ML19309F743

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IE Insp Repts 50-010/80-04,50-237/80-04 & 50-249/80-04 on 800220-22 & 26.No Noncompliance Noted.Major Areas Inspected: Internal Audits,Licensee Coordination W/Offsite Support Agencies & Review of Emergency Drills
ML19309F743
Person / Time
Site: Dresden  
Issue date: 03/11/1980
From: Essig T, Matson E, Oestmann M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19309F741 List:
References
50-010-80-04, 50-10-80-4, 50-237-80-04, 50-237-80-4, 50-249-80-04, NUDOCS 8004300555
Download: ML19309F743 (10)


See also: IR 05000010/1980004

Text

60043 0055 E

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U.S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

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REGION III

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Report Nos. 50-10/80-04; 50-237/80-04; 50-249/80-04

Docket Nos. 50-10; 50-237; 50-249

License Nos. DPR-2; DPR-19; DPR-25

Licensee: Commonwealth Edison Company

P. O. Box 767

Chicago, Illinois 60690

Facility Name: Dresden Nuclear Generating Stations, Units 1, 2, and 3

Inspection At:

Commonwealth Edison Company Corporate Office (February 20,

1980)

Dresden Site, Morris, Illinois (February 21-22, 26, 1980)

Inspection Conducted: , February 20-22, and 26, 1980

H 80

Inspectors:b.J.Oes

M

ann

csb

E. Matson

3/s 2./f o

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Approved by:

T.

. Essig, Chief

Environmental and Special

Projects Section

Inspection Summary

Inspection on Fchruary 20-22 and 26, 1980 (Report Nos. 50-10/80-04

50-237/80-04; 50-249/80-04)

Areas Inspected: Routine, announced inspection of: (1) Emergency Planning

for the three Dresden Units, including internal audits; licensee coordina-

tion with offsite support agencies; and review of emergency drills; (2)

Confirmatory Measurements, including the licensee's program for quality

control of nonradiological analytical measurements; evaluation of the

licensee's analytical results of pl' ant effluent samples obtained during a

previous inspection; and collection of plant effluent samples for future

comparative analysis; and (3) Environmental Protection including review of

the radiological and nonradiological environmental monitoring program for

1978. The inspection involved 42 inspector-hours on site by two NRC in-

spectors.

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Results: Of the seven areas inspected, no apparent items of noncompliance

or deviathns were identified in six areas; two apparent items of noncom-

pliance were identified in one area (deficiency - failure to collect and

analv".e fish for gamma isotopic for the first half of 1978; deficiency -

failure to report analyticccl results of fish collected during the second

half of 1978 in the Annual Report for 1978 - Paragraph 8.a).

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DETAILS

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1.

Persons Contacted

Principal Licensee Employees

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  • B. Stephenson, Station Superintendent, Dresden
  • B. Shelton, Administrative Assistant, Dresden
    • J. Golden, Administrator for Radiological Environmental Monitoring

Programs, Technical Services Department, CECO

P. Hayes Nuclear Technician, TSD, CECO

R. Moore, Nuclear Technician, TSD, CECO

CECO

C. McDonough, Assistant to the Director of the Environmental Affairs

Department (EAD), CECO

M. Waldron, Staff Biologist, EAD, CECO

  • E. Wilmere, Quality Assurance Coordinator, Dresden
  • J. Parry, Rad / Chem Supervisor, Dresden

T. Schneider, Chemist, Dresden

F. Jones, Radiation Protection Engineer

W. Roth, Instructor, Training Section, Dresden

Other Personnel

C. Novak, local landowner, near Dresden

J. Temple, Director, Emergency Services and Disaster Agency, Grundy

County, Morris, Illinois

C. Richards, Security and Disaster Services Chief, St. Joseph Hospital,

Joliet, Illinois

C. Leach, Lieutenant, Sheriff's Office, Grundy County, Morris, Illinois

J. Hornyan, Captain, Illinois State Police District 5, Lockport, Illinois

J. McClain, Lieutenant, Jr. Grade Port Safety Officer for Chicago District,

U. S. Coast Guard

  • Denotes those present at the plant exit interview conducted on

February 26, 1980.

    • Denotes participant in additional exit interviews conducted on

February 27, 1980, by telephone.

The inspectors also interviewed several other licensee employees during

the course of the inspection including chemistry, environmental, and

health physics technicians, members of the security force, and general

office personnel.

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General

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This inspection consisted of emergency planning, including the licen-

see's coordination with offsite support agencies and review of emer-

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gency drills. The licensee's emergency plan, Generating Stations

Emergency Plan (GSEP), with revisions through 1979, was,used as pri-

mary criteria for this inspection.

