ML17191A699

From kanterella
Jump to navigation Jump to search
Insp Repts 50-237/98-16 & 50-249/98-16 on 980505-08. Violations Noted.Major Areas Inspected:Plant Support
ML17191A699
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 05/26/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17191A696 List:
References
50-237-98-16, 50-249-98-16, NUDOCS 9806010173
Download: ML17191A699 (15)


See also: IR 05000237/1998016

Text

U.S. NUCLEAR REGULATORY COMMISSION

Docket Nos:

License Nos:

Report Nos:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

9806010173 980526

PDR

ADOC~ 05000237

G

PDR

REGION Ill

50-237; 50-249

DPR-19; DPR-25

50-237 /98016(DRS); 50-249/98016(DRS)

Commonwealth Edison Company

Dresden Nuclear Generating Station, Units 2 and 3

6500 N. Dresden Road

Morris, IL. 60540

May 5-8, 1998

W. Slawinski, Senior Radiation Specialist

K. Lambert, Radiation Specialist

Gary L. Shear, Chief, Plant Support Branch 2

Division of Reactor Safety

EXECUTIVE SUMMARY

Dresden Nuclear Generating Station, Units 2 and 3

NRC Inspection Reports 50-237/98016; 50-249/98016

This announced inspection consisted of an evaluation of the effectiveness of aspects of the

radiation protection (RP) program. Specifically, the inspection focussed on: (1) the radiological

planning and work controls during an ongoing, planned Unit 3 maintenance outage, including

as-low-as-is-reasonably-*achievable (ALARA) planning, oversight of work, and radiation worker

practices; (2) the circumstances surrounding planned intakes that occurred during the- latter

stages *of the recently completed Unit 2 refueling outage; and (3) the calibration and test

programs for certain radiation monitoring equipment. In these areas, one violation of NRC

requirements was identified, and the following conclusions were formed:

Plant Support

The ALARA group was actively involved in the work planning process~ and an effective

interface existed between RP and the work control group. Outage dose goals were

being met due to minimal emergent work and rework and successful performance of

work scheduled to date.

Radiological preparations for work activities were good with one exception related to the

  • preparation for high risk work in the drywell to repair a leaking control rod drive (CRD) .

. Those preparations failed to include surveys of shoot-out steel prior to the initiation of

work in the area, causing the CRD repairs to be delayed. ALARA plans were well

developed and clearly conveyed the radiological work requirements, and pre-job

briefings attended by the inspectors were thorough. Radiological control of work

activities and radiation worker practices were good. Engineering controls, ALARA

initiatives and job planning were instrumental in controlling dose.

One violation was identified concerning an inadequate evaluation of the airborne

concentrations during the tensioning of the Unit 2 drywell cover on April 11, 1998, *

contributing to an intake of radioactivity greater than that planned. Additionally, the RP

staff identified several problems related. to the work activity that Included job turnover

ahd supervisory oversight weaknesses, RPT job coverage deficiencies arid problems

with the scope of the pre-job briefings and associated documentation.

The calibration and test programs for the whole body contamination monitors and the

whole body counters (WBCs) were technically sound and implemented in accordance

with station procedures. Contamination monitor alarms were set at appropriate levels

and instrument sensitivity and alarm operability were successfully demonstrated.

However, a minor discrepancy was identified with the acceptance criteria specified in

the WBC calibration procedure and its application to the last full calibration.

Radiological postings were well maintained and accurately reflected the area

radiological conditions. Container labeling was acceptable, although some minor

deficiencies were noted, which the licensee planned to evaluate and address .

2

Radworker practices throughout the balance of the plant were appropriate, and

radiological housekeeping and material condition of reactor and turbine buildings was

good, with the exception of water intrusion problems in the Unit 2 condensate pump

booster area.

3

DETAILS

IV. Plant Support

R.1

Radiological Protection and Chemistry (RP&C) Controls

R1 .1

Radiological Planning for the Unit 3 Maintenance Outage

a.

Inspection Scope*(IP 83729)

The inspectors reviewed the radiological planning and dose goal development for the

planned 15-day Unit 3 maintenance outage (D3P02). The inspection included a review

of the planned outage work scope and work packages, review of dose projections, and

discussions with the ALARA and radiation protection (RP) staffs and plant workers.

b.

