IR 05000010/1998016

Insp Rept 50-010/98-16 on 980723-0918.No Violations Noted. Major Areas Inspected:Aspects of Licensee Mgt & Control, Sf Safety & Radiological Safety.Followup Insp Performed on Previously Identified Issue

ML20154F644
Person / Time
Site:	Dresden
Issue date:	10/06/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154F634	List: IR 05000010/1998016 ML20154F629
References
50-010-98-16, 50-10-98-16, NUDOCS 9810090299
Download: ML20154F644 (9)

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U.S. NUCLEAR REGULATORY COMMISSION  !

REGIONlli l i

Docket No: 50-010 License No: DPR-2

- Report No: 50-010/98016(DNMS)

Licensee: Commonwealth Edison Company l Facility: Dresden Station Unit 1

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Location: 6500 N. Dresden Road Morris, IL 60450' l Dates: July 23,1998 - September 18,1998 l

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Inspectors: William G. Snell, Health Physics Manager Ross B. Landsman, Ph.D., Project Engineer )

Approved By: Bruce L. Jorgensen, Chie a f4%

Decommissioning Branch

Division of Nuclear Materials Safety l- I L

9810090299 981006'.~

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EXECUTIVE SUMMARY I Dresden Station Unit 1 NRC Inspe: tion Report 50-10/98016(DNMS)

This routine decommissioning inspection covered aspects of licensee management and

control, spent fuel safety, and radiological safety. Followup inspection was alto f.srfomied on a previously identified issu Facility Manaoement and Control i e Score cards used by the licensee to assess work activities as a pro-active initiative for improving work force performance appeared to be having a positive impac (Section 1.1). )

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e Work was observed to be carried out in an orderly and well thought out manner with i adequate attention given to good work practices and worker safety. Good i

housekeeping practices were observed in the Turbine Building, the Spent Fuel Building, a.id within the Sphere. (Section 1.2) l l

Spfint Fuel Safety e The systems that monitor the Spent Fuel Pool were adequate to detect any change in fuel pool level that would challenge fuel integrity. (Section 11.1)

Radiolooical Safety e Workers were knowledgeable of their work area dose rates and were employing good l As-Low-As-Reasonably-Achievable work practices, which was being reflected in the low l doses received for various work activities. (Section Ill.1)

l e The licensee continued to make progress in the removal of radioactive waste from the radwaste vaults and tanks. Radiological controls associated with activities appeared to j be adequate. There was no evidence of radiological contamination of the river l

, sediment downstream of the Dresden Station. (Section Ill.2)

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M Report Details Summary of Plant Activities The licensee completed their characterization of spent Unit 1 fuel in the Units 2 and 3 Spent Fuel Pools (SFPs) while characterization of the fuelin the Unit 1 SFP was scheduled to begin in late September 1998. Waste removal activities for Radwaste Vaults 2 and 3 were temporarily suspended pending the issuance of a new vendor contract. Removal of material

from the Unit 1 Sphere continued, and the asbestos abatement for Unit 1 was completed, l. Facility Manaaement and Control Self-Assessment. Auditina and Corrective Actions 1 Scope (40801)

An assessment was made of a series of score cards developed by the licensee as an informal means of self-assessment and improvemen Observations and Findinos

The licensee had developed and initiated use of a series of eight score cards to be used by managers to assess work in progress. Areas covered by these score cards

included communication, management effect;veness, housekeeping, procedure use,  ;

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industrial safety, work practices, human error reduction indicators, and pre-job brief The goal was to increase the level of focus on work activities and pro'!ide a mechanism for giving immediate feedback to workers conceming job performance, which would j result in a more attentive and better trained work force. Initially, all managers were

beirg required to fill out at least one score card per week. In practice, managers were i averaging about one per day, with 60 percent of the jobs being covered on a weekly basis. Deficiencies identified were required to be discussed on the spot with the workers. There was also a requirement for the workers to sign the checklist and a space for them to provide comments if desire Although these score cards had not been used for very long, the feed back from management was that it was having a positive effect in that the number of issues being identified was decreasing. As time progressed it was expected that the frequency for using the score cards would be reduced as identified deficiencies in werk practices decline ' Conclusions The score cards were a pro-active licensee initiative for improving work force performance which appeared to be having a positive impac l l

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, Decommissionina Performance and Status Review a. Scope (71801)

