IR 05000237/1992011
| ML17177A492 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/18/1992 |
| From: | Michael Kunowski, Markley A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A491 | List: |
| References | |
| 50-237-92-11, 50-249-92-11, NUDOCS 9206260095 | |
| Download: ML17177A492 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION
. REGION III Reports No. 50-:237 /92011 (DRSS); 50-249/92011-(DRSS}
Docket No ; 50-249 Li~ense~ No~ DPR~19; DPR-25 Licensee:
Commonwealth Edison Company Opus.. West II Opus Place Downers Grove, IL 60515 Facility Name:
Dresden Nuclear Power Station, Units 2*and 3 Inspection At:
Dresden Site, Morris, Illinois Inspection ConducteQ:
May 11 - June.9, 1992*
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Inspectors:
6/;'6/92-Date Approved By: ~~ "/tr/7z-M. c. Schumacher, Chief Date Radiological Controls Section 1 Inspection Suinmary Inspection on Mav 11 - June 9, 1992. (Reports* No. 50-237/92011CDRSSl; 50-249/92011(DRSSll Inspection Summary Areas.Inspected: *Special, announced inspection of radiation protection program (IP' 83750) including audits and appraisals, staffing, training and qualifications, external and internal dose, ALARA, and contamination control Previous inspection findings were also reviewe.
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Results:
The radiation protection program was generally adequate, although dose for*theUnit 3 refueling outage exceeded the goal by about 160 person'.""rem owing principally to emergent work which extended the outage from 10 to 30 week Good ALARA performance was noted-for control rod drive maintenance and for disposal of 225 drums of old solidified radwaste (Section 6). *
However, a somewhat lax attitude toward radiological controls and ALARA was noted on an operator round and surveillance (Section
8).
Attitude problems were also suggested in recurrent ho_usekeeping probl~ms (S~qticm.9) !*,
A.. non"".'c;it~d.violation for failure ~o follow a procedure for posting a contaminated area wa identified by the inspector (Section Sa).
P9D2R06260095 920619 O
ADOCK 05000237 PDR
DETAILS 1~
Persons Contacted
@*D. F. Ambler, Health Physics Services Supervisor
- E. w. Carroll, Regulatory Assurance
- K. Deck, onsite Nuclear Safety
- L~ Gerner, Technical Superintendent
- J. M. Kotowski, Production Superintendent
- M. Lesniak, Health Physics Supervisor {Corporate)
- T. J. O'Connor; Assistant superintendent of Maintenance
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- L. L. Oshier, Lead Health Physicist, Operations Grou * W~ Schroeder, Station Manager
- R. W. Stobert, Operating Engineer
- R. c. Winslo~, Lead Health Physicist, ~ec~nical Grotip The inspectors also contacted other licensee personne *Denotes those present* at the exit.meeting on May 18~
199 @Denotes those contacted by telephone on June 9, 1992.
. General This.was part of an ongoing special inspection of the Dresden* radiation protection {RP} program in an attempt to better understand the reasons for what appear*to be persistent performance weaknesses in that progra It being performed by a radiation specialist temporarily.assigned to the station together with the assigned regional radiatio specialis The inspection is concentrating 6n observation of ongoing work in the radiologically controlled area (RCA},**
interviews with personnel, and independent measurements, in addition to the.normal core inspection_ progra.. Previously Identifi~d Inspection Finding' CIP 83750) (Closed) Non-cited Violation No. 50-237/91022-05 CDRSSl:
This violation involved an inadequate procedure for transferring resin from the fuel pool demineralizer and backf lushing after the transfer; The.
procedure was revised.* to include specific direction to operations personnel to ensure the deminerali.zer was adequately vented prior to backflushih (Closed) Violation No~ 50-237/91039-
.o.la(.DRSS) i-.5,a..,.24.9/91043~01a.(DRSS).and No.. 50..,.
237/91039-0lbCDRSS); 50-249/91043-0lb(DRSS):
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o oR This violation involved an instance of a worker jogging during his lunch hour in the reactor building RCA and an instance of several workers who moved fuel while signed in on the wrong radiation work per-mit (RWP).
- Appropriate corrective actions were take.
