ML17202U993
| ML17202U993 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 02/07/1991 |
| From: | Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202U992 | List: |
| References | |
| 50-237-91-02, 50-237-91-2, 50-249-91-02, 50-249-91-2, NUDOCS 9102220020 | |
| Download: ML17202U993 (9) | |
See also: IR 05000237/1991002
Text
"*
U.S. NUCLEAR REGUALTORY COMMISSION
REGION 111
Reports No. 50-237/91002(DRSS); 50-249/91002(DRSS)
Docket Nos. 50-237; 50-249
Licensee:
Commonwealth E~ison 'Company
Opus West Ill
1400 Opus Place
Downers Grove, IL
60515
Facility Name:
Dresden Nuclear Power Station, Units 2 and 3
Inspection At:
Dresden Site, Morris, lllinojs
Inspection Conducted:
January 3-23, 1991
Inspector:
_('\\ ~~ ~'--
M.A. Ku~
Senior Radiation Specialist
Accompanied By~~~~~_,,,,,
(January 23, l~;;_JL'i:" C. Schumacher
Approved By: ////f~,~
M. C. Schumacher, Chief
Radiological Controls and
Chemistry Section
Inspection Summary
2.-7-'1(
Date
- tz- 7 --<?/
Date
Date
lns~ection on January 3-23, 1991 (Reports No. 50-237/91002(DRSS);
SO- 49/91002\\DRSSJJ
Areas Inspected:
Routine, unannounced inspection of the solid radioactive
waste management and transportation of radioactive materials programs
(Inspection Procedure (IP) 86750).
The inspector was accompanied during
much of the inspection in this area by two representatives of the Illinois
. Department of Nuclear Safety.
In addition, several allegations concerning
the radiation protection program were reviewed (IP 83750).
Results: Overall, the licensee
1 s solid radioactive waste management
program is adequate.
The licensee has a good program for preparation and
transportation cf radioactive materials (Section 5). Weaknesses included
extended onsite storage of radioactive waste (Section 5), delay in cleanup
of the sludge tank room (Section 6), and investigation of discrepancies
between the results of primary and secondary personal dosimeters (Section
9A).
The station
1 s dose total for 1990 was high at 1399 person-rem ..
"* 1.
- 2.
3.
DETAILS
Persons Contacted
+T. Bennett, Radwaste Coordinator
+F. D. Bevington, Nuclear Quality Programs (NQP)
+E. D. Eenigenburg, Station Manager
M. J. Gagnon, Health Physicist
+T. J. Gallaher, NQP
W. Holcomb, Site Supervisor, Chem-Nuclear Systems, Inc.
K. Kociuba, Superintendent, NQP
D. Lowenstein, Regulatory Assurance
J. Mayer, Station Security Administrator
J. J. McGowan, Radwaste Shipping Supervisor
+L. L. Oshier, Group Leader, Operations/ALARA, Health Physics Section
+K. W. Peterman, Supervisor, Regulatory Assurance
@+D. Saccomando, Health Physics Services Supervisor
+G. L. Smith, Assi~tant Superintendent of Operations
+R. W. Stobert, Operating Engineer
+M. S. Peck, NRC Resident Inspector
+M. C. Schumacher, NRC Section Chief, Radiological Controls and Chemistry
Section
+ Denotes those present at the exit meeting on January 18, 1991.
@ Denotes those present at the exit meeting on January 23, 1991.
General
Routine, unannounced inspection of the solid radioactive waste management
and transportation of radioactive materials programs.
The inspection
consisted of a review of procedures and records; interviews of personnel;
observations of equipment, facilities, and the preparation of several
shipments of radwaste; and independent measurements (Inspection Procedure
(IP) 86750).
The inspector was accompanied during much of the inspection -
by two representatives of the Illinois Department of Nuclear Safety.
The inspector also reviewed several allegations regarding the radiation
protection program.
Audits and Appraisals
The inspector revi~wed the results of NQP Audit Number QAA 12-90-16,
which included a review of the process control program and radioactive
material shipment activities. The audit was an in-depth, gen~rally
performance-based review, conducted by experienced and knowledgeable
personnel.
