ML17174B141
| ML17174B141 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/10/1992 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17174B138 | List: |
| References | |
| 50-237-91-39, 50-249-91-43, NUDOCS 9202180094 | |
| Download: ML17174B141 (17) | |
See also: IR 05000237/1991039
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report Nos. 50-237/91039(DRP); 50-249/91043(DRP)
Docket Nos. 50-237; 50-249
Licensee:
Conunonwea lth Edi son Company
Facility Name:
Dresde~ Nuclear Power Station, Units 2 and 3*
Inspection At:
Dresden Site, Morris, IL
- .
Inspection Conducted:
December 7, 1991, through January 17, 1992
Inspectors: W. Rogers
- M. Peck
F. Brush
P. Lougheed
M. Kunowski
Approved By:
~~ ~
.
B. L. Burgess, Chief
Projects Section 18
Inspection Sununary
Inspection from December 7. 1991 through January 17. 1992 (Report Nos. 50-
237/91039CDRPl: 50-249/91043CDRPll.
Areas Inspected: Routine unannounced safety inspection by the resident and
regional inspectors, and an Illinois Department of Nuclear Safety inspector,
of licensee action on previously identified items; operational safety;
licensee event reports; monthly maintenance; monthly surveillance; followup of
events; refueling activities; radiological controls; radwaste issues;
management meetings; s.afety assessment; and quality verification and regional
requests.
Results:
Two violations were identified (section 2.e and 9).
One open item
was identified (section 12).
Plant Operations - Licensed operators performed their control room duties
adequately.
Fuel handling personnel performed their duties significantly
better than in previous inspection periods.
Fuel handling personnel were more
attentive and stopped when th~ situation warral"!t.ed._ Fu.e] handling supervision
was present and properly involved.
Equfpment-proble-ms were identified and
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9202180094 920211
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~DR
ADOCK 0500~~~~
resolved prior to continuation of fuel handling activities.
Some housekeeping
problems were observed.
Maintenance/Surveillance - Maintenance and test personnel performed their
duties adequately.
No new programmatic weaknesses were identified.
Radiological Protection - A communication weakness between two critical
supervisors, the radwaste operations engineer and the radiation protection
manager, was apparent (section 10). Weaknesses in the contamination control
portion of the radiation protection program were identified (section 3).
Also, worker implementation of established radiological practices were poor on
more than one occasion with a violation identified with multiple examples
(section 9). Slow progress was observed with several major radwaste projects.
Improvements in reducing station overall dose through good ALARA conunittee
involvement continue to be observed.
Safetv Assessment and Quality Verification - Numerous corrective actions are
being proposed in an integrated way to improve overall station performance.
Since most of these corrective actions have not been implemented, their impact
cannot be determined at this time. A weakness was identified in the 10 CFR
50.59 review process (section 2.c).
Some weakness was observed in the
timeliness associated with station response to a corporate reactivity
assessment (section 12.c). Also, the formal assessment report was long in
being issued.
2
.*
1.
DETAILS
Persons Contacted
Conuuonwealth Edison Company
- C. Schroeder, Station Manager
L. Gerner, Technical Superintendent
- J. Kotowski, Production superintendent .
D. Van Pelt, Assistant Superintendent - Maintenance
J. Achterberg, Assistant Superintendent - Work Planning
- G. Smith, Assistant Superintendent - Operations
M. Korchynsky, Operating Engineer
8. Zank, Operating Engineer
- R. Stobert, Operating Engineer
- T. Mohr, Operating Engineer
M. Strait, Technical Staff Supervisor
- D. Ambler, Radiation Protection Manager.
- K.
Koci~ba, Quality Assurance Superintendent
- D. Lowenstein, NRC Coordinator
- K. Deck, On-Site Nuclear Safety
- B. Viehl, Site Supervisor
- R. Radtke, Regulatory Assurance Supervisor
- B. Geier, Mechanical M~intenance Master
- J. Paczolt, Station Reactor Engineer
- Denotes those attending the exit interview conducted on
January 17, 1992.
The inspectors also talked with and interviewed several other licensee
employees, including members of the technical and engineering staffs;
reactor and auxiliary operators; shift engineers and foremen;
electrical, mechanical, and instrument maintenance personnel; and
security personnel .
