IR 05000249/1999005
| ML17191B285 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/17/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17191B284 | List: |
| References | |
| 50-237-99-05, 50-237-99-5, 50-249-99-05, 50-249-99-5, NUDOCS 9903250059 | |
| Download: ML17191B285 (20) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Docket Nos:
License Nos:
Report Nos:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9903250059 990317 PDR ADOCK 05000237 G
PDR REGION Ill 50-237; 50-249 DPR-19; DPR-25 50-237/99005(DRS); 50-249/99005(DRS)
Commonwealth Edison Company Dresden Nuclear Generating Station, Units 2 and 3 6500 Dresden Road Morris, IL 60540 February 22-26, 1999.
W. Slawinski, Senior Radiation Specialist M. Mitchell, Radiation Specialist Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
- EXECUTIVE SUMMARY Dresden Nuclear Generating Station, Units 2 and 3 NRC Inspection Reports 50-237/99005; 50-249/99005 This routine, announced inspection evaluated the effectiveness of the licensee's radiation *
protection program during the Unit 3 refueling outage, and focused on radiological planning and implementation of the as-low-as-is-reasonably-achievable (ALARA) program, the control and testing of portable ventilation and vacuum systems, outage staffing and training and the overall radiological performance and oversight of radiological work. An intake incident that occurred during the outage and the station's source term reduction program were also reviewed. The following conclusions were made in these areas:
Plant Support
Station dose performance for the Unit 3 refueling outage was excellent. Effective ALARA program implementation and generally good work planning, improved radiation worker performance and oversight of radiological work, and continued source term reduction initiatives produced the lowest collective refueling outage dose in station history (Section R1.1).
- The ALARA program was effectively implemented. ALARA plans were generally well developed and thorough, consistent with the potential radiological risks, and ALARA initiatives contributed to substantial dose savings. Protective clothing requirements were routinely relaxed to address heat stress concerns, improve worker efficiency and thereby reduce doses, and associated ALARA evaluations were technically sound to support the initiatives implemented (Section R 1.2).
- Weaknesses in the quality control and testing of a device fabricated by the licensee coupled with radiation protection staff communication problems and problems with the development and documentation of an ALARA plan, caused a worker to ingest a small quantity of radioactive material during local power range monitor replacement wor While no significant radiological consequences resulted, the worker was placed at increased radiological risk (Section R 1.3).
- The licensee implemented a relatively aggressive and effective source term reduction program, and continued to monitor and track its effectiveness and explore methods to achieve further station dose savings (Section R104).
- The licensee's program for the control and testing of portable high efficiency particulate air (HEPA) filtered systems and vacuums was generally effective. The licensee demonstrated good initiative and developed a program for chemical testing portable HEPA units (Section R2.1).
Isolated problems were identified with the radiological control of HEPA filtered systems and vacuums. One Non-Cited Violation was identified regarding the failure to follow a station procedure for return of filtered vacuum cleaners used in ra9iologically posted areas (Section R2.1).
- Radworker performance had improved compared to previous outages as evidenced by problem identification form data, the relatively low number of personnel contamination events and other performance information. Worker contaminations were routinely planned as an ALARA measure, which proved effective in keeping doses ALARA (Section R4.1 ).
Radiological postings were effectively maintained and accurately reflected the area radiological conditions, and high and locked high radiation areas were controlled consistent with station procedures and regulatory requirements. Appropriate contamination control practices were observed to be used by workers and radiological controls for observed work activities were as prescribed by the ALARA pla Housekeeping and material condition were generally good and exceptions noted by the inspectors were promptly corrected by the licensee (Section R4.2).
- Outage staffing and training for the radiation protection program was generally effective. The training of contract radiation protection staff was completed in accordance with station procedures, and adequately prepared workers for assigned outage tasks (Section RS.1 ).
