IR 05000254/1997025
| ML20203E495 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/09/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203E431 | List: |
| References | |
| 50-254-97-25, 50-265-97-25, NUDOCS 9712170077 | |
| Download: ML20203E495 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
REGION lil Docket Nos:
50-254;50-265
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License Nos:
DPR 29; CPR-30
Report Nos:
50 254/97025(DRS); 50-265/97025(DRS)
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Licensee:
Commonwealth Edison Company
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Facility:
Quad Cities Nuclear Power Station Units 1 and 2 Location:
22710 206th Avenue North Cordova,IL 61242 Dates:
November 3-7,1997
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Inspectors:
R. Paul, Senior Radiation Specialist K. Lambert, Radiation Specialist
Approved by:
Gary L. Shear, Chief, Plant Support Branch 2
Division of Reactor Safety
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EXECUTIVE SUMMARY I
Quad Cities Nuclear Pom Station. Units 1 & 2 NRC Inspection Reports 50-254/97025; 50-265/97025
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This routine inspection included a review of the respiratory protection program,1997 station radiation dose, source term reduction efforts, and follow up on several open items. In addition, the inspection included a review of personnel axposures received from performing the Unit 2
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Class 1 Pressure Test at power.
The 1097 station dose was lov er than projected largely due to reduced scope of worn
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and lack of significant emergeat work during the QLl'14 refueling outage and to better
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work planning and extscution during the recent Q2P01 maintenance outage
(Section R1.1).
The inspectors concluded that problems in the planning and conduct of testing resulted
in unnecesary dose to workers. The two re-performances of the test were expected to i
result in a total dose of about 300 millirem to personnel.
The respiratory protection program was well implemented, except for the storage of l
respirators where several full storage bins did not have dividers. Storage in this manner i
could lead to the deformation of the respirator face pieces and to problems obtaining a proper seal when used (Sectioq R1.3).
The station was effectively planning and coordinating work to reduce the source term
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and, therefore, the overall station dose (Section R1.4).
Records of spills and unusual occurrences involving the spread of radioactive
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contamination as required by 10 CFR 50.75(g) and station procedures were effectively maintained (Section R1.5).
Overall housekeeping and pesting were good; however, housekeeping in the Laundry-
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Tool Decon Building mechanical maintenance shop was poor (Section R2.1).
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Reoort Details
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IV. Plant Sunned R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 External Radiation Exoosure Control and ALARA imolementation a.
Esoection Scone flP 83750)
The inspectorc reviewed the station radiation exposure and N 4r<A goals for 1997, including the doses from recent outages Q2R14 and O2P01.
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Observations and Findings
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The projected station exposure for 1997 was 1260 person rom while ths ictual station exposure through October was 618 person-rem. The large reduction in exposure was primarily from exposure savings during refueling ouicqe O2R14. The projected exposure for this outage was 730 person-rem, while the actual exposure was 422 i
person rem. Major exposure savings were attributed to better than anticipated woin performE nce during the Unit 2 "A" recirculating pump motor removal, weld overlay work, asbestos insulation abatement related to the emergency core cooling system modification, and the lack of significant emergent work.
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Additional exposure savings were also realized during the recent maintenance outage, O2P01. The projected exposure for this outage was 32 person-rem, while the actual
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exposure was 15.8 person-rem. R6diation protection staff indicated that the savings was due to better planning and preparation for the reactor assembly, to innovative scaffolding arrangements, and to reduce crew sizes. As a result of the exposure reductions during the outages, the 1997 station goal was revised to 720 person-rem from 1260 person-rem.
c.
Conclusions The lower than projected 1997 station dose through October was largely due to reduced scope of work and lack of significant emergent work during the recent 02R14 refueling outage and to better work planninc and execution during the O2P01 maintenance outage.
R1.2 Station Dose Associated with ASME Class 1 Pressure Tesj a.
Insoection Scoos (IP 83750)
The inspectors reviewed the ASME Class 1 Pressure Tests for Unit 2 performed in May and June 1997 and the doses expendad. The inspectors also reviewed the projected additional dose for the required re-testing.
