ML17179B047
| ML17179B047 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/13/1993 |
| From: | Michael Kunowski, Mccormickbarge, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17179B045 | List: |
| References | |
| 50-237-93-22, 50-249-93-22, NUDOCS 9308260140 | |
| Download: ML17179B047 (40) | |
See also: IR 05000237/1993022
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/93022(DRSS); 50-249/93022(DRSS)
Dockets No. 50-237; 50-249
Licensee:
Commonwealth Edison Company
Opus West II I
1400 Opus Plac~
Downers Grove, IL 60515
Facility Name:
Dresden Nuclear Generating Station, Units 2 and 3
Meeting At:
Dresden Site, Morris, Illinois
Meeting Conducted:
July 12, 1993
Inspection At:
Dresden Site, Morris, Illinois
Inspection Conducted:
July 19 - 29, 1993
Inspector:
Reviewed By:
Approved By:
- Summarv-
/!. /(.~'
M. Kunowski
J. McCormick-Barger, ~ing Chief
Radiological Controls Section 1
W. G. S~Acting Chief
Reactor Support Programs Branch
A~o,oJJ
Oat .
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Meeting on July 12. 1993. and Inspection on July 19 *- 29. 1993 (Reports
No. 50-237/93022(DRSS); 50-249/93022(DRSS))
Areas Discussed and Inspected:
The Management Meeting was held to ~iscuss
radiological controls performance during the recently completed Unit 2 (cycle
13) refueling outage and was a follow-up to a Management Meeting held in
October 1992.
The inspection was a routine announced review of comp*l eted
outage activities and of an ongoing problem with low-level contam1natton:-
events (Inspection Procedure (IP) 83750).
In addition, the inspector .reviewed
licensee actions on several inspection follow-up items (IFis) and other
previously identified items .
Results:
Information discussed at the Management Meeting indicated
improvements in radiological controls had been made since the previous
Management Meeting (Section 7).
Examples of good performance observed during
9308260140 930818
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ADOCK 05000237
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the inspection included the planning and implementation of in-service
inspection (ISI) and control rod drive (CRD) replacement work (Section 6), and
the use of experienced ALARA (as-low-as-reasonably-achievable) personnel in
the station maintenance and radiation protection (RP) departments and in the
Engineering and Nuclear Construction (ENC) group (Section 3).
Examples of
poor performance included the limited consideration 6f the exposure impact of
an increase in Unit 2 outage scope, strained ALARA staff support because of
the expanded outage scope, and poor control of contamination cleanup
activities that resulted in numerous low-level contamination events (Sections
5 and 6). Welding and replacement pipe fit-up problems resulted in extra dose
for work on the reactor work cleanup (RWCU) system (Section 6). With
additional RWCU work planned for both units, management attention to address
these problems is necessary. Additional concerns were identified for
ineffective corrective actions for a mispositioned drywell temporary
vent.ilation system (Section 5) and relatively high non-outage daily dose
(Section 7).
One violation was identified for failure to mark contact dose
rates on bags of radioactive materials, a procedure violation (Section 8) .
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DETAILS
1.
Persons Contacted
Commonwealth Edison
@D. Ambler, Executive Assistant to the Site Vice-President
@R. Burns, Maintenance and Technical Training Supervisor
- @R. Flahive, Technical Services Superintendent
- J. Grzemski, Safety and Quality Verification (SQV)
- @B. Gurley, NRC Coordinator, Regulatory Assurance
- M. Hayworth, Lead Health Physicist-Operational
- @L. Jordan, Health Physics Services Supervisor
@J. Ktitowski, Operations Manager*
@T. O'Connor, Maintenance Superintendent
@P. Piet, Licensing Administrator
@P. Quealy, Lead Health Physicist-Technical
@F. Rescek, Radiation Protection Director (Corporate)
- R. Rysner, SQV
- @J. Shields, Regulatory Assurance Supervisor
- @G. Spedl, Plant Manager
@R. Stachniak, Support Operating Engineer
@B. Viehl, Station Engineering and Construction, Modification
Supervisor
The inspector also interviewed other licensee and contractor personnel.
Nuclear Regulatory Commission
@W. Axelson, Deputy Director, Division of Radiation Safety and
Safeguards
@P. Hiland, Chief, Reactor Projects Section lB
@B. Jorgensen, Acting Chief, Reactor Support Programs Branch
- @M. Leach, Senior Resident Inspector
@Denotes those individuals present at the meeting on July 12, 1993.
- Denotes those individuals present at the inspection exit meeting on
July 29, 1993.
2.
Licensee Actions on Previous Inspection Findings CIPs 83750 and 86750}
(Closed} Violation No. 50-237/92007-0ICDRSS):
An inadequate procedure
contributed to a spill during the transfer of resin from the Unit 2 RWCU
system to the spent resin tank.
