IR 05000010/1997015

Insp Repts 50-010/97-15,50-237/97-15 & 50-249/97-15 on 970722-0828.No Violations Noted.Major Areas Inspected: Solid Radioactive Waste Processing,Transportation & Portable & Area Radiation Monitor Test

ML20217A132
Person / Time
Site:	Dresden
Issue date:	09/15/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217A128	List: IR 05000010/1997015 ML20217A124
References
50-010-97-15, 50-10-97-15, 50-237-97-15, 50-249-97-15, NUDOCS 9709190081
Download: ML20217A132 (10)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50 10, 50 237,50 249 License Nos: DPR 2, DPR 19, DPR 25 Report Nos: 5010/97015(DRS), 50 237/97015(DRS),

50 249/97015(DRS)

Licensee: Comed Facility: Dresden Nuclear Station, Units 1,2 and 3 l

Location: 6500 N. Dresden Road Morris, IL 60450 Dates: July 22 - August 28,1997 Inspectors: R. Paul, Senior Radiation Specialist W. Slawinski, Senior Radiation Specialist

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Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9709190001 97091S PDR Q ADOCK 05000010 I PDR '

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EXECUTIVE SUMMARY Dresden Generating Station, Units 1,2 & 3 NRC Inspection Reports 50 10/97015, 50-237/97016, 50 249/97015 This inspection included a review of the solid radioactive waste (radwaste) processing, transportation, and portable and area radiation monitor test and calibration program *

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The transportation program was technically sound, and the April 1,1997, revision to the NRC and Department of Transportatloa (DOT) regulations were implemented

and incorporated into station procedures. Training was completed for personnel involved in shipping radioactive material, and radioactive material shipments reviewed by the inspectors were appropriately classified and documented. Scaling factors were determined and used in accordance with NRC guidance (Section

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R 1.2).

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The material condition of the radwaste systems and the radwaste storage areas was good. Surveillances and inventories of stored materials were performed as required. Significant radwaste has been shipped during the past year reducing backlo *

With the exception of some discrepancies noted with the calibration and test results of some beta gamma portable monitoring equipment, the overall calibration and test program for the Area Radiation Monitors (ARMS) and portable alpha monitoring, for the whole body frisker, for the whole body counter and for the tool monitoring equipment was wellimplemented (Section R2.2).

Appropriate radiological controls were developed for the Unit 1 underground tank sludge removal project and were implemented for Unit 1 SAFSTOR decommissioning wor I I

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Reoort Details '

IV. PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls R1.2 Solid Radioactive Waste and Transportation Programs 1 Insoection Scoce (IP 86750. Tl 2515/133)

The inspectors reviewed the licensee's solid radwaste and transportation program This included a review to ensure that the changes to 49 CFR Parts 100179 and 10 CFR Parts 71, effective April 1,1997, were incorporated into the transportation program. The aspects of the transportation program reviewed included training of personnel, procedures governing the transportation of radloactive material and records of past shipments of radioactive material. The inspectors reviewed the licensees program for determining scaling factors for the waste streams, as well as the vendor process used at the statloa. Also reviewed were the documentation for radwaste shipment nos. D 97 089 (dry active waste), D-97 216 (metal oxides) and 0692 7360 (dry active waste including metals and dewatered filters).

Specific documents reviewed include:

DRP 5600-03 (rev 00) " Determination of Waste Classification and Reportable Quantity,"

• DRP 5600 04 (rev 2) " Completion of the Radioactive Material Shipping Record DRP 5610-02 (rev 00) " Calculation of Curie Content of Radioactive Shipments,"

