ML17179A459
| ML17179A459 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/14/1992 |
| From: | Michael Kunowski, Markley A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17179A457 | List: |
| References | |
| 50-237-92-19, 50-249-92-19, NUDOCS 9209290017 | |
| Download: ML17179A459 (10) | |
See also: IR 05000237/1992019
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I II
Reports No. 50-237/92019(DRSS); 50-249/92019(DRSS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwea 1th Edi son Company
1400 Opus Place
Downers Grove, IL 60515
Facility Nam~: Dresden Nuclear Generating Station, Units 2 and 3
Inspection and Meeting At:
Dresden.Site, Morris, Illinois
Inspection Conducted:
June 10 through August 6, 1992
Meeting Conducted:
J~~Y~~~~:_2A;~/l_./
Inspectors:
.~ifno':S-k~~
.*.b~
A.*w. M~~
/n~
Approved By:
M. C. Schumacher, Chief
Radiological Controls Section 1
Inspection Summary
9-/LJ ~Cf'Z
Date
Inspection on June 10 through August 6, 1992. and Meeting oh July 17, 1992
(Report Nos. 50-237/92019(DRSS); 50-249/92019CDRSS))
. A~eas Inspected and Discussed at the Meeting:
Special, an~ounced inspection
of the radiation protection program (Inspection Procedure (IP) 83750),
including staffing, training, and qualifications; external and internal
exposure control, including ALARA considerations; and contamination control.
The inspectors alsb reviewed the program for transportation of radioac~ive ,
materials (IP 86750) and the ventilation system for several radioactive waste
. (radwaste) buildings (IP 84750).
In addition, a special meeting was held at
the request of the NRC to discuss actions on several radwaste issues.
Results:
The inspection identified weaknesses in radiological controls that
sugg~sted worker indifference to good radiological control~ and the need for
improved management oversight at the job site. Violations were jdentified for
failures to follow procedures, absence of radiation area postings, and
inadequate surveys (Sections 4 and 5).
The inspectors also observed .
. ventilation system problems in the radwaste and max recycle buildings that
reflected system design problems.
The licensee has made good progress toward
resolving sev~ral longstanding radwaste p~oblems (Section 7) and the
inspectors observed good radi ol ogi ca 1 controls. by radiation protection
technicians on several jobs (Section 5).
9209290017
ADOCK
A
920918
05000237
1.
DETAILS
Persons Contacted
@R. E. Aker, Performance Assessment
@*D. F. Ambler, Health Physics .Services Supervisor
- S. J. Bell, Chemistry and Radwaste Services, Corporate
- @*l. Bennett, Radwaste Coordinator
- W. Causer, Engineering Assistant
@*E. W. Carro 11, Regulatory Assurance
@F. Dundek,' Auxiliary Systems Group Leader
M. Gagnon, Health Physicist
@*L. F. Gerner, Technical Superintendent
- K. W. Heinrich, Chemistry and Radwaste Services, Corporate
- C. Herzog, Chemistry and Radwaste Services, Corporate
- S. Horvat.h, Health Physicist, Corporate
@M. Korchynsky, Unit 3 Operating Engineer
- T. Murphy, Radwaste System Engineer, Technical Staff
T. J. O'Connor, Assistant Superintendent of Maintenance
@*L. L. Oshier, Lead Health Physicist-Operations
@R. Radtke, Regulatory Assurance Supervisor
- R. Raguse, Health Physicist, Corporate
@W. Rakes, Radiation Protection Supervisor
- P. Roth, Chemistry and Radwaste Services, Corporate
@*D. Saccomando, Nuclear Licensing
@*C. W. Schroeder, Station Manager
- G. L. Smith, Assistant Superintendent of Operations
@D. S. Southcomb, Auditor, Nuclear Quality Programs
- R. W. Stobert, Operating Engineer
M. Strait, Technical Staff Supervisor
. @R. C. Winslow, Lead Health Physicist-Technical
- R. Hand, Supervisor, Environmental Services, Illinois Department of
Nuclear Safety (IONS)
- W. L. Axelson, Deputy Director, Division of R.adiation Safety and
Safeguards, NRC
@*M. C. Schumachei, Chief, Radiological Controls Section 1, NRC
The inspectors also contacted other licensee and contractor personnel.