RWCU and fuel pool cooling procedures
for both Units were revised to include appropriate precautions.and
limitations for transfers to the spent resin tank.
In addition,:tbe
licensee addressed a related command and control problem through .t~e
issuance of an operations department directive that stated that the
radwaste supervisor had authority over spent resin transfers ..
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(Closed) Open Item No. 50-237/92007-02(DRSS):
Review the results of the
licensee's evaluation of the continued use of action levels less
conservative than those suggested in the NRC Branch Technical Position
on waste classification. The evaluation indicated that the less
conservative action levels were only occasionally used, but the licensee
modified its practice, nonetheless, and appeared to be consistent with
the Position.
(Closed) Open Item No. 50-237/91039-02(DRSS): This item tracked
licensee action plans developed to address NRC SALP (Systematic
Assessment of Licensee Performance} Reports No. 50-237/92001;
50-249/92001.
Most of these plans were reviewed by the NRC resident
inspector staff and found adequate.
Review of the plan on the reduction
of high collective and individual doses was assigned to the regional
specialist. Further licensee effort in this area will be reviewed as
part of the Inspection Follow-up Item discussed in Section 6.
(Open) Inspection Follow-up Item (IFI) No. 50-237/92019-04(DRSS};
50-249/92019-04(DRSS):
Review corrective actions for the inadequate
ventilation system in the maximum recycle (liquid radwaste processing}
building.
In letter dated November 25, 1992, the licensee indicated
that two new high capacity exhaust fans would be installed by May 30,
1993.
In a subsequent letter dated May 28, 1993, this was changed to
July 31, 1993, because of outage demands.
During the current
inspection, the inspector noted that the air in the building was warm,
stagnant, and odorous. According to the licensee, problems were
encountered during installation of the fans and as of July 31 only one
had been installed and was operational. At the exit meeting
(Section 9}, the licensee stated that a letter to the NRC containing a*
revised installation date was forthcoming.
Miscellaneous Inspection Issues:
Further review by the inspector of
licensee information on resin density and chelating agent quantity have
resolved earlier questions.
In addition, completion of the Unit 1
chemical decontamination waste solidification project and a station
decision not to use fossil plant instructors for RP training of fossil
plant employees who occasionally work at Dresden obviate further
inspection effort in these areas at this time.
No violations of NRC requirements were identified.
3.
Personnel Qualification and Training (IP 83750}
The inspector reviewed the qualifications and training of the person
recently appointed as the Health Physics Services Supervisor.
With a
Bachelor of Science degree, nine years experience at Dresden-most of
which was in the RP department, and supervisory experience in RP and
another station department, this person met the qualifications
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requirement of Technical Specification (TS} 6.1.D. for this position .
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The inspector also noted that the recently completed Unit 2, cycle 13
refueling outage (D2Rl3) was the first outage with designated ALARA
coordinators in the mechanical, electrical, and instrument maintenance
departments.
The coordinators were experienced contract RP individuals.
Although th~ large influx of work requests throughout the early part of
the outage may have limited their time in the plant, they were viewed by
the inspector as a positive addition to outage radiological cont~ols.
Notable, strong performance was also observed in the ENC ALARA group.
No violations of NRC requirements were identified.
4.
Audits and Appraisals (IP 83750)
The inspector reviewed the results of several recent audits includingi
1) a routinely scheduled, corporate audit of RP and environmental
monitoring; 2) a special, in-depth review by station personnel of
radiological work practices believed to be responsible for a significant
increase during the outage in "reportable" personal contamination events
(PCEs)-~those that involve 1000 disintegrations per minute (dpm) or more
as detected with a hand-held frisker probe; and 3) a special, in-depth
review by corporate personnel of outage exposure performance and the
1993 annual exposure goal.
The three audits appeared to be in-depth,
performance-based, and conducted by experienced personnel.
The results
of the two special audits are discussed below.
During the inspection, a
review of a significant increase in "non-reportable" PCEs (those less
than 1000 dpm) was also being conducted by the licensee. This review
was initiated mainly because the number of non-reportable PCEs,
particularly those involving only the shoes, continued to increase,
although the number of reportable PCEs per entry into the radiologically
controlled area (RCA) decreased near the end of the outage;
No violations of NRC requirements were identified by the inspector.
5.
Contamination Control* (IP 83750)
For the outage (including pre-otitage preparation work), there were
As discussed above, the rate of non-reportable PCEs~ particularly
i~volving shoes, remained high when the outage ended.
The audit of the reportable PCE problem jdent~fied the major cause as
the failure of personnel to promptly identify and correct two lea ks of
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contaminated water in the Unit 2 west LPCI (low pressure coolant
inje,ction) room.
