IR 05000373/1988009

Insp Repts 50-373/88-09 & 50-374/88-09 on 880328-0407. Violations Noted.Major Areas Inspected:Transportation,Solid Radwaste Mgt & Radiation Protection Programs During Unit 1 Refueling/Maint Outage

ML20154B445
Person / Time
Site:	LaSalle
Issue date:	05/09/1988
From:	Greger L, Michael Kunowski, Paul R, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154B437	List: IR 05000373/1988009 ML20154B434 ML20154B439
References
50-373-88-09, 50-373-88-9, 50-374-88-09, 50-374-88-9, NUDOCS 8805170199
Download: ML20154B445 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-373/88009(DRSS); 50-374/88009(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 Conducted: March 28 through April 7, 1988 Inspectors: R E

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W W. J. Slawinski f!77 Date' '

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M. A. Kunowski b2 Date Approved By:

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L. f reger, Chief 99~88 -

Facilities Radiation Date Protection Section Inspection Summary Inspection on March 28 through April 7, 1988 (Reports No. 50-373/88009(DRSS);

No. 50-374/88009(DRSS))

Areas Inspected: Routine, unannounced inspection of the licensee's transportation, solid radwaste management and radiation prctection programs during the Unit I refueling / maintenance outage, including: organization and management controls (IP 83722); training and qualifications of contractor personnel (IP 83729); planning and preparation (IP 83729); external and internal exposure controls (IP 83729); control of radioactive materials and contamination (IP 83729, 83726); the ALARA program (IP 83729); solid radwaste (IP 84722); and transportation activities (IP 86721). Also reviewed were previous open items (IP 92701), an administrative overexposure event (IP 92701), the recirculation system chemical decontamination project, and spent fuel pool liner leakage (IP 92705).

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l Results: One multiple-example procedural violation was identified (failure to re-evaluate ALARA measures when radiological conditions significantly differ from those originally assumed - Section 12, failure to follow respirator return procedure - Section 8, and failure to follow !

personal frisking procedure - Section 17). Although one violation was '

identified, the licensee's radiation protection program continues to be effective in protecting the health and safety of occupational worker The licensee's ALARA measures appeared generally effective for reducing personnel exposure The licensee's programs for controlling solid radwaste and transporting radioactive material are effectiv ,

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DETAILS Persons Contacted

• L. Aldrich, Rad / Chem Supervisor

• C. Allen, duclear Licensing

• D. Brown, Quality Assurance

• G. Diederich, Station Manager M. Friedmann, Health Physicist T. Greene, Health Physicist

• D. Hieggelke, Lead Health Physicist

• W. Huntington, Services Superintendent

• J. Lewis, ALARA Coordinator R. Littleton, Site Coordinator, Power Systems Energy Services, Inc. (Contractor)

• Luett, Rad / Chem Supervisor Staff

• P. Manning, Assistant Superintendent, Technical Services

• Marcis, Engineering Site Superviscr G. McCallum, Health Physicist

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• J. Renwick, Production Superintendent

• J. Schrage, Technical Services Health Physicist

• A. Settles, Regulatory Assurance

• L. Shearer, Operations, Radwaste Group

• J. Steinmetz, Project and Construction Services

• L. Greger, NRC, Section Chief, Facilities Radiation Protection

• R. Kopriva, NRC Resident Inspector The inspectors also contacted other licensee and contractor personne * Denotes those present at the exit meeting on April 7, 1988. General This inspection, which began on March 28, 1988, was conducted to review the licensee's radiation protection program during the Unit I refueling / maintenance outage, and portions of the solid radwaste and transportation management program, including organization and management controls, qualifications and training, planning and preparation, external and internal exposure controls, control of radioactive materials and contamination, the ALARA program, and an administrative overexposure even Also, fuel pool liner leak integrity, open items, and the chemical decontamination of the reactor recirculation system were reviewed. The inspectors toured and conducted independent surveys of selected plant areas including the Unit 1 drywell. Area posting and general housekeeping were adequat One multiple-example procedural violation concerning ALARA reviews, respirator return record-keeping, and personal frisking was identified and is discussed in Sections 8, 12 and 17, respectivel l

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3. Licensee Action on Previous Inspection Findings (IP 92701 and 92702)

and on NRC Information Notices (IP 92701)

(Closed) Open Item 50-373/84006-03: Installation of additional permanent shielding around several Unit 1 containment penetration This modification has been scheduled for the next refueling outag Completion of the modification will be tracked under Open Item No. 50-373/88009-0 (Closed) Violation 50-373/87020-01; 50-374/870202-01: Failure to properly verify that source response was within the acceptance range of the decay-corrected initial calibration response for a liquid process monitor. The licensee re preformed the detector response check with a properly decay-corrected source. The detector responded to within 8.5%

of the expected response, within the 120% criterio (Closed) Open Item 50-373/87020-02; 50-374/87020-02: Evaluate the feasibility of reducing the number of egress locations before entry into gatehouse and improving the quality of personnel contamination surveys at other egress location The licensee evaluated the feasibility of reducing the number of egress points and has decided to eliminate seven egress points. The points _will be eliminated either by posting doors as

"no exit allowed," locking doors, or by redefining the boundaries of the radiologically controlled area (RCA). To improve the quality of personnel contamination surveys at other egress locations, the licensee has purchased and will be installing (or has already installed) six Nuclear Enterprises Model IPM-7 whole-body contamination monitors and several Nuclear Enterprises Model HFM7-A Hand and Foot Monitors. An additional IRT Portal Monitor has been installed in the gatehouse. The three total IRT Portal Monitors in the gatehouse have now been equipped with red and green personnel control lights to assure an approximate 2-second count. The licensee's actions in response to this open item have t'een extensiv (Closed) Open Item 50-373/87020-03; 50-374/87020-03: Protective saoe covers and gloves, to minimize the potential spread of contamination, are not provided at most of the frisker station The licensee has purchased 90 metal boxes for dispensing gloves and shoe covers. The boxes will be a mounted near frisking / contamination monitor stations with signs instructing contaminated personnel to don the gloves and shoes as needed, and to telephone rad / chem for assistance without crossing the step-off pad (50P).

