ML20214Q418

Notice of Violation from Insp on 860424-0509 & 0630-0710

ML20214Q418
Person / Time
Site:	Dresden
Issue date:	09/17/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214Q408	List: IR 05000010/1986005 ML20214Q418
References
50-237-86-08, 50-237-86-16, 50-237-86-8, 50-249-86-10, 50-249-86-19, NUDOCS 8609240351
Download: ML20214Q418 (1)

Text

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no NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-237 Dresden Nuclear Power Plant Docket No. 50-249 License No. DPR-19 License No. DPR-25 EA 86-137 During NRC inspections conducted during the period April 24 through May 9 and June 30 through July 10, 1986 a violation of NRC requirements was identified.

The violation involved the shipment of contaminated equipment which, upon arrival, was found to have radiation levels in excess of regulatory requirements. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below.

10 CFR 71.5 prohibits transport of any licensed material outside the confines of a plant or other place of use, or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation (DOT) in 49 CFR Parts 170-189.

49 CFR 173.441(a) limits the radiation level on the external surface of any package to 200 mR/hr.

Contrary to the above, on April 30, 1986, the radiation levels on the external surface of a wooden box containing contaminated equipment shipped by the licensee exceeded the 200 mR/hr limit.

This is a Severity Level III violation (Supplement V).

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit to this Office within 30 days of the date.of the letter transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION dk  %

hamesG.Keppler U Regional Administrator Dated at Glen Ellyn, Illinois this 176 day of September, 1986 G

.. gg 3 01986 Docket No. 50-10 Docket No. 50-237 Docket No. 50-249 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted by Mr. D. E. Miller of this office during the period April 24 through May 9, 1986, of activities at Dresden Nuclear Power Station, Units 1, 2, and 3 authorized by NRC Operating Licenses No. DPR-2, No. DPR-19 and DPR-25, and to the discussion of our findings with Mr. Scott and other members of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identt fies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in violation of NRC requirements, as described in the enclosed Notice. The inspection showed that action had been taken to correct the iuentified violation and to prevent recurrence. Our understanding of your corrective actions are described in Paragraph 9 of the enclosed inspection report.

Consequently, no reply to the violation is required and we have no further questions regarding this matter at this time.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room.

as -r n am n o O nd

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Commonwealth Edison Company 2 We will gladly discuss any questions you have concerning this inspection.

Sincerely, "Artginnt signed by E.p. S.%fer" W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch

Enclosures:

1. Notice of Violation

2. Inspection Reports No. 50-10/86005(DRSS);

No. 50-237/86008(DRSS);

No. 50-249/86010(DRSS) cc w/ enclosures:

D. L. Farrar, Director of Nuclear Licensing D. J. Scott, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division d f RII RIII R RII R Mill j Gr Cem i B j h er

NOTICE OF VIOLATION Commonwealth Edison Company Docket No. 50-10 Docket No. 50-237 Docket No. 50-249 As a result of the inspection conducted during the period April 24 through May 9, 1986, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation was identified:

10 CFR 71.5 prohibits transport of any licensed material outside the confines of a plant or other place of use or delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170-189.

49 CFR 173.475(b) requires that before each shipment of any radioactive materials package, the shipper shall ensure by examination or appropriate tests that the packaging is in unimpaired physical condition.

Contrary to the above, one package delivered to the burial site on March 14, 1986, and one delivered on April 3, 1986, from Dresden Station, were identified by a State of Washington inspector as each having a hole (or holes) in the package; there was no leakage of package contents.

i This is a Severity Level IV violation (Supplement V).

l The inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, no reply to the' violation

( is required and we have no further questions regarding this matter.

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Dated h) D Nw W. D. Shaf er/, ~ Chief Emergency Preparedness and Radiological Protection Branch mr -n.. . >-

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U.S. NUCLEAR REGULATORY COMMISSION REGION III Reports No. 50-10/86005(DRSS); 50-237/86008(DRSS); 50-249/86010(DRSS)

Docket Nos. 50-10; 50-237; 50-249 Licenses 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: April 24, 25, 28-30, and May 1, 2, 8 and 9, 1986 to Inspector: D. E. Mil er 6-@@

Date Approved By: L. R. reger, Chief 15 -2kD-d7G)

Facilities Radiation Protection Date Section Inspection Summary Inspection during the period April 24 through May 9, 1986 (Reports No. 50-10/86005(DRSS); No. 50-237/86008(DRSS); No. 50-249/86010(DRSS))

Areas Inspected: Routine, unannounced inspection of radiation protection aspects of Unit 2 operations and of Unit 3 recirculating system piping replacement program. Also reviewed were past open items, radioactive materials and radwaste shipment incidents, a radiological occurrence, an IE Information Notice, and review of three allegations.

Results: One violation was identified (inadequate examination of radioactive waste packagings - Section 9).

A / m/ . t a n c Q 1,1 Q W W W 'T W Q( J > +

DETAILS

1. Persons Contacted

• D. Adam, Compliance Coordinator

• J. Brunner, Assistant Superintendent, Technical Services

• T. Ciesla, Assistant Superintendent, Operations

• T. Gilman, Project Radiological Protection Coordinator

• S. Mcdonald, Rad / Chem Supervisor

• G. Myrick, Lead Health Physicist, Nuclear Services

• E. O' Conner, Assistant to Rad / Chem Supervisor J. Schrage, Health Physicist, Nuclear Services

• 0. Scott, Station Manager D. Sharper, Waste Systems Engineer

• D. Soccomando, Lead Health Physicist

• R. Stols, Senior QA Engineer

• J. Wujciga, Superintendent, Production

• R. Zentner, Assistant Superintendent, Maintenance The inspector also contacted several other licensee and contractor personnel.

• Denotes those present at the exit meeting.

2. General This inspection, which began at 8:00 a.m. on April 24, 1986, was conducted to examine radiation protection aspects of Unit 2 operations and the Unit 3 recirculating system piping replacement program. Also reviewed were past open items, radioactive materials and radwaste shipment incidents, a radiological occurrence, an IE Information Notice, and three allegations. Several tours of access control and work areas were made to observe and evaluate operational radiological controls.

