ML17194A368
| ML17194A368 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/08/1981 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17194A367 | List: |
| References | |
| 50-237-81-33, 50-249-81-25, IEB-80-03, IEB-80-3, NUDOCS 8112240240 | |
| Download: ML17194A368 (7) | |
See also: IR 05000237/1981033
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/81-33; 50-249/81-25
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth Edison Company
Po~t.Office Box 767
Chic~go, IL
60690
Facility Name:
Dresden Nuclear Power Station, Units 2 and*3
Inspection At:
Dresden Site, Morris, IL
Inspeeti~ber 27-30
Inspector:
R. A. Paul
and November 12, 13, and 16, 1981
Approved By: * -~
L. R. Greger, Chief
Facilities Radiation
Protection Section
Inspection Summary:
- ~ Z17f1
I
12./CJ/8/
Inspection on October 27-30 and. November 12, 13, and 16, 1981 (Reports No.
50-237/81-33; 50-249/81-25)
Areas Inspected:
Routine, unannounced inspection of licensee actions taken
- in response to Health Physics Appraisal findings, licensee event reports,
and IE Bulletins. The inspection involved 58 inspector-hou'rs onsite by one
NRC inspector.
- Results:
No items of noncompliance were found.
DETAILS
1.
Persons Contacted
- D. Scott, Station Superintendent
- D. Farrar, Assistant Superintendent, Administration and Support
Services
- G. Myrick, Radiation Chemistry Supervisor
- T. Gilman, Lead Health Physicist
- E. Wilmere, Quality Assurance Coordinato.r
- T. Tongue, NRC Senior Resident Inspector
- M. Jordan, NRC Resident Inspector
The inspector also contacted other licensee employees including
members of the technica,I and, engineering. staffs._
-!*Denotes .those attending the exit meeting. * .. *
2.
General
This inspection, 'which began at 8:30 a.m. on October 27, 1981, was
conducted to examine the licensee's actions in response to Health
Physics Appraisal (HPA) findings, licensee event reports, .and IE
Bulletins.
The inspection also included several plant tours, review
of posting and labeling, review of new portal monitoring equipment,
discussions with licensee personnel, review of licensee records,
reports, and personal exposure evaluations, and independent radiation
measurements by the inspector.
3.
Licensee Action on Previous Inspection Findings
4.
(Closed) Noncompliance Item (50-237/80-13-01; 50-249/80-17-01):
Failure to meet Technical Specification 6.2.B, adherence to radiation
protection procedure requirements.
Corrective action included training
of.all laundry operators, replacing inoperable Geiger-Mueller tubes in
the laundry monitor, and adding a weekly surveillance check of the
monitor and its us~~
(Closed) Noncompliance Item (50-10/80-11-01; 50-237/80-11-01;
50-249/80-15-01):
Failure to comply with 10 CFR 71 and 49 CFR 170-189
requirements.
Revised pertinent operating procedures (DOP2000-22 and
39) and QA procedures to assure inspection of drum closures prior
to shipment.
Organization and Management
As noted in a previous inspection report (50-237/81-23; 50-249/81-17),
the licensee was to clearly define the functional role for Health
Physicists (HPs) regarding the technical direction of Radiation
Chemistry Technicians (RCTs) and foremen.
In addition, it noted
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that position descriptions for the HPs did not address the role of
the HP in evaluating routine program implementation and RCT .perform-
ance.
Resolution of these matters is still under review.
(Open
item 237/81-23-01 and 02; 249/81-17-01 and 02.)
These matters were
discussed at the exit interview.
S.
The station's formal ALARA program is being implemented.
As part of
this program, the licensee has:
appointed an ALARA Coordinator;
created a Dresden ALARA Committee; appointed station ALARA repre-
sentatives whose responsihilities have been defined by the ALARA
Coordinator and approved by the Dresden ALARA Committee; and defined
dose reducti6n goals for outage* and non-outage jobs.
The licensee
also intends to use the benefit-cost computer segment of the corporate
ALARA program when it becomes operable.
It was noted during the inspection that theALARA Coord1nator had
not developed a method 'to measure and doc'ument the effectiveness of
the ALARA program, once imp1emented. ** This matter will be reviewed
by the Coordinator in the near future~
On the basis of a review of the minutes of the ALARA Committee and
- correspondence concerning the station's ALARA program, and discussions
with cognizant ALARA personnel, it appears that the licensee has
made a commitment to a formal ALARA program with the intent of
reducing personnel radiation exposure.
