IR 05000237/1987003

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Radiation Protection & Radwaste Mgt Program Insp Repts 50-237/87-03 & 50-249/87-03 on 861208-870206.Violations Noted:Failure of Employees to Perform Procedural Requirements
ML20211L932
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 02/17/1987
From: Grant W, Greger L, Miller D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211L660 List:
References
50-237-87-03, 50-249-87-03, NUDOCS 8702270181
Download: ML20211L932 (16)


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U. S. NUCLEAR REGULATORY COMISSION

REGION III

Reports No. 50-237/87003(DRSS); 50-249/87003(DRSS)

Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:

Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name:

Dresden Nuclear Power Station, Units 2 and 3 Inspection At:

Dresden Site, Morris, Illinois Inspection Conducted:

December 8-18, 1986, and January 6-13, and February 6, 1987 0. 8, ftn${tv d'/#/#7 Inspectors:

D. E. Miller Date W

lG

W. B. Grant

  • I Date

Approved By:

L. R. Greger, Chief k1116*7 Facilities Radiation Protection Date Section Inspection Summary Inspection on December 8-18, 1986 and January 6-13, and February 6, 1987 (Reports No. 50-237/8/003(DR55); No. 50-Z49/8/003(DR55))

Areas Inspected:

Routine, unannounced inspection of the radiation protection and radwasto management programs for operational and refueling / maintenance outage activities.

Also reviewed were past open items, radiation protection program improvements, a liquid effluent release event, and a solid radwaste l

transportation event.

Results:

Two violations were identified (failure of two employees to perform

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procedural requirements - Section 8; liquid release without operable monitor or action statement compliance - Section 8).

8702270181 870217

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DETAILS 1.

Persons Contacted

  • D. Adam, Regulatory Assurance Supervisor D. Ambler, Radiological Engineer
  • J. Brunner, Assistant Superintendent, Technical Services
  • E. Eenigenburg, Station Manager
  • R. Flessner, Superintendent, Services
  • P. Hamby, Health Physicist, Nuclear Services
  • E. O'Connor, Rad / Chem Supervisor
  • R. Jeisy, Station Quality Assurance (QA) Supervisor W. Johnson, Lead Chemist
  • J. Kotowski, Assistant Superintendent, Operations D. Sharper, Waste Systems Engineer
  • D. Soccomando, lead Health Physicist
  • J. Wujciga, Superintendent, Production
  • L. McGregor, NRC Senior Resident Inspector
  • P. Kaufman, NRC Resident Inspector The inspectors also contacted several other licensee and contractor personnel.
  • Denotes those present at the exit meeting.

2.

General This inspection, which began at 8:30 a.m. on December 8, 1986, was conducted to examine the radiation protection and radwaste mana programs for operational and refueling / maintenance activities. gement Also reviewed were past open items, radiation protection program improvements, a liquid effluent release event, and a solid radwaste transportation event.

3.

Licensee Action on Previous Inspection Findings (0 pen)OpenItems(237/86008-01;249/86010-01):

Cleanup program for outdoor areas.

The general cleanup of unwanted materials continues; most areas have been cleared of such materials.

As discussed in Inspection Reports No. 50-237/86023; No. 50-249/86028, there were more than 100 sea vans onsite that contained contaminated waste materials, contaminated tools, and other contaminated materials and equipment.

Since then, the licensee selected a bidder to take ownership of the vans and all contaminated material.

The bidder was to have transported the vans and contents offsite, decontaminate the recoverable materials,dder was toand properly dispose of the remainder.

The contract stated that the bi

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take possession of the materials at Dresden Station before transport.

It was subsequently discovered, however, that the successful bidder legally

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could not take possession of the materials at the Station because such possession was not permitted by the bidder's Agreement State radioactive material license.

Dresden Station then became the shipper.

The licensee and contractor checked the contents of each van to assure adequate packing of items and quantification of radioactive contents, and to add internal bracing of the van's contents to prevent load shifting during transport.

Consequently, the licensee's target date of mid-December for completion of removal of the vans from the site was not met.

