ML17193A439
| ML17193A439 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/12/1980 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Oconnor J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML17193A440 | List: |
| References | |
| NUDOCS 8010220439 | |
| Download: ML17193A439 (6) | |
See also: IR 05000237/1980013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION Ill
799 ROOSEVELT ROAD
GLEN ELLYN, ILLINOIS 60137
Docket No. 50-237
Docket N6. 50-249
Commonwealth Edison Company
ATTN:
Mr. James J. O'Connor
President
Post Office Box 767
Chicago, IL 60690
Gentlemen:
SEP 12 1980
Subject:
Health Physics Appraisal
~CENTRAL FllES
The NRC has identified a need for licensees to strengthen the health physics
programs at nuclear power plants and has undertaken a significant effort to
ensure that action is taken in this regard.
As a first step in this effort,
the Off ice of Inspection and Enforcement is conducting special team appraisals
of the health physics programs, including the health physics aspects of radio-
active waste management and onsite emergency preparedness, at all operating
power reactor sites.
The objectives of these appraisals are to evaluate the
overall adequacy and effectiveness of the health physics program at each site
and to identify areas of weakness that need to be strengthened.
We will use
the findings from these appraisals as a basis not only for requesting indivi-
dual licensee action to correct deficiencies and effect improvements but also
to improve NRC requirements and guidance.
This effort was identified to you
in a letter dated January 22, 1980, from Mr. Victor Stello, Jr., Director,
NRC Office of Inspection and Enforcement.
During the period June 18 to July 2, 1980, the NRC conducted the special appraisal
of the health physics program at *the Dresden Nuclear Power Station.
Areas ex-
amined during this appraisal are described in the enclosed report (50-237/80-13;
50-249/80-17).
Within these areas, the appraisal team reviewed selected proce-
dures and representative records, observed work practices, interviewed personnel,
and performed independent measurements.
We request that you carefully review
the findings of this report for consideration in improving your health physics
program.
Findings of this appraisal indicate that several significant weaknesses exist
in your health physics program.
These weaknesses, listed in Appendix A,
"Significant Appraisal Findings," include insufficient management support for
professional Health Physicists, RCT training, access control, contamination
control, abnormal c6ndition surveillance, monitor operability surveillance, and
emergency response.
While we believe that the identified weaknesses require
correction to enable you to perform well in* normal and abnormal conditions, your
present health physics program is considered adequate for continued operation
- while achieving acceptable corrective action:
Commonwealth Edison Company
- 2 -
SEP 12 1980
We recognize that an explicit regulatory requirement pertaining to each
significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for the
health and safety of workers and the public, you are requested to submit a
written statement within twenty (20) days of your receipt of this letter,
describing your corrective action for each significant weakness identified
in Appendix A, including:
(1) steps which have been taken; (2) steps which
will be taken; and (3) a schedule for completion of action.
This request
is made pursuant to Section S0.54(f) of Part SO, Title 10, Code of Federal
Regulations.
During this appraisal, it was also found that certain of your activities do
not appear to have been conducted in full compliance with NRC requirements,
as set forth in the Notice of Violation enclosed as Appendix B.
The items
of noncompliance in Appendix B have been categorized into the levels of
severity as described in our Criteria for Enforcement Action dated December 13,
1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations, requires
you to submit to this office, within twenty (20) days of your receipt of this
notice, a written statement or explanation in reply, including:
(1) corrective
steps which have been taken and the results achieved; (2) corrective steps
which will be taken to avoid further items of noncompliance; and (3) the date
when full compliance will be achieved.
You should*be aware that the next step in the NRC effort to strengthen health
physics programs at nuclear power plants will be a requirement by the Office
of Nuclear Reactor Regulation (NRR) that each licensee develop, submit to the
NRC for approval, and implement a Radiation Protection Plan. * Each licensee
will be expected to include in the Radiation Protection Plan sufficient mea-
sures to provide lasting corrective action for significant weaknesses identi-
fied during the special appraisal of the current health physics program.
Guidance for the development of this plan will incorporate pertinent findings
from all special appraisals and will be issued by NRR in the fall of this year.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title
10, Code of Federal Regulations, a copy of this letter and the enclosures will
be placed in the NRC's Public Document Room.
If this material contains any
information that you believe to be proprietary, it is necessary that you make
a written application within 20 days to this office to withhold such informa-
tion from public disclosure.
Any such application must be accompanied by an
affidavit, executed by the owner of the information, which identifies the
document or part sought to be withheld and which contains a statement of
reasons which addresses with specificity th~ items which will be considered
,\\
'
Commonwealth Edison Company
- 3 -
by the Commission as listed in Subparagraph (B)(4) of Section 2.790.
The
information sought to be withheld shall be incorporated as far as possible
into a separate part of the affidavit. *If we do not hear from you in this
regard within the specified period, this letter and the enclosures will be
placed in the Public Document Room.
We will gladly discuss any questions you have concerning this inspection.
Enclosures:
1.