(Closed) Violation 50-373/87032-05; 50-374/87031-05: Adequate procedures for operation and shutdown of the radwaste building heating and ventilation systems were not available. The licensee has revised procedure LOP-VW-03, Radwate Ventilation System Shutdown, to require operation of at least one exhaust fan when the radwaste ventilation system is shutdown and one or both reactors are operating. In addition, caution cards have been hung on the radwaste exhaust fan switches in the radwaste control room. The caution cards state that at least one fan must be operating. The licensee has also revised procedure LOP-WX-15, Dry Waste Compactor Operation, to instruct the operator of the compactor to verify that the radwaste ventilation system is operating before using the compacto _

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(Closed) Unresolved Item 50-373/87032-01; 50-374/87031-01: Review appropriateness of the continued use of the correction factor for beta dose TLD spikirg. The licensee has revised procedure LRP-1250-5, Film Badge /TLD Spiking, to delete the requirement for spiking TL0s with a teta source. The beta spiking will be performed quarterly using a T1-204 source as part of the corporate Interstation Comparison TLD Progra The inspectors noted several editorial errors in the revised procedure that will be corrected by the license In addition, the licensee has recalculated performance quotients using true values rather than absolute values and has determined that the quotients still meet the acceptance criteri (0 pen) Open Item 50-373/87032-02; 50-374/87031-02: Clarify procedure LRP-1340-10, Calculation of MPC-hours from WBC Data. The licensee has revised this procedure, but ambiguities still exis This matter will be reviewed at a future inspectio (Closed) Open Item 50-373/87032-03; 50-374/87031-03: Review effectiveness of controls on doors and ventilation dampers in the mechanical maintenance shop. The licensee has locked the roll-up doors in the shop, with keys assigned to the rad / chem staff. Dampers in the decon shop within the mechanical maintenance shop, and the control panel for the supply and exhaust fans, have been posted with signs prohibiting unauthorized operation. These controls have been explained to the maintenance workers in tailgate session (Closed) Open Item 50-373/87032-04; 374/87031-04: Review effectiveness of 1) the new, strict policy on repeat "no-shows" for respirator testing and whole-body countir.g, and 2) the liaison between mechanical maintenance and radiation protection. The licensee's new policy has been effective and will continu The liaison position, as staffed with a contractor, is no longer in effect; however, a liaison is still functioning between station construction and radiation protection. (See Section 4.) In addition, an individual has been designated to coordinate RWP activities in mechanical maintenance. Because of the success of the "no-show" policy, the appointment of a maintenance person to coordinate RWP activities, and the apparently continuing effort by the station to ensure that mechanical maintenance is aware of and adheres to station radiation protection procedures, this open item is close (Closed) Open Item 50-373/87032-06; 50-374/87031-06: Review procedures and training for drywell access during spent fuel movement. Prior to fuel movement during this outage, the licensee revised procedures LFP-100-1, Master Refuel Procedure, and LFS-100-4, Core Alteration i Shiftly Surveillances; and wrote a new procedure, LAP-1120-3, Drywell l Access Control During Fuel Moves. These procedures consistently describe drywell access controls during fuel movement. Formal training and notifications were given to personnel before fuel movement. In addition, with data obtained from a study conducted during this outage, the licensee has resolved the apparent discrepancy between a dose rate value in the FSAR and a previous study. The difference between the values is attributed

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to the fact that the FSAR value is based on calculations that did not consider background radiation levels, whereas background was included in values recorded in the previous stud (Closed) Open Item 50-373/87032-07; 50-374/87031-07: Implement separate controls for access to high, high-high, and very high radiation areas in the two units. The licensee has modified the status level designation of doors to high and high-high radiation areas in the two units so that different keycards are required for eritry. Access to doors to very high radiation area (those areas where a whole-body dose of >20 Rem could be received in one hour) is controlled on an individual entry basi (Closed) Open Item 50-373/87032-08; 50-374/87031-08: Review adequacy of the routine contamination survey program for horizontal surfaces above 6 feet and prepare to decon the radwaste truckbay above 6 feet. Based on their review, the licensee will continue to smear-survey horizontal surfaces above 6 feet only if individuals are scheduled to work in the area, except for the radwaste truckbay which will be surveyed and cleaned quarterl As described below, the licensee has made an adequate review of several recently issued NRC Information Notice Notice No. 86-20: Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 6 The station program for low-level radwaste adequately addresses the problems described in this Notice (see Section 14).

Notice 87-03: Segregation of Hazardous and Low-level Radioactive Waste Station procedures require ir,spection of solid radwaste to verify that no solid or liquid chemicals are packaged with the radwast Liquid radwaste is evaluated, usually with corporate assistance, to determine the presence of EPA nazardous wastes (see Section 14).

Notice No. 87-07: Quality Control of Onsite Dewatering / Solidification Operations by Outside Contractors. The licensee's QC and QA departments routinely audit radwaste/ transportation activities, including those involving dewatering / solidification operations by the onsite contractor (see Section 15).

Notice No. 87-31: Blocking, Bracing, and Securing of Radioactive Materials Packages in Transportation. Station procedures, with appropriate checklists, adequately address this Notice. The licensee's QC and QA departments also verify the blocking, bracing, and securing of radioactive materials packages in each shipment of radicactive material that leaves the site (see Section 15).

Notice No. 87-32: Deficiencies in the Testing of Nuclear-Grade Activated Charcoal. In response to this Notice, the licensee has changed vendors and now uses one of the two vendors who satisfied the requirements of interlaboratory comparison conducted for the NRC by the Idaho National Engineering Laborator _ _ _ _ _

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Notice No. 86-23: Excessive Skin Exposures due to Contamination with Hot Particles, and Notice No. 87-39: Control of Hot Particle Contamination at Nuclear Power Plants. The licensee has a strong corporate / station program concerning instruction on and control of hot particles (see Section 9 of this report and Section 15 of Inspection

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Reports No. 50-373/87032 and No. 50-374/87031).

