IR 05000373/1987032
| ML20236V957 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 12/01/1987 |
| From: | Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236V933 | List: |
| References | |
| 50-373-87-32, 50-374-87-31, NUDOCS 8712070195 | |
| Download: ML20236V957 (15) | |
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l U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/87032(DRSS); 50-374/87031(DRSS)
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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
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Inspection At:
LaSalle County Station, Marseilles, Illinois Inspection Conducted:
October 14 through November 5, 1987
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// go Inspector:
R. # Paul Date Accompanying Inspector:
M. A. Kunowski Approved By:
L. R.
e er, Chief
/ 2. - / - 87 Facilities Radiation Protection Section Date Inspection Summary Inspection on October 14 through November 5, 1987 (Reports No. 50-373/87032(DRSS);
No. 50-374/87031(DRSS))
Areas Inspected:
Routine, unannounced inspection of the licensee's radiation protection program, including:
organization and management controls, training and qualifications, internal and external exposure assessment and control, audits, ALARA activities, hot particle contamination events, and an incident concerning personnel contaminations caused as a result of exhaust blower shutdowns.
Results:
One violation was identified in one area (inadequate procedures for use and shutdown of the radwaste building heating and ventilation systems - Section 11).
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DETAILS
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Persons' Contacted-
- L.:Aldrich, Rad / Chem Supervisor
- R. Bishop, Services Superintendent-
- G. Diederich, Station Manager
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- D. Hieggelke, Lead Health Physicist
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- W. R.~.Huntington, Assistant Superintendent, Operations J. Jalovec,. Health Physicist
- K.'Kociuba, Quality Assurance, J. Lewis, ALARA. Coordinator
'*W.' Luett,' Rad / Chem Supervisor Staff
- P. Manning, Assistant Superintendent, Technical Services
- G. M. Myrick, Corporate, Nuclear Services Health Physics, Health Physics' Supervisor
- J..'Renwick, Production-Superintendent
- M. Richter,-Technical-Staff J._Schuster,. Chemist
- W. E.?Sheldon, Assistant Superintendent, Maintenance D. A. Winchester, Quality Assurance, Senior Inspector
- M.-Jordan, NRC Senior Resident Inspector
- R. Kopriva, NRC Resident Inspector The _ inspectors contacted other. licensee and contractor personnel.
- Denotes those present at the exit meeting on October 27, 1987.
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- Denotes those present at the exit meeting on November 5, 1987.
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- 2.
General This inspection, which began on October 14,'1987, was conducted to examine the licensee's radiation protection program.
The inspection included plant tours, review of posting and labeling, high radiation area controls, discussions with licensee and contractor personnel, and independent direct radiation and contamination surveys' performed by the inspectors.
Also' reviewed were open items and drywell access control during spent fuel movement.
One violation concerning adequacy of procedures was identified.
3.
Licensee Action on Previous Inspection Findings
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(Closed) Open Items (373/87020-04; 374/87020-04):
Use of mats at whole l body friskers to scrap shoes hinders identification of possible plant contamination problems.
The licensee has removed the mats.
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Organization and Management Controls The inspectors reviewed the licensee's organization and management
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. controls for radiation protection, including changes in the organizational structure and staffing, effectiveness of procedures and
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other manageme'nt techniques used to implement th'e program, experience-concerning self-identification and correction of program implementation-weaknesses, and' effectiveness of~ audits of the program.
Audits are
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Recent Rad / Chem pe_rsonnel changes includef Rad / Chem Supervisor staff person was promoted to ALARA Coordinator.
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l LA recently graduated health physicist was hired and' assigned to J
~the health physics group.
A Rad / Chem contractor has been appointed as liaison between the
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radiation protection staff and the station construction and
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mechanical maintenance staffs (Section 10).
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The current radiation protection staff appears stable with minimal staff turnover.
Thirty-two of the thirty nine RCTs are ANSI N18.1-1971 qualified; the others will be qualified in February 1988.
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Health Physics Staff Qualifications and Training i
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(HP), who recently received an M.S. degree, and four staff HPs.
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staff HPs each have a B.S. degree in health physics or a related field and range in station experience from six months to four years.
Currently, no required initial or continuing training programs exist for the HPs; however, the. licensee has compiled a listing of health physics and management training courses that HPs are encouraged to attend, as budget, scheduling, and individual HP interest dictate.
No problems were identified.
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6.