A total of 20 vans were transported offsite as of January 6,1987.

(0 pen) 0 pen Items (50-237/85026-01 50-249/85021-01):

Disposition of contaminated soil.

Thelicenseeplannedtosubmita10CFR20.302

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request to the NRC by December 31 1986, for permission to bury contaminatedsoilonownercontroiledproperty.

On January 5, 1987, Dresden Station received guidance from the CECO corporate office concerning their recommended method of onsite radioanalysis of the previously collected contaminated soil samples; the licensee began

)erformarce of the analyses on January 6, 1987.

No new target date had

)een established for submittal of the 10 CFR 20.302 request.

(0 pen)OpenItems(50-237/85041-02;50-249/85035-02):

Contamination reclamation program.

This matter is discussed in Section 4.

4.

Control of Radioactive Materials and Contamination materials and contamination, including: program for control of radioactive The inspectors reviewed the licensee's changes in instrumentation, equipment and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.

The licensee's contamination reduction program continues.

An overall reduction in the extent of contaminated areas and the concentration of contamination in contaminated areas is being realized.

Methods being used to reduce contamination spread events are discussed in Section 6.

The extent of contaminated areas and the concentration of contamination in contaminated areas is being trended.

Progress of the program will be reviewed during future inspections (50-237/85041-02; 50-249/85035-02).

During the current refueling outage, the drywell was pressure washed to reduce contamination levels, and the torus internals are being cleaned and repainted.

The licensee is planning a modification of torus basement sumps to decrease the probability of flocding and recontamination.

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The licensee began radiological sorting of potentially clean waste that is removed from controlled areas.

The sorting is being performed in a lowbackgroundarea(interimradwastestoragefacility)usingfriskers.

No problems were noted during the inspector s review of the sorting program.

No violations or deviations were identified.

5.

Internal Exposure Control The inspectors reviewed the licensee's internal exposure control and assessment programs, including changes to procedures affecting internal exposure control and personal exposure 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; and required records, reports, and notifications.

The licensee's program for controlling internal exposures includes the

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use of protective clothing, respirators, and ecuipment, and control of surface and airborne radioactivity.

A selectec review of air sample and survey results was made; no significant problems were noted.

Whole body count (WBC) data was reviewed for counts performed during the

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fourth calendar quarter 1986 on company and contractor )ersonnel.

Several followup counts were performed on persons who slowed elevated initial counts.

Followup counting was adequate to verify that the 40 MPC-hour control measure was not exceeded.

The licensee has initiated a program for trending WBC data greater than

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onepercentofMaximumPermissibleBodyBurden(MPBB).

The trending is in two categories; WBCs that initially were MPBB and reduced to near zero on recounting, greater than one percent of and WBCs greater than one percent MPBB.

The inspectors reviewed the licensee's trending data; no problems were noted.

No violations or deviations were identified.

6.

Personal Contamination Events Tracking of personal contamination events began during the Unit 3 recirculating piping replacement (RPR) program and is discussed in Inspection Reports No. 50-237/86008, No. 50-249/86010, No. 50-237/86023, and No. 50-249/86028.

The number of personal contamination events was trending downward, even though the number appeared large, until December 1986 when 264 events were reported.

Sixty-five percent of the

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264 events were clothing contamination; 70 percent of the clothing contaminations were shoe contamination events.

The 264 events are an increase of 105 percent from the previous month.

The licensee attributes the elevated number of personal contamination events to the Unit 2 refueling / maintenance outage, installation of fire protection piping which involved extensive work in building overhead areas which had accumulated small quantities of contamination over the years, work being performed in the Unit 2/3 radwaste building in preparation for major revamping work, and work performed in the Unit 2 and 3 torus basements to prepare for modification of sumps and sump pumps.

The licensee maintains records showing inplant areas in which individual personal contamination events occurred and the person involved; causes of these events are investigated.

