IR 05000338/1991001

Partially Withheld Insp Repts 50-338/91-01 & 50-339/91-01 on 910107-11.Major Areas Inspected:Physical Security Program, Including Mgt Support,Security Program Plans,Protected & Vital Area Barriers,Testing,Maint & Communications

ML17202V104
Person / Time
Site:	North Anna
Issue date:	02/11/1991
From:	Mcguire D, Stansberry W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML17202V105	List: IR 05000338/1991001
References
50-338-91-01, 50-338-91-1, 50-339-91-01, 50-339-91-1, NUDOCS 9102200020
Download: ML17202V104 (9)

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U.S. NUCLEAR RE~LlAL~OR~ COMMISSION

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• R.eports No.. 50-237 /91002{DRSS); 50:-249/91002(DRSS)

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Docket Uos. 50-237; 50-249 License~ No. DPR~19; DPR-25 Licensee:

Commonwealth Edison Compan Opus.w*est I II 1400 Opus *Place..

Downers. Gro~e~ IL. 60515

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Facility Name:

Dresden Nuclear Power Station, Uni:ts 2 and 3 Inspection At:

Dresdeh Site, Morris, Illinors.*

Inspection Conducted:

J.anuary 3-23,.1991

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Inspector:

Accompanied By:.

(January 23, 1991 Approved By: '////lb~

M. C. Schumacher, Chief.

Radiological Coritrols and*

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Inspection Summary

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~tion on January 3-23, 1991 (Reports No*~ 50~237/91002(DRSS');

W-m79I002 ( DRSS) ).

• Areas Inspected:

Routine, unannounced )nspection of the solid radioactive waste management and transportation of radioactive materials programs (Inspection Procedure (IP) 86750).

The inspector was accompanied during much of the inspection-in this area by two representatives of the Illinois Department of Nuclear Safet In addition,* several allegations concerning the radiation protection program were reviewed (IP 83750).

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Results: Overall, the licensee's solid radioactive waste management *

program is adequat The 1 i cen*see has a good program *for.preparation and transportation cf r~dioattive mate~ials (Section 5). Weaknesses included e~tended onsite storage of radioactive waste (Section 5), delay in cleanup of the sludge tank. room (Sectiqn 6), and investigation of discrepancies between the results of primary and* s_econdary personal dosimeters (Section 9A).

The station's dose total for 1990 was high at 1399 person-re.)

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. DETAILS

• r** Perso~s Contacted.

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+T. Bennett, Radwaste Coordinator

+F. D.. Bevington, Nuclear Quality Programs (NQP)

+E. D. Eenigenburg, Station Manager M. J. Gagne~, Hea 1th PhYs i cist *

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+T. J~*Gallaher~ NQP *.

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W. Holcomb, Site.Supervisor, Chem-Nuclear Systems, In K. Koci uba, Superi n_tendent, NQP

D~ Lowenstein, Regulatory Assurance

. J. Mayer, Station Security Administrator J. J~ McGow~n, *Rad~aste Shipping Supervi~or

• .+L. L Oshier, Group Leader, Operations/ALARA*, Health Physics Section

+K. W; Peterman*, Supervisor, Regulatory Assuranc @+D~ Saccomando, Health Physics Services*Supervisor

+G. L. Smith, A~sistant Superintendent of Operations

+R. W. Stobert, Operating Engineer

+M. S. Peck, NRC Resident Inspector

+M. C. Schumacher, NRC Se.ction. Chief, Radiological Controls and Chemistry Sect i.on

+ Denotes. those *present at the exit meeting en January 18, 199 @*Denotes those present at the exit meeting on January 23, 1991.

General Rout~ne, un~nnounced inspection of the solid.radioactiye waste management and transpo~tation of ~adioactive materials program~. Jhe inspection c0nsist~d of a.revi~w tif procedures and records; interviews of personnel;.

observations of equipment, facilities, and the prepa~ation of several shipments of radwaste; and independent measurements (Inspection Procedure (IP) 86750).

The inspector was accompanied during much of the inspection by two representatives of the Illinois Department of Nuclear Safet The inspector al~o reviewed several allegations regarding the radiation protection progra A~dits and-Appr~isal T~e inspector:reviewed the results oF NQP Audit Number QAA 12~90-16~

which included a review of the process control program and radioactive material shipment activities. The audit was an in-depth, generally performance-based re~iew, conducted by experienced and knowledgeable personne The inspector *also reviewed the results of several

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surveillanc~s condµcted by the NQP group of radwaste ~nd shipping ai:tivities, and observed quality control personnel,at th.e preparation of several.shipments of radwaste. * No.problems.were identified by the NRC inspecto The licensee's.formal _quality. contr'ol and assurance groups appear to be pro~iding good oversight of radioactive material shipment activities. *

.No violations* were identified by the NRC inspecto..

