IR 05000237/1989015
| ML17202G494 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/09/1989 |
| From: | Miller D, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G493 | List: |
| References | |
| 50-237-89-15, 50-249-89-14, NUDOCS 8906260187 | |
| Download: ML17202G494 (6) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/89015(DRSS); 50-249/89014(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 Inspection At:
Dresden Site, Morris, Illinois Inspection Conducted:
May 22-26, 1989
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Inspector:
D. E. Miller
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Approved BY:
M. Schumacher, Chief Radiological Controls and Chemistry Section Inspection Summary
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Date Inspection on May 22-26, 1989 (Reports No. 50-237/89015(DRSS); 50-249/89014(DRSS))
Areas Inspected:
Routine unannounced inspection of the licensee 1s operational radiation protection program including organization and management controls (IP 83722; 83750), training and qualifications (IP 83750), external exposure controls (IP 83724; 83750), internal exposure controls (IP 83750), control of radioactive materials and contamination (IP 83726; 83750), personal contamination events (IP 83750), and audits (IP 83750).
Also reviewed was a previous open item (IP 92701).
Results:
Overall, the radiation protection program is adequate and improvin The licensee generally responds positively to identified audit and assessment concern Prospects are for continued improvement in the radiation protection progra No violations were identifie Some programmatic weaknesses were identified and discussed with the license PDR ADOCK 05000237 G
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- DETAILS Persons Contacted
- D. Barnett, Quality Assurance
- E. Eenigenburg, Station Manager
- L. Gerner, Production Superintendent
- R. Janecek, Senior Participant, Nuclear Safety L. Jordan, Group Leader, Technical, Health Physics Services (HPS)
- T. Lewis, Regulatory Assurance L. Oshier, Group Leader, Operations/ALARA, HPS
- K. Peterman, Regulatory Assurance Supervisor K. Ritchie, ALARA Coordinator, HPS
- D. Saccomando, HPS Supervisor
- C. Schroeder, Technical Superintendent
- S. DuPont, NRC Senior Resident Inspector
- Denotes those present at the exit meetin The inspector also contacted other licensee and contractor personne.
General This inspection was conducted to review the licensee 1s operational radiation protection progra Also revi~wed was corrective actions for previously identified inspection findings and weaknesse The inspector toured licensee facilities to review posting, labeling, access controls, and radioactive materials handlin No significant problems were note Minor posting problems were brought to the licensee 1s attention; the problems were immediately corrected by the license Housekeeping was goo * Licensee Actions on Previous Inspection Finding (IP 92701)
(Closed) Open Item (237/89003-01; 249/89003-01):
Hold points in feedwater check valve maintenance procedur Procedure DMP 220-1, Feedwater Check Valve Disassembly, Seat and Disc Replacement and Reassembly, has been adequately revised to include radiological precautions and radiation protection hold point The inspector has no further questions at this tim.
Organization and Management Controls (IP 83722; 83750)
The inspector reviewed the licensee 1s organization and management controls for the radiation protection progra Also reviewed was the effectiveness of procedures and other management techniques used to implement the program, and experience concerning self-identification and correction of program implementation weaknesses.
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Contained in Inspection Reports No. 50-237/88024; 50-249/88025, is a description of changes made to the health physics organization except for technician Since then, rad/chem technicians have been permanently assigned to technician positions in the health physics or chemistry services organization These reassignments were made with few resulting programmatic problem Also, the Group Leader, Services position was eliminated; this position was titled Lead Health Physics Foreman prior to
- departmental changes previously described; the individual 1s duties were divided and given to other foremen and supervisors; the effect of this change will be reviewed during future routine inspection To identify programmatic weaknesses, the licensee utilizes Radiological Occurrence Reports (RORs), station and corporate QA audits and surveillances, industry assessments, and corporate assessment The inspector reviewed RORs written during 1989 through May 19, In general, RORs are adequately investigated to determine root cause, and corrective actions implemented to reduce possibility or reoccurrence; however, followup reviews do not always appear timely, and supervisory corrective actions for personnel failure to follow radiation protection procedures may sometimes not appear strong enoug Timeliness and corrective actions for RORs will be.critically reviewed during future routine inspections; this matter was discussed with the licensee during the inspectio Audits are discussed in Section 10.
. No violations or deviations were identifie Training and Qualifications (IP 83750)
The inspector reviewed the licensee 1s methods of determining qualifications of, and providing site specific training to, contract radiation protection technicians (RPTs).
The licensee, along with a contractor supervisor, reviews the resumes of contract RPTs before bringing the RPTs onsit Once onsite, contract RPTs attend NGET and take a health physics theory test; the required passing grade is 80 percent for senior RPTs and 70 percent for junior RPT Those RPTs passing the theory test are provided eight to twelve hours of training concerning station radiation protection procedures and practices; the RPTs are tested on the material presented, An instructor in the station 1s training department has developed a training/testing records card for contract RPTs to retain so that theory retesting would not be needed at other CECo stations for one year from a satisfactory test scor At present, there is no formal agreement between CECo stations to honor the training car No violations or deviations were identifie.