. 2.
Previously Identified Inspection Items {92701 and 92702)
a.
b.
(Closed} Open Item (50-237/88009-01; 50-249/88011-0l(DRSS: Overtime guidelines for rad/chem technicians from Generic Letter 82-12. The licensee revised the overtime policy as discussed in the NRC enforcement conference report 50-249/91041. Therefore, this matter is considered closed. (Open} Violation (50-237/91016-02(DRP}}: Lack of periodic calibration requirements associated with primary containment damper pressure switches. On July 15, 1991, a notice of violation was issued on this matter with a subsequent licensee response. A review of the licensee response identified a need for clarification of the corrective actions. This matter remains open pending the licensee's response and further inspector followup . 3
c .
(Closed) Unresolved Item (50-237/90022-02(DRP)):
- Appropr*iat~ne.ss_
of a control room habitability 10 CFR 50.59 safety evaluation. The licensee performed a*control room habitability analysis in. 1981 in response to a NUREG-0737 a*ction item~ The analysis* - acceptance criteria was from the NRC Standard Review Plan (SRP). One* of the acceptance criteria was no more. than' 30 rem thyroid _. dose to control room operators during an acctdent. * Th_e analysis concluded that the acceptance c~iteria was *met; One of ~he analysis assumptions was operator initiation of* the control room emergency control room ventilation system (CR~VS) eight hours after the accident .. Subsequently, the NRC acc.epted the analysis in a safety evaluation report (SER) dated M_ay 11, 1983. However, the analysis was not incorporated into the lice.nsee's safety analysis report {SAR).
~- -~ In 1987, the lfcensee identified a discrep'ancy between the control room habitability analysis and Technical Specifications de~ling with absorption*efficiency of*.the standby gas*treatment system (SGTS). *Also, an assumption for control room~irifiltration was identified to be incorrect.
- *
' . The licensee re-performed the analysis using the correct information with a resulting thyroid dose in excess of the SRP acceptance criteria. Subsequently, the licensee changed the assumption for operator initiation of the emergency control room ventilation system from 8 hours to 40 minutes reduc-i ng the thyroid dose to an acceptable 29.33 rem.
A licensee 10 CFR 50.59 safety evaluation dated April 4, 1988, concluded that the new analysis did not represent an unreviewed safety question. The bases for the conclusion was meeting the SRP dose acceptance criteria, completion of an electrical load analysis showing that loading the CREVS onto emergency power within the 40 minutes was acceptable and changing operating procedures to reflect the 40 minute assumption. This revised analysis was incorporated into the SAR in June 1988. 10 CFR 50.59 requires proposed changes increasing the consequences of an accident previously evaluated in the safety analysis report to be classified as unreviewed safety questions. 10 CFR 50.59 further requires NRC approval on all unreviewed safety questions before implementing the change. 10 CFR 50.7l(e} requires licensees to periodically update the SAR with analysis either submitted to the NRC or pursuant to NRC requirements. All licensee safety evaluations performed, to either support requested license amendments or to support conclusions that changes did not involve unreviewed safety questions, are to be included in the SAR update . 4
d.
.
- .,
The inspector reviewed the 1988 safety evaluation associated with .changing the habitability analysis assumptions. Afte,r 1nittal review the inspector referred the assumption change from 8 hours to 40 minutes to NRC licensing personnel for technical evaluation. NRC licensing personnel concluded in a July 3, 1991, evaluation that the time. reduction was acceptable.