The inspector also reviewed the results of several
surveillances conducted by the NQP group of radwaste and shipping
activities, and observed quality control personnel at the preparation of
several shipments of radwaste.
No problems were identified by the NRC
inspector.
The licensee's formal quality control and assurance groups
appear to be providing good oversight of radioactive material shipment
activities.
No violations were identified by the NRC. inspector.
2
"* 4.
5.
Changes in the Programs and Training and Qualifications of Personnel
.No significant changes have been made in the solid radwaste and
radioactive materials transportation programs since the last NRC
review in late 1989 (Inspection Reports No. 50-237/89025(DRSS);
50-249/89024(DRSS)).
Overall, the training and qualifications of the
personnel in the radwaste shipping group were good.
Most of the staff
have at least seven years of work experience at Dresden and at least two
years in the radwaste shipping group.
In addition, the members of the
group and the staff health physicists responsible for radwaste shipment
curie determinations have recently received three days of classroom
training in solid radwaste and shipping requirements at the licensee's
Production Training Center. Several of these individuals have taken
the course annually for the past several years.
No violations of NRC requirements were identified.
l.!!!£lementation of the Solid Radioacti.ve Waste Program
The licensee has an active solid radioactive waste program.
It has made
numerous shipments of radwaste to burial sites in the past several years
and has not received an NRC Notice of Violation in this area.
In 1990,
129 shipments of mainly dry active waste (DAW) and dewatered resins were
made.
Most of the waste was shipped as Class A, unstable; however,
several Class B shipments were made.
Several shipments were made in
burial site-approved high integrity containers to provide waste form
stability. Solidification for stabilization was not performed *in 1990;
however, some waste was solidified in cement to reduce dose rates prior
to shipment *using the onsite vendor's solidification procedures.
Chem-Nuclear Systems, Inc., the onsite vendor, has provided solidification
as well as dewatering services for at least the past 5 years. Except for
the discrepancy discussed below, the dewatering performed in 1990 was
done in accordance with the vendor's process control program and its
implementing procedures, which are controlled as station procedures.
For DAW, the inspectors noted that good use was made of volume reduction.
services, such as supercompaction and decontamination.
For all radwaste, *
waste classification to satisfy 10 CFR 20.311 has been performed for
several years using.an inhouse, QA-controlled software program.
No
problems with the l~censee's waste classification methodology were
identified by the inspector. The inspector also inquired about the
licensee's method for determining the quantity of chelating agent in
non-DAW radwaste shipments, as required in 10 CFR 20.311 (b). Licensee
representatives stated that they routinely use a value determined several
years ago, but they were unable during an initial search to locate any
records supporting the use of the value (the inspector notes that,
typically, chelating agent quantities are low in commercial power plant
radwaste).
The licensee agreed to conduct a second search for the
supporting records. This matter will be reviewed during a future
inspection .
During a review of shipment No. 01-91-039, a liner containing 5.3
curies on dewatered resins that was shipped on January 8, 1991, the
inspector observed a discrepancy between the dewatering procedure used
and the actual dewatering performed on the resin.
Procedure FO-OP-023,
3
"*
6.
11 Bead Resin/Activated Carbon Dewatering Procedure for CNS!14-215 or
- Smaller Liners,
11 Revision H, requires the operator, in step 5.2.10, to
monitor*the temperature of the liner during dewatering, and to secure
the dewatering and refill the liner with water if the temperature
increases to 100 degrees Fahrenheit or higher or if the temperature
increase exceeds 25 degrees Fahrenheit per hour.
However, according
to the vendor, the second of three 8-hour dewatering cycles was performed
on the liner over a late night work shift without an operator in
continu_ous attendance to monitor the tempe.rature.
This discrepancy
was discussed with licensee and vendor representatives, who stated that
the requirement for monitoring the temperature was intended for the
intitial hour or two of dewatering, when an exothermic reaction is most
likely to occur.
