IR 05000237/1992016
| ML17177A544 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 07/21/1992 |
| From: | Januska A, Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A543 | List: |
| References | |
| 50-237-92-16, 50-249-92-16, NUDOCS 9207280290 | |
| Download: ML17177A544 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Reports No~ 50-237/92016(DRSS); 50-249/92016(DRSS)
Docket.. No$. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company 1400 Opus Place Downers Grove, IL 60515 Facility ~ame: Dresden Nuclear Gerierating Station, Units 2 and 3 Inspection Ati Dresden*Site, Morris, Illinots Inspection Conducted:
June 16 - 22, 1992
./?1~
Inspectors:*
M. A.:Kunowski.
.-m~r-.
A. G. Januska
.. * :
.-7/1,~
- Approved By:
M. C. Schumacher, Chief Radiological Cont~ols Section 1 In~pettion summary.
7"'.'"21-;72-.
Date*
7-.2./-~ 2--
Date Date Inspection on June 16 - 22, 1992 (Report Nos. 50-237/92016CDRSS); 50-
,
249/92016(DRSS))
Areas Inspected:
Routine announced irispection of the liquid and gaseous radioactive waste program (Inspection Proced~re (IP) 84750).
The inspectors also measured dose rates around a radioactive waste shipment (IP 86750),
reviewed an administrative overexposure from work on a spent resin liner (IP 83750), and reviewed licensee Event Reports (LER~).
Results:
Liquid and gaseous radioactive waste programs were adequate;
. effluents and resulting doses had detreased. Weaknesses wer~ noted. with the operability of th~ service water radiation monitcirs (Section 7) and with the administrative overexposure resulting from a worker's failure to heed ~he dose rate alarm from his electronic dosimeter (Section 8).
Two non-cited violations wer.e identified during review of LERs (Section 2). *
9207280290 920721
~DR AD_OCK 050.0023 PDR
- DETAILS Persons Contacted
- T. Bennett, Radwaste Coordinator
- S. Berg, Assistant to the Production Superintendent
- E. Carroll, Regulatory Assurance
M. Gagnon, Health Physicist
- K. Kociuba, NQP Superintendent
- L. Oshier, Lead Health Physicist-Operations
- R. Radtke, Regulatory Assurance Supervisor
- D. Saccomando, Nuclear Litensing
- C. Schroeder, Station Manager R. Stobert, Operating Engineer
- A. Markley, Resident Inspector, NRC
- Present at the Exit Meeting on June 22, 199 The inspectors also spoke with other licensee employee.
Lice~see Event Report Followup (IP 84750) *
(Closed) LER 91-03, Unit 2:
"O~ission of Liquid Radwaste Dis~harge Composite Analysis Due to Management Deficiency."
On Febr~ary 1, 1991.,
the licensee determined that the composite liquid discha~ge sample for September 2 to October *3, 1990, had been discarded before required analyses were performe Technical Specification (T/S) 4.8.3. requires monthly analysis for gross alpha and quarterly analysis for Fe-55, Sr-89, and Sr-9 Data for similar samples for* August and* October 1990, were within expected ranges, as were the gamma isotopic and tritium data for the September 2 to October 3 period. This suggested that the
activity of the discarded sample was also within expected value Corrective actions included revising station procedures to emphasize the T/S analysis requirements and to strengthen chemistry department management oversight of surveillance *
This licensee-identified violation is not being cited because the cfiteria specified in Section VII.B.l of the."General Statement of Policy and Prricedures for NRC Enforcement Actions," (Enforcement Policy,.
10 CFR Part 2, Appendix C (1992)), were satisfie *
(Closed) LER 92-01. Unit 2:
"'A' Floor Drain Sample Tank Surveillance Interval Exceeded Due to Management Deficiency." T/S 4.8.D requires that a sample of this tank be analyzed every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when radwaste is being adde On January 9, 1992, the licensee determined that the 72-hour limit had been exceede Problems with a radwaste concentrator in the preceding days apparently distracted personnel from the 'need for a sample.* A sample was subsequently analyzed and the results indicated that tank activity was well below the T/S limits. With the time required for analy~i_ng the ~a.'!lp_le, _ th.e _72:-hour limit was -exceeded by
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- approximately one-hou Corrective actions included counseling radwaste personnel on the sampling and analysis requirements and development of a radwaste control room turnover ~heet that clearly indicates the sampling status of tank This licensee~identified violation is not being cited because *the criteria. specified in Section V.II.B.l of the "General Statement of Polity and Procedures for NRC Enforcement Actions," (Enforcement Policy, 10 tFR Part 2, Appendix C (1992)), were satisfied;
{Closed) LER 92-09, Unit 2:
"Unit 2/3 Reactor Building Vent (RBV)
Exhaust Iodine Discr~pancy Due to Procedure Deficiency." While..
preparing an effluent report, a Health Physicist discovered a seven hour and 50 minute lapse in iodine monitoring of the RBV owing to a maintenance outage on the system particulate iodine noble gas (SPING)
monito The usual backup RBV samples had been collected but discard~d.
without analyses because the analyzing technician was unaware. of the
- SPING outage and, therefore, of their importance in meeting the technical specifications (T/S).