Through further review of the 1988 safety evaluation, intervie*w of personnel currently associated with the licensee's safety evaluation process and review of the licensee's current safety evaluation procedur;es the inspector determined: (1)
- A weakness in the licensee's safety evaluation process was
present in 1988. When the licensee performed the 1988 safety evaluation it was with .no knowledge of the spe.cif.ic criteria the NRC reviewer initially used in judging the acceptability of the 8 hour operator action. This
-information was not included in the SRP or the SER. Also, the safety evaluation was performed with full knowledge of the previous 1981 analysis and li~ensing actions. Therefore,* ~hJ failure to properly update the SAR did not inhibtt the licensee's safety evaluation process. (2) Though adequate in many respects, the licensee's current safety evaluation procedures and training did not discuss calculation as~umptions. Also, when the same.set of . circumstances regarding the time reduction were recently p~sed to the licensee, personnel did not netessarfly conclude an unreviewed safety question existed. Therefore, the weakness in the licensee's safety evaluation process persists. (3) No unreviewed safety question existed when the licensee _changed the calculation assumption from 8 hours to 40 minutes. One of the conditions of an unreviewed safety question is the change must involve matters as described in the SAR, not all licensing bases documents. By not changing the SAR in 1983 to include the analysis, legally no unreviewed safety question could exist. (4) The licensee's failure to incorporate the 1981 analysis or the 1983 NRC SER into the SAR is a previously recognized generic problem. The licensee conunitted in earlier correspondence to address this deficiency through an ongoing SAR re-baseline program.
This matter is considered closed. (Closed) Violation (50-237/89025-02(DRSS}; 50-249/89024-02(0RSS)): Failure to perform the SPING-4 low range noble gas monitor calibrations in accordance with Technical Specification ~equirements. The vi'olation resulted from the use of very low 5
..
activity sources for calibrations. Subsequently, the.licensee revised the calibration procedure to ensure that radioactive sources used for the calibration were of sufficient activity and traceable to the National Institute of Standards and Technology. Future calibrations using this procedure will be reviewed during routine .inspections by regional specialists. Therefore; this item. is considered closed.
e. (Open) Violation (50-237/91024-0l(DRP)); Failure to properly calibrate main s~eam line radiation monitors. After considering the circumstances surrounding the 1 fcen.see improper setting of the radiati.on monitors the NRC concluded a violation did occur. However, the violation did.not warrant escalated enforcement action. No violations or deviations were identified in this area~ 3. Operational Safetv Verification C71707l The inspectors reviewed the fatil ity for conformance* with the 1 icense and regulatory requirements and that the licensee's management control system was carrying out its responsibilities for-_safe operatic~. On a sampl i ng basis, . the inspectors observed* cont ro 1 ro~>m. activities for proper staffi*ng; coordination of plan_t activities; following procedures; meeting the Technical Specifications; operator cognizance of plant parameters and ala.rms; electrical power configuration; and station management presence in-the control room. Control room logs were reviewed for accuracy and completeness. Tours of accessible portions of the facility were routinely conducted to assess worker adherence to radiation controls and the site security plan. Also, housekeeping and plant cleanliness were assessed. Significant observations while conducting tours were: a. The Unit 3 shield plugs and strong backs were observed on top of the installed Unit 2 shield plugs. The inspector inquired about the reactor building structural integrity with this much weight on the plugs. The licensee initiated a deviation report on the matter and evaluated that this configuration was acceptable. b. Several components within the drywell were observed where the c. sealtite (protective flexible rubber coated conduit) was either ~ extremely loose at the component connection, bent, torn or punctured at the component connection, or physically pulled away from the component connection. Seven work requests were initiated by the licensee to evaluate and repair the sealtite. Oil barrels and other flammable material blocking the fire extinguisher were observed in the 2/3 diesel room airlock. The 1 fcensee immediately removed the .mater.ta] . 6
.*
d *
e. On Decemb~r 5, 1991, the iris~ector noticed numerous portabl~ _ frisker alarm switches off in the turbin*e and reactor buildings. * Also, the posted frisking instructions were modified (taped over) to eliminate the recognifion of the* alarm function. Normally,. portable friskers are set to alarm audibly and visually when the-contamination count rate exceeds one hundred aliove background.
