IR 05000010/2013008
| ML14003A140 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/03/2014 |
| From: | Robert Orlikowski NRC/RGN-III/DNMS/MCID |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| Slawinski W | |
| References | |
| IR-13-008 | |
| Download: ML14003A140 (16) | |
Text
UNITED STATES ary 3, 2014
SUBJECT:
NRC INSPECTION REPORT 05000010/2013008(DNMS) - DRESDEN NUCLEAR POWER STATION, UNIT 1
Dear Mr. Pacilio:
On October 29, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed onsite inspection activities at the permanently shutdown Dresden Nuclear Power Station, Unit 1. The inspection continued with in-office review through December 6, 2013. The purpose of the inspection was to determine whether decommissioning activities were conducted safely and in accordance with NRC requirements. The October 2013 onsite inspection focused on preparatory work for the future demolition of Unit 1 storage tanks while our onsite efforts in April 2013 evaluated overall Unit 1 safe storage (SAFSTOR) dormancy conditions. The enclosed report presents the results of this inspection, which were discussed with Mr. M. Mason by telephone on December 6, 2013.
During the inspection effort, the NRC inspectors reviewed the radiological and material condition of Unit 1 systems, structures and components for continued SAFSTOR dormancy and your audit, self-assessment and corrective action program related to Unit 1 activities. Additionally, the inspectors reviewed the work planning, work execution and associated radiological controls for the demolition of two Unit 1 radwaste storage tanks.
The inspection consisted of an examination of activities at the site as they relate to safety and compliance with the Commissions rules and regulations. Areas examined during the inspection are identified in the enclosed report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observation of work activities, independent radiation measurements, and interviews with personnel.
Based on the results of this inspection, no violation of NRC requirements was identified.
In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRC's
"Rules of Practice," a copy of this letter and the enclosed report will be made available electronically for public inspection in the NRCs Public Document Room or from the NRC's Agencywide Document Access and Management System (ADAMS), accessible from the NRCs website at http://www.nrc.gov/reading-rm/adams.html.
We will gladly discuss any questions you may have regarding this inspection.
Sincerely,
/RA by Aaron T. McCraw Acting For/
Robert J. Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Docket No. 050-00010 License No. DPR-2
Enclosure:
Inspection Report No. 05000010/2013008(DNMS)
REGION III==
Docket No.: 050-00010 License No.: DPR-2 Report No.: 05000010/2013008(DNMS)
Licensee: Exelon Generation Company, LLC Facility: Dresden Nuclear Power Station, Unit 1 (permanently shut-down)
Location: Morris, IL 60450 Dates: Onsite Inspection on April 24 - 26 and October 29, 2013; In-office review through December 6, 2013 NRC Inspectors: Wayne J. Slawinski, Senior Health Physicist Jeremy E. Tapp, Health Physicist Observer: Navid N.Tehrani, Nuclear Safety Development Program Approved by: Robert J. Orlikowski, Chief Materials Control, ISFSI, and Decommissioning Branch Division of Nuclear Materials Safety Enclosure
EXECUTIVE SUMMARY Dresden Nuclear Power Station, Unit 1 NRC Inspection Report 05000010/2013008 (DNMS)
The Dresden Nuclear Power Station Unit 1 is a permanently shut-down and defueled power reactor that has been maintained in a prolonged SAFSTOR condition. Decommissioning activities occur periodically and as warranted by radiological, material or structural condition.
This routine safety inspection reviewed the overall effectiveness of the licensees programs for continued SAFSTOR dormancy. The planning and execution of preliminary work incident to the future demolition of Unit 1 radwaste storage tanks was also reviewed.
Safety Reviews, Design Changes and Modifications
- The licensee performed adequate safety evaluations or screenings, completed design change evaluations and properly assessed decommissioning impacts of various work activities, as required by Title 10 of the Code of Federal Regulations (CFR) 50.59 (Section 1.1).
- Systems and components associated with fire protection and effluent monitoring credited in the Unit-1 licensing basis met their intended design function. Systems isolated or reconfigured in the two years preceding the inspection were evaluated by the licensee consistent with the requirements of 10 CFR 50.59 (Section 1.2).