Other contributory causes identified included poor
worker dress-out and frisking practices, improper handling of bagged.
contaminated material, juxtaposition of ventilation exhau~t ducts and
contaminated areas, and the lack of centraliz*ed control of.the three
clean-up groups onsite *during the outage. These causes also* appe~red to
be applicable to the non-reportable PCE problem; however, implementation
of the major corrective actions was deferred until completion.of the
non-reportable PCE review.
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6.
Observations by the regional specialist and the senior resident
inspector (SRI) identified additional problems with contamination
control. During an inspection of the Unit 3 west LPCI room, the SRI
observed a leaky cooling line on the core spray system (Inspection
Reports No. 50-237/93020(DRP); 50-249/93020(DR~)). There was no catch
basin attached and the contaminated torus water in the line ~a£ being
allowed to drip to an "uncontaminated" area of the floor. A work
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request ticket attached to the line indicated that it was identified as
leaking four months ago in March 1993. A subsequent meeting between
licensee representatives, the specialist, and the SRI indicated that the
program for hanging catch basins needed improvement.
The SRI also
observed that one of his non-reportable PCEs had not been logged by the
Further inquiry by RP management indicated that
there was inconsistency among the RPTs about recording the
non-reportable PCEs and that the number may be higher than recorded.
The inspector also noted apparent different sensitivities in the PCM-18
contamination monitors and a repeat problem with directing flow from the
temporary drywell ventilation system through a contaminated area.to an
uncontaminated area~ In a previous inspecti-0n (Inspection Reports No.
50-237/91031(DRP); 50-249/91034(DRP)), the inspector identified the
improper set-up of the ventilation system for a Unit 3 outage.
On
February 12, 1993, the licensee identified a similar error with the
system set up for outage D2R13.
In another previous inspection
(Inspection Reports No. 50-237/93007(DRSS)_; 50-249/93007(DRSS)), the
inspector noted the hurried prqcessing of contractor personnel through
the protective clothing exercise in Nuclear General Employee Training;*
many of the reportable PCEs during the outage were attributed to poor
work practices and use of protective clothing.
Although there was minimal health and safety significance to the
reportable PCE problem and no health and safety significance to the non-
reportable PCE problem at the time of the inspection, they represented a
dramatic decline in the licensee's ability to control contamination and
was, as such, a weakness.
A concerted effort by the licensee to address
the problems identified by the inspector and the SRI, and the problems
identified by the licensee in the two special reviews of PCEs was
warranted.
Licensee actions in this area will be reviewed during future
inspections (Inspection Follow-up Item (IFI) No. 50-237/93022-0l(DRSS);
50-249/93022-0l(DRSS)).
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No violations of NRG requirements were identified; however, a weakness
in contamination control was identified~
Outage Exposure Control (IP 83750)
The Unit 2 refueling outage ran from January 17 to May 25, 1993, and
resulted in approximately 1245 person-rem (12.45 per~on~Sievert)~ &f
dose.
It exceeded the original scheduled duration of 91 days and.the
dose goal of 600 person-rem (6 person-Sievert) because of emergent work,
the addition of numerous work requests to resolve several longstanding
equipment problems, and the conducting of first-time preventive
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maintenance.
In view of the outage dose total, the station's 1993
annual goal of 8SO person-rem (8.S person-Sievert) was eventually
revised to 172S person-rem (17.2S person-Sievert).
Examples of outage jobs that were well. planned.and implemented included:
l} ISI, where SO person-rem (O.S person-Sievert} was accrued compared to
an estimate of 93 person-rem (0.93 person-Sievert}, and 2} CRD removal
and replacement, where new equipment and good mockup training resulted
in a dose of 2S person-rem (0.2S person-Sievert} compared to an estimate
of 47.7 person-rem (0.477 person-Sievert}. Other examples of good
exposure control efforts included the extensive use of lead shielding
and a drywell model, chemical decontamination of the RWCU and reactor
recirculation systems, a controlled or "soft" shutdown, reactor pressure
vessel nozzle flushing, power brushing, replacement of 107 test port
hollow plugs on the hydraulic control units with specially made solid
plugs (for shielding and to eliminate a crud trap}, and the use of wear-
resistant, chromium-impregnated Graphitar seals in the CRDs.