R1 R Report Details IV. Plant Support Radiological Protection and Chemistry (RP&C) Controls Radiological Planning for the Refueling Outage Inspection Scope (IP 83750, 83729)
The inspectors assessed the radiological planning and collective station and individual worker dose performance for the Unit 3 refueling outage (D3R15). The assessment consisted of an overview of outage work activities including rework, emergent work and work scope additions, a review of selected jobs, dose planning and dose projection practices, and discussions with as-low-as-is-reasonably-achievable (ALARA) and outage planning staff Observations and Findings The licensee's estimated dose and challenge dose goal for D3R 15 was 200 and 175 person-rem respectively, a goal which equated to a 21% dose reduction from the previous Unit 3 refueling outage when 222 person-rem was expended for similar scope work. While the estimated dose included contributions from some work scope additions.
and revised (increased) estimates for drywell in-ser\\iice-inspection (ISi) and drywell equipment/floor drain sump system maintenance, the challenge goal was not altered to account for the revised estimates or for expected doses from late work scope addition The most radiologically significant outage activities and associated dose estimates included drywell ISi activities (16 person-rem); main condenser maintenance and inspection (8.8 person-rem); drywell nuclear instrumentation maintenance (9.8 person-rem); scaffolding activities (17.9 person-rem); control rod drive maintenance (8 person-rem); and reactor disassembly and reassembly activities (6.6 person-rem).
Inspector review of the outage work planning processes, review of work packages, schedules and procedures, and discussions with the ALARA group disclosed that station and industry lessons learned were routinely incorporated into work planning, and that the radiation protection (RP) group was adequately integrated into the planning process. For example, the licensee addressed many of the scaffolding
- construction problems which occurred during the last (Unit 2) refueling outage, and expended only about 68% of the dose estimated for scaffolding activities. Specifically, the dose from drywell scaffolding work was reduced through use of snap-fit type hardware, streamlined scaffold constructions, prefabrication in low dose areas and improved work group supervision. Although unnecessary dose was expended because some scaffolds had to be rebuilt or were constructed and later determined not to be *
required; overall, the scaffold program was improve *
Individual worker doses were well controlled during the outage and were within the licensee's daily and annual administrative dose limits. Although dose related to drywell work and for refueling floor activities exceeded the licensee's challenge goal, balance of plant dose was significantly lower than projected and the station's collective dose met the licensee's challenge goal. Specifically, dose goals for refuel floor activities were exceeded by approximately 25%, in part, because of problems during certain reactor reassembly work which added about 2. 75 rem beyond that projected. Similarly, dose goals for drywell work were exceeded by about 19%, in part, because of some non conservative dose estimates. Nevertheless, collective dose for the outage (based on secondary dosimetry data) was 172 person-rem, just below the licensee's challenge goal. The refueling outage was the shortest in station's history at 26 days, and the collective dose was the lowest for a refueling outage at the station. This excellent dose performance was attributed to continued station source term reduction efforts, good A LARA initiatives and job planning, improved oversight of radiological work and lack of significant dose producing rework or emergent wor Conclusions Station dose performance for the Unit 3 refueling outage was excellent. Effective ALARA program implementation and generally good work planning, improved radiation worker performance and radiological work oversight, and continued source term reduction efforts produced the lowest collective refueling outage dose in station histor R1.2 ALARA Program Implementation Inspection Scope (IP 83750. 83729)
The inspectors evaluated the effectiveness of the licensee's radiological controls, work practices and oversight of radiological work activities, and the results of efforts to reduce dose and implement the A LARA program for D3R 15. The inspectors interviewed radiation workers (radworkers) and members of the RP staff; reviewed ALARA Action Reviews (AARs) including total effective dose equivalent (TEDE) ALARA reviews and evaluations for planned personnel contamination events, radiation work permits (RWPs) and applicable procedures; and observed ongoing work on the refuel floor and turbine dec Observations and Findings Radiation work permits, TEDE ALARA evaluations and dose expenditure.information for the following outage work activities were reviewed:
Drywell equipment/floor drain sump system maintenance Drywell nuclear instrumentation maintenance Main condenser maintenance/inspection activities Drywell scaffolding activities Torus desludging activities
Reactor disassembly/reassembly and related activities Refuel floor miscellaneous support activities ALARA plans and AARs and associated evaluations were generally thorough and well developed consistent with potential job hazards, and incorporated lessons learned and innovative dose saving products or technologies. ALA RA action reviews for those activities reviewed by the inspectors with estimated exposures greater than 5 person-rem were reviewed and approved by the Station ALARA Committee, as require ALARA plans for large or diverse scope activities and/or high risk work, such as reactor disassembly and reassembly, were divided into individual jobs or subdivided into job segments, and specific ALARA*and RP controls were delineated for each job* or segment. This was an effective practice that ensured appropriate radiological controls were in place. Good dose reduction techniques and ALARA/engineering controls were used routinely and included extensive hydrolyzing of piping systems, and judicious