IR 05000373/1986038
| ML20213E453 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/03/1986 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20213E435 | List: |
| References | |
| 50-373-86-38, 50-374-86-38, NUDOCS 8611130172 | |
| Download: ML20213E453 (8) | |
Text
-
-
__
-
_____
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_
.
.
- U.S. NUCLEAR REGULATORY COMMISSION
REGION III
.
Reports No. 50-373/86038(DRSS); 50-374/86038(DRSS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Commonwealth Eoison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
LaSalle County Station, Units 1 and 2 Inspection At:
LaSalle County Station, Marseilles, IL l
Inspection Conducted:
S tember 22-26, and October 9, 1986
~ f l3 [d
/
Inspector:
.A.Pauf-
/
/
Date
'
Approved By:
L. R. Greger, Chief
- ~3 4 Facilities Radiation Protection Date Section Inspection Summary Inspection on September 22-26, and October 9,1986 (Reports No. 50-373/86038; 50-374/86038(DRSS))
Areas Inspected: Routine unannounced inspection of the operational radiation protection program including organization and staffing, ALARA, control of radioactive materials and contamination, and radiation occurrence reports. Also reviewed were past inspection findings and licensee event reports.
'
Results: One violation was identified in one area (failure to make an adequate survey in accordance with Part 20 requirements - Section 13).
8611130172 861104 PDR ADOCK 05000373 G
- - _ _ - _ - _ _ _ _ - _ _ _ _ _ _ _
,
,
__
_
__
.
-
_
_
.
-
,
.
DETAILS
'1.
Persons Contacted
-
- L. Aldrich, Rad / Chem Supervisor
,
- R. Bishop, Services Superintendent G. Diederich, Station Manager
D. Hieggelke, ALARA Coordinator
J. Lewis, Contamination Control Coordinator i
W. Luett, Staff Assistant I
- R. Stobert, Quality Assurance Supervisor
- M. Vonk, Lead Health' Physicist d
The inspector also contacted several other licensee personnel including technicians, engineering assistants, foreman, and members of the technical staff.
- Denotes those present at the exit meeting.
'
2.
General This inspection, which began at 8:30 a.m., on September 22, 1986, was conducted to examine the licensee's operational health physics program.
Also reviewed were past inspection findings, licensee event reports, and an incident concerning worker intake of radioactive material. One violation concerning failure to make an adequate survey to meet regulatory
requirements was identified.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (373/86023-03; 374/86022-03):
Rad / chem staff plant surveillance and problem identification needs improvement.
RCT foreman have been assigned specific responsibilities for plant surveillance. Time in plant surveillance goals have been established and are being tracked for all rad / chem personnel.
Health physicists have been instructed in their surveillance responsibilities.
(Close'd) Open Item (373/ES023-02; 374/86022-02): Measures to be taken to strengthen observed weaknesses found as a result of a contamination incident on the refuel floor. Corrective actions include maintaining water level under the grating in the reactor cavity during reassembly activities, installation of an additional supply and exhaust fan for Unit 1 to reduce the differential pressure between the reactor units, installation of a padlock to prevent inadvertent opening of the main steam isoittion valve room door, verification of the air flow direction on the refuel floor, initiation of an investigation of the air flow in the reactor building, and performance of an evaluation of the refuel floor CAM setpoints.
'
.
_ _ _ _ _ _ _ _ _ _ _
.
.
.
.
4.
Organization, Management Controls, and Staffing The inspector reviewed the licensee's organization and mar.agement controls for the radiation protection program, including changes in the o~ganiza-tional structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.
Since previously reported in Inspection Reports No. 50-373/85036 and 50-374/85037, no significant organizational changes have been made. The two degreed professional health physicists who work for the lead health physicist and who were hired in 1985 have obtained more practical plant experience; the higher experience level has resulted in strengthened direct surveillance of work activities in controlled areas; this is a significant improvement over the conditions which existed about one year ago when the professional HPs reporting to the lead HP were relatively inexperienced. The licensee currently has a low staff turnover rate.
No violations or deviations were identified.
5.
Training and Qualification Specifically reviewed was RCT retraining and stationman initial radiation protection training.
The licensee is obtaining INPO accreditation for the RCT retraining program.
The program consists of 2.5 days training each quarter for eight quarters (two year recycle) and is tailored to meet training module requirements and specific RCT needs. Tests are given for each training module; a grade of 70% is required for passing. The licensee has recently formed a training committee which includes two RCT's to evaluate and determine RCT training needs; the licensee's RCT retraining program appears improved.
The current training program for stationmen, including classroom radiation protection manual review, is not a prerequisite for stationman qualification and is not always provided.
Stationman DJT is directed by stationmen foreman to the foremans satisfaction.
Except for radwaste training, no specific required qualification program has been developed for stationman.
The inspector discussed with the licensee the importance of providing radiation protection training for stationmen. The licensee has been awaie of the weaknesses associated with radiation protection training for stationman, and is considering an upgrading of the program. This matter was discussed at the exit meeting and will be reviewed at a future inspection.