External Exposure Control and Personal Dosimetry i
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 I
routine needs; and required records, reports, and notifications.
Discussions with licensee representatives and observations during plant l
tours indicated that the licensee's physical and administrative controls
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for external exposure are generally adequate.
Temporary shielding was I
used during the recently completed Unit 1 maintenance outage and l
continues to be used throughout the plant as needed.
Administratively, the' licensee has recently revised Procedure LRP-1120-2, Revision 8, High Radiation Area Access Control This procedure outlines the steps
necessary for personnel to gain access to high (0.1 to 1 R/hr) high-high l
(1 to 20 R/hr), and very high (> 20 R/hr) radiation' areas.
The licensee requires that prior to entering a high, high-high or very high radiation area, individuals must be authorized on an RWP, and are required to sign 1'
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J L-out.a key.or computer key-card, and an alarming dosimeter. :During the
inspection, two licensee employees ~ entered a high-high radiation area'
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- in Unit 2'instead of entering the corresponding room in Unit 1 as
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a specified by the RWP
.This incident is discussed further.in Section'14.
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-l The inspectors also 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.
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The inspectors reviewed licensee procedure LRP-1250-5, Revision 7, Film:
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Badge /TLD Spiking.
Two problems were noted:
(1) Contrary-to the i
procedure, the licensee was using the absolute values of the differences j
between the delivered doses and the reported doses, which ignores the il
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significance of negative' differences.
(2) In accordance with the procedure for the delivered beta dose, the licensee has been using values
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calculated by_ multiplying the beta dose of their depleted uranium (DU)
source by a correction factor supplied by the vendor who.previously provided their whole-body' badges.
However, for approximately the past two years, the licensee has been processing its own TLD's provided by a vendor.
The continued use of the correction factor, which was intended to correct for the difference between the beta dose delivered by the licensee's DU source and the dose delivered by the previous vendor's TL-204 source, is inappropriate.
This matter is considered an unresolved item which was discussed with the licensee and will be reviewed during a future inspection (Unresolved Items No. 273/87032-01;-No. 374/87031-01).
~To date, the licensee's~1987 person-rem total of 1278 is higher than the goal of 1150 person-rem.
According to.the licensee the Unit 2 refuel outage from January to. June 1987 was responsible for approximately 800 person-rem, of which 300 person-_ rem'were received on snubber testing and reduction and a drywell cooling modification.
The unscheduled Unit 1 maintenance outage from May to. September 1987 contributed approximately 300 person rem to the year-to-date total; this outage'is discussed further in Section 13.
7.
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 individua'l intakes meet regulatory requirements; ALARA considerations; and required records, reports, and notifications.
The licensee's program for controlling internal exposures includes the use of protective clothing, respirators, engineering controls, and control of surface and airborne radioactivity.
A selected review of air sample and smear survey results was made.
No major problems were identified.
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p Recently,,the'AL' ARA office ~has taken the responsibility for use ofL portable air. filtration / ventilation systems.
Procedures, ALARA', and logistical considerations for using the equipment have been developed in procedure LRP-1430-2, Revision 0, Utilization of Portable Air Filtration /
Ventilation Equipment.'
No problems _were identified with:the procedure.
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The frequency and location of routine air sampling with portable air samplers is described in procedure LRP-1140-1, Revision 2,_ Routine
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Surveys..In procedure'LRP-1360-6, Revision 8, Air Sampling of Suspected-Radioactive Airborne Areas, the techniques of and precautions for air sampling (with' portable samplers) are discussed.
The inspectors observed the placement and operation of several portable air samplers, reviewed results of_' analyses of several routine and job specific air' samples, and
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examined several RWPs for inclusion and clarity of internal exposure
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control and assessment requirements.
The inspectors noted that the licensee is revising procedures on routine performance checks for the
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multichannel analyzer and proportional counter used to analyze air.
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samples.
The circumstances of those revisions are discussed in Inspection Reports No. 50-373/87031; No. 50-374/87030.
No major problems were noted.
Recently, the license ~e had a few incidents involving the radwaste building ventilation system and the machine shop ventilation system.
These are discussed in Section 11'of this report (Inspection Reports No. 50-373/87032; No. 50-374/87031).
The licensee's whole body count and calibration program is described in Inspection Reports No. 50-373/87020; No. 50-374/87020;. no significant changes have occurred in this program.
