IR 05000237/1987021
| ML17199R317 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/05/1987 |
| From: | Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17199R315 | List: |
| References | |
| 50-237-87-21, 50-249-87-20, NUDOCS 8708110162 | |
| Download: ML17199R317 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/87021(DRSS); 50-249/87020(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:
June 11-12, 16-17, and July 15-17, 1987 (_:
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D. E. Miller Accompanying Personnel:
W.W. Ogg Approved By:
G. R. Pristas
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L. R. Greger, Chief Facilities Radiation Protection Section Inspection Summary Inspection on June 11-12, 16-17, and July 15-17, 1987 (Reports No. 50-237/87021(DRSS); 50-249/87020(DRSS))
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Areas Inspected:
Routine unannounced inspection of portions of the licensee 1 s radiation protection and radwaste management programs, including:
control of radioactive materials, high radiation areas, and drywell entries during spent fuel movement; audits; a hot particle incident; solid, liquid, and gaseous radwaste management; and transportatio Results:
No violations or deviations were identified.
8708110162 870806 PDR ADOCK 05000237 G
- DETAILS Persons Contacted
- D. Adam, Rad/Chem Supervisor D. Ambler, Radiological Engineer
- E. Armstrong, Regulatory Assurance Supervisor
- K. Brennan, Regulatory Ass.urance
- E. Eenigenburg, Station Manager
- R. Flessner, Superintendent, Services R. Jeisy, Station Quality Assurance Supervisor L. Jordan, Health Physicist
- D. Saccomando, Lead Health Physicist D. Sharper, Waste Systems Engineer
- R. Stols, Quality Assurance Engineer
- R. Higgins, NRC Senior Resident Inspector (Quad Cities Station)
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 June 11, 1987, was conducted to examine portions of the licensee's operational radiation protection and radwaste management program The inspection included several plant tours, review of posting, labeling, housekeeping, materials handling, and access control Also reviewed were selected open items and a hot particle incident.. Licensee Action on Previous Inspection Findings (Closed) Open Item (237/86023-01; 249/86028-01):
Enhanced access controls for elevated high radiation area This matter is discussed in Section (Closed) Open Item (237/86008-01; 249/86010-01):
Cleanup program for outdoor area The licensee has made a concerted effort to get rid of unneeded materials, package and transport radwaste materials for burial, and decontaminate materials for further later us In addition, overall housekeeping and appearance improvements are eviden Plans for disposal/
recovery of remaining materials are scheduled or implementation is in progres This matter is also discussed in Section 9.
(Closed) Open Item (237/85041-02; 249/85035-02):
Contamination reclamation progra The licensee has made a concerted effort to implement an effective contamination reclamation progra An overall downward trend in percentage of plant areas contaminated, and contamination levels in contaminated areas, has resulte In addition, more emphasis is being placed on repair and replacement of leaking equipment to reduce recontamination potentia.
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; and effectiveness of methods of control of radioactive and contaminated material As discussed in previous inspection reports, the licensee has experienced frequent flooding problems in both reactor building torus basements because of inadequate and frequently malfunctioning sump pump Each flooding recontaminated basement area The licensee has since modified the sump pumping systems to provide adequate reliable pumping capacity and has hard wired the pumps into the electrical suppl Future recontaminations of the torus basements should be less frequen The licensee has reduced the number of access and egress points to and from the turbine/reactor/radwaste building controlled are All egress points are equipped with whole body frisker Some remote buildings, outside the main controlled area, have contamination control boundaries and step-off-pads; these areas have minor amounts of contamination or are established because of the potential for contamination; these areas remain equipped with portable hand-held frisker As discussed in Section 7, several possible contamination control and monitoring improvements are being evaluate In addition, several improvements/changes have been implemented, including:
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0 Additional and/or improved wall and floor scaling/painting has been done within the controlled are A tool decontamination room has been established and made operationa Greater use is being made of broad area swipes to identify contamination sprea Floor cleaning machines are used to more efficiently clean broad flat areas.