4. Organization and Management Controls (IP 83722)

The inspectors reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, and experience concerning self-identification and correction of program implementation weaknesse Currently, 38 of the 39 station Radiation / Chemistry Technician (RCT)

positions are filled; one RCT was recently reassigned as engineering assistant to the ALARA Coordinator replacing the former assistant who was promoted to Radiation Protection Foreman. All 38 RCTs currently meet ANSI 18.1-1971 qualifications for technicians in responsible positions; the last group of 6 technicians became ANSI qualified in March 198 The permanent radiation protection staff appears stable w!th minimal staff turnove Since last reported (Reports No. 373/87032 and No. 374/87031), one of the station's four staff health physicists (HPs)

with nearly two years station experience tenninated employment. The licensee is actively recruiting to fill the vacated positio The remaining three staff HPs have degrees in health physics or a related field and range in station experience from about nine months to over four year The Rad /Chen contrictor who was a liaison between the radiation protection staff and station construction and mechanical maintenance has been reassigned to the ALARA group; however, much of the individual's liaison duties have been assumed by a newly appointed Rad / Chem contractor (Section 3). The latter individual reports to station constructio The inspectors reviewed the experience and qualifications of the two contractor liaisons; both individuals possess several years related working experience in radiation protection at various operating plant In 1988, the station formed a task force to review personal contamination event The task force is composed of two health physicists and supervisory personnel from plant services, operations, maintenance, and contractor organizations. The group typically meets at least weekly to review contamination events that occurred during the previous week (Section 9(c)).

No violations or deviations were identified.

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5. Training and Qualification of New Personnel (IP 83729)

l The inspectors reviewed the licensee's selection criteria and the 1 education and experience qualifications of contract radiation protection I personnel and training provided to the Licensee selection of contracted radiation protection-technicians includes review of resumes to determine conformance to ANSI 18.1-1971 criteria for responsible technician The licensee considers individuals with three years (6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) working experience in their speciality or two years plus a related associate degree, as senior technicians. Junior technicians must possess at least one year experience. The licensee does not routinely verify the experience / qualifications stated in resumes and normally reserves such verification for the contractor. According to the vendor site coordinator, resume authenticity is verified by telephone contact with previous employers. Over 50% of the contract radiation protection personnel hired for the outage have previous nuclear station radiation protection experience. Resumes of selected technicians currently working at the station were reviewed by the inspectors; no problems were note After technicians arrive on-site they are required to undergo a one-half day radiation protection theory (refresher) course. Senior technicians must pass with a minimum score of 70% a written exam on nuclear physics theory, 10 CFR 20, and practical health physics problem solving. A retest is allowed at the licensee's discretion for those who fail the initial exa The 40-50 question exam was reviewed by the inspectors and appeared to be moderately difficult; several completed exams were reviewe Following successful completion of the raciation protection theory exam for applicable personnel, each contracted technician is required to complete Nuclear-General Employee Training (NGET), respirator training and fit testing, and three days of site-specific radiation protection procedures training. An exam is administered-at the conclusion of the ,

procedure training; a minimum score of 70% is required for senior and junior technicians. Two control point technicians working at the station during the current outage also attended the procedures training but were not required to complete the test. During the outage, the two technicians were exclusively assigned to observe, and correct if necessary, workers removing PCs at the Unit 1 control point. Inspectors selectively'reviewe d lesson plans and training and exam records; no problems were note Technicians not meeting ANSI 18.1-1971 experience-criteria are assigned duties commensurate with their training and experience. The licensee's training and qualification program for contract radiation protection personnel appears acceptabl No violations or deviations were identifie :

6. , Planning and Preparation (IP 83729) l l

The inspectors reviewed the outage planning and preparation performed -l by the licensee, including: additional staf fing, special training, l increased equipment supplies, and job related health physics l consideration j l

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For the outage, health physics personnel were involved in pre-outage reviews for major jobs and routine jobs. The reviews were apparently performed in considt: ration of radiological conditions and scope of work to be performed and in accordance with procedures (except for incident described in Section 12). Radiation protection staff reported that there were periods in which many work requests reauiring review were issued at one time. However, the licensee indicated that although this problem slowed certain outage activities, there were no compromises in performing adequate radiological review The station's radiation protection group had been augmented with 30 contract health physics workers during the first several weeks of the outage and increased to 36 workers to provide more surveillance and control over radiological activitie For this outage, the station maintained adequate coordination between the station radiation protection department and contract worker . External Exposure Control and Personal Dosimetry (IP 83729, 83724)

The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in the program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports and notification !

For the Unit I refueling / maintenance outage, the licensee established a temporary radiation protection ingress / egress and dosimetry control

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station in Unit 2, Personnel needing access to the Unit 1 drywell (and the control rod drive rebuild room) were channeled through this statio Normally two radiation protection technicians continually man the control station where drywell related RWPs, associated survey maps and secondary dosimetry are maintained and issued. Minimum personal monitoring requirements for drywell access include a TLO, direct reading dosimeter (DRD), and an electronic dosimeter. Technicians manning the control :

station issue the electronic dosimetry and record the exposures received 1 by drywell workers on dose cards. The flow of materials, equipment and i personnel in and out of the Unit 1 entrance is monitored by the technicians manning the station and by one of two control point technicians assigned exclusively for that purpose. Dose cards maintained at the radiation

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protection office (main RCA control point) are used to track daily ORD exposures for non-drywell related wor )

Currently, about 2100 workers are issued dosimetry at the station, of which 65% are contractors supporting the outage. According to the licensee, this is the largest number of individuals that have been issued dosimetry at the station at any one tim For 1987, the station's total exposure was about 1395 person-rem; exceeding 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

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i on snubber testing and reduction and a drywell cooling modificatio The unscheduled Unit 1 maintenance outage from May to September 1987 contributed approximately 300 person-rem to the year-to-date tota The licensee's station exposure goals for 1988 and for the Unit 1 refuel / maintenance outage are 1100 and 520 person-rem, respectivel Through March 1988, 346 person-rem has been expende No violations or deviations were identifie . Internal Exposure Control and Assessment (IP 83729)

The inspectors reviewed selected aspects of the licensee's internal exposure control and assessment programs, including: determination whether engineering controls, respiratory equipment, and assessment of intakes meet regulatory requirements, and planning and preparation for maintenance tasks including ALARA consideratio Overview The licensee's programs for controlling internal exposures during this outage include the use of protective clothing, respirators, and portable ventilation equipment as well as control of surface and airborne radi'oactivity. The inspectors selectively reviewed the

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licensee's air sample and survey program for drywell activitie It appears that sufficient air samples are collected and analyzed, and that sufficient direct and smear surveys are performe The licensee used their commercial whole-body counter during this outage for base-line counting of incoming contractor personne The inspectors observed whole-body counting of several workers and '

selectively reviewed whole-body count results. No person exceeded the 40-hour control measure and no significant internal deposition was identified. Contractor and nonstation Ceco personnel are counted when they complete their work at the Station.