Appendix A, Significant
Appraisal Findings
2.
Appendix B, Notice of
Violation
3.
IE Inspection Report
No. 50-237/80-13 and
No. 50-249/80-17
cc w/encls:
Mr. J. S. Abel, Director of
Nuclear Licensing
Mr. D. Scott, Plant
Superintendent
Central Files
Reproduction Unit NRC 20b
Local PDR
Mr. Dean Hansell, Office of
Assistant Attorney General
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{/j/J!'
Sch~a
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Paull~
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Sincerely,
James G. Keppler
Director
Appendix A
Significant Appraisal Findings
Based on the Health Physics appraisal performed June 18 to July 2, 1980,
the following items appear to require corrective actions.
(Section
references are to the Details portion of the enclosed inspection report.)
1.
Organization and Management
The Health Physics program is generally weak, rigid in perspective,
and lacking in the qualities of curiosity and aggressiveness char-
acteristic of a good program.
It suffers from lack of professional
health physics guidance and review needed to maintain a progressive,
up-to-date program and from insufficient in-plant presence of first
line supervision.
Strong antagonisms exist between the Radiation/
Chemistry Technicians (RCT's) and the Health Physicists (HP's) and
there is an evident lack of cooperation needed to build a strong
program.
Management's failure to define the role of the professional
HP's and to support them on industrial relations issues has signifi-
cantly undermined their influence on the program.
(Section 2).
2.
Qualification and Training
Weaknesses in training and retraining of RCT's contribute strongly to
- weaknesses observed in the health physics program.
The evident need
is for training in the use of basic health physics skills to recognize,
investigate, and evaluate anomalies.
A combination of resources
including professional health physicists, experienced RCT's, and
foremen is needed to develop such skills.
Other weaknesses identified
were neglect of retraining, incomplete emergency training, degradation
of specific skills during the long period rotation between job assign-
ments, and RCT scheduling without regard to qualification status.
(Section 3)
3.
Access Controls
Access controls for high radiation areas (HRA's) do not provide
sufficient assurance that all HRA entries are made with full knowledge
of dose rate conditions nor do they require sufficient awareness to
ensure that overdue exit is promptly recognized.
Access controls for contaminated areas suffer from confusion over
required protective footwear, particularly in the area between double
step-off pads.
Access control requirements must be clearly defined, promulgated, and
enforced.
(Sections 5.4 and 5.6.)
Appendix A
- 2 -
4.
Contamination Control
Several weaknesses were observed relating to control of contamination
and contaminated material at the station:
a.
The presence of contaminated materials in an unrestricted area
dump (Section 5.7).
b.
An unlabeled, highly contaminated tool in a storage area in the
Unit 3 Reactor Building (Section 5.7).
c.
Failure to maintain acceptable control of contamination on
laundered protective clothing (Section 9.1).
d.
Frequent occurrence and casual acceptance of incidents of low
level personal contamination (Section 6.2).
e.
Poor facilities for personal and shoe decontamination (Section 9.4).
Overall, the general station attitude appears to be that contamination
cleanup is the province of the stationmen and is not of much concern to
anyone else (Section 9.2).
5.
Surveillance
The surveillance program, while acceptably performed under routine
conditions, is not sufficiently aggressive in the investigation and
evaluation of anomalous or unexpected conditions. It appears to lack
the elements of curiosity and concern essential to a high quality
surveillance program.
These characteristics were most noticeable in
the handling of contamination incident~, where surveys were directed
at defining control boundaries but not identifying and controlling
of the sources and routes by which contamination spreads.
Contamina-
tion occurrences appear to be treated as singular events without
relation to the overall pattern of contamination control.
This per-
formance clearly reflects weaknesses in training and management.
(Sections 2.3, 3.5, 3.6, 6.2, 6.4.)
6.
Instrumentation
Control room printouts of area monitor readings are illegible or
nearly so because of the large number of monitors on a single recorder.
As a data source, such a record would be virtually useless.
Also,
the non-inking condition of the reactor building vent monitor recorder
on June 27 went unnoticed and uncorrected.
Such situations indicate
an unacceptable surveillance program for these instruments.
Appendix A
- 3 -
The appraisal team also noted weaknesses of quality control practices
in the laboratory and counting room.
(Sections 7.5, 7.6, and 7.7.)
7.
Emergency Response
The following weaknesses in the station's preparedness for emergency
monitoring and sampling were identified:
a.
Lack of shielding at sampling stations for containment and
reactor coolant samples and in the hot laboratory.
(Sections
9.7 and 11.2.)
b.
Incomplete training of RCT's in emergency procedures for sampling
and monitoring.
(Section 11.3.)
c.
Poor hot sample handling practices indicating incomplete rehearsal
of emergency procedures.
(Sections 9.7 and 11.3.)
d.
Inadequate procedure (EPIP 300-11) for estimating emergency noble
gas release.
(Section 11.2.)
e.
Lack of guidance on the use of portable instruments for plume
monitoring.
(Section 6.6.)