. (Closed) Viol~tion No. 50-249/91033-0la CDRSS):
This violation involved the failure to perform pre-job ALARA briefings as prescribed by a. station procedur Th procedure was revised to remove an overly restrictive requirement regarding the briefings. It now allows flexibility in conducting briefings while ensuring that the radiological safety concerns, are
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appropriately addresse (Closed) Violation No. 50-249/91033-0lbCDRSSl:
This violation involved the failure to provide current survey records to workers as prescribed by a station procedur RP personnel were counselled on the need to provide current records and the procedure was
. revised to emphasize discussion of. survey data during the pre-job ALARA briefin (Closed) Violation No. 50-249/91033-02a CDRSS):
This violation involved the f ailµre to adequately evaluate the change in dose caused by a *change in the physical position of two worke~s. RP personnel were counseled on the need to evaluate th possible change in dose caused.* by changes in worker physical position in areas where high dose gradients exis * (Closed) Violation N ~249/91033-
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02bCDRSS):
This violation involved the failure to survey the inner surface~ of a double-disc gate valv RP personnel were * counseled on the need to ensure that surveys are conducted when. components are disassemble In addition, a special training session.on valves was provided to the RP technicians during ~heir recent continuing training session (Closed) Violation No. 50-249/91033-02cCDRSSl:
This violation involved the failure-to adequately.reevaluate the possible doses.to workers when actual inspection
h~ activities differed from those anticipated by RP personne RP personnel were counseled on the need to stop work if workers deviate significantly from anticipated work activitie In addition, station.workers were reminded of the necessity of adhering to
~lanned work activities to avoid: unnecessary
-_exposure..
(Closed) Violation No. 50-249/91033-
-02dCDRSS):
This violation involved the failure to reevaluate airborne radioactivity when actual inspection activities differed from those anticipated by RP personne As with the violation discussed in Section 3~e.,
RP personnel _were counseled on.the need.to re-evaluate radiological conditions when the work performed differed from.the planned wor (Closed) Violation No. 50-249/91033-03CDRSS):
This violation involved the failure to supply monitoring equipment to worker The RP personnel involved.were counseled, and enhanced training on dosimeter placement and the_ use of muitiple dosimeters was provided to all RP technicians during re-cent continuing training session.
Audits and Appraisals CIP 83750)
The inspector's review of recent Radiological Occurrence Reports (RORs), which are written to document radiation protection problems and associated corrective acitions, indicated the need for ~dditional-
- management attention. Although corrective actions were promptly.taken for most RORs, several written in 1992 involving relatively simple corrective actions were still open after two to four, months, compared to a one-month closure period recommended by station procedur Another ROR written for improper use of a portable ventilation unit had been closed and the schedule for corrective action had not been me The inspector also noted that four RORs were written over th_e past several months for contaminated equipment found outside the RC Licensee representatives acknowledged the need for again reminding station personnel regarding contaminated equipment cqntrol They also indicated that the completion of the recent refueling outage should allow
.more management. time for the -ROR program and stated that.the planned adqption of the "Integrated Reporting-Program"
should improve the documentation and resolution of radiological occurrence This program, which is in use at several other Commonwealth Edison stations, replaces several different event and problem reporting/tracking systems an is intended to provide for consistent trending, root cause determination; and corrective action implementatio The effectiveness of the program.will be reviewed d\\lring *
future inspections. *
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The inspector reviewed surveillances (termed*"Field *
Monitoring Reports") by the Nuclear Quality Programs (NQP) group of various radiation protection activities and* accompanied** ari NQP *. auditor during a review* of solidification of Unit 1 chemical decontamination wast These activities were performance based an done by experienced individual The waste solidification project itself was progressinq well. and:
was about 60% complet A problem* with a project procedure was identified by the inspector and the NQP auditor and was promptly addressed by station_
managemen The inspector also noted effective actlon by the plant manager when he observed during a tour on May 9, *1992, that two station maintenance wor~ers were engaging in poor work practices, including poor control of equipment at a*
contaminated area boundary; use of a radio (broadcasting a sporting event), and improper wearing of protective
clothin Prompt measures were taken to correct the minor contamination caused by the workers and to discipline the No violations of NRC requirements were identified by the inspecto.