The inspectors noted that no exposures greater than the 40 MPC-hour control measure have occurred in 1987 to date.
Procedures for operating the whole body counter (WBC) were available at the counting facility and the RCT on duty during the inspectors' visit was aware of the proper use of the procedural requirements for whole body counting and reporting criteria.
The inspectors reviewed the licensee's whole body count procedure LRP-1340-10, " Calculation of MPC-hours from WBC Data" and the method l
of relating an individual's whole body counting data to regulatory l
requirements (MPC-hour).
Use of this procedure was discussed with members of the HP staff.
The inspectors requested the staff to use the
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procedure to convert WBC data to MPC-hours from an excmple given by the
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inspectors; the results of the staff's conversion was incorrect.
After further discussion with the station and corporate HP staff, the inspectors' concluded that if useo correctly the procedure can be used to l
i make'the conversion; however, clarification in use of the procedure may
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This matter was discussed at the exit interview and will be l
reviewed'during a future inspection (0 pen Items No. 50-373/87032-02; No'. 50-374/87031-02).
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8.
Audits - Rad / Chem Improvement Plan II l
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In July 1987, an assessment of the radiation protection program has conducted by a CECO.offsite assessment team.
The evaluation inhuded review of ALARA; org' rization and administration; external," int $nal
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and contamination contrM; and training.
In addition, the team itembers conducted interviews', reviewed procedures, and performed job-site evaluation.
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For each of the c.~iteria reviewed, the team indicated the evaluation results and made improvement statement recommendations.
The inspectors reviewed the assessment team's findings and their recommendations and o
found that although no written response to the report was required the station has recently initiated a second Rad / Chem Improvement Plan which addresses each of the team's findings and recommendations.
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plan itemizes and presents a completion date for each proposed
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improvement and assigns responsibility to a staff member for completion
of each item.
The scope of the program appears comprehensive and appears to adequately address the assessment team's findings and recommendations.
9.
Control of Radioactive Material and Contamination
The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including:
adequacy of supply, maintenance, j
and calibration of contamination survey and monitoring equipment;
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effectiveness of survey methods, practices; equipment, and procedures; I
adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
/l'I The inspectors reviewed records of calibrations of several,fon,chider
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and G-M survey meters.
In addition, the inspectors observed the operation of the'iicensee's deepwell calibration facility and the calibrations of a survey mter and an area monitor used in the centrol,
room ventilation intake plenum. to significant problems,were observed.'
The number and location of RM-14 friskers at step-off pa$d (SOP) appeared to be adequate.
Two IRT portal monitors, one in the turtine building and one in the service building, were inoperable during the inspection.
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Two additional IRT monitors located in the gatehouse and several IPM-7 whole-body friskers located in the auxiliary and turbine buildings were operational.
The inspectors reviewed the operation and calibration procedures for the two gatehouse IRT whole body portal monitors.
Calibrations have been performed using ccbalt-60, and indicate that the worst case sensitivity of each monitor ranges from 33 nCi at the foot position 1.o 130 nCi at the waist position to 154 nCi at the head position.
Because the calibrations are performed without use of a calibrd:. ion phanthem, and only the worst case sensitivity is found using the :nrrent caMoration, the licensee is considering cross calibrating the detectors ty use of PCs I
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- Dn July 29, 1987, during a routine smear survey in.the maintenance decontamination shop (DS) an RCT found elevated levels of loose i
i contamination on horizontal surfaces about tert feet above the floor level.
The DS is'an enclosed area without a ceiling located within the maintenencjmachine(MandMJshopendiscontrolledasastepoffpad
(SDP) area.
Because the vesults were unexpected, th RCT performed a
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/ mear survey of horizontal surfaces in the surrounding M and M shop (not j
controlled as a contaminated area) and found smearable levels of 2,000 to 10,000 dpm per 100 cm2 The licensee investigated this matter to e
determinethecause$oftheelevatedmigratedcontaminationandfoundthat i
the DS filter train were not performing to their design function because
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several suction dampers had been closed.
The same condition was also
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found in the M and M shop.
The li.ensee discovered that although no j
instructions had been issued to close the & mpers after they had been j
opened,for use during work with contaminated equipmen^, maintenance i
persona l would norr.# 1y close the dampers.
The licensee also found that
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with the main H and N shop exhaust system running, the DS doors open, and
all naintenarse shop doors closed, the air patterns appeared stable.
