ML17193A442
| ML17193A442 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/29/1980 |
| From: | Baltzo R, Fisher W, Murphy D, Oestmann M, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17193A440 | List: |
| References | |
| 50-237-80-13, 50-249-80-17, NUDOCS 8010220486 | |
| Download: ML17193A442 (46) | |
See also: IR 05000237/1980013
Text
U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Report No. 50-237/80-13; 50-249/80-17
Docket No. 50-237; 50-249 *
Licensee:
Commonwealth Edison Company
P. 0. Box .767
Chicago, IL
60690
Facility Name:
Dresden Nuclear Power Station~ Units 2 and 3
Inspection At:
Dresden Site, Morris, IL
Inspection Conducted:
June 18 - July 2, 1980
'-//(.~
Inspectors:
M. C. Schumacher
11/ *r-RJ -
~
tv, X~ .. ~~'V
l~R. A. Paul
Approved By:
11;,Jt(i~<.Al-~-
M. J. Oestmann
(l L;,-,,
- ' l.-**z-~
1n. w. Murp y
/'}
/7
J!'At f.6,
R. M. Baltzo
'11./r-1_~
W. L. Fislfur, Chief
Fuel Facility Projects and
Radiation Support Section
Inspection Summary
I
Health Physics Appraisal on June 18 to July 2, 1980 (Report No. 50-237/80-13;
50-249/80-17)
Areas Inspected:
Special, announced appraisal of health physics program,
including organization, management, training and qualification, exposure con-
trol, radiological controls, surveillance, instrumentation, facilities and
equipment, ALARA, and emergency response.
The inspection involved approxi-
mately 540 inspector-hours onsite by five NRC inspectors.
8010220
Results:
Significant weaknesses were identified in the health physics pro-
gram in the areas of organization and management (Section 2), training and
qualifications (Section 3), access control (Sections 5.4 and 5.6), contamina-
tion control (Sections 5.7, 6.2, 9.1, 9.2, and 9.4) surveillance (Section 6),
instruments (Section 7.5, 7.6, and 7.7), facilities (Section 9.1, 9.4, and
9.7), and emergency response (Sections 3.7, 6.6, 6.7, 9.7, 11.2, and 11.3).
Four apparent items of noncompliance (infractions) were identified:
failure
to follow procedures (Sectons 5.7 and 9.1); potential unrestricted area dose
exceeding two millirems in one hour (Section 5.7); inadequate control of
high radiation area access (Section 5.4); and an unposted radiation area
(Section 5.7).
- 2 -
1.
General
The Dresden health physics program was evaluated during a special
appraisal that began approximately 2:00 p.m. June 18 and ended July 2,
1980.
The Appraisal Team consisted of three inspectors from the NRC
Region III office and two DOE contractor health physicists.
Training required for unescorted access was obtained the first after-
noon and was followed by a meeting with senior plant management onsite.
Thereafter, the team had free access to the entire plant subject only
to the licensee's normal controls for posted and/or locked areas.
Throughout the appraisal, the team emphasized direct interaction with
workers and direct observation of ongoing work by licensee and contractor
personnel.
Considerable time was spent by the team in making direct radiation and
contamination surveys to independently ascertain plant radiological
status and to make comparisons with licensee measurements.
The appraisal
extended to evening, midnight, and weekend shifts, as well as normal
day shifts.
The appraisal was essentially limited to Units 2 and 3
since Unit 1 is undergoing an extensive decontamination program and is
empty of fuel.
Units 2 and 3 were at power during the period.
The Appraisal Team observed a health physics program that was somewhat
old fashioned and that was geared to routine conditions but uncertain
and incurious in the face of nonroutine conditions.
Program implementa-
tion was without significant influence of professional health physicists.
The situation results from a severe union-management dichotomy, and
management weakness in the face of it, together with abetting weaknesses
in Radiation Chemistry (R/C) personnel training and selection.
Significant
findings relating to these problems and othe.rs are addressed in Appendix A
of the letter covering this report.
Other findings of lesser significance
are mentioned throughout the report.
2.
Organization and Management
2.1 Organization
Dresden Station is organized along the same lines as other reactor
stations in the Commonwealth Edison Company (CECo) system.
The
Radiatfon Chemistry (R/C) Department Supervisor (equivalent to
ANSI N18.1 Radiation Protection Manager) reports through the
Assistant Superintendent for Administration and Technical Services,
who is not qualified in health physics.
Direct interaction with
the station superintendent appears limited to attendance at a daily
meeting where attention is directed at daily work plans.
It is not
a forum for discussion of matters of general health physics interests,
however.
It was apparent to the Appraisal Team that the superintendent
was not well informed about all aspects of the health physics program
- 3 -
at Dresden, and in particular about arbitrary limitations that have
limited the scope and quality of professional health physicists at
the station.
In matters relating to plant surveillance and health physics control
at the work site, Radiation Chemistry Technicians (RCT's) report to
and are assigned by R/C Foremen.
The Foremen, Lead Health Physicist
(LHP), Health Physicists (HP's), and Engineering Assistants (EA's)
all report directly to the R/C Supervisor.
The professionally trained
HP's are physically separated from the RCT's and foremen and in fact
have minimal contact.
The separation of RCT's from HP's and absence
of an experienced HP in the chain of command between the Foreman and
. the R/C Supervisor places an unreasonable burden on the Supervisor
and* denies the Foremen much needed technical support particularly as
it affects the quality of RCT work.
Observations related to this
problem are also reported in Section 6.0 (Surveillance).
A recent organization plan for the R/C Department is flawed in that
the Lead Chemist reports to the Technical Supervisor outside the
department instead of to the R/C Supervisor (result of a change made
in 1979) .. Responsibility for radiochemistry is ambiguous because
station administrative procedures continue to allo~ate responsibility
to both supervisors.
Where the Lead Chemist is responsible for routine
analysis of radwaste releases, under emergency conditions this responsi-
bility transfers to the R/C Supervisor, who has no routine concern for
this activity.
Daily laboratory analysis, counting, and related sample collection
is performed by a common pool of Radiation Chemistry Technicians
(RCT's).
RCT's report to the R/C Supervisor in matters relating to
surveillance and work control and to the Lead Chemist related to
laboratory centered functions.
This dual responsibility again de-
creases the effectiveness of superviso~y effort.
Corporate Health Physics has no line relationship with the station
R/C Department.
Corporate is responsible for formulation of CECo
health physics policies, for development of certain generally
applicable procedures, and for providing emergency support to stations.
2.2 Emergency Organization
Dresden GSEP and EPIP's cover emergency organization and respon-
sibility drawing upon plant, corporate, and contractor personnel.
Corporate Command Center, Station, Environs, and Division Groups
are assigned specific functional areas of responsibility.
In an emergency, the R/C Supervisor is designated the Rad/Chem
Director reporting to the Station Group Director.
He has respon-
sibility for onsite radiation protection and radiological controls,
laboratory and counting room operations under the plant chemist,
- 4.-
"
onsite assessment of effluent releases, and early offsite environs
monitoring~ The last activity is coordinated by the Rad/Chem
Director until the designated Environs Director reporting to the
Environmental Director of the Corporate Command Center Group
takes over this function.
2.3 Management and Control
Perhaps the most significant problem at Dresden is the absence of
significant professional health physics influence on the health
physics program.
The causes appear to be the strong union-management
antagonisms that exist within the station's R/C Department, lack
of adequate training for RCT's and newly assigned HP's (Section 3.5),
physical isolation of the HP's and RCT's, and, most importantly,
failure of management to define and support the role of the HP's at
the station.
Instead of a mutually beneficial cooperation between
plant-wise RCT's and professionally trained HP's to build a strong,
aggressive, and up-to-date program, there exists mutual antagonism
and lack of respect.
The result appears to be a health physics pro-
gram geared to stereotyped, routine operations but possibly lacking
the aggressiveness and imagination needed to cope with abnormal
conditions.
The R/C Supervisor is responsible for management of the health
physics program.
Foremen reporting to him direct the day-to-day
activities of the RCT's who implement the program.
HP's, also
reporting to the R/C Supervisor, are expected among other duties
to evaluate program implementation, suggest needed program changes,
and otherwise provide assistance to the R/C Supervisor.
Actually, the day-to-day program is run by the RCT's in virtual
autonomy.
The foremen provide little day-to-day supervision other
than making work assignments, and the HP's are largely prevented
from making meaningful evaluation of program implementation because
of locally interpreted work rules.
These rules, which appear more
stringently interpreted here than at other CECo stations, effectively
prevent use of portable survey and counting instruments by HP's ,in
making evaluations of program effectiveness or in gaining familiarity
with plant conditions.
Such instrument use was described as subject
to grievance or threat of grievance on the basis of management doing
work of the bargaining group.
Resolution was said to *occur usually
at an early stage without written record and to be accompanied by
implicit or explicit pressures from the Industrial Relations (IR)
representative to avoid grievances.
The scope of HP responsibility
and the character of the HP program appears to be defined in quasi-
litigation involving the union representative and second level station
management.
The Superintendent indicated his own understanding that HP's could,
in_ the course of their duties, use instruments without necessarily
infringing upon the legitimate concern of the union and that he knew
- 5 -
of no grievance resolutions or pressures to the contrary.
Whether
these pressures are real or only perceived as real, the effect is
the same.
Professional HP evaluation of routine program implementa-
tion and of RCT performance is weak and the program is weak because
of it.
Currently, two foremen are concerned with radiation protection; one
works the assignment desk while the other handles other duties in-
cluding in-plant observation and supervision.
The observation of
the Appraisal Team that the foremen spent little time in-plant was
reinforced in discussions.with a number of licensee employees who
indicated that in-plant presence of the foremen had substantially
diminished.
This necessary element of first line management should
be restored.
Management tools to encourage quality performance (adequate job
description, performance standards, performance review) by RCT's
and management are generally missing.
Supervisory training for
foremen and HP's was minimal.
2.4 Management Support
Management support for health physics is weak.
Most significant
is the absence of professional HP program evaluation and guidance
described in the previous section (2.3).
The lack of station and
corporate support was frequently cited for the significant loss of
HP's from the station and from the company,
Lack of encouragement
for professional development, low salary, and excessive overtime,
all expressions of weak management support have also been cited.
These appear to be CECo system problems not restricted to Dresden.
Other indications include a weak RCT training/retraining program,
ineffective preparation of HP's, lack of health physics involvement
in radiation work planning by other departments, and lack of a
formal ALARA program.
There appears to be a basic station management misunderstanding of
what constitutes a good health physics program.
The program seems
to be viewed as a set of rules administered by the R/C Department,
imposed and enforced by the NRC, which yields enforcement sanction
points if violations are discovered.
The number of sanction points
(not man-rem etc.) is tracked. as a measure of program success.
2.5
Communications
Information flow within the 9epartment and with other departments
was of mixed quality.
The aforementioned antagonism and the re-
sulting communication gap between RCT's and HP's is of principal
concern.
Review of the RCT log indicates that it 'is not effectively
- 6 -
used for communicating health physics concerns among RCT's or
between RCT's, HP's, and foremen.
These channels must work if an
effective program is to exist.
Another factor that affects RCT-HP communication is the physical
isolation that exists between them.
The HP group, housed in the
Administrative Center beyond the gatehouse, often is not conveniently
available for consultation.
The morning meeting provides a vehicle for communication with other
department heads.
At this meeting, daily work plans are discussed,
work requests assigned priorities, and required signatures are ob-
tained for high priority work requests.
Not infrequently, the work
is already underway while the meeting is going on.
