IR 05000237/1986023
| ML17199F943 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 11/21/1986 |
| From: | Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199F942 | List: |
| References | |
| 50-237-86-23, 50-249-86-28, IEIN-85-046, IEIN-85-048, IEIN-85-092, IEIN-85-46, IEIN-85-48, IEIN-85-92, IEIN-86-020, IEIN-86-022, IEIN-86-023, IEIN-86-024, IEIN-86-042, IEIN-86-044, IEIN-86-20, IEIN-86-22, IEIN-86-23, IEIN-86-24, IEIN-86-42, IEIN-86-44, NUDOCS 8612030705 | |
| Download: ML17199F943 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/86023(DRSS); 50-249/86028(DRSS)
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 In~pection At:
Dresden Site, Morris, Illinois Inspection Conducted:
October 14-16, 21-23 and November 3-6, 1986 Inspector:
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D. E. Miller
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7://..a~z'~~c4./V Approved By:
L. Robert Greger, Chief Facilities Radiation Protection Section Inspection Summary Date Inspection on October 14-16, 21-23 and November 3-6, 1986 (Reports No. 50-237/86023(DRSS); 50-249/86028(DRSS))
Areas Inspected:
Routine, unannounced inspection of selected portions of the radiation protection and radwaste management program Also reviewed were past inspection findings, a radiological incident, a radwaste transportation incident, and selected IE Information Notice Results:
No violations or deviations were identified.
8612030705 861121 PDR ADOCK 05000237 G
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DETAILS Persons Contacted
- * * * * * * Adam, Regulatory Assurance Coordinator Ambler, Radiological Engineer Brunner, Assistant Superintendent, Technical Services
1Conner, Rad/Chem Supervisor Eenigenburg, Station Manager Flessner, Superintendent, Services Jeisy, Station QA Supervisor Johnson, Lead Chemist Schrage, Health Physics Group Leader, Nuclear Services Sharper, Waste Systems Engineer Soccomando, Lead Health Physicist
- L. McGregor, NRC Senior Resident Inspector
- P. Kaufman, NRC Resident Inspector
- E. Hare, NRC Resident Inspector The inspector also contacted several other licensee and contractor personne *Denotes those present at the exit meetin.
General This inspection, which began at 8:00 a.m. on October 14, 1986, was conducted to examine selected portions of the licensee 1s radiation protection and radwaste management program Also reviewed were past inspection findings, a radiological incident, a radwaste transportation incident, and selected IE Information Notice Several tours of access control and work areas were made to observe and evaluate operational radiological controls and radwaste handlin.
Licensee Action on Previous Inspection Findings (Closed) Violation (237/86016-01; 249/86019-01):
Excessive surface radiation levels on a package upon arrival at destinatio The inspector reviewed implementation of the corrective actions listed in the licensee 1s letter of response dated October 17, 198 The corrective actions have been implemented and appear adequat No further problems were identifie (Closed) Open Item (237/85005-04; 249/85004-04):
Procedure for alternate methods of effluent tritium quantificatio Procedures for airborne effluent tritium collection, analysis, and quantification using the silica gel method have been written, approved, and implemented; the procedures appear adequate.
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(Open) Open Item (237/85027-01; 249/85021-01):
Disposition of contaminated soi During this inspection period, the licensee collected, by hand digging and core drilling, samples of soil near the new and old liquid radwaste discharge lines (both of which have experienced leaks).