External Exposure Control and Dosimetry (IP 83750; 83724)
The inspector reviewed the licensee 1s external exposure control and personal dosimetry programs, including:
changes in facilities,
- equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; 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 1 The external exposure measurement and control program consists of whole body monitoring using thermoluminescent dosimeters, extremity monitoring 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 1 s whole body dose received during 1989 through May 7 was about 770 person-rem; the licensee 1s projected goal for 1989 through May 7, 1989 was about 774 person-re Most of the dose was received during the Unit-2 outage which ended February 1 In addition to the dose discussed above, about nine person-rem was received while performing preparation work for the Radioactive Waste Upgrade Project; the licensee plans to maintain separate records for the upgrade projec The licensee has altered its routine ahd job specific direct radiation monitoring programs to add flexibility and attempt to eliminate performance of unnecessary survey The program now calls for exercise of more judgement when establishing frequency and locations of routine surveys, and frequency of performance of RWP verification survey Also, to reduce surveys, the licensee has ordered several additional portable area radiation monitors (ARMs); the licensee plans to use the ARMs on RWP jobs where the ARMs can be positioned to monitor for changes in exposure rates so that frequency of performance of verifitation surveys by RPTs can be reduce The inspector selectively revfewed survey records, radiation work permits, and dosimetry reports for work being performed during this inspectio No significant problems were note No violations or deviations were identifie.
Internal Exposure Control and Assessment (IP 83750, 83726)
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; 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 licensee 1s program for controlling internal exposures includes use of protective clothing, respirators and equipment, and control of surface
and airborne radioactivit A selected review was made of air sample survey results, radiation work permits, and engineering controls for work performed during this inspectio No significant problems were note Whole body count data was selectively reviewed for counts performed during 1989 through May 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.
Control of Radioactive Materials and Contamination (IP 83750)
The inspector reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; 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 Several contamination control initiatives are discussed in* Inspection Reports No. 50-237/87036; 50-249/8703 Most of these initiatives have been implemente Implementation of these and other initiatives have appareritly resulted in reduced personal contamination incidents (Section 9).
Additional initiative that are in process or planned include relocation of most hot shop work to a new enclosed facility on the main turbine floo Contaminated hot shop tools are being moved from the maintenance shop area, which is outside the main RCA, to inside the RCA; a new tool storage area has not yet been established to house the tools; the tool storage area is planne Another planned initiative is establishment of a small tool decontamination station within the RCA near the Unit-2 trackway RCA egress poin During this inspection, several tours of radiologically controlled areas were made to review radioactive materials handling practice As discussed in past inspection reports,. several unobserved exits from the main RCA to outdoor areas exis Their existence increases the potential for loss of
- control of radioactive material During this inspection, the inspector was informed that in response to a CECo Radioactive Materials Task Group, the licensee is to provide an action plan by September l, 1989, concerning how the potential for release of radioactive materials via these exits will be reduc~ No other potential problems were noted during the inspector tour No violations or deviations were identifie.
Personal Contamination Events (IP 83750)
As previously discussed in Inspection Reports No. 50-237/88009(DRSS);
50-249/8801l(DRSS), early in 1987 the licensee formed a committee composed of several station managers and supervisors to review personal
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contamination events and develop an action plan aimed at reducing the number of such event The comprehensive plan that resulted consisted of more than 50 action item The action items have been completed or are in progres The number of personal contamination events meeting the industry reporting standard was 1,768 in 1986, 874 in 1987, 534 in 1988, and 100 in 1989 through May 21; indicating a significant reduction in events during a two and a half year perio The licensee continues to investigate individual personal contamination events to determine.root cause and continues to seek additional methods to reduce personal contamination event No violations or deviations were identifie.
Audits (IP 83750)
The inspectors reviewed the licensee 1s program for se)f-identification and correction of programmatic weaknesse The program consists of station quality assurance audits and surveillances, corporate audits and assessments, and industry assessment Selectively reviewed were individual audits and assessments, extent of audits and assessments, qualification of auditors/assessors, and adequacy and timeliness of corrective action This was a program revie The inspector reviewed results of station and corporate audits and assessments of the licensee 1s radiation protection program performed since July 198 Several possible improvements were identified during*
- the audits/assessments; none were regulatory violation The licensee 1 s audit/assessment/surveillance program provides good management control tools for self-identification of programmatic weaknesse Corrective actions normally appear adequate and timel 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 May 26, 1989, to discuss the scope of the inspection and the finding The inspectors also discussed the
. likely informational content of the inspection report regarding documents and processes reviewed by the inspector during the inspectio Th licensee identified no such documents/processes_as proprietar