- Denotes those present on July 17, 1992, at t~e meeting to.discuss
radwaste issues.
@Denotes those present at the exit meeting on August 6, 1992.
2.
General
This concluded a three-month special inspection of the Dresden radiation
protection (RP) program by two senior radiation specialists in an
attempt to understand the reasons for persistent performance weaknesses.
It emphasized observation of ongoing work in the radiologically
controlled area (RCA), interviews with both workers and managers,.
independent dose rate measurements, and the station program for
. 2
3.
maintaining exposures as-low-as-rea*sonably-achievable (ALARA).
The
inspectors also made extensive tours inside and outside of the RCA,
including both well travelled and infrequently travelled areas, to
observe radiological controls.
Nuclear General Employee Training (IP 83750)
The Nuclear* General Employee Training (NGET) for contractors.and new
station radiation workers (radworkers) is one and a half days of
instruction on RP and such topics. as security, industrial safety, and
Students in this initial training must show they can
properly don and doff protective clothing. Annually thereafter,
radworkers are required to take a half-day of refresher (requalifi-
c~tion) training. Written tests are given for both.
In an initfal NGET session attended by the inspector, the instructor, a
former RP and chemistry technician, was conscie~nt i ous and competent.
However, the session had little discussion of pra~tical radiological
problems such as those documented in station Radiological Occurrence
Reports (RORs) and no audible demonstration of electronic dosimeter (ED)
alarms.
Proper worker response to ED alarms has been a problem over the
past two years at the station.
An alarm training tape that was being
developed by the licensee was put into use following the inspection.
In
addition, the licensee was planning to incorporate more discussion of
RORs into future NGET sessions.
Both efforts will be reviewed during
future inspections.
The inspectors learned from licensee representatives that. NGET was to be
enhanced in September 1992 with advanced radworker topics after being.
twice postponed from earlier target dates of December 1991 and June
1992.
A more detailed training course involving advanced radworker.
t6pics w~s also being de~eloped for late 1992.
The inspectors. also.
learned from other plant personnel that NGET ~redibility sometimes
suffered from use of instructors with little recent plant experience.
Licensee management was aware of and dealing with this problem.
No violations of NRC requifements were identified.
.
.
.
4.
Material Conditions and Radiological Controls CIPs 83750 and 86750))
The inspectors reviewed material conditions, radiolrigical controls, and
radiation protection technician (RPT) performance during several plant
tours.
a.
Outside Areas
The inspectors identified unpasted, accessible radiation areas
(where dose rates could result in a wh6le body dose greater than
5 millirem in one hour or greater than 100 millirems in 5
consecutive days) on the Unit 2/3 radwaste building roof on
June 20, 1992, and around a seavan adjacent to the Unit 2/3 truck
bay on July 15-20, 1992.
These conditions, which were contrary to
the .requirements .of 10 CFR 20.203(b), were confirmed by licensee
surveys of the _roof on June 17 (10 millirem per hour) and June 22
(60-65 millirem per hour) and of the seavan on July 20 (4 millirem
3
per hour) (Violation No. 237/92019-0la(ORSS) and -Olb(ORSS);
249/92019-0la(ORSS) and -Olb(DRSS)).
The significant variation on.
the roof resulted from changing conditions in the radwaste rooms
below.
The inspectors also identified in both areas the failure of the
licensee to make surveys required by 10 CFR 20.20l(b) to evaluate
the potential radiation hazards. Specifically: licensee
representatives stated that the roof area had not been surveyed
since radwaste storage in the rooms below was discontinued in 1990
despite the fact that storage was resumed in 1991, and the seavan
had not been survey~d during the period from July 15 until July 20
(Violation No. 237/92019-02a(DRSS) and -02b(DRSS); 249/92019-02a
(DRSS) and -02b(ORSS)).
