ML19250A627

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IE Insp Repts 50-010/79-15,50-237/79-19 & 50-249/79-17 on 790828-31.Noncompliance Noted:Failure to Have Approved Calibr Procedure for Units 2 & 3 Liquid Effluent Monitor
ML19250A627
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 09/20/1979
From: Greger L, Hiatt J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19250A611 List:
References
50-010-79-15, 50-10-79-15, 50-237-79-19, 50-249-79-17, NUDOCS 7910240089
Download: ML19250A627 (8)


See also: IR 05000010/1979015

Text

.

U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-10/79-15; 50-237/79-19; 50-249/79-17

Docket No. 50-10; 50-237; 50-249

License No. DPR-2; DPR-19; DPR-25

Licensee:

Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name: Dresden Nuclear Power Station, Units 1, 2 and 3

Inspection At: Dresden Site, Morris, IL

Inspection Conducted: August 28-31, 1979

i

.U kW

Inspector:

3. W. Hiatt

9IJ0/ Pl

Approved By:

L. R. G

f

f 74' M

Fuel Facility Projects and

Radiation Support Section

Inspection Summary

Inspection on August 28-31, 1979 (Report No. 50-10/79-15; 50-237/79-19;

50-249/79-17)

Areas Inspected: Routine, unannounced inspection of reactor coolant radio-

chemistry, Unit I decontamination, and liquid and solid radioactive waste

systems, including:

effluent releases; records and reports of effluents;

effluent control instrumentation; procedures for controlling releases;

onsite storage; licensee event reports; and licensee action on previously

identified enforcement items. The inspection involved 34 inspector-hours

onsite by one NRC inspector.

Results: Of the seven areas inspected, no items of noncompliance or devi-

ations were found in six areas; one item of noncompliance was found in the

remaining area (Infraction - Failure to have an approved calibration pro-

cedure for the Units 2/3 liquid effluent monitor - Paragraph 8).

791024008

1202 247

.

DETAILS

1.

Persons Contacted

  • D. Adam, Waste Systems Engineer

G. Bergan, Chemist

J. Brunner, Engineer

T. Gillman, Health Physicist

M. Granas, Health Physicist

F. Jones, Health Physicist

  • W. McNeil, Engineer, Detroit Edison Company
  • J. Parry, Radiation Chemistry Supervisor

R. Ragan, Assistant Superintendent, Operations

D. Sharper, Radwaste Foreman

T. Schneider, Chemist

  • B. Shelton, Assistant Superintendent, Administrative
  • E. Wilmere, Q.A. Coordinator

The inspector also contacted other licensee employees, including

radwaste operators and radiation chemistry technicians.

  • Denotes those present at the exit interview.

2.

General

This inspection, which began at 8:15 a.m. on August 28, 1979, was

conducted to examine the licensee's liquid and solid radwaste activ-

ities for compliance with NRC requirements. During the inspection,

tours were made in the Unit I and Unit 2/3 radwaste areas and the

Unit I chemical cleaning facility. The inspector also examined the

Stock waste solidification system (See Paragraph 11).

3.

Licensee Action on Previous Inspection Findings

(Closed) Noncompliance (50-10/78-23, 50-237/78-21, 50-249/78-23):

Failure to meet FSAR commitment for monitoring liquid radwaste

effluents from Units 2 and 3.

The offline effluent monitoring

system was restored to operation in Ncvember 1978, calibrated, and

has been used during all liquid discharges from the Unit 2/3 liquid

radwaste system since that time.

4.

Organization

On August 27, 1979, the Radiation Chemistry, Tecnnical Staff, and

Quality Control Departments began reporting directly to the Assistant

Plant Superintendent, Administrative. Previously, the Radiation

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248

.

Chemistry Supervisor had reported to the Technical Engineer. The

Chemistry Supervisor will continue reporting to the Technical Engineer.

5.

Radioactive Liquid Releases

Theliceasee'sliggdradwastetreatmentwasdescribedinaprevious

inspection report.-

In November 1978 the licensee replaced the

conventional laundry system with two dry cleaning units, reducing

the discharges from Unit 1 to water used for washing respirators.

