IR 05000373/1989024
| ML20011E890 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/05/1990 |
| From: | Michael Kunowski, Paul R, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011E886 | List: |
| References | |
| 50-373-89-24, 50-374-89-23, NUDOCS 9002220675 | |
| Download: ML20011E890 (10) | |
Text
"
'
.
,
,
,
w 3,;
w
+
..
.
z i
- k!'
'
O
~
'O.S.cNUCLEAR REGULATORY-COMMISSION
REGION III
-
4
,
iReports.No. 50-373/89024(DRSS);- 50-374/89023(DRSS)
Docket,Nos. 50-373; 50-374-Licenses No. NPF-11; NPF-18 Licerisee:: Commonwealth Edison Company-Post Office Box 767
' Chicago, IL7;60690 Facility.Name:
LaSalle-County Station, Units 1 and'2
,-
.
InspectionLAt:
LaSalle County Station, Marseilles, Illinois.
InspectionLConducted tmb r 16,:1989, through January 5, 1990.
'
n
.p Inspector au[
'
A k
'
ate.
/
))$ '
'
'
-
M. : A. Kunowski 7 ~5 N
'
Date
.
.
hhk n
fa
.-Approved By:
. Schumacher, Chief Radiological-. Controls Date and Chemistry Section Inspection Summary
' Inspection on November'16, 1989, through January 5, 1990 (Reports
.J No. 50-373/89024(DRSS); No. 50-374/89023(DRSS))
.
Areas Inspected: Routine unannounced inspection of.the licensee's radiation j
protection-program during an outage, including organization and management
controls (IP 83750); external and-internal exposure controis-(IP 83750); ALARA, y
_4
= planning and, preparation (IP 83750), radiation ' occurrence reports (IP 83750);-
'
!and review ~of an allegation concerning the NGET program (IP 83729).
<
..
Results: The licensee's radiation protection program adequately protects the health and safety of workers. Good engineered ALARA controls were implemented and
,
observed by the inspectors.
Some weaknesses in the radiation protection program are discussed in Section 11.
a I
^
90d2220675 900206
,
_.
PDR: ADOCK 05000373 V:t T>
Q PNV gyj
6 _
,-
o
,
'
-
T,.
,
o :.
g
_
i
,
f
.t y
DETAILS
,
1.
Persons Contacted'
'
,
- J. Born, Ceco QA
,
- G. Diederich, Station. Manager l
- M.~ Friedmann, Health Physicist
.
y
- T. Hammerich, Regulatory Assurance Advisor
- M. Hayworth', Health Physicist
- D. Hieggelke', Health Physics Services Supervisor _
'
- W. Huntingtor., Services Superintendent
- W. Luett, Operational Health Physics a
A.'Magnafici, Outage Planning
- G. Myrick,-HP Supervisor, NSRP (Corporate)
!
- R. Lanksbury, Senior NRC Resident Inspector
!
- R. Kopriva, NRC' Resident Inspector
The inspector also contacted other licensee and contractor personnel.
- Denotes those present at the exit meeting on January 5, 1990.
I i
2.
General This inspection began on November 16,1989.
Reviewed was the operational-j health physics program during a major refueling and maintenance outage.
!
Also reviewed were several LERs.
Several tours of licensee facilities t
were made including the drywell to review posting, labeling, access and
,
contamination controls, and to observe engineered controls.
Several independent direct radiation surveys were performed.
Special attention-was given to station implementation of its ALARA program and practices, t
The primary purpose of this inspection was to assess the adequacy of
. implementation of the health physics program when challenged:by major
,
outage maintenance and refueling conditions.
The interactions between station health physics, contractor health physics,.and contract
.
maintenance / labor personnel were observed / reviewed during the course
of the inspection; the observed interactions appeared good.
3.;
Licensee Action on Previous Inspection Findings (IP 92701)
(Closed) Open Item (373/88028-01; 374/88028-01): Procedure on monitoring laundered protective clothing will be revised to specify the use of a beta-sensitive instrument when the regularly used laundry monitor is out
-
of service.