Both areas w~re posted as radiation area~
and added to the surveillance schedule.
Long term corrective
action included re-assignment of area posting responsibilities
from the station laborer group to the RP department and ~ssignment
- of specific plant areas for RP managers to tour daily and weekly.
The short and long term corrective actions to the two violations
appeared adequate.
Although not posted as a radiation area on Jun~ 16, the roof area
was posted as a radioactive materials area .. However, the posting
was well weathered, indicating it was irifrequently visited, and -
the area delineation was incomplete.
Additional evidence of
neglect were seen in nearby roof areas.
In one location, the
inspectors saw a high radiation area (HRA) sign fac~ down on the
floor and a radiation area sign taped over.
They apparently had
been used when high radiation area controls were temporarily
imposed and not removed afterwards.
Also neafby, the inspectors
saw a considerable accumulation of dirt on the roof from.which two
small trees were growing, cable trays containing debris, a
discarded empty radioactive material bag, and a chain fall painted
purple (later identified as having fixed contamination).
Conditions in both of the above areas* appeared to reflect
.
insufficient concern by workers as well as insufficient management
oversight to ensure good working conditions;
These matters were
discussed at the exit interview.
b.
Inside Areas
The inspectors made numerous entries into the reactor, turbine and
radwaste buildings during the inspection.
Housekeeping and
material conditions were generally good,
alt~ough the Unit l
radwaste control room and the adjacent outdoor storage were messy.
There were also examples of inconsistent postings of contaminated
areas of the kind noted in previous reports.
Two violations were identified.
5.
Maintaining Occupational Exposures ALARA (IP 83750)
The inspector reviewed the licensee's program for maintaining_
occupational exposures ALARA.
Overall, the program was adequate.
4
I
Details of the review are discussed below.
a..
Implementation of ALARA in Design Activities-
On Ju~e 19, 1992, the inspector attended an Installers ~alkdown
Meeting for Minor Modification Pl2~3-92-699. This involved
installing a modified spool piece and upgrading associated
restraints on the fuel *pool cooling bypass line to alleviate
cavitation-caused vibration.
An orifice on this line was a crud
- trap and a significant source of radiation exposure.
The meeti~g
was .attended by representatives from various corporate and pl ant
tech~ical groups and the licensee's architect-engineer (AE)
consultant.
Several weaknesses were noted at the meeting by station ALARA and
maintenance personne 1 and by the inspector including 1 ack of
'
certainty that the modification would eliminate the vibration,
engineering decisions made without adequate ALARA co'ns iderat ions
- (e.g., no hydrolazing ports or shielding supports), and lack of
ALARA training for two of the three engineers. irivolved.
Installation of the spool piece was p6stponed until station
concerns could be resolved.
A similar problem with the lack of ALARA considerations in a
modification was identified by the station in May 1.991 after.
unexpectedly high dose rates were identified around a hydrogen
water chemistry system skid ..
- b.
Unit 3 Incore Detector Replacement
On July 2, 1992, the inspector observed a portion of the pre-j.ob
briefing for a transversing incore probe (TIP) replacement and
reviewed the ALARA evaluations and radiation work permit.
The
briefing was conducted in the instrument maintenance (IM) shop by
an IM superviso_r, the assigned RPT, and an ALARA representative.
Later that day~ the inspector watched the job. Several
observations from the meeting and the job are described below.
A special planning meeting (a "Heightened Level of
Awareness" (HLA) meeting) was conducted on July 1, 1992, and
resulted in the reduction of the number of workers involved
in the job.
Distractions from non-participant IM personnel affected the
quality -0f the briefing.
Specific information about TIP decay time was not known by
personnel involved in the job, although it was known that a
minimum of three weeks had elapsed.