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The inspectors selectively reviewed the licensee's relevant whole body count (WBC) procedures and the WBC facility and equipmen The inspectors noted that a vendor recently verified that the WBC system response had not changed significantly since the previous calibration performed in March 1987. A full calibration of the WBC system is scheduled for April, 198 Respiratory Protection Workers' NGET cards indicate their qualifications related to respiratory protection. This includes their medical evaluation, proof they have received required training, and type of respirators ;

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they are qualified to wear. The inspectors observed the issuance of :

respirators durir several shift changes. To receive a respirator, !

the workers must show their NGET cards to the RC The RCT reviews the card to determine if the worker is qualified for the respirator requested, and is required by Procedure LRP-1310-4 to initial the Respirator Equipment Log Sheet to verify that the recipient was

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i qualified and the respirator was issued. The inspector noted that several of the Log Shects for March 1988 had not been initiale This is a violation of the licensee's Procedure LRP-1310-4 (Violation 373/88009-01(A); 374/88009-01(A)).

The licensee's primary respirator accountability mechanism to ensure respirator equipment is returned by an indiviaual before another respirator is re-issued to the same individual is that the RCT is required to initial the Log Sheet upon return. During this inspection, it was noted that several days'may elapse before the RCT verifies that respirators have been returned and initials the Log Shee This system for respirator accountability appears weaker than the licensee's previous system of requiring workers to turn in their NGET card before respirator issuance, and returning the NGET card after respirator retur This matter was discussed with the licensee and will be reviewed at a future inspection (0 pen Item 373/88009-02; 374/88009-02).

A cursory check of respirators that were ready for use showed that respirator inspection, storage, and maintenance was adequat One violation was identifie . Control of Radioactive Materials and Contamination (IP 83729, 83726)

The inspectors reviewed the licensee's program for control of radioactive ,

materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program; and experience concerning self-identification and correction of program implementation weaknesse Drywell Radiological Controls i The inspectors selectively reviewed records of routine and special radiation, contamination, and air sample surveys conducted during the outage to date. Routine weekly surveys are performed within l the drywell at various elevations and locations to identify general radiological conditions and trends. Jcb-specific drywell surveys are performed prior to job initiation and as needed during the course of a job. Survey results are normally reviewed by a shif t radiation protection foreman for completeness and any unusual conditions. Radiological protection requirements for drywell activities are dictated by the job-specific survey results and their implementation is verified by technicians providing job coverage and manning the control point station, and by the radiation protection foreman assigned to supervise drywell activitie i

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N The inspectors reviewed several RWPs and associated survey maps for various drywell work activities, discussed their appropriateness with radiation protection representatives, and observed numerous workers performing activities under the RWPs. No probleus were noted. Specifically, the inspectors reviewed RWPs No. 80279A and B for drywell s.iubber removal and No. 80346A for removal and installation of insulation in the drywel Protective requirements including respiratory protection appeared appropriate. Due consideration r ..;o appeared to be given to dosimetry placement and ALAR Generally, respiratory protection was not required for most drywell activities unless cutting, grinding or other possible airborne or liquid contaminant production activities were conducte No significant problems were noted with the methods established for control of radioactive materials and contamination, b. Radiological Controls for Diver Operations The inspectors observed portions of the dryer / separator pool gate repairs which required diver entry into the pool. An appropriate RWP was written and pre-job surveys of the work area were performe Adherence to station procedure LRP-2100-12, governing such activities, was verified by the inspectors and included an ALARA review and pre-job briefing, and use of multiple, personnel monitoring devices including remote readout electronic dosimetry monitored by RCTs covering the dive. Surfaces were wetted to reduce potential airborne contaminants when the gate was raised from the pool. No significant problems were identifie c. Personal Contamination Events LaSalle Radiation Protection Procedure, LRP-1470-6, requires a

"Personnel External Contamination Event P.ecord" be completed when personnel contamination (skin and/or clothing) is detected with an HP-210 probe or equivalent in a back 0round < 300 cpm or a

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"Contamination Event Log" entry made when contamination is initially detected with a whole-body contamination monitor but is not greater than 100 cpm above background with an HP-210. A Radiological Occurrence Report (R0R) is required if skin or personal clothing contamination yields radiation levels greater than 1 mR/hr above backgroun The inspectors reviewed personal contamination event (PCE) trending and summary data and discussed the identification, investigation, and corrective action program with the licensee; several recent events were specifically reviewed. In 1988, the station formed a task force to review PCEs and strengthen event investigation and implementation of corrective actions. Since then, the inspectors noted improvement in the investigation and documentation of PCE Corrective actions include contacting the individual's supervisor, counselling, and requiring those involved in repetitive events to re-attend relevant aspects of NGET. More stringent disciplinary actions have been taken when warrante g e d

In 1987, the station recorded approximately 565 PCEs of which 85%

occurred coincident with outage activitie Approximately 450 events occurred each in 1985 and 198 Ninety events were reported for the first three months of 1988; thirty-three since the start of the outage on March 13, 1988. The number of PCEs per 1000 RWP hours worked has trended down since 1985. The station averaged about 19 PCEs per 100 RWP hours in 1985 and about 3-4 in both 1986 and 198 However, such data comparison is highly dependent on the specific work activity and total number of RWP hours worked. It does not include events attributed to non-RWP activities which, as noted below, appear to comprise a significant contributio The licensee attributed the cause of most 1987 contamination events to "poor work practices" and "contaminated clean areas."

