IR 05000254/1998002

Insp Repts 50-254/98-02 & 50-265/98-02 on 980112-16. Violations Noted.Major Areas Inspected:Review of ALARA Planning,Radiation Work Permits & Observations of Radworker Performance

ML20202B050
Person / Time
Site:	Quad Cities, Dow Chemical Company
Issue date:	02/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20202B026	List: IR 05000254/1998002 ML20202B024 ML20202B039
References
50-254-98-02, 50-254-98-2, 50-265-98-02, 50-265-98-2, NUDOCS 9802110072
Download: ML20202B050 (13)

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U.S. NUCLEAR REGULATORY COMMISSION REGIONlli Docket Nos:

50-254;50-265 License Nos:

DPR 29; DPR 30 Report Nos:

50-254/98002(DRS); 50-265/98CO2(DRS)

Licensee:

Commonwealth Edison Company Facility:

Quad Cities Nuclear Power Station Units 1 and 2

Location:

22710 206th Avenue North l

Cordova,IL 61242

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Dates:

January 12-16,1998 Inspectors:

R. Paul, Senior Radiation Specialist W. Slawinskl, Senior Radiation Specialist

- K.. Lambert, Radiation Specialist Approved by:

Gary L. Shear, Chief, Plant Support Branch 2

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Division of Reactor Safety l

9902!10072 990205 PDR ADOCK 05000254 G

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EXCCUTIVE SUMMARY Quad Cities Nuclear Powar Station, Units 1 & 2 NRC Inspection Reports 50-254/98002; 50-265/98002

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This routine inspection included a review of ALARA planning, radiation work permits, and observations of radworker pc formance, in addition, the inspection included a review of posting and labeting, portable instrument calibrations, tool issuance and control, and the review of a 1996 release of construction material off site with direct radiation measurements greater than background.

Q1P01 outage ALARA plans and radiation work permits were comprehensive and

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observed radiation worker practices were good. Howover, an inconsistency was identified in that ALARA initiatives were not always listed in RWPs (Section R1.1).

One violation was identliW for hce shields in contaminated areas that were not issued

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by the radiation protection d6padrnent in addition, the face shields were left on the floor of contaminated areas, whhn could lead to the contamination of indiviouals using those face shields (Section R1.2).

A Non-Cited Violation was identifie;. Tilowiry materials outside the radiologically

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pested area (RPA) with direct radiatica measurements above background levels. The Licensee initiated prompt and extensive corrective actions once the contaminated material was identified outside the RPA (Section R1.3).

Radiological controls for tools and equipment used in RPAs were generally offective.

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Roane tool crib and storage area surveys pe: formed by the licensee and independent surveys performed by the inspectors during the inspecti',n confirmed the offectiveness of the radiological controls for tools and equipment. A car coding system was being developed to improve tha accountability and tracking of tools (Section R1.4).

The calibration and maintenance program for the portable instruments reviewed was

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sufficiently implemented. Several program weaknesses were identified by the inspectors, including poor response of some instruments at the lower end of their capability and the lack of a dedicated calibration crew. The poor response of instruments will be followed-up during future inspections (Section R2.1).

The radiological posting of facilities and equipment was good. Radiological

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housekeeping was good, except in the Laundry-Tool Decon building maintenance shop.

Labeling of containers was generally effective, with inspector identified deficiencies promptly corrected by radiation protection personnel (Section R2.2).

The licensee was taking good ccrrective actions to bring the radioactive waste systems

back to their normal flow paths and to reduce the number of outstanding work requests -

(Section R2.3).

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l Reoort Details IV. Plant Sunged

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R1 Radiological Protection and Chemistry (RP&C) Controls

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R1,1 Unit i Outaae Work control and ALARA Imolementation a.

Insoection Scooe (IP 83750)

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The inspectors reviewed the radiological controls implemented and the as-Icw as-reasonably-achievable (ALARA) goals for the Unit 1 surveillance outage (01F01). The inspectors also reviewed ALARA plans and radiation work permits (RWPs), and observed worker practices. The following high dose or potentially high dose jobs were observed in ptogress:

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Reactor core isolation cooling valve disassembly / repair / reassembly,

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Main condenser tube cleaning,

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Turbine bypass valves asbestos abatement,

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High pressure coolant injection steam valves repair,

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Waste collector pump and motor installatien and alignment.

