IR 05000373/1986023

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Insp Repts 50-373/86-23 & 50-374/86-22 on 860527-0603.No Violation or Deviation Noted.Major Areas Inspected:Solid Radwaste Mgt & Transportation Programs
ML20206Q950
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 06/26/1986
From: Greger L, Miller D, Paul R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206Q945 List:
References
50-373-86-23, 50-374-86-22, NUDOCS 8607070038
Download: ML20206Q950 (11)


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U.S. NUCLEAR REGULATORY COMISSION

REGION III

Reports No. 50-373/86023(DRSS); 50-374/86022(DRSS)

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Docket'Nos. 50-373; S0-374 Licenses No. NPF-11; NPF-18 Licensee:

Commonwealth Edison Company'

Post Office Box 767 i

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Chicago,-IL 60690.

Facility Name:

LaSalle County Nuclear Station, Units 1 and 2 Inspection At:

LaSalle County Station, Marseilles, IL Inspection Conducted: May 27-30 and June 2-3, 1986 S!8h Inspectors!

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Date D. E. Mille (o -M -8G, Date i

Approved By:

L. R.

ejer, Chief 6-A -6G

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Facilities Radiation Date Protection Section Inspection Summary-Inspection on May 27-30 and June 2-3, 1986 (Reports No. 373/86023(DRSS);

374/86022(DRSS)

Areas Inspected:

Routine unannounced inspection of the solid radwaste management and transportation programs.

Also reviewed were corrective actions for past inspection findings, open items, selected IE Information Notices, an airborne radioactive materials occurrence, and a review of. progress made concerning the radiation protection improvement program.

Results:

No violations or deviations were identified.

8607070038 860526 PDR ADOCK 05000373.

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DETAILS 1.

Persons Contacted

  • L. Aldrich, Rad / Chem Supervisor J. Andrews, Radwaste Document Coordinator
  • A. Bailey, Radwaste Shipping Coordinator
  • D. Berkman, Assistant Superintendent, Technical Services
  • R. Bishop, Services Superintendent

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S. Davis, Radwaste Coordinator

  • G. Diederich, Station Manager

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D. Hieggelke, ALARA Coordinator E. Huerta-Pavia, Health Physicist J. Lewis, Contamination Control Coordinator W. Luett, Staff Assistant

  • F. Ost, Health Physicist, Nuclear Services
  • R. Stobert, Quality Assurance Supervisor
  • M. Vonk, Lead Health Physicist

The inspectors also contacted several other licensee personnel including technicians, engineering assistants, foreman, and members of the technical staff.

  • Denotes those in the exit interview.

2.

General This inspection, which began at 9:00 a.m. on May 27, 1986, was conducted to examine the solid radwaste management and transportation programs.

Also reviewed were corrective actions for past inspection findings, open items, selected IE Information Notices, an airborne radioactive materials occurrence, and a review of progress made concerning the radiation protection improvement program.

Several tours of controlled areas were made to review postings and access controls.

The inspectors performed independent direct radiation and surface contamination surveys during the tours; licensee postings appeared appropriate.

3.

Licensee Actions on Previous Inspection Findings (Closed) Open Item (373/85025-04; 374/85026-04):

Solid radwaste remote barrel monitor.

See Section 4 for c, tails.

(Closed) Open Item (373/85025-05; 37,/85026-05):

Calculational method for beta emitters in solid radwaste.

See Section 4 for details.

(0 pen) Open Item (373/85014-02; 374/85014-02):

Alteration of SGTS sampling lines. The licensee has written appropriate work orders and design review requests, and funding has been approved.

Vendor scheduling is in progress.

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(Closed) Open Item (373/85036-01; 374/85037-01):

Review reduction of extended RWP's.

The licensee has reduced the number of extended RWP's for radiological controls and dose tracking for specific recurring tasks and routine tours from 66 to 7.

The inspectors reviewed the RWP's and found they were adequate.

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(Closed) Noncompliance (373/85014-01B; 374/85014-018:

Failure to make a personal contamination survey after exiting a step-off pad area.

First line supervisors have received additional training in their responsibi-lities for ensuring that workers observe proper radiological practices and i

adherence to radiological protection requirements.

The inspectors observed

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no significant problem with persons improperly frisking during an inspec-tion performed in November 1985 (Inspection Reports No. 50-373/85036; 50-374/85037) or during this inspection.

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(Closed) Noncompliance (373/85036-02; 374/85037-02):

Failure to comply with

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high radiation area procedural requirements.

In addition to existent requirements to provide adequate control over high radiation areas, the

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licensee initiated a procedural revision which requires that individuals

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who are responsible for the high radiation area access key or keycard sign the HRA access log upon return of the key or keycard.