Exposure control by ttie RPT was good with dose (0. 089 p*erson
rem) was about half the prejob estimate although dose rates
(150 mrem/hour contact) were similar to prev1ous TIP work
- and the duration (39 person-hours) five times the pre-job
estimate.
5
Contamination lev~ls of 1-1~5 million dpm/100 centimeters
squared.were expected and found.
Appropriate contamination*
control measures were taken.
The TIP cable was cranked too far into the drive machine and
the detector fell into the machine.
E~tra time was required
to retrieve the detector.
Cable cutters were dull and required extra time to sever the
TIP from the cable.
The spool for winding used cable was too small causing cable
to unwind and contaminate the floor.
'
Overall, the exposure for the job was low, but the pre-job
briefing distractions and the equipment problems listed *above
highlighted the need for improved recognition of ALARA principles
by work groups other than RP.-
c.
Heater Bav Entry
On June 17, 1992, the inspector accompanied a work group into the
Unit 3 turbine heater bay while the reactor power *was 450 MWe. *
The pre-jrib briefing by RP personnel was well done ~nd a reduction
in the number of workers was successfully negotiated.
During the
job, exposure cont ro 1 by the RPT was exce 11 ent.
Exiting personnel adequately removed protective clothing and
frisked themselves; however, hand-carried items such as
flashlights and papers were not surveyed prior to being handled on
the clean side of the step off pad and the RPT held contamination.
smears in his bare hands while surveying them and did not survey a
canvas bag used to remove equipment and the smears from the heater
bay.
Although contamination levels in the heater bay were low
(500-5,000 dpm/100 centimeters squared) and no workers were
contaminated, the contamination control practices ~xhibited were
poor and not unique as ~imilar occurrences were*noted during
previous inspections.
d.
RWP and ALARA Procedural Requirements
On June 17,
1992~ the inspector reviewed the following RWPs to _
determine if pre-job ALARA checklists and briefings were completed
in accordance with OAP 12-09, "ALARA Action Reviews;
11
RWP Number
- 20011A.
20290A
20323A
20334A
20336A
20349A
20355A
Job Description
Radioactive Waste Processing and Shipping
Hydrolaze Floor Drains in 2/3 Reactor Building -
General Access Areas
Remove and Replace Refuel Grapples
Replace 2B RWCU Post St~ainer/Cap Drain Line
Mechanically Overhaul RWCU MOV 3-1201-12
Cut Out and Replace V-36 AO Valve in Unit 1
Waste Surge Tank Cleanqut
6
20370A
Remove and Replace Unit 3 E TIP Detector
The review indicated that all the questions in the checklists had
- been addressed during RWP preparatfon, but a rationale or basis
for the answers was not always provided.
This is considered a
weakness.
The inspector's review also identified several instances where
required briefings were not given before work was performed on the
RWPs:
on May 12, 18, and 19, two workers and three RPTs on RWP
20290A; on May 28 and 29, and June 8; 10, and 15, 1992, ten
workers on RWP 20323A; and.on June 15 and 16, 1992, three workers
OAP 12-09 required briefings for
these jobs because they involved exposure estimates in excess of 1
person-rem or smearable contamination levels in excess of 250,000
disintegrations per minute (dpm) per lOO centimeters squared.
Workers and RPTs were subsequently given the req~ired briefings,
and RP personnel and job supervtsors we~e counselled on the need
to ensure that briefings are given.
The failure to follow the
briefing requirement of OAP 12-09 is an example of a violation of
Technical Specification (T/S) 6~2.8., which requires adherence to
radiation control procedures (237/92019-03a(DRSS); 249/92019-
03~(DRSS)).
Also during the RWP review, the inspector identified references to
three diffe~ent procedures for extremity dosimeter requirements
(DRP 1210~02, DRP 1210-04, and DRP 1210-05) which contained mutual *
inconsistencies.
No regulatory limits were approached during the
work but the need for better attention to detail was indicated.