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Observations and 14ndinos Based on the or;ginal scope of work, a refueling outage dose goal of 40 person-rem was projected. The actual outage dose was 22 person-rem as of Janua y 21,1998. Due to both units being shutdown, the scope of the outage was being expanded and radiation protection expected the dose goal to be exceeded. Radiation protection indicated that once the extent of the outage expansion was determined, a revised outage dose goal would be projected.

ine inspectors reviewed ALARA plans and RWPs for several high dose jobs including:

main condenser tube cleaning; turbine bypass valves asbestos abatement; Unit 1 safety relief valves repair / replacement; waste collector tank leak repair; and the Unit 1 drywell snobber inspections. ALARA plans and associated RWPs were comprehensive and included adequato ALARA initiatives, such as minimizing crew size, deconning and releasing areas from contaminated area status, and job specific instructions on lowering worker doses. However, the inspectors noted an inconsistency where ALARA initidives were not always reflected in the RWPs. Radiation protection (RP) staff indicand that the ALARA initiatives were discussed with individuals during the bre-job briefings and inclusion in the RWP was not required by procedure. The staff also indicated that it planned to review the relationship between ALARA plans and RWPs, to ensure that information was effectively communicated to 'he workcrs.

The inspectors observed portions of the main condenser tube cleaning and noted that ALARA initiatives were properly implemented along with the specific instructions in the RWP. During a high pressure coolant injection steam line valve repair, good communication between the maintenance workers and radiation protection technicians was observed. Workers notified radiation protection when the contaminated area needed to be expanded to facilitate work on the valve, and then waited until a RPT

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arrived to move the barriers. Radiation Protection was responsive in that a RPT arrived within a reasonable time and adjusted the contaminated area. The ALARA initiatives observed by the inspectors were, again, adequately implemented and dosimetry was worn on the thigh as required by the RWP. The inspectors also observed the alignment of the waste collector pump and motor in the basement of the radwaste building.

Appropriate protsLtive clothing was worn by the workers and dosimetry was placed on their heads in accordance with the RWP due to radiological hot spots in overhead piping. The inspectors also observed that workers moved to low dose waiting areas when possible.

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Conclusions Radiation worker practices during the Q1P01 surveillance outage were good. Al. ARA plans and F.WPs were comprehensive. However, an inconsistency was identified in that ALARA initiatives were not always listed in the RWPs.

R1.2 Issuance and Control of race shields a.

insoection Scoce (IP 83750)

The inspectors reviewed the station procedures for the issuance and control of faceshields, observed the use of faceshields, and discussed the program with radiation protection personnel, b,

Qbservations and Findinas

Station Procedure QCRP 5310-04," Issuance and Maintenance of Faceshields" stated that faceshields used for protection from radiation or used in contaminated areas were issued by radiation orotection and were to be treated in the same manner as respiratem equipment. Fat esuelds used for other purposes were issued from the tool cribs.

During a general inspection of the reactor building, the inspectors identified three faceshields left in the posted contaminated area of the Unit 2 decon shop. The inspectcsrs informed radiation protection, who sent a RPT to investigate the situation.

The RPT found five faceshields in the contaminated area of the decon shop, removed them for deconning and retum to the tool crib, and inliiated a problem identification form (PlF), PIF Q1998-00142. A smear survey of the faceshields did not identify any smearable activity. Further investigation, by radiation protection, revealed the faceshields were issued from the tool crib and should not have been in the contaminated area. The failure of faceshields, used in contaminated areas, to be issued by radiation protection was a violation of Technical Specification 6.11 and proc. lure QCRP 5310-04 (VIO 50-254/98002-01(DRS); 50-265/98002-01(DRS)).