The licensee also collected, by core drilling, soil samples in an area within the licensee 1s owner controlled area where the licensee intends to request permission to bury contaminated soil that is now temporarily stored above ground level in the licensee 1s protected are The samples are to be sent to a contractor for analysis in the near futur The licensee plans to submit a 10 CFR 20.302 request to the NRC before December 31, 198 (Open) Open Item (237/86008-01; 249/86010-01):
Cleanup program for outdoor area Since previously discussed in Inspection Reports No. 50-237/86016; 50-249/86019, significant progress has been made in cleanup of outdoor area Several buildings and trailers which previously contained radioactive materials no longer do so; the materials were either decontaminated, disposed of, or repackaged in sea vans for future disposition; the large quantities of slightly contaminated waste oil that were stored in drums and tanker trailers is being solidified for burial, the emptied drums were super-compacted and are being shipped for burial; individual piles of contaminated soil have been consolidated awaiting 10 CFR 20.302 submittal and disposition; and a general cleanup and disposal of unwanted materials continue There are more than 100 sea vans onsite that contain contaminated waste materials, contaminated tools, and other contaminated materials and equipmen The licensee has received bids from six companies for removal of the sea vans from the sit The awarded bidder is to properly dispose of the waste materials, and is allowed to recover (and own) any item that can be decontaminate The bidders all have NRC or agreement state licenses to receive and possess radioactive material Dresden Station plans to complete transfer of the vans to the selected bidder by mid-December 198 (Open) Open Item (237/85041-02; 249/85035-02):
Contamination Reclamation Progra This matter is discussed in Section (Closed) Open Item (237/85022-02; 249/85018-02):
Acceptability of licensee reorganizatio This matter was resolved through communications between NRR and Region II Internal Exposure Control and Assessment The inspector reviewed the licensee 1s internal exposure control and assessment programs, including:
changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications, and effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse.*
The licensee's program for controlling internal exposures includes the use of protective clothing, respirators and equipment, and control of surface and airborne radioactivit A selected review of air sample and survey results was mad No significant problems were note Whole body count data was reviewed for counts performed during the second and third calendar quarter 1986 on company and contractor personne Several followup counts were performed on persons who showed elevated initial count Followup counting was adequate to verify that the 40 MPC-hour control measure was not exceede No violations or deviations were identifie.
Personal Contamination Events Personal contamination events during the Unit 3 recirculating piping replacement (RPR) program are discussed in Inspection Reports No. 50-237/86008; 50-249/8601 Since completion of the RPR program, the number of personal contamination events per month has trended down; 151 events occurred during September 198 Sixty-eight percent of the 151 events were clothing contaminations; 85 percent of the clothing contaminations were shoe contaminated event The 151 events are an 18 percent reduction from the previous mont Even though the number of events per month is trending downward, the total number of events appears larg The licensee contributes the elevated number of personal contamination events to ongoing extensive decontamination efforts at the station; installation of fire protection piping which involves extensive work in building overhead areas which have accumulated small quantities of contamination over the years; work being performed in the Unit 2/3 radwaste building basement in preparation for major revamping work; and work performed in the Units 2 and 3 torus basements to prepare for modification of sumps and sump pump The licensee believes that personal contamination incidents will continue to decline as decontamination efforts continue and fire protection piping work nears completio The licensee maintains records showing implant areas in which individual personal contamination incidents occur and the person involved; causes of the events are investigate The names of persons who repeatedly become contaminated are provided to the appropriate supervisor Some skin contamination events involved 11hot particles; 11 these events are discussed in Section No violations or deviations were identifie.
Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including:
changes in instrumentation, equipment and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey
- data, effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse The licensee continues a major contamination reclamation progra Contaminated areas are being cleaned to "Clean" status or the contamination concentration reduce Several areas are being painted to improve the appearance of the facility and to make future decontamination efforts easier. Other housekeeping efforts, including tool and equipment cleaning and organizing, are being performe Progress of the reclamation program will be reviewed during future inspections (237/85041-02; 249/85035-02).
The licensee continues to experience incidents where hot particles are detected on the skin or personal clothing of worker The frequency of detection/presence of the particles varies widel During the period August 4 through September 19, 1986, eight such incidents were identified; the particles ranged from about 40 to 120 nanocurie The licensee followed up on each event and calculated skin doses wh~n appropriat The licensee 1s evaluations appear adequate and proper; no 10 CFR 20.101 limits have been exceede The licensee has been unable to positively identify the source of the hot particles or the mechanism of transfer to the worker 1s ski The licensee suspects that some particles are retained on laundered protective clothing and are later released and deposited on a worker 1s ski In response, the licensee has implemented a laundering program whereby dry cleaning machine loads are smaller; dry cleaning fluids are changed more frequently; after several uses, protective clothing is wet washed; and about 20 percent of laundered clothing is monitored by a sensitive sorting monitor set to alarm at two nanocurie The licensee is seeking to buy a laundry monitor that is more efficient than the installed monitor and less labor intensive than the sorting monito Also, the licensee continues to seek the source of the particle No violations or deviations were identifie.
Radiological Incident On September 23, 1986, a contractor carpenter foreman requested that a contractor electrician manager provide assistance for work to be done in the Unit 2/3 radwaste basement by providing temporary lighting in the collector tank roo The entire radwaste basement was posted and controlled as a high radiation are A radiation work permit (RWP) was written to include the electricians; two contractor electricians signed the RWP, were instructed in the radiation levels in the collector tank room, and were provided with electronic dosimeters (they also wore their self-readers and TLDs).