In spite of these successes, the addition of numerous work requests near
and shortly after the start of the outage resulted in deficiencies in
job planning and coordination of a large work force, and kept many of
the ALARA personnel at their desks processing paperwork instead of
monitoring jobs in the plant. Examples of outage jobs with planning and
implementation problems included:
l} the replacement of two sections of
RWCU pipe, where welding problems and replacement pipe that was too
short and was misaligned resulted in 66.8 person-rem
(0.668 person-Sievert} compared to the pre-job estimate of
22.9 person-rem (0.229 person-Sievert}; 2} the inspection and repair of
the 2-1001-lA and -18 valves on the shutdown cooling system, where
contamination control tent problems and poor audio-visual equipment
resulted in SO person-rem (O.S person-Sievert) compared to the pre-job
estimate of.13 person-rem (0.13 person-Sievert); and 3) the reactor
disassembly/reassembly, where after good performance on the disassembly,
equipment problems for the reassembly and schedule delays of the head
re-set because of other priority work resulted in 44 person-rem
(0.44 person-Sievert} compared to the pre-job estimate of
23.4 person-rem (0.234 person-Sievert).
As indicated in Section 3, a review of the station's radiation exposure
performance was conducted (March 22-26, 1993) by corporate personnel and
one person from the LaSalle County Station ALARA group.
The review
- documented several examples of good exposure control performance
(several were discussed above), but also identified several problems
including a lack of a detailed breakdown of outage work relative to
department goals {except ENC), failure to evaluate the exposure impact
of the approximately 200 backlogged work requests added late to the
outage, failure to modify the outage and 1993* exposure goalS to reflect
the addition of significant work to the outage, and the lack of*~-*
in-progress job oversight by ALARA personnel. These and other problems
identified by the review team, issues previously identified by the NRC
concerning the balancing of area work loads and coordinating work
support activities {Inspection Reports No. S0-237/93007{DRSS}; S0-
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249/93007(DRSS)), and the work implementation problems noted in the
previous paragraph, indicated a weakness in exposure control. While
some corrective actions were evident during the current inspection as
the licensee prepared for the upcoming Unit 3 refueling outage (D3RI3),
further actions are necessary. This area will _be reviewed during future
inspections (IFI No. 50-237/93022-02(DRSS); 50-249/93022-02(DRSS)).
No violations of NRC requirements were identified; however, a weakness
in outage exposure control was identified.
7.
Management Meeting
8.
On July I2, I993, the NRC and licensee personnel denoted in Section I
met at Dresden to discuss the status of radiological controls at the
station. The licensee's handout from the meeting is attached to this
report.
The meeting was a follow-up to a similar meeting held on
October I5, I992 (Inspection Reports No. 50-237/92029(DRSS);
50-249/92029(DRSS)) and discussions indicated that radiological controls
had improved since the previous meeting.
In addition, the new station
and RP department management was introduced, D2RI3 outage exposure and
contamination control performance was discussed, and the expectation to
incur several additional high dose outages to improve equipment
reliability was stated. During a tour of the plant conducted after the
meeting, NRC personnel raised a concern over the I-I.5 person-rem (O.OI-
O.OI5 person-Sievert) accumulated per non-outage day.
Although the
licensee had active hydrolazing and lead shielding programs, additional
effort to reduce this exposure appeared necessary.
For example, daily
exposure of work groups and individuals could be reviewed to identify
activities and individuals from which incremental dose savings could be
obtained. Another area for improvement was noted by the inspector in
the radwaste storage bay area where on two occasions, poor placement of
water shields and radwaste containers with high dose rates resulted in
unnecessarily high dose rates in the general area (see also Section 8).
The licensee's efforts on reducing non-outage daily dose will be
reviewed during future inspections.
No violations of NRC requirements were identified.
In-plant Observations and Independent Dose Rate Measurements CIP 83750)
In addition to the concern with the general area dose rate in the
radwaste barrelling area, the inspector observed on July I9 a large
number of bags of radwaste in Bay 7 that were not marked or tagged to
indicate the contact dose rate.
One bag on which the inspector
tentatively measured 0.22 rem/hour (2.2 milliSievert/hour) was
subsequently surveyed by the licensee and found to have a maximum
contact reading of 700 mill i rem/hour (7 mill i Sievert/hour).
The. failure
to mark, tag, or label the bags with the contact dose rate reading.is*
contrary to procedure DRP 1160-03, Revision 5, "RADIOLOGICAL SIGNS,
LABELS, SIGNALS AND CONTROLS," and is a violation of Technical
Speci fi cation 6. I I. I that requires that procedures for personnel
radi~tion protection be adhered to (Violation No. 50-237/93022-03(DRSS);
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50-249/93022-03(DRSS)).
This is the third example this year of
inadequate labeling of high dose rate container~. Previously, high dose
rates were found on unlabeled bags of dirty protective clothing
- (Inspection Reports No. 50-237/93007(DRSS); 50-249/93007(DRSS)) and on a
drum of compacted bags of radwaste ( i dent i fi ed _by the licensee on March
1) .
One violation of NRC requirements was identified.
9.