Too often,
workers show up "ready to go" except for radiation protection sur-
veillance.
Opportunity for effective ALARA review and effective
RCT scheduling is thus lost.
Total Job Management (TJM) adopted
by CECo is supposed to avoid such problems, but as yet has not been
very effective; the maintenance superintendent estimated the TJM
was about five percent implemented.
The inadequacy of the morning
meeting for communication between the R/C Supervisor and the Plant
Superintendent was already mentioned.
(Section 2.1).
2.6 Staffing
Total staffing of the R/C Department (Figure 2) of 44 (33 RCT's,
three foremen, three EA's, four HP's, and one R/C Supervisor) appears
generally adequate.
Contract technicians have not been used at the
plant since 1977.
Health physics group staffing is marginal owing to
a lack of plant experience (18 months average) of the professionally
trained HP's.
Turnovers continue to hurt this group as the HP with
Unit 1 decontamination project experience is leaving.
RCT staffing levels appear adequate for routine operations.
However, problems with qualifications of backshift RCT's were noted.
(Section 3.2)
Foremen staff (three) appears adequate but should be reviewed
because not enough in-plant observation and supervision occurs.
Outage staffing should also be considered because union agree-
ments apparently limit the number of RCT's who can work on the
backshifts without supervision.
The chemistry group of four chemists and one EA is experienced
and stable.
Four college trained chemists have Dresden experience
of one, two, seven, and eight years.
2.7 Audit Program
Audits and surveillances by onsite and offsite personnel in 1979
and 1980 were reviewed.
None of the licensee's audits provide or
- 7 -
are intended to provide an independent technical review of radio-
chemistry or radiation protection.
This finding applies to all
CECo nuclear stations.
The audits gave only limited attention to matters of radiation
protection or radiochemistry interest and the findings were gen-
erally unremarkable.
Surveillances tended to concentrate on solid
waste shipping.
Audit No. 80-11 of February 1980 examined qualifications of onsite
review participants.
Included in the audit information was a matrix
showing ten individuals as qualified (i.e., meeting ANSI Nl8.l-1971
requirements) in a lumped category of radiation protection/chemistry.
On the basis of knowledge immediately available to the inspectors,
two individuals were qualified in radiochemistry but not radiation
protection and two the other way around.
The remaining six
individuals were not evaluated but it is doubtful that all would
be qualified in both areas.
The Technical Supervisor, who selects
review participants, stated that a reviewer's qualifications are
matched to the topic being considered.
The Appraisal Team recommends
that licensee procedures ensure this consideration.
The offsite audit of May 20-22, 1980, was a rather comprehensive
QA audit of health physics activities.
Significant findings in~
eluded failure to follow procedural requirements for measurement
and investigation of internal dose and included inadequacy of the
RCT retraining program.
The auditor noted that the qualifications
of four RCT's were compared with and found to satisfy Section 4.6.2
"Staff Specialist" of ANSI Ni8.l-1971.
In the opinion of the Appraisal
Team, RCT's in responsible positions must meet Section 4.5.2 "Techni-
cians" of that standard.
(Section 3. 2)
2.8
Summary
Unusually strong union-management dichotomy and weak management
support for professional health physics activity have had a per-
vasive, deleterious effect on the Dresden radiation protection
program.
Mutual antagonism, disrespect, and lack of cooperation
between RCT's and HP's have helped shape a superficial, somewhat
outdated program which appears adequate for routine situations
but which may not be under anomalous conditions.
This is a
significant finding that should be corrected to ensure a fully
adequate health physics program.
3.
Selection, Qualifications, and Training
.-,, ..
3.1 Selection
CECo procedures by which RCT candidates are recruited or selected
were not observed directly.
However, by observation of job per-
- 8 -
DR.t.SD[N ORGANlZATfON
(Aee~ev1Arto)
SUP(P.\\NTt:NOCNT
--~~--~---,._..~--------~---.' r--~---'--~----~~-----__.--~--.j'---~---
ASST. 5UPt
,f
ASST. SUPT.
PrRSONNE:\\;..
ADMINISTRATOR
-i-Rl\\tNrN&
WPVR.
'
~ lNSTR.
~STAtF.
SH1J:T
tNGR~
t
ASST,. . SUP1':
UN\\\\ l
O?~ATIONS
. f\\DMIN.¢ SUPPORT
MAINT£NANl£
PU.OJECT MGR. 9,
~ Ov1A~~
COOROINATllR
.
-
STAfr. ACS~1 s
I
....
- OPE:t<.
WA~1E'
tNGQs
S'f$T~M
£:Ntifl-
k
k
r r
I
.
I
.
- ~_5-R_ u__,,'£-/0*-.. l~n.'c,~, _TC_. <:._H ___ Sti_A_n__,:* ,_M_A __ $_T_£R- -M-A,.-$it,g,___. MAST~
STO~t"
rvt"'\\,
-V~t'5',
SUPVR...
ME.CJ;.\\.
tl((..
INS'fg_
K£EPt.:R
l
R.CTs
.
formance and the effectiveness of training, the Appraisal Team
was able to identify factors essential to selection which must be
considered at Dresden.
RCT's are required to operate and evaluate the readings of several
small, single function portable instruments as part of a daily
routine.
RCT's also operate and evaluate the output of complicated
laboratory instrument systems.
However, under conditions of job
rotation at Dresden, the assignments recur at 6 to 12-month intervals
with no opportunity for study or retraining in the interim.
Further, RCT's suited to meticulous and dedicated laboratory and
instrument work draw upon skills vastly different from those re-
quired to exercise occasional authority over operators, engineers,
maintenance workers, and contractors in a production oriented work
place.
At CECo nuclear stations, RCT's are required to be proficient
in both areas.
The RCT candidate who can do both satisfactorily is
clearly a rare individual.
Separation of the two tasks would a~
once simplify selection and the problem of loss of competence owing
to the rotation period.
3.2 Qualification
In order to determine that Radiation Chemistry (R/C) Department
personnel qualifications meet ANSI N 18. 1 1971 standards, it was
- necessary to refer to separate records maintained by the Training
Department, R/C Supervisor, and RCT foremen.
Training Department
files are orderly but incomplete in that about a quarter of the
records do not list date of entry to the R/C Department at Dresden
Station, and there is no record establishing when or whether RCT
training was completed.
It was necessary to obtain these data by
reference to the supervisor and foremen records.
Since 1977, basic employee training data have been more systematic;
however, Training Department records do not keep current on con-
tent and completion dates for newly generated qualifying courses
related to new laboratory instruments and procedures.
It was
therefore impossible to verify by reference to records complaints
by RCT's that they had never been trained to perform functions
which are now part of the regular weekly assignment schedule (i.e.,
use of atomic absorption spectrometer, whole body counter, GeLi
counter, etc.).
The deficiency of records is largely attributable
to the divided responsibility for training at Dresden Station.
In common with other CECo nuclear stations, Dresden RCT's are
promoted to full journeyman status immediately upon completion of
their RCT training course.
No distinctions such as A level or B
level or years of experience are observed when they are given R/C
job assignments on a rotating weekly basis.
However, in practice,
- 9 -
the Appraisal Team recognized clear differentiation in job perfor-
mance, particularly with respect to routine and special surveillance
skills and in laboratory procedures.
It is further evident from a number of complaints received by the
Appraisal Team that about 30% of RCT's have not received training
which would qualify them to perform all assigned tasks.
This
deficiency has led to the practice of trading job assignments.
In
practice, several RCT's have gone for two or more years without
personally performing certain work assignments.
In addition, 14
of 33 RCT's had less than the requisite two years experience (ANSI
0 18.1 Section 4.5.2 "technicians") and were thus not qualified by
ANSI standards.
(Table 3.1).
It is therefore evident that backshifts and weekends are frequently
manned by inexperienced and unqualified personnel.
In the event of
an emergency, qualification deficiencies are likely to significantly
reduce capacity for effective response.
Table 3.1 - RCT Experience Summary
(as of 6/1/80)
Less than
2 years
14
2 to 6
years
14
Over 6
years
5
The R/C Supervisor, Lead Health Physicist, Lead Chemist, Health
Physicists, and Chemists meet their respective academic and
experience levels prescribed by ANSI N18.1-1971.
The Appraisal Team noted that disaffection and the lure of better
salaries, and improved working conditions elsewhere may be making
more inroads on Dresden Station's trained and experienced RCT's
and HP's than the radiation protection program can bear.
3.3 Training - General
The Dresden Station Training Department is located in a new admin-
istration and technical support service building just outside the
security gate house.
Well equipped classrooms and instruction
offices occupy about one third of the ground level.
An auditorium
permits training up to 50 persons at a time, using video tapes,
slides, or movies.
The Training Supervisor reports to the Personnel Administrator.
The principle mission of the Training Department was identified
as training of operator personnel.
Operator instructors exchange
positions with Operator Foremen to maintain currency.
Of a staff
of 12 instructors, eight are assigned to operator training, three
- 10 -
to general employee radiation protection training (NGET) and re-
training (NGER), and one to coordination of maintenance training.
The lead NGET instructor began teaching in 1977 after eight years
as an RCT and as an operator before that.
He has trained five
additional persons as auxiliary NGET instructors to handle peak
workload periods such as outages.
The Training Department provides routin~ operator pre-license
training (one year) and post-license training by means of a fifth
shift rotated into training.
Lesson plans for operator personnel
are derived from NUS.
Operator lesson plans are based on Nuclear
Energy Training Module 5 with supplements (i.e., 7-8 days) but do
not include sufficient training in instrument use and evaluation
to qualify them as self-monitoring individuals.
The Training Department also coordinates a comprehensive maintenance
skill advancement program based largely at CECo's Shorewood training
establishment.
Additional special courses (i.e., Control Rod Drive
Mock Up, Recirculating Pump Seal, Overhead Crane 0. 0. S., First Aid
and Fire Protection) are given at the station.
Approximately six
percent of maintenance staff mechanics and electricians are away at
scheduled training events throughout the year.
The training schedule
is not interrupted by outages.
The Training Department is not involved in RCT training, except for
annual qualification (NGER), fire, and first aid courses.
RCT train-
ing and retraining is addressed further in Section 3.5.
3.4 Nuclear General Entry Training
All persons entering the Dresden Station are required to receive
NGET unless they are to be escorted.
Special versions of the NGET
lesson plan have been developed for persons with restricted interests
such as emergency firemen, ambulance drivers, phone repairmen, and
food machine servicemen.
The normal radiation worker version lasts
four hours with the first 30 minutes devoted to security and general
safety and about three hours devoted to radiation protection topics.
It is followed (after lunch) by mask fitting and step-off pad procedure
(video tape and walk through).
Everyone does not receive the respirator
fitting and training and this can lead to uncertainty later in identi-
fication of persons unqualified to wear respirators.
(Section 4.3)
In June 1980, a written test was introduced.
Seventy percent correct
answers are required for a passing score.
Three failures were allowed
to repeat the course and take a different test.
Fourteen hundred and
thirty-five persons were NGET trained in 1979.
An Appraisal Team member attended the complete NGET in order to
evaluate scope and effectiveness.
The lesson plan included a broad
- 11 -
'1
selection of topics relevant to radiation protection with one
important exception.
Topics dealing with low-level exposure,
latent effects, vulnerability to internally deposited emitters,
and the relationship of these topics to cancer were given short
shrift and relegated to the end of each session, thus conveying
the impression that they were unimportant or irrelevant.
Moreover,
the relationship of these potential effects to the nuclear station
radiation protection program (i.e., access controls, work permits,
surveillance, whole body counts, and exposure records) was never
explained or referred to.