In addition the following actions have

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been taken to reduce personal contamination, events:

Institution of routine cleaning of the plant, including assignment

of designated stationman to each floor to conduct daily mopping; to see that leaks are contained; to keep all pipes, walls and equipmentuncontaminated;andtoremovetrashandusedRWEclothing.

Assignment of an RCT to the decon room to follow events.

  • Use of INP0 criteria to trend events.
  • Computer '. racking of events.
  • Requirement that contaminated individual takes his personal

contamination report (PCR) to his supervisor.

PCRs are given to department heads for trending.

  • Personal contamination events appear to be trending downward again during January, with 44 events reported through January 13, 1987.

No~ violations or deviations were identified.

7.

Radiation Protection Programmatic Improvement Initiatives

In response to findings from onsite, corporate, and industry quality assurance audits, the licensee has or will implement the following:

Establish remote Radiation Work Permit (RWP) review stations to

relieve congestion at the RWP issue area.

This has been accomplished.

  • Remodel the RWP office and evaluate the RWP remote stations

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for adequacy and necessity.

Planning is in progress.

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Modify radiation protection foreman tasks so that unit foremen can

provide more direct supervision of RCTs and oversight of radiological work.

This has been accomplished.

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Establish goals for personal contamination and radiological occurrence reports by. department.

Implementation in progress.

Establish a file and audit program for performance evaluations

of each rad / chem department employee.

This program has been initiated.

Establish a program where health physicists and station first line

supervisors tour the station on designated days to review ongoing radiation protection practices. This program has been initiated.

Program for evaluation of trending of whole body counting results

that are greater than one percent of an organ burden.

A health physicist now signs off on the vendor reports.

Corporate has a trending program and report.

This is considered implemented by the licensee.

Program for review and evaluation of vendor calibration of whole

body counter (annual).

This program has been developed.

Evaluate the frequency of source checking of two high radiation

range survey instruments.

The instruments have been marked for emergency use; a sticker was affixed indicating need for source check on high range before use.

The licensee considers this item complete.

Ensure the effectiveness of trending program for personal

contamination events.

The licensee n,as expanded the trending program to better identify root cause of events.

The licensee considered this item complete.

Ensure that the health physics staff spot checks selected RWPs for

adequacy. The licensee considered this item completed and implemented.

Ensure that RCTs question workers to determine their understanding

of RWPs.

The licensee considers this item completed and im through additional RCT training and foreman spot checking. plemented Develop action plan and implementing procedures for additional

posting and access controls for "very high radiation" areas.

The action plan and implementing procedures are being developed.

The licensee plans implementation by March 1, 1987.

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Ensure that health physicists spot check RWPs to evaluate adequacy

of prescribed air sampling.

These spot checks have been implemented; the licensee considers this item closed.

Serialize respirators with metal tags to aid in control and assure

ability to locate wearer if needed.

Serialization is complete.

Ensure that significant contamination events are being investigated

by representatives of the affected department and corrective actions address the cause.

A procedure change was initiated to address and implement this initiative.

Ensure that plant tours by health physicists include radioactive

materials storage areas and that prompt action is taken to correct any deficiencies.

Checklists have been developed to aid implementation.

The licensee has implemented this program.

No violations or deviations were identified.

8.

Liquid Effluent Release Event a.

Event At 1845 hours0.0214 days <br />0.513 hours <br />0.00305 weeks <br />7.020225e-4 months <br /> on January 5, 1987, a planned liquid radwaste release of "C" waste sample tank was started.

At 2350 hours0.0272 days <br />0.653 hours <br />0.00389 weeks <br />8.94175e-4 months <br />, the oncoming midnight shift radwaste foreman attempted to collect a routine sample of the ongoing release at the liquid radwaste monitor (this sample is analyzed for compliance with State of Illinois requirements).

The foreman found that there was no flow through the monitor.

The foreman investigated and found that three valves located between the licuid radwaste discharge line and the monitor were mispositioned, anc that, consequently, the discharge to the river was proceeding without an operable radwaste monitor.

The foreman terminated the release, which was nearly completed, and wrote a Deviation Report describing the "as found' conditiom b.