Exit Meeting
The scope and tentative findings of the inspection were reviewed with
licensee representatives (Section 1) at the conclusion of the inspection
on July 29, 1993.
The licensee did not identify any likely inspection
report material as proprietary.
The following matters were specifically
discussed by the inspector:
Attachment:
actions on previous inspection findings (Section 2),
outage exposure control successes and the weakness
(Section 6),
contamination control problems (Section 5),
the delay in correcting the maximum recycle building
ventilation exhaust system problems (Section 2), and
the violation (Section 8) .
Licensee Handout
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Dresden Station
NRC
RADIATION PROTECTION
MANAGEMENT MEETING
July 12, 1993
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Contents
o Introduction/Welcome . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Gary Spedl
Station Manager
a Issues Affecting RP Performance
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Roger Flahive
Technical Superintendent
o Station Radiation Exposure Overview
. . . . . . . . . . . . . Roger Flahive
Technical Superintendent
o Maintenance ........................................... Timothy O'Connor
Maintenance Superintendent
a Exposure Successes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Loi.s Jordan
Health Physics Supervisor
o Lessons Learned . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Patrick Quealy
Operational Health Physicist
GMOrlov--p. 2
Contents
o Exposure Challenges
..... _ ........................*............ Lois Jordan
- Source Term Reduction
Health Physics Supervisor
- Estimating Strategy
- Planning Process
o Station RP Challenges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Lois Jordan
- Contamination Control
Health Physics Supervisor
- Radioactive Material Control
- Advanced Radiation Worker Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Rich Burns
Maintenance/Technical Training Supervisor
o Plant Tour . . . . . . . . . . . . . . . . . . . . . . . . . .
Lois Jordan/Roger Flahive/Timothy O'Connor
o Questions/ Answers/Closing Remarks
Gary Spedl/Lois Jordan
GMOrlov--p. 3
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o Introductions
- NRC
- Commonwealth Edison
o Background
o Current Station Status *
o Agenda
INTRODUCTION/WELCOME
Gary Spedl
Station Manager
GMOrlov--p. 4
ISSUES AFFECTING RP PERFORMANCE
a Station Collective Radiation Exposure
- Long-Standing Equipment Issues
Roger Flahive
Technical Superintendent
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- Top 50 Technical Issues
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- Improving Radiation Protection Involvement In The Station Planning Process
a Station RP Challenges
- Source Term Reduction
- Contamination Control
"'. Radioactive Material Control
GMOrlov--p. 5
a Original Goal
a Current Status
a Revised Goal
a Future
STATION RADIATION EXPOSURE OVERVIEW
Roger Flahive
Technical Superintendent
'GMOrlov--p. 6
MAINTENANCE
Timothy O'Connor
Maintenance Superintendent
Management has taken aggressive steps during the refuel and forced outages to assure the quality
of maintenance activities with the expectation of long term improvement in equipment reliability
and operability
o Outage Scope
- Planning for 1993 Unit 2 Outage
- Original Scope
- Final Scope
- Forced Outage - Unit 3
o Strong management support for resolution of longstanding equipment problems
+ Tri-shielded cable installed in drywell on SRM and IRM detectors
+ Significant motor overhauls
./ 2A Rx. Recirc
.I 2B FW
.I 2C LPCI
.I 2D LPCI
.I 2B cs
.I 2A CB ..
.I 2B CB .
.I 2A SDC
.I 2C CB
.I 2D CB
.I D LIFT PUMP
.I 2A EHC
.I 2B EHC
.I 2A RWCU
.I 2A SBLC
+ 70 drives replaced with new seals by GE (Partnerships recommendations)
./ 1 2 drives were original since installation
GMOrlov--p. 7
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MAINTENANCE (cont'd).
o
Strong management support for resolution of longstanding equipment problems (cont'd)
+ MOVs
./ 61 safety related MOVs overhauled
./ 3 dp tests performed
./ 39 design changes performed to upgrade MOVs
./ On schedule to meet GL 89-10 commitments
+ Management of the Unit 2 refuel outage significantly improved over previous outages
.I High percentage of packages, parts, RWP's, and ALARA reviews at the working
department prior to the start of the outage
.I Contingency plans were in place
+ Used outside consultants to increase our specific understanding of equipment
./ Assure proper implementation of root cause corrective actions
./ Do the job right!