, However withithe DS shop doors open, and the outside and/or turbine buildinh dud opoh the air patterns were very unstable and tended to swirl in all/directiorss.
The combination of D sy dom not operating as designei. wg cpen doors in the M and M s%6, iscreases the probability of migr # ng. hose contamination.
To prevent t.1e migration of loose
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cont:minatfod Queing decontamination of contaminated equipment in the 05, Se licensee has taken the following corrective actions:
(1) all roll Gp doors are locked with Rad / Chem keys and unless authorized will s d e maintained closed; (2) caution tags will be placed on the exhaust and P supply air systems instructing persons to receive authorization before
\\ sktdown of the systems; (3) suction dampers will be maintained open
'as designed; (4) tailgate training sessions have been held with all maintenance personnel instructing them in the proper use of the ventilation damper system; and (5) signs will be placed on the dampers with instructions not to close.
The effectiveness of these actions will
be reviewed at future inspections.
This matter was discussed at the exit rheting (0 pen Items No. 50-373/87032-03; No. 50-374/87031-03).
10.
Radiation Occurrence Reports
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Radiation Occurrence Reports (RORs) for 1987 to date were reviewed.
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The licensee trends occurrences to determine repetitive violations and violators.
Because of several recent RORs issued against the mechanical maintenance
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[./ cspartment, the licensee established a new position, maintenance-radiation F
I protection coordinator.
The coordinatt works with maintenance and with the radiation protection-ALAM groups.to plan worVand write RWps
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involving radiological concerns.
In addition, the' coordinator provides
4 training to maintenance on seietted radiation protection subjects and to
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radiation protection on selected mainteidnce subjects.
The establishment of the coordinator position is a positive effort by the licensee to
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improve y terdepartment communication and worker radiological awareness.
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During an internal review of the R0Rs, the licensee noted several repeat occasions when workers failed to report for respirator testing and whole l.
b'ody counting.as scheduled.
This matter was discussed by the NRC
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' inspectors with the licensee, who stated that to correct this problem a new, strict policy.on "no-showr" has been implemented.
The policy
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. pre / ides for a written notice of appointments and withholding of the individual's>TLD badge if a rescheduled appointment is also missed.
4 The effects, if any, of,the new poM cy and of the maintenance-radiation protection coordinator will be reviewed at a future inspection (0 pen
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a Items No. 50-373/87032-04; No. 50-374/87031-04).
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Several other incidents that were the subject of RORs are discussed in
,j detaf f is. Sections 9, 'L4 and 15 of this report.
Overall, the~ licensee's
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~ review of~ R0Rs appears adequate.
No violations or deviations were identified.
11.
RadwasteVentilationandRadwasteTpuckbayContaminationEvents Radwaste Ventilation Contamination Event On Monday, October 19, 1987, at;0915, with both Units at approximately 95% power, the radwaste building ventilation (VW) system was shutdown to allow cleaning of supply air heat-recovery coils.
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shutdown.according to the licensee's procedure, LOP-VW-03, Revision 2, I
Radwaste Ventilation Eystem Shutd a n.
After the system was shutdown, four workers entered the area (Radwaste exhaust / filter penthouse), and after performing some work, discovered contamination on their hard hats and upper bodies upon deperting' the area.
The workers were
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decontaminated and.whole body counts were performed; no internal contamination was found.
Rad / Chem personnel and tech staff ventilation c
l specialists invest %ated the contamination event and determined that the
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contamination was cesium-138 and rubidium-88 which entered the area l
t': rough three partially-open VW exhaust filter-bank maintenance doors.
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The-doors were open because of faulty latches.
Because the VW system was shutdown, which resulted in the radwaste building being at atmospheric
+ pressure, the positive pressure in the main vent stack caused a back-flow of contaminated exhaust from the stack.into the interconnected VW exhaust system.
The licorpee's health physics staff concluded that the source of the radioactivity'was offgas from the main turbine gland steam exhauster system,, which enters the stack at Elevation 855'.
The VW exhaust system enters,tha stack at E!evation 857.
At 133Q, the doors to the filter bank 's> sing were closed, and at 1445, the VW was restarted.
Later that r
day, the latches on the filter bank doors were repaired.
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' The licensee's radwaste building exhaust system consists of three trains, two of which normally are operating.
Ea.:h train consists of prefilters, a HEPA filter, a heat recovery coil, a 43;000 cfm exhaust fan, and a 48" backdraft damper.