Several possible additional needed improvements were noted by the inspectors or resulted from discussions with licensee representative These include:
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Further improvement in step-off-pad design/erection to minimize possibility of contamination spread outside the pad are Improve compliance with step-off-pad egress procedures and technique Further decontaminate cable trays if an acceptable technique is identifie Improve radiological control of repair of internally contaminated equipment such as electrical motor Improve handling and storage of potentially contaminated tool Decontamination of contaminated ventilation systems where possibl Improve job planning to include disposition of contaminated materials and tool Improvement in laundered protective clothing monitoring is discussed in the following paragrap The monitor used to survey laundered protective clothing before reuse is capable of detecting a one mR/hr point source at one inch and provides an alarm at that leve The detectors are G-M tubes mounted in a frame under which the clothing, folded once, rides on a conveyer belt. This monitoring
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protection standard Because of the increased observation of hot particles and possibility that dry-cleaning may not remove all such particles from protective clothing fabric, CECo corporate representatives investigated more sensitive commercially available laundry monitors and recommended a model available from IR The licensee purchased the monitor, has it onsite, and is performing operational and calibration check According to the licensee, the new monitor should be capable of detecting between 60 and 100 nanocuries (depending on background radiation levels) of Co-60 when unfolded protective clothing rides on a conveyer at one foot per second under the detector No violations or deviations were identifie.
Control Of High Radiation Areas The licensee has revised Procedure OAP 12-4, Control Of High Radiation.
Areas (Revision 11), to:
Place primary responsibility for control of keys with the Rad/Chem Superviso Alter log-in and out requirements to include required use of log sheet Further formalize drywell entry requirements during refueling/
maintenance outages, and; Establish additional access controls for areas where whole body dose rate levels exceed, or could exceed, 15 rem/h Areas where.whole body dose rate levels exceed, or could exceed, 15 rem/hr are now designated high high radiation area Such areas are required to be posted as high high radiation areas and -be locked with a unique type of lock with the keys locked in a storage box in the Health Physicists' office; the key to the storage box is controlled by the Rad/Chem Superviso Record keeping for these locks/keys must be performed by the Rad/Chem Supervisor, Lead Health Physicist or a designated health physicis No violations or deviations were identifie.
Radiological Controls for Drywell Access During Spent Fuel Movement (TI 2500/23)
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The licensee employs a fuel-shute shield to limit dose rate levels in the drywell when defueling spent fue In addition, access to the third and fourth drywell levels is not permitted during spent fuel handling*
operation Access is controlled by placing covers over the ladders to these levels and locking the covers in plac The covers are posted with instructional signs indicating potential for elevated radiation level The locks are high high radiation area locks, the keys to which are controlled by the Rad/Chem Superviso *
Use of the fuel-shute shield and ;~position of drywell access limitations began in 1973 in response to a May 31, 1973 GE Operating Experience Repor The report analyzed dose rates in the drywe 11 from various fuel movement and fuel drop incidents with and-without a fuel-shute shiel With a fuel-shute shield in place, the maximum credible exposure rate would result from a fuel element held against the vessel wall above the vertical extent of the biological shiel Prohibiting access to the upper drywell levels reduces the maximum exposure rate to an individual in the drywell (worst case) to less than 100 mR/h The licensee places an area radiation monitor (ARM) in the drywell above the permitted access area; the ARM provides local alarm and a remote alarm at the drywell access contrpl point to alert personnel of change conditions.
- During the inspector's review, no procedural reference/requirement or checklist item designed to implement the drywell access control restri~tion was foun During the inspection and at the exit meeting the inspector asked the licensee to review applicabl~ procedures to determine if adequate implementing procedures exist and, if not, to develop and implement such procedural requirement The licensee agreed to perform the review and make necessary procedural changes.*
(Open Item 237/87021-01; 249/87020-01)
No violations or deviations were identifie.
Audits The inspector selectively reviewed onsite, offsite, and contracted audits performed by or for the licensee from July 1, 1986, to dat Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewe Two semi-annual offsite quality assurance audits of station activities were conducte Included were selected radiation protection and radwaste topic One finding concerning completeness of radwaste shipping papers was identifie The licensee's response to this finding has since been implemented and the item closed by the auditor Four stati-0n*quality assurance audits of selected radiation protection and radwaste topics wer~ performe Findings and observations included
- topics concerning radiological occurrence report corrective action implementation, ALARA meeting attendance, documentation of radwaste package visual inspections for freestanding water, R~key master list checks, and supervisory review of whole body frisker check The licensee's corrective actions have since been implemented and the items closed by the auditor The licensee contracted a consultant to review the station's contamination control program as it relates to apparently excessive personal contamination event The consultant's review was performed on May 11-18, 198 At the station's request, an INPO representative performed a special assistance review of the same subject on May 18-22, 198 Several conclusions and recommendations, res~lting f~om the reviews, are being evaluated by the license The extent of audits, qualifications of auditors, and adequacy of corrective actions appears goo No violations or deviations were identified.
