No: 50-10 License No: DPR-2 Report No: 50-10/99013(DNMS)

Licensee: Commonwealth Edison Company

Facility: Dresden Station Unit 1 !

Location: 6500 N. Dresden Road Morris,IL 60450 Dates: July 2,1999 - July 27,1999 Inspectors: W. G. Snell, Health Physics Manager Approved by: Bruce L. Jorgensen, Chief Decommissioning Branch Division of Nuclear Materials Safety 9908090044 990802 PDR ADOCK 05000010 0 PM ,

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I EXECUTIVE SUMMARY Dresden Station Unit 1 NRC Inspection Report 50-10/99013(DNMS)

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This routine decommissioning inspection covered aspects of facility management and control and radiological safet Facility Manacement and Control

• Overall, management and control of the decommissioning process was adequat Although there continues to be a turnover in the Unit 1 Radiation Protection Supervisor position, no problems were noted as a result of these changes. (Section 1.1)

• The licensee's 10 CFR 50.59 safety reviews were thorough, well documented, and adequate to ensure that changes to Unit 1 were properly evaluated against appropriate criteria. (Section 1.2) I

• Overall, the licensee's identification and resolution of issues that degrade safaty or quality were determined to be adequate to ensure safety and quality in the conduct of activities. The Problem Identification Form system was being effectively implemented to identify and respond to problems and concerns. (Section 1.3)

• Good housekeeping practices were observed in the Fuel Building and Radwaste Yard while efforts for improvement were continuing. (Section 1.4)

Radioloaical Safety

• The Radiation Protection Program was determined to be effective in carrying out its function of minimizing occupational exposure and ensuring radiological safet (Section l1.1)

• The licensee was doing a good job c' ssessing the radiological content of and handling of soil, asphalt, and concrete waste nuterial generated during decommissioning activities. (Section 11.2)

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Report Details Summarv of Plant Activities Dresden Unit 1 major activities during mid-1999 have focused on a continuation of the radwaste tank / vault waste removal activities and preparations for the installation of a new cask handling I crane system. This latter effort has primarily involved excavation work for the installation of piers to support the new cran . Facility Manaaement and Control Oraanization. Manaaement and Cost Controls Scooe (36801)

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 {

scheduling to determine their effectivenes Observations and Findinas in early June 1999, Mr. Harry Bush took over, on an interim basis, the position of Radiation Protection (RP) Supervisor for Unit 1. He will be succeeded by a permanent )

replacement around the beginning of October 1999 when Mr. Bush retums to the Unit 2/3 side of the plant to support the Unit 2 refueling outage. During the short period

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that Mr. Bush had been directing the RP Program on Unit 1, he had focused his efforts at better defining and raising worker expectations, and in improving the scheduling of work to ensure an adequate level of health physics coverage is available when neede Based on observations of work being performed, a review of various documents, and discussions with workers, it appeared that Mr. Bush's changes were being effectively incorporated into the progra The licensee had expected that by mid-summer 1999 the contract Radiation Protection l Technician (RPT) work force would have no longer been necessary to support Unit 1 activities. However, due to delays in the radwaste tank / vault waste removal activities, the reduction in the contractor RPT work force had been delayed. At the time of the ,

inspection it was expected that by mid-fall 1999 all the contractor RPTs will have been let go and only permanent Commonwealth Edison (Comed) Dresden RPTs will provide the radiation potection coverage for Unit c. Conclusions Overall, management and control of the decommissioning process was adequat A:though there continues to be a turnover in the Unit RP Supervisor position, no problems were noted as a result of these change ..