Management Controls, Training. and Qualifications CIPs 83729 and 83750)
The inspector reviewed management controls, training, and qualifications related to administration of the Dresden RP program including: organization, staff*ing, designation of authority, and evaluation of contract RP technician experienc Organization and Management Controls The RP organization remains essentially as described in recent inspection reports. Recent personnel changes included: appointment of an individual with RP technician (RPT) and RP supervisory experience as the new ALARA coordinator, promotion of an RPT to a training department position., and_ addition of. two consultants to assist with ALARA program and procedure
- consultants to assist with ALA.RA program and procedure upgrade Another consultant who was involved with procedure writing and contract RPT oversight for outage drywell work recently left Dresden for another assignmen No problems were noted with the experience of the involved individual The corporate RP liaison for Dresden Station has been
.spending about four days p~r week at the station to evaluate the status of previously made commitments to the various audits groups.in the RP area. The inspector also reviewed the organizational support for-the many*
RP improvements being tracked under the Dresden Man~gement Action Plan (DMAP) progra staff Training and Qualifications The inspector reviewed t~alning and qualifications of the licensee's* RP management personne The training department records appeared to be comprehensiv They consisted of records of training from other CECo stations as well as Dresde By contrast) it was difficult to ascertairt the relevant experience of incumbents in radiation protection positions owing to the apparent lack of experience r~cprds at the statio The training department files did not detaii experience acquired since joining CECo and.attempts to obtain this information via Radiation Protection from Industrial Relations arid the office manager were unsuccessfu The licensee stated tha documentation of incumbents* qualifications would b made availabl These will be reviewed in a future inspectio (Inspection Follow-up Item No. 50.:_
237/92011~01(DRSS); 50-249/92011~01(DRSS)). Contract RPT Training and Qualifications
. The inspector reviewed qualification records of *
contract RPTs (CRPTs) who* worked the just completed Unit 3.refueling outage.* Generally, they met requirements of the applicable ANSI standard (NlB.1-1971) and there was evidence of conscientious licensee effort to evaluate. and verify contractor resumes~
One CRPT supervisor's experience appeared not to meet the ANSI qualifications but reevaluation by the licensee based on ~dditional information obtained from the individual indicated the contractor-provided resume had somewhat understated his experienc Moreover, the licensee indicated-that the --ind-i v-idual had'- performed *
acceptably as a supervisor during the outag The
inspector noted that the* corporate guidance for awarding RP experience credi.t (NSRP Guidance 1700-1)
allowed a lot of leeway for individual judgement in deciding how much credit to give for work such as laundry monitorin.
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Another weakness in NSRP 1700-1 wa~ that it allows experience credit for certain related.technical training programs without regard to which ANSI standard on staffing and qualifications applies to a statio This would be acceptable for.stations.committed to ANSI 3.1-1978, but not for a station bound to N18.l-1971
such as Dresde Unwarranted awarding of experience credit did not affect the quaiifications.of any of the individuals reviewed but it was noted on several *
resume station requirements and guidance for CRPT training are given in Training Department Instruction TDI-70 CRPTs must complete nuclear general employee training (NGET), a health physics theory examination, and
Dresden RP and administrative procedures training and examinatio Failure to pass (80%) results iri an evaluation by the Support Services Group Leader and the HP Support Supervisor and possibly counseling and *
another opportunity to qualif A weakness in TDI-705 is that it does not provide guidance for this practic The inspector also noted that neither the theory nor the procedure examination appeared very challengin The licensee's program does not appea~ to test a
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candidate's ability to perform specific required task No violations of NRC requirements were identifie One inspection follow-up item was identifie * * External Exposure Control Including ALARA Considerations CIP 83750)
- on April 25, 1992, the licensee completed the Unit 3, *
12th refueling outage. *It began on September 8, 1991, and was originally scheduled for approximately 10 weeks, but.because of various maintenance and operational problems was extended to about 30 week The dose total for the outage was approximately 562 person~rem, compared to a.pre-outage estimate of 400 person-re Most of the additional dose was.due to emergent work and, except for previously noted problems with work. ori a recirculation pump discharge valve*
(Inspection Report No. 50-249/91033(DRSS)), exposure*
co~trol was adequate overall.. Notably, the rework of 28. control rod drives *(CRDs) went *well with the use of specialli designed transfer carts, flange shi~lds, and 7*
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removal tool*
The accrued dose was 0.178 person-rem
- .per CRD compared to 0.238 person-rem per CRD in the previous outag Good control of the assessment and shipment of 225 drums of radioactive waste (radwaste) that had been stored* onsite for over five years resulted in
approximately 5.35 person-rem, compared to.a pre-job estimate of 39.5 person-rem, and a mid~job revised estimate of 16.9 person-re The significant dose savings was attributed to the use of a robot, remote video cameras, a dedicated work group (including an*
JU>T, a radwaste group supervisor, and an ALARA analyst), and minimal need for repackagi"ng the drum In addition, the job, which was unique, also proved to be simpler than originally expecte The inspector also reviewed the actions regarding a licensee-identified problem with radiation worker termination exposure reports (Inspection Reports N /92002(DRSS); 50-237/92007(DRSS); 50-249/920b7(DRSS)).
