IR 05000237/1981023
| ML17194A151 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/26/1981 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17194A148 | List: |
| References | |
| 50-237-81-23, 50-249-81-17, NUDOCS 8109170244 | |
| Download: ML17194A151 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-237/81-23; 50-249/81-17 Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690
.Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Insp~ction At:
Dresden Site, Morris, IL Inspection Conducted:
July 21-31, 1981 Inspector:
Approved By: ~
R. A; Paul L. R. Gr~
Fa~ilities Radiation Protection Section Inspecti6n Summary:
e/z.~/e1 Inspection on July 21""'.31, 1981 (Reports No. 50-237 /81""'.23; 50-249/81-17)
Areas Inspected:
Routine, unannounced inspection of status of post-TMI requirements for operating reactors and licensee actions taken in response to Health Physics Appraisal Findings and items of noncomplianc The inspection involved 62 inspector-hours onsite by one NRC inspecto Results:
Of the two areas inspected, one apparent item of noncompliance
- was found in one area (Severity Level 5 violation - failure to follow radiation protection procedures - Section 6).
0109170244 e1oa2al PDR ADOCK 05000237
_G __
- --
--- _PDR
- DETAILS Persons Contacted D. Scott, Station Superintendent
- D. Farrar, Assistant Superintendent, Administration and Support Services
- G. Myrick, Radiation Chemistry Supervisor
- .T. Gilman, Lead Health Physicist
- S. McDonald, Chemist
- M. Jordan, N:RC Resident Inspector The inspector also contacted other licensee employees including members of the technical and engineering staff *Denotes those attending the exit meetin.
General
.This inspection, which began at 10:00 a.m. on July 21, 1981, was conducted to examine the licensee's actions on post-TMI requirements and the licensee's actions in response to Health Physics Appraisal finding The inspection also included several p"iant tours;*visual observations of facilities and equipment; review of posting, labeling; and independent radiation measure-ments by the inspecto General housekeepiJJ.g was adequat.
Licensee Action on Previous Inspection Findings (Open)
Noncompliance Item (50-237 /80.;.13; 50-249/80-17): Failure to meet Te.chnical Specification 6..2. B, adherence to radiation protection procedure requirement This ma~ter had not been correcte A similar item of noncompliance was found during this inspectio (Closed) Noncompliance Item (50-237 /80-13; 50-249/80-17):
Release of licensed material to ab unrestricted are~ such that there was the potential for an individ~al to receive a dose greater than 2.millirems in one hour or greater than 100 millirems in seven consecutive day A new procedure defining the steps needed to gain access to the dump was issued, a quarterly radiation survey of the area is now taken, and two fences with lockable gates were constructe.
Organization and Management The Health Physics Appraisal noted that organizational and managerial improvements were needed to solve problems which included lack of pro-fessional health physics guidance,. antagonisms between the Radiation Chemistry Technicians (RCT' s).and Health Physicists (HP' s) and the ro.le of the HP in the Radiation Chemistry Departmen To resolve those problems the licensee has done the following:
- 2 - Used the monthly departmental meetings to improve communications between the RCT's and the.HP' Although the licensee thinks this forum has partially accomplished its intended pur:pose, they are still aware of existing antagonisms and of the need to continue actions to resolve the Based on discussions with several RCT's and two HP's, it is the inspector's view that some of the observations made during the Health Physics Appraisal concerning mutual antagonisms, disrespect, and lack of cooperation between the two groups still exists.. A recommendation made by the RCT's to increase communication and reduce antagonisms was for HP's to spend more time with the RCT's in the field to better understand what work they do and how it is accomplishe This appears to be a valid recommendatiO Assigned HP's (on a rotating schedule) to the Foreman's area to
. increase interaction between the HP' s, * RCT' s, and Forema Licensee representatives ~eel that although this progr~m has not been as effective as intended, they will continue to use and improve the program by assigning HP's to job-spetific tasks involving RCT's and the foreme Required the RCT foremen to.make plant tours with increased frequency and to establish a daily log summarizing the:lr activitie A review of the log shows the in-plant presence of.the foremen.has significantly increased, however, further increases appear desirable to improve first line managemen Initiated an analysis to determine the responsibilities of each position in the Radiation Chemistry Department, ;ifter which, the licensee will clearly define the furictioilal role for HP's in the technical direction of RCT's and Forema At the time of the inspection, the licensee had completed the analysis of RCT job positions and had begun the analysis of responsibilities of each position in the Radiation Chemistry Organi-zatio This matter wl.ll be reviewed furthe_r during a future in-spectio Included the corporate health physics staff in grievances which impact on health physics activities at the Statio This has been accomplishe Contracted a consulting firm to develop job position descriptions and professional development programs for HP' The job descriptions, which emphasize the HP' s responsibility for qu'ality control of health physics activities, had been drafted and reviewed during this inspectio It was noted that the position description for HP's does not speak to the role of the HP in evaluating routine program implementation and of RCT performanc This matter, which is related to item d, above, will be reviewed during a future inspectio * Developed draft proposed policy and procedures for ALARA, appointed an ALARA Coordinator, and will begin meeting in. August 1981, to produ~e
.