, Safety Reviews Scooe (37801)

The inspector reviewed the licensee's program for complying with 10 CFR 50.59. The review included an examination of a selection of the licensee's 50.59 reviews to determine if the licensee had been adequately evaluating proposed changes, tests, and experiments as specified by procedur Observations and Findinas The inspector reviewed a list of the 50.59 safety evaluation reviews conducted for Unit 1 since the beginning of 1998, which included over 40 completed safety evaluations. In all cases the evaluations concluded an unreviewed safety evaluation did not exist. The inspector conducted a detailed review of four of the safety evaluations: 1998-03-195,

'which addressed an administrative change in the Technical Specifications related to fuel pool water level as it related to an emergency plan activation; 1998-04-254, which addressed the removal of equipment and piping from the spent fuel pool; 1999-01-028, which addressed the discharge of processed liquid radweste from Unit 1 through the Unit 2/3 Radwaste System into the Unit 2/3 Discharge Canal; and,1999-02-054H, which was a modification to 1999-01-028. The inspector concluded that in each cace, the evaluations were complete, thorough, and in compliance with the licensee's procedures and 10 CFR 50.5 ~ Conclusions The licensee's 10 CFR 50.59 safety reviews were thorough, well documented, and adequate to ensure that changes to Unit 1 were properly evaluated against appropriate criteri .3 - Egif-Assessment. Auditino and Corrective Actions Scooe (40801) -

' The licensee's controls for identifying, resolving, and preventing issues that degrade safety or quality were examined. The program was reviewed to ensure that management and staff were knowledgeable of plant / activity performance and l contributed effectively to safety and quality in the conduct of important activitie Observations a,nd Findinos On March 29,1999, Mr. Robert Speek assumed responsibility for Unit 1 as the representative from Nuclear Oversight. Mr. Speek provides an independent I oversight / audit function of Unit 1 activities. Discussions with Mr. Speek indicated he j was spending 30-40 percent of his time in the field observing activities, was attending l'

pre-job briefings l was conducting a monthly site tour, and conducting a quarterly onsite/offsite review. Mr. Speek was writing field observations which were written up

. and issued to Unit 1 management monthly. Based on observations by the inspector and discussions with Unit 1 personnel, it appeared that Mr. Speek was finding and providing relevant issues to management regarding work activities on Unit ,

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The inspector reviewed the Problem identification Form (PlF) system, which is employed for the documentation, tracking, and resolution of problems and concerns. A general review of the PlFs written on Unit 1 during 1999 found them to be problems or concerns that met the threshold for being placed on the system, and their resolutions appeared to be timely and adequate. A detailed review was made of several of the items that had been placed in the PIF system. In all cases reviewed, the problem or concern was adequately documented, assigned to appropriate personnel for followup, and the resolution reasonabl c. Conclusions Overall, the licensee's identification and resolution of issues that degrade safety or quality were determined to be adequate to ensure safety and quality in the conduct of activities. The PlF system was being effectively implemented to identify and respond to probius and concem Decommissionina Performance and Status Review a. Scope (71801)

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Plant tours were conducted to evaluate the material integrity of structures, systems, and 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 inspector toured the Unit 1 Fuel Building, Radwaste Yard, and the laydown area for dirt removed from the Fuel Building as a result of the pier installation activitie Considerable effort had been put into improving housekeeping practices, which was evident during the tours, particularly in the Radwaste Yard. Although mr y work activities were taking place in the Fuel Building, the licensee was doing a good job of minimizing the clutter and removing no longer needed materials and equipment. No problems were noted with the material integrity of structures, cystems, and components observed that could be considered adverse to safet c. Conclusions Good housekeeping practices were observed in the Fuel Building and Radwaste Yard while efforts for improvement were continuin J l

l 11. Radioloalcal Safety 1 Occupational Radiation Exoosure a. 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 l

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. Observations and Findinas Unit i exposure continues to be below estimates, primarily due to the delays in the Radwaste Vault clesnup activities. Total 1999 dose through June was

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13.032 person-Rem versus a beginning of the year estimate of 19.528 person-Rem for

' the same period. Once the Radwaste Vault cleanup activities resume, actual total dose is expected to start to " catch up" with the estimated dose The inspector discussed the incorporation of As-Low-As-Reasonable-Achievable (ALARA) into work packages with the ALARA Manager, and examined various documents to verify that ALARA was being adequately addressed. An examination of several ALARA reviews indicated that ALARA was being properly addressed procedurally, while discussions indicated it was an important consideration in job plannin , Conclusions The RP Program was determined to be effective in carrying out its function of minimizing occupational exposure and ensuring radiological safet . 2 RadWaste Treatment. and Effluent and Environmental Monitorina Scope (84750)

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An inspection and evaluation were made of the handling of radioactive soil, concrete, and osphalt associated with site decommissioning activities, Observations and Findinas I