Self-Assessments, Audits and Corrective Actions
- The licensee was generally effective in identifying issues, evaluating their consequence and implementing actions to address immediate concerns commensurate with importance to safety and risk. However, fundamental causes of continued groundwater intrusion into certain Unit-1 systems or areas had not been fully explored to allow sustained actions to prevent recurrence (Section 2.1).
- Licensee audits and other assessments were effective at identifying issues and improvement opportunities. Corrective actions associated with identified issues were entered into the corrective action program (CAP) and timely resolved in most instances (Section 2.2).
Decommissioning Performance and Status
- Unit-1 material and radiological condition met industry quality standards as areas were demarcated, controlled and conditions potentially adverse to SAFSTOR dormancy or worker safety were minimized to the extent practicable. Radiological barriers and postings satisfied regulatory requirements (Section 3.1).
- Combustibles were minimized and flammables were properly stored and controlled to prevent ignition. Fire protection water delivery, supply and detection equipment was consistent with the facility design basis (Section 3.2).
Maintenance and Surveillance
- Surveillances were performed in a manner prescribed by the licensees procedures to satisfy technical specification requirements (Section 4.1).
Occupational Radiation Exposure
- Surveys were performed adequately to identify the radiological hazards present. Area radiological controls were adequately established and prescribed in radiation work permits (Section 5.1).
- Effective radiological controls were implemented for segmentation activities conducted in preparation for radwaste tank demolition. Radiological coverage was adequate, workers were properly equipped, and followed work plans and safety protocols specified in planning documents (Section 5.2).
Report Details Summary of Unit 1 Activities During the inspection, limited decommissioning work took place as the licensees activities primarily involved routine surveillance work to support continued SAFSTOR dormancy.
Preliminary work incident to the future demolition of two Unit-1 storage tanks was conducted during the latter phase of the inspection.
1.0 Safety Reviews, Design Changes and Modifications (IP 37801)
1.1 Design Changes, Tests and Modifications a. Inspection Scope The inspectors selectively reviewed Title 10 of the Code of Federal Regulations (CFR) 50.59 screenings and/or evaluations and associated design change documentation for a variety of Unit-1 facility modifications completed in the approximate two year period that preceded the inspection. The modifications were performed in support of maintaining SAFSTOR dormancy. The inspectors reviewed the details of the licensees evaluations to determine whether safety judgments were appropriate and whether key considerations were effectively evaluated.
b. Observations and Findings The inspectors reviewed Design Change (Engineering Change (EC)) Packages dealing with: (1) configuration changes to the fire protection water supply (EC 359644);
(2) installation of a new discharge line from the radwaste area sump pump in the chemical cleaning building to the turbine building drain tank (EC 376167); and (3) improvements to the chemical cleaning building drainage system (EC 379166). The design changes were completed to address water intrusion or potential deluge issues and thereby reduce the likelihood of an uncontrolled radioactive release of liquid effluents to the environment. The fire protection configuration changes removed or mechanically isolated portions of the Unit-1 fire protection system that were no longer required. The new discharge line routed Unit 1 sump discharges to a common drain tank in the Turbine Building.
The inspectors determined that the licensee appropriately considered the inter-relationship between the modification and other systems or components potentially affected by the change. During Unit-1 walkdowns, the inspectors observed portions of those modifications and determined that they appeared consistent with the change packages. The inspectors found that safety/design change evaluations adequately assessed decommissioning impacts and were developed as part of the licensees ongoing process of system, structure and component isolation for SAFSTOR dormancy.
No findings of significance were identified.
c. Conclusions The licensee performed adequate safety evaluations or screenings, completed design change evaluations and properly assessed decommissioning impacts of various work activities, as required by 10 CFR 50.59.