- Hot Particle Incident At about midnight on July 9, 1987, a station mechanical maintenance worker alarmed a portal monitor in the gatehouse when leaving work at the end of his work shift. The worker reentered the protected area and proceeded to the personnel decontamination room where a rad/chem technician (RCT)
frisked the worker and found a radioactive particle about an inch below his left elbo The RCT used a piece of duct tape to remove the particle from the worker's ski The RCT then placed the particle and tape in a Petri dish for liter radi~isotopic analysi No additional contamination was found on the worke The RCT questioned the worker concerning where he had worked during his work shift, and then informed the radiation protection foreman on duty about the incident, The foreman contacted a health physicist and described the inciden The foreman was instructed not to permit the worker to enter a radiologically controlled area until a dose evaluation and investigation was complete The worker was allowed to go hom On July 10, 1987, an investigation into this incident was begun by two health physicists and the regulatory assurance superviso The results of their investigation are discussed belo The inspector performed an independent review of the incident incuding interview of the worker, job site visits, performance of dose calculations, and records review, as noted belo Event Chronology On July 9, 1987, the station mechnical maintenance worker was assigned to work on a condensate booster pump located in the Unit 2 turbine building basemen The area was slightly contaminated and the background radiation levels were lo The worker wore prescribed protective clothing; no respirator was prescribe Three times during his work shift, the worker entered the controlled area, donned protective clothing, and worked on the booster pum When leaving the controlled area each time after working on the pump, the worker whole body frisked himself in a PCM whole body frisker at the Unit 2 trackwa There are five PCM friskers at the trackwa During the first two exit frisks, the PCM did not alarm indicating that no significant contamination was present on the worke During his third exit frisk, the PCM alarmed and indicated contamination was detected by two frisker zone The worker then used a second PCM to verify the alarm The second PCM did not alarm and the LED message indicated that he was not contaminate He assumed that the second PCM was correct; however, he indicated that near the end of the count cycle on the second PCM, he noted that the instrument trouble light was li *
The worker then went to the mechanical maintenance shop where he stayed for the remainder of his work shift; no contaminated materials were worked on during this latter perio At the end of the work shift, the worker alarmed the portal monitor in the gatehous Isotopic Identification and Dose Calculation On July 10, 1987, the licensee analyzed using GELi; counting equipment, the radioisotopic content and quantity of the particle found on the worker 1 s elbow. The licensee determined that the particle contained 660 nanocuries of cobalt-6 Entries and exits to and from the radiological controlled area are controlled by key card; card use is logged by the security compute The first two entries and exits of the worker were logge During the third entry and exit, the security computer was inoperabl Entry and exit times were estimated through discussions with the worke Since no whole body frisker alarm was received during the first two exits, the licensee assumes the particle got on the worker 1 s skin during the third entr The worker entered the area and donned protective clothing at about 2130 hour0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> The licensee considers 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> on July 9, 1987, to be the earliest time that the particle could have been on the worker 1 s skin, and 0005 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on July 10, 1987, as the time the particle was removed from the ski The licensee therefore used 2.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> skin contact time when calculating the worker*s dos In accordance with procedures, the licensee calculated the skin exposure to 660 nanocuries of Co-60 for 2.58 hours6.712963e-4 days <br />0.0161 hours <br />9.589947e-5 weeks <br />2.2069e-5 months <br /> to be 7663 mre The inspector calculated the skin exposure using the VARSKIN computer code (draft NUREG/CR 4418) and the licensee 1 s time and activity determinations,to be approximately 7000 mre The licensee and NRC calculation results are in reasonable agreemen As noted in IE Information Notice 83-59, skin exposure to the arm at/or below the elbow is considered extremity exposure with a quarterly limit of 18,750 mre No exposure in excess of regulatory limits is indicate Apparent Programmatic Weaknesses Associated With This Event During this inspection, the inspector visited the work site, reviewed applicable records and reports, and interviewed the mechanical maintenance worke The following apparent programmatic weaknesses were identified by the inspector and the licensee during review/investigation of the event.