A partial measure of the
effectiveness of the program can be made during the scheduled January
through April 1981, Unit 3 outage.
(Closed item 237/81-23-03;
249/81-17-03)
6.
Laundry Monitoring
As a .result of HPA findings concerning the dose contributed by
laundered contaminated clothing, the licensee made an evaluation to
determine this dose by placing film and TLD badges at various loca-
tions inside several pieces of contaminated coveralls.
The clothing
was placed on six fiberglass mannequins, three containing water, the
others air. * The badges were exposed for .8, 24, and 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, respec-
tively.
The preliminary results of this study indicated exposure rates ranging
from 0. 48 to 0. 62 mR/hr t.o badges worn under coveralls contaminated
from 5,000 to 10,000 cpm (80,000 to 160,000 dpm).
A licensee repre-
sentative indicated that further evaluations will be made, time per-
mitting.
(Closed item 237/81-23-04; 249/81-17-04)
7.
Access Controls
The HPA identified several weaknesses concerning:
controlled area
access accountability for high radiation and contaminated areas; the
number and distribution of keys for high radiation areas (HRAs);
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knowledge of dose rate conditions in JIRAs; and adherence to JIRA
access and e*it control procedures.
Since the HPA, the licensee; introduced a coded magnetic card system
to maintain a record of entries and exits from controlled areas;
reviewed .the possibility of placing the badge rack in the gatehouse
to enhance control of dosimeter use; has decided to issue self-
reading dosimeters to operating personnel so they may check their
accumulated exposures during their rounds; instructed persons enter-
ing JIRAs of the importance of reviewing survey information; and
intends to define the area between double step-off ""pads as a contam-
inated area which requires the use of minimum protective clothing.
Although the licensee's reevaluation of the JIRA key distr1bution
system did not result in any major changes, they have reinstructed
those persons responsible for distributing the keys in the necessity
of maintaining proper control.
A review of Radiation Occurrence Reports indicated there were 24
occasions in 1981, to date, when persons failed to notify the NSO
when they exited a JIRA.
This is contrary to station procedure DAP
i2-4.
This matter was brought to the attention of the licensee who
indicated that reinstruttions, stressing the need to follow the
requirements, will be presented to all cognizant persons.
This
matter will be reviewed at a future inspection.
(Open item
237/81-33-02; 249/81-25-02.)
This matter wa~ discussed at the exit
interview.
8.
Surveillance
The HPA noted that the licensee's health physics surveillance program:
needed improvement in the evaluation of anomalous and unexpected
conditions; lacked curiosity and concern; and reflected weaknesses
in training and managemen~ .
. The licensee's primary corrective actions to improve the quality of
the surveillance program for non"'routine events are described in
Sections 4 and 5 of the previous inspection report (237/81-23;
249/81-17).
In addition, tlie, licensee has increased the frequency
of certain types of surveys to help identify anomalous conditions
and potential problem areas.
This matter was discussed at the exit
interview.
9.
Instrumentation
During this inspection, it was noted that certain previously identi-
fied problems concerning weaknesses in the instrumentation program
have been reviewed by the licensee and the following actions have
been taken:
a.
Installed new fixed radiation monitor recorders in the Unit 2
control room.
The Unit 3 recorders will be replaced in early
1982.
- 4 -
,* ,
b.
Increased routine surveillance of fixed radiation monitor
readouts.
c.
Improved the documentation of instrument calibration records.
d.
Purchased several additional high r~nge, portab~e instruments.
e.
Provided sufficient Cutie Pie (CP) instri.unents so that each RCT
has the option of having his/her individual instrument.
f.
Ac~uired three ~ariiculate~ iodine,* and noble gas constant air
monitors* to sample asse'inbly areas and the control room during
emergency conditions.
g.
Acquired and installed new GeLi and alpha/beta proportional
counting systems to replace current analytical counting equip-
ment.
h.
Assigned a permanent foreman to the chemistry laboratory.
These matters were discussed at the exit meeting.
10.
Contamination Control Monitors
The licensee recently installed three liquid scintillation portal
monitors {one in the Unit 2 trackway and two in the gatehouse) to
improve the detection of low-level personal contamination.
