IR 05000373/1987005
| ML20212N278 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 03/09/1987 |
| From: | Grant W, Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20212N271 | List: |
| References | |
| 50-373-87-05, 50-373-87-5, 50-374-87-05, 50-374-87-5, NUDOCS 8703120428 | |
| Download: ML20212N278 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/87005(DRSS); 50-374/87005(DRSS)
Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
LaSalle County Station, Units 1 and 2 Inspection At:
LaSalle County Station, Marseilles, Illinois Inspection Conducte :
February 3-19, 1987
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/ 9 /T7 Inspectors:
W. B. Grant
Date h. f. Y D. E. Miller S /9/67 Date Approved By:
L. R.
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/89 Facilities Radiation Protection Section Date Inspection Summary Inspection on February 3-19, 1987 (Reports No. 50-373/87005(DRSS);
50-3/4/8/005(UR55))
Areas Inspected:
Routine, unannounced inspection of radiation protection activities during refueling of Unit 2, including:
organization and management controls; audits; radiation protection procedures; training and qualification of new personnel; external exposure control; internal exposure control, ination; radiation occurrence reports; control of radioactive material and contam previous inspection findings and an allegation concerning the use of respiratory protection.
Results:
No violations or deviations were identified.
0703120420 870310 PDR ADOCK 05000373 O
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DETAILS 1.
Persons Contacted
- L. Aldrich, Rad / Chem Supervisor-R. Bishop Services Superintendent
- G. Diederich, Station Manager D. Hieggelke, Lead Health Physicist E. Huerta-Pavia, ALARA-Coordinator J. Lewis, Contamination Control Coordinator-W. Luett, Staff Assistant
- P. Manning, Assistant Superintendent, Technical ervices R. Stobert, Quality Assurance Supervisor
- J. Winchester, QA Engineer The inspectors also contacted several other licensee 3ersonnel including technicians, engineering assistants, foremen, and mem)ers of the technical staff.
- Denotes those present at the exit meeting on February 19, 1987.
2.
Genaral This inspection, which began at 8:30 a.m. on February,3, 1987,ities was conducted to examine the licensee's radiation protection activ during the Unit 2 refueling ard maintenance outage.
The inspection included numerous plant tours, review of posting and labeling, high radiation area controls, discussions with licensee and contractor personnel, independent radiation measurements by the inspectors, ion.
and review of an allegation concerning use of respiratory protect Housekeeping was generally very good.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (373/85030-03; 374/85031-04):
Formalize sampling programs to routinely monitor sump aump collections from the Interim Radwaste Storage Facility (IRSF).
)rocedure LOA OPL 01JM106, Guideline for Monitoring, Sampling and Disaosal of Water Run-Off Collected in the IRSF Sumps, Revision 0, whici was effective January 1987, closes this open item.
(Closed) Open Item (373/86038-01; 374/86038-01):
Radiation protection training for stationmen is not a prerequisite and is not always provided.
The training program for stationmen has been upgraded to include radiation protection training.
Stationmen who are not qualified by training are required to work under the direct supervision of a qualified person.
(SeeSection7).
e 4.
Organization and Management Controls The inspectors reviewed the licensee's organization and management controls for radiation protection, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of the program.
Audits are discussed in Section 5.
Recent Rad / Chem personnel changes include:
The Lead Health Physicist was transferred to Braidwood Station.
- A Health Physicist was promoted to ALARA Coordinator.
- A recently graduated Health Physicist was hired and is assigned
to the ALARA group.
The persons newly occupying the above positions are qualified in accordance with ANSI N18.1-1971 for their respective positions.
No violations or deviations were identified.
5.
Audits The inspectors reviewed onsite and offsite audits of the radiation protection program conducted from July 1, 1986 to date.
Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewed.
A semiannual offsite Quality Assurance audit of station activities was conducted on September 9-12, 1986.
Included were selected radiation protection and related training qualifications, and surveillance topics.
There were not significant radiation protection related findings.
Onsite quality assurance surveillances of radiation protection activities and housekeeping were selectively reviewed.
These surveillances included observation of compliance with radiological 3rotection requirements specified on radiation work permits.
No pro)lems were identified by the auditors who performed the surveillances.
The extent of audits and qualifications of auditors appear adequate.
No violations or deviations were identified.
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6.
Radiation Protection Procedures The inspector reviewed the following radiation protection procedures to determine if they are consistent with 10 CFR requirements, FSAR commitments, and good health physics practices.
No problems were noted.