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Changes in the Programs. and Training. ahd Qua i if i cat i ~n s of Personne 1 No significant changes have been*made in the solid radwaste and*.

r~dioactive*materials transportation.programs since.the last NRC *

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• r.eview in late 1989 * (Inspection Reports N.o. SQ.;.237-/89025.(DRSS);

• 50-249/89024(DRSS)). *overall,.. the training and quali.ficationsof the personhel jn the radwaste shipping group were good.* Most of the staff have at least seven* years of work experience at Di:.esden and at least two years.in the radwaste shipping grou In additio~, the members-of the group and the staff heal.th physicists responsible for radwaste shipment*

• curie ~eterminations have recently.received three days*of classroom trairiing in soli~ radwaste and shipping requirements at the licensee's Production Training Center. Several 6f these individuals have taken the cours~ annua.lly.for the ~ast.se~eral years. :

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No violati.ons of tlRC requirements wer*e.identif.ie.

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Implementatfon of the Solid Radioactive Was*t.e Program-The licensee has* an* active*solid radioactiv~.waste progra It-has made numerous shipments of radwaste tb burial sites in the.past several years and has not received an NRG Notic~:of Vi-0lation in thfs are In 1990, -

.129 shipments of mainly dry* active waste (DAW) and dewatered resins were made~ Most of the waste was shipped as Class A*, unstable; however,

• several *Class B shipm~nts*were made.* Several shipments were made in

.burial site-approved high integrity ~ontainers to.provide waste form stability. Solidification for stabilization was not performed in 1990; -

however, some waste was solidified in cement to reduce dose rates prior to shipment using the onsite vendor's so.lidification procedure Chem-Nuclear Systems, Inc., the onsite vendor, has provided solidification as wel.l as dewate~ing services for at least the past 5 years. Except for the discrepancy discussed below, the dewatering performed inl990 was done iri accordance with the vendor's process ~ontrol program and its implementing procedures, which are controlled as station procedure For DAW, the inspectors noted that good* use. wis made of volume reduction services, such as supercompaction and decontamination~ *For all radwaste, waste classi'fication to satisfy 10 CFR 20.311 has been performed for *

sev~ral years ~sing an inhouse, QA-controlled software progra No pr9blems with. the licensee's waste classification methodology were*

-identified by the inspector *. The inspe.ctor also inquired about the licensee's method for determining the quantity of chelating agent in non.:-DAW radwaste shipments, as required in 10 CFR 20.311 (b). -Licensee representatives stated that they routinely use a value determined several years ago, but they were unable during an initial search to locate any r~cords supportin~ the use of the ~alue (the inspector notes ~hat,.

typically, chelating agent quantities are low in commercial power plant radwa~te).. The licensee agreed to conduct a.second search for the supporting record~_. This matter _will be reviewed during a future inspectio During a review of shipment No. 01-91-039, a liner containing curies on dewatered resins that was shipped on January 8, 1991, the inspector observed a discr~pancy.between the dewatering procedure used -

and the actual dewate~ing ~eiformed on the resin; Procedure FO-OP-023,

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"Bead Resin/Activated Carbon Dewatering Procedure for CNSI 14-215 or.

Smaller Liners," Revision H, requires the operator, in step 5.2;10, to monitor the* temperature of the liner durin~ dewatering*~ and to secure the dew~terinQ and refill the line~ 1 with water *if the temperature increases-to lOU degrees Fahrenheit or higher or if _the temperatur~ *

increase exceeds )5 de~rees Fahrenheit per hour. * However~ according to the v.endor, the second of:-three 8-hour-dewatering cycles was performed on the 1 iner *over a lat,e night work ~hift without an oper11tor* in. *

continuous attendance to monitor the tempe.ratur This discrepancy

. was discussed with licensee and vendbr~epresentatives, who stated that the requ'irement for monitoring the temperature.was intended for**the

intitial *llour or two of. de_watering,.when an exothermic reaction is most li.kely t~ oc_cu The li.. censee agreed to revise the procedure to :specify the intended peri-0d of temperature monitoring. This revision will be reviewed durihg a future inspection (Open Item No. 50-237/91002-0l(DRSS);

50-249/91002-01 ( DRSS))

