IR 05000237/1990012
| ML17202L225 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/27/1990 |
| From: | Michael Kunowski, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202L224 | List: |
| References | |
| 50-237-90-12, 50-249-90-11, NUDOCS 9005080105 | |
| Download: ML17202L225 (7) | |
Text
U.S NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/90012(DRSS); 50-249/900ll(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:
Mar~h 21 through April 10, 1990 Inspectors:
11.A. /'~.
M. A. Kunowsk1
_
Radiation Specialist-*
t'.!f k~- {f1 R. A. Paul
.
...
- senior Radiation Specialist Approved By:
LY. £. <;tz~'-v M. C. Schumache~
Radiological Controls and Chemistry Section Inspection.Summary
/?eY'1) -<7 i Pye; Date
.
Ins ecti6n on March.27 throu h A ril 10 1990 (Re arts No. 50-237/90012(DRSS)**
50-249 90011 DRSS Areas-- Inspected,i? Rou_tj ne;-, unannounced inspect ion of the radiation protection program (insp:e_ctfori,P:r0:¢edure (IP) 83750) including audits and appraisals;
- changes'.'-.f~,p-efsc;>nner*;;_and: training and qualifications of new personnel; externa L a*.nq?t'nte.rnaT exposure contro 1 s including ALARA considerations; and. contror;.*c)y~,_radfoactive materials-and contamination (IP 83726). *
Results: -Overa-fl\\,the. r*adiation protection program is adequat Material cond1t1on improvements in Unit 2 and Unit 3 are continufng, and.the number of personal contaminations in 1989 was lo However, several exposures exceeding administrative limits and an unexpected 7 Rem extremity exposure suggest weak prejob dose evaluation In addition, an Unresblved IteITT (Section 7) was identified for the inadvertent release of contaminated equipment from the sit *
9005080105 900427 PDR ADOCK 05000237 Q
- DETAILS Persons Contacted G.. Bergan, Nuclear Safety
+R. Burns, Training Department, Lead Instructor, Support Services
+E. D. Eenigenburg, Station Manager
+R. Falbo, Regulatory Assurance Assistant
+L. F. Gerner, Technical Superintendent L. Jordan, Group Leader, Technical, Health Physics Services
+K. Kociuba, Nuclear Quality Programs (NQP) Superintendent
- R. Lee, ALARA Co~rdinator D. Marco, G~neral Training Instructor L. Oshier, Group Leader, Operations/ALARA,. Health *Physi.cs* Services
+K. W. Peterman, Regulatory Assurance Supervisor.
@+D. Saccomando, Health Physics Services Supervisor
+J. Schrage, Nuclear Servi~es Radiation Protection
+K. Yates, Nuclear Safety*
.S. DuPont, NRC Senior Resident Inspector D. Hills, NRC Resident Inspector
+Denotes those present at the exit meeting on April 4, 1990.
@Present at telephone c9nference_on April 10, 199 The inspectors al$O ~6ntacted other licensee and contractor personne~~ General *This inspection was conducted to review the licensee's operational.
radiation protection progra The inspectors reviewed records, interviewed personne 1, and toured facilitie Dose rate and cont_amj nation surveys were also c.onduct,e Audits and Appraisals (IP 83750)
The inspectors reviewed reports of several major audits conducted since the previous NRC radiation protection inspection in May 1989 (Inspection Repor~
.-.N9.~,:, SQr 2~~i~9015(DRSS); 50-249/89014( DRSS)).
