ML20148D556
| ML20148D556 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/15/1964 |
| From: | Thornburg H US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML20148D554 | List: |
| References | |
| 50-010-64-04, 50-10-64-4, NUDOCS 8010080753 | |
| Download: ML20148D556 (12) | |
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7 U. S. ATOMIC ENERGY COMMISSIL
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REGION III DIVISION OF COMPLIANCE May 15, 1964 CO REPORT NO. 10/64-4
Title:
COMMONWEALTH EDISON COMPANY LICENSE NO. DPR-2 Date of Visit:
May 11, 1964 By H. D. Thornburg, Reactor Inspector
SUMMARY
i During the course of a recent visit to the site, union personne 4. made j
allegations that the Dresden Station managenent had implemented proce-dures for the control of access to high radiation areas which did not comply with a waiver of the provisions of 10 CFR 20.203(c)(2) granted to the Commonwealth Edison Company by the Division of Licensing and Regulation. They alleged further that the procedure which had been written to implenent the provisions of the waiver had been violated by Station personnel to the point where radiation safety had been compromised.
A study of radiation area access control in the light of the above allegations was made by the inspector on May 11, 1964 with the following j
results:
1.
It was apparent that confusion had arisen with respect to the control of keys to high radiation areas during earlier periods of the shut-p down; however, it appeared that the procedure was working properly i
on May 11.
It does not appear that the earlier loss of control amounted to a hazard to operating personnel or other members of the i
public.
2.
Conditions observed at the site do not indicate that the implementation of radiation protection procedures has been substandard.
3.
A finding with regard to whether the procedure outlined in Appendix B complies with that outlined in Appendix A requires careful reading of the language combined with an evaluation of managerent's intent and the intent of the provisions of 10 CFR 20.203(c)(2). A second question raised is whether or not the violations of the existing procedures by individuals constitutes noncompliance with the waiver granted in August 1962.
(continued) 8010080 75 3
, Sum g y (continued)
It is the inspector's opinion that the first consideration does not cons'itute noncompliance with the waiver of the provisions of 10 CTR 20.203(c)(2). The second consideration may in fact involve noncompliance.
However, on the basis that the procedure is presently operating properly, it is the inspector's opinion that enf orcement action is not necessary. This opinion is influenced by the fact that enforcement action might indirectly bring disciplinary action by the company against the procedure violators.
3 DETAILS I.
Scope of Visit A visit was nade to the Dresden Nuclear Power Station on May 8,1964 to provide an orientacion trip for Mr, J. Cermak at the request of DRL supe rvi s i on.
During the course of the visit, union personnel made certain allegations with respect to access control to high radiation areas. A visit was nede to the site on May 11, 1964 to obtain information portaining t
to these allegations.
f (This report does not contain information obtained with regard to shutdown activities on this and other visits.
Such in.fornation will be contained in a subsequent Compliance report.)
The following personnel were contacted dering the ccurse of the visit:
H. K. Hoyt, Station Superintendent C. B. Zitek, Assistant Station Superintendent J. Hughes, Division Safety and Radiation Protection Engineer E. Moran, Instrument Mechanic, IBEW Local No.1460, Member Executive Committee f
J. McAscy, Radiation Protection Man, IBEW Local No.1460, Chief Steward, Dresden Station 1
II.
Results of Visit A.
Background
It will be noted in the previous report, CC Report No. 10/64-3, that a waiver of the provision; of 10 CFR 20.203(c)(2) was granted by the Division of Licensing and Regulation to Commonwealth Edison (at Dresden) on August 23, 1962. The waiver was granted en the basis that (continued)
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i Results of Visit (Oontinued)
- the doors to certain areas 1/ of the plant which met the requirements of the Part 20 definition of a high radiation i
area l'(Section 20.202(b)(3)l7 were to be maintained j
locked. A procedure for limiting access to these areas was proposed by Commonwealth Edison and approved by the Division of Licensing and Regulation in the above referenced waiver. -(See attached Appendix A.)
Commonwealth Edison implemented the procedures outlined in their application for waiver in Station Order N-300.
(See L
attached Appendix B.).
The implementation was placed in effect in September 1962.
f B.
Positions of Union Personnel On May 8, union representatives contacted the inspector and alleged the following with regard to Commonwealth Edison's implementation of the above described waiver:
1.
Station Order N-300 does not properly reflect j.
the procedures approved by the Commission.
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a.
When the alternate key is controlled by a member of plant supervision (for example a Maintenance Foreman) a single call is made upon the first entry into the hi8h radiation area.