1.2 Decommissioning Activities a. Inspection Scope The inspectors sampled modifications and/or repair activities besides those described in Section 1.1 above to determine if the licensee altered systems, structures or components (SSCs) without the necessary safety reviews. The inspectors selectively sampled SSCs described in the Unit-1 Defueled Safety Analysis Report (DSAR) to determine if configurations and capabilities aligned with those described in the design basis.
b. Observations and Findings The inspectors verified that components associated with fire protection and effluent monitoring credited in the Unit-1 licensing basis (DSAR, Revision 6) met their design function. The licensee isolated or modified portions of these systems and components as evaluated through the 10 CFR 50.59 process, and demonstrated that the systems retained their intended function or otherwise the changes did not adversely impact safety function. The inspectors also found that methods implemented to reduce water intrusion into Unit-1 structures were generally successful with some exception, as described in Section 2.1.
No findings of significance were identified.
c. Conclusions Systems and components associated with fire protection and effluent monitoring credited in the Unit-1 licensing basis met their intended design function. Systems isolated or reconfigured in the two years preceding the inspection were evaluated consistent with the requirements of 10 CFR 50.59.
2.0 Self-Assessments, Audits and Corrective Actions (IP 40801)
2.1 Identification, Resolution and Prevention of Problems a. Inspection Scope The inspectors reviewed numerous Unit-1 related corrective action program (CAP)
documents generated in 2012 through March 2013, to determine if a sufficiently low threshold for problem identification existed, to determine the quality of followup evaluations including extent of condition, to assess safety significance and to determine whether the licensee assigned timely and appropriate prioritization for issue resolution.
Inspector review focused on the scope and depth of the licensees evaluations to determine whether the fundamental cause of an issue was identified to allow corrective action to be properly targeted. Corrective action program documents reviewed by the
inspectors encompassed a range of issues related to fire protection components, effluent monitoring, groundwater intrusion and radiological controls. The CAP documents reviewed by the inspectors are listed in the attachment to this report.
b. Observations and Findings The inspectors determined that issues related to Unit-1 were identified at a low threshold irrespective of the subject matter and documented in the CAP system. Issues were effectively screened, prioritized and evaluated commensurate with safety significance in most instances. The scope and depth of evaluations was adequate in that they addressed the significance of issues and assigned a course of corrective action to address any immediate concern. However, the inspectors noted that remedial actions did not always address the fundamental problem so as to prevent recurrence.
Specifically, in December 2010, the Unit-1 circulating water system piping leaked and caused the Unit-1 condenser hotwell basement to flood. Groundwater and water from a steam heating system underground line leak infiltrated the circulating water system because the piping had likely degraded during the prolonged SAFSTOR dormancy period. Corrective actions focused on plugging the circulating water pipe leak that caused the hotwell basement to flood and isolating the steam heating system to address the immediate flooding issue. However, actions were not taken to rectify suspected degradation of the circulating water piping system, or to establish a program for routine monitoring of underground piping for water intrusion. The inspectors noted that water intrusion into the circulating water system reoccurred in 2013, as did similar problems in the dry waste storage pits. While the water intrusion problems did not adversely impact the environment as radioactively contaminated water did not seep into the ground, the issues burdened radwaste systems unnecessarily because the water needed to be processed before discharge.
No findings of significance were identified.
c. Conclusions The licensee was generally effective in identifying issues, evaluating their consequence and implementing actions to address immediate concerns, commensurate with importance to safety and risk. However, fundamental causes of continued groundwater intrusion into certain Unit-1 systems had not been fully explored to allow sustained actions to prevent recurrence.
2.2 Audits and Self-Assessments a. Inspection Scope The inspectors reviewed Unit-1 related audits conducted by the licensee since 2011, and the results of a 5-year structural inspection of Unit-1 conducted by a contractor in 2010.