Observations and Findings

The station's work control group included an RP staff ALARA representative to ensure

RP involvement in the work planning process. To initiate work at the station, an action

request (AR) was generated and screened by the work control group. A work request

(WR) was generated, if necessary, based on the scope of the work and the radiological

conditions. that may be involved. If the WR involved work in a radiologically protected

area (RPA) or radiological work in other areas, the WR was reviewed by the work

control group's ALARA representative, and radiation dose estimates were generated .

from job history files and plant radiological data base information. Work packages were

then forwarded by the work control group to the ALARA staff for an ALARA action

  • review (AAR), if procedure specified dose or work area radiological condition thresholds

were met. The work package and, if applicable, the AAR were used to develop the

RWP. The RWP was subsequently reviewed and approved by work control group's

ALARA representative and, if necessary, the ALARA group.* Inspector review of work

packages, outage work schedules and discussions with the ALARA group disclosed that

the outage planning and scheduling process was adequately developed.

The station's dose goal for D3P02 was eight person-rem, based on the limited scope of

work that was scheduled and the lack of significant emergent and rework that was

anticipated. The most radiologically significant outage activities included control rod

drive maintenance (1.1 person-rem); drywell nuclear instrumentation maintenance (1.5

person-rem); main condenser maintenance (1.1 person-rem); miscellaneous drywell

maintenance (1.0 person-rem); and turbine building X-area maintenance (0.9

person-rem). Although little emergent work was projected for the outage, outage

maintenance activities identified a leak in the "A-6" control rod drive (CRD) mechanism,

necessitating its immediate repair. The emergent CRD repair work was expected to add

about 0.5 person-rem to the outage dose goals. The station had not identified any

additional significant dose producing emergent work or rework during the outage to

date. Consequently, little impact on the dose goal was expected from either emergent

work or rework .

4

The licensee was evaluating a proposed extension to the outage schedule by four days,

to repair a circulation water valve located outside the protected area. If the outage

  • extension occurred, additional but yet undefined work within the RPA was expected to

be planned. Despite any extension to the outage, the ALARA group believed that the

originally projected dose goals would be achieved due to the lack of emergent work and

rework and the success experienced in completing scheduled activities. As of May 8,

1998, with the outage about 40 percent complete, the station had accumulated an

outage dose of 1.9 person-rem (25 percent of the outage dose estimate). Based on the

work progress and dose to date, the outage dose goal was being revised to six

person-rem.

c.

Conclusions

The ALARA group was actively involved in the work planning process, and an effective

interface existed between RP and the work control group. Outage dose goals were

being met due to minimal emergentwork and rework and successful performance of

work scheduled to date.

R1 .2

ALARA Controls and Oversight of Radiation Work

a.

Inspection Scope (IP 83729)

The inspectors reviewed the effectiveness of the station's radiological controls, work

practices, and oversight of radiological work activities. The inspectors interviewed

workers; reviewed AARs and radiation work permits (RWPs), total effective dose

equivalent (TEDE) ALARA evaluations, and applicable procedures; attended pre-job

briefings; and observed ongoing work in various areas of the station~

b.

Observations and Findings

Radiation work permits, AARs, TEDE ALARA evaluations arid associated radiological

controls for the following work activities were reviewed:

A-6 control rod drive leak repair

Reactor water clean-up (RWCU) pipe replacement

Unit 2 dryer/separator pit and "cattle chute" decontamination

Rebuilding of the high pressure core injection check valve # 2301-7

The inspectors noted good engineering controls to reduce general area dose rates and

surface contamination dispersal including hydrolyzing of pipes and valves, judicious use

of water as a wetting agent to reduce the potential for non-fixed contamination from

  • becoming airborne, and use of high efficiency particulate air (HEPA) vacuums during

grinding operations. Additional ALARA controls observed in use included wireless

remote monitoring equipment, a variety of protective clothing, and air supplied bubble

hoods. Also, personnel contaminations and intakes were on occasion planned as a

dose savings method, if the ALARA evaluations determined that worker dose would be

5

reduced if work was performed without the use of respiratory protection equipment or

performed with less restrictive protective clothing.