In the absence of such explanations,
production oriented workers in Operations and Maintenance may
develop negative attitudes toward R/C Department functions and
eventually come to disregard protective procedures.
The lack of
cooperation by some personnel that is evident at Dresden now may,
in part, be attributable to this missed opportunity for promoting
the role and function of the R/C Department during NGET and NGER.
Conversely, some topics in radiation science are important to the
further development of radiation protection for operators and RCT's
but are not directly relevant to general entry training.
Redistribution of the time involved may assist in keeping the course
within its four hour time frame.
3.5
RCT Training
Training new RCT candidates in radiation protection (background
and skills) is carried out completely within the R/C Department.
A health physicist or chemist is assigned to prepare, organize,
and deliver the course to each class of six or seven candidates.
While he develops his lesson plan with reference to earlier courses
and is free to add in fresh material, this method suffers a disad-
vantage in that each health physicist usually enters the classroom
without previous classroom teaching experience.
Unlike many tradi-
tional graduate departments, health physics degree candidates are
not always provided an opportunity to teach undergraduate classes
and it can not be assumed that they have the necessary skills.
As a result, the novice instructor may tend t6 talk over the head
of his class.
Since no RCT class was in process, training pro-
ficiency could not be directly observed.
The Appraisal Team could
only note that RCT's complained that chemists and health physicists
regularly appeared to present their course work at a level above the
student's comprehension and this contributed to a general feeling of
antagonism and mutual distrust.
Use of health physicists and chemists as the primary RCT instruction
source introduces a second element of discord in that the instructor
is normally new to Dresden and to a working environment.
Given the
rigid restrictions on what activities health physicists are eligible
- 12 -
to do in the bargaining unit's domain, limited opportunity is
available to temper their academic knowledge with reactor ex-
perience.
On the other hand, RCT students have one or two years
experience and are already plant-wise and share worker developed
attitudes toward many of the topics being discussed.
In the absence
of practical experience, the instructor is put at a severe disadvant-
age and classroom rapport, which is essential to effective training,
is undermined.
The existing RCT training organization is ~ major source of dis-
cord and antagonism within the Rad/Chem Department.
The normal
working relationship between RCT's and health physicists, already
strained by rigidly enforced definitions of bargaining unit pre-
rogatives, is undermined at the beginning of their career at Dresden.
The Appraisal Team's observations of RCT and HP performance indicate
that the RCT training responsibility needs thorough review and recon-
sideration.
The most recent RCT initial. training class was offered March through
June 1979.
It consisted of:
three weeks classroom training related
to general math, radiation science, and radiation protection; three
weeks devoted to chemistry and laboratory procedures:
and eight
weeks of on-the-job training.
Lesson plans examined were informal
collections of outlines and data which do not provide an indication
of when the material was ~dopted or approved.
In general, the
selection of topics appeared to follow outlines familiar in on-station
power reactor training elsewhere.
There was no opportunity for the appraisal team to directly observe
RCT training.
However, suspected deficiencies in training ~ere
confirmed by observation of RCT job performance and by subsequent
interviews with RCT's and other R/C personnel.
Among the significant
weaknesses observed were:
failure to recognize the need in good
radiation protection work to deviate from routine duties to pursue
and evaluate anomalous conditions; failure to recognize certain
conditions (particularly contamination incidents) as anomalies to
be pursued beyond the point of establishing control boundaries;
absence of system training relevant to radiation protection needs;
and inaccurate timekeeping.
3.6
RCT Retraining
In addition to weaknesses in subject matter and delivery enumerated
above, the ambitious retraining effort which began in 1976-1977 has
virtually been abandoned in 1979 and 1980.
Since 1977 (the apex of
Dresden support), training schedules have regularly been interrupted
in each instance where a need for RCT services develops and preempts
their attendance.
This practical coRsideration has not been allowed
to interfere with maintenance or operations instruction schedules.
- 13 -
In 1977 and early 1978 the RCT retraining program identified*
approximately 35 classroom and laboratory courses ranging from
one hour to one day.
Topics for retraining included plant wide
requirements for fire fighting, first aid, and NGER.
Additional
courses relevant to RCT interest covered whole body counting,
mask fitting, rad waste, CPR, gas samplers, and many other areas
representative of a dynamic and developing field.
In 1977, only
18 of 2~ RCT's fully participated.
Since that time, participation
.has decreased and, currently, many recent RCT's have never received
special retraining topics which may not have been included in their
initial training.
(Section 3.5).
There is no evidence that the retraining concept at Dresden re-
cognizes a need to review and update RCT performance .in those
topics covered in their initial training course.
This deficiency
is all the more conspicuous in view of the lack of regard for
presentation and effectiveness of the initial RCT training.
The
RCT training program at Dresden station is weak and the retraining
pro~ram is currently nonexistent.
This results in observably weak
RCT performance (Section 6) in several areas, particularly those
that contribute to effective handling of nonroutine or unplanned
events.
It is likewise evident that Dresden commitments to RCT excellence
through retraining falls short of the effort expended for other
personnel.
On the basis of station records, the appraiser estimated
RCT retraining at about one to two percent full time equivalent com-
pared with about 18 percent for operators, 8 percent for maintenance
personnel, and 11 percent for station men.
3.7
Emergency Training
Dresden Station training provides for a limited discussion of the
Emergency Plan (GSEP), of the emergency plan implementing proce-
dures (EPIP's), and of the individual's role in an emergency during
the initial orientation (NGET) for employees and contractors.
Basi-
cally, personnel are informed about emergency signals and assembly
areas.
The annual retraining (NGER) required for renewal of the
security badge includes repetition of this same material.
The licensee uses quarterly drills for training.
However, they
usually provide only minimal training to RCT's.
The annual medical
drill has limited involvement of the RCT's, as it is principally
directed toward ambulance and medical personnel.
Drills are seldom
held on weekends or on backshifts to test how rapidly offsite per-
sonnel could respond.
Critiques are held after each drill but
individual performance of specific emergency duties as demonstrated
in the drills is not routinely evaluated.
- 14 -
The drill conducted on June 19, 1980, (Section 11.3) was the first
in which RCT's were heavily involved in emergency response teams to
collect simulated highly radioactive samples and to provide radiation
assessments.
It also included use of environs teams to verify communi-
cations and to simulate plume tracking.
The licensee plans to conduct
more such drills in the future.
With the development of a new emergency plan and new implementing
procedures, the licensee's productions training department prepared
a detailed lesson plan for emergencies.
The lesson plan appeared to
be adequate.
However, the instructor teaching the program at the
--station has had limited experience in the subject and should receive
specialized training in this area.
Training was given to station personnel with GSEP responsibilities.
Approximately one-half of the RCT's received a review of the emergency
procedures (EPIP's 300-8, 300-9, 300-10, and 300-11) for post-accident
sampling of containment atmosphere, reactor coolant, and release rate
determination before the June 19, 1980, drill.
Discussion with in-
dividual RCT's indicated, in some cases, an unclear understanding of
their roles except for mustering at the Operational Support Center (OSC)
for further instructions.
Appraisal Team observations of this drill
identified sample handling and other practices that could be hazardous
during an actual emergency.
(Sections 9.7 and 11.2)
3.8
Summary
Based on the appraisal findings, significant improvements are needed
with regard to RCT qualification and training to achieve a fully
acceptable program.
Appraisal team observations indicated weaknesses
in basic health physics fundamentals, weakness in the identification
and evaluation of anomalous conditions, incomplete emergency training,
neglect of retraining, decline in competence resulting from the long
period rotation schedule, and failure to recognize RCT qualification
status in the rotation schedule.
4.
Exposure Control
4.1 External Dosimetry Program
The external exposure measurement.during routine operation consists
of timekeeping, paired indirect reading pocket chambers (pencils),
and Landauer film badge services.
The biweekly film badge results
are maintained as the official record for personal exposure data.
The timekeeping and pencil results used for daily updating of per-
sonal exposures are entered into the official exposure records only
when film badge results are not available (i.e., lost or damaged
f_ilm badge) .
- 15 -
,.
Weaknesses in the computerized official1,xposure records system
were observed during the Zion appraisal- .
The principal problem
was that performance standards and procedures for the control and
traceability of changes to the official exposure records had not
- been established.
In addition, the potential of the system for
retrieving selected dose data and for computer auditing of redun-
dant exposure files had not been exploited.
The same system weak-
nesses were also observed at Dresden.
However, Dresden station
practices resulted in satisfactory documentation of exposure record
changes.
The various records (film badge, pencil sheets, lost/damaged
badge reports, etc.) are maintained in easily accessible biweekly
report*files.
However, retention time* had not been defined for these
supporting dosimetry records.
Generally, the* exposure program suffers from lack of good review
and built-in quality assurance.
Various people have responsibility
for different parts of the program, but no one person provides
continuity through an overview of the entire program.
Little pr
no interaction is maintained between the RCT's who imple~ent the
program in-plant and the health physics professionals responsible
for the overall program.
The pencil dosimeters are not quality assurance tested as suggested
by ANSI 13.5 "Performance Specification for Direct Reading and
Indirect Reading Pocket Dosimeters of X and Gamma Radiation."
New
pencils are placed in service after leak testing.
When a discharged
pencil is encountered during the daily pencil reading, the dosimeter
is taken out of routine use and "quality controlled" according to
DRP-1250-3.
The procedure includes leak testing and 45 mR and 145
mR source exposure checks.
If the pocket chamber performs satis-
factorily, it is returned to routine use.
The approximately 1700
self-reading pocket dosimeters, which are available for routine use
and for timekeeping purposes, are subject to the same program.
Film badges spiked over a range of about 100 to 3000 millirems
are routinely submitted to the vendor for evaluation.
The data
reviewed.by the appraisal team indicated that at the lower end of
the scale. the vendor consistently reports a dose higher than
supposed by the licensee.
The licensee looks at but does not
evaluate these data so that it is not known whether the bias
exists in the spiking or in the vendor's analysis.
The licensee
should also review neutron dose accounting because the track etch
dosimeter used very likely underresponds to the moderated neutron
fields seen at the station.
The station relies upon the use of timekeeping in high radiation
areas to control daily dose limits.
Available self-reading pocket
chambers are seldom used with .. timekeeping, and indirect reading
!/ RIII Inspection Report 50-295/80-05
- 16 -
pocket chambers are usually immediately read only at the request
of the employee or a supervisor.
A review of the timekeeping/
pencil sheets and the film badge results indicated that the
timekeeping results were routinely much higher than the associated
film or pencil results.
In some cas~s, the timekeeping results
were a factor of ten higher.
Timekeeping is a historical method of dose control.
When done
well, it is an impressive demonstration of job control from a
radiation safety standpoint.
In many cases, dose estimates will
not vary from other dose measurements by more than 20 percent.
However, it is a difficult skill to master, and the technique is
subject to errors from such factors as radiation field complexity,
size and scatter of crew(s) monitored, and the ability and diligence
of the RCT involved.
The discrepancies noted here would indicate
the *skill is not well mastered by the relatively inexperienced group
of RCT's at the station.
Discrepancies are usually inconsequential since the film badge
results are used to generate the official individual dose records.
However, when the film badge is lost or damaged, timekeeping re-
sults (plus the pencil results) are used to assign the individual's
dose, which, in most cases, means assigning a dose significantly
higher than probably received.
Although the method used is con-
servative, the dose assessed should be based on the most reasonable
or realistic estimate.