(50-373/86038-01; 50-374/86038-01)
No violations or deviations were identified.,
6.
External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure 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 measurement and control program is that TLD's are now used instead of film badges. The licensee reads the TLD's with an automated Panasonic TLD system. The licensee's TLD program is NAVLAP certified. The system is essentially the same as that used by other CECO stations and has been reviewed by NRC inspectors at those stations. Based on those reviews, it appears the licensee has an adequate calibration, processing, and QC/QA program.
The inspector verified that the licensee is using appropriate NRC guidance which specifies that whole body dose be determined using a maximum absorber
thickness of 1000 mgm/cm when eye protection is provided. Safety glasses (> 700 mgm/cm ) are required for entry into the radiologically controlled
areas. The itcensee's personnel dosimetry system uses an absorber thickness of 1000 mgm/cm' for whole body dose determination. No problems were noted.
The inspector selectively reviewed the licensee's exposure records. The i
records indicate that no persons have exceeded regulatory limits. The occupational dose for the station in 1986 to date is about 800 person-rems.
No violations or deviations were identified.
7.
Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including:
changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports and notifications; and effectiveness of managemant techniques used to implement these programs, including experience concerning self-identification and correction of program implementation weaknesses.
The licensee's program for controlling exposures has not changed since described in Inspection Reports NO. 50-373/85036; 50-374/85037. The licensee has recently taken steps to strengthen the radiological air sampling program. These steps include increased frequency, kind, evaluation, recording, and location of air samples, and assignment of responsibility for insuring implementation of the improved program.
The inspector selectively reviewed whole body count results for 1986 to date; it appears no worker has exceeded the 40 MPC-hour control measure.
No violations or deviations were identified.
8.
ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; and establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
_
__
_
_
.
.
.
The licensee's ALARA program is described in Inspection Reports No. 50-373/85014; 50-374/85014; no significant changes have occurred in the program or its implementation.
Procedural revisions have been made concerning the criteria for initiating formal RWP ALARA reviews, and enhanced emphasis is placed on following job progress to assess the effectiveness of ALARA actions.
Lessons learned from ALARA evaluations will be modified to improve communications to improve timeliness of completion.
A Modification Review Committee has been recently developed to review the status of the five year plant modification schedule and to review requests for modifications.
The A.LARA coordinator has been appointed to this committee. This appointment will strengthen the ALARA program because the coordinator will have early notification of pending work, and he can be more effective in performing pre-job reviews. This programmatic change is expected to improve the ALARA program.
No violations or deviations were identified.
9.
Audits The inspector reviewed onsite audits of the radiological control program conducted during 1986 to date.
Extent of audits and adequacy of corrective actions were reviewed.
An onsite quality assurance audit, performed in June 1986, identified two findings and three observations concerning health physics programmatic activities; corrective actions for the findings and observations have been completed, reviewed by QA representatives, were considered adequate, and closed.
An industry audit was performed; the audit findings concerned management and supervisor involvement to ensure worker adherence to radiation protection procedures, ALARA pre and post-job analysis, limitation on use of respirators, the station air sampling program, and stationman work practices. According to a review of Action Item Reports (AIR's) issued for each finding, it appears the licensee has taken sufficient corrective actions.
No violations or deviations were identified.
10. Radiation Occurrence Reports Radiation Occurrence Reports (RORs) for the period May through August 1986 were reviewed. The licensee trends occurrences to determine repetitive violations and violators.
The inspector noted that the licensee continues to provide sufficient management attention to followup and investigation of RORs.
It was also noted that more ROR's are initiated as a result of problems identified by workers in the field rather than as the result of an event.
Licensee representatives indicated that more worker identified ROR's are the result of increased staff attention to potential problems during performance of surveys and surveillances.
y
-
w w
.
.
'
No violations or deviations were identified.
11. Rad / Chem Improvement Plan
'
The inspector reviewed the status of the Rad / Chem Improvement Plan which was developed by the licensee to strengthen identified radiological controls weaknesses, and to improve the overall performance of the program.
Improvements which have been implemented since the previous inspection (Inspection Reports No. 50-373/86023; 50-374/86022) include:
installation of IPM-7 frisker booths, approval for installation of cement block frisker
, stations, completion of high radiation door (HRA) alarm devices, and initiation of a preventive maintenance program for HRA door hardware. With these actions, the licensee has essentially completed the Rad / Chem Improvement Program.
No violations or deviations were identified.
12. Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effective-ness of survey methods, practices, equipment, and procedures; adequacy of review and disseminatien of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
The licensee has continued to implement the radiological housekeeping and contamination control program as part of the station ALARA program.
Records indicate that in addition to concentrating on contamination control, the
licensee is actively pursuing a reclamation program for reducing total contaminated areas; this is evidenced by the total plant contamination area having been reduced from 45 percent to 36 percent between January and September 1986.