3. Licensee Actions on Previous Inspection Findings (Closed) Open Item (10/83-11-02; 237/83-19-02; 249/83-17-02): Procedure for disposal of waste oil. The licensee has written and implemented Procedure DCP-1600-14, " Unconditional Release of Bulk Liquids and Used Makeup Demineralizer Resin"; this procedure includes waste oil. The procedure establishes a requirement for a Co-60 and Cs-137 LLD of 5.0E-8 pCi/ml, and presents standardized sample volumes, LLD determina-tions, and counting methods. No additional problems were identified.

(Closed) Open Item (237/85022-01; 249/85018-01): Calibration of new liquid radwaste monitor. The monitor was designed with a sodium iodide detector which views a shielded flow through container; the detector electronics had a background subtract feature which was fed by a GM detector; preliminary testing determined that the background subtract configuration was not viable for other than monoenergetic radiation ,

background sources. The licensee duplicated the liquid monitoring (

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chamber to provide the background subtract signal; the duplicate chamber views clean water; this configuration was functional as verified by testing in actual background conditions at the station. The licensee then determined the effluent liquid detector efficiency and linearity using licensee-prepared Cs-137 liquid sources; the efficiency determined compared favorably with vendor supplied efficiency data. The efficiency testing was done during January and February 1986. Secondary calibration and linearity checks, to be performed in the future, will use solid Cs-137 sources; the expected detector responses to these sources;was established at the time primary calibrations were performed. Calibration procedures for use of the solid sources are to be developed before the next required calibration is due.

(Closed) Open Item (237/85041-01; 249/85035-01): Commitment to perform surveys of gang boxes. Routine surveys of gang boxes is being done weekly. The licensee plans to formalize the requirement to survey gang boxes after resolution of certain coordination and records keeping problems.

(0 pen) Open Item (237/85026-01; 249/85021-01): Install new liquid radwaste discharge line, remove temporary tie to Unit 1 discharge line (soft pipe), and determine disposition of contaminated soil. The new liquid radwaste discharge line has been installed and the soft pipe temporary tie to Unit 1 discharge line has been removed. Disposition of contaminated soil has not been determined; the licensee stated that contact with NRR concerning the soil would soon be made.

4. Organization and Management Controls The inspector reviewed the licensee's organization and management controls for radiation protection, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of the program.

Recent changes to the Rad / Chem Department include:

• A CECO corporate office health physicist has been transferred to Dresden Station and assigned as Assistant to the Rad / Chem Supervisor.

• The Dresden Lead Health Physicist was transferred to Ceco corporate office.

• A Dresden Health Physicist has been promoted to Lead Health Physicist.

• A health physicist employed by Impell has been temporarily assigned to the Rad / Chem Department.

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The new Dresden Lead Health Physicist is qualified as a " Supervisor not Requiring AEC Licence" in accordance with Section 4.3.2 of ANSI N18.1-1971.

She also meets the requirements for " Radiation Protection Manager" listed in Regulatory Guide 1.8-1975. l Except as described above, the Rad / Chem Department remains assentially unchanged from that discussed in Inspection Reports No. 50-10/85008; No. 50-237/85002; No. 50-249/85018.

The inspector selectively reviewed Radiological Occurrence Reports (RORs) written during 1986 to date. The inspector noted that licensee followup ,

were generally good. The inspector noted that personnel actions continue l to be taken for persons identified as being habitual offenders of i radiological procedures or who display disregard for good health physics l

practices.

i No violations or deviations were identified.

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5. Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual .

intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; ar.d required records, reports, and notifications.

The licensee's program for controlling internal exposures includes the use of protective clothing, respirators, and equipment, and control of surface and airborne radioactivity. A selected review of air sample and smear survey results was made. No significant problems were noted other than contamination controls noted in Section 6.

Whole body count data was reviewed for counts performed during the first calendar quarter 1986 on company and contractor personnel. Several followup counts were performed on persons who showed elevated initial counts. Followup counting was adequate to verify that the 40 MPC-hour control measure was not exceeded.

No violations or deviations were identified.

6. Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.

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A tool and equipment decontamination facility is being constructed in the Unit 2 Turbine Building. Most decontamination equipment is installed and operational. Major structural and ventilation modifications remain to be completed before the facility is considered fully operational. The installed equipment includes a freon cleaner and a shot blaster. The facility is now being operated by a contractor; permanent manning has not been assigned, but will probably be assigned to a station work group. A tool control tagging and logging system is being used on a trial basis.

A major decontamination of liquid radwaste facilities is in progress. A major modification of the system is proposed; a contract has been let to evaluate the need and engineer the changes. The ability to maintain equipment and prevent or reduce contamination incidents is included in the design criteria. .

The decontamination foreman maintains records of area decontaminated, time spent, and dose received. During the first calendar quarter 1986, 17 person-rem was received during 764 person-hours of decontamination work done by a contractor. A major portion of this work effort was expended in decontamination of the liquid radwaste facility. No record of hours worked by station work crews doing decontamination work was maintained.

The recent past history of the Station Decontamination (Reclamation)

Program is discussed in Inspection Reports No. 50-10/85017; No. 50-237/85041; No. 50-249/85035. In that report, it was noted that the program had, in effect, been discontinued due to manpower constraints. The reclamation program was to be performed by a plant housekeeping crew composed of persons from various station departments, and a dedicated crew of three "B" Operators. The assigned personnel are seldom available to perform the decontamination duties; therefore, little progress has been made. This matter was discussed with licensee personnel and remains an Open Item (237/85041; 249/85035-02).

During tours of radioactive materials areas outside of the main plant facilities, the inspector noted that several postings and barr!er ropes were weathered and needed replacing; these were promptly corrected by the licensee. Also noted during the tours was a general lack of good housekeeping, apparent use of LSA 55 gallon ~ drums for various non-radio-logical purposes, and extensive use of temporary radioactive materials areas / trailers / containers that have been in use for several years and 6 a in poor physical condition. Several licensee supervisors and ranagers toured these areas with the inspector and the NRC Senior Resident Inspector. This matter was discussed with licensee managers during the inspection and at the exit meeting. (237/86008-01; 249/86010-01).