Decommissioning activities were evaluated to verify the licensee and its contracted '

work force were conducting decommissioning activities in accordance with licensed '

requirements. Plant tours were conducted to evaluate the material integrity of structures, systems, and components necessary for the conduct of safe decommissioning and to evaluate plant housekeepin ,

b. Observations and Findinas The inspector attended a High Level of Activity briefing in preparation for the removal of a scavenger from the Unit 1 SFP. The briefing ensured that all personnel involved in the activity understood the scope of the work, what everyone's roles were, anticipated dose rates, and what actions to take in the event unexpected elevated dose levels occurred. Following the briefing, the inspector observed the removal of the scavenger from the pool. The work was carried out as planned with no problems note Throughout the job the workers demonstrated good work practices and conducted the job with attention to the As-Low-As-Reasonably-Achievable (ALARA) concep The inspector conducted several tours of the Unit 1 Turbine Building, the Spent Fuel Building, and the Sphere. Good housekeeping practices were noted in all areas. No I problems were noted with the materialintegrity of structures, systems, and components observed that could be considered adverse to safety, c. Conclusions Work was observed to be carried out in ar; orderly and well thought out manner with adequate attention given to good work practices and worker safety. Good housekeeping practices were observed in the Turbine Building, the Spent Fuel Building, and within the Spher II. Spent Fuel Safety l SFP Safety at Permanentiv Shut Down Reactors a. Scope (60801)

The inspection evaluated the SFP and fuel pool safety. Factors considered in the evaluation included: siphon and drain protection; SFP instrumentation alarms and leakage detection; SFP chemistry and clean lines control; criticality controls; and SFP generation and power supplie b. Observations and Findinas The SFP system consists of two pools, the SFP and the fuel transfer pool, connected and separated by movable fuel pool gates. The pools are constructed of reinforced concrete that was originally epoxy coated. During the inspection the licensee was

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l performing tneirihree year fuel pool structural integrity inspection to monitor the integrity of the concret Subsequent to the January 1994 potential loss of water event, the licensee took corrective actions that preclude a loss of water below the top of the fuel assemblie The only opening below the normal water surface in the SFP is the opening between the SFP and the transfer pool. This is normally sealed with the fuel pool gates. Water

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in the transfer pool is maintained at the same level as in the SFP. Thus, even if the

- seals failed, water would not drain from the SFP to the transfer pool. The fuel transfer l

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tube, the main concern of the 1994 event, has been welded shut with a blind flange and the tube is periodically inspected for leakage past the blind flange. To date no leakage has been observed.

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The new SFP filter /demineralizer and all of its piping are located above the water level in the pool so the suction and retum lines (one in each pool) cannot drain the pool Nevertheless, the suction pump itself is located in the water in the SFP at an elevation above the top of the fuel. The discharge lines have anti siphon levels at the water surface to preclude siphoning. The filter /demineralizer system has a high delta-pressure cutout on the pump to preclude any inadvertent pool draining. The existing pipe penetrations into the transfer pool have either been cut and capped or had anti siphon holes added which are inspected periodically for blockag There are three independent supplies of makeup water for the SFP. Normal makeup comes from the site clean demineralized water system powered by normal AC powe An attemate path for makeup is available from the site contaminated demineralized water system, also powered by normal AC power. These two systems are sufficient for the amounts required to make up the normal evaporation losses. Large capacity l makeup is available through either the contaminated demineralized system or the fire protection hose station in the SFP Building. Other close oy sources of fire water can also be utilized for more makeup capacity on an as needed basis. There are two diesel driven fire pump SFP instrumentation consisted of level, temperature and radiation alarms. Any ,

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significant water loss would be promptly detected by means of a fuel pool trouble alarm in the Control Room (CR) which monitors low water level and high water temperrtur The level and temperature are also recorded every shift by localinstrumentation. In addition, an area rediation monitor is located in the pool area which is also alarmed in the C In response to the 1994 event, and because there was no leak detection system for the SFP, the !icensee has initiated monitoring and trending of the level of the SFP. Water makeup is trended to detect any appreciable change that might be indicative of a degradation of SFP wall integrity. Normal loss of inventory is through su':sa

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evaporation which amounts to approximately 8 - 12 inches / month. However, the evaporation rate is high! . moendent upon pool temperature, building temperature, humidity and any air f Y ass the pool surface. Since the licensee started l monitoring after the 1. - . ent there has been no leakage observed. SFP chemistry

and cleanliness control are excellent since the 1994 event with the addition of the new SFP water filter /demineralizer.

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A variety of site requirements ure in place to provide sufficient assurance that the spent i fuel storage will preclude criticality. The only fuel moves anticipated in the near future are for the fuel characterization of the Unit i fuel bundles in preparation for dry cask i storage. Acceptable geometry will be maintained throughout the moves. There are

} - heavy load handling limitations over the SFP. The rack system was designed to

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prevent criticality and calculations have shown that it would remain true with a dry pool.

l At present, there is no system needed to cool the SFP since the Unit 1 fuel does not

generate sufficient heat to require cooling.

] Conclusion l

l The systems that monitor the SFP were adequate to detect any change in fuel pool

! level that would challenge fuel integrity.