The inspectors

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reviewed the logs, and with the exception of a few discrepancies, it appeared the keys are adequately returned and controlled.

(Closed) Open Item (50-373/85036-03; 50-374/85037-03):

Problems noted during surveillance / plant tours.

Additional friskers, frisker booths, and whole body frisker-stations have been located throughout the station nearer to step-off pads.

The location of the friskers has resulted in more effective use of the friskers, and adherence to frisking requirements.

(Closed) Open Item (50-373/84031-02; 50-374/84038-02):

Use of urinalysis to

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determine whole body intake of radioactivity.

The licensee uses a corporate

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developed generic procedure, " Determination of Internal Body Burdens from

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Urinalysis," to describe the calculational methodology used to represent

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estimates of internal body burdens and MPC-hours from urinalysis.

4.

Solid Radioactive Waste

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The inspectors reviewed the licensee's solid radioactive waste management program, including:

determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality assurance programs; adequacy of required records, reports, and notifica-tions; and experience concerning identification and correction of

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programmatic weaknesses.

Several tours of packaging and storage areas

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and the radwaste solidification system control room were made. Audits

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are discussed in Section 6.

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Solid radioactive waste consists of spent resins, filter sludges, evaporator bottoms, and dry active wastes (DAW).

If compactible, DAW is placed into 55 gallon steel drums and compacted; if not compactible, DAW is packaged in 96-cubic -foot steel bins.

The DAW compactor has self-contained filtered ventilation.

Evaporator bottoms (wet waste) are solidified using a Stock Equipment cement solidification system.

The system consists of a drum preparation station, drumming station, radwaste building bridge crane, storage area, and provisions for a remote radiation readout.

Programmed amounts of waste and cement are added to drums through a bunghole in the nonremovable top of the drum.

After the drum is tumbled, more waste and cement can be added and the drum retumbled to promote uniform mixing and solidification.

Measurements are made to determine drum radiation levels, curie content, and contamination levels.

Until March 15, 1986, bead resins and filter sludges (powdered resins) were solidified using the stock equipment.

During the period January 30, through March 14, 1986, powdered resins were transferred from decant tanks to the drumming units for solidification; 144 drums of processed powdered resin resulted.

During routine QA checking of selected processed drums, free standing liquid was found in some.

The licensee stopped processing; started investigating to identify the problem, and continued drum inspection to identify those with free standing water.

The contact dose rate on the drums ranged from 1 to 11 R/hr.

Because an average of seven drums result from processing of a powdered resin decant tank, and the last drum from each batch has the highest probability of free standing water (because of process methods), the licensee first inspected the last drum in each batch.

If the last drum in the batch was solidified, the remainder was assumed to be solidified.

If the last drum had free standing water, the complete batch was suspect.

To date, 54 drums have been inspected, 14 of which were found to have free standing water; 27 drums remain to be inspected.

According to licensee records, about seven person-rem has been received inspecting the 54 drums; the inspection is performed with the drum in a shielding container constructed under the direction of the ALARA

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Coordinator.

The drums that have free standing water remain in storage; the licensee is investigating possible methods of removal of the water and/or addition of solidifying agents.

The licensee has determined that problems with decant tank level indicators are the probable cause of incomplete solidification in some drums.

False level indications can result in not enough liquid being decanted in the decant tanks, too much liquid being fed to the drumming units, and the resulting incomplete solidification in the drums.

The licensee is investi-gating the level indication problems and possible alternate methods of resin packaging for disposal.

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During a previous inspection (Inspection Reports No. 373/85014; 374/85015),

it was noted that although the radwaste facility had an installed shielded drum survey booth, the bocth was not being used because the licensee had not installed the remote readout system for which the booth was designed.

This issue was raised by the inspectors as an ALARA concern.

Since then, the remote monitoring system for the booth has been obtained, installed, calibrated, and made operational.

The inspectors observed the monitoring system, reviewed the calibration method and procedure, and discussed the systems operational use with licensee representatives.

No problems were identified.

This open item is considered closed.

(373/85025; 374/85026-04)

During a previous inspection (373/85025; 374/85026), the inspector noted that the calculational method used to determine curie content in packaged drums did not incorporate certain beta emitters.

Since then, the method of calculation has been altered.

Beta emitter curie content is calculated from scaling factors provided by a contractor who analyzes samples from the station's waste streams.

Beta emitter content is keyed to gamma isotope presence / quantities; the gamma isotopic analyses are performed at the station.

The inspectors reviewed the revised calculational methods; no problems were noted.

This open item is considered closed.