The confirmatory measurements inspection included review of the licen-

see's quality control program of nonradiological analytical , measurements,

evaluationofthelicensee'sanalyticalresyJtsofplanteffluent

samples collected in a previous inspection,- and collection of plant

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effluent samples for future comparative analyses.

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The licensee's environmental protection program was reviewed, including

administrative and procedural control systems, quality assurance and

control of analytical measurements, implementation of the Radiological

Environmental Monitoring Program (REMP), and the nonradiological En-

vironmental Monitoring Program (NREMP). The licensee's Appendix A

Technical Specifications, Section 4.8.E and Section 6.6.C were used

as primary criteria for this inspection. No Appendix B Technical

Specifications have been issued for this station at this time.

3.

Management Controls

The inspectors examined management controls, including organizational

structure, and assignment of responsibilities and authorities, and

procedural controls of nonradiological and radiological environmental

monitoring programs, and emergency planning.

J. Hughes has been

appointed Director of the Environmental Affairs Department, and has

overall responsibility regarding the licensee's nonradiological pro-

grams. The radiological environmental monitoring program (REMP) is

conducted under the administration of Dr. John Golden in the Technical

Services Department.

V. Chaney remains the Emergency Planning Coordinator responsible to

D. Galle, Operations Manager in the Nuclear Stations Division.

The administrative functions relating to these programs have remained

thesameasdiscgysedinapreviousenvironmentalandemergencyplan-

ning inspection

No apparent items of nonccmpliance or deviations were identified.

4.

Licensee Internal Audits

The inspectors reviewed licensee audits of emergency planning, environ-

mental monitoring, and chemistry procedures utilized in the plant's

chemistry laboratory. The inspector noted that the licensee's Quality

Assurance Department performed audits of emergency planning in March

and May of 1979, pertaining to the conduct of drills, the GSEP in-

ventories and the annual review of the licensee's Emergency Plan

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Implementing Procedures (EPIPs). A follow-up reaudit of the defi-

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IE Inspection Reports Nos. 50-10/78-32; 50-237/78-30; 50-249/78-30.

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IE Inspection Reports Nos. 50-10/75-08; 50-237/75-13; 50-249/75-11.

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ciencies identified in the audits was conducted in October 1979 and

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the items closed out on January 2, 1980. A problem of being able to

reach the control room when the licensee's emergency telephone number

is busy was identified in September 1979. However, the licensee

initiated an action item request to insure that a proper searching

feature be installed after the new telephone system is in place.

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This item will be examined during a subsequent inspection.

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An environmental audit conducted by the Quality Assurance Department

on September 19, 1979, identified a discrepancy, a failure to complete

thr. annual 1979 milk cow census for REMP. The inspector noted that

on October 7, 1979, the licensee's contractor, Eberline Instrument

Corporation, completed the cow census. No other discrepancies were

noted.

No problems were identified in an audit on the chemical control of

reactor coolant conducted in September 1979.

No apparent items of noncompliance or deviations were identified.

5.

Coordination with Offsite Support Agencies

The inspectors reviewed records and written agreements relating to

the licensee's coordination of emergency planning with offsite sup-

port agencies, listed in the GSEP. The inspector reviewed 16 letters

of agreement the licensee renewed with offsite support agencies

during CY 1979. These letters are presently being renewed on a bi-

ennial basis. The inspector discussed the subject of coordination

with licensee representatives and with persons, either in person or

by telephone, identified in Paragraph I from offsite support agencies.

These discussions verified that the existing agreements between the

licensee and the offsite support agencies remain in effect and that

the licensee's contact and coordination were adequate for these

agencies to maintain and effective response capability. The licensee

held its annual coordination meeting in November 1979, with offsite

agencies to discuss the GSEP and responsibilities in handling radia-

tion accidents.

During the visit to St. Joseph Hospital, the inspector discussed the

agreement the licensee has with the hospital regarding medical arrange-

ments. The inspector examined the special hospital room reserved for

licensee personnel. No problems were identified.

No apparent items of noncompliance or deviations were identified.

6.

Emergency Drills

The inspectors reviewed records of emergency drills and test exercises

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conducted by the licensee during 1979. During the first quarter of

1979, the licensee encountered an actual event involving transportation

of a spent fuel cask which collapsed a trailer.

In addition, a fire

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occurred in February 1979 involving the main transformer at Dresden

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Unit 3.

The fire departments in Coal City and Morris, I.llinois, were

called to provide fire assistance.

