IR 05000237/1981004
| ML17193B317 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/04/1981 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17193B316 | List: |
| References | |
| 50-237-81-04, 50-237-81-4, NUDOCS 8104130482 | |
| Download: ML17193B317 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-237/81-04 Docket No. 50-237 Licensee:
Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Unit 2 Inspection At:
Dresden Site, Morris, IL License No. DPR 19 Inspection Conducted:
January 15-16, 20-22, and February 2-3 and 5, 1981
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Inspector:
. A~ au Approved By: \\:@.;~~mg Facilities Radiation
Protection Section Inspection Summary Chief
/Jfr-ulf J
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~/1'/81 Inspection on January 15-16, 20-22, and February 2-3, and 5, 1981 (Report No. 50-237/81-04)
Areas Inspected:
Routine, unannounced inspection of radiation protection activities during refueling, including:
management, planning, training, procedures, exposure controls, posting and controls, and licensee event report The inspection involved 63 inspector-hours onsite by one NRC inspecto Results:
No items of noncompliance or deviations were identifie ** DETAILS Persons Contacted
- D. Scott, Station Superintendent
- J. Eenigenburg, Assistant Superintendent, Maintenance
- D. Farrar, Assistant Superintendent, Administration and Support Services
- G. Myrick, Radiation Chemistry Supervisor
- T. Gilman, Lead Health Physicist S. McDonald, Chemist E. Wilmere, Quality Assurance Coordinator 0. Flowers, Engineering Assistant B. Zank, Training Supervisor The inspector also interviewed other licensee and contractor personne *Denotes those attending the exit meetin.
General This inspection, which began at 8:00 a.m. on January 15, 1981, was conducted to examine the licensee's radiation protection activities during the current Unit 2 refueling and maintenance outag The inspection included observations of the removal of a control rod drive and in-service inspection work (ISI) in the drywell, discussions with licensee and contractor personnel, independent radiation measurements, and a review of licensee records and occurrence report Other refueling activities were observed during several tours of the facilit With the exception of a few minor discrepancies, plant housekeeping was generally acceptabl.
Organization The licensee has contracted twelve additional radiation protection workers for this outag One of the acting R/C foremen is designated liaison for the contractor personnel, who are generally assigned radiation protection coverage for nonlic~nsee worker The licensee requires contract radiation protection personnel to meet the quali-fication and experience criteria in ANSI Nl Review of several contractor resumes indicated those standards were being me The current health physics staff is comprised of one R/C Supervisor, three HP's; one acting HP, four engineering assistants, three foremen, one acting foreman, four chemists, and 32 RCT' During the inspection, all major jobs were under RCT surveillance; RCT foremen made several in-plant tours of the jobs dail ** Outage Planning and Preparation In addition to the refueling operation, the major radiation jobs included turbine work, snubber inspection, ISI, piping/hanger walkdown and installations, clad removal/sparger replacement, torus modification, and CRD repai Health physics personnel participated in all pre-outage meetings and currently attend the daily outage meeting According to licensee personnel and the inspector's observations, recommendations made by health physics personnel at these meetings will account for exposure reduction for the outag.
Training General employee training classes have been given almost daily since the beginning of the outag The training adequately covers the requirements of 10 CFR 19.1 All persons attending the training are tested and must receiv~ a 70% passing grad Failures are allowed to repeat the course and take a different tes Three persons who failed both tests were not permitted to work in the station during this outag Selective training records for contractor personnel were reviewed; no discrepancies were note In addition to the general employee training, contract radiation protection personnel were familiarized with radiation protection procedures before being assigned to health physics coverage of outage job.
ALARA Although formal ALARA reviews and specific man-rem goals were not established for this outage, consideration was given to ALARA on specific job An example is the effort given to the control rod drive (CRD) removal/replacement jo The licensee determined that due to space and physical limitations, it was impractical to implement engineered controls to reduce exposure associated with the removal/
replacement of the 99 drive mechanism Instead, they constructed a CRD mock-up for maintenance and RCT personnel training, with the intent of increasing work efficiency and reducing occupancy time, thereby reducing personal exposure Because of inordinately high radiation readings of the CRD mechanisms found during this outage, approximately 2.4 man-rems per CRD is expected for the repair wor The use of the mockup is expected to save significant personal exposur During the inspection tours, special emphasis was placed on observing work habits and discussing work practices with workers and RCT's to judge adherence to good health and safety practices, including ALAR During a tour of the third level in the unit 2 drywell, an ISI worker was observed leaning on a recirculation line which read approximately 500 mR/hr on contac The worker was using the line as a support for his writing pa ~.