Monitor Requirements When making planned liquid radwaste releases to the river, the

licensee routinely performs the technical specification action statement requirements (Technical Specification No. 3.2 and Table No. 3.2.4) that would apply if the effluent monitor were inoperable.

The action statement requires that prior to initiating a release at least two independent samples be analyzed and at least two members of the facility staff independently verify the release calculations and discharge valving.

These requirements appear in licensee Procedure No. DOP 2000-28, " Radioactive Waste Discharge to River,"

which implement Section 8.2.3 of the station's Offsite Dose Calculation Manual (0DCM).

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Investigation Summary At about 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> on January 6, 1987, the licensee informed onsite

~NRC representatives that there had been a problem with a liquid radwaste release the previous day, and that the licensee had started an investigation into the event.-

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At about 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> on January 7, 1987, the licensee informed onsite

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' NRC representatives of the licensee's preliminary findings. The NRC

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Senior Radiation Specialist, who was onsite, performed an independent investigation of the event.

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Based on NRC and licensee investigation of the event, the following was determined.

The investigation details are discussed in Section 8.e. below.

The following matters were also discussed

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during the enforcement conference.

(Section12)

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The relatively inexperienced B-operator who performed the initial valve lineup failed to assure the proper positioning of two valves (designated on a 00P 2000-28 checklist), failed to read

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and comply with a temporary procedure change (which was attached i

to the release paperwork) concerning the proper positioning of a third valve, and failed to perform a D0P 2000-28 procedural

step which reguires that sample flow be verified 15 minutes after initiating the radwaste liquid release.

The B-operator also stated that he had performed a procedural requirement to

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check the liquid monitor readout after he initiated the release, but failed to recognize that the monitor readout was abnormal.

The operator's failings appear attributable to poor-performance

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on his part, weaknesses in the method of informing operators of

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procedural changes, and weaknesses in radwaste operator training.

Technical Specification 6.2 requires that detailed written procedures including applicable checkoff lists be prepared, ion approved, and adhered to, to implement Offsite Dose Calculat

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Manual (0DCM) reguirements.

Procedure D0P 2000-28 contains the i

ODCM implementation requirements.

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Failure of the B-operator to perform certain procedural requirements of D0P 2000-28 is considered noncompliance with

Technical Specification 6.2 requirements (237/87003-01; 249/87003-01).

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The radwaste foreman on duty during performance of the valving

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checklist knowingly failed to perform the required independent valve position verification, while signing the checklist

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indicating that he had performed the verification.

The foreman i

stated that he did not perform the independent verification i

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because he was busy, was not feeling well, and because he trusted the radwaste operator to properly perform the lineup.

He stated that he had never previously failed to verify a valve lineup when he was supp(He did indicate, however, that he had osed to do so, nor was he aware of anyone else laving done so.

previously, on occasion performed the valve lineu1 without anyone performing an independent verification.) T1e foreman had provided little or no guidance to the relatively inexperienced B-operatorfor the January 5,1987 release.

Failure of the radwaste foreman to perform the required independent valve position verification, while signing the checklist indicating that he had done so, is considered willful noncompliance with Technical Specification 6.2 requirements (237/87003-01;249/87003-01).

The planned liquid radwaste release on January 5, 1987, was

made with the liquid radwaste monitoring instrumentation inoperable and the limiting condition for operation action statement (Action B of Table 3.2.4) not complied with.

Technical Specification 3.2.F.1 requires that the liquid radwaste effluent gross activity monitor be operable or that Action B of Table 3.2.4 be complied with.

The liquid radwaste Technical Specification 3.2.F.1 requirements (pliance with237/87003-02; release made on January 5, 1987, was in noncom 249/87003-02).

The B-operator was aware that the radwaste foreman had falsely

signed the valving checklist verification but informed no one.

The liquid radwaste released to the river did not exceed

regulatory limits.

d.

Immediate Licensee Corrective Actions On January 7, 1987, the licensee informed onsite NRC representatives that the radwaste foreman was suspended from duties on the previous day pending determination of formal disciplinary actions.