LRP 1110-2, Revision 1, Notification and Reports LRP 1110-3, Revision 3, Effluent and Waste Disposal Semiannual Report Preparation and Submittal LRP 1120-1, Revision 5, Controlled Area Access LRP 1120-2, Revision 7, High Rad Area Access Control LRP 1130-1, Revision 5, Radiological Signs and Labels LRP 1160-4, Revision 5, ALARA Action Review LRP 1210-9, Revision 5, Timekeeping LRP 1210-10, Revision 6, Radiation Protection Exposure Timecard LRP 1250-1, Revision 5, Film /TLD Badge Issuance and Completion of
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Occupational External Radiation Exposure History Form'NRC-4 LRP 1250-2, Revision 7, Exposure Control LRP 1250-3, Revision 5, Personnel Dosimetry Placement Guidelines LRP 1250-5, Revision 7, Film Badge /TLD Spiking LRP 1250-6, Revision 4, Quarterly Onsite TLD Surveillance LRP 1250-10, Revision 3, Radiation Exposure Investigation Report LRP 1280-2, Revision 4, Dose Rate Surveys LRP 1340-5, Revision 8, Whole Bo<fy Count Routine Operations LRP 1340-10, Revision 2, Determination of MPC-Hours for WBC Data - Acute Exposure LRP 1360-6, Revision 8, Air Sampling of Suspected Radioactive Airborne Areas LRP 1360-7, Revision 4, Sampling Containment Air for Vent and Purge
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,j LRP.1360-8, Revision 3, Limiting Internal Exposure Utilizing MPC-Hour Accountability LRP 1410-1, Revision 4, Protective Clothing LRP 1420-1, Revision 3, Contaminated Personnel Effects LRP 1440-2, Revision 2, Movement of Radioactive Materials LRP 1470-3, Revision 2, Skin Dose Equivalent Determination from Skin Contamination LRP 1470-6, Revision 5, Personnel Decontamination LRP 1470-9, Revision 4, Area and Equipment Decontamination LRP 1710-1, Revision 2, Radiation Protection Information for Escorted Visitors 7.
Training and Qualifications of New Personnel The inspectors reviewed the education and experience qualifications of new plant and contractor radiation protection and chemistry personnel, and training provided to them.
Also reviewed was radiation protection training provided to other contractor personnel.
Training for contractor Radiation Protection Technicians (RPT) hired for the Unit 2 refueling / maintenance outage was conducted in December 1986.
A one-week (40-hour) training program was provided by the LaSalle station training department and rad / chem management personnel The program covered station rad / chem procedure implementation and health physics problems and practices.
Two 100 point exams were given after completion of the training; a passing grade of 70% was required for each.
The inspectors reviewed lesson plans, completed exams, and contract RPT resumes; no problems were noted.
In response to inspector concerns (373/86038-01; 374/86038-01), the licensee has upgraded the radiation protection training for stationmen.
The current training program for stationmen includes classroom radiation protection training plus practical factor qualification.
In addition, stationmen who are not qualified by training and by demonstration of practical factors are required to work under the direct supervision of a qualified stationman.
The inspectors reviewed the stationmen training program and records of qualification; no problems were noted.
Contractor personnel training records were selectively reviewed.
Contractors receive a basic eight-hour Nuclear General Employee Training (NGET) course. When required, contractors receive additional training commensuratewiththeirjobrequirements.
The inspector attended portions of an NGET class.
The classroom was of adequate size and well equipped.
The class size allowed for individual attention.
In general,
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l the presentations were of good quality and students participated.
An exam requiring a 70% passing grade was given after completion of each portion of the training session.
No problems were noted.
No violations or deviations were identified.
8.
External Exposure Control The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in program to meet outa0e needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports and notifications.
For the Unit 2 refueling outage, the licensee has established a satellite radiation protection office at the drywell entrance.
Two contract radiation protection technicians (RPTs) man a dosimetry desk where additional secondary dosimetry is issued, if needed, and where radiation dose received by individuals is recorded on dose cards.
The flow of materials and eguipment in and out of the control point is monitored by the RPTs as is personal frisking performed in an adjacent shielded frisking booth.
The inspectors selectively reviewed Radiation Work Permits (RWPs)
and associated radiation surveys, observed instructions provided to individuals when they sign RWPs, and observed work being performed under selected RWPs; no problems were identified.
The inspectors selectively reviewed exposure records including TLD and self-reading dosimetry results.
The records indicate that no person exceeded regulatory limits.
The occupational external dose for the station in 1986 was 897 person-rem.
No violations or deviations were identified.
9.