use of temporary shielding, portable filtered ventilation systems and remote monitoring equipment. The licensee also used lapel air samples to monitor worker breathing zones, to address air sampling problems that occurred during a previous outag Personnel contaminations and on occasion small intakes of radioactive material were planned as dose savings methods, if ALARA evaluations determined that worker efficiency would be improved and TEDEs would be reduced without the use of respiratory protection equipment or performed with less restrictive protective clothing (PC). For exa~ple, the licensee routinely relaxed PC requirements to address drywell heat stress concerns, and several low level personnel skin contaminations were planned as ALARA initiatives. Inspector review of selected TEDE ALARA and planned worker contamination evaluations revealed that they were completed in accordance with station procedures and adequately supported the licensee's decision to relax requirement Coordination and oversight of radiological work was provided by ALARA engineers assigned to specified areas of the plant, and periodic or continuous job coverage by radiation protection technicians (RPTs) for high risk activities. A practice successfully used during other recent outages. ALARA engineers were assigned around the clock coverage for the dryWell, reactor and turbine buildings, and the refuel floor and t:>alance of plant. The inspectors observed appropriate ALARA controls and RP oversight during replacement of ~ spent fuel pool gate seal and during turbine calibrations and related activities completed late in.the outag *
Overall, the A LARA program was effectively implemented as. evidenced by the outage dose performance described in Section R 1.1 of this report. However, as described below and in Section R1.3, some exceptions were noted. For example, considerable unanticipated dose was expended during one phase of the reactor reassembly process because of problems with a product used for the first time at the station, coupled with job planning and execution deficiencies. According to the licensee, higher than normal reactor cavity temperatures may have caused a strippable coating that was sprayed on the cavity walls and floor to control contamination to lose its adhesion. These problems were compounded when the coating was subsequently removed and water that had collected on the coating cross contaminated the "clean" cavity floors. The licensee was
- incorporating lessons lea.med from these problems into its job history database to avoid recurrenc Conclusions Overall, the ALARA program was effectively implemented. ALARA plans were generally well developed and sufficiently thorough, consistent with the potential job hazards. Protective clothing requirements were routinely relaxed to address heat stress conc~ms, improve worker efficiency and thereby reduce doses, and TEDE ALARA reviews were technically sound and supported these good ALARA initiative Licensee identified deficiencies in. ALA RA planning or job execution were captured in lessons learned and job history files for future applicatio R1.3 Review of Intake Incident During Removal of Local Power Range Monitors CLPRMs) Inspection Scope (IP 83750. 83729)
The inspectors reviewed the circumstances surrounding a licensee identified unplanned intake of radioactive material that took place during D3R 15, while LPRM detector strings were being removed from the reactor vessel on February 8, 1999. The inspeCtors discussed the event with RP staff;* and reviewed the licensee's investigation of the incident, the RWP and ALARA plan for the job and the licensee's intake and skin dose assessments and associated procedure *
- Observations and Findings During the back shift on February 8, 1999, a contractor working under vessel was contaminated and ingested a small volume of radioactively contaminated liquid, when reactor water splattered down onto the worker as the individual loosened an LPRM detector for subsequent removal. The problem occurred during the early phases of the job, while the second of seventeen LPRMs was being remove To release an LPRM from its housing, a "seal can" was used. The device was designed to break the detector free from its housing and divert water from the in-core housing to the drywell sump. The cylindrically shaped seal cans were threaded at the top and were equipped with a concentrically located "push rod" that extended vertically through the cylinder, several inches longer than the full length of the can. The threaded connection at the base of the LPRM housing protruded from the bottom of the reactor vessel, and was intended to mate with the seal can threads and provide a water tight barrier. Following the licensee's previous practices, the seal can was threaded onto the base piece, and the push rod manually forced upward toward the vessel to break the detector assembly seal. The force exerted by the push rod allowed the LPRM to unseat so it could be subsequently removed from the vessel. This method was used to remove the first LPRM string on February.8, 1999. However, the next LPRM was not unseated after moderate force was applied to the push rod and the
"sledge hammer contingency method" was used. This contingency was routinely used successfully in t.he past by the licensee. In an effort to release the LPRM, the bottom of the push rod was struck with a sledge hammer, which was intended to jar the detector