In 1987 and 1988 to date, about 27% and 20% of the PCEs were attributed to contaminated clean areas, respectively. However, the licensee believes the data may be skewed, particularly in 1987, because of doubts concerning determination of the true root caus Alternatively, many contaminated clean area events may be attributed to weaknesses in the routine radiological survey program for clean areas. In addition, worker adherence to frisking procedures may need strengthening as described in Section 17 and further evidenced by several outage-related significant PCEs (>30,000 dpm on the skin)

which were initially identified at downstream whole-body contamination monitors and not detected at the drywell egress frisk statio Only about 20% of the approximately 20 outage related contamination events occurring in the drywell were detected at the drywell egress frisker (hand-held) station. Skin contamination including hot particles could go undetected if hand-held detector frisks performed after PC removal are not performed properly. Although workers exiting the RCA usually pass through a whole-body contamination monitor and then must pass through a gatehouse portal monitor before leaving the l station, this is done after donning street clothes which could mask I the presence of beta emitter < Therefore, it appears desirable to monitor primary egress poi' ., during periods of increased plant traffic flow to assure personal frisking is performed properly, contaminated equipment and tools are not inadvertently taken into i clean areas, and frisker alarms are reporte l The 1988 station goal is 245 PCEs; individual department and work group goals have also been established. These goals may be difficult to meet unless the licensee reduces the number of events occurring in clean areas and improves worker adherence to radiological work practices. Therefore, it appears desirable to review the routine radiological survey program conducted in general (clean) plant areas, particularly as performed at and around S0P These matters were discussed at the exit meeting and will be reviewed during a future inspection (0 pen Item No. 373/88009-03; l 374/88009-03).

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d. "Hot Particle" Events and Skin Dose Assessment The inspectors selectively reviewed the licensee's investigation of personal contamination incidents involving minute discrete radioactive particles (hot particles) recorded for 1987 and 1988 to date. Seven incidents were identified during this period, three of which were previously discussed (Inspection Reports No. 373/87032; 374/87031). The licensee conducts an investigation of each event including interviews with the individual involved and a review of related work activities. A skin dose assessment is performed for all hot particle events, and for non-hot particle skin contamination events involving greater than 1.7E6 dpm on the soles of the feet or palms of the hands, and greater than 42,000 dpm on other area The inspectors reviewed the licensee's investigation and dose calculational methods; no problems were noted. No overexposures occurred as a result of the incidents and no violations of regulatory requirements were identified; however, improvements are desirable in documenting the assumptions used to determine the duration of the exposur e. Laundry Program Protective clothing is laundered at the licensee's facility by stationmen using three dry-cleaning units and/or by sending the laundry to a commercial laundry for wet washing. In 1988, the station began using the services of a commercial nuclear laundry facility located nff-site but near the statio Approximately 80%

of the laundry resulting from outage activities is currently sent to the vendor, the remainder is laundered by the license Licensee representatives stated that the turnaround time for the vendor is about two day The licensee appears to have an adequate supply of "clean" PCs available for the outag The licensee recently made operational an automated launary monitor employing gas flow proportional detectors located above and below, and traversing the width of a cenveyor mesh. The station fabricated two cobalt-60 100 cm2 plate sources each with an activity of about 120 nCi to establish monitor alarm setpoints. The licensee plans to gradually reduce the monitor alarm setpoints to comply with recently issued corporate guidance. The corporate release limit of 104 nCi/cm is based on contamination inside the PC so as not to exceed 25% of the NRC quarterly skin dose limit from a four-hour cobalt-60 hot particle skin exposure. Accoraing to the licensee, the vendor laundry monitors clothing using equipment and methods equivalent to those of the licensee. Vendor monitor alarm setpoints are established using one of the licensee's fabricated sources and are set slightly below that used by the license e. The licensee randomly spot-checks (monitors)

clothing laundered by the vendor. The inspectors observed workers using the station laundry monitor and questioned them concerning monitor alarms and PC rejection criteria; no problems were note Any article of clothing which causes the monitor to alarm two out of three times is considered to have failed; clothing is monitored

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inside out. Procedures have been developed for operation and alarm setpoint verificatior. af the monitor and for laundering and surveying methods. However, tht procedures do not address the frequency of alarm setpoint veri _fication, indicate that PCs be monitored inside out, and do not ade.ress spot-checking of vendor-laundered item The licensee agreed to revise the procedures to address thcse item The procedures will be reviewed at a future inspection (0 pen Item'

No. 373/88009-06; No. 50-374/88009-05).

No violations or deviations were identifie . Radiation Occurrence Reports (RORs)

The inspectors reviewed RORs generated pursuant to station procedure LRP-1150-1 for 1988 to date and reviewed trending data for 1987. .The licensee trends and categorizes RORs by work group and type of occurrence under the major classifications of external dose control, internal dose and surface contamination, administrative controls, and others. R0Rs are generally written for violations of station radiation control standards and procedures and any significant action or situation inconsistent with the ALARA philosoph During the first three months of 1988, eleven R0Rs were generated. Most involved contamination or exposure control problems caused by failure to follow radiation protection procedures or adherence to RWP requirement The reports were reviewed for significance, recurrence, and adequacy of corrective actions. No significant problems were identified; adequate corrective actions appear to have been taken. Three RORs generated in March 1988 remain open pending further licensee investigation. One recent exposure incident that was the subject of an ROR is discussed i in detail in Section 12. Sixty-three R0Rs were generated in 1987, 35% r attributed to contamination control problems and 27% to administrative (procedure or RWP non-adherence) controls. Since previously reported (Reports No. 373/87032 and No. 374/87031), two RORs were issued against ;

the mechanical maintenance department; no significant repetitive problems were noted in 1988. None of the R0Rs generated thus far in 1988 were related to respirator testing or whole body count scheduling, i

Overall, the licensee's review and corrective action program for RORs appears adequat No violations or deviations were identified.