The subsequent entries i
and exits of each worker into and from the high radiation area are recorded on a form which is maintained at the entry F
to the area.
l (continued) f 1/
On the basis that it was not clear to which areas of the plant the waiver applied, a Form AEC-599 was issued en April 10, 1564.
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4 Results of Visit (continued) bi Item (4) of attached Appendix A indicates that each individual entering a high
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radiation area should notify the Shift Engineer or his alternate in the control
- room, c.
The alternate keys are placed in service when the reactor is shutdown.
The keys should only be used when the reactor switch is placed in the shutdown position.
L 2.
Commonwealth Edison personnel have violated the provisions of both Station Order N-300 and the waiver granted by the Commission.
a.
Mr. Moran cited an instance in which he was dispatched to the high radiation area with both the key and the control room clip board upon which key checkout and high radiation entry and exit times ate recorded.
b.
A maintenance supervisor has allowed a naintenance mechanic to pcssess the key on occasion.
Item (2) of Appendix A states that the alternate 1 eys must be in the possession of some other plant supervisor.
c.
Personnel had signed out keys with no record available of entry to or exit from a high radiation area.
Union personnel alleged further that the confusion resulting from the varying interpretations of the key control procedure had resulted in loss of control of access to high radiation areas, rhich amounted to a s:fety problem in their opinion.
TI A inspector stated that he would look into the allegations made by the union person wl on the following Monday, Fiay 11, 1964.
(continued) t
. j Feea'tr cf Visit (continuad) 1 C.
Fesition of Monatement The insptetor discussed the situation with management subsequently.
j Mr. Hoyt stated that Station Order N-300 had been written to expand the i
procedures outlined in Cemmonwealth Edison's request for a waiver into an operating procedure. He stated further that Station order N-300 represents r
the company's intent in this matter.
i Mr. Hoyt indicated that confusion had ariser. with respect to the proper use of the keys in question. He stated that Mr. Zitek had recently been assigned the task of reviewing the use of the keys with all personnel end personally raditing the use of the procedure for a
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period to assure himself that it was indeed being followed. He aleo stated that the procedure must be reviewed and clarified to eliminate the btsis for confusion. Such a review will be performed shortly l
according to Mr. Ecyt.
1 D.
Inspection Obs ervaticas j.
On May 11,1964, the inspector reviewed the control of high radiation crea keys and radiation area procedures in general at Dresden.
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The following infornation was obtained 1.
Two keys were under.the. control of the, Shift. Engineer on. duty.
l Proper entries had becn made in the log on May 11, 1964.
2.
One key was under.the control of a maintenance forencn who l
htd a crev vorking in the Sub Pile Room on May 11, 1964.,
t a.
The foreman had signed the key out properly.
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b.
He had notified the control room of his entry into i
the room.
.i c.
The na=es cnd times of entry end exit of all personnel in the maintenance crew were entered on a log sheet at i
the entrance to the radiation area.
l 3.
Esch h> gh rtdiction trea of the plant is covered c,y c Rapittien f
W rk Ps; nit whi:h outlines the procedures for gaining entry, i
describes ths ns.ture of the source of radiction, specifies genere.1 pro:w:tive clothing requirements and monitoring q
instructient, and provides other information.
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&. %esuitc of Vieit (continued) 4 To gein entry to a high radiation area, one must contact Radiction Frotection personnel to obtain survey data and protective clothing requirements.
One man ent.cring a high radiation aree can monitor for himself if he is qaalified-to use en instrument. With more than one man present, Radiation Protection personnel must make the survey.
5.
When one of the altern:ce keys is released to another plant supervisor to allow entry to a high radiation aren, it is done vir.h the approval of the Shift Engineer on duty.
6.
The inspector examined the current plant exposure records /
2 and fcund thet the highest individual exposure accumulated for the veck of May 4 was approximately 120 mrem. The maxi-mum eccezulcted individual exposure for the second quarter of 1964 was apprcximately 550 mrem.
The inepector entered radiation areas of the plant on several occasions during the present shutdown prior to May-11, 1964, to observe varicus operations in progress. It was the inspector's observation that normal rodf.ation control procedures were in force.
The folicwing items were noted:
P 1.
Exporure limits were specified by Radiation Protection personnel.
5 2.
Protective clothing requirements appeared to be proper.
l 3.
Personnel working in the areas appeared to be familar with*
i work procedures.
4.
The entrances to radiation areas were equipped with stepoff ps.de, itendry hampers, and temporary floor covering. The radiction areas vere not cluttered with contaminated cicthing, t
equipment, etc.