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It appears likely the hot particle had been attached to protective clothing and was transferred to the worker's ski Future use of a new laundry monitor (Section 4)
should identify hot particles greater than 100 nanocuries on laundered protective clothing and reduce hot particle event The worker used a whole body frisker when the frisker trouble light was lit. The frisker apparently was malfunctioning and did not detect the hot particle on the worker's skin. According to the worker, no instructions had been given, or were posted, to direct people not to use whole body friskers with trouble lights li Use of such friskers with lighted trouble lights was discussed at the exit meetin (Open Item 237/87021-02; 249/87020-02)
No hand frisking booth is located near the turbine building basement work sit Frisking before donning personnel clothing may have detected the particle sooner and reduced the time the particle was on the ski The licensee stated that a review would be made to determine if a shielded frisker could be located near the condensate booster pump are The licensee's investigation of this event was timely and thoroug No violations of regulatory requirements were identified.
Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications, and experience concerning identification and correction of programmatic weaknesse Audits are discussed in other sections of this repor The vendor operated solid radwaste solidification system previously located outdoors adjacent to the radwaste building was relocated indoors in the radwaste truck bay and portions of the drum storage are No radioactive materials are now transferred through hoses outdoors for processing other than waste oil which has small radioactive contamination concentrations.
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The licensee continues to package and ship for burial radioactive materials that have accumulated over the past few years, that were generated during the Unit 3 recirculating system piping replacement, and that resulted from the Unit 1 decontamination projec Included are bins of contaminated dirt that have been stored in a fenced-in area near Unit 1 for several year Excess metals and tanks that are slightly contaminated are being packaged and shipped to a contractor facility where the metals are decontaminated and recovered or repackaged for burial if the decontamination is not successfu Only a small percentage of the large accumulation of radwaste/excess materials remains to be disposed o No problems were noted during the inspectors review of waste characterization/classification, package marking, and required records and report No violations or deviations were identifie Liquids and Liquid Radioactive Wastes The inspector reviewed the licensee 1 s reactor liquids and liquid radwaste management programs, including:
determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether liquid radioactive waste effluent were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse Quality assurance audits are discussed in Section The inspector selectively reviewed records of batch liquid radwaste releases made during 1987 to dat It appears that the technical specification requirements for sampling, analysis, and release concentrations have been complied wit Calibration of the liquid radwaste monitor is discussed in Inspection Reports No. 50-237/86008(DRSS); No. 50-249/86010(DRSS).
No problems were note The licensee has considered the originally installed service water monitors inoperable since the revised radiological environmental technical specifications became effective in March 198 The monitors were considered inoperable because they lack adequate detection sensitivit In accordance with the technical specification 1 s action statement, the licensee collects service water grab samples every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzes the samples for radioactive materials conten The licensee has installed replacement monitors for the service water
- systems and is testing and calibrating the monitor The licensee anticipates that some shielding of plant system process lines may be necessary to maintain background radiation levels at the new monitors to acceptable level No violations or deviations were identifie.
Gaseous Radioactive Waste The inspector reviewed the licensee's gaseous radwaste management program, including:
determ'ination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesse Audits are discussed in Section The licensee's gaseous effluent monitoring and sampling systems remain as described in Inspection Reports No. 50-237/85022(DRSS);
No. 50-249/85018(DRSS).
The licensee is required by technical specification to perform functional tests, source checks, and calibrations of the effluent and certain process monitors at set frequencie A selected review of records concerning these requirements for the period 1986 through 1987 to date was performed; it appears that they were accomplished as require Records of particulate, iodine, and noble gaseous radioisotope sampling, analyses, and quantification were selectively reviewed for 1987 to dat No problems were note No violations or deviations were identifie.
Transportation of Radioactive Materials The inspector reviewed the licensee's transportation of radioactive materials program, including:
determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesse Quality assurance is discussed in other sections of this repor Transportation activities remain as described in Inspection Reports No. 50-237/85026(DRSS); No. 50-249/85021(DRSS).
Records of radioactive shipments made during 1987 were selectively reviewed for compliance with 49 CFR 173, 10 CFR 61, and 10 CFR 7 No problems were identifie No violations or deviations were identifie.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on July 17, 198 The inspector summarized the scope and finding of the inspectio The inspector also discussed the likely information content of the inspection report with regard to documents and processes reviewed by the inspector during the inspec~ion. The licensee identified no such documents/processes as proprietar In response to certain items discussed by the inspector, the licensee: Stated that applicable procedures would be reviewed to determine if drywell access restrictions during spent fuel movements are adequately implemented, and that such procedural implementations would be added if they are not presently include (Section 6) Stated that PCMs would be posted with instructional signs stating that the instruments should not be used when trouble lights are li (Section 8)'
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