The licensee's procedure now requires analyses of the backup sample~ whether needed for T/S purposes or no Two noh-~ited violations were identifie.
Audits and Appraisals (IP 84750)
.The inspectors reviewed audit No. 12-92-04 conducted in April 1992, by the onsite Nuclear Quality Program~ (NQP) group of the station's radioa~tive waste (radwaste) and environmental monitoring progr~ms: A audit of these areas is performed annuall In *addition, because of previously identified proble~s, the auditors focused on procedure adherence, communication to workers of expected levels of performance, and adequacy of supervisory overview of worker The audit appeared to be performance-based and conducted by knowledgeable and experienced personne Except for a concern about the operability of the service water radiation monitors (discussed in Section 7), no problems were identifie No violations of N_RC regulati9ns were identifie.
Liquid Radwaste (IP 84750)
The inspector reviewed the implementation of the liquid radwaste progra~. This was accomplished thr~ugh discussions with personnel, observations of radwaste control room activitie~, and a review of record *
The quantity of radioactive material reported released in liquid effluents in the past three years (1989-1991) has been low with tritium ranging from about 13 to 20 curies annually and the remaining isotopes at about 0.7 curies annuall Most was released in batches from the outside tank farm, which includes a waste (equipment drain) surge tank (17,000 gallons), three wa~~e sample tanks (33,000 galloris_each), and
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two floor drain sample tanks (22~000 gallons each).
Previously, the releases were made f~om one of the sample tanks, but the procedure was recently revised to use a singl~ tank (waste surge) for routi~e release fn order to reduce their-number and the opportunity for valve lineup error.
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Iri addit~on, some radioactive material (usually less than 1 millicurie *
per year) from tube leaks in a low pressure ~oolant injection heat exchanger was also released in the service wate The offsite doses from the liquid radwaste released from the station was well below T/S *
limits;
Since the beginnirig of 1992, station operators have been assigned lo radwaste as part of their normal duties. Previously, radwaste activities were performed by a group of personnel exclusively-assigned to that area. Observations by the inspector bf radwaste control room personnel indicated they were knowledgeable of assigned task~. An.
- experienced and dedicated group of radwaste supervisor$ (foremen)
appeared to provide the necessary oversight of operators as they rotate through the radwaste are An example of oversight was noted during the inspection when one of the foremen.prohibited a pl~nned liquid radwaste discharge because the newly written procedu~e fo~ the discharge assumed
~ level of knowledge of radwaste systems that the station operators might not yet have a~quire T.he review of radwaste control room activitfes also indicated a need for increased management*attention to maintain radw~ste equipmen Approximately ten work requests more than a year old were observe Of particular concern were the work requests to repair level indicators for the concentrators and the concentrated waste tank where absence of accurate level indication can lead to overflow of.concentrated radwaste, a problem that has occurred at the station~ At the exit meeting (Section 10), the licensee agreed to discuss this matter at an already scheduled July 17, 1992 meeting on radwaste issue No violations of NRC requirem~nts ~ere identifie.
Gaseous Radioactive Waste (IP 84750)
The inspectors reviewed the licensee's gaseous radwaste management*
program, including changes in etjuipment ~nd protedures, gaseous process and effluent monitors, and records of effluent release.
Gaseous effluents are exhausted from the plant via three release points:
the elevated (about 100 meters) 01 and 02/3 chimneys and the
~emielevated (t~rbine building roof) joint 02/3 reactor building ventilation (RBV) stack. Samples from the individual Units 2 and 3 exhaust plenums are taken to backup: the RBV sample Chimney releases are continuously monitored by sodium iodide and geiger mueller detectors and SPING monitors. They are quantified from continuously colletted particula.te and iodine SPING samples, analyzed
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weekly, and from weekly grab samples for noble ga RBV releases are similarly quantifie Weekly particulate samples are also composited-monthly for vendor analyses of gross alpha and non gamma emitting beta isotopes. Tritium is collected and analyzed monthl The inspector~
verified that compensatory samples were taken in accordance with T/S 3.2.G.3 when the 02/3 chimney and backup system were out of service.*
The inspector reviewed the semiannual effluent reports fof 199 Total noble gas released in 1991 was about 13 curies, down by about 38% from the previous year. There were no reported instances of exceeding release technical specification The inspect6r also reviewed a licensee 'identified abnormal release cau~ed when a mechanic mistakenly disassembled the RBV samplfng ~ystem beyond a tagged isolation valve thus allowing local (turbine building}*
air to dilute the RBV air flow.ing through the* sampler for apout 30 minute The valve was* reinstalled and the low flow alarm cleare Corrective actions were appropriate and timely and also incl~ded training for involved individuals..