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- in.the past several years, the l.icensee has been.reducing a relatively * large backlo~ of radwaste stored onsite.. These efforts have accounted for much of the 1arge volume of radwaste shipped from the plant in 1989 when appr6ximately 7~060 cubic feet of.radwaste; containing approximately 2538 curies, was shipped, and in 1990 when approximately 85263 cubic feet of radwaste, containing approximately 509 curies, was shipped.. The need

.for additional action by the licensee, however, was noted for radwaste stored in the south storage.bay of the ~adwaste* buildin In this-area,

- the licensee has 213 55-gallon drums of radwaste, about half of which apparently were solidified when the licensee's installed Stock Equipment

. Company solidification system was operational, from approximately 1979-198 For some of these drums, the licensee has general information

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on type of *waste and date of solidif1cation, but for most of the 213

. drums the licensee does not have this i.nformatio Licensee records of an inventory conducted *arourid* September*1989 indicated: that the physical condition.of most of the drums is good; however, some have*

. missing lids oi are otherwise da~aged; Di~cussions with the* licensee indicat~d that no plans have.been developed to date to ship the drum to a burial* site. As' discussed.in Generic Leiter 81-38, "Storage of*.

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. Low-Level Radioactive Wastes at Power Reactor Sites, 11 radioactive.waste should not be stored onsite in excess of.-5 years.-* The storage of the drums. in.the south* storage.bay fo excess of 5 years, the,lack of records on the origin of much of the wast~, and the lack of a definite plari to re-characterize and.ship the waste for.btirial. ~s a weakness in the licensee's solid radioactive waste program. This matter will be reviewed during subsequent inspection. _-""

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No violations of NRC requirements were identified; however, one program

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Radwaste Sludge Tank Room The inspector *review~d the li~ensee's*progress on the cleanup of the radwaste sludge tank room.: Details of the Circumstances of the contamination of this *room and the adjacent spent resin tank room are provided in NRC Meeting ~eports No~ 50-237/89020(DRSS);.

N /89019(D~SS). An expected cl_~anµp completion date.of

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Jurl'e 30, 1990*, was given in a:. letter from the licensee dated

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October 6~ 1989, a~d was revised ~o December 31, 1990, in a lett~r dated October 2IT, *199 As discussed in *;nspection Reports N ~237/90026(DRSS); 50-249/90025(DRSS), the cleanup of the spent resin tank room has been complete Discussions during the current

. inspection indicated that the cleanup of the, sludge tank room, however, is rinly abotit 10% complete and, initially, ~a~ halted because.of mechanical problems with the ~obot used for.the cl~anup~ According to the licensee, the mechanical problems have beenremedied, but.-

resumption of the cleanup has been delayed while personnel issues. * * *

regarding who will operate the robot are res6lve In a letter dated'

January* 23, 1991, the, licensee st.ated that the cleanup should be.

completed by June 30, 199 The completion of the cleanup has bee delayed twice, the most recent delay involving personnel issues..

No violations of NRC. requirenients we.re -ident'ified; however, increased attention.by th_e. licensee appears needed to ensure a timely cleanu Un~t 1 Chemical Decontamination Waste Project The licensee recently initia_ted a project to solidify and-ship for burial the waste generated in mid-1984-to early 1985 during the ~hemica decontaminatio.n of Unit I *(details of the 'decontamination project are discussed in several previous inspection reports including, NRC

Inspect ion Reports No. 50-10/84-05; 50-237 /84-07; 50-249/84-06, and.

No. 50-010/84-15; 50-237/84-18; 50-249/84-17).

The solidiflcation will be performed by a vendor (Diversified Technologies of Chesterton, MD)

using an NRC-approved process that uses viny.l ester styrene as the solidification agen Licensee representatives stated that the project is tentatively scheduled to be completed in'.early 1992 and may result in shipment for burial of 500-900 55-gallon drums of solidified.waste depending on the amount of dilution required~ Radiation protection considerations of the project, compliance with th~ limitations of the NRC approval of the solidific~tion *process, and ~dherence tb NRC and DOT' shipping re~uireme~ts Will be reViewed during future routine inspection *

No violations of NRC requirements were ident,fie.

. Shipping of Low-Level -Wastes for Disposal, and Transportation of Other Radioactive Materials

• 1n addition to*129 rad~*aste shipments made in 1990, the licensee made approximately 200 shipments of non-radwaste radioactive material Most of these shipments were-of conta~inated protective clothing, which was*

sent to the commercial nuclear laundry in nearby Morris, Illinois.. A review by the inspector of records for several shipments identified no problems, and according. to licensee representatives there have.been no problems with shipments made in 1990.:

T.he fospector also observed the preparation of two shipments of resins,*

conducted. ind_ependent dose rate measurements of the shi.pments, and

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• reviewed assotiated record One of ihe shipment~* involved the*

nonrouti~e use of a ~ersonnel barrier for the shipping cask because of high dose rates. *No problems with these.two:snipments were identi,fied by the inspe~to *No violations.of NRC req.uirements were identi.fie..