Timekeeping data are also used as the basis for developing the li-
censee's REP program wherein exposures are retrospectively apportioned
to different job activities. Errors undermine timekeeping's
accuracy
and usefulness as an exposure predictor for recurring jobs.
More
importantly, ALARA is subtly undermined because the consistent time-
keeping overestimate results in unnecessary and wasteful (in terms
of dose) crew changes in order to stay within assigned daily dose
limits.
Based on the appraisal findings, this portion of the licensee's
program is acceptable.
However, the following should be considered
for improvement of the program: review of timekeeping* results, use
of self-reading dosimeters as a supplement to timekeeping, better
quality assurance for pocket chambers and film dosimeters, and
evaluation of neutron dose accountability.
4.2
Internal Dosimetry
Internal exposure measurement (whole body counting and urine
analysis) is supplied by RMC.
The whole body counter (WBC) is
dependent upon an associated computer for continued operation.
The ability to manually operate the WBC and interpret the results
onsite is nonexistent.
Urine sampling is the backup for the WBC;
however, the WBC is the primary means for internal measurement.
- 17 -
"
A baseline whole body count is required for badging of potential
.radiation workers and another is required upon termination.
A second counter was set up to help process contractors during
the last outage.
The quality assurance (QA) for internal measurement is vendor
supplied.
Check sources supplied are used in the same rolled up
fashion observed at other CECo stations.
NBS traceability of
these sources appeared to be five to ten years old.
The licensee
performs no QA with other standard sources nor are recounts used
for replication checks.
The offsite audit of May 20-22, 1980, noted that during the high
traffic period of the last outage, standard source and empty bed
counts were frequently not done at the end of the day as required
by licensee procedure DRP 1340-2.
On the advice of the vendor,
the requirements were changed to require these counts in the morning
and/or over lunch.
No problems in adherence to the revised procedure
were noted during the appraisal.
The WBC is located in an area that is subject to changing Back-
ground radiation levels.
The problems associated with the WBC
facility are addressed in Section 9.3.
The action level in percent of MPBB are posted and adequate.
The mechanism for investigation of possible internal depositions
(showering, recounts, etc.) is well established and has adequate
forms for documentation available (DRP 1340-2).
Two forms are.
used in evaluating a suspected deposition.
The first form contains
the essential information about the individual and the WBC results;
the second form contains the followup information.
The second
form contains no personal identification and when filed, the two
forms may not be attached to each other and thus may become
separated.
This practice is not consistent with the maintenance
of scientific or legal records or with the recommendations of
ANSI N13.6, "Practice of Occupational Exposure Records Systems."
Based on the appraisal findings, this portion of the licensee's
program is acceptable; however, the following matter should be
considered for improvement of the program:
better identific.ation
and filing of the investigation forms.
4.3 Respiratory Protection
The licensee has implemented a respiratory protection program that
includes procedures covering administrative and technical details
required by 10 CFR 20.103 and Regulatory Guide 8.15.
Basic
engineering control~ in use include fume hoods in hot laboratories
and sampling area, temporary ventilation systems, and directed air
flows.
- 18 -
Qualification of respirator wearers includes medical approvals,
training, and fitting.
However, licensee procedures do not ensure
that accurate, timely information regarding approved users is
available to an RCT at the mask issue room.
There, qualification
is often confirmed by questioning of the would be user.
Security badges giving unescorted access imply but apparently do
not guarantee that all qualifications for use have been met because
of individual variances permitted.
Security badges are sometimes
punched to indicate that an individual requires a special respirator.
NGET cards, which indicate respirator approval status have not been
issued to all station personnel and their use to identify qualified
users is not stressed.
Quantitative fitting results are entered on
an individual's NRC Form 5, but these are not sufficiently timely
for use in issuance and, furthermore, are kept in the Administrative
Center outside the gatehouse.
The program appears to lack the built-in controls and internal
audits necessary for management to ensure program reliability.
By
procedure, each respirator is cleaned, inspected, and packaged for
reissue.
However, no program exists to examine a sample of these
available masks.
Quantitative fit test results are apparently not
reviewed by cognizant management; nor, apparently, are issuance
records spot checked to ensure that qualifications are being met.
Based on the appraisal findings, ihis portion of the licensee's
program appears acceptable.
However, the mask issuance procedure
should be upgraded to ensure that qualified users can be readily
identified by the issuing RCT.
Built-in controls and/or audits
necessary to ensure proper program functioning should also be
considered.
4.4 Emergency Conditions
Provisions for dosimetry services for unusual or emergency situations
appear generally adequate.
Significant backup of dosimetry and
respirator supplies and bioassay capability exists at other CECo
stations and/or from licensee contractors.
Dresden's supply of
full-face filter respirators, self-contained breathing apperatus,
and spare air bottles appears adequate for short term emergencies.
Potassium iodide tablets for thyroid blocking are available onsite
and the licensee's medical director has provided instructions for
their use.
Based on the appraisal findings, this portion of the licensee's
program appears acceptable.
- 19 -
5.
Access and Contamination Control
5.1 Restricted Area Access
The Dresden restricted area is basically the same as the protected
area defined for security purposes.
All major buildings (Reactor,
Turbine, Radwaste) except the Administrative Center are within
this area.
Access through a guardhouse requires an identification
security badge or escort.
The security badges are color coded to
indicate levels of unescorted access permitted.
Based on the appraisal findings, this portion of the licensee's
program appears adequate.
5.2 Controlled Area Access
Unescorted access to controlled areas requires completion of
radiation protection training in addition to the basic security
orientation.
It also requires a baseline whole body count.
Persons entering the controlled area are required to wear a film
badge and pocket dosimeter, which are available from the R/C office
or from badge racks at access control.
There is presently no
mechanism to ensure that persons entering are wearing personal
dosimetry.
Security guards stationed to check that persons are
properly badged do not routinely check that dosimeters are worn.
Individual entries to controlled areas are not recorded and per-
sonnel accountability in an emergency will depend upon a comparison
of gatehouse and assembly area muster records.
The station is chang-
ing to a coded magnetic card system which will permit or deny access
to specific areas based on authorization status entered in a computer.
It will maintain a log of entries and exits wherever a magnetic card
is used.
The system, scheduled for implementation sometime in the
third quarter of 1980, should greatly speed up personnel accountability.
However, the appraisal team notes that precise accountability of
persons in the Reactor Building, a significant concern in a serious
emergency, will be jeopardized unless all in and out movements 'there
are recorded.
Based on the appraisel findings, this portion of the licensee's
program is acceptable.
However, the licensee should consider
implementing measures to ensure that personal dosimeters are worn
in the controlled area and to enhance accountability of persons in
the Reacto~ Building.
5.3 Radiation Area Access
The entire controlled area was designated as a radiation area and
was properly pogted.
Within that general designation, radiation
levels varied markedly.
"Hot Spot" signs are used to call atten-
tion to areas w9ere localized higher radiation levels exist.
Some
- 20 -
of these signs were old (two to four years) and carried radiation
level information that disagreed with more recent licensee surveys
or inspector surveys.
Radiation levels were sometimes significantly
changed although the radiation area status had not.
Based on the appraisal findings, this portion of the licensee's
program is acceptable.
However, local postings of radiation level
information should be maintained up-to-date.
5.4 High Radiation Area Access
Control of high radiation area (HRA) access is basically weak.
It relies on faithful adherence to administrative procedures for
key issuance and entry notification.
The procedure requires that
keys be logged out and returned after use and that the control
room be notified of each actual entry and that it be logged in a
HRA control Log.
Approximately 50 keys have been issued to the
various departments a'nd a master assignment log is kept by the
R/C Supervisor. It is unlikely that the control room personnel
can maintain continuing awareness of entries because of the large
number of keys potentially available and because of competing
demands for their attention.
Operator and foreman rounds are usually made alone and without
dose rate instruments.
Radiation levels are not posted at the
entrance to an HRA, partly to encourage contact with the R/C
Department regarding radiological conditions.
Even with this
information, such entries are vulnerable to abruptly changed
field conditions.
The licensee uses fences and gates of varying heights and locked
doors to bound HRA's.
Except for one described below, all were
locked and plainly posted;
Fences and/or gates ranged upward
from about three and a half feet and were adequate to prevent
inadvertent but not deliberate entry.
The areas noted were below
one rem per hour and under waivers to 10 CFR 20.203(c)(2) often
granted would not require locking.
However, the licensee makes
no apparent distinction between HRA's of varying severity.
More-
over, fence heights were said to be a matter of discretion of the
Maintenance Department, which installs them, rather than the R/C
Department.
Clear noncompliance with 10 CFR 20.203(c)(2) HRA control requirements
was identified on June 20, 1980, at the unit 2 west CRD accumulator
bank.
The fence (approximately five foot) barricade was unsecured
at one end leaving an opening for unobstructed access.
Exposure
rates ranged to about 130 mR per hour.
The R/C Supervisor had the
problem corrected the following day.
Based on the appraisal findings, HRA access controls should be
strengthened.
Of most concern are better dose rate information
- - 21 -
for operators making rounds and better control room awareness of
all HRA entries, particularly in areas where fields above one R
per hour exist.
5.5 Airborne Radioactivity Area Access
By procedure, the licensee posts airborne areas when air samples
exceed 25% of MPC.
Also, areas where contamination greater than
5000 counts per minute per square foot exists in substantial ex-
tent are automatically posted as airborne.
The station makes a
practice of taking job specific air samples for work in these areas.
Entrance postings give neither measured airborne activity nor level
of contamination, although both aie available from survey sheets.
Entry to these areas requires use of respirators which are obtained
through the R/C Department.
Based on the appraisal findings, this portion of the licensee's
program is acceptable.
5.6
Contaminated Area
Contaminated area access control is marginal.
Dresden procedures
do not explicitly define contaminated areas, do not explain appropriate
behavior between step-off-pads (SOP's), and, until recently, did not
address specific protective clothing (PC) requirements.
Contaminated areas in the plant are generally well identified by
standard means such as barriers, posting, and SOP's.
However, two
interpretations of double SOP behavior are practiced.
One group,
largely operators who make rounds, regards the area between the
two pads as clean ~nd enters accordingly; it obviates the need for
protective footwear if one only wants to open a door and look inside.
The other view, espoused generally by the R/C Department and others,
regards the area as suspect requiring protective footwear (booties).
This discrepancy probably contributes to the frequent incidence of low
level shoe contamination seen at the station.
Protective clothing requirements are set from RCT surveys.
A recent
innovation has the surveys reviewed and requirements stamped on the
survey while still fresh in the mind of the surveyor.
The new pro-
cedure also recognizes a minimum clothing requirement for observers
and no-touch.workers.
Observations by the Appraisal Team of collec-.
tions of rubbers without the procedurally required booties, and of
entries between double SOP's indicate the need for improvement.
The
procedure can remain viable only if the conditions are truly followed
and if the question of SOP behavior is settled.*
The.Appraisal Team made extensive surveys to confirm postings and
generally check the licensee's contamination surveillance.
Removable
- 22 -
floor contamination was generally within the lice2see's "standard"
of 100 counts per minutes per square foot (cpm/ft ) when his field
method was used.
However, smear surveys of other horizontal2surfaces
appeared less diligent and levels in the range of 400 cpm/ft were
commonly found with isolated spots ranging to several thousand.
In discussion with RCT'~, it was learned that new protective clothing
(PC) or clothing indistinguishable from protective clothing is
sometimes worn by nonradiation workers.
Sometimes, new protective
clothing was put into service without the required identification
markings.
In either case, confusion is introduced and the job of
contamination control made more difficult.