The au di ts were
,* in~de.P,,~.~!,~}.'a*~g(jod! mix of programmatic and performance-based review
- activfti:S$'~\\.The~*.~re conducted by the ons i te NQP group, the corporate radi a~jri~.fir-ptec_tJQli performance assessment group, and a major industry group~:J).::~~$*~.~~1~?;*[~~F,:; :
The audits-*noted several program str*engths including the station's personal contamination reduction efforts and the quality of the ALARA plan developed for the the Radwaste Upgrade Projec Significant findings included friskers rendered essentially useless for personal contamination surveying in several plant areas because of high background radiation levels, the large volume of low-level contaminated material stored onsite, and several inadequate pre-job and post-job ALARA review The station
- respons~s to audit findings were generally adequate, but observations by the inspectors during this inspection (Section 5) indicated the need for additional*i~provements in pre-job dose evaluation The inspe'ctors ar~o reviewed the licensee's radiological occurrence reports (RORs.) to determine if programmatic problems exist and *if deficiencies were promptly and adequately correcte The.first revisio~
of the ROR program procedure has been developed by the corporate Nuclear Safety group and will be initiated soo According to licensee representatives, the revision will enhance the ROR program.. The procedure will be reviewed during a future inspectio The inspectors reviewed RORs generated from July 1989 to March.199 buring this period, the licensee identified about fifteen incidents involving contamination controls, six incidents concerning high radiation area (HRA) controls, and several others involving administrative and exposure control problem~. Of the RORs reviewed, an inordinately high number wer~ the res~lt of individuals not following radiation protection procedures or good health physics practice Although the RORs were generally well investigated and timely, and adequate corrective actions were *usually taken, more management attention is required to ensure that the corrective actions for RORs involving exposure control and procedural violations are sufficiently strong to prevent recur_renc :In addition, as mentioned above, several RORs concerned HRA control**
problems, ~uch as missing HRA keys, and unsecured, unattended, or broken HRA door Although corrective actions were taken for each individual
- event, stronger actions will be necessary if these problems continu This matter was discussed at th~ exit meeting and will be reviewed during a future inspection.(Open Item No 50-237/90012-0l(DRSS);
50-249/90011-0l(DRSS)).
No violafions of NRC requirements were identifi.ed by the.inspector Personnel and Trainin ualifications of New Personnel The inspectors reviewed major personnel changes and the training and qualifications of new personne No problems were identifie An experi~n~ed.-staff health physicist is on maternity leave and is not
expect~d;*to return., A licensee representative stated that her position would: be.* filled-., Partially in response to audit findings, discussed above; a: new *. A~RA Coordinator and an A LARA engineering assistant were
.*selected~:~. Dis~u~sions with these individuals and a review of some of their work' indicated that they are knowledgeable, have extensive experience in nuclear power, particularly at Dresden, and are enthusiastic about their new position With strong stati-0n upper management support, the new ALARA staff should greatly improve the ALARA progra In
.
addition, an individual with a Master of Science degree in Health Physics was added to the radiation protection staff, and an individual with an engineering degree and experience as a radiation protection technician
- at Dresden;and as a quality assurance inspector at LaSalle was appointed supervi sgr** of the quality assurance group at Dresde These re.cent appointments. should enhance the radiation protection progra No ~iol~ttons of NRC reqtiirements were i~entified.*
5.. External Exposure C6ntrol, including ALARA Considerations (IP 83750)
Station dose total for 1989, with contribution from.two refueling outages and the Radwaste Upgrade project, was 11j9 person-re~. The dose t~tal in 1988 was 1407 person-re Licensee representat.i ves stated the exposures in 1989 and 1990, to date, were within regulatory limit However, licensee records indicated three whole body exposures above administrative limits and' one significantly higher (7 Rem) than expected extremity exposure occurred between December 1989 and February 199 All were incurred during repair work on the Unit 2 cleanup heat exchanger system and involved *elevated general area dose.rates and 1oca1 i zed hotspots or 1 arge dose* rate gradient A 1 though identified by licensee audits and reviews (Section*3), the inspectors'
review ~nd discussion of these events indicated persisting weaknesses in pre-job dose evaluations that merit additional licensee* attention.. This
- matter was discussed at the exit interview and licensee followup will ba reviewed in subsequent inspections (Open Item N /90012-02(DRSS)~
50~249/90011-02(DRSS)).
The inspectors conducted independent exposure surveys throughout the facilitie~. Observed measurements were in agreement with postings an i censee survey data, and hi-gh radiation areas were 1 ocked as require The licensee recently implemented a hot spot tracking program and a gene~al access exposure level reduction progra Discussions wit licensee representatives and observations in the plant indicated that
- .generally these programs were being effectively implemented; however, the inspectors observed several sections of the fuel pool cooling lines with affixed work* request tags dating from January through March 1989, an measured elevated dose rates in the general areas adjacent to these line The work request tags were for installation.of temporary shielding and installation of a connection for hydrolazing equipmen Discussions with licensee representatives indicated that shielding had not been installed becaus~ it would' probably be inplace for longer than the 6-month limit*
that the'-.:stati'on~*s;tech staff had.set for temporary shieldin The delay for i nst~llat.fon. of *the hydro 1 azi ng connect ion was attributed to the 1 ack
- of welder~-*c.er.tified' to weld on the aluminum pipe of the cooling line Additional~- timely management attention to reduce exposure from these 1 i nes is. needed*~..