No violations or deviations were identified.

7. Personal Contamination Events; Recirculating Piping Replacement (RPR)

The inspector reviewed the history of personal contamination events experienced in the first calendar quarter 1986 during the RPR Project.

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l For each event the licensee documented the portion of the body and/or clothing contaminated, the extent of contamination, and the results of investigation of each event.

During January, there were 359 contamination events; 31 percent were skin, 48 percent were personal clothing, and 21 percent both personal clothing and skin. This amounted to a contamination event for 2.4

. percent of the drywell entries during January. The licensee identified a need to institute additional requirements for protective gloves, and taping of gloves, and better observation of disrobing.

During February, there were 182 contamination events. Skin and personal clothing contaminations decreased by about 50 percent. There was a contamination event for 1.2 percent of the drywell entries. Much of the reduction was attributed to changes in protective clothing requirements.

During March, there were 77 contamination events. There was a contamina-tion event for 0.5 percent of the drywell entries. A portion of the reduction was due to a reduction in the number of jobs performed where there was a high potential for a resulting contamination. event. Other reasons for reductions are described below:

Since the start of the RPR Project, the licensee maintained a computer listing which included contamination events, exposure investigations, and radiological occurrence reports; the listing was by name and badge numbe r.- Using this listing, the licensee identified persons who needed further guidance or indoctrination and provided it, and initiated personnel actions for those who habitually failed to follow radiological procedures or good health physics practices. Many of the clothing contamination events were shoe contaminations of minor importance; these resulted from minor contamination spread events, many of which were caused by improper disrobing at step-off pads. The licensee increased disrobing surveillance during the course of the period, and the contamination events diminished.

The number of personal contamination events appear large. However, the contamination event frequency does not appear inordinate for the massive work effort involved in the RPR Project. Monitoring of personnel to identify personal contamination was good; decontamination and followup monitoring was good, and; whole body counting was performed when skin contamination events indicated that intakes were possible. There is no indication that any person left the station with identifiable quantities of radioactive contamination on the skin or clothing, and no intake in excess of the 40 MPC-hour control measure was identified.

No violations or deviations were identified.

8. Radwaste Cost / Benefit and Dose / Benefit Analysis In response to a concern raised during an earlier inspection, the licensee conducted a comparative cost analysis (dose and monetary) of continued use of vendor radwaste solidification for resins and sludges 6

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versus use of the installed solidification equipment at Dresden station. l The analysis was completed by Dresden Station personnel in February 1986. The analysis used a projection of waste volumes expected in 1986; )

the costs and doses used in the analysis were based on past experience i with the vendor solidification service and solidification using the )

installed equipment. All costs and doses incurred from generation to burial were considered in the analysis.

The analysis concluded that use of the vendor solidification' service  ;

results in both monetary and person-rem savings. The projected savings  ;

estimates for Dresden Station were about $1,300,000 and 170 person rem for 1986. The radwaste cost / benefit summary has been forwarded to appropriate CECO corporate office personnel by Dresden Station management.

No violations or deviations were identified.

9. Radwaste Shipment Incidents On March 15, 1986, NRC Region III was informed by the licensee of a violation associated with a shipment of low level waste from Dresden Station that arrived at the Richland, Washington low level waste burial site on March 14, 1986. A State of Washington inspector had identified three small holes six to eight inches from the bottom of a 55 gallon drum (DAW 123-86). This was a violation of the State of Washington Radioactive Materials License Condition 27.F (package deformation).

There was no leakage of package contents. The State of Washington suspended the licensee's burial permit for seven days because of the violation. According to the licensee, the holes appeared to be manufacturing flaws which were not identified by the manufacturer or during inspections at the station. In response, the licensee recommended that appropriate inspections of the drum manufacturer's QA program be scheduled. Also, the licensee revised Procedures D0P 2000-22 and 41 to require increased surveillance of packagings before they are filled, and instructed appropriate personnel concerning the procedure revisions.

On April 4, 1986, NRC Region III was informed by the licensee of a violation associated with a similar shipment arriving at the burial site on April 3, 1986. A State of Washington inspector identified a small crack in a crease in an over pack drum; the over pack drum contained two " pucks" from a super compactor. Again there was no leakage of package contents. The licensee's burial permit was again suspended for seven days. According to the licensee, and verified by the Region III radiation specialist, special note of an existing crease on the over pack drum was noted on the QC checklist for the shipment; no hole was observed by the QC inspector in the crease. The licensee believes that the crack occurred during transport. The licensee revised procedure DOP 2000-40 to include a requirement to obtain approval of the Waste Systems Engineer before shipment of packages displaying certain deformations.

The above shipments are considered in violation of 10 CFR 71.5 and 49 CFR 173.475(b). The corrective actions appear adequate to prevent recurrence. (237/86008-02; 249/86010-02).

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e naa violation was identified.

10. Radioactive Material Shipment Incident On April 29, 1986, Dresden Station (shipper) shipped contaminated under-water cutting equipment, owned by a contractor, to Carolina Power and Light Company's Brunswick Station (consignee). The cutting equipment was packaged at Dresden Station by the contractor; the packaging was wooden boxes; the boxes were placed on a flat-bed trailer and shipped sole-use.

On April 30, 1986, Dresden Station was notified that, when received, one box had contact dose rates greater than 200 mR/hr in three places. On the next day, the Dresden Station Rad / Chem Supervisor and a health physicist arrived at Brunswick Station to inspect the shipment. The Dresden Station representatives verified contact readings of 325, 300, and 500 mR/hr as measured with a teletector on these separate sides of ("

the box. Because the box had been surveyed with an R0-3 (ion chamber) instrument before shipment, this survey geometry was simulated by placing the Teletector detector at two inches from contact with the box; the

.500 mR/hr reading dropped to about 160 mR/hr, and the 325 and 300 mR/hr readings dropped to about 230 mR/hr. The 160 mR/hr reading corresponded to the maximum reading recorded on the shipping papers. The calibration of the R0-3 survey instrument, used at Dresden Station to survey the box before shipment, was checked. The instrument was found to read ten percent low, which is within acceptable tolerance.