Allegation Followup

. The NRC Senior Resident Inspector at Ores.den recently rece.ived* tw allegations regarding the radiat)on protection program at Dresden~* They were evaluated ~urin~ the current inspec~ion through record. and procedure review, discussions with licensee and contracto~ personnel, and through observatio*ns in the main**radiologically control.led area (RCA).

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. *(Closed) Alleg~t~on.(A~S No. ~ii1~9o~A-6120}

AllegatiOn:. The discrep(!ncy between a dose record mair;tained by a worker and the licensee's record f6r the worker is large~ than the alleger has seen at other Corrunonwealth Edison* plants for similar records. *

Discussion:

The alleger gave ~pecifii valu~s for the worker's dose recbrd and the licensee's r~cord as* of November 19, 199 He also*

indicated that, similarly, three other workers had larger than expected discrepancies between their personal records and the licensee's records, but he did not have specific dose values *for those worker The. inspector contacted.the.. first worker to verify

the dose values initially received. during the allegation and

• obtained additiOnal dose information that the worker had recorded*

in his* personal log. According to the worker, he recorded in his own log the dose values.from his secondary dosimeter (an electronic dosimeter) that he recorded on the.licensee's dose cards.* The inspector then compared the values obtained from the worker with the values in the licensee's records. Although there were

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differences between 3 of theapproximately 40 values compared, they were not signif i~ant. Howeveri the inspector observed significant d~fferences between the dose card values and values re~orded on the thermoluminescent dosimeter (TLD) badge (the licensee's primary dosimeter) worn by the worker in October and Novemb.e The

inspector also noted similar discrepandes in the recor:-ds for a significant number of other workers. These differenc~s may indicate possib*le problems wfth dosimeter performance or with the way the dosimeters are being worn by the worker The accreditation * *

of the licensee in January 1990 as.a* TLD processor by the National Voluntary Laboratory Accreditation Program (NVLAP).provides

• reasonable assurance that the TLDs used. are not fault *.

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The licensee has.a procedure, DRP 1250-5, "Comparison *of Personnel Dosimetry Results, 11 Revision 4, that provides* for comparing the*.

results of TLDs and secondary dos.imeter The procedure states.*

that the comparison. should be done every badge period and that.

. differences of greater than~5S shoyld be.~nvestigated. Discussions

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with licensee represeritati.ves and a review of recor'ds ::indicated.*

. that although '.the. coinpad s*ons ~ere being 'performed' many of the differences gr.eater than 25% for October, November, an.9 December

. wer.:e~ not investigated. (including the October comparison for the worker. discus.sed above) or~ the investigations were not timely... l,n additio~, numerous comparisons (including the November compar.ison*

for the worker) were made wjth:~ri. incorrect formula which resulted in calculated differences of. less. than 25% when the dHferences were*

.,. actually greater than* 25% when calcti'lated using the formula in the* *

procedu'r The failure _to fo now the recommendations Of the *.

'procedure re_presents 'a weakness fri the *licensee's radiatio.n.. *

protectiQn progra This matter ~as discuss~d with the seniri *manager in _the licensee,'s r.adiafion prote*ction group, who agr*eed to

perform the comp~risons and investigations in accordante ~ith the

... procedure for October~ November, and December.* The results.. of th effort will*oe* reviewe*d iii, a future.inspection (Open Item-N * 50-231/91002-02(DRSS); 50~249/91002~02(DRSS)). The apparent root***

cause of.the probler.i' was the high work load of tfi'e staff h1C:.s lth.

. physics grou *

Find~~: The allegation.was su.bstantiated-_. *For October -~nd

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November _1990, a larger than usual discrepancy existed between the personal dose record !Jla*intained. by*~. worker and a record mai.ntained by*the license Larger than usual.*discrepancies were also ob*serv fo~ other work~r ~9wever, the ~ecent NVLAP accreditation.of the licens~e-'s TLD progra!'Jl prov.ides reaso.nable as:surance that worker dose was.~ccurately monitored with TLDs.*

~o ~iolations of ~RC requirements were identified; however, a.. weakness in the licensee's ra'diation protection program was identified..