Interviews with radiation protection personnel revealed that historically plant locations experience a wide variation in . background levels as the reactor power level changes. Therefore, alarms have been negated to eliminate repetitive adjustments; This practice* was not procedurally documented as a recognized practice wi:thin the radiological_ controlled boundaries . . The inspector noted:
- Both units were shutdown with no power dependent areas
presently in the plant. Therefore, the reasoning for negating the alarm did' not presently exist.- That total reliance on count rate meter observation could lead to an excessive number of plant ~quipment and personnel contaminations by those individuals not thoroug_hly trained * in the interpretation of increasing count rate as seen* on the meter. On December. 17, 1991, the inspector observed se~eral work areas in and around radiation boundaries that were below standard work practices for radiological work are~s. At elevation 488' of the Unit 3 turbine building, near the condensate booster pump minimum flow recirculation valve, tools were laying across the radiation boundary contacting both clean and contaminated areas simultaneously. At elevation 517' of the Unit 3 reactor building, near the west control rod driv~ hydraulic accumulator bank, hoses and power cables laying. across the radiation protection boundary were not secured to preclude them from being pulled from the contaminated to the clean area. At elevation 517' of the Unit 3 reactor building, near the east low pressure coolant injection hatch, air line hoses crossing the radiation protection boundary were not taped or secured at the boundary in any manner. At elevation 613', on north side of the Unit 3 reactor building refuel pool, a continuous atmospheric monitor {CAM) sample hose running across a contaminated boundary of the 7
floor was not secured to preclude it from being pulled from ~ the contaminated to the clean area. The inspector discussed these observations with radiation protection personnel. Radiation protecti-0n p~rsorinel indicated that although the observed activities were common practice, *such practices were not incorporated into station procedures~
. . . The inspector was concerned that personnel performing work related activities within radiation protection bounda~ies, were not instructed on the conduct of work activities in and around those protected boundaries. Such continued practices.could lead to an increase in contaminations to plant personnel and non-contaminated plant areas.
Specific inspections of select engineered safety features (ESF) were performed. The ESFs were reviewed for proper valve and electrical * alignments. Components were inspected for leakage, proper lubrication, abnormal corrosion, proper ventilation and cooling water supply availability. Tagouts and jumper records were reviewed for accuracy where appropriate. The ESF systems reviewed were: Unit 3 -: Isolation Condenser (including drywell inboard isolation valves)
- One Target Rock and Four Electromagnetic Relief Valves - Inboard and Outboard Main Steam Isolation Valves - Standby liquid Control System - Selected. piping and components within the Primary Containment No violations or de~iations were identified in this area. 4. licensee Event Reports Followup (90712 and 92700) Through direct observations, discussions with licensee personnel, and review of records, the following event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications. (Open) lER 237/91004, Reactor scram on high steamline radiation caused by resin intrusion from the reactor water cleanup system (RWCU). The licensee's lER delineated six long term corrective actions to be accomplished. Two of the corrective actions, inspection of all RWCU demineralizer underdrains and installation of a new type of RWCU post- strainer, were outstanding at the end of the inspection period. The lER will remain open until the two remaining long term corrective actions are completed. No violations or deviations were identified in this area. 8
5.
- Monthlv Maintenance Observation C62703l
Station maintenance activities affecting the safety-related and important to safety systems and components listed below were observed/reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, and industry codes or. standards and in conformance with Technical Specificati<>ns. The following items ~ere considered during this r~view: the limiting conditions for oper~tion were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrations were performed prior to returning components or systems fo service; quality control records were maintained; activities were .accomplished. by qualified personnel; parts and materials used were properly certified; .radiological controls were implemented; and, fire prevention controls, were implemented. Work requests were reviewed to determine* status of' * outstanding jobs and to assure that priority was assigned to safety- related equipment maintenance affecting system performance. The following maintenance activities were observed and reviewed: Unit 2 - Unit 2 250 Vdc Battery Addition - Unit 2/3 Diesel Generator Cooling Water Pump Suctio*n Line Replacement Unit 3 - 3A/B/C/D CCSW Pump Discharge ls~lation Valve Rebuild - 3-1001-lB Shutdown Cooling Isolation Valve Rebuild - 3-1501-26B LPCI B Loop Inboard Manual Isolation Valve Rebuild - Standby Liquid Control Piping Heat Trace and Re-Insulation - Unit 3 Refuel Grapple Repair - Unit 3 Condensate Booster Pump Bypass Valve Rebuild No violations or deviations were identified. 6. Monthlv Surveillance Observation (617261 Surveillance testing required by technical specifications, the FSAR,* ,maintenance activities or modification activities were observed and/or reviewed. Areas of consideration while performing observations were procedures adherence, calibration of test equipment, identification of test deficiencies, and personnel qualified for the task. Areas of consideration while reviewing surveillance records were completeness, proper authorization/review signatures, tests results properly dispositioned, and independent verification documented .. The following activities were observed: 9