The inspectors attended pre-job briefings for the work activities listed above and noted

that the briefings were thorough and comprehensive. The work scope and workers'

roles were clearly discussed; radiological information was exchanged; and good

communication between work groups and radiation protection staff was evident." The

inspectors observed work activities and radiation worker (radwmker) practices

associated with th*e control rod drive leak repair, RWCU pipe section replacement and

decontamination, and removal of the "cattle chute" from the Unit 2 dryer/separator pit.

During these activities, radiological controls were implemented in accordance with the

RWP and AARs, and workers generally demonstrated appropriate use of ALARA

techniques and were aware of radiological conditions in their work areas. Workers were

also observed appropriately *removing protective clothing and exhibited good radworker

practices.

Although the overall preparations and radiological control of work activities were good,

the inspectors noted an example when the radiological preparation for a high risk job

was not completed prior to commencement of the work. Specifically, while several

workers prepared to remove under-vessel "shoot-out" steel and complete other work in

the drywell in preparation for CRD leak repairs, a radiation protection technician (RPT)

identified significant levels of smearable contamination on the steel. Since significant

levels of contamination were not anticipated, the RPT stopped the work and informed

the workers that protective clothing requirements would have to be reevaluated and that

another pre-job briefing conducted before removing the shoot-out steel. The inspectors

noted that the technician acted appropriately to the unexpected conditions; however, the

inspectors expressed concern that the pre-job surveys failed to include the shoot-out

steel. The licensee acknowledged that pre-job surveys should have been more

extensive and was evaluating the matter.

c.

Conclusions

Radiological preparations for work activities were good with one exception related to the

preparation for high risk work in the drywell to repair a leaking CRD. ALARA plans were

well developed and clearly conveyed the radiological work requirements, and pre-job

briefings attended by the inspectors were thorough. Radiological control of work

activities and radiation worker practices were good. Engineering controls, ALARA

initiatives and job planning were instrumental in controlling dose.

R1 .3

Review of Planned Personnel Contamination and Intake Incident

a.

Inspection Scope (IP 83750)

The inspectors reviewed the circumstances surrounding planned personnel

contaminations and intakes that took place during the latter stages of the Unit 2

refueling outage on April 11, 1998, while tensioning the Unit 2 drywell cover. The

inspectors reviewed the licensee's investigation of the event, the applicable RWP and

6

ALARA evaluations; reviewed procedures and supporting documentation; and discussed

the event with RP staff.

b.

Observations and Findings

The drywell cover installation work involved a two person crew working in the reactor

cavity for about two hours, tensioning the cover bolts and studs. Work area dose rates

were generally low (about 100 millirem/hour). while removable contamination was

significant, ranging from several hundred millirad/hour up to about 3 rad/hr over a 100

square centimeter surface area. Further decontamination of the cavity was not

performed because the ALARA group determined that the overall dose expenditure

would exceed the dose accrued during the war~ evolutions in the area. Engineering

controls included the use of a HEPA filtration unit positioned near the workers to control

airborne radioactivity and surface wetting and misting. Respiratory protection

equipment and face shields were not required to be worn by the workers, and nylon

coveralls were used over protective clothing in lieu of heavy rubber gear to avoid heat

stress problems.

On April 11, 1998, two contract boilermakers completed the work and alarmed the

contamination monitors as they attempted to exit the RPA. Contamination was detected

on isolated areas of the face of both workers up to about 20,000 disintegrations per

minute (dpm), and an additional 250,000 dpm was detected on the forearm of one

worker. Both workers were decontaminated; however, they intermittently alarmed the

portal monitors prompting invivo (whole body count (WBC)) bioassays. Initial WBCs on

April 11 detected small intakes of cobalt-60 and manganese-54 for both workers.

Follow up WBCs taken two and three days post event showed that the intake cleared

one of the workers, and resulted in a committed effective dose equivalent (CEDE)

equating to 2 mrem. However, the other worker's WBC continued to indicate the

presence of radioactive material, suggesting that inhalation may have been a primary

route of intake. Dose calculations performed by the RP staff concluded that the internal

(inhalation pathway) dose to the worker was 68 mrem CEDE, and the TEDE was 212

mrem. Shallow (skin dose equivalent (SOE)) doses incurred by both workers due to

skin contamination were minimal. The inspectors reviewed the licensee's dose

evaluations and supporting data, and concluded that the assessments were technically

sound.