In September 1979 the licensee plans to test a respirator dry

cleaning unit and a closed cycle respirator wash unit.

Successful

use of these units could eliminate essentially all liquid releases

from Unit 1.

The inspector selectively reviewed che licensee's calculation and

discharge checklists (DOP 20t.0-25 and DOP 2000-28) and " Liquid

Radioactive Waste Discharge Records" for the period from July 1978

through June 1979. Most of the releases were less than 10% of the

Technical Specification limit; none exceeded the limit. The inspector

noted that releases from Unit I decreased by about 70% following the

installation of the dry cleaning units.

No items of noncompliance were identified.

6.

Radioactive Liquid Storage

Results of surveglance procedures DOS 2000-1 (Units 2/3) and DOS

2000-2 (Unit 1),-

written to assure compliance with Technical

bythelicensee,g7.,werereviewed.

Specification 3.

D

Except as previously reported

no discrepancies from the technical specification

activity or surveillance requirements were noted. DRP 1710-4 had

been amended to speci

notification levels and the storage tanks to

j

be sampled for Unit 1

No items of noncompliance were identified.

7.

Effluent Reports

The inspector reviewed the licensee's semiannual effluent reports

for 1978 (liquid and solid radwaste only). Using the licensee's

weekly discharge data, the inspector independently calculated the

liquid discharge data for selected months; no discrepancies from the

reported data were noted. The report met the requirements of Tech-

nical Specification 6.6.C.

No items of noncompliance were identified.

1/

IE Inspection Reports No. 50-10/78-23, 50-237/78-21, 50-249/78-23.

2_/

Ibid.

3/

LER 50-237/79-43.

.

4/

IE Inspection Reports No. 90-10/78-23, 50-237/78-21, 50-249/78-23.

I!

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1202

249

8.

Effluent Control Instrumengtion

The Units 2/3 offline liquid effluent monitor was returned to service

in November 1978. No discharges were made until the first quarter

of 1979, at which time the monitor was calibrated. The calibration

method used is similar to the method used to calibrate offgas monitors.

The licensee performs a linearity check of the monitor, correlates a

gamma analysis (GeLi) of a predischarge tank sample to the monitor's

response during the release of the tank, and uses the curve generated

by the linearity check to graph release concentration (uCi/ml) versus

monitor response (eps). The licensee was aware that this calibration

method would be effective only if the relative percentages of nuclides

in liquid radwaste remained constant. A review of monthly gamma iso-

topic analyses for 1979 (through June) indicated little variance in the

percentages. Cobalt-50, Cobalt-58, and Manganese-54 were the main con-

stituents. The inspector will review the calibration method further

during a future inspection.

The inspector noted that there was no approved procedure detailing

this calibration method, which was used for the first quarter and

second quarter 1979 calibrations. This is considered an item of

noncompliance.

9.

Procedures for Controlling Releases

The inspector reviewed the following revised procedures:

DCP 1200-5

Rev. I

" Reporting Conditions for Selected

Laboratory Analyses"

DCP 1600-7

Rev. 2

" Sampling and Analysis of Radwaste Tanks"

DCP 1600-8

Rev. 3

" Composite River Sampling"

DCP 1600-11

Rev. 3

" Routine OffGas Sampling and Analysis"

DCP 2700-6

Rev. 4

" Determination of Noble Gas Release

Rate From D1 and D2/3 Chimneys Using

the Marinelli Beaker"

DCP1200-5wasrevisedtocorrecttypogragicalerrorsandtoassure

agreement with DRP 1710-4 and DCP 1400-5.-

The revisions made to

the other procedures were to add or delete the procedure from posted

procedure status.

Except for the item discussed in Paragraph 8, no problems with

procedures were noted, and no items of noncompliance were found.

5/

Ibid.

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1202

250

10.

Reactor Coolant Water Quality

A

Records of radioactivity e asurements in reactor coolant water were

reviewed for the period from September 1978 through August 1979. Ne

discrepancies from technical specification surveillance or activity

requirements were noted. The inspector observed that the amount of

total iodine in the Unit 3 reactor coolant was three to four times

greater than that in Unit 2.