The
licensee intends to install a similar monitor adjacent to the radia-
tion chemistry office.
Measurements were made by the inspector and a licensee health
physicist to compare detection sensitivities between the "new" and
"old" portal monitors.
Several cesium-137 check sources were placed
at different locations on the body.
The comparisons indicate the
new monitors (set at their current .sensitivity) will dete~t approxi-
mately 1 uCi 20-40 percent of the time and approximately 2 uCi 100
percent of the time.
Garments with more ev~nly distributed contam-
ination levels ranging from .18 to .37 uCi were detected approxi-
mately 70 percent of the time.
The previously used G-M type portal
monitor did not respond to activity levels up to 3 uCi.
The licensee has reduced the quantity of low-level contamination
leaving the facility as evidenced by the increased amount of per-
sonal clothing and equipment found to be contaminated by the new
system.
11.
External Exposure Control
The inspector reviewed the licensee's evaluation of a contract
employee who exceeded 40 MPC-hours intake (lung uptake of 110 nano-
curies of cobalt-60) during the first quarter, 1981.
Licensee action
was taken in accordance with the requirements of 10 CFR 20.103(b)(2).
The inspector agreed with the licensee's assessment.
No similar
event occurred during the same quarter.
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.....
. . "
No items of noncompliance or deviations were identified.
12.
Review of Nonroutine Events
The inspector reviewed the licensee's corrective actions concerning
the radiological aspects of the following Licensee Event Report.
"LER* 50-237/81-60
Ratio o{ offgas .long to short-lived isotopes
was out of established technical specification
range.
A riew sample wa:s not collected and no
.new ratio was established~ The offgas record-
ing log has.been *changed to require the NSO to
record the ratio and to ensure the ratio is
within the proper range.
The event did not have significant radiological consequence.
13.
Review of IE Circulars
The inspector reviewed the licensee's actions regarding the following
IE Circulars.
IEC 79-09:
IEC 79-21:
IEC 80-14:
Occurrences of Split or Punctured Regulator
Diaphragms in Certain Self-Contained Breathing
Apparatus.
Licensee Action:
Reviewed equipment and found
four of the apparatus addressed by the Circular.
R~vised operating instructions, increased
inspection frequency, and discussed IE Circular
in retraining classes.
Prevention of Unplanned Releases of Radio-
activity.
Licensee Action:
Reviewed radwaste procedures,
"as-built" systems having the potential for
inadvertent release, and tank vent and overflow
routing.
No significant changes were imple-
mented as a result of the Circular review.
Radioactive Contamination of Plant Demineralized
Water System and Resultant Internal Contamination
of Personnel.
Licensee Action:
Ensured adequate separation
between clean demineralized water and contam-
inated systems, installed copper wire valve
seals on accessible vent and drain lines to
prevent transfer of contaminated to.noncon-
taminated water, instituted valve seal
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IEC 80-18:
IEC 81-09: .
14.
Review of IE Bulletins
iEB 80-03:
15.
Exit Interview
checks once per month, and use of procedures
and Radiation Control Standards to reduce
likelihood of consuming contaminated water ..
Safety evaluations for changes to Radioactive
Waste Treatment Systems.
Licensee Action:
Safety evaluations are
reviewed against the requirements of the
Technical Specifications and the Safety
Analysis Report.
Containment Effluent Water that Bypass
Radioactivity Monitors
Licensee Action:
Review indicated that no
water system effluents flow directly to the
environrrient from containment, and all
systems with setondary paths are designed
to prevent contamination escape to the
environment.
Loss of Charcoal from Standard Type II, 2
inch Tray Adsorber Cells.
Licensee Action:
Visual examination of the
cells were made and, no problems were noted.
The inspector met with licensee representatives (denot~d in Secti~n
1) at the conclusion bf the inspection on November 16, 1981.
The
inspector summarized the scope and findings of the inspection.
In
response to certain items discussed by the inspector, the licensee:
a.
Acknowledge the .remarks concerning.the.review of the Significant
Items found during the Health Physl.cs Appraisal (Sections 4, 7,
8 and 9).
b.
.Stated that they would review methods to reduce violations of the
high radiation area access and exit requirements.
(~ection 7).
-:,' 7 -
__ ...... .