free from its housing. The seal can leakage occurred while this contingency was being implemented. The water leakage problem occurred because threaded connections on the base of the detector housing and the seal can did not fully engage and form a proper seal. This caused water to leak around the top of the seal can and contaminate the worke Since the seal cans were last used, the licensee modified the design of the can and the mechanical maintenance staff fabricated new devices. The modified seal cans included a larger diameter push rod and an improved water drain line coupling and packing. However, according to the licensee, the push rods on the new cans may have been too long and interfered with the threaded connections between the upper portion of the seal can and detector assembly base piece. Since the threaded connections could not fully engage and be tightened, the seal can was not properly mated with the base of the detector housing and a leakage path was created for liquids present in the in-core housing. The device fabrication problems were exaggerated when the push rod was forced upward using the sledge hammer. The RP staff indicated that the new seal cans were not bench or field-tested prior to use, because similar devices were used successfully in the past and only minor changes were made to the can's desig Since seal can leakage was not expected and worker heat stress was a concern for the job, protective clothing (PC) requirements were relaxed as part of the ALARA plan and personnel (skin) contaminations were planned. Breathable water resistant PCs were used with face shields in lieu of heavier rubber gear and supplied air hoods. During recent previous outages, similar work was successfully completed using rubber gea-r and face shields. However, for the initial job evolution during the back shift on February 8, 1999, the face shields were not equipped with bibs (flaps) to protect the underside of the worker's chin and neck areas because the RP staff was not aware of the expectation for their use, as had been the standard dress for under vessel work during D3R 15. The licensee speculated that had the face shields been equipped with bibs, the worker's skin would not have been splashed and the intake avoided despite the seal can problem When the worker was splashed, it was quickly recognized by the radiation protection technician (RPT) that provided job coverage and surveys were performed. High levels of contamination (more than 3 million disintegrations per minute) were identified on the worker's PC and a potential intake was suspected because the individual's nose and mouth areas were contaminated and positive nasal smears were obtained. Whole body count bioassays taken shortly after the event and follow-up counts the next several days showed an intake of radioactive material equating to a committed effective dose equivalent (CEDE) of approximately 11 mrem. A sample of reactor vessel water that leaked during the work activity was collected and analyzed by the licensee, and showed both activation and fission products including a small transuranic component, which the licensee accounted for in its initial dose assessment. The inspectors reviewed the licensee's preliminary dose assessment and concluded it was technically sound. The inspectors independently calculated the workers CEDE from beta/gamma emitters based on whole body count data, and results were consistent with the licensee's. The water sample collected by the licensee was sent for vendor analysis
and the results were pending. The licensee's final dose assessment due to transuranic activity will be based on the results of the vendor's analysi The RP staff responded quickly, stopped the job and developed a recovery plan that included use of a modified seal can equipped with an extended threaded (nipple) piec Also, before the job resumed, protective clothing was modified to reduce the potential for skin contamination and rubber gear replaced the breathable water resistant suites and face shields were equipped with bibs. The job continued uneventfully for the remainder of. the back shift although some minor seal can leakage continued. The job was completed during the day shift on February 9, 1999, however, supplied air hoods replaced the face shields and bibs to ensure worker protection for the remainder of the job. The licensee's investigation of the incident identified that the seal cans were improperly fabricated and that the ALARA plan should have required the use of supplied air hoods until the effectiveness of the new seal cans was assure The inspectors' review also identified the following problems related to this incident:
The quality control and testing program for the new seal cans was wea Specifically, the licensee failed.to identify that the seal cans were not properly fabricated and failed to test the devices prior to actual field us Shift turnover between the day and night shift RP staff on February 8, 1999, was not sufficient to ensure expectations for worker protection (i.e., face shields with bibs) were known, and to ensure that proper functioning of the seal cans was understood. The communication problems were compounded because the night shift drywell supervisor was not experienced in LPRM replacement and seal can use, and was unaware that the cans should not lea The PC requirements in the ALARA plan were relaxed in an effort to address worker heat stress and comfort; however, the plan did not adequately consider that untested, newly fabricated devices were to be used in a high radiological risk work environment, which warranted a more conservative approach. Also,
. the A LARA pre-job brief checklist did not document the need for the face shield bib *
Non conservative decisions were made by night shift RP supervision because the job was allowed to continue without the use of supplied air hood The licensee planned to address the seal can fabrication and testing problems prior to the next refueling outage and planned to capture the PC issues in the post job A LARA review file Conclusions Weaknesses in the quality control and testing of a device fabricated by the mechanical maintenance staff, coupled with RP staff communication problems and problems with the development and documentation of an ALARA plan, caused a worker to ingest a
small quantity of radioactive material. While no significant radiological consequences resulted, the worker was placed at increased radiological ris R Source Term Reduction Program Inspection Scope (IP 83750)