The review was performed to determine whether these evaluative methods were effectively managed, were of sufficient rigor to assess the subject areas and to determine whether identified issues were captured in the CAP and being addressed.
b. Observations and Findings The inspectors found that a 2011 Nuclear Oversight audit of Unit-1 systems and programs was of sufficient scope/depth to determine overall adequacy of SAFSTOR dormancy conditions. Corrective actions associated with identified issues were entered into the CAP and timely corrective actions were executed with one exception. The exception involved an audit identified deficiency for lack of timely actions to implement a Unit-1 groundwater intrusion monitoring plan, as discussed in Section 2.1 above. The audit report documented that the corrective action due date had been extended several times over a six month time frame. Moreover, the inspectors noted that the licensee had not implemented the monitoring plan for more than a year after the recommended action was developed. The inspectors determined that the most recent 5-year structural inspection of Unit-1 was comprehensive, thorough and identified a variety of deficiencies which were being adequately addressed by the licensee. The deficiencies involved mostly cosmetic issues which did not impact structural integrity of SSCs important to the SAFSTOR condition. The inspectors also noted that specific actions taken or planned to address each deficiency was not well documented; therefore, NRC verification of individual corrective actions could not be accomplished.
No findings of significance were identified.
c. Conclusions Licensee audits and other assessments were effective at identifying issues and improvement opportunities. Corrective actions associated with identified issues were entered into the CAP and timely resolved in most instances.
3.0 Decommissioning Performance and Status Review (IP 71801)
3.1 Unit 1 Facility Tours/Walkdowns a. Inspection Scope The inspectors conducted extensive tours of Unit-1 facilities during the inspection to observe radiological and material condition and to assess the overall adequacy of SAFSTOR dormancy. During these walkdowns, the inspectors evaluated area radiological condition, radiological control and associated posting/labeling, and reviewed the overall physical condition of systems, structures and components important to long term layup of the facility.
b. Observations and Findings Radiological controls were sound as all areas were clearly demarcated, posted and barriers in-place as prescribed by 10 CFR 20 and the licensees procedures. Most areas were radiologically benign as contamination levels were low and area radiation levels were well controlled. High radiation areas were kept to a minimum. Material condition was maintained to industry quality standards and overall was adequate given the age of the facility and extended dormancy period. Material condition issues were primarily cosmetic and did not appear to impact the structural integrity of SSCs important to long-term dormancy of the facility.
No findings of significance were identified.
c. Conclusions Unit-1 material and radiological condition met industry quality standards as areas were demarcated, controlled and conditions potentially adverse to SAFSTOR dormancy or worker safety were minimized to the extent warranted. Radiological barriers and postings satisfied regulatory requirements.
3.2 Fire Protection Walkdown a. Inspection Scope The inspectors toured various areas of Unit-1 to observe control of combustibles and flammables, and to review the availability and material condition of fire protection related equipment.
b. Observations and Findings Combustibles were minimized and flammables were properly stored and controlled to prevent ignition. The Unit-1 diesel driven fire pump and associated starter batteries were in a state of readiness as documented in surveillances recently completed by the licensee. Problems associated with the fire pump identified by the license in mid-2012 were rectified through an overhaul of the pump motor. The inspectors selectively verified through observation that fire protection water delivery, supply and detection equipment was consistent with facility design basis as provided in Revision 6 of the DSAR.
No findings of significance were identified.
c. Conclusions Combustibles were minimized and flammables were properly stored and controlled to prevent ignition. Fire protection water delivery, supply and detection equipment was consistent with facility design basis.
4.0 Maintenance and Surveillance (IP 62801)
4.1 Review of Preventative Maintenance and Surveillance Documents a. Inspection Scope The inspectors selectively reviewed various Unit-1 surveillance activities completed by the licensee in the approximate twelve month period that preceded the inspection to assess compliance with technical specifications and the licensees procedures.
b. Observations and Findings Licensee records demonstrated that surveillances related to Unit-1 fire protection systems and for cold weather preparations were completed consistent with procedural requirements. The surveillances included written instruction and precautions for
performance of the surveillance, appropriate acceptance criteria along with references to vendor literature as is the industry norm. Surveillance acceptance criteria were met for those surveillances reviewed or otherwise were documented, resolved and subsequently closed-out through remedial action.
No findings of significance were identified.
c. Conclusions Surveillances were performed in a manner prescribed by the licensees procedures to satisfy technical specification requirements.