The electricians, who had never been in the radwaste basement, were instructed to accompany carpenters, who were to construct scaffolding in the collector tank room, into the radwaste basemen *
When the entry was made later in the day, the carpenters and electricians donned their protective clothing and began the entr The carpenters began assembling scaffolding to take into the basement; the electricians walked past them and entered the basement (down two flights of stairs) ahead of the carpenter The electricians saw what they thought was the area that needed lighting and walked into the spent resin and waste sludge rooms (general area exposure rates ranging to about 6 R/hr) instead of the collector tank room where the exposure rates were 60 to 120 mR/hr; the door to the spent resin and waste sludge rooms was open and unmarke The electricians were in the wrong rooms for about five minutes when they noted that their electronic dosimeters were indicating increased response and had accumulated dose indications of about 100 mR, at which time they decided to leav As they left, a carpenter told them that they had been in the wrong room and showed them where the collector tank room was and what needed to be done; the electricians then performed their task in the collector tank room (in about 15 minutes) and left the basemen Upon return to the radiation protection office, the electricians dosimetry indicated about half the authorized administrative limit of 300 mR set for the jo However, the RCT on duty observed that the electronic dosimeter had registered a maximum exposure rate of 3.7 R/hr which was much higher than expected for the jo The RCT immediately notified radiation protection supervisors and managers and an investigation was begu The licensee's investigation determined that the principal source of exposure in the resin tank room was resins on the floor and that the recorded doses on dosimetry worn at chest level required adjustment upward by a factor of two to properly reflect total body dos With this adjustment, both electricians exceeded the authorized administrative dose limi No regulatory limit was exceede The licensee's investigation identified several contributing causes for the event, including:
The pre-job briefings did not adequately communicate the need for coordinating the radwaste basement entry between the two crews; the carpenters did not know that the electricians were not familiar with the radwaste basemen The workers' supervisors also did not adequately communicat *
The RWP did not adequately address the radwaste basement; only the collector tank room was graphically depicted and discusse *
The electricians had not grasped their orientation into the use and function of the electronic dosimeters when the dosimeters were issued to them by the RC *
The practice of posting large areas as high radiation areas without positively indicating or controlling areas where the radiation levels are greatly elevated above the surroundings needs to be reevaluated.
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The licensee 1s immediate corrective actions were to require continual RCT attendance for work in the radwaste basement; and closing, locking, and identifying the access door to the spent resin and waste sludge tank room Longer term corrective actions are to include instructing RCTs and rad/chem foreman to conduct comprehensive pre-job briefing The licensee 1s identification, investigation, and initiation of corrective actions for this incident appear good; however, methods of providing additional control of access to certain high radiation areas appears desirabl High radiation areas are defined as 100 mR/hr or greater in the regulations, with no additional controls required when the exposure rates reach much higher level As evidenced by this and past incidents, it appears that a good health physics practice would be to provide enhanced access controls for elevated high radiation areas, failure to provide this enhanced access control appears to be a programmatic weaknes This matter was discussed with the licensee during the inspection and at the exit meetin (237/86023-01; 249/86028-01)
No violations or deviations were identifie Audit The inspector cursorily reviewed a report of an industry audit conducted during 1986, and proposed licensee corrective action Discussed below are the radiation protection audit findings (generalized) and possible corrective measures.
Need for increased supervisory overview of ongoing program The licensee plans to increase oversigh *
Need for RWP improvement The licensee is implementing changes to better convey radiological conditions to worker *
Need for additional information signs in some area The licensee is considering possibilitie *
Need to improve torus basement sump Temporary modifications have been completed; permanent modifications are to be implemente *
Need for increased air sampling in some case The licensee has partially implemented corrective measure *
Need to improve DAW reduction method The licensee anticipates implementation of sortin *
Need to improve contaminated work area control Anticipated corrective actions include greater supervisory oversight and increased attention to reducing personal contamination event *
Possible leak from tanker and drums of used (contaminated) oi The oil is being solidified for buria Plans for future onsite cleanup and reuse of oil, instead of disposal as radwaste, are in progres *
Need to restrict contamination to sourc The licensee had improved identification, documentation, and correction of leaking contaminated system Also, the contamination reclamation program should reduce contamination spread incident There were no inspector identified violations or deviation.