Internal Exposure Control The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
The licensee's program for controlling internal exposures includes the of surface and airborne radioactivity.use of protective clothing, respirators, eng and control A selected review of a and smear survey results was made; it appears that sufficient air samples have been collected and analyzed during the outage.
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The licensee uses a vendor furnished whole body counter (WBC) for baseline counting of incoming contractor personnel and for counting station personnel at regularly prescribed frequencies.
Contractors are also counted upon completion of their outage activities at the station.
The inspectors selectively reviewed WBC results for the third and fourth quarter 1986.
No exposures greater than the 40 MPC-hour control measure were indicated.
Several followup counts were performed on persons who showed elevated initial counts.
Followup counting was adequate to verify that the 40 MPC-hour control measure was not exceeded.
No violations or deviations were identified.
10.
Radiation Occurrence Reports Radiation Occurrence Reports (RORs) for 1987 to date 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 R0Rs.
As an example, ROR 8703 was written January 26, 1987, when a wrench having fixed contamination was found in the clean contractor fabrication shop.
Corrective actions included:
Hot tool storage area established in the Turbine Building
Hot tools painted for easy identification
The fabrication shop is surveyed more frequently
Tailgate sessions were held by the contractors to discuss hot tool
handling and storage.
Licensee representatives stated that more worker identified RORs are being written and are the result of increased staff attention to potential problems during performance of surveys and surveillances.
No violations or deviations were identified.
11.
Control of Radioactive Materials and Contamination, Surveys, and Monitoring materials and contamination, including: program for control of radioactive The inspectors reviewed the licensee's adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
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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 area; this is evidenced by total plant contamination area having been reduced during 1986.
No violations or deviations were identified.
12.
Surveillance; Plant Tours Based on several tours of the plant, the inspectors noted:
(1) No persons were observed violating procedural or regulatory requirements; this includes observation of wor (ers performing activities at the drywell control point and under the requirements of several different RWPs.
(2) Independent radiation surveys performed by the inspectors indicated radiation areas were posted as required.
(3) Radiation postings outside of buildings and in outside storage arear were in need of attention, some postings had fallen down and others were weathered beyond readability.
The licensee committed to upgrade the current posting and to inspect all outside radioactive postings monthly.
No violations or deviations were identified.
13.
Allegation (87-A-0008)
An anonymous telephone call was received in Region III on January 22, 1987, from a contractor worker concerning the use of respirators at LaSalle Station.
The telephone call was disconnected during the conversation; the worker did not call back.
Before the call was disconnected, the worker stated that he was not provided with a respiratorwhileperformingcuttingandgrindingworkinthereactor drywell.
The only equipment issued was a " dust mask (a cotton face mask).
He was not sure what the Radiation Work Permit (RWP) for the jobrequired(respiratoryprotection),nordidheknowwhetherthe material being worked on was contaminated.
The worker's concern was treated as an allegation and investigated.
The allegation is restated below along with a followup discussion of investigation findings.
A similar concern was received by Region III on January 28, 1987, from a second anonymous caller.
Allegation:
The worker was not provided with a respirator while performing cutting and grinding work in the reactor drywell (Unit 2).
Discussion:
On January 23, 1987, a Region III radiation specialist contacted the LaSalle Station Radiation Protection Manager (RPM) about this matter.
The RPM stated that some cutting and grinding being performed in the drywell was being done without respirators because radiological surveys conducted on the materials (to be worked on) showed the materials to be free of radioactive contamination.
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During this inspection, the inspectors verified by review of radiological survey records and RWPs, and discussions with licensee personnel, that respiratoryprotectivedeviceuseforseveralcuttingandgrindingjobs being performed in the drywell was not needed for radiological protection reasons; dust masks were, however, being used to limit respiration of nonradioactive ) articulates.
Because neither the callers' names or the specificjobst1eywerewasworkingonwereprovided,theinspectorscould not-judge the adequacy of the specific radiological protection provided to the anonymous callers.
However, cs stated above, no problems were identified during review of protection provided for similar work performed in the drywell.
The inspectors, however, recommended to the licensee that they assure that workers are provided adequate job specific indoctrination to keep them informed of radiological working conditions.
Finding: While the allegation was substantiated, no violations of regulatory requirements were identified.
The licensee's practice for identifying needed respiratory protection was acceptable.
14.
Exit Meeting Theinspectorsmetwithlicenseerepresentatives(denotedinSection1)
at the conclusion of the inspection on February 19, 1987.
The inspectors discussed 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 during the inspection.
The licensee identified no such documents / processes as proprietary.
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