The inspectors reviewed the licensee's efforts and future plans to reduce area dose rates in radiqlogically protected areas (RPAs) and evaluated the source term reduction program implemented at the station. The inspectors interviewed RP supervisors and the source term reduction coordinator, reviewed source term data including radiological survey results, and performed plant walk-downs and observed source term initiative Observations and Findings The licensee continued to address previous station source term problems and implemented a relatively aggressive source term reduction program that included expanded initiatives for permanent shieldi'ng, regular hydrolyzing and flushing of piping systems and components and planned chemical decontamination of certain system The station's "hot spot" reduction program continued to reduce the number of localized areas of elevated radiation within the RPA. Over the last two years, the licen_see reduced the number of hot spots from 40 to less than 10. Hot spots were tracked and surveyed at predetermined intervals and action plans are being developed to address the remaining locations. A no longer used autoclave system and two hot spots located in associated piping runs are planned to be removed in several months and another spot is scheduled to be permanently shielded later in 1999. About 30 permanent hydrolyze taps are installed at the station and most are used regularly prior to refueling outages to reduce elevated area radiation levels. Inspector review of D3R 15 survey data showed that hydrolyzing achieved reductions in area dose rates one to two orders of magnitud Since 1998, the licensee expended considerable effort to complete engineering and ALARA evaluations and install modification packages to expand the number of permanent shielding installations thro1,.Jghout the RPA. Over approximately the last six months, the station more than doubled the number of permanent shielding installation Completion of the project, however, was postponed and expected to resume after D3R15. As of D3R15, about 80% and 40% of the permanent shielding project for Units 2 and 3, respectively, were completed. Collective station dose savings after project completion were estimated at more than 20 rem annuall Future source term reduction activities for 1999 tentatively include a chemical decontamination of the fuel pool cooling systems and consideration for a similar decontamination of the shutdown cooling systems. These initiatives are projected to save collectively about 10 rem annually.
- Conclusions The licensee implemented a relatively aggressive and effective source term reduction program, and continued to monitor and track its effectiveness and explore methods to achieve further station dose saving R2 Status of RP&C Facilities and Equipment R Control and Testing of Portable High Efficiency Particulate Air (HEPA) Systems Inspection Scope (IP 83750)
b.
The inspectors reviewed the licensee's program for testing, issuance, use and storage of portable HEPA filtration systems and HEPA equipped vacuum cleaners. Relevant procedures were reviewed, RP staff responsible for the program were interviewed and areas of equipment use and storage were inspected. The following procedures were reviewed:
. DRP 6210-17 (Rev 01), "Issuance and Control of Vacuum Cleaners in Radiologically Posted Areas;"
DRP 6210-16 (Rev O},"Set-up and Operation of Portable Air FiltrationNentilation Equipment."
Observations and Findings During the last year, the licensee instituted a program using dioctylphthalate (DOP)
aerosol to test portable HEPA unit filters. The testing was conducted by a contractor above and beyond the normal procedures for use of portable HEPA units, to determin if such tests would be beneficial to the contamination control program. As a result of the testing, the licensee determined that the test program enhanced existing measures of contaminant control. The licensee is currently in the process of formally instituting the program through procedural changes, and anticipates training RP staff to conduct the testing on site. This testing program, when fully implemented, will place the licensee among industry leaders in this area since similar test programs are not routinely implemented for such equipment at most industry site The inspectors evaluated equipment storage and use practices and noted compliance with the procedural requirements in most instances. However, on February 24, 1999, the inspectors observed that two HEPA vacuum cleaner units were returned to storage and not checked in (radiologically surveyed) as required by station procedure (DRP 6210-17 (Rev 01)). One unit had recently been returned to the storage area and was not checked in and the other was returned days earlier and its presence in the storage area was unknown to the RP staff. On February 25, 1999, the licensee inventoried all the vacuum cleaners and portable HEPA filtration units in the storage area and identified that a portable HEPA filtration unit had also been improperly returned to storage. Similar to the vacuum units identified by the inspectors, the air filtration unit had not been surveyed prior to placement in storage. According to the licensee, both 1 1
- the vacuums and the air filtration unit were likely surveyed by the RP staff at the time they were removed from the job site, but should have been surveyed prior to placement in the storage area. Subsequent licensee surveys showed that none of the improperly checked-in units were contaminated beyond the licensee's threshold; consequently, the radiological consequences of this problem were minimal. Upon this finding, the health physics staff initiated a Problem Identification Form (PIF) (# D1999-01105) and wrote an information article for the daily plant bulletin describing the finding and reiterating the procedural requiremen Technical Specification (TS) 6.8.A requires, in part, that written procedures be established and implemented covering the activities recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978. Appendix A of RG 1.33 recommends that radiation protection procedures be implemented covering* radiation surveys and contamination control. Procedure DRP 6210-17 (Rev 01), "Issuance and Control of Vacuum Cleaners in Radiologically Posted Areas" was developed to meet this requiremen DRP 6210-17 (Rev 01), "Issuance arid Control of Vacuum Cleaners in Radiologically Posted Areas", Step G.3.e. states that "the vacuum cleaner shall be surveyed by radiation protection prior to its return to the designated storage area, to ensure there is no external contamination and to verify external dose rates of the filter and canister."