When more sensitive counting methods were used (e.g., low background,
laboratory proportional counters) floor contamination was still rea-
sonable but not always within the 100 counts per minute per square
'foot "standard." However, only approximate comparisons were possible
owing to the antiquated standard which was written for an unspecified
portable GM survey meter.
In effect, the "standard" is no standard
at all.
The 100 counts per minute per square foot "standard" is included
in the "Radiation Control Standards" package for all CECo stations
that is negotiated with the union and cannot, therefore, be changed
unilaterally.
The Appraisal Team understands that a change to suit-
able units is part of the package that has been under negotiation
for several years and is nearing agreement.
If true, it would be a
significant step toward defining a meaningful removable contamination
limit.
Based on the appraisal findings, the licensee needs to clearly define
and enforce the requirements for contaminated area access in order to
achieve an acceptable program.
The improvement should include meaning-
fully defined removable contamination lim~ts.
5.7
Contaminated Materials Control
The licensee, in response to IE Bulletin 80-22, identified two
onsite dumps that unexpectedly contained radioactive materials.
Both areas were some distance from any site boundary.
However,
the inspectors observed that the areas were accessible without
interdiction from road and river and were thus not in restricted
areas as defined in 10 CFR 20.3(a)(14).
The material consisted
mainly of metal objects such as buckets, drums, and tanks.
A resin tank in one area read 130 mR/hr at two inches and .IO mR/hr
at three feet thus giving noncompliance with 10 CFR 20.lOS(b)(l)
for a potential dose of two millirems in one hour.
Removal of the
radioactive material from a controlled area to an unrestricted area
violated Dresden's "Radiation Control Standards" and thus Technical
- 23 -
Specification 6.2.B which requires adherence to the stations radio-
logical procedures.
The licensee was in the process of removing the material from the
dump site at the time of the appraisal.
The inspectors were in-
formed by telephone that all the material had been removed to a
restricted area and that the dump site survey had been completed
by July 12, 1980.
This matter was discussed at the exit interview.
Some of the material was recognized as having come from pilot runs
with the new waste solification system but licensee employees ipter-
viewed were unable to explain the occurrence.
Licensee practices
observed with regard to normal trash appeared satisfactory.
Trash
bound for the dump is surveyed and placed in bins under the direction
of the R/C Department.
The bins are kept locked and the key is kept
by the R/C Department so that unsurveyed trash cannot be added.
During an appraisal team survey on June 21, 1980, a pair of con-
' taminated pliers was found in a storage cage on the 670' level at
the Unit 3 Reactor Building.
The unmarked tool read about 80,000
cpm (at contact, window open) and a smear of its entire surface
showed about 700,000 dpm.
The tool was removed after .the R/C
foreman was notified.
Based on the appraisal findings, control of contaminated materials
needs to be strengthened to achieve a fully acceptable program.
6.0 Surveillance
6.1
Routine
Daily surveys, sample collections, and other routinely assigned
RCT surveillance activities were observed by all members of the
team throughout the 12-day appraisal.
Observations included all
three shifts and weekends although the majority of routine survey
work is performed during days.
Minimum routine ~urvey frequencies
are determined on the basis of work load in the area and the
vulnerability to spreading contamination.
Additional surveys are
ordered by the foremen in response to new work requests in order
to keep current on a continuously variable situation.
The foremen expressed concern that frequently they are not pro-
vided advance warning of new work requests to ensure timely survey
coverage of the affected area.
Survey reports are maintained on over 100 survey charts of the
two reactor and turbine buildings and 40 additional clean support
areas.
For convenience in assignment and filing, routine survey
- 24 -
"
area charts have been reduced to 8" x 11" size.
A standard notation
system has been developed to enable the reviewer to distinguish bet-
ween direct exposure and wipe sample data.
The form also provides
for notation of the surveyors' initials and operating conditions
prevailing at the time of the survey; however, these items are fre-
quently not recorded.
In addition to the formally identified survey
areas (maps), a general survey form "Station Radiation Survey Report"
for documenting nonroutine surveys has been developed.
The file
contained a number of such records.
Co~pleted surveys are filed in
duplicate sets of loose leaf notebooks by location and date to
provide a ready reference for the foremen and *the RCT's.
Each
survey is numbered and a record that the survey was completed is
entered in the RCT operations and staffing log.
The Appraisal Team reviewed survey records covering six preceding
months.
Three hundred fifty-two surveys were conducted during
the 30 days immediately preceding the appraisal.
Number of surveys
per month appeared to be reasonably constant over the period.
How-
ever, in about half of the records reviewed the amount of survey
data appeared to be barely sufficient to support evaluation of area
control requirements.
This inference was corroborated by comparison
surveys conducted by an appraiser in several of these areas.
Routine survey coverage in main traffic and work areas was adequate
to locate control work areas and establish perimeters or provide
a basis for timekeeping.
However, Dresden records2do not indicate
the widespread low-level contamination (400 cpm/ft ) that exists
on horizontal surfaces in out-of-the-way locations in both reactor
buildings.
As a consequence, the source of contamination and
opportunties for control have not been evaluated.
This is significant
in view of the number of personal contamination events being encount-
ered at Dresden (see below).
The Appraisal Team concluded on this basis (and other supporting
observations) that in general RCT performance has adapted to satisfy
minimal norms for routine service and consistently lacks elements of
curiosity and concern essential to a high quality surveillance program.
This in turn appears to reflect RCT training deficiencies, lack of
direct supervision by their foremen, and a high degree of isolation
from professional health physicists, who normally pursue findings of
this kind.
6.2 Contamination
The Appraisal Team members observed five incidents where plant workers
arrived at the RCT office or decontamination station with contaminated
clothing or shoes.
Examination of a contamination log book at the
station showed that there have been nine skin contamination events in
the past year and 83 personal clothing and shoe contaminations in only
-six months.
Furthermore, plant workers have become proficient at
- 25 -
decontaminating themselves and frequently do not leave a record.
In
all, the Appraisal Team feels that an overly casual interest is
manifested by the R/C Department regarding the control of repeated
contamination and the cause and effect relationships which could
result in control.
Of further concern, the contamination logs identify persons, area
of the body or article of clothing, date, and contamination level
but do not specify* locations where the problem was encountered or
what activity was taking place.
Further inquiry indicated that
contamination records are not routinely reviewed to identify
patterns.
This appears to confirm that incidental low level con-
tamination is generally accepted at Dresden Station and is not
perceived as related to principal RCT functions, such as surveys,
timekeeping, and sample collecting.
6.3 Air Sampling
Air contamination in working areas is monitored by means of high
volume air samples assigned by the foreman in connection with
direct exposure and wipe sample surveys.
The sample taker/surveyor
is likewise responsible for counting and recording his results on
the survey record.
This association of duties makes for a more
complete area survey record and has resulted in excellent coverage
of the plant.
The only negative factor is that samples are not
always taken in the area of greatest concern if it is not located
within 10' (line cord distance) of the 110 volt line outlets.
Dresden Station uses both air sa2ple measurements and a removable
contamination limit (5000 cpm/ft ) as criteria for establishing
respiratory requirem~nts.
6.4 Nonroutine
Pursuant to findings relative to routine surveillance, the Appraisal
Team made a special effort to evaluate RCT response to several
unplanned situations which came to our attention.
These included
items of varying severity.
Two RCT's returning from a routine survey assignment failed to
respond to indications of a contaminated shoe counter that was
blocking traffic at the trackway 2 entry.
Not only did the
problem remain uncorrected until other RCT's took care of it, but
the group of operators and maintenance men whose work was*delayed
received an unmistakable message that R/C representatives are not
concerned with minor contamination.
On another occasion, an RCT was observed performing assigned
surveys in support of work in progress.
Direct exposure measure-
ments and timekeeping were conducted proficiently by the experienced
RCT who exercised effective control over personnel in this area.
-
26 -
Observations at the job site indicated that an air sample, not
specified by the foreman on the controlling work permit, should
have been taken.
The situation was pointed out to the RCT, who
agreed with the appraiser that air contamination there was a
possibility.
A third situation arose when on the evening of June 27, 1980,
jack hammer operators returning from a work assignment near the
unit 3 CRD area were. found to have extensive contamination.
The
first RCT they encountered told them to put their clothing in a
plastic bag and take a shower and returned to his routine assignment.
Following an inquiry made by the Appraisal Team, a second RCT surveyed
the clothing and then went to survey the work area.
His survey was
conducted along routine lines to establish a contaminated area peri-
meter, without ascertaining the source and circumstances by which
contamination was present at a point considered to be clean earlier
in the day.
The following morning RCT foremen had be.en advised of the Jack
hammer.incident and procedures were initiated to decontaminate
the area.
The foremen had established to their own satisfaction
that the source of cont
1amination at the work site was related to
work in the CRD work area 40' away.
This cause-effect relation-
ship was based on a long history of problems in the CRD cage, but
the appraiser saw no evidence that an attempt had ever been made
to employ RCT surveillance techniques to illuminate the.situation
and thus to lend support to their appeals for corrective action.
Measurements such as detailed distribution of contamination, and
isotopic makeup of contamination and supporting air samples, which
are but an extension of routine RCT procedures, were not made in
this case.
On further discussion of this observation with the
foreman and several RCT's, the Appraisal Team's observations were
confirmed as generally stated.
Apparently the RCT's at Dresden Station have accepted narrowly
defined roles related to routine work.
They may not be able to
recognize departures from the routine or the essential role they
are expected to play _in the face of nonroutine situations.
Ability
of RCT's to respond appropriately and proficiently to the challenge
of any accident is suspect.
6.5
Emergency Monitoring Onsite
The Radiation/Chemistry Department is responsible for onsite
emergency monitoring; other station personnel are generally un-
qualified to perform such duties.
The station chemist, who reports
to the R/C Director during an emergency, is responsible for the
necessary analysis of samples collected by the RCT's.
During off-
shifts, the two or three RCT's present will have to make needed
measurements both onsite and offsite until additional help arrives
(30 minutes to one hour).
- 27 -
,,
Containment sampling and analysis, reactor water sampling and
analysis, and estimation of airborne effluent releases are the
emergency tasks that may have to be performed immediately.
The
Appraisal Team believes that a minimum of two fully competent
RCT's would be needed to initiate these tasks within one hour on
whatever
response
rooms or
shift a response is required.
Moreover, timely emergency
depends on the availability of the laboratory and counting
convenient backup capabilities.
Appraisal Team members also discussed with control room personnel
their emergency duties and responsibilities as described in the
GSEP.
In general, these individuals appeared well acquainted with
their emergency duties.
6.6 Emergency Environmental Monitoring
The licensee's Environmental Director who has the overall responsi-
bility for the (routine and nonroutine) radiological environmental
monitoring program (REMP), manages contracts with the environmental
monitoring contractor (Eberline Instrument Corporation) and the
meteorological contractor (Murray and Trettle, Inc.).
During an
emergency, the Environmental Director provides, through the
Corporate Command Center, direction and guidance to the emergency
environs team at the station.
Initially, the professional health
physics staff is responsible for the emergency offsite .monitoring.
The licensee's environmental contractor will assume the job of
emergency environmental monitoring upon arrival at the site.
License procedure EPIP 300-12, "Initiation of Environmental Monitor-
ing Activities by the Rad/Chem Director," specifies team surveys to
confirm and/or identify.releases and specifies samples to be taken.
Beyond specifying minimal survey equipment, the procedure offers no
guidance on the use of portable instruments for plume monitoring.
Additional guidance is needed.