1 ALARA (IP 83728 and 83729)  ;

The person responsible for the ALARA program was involved in the planning of certain outage jobs. Some of the major outage jobs include removal and replacement of 16 control rod drives (CRD); decontamination of the l drywell; drywell insulation; removal, testing and replacement of snubbers; and the installation of supplemental cooling equipment in the drywel l

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The licensee took major ALARA steps to reduce exposures for the outag To implement ALARA for certain job tasks, the licensee performed a chemical decontamination of the recirculation loops (Section 13), flushed the ECCS system, hydrolazed the reactor cavity drain and the scram discharge volumes, purchased a CRD removal / replacement machine, shielded the reactor bottom drain line and hot spots as warranted, and video taped drywell work. Except for the problem described in Section 12, no violations or deviations were identifie . Personal Exposures in Excess of Administrative Limits At about 9:30 p.m. on March 30, 1988, five construction workers performed flapping (power sanding) operations on a feedwater nozzle located on the 796-foot elevation of the Unit 1 drywel Based on a survey performed at about 5:00 p.m. on the same day, the highest radiation fields found ranged from 1.5 R/hr and 12 R/hr at 18 inches and contact, respectively, on the top of the feedwater nozzle to 6 R/hr and 45 R/hr at the same locations on the bottom of the nozzle. The workers were personally timekept and '

under constant surveillance of a health physics technician. Each worker wore five alarming digi-dosimeters, five TLDs and five DR0s on various parts of their body, and were authorized a whole-body dose limit of 300 mrem for the day. The digi-dosimeters were set to alarm at 256 mre During the flapping, two of the workers exceeded the authorized limi One worker whose dosimetry equipment was worn above his right knee 6 received 385 mrem and 390 mrem on the DRD and digi-dosimeter, respectivel The other worker whose dosimetry was worn above the right elbow received '

450 mrem and 588 mrem on the DRD and digi-dosimeter, respectively. After the second worker exceeded the authorized limit the licensee discontinued feedwater nozzle flapping operations, performed a post-job survey, sent l 4 the TLDs for processing, and initiated an ROR and an investigation to determine the cause of the administrative overexposure , The licensee's review of the incident indicated the following: Stay times for all workers were based on radiation fields found

during the 5

00 p.m. pre-job survey and a pre-job survey performed by the attending health physics technician immediately before the operation started. The stay times for both workers who exceeded the administrative limit were based on a contact dose rate of a 10 R/hr, hot spot found on the left side of the pipe. Although the workers l were not performing flapping operations at this spot, the technician conservatively determined it was the highest dose rate to which the workers could be exposed, A survey performed after the ircident indicated a small hot spot of 20 R/hr on the feedwater nozzle near the 10 R/hr hot spot found during the pre-job surveys. The 20 R/hr spot was not found during the pre-job survey The first worker to exceed the administrative limit was working in a position such that his right knee was close to the nozzl After working in this position for a while he thought he heard his

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digi-dosimeter alarm, however, he wasn't sure, and after thinking about it for a few moments he decided to leave the work are The second worker to exceed the limit was working even closer to the nozzle and was authorized to work in the area for'90 second However, during that time, the digi-dosimeter set to alarm at 256 mrem malfunctioned and no alarm was sounded; he continued to wor The workers probably exceeded the administrative limit because of their location relative to an unknown higher radiation field, and because one worker didn't hear his digi-dosimeter and the other worker's digi-dosimeter malfunctione The processed TLDs indicated the worker whose right knee and the worker whose right arm were close to the 20 R/hr hot spot received whole-body doses of 546 mrem and 410 mrem respe.:tivel The inspectors' review of the incident indicated the following: The licensee's ALARA review for this job was based on radiological survey results found during a similar job previously performed in Unit 2. The highest radiation level found on the feedwater nozzles during those surveys was 6 R/hr. Although procedure LRP-1160-4,

"ALARA Action Review," allows the licensee to base ALARA reviews on radiological conditions from similar jobs previously performed, it also requires that if actual radiological conditions are significantly different than the values first used (6 R/hr), then the ALARA review ,

shall be amended or rewritten. The survey results used for this job indicated 10 R/hr to 40 R/hr hot spots on the feedwater nozzle -

and the ALARA review was not r(written or amended; this is a violation of procedure LRP-1160-4 (Violation No. 373/88009-01(B);

374/88009-01(B)). Although the 20 R/hr hot spot was not identified during the pre-job surveys, the radiation protection technician covering the job had set stay times conservatively enough to prevent a regulatory overexposur . Unit 1 Recirculation System Chemical Decontamination During this outage, the licensee chemically decontaminated the Unit 1 recirculation system. The decontamination was performed by LN Technologies Corporation (LN) using the LOMI (Low 0xidation-State Metal Ion) decontamination process. LN has used this process recently at i several other Commonwealth Edison plants, however, this was the first use at LaSalle. Preliminary results of the decon indicated that decontamination factors of 3-5 were attained and that approximately 31 curies of Co-60 and 90 curies of Fe-55 were removed from the syster LN also packaged and solidified the resins used for the decon (Sections 14 and 15). An inspector observed the setup and initiation of the sluice of resin from the ion exchange vessels to a liner in the Unit 1 Reactor Building trackway. The setup included coordination of activities with security and the shift engineer, designation of a temporary high radiation area, obtaining dose limit extensions for workers, and conducting a pre-job briefing. The sluicing operation was conducted during the late '

backshift hours. No problems were identified ~by the inspecto :

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i 14. Solid Radwaste (IP 84722)

The inspectors reviewed the licensee's solid radwaste program for compliance with waste generator requirements in 10 CFR 20.311 and 61.5 Included in this review was an examination of waste manifests, scaling factor and curie-content determinations, and management oversigh As stated in Section 15 most of the radwaste shipped by the licensee is dry active waste (DAW). A smaller volume is solidified and dewatered waste. To date, the licensee has not shipped liquid process /radwaste filter A selective review of manifests for shipments made in 1987 and 1988 indicated that the manifests contained all of the information required by section 20.311 (b) and (c).