According to the licensee, suspected

problems with the 7 X 7 fuel in the Unit 3 core are probably respon-

sible for this difference.

No items of noncompliance or deviations were noted.

11.

Solid Radioactive Waste

The Unit 1 spent resin and sludge storage g nks and vaults were

described in a previous inspection report.-

Installation and

opera ility tests of level instrumentation and sump pumps in the

tanks and vaults were completed in April and May 1979, respectively.7j

These modifications should relieve tank overflow problems.

In February 1979, the licensee began operational tests of the Unit

2/3 Stock radwaste solidification system. About 300 drums of con-

centrated waste, filter sludge, and resin have been processed.

During the tests, capping problems, including burred threads on drums

and excessively soft gaskets, were encountered. The problems were

correcced and the licensee intends to have the system fully oper-

ational by mid-September 1979. The inspector, accompanied by licensee

personnel, toured the system and noted the following radiation

protection problems.

The design of the " labeling station" is such that considerable

streaming of radiation occurs through two openings designed for

smearing drums. The licensee stated that one of the openings will

be totally enclosed, while the other will be fitted with removable

plugs which will be used as access for remote smear handling tools.

Drums must be raised above shield walls for loading into shipping

casks and moving to the labeling station. This causes flucuations

in the radiation levels in the truck bay area.

It is likely that if

several high level drums are moved at once (using a pallet designed

for loading into casks), radiation levels may exceed 100 mR/hr. The

licensee stated that methods would be aeveloped to insure compliance

with 10 CFR 20.203 requirements for control of access to high radiation

areas. According to licensee personnel, radiation levels at the

control room viewing window have approached 90 mR/hr during drum

movement. The licensee plans to increase shielding by .'nstalling

either a leaded or water filled window.

6/

Ibid.

7/

Ibid.

1202 251

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.

~

10.

Reactor Coolant Water Quality

Records of radioactivity measurements in reactor coolant water were

reviewed for the period from September 1978 through August 1979. No

discrepancies from technical specification surveillance or activity

requirements were noted. The inspector observed that the amount of

total iodine in the Unit 3 reactor coolant was three to four times

greater than that in Unit 2.

According to the licensee, suspected

problems with the 7 X 7 fuel in the Unit 3 core are probably respon-

sible for this difference.

No items of noncompliance or deviations were noted.

11.

Solid Radioactive Waste

TheUnitIspentresinandsludgestoragegynksandvaul.tswere

described in a previous inspection report.-

Installation and

operability tests of level instrumentation and sump pumps in the

tanks and vaults were completed in April and May 1979, respectively.77

These modifications should relieve tank overflow problems.

In February 1979, the licensee began operational tests of the Unit

2/3 Stock radwaste solidification system. About 300 drums of con-

centrated waste, filter sludge, and resin have been processed.

During the tests, capping problems including burred threads on drums

and excessively soft gaskets, were encountered. The problems were

corrected and the licensee intends to have the system fully oper-

ational by mid-September 1979. The inspector, accomparted by licensee

personnel, toured the system and noted the following rauiation

protection problems.

The design of the " labeling station" is such that considerable

streaming of radiation occura through two openings designed for

smearing drums. The licensee stated that one of the openings will

be totally enclosed, while the other will be fitted with removable

plugs which will be used as access for remote smea

.ndling tools.

Drums must be raised above shield walls for loading i-

.pping

casks and moving to the labeling station. This caus

.uations

in the radiation levels in the truck bay area.

It is lixely that if

several high level drums are moved at once (using a pallet designed

for loading into casks), radiation levels may exceed 100 mR/hr. The

licensee stated that methods would be developed to insure compliance

with 10 CFR 20.203 requirements for control of access to high radiation

areas. According to licensee personnel, radiation levels at the

control room viewing window have approached 90 mR/hr during drum

movement. The licensee plans to increase shielding by installing

either a leaded or water filled window.

~6/

Ibid.

02 252

7/

Ibid.

-5-

.

These items will be reviewed during future inspections.

No items of noncompliance were identified.

12.