In May 1979, the licensee con-

ducted the annual drill involving the Radiation Management Corporation,

Et. Joseph Hospital, and the Coal City Emergency Squad. This drill

wasobservedpyNRCpersonnelandwasdiscussedinapreviousinspec-

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tion report

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The licensee also conducted drills in September and November 1979

involving communications and a simulated fire. All drills were

observed by the Emergency Coordinator who prepared necessary docu-

mentation and critiques and pointed out deficiencies noted during

the drills. Recommendations to resolve any deficiencies were pre-

pared and entered into the licensee's Action Item Request Tracking

System. These items are not removed from the system until they are

completed.

No apparent items of noncompliance or dteiations were identified.

7.

Confirmatory Measurements

Licensee Program for Quality Assurance / Quality Control of

a.

Analytical Measurements

(1) Nonradiological Analysis of Reactor Coolant

The inspectors reviewed selected licensee procedures and

records relating to nonradiological analysis of reactor

coolant. Procedures reviewed covered analysis for chloride,

dissolved oxygen, total suspended solids, total hardness,

silica, turbidity, sodium hydroxide, conductivity, pH, and

spectrometric analysis of various reactor coolant metals.

All procedures noted above were current (most having been

revised in 1979) and were deemed technically adequate.

The inspectors toured the licensee cold chemistry laboratory

and observed that all laboratory instruments appeared to be

functional, and calibration stickers current. The inspector

discussed the poor housekeeping of the laboratory with li-

censee representatives. This item will be examined during

a subsequent inspection. Records of maintenance, calibration

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and daily operations were reviewed and found to be satisfactory.

(2) Training of Chemistry Laboratory Personnel

The inspectors discussed the training program that the licen-

see implements for training chemistry personnel on the job.

Such training includes supervisory observation of analytical

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measurements. The licensee has established a formal train-

ing program for new Rad / Chem Technicians. This includes a

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IE Inspection Reports Nos. 50-10/79-11; 50-237/79-14; 50-249/79-12.

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procedure (DCP-1900-1, Revision 0, dated March 1979) which

provides guidelines for training such technicians in the

basic chemistry principles.

(3) Quality Control of Laboratory Practices

The inspectors discussed quality control of laboratory

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practices with licensee representatives. This included

the recommendation to review Regulatory Guide 4.15,

Revision 1, " Quality Assurance for Radiological Monitoring

Programs (Normal Operations) - Effluent Streams and the

Environment," dated February 1979. The licensee represen-

tative stated that improved quality control of laboratory

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practices is being emphasized by the licensee.

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No apparent items of noncompliance or deviations were identified.

b.

Results of Comparative Analysis

The inspectors reviewed the analytical results of gaseous and

liquid wastes, particulate filter and charcoal adsorber samples

collected from the Dresden Station in November 1978. A summary

of these results by sample type and radionuclide is presented

in Table 1.

The resu'..ts of the licensee's and the NRC Reference

Laboratory's analyses were compared using the " Criteria for

Comparing Analytical lleasurements" (Attachment 1). The results

were discussed with t'ae licensee. The licensee failed to detect

Kr-85 in the analysis of gaseous waste. Normally, the licensee

does not analyze for Kr-85 in these comparisons, because the

gamma peak corresponds c1:sely to the annibalation peak of 0.51

Mev. Since the licensee has agreements or possible agreements

with Xe-133m and Xe-133, the gas sample must have been homogenous.

If this result were real and representative, the licensee may

have underestimated the quantity or concentration of this radio-

nuclide released at the time of the sample collection.

Examination

of the gaseous effluent released at that time indicate that the

effluent technical specifications were not exceeded.

The licensee also failed to properly quantify Ba-140 activity

in the analysis of the particulate filter. The licensee could

offer no explanation for this failure, the results of which are

approximately 60% of the NRC Reference Laboratory results. This

has been g continuing problem as identified in a previous in-

spection.-

The licensee agreed to investigate whether the

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calibration of the gamma spectrometer was in error since the

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other radionuclides, although having possible agreements with

the NRC Reference Laboratory's results, had ratios of about 60%

of the NRC Laboratory's results. This item will be examined

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during a future comparison. This result, which was in the non-

conservative direction, did not result in the effluent technical

specifications being exceeded at the time of sample collection.

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IE Inspection Reports Nos. 50-10/78-32; 50-237/78-30; 50-/78-30.

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No apparent items of noncompliance or deviations were identified.

C.

Collection of Samples for Future Comparative Analyses

The inspectors collected samples of liquid and gaseous waste, a

particulate filter, and a charcoal adsorber sample from the li-

censee for subsequent comparative analyses. Results of these

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analyses with particular emphasis on Kr-85 and Ba-140 will be

compared during a future inspection.

8.

Environmental Proection Program

Implementation of the Radiological Environmental Monitoring

a.

