IR 05000237/1987036
| ML17199T463 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/08/1987 |
| From: | Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| 50-237-87-36, 50-249-87-35, NUDOCS 8712140256 | |
| Download: ML17199T463 (9) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I II Reports No. 50-237/87036(DRSS); 50-249/87035(DRSS)
Docket Nos. 50-237; 50-249 Licenses No. DPR-19; No. DPR-25 Licensee:
Commonwealth Edison Company P. 0. Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Dresden Site, Morris, Illinois Inspection C~~f November 2-6 and 23-24, 1987
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7~ Inspector:.
D. E. Miller Accompanying Personnel:
Approved By:
Inspection Summary Protection 1z-e-e1 Date 12..-8-!37 Date Inspection on November 2-6 and 23-24, 1987 (Reports No: 50-237/87036(DRSS);
. No. 50-249/87035(DRSS)) *
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Areas Inspected:.Routine unannounced inspection of portions of the licensee's rad1at1on protection program, including:
organization and management controls, external and internal exposure controls and assessment, control of radioactive materials, audits, personal contamination events, and actions taken for previous inspection findings.. A preliminary review of a.llegations concerning control of radioactive.materials was also performe Results:
No violations or deviations were identified.
871 2140256 871208
~DR ADOCK 05000237 PDR
- DETAILS Persons Contacted
- D. Adam, Rad/Chem Supervisor D. Ambler, Radiological Engineer
- E. Armstrong, Regulatory Assurance Supervisor
- W. Bertourne, QA Engineer K. Brennan, Regulatory Assurance
- J. Brunner, Assistant Superintendent, Technical Services
- E. Eenigenburg, Station Manager M. Evans, Stationmen General Foreman L. Jordan, Heal th Physics Coordinator
- D. Saccomando, Lead Health Physicist
- C. Schroeder, Superintendent, Seryices
- P. Ka0fman, NRC Resident Inspector The inspector also contacted several other licensee personne *Denotes those at the exit meetin.. General.
This inspection, which began on November 2, 1987, was conducted to review the.licensee.'s operational radiation protection progra Also reviewed were past open items, and a preliminary review of certain allegations.*
The inspectors toured licensee facilities to review posting, labeling, access controls, and work in progres Also; the inspectors performed independent direct radiation and contamination survey No posting or labeling problems were note Housekeepin~ was generally goo * Licensee Action on Previous Inspection Findings (Closed) Open Item (237/87021-01; 249/87020-01):
Make necessary procedural changes for drywell spent fuel movement in the reactor vesse The licensee revised Procedure DFP 800-1, "Unit 2/3 Master Refueling Procedure," to add requirements for restricted drywell access and installation of additional monitoring equipmen The requirements and monitoring equipment installation. were a normal part of precautions taken during refueling but were not included in procedure The revised procedure is in the review process and will be implemented* before the next refueling outag (Closed) Open Item (237/87021-02; 249/87020-02):
Need for additional instructional signs on PCM-1 whole body frisker The licensee has installed instructional signs on the friskers informing the user not to use the frisker when the 11 trouble 11 light is illuminated unless otherwise instructed by radiation protectio **
- Organization and Management Controls (IP 83722)
The inspectors reviewed the licensee 1s organization and management controls for the ra_di at ion protection and radwaste management programs inc 1 udi ng changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of a~dits of these program Since previously discussed in Inspection Reports No. 50-237/86008; No. 50-249/86010, several radiation protection staffing changes have been mad The changes include:
Two changes in the Rad/Chem Supervisor positto The incumbent.and first replacement both terminated employment with CEC The second replacement held the Rad/Chem Supervisor position before, and has since held several technical and supervisory positions within CECo; he appears qualified in accordance with ANSI N18.1-1971 to hold the position of '
1Radiation Protection Manager
Several changes in health physitist staffin The changes involved hiring and transfer of junior health physicist Health physics staffing currently includes a Lead Health Physicist, Health Physics Coordinator, and four Health Physicist The Lead Health*
Physicist, Health Physics Coordinator, and two of the Health Physici$ts each have several years experienc The Lead Health Physicist meets the 11 Radiation Protection Manager 11 criteria in accordance with ANSI Nl8.l-197 An additional Health Physicist holds the position of Lead Radiological Engineer, reporting directly to the Rad/Chem Supervisor, and supervises the ALARA organizatio The inspectors r~viewed licensee Radiological Occurr~nce Reports (RORs)
written during June through September 1987. * There were about 20 RORs written during the perio The RORs are used as a management tool to record radiological problems, followup investigations, and corrective actions as applicable. lhe licensee's followup and corrective actions were usually timely and thorough.. The reported event subjects were varied, with no outstanding repetitive similar occurrences noted. *
No violations or deviations were identifie.