- The P2 computerized scheduling tool was effectively used by all departments
.! Tracking of 10,000 activities during D2R 13
GMOrlov--p. 8 *
MAINTENANCE (cont'd)
o
Strong management support for resolution of longstanding equipment problems (cont'd)
- Adequacy of post maintenance testing (PMT) improved
.I Work Analyst Guide created
.I PMT matrix created
.I PMT data sheets enhanced
.I PMT tracking system created
All testing performed during one equipment run
Equipment operability assured prior to declaring equipment operable
o
Progress has been made in enhancing safety and performance
- Effective root cause analyses were performed
.I Reactor recirc pump seals
.I SBLC pump/motor vibration
.I Stator water cooling pump vibration
.I Condensate/booster system
.I LPCI pump vibration
.I Reactor feed pumps
.I CCSW system
.I Reactor water cleanup aux pump vibration
GMOrlov--p. 9
MAINTENANCE (cont'd)
o
Areas for improvement have been identified, and steps are being taken to address them
D
D
- Training needs have been identified
./ Vertical pump alignment
Challenges to address
.t Selection and use of tools in a manner to minimize equipment damage
.t Radiological practices
.t Administrative controls
Out-of-service program adherence
.t Improve efficiencies with the workers by reducing barriers
Procedural improvements have been identified
./ How to recognize problems during component disassembly/assembly
./ Tool techniques
./ Team formed to implement changes
GMOrlov--p. 10
MAINTENANCE( cont'd)
o
Areas for improvement have been identified, and steps are being taken to address them
(cont'd)
- Major improvements to vendor manuals possible
./ Correct critical dimensions
./ Coupling sizes/configurations
./ Disassembly/reassembly clarifications
./ Vendor or modification enhancement
./ Elimination of non-Dresden specific sections
- Videotaping of major equipment repairs was performed
./ Tool technique
./ Problems noted (what to look for)
./ Visual aids to support classroom sessions
./ Mock-ups for vertical pump alignment
GMOrlov--p. 11
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EXPOSURE SUCCESSES
Lois Jordan
Health Physics Supervisor
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Lead Shielding
- Approximately 50,000 pounds of lead shielding were used in drywell
- Person-rem savings for the temporary shielding installed in the drywell was 430
person-rem.
- General area dose savings was 1 20 person-rem
- Job specific dose savings of 31 0 person-rem
- General Area dose rate reduction of 33 %
- Good Tech Staff support for permit analysis
- Good Laborer support for shielding installation
- The use of "Lead PC" (computer software) for the Reactor Water Cleanup (RWCU) system
to increase the allowable weight limit of the system.
- Lead shielding was used as an effective ALARA tool in several other areas of the plant
during the D2R 13 outage. These areas included:
savings of just over 40 person-rem
- In the RWCU .Pipeway a calculated dose savings of almost 44 person-rem achieved using
lead shi.elding
- In the Shut Down Cooling pump room over 7 person-rem saved
- Dose savings of almost 34 person-rem in Isolation Condenser #2 Valve Room
- Almost 19 person-rem saved in the Isolation Condenser #3 Valve Room
GMOrlov--p. 12
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EXPOSURE SUCCESSES (cont'd)
o
Chemical Decontamination
- Recirculation system chemical decontamination resulted in a drywell decon factor of four
- Estimated dose savings of 250 person-rem
- Chemical decontamination of the RWCU obtained an average decon factor of two to three
- Estimated dose savings of 1 20 person-rem
o
In-Vessel Nozzle Flushing
- Reductions in contact dose rates and general area dose rate (dose reduction of 2 to 5)
- Expended 0.343 Person-rem for flushing activities
- Dose savings resulting from the flushing estimated to be 17 .2 person-rem
- Average decontamination factor of twelve for the instrument nozzles
- General area dose rates were reduced by a factor of 2. 7 for the N-4 nozzles.
GMOrlov--p. 13
EXPOSURE SUCCESSES (cont'd)
o
Source Term Reduction
- There were several successes related to the source term reduction program
during D2R13. Among these successes were:
- Completion of 31 hydrolazes related to outage work
- An average decon factor of ten from completed hydrolazes
- 107 of 1 77 P4 plug change outs completed
- An average dose reduction factor of twenty was realized from the P4 plug change
outs
EJ
ALARA Camera Usage
- The use of ALARA cameras to monitor specific areas for specific jobs proved to be
extremely effective
- Camera usage was highly effective in minimizing the person-rem expenditure on
supervisory and support personnel
- The combination of an intercom system and cameras to enhance communications
between the work area and supervisory personnel in a low dose area greatly enhanced
dose savings as well
GMOrlov--p. 14
EXPOSURE SUCCESSES (cont'd)
o
Contamination Control
- Use of "Cool Suits" to help reduce heat stress while still
providing waterproof protection.
- Reactor reassembly put back together "clean" during D2R12, therefore deconning of the
cavity reactor components was not necessary
- Use of large HEPA units
- Encapsulation to fix contamination
- Glove bags for hydrolazing
o
CRD Pull/Put
- A total of 70 drives were replaced this outage.