Several minor sampling difficulties observed during the June 19,
1980, drill included a small-scale sample recording map, and un-
weighted and difficult~to-sink water sample collectors.
Possibly
more significant was the use of a four foot long section of copper
pipe ahead of the charcoal adsorber in the three onsite monitoring
stations.
The effect on iodine collection efficiency had not been
evaluated.
The meteorological tower and associated recorders at the tower base
and in the control room were operable and properly calibrated.
This
is the responsibility of the licensee's meteorological contractor.
6.7
Summary
Based on the appraisal findings, surveillance,. especially for
nonroutine conditions, needs improvement to achieve a fully
.- 28 -
..
.,:
acceptable program.
Such occurrences as unexpected spread of
floor contamination and low level personnel contamination 'need
more aggressive followup and evaluation.
Emergency procedures
should contain additional guidance on the use of portable instru-
ments for plume monitoring.
Routine surveillance is generally
acceptable but stereotyped and oriented more to definition of control
boundaries than to source identification and control.
RCT performance
shortcomings and management's acceptance of them appear to reflect
management and training weaknesses described elsewhere (Sections
2 and 3).
7.0
Instrumentation
7.1
Portable Instruments
An adequate supply of dose rate instruments is available for routine
use.
Of the approximately 50 Cutie Pie (CP) type instruments at the
station, 37 were in service during the appraisal, with 11 to 15 of
the instruments readily available at any given time.
Enough additional
CP's are on order such that each Rad/Chem Technician (RCT) will even-
tually have an assigned instrument.
Instrument calibration records were reviewed and found to be
adequate.
Throughout the records lapses in calibration frequency
were observed; however, investigations into the discrepancies showed
the instruments were usually in the instrument maintenance shop for
checking or repair.
Better documentation in the calibration records
should be used to explain the apparent voids.
An instrument maintenance program exists with the Instrument
Maintenance Shop.
The program has a full-time instrument mechanic
dedicated to the maintenance, repair, and electronic calibration
of the H.P. instruments.
A log is maintained on all instruments
repaired.
At pre~ent~ a problem has been encounte~ed in getting
the necessary parts to repair Eberline instruments; therefore,
s~veral instruments are out of service.
The gamma calibration sources have not been calibrated to NBS
traceable standards.
However, a new facility calibration procedure
is being developed to utilize the recently purchased MDH X-ray
monitor, which presently has NBS traceability.
Also, the maximum
exposure rate currently achievable is only 30 R/hr, which is
inadequate for calibration of the high range instruments.
The
Xetex high range instruments (up to 1000 R/hr) are sent to the
vendor for high range calibration yearly.
A U-238 slab is used
to develop a single point beta calibration curve for the CP's.
- 29 -
Neutron calibrations are performed at the Zion plant; problems
with neutron calibrations were identified during the appraisal of
the Zion facilities.
However, a neutron startup source is used
as a source check for the neutron instruments.
GM instruments
are electronically calibrated and then must pass a source check
across all ranges before being put into use.
Based on the above findings, this portion of the licensee's program
appears acceptable.
However, a better neutron calibration system
should be considered.
7.2
Emergency Instruments
The portable instruments available in the plant for use during an
emergency are generally adequate except for the high range instru-
ments. *At present two Xetex high range instruments are available
at the station; however, three additional high range (up to 1000
R/hr) are on order.
Experience from TMI and the performance
criteria stated in ANSI 323 suggest that instrumentation should
exist for measurements up to 10,000 R/hr .
. The licensee maintains a limited number qf emergency survey instru-
ments.
These were found to be in accordance with the inventory list
for the GSEP trailer and to be maintained operable with current cali-
bration tags.
GM survey instruments are calibrated yearly and checked
quarterly.
CP's and high range CP's, alpha survey meters, neutron
survey meters, and high volume air samplers are calibrated on a six-
month schedule.
This schedule is inconsistent with that used to
calibrate the portable instrumentation used routinely but is considered
adequate.
The licensee recently obtained two survey instruments SAM
II with scintillation probes for emergency radioiodine monitoring.
Based on the appraisal findings, this portion of the licensee's pro-
gram is acceptable.
However, suitable high range portable instruments
should be added when available.
7.3 Air Monitors
The H.P. program relies primarily upon portable air sampling equipment.
Air samplers are calibrated quarterly and are well maintained.
The
station has a continuous air monitor for use in the Techncial Support
Center.
Three more are on order to monitor the assembly areas (2),
and the control room (1) atmospheres during emergency conditions.
Problems have been encountered in the performance testing and calibra-
tion of the instrument on hand and it is not yet being utilized.
An
adequate supply of air monitors appear.s to be available for routine use.
Based on the appraisal findings, this portion of the licensee's
program appears adequate.
However, the new constant air monitors
should be placed into service promptly.
- 30 -
7.4 Contamination Control Monitors
An adequate supply of contamination control monitors is available.
The hand and shoe counters and friskers are electronically calibrated
quarterly and source checked in a low background area.
Alarm points
are checked daily using a low-level check source.
Throughout the
plant friskers were commonly found set on the IOX scale and, in one
instance, the lOOX scale; thus the possibility of detecting low-level
contamination requires that the user be well trained in the proper
interpretation of the instruments' response.
In these high background
areas, the use of a shielded area (such as the one built for the hand
and shoe counter on the main turbine floor exit) would be beneficial.
The sensitivity of the hand and shoe counters appeared to be excellent.
This can be seen in the number of contamination reports that have
been filed and in the frequency of use of the shoe decontamination
area.
It was also confirmed in checks made by the appraisal team.
Based on the appraisal findings, this portion of the licensee's
program appears acceptable.
7.5 Fixed Area Monitors
An adequate supply of fixed area monitors is in place for routine
use throughout the station.
Maintenance and calibration programs
exist to maintain the monitors.
The range of the monitors is
insufficient for accident conditions and do not meet the guidance
of ANSI 320.
A generic problem in the use of the multiple point recorder exists
at the station.
Approximately 30 points are printed on the area
monitor charts for each unit.
Identifying trends is nearly impossible.
Not only is the chart cluttered, but the number printouts are illegible.
Based on the appraisal findings, monitor recording should be improved
to ensure a fully acceptable program.
7.6 Process and Effluent Monitors
An adequate supply of process and effluent monitors is available for
routine purposes.
A program is available for adequate maintenance
and calibration of the instruments.
Sample lines from the main
chimney sampler and the reactor building vents appear to be well
placed and designed.
The range of the monitors is inadequate to
meet the emergency performance standards stated in ANSI 320 or the
criteria from THI Lessons Learned.
New sampling and monitoring
capabilities are being developed to .meet the requirements of
NUREG-0578 (Section 11.2).
- 31 -
All recorders are checked at least daily with the date and time of
the check noted on the chart.
No personnel identification is noted
on the chart.
During the appraisal period (June 27, 1980), the
Reactor Building Vent Exhaust Monitor recorder was not printing.
The chart was last checked at 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> on June 26, 1980', and
ink flow subsided at approximately 2315 hours0.0268 days <br />0.643 hours <br />0.00383 weeks <br />8.808575e-4 months <br />.
While reviewing
the radiation monitor readout in the control room, one of the
Appraisal Team members found the nonrecording chart at 1115 hours0.0129 days <br />0.31 hours <br />0.00184 weeks <br />4.242575e-4 months <br />
on June 27, 1980.
This problem should have been noticed before 12
hours had elapsed.
Based on the appraisal findings, better review of monitor recording
is needed to achieve a fully acceptable program.
7.7 Analytical Instruments
Analytical capabilities for routine counting of gross beta and
alpha activities appear to be outmoded.
In addition, the instru-
ment records for standardizing and calibrating of these counters
were over ten years old.
The station is to upgrade the counting
equipment with new alpha/beta counters when the new counting room
becomes available.
These new counters will have to be calibrated
before use and new records of calibrations must be available at
the station.
The two GeLi detectors and associated equipment are
several years old and are also scheduled for replacement.
Quality control in the laboratory and counting room is weak.
Laboratory quality control does not include the use of spikes or
blind samples.
No control charts of reference source counts or
background measurements were available.
Although the licensee has QC procedures for setting up the Hewlett-
Packard Multichannel Ana,lyzer, data on performance checks were not
available.
Chemical procedures and check sheets for laboratory
results do not contain acceptance criteria.
A management member
reviews counting data daily and is responsible for verbally notifying
management if results are out of specification.
Such notifications
of variant results are not documented.
The licensee is training
the RCT's to use the multichannel analyzer.
Following the one week
training period (as part of the normal work schedule), a RCT may
not operate the equipment for 30 or more weeks.
Due to this rota-
tion schedule, some RCT's on off~shifts do not feel confident to
run analyses without assistance.
A similar problem exists with
respect to other sophisticated procedures.
Several alternatives could possibly be adopted to alleviate this
problem, such as the use of dedicated specialists, reorientation
of RCT's at time of rotation, or creation of separate technician
pools for chemistry and radiation protection activities.
- 32 -
Based on the appraisal findings laboratory quality control
should be improved to achieve a fully acceptable program.
8.
Radwaste.Management
8.1 Solid Radwaste
Solid wastes prepared for shipment at Dresden include compacted
materials (paper, plastics, etc.) in drums, noncompactible solids
(e.g., construction materials) in metal bins, and solidified wastes
(spent resins, filter sludges, and evaporator bottoms) in drums.
Operators solidify radwaste under the direction of a Radwaste Foreman.
Other solid wastes are handled by the Stationmen under the direction
of their foremen.
Technical guidance is provided by the Waste Systems
Engineer.
Solidified waste volume has been significantly reduced (Table 8.1)
with the startup in late 1979 of a new waste solidification system.
The savings (a factor of two to four) result from more efficient
mixing allowing a higher waste-to-cement ratio.
Volume reduction
has also resulted from more effective regeneration and cleaning of
- condensate demineralizers and by permutation of resin beds to extend
useful life.
An effort is also being made to reduce other solid
waste volume by such measures as better identification and segrega-
tion of trash and removal of items from packaging before entry into
controlled areas.
TABLE 8.1
Volume of Solidified Wastes by Year
Total Sol~d
Year
Waste (ft )
% DAW
79447
64
62604
41
36687
44
- 5288 ft3 during July-December 1979
Total Sol~dified
Waste (ft )
28601
36936
20543*
The new solidification system with both drumming stations operating
would allow a throughput of about six drums per hour.
The system
does have some problems arid generally one drumming station is operable
at any given time. Still the new system is a significant improvement
over the old and, according to licensee estimates, has resulted in
reduction of associated man-rem by about 75%.
- 33 -
Solid waste drum storage capacity is about 2400 drums, including
1500 drum storage* capacity added with the new solidification system.
At the end of June 1980, approximately 750 drums were onhand await-
ing shipment.
Based on the appraisal findings, this portion of the licensee's
program appears to be acceptable.
8.2 Liquid Radwaste
Operators under the direction of radwaste foremen run the liquid
waste treatment system.
Te~hnical guidance is provided by the
Waste Systems Engineer.
RCT's working for the Station Chemist
sample and quantify releases to ensure that regulatory requirements
are met.
Liquid wastes are treated within the plant by evaporation and/or
demineralization.
About 99 percent of the water is recycled within
the plant.
The remainder is released to the Illinois River via the
unit 1 or unit 2/3 discharge canals into a dilution flow ranging
from 25,000 to 500,000 gallons per minute {gpm).
Approximately 0.26
Ci were released in liquids during 1979.
Approximately 0.3 Ci were
released during the first six months of 1980.