External Exposure Control and Personal Dosimetry (IP 83724)
The inspectors reviewed the licenseeis external.exposure control and personal dosimetry programs, including:
changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; _planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse.
The external exposure measurement and control program consists of whole body monitoring using thermoluminescent dosimeters, extremity moni.toring using film ring badges, self-reading dosimeters, integrating alarming dosimeters, direct radiation surveys, radiation work permits,
administrative dose limits, and a radiation dose recording syste The licensee's whole body exposure received for 1987 through October was 1095 person-rem.. The pre-established goal for 1987 was 938 person-rem.*
According to a licensee representative, about 350 person-rem was received during the 1987 outage performing tasks which were unplanned and unforesee These tasks* included extensive rewelding on support "cheek plates" in the drywell, additional snubber testing because of failures which extended the testing requirements, *and isolati6n valve reworkin The inspectors selectively reviewed direct radiation survey records, radiation work permits, ALARA review records, and dosimetry reports fo work be1ng performed during the inspectio No problems were note No violations or deviations were identifie ~.
Internal Exposure Control and Assessment (IP 83725)
The inspectors reviewed the licensee's internal.exposure control and assessment p~ograms, including:
changes in facilities, equipment, personnel, and.procedures affecting internal exposure control and
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personal assessment; determination whether engineering controls,
- respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications;.
effectiveness of management techniques used to implement these programs;*
and experience concerning self-identification and correction of program implementation weaknesse Audits are discussed in Section The licensee's program for.controlling internal exposures includes the use of protective clothing, respirators ~nd equipment, ~nd control of surface and airborne radioactivit A selected review of air sample survey resuyts was made; no.significant problems. were note * Whole *body count data was reviewed for counts performed during the third calendar quarter 1987 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 *
The licensee is planning to m*ake several changes to their respiratory protection program.* These changes include a computerized records system whereby training, medical qualifications, individual use of respirators, times of:use, and MPC-hours would be computer recorde To implement the program, bar codes would be placed on NGET cards of potential users and on each respirator. Additional computerized records would be kept for maintenance/repair of individual respirators and portable distribution manifolds; the manifolds would also be bar code Additional changes.
to fit testing efficiency determinations, testing of used filters, and permissible levels of fixed contamination on respirators are planne **** **
No violations or deviations were identifie Control of Radioactive Materials and Contamination (IP 83726)
The inspectors 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 Since previously discussed in Inspection Reports No. 50-237/87021; No. 50-249/87020, several contamination control improvements have been mad These improvements include:
Imposition of greater controls for work performed in overheads within the controlled are The controls include more extensive swipe surveys, use of paper suits in areas where contamination levels are low, and improved contamination controls for areas underneath the overheads entered and worked i *
Placing greater emphasis on swiping out-of-the-way floor areas and equipment while performing routine swipe survey *
Giving increased attention to swipe surveys in contaminated area~*
where work is being performed, and to boundaries to these areas.
Enlarging step-off-pad (SOP) areas when work is to be perf6rmed in the area, and reducing the SOP area when the work is complete Also, improved boundary demarcation methods are being use *
Wet-dry vacuum cleaners are locked-up and issued on a daily or shiftly basis. After use for the shift or day, they are taken to the tool decon room where they are checked-in, decontaminated, and returned to locked storage for reissu *
Laundry monitoring improvements are discussed in Section 1 Additional improvements that are being considered by the licensee include:
Relocation of certain hand-held frisker booths and clothing change areas to lower background radiation level area Specific changes are being considere *
Performance of routine cleaning/decontamination of tools in 11gang boxes 11 within the controlled are *
Construction of a tool storage/issue crib in the Unit 1 Turbine Building, with the intent of reducing the number of 11gang boxes 11 in the controlled area and thereby increasing control of potentially contaminated tool *
The licenseeis tool decontamination facility is described in previous inspection reports. According.to licensee representatives, the facility is being operated 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and there is no backlog of contaminated t~ols and equipment awaiting decontamination except for items that cannot presently be handled in the facility or decontaminated using.the equipment on han The licensee.stated that the facility is cramped, and sometimes too hot in the summer to operate the Freon machin The. licensee stated a long range plan to relocate the facility to a larger area where the temperature can be somewhat controlle The licensee continues to implement an aggressive surface and equipment decontamination program to release areas from contamination controls, and reduce contamination levels in infrequently entered area No violations or deviations were identifie.