The licensee agreed to revise the procedure to specify
the intended period of temperature monitoring. This revision will be
reviewed during a future inspection (Open Item No. 50-237/91002-0l(DRSS);
50~249/91002-0l(DRSS)).
In the past several years, the licensee has been reducing a relatively
large backlog of radwaste stored onsite. These efforts have accounted
for much of the large volume of radwaste shipped from the plant in 1989
when approximately 79060 cubic feet of radwaste, containing approximately
2538 curies, was shipped, and in 1990 when approximately 85263 cubic feet
of radwaste, containing approximately 509 curies, was shipped.
The need
for additional action by the licensee, however, was noted for radwaste
stored in the south storage bay of the radwaste building.
In this area,
the licensee has 213 55-gallon drums of radwaste, about half of which
apparently were solidified when the licensee's installed Stock Equipment
Company solidification system was operational, from approximately
1979-1985.
For some of these drums, the licensee has general information
on type of waste and date of solidification, but for most of the 213
drums the licensee does not have this information.
Licensee records
of an inventory conducted around September 1989 indicated that the
physical condition of most of the drums is good; however, some have
missing lids or are otherwise damaged.
Discussions with the licensee
indicated that no plans have been developed to date to ship the drums
to a burial site.
As discussed in Generic Letter 81-38,
11Storage of
Low-Level Radioactive Wastes at Power Reactor Sites,
11 radioactive waste
should not be stored onsite in excess of 5 years.
The storage of the
drums in the south storage bay in excess of 5 years, the lack of records
on the origin of much of the waste, and the lack of a definite plan to
re-characterize and ship the waste for burial is a weakness in the
licensee's solid radioactive waste program.
This matter will be reviewed
during subsequent inspections.
No violations of NRC requirements were identified; however, one program
weakness was identified.
Radwaste Slu~ank Room
The inspector reviewed the licensee's progress on the cleanup of
the radwaste sludge tank room.
Details of the circumstances of the
contamination of this ioom and the adjacent spent resin tank room
are provided in NRC Meeting Reports No. 50-237/89020(DRSS);
No. 50-249/89019(DRSS).
An expected cleanup completion date of
4
"*
7.
June 30, 1990, was given in a letter from the licensee dated
October 6, 1989, and was revised to December 31, 1990, in a letter
dated October 20, 1990.
As discussed in Inspection Reports No.
50-237/90026(DRSS); 50-249/90025(DRSS), the cleanup of the spent
resin tank room has beeh completed.
Discussions during the current
inspection indicated that the cleanup of the sludge tank room, however,
is only about 10% complete and, initially, was halted because of
mechanical problems with the robot used for the cleanup.
According
to the licensee, the mechanical problems have been remedied, but
resumption of the cleanur has been delayed while personnel issues
regarding who will operate the robot are resolved.
In a letter dated
January 23, 1991, the licensee stated that the cleanup should be
completed by June 30, 1991.
The completion of the cleanup has been
delayed twice, the most recent delay involving personnel issues.
No violations of NRC requirements were identified; however, increased
attention by the licensee appears needed to ensure a timely cleanup.
Unit 1 Chemical Decontamination Waste Project
The licensee recently initiated a project to solidify and ship for
burial the waste generated in mid-1984 to early 1985 during the chemical
decontamination of Unit 1 (details of the decontamination project
are discussed in several previous in~pection ieports including, NRC
Inspection Reports No. 50-10/84-05; 50-237/84-07; 50-249/84-06, and
No. 50-010/84-15; 50-237/84-18; 50-249/84-17).
The solidification will
be performed by a vendor (Diversified Technologies of Chesterton, MD)
using an NRC-approved process that uses vinyl ester styrene as the
solidification agent.
Licensee representatives stated that the project
is tentatively scheduled to be completed in early 1992 and may result in
shipmerit for burial of 500-900 55-gallon drums of solidified waste
depending on the amount of dilution required.
Radiation protection
considerations of the project, compliance with the limitations of the
NRC approval of the solidification process, and adherence to NRC and
DOT shipping requirements will be reviewed during future routine
inspections.