- The dose/drive for this evolution was 428 mRem/drive (This figure
encompasses pull/put as well as removal and installation of interferences and shielding)
- Previous Commonwealth Edison average 1 . 1 Rem/drive
GMOrlov--p. 15
';
EXPOSURE SUCCESSES (cont'd)
o
CRD Pull/Put (cont'd)
- No CRDs failed the friction testing.
- NES CRD removal tool was purchased and used with great success
- NES personnel extremely helpful
- Communication problems eliminated by using a telephone-wire driven system
- All shoot out steel removed; ALARA shields installed on drives not removed
o
Soft Shutdown
- The Soft Shutdown was effective in reducing the Co-60 released to reactor coolant
- Peak reactor coolant Co-60 activity reduced by a factor of 6.46 when compared to the
normal shutdown on 8-2-92. The Co-60 activity increased by a factor of 373 for the
normal shutdown* on 8-2, while during soft shutdown the activity increased by a factor of
57.3
- Total Co-60 concentration released to reactor coolant at peak decreased by 85%
when compared to the normal shutdown on 8-2-92. The maximum Co-60 concentration on
8-2 was 9. 7E-2 uCi/ml, while during soft shutdown the maximum concentration of Co-60
was 1.5E-2 uCi/ml
- Total shutdown time attributed to soft shutdown was 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
GMOrlov--p. 16
.. ,
EXPOSURE SUCCESSES (cont'd)
o
Pre-Job Briefings
- The extensive use of pre-job briefings during the outage were an effective and very
informative ALARA tool.
- During the pre-job briefing the following issues were covered:
- Location of work to be performed
- Radiological conditions at the work site
. * RP requirements such as engineering controls, clothing, shielding
- Understanding of dosimetry alarms
- Work practices to minimize potential contamination
- DAW minimization
- The use of the drywell model and surrogate tour system helped to enhance the
effectiveness of the pre-job briefings.
- Photographs, P&IDs and an opportunity for workers to ask questions to familiarize
themselves with the work and the work area proved to be very beneficial.
. . *:
GMOrlov--p. 17
'".j
EXPOSURE SUCCESSES (cont'd)
o
ISi Activities
- Several controls were implemented in order to expedite work and reduce exposure for the*
tasks
- The removal of scaffolding was not performed until the shielding was installed to reduce
the additional exposure of reinstalling scaffolding.
- A detailed schedule was developed which encompassed scaffold requirements, shielding
installation, insulation removal and installation, nozzle hydrolazing, work area congestion
- Each inspection point was assigned an inspection number
- Each point was marked with a neon pink tag and also marked on the drywell model. The
model proved to be extremely beneficial for ISi work by answering worker questions about
point locations, hot-spots, and interferences that might be encountered.
- Dedicated personnel were assigned to this project for completion of all activities. This
provided consistent surveys of the area by the R.P. personnel, and continuity of the work
flow
- Daily team meeting were held to establish priorities, confirm support needed and identify
problems which may exist
- Shiftly* meetings were also held to inform the work crews of conditions on a point by
- point. basis .
.
.
.
- These activities were completed with a dose expenditure of 50 person-rem with an
original estimate of 98 person-rem
GMOrlov--p. 18
EXPOSURE SUCCESSES (cont'd)
o
SRM-24 Removal
- Duane Arnold involvement
- Shielded bucket method quick, safe, and effective. Good method for hot or highly
activated detectors (Nuclear Network)
- Total dose for removal of both the IRM-16 and the SRM-24 was 507 mREM
- Contact dose rates on SRM-24 disposal spool were 40R/hr. This was consistent
with GE's calculations
- Lessons learned from pulling the "cold" IRM-16 successfu.lly incorporated
into the ,,hot" SRM-24 removal
- "Tiger Team" concept was highly effective in promoting teamwork on high risk or high
attention jobs
- Duane Arnold interest in forming a partnership and trade information on a
regular basis
- No Administrative Over-Exposures
- Contaminations. Controls
GMOrlov--p. 19
EXPOSURE SUCCESSES (cont'd)
o
Spent Resin Tank Room Ventilation Mod
- Reverse air flow of spent resin tank room from positive to negative
- Estimated 4.800 person-rem
Actual .949 person-rem
- Design was reviewed and modified so that all work could be performed
from the outside of the room
- Vent duct and hangers were pre-fabricated in the shop
- Penetration plate was pre-fabricated and pre-assembled prior to installation
- Existing scaffolding in the area was modified rather than new scaffolding built
-. Usage of temporary lead shielding
GMOrlov--p. 20
EXPOSURE SUCCESSES (cont'd)
o
Waste Collector System Mod (Radwaste Upgrade Project) - in Progress
- Demolition and replacement of Waste Collector System Piping, Valves and Pumps
- Estimated 13.221 person-rem
Actual 3.259 person-rem
40% of job completed using 25% of estimate dose.