On January 8, 1987, the licensee provided to the inspector a copy of thelicensee'sPotentiallySignificantEventpreliminaryreport which summarized the licensee s investigation, findings, and proposed corrective actions. On January 13, 1987, the licensee verbally updated the inspector concerning the following corrective actions taken and proposed.

The involved radwaste foreman was given ten working days

off without pay and was demoted to an engineering assistant position.

The B-operator was given one day off without pay.

  • All station employees were being informed of this incident,

its ramifications, and the importance of strict procedural compliance.

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Two of the valves that were mispositioned were permanently

locked in their proper position.

Modifications are planned which will simplify the valve positioning checklists and reduce possibility of valving error.

Additional training of radwaste foreman and B-operators is

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planned.

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Investigation Findings Details The radwaste foreman on. duty,he paperwork for release of ' C"dur

radwaste release, assembled t

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Waste Sample Tank river discharge.

The paperwork consisted of two temporary procedure change sheets for Procedure.00P 2000-28

" Radioactive Waste Discharge to River;" three checklists on which discharge times, activities, tank levels, etc, are recorded;.a checklist for valve lineup for "C" Waste Sample Tank; and a checklist for lineup-of the Off-Stream Liquid Effluent Monitor.

The radwaste foreman, who has.a desk in the shift supervisor's office, had another operator hand carry the paperwor( to the radwaste control room where a relatively inexperienced B-operator was given the paperwork.

The only instruction provided the B-operator was for him to' call the foreman when the release was ready to be started.

When the B-operator called the foreman and told him.the release was ready to start, the foreman told the B-operator to start the discharge and he would be down later to sign off the valve verifications on the checklists.

The radwaste foreman later went to the radwaste control room and signed the valve verifications without checking the valves or otherwise-verifying proper discharge or monitor sample flows.

There was little conversation between the radwaste foreman and the

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B-operator. When asked why he did not perform the valve lineup verifications, the radwaste foreman stated that he was busy, was not feeling well, and because he trusted the radwaste operator to properly perform the lineups.

During interviews with other radwlste foremen and radwaste operhtors, there was no indication that other radwaste foremen have failed to provide adequate guidance to and supervision of operators or that they have failed to perform the required valve lineup verifications.

As stated above, radwaste foremen have a desk in the shift supervisor's office.

This is to provide eas the radwaste foremen and shift supervisors, y interface betweenparti start of a shift.

According to those interviewed, radwaste foremangenerallyspendamajorityoftheirondutytimeinthe

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e field providing, supervision of operators and oversight of..

radwaste operations.

Due to the physical separation between the shift supervisor's office and the D2/3 radwaste control room and radwaste. areas, it. appears that better awareness of radwaste conditions and supervision of radwaste operators may be achieved by locating the radwaste foremens' desk in these areas.

This matter was discussed during the enforcement conference (Section12).

- The relatively inexperienced 8-operator involved in this event-stated that he had performed but one previous liquid radwaste release.

He stated that for the previous release a radwaste foreman had walked through the checklists with him but did not F.

train him concerning temporary procedure changes that may be attached to the discharge paperwork.

The B-operator stated that when the discharge paperwork for. discharge of "C" Waste Storage Tank was brought to him on January 5, 1987, he. reviewed Procedure D0P 2000-28 before starting the checklists.

He stated that he did not notice the temporary procedure change.

paperwork; positioning of a valve attached to the releasenor did he concerning

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properly perform temporary procedure changes, and therefore did not properly position a valve in the liquid effluent monitor

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sample line.

During performance of the liquid effluent monitor sample line checklist, the B-operator was to open two valves; the operator stated that he checked the valves by hand, thought

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The operator said

that he had been taught the proper. method of valve position verification,tioning of the valves prevented sample flow though but did not use the techniques in this instance.

Improper posi the radwaste liquid effluent radiation monitor. The B-operator completed the remainder.of the checklists and called the foreman.

The foreman told the B-operator to start the release.