The failure to follow the requirements of the vacuum cleaner control procedure is a violation of TS 6.8.A. However, this Severity Level IV violation is being treated as a Non-Cited Violation (NCV), consistent with Appendix C of the NRC Enforcement Policy (NCV 50-237199005-01 (DRS); 50-249/99005-01 (DRS). This violation is in the licensee's corrective action program as PIF Number D1999-0110 Conclusions The licensee's program for the control and testing of portable HEPA filtered systems and vacuums was generally effective. The licensee demonstrated good initi.ative and developed a program for DOP testing portable HEPA units. However, isolated problems were identified with the radiological control of these units. One NCV was identified regarding the failure to follow a station procedure for return of filtered vacuum cleaners used in RPA R4 Staff Knowledge and Performance in RP&C R Review of Radiation Worker (Radworker) Performance Inspection Scope (IP 83750)
The inspectors evaluated overall radworker performance during D3R 15 through discussions with RP staff; direct observation; and review of the PIF data base, individual PIFs, personnel contamination event (PCE) reports and other performance data. The following procedures were reviewed:
DRP 5720-02 (Rev 01), "Identification and Control of Individual Radioactive Particles;"
DRP 5720-04 (Rev 9)," Routine Personnel Decontamination." Observations and Findings The inspectors reviewed selected PIFs generated during the outage to determine the scope and depth of radiation protection problems identified by the staff and the corrective actions implemented. The review disclosed no negative trends, recurring problems, or significant radworker performance problems. Most performance issues were minor and corrective actions were timely and appeared appropriat Reestablishment of the greeter program and use of tum styles to verify electronic dosimetry activation contributed to improved radworker performanc The inspectors reviewed the application of a program for planned personnel contaminations, an ALARA initiative used to reduce the TEDE as discussed in Section R 1.2. During the outage, the RP staff made generous and effective use of this program and PC requirements for several jobs were relaxed. For D3R15, over 75 individual planned PCEs were authorized and 13 actually occurred. None of the planned contaminations exceeded the expected dose thresholds and the program was successful in limiting total exposur A total of 12 unplanned personnel contaminations occurred during the refu~ling outage, including the one resulting in the intake discussed in Section R1.3. Doses from unplanned contaminations were low and the licensee responded timely and took appropriate corrective adion. The staff properly assessed each individual for the possibility of intake and whole body counts were taken when warranted. Individuals
. unable to clear the contamination monitor were required to clear the same monitor after decontamination, and a second more sensitive monitor prior to being released. The licensee was able to detect an intake of cobalt-60 well below the limits required by 10 CFR 20.1502 for assessing dose through the use of the monitors. While all actions taken by the licensee as a result of identified contaminations were appropriate and prudent, the inspectors noted that the personnel contamination reports lacked documentation of negative findings. This was brought to the attention of RP nianagement, who planned to review the matter and correct the deficiency as appropriat Conclusions Radworker performance had improved compared to previous outages as evidenced by PIF data, the relatively low number of personnel contamination events and other performance information. The staff's response to unplanned personnel contamination events was appropriate and timely. Worker contaminations were routinely planned as an ALARA measure, which proved effective in keeping doses ALAR. 13
- R Plant Walkdowns and Other Observations Inspection Scope (IP 83750, 83729)
The inspectors made several walkdowns of RPAs inside the power block for both Units 2 and 3, and assessed material condition, radiological housekeeping, posting and labeling and radiation work.er practice Observations and Findings Radiological postings for both Units 2 and 3 were well maintained. The inspectors determined through independent measurements that radiation areas and high radiation areas were appropriately posted, and that high and locked high radiation areas were controlled consistent with station procedures and regulatory requirements. Appropriate contamination control practices were observed to be used by individuals conducting work activities on the turbine deck and refuel floor, and ALARA controls for replacement of the Unit 2 spent fuel pool gate seal were as prescribed by the ALARA plan and RW Plant housekeeping and material condition was generally good with some exceptions in certain areas of the radwaste building and Unit 3 turbine building, which were brought to the attention of RP management and corrected. The exceptions included trash bags and mi~cellaneous equipment and supplies generated