• Dresden Unit 1 Radwaste Facility Wet Waste Processing Project No. 21.1,

• DOP 2000-44 (rev 1) " Radioactive Waste Shipping," and

DRP 5600133 (rev 00) " Trending for Shifts in Scaling Factors and Waste Stream Samples." Observations and Findinas The inspectors verified that the licensee maintained current copies of NRC, DOT and applicable buriel site regulations. Review of training records determined that personnel authorized to approve or otherwise involved in shipments had completed the appropriate training. Interviews were conducted with licensee persunnel responsible for the transfer, packaging and transport of radioactive material which determined that they were knowledgeable of the revised transportation regulation Transportation procedures incorporated the revised regulations and included guidance on how to determine the proper shipping name in accordance with the

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I reguistions and on how to classify low Specific Activity (LSA) material and Surface Contaminated Object (SCO) shipments. The licensee also incorporated the System International (Sil units into the pro 0 ram prior to April 1,1997, as require The licensee used a vendor computer program (i.e. Radman) to generate shipping and A, values for severalisotopes, including cobalt 60, cesium and americium 241. The inspectors also verified through independent calculations that the radwaste activity limits for waste classification of shipment No. D 97 216 had been appropriately characterized as class A unstable waste. The inspectors observed that the licensee prepared shipping papers consistent with the regulations and that the shipments were appropriately tracked and logge The inspectors compared the solid radwaste system to the description in the updated Final Safety Analysis Report (FSAR) and found that it was consistent with the FSAR. The licensee identified and documented the stations solid radioac waste streams as including dry active waste, filter cartridges, primary resins, radweste domineralizer resins, decontamination resins, and evaporator concentrates. Scaling factors for 10 CFR part 61 waste characterization analyses

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were generated as described in procedure No. DRP 5600. The RP staff determined scaling f actors in accordance with the guidance contained in the NRC Branch

! Technical Position on waste classification and waste form. The scaling factors used agreed with past results.

l Conclusions l The licensee's solid radwaste and transportation programs were technically sound.

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The April 1,1997 revisions to the transportation regulations were incorporated into the procedures and appropriately implemented. Radioactive material shipments reviewed by the inspectors were appropiiately classified and documented, and training was completed for personnel involved in shipping radioactive materia R2 Status Of RP&C Facilities and Equipment R2.1 Solid Radwaste Facilities Insoection Scone UP 86750)

The inspectors cbserved the condition of the solid radwaste processing and radioactive materials storage areas including the Unit 2/3 radwaste control room, Unit 1 radwaste material storage areas, ser. vans used for storage and shipping, and the vendor processing system. The inspectors also evaluated the radwaste surveillance and inventory programs for stored radwastes, Observationis and Findinas_

The material condition of the systems and storage areas was good. All areas were posted and controlled in accordance with licensee procedures, and good radiological

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housekeeping was observed. Considerable improvement has been made in refurbishing the Unit 2/3 radwsota facility during the past yea The inspectors reviewed the licensees inventory and surveillance program for stored material which included dry active waste, spent resin in high integrity containers (HICs), contaminated equipment, and other waste. The inventory of all stored waste was found to be completed in compliance with station procedures. The inspectors verified that valid licenses and certificates of compliance were used for shipping casks and HICs. The disposal of accrued wastes from Units 2 and 3 has continued, and in 1997 to date, there were 110 shipments of solid radwaste to

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either a burial site or waste processor. Aside from the few designated areas for waste storage, there were no temporary satellite areas for storage of radwaste on-sit Radwaste removal from Unit 1 in 1996 consisted of about 200 shipments of radwaste material (10 million pounds) which included about 207,000 pounds from

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the desludging of the T 114 tank demolition project. In addition, there was about 40,000 cubic feet of loose asbestos shipped and 100,000 cubic feet of contaminated soll. The efforts to remove Unit 1 generated contaminated material from the site continued during 199 Conclusions The material condition of the radwaste systems and the radwaste storage areas was good. Surveillances and inventories of stored materials were performed as required. The licensee continue to make progress toward decreasing the amount of stored wastes on sit R2.2 Radiation Monitorina Eauloment and Facilities a. Inspection Scone (IP 83750)