The traias feed into a common header which is
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's connu:ted to the vent stack.
In the W shut'! awn procedure, a precaution
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is given that airborne radioactivity in radwaste pump rooms, tank rooms,
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valve aisles, and the circulating water system ball collector pump
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e cubicles may increase (presumably from the loss of exhaust ventilation in these areas); however, no precaution is given for the backflow of
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potentially-contaminated exhaust from the main stack through the closed backdraft dampers.
In the initial evaluation of the contamination event, the licensee assumed that one or more of the backdraft dampers did not seal and that this contributed to the release of the contamination.
The dampers were not checked by the licensee before or during the event, but were later tested and found to be working properly.
In subsequent interviews with NRC inspectors, a licensee tech staff ventilation specialist stated that backdraft dampers are generally assumed to leak.
Rad / Chem personnel stated that the VW shutdown procedure has been revised and will include a requirement to keep one of the three exhaust fans operating when the reactors are at power.
Continuous operation of one of the three fans should limit backflow of potentially contaminated exhaust from the main stack through closed backdraft dampers and unsealed filter bank doors.
Radwaste Truckbay Contamination Event On Monday, October 19, 1987, six individuals who had been working in the radwaste truckbay while the VW system was shutdown were found to have low level contamination on their shoes.
Rad / Chem personnel determined that the contamination was Co-60 and Mn-54, and surveyed the truckbay area to determine the extent and origin of the contamination.
The survey indicated contamination ranging from 1,000-23,000 dpm/100 cm2 on horizontal surfaces above the floor and from 1000-2000 dpm/100 cm2 on the floor.
The highest levels were found on the portable air mover used on October 19, 1987, to control airborne radioactivity in the filter aisle-decon pit entrance, and on the top of a frisker station located near the filter aisle-decon pit.
Previous routine surveys indicated that smearable floor values are normally_less than 1000 dpm/100 cm2 According to Rad / Chem personnel, horizontal surfaces above the floor are usually not smear surveyed during routine surveys because general access RWPs for the radwaste truckbay prohibit climbing or working at levels above six feet.
In their initial evaluation of the event, Rad / Chem could not establish the source of the contamination, but speculated that the contamination may have been spread due to a combination of the shutdown VW system, open access doors to the truckbay area, and work activities using a portable air handler.
Also during this period, a 55 gallon drum of DAW was compacted.
The compactor, located near the filter aisle-decon pit area, is equipped with a roughing filter, two HEPA filters, and a blower.
According to the licensee, the compactor can be used as a stand-alone unit but has not been used as such.
The exhaust from the blower is hardpiped into the VW exhaust system.
The licensee procedure, LOP-WX-15, Revision 3, Dry Waste Compactor Operation, states that as a prerequisite to compactor operation, the VW system must be in operation; however, the procedure does not specify how the operation of the VW system is verified.
The NRC inspection indicated that the two procedures, LOP-VW-03, Revision 2, and LOP-WX-15, Revision 3, are inadequate in that (1) LOP-VW-03, Revision 2, did not consider leakage through back-draft dampers, and (2) LOP-WX-15, Revision 3, did not specify how the compactor operator ensures that the
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radwaste ventilation system is operating.
As such, the licensee is in
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. violation of Technical Specification 6.2.A.1 which requires that detailed written _ procedures. including applicable checkoff lists be prepared, approved, andLadhered to for applicable procedures recommended in Appendix A of
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Regulatory Guide ~1.33,~ Revision 2, February 1978.
Section 4(t) of Appendix A requires procedures for'the shutdown of the radwaste building
heating and ventilation systems.
This matter was discussed at.the exit-i meeting (Violation No. 50-373/87032-05; No. 50-374/87031-05).
No violations or deviations were identified.
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Radiological. Controls for Drywell During Spent Fuel Movement (T.I. 2509/23)
The licensee employs a fuel-chute to limit dose rate levels in the drywell when moving spent fuel. ' During the Unit'1' first cycle refuel outage in October 1985 to September 1986, access to the 777' and 796'
elevations was controlled by RWP and required the attendance of an RCT.
Access above 796' was prohibited.
At the start of the Unit 2 first cycle'
refuel outage in January to June 1987, the licensee placed 20 electronic dosimeters at Elevations 799'. and above during spent fuel movement to.
monitor total dose and highest dose rate.~
Based on the results the licensee controlled access to elevation 777' and below by RWP and requireJ RCT attendance for access to elevation 796' during the remainder (.
of the outage.