Unit 3 - DOS 700-1, SRM Rod Block Functional. Test - DOS 700-3, SRM Detector Position Rod Block Functional Test - DOS 700-6, SRM Functional Test Prior to Core Alterations * - DOS 300-4, Control Rod Drive Timing - DOP 9900-71, Control Rod Drive Friction Testing - DES 6600-08, 2/3 Diesel Generator 18 Month Maintenance No violations or deviations were identified. 7. Events followyp (93702) During the inspection period, the licensee experienced several events, some of which required prompt notification of the NRC pursuant to 10 CFR 50.72. The inspectors pursued the events onsite with the licensee* and/or NRC officials. In each case, the inspectors reviewed that the ltc~nsee notification was accurate and timely, that the licensee was taking prompt and appropriate actions~ and that activities were conducted within regulatory requirements. The specific events were as follows: January 2, 1992 Loss of shutdown cooling on Unit 3 due to apparent spurious high temperature signal January 13, 1992 Loss of shutdown cooling on Unit 3 due to relay failure in the high reactor temperature isolation circuity. No violations or deviations were identified. 8. Refyeljnq Activities (60710) Inspectors closely monitored refuel activities associated with preparations for the Unit 3 core reload and core alterations subsequent to those preparations. The inspectors verified the licensee's compliance with license requirements and procedures conunensurate with reactor core alteration refueling activities. Inspection activities included licensee's compliance to the procedures and surveillances as listed below: - DFP 800-1 Master Refuel Procedure - OAP 7-7 Conduct of Refueling Operations - DOS 800-1 Refueling Interlock Check - Special Procedure for Handling Damaged Fuel Bundle Bails Significant observations associated with refuel activities are discussed below. a. The inspector witnessed the proper movement of the two fuel assemblies with damaged fuel bundle bails to new storage locations within, the spent fuel_ p_ool. The new locations did not present any encumbrances to the-forthcomin*g reload~activities. 10
...
b. On December 27, 1991, the refuel grapple hoist became mechanically and electrically disabled in the full up position with a fuel assembly loaded onto the grapple. Station management as well as other licensee personnel involved, discussed, planned, and executed those steps necessary to remove the fuel assembly from the disabled grapple. Inspectors witnessed judicious application of the heightened level of awareness program as well as sound fundamentals in the areas of radiation protection and nuclear engineering support. c. The inspectors followed the refuel bridge grapple hoist repairs and subsequent replacement of the counter-torque circuit and a grapple hoist braking logic card. Good trouble shooting techniques and proper application of work procedures were witnessed.
d. On December 24, 1991, inspectors witnessed the control room operators' response to spiking sourc~ range monitors (SRMs) 21 and 23 while fuel movement was in progress. Control room operators ordered an inunediate stop to fuel movements. Clear and concise conununications between the refuel bridge and the control room were heard. e. f. Trouble shooting was inconclusive until January 5, 1992. At which time electricians discovered that both the refuel bridge and the control rod drive undervessel work platforin were powered at the same 480 VAC breaker cubicle. A temporary alteration was authorized t~ lift the power leads to the control rod drive platform at the breaker cubicle diminishing the noise signal between the control rod drive platform power cable and the SRM detector cables. During grapple repair activities the inspector noted the lack of a tool/material accountability log around the spent fuel pool and refuel bridge. This situation was reported to operations management. Following additional discussions with plant management the licensee initiated new administrative controls which included an accountability log. During actual reactor vessel reload (between January 5 and January 10, 1992) inspectors observed good verbal conununications between crew members and the foreman, and between refuel bridge personnel and the control room communicators. Also, good application of dual verification of critical steps associated with fuel pool fuel assembly location, latching and unlatching of fuel assemblies, and the placement and unlatching of the fuel assembly within the reactor vessel was observed. Inspectors also audited and inventoried refuel bridge tools, equipment.Bnd other material controlled under Dresden Administrative Procedure-(DAP)-7""-35, "Foreign_Mater_ials Exclusion 11
- .