Es.dic. tion Protection personnel were alert to the hazards exietirs in the radiction areas and did not hesitate to inotruct personnel, i
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2/ It thould be nc.ted that radiation exposure records are maintained at Dresden which include the latest film badge data to which the daily t
doeinster data times a factor of 1.5 is added.
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k<.s ul ts of Vis it (continued)
E.
Discussions with Union and Management Personnel Following the Investigotion The inspector attempted to' inform the union representatives of the i
disposition of their allegations and answet several specific questions following the investigation on May 11, 1964. Ths inspector also called Mr. McAsey at home on May 12, 1964, in an effort to communicate effectively.
M Essenticily, the inspector informed union personnel that an investigation had been made of their allegations. The inspector would l
forward a repcrt through normal channels to Compliance Headquarters con-i taining the cliegations and the inspection findings. The inspector stated ther no action vould be taken in the field because, in the inspector's F
opinion, no clear end present threat to the public health and safety was spptrent.
Unicn personnel were also informed that the report would be reviewed by Complisace and Enforcement personnel.
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I An ettempt was made on May 11 by union personnel to have the inspector discuss the individual (11egations.
During the discussion, the inspecter was asked the follcwing questions by union personnel and made the fo11 ewing replies:
s Should.thsthreekeysbedistributydonlywhenthe Question:
reacter switch is in the shutdown 2 porition or can they be distributed any time the reactor is shut down?
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Ataver:
It would appear thtt from the radiation safety stand-l point and from the seneral usage of reactor jargon j
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thtt shutdown in this case applies to the situation where the nuclear reaction has been terminated and l*
gas tnd fluid flow through the principal process systems has been discontinued.
i Questice: Which procedure should we use at present?
i Ansvtr:
The one approved by management as 1cng as no clear and l
present danger.to the public health end safety exists.
l Conplitt.ce with the terus of the license and the Feders' Regelttiens is a matter between the Connission a.nd l
montFement et this point.
l (continued) l
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3/ See Item (2) of attached Appendix A.
(During shutdovn periods....)
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, Per*1tt of Visit-(continued).
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Mr. Morsn did not acknowledge that no hazard to the public health and safety existed.
The inspector discussed with management radiation area access control and the compliance aspects of the above allegations.
It was O
noted thst the period during which the maintenance supervisor is con-tacting RAdietion Protection _ personnel for survey data and protective.
clothing requirements prior to the entry to a radiation area is not formalized to the point of requiring the use of a special form.
Management stated that a Radiation Work Fermit existed for all radi-ation areas tnd t Special Work Permit would bv used in cases where it was. cstissted that any' individual's exposure would exceed 50 mrem or other special radiation safety considerations were necessary (e.g.,
respiratory equipment, etc.)
Mr. Hoyt indicated that disciplinary action (loss of one day's work) cight possibly be taken against procedure violators by the company if. conditions warrant.
It did not appear that such action would be taken against individuals it the time of the visit.
The inspector stated that a Form AEC-592 would not be used because:
(1) the sensitive nature of the allegations, (2) the fact s
that Commonwealth Edison's waiver from the requirements of 10 CFR 20,203 are under consideration of DRL personnel at present, and (3) the intricate interpretttien necessary to resolve the procedural questions.
The inspector indicated to both union and management personnel that the views which were expressed represented the inspector's opinion and not the official position of the U. S. Atomic Energy Commission.
It vaa also stressed thet the inspector's report would be reviewed by the Headquarters Regula. tory Staf f.
Attachmette:
Appendices A 6 B.
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APPENDIX A j
PROCEDURES FOR Tile C0!i1ROL I
0F KEYS TO LOCK'ED li1GH KADIAT10ti AREAS AT DRESDEN i
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1.
Requested by Commonwealth Edison Company on April 17, 1962.
h 2.
Approved by Director, Division of Licensing and Regulation on August 23, 1962.
(1) The keys to locks for high radiation areas are the respcnsi-bility of the Shift Engineer.
The Shift Engineer is a mer?Iber of management and holds full responsibility for the t. ale and proper operation of the plant during his assigned shift.
(2)
During any t ime the plant is in operation the one key available is under the control of the Shift Engineer.
During shutdown periods the other two keys may be in the possession of some other plant supervisor, (3) Access to high radiation areas at any time is not per nitted unless authorized by the Shift Engineer.