The licensee has revised the procedure to specify the use of
-
a beta-sensitive G-M detector (a thin-window, pancake probe) when the regularly used monitor is out of service.
In addition, the radiation
'
limit.for laundered clothing was changed from 1 mR/hr above background at
-
two inches to 10,000 dpm above background at two inches.
,
2
W r,
':.
'i n
,
c I-(Closed)'Open Item (373/88028-02;-374/88028-02):
Procedure on-calibration-
~ and source check of the automated laundry monitor needs revision to.
.
' eliminate' the-practice of using for daily source checks a source with
"
higher activity than-that of the source used for.'the full. calibrations.
L
. The licensee revised the procedure to specify the use of the same source
-
-
,
for the daily,checksLand the-full calibrations.
P
-
(Closed)~ Violation-(373/88017-01; 374/88017-01):
Failure to perform an adequate evaluation to determine radiological conditions of equipment-transferred to an.offsite vendor.
The unconditional release program has been revised to provide better~ release surveys and traceability.
In-addition', theilicensee has reduced unmanned exit control points.
strengthened the. routine survey program outside the RCA, provided training to the RP staff emphasizing the importance of unconditional surveys, and
^y performed an extensive survey of areas outside the RCA.
(0 pen) Open Item (50-373/89017-02; 50-374/89017-02): Actions taken to.
reduce radioactive spills.
The licensee has grouped the cause of spills into.three categories:
poor._ planning, communication, and personnel error; mechanical failure; and system design problems. 'To correct these problems the operating department has revised procedures concerning liquid transfers
'
and systems draining, incorporated into the training program methods to prevent spills, increased worker awareness concerning spills, and addressed me'chanical failures on a case by case basis.
This item remains open.
.
pending a review of the effectiveness of these actions.
(Closed) Open' Item (373/89017-03; 374/89017-03):
Continuation of HRA
- i
. control problems.- Because the station's HRA radiological controls are l
strong,_the licensee believes that poor understanding of HRA controls
!
caused the continuing problem. As a result, training on high radiation area access controls is stressed in NGET, annual retraining and department meetings.
These actions appear to be effective; there have been no HRA incidents since May, 1989.
(Closed) Open Item (373/89017-04; 374/89017-04):
Review of licensee's-i efforts to reduce personal exposure for 1989.
Personnel exposures for
1989 were reduced by about 50. percent from 1988.
See Sections 6 and 8.
4.
Organization and Management Controls (IP 83750)
i The licensee's organization and management controls for the radiation protection prcgram were reviewed, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.
Since the radiation protection organization was previously described in Inspection Reports No. 50-373/88028; 50-374/88028, the licensee has made
!
,'
significant changes. A new RPM is the health physics supervisor.
Reporting.to this position are five department supervisors who head different program areas.
These programs include technical, operational, GSEP, foremen, and scheduling / planning.
The ALARA staff is part of the operational program, i
'
p
m
- .-
,
,<
l,
.
t
' '
There. are currently 36 radiation protection technicians (RPTs) and~ six -
'
~ foremen. During this outage,. foremen were assigned to oversee drywell
.
. ork activities and'act as coordinators between plant and contractor.HP w
,,
-personnel. iThe licensee contracted about 45 RPTs'to support' work being
'
performed during'the' current outage. Also contracted were specialists-
'
,
-
assigned to supplement the ALARA and health physicist staffs.' Training--
.
and_ qualifications of contract technicians is discussed in Section 5.
>
5.
Training'and Qualifications of New personnel (IP 83750)
The inspectors reviewed the training and qualifications of _ contract I
radiation = protection technicians (RPTs).- For the current outage, the
,
licensee employed approximately 30 senior and 15 junior ~ RPTs. Generally, t
the licensee required senior RPTs to have. three years of-experience and
.
junior RPTs to have one year.
Exceptions were allowed for individuals -
!
y with college degrees and RPTs who had worked at LaSalle previously and were known to be good workers.
Inspector review of RPT resumes identified no major problems.