The Dresden. Station representatives observed the opening of the ,

box. According to the representatives, some shifting of small parts (with near contact dose rates up to 800 mR/hr) had occurred inside the box; this shifting had caused increased localized dose rates on two sides of the box. The representatives, estimated the maximum shifting distance to be about four inches, and that this shifting was enough to cause the noted increases; the representatives stated that bracing in the box was not adequate to prevent the shifting.

Proposed licensee corrective actions include use of portable survey instruments with small diameter detectors to survey package contact dose rates, and proceduralizing responsibility for assurance that package internal bracing is adequate. Until tha above actions are formally established, a health physicist will en,sure the actions are performed.

The regulatory requirements addressing radiation level limitations for this shipment are found in 49 CFR 173.441(b). This requirement appears to clearly limit radiation levels on the external surfaces of packages for open transport vehicle, exclusive use shipments to 200 mrem /hr.

However, discussions with an NRC Office of Inspection and Enforcement representative indicated the possibility that the radiation levels found on this shipment, between 230 and 400 mR/hr, may have been acceptable.

Therefore no enforcement action is being taken at this time. The matter is considered unresolved pending clarification of the Department of Transportation radiation level limits by the NRC Office of Inspection and Enforcement (IE). In addition to interpretation of 49 CFR 173.441(b),

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definitions of acceptable methods (monitoring instrumentation) for measuring " surface" radiation levels requires resolution by IE.

. (Unresolved Item 237/86008-03; 249/86010-03) i Two unresolved matters were identified.

11. Radiological Occurrence, Unit 3 On April 30, 1986, a pipefitter was preparing to work in the overhead of the drywell basement; his job was to grind on a drain line nipple. Tne pipefitter notified the contract Rad / Chem Technician (RCT) covering the

, area. The RCT checked recent survey data for the area, and instructed the pipefitter concerning proper protective clothing and general area dose rates. The pipefitter showed the RCT the work area by looking through the grating of the level above_the basement overhead; the i specific work area was not well_ lit; no specifics about how the work would proceed were discussed. The pipefitter set-up the work area and tools but did not start work until after a break. The RCT turned over job-surveillance to another RCT before the pipefitter returned; the second RCT saw another worker near the area mentioned, and assumed this was the job discussed by the first RCT; therefore, the second RCT did not intermittently observe and monitor the pipefitter's work area.

The pipefitter went to work without notifying the second RCT. The pipefitter made a total of three entries and received 140 mrem on his self-reader. He was permitted to receive 200 mrem per day. Since he normally received about 50 mrem per day, he requested a specific survey i of his work area before starting work the following day on the same drain line. When the survey was done, and the job discussed between the RCT (who performed the survey) and the pipefitter, it was found that the pipefitter had been resting his head on a drain line while working. The drain line was later found (by TLD study) to read about 150 mrem /hr on cantact. Because the pipefitter's dosimetry was in his breast pocket, it did not record the pipefitter's limiting whole body dose which was to his head.

The licensee immediately wrote a Radiological Occurrence Report and began an investigation. The investigation included personnel interviews, TLD studies of the work area, and a review of access control log entries.

The inspector, who was informed of the incident shortly after it was identified by the licensee, sat in on personnel interviews and followed i the course of the investigation.

! As a result of the licensee's investigation, a whole body dose of 397

) millirem was assigned, instead of the 160 millirem indicated by 1 sel f-reader. The assigned dose was based on the dose rate gradient l' variance, between the dosimetry location (on the pipefitter's chest)

! and the pipe that he rested his head on. The inspector agrees with j the licensee's evaluation and dose assigned to the pipefitter.

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'1 The licensee's corrective actions included: s 3

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• Craft foreman and supervisors were ' informed of the inciden9and' , ' J'i were instructed to assure that worke's rhave' good communications i with RCTs concerning specifics for each job to be worked. 7.  ;,; ,

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• A general meeting was held with contract RCTs and foremen to \  ;

reemphasize the requirement that specific survd/s be performed for '

each job before work begins, and that turnoverssbetween RCTs be '

thorough and specific. ,

• A required reading memo, outlining this incident and reiterating -

proper work habits and job coverage, was issued to each RCT , '

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• The method of work which required an askdard body position far this , ii' job was evaluated; as a result, a piece of'ductwork was emoved to provide easier access to the work area. 7

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!4 Q, s t i The licensee's investigation was timely and'thorouin,'and corrbctid q I actions-good. This matter is considered licen'see -identified anel n T corrected. No additional probler.s were identified.

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s There were no inspei: tor identified violations, op deviay:ons. 'll

12. IE Information Notice i The inspector reviewed licensee action in res anse to the followinY selected IE Information Natice. The actions are considered adequate.

No. 85-81: Problems Resulting in Erroneously High Reading.with Panasonic

• j 800 Series Thermoluminescent Dosimeters. Tne Ceco Nuclear Se'rt f ces department responded to this, notice by generic letter dated .No,venifer 7, 1985. According to the letter, the licensee had observed same anomalous readings from phosphors covered by lead filters wh(le perforsing , ;i d acceptance tests on the dositaters. Due to this, and other' q'uality/ design.

deficiencies, all dosimeters,'were returned to the v6nocr'for repair or <

replacement. According to Fice'nsee reprc.centatives, no problems.have . 'I '

since been encountered. The licensee stated 'that.' appropriate precaut'ons

( would be taken to protect TL".d if they a're requir5d to be worn W advsrse environmental conditions, suctias those discussed,11 the Notice.

( 13. Allegation Followup Discussed below are three separate.r.nonymous allegations, d concerns, brought to the attention of NRC Region III. These allegations were evaluated when received to determine need for immediate onsite followup; such need was not indicated. The evaluations included preliminary review of information gathered during. telephone interviews with the licensee concerning the general subject' matter of,the allegations. Further reviews of the allegatiors were performid during this inspection.