The inspectors reviewed the operation and calibration methodology for the portable beta gamma monitoring equipment and area radiation monitors (ARMS). The inspection included a walk down of some of the ARMS, the calibration f acility and equipment; observation of radioactive source condition and monitor alarm set points, and review of procedures, detector operability history, and calibration and test results, b. Observations and Findinas Calibration and instrument tests were performed as required, and equipment was as described in the FSAR. The portable monitoring / survey equipment consisted mainly of gelger mueller and ion chamber detectors. Alarms for the ARMS were found to be set at prescribed levels, and operability tests were peiformed as require Calibration and test methodology was technically sound for all monitoring equipment reviewed during the inspection, arid beta-gamma standards appeared to be in good physical condition. Calibration procedures for all portable hand held

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instruments continued to be upgraded; however, the inspectors identified a weakness in the procedures concerning tolerance limits for "as found" and "as lef t" limits for portable detection instruments. Specifically, the radiation protection ,

group did not document if instruments approached tolerance limits, as a mechanism

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to track degraded performance over time. The problem, however, was corrected by the licensee during the inspection through the establishment of a tracking system, c. Conclusions The overall calibration and maintenance program for those monitors reviewed was wellimplemented, and the monitors were noted to have good operability histor With the exception of the Inspector identified calibration procedural weakness, the procedures were sufficient to accomplish a sound calibration and test progra R2.3 Unit 1 Radiation Protection Proaram Activities (SAFSTOR)

a. Inspection Scope HP 83760 and IP 86750]

The inspectors reviewed the Unit 1 radwaste decommissioning project related to the removal and packaging of all residual wet waste contained within the tanks and vault of the Unit 1 radwaste and decant facilities. Also reviewed was the status of the Unit 1 decommissioning activities. The inspectors walked down the facilities and equipment used for the cleanup project, reviewed relevant procedures and discussed plans and contingencies with cognizant personnel. The inspectors also toured various areas of the Unit 1 facility including the sphere, fuel building and radioactive waste storage area Observations and Findinas The purpose of phase 2 of the decommissioning project is to accomplish a cleanup of the residual waste In various Unit 1 underground radwaste tanks, vaults and sumps. After the sludge and debris removal, the next phase of the project is to remove and dispose of the tanks. The inspectore determined that good radiological controls (including precautions taken for transurananic radioactivity) were implemented, procedures were written and appeared comprehensive, contingencies were in place for various accident scenarios, a 10 CFR Part 50.59 review was performed, and an evaluation was perform 9d to calculate dose rates both inside and outsido equipment structure Unit 1 decommissioning activities continued with focus on dry cask storage planning. System, structure and component maintenance and cleanup was performed, and the sphere asbestos and material abatement projects continue Licensee personnel dose for Unit 1 activities was about 11 person rem for 1997 to date. The inspectors noted that general housekeeping was good and radiological controls and postings were in plac . _ - _

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c. Conclusions Unit 1 decommissioning activities continue to progress. Spent fuel pool cleanup and containment asbestos abatement projects were completed with good radiological control l R3 Miscellaneous RP&C lasues (Closed) Violation 50 237/9501101: 60 249/9501101 EA #95 214 (01013)):

Failure to maintain the radiation levels on a package delivered to a carrier for transportation within Department of Transportation (DOT) required limits. To improve oversight of radioactive material package transportation, the station j

procedure governing radioactive material shipments was revised to require that a !

qualified member of the health physics staff be present and independently verify

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that each package loaded onto the transport vehicle satisfies applicable DOT !