During an inspection of the radwaste building, the inspectors also identified a facesh! eld lying on the floor of a posted contaminated area, Wnile this faceshield sas issued oy radiation protection, the insoectors discussed with the RP staff the potential for individuals becoming contaminated by wearing faceshields that were laying in contaminated areas. Radiation protection staff indicated it was their expectation that faceshields be treated like respirators and not left in contaminated areas. They also

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Indicated that they would review the issuance and control of faceshields to identify additional corrective actions that could be implemented.

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Conclusions One violation was identified for faceshields in contaminated areas that were not issued by radiation protection. In addition, faceshields left on the floor of contambated areas could lead to personal contamination of individuals using those faceshields.

l R1.3 Contaminated Material Released Orfsite a.

Insoection Scooe (IP 83750)

The inspectors reviewed a 1996 release of contaminated cement blocks offsite. The inspection included a review of the PlF, relevant procedures, and discussions with radiation protection personnel.

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Observations and Findinos in July 1996, a contract RPT (CRPT) wan surveying, for unconditional release, cement blocks that had been used for shoring office trailers The CRPT identified 10 blocks with direct measurements up to 5000 disintegrations per minute (dpm) outside the radiologically posted area (RPA) at the north end of the pr)tected area. Srnearable contamination was not identified. The licensee generated a P:F and initiated an investigation. The investigation revealed that the blocks came from an area outside the protec'ad area, but inside the owner controlled area. There were approximately 2000 blocks in this area. Subsequent random surveys of these blocks, which originally came from the RPA, revealed several blocks with direct fixed cor.tamination ranging from 1000 to 30,000 dpm, with no smearable activity identified. The area was then controlled and posted as a radioactive mateFat area. The blocks were transported back to the Dry Active Waste storr.ge buliding and other areas in the owner controlled area were searched for additional blocks.

Radiation protection supervision was informed that some blocks had been taken offsite by employees. The licensee ran an article in the daily news letter informing employees of the event and asked that anyone who had taken blocks from the site contact radiation protection so that surveys of the blocks could be performed. However, additional information was not obtained. RPTs were sent to four employees' homes where blocks had been taken. Surveys of approximately 500 blocks at employees' homes did not

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identify any direct measurements or smearable contamination, except at the home of

me RPT. Three blocks out cf 225 bic:ks at the RPT's home were identified with direct measurements ranging from 1000 to 10,000 dpm, with no smearable activity identified.

All blocks with identified contamination were trarsported back to the station.

The licensee did not find a conclusive cause to the event, but indicated that contamination could have been missed during unconditional relee e surveys or that a

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pallet of contaminated blocks had been mistakenly taken to the area with a load of a

noncontaminated blocks. The radiological significance of the event was minimal as no personnel contamination events occurred as the result of this event.

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The inspectors revieweo Procedure QCAP 0600-01, " Control of Materials for Unconditional Release From Radiologically Posted Areas," which stated that the release limits were no direct or smearable contamination above background. The release of blocks with direct measurements above t,ackground was a violation of precedure QCAP 0600-01. This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.

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Conclusions A Non-Cited Violation was identified for allowing materials outside the RPA with direct measurements above background. The licensee initiated prompt corrective actions once contaminated material was identified outside the RPA.

R1.4 Issuance.and Control of Too'p,Msod in Radiologically Protected Areas a.

insoection Scoce The inspectors reviewed the licensee's program for the issuance and radiological control of tools and equipment used in radiologically protected areas (RPAs). The review consisted of in-plant observations, independent inspector survey of tools and other items, review of the tool survey program, and discussions with workers.

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Observations and Findings Small tools and other equipment belonging to the station and used in RPAs were issued primarily from the tool crib located in the turbine building (i.e contaminated tool crib) or, if necessary, the clean tool crib in the service build!r.g. Instrument maintenance (IM) and electrical maintenance (EM) staffs also maintained tools in gang boxes and cabinets located in various areas of the plant.

Tools were surveyed by radiation protection personnel after use in contaminated areas and released for return to the tool crib or other storage area provided fixed contamination was less than 50,000 dpm ano ao removable contaminatior' was

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detected. Tools and equipment with fixed contamination were identified * magenta colcred paint. Tools found to exceed the release criteria were transferred either to the Laundry-Tool Decan (LTD) building or Unit-2 decontaminaticn shop, and decontaminated prior to retum to the tool crib or other plant storage area.