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/.- a. On November 25, 1985, an NRC resident inspector at Dresden Station

, i received a telephone call from an individual who wished to remain t anonymous. The subject of the call and followup discussion is l x ' '

presented below:

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l 3 ]( Allegation: A radiation protection supervisor was observed acting in an erratic, over-emotional manner; because of this, the caller r,. .

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, questioned the psychological stability of the subject individual.

Discussion: During discussions with licensee managers, the inspector was informed that the subject individual had been observed periodically since the initial phone report from the NRC inspector (11/25/85), and that he had not displayed abnormal behavior. No violations of NRC requirements or need for further followup were identified.

1 b. On January 15, 1986, D. E. Miller, Senior Radiation Specialist,

's received a telephone call from a male contractor who was working la h 'yq for a firm who was contracted to do work at Dresden Unit 3. The contractor said he had concerns about working conditions at Dresden 3. He said he was not making an allegation; he would not i

give his name; and he said that he did not intend to submit anything in writing. The subjects of the call and followup discussions are

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presented below:

1 Allegation: Pocket dosimeters show excessive drifting. He had two off-scale dosimeters recently when exiting the drywell; doses were 1>

estimated by Dresden radiation protection personnel using his time in the area and past surveys. His TLD was not read to confirm the  ;

estimates even though he had requested it be read. He claimed that l the dose estimates were not made using the most recent surveys. l l

I Discussion: The licensee st'ated that during the period in question frequent problems with excessive drifting were experienced with a specific model of pocket dosimeters. After investigation, the licensee determined that the dosimeters were not compatible with dosimeter chargers from a differect vendor, and that damage to dosimeter electrodes caused the excessive drifting. The licensee I discarded the damaged dosimeters and acquired chargers that were compatible with the pocket dosimeters; no further problem with

( excessive numbers of drifting dosimeters has been encountered.

A review of TLD readings for personnel employed by the named contractor for the fourth calendar quarter 1985 and for January 1986 identified no exposures in excess of NRC limits. Without further specific information, the alleger's dose estimate could not be specifically r* .wed. However, the lack of an excessive exposure from TLD res .s for the period in question eliminates the pessibility of an everexposure to the alleger.

Portions of this allegation could not be substantiated due to a lack of specific information. However, a problem concerning dosimeter drifting was confirmed; adequate corrective actions had been taken by licensee personnel.

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Allegation: My NGET card from Zion Station requires me to use a respirator with a small facepiece. Dresden had no small facepiece masks. I was retested at Dresden and they said it was okay to wear-the medium size. I do not believe I get a good facepiece fit.

Discussion: The inspector reviewed the licensee's respirator fit test procedures; no problems with the licensee's fit testing methods were identified. According to licensee personnel, on at least one recent occasion a supplied air hood was provided to an individual who could not be fitted with available facepieces. No violations of NRC requirements were identified.

Although the allegation could not be substantiated due to the lack of specific information, review of the licensee's respirator fit test program did not identify any significant problems.

Allegation: Newer employees of a named contractor are being put to work without adequate mock-up training.

Discussion: The newer employees alluded to were apparently technical employees who were involved with. limited tasks. These employees did not participate in mock-up training because there was no intent for them to do hands-on work. These employees did receive all NGET and supplemental ALARA training.

The allegation was not substantiated because the work performed by the referenced employees did not require mock-up training.

c. On March 5, 1986, NRC Region III received a memorandum from NRC Region IV. The memorandum informed Region III that the Kansas-Department of Health and Environment's Bureau of Air Quality and Radiation Control had interviewed an individual who claimed to be suffering from a radiation induced illness. The interview was requested by the Kansas Highway Patrol who had received a call from a local hospital.

The individual had gone to the emergency room at the hospital with respiratory symptoms which he feared were a result of radiation exposure and contamination which he received while working at Dresden Station the previous week.

On March 11, 1986, an NRC Region III representative telephoned the alleger to obtain additional information. The alleger stated that he worked for a contractor at Dresden Station for several days.

After receiving training at Dresden, his foreman (name not recalled) took him on a plant familiarization tour of Units 2 and 3. The allegations concern the period of the plant tour; they are presented and discussed below. The alleger requested anonymity.

Allegation: Everywhere we went during the tour there were people in anti-contamination clothing; some also had on respirators; we were in street clothes.

12

Discussion: During review of the allegations, the foreman who conducted the tour was identified. The foreman recalled that he toured four recently hired contractors in the referenced timeframe, and that no radioactively contaminated areas were entered during the tour.

Several clothing change areas are in uncontaminated areas. People change from street clothing into clean anti-contamination equipment at these change areas before entering contaminated areas. The anti-contamination equipment is removed before reentering an uncontaminated area. The alleger may have misinterpreted what he saw, thinking he was within an area requiring protective equipment use. .The foreman stated that he did not recall being asked, by any of the electricians being toured, why workers were wearing protective clothing.

The allegation review did not identify any problems.

Allegation: When I went through the whole body frisker, my left hand alarmed the frisker twice. (The alleger initially stated, to State of Kansas personnel, that he had been instructed by the foreman to wipe his hand on his trousers. In the March 11, 1986 telephone conversation with NRC:RIII personnel, he stated that he could not recall either wiping his hand on his trousers or being instructed by the forement to wipe his hand on this trousers.)

Discussion: The foreman who conducted the tour for the four recently hired contractors recalled that one of the contractors did not properly insert one arm in the whole body frisker; he received an alarm due to the improper usage and an instructional display message to recount (start again). The foreman said the individual received the same alarm a second time. The foreman stated that he then instructed the contractors how to properly activate counting cycles on the whole body frisker, and the individual did not alarm the whole body frisker on his third attempt. The foreman indicated that he did not recall instructing the individual to wipe his hand on this trousers.

None of the four contractors on tour were whole body counted on the last day the alleger was at Dresden Station. According to the licensee, short term employees who have not entered contaminated areas are not whole body counted. However, when exiting the station, all personnel pass through a portal monitor at the guard house; there is no record or other indication that any of the toured contractors or the foreman were found to be contaminated on the referenced tour date.