Similar procedure inconsistencies wer~ identified in an earlie~
inspection (Inspection R~ports No. 237/90026(DRSS); 249/90025
(DRSS)).
.
On June 19, 1992, an NRC inspector observed a station maintenance
worker remove his dosimeters and begin work in the Unit 2 High
Pressure Coolant Injection pump room, a po~ted radiation area.
He
worker put them ~~ again when approached by the inspector.
According to a licen~ee followup, the worker r~moved the dosi-
meters because he was concerned about them falling through .the
grating he was working from.
The worker was counseled and given
one day off without pay.
The failure to follow the require~ent of
the RWP (No. 20356A) to wear the dosimeters is contrary to OAP 12-
25, "Radiation Work Permit Program," and is another example of a
violation of T/S 6.2,B. (237/92019-03b(ORSS); 249/92019-03b
(DRSS)).
.
e.
High Radiation Area Door Controls
The inspector reviewed a recent ROR written for a high radiation
area door found unlocked on July 6, 1992.
Although dose rates in
the area at the time did not require the door to be locked, this
problem and other recent similar problems with areas controlled as
high radiation areas, indicated a need for greater management
attention.
7
...
6.
One violation was identified.
Radwaste Ventilation Problems (IP 84750)
On July 6, 1992, during a tour of the ~adwaste and max recycle (floor
drai~ ~recessing) buildings, the inspector observed three doors leading
to the outside that were blocked fully open, contrary to a sign posted
on each door that read "Door to remain closed at all .times to maintain
ventilation flow except for ac~ess." Air flowed noticeably into the
buildings through two of the doors, but not through the third door,
located on the roof of the max recycle building .. This door offered a
potentially unmonitored release path although probably of limited
.radiological significance owing to the low level of contamination and
absence of recent airborne radioactivity problems in the area. This was
later corroborated by .a licensee survey of the adjacent roof area which
found no contamination.
Nevertheless, it was of concern because of the *
apparent disregard by plant personnel of the instructions posted on the
doors and management's apparent tolerance of.this attitude.
The short term corrective actions for.these problems included closing
the doors, initiating a work request to repair or replace the radwaste
building door which was in disrepair, and emphasizing py memoranda to
each plant employee that outside doors to all three buildings ~ere* to be
maintain~d closed, in accordance with posted instructions.
The open doors also prompted inspector concerns regarding adequacy of
radwaste ventilation systems.
Licensee tests on July 10, 1992,.found
that inside pressures were negative with respect to the outside except
for the max recycle building which was slightly positive with outside
doors open.
With doors closed the radwaste building met its design
specification of -0.25" while the max recycle building was about -0.05"
compared with its design specification range of -0.105" to -0.145".
However, neither building .could be shown to meet the Final Safety
Analysis Report (FSAR) design basis of -0.25" water pressure
differential between clean areas and those with the gre.atest
contamination potential.
The radwaste building measured -0.125" with
doors c;losed and -0.10" to ,...0.18" with doors open .. The differential was
not measured in the max recycle building because of the lack of
installed pressure instrumentation.
The licensee was able to bring max recycle differential pressure to -
0.18" to -0.20"
by shutting off the one ventilation supply fan
previously used, with intention to operate this way until new_exhaust
fans with higher capacity were installed.
The need to maintain outside doors closed and the problem with the ~ax
recycle building meeting the design specification were identified during
modification and review of the ventilation sy~tem which took place from
1986-1989. After the modification was completed in April 1989, signs
were posted on the doqrs and workers were informed of the need to keep
them shut, and work requests were issued to replace the max recycle
ventilation exhaust fans, which had been found to be undersized;
ho~ever, the requests were canceled in May 1~90 owing to l~ck ~f funds.
Problems with low level contamination of personnel attributa~le to the.
8
ventilation system occurred in 1990 and 1991, and replacement fans were
again requested.
They are expected to be installed by 1993.
In summary, management actions to correct the max recycle building
ventilation problem identified in. 1986-1989 were inadequate and the
.. ventilation system was operated in a generally degraded manner since
then.