The RP department performed routine weekly surveys of hand tools and other equipment stored in the turbine building (contaminated) tool crib, and monthly surveys of the mechanical maintenance (MM)(clean) tool crib and the IM and MM (contaminated)

tool rooms in the service building. Tools stored in gang boxes and cabinets in various plart areas were also randomly survc/ed by RPTs monthly. Approximately 10% of the tools stored in the tool crib were randomly surveyed in accordance with station procedure QCRP 6020-03, Revision 8," Radiological Surveys." The lictnsee's surveys occasionally identif' 1 fixed contamination on individual tools above the 50,000 dpm release criteria; however, the contamination was usually isolated to a very small acea of the tool and typically in tool crevices and other difficult to survey locations. The licensee attribted the isolated contamination to the thoroughness of the surveys after decontamination. Removable contamlaation war, rarely identified on tools and other

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items stored in the tool cribs, tool rooms or gang boxes and cabinets located throughout the plant.

Inspector review of the weekly and monthly survey results In the contaminated tool crib and tools stor.)d in gang boxes and cabinets identified no problems, independent

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inspector measurements of randomly selected tools and equipment maintained in the turbine building tool crib and ;n gang boxes and storage cabinets in the LTD and reactor buildings confirmed the adequacy of the licensee's radiological control of tools used in RPAs.

The licensee currently has no accountability system to track the issuance and return of tools used in RPAs and non-RPAs Specifically, no mechanism was in place for assignment of tools issued from e tool crib to an individual or group, for tracking them to ensure surveys were completed, for decontamination if required, cod for return to the appropriate storage area after use. Although the lack of a tool accountability and tracking system had not adversely impacted the radiological control of tools, the

licensee recognized the benefits of improved controls. A bar code tracking system was being developed for tools and equipment, which the licensee planned to implement in 1998.

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Conclusions Radiological controls for tools and equipment used in ccataminated areas were generally effective. Tools were surveyed after ms iii an RPA and decontaminated, as necessary, prior to retum to a tool crib or othe.ool storage area. Routine tool crib and storage area surveys performed by the licensee, and ino 3 pendent surveys performed by the inspectors during the inspection confirmed the effectiveness of the radiological controls for tools and equipment. A bar coding system was being developed to improve the accoun'. ability and tracking of tools.

R2 Status of RP&C Facilities and Equipment R2,1 Radiation Monitoring Eouloment ard Facilities a.

Insoection Scoce (IP 83750)

The inspectors reviewed the operation and calibration methodology for the portable beta-gamma monitoring equipment. The inspectors walked down the calibration facility and equipment, observed radioactive source condition, compared results from an

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independent source check of certain instruments to the licensee's results, and reviewed selected procedures, detector operability history data, aad other cclibration and test results.

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, Observations and Findings Calibration and instrument tests were performed as required, and equipment was as described in the FSAR. The portable monitoring / survey equipment consisted mainly of Geiger-Mueller (GM) and ion chamber detectors. In general, calibration and test methodology was technically sound for all portable monitoring equipment reviewed during the inspection. Most detectors were calibrated and tested by the licensee,

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however, neutron and alphs detection equipment, and air sampling equipment was calibrated by a vendor. There was no dedicated group of calibration technicians and calibrei;cns were performed by RPTs who frequently rotate through the calibration facility. One problem caused as a result of this practice was lack of ownership. The lack of ownership may hava been reflected in the inspectors observations that several beta standards used for calibration of hand held GM detectors were in poor physical condition, which was not rc?orted by the technicians. The degraded standards were not used to calibrate instruments used to quantify radioactive material r)n tools and equipment for unconditional release; however, other in-plant assessments were performed using the detectors calibrated using those sources. The licensee stated that these standards would be replaced with new ones.