At least annually, the licensee sends waste stream samples to Science Applications International Corporation (SAIC) for isotopic analyses and scaling factor determination. These waste steams samples include swipes from the compactor and general plant work areas (for DAW characterization)

and samples of reactor water, reactor water crud, evaporator bottoms (concentrator wastes), and waste sludge, spent resin, ultrasonic resin cleaner (or URC), and phese separator tanks. In addition, in-house isotopic analyses are usually performed for each batch of liquid system

, waste prior to dewatering ai.a solidification. For DAW, in-house isotopic analyses are performed quarterly to determine if there has been a significant change from the values determined by SAIC. Results of SAIC analyses and scaling factor determinations, and dose rate measurements 3 of prepared packages are used by the licensee to generate manifest A selective review by an NRC inspector of the results of these analyses and determinations indicated no problem To date, the licensee has not shipped Class B or C waste. The Class A waste is shipped either as unstable waste or as stable waste in high integrity containers or solidified in cement with the licensee's Stock Equipment Company solidification system or, more commonly, with a vendor's solidification system (Westinghouse Hittman Nuclear Incorporated).

Station QC verifies dewatering and solidification. The NRC inspector identified no problems with the licensee's waste characterization and stabilization program In early 1988, the onsite QA department conducted an audit of Westinghouse Hittman's onsite operations to verify that the vendor was implementing their (Hittman's) QA program for radwaste solidification and packagin The audit was initiated after a similar audit of the same vendor at Byron resulted in several findings. The audit at LaSalle resulted in 5 findings and 3 open items, all of which had been closed by the time of the NRC inspectio For the spent resin from the recirculation system decontamination job (Sections 13 and 15), the licensee determined the quantities of chelating agents (required by 10 CFR 20.311 and by the burial sites) and EPA hazardous wastes. Because the chelant loading (consisting of formic and

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v picolinic acids) was 5.4% by weight, exceeding the burial site limit of 0.1%, the licensee stabilized the waste in cemen The only hazardous waste in the resin was chromium, but because the concentration of the chromium'was below EPA limits, the solidified waste was not considered a mixed waste (see NRC Information Notice No. 87-03). In addition, tests were performed on samples of the solidified wastes to verify that requirements of LN's Process Control Program were met. According to a licensee representative, the solidified waste met those requirement No deviations or violations of NRC requirements were identifie . Transportation of Radioactive Materials (IP 86721)

The inspectors reviewed the licensee's radioactive materials transportation program to determine whether shipments are prepared and made in compliance with NRC and DOT requirements and with the licensee's administrative and implementing procedures. In addition, selected aspects of the corporate and station oversight activities were reviewe Most of the radioactive material shipped from the station, by volume and by activity, is low specific activity (LSA) DAW and solidified or dewatered wet wast In 1987, approximately 150 shipments of radwaste (totaling approximately 2300 Ci) were made, with most of the radwaste sent to the burial site in Beatty, NV. To date in 1988, 14 shipments have been made. Most of the DAW shipped is packaged in 55 gallon drums, but 96 ft3 boxes are occasionally used. Recently, the station has been shipping compressible DAW to facilities in Illinois and Tennessee for supercompaction. In addition, non compressible, contaminated metal items have been sent to waste-treatment facilities in Pennsylvania and Tennessee for decontamination and disposal. The licensee expects to make greater use of the supercompaction and decontamination facilities in the futur Solidified /dewatered wastes are shipped in 55 gallon drums, or large capacity liners and high-integrity containers. Radwaste shipments are usually controlled by the operations departmen As part of the contract for the decontamination of the Unit 1 recirculation system (Section 13), the vendor sluiced the resin from the ion exchange beds to a vendor-supplied liner, solidified (with cement) the waste after dewatering, and will be transporting the liner to a burial site. Because the resin contained greater than Type A quantities of radioactive material, the licensee as a shipper had to comply with requirements of the general license specified in 10 CFR 71.1 (Preliminary calculations indicated the resin contained approximately 31 curies of Co-60; the Type A limit for Co-60 is 7 curies.) As required in section 71.12, the license was registered as a user of the Model LN 14-170 cask containing the solidified resin prior to using the cas With the start of the 15-week outage, the licensee has been shipping protective clothing (PCs) to a nearby nuclear laundry (see Section 9).

The PCs are shipped as LSA and packaged in 96 ft3 boxe Laundry shipments are controlled by the stationmen departmen *

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In addition to radwaste and laundry, the licensee also ships radioactive samples to contractor labs for analyses. This material is usually sent as "excepted material, limited quantity," per 49 CFR 173.421 or as Type A material. Shipments of samples are usually controlled by the chemistry departmen A review by an NRC inspector of selected shipment records for 1987 and 1988 and the 1987 semi-annual solid waste reports (required by Technical Specification 6.6.A.4.), discussi~ons with licensee representatives, and observations of packages being loaded for shipment offsite indicated no problem Coordinating the shipments of the three departments for radiological purposes is the health physics staff (HP) and the QA and QC department HP surveys all outgoing packages and vehicles containing radioactive material. In addition, HP verifies curie content calculations; reviews shipping papers and package marking and labelling; and verifies that the ;

consignee is licensed to receive the radioactive materia The QA and QC departments review all of the shipments for compliance with selected procedures, requirements, and commitment In addition to inspections of each shipment prior to shipment, the QA department performs monthly surveillances of radioactive shipment

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activities and an annual audit of radwaste-transportation activitie The QA department has also inspected the new offsite nuclear laundry used by the station and has inspected repair work being done on a licensee-leased shipping cask at two out-of-state facilities. A selective review by an NRC inspector nf reports of these surveillances and of the 1987 audit indicated that the scope of the surveillances and audit was adequate. Training records for several of the QA personnel -

involved in reviewing shipments indicated that the auditors were qualified to review this are The NRC inspection indicated overall high corporate and station involvement and performance in transportation activitie No deviations or violations were identifie . Fuel Pool Liner Leakage (IP 92705)

Each of the station's two units is equipped with a spent fuel storage pool lined with stainless stee Each pool is designed such that it cannot be drained to a level below that of the top of the fuel storage racks. A leak detection system is provided for the detection and collection of possible leakage behind the pool's liner plate. Each liner is segregated into quadrants which collect leakage (through leak-off lines) at independent sumps located under each corner of the pool. Flow from the sumps is monitored by flow switches equipped with alarms that annunciate in the control room; alarms are set at 1.92 gp Liner leakage is diverted from the sumps into the waste collector tank.