L 111. Radioloalcal Safety

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i Il Occupational Radiation Exposure

Scope (83750)

An inspection and evaluation were made of the radiation safety program to ensure that procedures and controls were adequate to minimize occupational exposure to radiological materials and to identify potential problem area ' '

b.- Observations and Findinos During tours of the Unit 1 Turbine Building, SFP and Sphere, the inspector noted that areas appeared to be properly controlled and appropriately posted. Observations of '

work in progress and discussions with workers determined that workers were properly dressed, understood the radiological controls for their work area, were cognizant of the dose rates, and that they were employing good ALARA practices. A number of workers were observed removing uti-Cs, using personnel contamination monitors, and conducting hand and foot frisks with G-M pancake probes. All practices observed were noted to be acceptabl A review of dose goals for 1998 for Unit 1 determined that the accumulated dose as of September 1,1998 was 37 person-rem, versus an annual goal of 48 person-re While most jobs were being completed with total doses well below the projected dose for the job, the one area where the actual dose was in excess of the initial goal was the Radwaste Vault removal project. This work activity had increased significantly in scope since it was started, which accounted for the higher than projected dos Conclusions  !

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Workers were knowledgeable of their work area dose rates and were employing good ALARA work practices, which was being reflected in the low doses received for various l work activitie '

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Il RadWaste Treatment. and Effluent and Environmental Monitorina i

! Scope (84750)

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An inspection and eva!uation were made of tho radioactive waste treatment systems

and activities. Soil samples were collected for the independent analysis of dredging

. spoils from the Illinois River.

I Qbsyrvations and Findinas I

The incoectors toured the radwaste yard and facilities to evaluate activities involving

, the removal of sludge / water from the radwaste vaults and tanks. Progress was slow I

but steadily progressing in the removal of the sludge from the radwaste vaults. The

, vendor's system for removing and drying the sludge and then depositing it into a high

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integrity container was working well. However, because of the significantly expanded

scope and cost of the radwaste vault cleanup, Commonwealth Edison (Comed) had

halted this work to pursue a fixed cost contract for it's comp!stion.

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! On July 27,1998, the inspector accompanied Comed personnel during the collection of

environmental soil samples from along the Illinois River. The purpose was to sample j dredging spoils resultirig from past river dredging by the Army Corp of Engineers for the presence of radioactive 'ontamination. Although it was assumed that no releases had occurred from the Dresc.- .i site over the years that could have contaminated the river j sediment, the intent was to conduct sampling to verify if this was indeed th< .

Comed personnel collected approximately 40 samples from two separate dret, . g j sites downstream from Dresden and along the south side of the river, plus several i control / background samples from upstream of Dresden. The NRC collected a total of

18 samples downstream of the Dresden site while one control / background sample was j collected upstream. The NRC and Comed analyzed the samples for manganese 54, I

fron 59, cobalt 58 and 60, zinc 65, and cesium 134 and 137. The NRC's results of j analyses of the samples showed that all isotopes examined were at or below the

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background environmental levels, and were consistent with the results from the i upstream control sample. The results of the samples analyzed by Comed were similar i to the results obtained by the NRC.

Conclusions

) The licensee continued to make progress in the removal of radioactive waste from the radwaste vaults and tanks. Radiological controls associated with activities appeared to be adequate. There was no evidence of radiological contamination of the river sediment downstream of the Dresden Statio l

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IV. Previously identified Violations and Deviations (92702)

(Closed) VIO 50-010/97013-0.2: Violation involving personnel failing to review radiation survey maps or otherwise verify dose rates prior to conducting equipment rounds in the Unit 2 Turbine Building. This violation occurred because surveys had not been performed to reflect changing dose rates that had resulted from an increase in reactor power Ic/el. Because Unit 1 is permanently shut down and can therefore not have changes in dose rates due to changes in reactor power level, this item is not pertinent to Unit V. Manaaement Meetina The inspectors presented the inspection results to members of licensee management at the conclusion of the onsite portion of the inspection on September 18,1998. The licensee acknowledged the findings presented. The licensee did not identify any ct the documents or processes reviewed by the inspectors as proprietar ;

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PARTIAL LIST OF PERSONS CONTACTED l l

Licensea

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• B. Christel, Decommissioning Engineering Manager  !

l *B. Kobel, Compliance Engineer I l *J. N. Leech, Decommissioning Plant Manager Unit 1 l J. Limes, Licensing /Corapliance Engineer

• C. McDonough, Decommissioning Business Services Manager, and the j Decommissioning Maintenance & Construction Manager i

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l R. Norris, Unit i RP Lead Supervisor l F. Resick, Comed Corporate Health Physicist l * Denotes those attending the exit meeting on September 18,199 ,

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The Inspector also interviewed other licensee personnel in various departments in the course of the inspectio :

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INSPECTION PROCEDURES USED t

IP 40001: Self-Assessment, Auditing, Corrective Action i IP 71801: Decommissioning Performance and Status Review at Permanently Shut Down Reactors l l

lP 60801: Spent Fuel Safety at Permanently Shutdown Reactors IP 83750: Occupational Radiation Exposure i IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring l IP 92702: Followup on Corrective Actions for Violations and Deviations I l

ITEMS OPENED, CLOSED, AND DISCUSSED Closed 010/97013-02 VIO Failure to verify dose rates prior to conducting rounds.

l DOCUMENTS REYlEWED j Unit 1, Facility Operating License No. DRP-2, Amendment No. 39, Appendix A, Technical Specifications, issued July 8,1997

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