The intakes were initially thought to be unplanned, and a prompt investigation was

conducted by the licensee. However, the investigation did not identify any unplanned

intakes, although the magnitude of one of the intakes exceeded the. planned dose.

According to the licensee, confusion occurred within the RP organization about what

was planned for the job. The day shift RP staff understood that both worker

contaminations and intakes were planned for the cover tensioning work; however, both

the night shift RP staff.on duty when the contaminations occurred and the involved

workers were unaware that intakes were planned. The licensee's investigation found

that documentation was misplaced, pre-job briefings may not have been attended by all

appropriate staff, RP turnover from day to night shift was poor, RPT coverage for refuel

floor activities may not have been adequate and RP management oversight of the job

7

was insufficient. Specifically, the TEDE ALARA evaluation and supporting

documentation used to justify the planned intakes and establish its parameters was lost

from the licensee's RWP file and never found. Additionally, all necessary night shift RP

staff may not have attended the April 2 and April 6, 1998, pre-job briefings at which the

planned intakes were discussed. While night shift RP staff that were interviewed by the

  • 1icensee during their investigation claimed they attended the briefings, attendance could

not be confirmed because records of these briefings were incomplete. Also, no

attendance records were maintained for several, less formal daily shift briefings that

were reported to have been held on the refuel floor between April 7 through April 11,

1998. The lack of briefing checklists documenting the topics discussed during each of

these briefings compounded the staffs confusion. The licensee further indicated that the

briefings on April 2 and 6 may have been overly broad, since several other phases of

reactor reassembly were also discussed at those briefings.

The licensee recognized that the failure to complete pre-job briefing checklists and

maintain complete attendance records for each briefing was contrary to Dresden

Administrative Procedure (OAP) 12-09, (Rev 14) "Dresden Station ALARA Program."

Technical Specification (TS) 6.8.A requires, in part, that written procedures be

established and implemented covering the activities recommended in Appendix A of

Regulatory Guide (RG)1.33, Revision 2, February 1978. Appendix A of RG 1.33

recommends that procedures be implemented covering procedural adherence and the

ALARA program. OAP 09-13 (Rev 6) "Procedural Adherence," requires, in part, that

procedures be adhered to during the course of activities and that each step of the

procedure be performed exactly as written. The failure to follow the requirements of the

ALARA program procedure with respect to documentation of pre-job briefings is a

violation of TS 6.8.A. However, this non-repetitive, licensee identified violation is being

treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC

Enforcement Policy (NCV 50-2371980016-01; 50-249/98016-01 ).

The licensee's (recreated) TEDE ALARA evaluation indicated that air concentrations of

12 derived air concentrations (DACs) were anticipated during the tensioning work, but

engineering controls were expected to reduce these concentrations to 2 DAC. The

TEDE ALARA evaluation determined that use of respiratory protection equipment would

not result in an overall reduction in worker doses, and concluded that worker

contaminations and intakes were justified. Radiological hold points of 2 rad/hour

smearable contamination over.a 100 square centimeter surface area and 2 DAC

airborne were established to limit worker shallow (skin) dose to less than 50 mrerri'and

the CEDE to 10 mrem. The licensee also assumed that its engineering controls coupled

with the greasy (heavy) form of the work surface contamination was sufficient to

maintain airborne concentrations less than the 2 DAC hold point.

The inspectors identified problems concerning the licensee's air sampling for this

evolution: Two stationary air samples were collected in the cavity during the job

evolution. The air samplers were physically located about 180 degrees apart within the

cavity where the work took place. Post job analysis of these air samples showed air

concentrations to be between 0.3 and 0.6 DAC. However, the air samples were not

always representative of the work environment during the entire job evolution because:

8

(1) air was sampled in stationary locations while the workers moved around the

circumference of the cavity; and (2) the samples were collected for approximately 22

and 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> durations, respectively, while the work was complete in about two hours.