Of additi~nal concern were the apparent tolerance of radwaste
doors being left open and a two-year lapse between completion of the
ventilation system modification and declaration of the system operable.
These weaknesses were discussed at the exit interview and licensee
corrective actions will be reviewed during a future inspection
(Inspection Follow-up Item 237/92019-04(DRSS); 249/92019-04(DRSS)).
No violations were identified.*
7.
Meeting to Discuss Radwaste Issues
The licensee reported significant progress on a number of outstanding
. radwaste issues at a July 17, 1992, meeting was at Dresden attended by
licensee, state, and NRC representatives. A similar meeting was held in
June 1991 (Inspection Reports No. 010/91001; 237/91018; 249/91017).
a.
Radwaste Upgrade--The project was 63% completed with full
completion expected in 1993.
The final dose total estimate is 500
person-rem, compared to an original estimate of 1958 person-rem.
Dose savings were attributed to aggressive source term reduction,
use of automated equipment, and ALARA training classes: *
b.
Contaminated Soil--Fences have been erected around two piles of
soil and a vegetation ground cover is planned.
A 10 CFR 20.302-
type petition has been filed with the IONS for one of the piles
and is planned for the other pile. Contaminated soil in four
other areas is expected to be left inplace until decommissioning,
- in accordance with 10 CFR 50.75(g) evaluation.
c.
Radwaste Backlog~-A backlog of about 60000 cubic feet of radwaste
on hand in July 1989 was reduced to less than 8000 cubic feet in
June 1992.
It included already solidified drums needing
characterization, liquid decontamination solution from the unit
one cleanup and other solid wastes.
The work was achieved with
low dose expenditure and 660 shipments were made.with no
regulatory problems.
d.
Radwaste Ventilation--The licensee has recently begun to address
radwaste ventilation problems including those discussed in Section
6.
Among actions taken were plugging of holes in the ceiling of
the spent resin and sludge tank rooms and installing an exhaust
duct from the spent resin tank room to improve air flow and
replacing two supply fans to improve reliability.
e.
Contaminated Area Reduction--A station goal was established to
reduce the amount of contaminated floor from the current.27% to
5%.
Implementation plans, which are still being developed, will
concentrate on the torus basements, the turbine floor, and floors
of the reactor building equipment drain tank rooms.
The licensee
9
~
has also adopted a commonly used contaminated area definition of
1000 dpm/100 square centimeters.
f.
Recent Unplanned Exposure Event--The 1icensee briefly described
the June 3, 1992, unplanned exposure of a contract radwaste
technician during the installation of a lid on a liner of
. radwaste.
The technician received approximately 197 millirem
compared to a 100-mi'llirem administrative limit. This event is
discussed in .Inspection Reports No. 237/92016; 249/92016.
g.
Clean-up of the Spent Resin Tank and Sludge Tank*Rooms--The
licensee stated that the approximately one barrel of resin that
spilled in the spent resin tank room on March 1, 1992 {Inspection
Reports No. 010/92002; 237/92007; 249/92007), would be cleaned up.
by the end of 1992.
In addition, with the clean-up of the sludge
tank room about 95% completed~. the cost-benefit of further clean-
up was being evaluated.
The licensee agreed to inform the NRC in
writing of the results of the evaluation.
NRC representatives acknowledged good licensee performance overall in
this area.
8.
Exit Meeting
The scope and findings of the inspection were discussed with licensee
representatives {denoted in Section 1) on August 6, 1992.
Specifically,
the inspector discussed the.NGET program weaknesses and early
improvements made by new personnel {Section 3); material condition,
posting, and survey problems {Section 4); ALARA program problems and
good job coverage provided by RPTs {Section 5); and radwaste ventilation
problems {Section 6).
The relative ease with which these problems were
identified was emphasized and the need for increased management presence
in the plant was highlighted.
The licensee acknowledged the comments
and did not identify any likely inspection report material as
proprietary.
10