(373/85025-05; 374/85026-05)

No violations or deviations were identified.

5.

Transportation of Radioactive Materials The inspectors reviewed the licensee's of radioactive materials transportation program, including:

determination whether written implementing precedures ar.e adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses.

Audits and surveillances are discussed in Section 6.

Shipments of low specific activity (LSA) waste to licensed burial sites are the major transportation activity.

Contaminated solid trash (paper, plastic, wood, metal, discarded clothing, etc.) is either packaged in 55 gallon steel drums and compacted or packaged in large metal boxes if the materials are not compactible.

New DOT Specification 17-H drums are used which meet the 00T 7-A performance specification.

Liquid wastes consisting of resins, filter sludge, and eva? orator bottoms are solidified using a Stock Equipment Company cement solidification system.

Records of radioactive shipments made during 1986 to date were selectively reviewed for compliance with 49 CFR 172-173 and 10 CFR 71.

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i On May'5, 1986, the State of Washington notified LaSalle Station that a

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j radwaste shipment from LaSalle contained a deformed drum when received at US Ecology's burial site on May 5, 1986.

The shipment-departed LaSalle Station on May 1, 1986. The State of Washington cited LaSalle Station for j

a-violation of US Ecology's State of Washington Radioactive Materials l

License No. WN-1019-2, Condition 27(f); no violation of U.S. Department

of Transportation requirement was identified.

The State of Washington did j

not withhold LaSalle Station's authorization to ship to the Richland,

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Washington burial site, but recommended that corrective actions be taken j

to assure: future compliance with applicable State regulations. The

licensee's proposed (draft) corrective actions include a requirement for i

a management person to inspect DAW drums before loading; and to provide additional training to stationmen concerning DOT and burial site require-

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ments, and precautions to take when packaging DAW.

Implementation of the

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licensee's corrective actions will be reviewed during a future inspection.

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(0 pen Items No. 373/86023-01); 374/86022-01 The information on the

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shipping papers appear to satisfy.NRC, DOT!)and burial site requirements.

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l No violations or deviations were identified.

I 6.

Audits i

The inspectors reviewed onsite and offsite audits of the radwaste-i management program conducted during 1986 to date.

Extent of audits, qualifications of auditors, and adequacy of corrective actions were

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reviewed.

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One onsite quality assurance audit was performed; the audit subjects were i

mainly compliance with selected radwaste packaging and shipping procedures.

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One finding was made concerning inability to verify that one batch of

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solidified waste was tested for solidification (lack of free standing

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water) before the drums were shipped.

The corrective action was to revise

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Procedure LOS-WX-SRI to include a formal tracking mechanism to assure that testing for solidification is done in accordance with requirements.

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The corrective action has been completed; the onsite quality assurance L

l department considered the corrective actions acceptable, and has closed-l the finding. A surveillance check of each radwaste shipment was made by i

l QA representatives; one truck was rejected because of bald tires.

Three

surveillances of radwaste handling and packaging were performed; observa-

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tions concerning housekeeping, step-off pad maintenance, and compliance

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with good health physics practices were made; corrective actions for the j

observations have been reviewed by QA representatives, considered adequate, l

and closed.

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One corporate audit was performed; the audit included review of SNM i

shipment records and observation of a radioactive materials shipment including packaging, surveys, paperwork, and QA activities.

There

j were no findings.

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

No violations or deviations were identified.

7.

Rad / Chem Improvement Plan The inspectors reviewed the status of the Rad / Chem Improvement Plan which was developed to strengthen the weaknesses identified in the area of radiological controls, and to improve the performance of the program.

Improvements which have been implemented since the previous inspection (Inspection Reports No. 50-373/85036; 50-374/85037) include:

installation of nine beta sensitive whole body frisker booths, installation of five gamma sensitive IRT portal monitors to replace the Eberline hand and foot monitors, appointment of a leaC RCT foreman, installation of 86 of the 139

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high radiation door aiac,T. devices, the remainder of which should be completed by June 30, 1986, use of the standard technical specifications for radiological controls over high radiation areas, implementing additional restrictions on control of high radiation area key and keycards, installation of the remote waste barrel monitoring system, and using contractor film badges with the security badges.

Based on the inspectors'

review of the Improvement Plan, it appears that the significant weaknesses have been sufficiently addressed.

8.

External Exposure Control and Personal Dosimetry The inspectors reviewed the licensee's external exposure control and personal dosimetry program, including:

changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine needs; and required records, reports, and notifications.

The only significant change in the licensee's external exposure measurement and control program is that personal film badges are now issued and returned with the security badge at the gatehouse.

This change was made to decrease employee misuse of the film badge.