A review of exposure records for the named contractor indicated that none of the contractor workers had exceeded the allowable administrative dose limits on the referenced tour date.

The allegation review did not identify any problems.

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f Allegation: Although not mentioned by the alleger in the March 11, 1986 telecon, a positive urinalysis result for cesium-137 was reported by the State of Kansas for a urine sample collected by the State while the alleger was in the hospital.

Discussion: The presence of cesium-137 in the alleger's urine is not compatible with the alleger's known activities of the Dresden plant.

Discussions by Region III personnel with personnel from the State of Kansas laboratory which performed the urinalysis revealed an error had been made in the uncertainty associated with the reported cesium-137 concentration in the urine. The corrected uncertainty at the 2-sigma confidence level exceeds the net counts and therefore the cesium-137 is not considered to be present.

The allegation was not substantiated.

14. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on March 9, 1986. The inspector summarized the scope and findings of the inspection. .The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietary. In response to certain items discussed by the inspector, the licensee:

a. Stated that improvements would be made in outside housekeeping and radioactive materials storage areas. (Section 6)

b. Acknowledged the violation. (Section 9)

c. Acknowledged the unresolved items concerning the radioactive materials shipment to Brunswick Station. (Section 10)

d. Acknowledged the inspector's comments about the timely and thorough investigation and evaluation of a radiological incident in Unit 3.

(Section 11) 14

JUL 281986 Docket No. 50-237 Docket No. 50-249 Docket No. 30-18425 Commonwealth Edison Company ATTN: Mr. Cordell Reed Vice President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the routine safety inspection conducted by Messrs. D. E. Miller and W. J. Slawinski of this office during the period June 30 through July 10, 1986, of activities at Dresden Nuclear Power Station, Units 2 and 3, authorized by NRC Operating Licenses No. DPR-19 and No. DPR-25, and materials under Byproduct Materials License No. 12-05650-19 at the Mazon Emergency Offsite Facility, and to the discussion of our findings with Mr. Kalivianakis and other members of your staff at the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

During this inspection, certain of your activities appeared to be in violation of NRC requirements. We are releasing this report at this time for your information. You will be notified by separate correspondence of our decision regarding enforcement action based on the findings of this inspection. No written response is required until you are notified of the proposed enforcement action.

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, and the enclosures will be placed in the NRC Public Document Room.

ii6G8GL&h32 2pp f

Commonwealth Edison Company 2 Mb 28 hid6 We will gladly discuss any questions you have concerning this inspection.

Sincerely, wth.T,Tn=T sTrea3 Er W.D. Shafer" W. D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch

Enclosure:

Inspection Report No. 50-237/86016(DRSS);

No. 50-249/86019(DRSS) cc w/ enclosure:

D. L. Farrar, Director of Nuclear Licensing D. J. Scott, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Phyllis Dunton, Attorney General's Office, Environmental Control Division 5

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U.S. NUCLEAR REGULATORY COM ISSION REGION III Report Nos. 50-237/86016(DRSS); 50-249/86019(DRSS); 30-18425/86001(DRSS)

Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25; 12-05650-19 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, Illinois 60690 Facility Name: Dresden Nuclear Power Station, Units 2 and 3 Inspection At: Dresden Site, Morris, Illinois Mazon E0F, Mazon, Illinois Inspection Conducted: June 30 and July 1-3, 9 and 10, 1986 Inspectors: D. E. M ler

'f 7 t h0 Datt w .M W.Jblawinski 7

• N6 Date pJPSA3 Approved By: L. R. Gre r, hief 7/N79[ 4 Facilities Radiation Date Protection Section Inspection Summary Inspection on June 30 through July 10, 1986 (Report Nos. 50-237/86016(DRSS);

50-249/86019(DR55))

Areas Inspected: Routine, unannounced inspection of the radwaste management program and selected portions of the radiation protection program. Also reviewed were past open items, a radioactive material shipment incident, and Byproduct Materials License No. 12-05650-19 for sources at the Mazon EOF.

Results: One violation was identified (inadequate packaging of a radioactive material shipment - Section 12).

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DETAILS l

1. Persons Contacted i

• D. Adam, Compliance Coordinator '

• J. Brunner, Assistant Superintendent, Technical Services

• E. O' Conner, Assistant to Rad / Chem Supervisor

• R. Flessner, Superintendent, Services

• K. Hostert, Lead Rad / Chem Foreman

• R. Jeisy, Station QA Supervisor

• N. Kalivianakis, Nuclear Division Vice President

• C. Lincoln, Radwaste Foreman (solid)

R. Meadows, Master Mechanic

• F. Rescek, Lead Health Physicist, Nuclear Services

• D. Sharper, Waste Systems Engineer

• D. Soccomando, Lead Health Physicist

• J. Wujciga, Superintendent, Production The inspector also contacted several other licensee and contractor personnel.

• Denotes those present at the exit meeting.

2. General This inspection, which began at 7:30 a.m. on June 30, 1986, was conducted to examine the licensee's radiation protection and radwaste management programs. Also reviewed were past open items, a radioactive materials shipment incident, and the byproduct materials license for radioactive sources at the Mazon E0F. Several tours of access control and work areas were made to observe and evaluate operational radiological controls and radwaste handling.

3. Licensee Actions on Previous Inspection Findings (0 pen) U, resolved Item (237/86008-03; 249/86010-03): Interpretation

of 49 CFR 173.441(b), and acceptable methods of measuring " surface" radiation levels of ra 6 active materials packages offered for transport.

Interpretation portion of this unresolved item resulted in the violation of 49 CFR 173.441 presented in this report; details are discussed in Section 12. Acceptable methods of measuring " surface" radiation levels have not yet been resolved; however, a memorandum requesting clarification was sent to the Safeguards and Materials Programs Branch, IE, on June 19, 1986.

(0 pen) Open Item (237/85026-01; 249/85021-01): Disposition of contaminated soil. The licensee is preparing a submittal to NRR regarding this matter. l l

(0 pen) Open Item (237/86008-01; 249/86010-01): Cleanup program for  !

outdoor areas. The licensee has begun a major long-term cleanup project.