'
Training for contract RPTs included 1.5 days of lecture on licensee procedures and 0.5 day of self-directed study of basic health physics
-
'
theory. A 30 question exam on the procedures was given after the lecture, with a minimum passing score of 80% required of seniors and 70% required of juniors. A-30 question exam on the theory was also-given,.with a.
,
minimum passir9 score of 80% required of seniors; junior RPTs were not required to take the theory exam.
RPTs who failed one or both of the exams were allowed to take another_ version of the exam (s) after some i
'special study. The licensee reserved the right not to retain individuals
'
who passed the retake examinations; and, in one case, a senior HP technician
>
was not. hired.
Inspector review of the exams' indicated that in general, they were moderately difficult. The-utility has established a training / testing record card for contract RPTs that exempts them. from theory training / testing at other CECO stations if they pass testing at another CEC 0 station within the past year.
The inspectors also briefly-reviewed a special training-program developed by the radiation protection department for new. contract laborers and craft personnel.
Instituted during the previous outage, and continued during the current outage, this program consists of an informal discussion
-
session between a licensee or contract ALARA representative and a small_
t group of contract workers who have never worked in a nuclear power plant.
The discussion centers on basic radiation protection requirements, basic
'
,
health physics theory, and practical information such as protective clothing donning and removal techniques.
Licensee representatives-stated that feedback from participants has been favorable because of the small size of each group and the informal nature of the presentation. Also, the
,
small size of each group and the informal nature of the presentation has elicited questions that new workers are reluctant to ask at the formal NGET sessions where exams are required, classes are large, and the nuclear power plant experience level ranges widely.
Development and presentation of this training program is indicative of an aggressive radiation protection program.
No violations of NRC requirements were identified.
,
R
.,
.,
g # C.
- 1
,
6i External Exposure Control and PersonallDosimetry'(IP 83750)
'
E
~
-The inspectors reviewed the licensee's external-exposure control and-h personal dosimetry programs, including:. changes in facilities, equipment,-personnel, and procedures; high radiation area controls; adequacy of.the dosimetry program to meet routine and emergency needs;'
planning and preparation:for maintenance and refueling.. tasks including
' ALARA ' considerations; required records, reports, and notifications; effectiveness of management techniques-used.to implement these programs
.and experience concerning self-identification and correction of program
'
implementation weaknesses.
>
There have been no'significant changes in the licensee's external exposure measurement and control program.
The licensee's total person-rem for 1989.
was 1385; of this, the 1988-Unit 2 refuel outage carry' over into 1989 was responsible for about 250 person-rem, and the 1989' refuel outage was
.C responsible for about 800 person-rem.
l
'
For the current outage, the licensee established a temporary radiation protection -ingress / egress and dosimetry control station in the Unit 2 reactor building for personnel needing access to the Unit I drywell.
This station was continually manned by several RPTs.
Minimum personal monitoring requirements for drywell access include a TLD, self-reading
-!
dosimeter (SRD), and an electronic dosimeter,. Technicians manning the.
1l control station issue the electronic dosimetry and record on dose cards
- the exposures received by drywell workers. The flow of materials,
+
equipment,-and personnel to and from the drywell is monitored by the
,
technicians manning the station.
In addition, other RPTs are assigned each shift to cover all RWP work in the'drywell.
The licensee continues to use dose cards for daily dose accountability.
Persons receiving exposure are required to' fill out the cards. 'All-exposures are reviewed to ensure dose approvals are not exceeded and were i
properly authorized. A computer program identifies workers whose exposures
exceed the. predesignated exposure levels.
Based on plant tours in the j
auxiliary, reactor, and turbine building and the drywell, observation of work activities, and post-job interviews with workers who performed tasks not directly observed by the inspectors, it appeared that RP coverage was-
good.
It also appeared that the supply of portable instruments and
-
ventilation equipment, protective clothing, and respiratory protection equipment for-the. outage was sufficient.
!
No violations or deviations were identified.
,
7.
Internai Exposure Control and Assessment (IP 83750)
i 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 considerations.