The inspectors selectively reviewed the exposure records, including film badges and self-reading dosiraeter results.

The records indicate that no persons exceeded regulatory requirements.

The occupational external dose for the station in 1985 was 640 person-rem, 392 of which was received by contractor employees.

The occupational exposure dose through May 25, 1986 was 630 person-rem, about 120 person-rem above the projected dose for the period.

The increased exposure'was primarily caused by a major change of scope in the Unit 1 refueling outage.

No violations or deviations were identified.

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9.

Radiation Occurrence Reports Radiation Occurrence Reports (RORs) for the period January through May 16, 1986 were reviewed.

The licensee trends occurrences to determine repetitive violations and violators.

The inspectors review of RORs indicated one repetitive occurrence concerning routine survey findings of

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' radioactive material in clean waste containers before the contents were

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released.to an uncontrolled area.

The licensee is reviewing corrective

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actions.to be taken to ensure workers properly segregate waste before i

disposal.

The inspectors noted that the licensee continues to give sufficient i

management attention and investigation to followup of RORs.

It was j

also noted that most RORs are event oriented and not initiated as a result

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of problems identified by workers in the field.

Licensee representatives

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indicated that many problems are identified in the field by members of their' staff and resolved at the time of identification.

However, based

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on inspector observations, discussed in Section 10, it appears that either i-the licensee is not adequately identifying such problems or that RORs are

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not being written for identified problems.

This matter was discussed at i

the exit interview and was also discussed during a previous inspection

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(Inspection Reports No. 50-373/85014; 50-374/85014).

No violations or deviations were identified by the inspectors.

l 10.

Surveillance - Plant Tours The following problems were identified during tours of the plant:

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On one occasion a contract worker who had removed his protective

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clothing in accordance with step-off pad instructions exited-from the

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step-off pad area without first performing a personal contamination

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survey. The inspector discussed this matter with the worker who i

stated that although he was aware of the requirement to frisk before l'

changing into his personal clothing, he normally performed a frisk j

after he changed into his personal clothing.

He indicated that in

the future he would frisk in accordance with requirements.

t On three separate occasions workers failed to follow posted

j instructions concerning the use of a portal monitor.

The inspectors i

discussed this matter with the workers who stated they were unaware

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that the monitor was operating because it was recently inoperable for

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This portal monitor is located downstream of the

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frisker/frisker booths used to meet SOP survey requirements, and is used as an additional monitoring device.

Posted instructions concerning frisker locations at most SOPS were l

correct, however, at some SOPS there were no instructions.

l On two separate occasions there were instances of bagged and unbagged

j respirators found on top of ductwork in the instrument decon room.

The unbagged respirators apparently had been used but not returned

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to the respirator station.

The licensee will review this matter to

determine if there is a significant weakness-in.the respirator distri-i bution and return program.

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Protective clothing was found throughout the Unit 1 reactor building,

especially in the changeout area near the entry into the Unit 1 F

drywell.

In most cases, the protective clothing appeared to be unworn but not returned to the clothing bin; however, in some cases

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it appeared the protective clothing had been worn and not properly

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i placed into the designated hamper receptacles.

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l Several friskers were found inoperable.

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Based on these observations and discussions with the RPM, it appears that

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Rad / Chem staff plant surveillance and staff identification of problems

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needs improvement.

This matter is discussed at the exit meeting.

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11.

Elevated Contamination on the Refueling Floor and in the Unit 1

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Reactor Building i

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The inspectors reviewed the circumstances concerning elevated floor and I

horizontal surface contamination levels on the refuel floor and other j

Unit I reactor building floors during the Unit 1 refueling outage.

i Contamination levels ranged up to 5000 dpm/100 cm2 beta gamma on the main j

floor of the reactor building, to 50,000 dpm/100 cm2 beta gamma on the-refueling floor.

The contamination was identified when persons frisking i

i themselves after they had completed their work activities and upon exiting

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the refuel floor found personal contamination levels ranging from 1000-2000 dpm/100 cm2 beta gamma.

Followup, smear surveys showed extensive i

areas of the reactor building were contaminated. A constant air monitor l

(CAM) operating on the refueling floor showed no increase in activity while o

the workers were performing their tasks.

However, the CAM recorder showed

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i an increase about 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> earlier, while no work was being performed.

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Based on the results of the whole body counts of the stationmen working on j

the area, it appears no person was exposed to greater than one MPC-hour.

i As a result of the investigation into this problem, it appears that

elevated contamination and airborne levels resulted from a ventilation

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problem either caused by a differential pressure between Unit 1 and Unit 2, i

or by opening of the reactor building outboard main steam isolation valve i

room door.