As with the Unit 1 outage, access above 796' was prohibited.
According to the licet.see, these restrictions will pronibit L
access to areas in the drywell above the sacrificial biological shield (SBS) and near SBS penetrations where extremely high exposure rates may i.
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exist during spent fuel movement.
The inspectors noted that one of the-licensee's dosimeter dose rate values, 110 mR/hr at elevation 818', was two times greater than a value indicated in Final Safety Analysis Report for an apparently similar location.
Restrictions were posted during the outages near the entrance to the drywell and at the temporary drywell access control desk.
In addition, according to the licensee, the restrictions were listed in RWPs and were explained to department representatives at the morning outage meetings and to radiation protection personnel; however, no formal training and retraining program exists to explain to all drywell workers the potential hazards, protective work controls /limitati 7, and evacuation signals and routes.
Existing radiation protection proadures do not specifically address drywell access during spent fuel m vement.
In addition to the posting, RWP controls, and the informal training, l
the licensee also provides electronic alarming dosimeters to all persons entering the drywell.
The dosimeters can be set to alarm at specified doses and dose rates.
The licensee's refuel procedures also address drywell radiation levels during spent fuel transfer.
Mastcr Refuel Procedure, LFP-100-1, Revision 10, instructs fuel handlers that monitoring of the upper drywell level or restriction of access to the upper level by radiation protection staff is required during core alterations; however, Rad / Chem's informal procedure prohibits access by anyone to the upper level.
Core Alteration Shiftly Surveillance, LFS-100-4, Revision 5, requires shiftly notification of the Rad / Chem
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foreman during core alterations; however, there is no provision for a l
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l communications link between the drywell access control desk and the fuel handlers.
The licensee agreed to (1) review the apparent discrepancy between-the measured and FSAR dose rate values; (2) formalize drywell control procedures and training regarding drywell access during spent fuel movement; (3) resolve the apparent discrepancy between radiation protection and fuel handling restrictions on occupancy of the upper drywell level and; (4) establish and test a direct (non-dedicated)
communications link between the drywell access control desk and the fuel handlers during spent fuel handling.
These items will be reviewed at a future inspection (0 pen Items No. 50-373/87032-06; No. 50-374/87031-06).
No violations or deviations were identified.
13.
Unit 1 Maintenance Outage The inspectors reviewed radiological aspects of the recently completed Unit 1 maintenance outage.
The major maintenance items and the health physics concerns involved in this unscheduled outage were discussed in Inspection Reports No. 50-373/87020; No. 50-374/87020.
According to licensee representatives, the outage lasted 109 days and resulted in approximately 290 person-rems, of which 196 person-rems were incurred from activities associated with the pull, repair, and reinstallation of the 1B recirculation pump (RP).
Of the 52 RWPs related to the RP job, the RWP written for the interference removal and reinstallation was responsible for the largest person-rem total, 56 person-rems.
The licensee attributed the relatively high value to the time required to install brackets so that in future outages the interferences could be reinstalled with bolts rather than welding.
The licensee reasoned that for subsequent interference reinstallation, Dolting would require less time, and thus, cost less person-rem expenditure than re-welding.
The licensee acknowledged that future removals of the interferences by unbolting would probably require more time than cutting, but stated that the person-rem savings realized during reinstallation would more than offset the possibly higher person-rem cost of unbolting interferences during removal.
No violations or deviations were identified.
14.
Unintentional Entry Into A High Radiation Area On October 15, 1987, two maintenance workers inadvertently entered
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the Unit I reactor water cleanup valve aisle on the 807' floor lt 41 to l
work on equipment.
The area they intended and were authorized te
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under an RWP was the Unit 2 reactor water cleanup valve aisle on the
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same level.
Both areas are controlled as High-High Radiation Areas (HHRAs) and require authorization and key cards for entry.
One set of key cards is used for HRAs in both units, and another set of key cards is used for HHRAs in both units.
After working in the Unit 1 valve aisle I
for approximately five minutes, one of the workers' electronic dosimeters
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alarmed, after which the workers departed from the area.
The workers
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notified the health physics office to inform them that something was wrong because the electronic dosimeter alarmed at 45 mrems in about five minutes, an unexpected reading in that the RWP indicated dose rates of
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about 26 mR/hr.