- Utilization of remote cutter
- Utilization of temporary lead shielding
- Hydrolyzing of Waste Collector Tank and flushing of hot spots to
reduce working dose rates
- Established a dedicated work crew using most experienced workers
- Pre-fabrication of materials in a low dose area
GMOrlov--p. 21
EXPOSURE SUCCESSES (cont'd}
o
Unit 3 Fuel Pool Cleanup
- Cut and shipped 56 control rod blades
-: Estimated 4.856 person-rem
Actual 4. 284 person-rem
- Established a dedicated work crew
- Underwater hydrolazing
- Weekly inter-departmental meetings
- Efficiency in blade cutting and loading resulted in 22 blades loaded into one liner (normal
loading is 13-18) thus eliminating the need for a further shipment
GMOrlov--p. 22
LESSONS LEARNED DURING D2R13
Patrick Quealy
Operational Health Physicist
o
- Lead Shielding
- Detailed mock-up training
- Evaluate increased use of washable sleeves
- Evaluate enhancements to lead installation training
- Chemical Decontamination
- Investigate the need to restrict work above decontamination hoses
- Look into restricting use of PCMs near decontamination equipment
- Nozzle Flushing Lance Redesign
- Source Term Reduction
- Evaluate methods to enhance communication between ALARA and crew
- Investigate need to define and enhance communication between departments
involved with Source Term Reduction
- ALARA Cameras
- Evaluate benefits to use of voice activated communications systems to
enha~ce camera usage
- Evaluate need for camera on CRD platform
- Pre:--lnstallation of sleeving on cameras
GMOrlov--p. 23
I
I
LESSONS LEARNED DURING D2R13 (cont'd)
- Contamination Control
- Evaluate expansion of drywell bullpen
- Investigate the possible methods to reduce shoe contaminations
- Investigate the concept of a "Decon Team"
- Evaluate types of PC clothing
-- Nylon Raingear
-- "Cool Suits"
-- Nylon patched clothing
- HEPA Ventilation
- Evaluate feasibility of drywell "octopus"
- Enhance HEPA program
Major Events
- ISi Inspections
- Assess further benefit to "dedicated" project personnel
- RVWLIS Modification
- Look into enhancements in temporary ventilation process
. - IRM/SRM Cable Replacement
- Evaluate crew sizes
- Investigate benefit from sealing room
GMOrlov--p. 24
- -.1
'
. *
LESSONS LEARNED DURING D2R13 (cont'd)
- Valve Activities
- Investigate enhancements to tent/containment program
- Evaluate potential new valve decontamination methods:
-- Encapsulation
-- Bead blasting
-- Hydrolazing
o
Communication to better capture the outage
- Extensive Use of CC:Mail
- Outage Diary
. *'
GMOrlov--p. 25
I.
'
"
'
-EXPOSURE CHALLENGES
o
Source Term Reduction
D
- Successes
- Tip of the Ice Berg
- Remaining Issues
- line rerouting
- line elimination
- expanded chemical decontamination issues
- effective trending, identification, and resolution
- cobalt reduction
- industry initiatives
Estimating Strategies
- - Goal
- Team Concept
- - Current: Establish D3R13 Outage Work Scope
- Developed Strategies/Actio_n Plans
- Establishing an Exposure Budget
- "Building in" the Engineering Control Costs to Achieve ALARA
- Work the Schedule
. *.,
Lois Jordan
- Health Physics Supervisor
GMOrlov--p. 26
.,*
EXPOSURE CHALLENGES (cont'd)
o
Work Control/Scheduling Process
- Goal
- Team Concept
- Decision Making Process
- Establishing Engineering Controls
GMOrlov--p. 27
'1
L
-- -- -
" .*
STATION RP CHALLENGES
o
Contamination Control
- Percentage of plant contaminated
- Personnel contamination events
- trend
- detriments
- root cause evaluation
.I potential areas for review
.I interim actions
o
Radioactive Materials Control
- Self identified need to improve the program
- Key elements
- Expected results
Lois Jordan
Health Physics Supervisor
GMOrlov--p. 28
- STATION *RP CHALLENGES
o
Radiation Worker Training
- Topics
- Targeted Groups
- Goal
Rich Burns
Maintenance/Technical Training Supervisor
GMOrlov--p. 29
' ..
"'
'*
.I
'
"II"
PLANT TOUR
Lois Jordan/Roger Flahive/Timothy O'Connor
GMOrlov--p. 30
. " .
QUESTIONS/ ANSWERS/CLOSING REMARKS
Gary Spedl/Lois Jordan
GMOrlov--p. 31