No violations of NRC requirements were identified.
8.
Shipping of Low-Level Wastes for Disposal, and Transportation of Other
Radioactive Materials
In addition to 129 radwaste shipments made in 1990, the licensee made
~
approximately 200 shipments of non-radwaste radioactive materials. Most
of these shipments were of contaminated protective clothing, which was
sent to the commercial nuclear laundry in nearby Morris, Illinois. A
review by the inspector of records for several shipments identified no
problems, ~nd according to licensee representatives there have been no
problems with shipments made in 1990 .
The inspector also observed the preparation of two'shi~ments of resins,
conducted independent dose rate measurements of the shipments, and
5
reviewed associated records.
nonroutine use of a personnel
high dose rates.
No. problems
by the inspector.
One of the shipments involved the
barrier for the shipping cask because of
with these two shipments were identified
No violations of NRC requirements were identified.
9.
Allegation Followup
The NRC Senior Resident Inspector at Dresden recently received two
allegations regarding the radiation protection program at Dresden.
They
were evaluated during the current inspection through record and procedure
review, discussions with licensee and contractor personnel, and through
observations *in the main radiologically controlled area (RCA).
a.
(Closed) Allegation (AMS No. RIII-90-A-0120)
Allegation:
The discrepancy between a dose record maintained by a
worker and the licensee's record for the worker is larger than the
alleger has seen at other Commonwealth Edison plants for similar
records.
Discussion:
The alleger gave specific values for the worker's dose
record and the licensee's record as of November 19, 1990.
He also
indicated that, similarly, three other workers had larger than
expected disc'repancies between their personal records and the
- licensee's records, but he did not have specific dose values for
those workers.
The inspector contacted the first worker to verify
the dose values initially received during the allegation and
obtained additional dose information that the worker had recorded
i~ his personal log.
According to the worker, he recorded in his
own log the dose values from his secondary dosimeter (an electronic
dosimeter) that he recorded on the licensee's dose cards.
The
inspector then compared the values obtained from the worker with
the values in the licensee's records. Although there were
differences between 3 *of the approximately 40 values compared, they*
were not significant. However, the inspector observed significant
differences between the dose card values and values recorded on
the thermoluminescent dosimeter (TLD) badge (the licensee's primary
dosimeter) worn by the worker in October and November.
The
inspector also noted similar discrepancies in the records for a
significant number of other workers. These differences may .
indicate possible problems with dosimeter performance or with the
way the dosimeters are being worn by the workers.
The accreditation
of the licensee in January 1990 as a TLD processor by the National
Voluntary Laboratory* Accreditation Program (NVLAP) provides
reasonable assurance that the TLDs used are not faulty.
The licensee has a procedure, DRP 1250-5, "Comparison of Personnel
Dosimetry Results,
11 Revision 4, that provides for comparing the
results of TLDs and secondary dosimeters.
The procedure states
that the comparison should be done every badge period and that
differences of greater than 25% should be investigated. Discussions
6
'*
b.
with licensee representatives and a review of records indicated
that although the comparisons were being performed, many of the
differences greater than 25% for October, November, and December
were not investigated (including the October comparison for the
worker discussed above) or the investig~tions were not timely.
In
addition, numerous comparisons (including the November comparison
for the worker) were made with an incorrect formula which resulted
in calculated differences of less than 25% when the differences were
actually greater than 25% when calculated using the formula in the
procedure.
The failure to follo'w the recommendations of the
procedure represents a weakness in the licensee's radiation
protection program.
This matter was discussed with the senior
manager in the licensee's radiation protection group, who agreed to
perform the comparisons and investigations in accordance with the
procedure for October, November, and December.
The results of this
effort will be reviewed in a future inspection (Open Item No.
50-237/91002-02(DRSS); 50-249/91002-02(DRSS)).
The apparent root
cause of the problem was the high work load of the staff health
physics group.
Findj_!!,9s:
The allegation was substantiated.
For October and
November 1990, a larger than usual discrepancy existed between the
personal dose record maintained by a worker and a record maintained
by the licensee. Larger than usual discrepancies were also observed
for other workers.