A review of selected
records since 1977 indicated releases were below five percent of the
.technical specification limits.
Since 1978, radioactive effluents
have decreased owing to replacement of the laundry system by a dry
cleaning facility.
Based on the apprasial findings, this portion of the licensee's
program appears to be adequate.
8.3
Gaseous Radwaste
Gaseous radioactive effluent is released via the unit 2/3 reactor
building vent (RBV) and via the 300-foot-high unit 2/3 chimney.
The RBV discharge is*monitored and activity above the set point
causes shutdown of the pathway and startup of the Standby Gas
Treatment System (SBGTS), which discharges to the chimney.
The
bulk of the chimney airflow is from turbine building ventilation
air. Activity comes from the treated offgas, turbine gland seal
exhaust, and the radwaste building ventilation.
The off-gas is
treated by passage t~rough a recombiner, charcoal beds, and HEPA
filters before discharge.
Both release paths are monitored for noble gas release and con-
tinuously sampled for iodines and particulates.
Both monitors
read out in the control room and are recorded on a six-cycle strip
recorder. \\Calibration charts relating monitor reading to release
rate (uCi/second) are posted beside the recorders.
Chimney monitor
data are also available in printed format from the control room
computer.
- 34 -
At the time of this review, the combined chimney release rate was
about 3500 uCi/sec (110 counts per second) with units 2 and 3
operating at 605 and 815 MW (electrical), respectively.
The alarm
set point was 105,000 uCi/second.
The unit 2 and 3 vents were
releasing in the ranges of 43 to 52 and 60 to 100 uCi/second,
respectively.
This condition represented less than one percent
of the instantaneous noble gas release rate limit.
Isotopic distribution of noble gas discharge is obtained from
GeLi analysis of grab samples taken from the chimney (monthly)
and RBV (weekly).
The distribution is applied to measurements of
gross activity released to determine releases by isotope.
Conver-
sion factors relating monitor readings and discharged activity
are based on comparing monitor readings with isotopic analyses of
grab samples following each quarterly electronic calibration by
instrument maintenance.
Continuo~sly collected filters are periodically removed and counted
to determine particulate and iodine releases.
Additionally, a
monthly particulate filter is forwarded to a licensee contractor
(Eberline) for analysis and confirmation.
The contractor also
performs tritium analyses; a new scintillation counter ordered
for 1981 will give onsite tritium capability.
Selected release records for 1979 and 1980 reviewed indicated no
releases exceeding regulatory limits.
However, recurring inter-*
ference is seen from time to time in the iodine region of the
station whole body counter located south of unit 3 reactor build-
ing.
(Section 9.3).
The licensee presumes but so far has not
established a relationship to station releases.
This needs to be
explored.
The chimney monitor/sampler is located in the rear of the radwaste
building 40 feet from the base of the chimney.
Lead shielding and
the distance from the chimney and from underground treatment system
components protect the sampling point from elevated backgrounds
which might interfere with measurements during an accident.
Examina-
tion of the design and components of the sample line reflect satis-
factory consid~ration for principles of isokinetic sampling and
delivery of a representative sample at the point of measurement.
Dresden chemists also perform weekly analysis of air ejector,
filter building, and recombiner grab samples.
These measurements
are routine in-house surveillance of fuel condition independent
of discharge monitoring but with considerable predictive value
and thus relevant to overall control.
Based on the appraisal findings, the gaseous radwaste management
program appears acceptable.
However, investigation should be made
to determine if interferences seen on the whole body counter are
related to station releases.
(Section 9.3)
- 35 -
>
9.0 Facilities
- =
9.1
Laundry
The Dresden decontamination laund~y occupies two sites.
The
original facility at unit one was not examined.
The unit 2 and 3
facility is located in a 40-foot mobile unit in the unit 3 track-
way.
Available space for the three dry cleaning units and one
dryer is augmented by enclosure of a 12' x 20' area of trackway
by a 4' chain fence.
The facility is operated by two to four stationmen.
The station-
man foremen, who also have other concerns, are responsible for
overseeing the facility's operation.
At the time of the appraisal, with only a modest workload, each
day's input was folded and ready by mid-afternoon.
Even so,
exposure measurements in the vicinity of "clean" materials were
2-3 mR/hr and levels up to 110 mR/hr were encountered in the
soiled clothing area inside the fenced enclosure.
One of the
friskers and the ion chamber survey meter assigned to the laundry
were found to be inoperable.
Additional exposure measurements
(with an R0-3A) at the Unit I trackway SWP clothing supply area
were 2-3 mR/hr as a result of several hundred folded, clean
coveralls on the shelves.
Clothing contamination exceeded station
limits (3000 cpm) in 20 of 23 samples tes~ed with levels ranging
from 4000 to 22,000 cpm.
This suggests little cognizance of the
radiation protection role at the laundry and the absence of a
quality control program.
It was reported that, during the last outage, incoming soiled
laundry at the unit 3 track way was stacked higher than the roof
of the mobile unit and that individual contaminated garments were
contaminated up to 500 mR/hr.
This combination of reports and
observations suggests that exposure levels at the laundry have
been much higher than those observed during the appraisal.
Also,
no use is made of shielded clothes bins or.ventilated hood sorting
facilities to control this reducible exposure to laundry operators.
Operation of the clean laundry monitor instrument was observed and
discussed with the assigned stationmen and foremen.
The monitor,
improvised from the foot counter components of a hand and foot
counter, is surrounded by lead bricks.
If used properly, this
improvised unit can perform better than counters routinely encount-
ered at other nuclear station laundries.
With insights provided by
the foreman, and assistance of a health physicist and instrument
mechanic, the advantageous features of the counter could be developed
as an advancement in the industry and a significant ALARA contribution.
- 36 -
Judging from measurements made during this appraisal (and experience
elsewhere), heavily contaminated "clean" garments may contribute
five to ten millirems per hour to the wearer.
In some cases, beta
dose contribution (unrecorded by dosimetry) could be much higher.
Based on the appraisal findings, significant improvements in the
control of contamination levels on reusable laundry are needed to
achieve a fully acceptable program.
As part of this improvement,
an evaluation should be made of the contribution to dose from
laundry in order to determine the acceptability of current laundry
limits.
Acceptance criteria should be defined in terms of the
monitors used for laundry surveillance.
A quality assurance
program for laundered protective clothing should be established.
9.2 Equipment Decontamination Areas
A limited number (6) of decontamination shops (decon pads) are
provided throughout the plant.
The principal one is ~t one end
of the Unit 1 machine shop.
The shop is reasonably confined by a
12-foot concrete block wall' on the machine shop side and totally
enclosed around the others.
Ventilation appears to be adequately
controlled.
A wipe sample survey conducted by the Appraisal Team
showed that the area was in good order and controlled.
It was, however, noted that hot tool boxes stored in the area are
not uniformly identified by radiation labels in accordance with
Dresden procedure.
No evidence of excessive radiation exposure
or smearable contamination was seen.
The in-plant decon pads
were observed from time to time in passing.
In each case, the
activities within were indicative of proper regard for personal
exposure control and Dresden procedures.
However, the number of
incidents (reported under nonroutine surveillance) involving re-
peated recontamination of floor areas outside the Unit 3 Control
Rod Drive (CRD) pad (570 foot level) elicited more detailed
investigation.
The particular concern is that the CRD maintenance facility itself
has been a source of contamination to the surrounding areas.
The
temporary facility consists of a plastic covered wire fence perimeter
and a CRD disassembly area with an improvised airborne contamination
control system (a homemade hood of plastic sheeting, an exhaust duct
and a HEPA filter).
R/C Department requests to have more effective
contamination controls installed or to have the work moved to the
permanent Unit 2 CRD maintenance area have apparently been ignored.
An additional concern is the attitude that the contamination of sur-
rounding areas is not the responsibility of the offending department
but is the responsibility of the stationmen.
This attitude violates
a longstanding and successful tenet of radiation protection that
those who make the mess should be responsible for cleaning it up.
- 37 -
A similar situation exists with the continual recontamination of
the Unit 2 accumulator gallery as a result of work activity in the
Traveling In-Core Probe (TIP) room.
Based on the appraisal findings, this portion of the licensee's
program is acceptable; however, improvement or the relocation of
the temporary CRD repair area should be investigated.
9.3 Whole Body Counter
The present location of the whole body counter facility is adequate
0 to provide the necessary measurements for the internal dosimetry
program.
However, improvement is needed.
The facility is subject
to rapid changes in background radiation levels.
A common problem
is the unexplained appearance of I-131 during counting.
During the
Appraisal Team's visit, extraneous I-131 was seen in two whole body
counts.
This recurrent phenomenon is thought to be due to normal
station releases being held in an inversion layer or by some other
meteorologic condition.
However, no investigation has been made of
the relationship between this interference and plant releases or
meteorological conditions.
When the problem appears, either the
person is recounted at a later time or a new background is taken
before recounting.
The facility is also affected by radwaste ship-
ments which must pass nearby.
Additionally, the background radiation
levels are apparently dependent upon the status of the three plants.
The RMC report of 1/9/78 referred to significantly fluctuating back-
ground.
Since then, a standardized reference paragraph has been
included in each RMC report which alludes to the fluctuating back-
ground and erroneous I-131 results.
The present whole body counting facility lacks an easily accessible
shower and/or personal decontamination area.
In order to determine
if positive whole body count results are due to external contamination,
the person involved must dress, return to the Access Building personal
decontamination area, shower, and then return to the whole body count-
ing facility.
The licensee has developed plans to relocate the whole body counter
in the Access Building.
The new area, though somewhat small, is
well shielded and will have access to the nearby personal decontam-
ination area and shower.
The new location should eliminate the
problems associated with the present facility.
Based on the above findings, this portion of the licensee's program
appears acceptable.
However, as indicated in Section 8.3, the inter-
ferences observed in the iodine channel of the whole body counter
should be investigated.
- 38 -
9.4 *
Personal Decontamination
With only one shower stall, the personal decontamination area is
adequate for one or two persons.
The facility would be unable to
accommodate a larger group and the necessary R/C personnel.
In
an emergency, when a greater incidence of personal contamination
might be expected, the facility would be inadequate and no auxiliary
personal decontamination areas have been established.
The personal decontamination area also serves as the medical/medical
decon area.
The ability to work on an injured person who required
a stretcher would be severely hampered.
Remodeling plans have been
made to establish a dedicated medical decontamination area in the
Access Control Building.
A dedicated shoe decontamination area has been established.
This
area lacks so~e of the necessities for the proper decontamination
of footwear.
No running water is available; no contaminated waste
cans are available for proper disposal of paper towels.
Also, no
procedure or guidance on proper techniques for decontamination of
shoes is available to the individual.
The housekeeping in the shoe
decontamination facility and the surrounding area is poor.
Based on the appraisal findings, facilities for personnel and shoe
decontamination should be improved to achieve a fully acceptable
program.
9.5
Instrument Storage
The instrument storage facility, which consists of several shelves
and three lockable wall cabinets, is excellent.
The room is segre-
gated from the general work areas and from traffic flow.
However,
as the instrument inventory increases the area may become too small.
Based on the above findings, this portion of the licensee's program
appears acceptable.
9.6 Emergency Facilities and Supplies
The licensee provides emergency supplies and kits at the GSEP trailer
onsite, the medical decontamination area in the station, and the St.
Joseph Hospital emergency room for contaminated injured personnel.
Although stretchers, respiratory equipment, and first aid kits are
distributed throughout the station, emergency supplies and instruments
are not located in the station control room.