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(Closed) Alle~~ti6n (AMS No. RIII~90~A-Oi29)

. The NRC Se.nior Res'ident Inspett~r at Dresden receiv'ed two.

allegations from* ari individua*l that *arebe.ing tracked. by one AMS Numbe One of the allegations pert~ins to the adherence to radiation protection requirements* by the Dresden. se~urity_*

force. This.allegation is disq.1ssed.below~ It was.evaluated

• during the curren~_1nspection*ihrough record review~ dis~usst&ns *

with personnel in the radiatiOn protection and security' groups, arid. through observations.in :the main RCA.* The remaining allegation is d.i scu ssed in* Inspect i ori.Reports No~* 50~237 /90028 ( DRSS); *.

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Allegation:

The alleger was requfred, *during the recent.Unit 3 refueling outage, to work in *a contaminated area without prdtecti~e

clothin Discussion

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radiatio.n specialist, the alleger contended that this was an* exampl of ar. a_tt itude of the securi.ty. force's management that radi at i.on. * *

protection requirements n:iay be igno.red *it meeting those_ requirements jeopa_rdizes. meeting 'the NRC*.se.curi_ty *requirements *

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• • The ins.pector*.revi~wof.the e'vent indicated that the alleger was posted in_~ ridn-contaminated area that. subsequently became *

contaminated because of improper handling of contami~ated equipment

. at an adjacent jobsi t Some of. the a Heger 1 s. company-issued

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, uni form a 1 so became contaminated;.however,. the *contaminat io.n.was

• very low-level'( les_s than 100 *counts per *minute per fr'isker probe a_rea).

The *alleger also stated to the -inspector that security *

~ariagement knew.that*he probably had become ~oAtaminated, *but.kep~

him at his post in order to mai.ntain* security requiTement The* *

inspector was unable*to. verify this statement in his* discussions*

• with various contract.or-and licensee personnel and.in a review of relevant records~.The records did _reveal that security guards were

.. rarely the subjects of Personal Contamination Event Reports and had not been w~itten up in the past year*in Radiological Occurrence.

. Reports whi'ch would indicate no s_ignificarit problems with security

.personnel with q~,garc;I to radiation p.. rotectio Radiaticn protection* *

supervisors* indicated that, generally, the attitude of the security for.ce toward radiation protection requirement's was good~ Securit.{

guards interviewed by the insp*ector stated that security rn.anagement had-not told or implied to them tbat radiation protection require-ments may be igl'lored *ff meeting those requirements means that* a

• security requ_i tement may not be**' met~ *

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Findings:.* The, allegation was _no~ substantiate No violation~ of NRG requirements were identified:

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Ext~rnal Exposure and tonia~ination'Control (IP 83750)

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• Statio~ dose total for 1990, ~ith contribu~ion from two ref~eling outages*

and the Radwaste Upgrade.Project, was high at 1399 perso.n-re Emergent work on.the Unit 2 cl~anup*heat exchanger system early in the year ari *the ext~nded ~nit 2 refueling outage in the later half of the *yea~ (the outage began on September 24and was scheduled fbr about 72 days, but*

extended through December) c.ontributed.to* the. high tot~ 1.. _The dose tota 1

. in 1989 was 1139 person'.'"re *

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For personal contamination events, the li~ensee* dqcumented 286 in 1990, compared to *215 in 198 Although the 1990 total is higher, the licensee's efforts in this area ~r~ still goo *

1 Exit-Meeting

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The inspector met with the i'ndividuals,: denoted in Section. 1, at *the

• cor.clusion *of the regular in'spectiqn on January 18, and after a review o the allegatioris on. January 2 The*:t.entative findings of the inspec;tion

• were summarized and certain findings were discussed with licen*see manageme~t, including the good performance of.the licerisee's.radwaste

,. shipping program (Section 5), the *continuing* efforts to. reduce the

• backlog of radwaste stored onsite (Section 5);*the start of the.project to solidify and shi'p for.the burial the waste from ~he chemic *

decontamination of*Unit 1 (Section 7), continued"storage of old drums of

- rad~aste (Section 5), the delay.in the cleanup of the sludge tank roo~

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., (Section *6), poor impienientaUon of the procedure for comp-cfring' dosimeter

• resu.lts (Section 9A),- and the.Open Item regi;\\rding the inconsistency

. Q.etween _a dewatering procedur~ and actual :p'ractice (Sectlon 5).

puring dis~ussion of the Open -lt~m. the~RC representati~es.stated that the-*

. licensee-should el)SUre that vendors ~re following thei_r own procedures*

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.~r initiating the apprcipriate change :retjuests~ The licensee a~~nowledged this cormnent an*d stated that a *review of the problem had been initiate The licensee also acknowledged the othe.r fi_ndings "and did not identify any tentative inspection.report material as proprietar,r,-

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