The open door alters the air-flow in the reactor building and j

causes air flow from the rractor cavity to the refuel floor and down

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through the equipment hatcaes to lower elevations of the_ reactor building.

The Unit 1 cavity was opea during this period as were the equipment ~

hatches; there was no work in progress on'the refuel floor at the time,

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and according to the CAM, this ventilation problem occurred several hours-i before work began.

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As a result of the ventilation problem, higher levels of contamination apparently settled in the area of'the refuel floor where the workers had

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been scheduled to decontaminate. The licensee was not aware of the changed l

radiological conditions, so subsequently when the workers performed their i

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decontamination activities,~ scoe of the contamination may have gone airborne which caused the personal contaminations.

Because the increased contamina-

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tion levels were unexpected and unknown by the licensee, no precautions l

were taken to prevent personal contamination.

Smears taken in the area earlier on the same day indicated much ' lower levels of contamination.

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The inspectors review of the incident identified several problems.

Air samples' taken during the previous two days were used to determine i

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airborne radiological conditions for the work activities scheduled

.ir. the Unit 1 cavity and refueling ~ floor.

However, air samples were'

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not taken in the area during those activities to determine radio-

' logical conditions.

Nor was the CAM ideally located near the area to

determine changing radiological conditions.

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The CAM chart was not reviewed before the work activities began.

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i it had, the licensee would have recognized there had been a change in airborne-radiological conditions earlier in the evening, and taken

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appropriate action.

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The results of the CAM filter which collected the increased airborne activity resulting from the ventilation problem, was not used to determine what the radioactive concentrations were when the evolution

occurred.

The use of this information after an evolution has occurred will aid during the investigation of the event, and is a good health

j physics practice.

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The inspector discussed these problems with the licensee during the

inspection and exit interview, and was informed that this matter would be

fully investigated and corrective actions to strengthen these weaknesses j

would be taken. The corrective actions will be reviewed at a future-j inspection (50-373/86023-02; 50-374/86022-02)

I 12.

Use of Area Constant Air Monitors l

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The license uses area constant air monitors (CAMS) to sample airborne

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particulate and halogen activity within specified work areas inplant.- The i

particulate filter is continuously monitored and the detected particulate

activity is recorded on strip charts on the CAMS; the halogen filter must

be removed and counted with other detection equipment.

These CAMS, not i

required by technical specifications, are described in the FSAR as trending i

l devices; no calibration ~is specified; only' source checks are specified.

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Alarm setpoints are generically specified in the FSAR, with'no indication i

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of the setpoints correlation to MPC-hours.

During the review of the

refueling floor airborne activity event, the inspectors noted that the

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CAM recorded information was used by the licensee only to establish the

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approximate' time and duration of the event.

No attempt was made to use j

the recorded information, or to analyze the sample filter paper, to

estimate airborne concentration during the event, nor does'there appear

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to be any requirement to do so.

During discussions with licensee

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l personnel, they did not appear knowledgeable concerning the CAMS.

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particulate detection efficiency or the rationale for the established alarm setpoint value.

The inspectors discussed with the licensee the desirability of investigating the area CAMS' programmatic use to determine if improvements in calibration and setpoint methods would increase the value of these monitors / samples as health physics tools.

13.

IE Information Notices The inspectors reviewed licensee action in response to the following selected Information Notices.

These actions are considered adequate.

No. 85-81:

Problems Resulting In Erroneously High Reading with Pansonic 800 Series Thermoluminescrent Dosimeters (TLD's). The licensee does not currently use TLD's, however, they do intend to use Panasonic TLD's in the near future. The corporate health physics group has taken appropriate action in response to this Information Notice for other utility stations using the TLD.

The same actions will be taken for the LaSalle Station.

No. 85-42:

Loose Phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter Elements.

Same response as to No. 85-81 above.

No. 86-22:

Underresponse of Radiation Survey Instrument to High Radiation Fields.

The licensee has never used the Eberline Model ESP-1 with a MP-290 gamma probe.

These instruments will not be used until this matter is resolved.

14.

Ex_i,t Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection and summarized the scope and findings of the inspection activities.

The inspectors also discussed the likely informational contents of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.

The licensee did not identify any such documents or processes as proprietary.

In response to the inspectors' comments, the licensee:

a.

Stated that efforts will be made to improve the quality of the radiation protection staff's plant surveillances to identify, report and correct problems concerning radiological protection.

(Sections 9 and 10)

b.

Stated the corrective actions concerning the ventilation problem which probably caused the increased airborne activity in Unit 1 have been initiated.

(Section 11)

c.

Stated that a review of the programmatic use of the area CAM's will be made.

(Section 12)

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