An'RCT responded and proceeded to the Unit 2 valve aisle, the area in which the employees were authorized to work.
When the RCT found no one, he proceeded to the same area on the Unit 1 side where he located the workers.
After discussing the matter with the employees, the RCT noted the electronic dosimeters indicated they were' exposed to dose' rates ranging from 1.5 R/hr to 6.4 R/hr.
The RCT then performed surveys in the area (Unit 1) and found radiation fields ranging from l'R/hr to 6.5 R/hr, readings which correlated to those of the electronic.-
dosimeters.
The licensee initiated an investigation of-this incident and found no specific reason for the workers' entry into the' wrong area. ~Because the licensee controls high-high' radiation areas by requiring the use.of electronic dosimeters possible whole body overexposure were prevented.
The licensee speculated that the practice of using the same key cards for entry into HHRAs in both units contributed to the incident.
As a result, the licensee will utilize separate key cards for each unit's HRA and HHRA areas.
The licensee expects to complete this action by December 31, 1987 (0 pen. Items No.- 50-373/87032-07; No. 50-374/87031-07).
The licensee also discussed this matter specifically with each of the.two-
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maintenance workers and their foreman, and instructed them to be more attentive to RWP required entries into HRAs; the same instructions and cautions were later given to all maintenance workers and foremen.
At the exit interview, the licensee was. informed that the inspectors became aware of this potentially significant occurrence during a discussion with an employee on October 22, 1987, one week after the incident occurred, even though the inspectors were onsite when the incident occurred.
The inspectors stated that although the-licensee has historically informed them of potentially significant radiological events, they were concerned about the failure to notify them of this event.
No violations or deviations were identified.
15.
Skin Exposures by " Hot Particles" The inspectors reviewed the licensee's investigation of three incidents in which minute discrete radioactive particles (hot particles) were found; one on the back of a worker's upper arm (225 nanocuries cobalt-60), one
. on the inside of a worker's shirt (54 nanocuries cobalt-60), and one on the inside of a worker's trousers (58 nanocuries cobalt-60).
The 54-and 58-nanocurie particles were discovered on the individuals by the IPM-7 (beta sensitive) whole body frisker at the 15-line in the Turbine Building (TB).
The 225-nanocurie particle was discovered by the IRT (gamma sensitive) portal monitor in the gatehouse.
The licensee conducted an investigation of each incident, including interviews with the individuals, review of their previous and current work activities, entries and exits from controlled areas, their frisking
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methods, and determination of length of exposure.
In each incident, it appears.the individuals worked in accordance with RWP and procedural requirements.
No specific cause could be determined, nor could an explanation be given.for the origin of the particles.
The inspectors interviewed one of the participants in the incidents, reviewed the licensee's investigation results and calculation methods, and performed independent calculations.
The licensee calculated skin doses in the two incidents involving the 54-and 58-nanocurie sources to j
be less than 300 mrems, and the dose to the worker with the'225 nanocurie
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particle.to be about 5 rems.
The licensee and NRC calculations are in agreement.
No overexposure occurred as a result of the incidents, and no violations of regulatory requirements were identified; one weakness was noted.
The licensee's investigations appeared adequate.
The apparent weakness associated with one of the incidents involved the worker who had the 225-nanocurie particle on the back of his arm.
The worker reportedly successfully' completed other contamination surveys before the particle was detected on the IRT portal monitor in the gatehouse.
One surmy reportedly was performed using a hand-held frisker after the worker removed his protective clothing, another reportedly was performed using the IPM-7 whole body frisker at the 15-line in the TB, and the last survey reportedly was use of the IRT at the 26-line in the TB.
The licensee determined that the particle was not detected at the 15-line because of the location of the particle could have easily prevented detection due to a design limitation of the detector.
The inspectors agreed there may be a design limitation; however, after observing many workers using the IPM-7 they noted that a significant number did not use the instrument as designed (see exit meeting -
Section 17).
The inspectors concluded that improper use of the instrument, in addition to the existing design limitation, would decrease the sensitivity for particle detection.
The licensee determined that the particle was not detected by the IRT at the 26-line because the instrument detection sensitivity was set at 270 nanocuries; the particle on the worker's arm was 225 nanocuries.
The licensee also concluded that although the particle could have been detected with the routine hand held frisker, given the position of the particle and the industry known difficulty of detecting non-visible hot particles, the particle could have easily gone undetected unless an absolute total whole body frisk was performed; the inspectors agreed.