Audits The inspectors selectively reviewed onsite and offsite audits performed by the licensee from May 1, 1987, to dat Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewe One semi-annual offsite quality*assurance audit of station activities was
~onducted.. Included were selected radiation protection topics. Dne finding concerning completeness of radioactive source inventories was identifie The ~orrective actions have yet to be reviewed by the auditor *
One station quality assurance audit of selected radiation protection topics was performe There were two.findings and two observation The findings and observations concerned daily dose rate verifications for Type 2 RWPs, frequency of ALARA meetings, outdated procedures in mask issuance area, and maintenance of the mask issuance lo The findings
. and.observations have since been responded to by appropriate licensee.
personnel, corrective actions completed, the corrective actions reviewed and closed by the auditors., The inspector considers the corrective actions to be adequat No violations or deviatibns ~ere identifie.
Personal Contamination Events Personnel contamination events have been tracked quantitatively by the licensee over the last four years and reviewed during several NRC *
inspections dtiring the ~eriod. During 1986 the licensee had 1760 reportable personal contamination incidents; reportable meaning tha the person's skin arid/or personal clothing was contaminated such that when monitored with a pancake probe frisker a response of greater than 100 counts per minute is detected; this reporting criteria is recommended by INP *.
The licensee has made extensive reviews to determine ihe causes of the apparent inordinately high number of personnel contamination incident As a result of the reviews, several contamination control *improvements were initiated; some have been completed and others are in progress or planne During 1987 through October the licensee has recorded 836 personnel contamination *events, 79 percent of which occurred during the first half of this perio The number of events during the latter part of 1987 reflects a significant reduction from those experienced in 1986 but remains hig The inspector reviewed the licensee 1s method of recording and investigating personnel contamination event Because of the large number of events, investigation is not always comprehensiv A portion of the followup of individual events is assigned to the immediate supervisor of CECo employees, or the manager of contractor employee During review of these followups, the inspector learn~d that th followups performed by CECo supervisors is frequently not timely and/or comprehensiv Contractor followups appear more thorough and timel Also learned was that there is no policy or implementing method to ensure that persons who become contaminated at a higher than average frequency receive special attention such as individual counseling, retraining, and/or increased observation of work habits and practice The inspector discussed at the exit meeting the apparent need for more comprehensive and timely contamination followup (Open Item 237/87036-01;
249/87035-01).
No violations or de~iations were identifie.
Monitoring of Laundered Protective Clothing (PCs)
The i nspe.ctors toured the station 1 s protective clothing laundry in the presence of the radiation protection foreman assigned to laundry monitoring.. The licensee maintains both a wet and Freon cleaning system laundry housed in the Dresden-I Turbine Building trackway. * Due to EPA restrictions against Freon burial, dry cleaning usage is being reduce A 11 the licensee 1 s laundry equipment is of good quality and less than one-year ol The new laundry monitor, IRT Corporation 1s Automated Contamination Monitor (ACM) 110-B with moving conveyor, was installed in June 198 After installation, the ACM'llO~B was electronically calibrated, and adjusted by a Health Physicist and IRT Corporation representative to provide an alarm at 100 nCi of cobalt-60 inside the cloth. of PC coverall The source used was a 100 mCi cobalt-60 source fabricated by the licensee from cobalt-60 solution which the inspector*
noted was certified to be traceable to NB The licensee stated that a more extensive calibration is scheduled to be performe Operating procedure SP 87-7-118, written to cover operation of the laundry monitor, includes daily preoperational sensitivity source-check In a telecon with the ACM engineer of the IRT ~orporate office, the inspectors were informed that recommendations concerning ACM calibration methods are not included in the manufacturer 1s manual but are left to the custome The engineer stated that a statistical variance test
should be performed to determine the reliability of the machin The inspectors discussed with the licensee the desirability of performing such tests and development of a procedure which includes the test and test frequencies to establish a quality control/quality assurance program for the AC The licensee stated that performance of a statistical variance test would be considered when the more extensive calibration is performe * *
Protective clothing sorting is done under a large canopy type hood which is exhausted through a HEPA filter; respirators are worn during sortin The inspectors witnessed a demonstration of effective air flow up the hoo The licensee stated that a new sorting table is being fabricated which has exhaust air cufrent pulled down through ducts built into the table botto The licensee collects an air sample continually at a location which appears representative of breathing zone geometry at the sorting table; samples are collected every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and analyze Occasional grab samples are also collected and analyze The inspector examined air sample results for the period June 1 through October 31, 1987 (110 samples).