Consequently, the air samples were diluted with air obtained during non-work related

time periods. Furthermore, the seven hour duration sample was discontinued about one

hour before the job was complete, and the other sample continued to be collected for

about three hours after the job was completed. A continuous air monitor (CAM) was

operating on the refuel floor during the job; however, it was not used to sample the

cavity work air environment so as to provide a real time indication of the air

concentrations. Although a 2 DAC air concentration hold point was established and was

a key parameter for allowing the work to be completed without respirators, appropriate

measures were riot implemented to ensure the hold point was not exceeded while the

job progressed. Although the event did not result in a significant intake of radioactive

material and the potential for an exposure in excess of regulatory limits was small, the

weaknesses in imp.!ementing the air sampling program, together with the other problems

that occurred during the job, placed the workers at increased radiological risk.

10 CFR 20.1501 requires that each licensee make or cause to be made surveys that

may be necessary for the licensee to comply with the regulations in Part 20 and that are

reasonable under the circumstances to evaluate the extent of radiation levels,

concentrations or quantities of radioactive materials, and to the potential radiological

hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an

evaluation of the radiological conditions and potential hazards incident to the production,

use, transfer, release, disposal, or presence of radioactive material or other sources of

radiation. The failure to adequately evaluate the airborne concentrations in the cavity

during the tensioning of the drywell cover was a violation of 10 CFR 20.1501, 'to

demonstrate compliance with the dose limits in 10 CFR 20.1201 (a)(1 )(i) (Violation No.

50-237/98016-02; 50-~49/98016-02) .

. The licensee formulated several proposed corrective actions to address the self-

identified problems related to the event and those problems identified by the NRC

inspectors. Proposed corrective actions included better controls over original RWP file

documentation, reduced scope of pre-job briefings and conducting them in the ALARA

briefing room to allow enhanced communication and better interaction with work crews,

  • improved RP shift turnover briefings and consideration for the use of lapel air sampling

in certain situations.

c.

Conclusions

One violation was identified concerning an inadequate evaluation of the airborne

concentrations during the tensioning of the Unit 2 drywell cover on April 11, 1998,

contributing to an intake of radioactivity greater than that planned. Additionally, the RP

staff identified several problems related to the work activity that included job turnover

and supervisory oversight weaknesses, RPT job coverage deficiencies and problems

with the scope of the pre-job briefings and associated documentation, contrary to station

procedure.

9

R2

Status of RP&C Facilities and Equipment

R2.1

Calibration and Test Program for Radiation Monitoring Equipment

a.

Inspection Scope (IP 83750)

The inspectors reviewed the calibration and test program for whole body contamination

monitors and the invivo whole body counters (WBCs ). The inspection included a

walkdown of selected monitors, independent testing of monitor alarms and set points,

- observation of calibration source condition, and review of procedures and calibration*

and test res.ults. The following procedures were reviewed:

DRP 5822-07 (Rev 01 ), "Calibration, Maintenance and Operation of the IPM-9

Whole Body Frisking Monitor;"

DIS 1800-04 (Rev 09), "Personnel Contamination Monitor (PCM) Calibration;"

DRP 5822-08 (Rev 0), "Sensitivity Checks of Personnel Contamination

Moriitors;"

DRP 5822-10 (Rev 0), "Operation and Calibration of the Eberline PM-7 Portal

Monitors;"

DRP 5822-41 (Rev 03), "Calibration and Operational Checks of the Eberline

PCM-2 Whole Body Contamination Monitor;" and

DRP 5410.:.08 (Rev 01), "Abacos Plus Whole Body Counter Calibration."

b.

Observations and Findings

Over the last couple years, the licensee purchased and put into service several new

whole body contamination monitors, as part of a* 1ong term program to upgrade radiatio.n

monitoring equipment. Three types of personnel whole body contamination monitors

were used to detect contamination from beta and/or alpha emitting radionuclides.

Whole body portal monitors were used to detect gamma emitting radioactive material.

Beta and alpha sensitive contamination monitors were calibrated annually using

radioactive sources traceable to the National Institute of Standards and Technology

(NIST). Detector efficiencies for cobalt-60 and technetium-99 beta emitter response

ranged from about 8-20%, depending on the monitor and its specific detector, and 10-

25% for response to an americium-241 source (alpha emitting). Contamination monitor

alarms were set at 5000 dpm beta and 1000 dpm alpha. The gamma sensitive portal

monitors detected less than 50 nanocuries cobalt-60 at a 90% confidence level, and

alarms were set at approximately 40 nanocuries. These monitors were calibrated semi-

annually and were used as a passive (screening) monitoring system, in lieu of the whole .

body counters.