Radwaste Transportation Incident On October 13, 1986, a radwaste shipment consisting of dry active waste packaged in twenty 55-gallon metal drums and eight 96 cubic-foot metal boxes, loaded in an exclusive use closed trailer, left Dresden Statio The shipment had been prepared, loaded, and inspected in accordance with approved Station procedures with no abnormalities identified before shipmen Upon arrival of the shipment at the Beatty, Nevada burial site on October 16, 1986, a State of Nevada inspector observed that the lid on one metal box was slightly raised between two 11 seal lock clips, 11 and that an opening of about 1/8 inch existed between the box lid and the box lid seating surface along a six to eight inch pat There was no line-of-sight opening, and no material leaked from the package which contained contaminated solid metal and plastic material The Dresden Waste System Engineer was notified of the incident of October 16, 1986; he and a Nuclear Services Technical representative arrived at the burial site on October 17, 1986, to inspect the box and discuss the incident with burial site and state personne The metal boxes in the shipment had been placed adjacent (longitudinally)
in a staggered fashion and were blocked to remain in that positio The licensee representatives observed that the box in question had several shining metal surfaces where adjacent boxes had apparently rubbed during transport; it appeared that the relative motion of boxes in contact during transport could have caused the distortion in the box li Burial site employee's pounded the box lid into it's seated position and then placed the box in a disposal trenc The State of Nevada did not terminate Dresden's burial site privileges because of this incident, but did request that additional blocking be considered to preclude recurrence of this type inciden In response, the licensee revised procedure No. DOP 2000-39, Loading of Radioactive Waste Shipments, to specify addition blocking and bracing of shipments containing metal boxes so that the boxes do not contact each other during transpor Also, the licensee informed all Dresden personnel who are involved in radwaste packaging and shipping of this incident and the corrective action No additional problems were noted during the inspector's review of this inciden No violations or deviations were identifie,
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r 1 IE Information Notices The inspector reviewed the licensee's internal responses to selected IE Information Notice The licensee's evaluations, conclusions, and corrective actions appear appropriate and adequat The following notices were reviewed:
No. 85-46:
Clarification of Several Aspects of Removable Radioactive Surface Contamination Limits on Transport Package In response, the licensee developed methods of improving arrival and departure surveys performed on spent fuel shipping cask No. 85-48:
Respirator Users Notice:
Defective Self-Contained Breathing Apparatus Air Cylinder Dresden Station does not use the subject hooped-wrapped aluminum air cylinder No. 85-92:
Survey of Wastes Before Disposal from Nuclear Reactor Facilitie Presently, no segregation is performed; all wastes from controlled areas are disposed of as contaminate The licensee plans to develop a program to monitor and segregate potentially clean wastes being removed from controlled area No. 86-20:
Low Level Radioactive Waste Scaling Factors, 10 CFR 6 The licensee collects and has analyzed waste steam samples, and develops scaling factors in accordance with 10 CFR 61 requirement Frequency of sample collection, analysis, and scaling factor development complies with regulatory requirement No. 86-22:
Underresponse of Radiation Survey Instrument to High Radiation Field The licensee does not use the subject Eberline Model No. ESP-1 survey instrumen No. 86-23:
Excessive Skin Exposures Due to Contamination with Hot Particle Dresden Station experiences incidents of hot particle skin contaminatio The licensee has developed procedures for followup of skin contamination events and calculation of dose to ski No. 86-24:
Respirator Users Notice:
Increased Inspection Frequency for Certain Self-Contained Breathing Apparatus Air Cylinder Dresden Station does not use the subject air cylinder No. 86-42:
Improper Maintenance of Radiation Monitoring ~ystem This notice discusses use of jumpers and verification of Jumper remova Dresden Station procedures require that a second independent person verify jumper installation and remova No. 86-44:
Failure to Follow Procedures when Working in High Radiation Area This notice concerns entry into TIP room The licensee's administrative procedures require that TIPs not be moved during personnel entries into the TIP roo The licensee is considering use of additional postings to ensure administrative requirements are adhered t I,
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1 Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on November 6, 198 The inspector summarized the scope and findings of the inspectio The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee identified no such documents/processes as proprietar In response to certain items discussed by the inspector, the licensee: Acknowledged the need to continue management support for the contamination reclamation progra (Section 6.) Acknowledged the need to expedite the 10 CFR 20.302 submittal concerning disposition of contaminated soi (Section 3.) Acknowledged that enhanced access controls for high radiation areas with elevated exposure rates may be desirable; acknowledged that the inspector considers this matter to be a licensee programmatic weakness; and acknowledged the inspector's requests for a written response, with proposed corrective actions, to this apparent weaknes (Section 7.)
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