Program (REMP)

The inspectors examined the REMP results for 1978 for compliance

with the requirements of the Section 4.8.E, particularly Table

4.8.1, and Section 6.6.C of Appendix A Technical Specifications.

The inspector found that the licensee had not collects d or ana-

lyzed fish for gamma isotopic during the first half of 1978.

This constitutes an apparent item of noncompliance. The licensee

has hired Ecological Analysts, Inc., as a subcontractor to the

licensee's contractor, Eberline Instrument Corporation, to collect

fish samples in the future.

The licensee had also conducted special sample collections and

analyses following increased effluent activity release rates

associated with operational occurrences. Actions taken were

found to be adequate and notification to the NRC timely and as

described in the Annual Reports.

Schedules for calibration and

maintenance of monitoring equipment had been completed as required.

Review of the licensee's Annual Report for 1978 indicated that

the analytical results for fish collected the second half of

1978 were not reported. This omission constitutes an apparent

item of noncompliance. A licensee representative said that an

errata sheet on the analytical results would be submitted in the

1979 Annual Report, to be issued in March of 1980.

Two apparent items of noncompliance were identified.

b.

Implementation of the Nonradiological Environmental Monitoring

Program

The inspectors examined selected results of the licensee's non-

radiological environmental monitoring program for 1977 and 1978.

These programs were conducted by the licensee's contractor,

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Hazleton Environmental Sciences Corporation. The inspectors

reviewed the licensee's Annual Report for January through

December 1977, pertaining to aquatic monitoring, including

water chemistry, bacteriology, phytoplankton, macroinvertebrates,

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periphyton and fishery studies of the DesPlaines, Kankakee, and.

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Illinois Rivers. This program started in October 1967, has been

continued primarily in regards to the requirement of the licen-

see's National Pollutant Discharge Elimination System (NPDES)

Permit issued by the State of Illinois. The Appendix B Tech-

nical Specifications on environmental protection conditions for

the Dresden Station have not been finalized as yet.

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The licensee also submitted his report on fisheries studies con-

ducted in 1978. This report included studies of the species,

number and biomass of fish escaping from the Dresden cooling

pond via the spillway, impingement of fish on the intake, and

fisheries abundance in the cooling pond and the DesPlaines,

Kankakee and Illinois Rivers. One objective of these studies is

to determine the environmental impact of the fisheries during

indirect open cycle (once through) operation of the cooling

pond. The results indicate that escaped fish from the cooling

pond could be discharged to the Illinois River rather than back

to the intake structure, thus minimizing any environmental im-

pact.

In addition, it is expected that recruitment of fish

eggs and larvae to the pond could substantially increase during

the spring and summer months, thereby resulting in a beneficial

effect on the fish community.

No apparent items of noncompliance or deviations were identified.

C.

Cooling Lake Seepage

The inspectors discussed with licensee representatives the pro-

posed recommendations to preclude further effects of seepage

from the cooling lake. The license is preparing a response to

the NRC letter of February 1, 1980.gj The inspector also dis-

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cussed the status of the plans for controlling the cooling lake

seepage with Mr. C. Novak, a local landowner. This item will

be examined in a future inspection.

d.

Quality Assurance and Quality Control of Analytical Measurements

The inspectors determined the quality control of analytical

measurements for the radiological and nonradiological environ-

have remained the same as described

mentalmonitoringprogramgj

in a previous inspection

9.

Tour of Dresden Unit 1, Decontamination and HPSI Facilities

The inspectors toured the Dresden Unit 1 building, the Decontamina-

tion and the HPSI facilities during this inspection. In addition,

a tour to observe the cooling lake, the intake and discharge canals

of Units 2/3 and Unit I were taken. No problems were identified,

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except for the cooling lake seepage through the northern dike as

discussed in Paragraph 8c.

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Letter dated February 1, 1980, from G. Fiore11i, NRC to C. Reed, CECO.

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IE Inspection Reports Nos. 50-10/78-19; 50-237/78-17; 50-249/78-10.

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Exit Interview

The inspectors met with licensee representatives denoted in Para-

graph 1 at the conclusion of the inspection on February 26,.1980,

and discussed by telephone with Dr. J. Golden on February 27, 1980,

the scope and findings of the inspection. The licensee discpssed

their program to prevent recurrence of missing fish sample collection

and analyses, and respective reporting requirements. The licensee

also reported that they are in the process of preparing a response

to the NRC's correspondence pertaining to the cooling lake seepage

problem.

Attachments:

1.

Table 1, Program, Dresden

Confirmatory Measurements

2.

Attachment 1, Criteria for

Comparing Analytical Measurements.

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