No violations or deviations were identified.
13. Workers' Intake of Radioactive Material The inspector reviewed the circumstances surrounding an incident in which two workers received an intake of radioactive material while working in the control rod drive (CRD) repair room on June 16, 1986. The inspector contacted health physicists and plant management personnel, and reviewed radiation protection records including bioassay results, survey results, and the results of the licensee's investigation of the incident.
On June 16, 1986, an employee who had been working on a contaminated pump bearing in the CRD repair room alarmed a whole body frisker (IPM-7). The worker was directed by RCT's to go to the personnel decontamination room where small quantities of radioactivity were thought to be detected on two locations on the trunk of his body. No nose swabs were collected from the individual during this survey. The worker was then instructed to have a whole body count (WBC), the results of which indicated an intake of about
.
200 nanocuries of cobalt-60 and 200 nanocuries of manganese-54. Two other
-
,- _
.
~
.
.
employees who had worked on the pump bearing with the worker who received
-
the intake were requested to have WBCs; the results of their WBCs indicated one of the two persons received an intake of 75 nanocuries each of cobalt-60 and manganese-54. The activity deposition was due to ingestion or an inhalation of material which translocated rapidly to the GI tract.
In both cases, it appears the material was detained in the GI tract for three to four days before being eliminated. The licensee assessed that the intakes did not exceed the 10 CFR 20.103 forty MPC-hour control measure. The inspector agreed with the assessment.
In reviewing this matter the inspector noted that according to the employees, they worked for approximately two hours reassembling a contaminated pump bearing before taking a break. This job was performed under an RWP and the workers indicated they wore RWP required protective clothing (PC's), whole body frisked themselves after removing their PC's at the step off pad, and found no radioactivity on their person during the frisk survey.
Respirators were not worn for the reassembling phase of the job. Plastic face shields were used for eye protection against beta activity. No air samples were running at the time the intakes apparently occurred.
Smear surveys performed in the CRD work area subsequent to the employees'
2 on the intake indicated loose contamination levels up to 80,000 dpm/100 cm
plastic face shields, 200,000 dpm/100 cm inside a hot tool box, 100,000
2 dpm/100 cm on the outside of the pump seal casing, 200,000 dpm/100 cm on 2 on a chain fall.
the inside of the pump seal casing, and 10,000 dpm/100 cm The pre-job surveys of the area, performed on June 13, 1986, (three days before the intakes) did not identify the loose contamination on the above noted items (including the plastic face shields), nor was the licensee aware that face shields located in the CRD area were being reused by CRD workers. These pre-job surveys were inadequate in this case to ensure that individuals would not be permitted to intake radioactive material in quantities greater than 10 CFR 20.103 limits, as required by 10 CFR 20.201(b). (50-373/86038-02; 50-374/86038-02)
Although the workers may have received the intake as a result of contact with the contaminated items, the mechanism by which the actual ingestion /
inhalation occurred could not be determined; nor was it established if the workers had violated RWP requirements or used poor radiological work practices.
As a result of this incident, the licensee has strengthened the radiological air sampling program, issued a policy requiring surveys of plastic face shields before reuse, and instructed health physics foremen to ensure adequate pre-job and routine surveys are performed.
The corrective actions appear adequate to prevent recurrence.
One violation was identified.
-
._
-_ _ ____________
,
.
.
'
14.
Surveillance; Plant Tours Based on several tours of the plant, the inspector noted the following:
(1) No persons were observed violating procedural or regulatory requirements; this includes observation of workers performing activities under the requirements of six different RWP's.
(2) Independent radiation surveys performed by the inspector indicated radiation fields were posted as required. (3) A bag of contaminated waste, reading approximately 100 mR/hr at the surface, was found by the inspector outside of a roped off area designated for radwaste storage. A piece of copper tube was protrud-ing from the taped section at the top of the bag and was found to have loose contamination. The licensee subsequently surveyed the bag, smeared the copper tubing, and placed the bag into the designated area. The licensee stated that stationmen will be instructed to ensure all contaminated articles are fully enclosed within the bag and properly stored.
(4) Several smears of inplant horizontal surfaces, and outside of plant equipment, were taken by the inspector. With the exception of one smear reading in excess of 2000 dpm/100 cmr found on a cable tray in Unit 1, no other detectable levels of activity were found. The licensee has committed to decontaminate the cable tray and other horizontal surfaces of the plant during scheduled general plant cleanups.
No violations or deviations were identified.
15.
Exit Meeting
,
The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on October 9, 1986. The inspector summarized the scope and findings of the inspection. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such document / processes as proprietary.
In response to certain items discussed by the inspector, the licensee:
a.
Acknowledged the violation.
(Section 13)
b.
Stated that upgrading of the stationman training program will be considered.
(Section 5)
i c.
Stated that stationmen have been reinstructed in the importance of properly bagging, transferring, and storage of radioactive waste.
'
(Section 14)
l
,
i
- - - -
--
.--.1