No violations of NRC requirements were identifie :*
Internal Exposure Control and Assessment (IP 83750)
The inspectors reviewed selected aspects of the licensee's internal exposure control and assessment programs, including:
determination
whether engineering controls, respiratory equipment, and assessment of intakes meet regulatory requirements, and planning and preparation for maintenance tasks including ALARA consideration Air sample data ~ere selectively reviewe Air samples appear to be taken, counted, and evaluated in accordance with procedural requirement The pr,ocedures.appear adequate for use 1n determining air samp 1 e results, and type and placement of air sampler Special air ~amples are collected t6 establish RWP requirements and job conditions, and it appears the licensee* adequately uses air sample results to establish requirements for use of respirators and protective clothin The licensee uses a commercial standup whole body counter as the primary instrument to measure radioactive intakes and a commercial laydown system as back-up. * The inspectors selectively reviewed the 1 icensee' s whole body count (WBC) procedures, the WBC facility and equipment, and discussed the program with health physics (HP) personne The inspectors alsa reviewed the results of the calibration performed on the counters by the vendor ir June *1989; no prob l em_s were i dent i fi e The inspectors requested a member of the HP staff to use Procedure DRP 1340-5, *Revision 2, "Calculation of MPC-Hours (Maximum Permissible
"
Concentration-Hours) and Organ Dose Based on Whole Body Count Data.. from Acute Uptakes, 11 to conve~t WBC data to MPC-hour~ from an example given by the inspectors;. tbe r*esults of the staff 1 s conversion was correc A review of WBC results for 1989 through February 1990 indicated no intakes in excess of the 40-hour contra 1 measure.*
Se 1 ected aspects of t_he 1 i censee.' s respiratory program were reviewe To ensure that bnly ~ualified ~orkers receive respirators, worke~s'
~uthorization information include respirator qualification~, proof of
~equired traintng, an~ expiration dat Provisions ara made during the i.ssuance*.and return cycle for MPC-hour accountabilit The respiratory program appears adequat No violations of NRC requirements were identifie.
Control of Radioactive Materials and Contamination (IP 83750 and 83726)
- .. The*.ins~e~t~~};~~:;\\wed the licensee's program for control of radioactive materfals~~*~uid ;.i:ontami nation including:
adequacy of supply, maintenance, and'*c-~.l~ib.fati,O'l"li'ofJ:contamination, survey, and monitoring equipment; adeqi.ia6y':.'9f.-*rev*iew}and dissemination of survey data; and effectiveness of method.s* *af*.control of *radioactive and contaminated materi a 1 Several contamination control initiatives have been implemented since the previous *NRC HP inspection (Inspection Reports No. 50-237/89015(DRSS);
50-249/89014(DRSS)) which include, relocation of routine hot shop work to the radiologically controlled area (RCA), establishment of a tool storage area on the Dl and D2/3 turbine decks, and establishment of a tool decontamination station within the RC These areas were visited;
- \\
A no proble!ll.S w~th design or use were note The licensee's continuing initiati.ves-t!b control contamination and maintain the cleanliness of the operating~'st.ation appear effectiv The number of personal contamination events has been reduced_ from* 1, 786 in 1986 to 215 in 1989; of 40.smears taken at different locations by the inspectors, non~ was above 100 cpm/100 cm2:
The inspectors selectively r.eviewed the licensee 1's investigation of pers~nal contamination events (PCEs) and hot particl~'events. N overexposures have occurred as a result of these events.. The inspectors reviewed the licensee's investigation and dose calculational methods; no problems were not~d. The licensee investigates each PCE; the investigation
. includes interviews with the individual and a review of related work activitie For each hot particle event, a skin dose assessment is also performe The licensee was requested by the inspectors.to compute skin dose for some hypothetical hot particle i~cidents using different radioisotopes at ~ skin depth of 7 mg/cm2 averaged over 1 cm2 at varying shielding thicknesse Licensee and NRC calculations were in good agreemen The inspectors reviewed monitor alarm setpoint methodology, and-functional tests and calibration procedures for the RCA exit friskers (PCM-lBs} and the gatehouse poftal monitor The required tests and calibrations appeared to have been performed in accord~nce with the applicable procedure The PCM-lBs are set to alarm at a nominal 5000 dpm/100~cm2.;*
(i.e., 2.5 nanocuries); operational source checks are made using* **