Calibration and test methodologies and associated procedures were technically sound,

and calibrations of those monitors selected for review by the inspectors were performed

as required by procedure. Alarm sensitivity functional checks were performed daily on

most monitors and weekly on others, using radioactive sources with activities equivalent

to the alarm set points. The license demonstrated the alarm sensitivity check for

several monitors selected by the inspectors. The checks employed the use of a 40

10

nanocurie cobalt-60 button source for the portal monitor and technetium-99 and

americium-241 sources in varying geometries for the other monitors. Detector alarms

activated as required, although repeated attempts were required for one of the portal

monitors.

Two WBCs were used and calibrated annually by the station. The last calibration was

performed with a mixed gamma emitting NIST traceable (nominal 10 microcurie)

calibration source, housed in a phantom to provide a reference counting geometry for

the lungs, whole body and thyroid. Calibration methodology was also technically sound

and procedures included tolerances that satisfied applicable American National

Standards Institute (ANSI) performance criteria. However, the inspectors identified a

minor problem with the application of the full width half maximum tolerance criteria

specified in the procedure, relative to the last calibration for one of the WBCs. The

health physicist responsible for the calibration acknowledged the discrepancy and

planned to revise the tolerance criteria in the procedure to ensure its consistency with

ANSI recommendations.

c.

Conclusions

The calibration and test programs for the whole body contamination monitors and the

WBCs were technically sound and implemented in accordance with station procedures.

Contamination monitor alarms were set at appropriate levels, and instrument sensitivity

and alarm operability were successfully demonstrated .. A minor discrepancy was

identified with one of the acceptance criteria specified in the WBC calibration procedure

and its application to the last full calibration.

R4

Staff Knowledge and Performance in RP&C

R4.2 . Plant Walkdowns and Other Observations

a.

Inspection Scope (IP 83750)

Several walkdowns of the reactor and turbine buildings were conducted during the

inspection to review radiological posting and labeling, housekeeping and radworker

practices.

b.

Observations and Findings

Radiological postings were well maintained. The inspectors determined, through

independent measurements, that radiation areas and high radiation areas were

appropriately posted, and that high and locked high radiation areas were controlled in

accordance with station procedures and regulatory requirements. However, the

inconsistency with some of the radiation area postings between Unit 2 and Uni~ 3

reactor buildings described in Inspection Report 50-237/98011 (DRS); 50-249/98011

(DRS) continued, and will be evaluated by the licensee in June of 1998, as previously

committed. Labeling of containers was adequate; however, some minor deficiencies

were noted with the labeling of equipment and tool containers, which the licensee

11

planned to evaluate and address. Appropriate contamination control practices were

observed to be used by workers during balance of plant work activities observed by th.e

inspectors throughout the inspection.

Radiological housekeeping and material condition in the reactor and turbine buildings

was good with the exception of the Unit 2 condensate booster pump area. Several wall

and floor areas of the booster pump room were cracked; paint was chipped and peeled;

and-water was puddled on the floor in several areas. Station personnel indicated that

ground water in-leakage had been a recurrent problem in this area and caused the

problems observed by the inspectors. While most of the room was non-contaminated, a

section was .controlled as a contaminated area, increasing the potential for

contamination control problems should ground water intrusion continue. The licensee

acknowledged the inspectors' concerns and indicated that plans were being considered

to improve the condition of the area.

c.

Conclusions

Radiological postings*were well maintained and accµrately reflected the area

radiological conditions. Container labeling was adequate, although some minor

deficiencies were noted, which the licensee planned to evaluate and address.

Radworker practices throughout the balance of the plant were appropriate and

radiological housekeeping and material condition of reactor and turbine buildings was

good with the exception of the Unit 2 condensate pump booster area.

V. Management Meetings

XI

Exit Meeting Summary

The inspectors presented the preliminary inspection findings to members of licensee

management on May 8, 1998, and further discussed the findings with the acting radiation

protection manager (RPM) during a telephone conversation on May 21, 1998. The licensee

acknowledged the findings presented and did not identify any of the documents reviewed as

proprietary .