'
r
~
q py
,
,
,
- y ^ e ',
,,
L
. The licensee's ' program.for. controlling' internal exposures during;this; outage includes.the use' of protective clothing, respirators, and portable
~
-ventilation equipment as well as control of surface and airborne radioactivity. The inspectors selectively' reviewed the licensee's air
-'
t
'
sampling and survey program for drywell activities; it appeared that
sufficient air samples are collected and analyzed.and that sufficient
. direct and smear surveys'are performed; RWPs, air activity' surveys,
~
MPC-houredeterminations, and whole-body count data-for the current outage-were selectively, reviewed:
no significant problems were noted.
, appeared to adequately reflect the respiratory protection requirements for
's the job. A cursory check of respirators ready.for use showed that
.t respirator inspection, storage, and maintenance was adequate.
'
The. licensee used a "Fastscan" whole-body counter during this outage
for counting incoming and outgoing contractor personnel. - The licensee
!
continues to use their. lay-down whole body counter as_a backup to the
"Fastscan." Calibration records of the "Fastscan" were not reviewed during
,
this inspection. RPTs performing whole-body counts appeared knowledgeable
'
in the use of the equipment and WBC procedures.
No person. exceeded the
-
'40-hour. control measure, and no significant internal deposition was-l
>
~ identified.
.
The licensee is'using portable HEPA ventilation units for various ventilation / filtration activities during this outage.
The portable air equipment is used for the containment and reduction of airborne contamination, or for ventilation in which an area.may. require ~ continuous supply of air in order to maintain proper environmental controls; it
. appeared the field application of this equipment is effective.
No violations or deviations were identified, a
8.
Maintaining Occupational Exposures ALARA (IP 83750)
!
The inspectors. reviewed the licensee's program for maintaining
,
'
occupational exposures ALARA, including:
changes in ALARA policy and
.
procedures; ALARA. considerations for maintenance and-refueling outages; worker awareness and involvement in 'the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were management techniques used to implement the program and experience
concerning self-identification and correction of implementation weaknesses.
The-station ALARA group is currently staffed with a newly appointed ALARA coordinator, two degreed ALARA engineers, two engineering assistants, a
"
contract health physicist and three upgraded RPTs.
For this refueling outage the CECO engineering / construction group (ENC) hired a contract ALARA engineer / coordinator and three ALARA specialists to provide ALARA
,
reviews /recommendat'ons/ dose projections for major modifications; the i
"
group also provided shiftly oversight of contract / CECO work activities in the drywell.
In addition, the general contractor (EUNC) performing most of the major modification work provided an ALARA coordinator and staff to provide expertise in planning / scheduling / implementation of ALARA activities with the plant and ENC staff. This is the first time the construction
6
.,
_
.
.
gj
-
=
m
,
- g ". i
'
,
n
,
- group has provided an' experienced ALARA staff-to this site for routine
-
refueling outage. The' combined effort of-these groups and the improved i
overall contractor, performance helped totsignificantly-improve the stations ALARA effort for_this refueling outage;
-
-
i-The' station _ALARA group' reviewed engineered designed work modifications-
and maintenance work packages that involve almost all dose producing-jobs.
!
i'
Information. gained from coverage of work performed during previous refueling -
outages was used to aid in the planning and preparation of similar-jobs Lduring this outage. The station identified high exposure jobs, determined n
shielding.'and contamination requirements, established an interface between.
work groups,2 and developed outage task person-rem projections. - Development-and implementation of engineering' controls was the responsibility of the-
'ALARA group.Since the licensee has implemented the'"ALARA Traveler" program, which al. lows ALARA-input at an earlier stage in the development
,
of-a work request, the ALARA group has more opportunity to perform adequate
'
'
reviews and to _ identify proper engineering-and radiological cont'rols.
ALARA initiatives taken for the outage include:
chemical decontamination
,
of the recirculation system; considerable use of temporary shielding of piping, recirculation nozzles, RWCU lines, and the reactor bottom-head drains and pumps;-use of-the CRD shielding device; use of TV cameras;.
~ flushing.of valves, pump drain lines and crud' traps; and preplanning of
. maintenance.and-refueling activities which provided more lead time for
- '
' ALARA review and implementation of engineering controls.