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Observation and Findinos r
In May 1997, e pressure test of Unit 2 reactor vessel and associated piping was
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performed at 800 pounds per square inch (psi) by pressurizing the system with the
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control rod drive (CRD) pumps and walking down the dry well to identify leaks. The total
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dose to the three inspectors and two radiation protection technologists (RPTs) involved with the evolution was 58 millirem (mrem). Because the ASME Class 1 Pressure Test was to be performed at 1005 psi, the test in May could not be used, and a seced test was performed in June 1997, with the unit at 12 percent power. The total dou : om this second test to the three inspectors and three RPTs was 227 mrem. The inspectors L
discussed past doses for the test with radiation protection staff who indicated that the historical dose average for tt i oressure tests was 70 mrem.
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The inspectors determined that approximately 150 mrom of additional dose was received performing the test in June at 12 percent power versus the historical doses received for performing the test. In addition, the inspectors teamed that the test was incorrectly performed and would have to be repeated with the personnel spending additional time looking for leaks. Radiation protection staff projected an additional dose of 75 mrom for this retest.
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Conclusions The inspectors concluded that problems in the planning and conduct of testing resulted
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in unnecesary dose to workers. The two re-performant,es of the test were expected to result in a total dose of about 300 mitirem to personnel.
R1.3 Resoiratorv Protection Proaram a.
Insoection Scoce (IP 93750)
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The implementation of the resp Morf protection program was reviewed. This review
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included respirator maintenance awj storage, fit testing, respirator issuance, and g
epplicable prr'cetres.
a b.
Observation and Findin?
The inspectors reviewed int iesp,:.itory protection program procedures and concluded that procedures were adequate to enr.ure that the program was effectively implemented.
Procedures reviewed included bioassay, issuance and fit testing, and maintenance of respirators. The use of respirators and engineering controls was determined through the ALARA reuw process. A corporate policy statement discussed the use of process or engineering controls; routine, nonroutine and emergency use of respirators; the periods of respirator use and relief; inspection of respirators for operability and maintenance; and qualitat* a and quantitative respiratory fit testing.
The inspectors observed the fit testing of an individual. The RPT performing the testing was knowledgeable in the fit testing process and referred to the procedure during the m
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test to ensure compliance with the procedure. The station used a computerized tracking system to ensure that respirators are only issued to those individuals with a current physical, training, and fit test. A second RPT was asked to demonstrate the issuance of respirators. For the demonstration, the name of an individual who had received a physical and training, but who had not been fit tested, was selected, The computer program correctly indicated that the individual should not be issur d a resprator. The RPT indicated that he would inform the individual that a respiratoi could not b9 issued and that the individual should inform his supervisor. The RPT also Hi%ted that ;f needed, a fit test could be arranged for the individual so he could be ssued a respirator.
The respirator storage, cleaning, and maintenance areas were well organized and exhibited good housekeeping. Respirators had been placed in plastic bags and stored in bins in cabinets. Most of the storage bins were compartmentalized to prevent the over stacking of respirators in bins. However, several bins were observed viithout dividers and filled with respirators. The stacking of respirators in this manner could lead to the deformation of the face piece and to potential problems obtaining a proper seal when used. The inspectors discussed this weakness in the storage of respirators with radiation protection management who stated that it was not their expectation to have respirators stored in this manner and would take steps to correct the condition.
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Concluslom The respiratory protection program was well implemented. A weakness was noted in the storage of respirators, where several storage bins did not have dividers and were full of respirators. Storage in this manner has the potential to deform the face piece, which could lead to problems obtaining a proper seal when used.
R1.4 StatLon Exoosure and Source Term Reduction a.
tr.pdion Scoce (IP 8375D)
P s inspectors reviewed the source term reduction program and discussed the progress in source term reduction, including the schedule of planned work, with radiation protection ALARA personnel.