Because of a software error, 98 termination letters issued recently did not include all of the thermoluminescent dosimeters worn by the worker According to the licensee, the software was revised and corrected versions of the termination letters were mailed in early Ma No violations.of NRC requirements were identified.* Internal E~pos~re Co~t~ol (IP 83750)
The inspector reviewed the licensee's internal exposure control and assessment programs~ including: changes to facilities, equipment, and procedures affecting exposure control and assessment; determination whether respiratory equipment and assessment of inc;ii vidual intakes met regulatory requirements; required records, reports, and
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notific~tions; effectiveness of ~anagement techniques*used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesse No major problems were identifie Selected results of the review are discussed belo a..
Internal Exposures and Whole Body Counting Several minor intakes of radioactive material occurred during the past yea The most significant involved a fuel handler removing control* rod blades from storage locations in the spent fuel pool on April 28, 199 This work**invo'lved attaching a-~'grapple-0 to the.blade and removing it using the refueling bridge cran On one
occasion, a blade stuck in its storage bin prompting the fuel handler to attempt to free it by pushing and pulling on the cable attached to the grappl This resulted in contamination of the fuel handler's face and protective and personal. clothing and an apparent intake of a few percent Qf regulatory limits.* It is
- not clear that the worker's actions in trying to free the blade were consistent with the governing RW The RPM assigned a health physicist to review this even The results of that review will be examined during a future inspectio The inspector also reviewed records for the whole body counter The review indicated that calibrations appeared to have been performed appropriately and within the scheduled calibration period '
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' Respiratory Protection and Air Sampling The inspector also reviewed the licensee's criteria for
.selection of respiratory equipment, as discussed in*
procedure DRP 1620-03, "Guidelines for Basic Protective Clothing and Respiratory Protection." It requires the use of respirators when dry, fine, easily dispersible particles exist at levels greater than 22,000 dpm/100 squared centimeters,. when contamination exists above so,ooo dpm/100 squared centimeters until air sample results are evaluated, and whenever welding, flamecutting, grinding, or heating is done on radioactive materia The inspector interviewed several RP supervisors to *.
determine their understanding of respiratory ~rotection procedural requirements, discretion allowed, and practical implementation of sam Ali individuals had a consistent understanding.of the procedure and indicated that work activities and conditions were evaluated in 'determining respiratory requirement The inspector also questioned the technical basis for requiring the use of respirators at the contamination revels mentioned above and. expressed concern regarding possible ov~r~reliance on respirators rather than engineering control The licensee indicated that that information was not immediately available, but agreed to obtain it. This information will be reviewed during a future inspection (Inspection Follow-up Item No. so-237 /92011-02 (DRSS);
50-249/92011~02(DRSS)).
The inspector also reviewed lower limit of detection calculations for the GeLi and the Tennelec counting systems"for several samples*of containment atmosphere and general area air sample Results of these lower
limit of detection calculations indicated no problems with counting methodolog No violations.; of NRC requirements were identifie One inspection foilow-up item was identifie.