The release

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was started.

The B-operator stated that he was aware that the radwaste foreman was required to perform a valving verification,

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t but he informed no one that it had not been performed prior to

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A DOP 2000-28 procedural step requires that sample flow through the monitor be verified 15 minutes after initiating the liquid radwaste release.

The B-operator stated that he failed to remember to perform this procedural requirement.

Therefore, the release continued without sample flow through the monitor.

An additional problem with sample flow alarm indication is

described in a following subsection.

The B-operator stated that he had performed a procedural requirement to check the liquid monitor readout after the release was started, but failed to recognize that the monitor reading was abnormal.

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Radwaste operators received generic radwaste systems training at Ceco's Braidwood Training Center; the training is INP0 accredited.

However, the training is systems oriented. Noformaloron-the-job training or qualification program is routinely provided to radwaste operators for specific operational radwaste procedures.

The B-operator stated that he had received generic training concerning the proper methods of assuring proper valve positioning, but had failed to properly, apply the methods on two of the valves later found to be mis)ositioned.

Also, had the B-operator been more familiar with tie valve lineup checklists he should have realized thatthetwovalveswererequiredtobeclosedonapost-discharge checklist and his supposedly finding the valves open would indicate that the previously performed checklist would not have been properly performed.

The B-operator's actions in performance of the radwaste liquid release was poor; additional training appears needed.

Supervision of the B-operator provided by the radwaste foreman was essentially nonexistent.

The liquid radwaste effluent monitor low sample flow alarm

is actuated by a flowrater.

According to licensee representatives, during flushing of the monitor and associated piping after termination of a liquid release the flowrater plumette occasionally " hangs-up" in the full scale flow position thereby defeating the low flow alarm. The radwaste foreman, who identified that there was no flow through the monitor, indicated in the deviation re) ort that the low flow area was not lit he laterstatedthatt1eplumettemayhavestuckduringthefiush cycle performed after the previous liquid release.

During interview, the B-operator stated that when he performed a checklist item calling for "After flow is verified, reset the 2/3 Radwaste Discharge Loss of Sample Flow Alarm," he found that the alarm light was not lit.

He stated that he mentally questioned why the alarm light was not lit, but did not inform the radwaste foreman or investigate further.

It appears that the semple flowrater should be repaired or l

replaced, or an additional procedural step developed to assure proper actuation of the low sample flow alarm.

Revised radwaste procedures and temporary procedure changes are

routed to radwaste foremen for filing and implementation.

For the temporary procedure changes for this event, the change sheets were copied by the radwaste foreman and attached to the release paperwork.

The release paperwork does not include the entire DOP 2000-28 procedure, only the applicable valving

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checklists for the specific liquid radwaste tank to be released to the river and temporary procedure changes.

There is no program for distribution of appropriate procedures and changes to radwaste operators for their review, nor is there a formal program for assuring that operators are informed of applicable changes.

The licensee depends on an informal system whereby radwaste foreman inform appropriate radwaste operators of changes.

In this case, the informal program failed.

The release was in progress for several hours before it was

recognized that there was no sample flow through the monitor.

Even though the valving errors were made and valve positioning was not verified, there were several indicators that should have caused earlier detection of lack of sample flow through the monitor.

They include:

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The B-operator failed to question why the monitor low flow alarm target was not lit when he performed a checklist item to reset the alarm target.

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Proper performance of a procedural requirement to verify sample flow through the monitor 15 minutes after the release was started was not accomplished.

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The B-operator did not recognize that the monitor count-rate strip chart indication was abnormal. The radwaste foreman apparently also did not notice the abnormal strip chart indication.

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Had an attempt been made to collect the routine grab.

sample from the monitor shortly after the release was started, instead of near completion of the release, the

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loss of flow would have been detected earlier.

According to other radwaste foremen, the sample or a portion of it, thiscase,ycollectedearlyinthereleaseperiod.

is normall In

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the oncoming radwaste foreman recognized that

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no sample had been collected and that the release was nearly completed; he attempted to collect the sample immediately.