All air samples yielded a concentration less than 7.5 x E-10 uCi/cc; the counting data appeared to differ little from natural radioactivit The inspectors also examined whole body count records of the ten laundry workers for the current yea Laundry workers are counted three times annuall The inspector found.that all workers were counted timely, and that no worker had a detectable intak The rejectioQ criterion for PCs is that if a garment is washed twice and still causes an alarm on the.ACM-i10-B, it is discarded as radwast The licensee representative stated that the overall rejection of wet laundry is approximately 10%, and *approximately 25% for Freon cleaned laundr The inspectors observed a sampling of 25 pieces of wet laundered protective clothing being checke Three garments (12%)*caused an alarm, which is in good agreement with the licensee 1s statemen No violations or deviations were note.
Unit 1 Fuel Pool The licensee-continues to maintain spent fuel in the Unit 1 spent fuel poo According to licensee representatives, the fuel pool recirculating system cleanup filter failed 11several years 11 ag Since then there ha been no pool water recirculation and/or cleanu Because of the age of spent fuel in the pool, no pool water cooling system is neede The inspectors toured the fuel pool area; the pool water is cloudy and obviously contains particulate and organic matte The sides of the pool, fuel outer surfaces, and pool floor are *coated with a buildup of some type of adhering material several centimeters thic According to licensee representatives, failed spent fuel assemblies have been stored in.the pool over the years and some fuel material probably is incorporated in the material coating the surface The licensee routinely collects fuel pool water (uncirculated) dip samples and performs gamma isotopic analyses and pH determination The pool water is of nominally neutral pH, the isotopic content of an October 5, 1987 dip water sample was mainly Cs-137 (7.9 E-2 uCi/cc), Cs-134 (1.8 E-2 uCi/cc), and Co-60 (7.5 E-5 uCi/cc).
The licensee recently collected samples of the material coating the pool/fuel surfaces and sent the sample~ to a vendor for isotopic analysi The pool water level is monitored by a float switch which provides an alarm on the Unit 1 radwaste control panel with a slave alarm in the Unit 1 control roo Hard piped pool water fill lines are available to add water to the pool from two water sources if water addition is necessar The licensee has budgeted money to perform a cleanup of the pool water and surfaces and to install a filter/demineralizer system to maintain the pool water cleaner than at presen The cleanup is pl_anned for early 198 Progress will be reviewed during a future inspection (Open Items 247/87036-02; 249/87035-02).
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No violation~ or deviations were identifie.
Allegations (AMS NO. RIII-87-A-0142)
On October 27, 1987, an individual contacted Region III with information concerning radiation protection at Dresden Nuclear Station. * The genera1**
topics concerned removal of potentially contamihated tools and clothing*
from the station and use of personal contamination detection device.
During this inspection, the inspectors performed a preliminary review
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of the allegations to determine if immediate action was needed to ensure the health and* safety of the public or the safe operation of the nuclear statio Inasmuch as no such situation was found, on November 13, 1987, Region III forwarded the allegation to the licensee and requested that they fully analyze the allegations, initi.ate an appropriate investigation, take all actions they deem appropriate, and. submit the results of their review and disposition of these matters to Region III; Region III will review the licensee's response to this request as necessary during a future inspectio *
13. * Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on November 24, 198 The inspectors summarized the scope and findings of the inspectio The inspectors also discussed the likely information content of the inspection report with regard to documents and processes reviewed by the inspectors during the inspection:
The licensee identified no such documents/processes as proprietar In response to an inspector's comment the licensee acknowledged the apparent need for a more comprehensive followup of personal contamination events, and for greater efforts to determine the reason for repetitive events and to make necessary corrective actions (See Section 9).
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