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4. Training and Qualification The inspectors reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted radiation protection personnel; and provision of appropriate radiation protection, radwaste, and transportation training for station personnel. Also reviewed was management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section 11.

An inspector attended the licensee's nuclear general employee training (N-GET). The N-GET consists of videotape, slide, and oral presentations, which are augmented by a question and answer session between each segment.

The subjects of major training segments are Security, Radiation Protection, and Respiratory Protection. An examination is given at the end of each segment; a passing grade (70 percent or greater) is required for each segment. If Segment 1 (Security) is failed, the trainee is excused from the class and must start again the following week. If Segments 2 or 3 are failed, the trainee must return the following week to attend the segments failed and be retested. A handbook titled, " Nuclear General Employee Training N-GET," is provided to each trainee for future reference.

Respiratory protective device fit testing is available for those whose job requires them to maintain respiratory protection qualifications.

This training appears to meet the requirements of 10 CFR 19.12,

" Instructions to Workers."

The inspectors reviewed the Rad / Chem Technician (RCT) retraining program.

In early 1985, the licensee formed a Continuing Training Committee to establish and implement a continuing training program for RCTs. The committee consists of two health physicists, two RCTs, an RCT foreman, a training coordinator, and two trainers. The committee determines what training will be provided to RCTs during each calendar quarter. RCT input concerning training needs is solicited. RCT duty scheduling was altered to permit one week of retraining for each RCT each calendar quarter. This training schedule began in early 1986. After completion of training in each subject area each training day, written testing is performed, or the student demonstrates task performance as applicable.

The licensee uses participant evaluation forms (optional) to solicit trainee comments about training provided or desired. No problems were noted.

Training in radwaste packaging and shipping was provided to one health physics, three waste systems, and three quality control personnel during July 1985. This training, performed at the Production Training Center, included the subjects required by IE Bulletin 79-19. Also, radwaste packaging and shipping topics are included in the RCT continuing training program. No problems were noted.

No violations or deviations were identified.

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. 5. External Exposure Control and Personal Dosimetry The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities,.

equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management technicues used to implement these programs and experience concerning self-icentification and correction of program implementation weaknesses.

Audits are discussed in Section 11.

The external exposure measurement and control program consists of whole body monitoring using thermoluminescent dosimeters (TLDs), extremity monitoring using film ring badges, self-reading dosimeters (SRDs), direct radiation surveys, radiation work permits, administrative dose limits, and a radiation dose recording system.

The inspectors selectively reviewed Forms NRC-4 and licensee administrative dose limit extensions for persons who exceeded 1250 millirem per calendar quarter during the first calendar quarter of 1986. No problems were noted.

The inspectors selectively reviewed direct radiation survey records, radiation work permits, ALARA review records, and dosimetry reports for work being performed during the inspection. No problems were noted.

No violations or deviations were identified.

6. Solid Radioactive Waste The inspectors reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesses. Audits and training are discussed in other sections of this report.

rogram remains essentially as The licensee's described solid radwaste in Inspection Reportsmanagement No. 50-237 p/85026(DRSS); 50-249/85021(DRSS).

In addition, the licensee occasionally employs a vendor supplied super compactor to further compact DAW filled drums and empty contaminated drums; the resulting " pucks" are placed in new drums for shipment and burial.

Large quantities of DAW and contaminated oil are stored onsite awaiting arrival and operation of~the licensee's mobile incineration system. The stored materials have accumulated over several years; most of the DAW was generated during major outage projects, and the Unit 1 decontamination, when radwaste. packaging systems could not keep pace with waste generation.

4

F As described in past reports, the vendor solidification equipment is located outdoors; resins and sludges are fed to the equipment through soft piping. The licensee plans to alter the station s installed radwaste solidification facility to accommodate indoor use of the vendor solidification equipment. The alteration will include upgrading the installed crane to handle increased loads, and installation of additional shielding arrangements so that several liners can be loaded, prepared, and stored awaiting shipment. .The licensee plans to complete the alterations before winter.

No violations or deviations were identified.

~7. Liquids and Liquid Radioactive Wastes The inspectors reviewed the licensee's reactor liquids and liquid radwaste management programs, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesses. Quality assurance audits are discussed in Section 11.

The inspectors selectively reviewed records of batch liquid radwaste releases made during 1986 to date. It appears that the technical specification requirements for sampling, analysis, and release concentrations have been complied with. Calibration of the liquid radwaste monitor is discussed in Inspection Reports No. 50-237/86008(DRSS);

50-249/86010(DRSS). No problems were noted.

The licensee has considered the originally installed service water monitors inoperable since the revised radiological environmental technical specifications became effective in March 1985. The monitors are considered inoperable because they lack adequate detection sensitivity. In accordance with the technical specification's action statement, the licensee collects service water grab samples every

~

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzes the samples for radioactive materials content.

The licensee purchased replacement monitors for the service water systems but found that the background radiation levels at their intended location were too high to permit adequate functioning of the monitors. The licensee has since ordered additional monitoring equipment intended to provide background subtract circuit signals for the new service water monitors.

No violations or deviations were identified.

8. Gaseous Radioactive Waste The inspectors reviewed the licensee's gaseous radwaste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; determination whether 5

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. gaseous radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether process and effluent monitors are maintained, calibrated, and operated as required; and experience concerning identification and correction of programmatic weaknesses. Audits are discussed in Section 11.

The licensee's gaseous effluent monitoring and sampling systems remain as described in Inspection Reports No. 50-237/85022(DRSS); 50-249/85018(DRSS).

The licensee is required by technical specification to perform functional

. tests, source checks, and calibrations of the effluent and certain process monitors at set frequencies. A selected review of records concerning these requirements for the period 1985 and 1986 to date was performed; it appears that they were accomplished as required.

Records of particulate, iodine, and noble gaseous radioisotope sampling, analyses, and quantification were selectively reviewed for 1986 to date.

No problems were noted.

No violations or deviations were identified.