5.0 Occupational Radiation Exposure (IP 83750)
5.1 Review of Radiological Controls, Barriers and Conditions a. Inspection Scope The inspectors conducted Unit-1 facility tours including the Unit-1 sphere, the fuel building and the chemical cleaning building to observe radiological conditions, discuss safety and to assess the potential impact of future work activities on maintaining SAFSTOR dormancy. During the walkdowns, the inspectors evaluated material condition and housekeeping, area radiological condition, radiological access controls and associated posting/labeling, and assessed the overall condition of systems, structures and components that support long-term SAFSTOR of Unit-1.
b. Observations and Findings The inspectors found that controls associated with Unit-1 facilities included administrative controls necessary to prevent unauthorized entry into contaminated areas and high radiation areas. The inspectors determined that the Dresden radiation protection organization completed routine area surveys and surveys to ensure work specific radiological hazards were adequately identified, controlled and posted in accordance with 10 CFR 20 requirements. The inspectors also determined that licensee staff analyzed an appropriate percentage of smear surveys and air samples for the presence of transuranic isotopes consistent with industry practices and the licensees procedure.
No findings of significance were identified.
c. Conclusions Surveys were performed adequately to identify the radiological hazards present. Area radiological controls were adequately established and prescribed in radiation work permits.
5.2 Demolition of Outdoor Radwaste Tanks a. Inspection Scope On October 29, 2013, the inspectors evaluated the radiological and industrial safety
controls during work affiliated with the demolition of Unit-1 outdoor radwaste tanks (T-104 A/B). On that day, the licensee was segmenting (cold cutting) tank feed and return lines both external and internal to the tank pump house. The inspectors observed field conditions, discussed job safety with workers and evaluated compliance with the requirements specified in the radiation work permit (RWP) and those provided in the as-low-as-is-reasonably-achievable (ALARA) Plan.
b. Observations and Findings Tanks T-104 A/B and associated piping were characterized by the licensee as Level 3 alpha radioactivity areas with loose alpha contamination levels approaching 100,000 disintegrations per minutes (dpm). As a result, rigorous engineering controls were established to prevent worker intakes and to control the potential spread of contamination during system breach. The inspectors found that workers were equipped with the proper respiratory protection equipment, glove bags were used as intended as were portable high efficiency particulate air (HEPA) filtration units specified in planning documents. Air sampling was performed in work areas and to monitor worker breathing zones until the effectiveness of airborne controls was demonstrated and the sampling subsequently relaxed.
The inspectors observed that appropriate radiological coverage was provided by radiation protection staff and that work package compliance was achieved with one minor exception which the licensee rectified. The exception related to an adjustment to the RWP and ALARA Plan package to clarify breathing zone sampling. The inspectors found that appropriate methods were deployed to reduce the potential for airborne radioactivity and for contamination control. The inspectors found that personnel were aware of job controls specified in planning documents and demonstrated proper radiological safety protocol.
No findings of significance were identified.
c. Conclusions Effective radiological controls were implemented for segmentation activities in preparation for radwaste tank demolition. Radiological coverage was adequate, workers were properly equipped and followed work plans and safety protocols specified in planning documents.
6.0 Exit Meeting The inspectors presented the preliminary results of the April 2013, onsite inspection to Mr. Marik and other Dresden staff on April 26, 2013. On December 6, 2013, one of the inspectors discussed by telephone the final inspection results with Mr. Mason. The licensee acknowledged the results presented and did not identify any of the documents reviewed by the inspector as proprietary.
ATTACHMENT: SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED
- S. Marik, Station Plant Manager
- H. Bush, Radiation Protection Manager
- M. Mason, Unit 1 Project Manager
- B. Kapellas, Operations Director
- P. OBrien, Regulatory Assurance R. Christensen, Unit 1 Senior Project Manager, Demark, Inc H. Datil, System Engineer
- Denotes participation in April 26, 2013 exit meeting.