9.
. Program for* the Unit 2/3 Refueling Floor (Access Control Points to the Foreign Material Exclusion Areas)n. Inspectors found material logs to be current and in order, and the materials within the exclusion area secured by lanyard or otherwise stored inside tool or equipment boxes.
g. On January 7, 1992, *during a routine .. ,_check a ;~eactor engineer determined that the rod worth minimizer (RWM) -was* *not in* service contrary to administrative procedures. Operations was immediately notified and fuel handling operations_ suspende_d ..
- .
Personnel initiated a review into how this occurred and determined that the RWM had -been taken out of service to allow _performance of a refueling interlock surveillance and had no~-been returned to service following.completion of the surveillance. Further review determined that the administrative requireme.nt_ was vague.and * * poorly 1 ocated. within the refueling procedures*~ This particular administrative requirement was due to*a vendor .recommendation and not a 1 icense or regulatory requirement.
Fuel handling activities proceeded after the RWMwas returned to service, all refuel prerequisites verified to.-be met and. refuel checklists revised to require the RWM tn service before moving fuel. No violations or deviations were identified in this area * Radiological Controls (IP 83750) The station dose for 1991, a year that inc 1 uded 72 .. days of a scheduled refueling outage (Unit 3) and approximately 230 days of non-scheduled outage (Units 2 and 3), was 1005 person-rem. This is the lowest station dose since 1973, and partly reflects the recent, overall good performance of the station's ALARA group regarding preplanning of work activities (Inspection Report Nos. 50-237 /90026(DRSS); 50-249/90025(DRSS)). An examp.le of this was the removal of the Unit 2 reactor cavity bulkhead drain line prior to painting the 4th floor of the drywell. On November 26, 1991, while working in the dry well on a check valve, a maintenance worker became concerned about proper positioning of his dosimetry. He moved his dosimeters from his* chest to his knee where the dose rate was expected to be higher, but did not inform radiation protection (RP) until sometime later. No administrative limits were exceeded and the dose rate difference was determined to be only 10 millirem. In addition to dosimetry control, several problems with RP control of the job were identified. Appropriate immediate corrective actions were taken and longer term actions were recommended. Overall, the investigation was thorough and well documented . 12
.... .On December 5, 1991; NRC inspectors observed a worker not wearing his electronic dosimeter (ED) jogging up and down stairs in the reactor building. The individual stated that he, as well as .several unnamed workers, occasionally jogged in the reactor b~ilding during lunch. Technical* Specification 6.2.B requires that radiological control procedures be maintained, made available to station personnel, and adhered to. Additionally, procedure OAP 12-25, Rev. 1, nRadiation Work Permit Programn states in part that each worker performing a job under a radiation work permit (RWP) must follow the requirements of the RWP. The inspector's review identified that the ED was forgotten while changing clothes, the worker signed in on a RWP which did not address reactor building access, and he had forgotten to sign the ~ppropriate RWP for entering the reactor building. The failure to follow procedure OAP 12-25, is considered an example of a violation of Technical Specification 6.2.B (Violation 237/91039-0la(ORSS); 249/91043- 0la(ORSS)). The licensee's subsequent investigation did not identify other individuals who used the radiologically controlled area (RCA) for recreational activities; however, some workers felt that such activities were not specifically prc~ibited. In response to this event, the licensee counselled the worker and issued a directive to all plant personnel prohibiting recreational activities in the RCA and reiterated the requirements for RWP compliance. On December 18, 1991, NRC inspectors identified that four f~el handlers were moving fuel, but were not signed in on the proper RWP. The RWP which authorized moving fuel was No. 10608A and the workers had signed in on RWP No. 10609A. Fuel movements were stopped and the workers subsequently signed the correct RWP.* Furthermore, they were counselled on the need for performing work on the appropriate RWP. The failure to follow the requirements of the RWP is another example of a violation of Technical Specification 6.2.B. (Violation 237/91039-0lb(DRSS); 249/91043- 0lb(DRSS)). One violation was identified. 10. Radwaste Issues <IP 84750) The status of several major ongoing radwaste projects was reviewed to update information obtained during previous inspections (Inspection Report Nos. 237/91012(DRSS); 249/910ll(DRSS}, 10/9100l(ORSS); 237/91018(DRSS); 249/91017(DRSS). The solidification of Dresden Unit 1 chemical decontamination waste had been scheduled to begin in the fall of 1991. However, problems in procurement of processing equipment and modification of the *processing building to establish a -0.25" pressure differential have delayed the start date of solidification until March 1992. 13
11.