However, the recent NVLAP accreditation of the
licensee's TLD program provides reasonable assurance that worker
dose was accurately monitored with TLDs.
No violations of NRC
requirements were identified; however, a weakness in the licensee's
radiation protection program was identified.
(Closed) Allegation (AMS No. RIII-90-A-0129)
The NRC Senior Resident Inspector at Dresden received two
allegations from an individual that are being tracked by one
AMS Number.
One of the allegations pertains to the adherence
to radiation protection requirements by the Dresden securityc
force. This allegation is discussed below.
It was evaluated
during the current inspection through record review, discussions
with personnel in the radiation protection and security groups,
and through observations in the main RCA.
The remaining allegation
is discussed in Inspection Reports No. 50-237/90028(DRSS);
50-249/90027(DRSS).
.
Allegation:
The alleger was required, during the recent Unit 3
refueling outage, to work in a contaminated area without protective
clothing.
Discussion:
In a telephone conversation with the Region III
radiation specialist, the alleger contended that this was an example
of an attitude of the security force's management that radiation
p~otection requirements may be ignored if meeting those. requirements
jeopardizes meeting the NRC security requirements.
7
10.
11.
The inspector review of the event indicated that the alleger
was posted in a non-contaminated area that subsequently became
contaminated because of improper handling of contaminated equipment
at an adjacent jobsite. Some of the alleger's company-issued
uniform also became contaminated; however, the contamination was
very low-level (less than 100 counts per minute per frisker probe
area).
The alleger also stated to the inspector that security
management knew that he probably had become contaminated, but kept
him at his post in order to maintain security requirements.
The
inspector was unable to verify this statement in his discussions
with various contractor and licensee personnel and in a review of
relevant records.
The records did reveal that security guards were
rarely the subjects of Personal Contamination Event Reports and had
not been written up in the past year in Radiological Occurrence
Reports which would indicate no significant problems with security
personnel with regard to radiation protection. Radiation protection *
supervisors indicated that, generally, the attitude of the security
force toward radiation protection requirements was good.
Security
guards interviewed by the inspector stated that security management
had not told or implied to them that radiation protection require-
ments may be ignored if meeting those requirements means that a
security requirement may not be met.
Findings:
The allegation was not substantiated.
No violations of
NRC requirements were identified .
External Exposure and Contamination Control (IP 83750)
Station dose total for 1990, with contribution from two refueling outages
and the Radwaste Upgrade Project, was high at 1399 person-rem.
Emergent
work on the Unit 2 cleanup heat exchanger system early in the year and
the extended Unit 2 refueling outage in the later half of the year (the
outage began on September 24 and was scheduled for about 72 days, but
extended through December) contributed to the high total. The dose total
in 1989 was 1139 person-rem~
For personal contamination events, the licensee documented 286 in 1990,
compared to 215 in 1989.
Although the 1990 total is higher, the
licensee's efforts in this area are still good.
Exit Meeting
The inspector met with the individuals, denoted in Section 1, at the
conclusion of the regular inspection on January 18, and after a review of
the allegations on January 23.
The tentative findings of the inspection
were summarized and certain findings were discussed with licensee
management, including the good performance of the licensee's radwaste
shipping program (Section 5), the continuing efforts to reduce the
backlog of radwaste stored onsite (Section 5), the start of the project
to solidify and ship for the burial the waste from the chemical
decontamination of Unit 1 (Section 7}, continued storage of old drums of
radwaste (Section 5), the delay in the cleanup of the sludge tank room
8
(Section 6), poor implementation of the procedure for comparing dosimeter
results (Section 9A), and the Open Item regarding the inconsistency
between a dewatering procedure and actual practice (Section 5). During
discussion of the Open Item, the NRC representatives stated that the
licensee should ensure that vendors are following their own procedures
or initiating the appropriate change requests.
The licensee acknowledged
this comment and stated that a review of the problem had been initiated.
The licensee also acknowledged the other findings and did not identify
any tentative inspection report material as proprietary .
g'