The licensee estimates that about 800 person-rem was saved in this manner.
p No violations or deviations were identified.
'
9.
personal Contamination-Events (IP 83750)
Personal contamination event-(PCE) reportin;; criteria, procedures, and
skin dose calculation methodology remain' as previously described (Inspection Reports'No.50-295/87037;50-305/87038).' The inspectors
.
,
selectively reviewed personnel contamination incident reports generated
'
from: June through December 1989. There were 220 PCEs reported for'1989; most of these events occurred during peak outage activities.- Several hot particle events were reviewed by'the inspectors; skin dose calculations performed by the ' licensee showed that no '10 CFR 20 exposure limits were
- approached.
No violations or deviations were identified.
10.
Equipment and Facilities (IP 83750)
,
,The licensee is upgrading its contamination control capabilities.
State-of-the-art portal monitors, equipped with plastic scintillators,
,
have~ been installed in the main security gatehouse; these monitors replace liquid scintillation-based monitors. A dry-active waste (DAW) sorting table equipped with 18 plastic scintillator detectors has been purchased and, according to the licensee, will be operational for the upcoming outage. The new portal monitors and the sorting table should improve the licensee's capability to detect low-level contamination on~ personnel and DAW.
l
s
~~
p
.
_
.
,,
g,
- q.
r* ] ;.
l
-
v:...
-
c :.
y
,
,
^
.No violations or deviations'were identified.
,
_.
.
,11~-.? Worker's' Intake of Radioactive Material
'
The~ inspector reviewed the circumstances surrounding an incident'in which
two workers received an intake of radioactive material while' working in the suppression' pool. The: inspector contacted health physicists, radiation
'
_ protection technicians,-the workers involved, and reviewed radiation protection records. including bioassay results, survey results, and the esults of the licensee's investigation of the incident (ROR 89-48).
r
,
On December 26, 1989, two employees, who had been.in a rubber raft in the j
suppression pool to retrieve floating debris, alarmed the whole body
'
friskers (IPM-7s)-after exiting'the area.
Subsequent frisker surveys identified contamination levels (primarily on the face) ranging from.
-10,000,dpm/100 cm to.20,000 dpm/100 cm. Nose swabs were not collected
2
,
during this ' survey; however, a gross nasal smear was taken after the workers performed-several decontaminations. After several more-l
'
decontaminations were performed, both individuals cleared the.IPM-7s
located in the RCA; however, they were unable to clear the'PM-7 monitors located in the. Main Access Facility (MAF). As a result, a radiation protection foreman performed personal surveys using GM instrumentation;
>
no measurable radioactivity was found. The foreman pulled the workers TLDs _ and instructed them to report to the HP' office the_ next morning.
Surveys performed the following morning with a' scintillation-detector indicated positive. readings immediately below the rib; cage. Whole body
-
counts (WBC) were' then performed which indicated an intake of about 122 nanocuries'of manganese-54 and 186 nanocuries of_ cobalt-60.for one worker, and 63_nanocuries of_ maganese-54 and 86 nanocuries.of cobalt-60 for the other, The activity was due to ingestion or an inhalation of material which translocated rapidly to the GI tract and eliminated within five days. The licensee. assessed that the intakes.did not exceed the 10 CFR 20.'103-40 MPC-hour control measure. The inspector agreed with the assessment.
-
Although a documented ALARA review was not written for the operation, it appeared that ALARA concerns were discussed by members of the HP staff during the pre-job meeting. The HP primarily responsible for the job was assigned another task on the day of the job and was not involved in the planning; neither he nor the other HP who attended the planning meeting was onsite during the evolution. ~However, the job was covered by two RPTs who attended the planning meetings.
Rubber / plastic Protective clothing was worn by the workers; however, because of safety considerations and preliminary air samples which indicated.01 percent MPC, respirators and plastic face shields were not worn.
The individuals in the raft also
'
-wore life vests.
Surveys performed on. structural steel, and other locations which could be-reached from th_e suppression pool platform, indicated that direct radiation _ fields ranged from 80 mR/hr at the surface of the water to 250
,;
mR/hr in other areas.