a computer program which will enable the licensee to perform ALARA cost-benefit analyse The progress of this piogram will be reviewed during a future inspectio J; Reorganized the Radiation Chemistry Department so the chemists report to the Radiation Chemistry Superviso The following cominents concerning additional matte.rs noted in Section 2 of the Health Physics Appraisal (Organization and Management) are based on observations.and discussion with employee personnel during this inspection:
(1) It appears that station management are better informed, more supportive of the health physics program, more willing to make constructive changes in order to strengthen the program, and, giving more attention to those problems which have negatively affected the health physics program over a long perio (2)
The continued absence of an experienced HP in the chain of command between the Radiation Chemistry Foremen and the Radiation Chemistry Supervisor appears to place an unreasonable burden on the Radiation Chemistry Supervisor because of his involvement in the daily super-vision of the HP progra (3)
There appears to be some liberalization nf work. rules which allows HP's io make more meaningful evaluation of program imptementatio All of the above items were discussed in the exit intervie.
Qualifications.and Training The Health Physics Appraisal identified weaknesses in training/retraining of RCT's and a degradation of job skills during the relatively long rotation period between job assignment The licensee has made significant improve-ments-in these area Since the Health Physics Appraisal, the licensee has develOped a six-month training program for.new RCT candidates which consists of on-the-job train-ing and formalized course work given by health.physicists, chemists, and Training Department *instructor The course work consists of trainl.ng related to mathematics, fundamentals of nuclear physics, health physics, chemistry, and laboratory procedure Tests are given after each training section is completed with a passing
.grade of 70 percent correct needed to meet the RCT job requirement A review of the training lessons indicated the content of the course material to be sufficient to cover the objectives of the.training progra A review of several of the completed tests showed most scores were in the 80-90 percent correct rang The licensee conducted and documented a five-day RCT retraining session in October-November 198 Additional training has been provided in Emergency Plan Implementing Procedures _for.all RCT' Furth¢r RCT re-training is scheduled for October 1981, after which tests will be given to determine the RCT' s.level of comprehension of the material presente The licensee is also planning to develop a.standardized training/retraining program for RCT' s over the next two year Aithougb. the license,e has taken the above actions to -improve RCT training/retraining, it appears they will still fall shbrt bf the effort expended for other station personnel for some tim Since the Health Physics Appraisal, twelve RCT trainees have been hire The Radiation Chemistry Supervisor stated that the candidates were chosen by a new, mbre formalized selection progra The licensee believes this program will aid in the selection of qualified RCT traines It was noted during this inspectiOn that, although all RCT's now meet ANSI experience standards (ANSI 18.l, Section 4.5.2), there are still RCT's who have not performed certain job functions for extended time period The licensee continues to ailow RCT's to trade work assignment As noted during the Health Physics Appraisal, this practice c0uld reducethe li-censee's ability to respond in an emergenc The licensee should identify individual RCT deficiencies and addresss these weaknesses in the retraining program The items in this Section were discussed at the exit intervie.