No violations of NRt requirements were identified. - Air Cleaning Systems (IP 84750)
The inspectors performed a selective review of the surveillance test data fbr high efficiency partic~late air (HEPA) filters and charcoal adso~be~s for the ~ontrol room, technical support center, and the Units
- 2 and 3 high range sampling system ventilation system The data shows that the dioctyl phthalate (DOP) penetration and the halogenated
. hydrocarbon penetration was less than the one percent criteria for HEP filters and charcoal adsorbers respectivel In addition, a laboratory analysis of a representative carbon sample from ea~h train for methyl iodide removal has been performed by a cont~actor with r~cords showing the removal efficiency to be greater than the 95 percent criterion specified in the li~ensee's procedure *
No violations of NRC requirements were identifie.
Effluent Control Instrumentation (IP 84750)
The inspectors selectively reviewed calibration.and functional test records and selected setpoint records for liquid and gaseous effluent radiation monitor The inspectors also walked down each of the liquid radwaste monitors and the gaseous particulate and iodin~ monitor Technical Sp~cifications 4.2.F (for liquid effluent instrumentation) and 4.2.G (for gaseous effluent instrumentation) require calibration of the monitors *t 18 month intervals and qµarterly functional test The talibrations and functional tests were performed ~s require As discussed in Section 3, a recent NQP audit (in April 1992) identified a concern in that for approximately three years, the station has been analyzing twice daily grab samples of the service water although the
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monitors are still in-servic Such samples are required if the monitors are inop~rable (Action A of Table 3.2.4, T/S 3.2.F.3.) but in this case the monitors have been maintained in service; The stations
- response to the concern indicated th*t becayse of high background it was questionable whether the ~onitors could meet the required sensitivit Licensee r~presentative~ told the inspectors that this matter was being reviewed by the corporate staff with completion expected by mid-Jul This matter will.be reviewed during a future inspection (lnspeGtion Follow-up Item (IFI) No. 50-237/92016-01;. 50-249/92016-01).
A review by the inspector of liquidradwaste monitor chart records indicated erratic response during s~veral discharge The licensee indicated that this problem was attributed to some unshielded.cable that has since been repaired. Because no discharges had been made since the*
- .cable repair, this matter will be reviewed during a futur*e inspection (IFI No. 50-237/92016-02; 50-249/92016~02).
No violationi of NRC requirements were identifie * External Exposure Control CIP 83750)
On June 3, 1992, a worker employed by the radwaste processing vendor received an exposure in excess of the station's applicable administrative limit (100 millirem) while installing a lid on a liner of spent, dewatered resin.. This operation is routine, and had been done in the past three years* by the worker without inciden However, this time the lid became misaligned and the pneumatic installation tool did not function properl Instead of informing the assigned radiation
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protection technician "(RPT) of the problems, he continued workin While attempting to correct the problems, the worker leaned over the.
shield wall around the liner where the dose rate was approximately rem/hou Although the dose rate alarm on his electronic dosimeter (ED)
sounded he kept working until the lid was installed properl The total dose alarm Df his ED also sounded, but he apparently did not recognize *
it until he left the area and his dose rate alarm stoppe The ED indicated a dose of 147 m*illirem; however*, the licensee assigned him 197 millirem based on his thermoluminescent dosimeter (TLD)..
Although the dose received by the worker was well below regulatory*
limits, this ev~nt, together with two earlier similar instances of personnel working through dose rate alarms (Inspection Report No. 50-249/91033;
~nd Nos. 50-237/92011; 50-249/92011) indicated a weakness in the radiation protection progra Interviews by the inspectors indicated differences between RPTs in their monitoring of this job and in their expectations of worker response to dose rate alarms which could have confused the worke *
The inspector's review indicated that the licensee promptly investigated the incident and took firm corrective actions.which included removal -of
- the worker from the site and issuing clear instructions to the RPT However, the Radiological Occurrence Report used to document the investigation was deficient in that~ it ~id n~t mention.the ~ifferences
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in RPT coverage of work in the liner processing area. According to the licensee, these differences had also been identified during their
. investigatio The effectiveness rif the corrective actions will be reviewed during future inspection No viofations of NRC requirements were identifie.
Plant Tours CIPs 83750 and 86750)
The inspector made several facility tours to make dose rite measurements and to observe postings, personnel performing various jobs (including late night shift work), equipment condition, and housekeepin In addition, dose rates a~ound a cask of spent resin awaiting shipmerit ~ere measure No problems were identifie * No violations of NRC requirements were identified.:
1 Exit Interview The scope and findings of the.inspection were reviewed with licensee representatives (Section,!) at the conclusion of the inspection on June 22, 199 During the exit interview, the inspector discussed the likely informational content of the inspectiori report with regard to documents or processes reviewed during the inspection. licensee representatives did not.identify any such documents or processes as
_proprietar The following matters were specifically discussed by the inspector:
- * the need for an operability determination for the service water radiation m6nitors (Section 7),.lack of -operable level instrumentation on the concentrlt6~ w*st~
tank (Section 4), and.*
- problems associated with the administrative overexposure of a worker in the radwaste liner processfrig area: including differences between RPTs providi~g cbverage. (Section 8);
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