As a result of the decommissioning project under way on Unit 1, a number of activities have resulted in the generation of waste soil, concrete, and asphalt. To ensure these materials wer* being properly addressed radiologically, the inspector reviewed the licensee's actais in the assessment and handling of these material As a result of the Fuel Building pier installation activities a large amount of dirt has been removed and placed adjacent to the Radwaste Yard. Some of the dirt had been sampled and found to be clean (free of radioactive material), while some had been found to be contaminated with very low levels of radioactivity, (primarily cesium-137). l

~ Dirt that had been piled prior to being sampled was assessed based on four soil samples taken from various locations around each pile. However, some of the dirt had been sampled as it was removed during excavation, and had therefore already been assessed as to whether it was clean or contaminated prior to being placed in piles. Dirt determined to be contaminated was covered with tarps to prevent it from being wind blown or washed away due to rain. Although this work was still under way during the inspection, eventually all the waste dirt was to be sampled and classified as either clean or contaminated, with the intent to dispose of the clean dirt in an offsite landfill. On an interim basis, and to provide a greater assurance that the dirt would not be inadvertently spread, the contaminated soil was being placed in an existing hole where the concrete pads for the fuel casks are to be located. Contaminated soil that could not fit into the hole was expected to be placed in containers over the winter. A tour of the area

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determined that the postings and barriers were adequate and the contaminated dirt was covered and being controlle The licensee was taking similar precautions with waste asphalt. This material was sampled, turned over by an endloader and additional samples taken, to ensure that it was clean before it would be released. Concrete rebble was being hand frisked and stored in sea-land containers if contaminate I The licensee was also ensuring that any areas identified as contaminated as a result of ,

excavation activities were being added to their "50.75(g) list" of items being tracked as j required by 10 CFR Part 50.75(g).

] Conclusions The licensee was doing a good job of assessing the radiological content of and handling of soil, asphait, and concrete waste material generated during decommissioning activitie '

V. Pinaaement Meetina The inspector presented the inspection results to licensee management at the conclusion of the !

inspection on July 27,1999. The licensee acknowledged the findings presented. The licensee did not identify any of the documents or processes reviewed by the inspector as proprietar ;

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PARTIAL LIST OF PERSONS CONTACTED {

Licensee

, Ken Ainger, Licensing Director, Zion /Dresden Unit 1

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Harry Bush, Lead HP Supervisor, Unit 1 Nate Leech, Dry Cask Storage Project Manager Jim Limes, Licensing / Compliance Engineer C. McDonough, Unit 1 Maintenance & Construction

• Paul Planing, Plant Manager Unit 1

' Bob Speek, Nuclear Oversight Tim Smith, ALARA Manager i

• Denotes those attending the exit meeting on July 27,199 The inspector also interviewed other licensee personne! in the course of the inspectio INSPECTION PROCEDURES USED i IP 36801: Organization, Management & Cost Controls at Permanently Shut Down P,eactors IP 37801: Safety Reviews, Design Changes, and Modifications at Permanently Shut Down Reactors IP 40801: Self-Assessment, Auditing, and Corrective Action At Permanently Shut Dowii Reactors IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down Reactors IP 83750: Occupational Radiation Exposure IP 84750: RadWaste Treatment, and Effluent and Environmental Monitoring LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable Comed Commonwealth Edison J CFR Code of Federal Regulations j

.NRC' ' Nuclear Regulatory Commission PlF Problem identification Form RP Radiation Protection RPT Radiation Protection Technician

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DOCUf.1ENTS REVIEWED

' DAP 12-09, Dresden Station ALARA Program, Rev.16, Pre-job Briefing Checklist for RWP 991013, dated 2/23/9 DRP 5500-01, Radiologica/ Respiratory Contro/ Program, Rev. 5. TEDE ALARA Evaluation Worksheet for RWP 991013, dated 2/18/9 .59 Safety Evaluations: 1998-03-195, 1998-04 -254, 1999-01 -028, 1999-02-054 H Unit 1, Facility Operating License No. DRP-2, Amendment No. 39, Appendix A, Technical l Specifications, Issued July 8,1997.

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