9. Transportation of Radioactive Materials The inspectors reviewed the licensee's transportation of radioactive materials program, including: determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were a_ny transportation incidents

. involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses. Quality assurance and training are discussed in other sections of this report.

Transportation activities remain as described in Inspection Reports No. 50-237/85026(DRSS); 50-249/85021(DR$5). A transportation incident is discussed in Section 12 of this report.

Records of radioactive shipments made during 1986 were selectively reviewed for compliance with 49 CFR 173, 10 CFR 61, and 10 CFR 71.

No problems were identified. ,

No violations or deviations were identified.

10. Maintaining Occupational' Exposures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; Establishment of goals and objectives, and effectiveness in meeting them.

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O Also reviewed was management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.

The ALARA program remains as described in previous inspection reports.

Procedural and records maintenance refinements have aided in task related information recording and retrieval. Also, procedure DAP 12-9, "ALARA Action Review," has been revised to provide assurance that post-job reviews are performed, audited for completeness, and that recommendations and lessons learned are made available for consideration during future ALARA reviews for similar work.

The station ALARA goal for 1985, not including the Unit 3 RPR project, was 1490 person-rem; actual dose received was 1036 person-rem. The goal for 1986, not including RPR, is 1056 person-rem; 635 person-rem was received by July 1,1986. The projected ALARA goal for the 1985-6 Unit 3 RPR project was 1990 person-rem; the licensee stated that the goal will not be exceeded.

No violations or deviations were identified.

11. Audits The inspectors reviewed onsite and offsite audits of the radiation protection and radwaste management programs conducted from July 1, 1985 to date. Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewed.

Two annual station audits, and a special station audit, of radiation protection surveys and records were conducted. Two findings, six observations, and one open item resulted from the audits. Most of the findings and observations concerned records completion, timeliness, or storage requirements; all findings, observations, and the open item have since been closed except for an observation concerning a high radiation area key log (the response is due July 21,1986). In addition, 33 station QA surveillances of work activities and drills were performed; several minor radiation protection problems were identified and corrected.

One annual station audit of activities and documentation associated with radwaste was performed; included was adequacy of training provided to certain personnel assigned to radwaste packaging and shipping duties.

There was one audit open item concerning training records; this item has since been closed. In addition, a surveillance check of each radwaste shipment was made by QA representatives; no significant problems were identified during the QA surveillances.

A semi-annual offsite Quality Assurance audit of station activities was conducted on April 22-25, 1986. Included were selected radiation protection and radwaste topics. One finding concerning compliance with a specific ODCM requirement for allocating gaseous effluent discharges to a specific unit, and one observation concerning personnel frisking, resulted from the audit; the licensc9's response to the finding and ob,servation is yet to be reviewed by the audit team.

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, The extent of audits, qualifications of auditors, and adequacy of corrective actions appear good.

No violations or deviations were identified.

12. Radioactive Material Shipment Incident An incident concerning a Type A quantity (17 millicuries of Co-60) radioactive shipment sent from Dresden Station on April 29,'1986, is described in Section 10 of Inspection Reports No. 50-10/86005(DRSS);

50-237/86008(DRSS); 50-249/86010(DRSS). The licensee immediately notified the onsite NRC Senior Resident of the incident. In brief, portions of the contents of a package, transported on a sole-use flatbed trailer, shifted; during transport; some radiation readings increased at two inches from the package surface. They read 230 mR/hr at two localized spots when received at Brunswick Station on April 30, 1986. These increased radiation levels appeared contrary to 49 CFR 173.441(b)(2) because the apparent limit at the package " surface" is 200 mR/hr. However, this matter was considere<i unresolved pending disposition of a then pendir.g contested violation in NRC Region II, and further clarification by the NRC Office of Inspection and Enforcement (IE). The NRC Region III office has since been in~ formed by IE that 49 CFR 173.441(b)(2) limits the surface radiation level to 200 mR/hr on packages when the packages are transported on a sole-use flatbed trailer. The radioactive materials shipment, made from Dresden Station on April 29, 1986, to Brunswick Station is therefore considered in violation of 49 CFR 173.441(b)(2).

One violation was identified (237/86016-01; 249/86019-01).

13. Byproduct Materials License No. 12-05650-19 This license authorizes use of radioactive sources at CECO's Mazon Emergency Offsite Facility. A nominal 21 curie cesium-137 sealed source is used for TLD irradiation and calibrations. The licensee intends to eventually move the source to LaSalle County Station, and include it in the station's operating license. The primary source users are employees of LaSalle County Station.

The inspectors reviewed the licensee's compliance with the conditions of their byproduct materials license (Mazon site) and found that:

• Sources on hand are as permitted by the license.

• The facility, source interlocks, and materials security is as described in referenced applications and letters.

• Users are adequately trained.

• Inventory and leak testing is performed as required.

• Survey instruments are being adequately calibrated at the required frequency. ,

• Area surveys are being performed as required.

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• Postings are adequate and appropriate.

• Interlock functions were observed to properly operate.

• Adequate dosimetry is provided to users.

14. Contamination Reclamation Program The licensee has undertaken a major decontamination and reclamation program. The program involves eventual cleanup and/or decontamination of most plant areas, and painting or repainting to restore the facility's appearance. The licensee stated that this a long-term project.

According to the licensee, there are 41 active radiation work permits for the program. Nearly seven thousand person-hours have been worked on the project to date. In addition, over seven thousand person-hours have been worked during 1986 in the tool and equipment decontamination room.

Because of the RPR project and existence of large quantities of tools and equipment from past outages, tool and equipment decontamination is a majorproject.

Progress of the reclamation program will be reviewed during future inspections (237/85041-02; 249/85035-02).

No violations or deviations were identified.

15. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on July 10, 1986. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee identified no such documents / processes as proprietary. In. response to certain items discussed by the inspector, the licensee:

a. Stated that the improvements being made in outside housekeeping and radioactive materials storage areas would continue (Section 3).

b. Stated that plans are being made to relocate the vendor radwaste solidification equipment indoors before winter (Section 6).

c. Acknowledged the violation (Section 12).

d. Stated that the contamination reclamation program would continue (Section 14).

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