This matter was discussed with the contract radiation protection fore-man responsible for the ISI job coverag The foreman stated that to his knowledge the worker was assessed of the radiation fields, received
~he required tr~ining, and should have been aware of the need to minimize personal exposur This was later confirmed in an interview with the worker and a licensee representativ This matter was discussed at the exit interview; the licensee was requested to review the training program in light of this proble A second ALARA concern of the inspector involves the rigid implementa-tion of a daily exposure limit for worker This practice may work contrary to the ALARA concept if abused by workers or if total working time for a job is increased significantly because of a need to involve additional worker This matter was discussed at the exit meetin.
Procedures Selected operating and administrative procedures were reviewed to ensure proper implementation during outage activitie One problem noted was incomplete records for respirator us This matter was discussed at the exit interview and will be.reviewed at a future inspectio No items of noncompliance or deviations were identifie.
Exposure Controls - Internal The respiratory protection program meets the requirements of 10 CFR 20.103 and Regulatory Requirement 8.1 Persons required to use respiratory equipment for outage activities need medical approval, training, and quantitative fit testin The inspector observed fit testing of several contractor personnel and selec-tively reviewed fit test results, training, and medical approval record No problems were noted; it appeared that only those persons who satisfied the licensee's requirements were authorized to wear respirator In Vivo Counting For this outage, the licensee rented a commercial whole body counter for base line counting of incoming contractor personne Most CECo workers were base line counted on the licensee's permanent whole body counter (RMC).
The inspector observed workers being whole body counted and also selectively reviewed their result No significant internal deposition was identifie All contractor and nonstation CECo personnel are counted when they complete their work at the statio The results of these counts will be reviewed at a future inspection of outage activities.
No items of noncompliance or deviations were identifie.
Posting, Labeling, and Control With the exception of two minor discrepancies, which were corrected by the licensee during the inspection, the use of special work permits, survey postings, contamination control points, and high radiation caution sign postings conformed to regulatory requirements and licensee procedure No items of noncompliance or deviations were identifie.
Review of Nonroutine Events The inspector reviewed the licensee's actions with respect to the radiological aspects of the following licensee event report No items of noncompliance or deviations were identifie LER 50-249/80-12 LER 50-23,7 /80-33 LER 50-237/80-41 ARM trip points exceeded the technical specifi-cation limit (April 9, 1980).
Leak in the 2B LPCI Heat Exchanger released approximately 150 uCi to the cooling lake (October I, 1980).
ARM trip points exceeded the technical specifi-cation limit (November 12, 1980).
None of the above events had significant radiological consequence.
Isolation Condenser Release A short duration radioactive release occurred on January 3, 1981, during testing of the Unit 2 isolation condense The NRC was notified when the licensee, acting in accordance with their procedures, found unexpected radioactivity in onsite ground samples (snow and ice).
NRC radiation specialists responding to the notification independently made direct radiation measurements and collected ground samples at downwind locations both onsite and offsit Rust colored patches of ice and snow readily identified where the water from the plume fell to the groun The highest radioactivity was found under the isolation condenser ven Neither NRC nor licensee samples indicated release offsit Analysis of water remaining in the isolation condenser indicated less than one millicurie of activity was released with the 6,000 gallons of water which boiled off and were released through the isolation condenser ven The radioactivity resulted from a history of refilling the isolation condenser secondary with contaminated water from the condensate storage tan Although excessive radioactivity had not been seen in samples taken from the stagnant isolation condenser reservoir, the rapid boiling accompanying the test apparently released radioactive material which had collected in the bottom of the reservoi The licensee collected the contaminated snow and ice in containers for subsequent disposa '
Licensee corrective action to prevent recurrence will be reviewed during future inspection No items of noncompliance were identifie.
Exit Interview The inspector met with licensee representatives (denoted at the conclusion of the inspection on February 5, 198 summarized the scope and findings of the inspectio In certain items discussed by the inspector, the licensee:
in Paragraph 1)
The inspector response to Indicated that a formal program which includes training in the concept of ALARA is being develope (Paragraph 6) Acknowledged the inspector's concern about procedures and policies which may lead to practices contrary to ALAR (Paragraph 6) Confirmed that discrepancies noted regarding posting and control of certain areas had been corrected during the inspectio (Paragraph 9) Stated that the problem of incomplete records for respirator use would be reviewe (Paragraph 7)
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