The calibration procedurec for all portable hand held instruments had been recently upgraded. However, the inspectors identified a weakness with the procedures in that they did not address the actions that should be taken when the "as found" results are outside the acceptable tolerance limits indicated in the procedures. The current practice was to adjust the *ss fouad" reading on the detector and to the midpoint of the expected reading without documenting that the "as found" reading was outside the tolerance limits. Without documentation, there was no mechanism to track degraded detector performance over time. The inspectors also independently used different strength

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calibration standards to check several GM detectors' calibrations, and found they responded as expected on all but the lowest range of each instrument.

• The condition of calibration standards, and the "as found" readings of instruments being found outside of tolerance limits were discussed with the radiation protection manager and his staff who indicated they would perform an evaluation to determine the scope of the problem and take corrective actions where necessary. The NRC will folicw-up this matter during future inspections (IFl 50-254/98002-05(DRS); 50-265/9802-03(DRS)).

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Conclusions The calibration and maintenance systom for those instruments reviewed was sufficiently implemented. However, the inspectors identified calibration procedural weaknesses, poor response of some detectors at the lower end of the detector's capability, and lack of a dedicated calibration crew, P2.2 Radioloaical Postina and Labelina of Facilities and Eculoment

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Insoection Scoce (IP 83750)

The inspectors performed several inspections of the reactor, turbine, and Laundry-Tool Decon (LTD) buildings, including the Unit 1 and Unit 2 corner rooms and torus general areas, b.

Observations The inspectors noted that the entrance to the radiologically posted area (RPA) was posted as a radiation area. Areas in the RPA with elevated dose rates were identified by diamond signs that indicated dose rates were either 0-5, J-25, or grcater than 25 milliroentgen per hour (mR/hr). The inspectors noted this was effective in informing

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workers of the dose rates in areas they were working. Radiation protection sta.' aad r

posted several preferred routes in the reactor building to direct individuals around areas with higher dose rates. High radiation areas em locked high radiation areas were observed as being properly posted and contro: led. The inspectors independently

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verified that radiological postings reflected the actual area radiological conditions.

Radiological housekesping in the reactor, turbine, and LTD buildings was generally good Howver, the housekeeping of the LTD building maintenance shop was poor, which has been a continuing problem. The housekeeping issue in the maintenance shop was brought to the attention of radiation protection who took action to remedy the situation. The inspectors noted during an inspection of '..o LTD building later in the week, that the nousekeeping in the maintenance shop v,as improved.

Labeling of containers throughout the RPA was generally good. The inspectors identified a few minor labeling inconsistencies, such as empty containers with labels and containers with labels that did not contain all appropriate information. Radiation protection personnel promptly corrected the labeling inconsistencies after being notified.

Cabinets, tool boxes, and gang boxes containing tools or equipment were posted as

" radioactive material, tools and equipment." Radiation protection management was l

questioned why no radiologicalinformation was present on the labels and responded that tools in use had less tb 50,000 dpm direct activity with no smearable activity and workers were aware of the limits. The inspectors questioned several workers on the acceptable radiation limits for tools, with only one worker correctly identifying the limits.

Radiation protection management was informed of the workers response to the

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inspectors questions. They indicated that radiological information would be added to the labels and that workers would be reinformed of the radiologicallimits for tools.

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Conclusions The radiologYal posting of facilities and equipment was effective. Radiological housekeeping was good with the exception of the LTD maintenance shop, which was effectively addressed by the licensee. Labeling of containers was generally effective, with the inspector identified deficiencies promptly corrected by radiatica protection personnel.

R2.3 Radwaste Eauisment initiatives a.

Moection Scoce (IP 84750)

The inspectors reviewed the initiatives underway in radwaste to bring the floor drain and waste ccliector systems back to normal processing ficw paths b.

Observations The inspectors reviewed a list of the top eight work requests, which were needed to achieve separate flow paths for the floor drain and waste collector systems. Currently, one system can be operated at a time as the only operable pump and filter are the ones shared by the systems. Upon completion of the eight work requests, both systems would be available in addition to the shared backup pump and filter. The radwaste coordinator indicated that work had begun on the requests and discussions were

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' ongoing regarding a revised, more timely work schedule for completion of the eight l

priority work requests while both units were shutdown. The current schedule indicated l-the majority of the work would be completed in March 1998, with one valve not schedule l

for repair until June 1998.