Control* of Radioactive Material CIP 83750)
The inspector reviewed.the licensee's program *for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calipration 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 radioactivity and contaminated material* controls~ *
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Selected results of the review are discussed belo Posting of Radiologically Controlled Areas During several tours of the reactor and turbine buildings on June 4-6, 1992, the inspector rioted approximately 10 contaminated areas where. "floor and equipment contaminated" signs were not posted to* warn personnel entering from al~ directions, as required by
- station procedure DRP 1160~3, "Radiological Signs,
Labels, Signals and Controls."
In this ihstance, signs were not ~osted at the step-off pad side bf the areas~
These problems were identified to the licensee and corrective actions were take According to the.*
licensee, no personnel became contaminated because of, the lack of the sign The failure* to follow the
procedure is a violation of Technical Specification 6.2.B which requires that radiation control procedures be maintained, made available to all station personnel, and adhered to'; however, as allowed by the criteria *
specified in Section VII.B. (1) of 10 CFR Part 2, Appendix C, a Notice of Violation will not be issue Other areas with confusing postings were noted during tours, and iri consideration with the contaminated area posting violation indicated a need for greater management attentio * Observation of Operator Rounds and Surveillances The inspector accompariied an operator* performing routine rounds and a surveillance that involved access to the Unit 2 torus catwalk area and basemen During the operator rounds, no problems were encountere The licensee's-- control* of contamination was such that there was no time during the rounds in which the operator had
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to get dressed in protective clothing to perform his dutie During the surveillance, however, several
- weaknesses were noted *.
Although the applicable RWP allowed access to high radiatiol') areas* (HRAs,) and tbe survey *of. the torus area to be entered indicated dose rates up to 150 millirem/hour, RP personnel* issuing.the HRA key and electronic dosimeters (EDs) did not reset *the EDs to alarm at a dose rate appropriate to* the area; instead, the EDs were left at the original alarm setting of 20 millirem/hou The operator did not question the appropriateness of.the ED.*
- alarm settin * *
When the ED high dose rate alarm sounded during the surveillance alorig the catwalk, the operator continued workin When questioned.bY the inspector, the operator indicated.that he should back away from the high dos.e rate area, but that it would be acceptable to finish the wor *
The operator did not bag his belt, radio, or flashlight upon exiting the.* contaminated area after the surveillance Wa$ complete Instead he carried this equipment in his bare hands to the frisker station where he
surveyed himself and the equipmen When questioned as to the proper method of removing materials from a contaminated area,
- the.operator responded that technically.th materials should have been bagged, but that since this was a. low contamination area, this.
was an*acceptable practic~.
The inspectors will make additional observations of radiation worker performance during future inspe6tions~
No violations of NRC requirements were identifie.
Plant Tours CIP 83750)*
The inspector perf orined several tours of the RCA including the reactor building, turbine building, radwaste.facilities and spent fuel pool facilitie The inspector made the following observation *
Contamination monitoring, portable survey, and area radiation monitoring instrumentation in use throughout the plant had been recently source checked and had appropriata current calibrations:* *
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The posting proble~s discussed in Section 8~
Housekeeping and material conditions were generally good but problems with accumulations of tools, trash and other materials were noted on.turbine building*
levels 561' and abov These were identified to the licensee*but the same-problems were seen again on th four subsequent days. Housekeeping problems have been discussed previous inspection reports.*
Independent dose rate measurements taken by the inspector agreed with li~ensee posting No violations of NRC requirements were -identified..
1 Exit Meeting The scope and findings of the inspection were discussed with licensee representatives (denoted in Section 1) on May 18, 199 Specifically, the inspector discussed RORs (Section 4), the difficulty in locating personnel qualification rec:ords (Section 5.b.), improved Ai.ARA
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for CRD work during the.outage (Section 6), the absence of~ technical basis for respirator use (Section 7~b.),
and observations of poor housekeeping in the t~rbine buildings (Section 9).
The licensee acknowledged the inspector's comments and stated that efforts were underway to speed the disposition of ROR No likely inspection report material was identified as proprietar The licensee was informed ori ~u~e 8, 1992, of a non-cite violation fo~ failure to follow a posting prpcedure (Sectioh 8.a.).
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