Two violations were identified.

9.

Solid Radwaste Transportation Incident On December 8, 1986, the licensee was notified by the Barnwell, S.C.

l burial site of a problem with a solid radwaste shipment that left Dresden Station on December 4, 1986.

The shipment was concentrated waste solidified in a liner and transported in a shielding cask.

The burial l

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S site informed theLlicensee that smearable contamination levels up to 177,000 dps/100 cm2 were found in the.inside bottom of the shielding cask; condition 60 of the State of South Carolina Radioactive Material

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License No. 097 (burial site's license) permits up to 20,000 dpm/100 cm2, f

Two CECO employees.went to the burial site on December 9, 1986, to

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' inspect the shipping cask.

Dresden station radwaste department employees reviewed'onsite operations and equipment to seek the source of the radioactive materials.

It was found that a process shield, in which the

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liner was processed and stored onsite until transfer to the truck

mounted shielding cask for transport, also had radioactive materials on the inside bottom; the physical quantity of material was "a couple of-cupfulls." No other onsite process shield was found to contain radioactive materials.

The licensee considers the process shield to be

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the source of.the material found in the shipping cask; the process shield was decontaminated.

i On December 22, 1986, Dresden Station received a letter from the State of South Carolina Bureau of Radiological Health stating that no violations or

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civil penalty would be imposed in this case.

Dresden Station was requested to submit written corrective actions.

The written corrective actions were submitted as requested; they included additional proceduralized routine quality assurance inspections of onsite process shields.

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No violations of NRC or COT requirements were identified.

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Plant Tours

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Several tours of radiologically significant areas were made to review posting, access' controls, contamination controls, and housekeeping.

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i During these tours it was noted that many improvements have been made or

.are in progress of being made to strengthen the health physics program during routine operation and refueling outages.

The improvements include:

Increased numbers of shielded frisker stations throughout the plant

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with more comprehensive instructions concerning actions to follow when personal contamination is detected.

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Increased use'of whole body. friskers throughout the plant.

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A new personnel decontamination facility located in the access i

control building, and relocation of the shoe decontamination l

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Increased surveillance of plant activities by health physicists and

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RCT foremen.

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Increased number of plant areas that have been decontaminated and

repainted.

Good housekeeping throughout the plant.

  • No instance of persons not adhering to procedures was noted during these tours.

No violations or deviations were identified.

11.

Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of,the inspection on January 13, 1987.

The inspector summarized the scope and findings of the inspection.

The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee identified no such documents / processes as proprietary.

In response to certain items discussed by the inspector, the licensee:

a.

Stated that the improvements being made in outside housekeeping and radioactive materials storage areas would continue (Section 3).

i b.

Acknowledgedtheviolations(Section8).

c.

Stated that the contamination reclamation program would continue (Section3).

12.

Enforcement Conference An enforcement conference was held February 6, 1987, to discuss the January 5,1987, licuid radwaste release event, Region III staff concerns about the errors mace during the release, and the associated apparent violations of requirements, including wi11 fulness.

The principal attendees at the meeting held at the NRC Region III office are listed below.

i l

Region III employees indicated their concern about the actions of the

B-operator and radwaste foreman, and possible training, equipment, and arocedural shortcomings.

The licensee presented corrective actions that lave been taken and are proposed.

Principal Licensee Attendees

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D. Galle, Assistant Vice President and General Manager B. Stevenson, Manager, Nuclear Safety D. Farrar, Director, Nuclear Licensing

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N. Kalivianakis, Vice President, Nuclear O J. Eenigenburg, Station Manager (Dresden) perations L. Gerner, Superintendent,-Compliance l

Principal' Region III Attendees

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A. Davis, Administrator J. Hind, Director, Division'of Radiation Safety and Safeguard

- C. Paperiello, Director, Division of Reactor Safety W. Shafer, Chief, Emergency Preparedness and Radiological Protection Branch L. Greger, Chief, Facilities Radiation Protection Section B. Stapleton,. Enforcement Specialist

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