The workers wore approriate dosimetry and carried an ionization chamber; their personal exposures were less than 100 mrem.
l l
f
, ;'
r m. J. g
,
,
6 9 ISmear surve'ys performed at the entrance of the suppression pool, including.
P.
- the -platform. indicated low level contamination.. Although. it appears the p'
-workers may_have received the' intakes as a result of contact with contaminated structural steel, and a' chain fall with smearable L
contamination: levels of 200,000 dpm/100 cm2, the mechanism by which the actual ingestion / inhalation occurred could not'be determined.
As a' result of-the_insprectors review, the following weaknesses were identified:
lack of a. safety engineer involvement in the job planning, absence of' professional HP coverage, fai_ lure to~ take' early nasal smears,
.and failure to perform a-whole body count after repeated failures on the day'of the event; the whole body count was. performed the next morning.
These matters were discussed at the exit interview.
The licensee's documented actions taken to prevent recurrence of incidents of this nature will be reviewed at a future inspection.
(0 pen Item 50-373/89024-01;-
l; 50-374/89023-01).
12. Tours The inspectors reviewed radiological controls outdoors and in the turbine, auxiliary, and reactor buildings, including the Unit I drywell.
!
No major. problems were identified; however, several minor problems were identified.
Lighting in several areas of the Unit I drywell was poor, and one work area was posted as a Radiation Area although the entrance to the drywell was posted as.a High Radiation Area.
In addition, upon exiting the Unit I drywell though the. equipment hatch, the inspector observed several workers sitting in an area where_the dose rate was 2-3 mR/hr. The inspectors suggested to licensee representatives that'
an adjacent area, where the dose rate was less than 1 mR/hr, be used by
.;
workers as a staging or break area.
The licensee agreed to correct these problems.
R
'13.
(Closed) Allegation Followup (AMS No. RIII 89-A-123)
An NRC Resident' Inspector at the Zion Station was visited in the NRC i
Resident office by an individual who expressed concerns about-the General Employee' Training Program (NGET) at Zion and other CECO stations.
The allegation concerning the NGET at LaSalle Nuclear Station is presented and discussed below.
,
Allegation:
The LaSalle station NGET training program is weak because it l
consists only of videotape presentations.
!
' Discussion: All aspects of the_ licensee's NGET program have been reviewed by various NRC inspectors and by CECO corporate and industry auditors.
l Contractor Radiation Protection Technician (RPT) and respiratory user-I training has also been reviewed. The NGET consists of videotapes and
'
presentations with question and answer discussions / sessions routinely held between segments.
The major training segments include Radiation Protection l
Security,-Quality Assurance, Quality Control, Safety, and Respiratory L
Protection.
Tests are administered which require a 70 percent passing l
grade, In addition, a handbook titled " Nuclear General Employee Training L
i i
- !{h~
][
'
>
' se: ', *
,,
'
,
s
~
N-GET":is provided'to each_ trainee.- The NGET program was certified ~in
.1985 by the Institute of Nuclear. Power Operations (INPO).
INPO routinely-
? audits the NGET program. The NGET program also meets the requirements
'" _
of 10 CFR 19.12, " Instructions to Workers," which does not specify a 1 -
required presentation methodology.-
' Finding: The-allegation was not substantiated in that the NGET program consists-of other than taped presentations.
Regulatory requirements are being met.
,
,
. 14. - Exit Meeting The inspector met with licensee representatives (denot' d in Section 1) at e
.
the conclusion of the inspection on January _5,1990, to discuss the scope-
'
of the inspection and the findings..The-inspectors also discussed the likely informational content of the inspection report regarding ' documents and processes reviewed by the inspectors during the inspection. The-licensee did not identify any such documents / processes as proprietary.
The matter discussed'specifically by the inspectors was the-apparent
weaknesses identified during the suppression pool surface cleanup on a raft. The licensee stated ~ corrective actions will be implemented
.
(Section 11).
I s
,
, -
i 4-
'
'
,
,