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Shiftly operator rounds include visual observation of each sight flow indicator, recorded (checked-off) on "Reactor Building and Off-Gas i Building Rounds" sheets. Abnormal conditions identified during rounds are required to be corrected on the spot or reported to the shift foreman. The inspector selectively reviewed operator rounds sheets for 1988 to Cate; no liner leakage was noted. According to the licensee,

, no signif. cant liner leakage has ever been identifie No violations or deviations were identifie . Surveillance-Piant Tours The following wera identified during tours of the plant: On one occasion, workers who had removed their protective clothing in accordance with step-off pad (S0P) instructions, were observed to exit from the 50P area and perform a rapid, superficial frisk of themselve The failure to make a personal contamination survey (whole-body frisk) in accordance with frisking instructions is a violation of the licansee's procedure, LRP-1480-4, "Personal External Contamination Surveys (Hand Held Probe)," (Violation 373/88009-01(C); 374/88009-01(C)). Somewhat related to this violation are the inspectors' concerns pertaining to personal contamination events; see Section 9 One of the major egress points from the reactor building during this outage was the Unit 2 D/G corridor which is equipped with three whole-body friskers. Contract HP technicians are scheduled to cover l this egress point during selected peak traffic hours. The primary !

function of the technicians are to ensure that workers sign-in on !

the correct RWPs, ensure workers properly moniter themselves, direct

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contaminated workers to the 15-line monitoring station in the turbine building, and ensure no tools / equipment are carried out. On a few occasions during this inspection it was observed that technicians d

were not in attendance during the selected hours for cove age in the Unit 2 D/G corridor, and on one occasion the inspectors noted the attending technicians were not aware of their responsibilities for ensuring worker adherence to requirements. In addition, the

insoectors noted that significant numbers of workers egress at this location during non peak periods in which HP technicians were not in attendance. Although a large percentage of workers egressing at this location have performed hand-held frisk surveys at upstream work locations, the lack of full-time health physics coverage at the primary reactor building egress location during a major maintenance outage is a poor practice. This matter was discussed at the exit intervie ;

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c. During a tour of the auxiliary building on elevation 767', the inspectors observed the sampling and measurement skid of the SAIC Model 400 Radioactive Gaseous Effluent Isotopic Monitoring System (RAGEMS) used by the State of Illinois to monitor station gaseous releases from the stack. From discussions with licensee representatives, it was determined that the licensee does not impose as stringent of radiological controls for State of Illinois personnel who are performing work on the RAGEMS as are imposed for CECO personnel who perform work on the licensee's gaseous effluent monitoring equipment. State of Illinois personnel reportedly do not routinely consult with licensee radiation protection personnel

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before working on the RAGEMS, and licensee personnel do not normally perform radiological surveys of the RAGEMS equipment incident to work performed by State of Illinois personne However, according to licensee personnel, the RAGEMS skid presented only a minimal radiological concern, similar to that of the licensee's own stack monitoring syste Licensee representatives stated that the electronic repair equipment used by the State of Illinois technician who maintains the RAGEMS is surveyed by the licensee before removal from the plant. Discussions with the licensee and the technician indicated that samples from the skid are not removed from the station by the technician. According to the technician, these samples (iodine and particulate cartridges from the automated sampling and measurement portion of the RAGEMS) are disposed of by the technician in the station's tras The employee did not indicate that he performed surveys in the skid or of the filters i with a survey meter, nor was a survey meter visible in the skid or with the technician's equipment. The technician stated that his training was in electronics and that he was responsible for maintaining the skid. A review of CECO training records indicated that the technician has received NGET training. According to the technician this particular skid was a prototype of systems installed at other stations in Illinois and has been plagued with electronic and mechanical problems. Discussions with the technician and the licensee indicated that the licensee was unaware of the extent and frequency of maintenance performed on the syste )

The licensee agreed to perform more extensive surveys of the intericr and eAterior of the skid, to ensure that any material removed from the skid is properly disposed of, and to ensure that station radiation protection procedures are followed during maintenance on the syster. This matter will be reviewed further at a future inspection (0 pen Item No. 373/88009-04; No. 50-374/88009-04).

d. During one of the tours of the Unit 1 drywell, license representatives emphasized to the inspectors that prior to the outage a high priority was place on painting the drywell control area (bullpen) to facilitate decontamination; and that during the outage the RCTs assigned to the bullpen are instructed to keep workers who are in the bullpen area away from the drywell hatch. The licensee stated that although the dose rate at the hatch was only 1 mR/h (approximately), the dose rate in an adjacent area was 0.3-0.5 mR/h. The instruction was 22 i

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,3 intended as an ALARA dose-saving measur During this tour, the inspectors observea workers staging in this low-dose area and an RCT directing personnel away from the drywell entrance. The inspectors also observed signs posted outside the drywell directing personnel away from higher dose areas. Inside the drywell, tne inspectors observed postings, temporary shielding, portable HEPA ventilation systems in use, and several RCTs and work groups. No problems were note RWPs for drywell work were posted at the work area control points and appeared to adequately reflect the respiratory protection requirements for the job; health physics personnel manning these control points verify workers are properly equippe . Exit Meeting (IP 30703)

The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on April 7, 1988. The inspectors summarized the scope and findings of the inspection and also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar In response to certain items discussed by the inspectors, the licensee J

acknowledged: the procedural violation (Sections 8, 12, and 17). the inspectors' comments concerning unmanned RCA egress control points and stated that a review would be made to determine if stronger controls were needed at the Unit 2 D/G corridor (Section 17). the inspectors' comments concerning the number of personal contamination events attributed to "contaminated clean areas" (Section 9(c)). the inspectors comments on the high level of corporate and atation involvement in transportation activities (Section 15). the inspectors comments on the licensee's recent acquisition of several whole-body and hand and foot monitors; and on the improvements in contamination detection ability at the gatehous NRC management comments on the noticeable, high quality improvement in the station's radiation protection program over the past several year _ _ _ _ _ _ _