The coordinator was also prioritizing the remaining radwaste work requests with the primary goal of repaliing operating equipment and abandoning old equipment. This v ould include electrical work, lighting issues, leak:ng valves, and breakers that periodically trip. Once prioritizad, a work schedule was to be developed.

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Conclusions The licensee was taking good corrective actions to bring the radwaste systems back to their normal flow paths and reduce the number of outstanding work requests, X1 Exit Meeting Suminary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on January 16,1998. The licensee acknowledged the findings presemed,

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The licensee did not identify any information discussed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Baumer, Regulatory Assurance A. Chernick, Regulatory Assurance Supervisor D. Cook, Plant Manager D. Kallenbach, Radiation Protection Scheduler T. Kirkham, Lead Health Physicist-Technical E. Kraft Jr., Site Vice-President L. Pearce, General Plant Manager G. Powell, Radiation Protection Manager W. Schmidt, ALARA Cooroinator NEC L. Collins, Resident inspec'or

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K. Walton, Resident Inspector l

lNSPECTION PROCEDURES USED IP 83750 Occures'lonal Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ITEMS OPENED, CLOSED, AND DISCUSSE Ooened 50-254/265-98002-01 VIO Failure of Radiation Protection to issue faceshields used in contaminated areas.

50-254/265-98002-02 NCV Release of material outside the RPA with direct radiation measurements above background.

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50-254/265-98002-03 IFl T e cor.dition of portable instrument calibration standards

.id the "as found* readings of portable instruments with G-M detectors being outside tolerance limits during calibrations.

Closed 50-254/265-98002-02 NCV Release of material outside the RPA with direct radiologicd contamination above background.

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USED LIST OF ACRONYMS ALARA As Low As Reasonably Achievable CRPT Contract Pediation Protection Technician dpm disintegrations per minute FSAR Final Safety Analysis Report GM-Geiger Mueller LTD Laundry-Tool Decon mR/hr milliroentgen per hour NCV Non-Cited Violation NRC Nuclear Regulatory Commission PlF Problem Identification Form -

RP Radiction Protection RPA Radiologically Posted Area RPT Radiation Protection Technician RWP Radiaticn Work Permit VIO Violation l

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O LIST OF DOCUMENTS REVIEWED ANSI, N323-1978, Radiation Protection Instrumentation Test and Calibration

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QCAP 0600-01, Revision 1, Control of Materials for Unconditional Release From Radiologically Posted Areas QCAP 0000-04, Revision 1, Exit Authorization for Vehicles and Materials Fmm the Protected Area QCRP 0300-07, Revision 3, DAM 4/3 Calibration OCRP 0600-04, Revision 1, ALARA Action Reviews

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OCRP 5010-01, Revision 7 Radiological Posting & Labeling Requirements QCRP 5310-04, Revision 4, Issuance & Maintenance of Face shields QCRP 5500-1, Revision 3, Respiratory Protection Program Administrative Guide s

QCRP 6200-05, Revision 1, Writing Radiation Work Permits

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PIF 96-2371, Uncontrolled Radioactive Material-Cement Blocks PIF Q1998-00142, Five Face shields Found in Contaminated Area Radwaste Top 8 Work Requests RV'P #: 983250, Revision 0,0-2006 Waste Collector Pump: Rtpair Pump / Coupling /VIBS RWP #: 981033, P.evision 0,1-1301-16 Valve: D'sassemble/ Repair / Reassemble / Test RWP #: 980031. Revision 1, U-13501 Main Condenser. Tube Cleaning RWP #: 981020, Revision 0, U1 ERV/SRV/ Target Rock Valves: Repair / Replace RWP #: 983064, Revision 1, U1 Turbine Bypass Valves: Asbestos Abatement RWP #: 981030, Revision 0, U1 Snubbers: Drywellinspection/ Replacement RWP #: 983025, Revision 0, Rad Waste Collector Tank Leak Repair

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