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Observations and Findings Al. ARA personnel discussed a list of planned source term reduction projects anticipated to be done by the end of the 01R15 outage, scheduled for the fall of 1998, or shortly afterwards. This list included the following:
U-1, U-2 drier separator drain lines near the 1-1901-114 valve by hydrolase and
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flushing; U-2, U-1 west skimmer surge tank weir duct by robot scrub and flush;
U-1 emergency core cooling system suction ring header by robot scrub and
flushing; U-1, U-2 fuel pool neat exchangers by flushing as needed;
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U-1 north and south scram discharge headers by hydrolase and flushing; and
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U-1,1 A and 10 RHR heat exchangers lower shell head by hydrolase and
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flushing.
The A1. ARA personnel also indicated that items on the list can be df/eted or added dependent on priorities, marpower, and budgeted resot.rces.
During several tours of the reactor building, the inspectors noted areas with elevated
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dose rates including the skimmer surge tank weir ducts. Radiation protection staff Indicated that the Unit 2 ducts were planned for robot scrub and flushing within the next several weeks and that if successful, Unit 1 weir ducts would follow shortly. The
inspectors Mso noted that the station non-outage daily exposures had been steadily declining, which can be attributed to the source term reduction program, c.
Conclusl0DS The inspectors concluded that the station was effectively planning and coordinating work to reduco the source term and the overall station dose.
R1.5 Decommissionino Recordkeeoing (10 CFR 50.75(g))
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Insocction Scoce (IP 83Z50)
The inspectors reviewed the licensee's documentation of spills or unusual occurrences involving the spread of contamination in or around the facility as required by 10 CFR 50.75(g) and procedure QCRP 6100-01, Revision 2, "10 CFR 50.75(g) Documentation."
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Observations and Findings The inspectors noted that the radiation protection department maintains a file on spills for decommissioning purposes. A review of the files indicated that the appropriate -
information required by 10 CFR 50.75(g) was included. This information included drawings of the contaminated area, cost estimate for remediation, and the nuclide and activity present.
in addition, the inspectors noted that NRC Inspection Report Nos. 50-254/97009(DRS)
and 50-265/97009(DRS) documented two areas of low level contamination, the waste water and sewage treatment outdoor sludge drying areas, that were not included in the decommissioning files. The inspectors review of the files identified that the radiation protection staff had properly evaluated these areas and included them in the decommissioning files.
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Conclusiong
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The radiation protection staff was effectively maintaining records of spills and unusual occurrences involving the spread of radioactive contaminaVon as required by 10 CFR
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50.75(g) and station procedures.
R2 Status of RP&C Facilities and Equipment R2.1 General Tours of Reactor and Radwaste Buildinas (IP 83750)
The inspectors performed severalinspections of activities in the reactor and radwaste buildings and observed radiation worker practices. Radiological postings and boundaries in the buildings were generally well maintained, and housekeeping was good. Observed workers demonstrated knowledge of radiological conditions and were wearing appropriate dosimetry.
The inspectors also toured the Laundry-Tool-Decon (LTD) building and noted poor radiological housekeeping in the mechanical maintenance shop. Many bags of equipment to be deconned were lying on the floor, and a respirator face shield was
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laying on a 166 in the decon area which was posted as a contaminated area. A cart was observed w th radioactive material tags partially under parts, but not attached, which questions whether the parts were contaminated or not. Although these problems could be httributed to outage recovery activities, this area has been a concern in previous inspections.
Overall housekeeping and posting were good. However, housekeeping in the LTD building mechanical maintenance shop was poor.
R7 Quality Assurance in RP&C activities The inspectors reviewed quality assurance audits of the respiratory protection program.
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There were several audits / observations of the program, which focussed on the training of respirator users during nuclear general employee training, the use of respirators during a general site emergency plan drill, and the use of respirators by personnel handling asbestos The audits / observations appeared thorough and indicated that the training end use of respirators was appropriate. The audit of the emergency plan drill identified an area where improvements could be made. The audit indicated that the drill
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could be enhanced by having individuals actually don respirators and protective clothing versus simulating those activities.
- The inspectors also noted that the audits of the respiratory protection program did not review procedures or the overall implementation of the program, but were mainly focused on the actual use of respirators.