l requirements, implementation of this revised procedure was verified through i

inspector review of shipment manifests, package inspection checklists and l

discussions with involved radiation protection staff. Additionally, the training of I

contractor personnel that perform radioactive material shipments was expanded to coincide with that provided to station personnel, along with improvements in training documentation. This item is close (Closed) Violation 50 237/97010-01: 50 249/97010 01: Failure to provide workers an exit from a locked high radiation area. The lock on the door hasp was removed and the core from the lock was installed in the door, allowing unobstructed egress from the area. The procedure for locked high radiation area access was revised to require establishment of a mechanism to track and log individual entry and egress from locked high radiation areas and to require a physical search prior to securing the area. This item is close (Closed) IFl 50 237/97010-04: 50 249/97010-04: Adequate implementation of the

" greeter" program. Additional instruction was provided to station personnel involved in the greeter program to include guidance on high radiation area controls and housekeeping responsibilities. Prior to this instruction, greeters did not routinely challenge workers entering the radiologically protected area (RPA) about high radiation area responsibilities and housekeeping. An inspector interviewed greeters and other radiation protection staff regarding greeter program implementation and observed greaters stationed at main access control points for both Units-1 and 2/3 Workers entering the RPA were appropriately quizzed by the greeters. This item is close (Closed) URI 5033]L95002 04: 50-249/95002 04: A chair, contaminated with cesium 137, was identified in the chemistry office outside the RPA. The licensee's evaluation of this incident was unable to determine its cause or if the contamination was intentional. Nevertheless, the evaluation identified problems with the personnel monitoring equipment at the egress to the chemistry laboratory and with chemistry laboratory and office security. To address these problems, the station improved chemistry laboratory key control and the security and tracking of

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radioactive sources used and prepared in the laboratory. Enhanced monitoring equipment was also installed at the egress to the chemistry laboratory. An inspector's tour of the chemistry laboratory revealed no problems with the availability and use of personnel contamination monitoring equipment or with laboratory and radioactive source security. This item is close (Closed) ViolatiorditQ:237/96004 08: 50 249/96004 08: Failure to evaluate the

radiological conditions in the Unit 2 drywell basement during cleaning activitie The radiation protection technician (RPT) involved in the incident and responsible

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for job coverage was restricted from work on high risk jobs until completion of i

additional training. Special training was also developed and provided to RPTs concerning pre job briefing and survey requirements for high risk job coverag i Oversight of RPT field job coverage was also expanded to allow for increased '

radiation protection supervisor presence during selected high risk jobs. This item is j close I j V. Manegement Meetings

X1 Exit Meetina Summarv On August 28,1997, the inspectors presented the inspection results to licensee management. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - - - _____ _ __ _ ___ _-__

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PARTIAL LIST OF PERSONS CONTACTED l Comed L. Aldrich, Assistant RPM M. Friedmann, Lead Health Physicist J. Hill, Lead Radiation Protection Supervisor  !

C. Howland, Radiation Protection Manager i L. Jordan, Traln!ng Department T. Nauman, Unit 1 Plant Manager J. Perry, Site Vice President F. Spangenburg, Regulatory Assurance Manager >

1 INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 86750 Solid Radwaste and Transportation a

ITEMS OPENED, CLOSED, AND DISCUSSED Closed i 50 237/249 95011 01 VIO Failure to maintain the radiation EA #95 214 (01013) levels on a package delivered to a carrier for transportation within DOT requirement /249 97010-01 VIO Failure to provide workers on exit from a locked

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high radiation are /249 97010-04 IH Adequate implementation of the " greeter program".

50 237/249 95002 04 URI A contaminated chair was found outside the RP /249 96004-08 VIO Failure to evaluate the radiological conditions in the Unit 2 drywell basement during cleaning activities.

Discussed Non ,

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PARTIAL LIST OF DOCUMENTS REVIEWED i

DIS 1800 05 Unit 2 Area Radiation Monitor Station 1 Calibration Data Shee DlS 1800 06 Unit 3 Area Radiation Monitor Station 30 Data Shee Dresden Station FSAR, Sections 11 and 1 Dresden Station Unit 1 Decommissioning Report '

Dresden Memo, Define the Types and Quantity of Portable Instrumentation dated November 25,199 I l

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