12

PARTIAL LIST OF PERSONS CONTACTED

G. Abrell, Regulatory Assurance

L. Aldrich, Acting Radiation Protection Manager

J. Almon, Training Manager

S. Barrett, Operations Manager

S .. Cieszkiewicz, Health Physicist

R. Freeman, Site Engineering Manager

M. Friedman, Lead Technical Health Physicist

R. Gideon: Unit 2 Outage Manager

C. Howland, Unit 1.Plant Manager

J. Kuczynski, Health Physicist

J. Lewis, Business Manager

W. Lipscomb, Assistant to Site Vice President

D. Miller, Unit 1 Lead Radiation Protection Shift Supervi~or

J. Moser, Lead Operational Health Physicist

P. Quealy, Unit 1 Health Physics Supervisor

F. Spangenberg, Regulatory Assurance Manager

  • P. Swafford, Station Manager

D. Winchester, Manager, Quality and Safety Assessment

, IP 83750

IP 83729

Opened

50-237 /98016-01

50-249/98016-01

50-237/98016-02

50-249/98016-02

Closed

None

INSPECTION PROCEDURES USED

Occupational Radiation Exposure

Occupational Radiation Exposure During Extended Outages

ITEMS OPENED AND CLOSED

NCV

Failure to document pre-job briefings and maintain attendance

records.

VIO

Failure to adequately evaluate airborne concentrations during

tensioning of the drywell cover.

13

AR

AAR

A LARA

ANSI

CEDE

CRD

DAC

DPM

HEPA

NIST

Radworker

RG

RP

RPA

RP&C*

RPT

RWCU

RWP

SOE

TEDE

TS

WBC

WR

LIST OF ACRONYMS USED

Action Request

ALARA Action Review

As-Low-As-Reasonably-Achievable

American National Standards Institute

Committed Effective Dose Equivalent

Control Rod Drive

Derived Air Concentration

Disintegrations Per Minute

High Efficiency Particulate Air

National Institute for Standards and Technology

Radiation Worker

Regulatory Guide

Radiation Protection

_

Radiologically Protected Area

Radiation Protection and Chemistry

Radiation Protection Technician

Reactor Water Cleanup

Radiation Work Permit

Skin Dose Equivalent

Total Effective Dose Equivalent

Technical Specification

Whole Body Counter

Work Request 14

PARTIAL LIST OF DOCUMENTS REVIEWED

D3P02 Schedule, Revision 9

RWP 980019, Rev 0, Units 2 And 3 Refuel Floor Preparation and Maintenance Activities

RWP 988101, Rev 0, D3P02 Drywell Nuclear Instrumentation Maintenance Activities

. RWP 988102, Rev 0, D3P02 Drywell In Service Inspection (ISi) Activities

RWP 988103, Rev 0, D3P02 Drywell Control Rod Drive (CRD) A-6 Leak Repair

RWP 988202, Rev 0, D3P02 Reactor Building Reactor Water Clean-Up (RWCU) System

Maintenance Activities

RWP 988303, Rev 0, D3P02 Turbine Building X-Area Maintenance Activities

RWP 987201, Rev 0, D2R15 Reactor Disassembly/Reassembly and Related Activities

DRP 5822-07 (Rev 01 ), "Calibration, Maintenance and Operation of the IPM-9 Whole Body

Frisking Monitor"

DIS 1800-04 (Rev 09), "Personnel Contamination Monitor (PCM) Calibration"

DRP 5822-08 (Rev 0), "Sensitivity Checks of Personnel Contamination Monitors"

DRP 5822-10 (Rev 0), "Operation and Calibration of the Eberline PM-7 Portal Monitors"

DRP 5822-41 (Rev 03), "Calibration and Operational Checks of the Eberline PCM-2 Whole

Body Contamination Monitor".

DRP 5410-08 (Rev 01), "Abacos Plus Whole Body Counter Calibration"

DRP 6020-02 (Rev 04 ), "Radiological Air Sampling"

OAP 12-09 (Rev 14), "Dresden Station ALARA Program"

PIF #01998-02701 and Prompt Investigation, "Possible Intakes While Tensioning the Drywell

Head"

15