nominal 4-nanocurie cobalt-60 sourc A more appropriate check source would be in the range of 2.5 nanoc~ries, the point at which the ~Ait is set to alar This was discussed with a licensee representative who stated that the source and the procedure would be changed accordingl The inspectors also reviewed the circumstances of an incident where Dresden inadvertently shipped contaminated equipment as.noncontaminated equipment to the Braidwood statio In February 1990, four drums of supposedly uncontaminated scaffold connectors (knuckles) were sent by Dresden to Braidwoo Personnel at Braidwood who were sorting the knuckles found four knuckles labeled as radioactive materia A subsequent survey by Braidwood HPs determined that they. were not contaminated, but contamination was found on two other knuckle *One had 50000 dpm fixed and 2000 dpm smearable contamination; the other had 5000, apm,dtxed. an.ct'-1000 dpm smear ab 1 e contamination.* *The contamj nation o botMknyc~~"es wa$:'.limited to an approximately 25 cm2 area on an inner sur-t~C:e~f;The:.remaHting knuckles, the drums, and the.wor~ers who did the sorting; wer:e,sµrv~ed and found to be free of contaminatio Dresden's i flVest:fQ~tiojJ;,~~~~".P.li ned that the drums had been surveyed prior to rel ease fronfo**s9~n,#-~u,t:.. 'fne knuckles had no The failure to survey the knuckles is contrary to Procedure DRP 1480-1, Revision 8, "Contamination Surveys.
In addition, the failure to remove the radioactive material warning labels from the non-contaminated knuckles is contrary to Procedure DRP 1160-3, Revision 4, "Radiological Signs, Labels, Signals and Controls. This problem will be tracked as an Unresolved Item pending further NRC review (No. 50-237/90012-03(DRSS); 50-249/90011-03(DRSS).
One Unresolved Item was identifie.
Station Exit Controls (IP 83726)
During this ana* other NRC HP inspections, it has been observed that whi 1 e there are many 1 ocat iOns where final pers_ona 1 contamination surveys can be performed before exit to the gatehouse, under normal conditions only one location has a radiological control station (the Unit 2 trackway)
which is m~nned only during the day shif The other.exit locations are equipped with whole body frisker booths and do not have.HP technicians in attendanc During major outages,.the Unit 2 station i~ manned only during*the day and afternoon shifts, and the Unit 3 trackway exit is manned during all three shift Exit locations which are not manned do not provide as good a quality personal contamination and equipment
- control as those which are manned.* Although the licensee has recently*
reduced the number of exit lotatioris at the station it appears there remains a disproportionately l~rge nu~ber of these locations compared to other Region III nuclear plant This practice could lead to degradation
. of the 1icensee 1 s contami nati o.n contro 1 program if significant numbers of personnel are allowed to exit the controlled area via the other locations~
This matter was discussed *with the.health physics sup*ervisor and.will be reviewed in future inspection No violations df NRC requirements were identifie.
E~it Meet~ng'(1P 30703)
The inspectors met with the individu~ls, denoted in Section 1, at the conclusion of the ohsite inspection, and summarized the tentative finding S~ecifically, the inspectors discussed the *incident involving the* contaminated knuckles (Sect ion 7); the good quality *of severa 1 recent audits and reviews (Section 3); the concern about the nature of several
~ORs and the effectiveness of licensee corrective actions (Section 3);
the noticeable improvements in plant material condition and contamination control (Section 7); the concern about administrative overexposures; and*
the timeliness of action regarding the. relatively high rates from the fuel pool cooling lines (Section 5).
In response to inspector questions, the licensee stated that the entire Unit 1 containment was controlled as a HRA becaus_e required access was minimal and the costs of erecting adequat~.HRA b~rriers throughout containment cbuld be prohibitiv The',Y--~ls~<.>st~ted... t.hat protective clothing was required for contamination
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On Apri.]; 10>;* 1990", the inspectors informed* a 1 i censee representative (denoted* i IT-SeGtforr 1) that the -7-Rem extremity exposure and the administrative overexposures represented a weakness in pre-job dose evaluations and that a written reply would be requested describing the actions taken to improve job plannin The inspectors also discussed the status of efforts to reduce the number of exits from the RCA and the extent of HP coverage at.these points (Section 8). * The licensee acknowledged the findings and did not identify any inspection material or information as proprietar