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R8 Miscellaneous RP&C lssues R8.1
$josed) VIO 50-254/97007-01(DRS): 50-265/97007-01(DRS): Failure to use engineering controls to control airborne radioactivity by the failure to ensure the operability of a HEPA vacuum unit and the failure to perform the decontamination of a valve disc assembly inside a glove bag. Actions taken to prevent recurrence included revising Quad Cities Administrative Procedure (QCAP) 640-04 " Installation and Use of Containments" to include requirements of a pre-job briefing when using containments, and incorporating a statement in the applicable radiation work permits to ensure that HEPA ventilation on containments is operational. The inspectors verified that the procedural revisions were made and that RPTs interviewed were aware of the revisions.
This violation is closed.
R8.2 $losed) VIO 50-254/97007-02(DRS): 30-265/97007-02(DRS): Failure to adhere to station procedures (OCAP 600-01 * Control of Materials for Unconditional Release from Radiologically Posted Areas"), which resulted in the release of radioactive contaminated material to an off-site facility that did not have an NRC license to receive or possess the material. To prevent recurrence the licensee trained all personnel who perform unconditional release surveys on proper survey techniques and on questions to ask about material to be released so an edequate risk assessment can be made about the material. The inspectors reviewed the licensee's corrective action system and did not identify any additional problems. This violation is closed.
R8.3 LClosed) VIO 50-254/97009-01(DRS): 50-265-97009-01(DRS): Failure to provide an individual an exit from the drywell locked high radiation crea (LHRA). Actions taken to prevent recurrence of the violation included revising procedure QCAP 0620-01 "High Radiation Area Access" to require that the independent verifier initial a log to verify that all persons are out of the LHRA before finallocking. During the inspection, the inspectors verified that procedure revision had been made and that those radiation protection technicians interviewed were aware of the new requirement. This violatioriis closed.
X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on November 7,1997. The licensee acknowledged the findings presented and did not identify any information discussed as proprietary,
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PARTIAL LIST OF PERSONS CONTACTED Licensee P. Behrens, Chemistry Supervisor A. Chernick, Regulatory Assurance supervisor D. Cook, Plant Manager F. Famulari, Quality and Safety Assessment T. Kirkham, Lead Health Physicist - Technical G. Powell, Radiation Protection Manager W. Schmidt, A'_ ARA Coordinator
- M. Wayland, Maintenance Manager NflG K. Walton, Resident inspector INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 92904 '
Followup - Plant Support LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened None C1010d 50-254/265-97007-01 VIO Failure to use engineering controls during the decontamination of a valve disc assembly (Section R8.1)
50-254/265-9/007 02 VIO Failure to follow RP procedures during the survey and unconditional release of material (Section R8.2)
50-254/265-97009-01 VIO Individuallocked inside an LHRA (Section R8.3)
Discussed None
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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers
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CFR Code of Federal Regulations '
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CRD Control Rod Drive HEPA-High-Efficiency Particulate Air IP -
Inspection Procedure.
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LHRA Locked High Radiation Area LTD Laundry-Tool-Decon mrem millirem NRC Nuclear Regulatory Commission
- psi Pounds per Square Inch RHR-Residual Heat Removal-RP&C-Radiation Protection and Chemistry RPTs
' Radiation Protection Technologists VIO Violation
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LIST OF DOCUMENTS REVIEWED -
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-1QCAP 0610-04, Respiratory Protection Program QCRP 5500-01, Respiratory Protection Program Administrative Cuide
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l QCRP 5510-01, Respirator Selection, Issuance, and Utilization
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s QCRP 6100-01,10CFR50.75(g) Documentation
QCRP 6200-05, Respiratory Protection Evaluation for RWPs QCRP 5510-03, Operation of the TSI Model 8020 Portacount Plus
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Respiratory Level II - SCBA, Initial and Annual Retraining
Appendix R Modifications Summary (Unit 1)
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- Dose Classification 1997 e
- Q2R14 exposure Data
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January outage planning summary i
Locked High Radiation Area Timekeeping Sheet, June 22,1997 Time line for Q2R14 Class 1 System Leakage Test RWP #: 972074, Revision 1, U2 Drywell: Low Power Level VTl/ Minor Repairs (Q2R14)
RWP #: 972067, Revision 1, U2 Vessel Hyoro: VTl/ Minor Drywell Valve Repairs (Q2R14)
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