Radioactive Matsrials Shipments

Selected solid redwaste disposal records for the period from September

1978 through Ju'.y 1979 were reviewed. Shipments of solidified

resin, filter aludge, concentrated waste, and dry active wast _ were

made. Records reviewed indicate that shipments containing greater

than Type A quantities were made in either a DOT specification

container or a package for which an NRC certificate of compliance

had been issued. Shipments were made under license procedures DOP

2000-40 " Inspection of Radioactive Waste Shipments" Rev. I and DOP

2000-39 " Loading of Radioactive Waste Sh2pments" Rev. 1.

The inspec-

tor noted that these procedures contained instructions and data

sheets which satisfied the requirements of 10 CFR 71.54 and 71.62.

The inspector reviewed records of the licensee's onsite Quality

Assurance Department's 1978 and 1979 (through July) audits of radio-

active material shipments. The Department performed a formal audit

in May 1979 and conducted periodic spot checks of shipments. The

inspector noted that no problems with NRC requirements were found.

13.

Review of Nonroutine Events

Licensee corrective actions on the following licensee event reports

were reviewed:

LER 50-10/79-01

Radwaste leakage from condensate storage

tank (5/18/79)

LER 50-237/79-10

Blowout of Unit 2 reactor building blowout

panels (2/2/79)

LER 50-249/79-17

Failure of fuel pool area radiation monitor

(7/13/79)

LER 50-237/79-40

Leakage of contaminated water from the

Units 2/3 radwaste reboiler room (6/5/79)

LER 50-237/79-43

Excessive activity in above ground storage

tank (6/12/79)

As a result of the Unit 1 leak, about 30 tons of contaminated soil,

containing a total of 15 mci's of radioactivity, were shipped to a

licensed burial site for disposal. No workers were contaminated by

the water from the leaking line.

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1202

253

.

The licensee stated that the blowout of the reactor building blowout

panels did not cause a release of radioactivity to the atmosphere.

Air samples taken on the refueling floor before the event were in

the 10E-11 uCi/cc range; air and snow samples taken outside the

building following the event were at background levels. The inspector

reviewed the licensee's evaluation and concurred with the results.

No personal contamination resulted from leakage of water from the

radwaste reboiler room. Three 55-gallon drums of dirt, containing a

total of about 10 uCi's, were shipped to a licensed facility for

disposal. A floor drain will be installed in the reboiler room in

the fall of 1979.

The inspector noted that the excessive activity in the above ground

storage tanks was the second such event in the last 18 months (LER

50-237/78-27).

Licensee actions following discovery of the activity

were in compliance with technical specification 3.8.D.

14.

Status of Unit 1 Decontamination

The chemical decontamination of Unit 1 is now scheduled for February

'

1980. The radiation protection department has been providing health

physics support and developing health physics procedures for the

decontamination (e.g. sampling,the cleaning agent during the cleaning,

calculating the curie content of Dow solidification system drums,

effluent sampling, etc.).

No licensee radiation protection staffing

increases are planned; contract technicians will be used if additional

manpower is needed. Dow Chemical plans to provide their own health

physics technicians, who will perform independent sampling and

surveys. However, overall health physics control will be maintained

by the licensee.

During a tour of the chemical cleaning building, the inspector noted

that the Dow solidification system truck bay area may have the same

variable radiation problems during drum loading as the Stock system

(see Paragraph 11). The licensee stated that this problem will be

evaluated. This item will be reviewed further during future inspections.

15.

Exit Interview

The inspector met with licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection on August 31, 1979, and

further discussed the inspection findings with Messrs. Bergan,

Parry, and Ragan on September 14, 1979. The following matters were

discussed:

The purpose and scope of the inspection.

a.

1202 254

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.

b.

The previous item of noncompliance.

(Paragraph 3)

c.

The problem with fluctuating radiation levels in the Unit 2/3

radwaste solidification system during transkrs of solidified

drums. The licensee stated that measures will be taken to

assure compliance with 10 CFR 20.203.

(Paragraph 11)

d.

The potential problem with radiation levels in the Unit I

solidification system during loading of solidified drums into

casks. The licensee acknowledged the inspector's comments and

stated that the problem will be reviewed.

(Paragraph 14)

e.

The item of noncompliance.

(Paragraph 8)

f

L

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1202 255