The licensee was cautioned about the need to ensure that all workers who perform hand held frisks do an adequate survey.
These matters were discussed at the exit interview.
As part of the overall contamination control program, the licensee has given specific guidance to the RCTs to alert them of the industry concern about controlling and detecting hot particles.
The guidance delineates particle detection, removal, and analysis, and will be incorporated into the rad / chem procedures.
In addition, several beta
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l-sensitive whole body friskers are being purchased for installation at l
strategic egress positions.
The licensee has also scheduled RCT coverage l
at the 15-foot line in the TB during lunch hours to strengthen radiological controls.
The licensee has recently installed an automated protective clothing
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laundry monitor (IRTACM-408), utilizing large area detectors, which provides increased sensitivity for detection of hot particles.
In i
conjunction with recent HP corporate guidance (NSHP RP Guidance 1410-2),
" Release Criteria for Onsite Protective Clothing Laundries," the licensee has attempted to establish a release limit for laundry of 33 nCi/100 cm,
The release limit is based on contamination inside the protective clothing (PC).
In addition to increasing detection of protective clothing hot particles, the licensee expects.to reduce the number of PCs currently worn with general contamination levels in excess of this limit.
Those PC's which exceed the limit will either be discarded or sent to a commercial (licensed) laundry for wet washing and recounting.
No violations or deviations were identified.
16.
Surveillance; Independent Surveys; Plant Tours Based on several tours of the plant, the inspectors noted:
(1) No persons were observed violating procedural or regulatory requirements; this included observations of workers performing activities under the require-ments of several different RWPs.
(2) At almost all frisker stations, instructions were posted that require persons who have detected personnel contamination to go to the nearest telephone and notify the Rad / Chem Uepartment.
(3) Independent radiation surveys performed by the inspectors indicated radiation areas were posted as required.
(4) The results of 49 smears taken by the inspectors of floors and other horizontal surfaces indicated six areas in excess of 1000 dpm/100 cm, these smears ranged
from 1000 to 6000 dpm/100 cm2 beta gamma.
Of the six smears, four were taken in the radwaste building.
As a result of the loose contamination levels found on horizontal surfaces and the incident concerning personal contamination events in the radwaste truckbay (discussed in Section 9), the inspectors expressed concern at the exit meeting that tolerance of loose contamination buildup is a poor radiological practice.
They further stated that a stronger routine horizontal smear survey program may be required to identify those areas which require decontamination.
The buildup of loose horizontal contamination in the radwaste truckbay is partially the result of the licensee's program which requires smear surveys be performed on horizontal surfaces above six feet only if individuals are scheduled to i
work at that level, and which requires an RWP.
Another contributing factor for buildup is the frequency with which large truckbay doors are opened and closed, which may disrupt designed air flow patterns and increase the probability of causing migration of loose contamination into the cement solidification barreling and storage area.
These matters were discussed at the exit interview and will be reviewed at a future inspection (0 pen Items No. 50-373/87032-08; No. 50-374/87031-08).
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On
' 17 - Exit Meeting
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The inspectors met with licensee representatives (denoted in Section 1)
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on October 27 and at the conclusion of the inspection on November 5, 1987.
The. inspectors summarized the scope and-findings of the inspection.
The. inspectors also discussed the likely informational content 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 / processes as proprietary.
In response to certain items discussed.
by.the inspectors, the licensee:
a.
Acknowledged the violation (Section 11).
b.
Stated that a review of whole' body count Procedure LRP-1340-10 will l:
be made to determine if clarification in the.use of the procedure L
1s required (Section 7).
c.
Acknowledged the inspectors' comments concerning the need to. ensure-the M and M shop and decontamination facility ventilation system is-operated as designed (Section 9).
d.
Stated that not informing the inspectors of the workers' inadvertent.
entry.into a'high radiation area while the inspectors were.onsite was.an oversight and not intentional (Section 14).
e.
Stated that a review will be made to determine adequacy of the routine smear survey program for horizontal surfaces, and that preparations for a major decontamination of the radwaste truckbay are being made (Section 11).
f.
Stated that consideration is being given to the backfitting of the existing IPM-7 whole body friskers by installing photo-cells to ensure workers use the instrument properly.
Also, newly purchased.
IPM-7s will have the photo-cell feature.
In addition, stronger surveillance of IPM use will be initiated (Section 15).
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