INSPECTION PROCEDURES (IPs) USED IP 37801 Safety Reviews, Design Changes and Modifications at Permanently Shutdown Reactors IP 40801 Self-Assessment, Auditing and Corrective Action at Permanently Shutdown Reactors IP 71801 Decommissioning Performance and Status Review at Permanently Shutdown Reactors IP 62801 Maintenance and Surveillance at Permanently Shutdown Reactors IP 83750 Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED Opened & Closed None PARTIAL LIST OF DOCUMENTS REVIEWED Dresden Nuclear Power Station, Unit 1, Defueled Safety Analysis Report, Revision 6 Apparent Cause Report, Dresden Unit 1 Circulating Water Line Leak (CR 1153623), dated February 1, 2011 CR Database List for Dresden Unit-1, January 2012 - March 2013 Nuclear Oversight Audit Report, Dresden Unit 1, dated December 6, 2011 DDP 03, Administrative Controls for Unit 1 Structures During Periods of Low Temperatures, Revision 03 DDP 05, Control of Decommissioned Plant Equipment for Dresden Unit 1 SSCs, Revision 17 Engineering Change No. 376167, Install New Discharge Line from Radwaste Area Sump Pumps in Chemical Cleaning Building to Unit 1 Turbine Building Drain Tank, Revision 001 Attachment
Engineering Change No. 359644, Unit 1 Fire Protection Water Supply Configuration Changes for SAFSTOR Dormancy, Revision 002 Engineering Change No. 379166, Unit 1 Chemical Cleaning Building Drainage System, Revision 001 Dresden Unit 1, Five Year Structural Inspection Report, Volumes 1 and II, November 2010 Surveillance for MA-DR-MM-5-46000, Inspection and Preventive Maintenance on Unit 1 Service Air Compressor, April 11, 2011 and Associated EC 384021 for Air Compressor Overhaul Surveillance Documents for MA-DR-MM-5-46000, Inspection and Preventive Maintenance on Unit 1 Service Air Compressor, February 1, 2013 Surveillance Documents for DOS 0010-20, Cold Weather Operations for Unit1 and Out Buildings, December 15, 2012 Surveillance Documents for DFPS 4123-01, Unit 1 Diesel Fire Pump Operability, dated January 28, and February 25, 2013 Surveillance Documents for DES 8300-13, Unit 1 Diesel Fire Pump and Starting Batteries Surveillance and Maintenance, dated July 14, 2012, October 22, 2012 and January 8, 2013 CR 01366729, Unit 1 Fire Line Leak, dated May 15, 2012 CR 01362953, Leak on Unit 1 Fire Header, dated May 5, 2012 CR 01406623, Maintenance Rule Functional Failure, dated August 7, 2012 CR 01398213, Unit 1 Diesel Fire Pump Failed Annual Capacity Surveillance Test, dated August 7, 012 CR 01450613, Unit 1 Water Found in Radwaste DAW Storage Pits, dated December 5, 2012 CR 01506055, Water Found in Abandoned Unit 1 Circulating Water Inlet Lines, dated April 24, 2013 CR 01419467, Demolition of Unit 1 T104A/B Tank Farm, dated September 28, 2012 CR 01384765, Level 3 Alpha Area Identified, dated July 2, 2012 CR 01445790, Issues Identified in Unit 1 Chemical Cleaning Building, dated November 29, 2012 CR 01580664, Clarification of RWP Requirement, dated November 4, 2013 Air Sample Results for T-104 Tank Farm and Pump House Work, dated October 28 7 29, 2013 RWP 10014452, Revision 0, 2013 Unit 1 Safe Store Activities ALARA Plan for RWP 10014452, dated August 22, 2013
Teledyne Brown Engineering, 10 CFR Part 61 Analyses for Tanks T-104 A/B, dated May 14, 2013 LIST OF ACRONYMS USED ADAMS Agencywide Document Access and Management System ALARA As-Low-As-Is-Reasonably-Achievable CAP Corrective Action Program CFR Code of Federal Regulations CR Condition Report DNMS Division of Nuclear Materials Safety DNPS Dresden Nuclear Power Station DSAR Defueled Safety Analysis Report EC Engineering Change HEPA High Efficiency Particulate Air NRC U.S. Nuclear Regulatory Commission RADWASTE Radioactive Waste RPT Radiation Protection Technician RWP Radiation Work Permit SAFSTOR Facility in Safe Storage Condition SSC System, Structure and Component 3