(4)
In addition to the receipt of an authorization to enter a high radiation area and the special key,nthe individual must contact the Shift Engineer, or his designated al.tcrnate in the esstrol room, imrnediately prio'r to entry into and imme-diate4y upon exiting from the high radiation area. These calls are recorded on a log sheet and also the time at which j
the key was obtained and returned. Said requirements operate t
as a method of timekeeping and serve as a safety check in the an individual should become ill or physicaily injured event while p r e r.e n t in the high radiation area.
(5) All personnel entering areas of unk.own radia tion l e ve l t; are required to carry radiation survey in8truments.
(6) As a routine operation, personnel open the locked doors to the high radiation areas.and proceed only into the shielded labyrinth to lis ten for abnorma l sounds, es pecially those j
produced by s t eam leaks or :ua l f unc tioning equipent.
There entries are usually made on a once per day f requency and are j
limited to a f ew minutes dura tion.
Occasionally, conditions within a high radiation area will necesr.itate more detailed examination.
AFFD;DD A f
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Appendix A 2-1 Cperating perso.,nel request a radia t i on t urvey o f t he. area by the radiation protection personnel before undertaking further exposure. This work is a ll under the direct super-
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vision and with full knowledge of the Shift Engineer.
(7) High radiation areas are not surveyed for radiatien levels en a routine basis.
Spot checks are made at the outside i
surface of the compartment doors only. Special surveys of the int e,rior of the compartment s are made only upon instruc-tions ! rom the Radiation Protection Engineer or when re-quired to permit work to be performed in the compartment.
(8) All surveys performed by radiation protectitn personnel are reported on special reccrd forms which are serially numbered and filed with all permanent radiatien protection records.
Unusua l or alsnorma l condi tions a re ref erred t o the Radiation Protection Engineer and the Shift Engineer.
(9) In the event a fuel element leak occurred, the radiation monitors at many points would indicate this increase, in addition to those monitoring the air ejector ef fluent.
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The Operators and the Shift Engineer would be aware of any increase and therefore permission for entry would be refused and the key to the air ejector compartment or othcr j
affected high radiation area withheld until the area was surveyed by radiation protection personnel.
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i STATION INSTRUCTION NO. M-300 USE OF 5:LTS TO HIGH RADIA1105 AREAS To conform to AEC license regulations concerning entrance of personnel into areas of high radiation, the following rules overning the use of "R" keys to such areas must be adhered to:
NOTE:
To provide more accurate registration of the "R" keys on the daily log sheets, three "R" keys have been provided, with numbers and color codes as follows:
- 3 - yelles.
- 1 - black; #2 - white; A.
During Normal Operation 1.
Only the #1 black "R" key will be. in service for all pinnt personnel; the #2 key will be in custody of the Statiet.
Operating Engineer-Mechanical; and the #3 key in custody of the Station Ope ting Engineer-Electrical.
r 2.
The Shift Engineer on duty will be responsible for the #1 key.
He may assign the issuing of the key to the Senior Control Operator with proper communication and the Control Operator
.on duty will be responsible i
log.
for the entries into the "R" key I
L 3.
All personnel given permission to use the "R" key to enter a i
I high radiation area sna11 make the proper initial entries in the "R" key log in the Control Room.
i 4.
The person to whom the "R" key was assigned sha ll centact the Shift Engineer or his designated alternate in the Control Room immediately prior to entry into and immedia tely upon exiting from the high radiation area.
These times shall be recorded in the "R" key log.
B.
During Shutdown Periods
'.. The "1 "R" key will cantinue in service as listed in i'a r t A and will be used primarily by the operating group.
2.
The 62 and #3 keys will be brought into the Control Rc m and i
n signed to other plant supervisors as required.
Suc h a s s i s;n -
mcnts will be logged in the "R" key log.
These extra. keys may also be used by the Shift Engineer for operating perr.onnel.
3.
The supervisor or his designa ted alterna te sha ll contac t the
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Shift r.ngineer or his designated alternate ia the to".. trol Rocm pric: tc the initia l entry into and after the las, e :- i t ' ton 1
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Ld U U (S-300 Cant.)
. a h i gn r a c'ia t ua n a r t u by his w,rk group te pu r ' or. ins ecti"ns o r c.a i n t ( na nc. e. Tht <>ther ent rances a n d e >. i t.s shall be l'gged regular "R" key log sheett at the entrance te L l:e.i r d i " i d ua l
- n high radiation area bs the superviscr nr hie designa t ed a lt er.
nates.
Tne s e shee S are to be returned to the 'il : -
c :. r e e r later for the records.
4 Prior to plant startep the h2 and 43 "R" keys must be r e t u r r.ed to the Shift Engineer in the Control Room, legged in, and returned to the respective custodians as stated in A-1, d
I g;. 17:,
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