The GSEP trailer was found to be maintained in good order with each
drawer labeled with the supplies present.
During the June 19, 1980,
drill, some supplies were brought into the station the day before for
use in the emergency drill.
Licensee representatives recommended
- 39 -
that some of the emergency supplies be located in the station
near the trucks that would be used by the environs teams.
The
Appraisal Team agrees that the licensee should provide a location
for placing certain emergency supplies in the station nearer to
where they will be used.
Emergency supplies and survey instrumentation were found present
at the above mentioned locations in accordance with licensee's
procedures DRP 1470-2 and 1740-2, both dated September 1979,
except for the keys for the environs stations.
The keys, which
had been used in the June 19, 1980, drill, were later found in a
van used by an environs team in the drill.
Based on the appraisal findings, this portion of the licensee's
program appears acceptable.
9.7 Analytical Laboratory and Counting Room
Analytical laboratory facilities (cold laboratory, hot laboratory,
sample preparation room, counting room, and gamma spectrometry
room) are generally overcrowded, poorly organized, .and subject to
poor housekeeping.
The licensee was in the process of converting
recently vacated radiation protection office space to an expanded
counting facility, which will also house the whole body counter
when it is moved (Section 9.3).
Analytical equipment in the cold and hot laboratories appeared
adequate.
Some of the counting room equipment is outmoded and
scheduled for replacement (Section 7.7).
The cold and hot laboratories and the sample preparation rooms
are adequately equipped with fume hoods and sinks with drains
routed to holding tanks.
A lead cave was in the corner of the
hot laboratory, but there was no shielding within a hood for the
handling of very hot samples that might be collected during an
accident.
Lead bricks were said to be available from the store-
room.
The appraisal Team observed poor sample handling procedures in
the hot laboratory, such as ungloved handling of samples, trans-
port of samples from the hot laboratory without monitoring, and
personnel leaving the hot laboratory without hand and foot moni-
toring.
Such practices are fundamental to a well run radiochemistry
laboratory.
The licensee has recently appointed a foreman as laboratory co-
ordinator.
This should result in an improvement of laboratory
operations.
However, the foreman still needs some training to
become fully conversant with his duties.
- 40 -
..
The licensee lacks a portable GeLi system in the event that the
counting room becomes uninhabitable during an accident.
The
licensee plans to use counting facilities at the other licensee
plants as backup facilities, as well as the licensee's contractor,
Radiation Management Corporation, and the nearby GE Horris Plant.
Based on the appraisal findings, sample handling practices in the
hot laboratory should be improved and ventilated shielding for hot
sample handling should be provided.
9 .. 8 R/C Department Office Space
Space dedicated for non-laboratory work.of the R/C Department has
recently been enlarged and upgraded.
The R/C Supervisor and the
HP group have recently been moved into the Administrative Center
outside the main gate.
The space is adequate, but the move greatly
increases the physical isolation of the HP's from the foremen and
RCT's.
In addition, the exposure records system, including the
computer terminal giving access to the records, is not convenient
to access control, a disadvantage particularly when large numbers
of people are being processed.
The former lunchroom has been converted into a service area for
transacting business with R/C personnel, a foremen's office, an
RCT work area, and an instrument storage room.
The facility is
conveniently located at the junction of access corridors to all
units.
A disadvantage of the arrangement is the increased isola-
tion of the foremen from the service counter and thus from a main
point of interaction between the department and outsiders.
Based on the appraisal findings, the facilities appear to be
acceptable.
However, the licensee should consider installing a
window with pass-through between the foremen's office and the
service counter and providing of HP office space near access control.
10.
A1ARA
No formal A1ARA program exists at Dresden.
Man-rem goals are not
established for the station, for the departments, or for specific jobs.
Job planning does not routinely involve the R/C Department and work
requests are not routed through it for an A1ARA assessment.
The station does participate in a Radiation Evaluation Program (REP)
established by the corporate office.
REP provides exposure data by
work task and, if used properly, could be useful in identifying work
requests where A1ARA review might be beneficial.
At present, REP is
strictly an after-the-fact record.
Moreover; REP is flawed because of
inaccuracies in the data base (Section 4.1) and is therefore of question-
able use at this time.
An effective ALARA program must involve the
entire station and not just the R/C Department or health physics group.
- 41 -
. .. * ...
- ~ *-~~
. -*-;*** .
...
ALARA principles have been applied in singular cases at the station.
A noteworthy example was the use of hydrolazing to decrease dose
associated with NRC mandated work in the torus areas.
Another signi-
ficant ALARA benefit was realized when the new solid waste handling
system was installed (Section 8.1).
Yet another occurred with the use
of a shielded platform during work done in the reactor vessels.
The
dose saving in each of these cases was significant and probably necessary
to avoid an intolerable burden on the station.
The need for a formal
ALARA program increases with plant age.
Two areas currently ripe for
review are routine maintenance and wearing of laundered protective
clothing (Section 9.1).
Based on the appraisal findings, this portion of the licensee's program
appears acceptable.
However, the licensee should consider implementation
of a formal ALARA program with a dedicated ALARA engineer or health
physicist.
11.
Accident/Reentry
11.1 Leakage Outside Containment
In response to item 2.1.6.a of the TMI-2 Lessons Learned Task
Force Report (NUREG-0578), the licensee has implemented a leakage
control program for systems outside containment.
Included in the
consideration were the high pressure coolant injection system (HPCI),
isolation condenser, low pressure coolant injection system (LPCI),
core spray, shutdown cooling system, reactor cleanup system, primary
system instrumentation, reactor water sample system, primary system
isolation valves, and the standby gas treatment system (SBGTS).
The program, as defined in administrative procedure DAP 14-2,
"Leakage Reduction Program," and in technical procedure DTP-9,
"Leakage Detection and R~duction Program," consists of baseline
leakage measurements, periodic visual inspections for leakage by
the operating department, once per refueling cycle measurement *Of
.leakage by the technical staff, and priority processing of leakage
related work requests.
A technical staff engineer was assigned
to work in the area of leak reduction.
Baseline measurements made
in December 1979 showed approximately 15 and 30 gallons per hour
on units 2 and 3, respectively.
The Appraisal Team did not review this program in detail.
However,
inspector observations, including those made during rounds with
operators, indicated no significant leakage.
11.2 Post Accident Sampling and Monitoring
The results of a shielding study by a licensee contractor indicates
that access to the reactor building for reactor coolant and containment
- 42 .,.
sampling would probably be impossible under worst case accident
conditions.
The licensee is now constructing sampling buildings
outside of each reactor building that will permit sample collec-
tion and dilution under such conditions.
The facilities, which
will also be used for routine sampling, are scheduled for January
1981 completion.
Interim emergency sampling procedures (EPIP's 300-8, 300-9, 300-10)
for less than worst case conditions are inplace but are weak owing
to the lack of local shielding at the sampling stations in the reactor
building or in the hot laboratory (Section 9.7).
In addition, the
procedure (EPIP 300-9) for taking the reactor coolant sample does not
address purging .of the sample lines.
The procedures do specify the
use of cart mounted lead shields for transporting the samples to the
hot laboratory and counting rooms for analysis.
These were observed
along with tongs provided for remote sample handling.
However, the
facility with which 15 cc gas sample vials could be handled with tongs
appeared not to have been determined.
The current systems for monitoring the chimney and the reactor.
building vents do not meet the dynamic range recommended in the
TMI-2 Lessons Learned Task Force Report (NUREG-0578) item 2.1.8.b.
A modification to provide instruments with the required ranges
for these release paths is underway and scheduled for January 1981
completion.
An interim procedure (EPIP 300-11) has been written for estimating
accident noble gas releases by means of direct readings on the unit
2/3 chimney sample line with a portable survey instrument.
The
inadequacy of this procedure was revealed to the licensee when an
attempt was made to use it during the June 19, 1980, emergency drill.
The failure resulted because of an illegible graph legend and because
the procedure was not well understood.
Based on the appraisal findings, the licensee needs to strengthen
his capability for emergency sampling and monitoring in order to
achieve a fully acceptable program.
Improvements should include
thorough rereview with actual walk-through of pertinent procedures,
upgraded shielding at the current sampling stations, and thorough
training in the procedures for all RCT's, chemists, and HP's
(Section 3.7).
-
43 -
11.3 Emergency Drill of June 19, 1980
The licensee conducted an exercise to demonstrate integrated
emergency response capability. It was generally successful in
this, and moreover provided a significant training experience for
the station, including R/C Department personnel who were heavily
involved (all but three of 23 RCT respondents were used).
It
also provided a valuable diagnostic for the observing Appraisal
Team members who were present in the Technical Support Center
(TSC)and Operations Support Center (OSC), and who accompanied
sampling and survey teams and observed laboratory analyses.
The licensee's organizational response, including that of the R/C
Department, was generally adequate.
R/C foremen displayed evident
awareness that only 17 of 23 responding RCT's had been emergency
trained and made team assignments accordingly.
The exercise
demonstrated weaknesses in emergency sampling procedures (Section
11.2), in shielding provisions made for sampling stations and hot
laboratory (Sections 9.7 and 11.2), and in basic hot laboratory
sample handling practices (Section 9.7).
The poor sample handling
techniques observed during the drill (ungloved sample handling,
absence of finger dosimeters, sample transfer within the counting
room, and unshielded syringes) were basically not different from
those practiced with low-level routine samples.
One can speculate
that practices would have been much better given truly "hot"-samples
but the need for review of basic principles as discussed in Section
3.6 was clear.
The drill scenario was flawed in that simulated high
radiation levels were not assigned to samples and key locations so
that such matters could be better gauged.
The Appraisal Team also noted that the noise level in the OSC
interfered wi~h radio and telephone communications, that there
was no procedure for systematically debriefing returning survey/
sampling teams to obtain pertinent survey information, and that
there was no means for recording and displaying such information
in the OSC.
Based on the Appraisal Team's observation, the licensee conducted
a satisfactory drill.
However, the lessons learned from this drill
should be incorporated into emergency procedures and training and
should be applied in future drills.
12.
Exit Interview
.*. ,,., .*
The results of the appraisal were discussed with representatives of
licensee corporate and station management (Section 13) at the close of
the appraisal on July 2, 1980.
Significant findings in the areas of
Organization and Management (Section 2), Qualifications and Training
(Section 3), Access Controls (Section 5), Contaminatio~ Controls (Sections
5, 6 and 9)'; Surveillance (Section 6), Instrumentation (Section 7) and
- ...
- 44 -
..
I
-If
W. Hildy, Master Instrument Mechanic
H. Waclaw, Engineering Assistant
M. Stanish, Quality Assurance Coordinator
T. Walsh, Engineering Assistant
B. Coen, Technical Staff Engineer
B. Dunbar, Technical Staff Engineer
B. Saunders, Security Supervisor
L. Dimmock, Shift Foreman
D. Reece, Shift Engineer
CECo Offsite
- C. Reed, Vice President
- F. Palmer, Manager, Nuclear Generation
- J. Bitel, Manager, Technical Services Nuclear
- G. Abrell, Quality Assurance
- J. Smith, Staff Assistant
- H. Dellsy, Staff Assistant
W. Nestel, Station Nuclear Engineering
- E. Pierard, Industrial Relations
Non CECo
- J. Barker, Resident Inspector USNRC
- T. Tongue, Resident Inspector USNRC
- A. Davis, Region III USNRC
- W. Fisher, Region III USNRC
- Denotes those present at the exit interview of July 2, 1980.
The Appraisal Team also interviewed other licensee and contractor
personnel during the appraisal.
- 46 -