Contamination Control The Health Physics Appraisal noted several weaknesses relating to control of contamination and contaminated materia Since the appraisal, the licensee has r~minded the RCT's of the need to thoroughly survey all materials being released to uncontrolled areas;
_restricted access to the. dump site; written a procedure.to define steps needed to gain access to the dump site with.scrap material; instituted a quarterly radiation safety surveillance program for the dump; stteng-the*ned the tra:lning program to include instructions concerning control of contaminated tools; constructed a new tool and shoe decontaminatibn area; implemented a routine survey program to.ensure that personnel, shoe, and tool decontamination areas are kept clean and are used properly; and moved the decontamination laundry facility.to the Unit 1 trackwa During the appraisal, the licensee was found in noncompliance for allowing laundered p.rotective clothing in the clean laundry storage b~ns to be in excess of their 3000 cpm limi In response to the noncompliance, the licensee stated that by October 13, 1980, they would conduct a training session for the stationmen and their foreman onthe proper use of the laundry monitors, and would establish a weekly surveillance of the laundered clothin Both of these actions were taken on tim However,
- 5 -
- .
on the basis of inspector and licens.ee surveys.made of laundered* clothing and an evaluation of the laundry monitoring system during this inspection, it was found that: Some stationmen who had not received the initial laundry monl.toring training were performing laundry monitoring without proper instruction One probe in the laundry monitor was inoperabl Several pieces of laundered clothing were found reading up to 10,000 cpm, which is in excess of the 3000 cpm.limit specified in the section entitled "Laundry Facility" of the Radiation Control Standard This is a repeat item of noncompliance with Technical Specification 6. No evaluation had been made to determine the dose contribution from laundry, in order to determine the acceptability of current laundry limits, as recommended in the Health Physics Appraisa After these observations were brought to the licensee's.attention, they took corrective action and actions to avoid further noncomplianc These included: Instructed all.stationmen in the proper operation of the laundry monitor and instructions will be given. to all.future stationmen who operate the uni Replaced the inoperable Geiger-Mueller tube and changed.the *grating over the tubes to allow greater counter sensitivit Instructed the RCT's to make. a weekly survei~lance check of the monitor and the stationmen's use of the monito.r:
Additionally, in response to a concern raised during *the Health Physics Appraisal, the licensee has assigned an HP to makean evaluation of the contribution to dose from laundered clothing to.determine acceptable laundry limit This evaluation was in progress at the end o'f the inspectio The above matters, which were discussed at the exit interview, will be reviewed further during a future inspectio.
Emergency Response The Health Physics Appraisal noted several weaknesses in the licensee's preparedness for emergency monit.orin,g and samplin Since the appraisal, the licensee has done the follo,ing: Built heavy duty carts with lead brick shield Built a lead shield with a double leaded glass viewing window in a fume hood for handling highly radioactive sample Trained the RCT's in emergency sampling procedures EPIP 300~8 through 300-11 and in methods of proper use of sample handling equipmen Revised the procedure for estimating emergency noble gas relea~e to correct a discrepancy noted in the Health Physics Appraisa Provided training in "Environmental Emergency Plan Impleinenting Procedures" ED-10, by members of the corporate office, for the r.adiation chemistry. staf The licensee is developing a procedure covering plume monitoring and sample method The training of.station personnel and the installation Qf equipment and shielding referenced in the above items*.was verified by the inspecto It was noted that the lead glass shi~ld was positioned too deep in the fume hood for easy access and efficient us The licensee stated they would reposition the barrier close to the front of the.hoo One of the weaknesses noted in the Health Physics Appraisal was the lack of shielding at sampling stations in the Reactor Buildin This weakness was not corrected because the licensee determined additional shielding in those areas was infeasibl This problem will be corrected in the near future when the High Radiation Sampling Building is operabl The items in this Section were discussed at the exit intervie.