The project to characterize' repackage as necessa'ry' and *Ship . for burial approximately 200 55-gallon drums of waste .from the early 1980s was scheduled to begin around August 1991. *Progress has been s 1 ow, due to work force availability and overhead crane problems.
. . . . . . Cleanup of the sludge tank room has~been.delayed.several times, most recently due to a pipe leak and cleanup in an adjacent vault.
- The cleanup activity is scheduled to be completed around July
1992. . Several other radwaste issues were also reviewed.
. In late 1_991, due mainly to a lack of steam for the radwaste concentrators, the storage capacity _of the floor drain system was exceeded and water was transferred to a Un.it .1 storage tank .. During the transfer~ water leaked into a Unit. 1 pipeway through* a freeze-damaged section of pipe.* In addition, the *tank's two heaters were found to be inoperable. The pipe was r~paired and a surveillance was initiated to monitor the temperature in the
pij)cway atid the.integrity of the pfpe. * By*the end of inspection period, .one of the heaters had been repaired, and a supply of steam from a temporary boiler allowed re(tuction of the flood drain inventory using the concentrators.
- * *
on*December 19, 1991, radwaste management made a *discharge of radwaste in an attempt to verify the integrity* of the liquid radwaste discharge line. The integrity of .the line was suspect because it was.frozen on the previous day and a groundwater sample taken near the discharge point was interpreted as indicating low- level contamination (4.SE-7 microturies/gram of Co-60). The December 19th discharge did not verify the integrity of the line and the decision to use liquid radwaste to verify the integrity was poor. Similar use of liquid radwaste in March 1991, resulted in the unnecessary re 1 ease of sever a 1 hundred. ga l1 ons of radwaste through an underground pipe leak (Inspection Report 50- 237 /91012 (DRSS); 50-249/91011 (DRSS)). Mi:s-conununicat ions between radwaste and radiation protection management were apparent. Radiation protection management believed no radwaste would be discharged until line integrity was verified. A subsequent review by the plant chemist of the groundwater analysis determined that no activity above background was present. Also, a leak rate test was conducted on the discharge pipe and verified its integrity. No violations or d~viations were identified. Management Meetings (30702) a. On December 16, 1991, NRC regional management met with CECo corporate and station management at the Dresden training center . . ., _____ The purpose of th.e me_e_t i ng was to update NRC personnel on 1 i censee short term and long term corrective actions to improve performance 14
Ir . at the Dresden Station. Distuisions tentered upon action ~lan prep~ration and resources ~vailability. b. On Detember 17, 1992, CECo hosted a technical meeting_with NRC . Region III staff on the. source term reduction program at all six-* nuclear sites.* The licensee provided Dresden _specifi'c.coll~ctive
- radhti on exposure goa 1 s for the' next five years. * The goa 1 for* -* *
1991 was slightly exceeded but actual exposure was the lowest in over a decade. The goal for 1992 is 425 rem/reactor decreasing to 182 by 1996. These initiatives and goals will be monitored as part of the open item discussed in paragraph.12.~.