during the outage that were not consistently labeled, a mop bucket partially crossing a contaminated area boundary and used PCs not stowed in proper receptacles. The inspectors noted that some turbine building floor drains appeared to be fully or partially clogged with dirt and accumulated residue. Radiation protection management acknowledged the observation, indicated that they were not aware of any clogged turbine building floor drains but planned to review the matte Conclusions Radiological postings were well maintained and accurately reflected the area radiological conditions, and high and locked high radiation areas were controlled consistent with station procedures and regulatory requirements. Appropriate contamination control practices were observed to be used by workers and radiological controls for observed work activities were as prescribed by the ALARA plan and RW Housekeeping and material condition were generally good and exceptions noted by the inspectors were promptly corrected by the licensee.
RS Staff Training and Qualifications in RP&C R Staffing and Training/Qualifications for Refueling Outage Inspection Scope (IP 83750, 83729) The inspectors reviewed the outage staffing plan for the RP program, and the qualifications and training of contract RP staff. The inspectors interviewed radiation protection personnel that coordinated training and assigned duties for contract radiation protection technicians (CRPTs), and reviewed training matrices and discussed the training program with license staf Observations and Findings Prior to hiring CRPTs, radiation protection (RP) supervision reviewed candidate resumes and contacted previous employers of selected candidates to verify experience and references. Industry standardized qualification criteria was established for senior and junior CRPTs. Training requirements for prospective CRPTs included successful completion of the licensee's standardized core training at its Professional Training Center (PTC) within the previous two years, and a minimum score of 80% on the standardized Northeast Utilities Health Physics Theory Exam within the previous three years. As part of the on-the-job-training process, CRPTs were required to demonstrate proficiency in conducting radiation surveys, and successfully complete other specific task performance evaluations based on planned duty assignments. CRPTs were also *
required to complete station radiation protection and administrative procedure training, and selected CRPTs completed task specific training related to diver coverage, radioactive material shipping and the unconditional release program. Written tests were administered and\\or task performance was demonstrated to verify that procedure and task specific training was successfully completed. A matrix maintained by the licensee documented key training and qualification information for each CRPT, and was used by outage management to ensure that only qualified CRPTs were assigned specified tas.k The licensee augmented the radiation protection staff with 41 CRPTs and 13 ALARA planning staff. The licensee also used RP staff from sister stations or qualified station staff outside its immediate RP organization to supplement the outage organizatio The RP supervisory activities remained primarily a responsibility of the licensee's permanent staff, although some contract and sister station staff filled supervisory positions. This practice, however, led to minor problems as isolated instances of improper decision making based on plant differences and staff experience occurre Conclusions Outage staffing and training for the RP program was generally effective. The training of contract RP staff was completed in accordance with station procedures, and adequately prepared workers for assigned outage tasks.
\\ *
RS Miscellaneous RP&C Issues R (Closed) Violation 50-237/98016-02(DRS); 50-249/98016-02(DRS): Failure to adequately evaluate the airborne radioactivity concentrations in the reactor cavity during tensioning of the Unit 2 drywell cover. Several corrective actions were taken by the licensee to address this problem. Radiation protection management and technician staff met and discussed air sampling standards, expectations and procedure implementation; additional training on air sampling techniques and requirements was provided to the technician staff; lapel air samplers were purchased and successfully used during D3R15; and the radiological air sampling procedure was revised to improve clarity and consistency and a new procedure was developed to address use of the lapel air samplers. These procedures were reviewed by the inspectors and appeared adequate. These corrective actions were effective since no similar air sampling problems occurred during D3R15. Consequently, this item is close V. Management Meetings X1 Exit Meeting Summary The inspectors presented the preliminary inspection results to members of licensee management and other station staff at the conclusion of the site inspection on February 26, 1999. The licensee acknowledged the findings presented and did not identify any of the information reviewed by the inspectors as proprietary.