Possible Overexposure to Worker The inspector reviewed the licensee's investigation of a contract.employee's whole body exposure received during the period April 27-29, 198 The employee's whole body film badge results showed he received 2400 mrem for that period and 1240 mrem during the period March 1 through April 26, 198 As a result of the investigation, the licensee determined.that the employee removed.his personal dosimetry from his chest so he could transfer them to his upper back area, and in doing so, dropped them into an area containing significantly higher radiation levels than his work locatio The recovered film badge read 2400 mrems, the two self-reading dosimeters read 258 and 340 mR respectivel The licensee determined the film badge was located in *a higher radiation field than the self-reading dosimeters, therefore, causing the higher reading on the film badg On the basis of this in-formation, discussions with the employee and other employees including the RCT responsible for the timekeeping.for this job, and on survey results, the licensee determined that the worker's whole body exposure for the three-day period was 668 mrem The quarterly whole body exposure assigned to the worker was 1908 mrem The inspector concurred with the licensee's ev~luatio.
Followup on TMI Action Items The status of the following items is based on evaluation of previous reviews by the resident inspectors and regional specialist ~nspectors and review during this inspection of licensee actions to correct the problems noted during those review Plant Shielding (2.1.6.b)
The licensee was notified by the NRC in a letter dated March S, 1980, that the licensee Jias satisfied the intent of the Category "A" require-ment Further review of the shielding evaluation, documentation of safety equipment degradation, and necessary modifications are scheduled by the licensee for completion by. January 1,* 1982 (Categ*ory "B" Items). Post-Accident Sampling (2 '.1. 8. a)
,
This item was inspect~d by the Regton IIIHealth"Phys{cs Appraisal Team during the period June 18 to July 2, 1980:
The corrective action the licensee took ccincerning weaknesses identified in the interim emergency sampling procedures during that appraisal included; additional heavy duty lead shielded carts, a leaded glass radiation barri.er for handling highly radioactive samples, and instruction to the RCT's to purge the reactor coolant sample lines before samplin The identified weakness concerning the lack of local shielding at the sampling stations in the reactor building was not corrected because a study by t:he licensee showed* additional shielding to be infeasibl This *matter will be corrected in the near future when the High Radiation Sampling Buildings are operabl It appears the licensee has met the intent of the Category "A
requirements and is working to meet the Category "B" requirement Instrumentation for Monitoring Accident.Conditions 2.1. 8. b The interim requirements (II.F.1, 1.and 2) were in:spected by the Region III Health Physics Appraisal Team during the period June 18 to July 2, 1980. Interim procedures (EPIP 300-10 and 11) cover post-:accident sampling and.release rate determination for radio-iodine, particulate, and noble gas release The discrepancy noted during the appraisal concerning the illegible graph legend in EPIP 300-11 has been correcte The equipment necessary to make the release rate determination was availabl A containment high range monitor has been installed in the Unit 2 drywell and one will be installed in the Unit 3 drywell during the.next refueling outag It appears the licensee has met the intent of the Category "A" requirement Inplant Radiation Monitoring (Iodine) 2.1. The licensee utilizes a portable Eb~rline Stabilized Assay Meter, Model SAM 2, for iodine monitorin Sample collection is by means of portable iodine samplers using silver zeolite cartridge Procedures have been developed (EPIP 300-10) and training of technicians responsible for collecting and counting air samples has been complete The equipment, training and written pro-cedures were verified by the inspecto.
Exit Interview Th:e inspector met with license*e representatives (denoted in SectiOn 1)
at the conclusion of the inspettion on July 31, *198 The inspector summarized the scope and findings of the inspectio In response to certain items discussed by the inspector, the licensee:
- Acknowledged the inspector's remarks concerning the noncompliance and the significance of a repeat item of noncomplianc (Section 6) Acknowledged the inspector's remarks concerning the review of the Significant Items found during the Health Physics Appraisa (Sections 4, 5, 6, and 7). Stated that all significant radiation protection instructions will be included in the approved plant pro~edure system, rather than in the form of memo (Sectibn 5, Report No. 50-237/81-10)
- 9 -