. . . c. On January* 13, 1992, NRC regional management and CECo c_orporate . and station management met at the*NRC regional office. The purpose of the meeting was to d.iscuss licensee management* expectations as*they relate to operators.*. Also, t~e licen*see . . provided an. assessment of operations* and initiatives underway to imp rove perf ormanc_e in this area. No violation~ or deviations we~e*identified. 12. Safety Assessment and Ou.ality Verification (40500) * a. During the inspection period the inspector ~eviewed the licensee's response dated Nov~mber 1, 1991, to the recent Systematic Assessment of Licensee Performance Report. The inspector determined 25 discrete actions documented as either had occurred or would occur to improve performance. The inspector verified implementation of a number of the actions. However, a. number of* the actions require further inspection to determine the effectiveness of these actions in improving performance. Therefore, the actions discussed below are considered an open item (50-237/91039-02(DRP)). The licensee actions are: Development and implementation of the Dresden Management Action Plan Actions associated with shift engineer observations of other shifts Actions from the Operations Improvement Team Actions to reduce high collective and individual radiation exposures Issuance of work analyst guidelines for the preparation of work request packages . Actions from committees on work control, tool improvement, professionalism and intra-departmental relationships R~vision of ENC QE 40.l, "Evaluation and Review of Potential Design Concerns for Impact on Plant Operability" Evaluation of the current e~perience level and future needs of the site engineering staff Implementation of those programs to increase retrievability of plant,d~~ign specifications, industry design codes and safety system reqtifrements 15 . :;: .
,, Establishment of a technical requirements document.for quality calc~lations b. The inspector reviewed the resume of the recently appointed plant manager and determined by virtue of his education, previous job experience and training that he met the regulatory requirements . *. deljneated in ANSI 18.l - 1971, "Select fan and Trainfog of Nuclear Power Plant Personnel," for the plant manager position.
c. The inspector identified a lack of an accountability log on the refuel bridge, the inspector reviewed the licensee's reactivity assessment performed in late July 1991. The inspector noted that the assessment report dated October 11, 1991, identified the need for such a log. The station response dated November 15, 1991, stated that the development of such.a log would be accomplished 90 days after corporate nuclear operation directives on the subject were issued. Between late July and October the *station personnel were aware of the concern because they had been given a verbal debriefing of the findings and two ass~ssment report drafts were submitted for station conunent. No viol~tions or deviations were identified. 13. Reqjonal Requests a. On January 8, 1992, regional management requested .. the resident staff to contact licensee management regarding a Part 21 notification on Johnson/Yokagawa controllers. That same day the inspector informed technical staff management of the problem. The licensee was already aware of the problem and was in the process of identifying where the controllers were installed within the facility. Subsequently, the licensee determined that ten of the controllers were installed in the high press~re core injection, low pressure core injection and control rod drive systems and two were in the shop .. The licensee initiated work requests to remove the controllers for vendor repair prior to either unit startup. b. In December, 1991, regional management requested information as to whether the standby gas treatment and control room ventilation systems had backdraft protection when a division was in maintenance. SGTS has dampers in the suction and discharges of the fans providing such protection. The control room ventilation system has no inter-division backdraft protection since it is essentially a single division system. c. In a memorandum dated December 20, 1991, the Director, Division of Reactor Projects, instructed the resident staff to discuss the recent Fermi 2 crane overhead line event and the Palo Verde partial loss of 13.8 kv power event with the plant manager. Following the discussion the plant manager conunitted to: 16
'. By December 23, 1991, review station policies for crane use~ ... particularly in the area of high voltage lines By December 23, 1991, review station policy for truck . operation. . :
Conduct heightened level of awareness briefings before.using cranes. These briefings will continu~ until station . ; management is satisfied that p'ersonne r and pr:--oc,edures ., .*. . .. adequately address. this subject.
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Discus$ this subject with all plant personnel during the week of December 23, 1991, and again during the week of January 6, 1992. --
By December 24, 1991, flyers will be posted at the station on this subject. d. In a Fall 1991 memorandum, regional management requested . information on. the out of- service times of sele*ct safety syste*ms for six month period beginning in June 1991 *. The informatiQn was provided in December 1991.
No violations or deviations were identified. 14. Ooen Items * Open items ~re matters which: have been discussed with the licensee; will be. further reviewed by the inspector; and involved some -actions on the part of the NRC, licensee, or both. An open iteni disclosed during the inspection is .discussed in paragraph 12.a. * 15. Exit Interview The inspector~ met with licensee representatives (denoted in paragraph 1) during the inspection period and. at the cone 1 us ion of the inspection period on January 17, 1992. The inspectors sununarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the infonnat.ion and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature. 17 }}