PARTIAL LIST OF PERSONS CONTACTED Larry Aldrich, Radiation Protection Manager John Almon, Training Manager Steve Barrett, Operations Manager Rick Conklin, Radiation Protection Supervisor Donna Fay, ALARA Analyst Michael Hawks, Source term Reduction Coordinator Richard Kelly, Regu.latory Assurance, NRC Coordinator Debra Miller, Radiation Protection Operation Supervisor John Moser, Radiation Protection 01.!tage Manager Dave Nestle, Health Physicist Robert Norris, Radiation Protection Supervisor Frank Spagenberg, Regulatory Assurance Manager Pres.ton Swafford, Station Manager Dave Van Aken, Radiation Protection Supervisor IP 83750 IP 83729 IP 92904 Opened and Closed 50-237 /99005-01 50-249/99005-01 Closed 50-237/98016-02 50-249/98016-02 INSPECTION PROCEDURES USED Occupational Radiation Exposure Occupational Radiation Exposure During Extended Outages Follow-up Plant Support ITEMS OPENED AND CLOSED
- NCV Failure to survey and control portable HEPA vacuums returned to storage after use in the RPA VIO Failure to adequately evaluate airborne concentrations during tensioning of the Unit 2 drywell cover
AAR A LARA CEDE CRPT DOP HEPA LPRM NCV PCE PIF PTC Radworker RG RP RPA RP&C RPT RWP TEDE TS LIST OF ACRONYMS USED ALARA Action Review As-Low~As-ls-Reasonably-Achievable Committed Effective Dose Equivalent Contract Radiation Protection Technician Di-Octyl Phthalate High Efficiency Particulate Air Local Power Range Monitor Non-Cited Violation Personnel Contamination Event Problem Identification Form Professional Training Center Radiation Worker Regulatory Guide Radiation Protection Radiologically Protected Area Radiation Protection and Chemistry Radiation Protection Technician Radiation Work Permit Total Effective Dose Equivalent Technical Specification*
PARTIAL LIST OF DOCUMENTS REVIEWED Station Procedures OAP 12-09 (Rev 16)
DRP 5500-01 (Rev 05)
D.RP 6020-02 (Rev 05)
DRP 5300-02 (Rev 01)
DRP 5821-36 (Rev 00)
DRP 6210-17 (Rev 01)
DRP 6210-16 (Rev 0)
DRP 5720-02 (Rev 01)
DRP 5720-04 (Rev 09)
RWPs and ALARA Plans Dresden Station ALARA Program Radiological Respiratory Control Program Radiological Air Sampling Program Exposure Review and Authorization Operation of the Gilian Personal Air Sampling System Issuance and control of Vacuum Cleaners in Radiologically Posted Areas Set-up and Operation of Portable Air FiltrationNentilation Equipment Identification and Control of Individual Radioactive Particles Routine Personnel Decontamination RWP # 997209 (Rev 0)
03~ 15 Reactor Disassembly/Reassembly & Related Activities *
and ALARA Review RWP # 997208 (Rev 01)
and ALARA Review RWP # 997105 (Rev 0)
and ALARA Review RWP # 997304. (Rev 0)
and ALARA Review RWP # 997205 (Rev 0)
and ALARA Review RWP # 997108 (Rev 0)
and ALARA Review D3R15 Refuel Floor Miscellaneous Support Activities D3R 15 Drywell Scaffolding Activities D3R15 Main Condenser Maintenance/Inspection D3R 15 Torus Internals Activities Drywell Nuclear Instrumentation Maintenance Activi.ties
- Investigation Reports and PIFs Apparent Cause Evaluation (2/22/99)
PIF # 1999-00745 and# 1999-00717 Ingestion Incident During LPRM Work LPRM Slam Can Failure and Uptake in Drywell Personnel Contamination Reports and Records for D3R 15 D3R 15 Exposure Performance Data D3R 15 RWP Report 20