IR 05000373/1992026
| ML20128B637 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/23/1992 |
| From: | Louden P, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128B563 | List: |
| References | |
| 50-373-92-26, 50-374-92-26, NUDOCS 9212040035 | |
| Download: ML20128B637 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report' to. 50-373/92026(ORSS); 50-374/92026(0RSS)
Docket Ncs. 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: November 2 through 6, 1992 Inspector:
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P. L. Louden Dtte /
Radiation Specialist Approved By:
LdD$._ Sjf o/p/m Willi ~am Snell, Chief Date '
Radiological Controls Section 2 Inspection Summary Inspection on November 2 throutah 6. 1992 (ReDort Nos. 50-373/92026(DRSS): 50-374/92026(DRSSI)
Areas Inspected _:
Routine announced inspection of the licensee's radiation protection (RP) program during outage activities (Inspection Procedure (IP) 83729), including changes in organization, internal exposure con' col, external exposure control, contamination control, maintaining occupational exposures as-low-as-reasonably-achievable (ALARA), radiological events, and licensee action to previously identified inspection findings.
Results: One violation for failure to follow Radiation Work Permit (RWP)
procedures.
Specifically, the resident inspector observed an operator climbing while in minimal protective clothing (PC) which was prohibited by the RWP under which he was working.
Additionally,- one non-cited violation was identified in association with the inadvertent downposting of a required (acked high radiation area door on October 15, 1992. The' licensee has enhanced its ALARA staff to include liaisons and coordinators-to the Engineering and Construction Department. Overall, the licensee is progressing on schedule through the current refueling outage (LIR05) and doses for major jobs art going as estimated.
9212040035 921124 PDR ADOCK 05000373 G
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1.
Persons Contacted Licensee __ staff
- D. Carlson, Regulatory Assurance, NRC Coordinator
- G. Diederich, LaSalle Station Manager
- M. Friedman, Technical Lead Health Physicist
- H. Hentschel, Assistant Superintendent, Operations
- D. Hieggelke, Health Physics Services Supervisor
- N. Hightower, Radiation Protection Technician
- W. Huntington, Superintendent, Technical Services
- K. Kocinba, Superintendent, Quality Verification
- J. Lewis, Operational Lead Health Physicist
- J. Lockwood, Supervisor, Regulatory Assurance
- T. Nauman, Master Mechanic, Maintenance Department
- L. Oshier, Corporate, Radiation Protection Liaison
- M. Santic, Assistant Superintendent Maintenance
- J. Schmeltz, Superintendent, Production Services
- J. Shields, Nuclear Licensing Administrator
- J. Terrones, Quality Verification Inspector
- D. Trager, Training Department
- J. Watson, Compliance Engineer, Nuclear Licensing Nuclear Reculatory Commission
- D. Hills, Senior Resident Inspector
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The inspector also interviewed other licensee personnel in various
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departments in the course of the inspection.
- Indicates those present at exit meeting on November 6, 1992.
2.
Licensee Action on Previous Inspection Findinos (IP 83750)
(Closed) Violation No. 50-374/91029-01:
Failure to perform an adequate survey associated with an administrative overexposure event involving an individual working on the 28 Fuel Pool Cooling Heat Exchanger.
The licensee had completed all corrective actions to prevent recurrence of the problem which-led to the administrative overexposure. These corrective actions included a review of the audibility of the electronic dosimeters, the quality of turnovers by radiation protection shift supervisors, and informational logs included on RWPs.
All of these actions appear to be effective in preventing recurrence. This violation is closed.
(Closed) Violation Nos. 50-373/92018-01: 50-374/92018-01:
Failure to provide appropriate shipping information on a Department of Transportation Yellow-III label. This event occurred due to inadequacies in the procedure which governed the preparation of such shipments requiring a iellow-III label. The procedure has since been revised to ensure all necessary information is completed for shipments
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requiring such a label. This violation is closed.
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3.
Channes (IP 83750)
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a.
Station RP Department The station's RP and other interacting departments have undergone several changes since the last inspection.
The Operational-Lend Health Physicist was re-assigned to act as RP liaison to the maintenance deparement. The dosimetry supervisor assumed the role of Operational Lead Health Physicist.
During the recent manpower reduction at the station, the RP department incurred the loss of one of their RP Shift Supervisors. This vacancy is currently being filled by two qualified individuals who had been on a two year rotational assignment to the training department.
The inspector noted no negative 'mpact to the station's RP program as a result of these change.
The station has supplemented the Engineering and Construction (ENC) staff with a department *1 ALARA coordinator. This individual is responsible for supervising, coordinating, and providing liaison duties for the station maintenance department and contractor construction group.
This individual is supported by ten personnel who have assignmo is to monitor and coordinate work progress in specific maintenaice groups (electrical, mechanical, and instrumentation mair.:enance).
Four of the ten supporting personnel have industry experience with ALARA programs, and the addition of this group has to date been an enhancement to the cverall performance of the RP department during the current refueling outage.
b.
Contract Radiation Protection Technicians (CRPTs)
The statioti has supplemented its RP staff to support the outage with 26 American National Standards Institute (ANSI) qualified technicians, 8 non-ANSI technicians, 9 clerical personnel, and 3 site / shift supervisors. The inspector reviewed the qualifications and selection process used in selecting CRPTs and noted no problems.
No violations or deviations were identified.
4.
Internal Exposure Controls (IP 837291 The inspector reviewed the results of the licensee's whole body counting and internal dose assessments.
No intakes had occurred since the previous inspection which exceeded the 40 MPC-hr control measure.
One intake event was reviewed by the inspector to verify W accuracy of station methodologies used to determine internal eg wes.
All calculations and records were found to be accurate and in order.
No violations or deviations were identified.
5.
External EXDosure Controls (IP 8372H The inspector reviewed selected standing and special Radiation Work Permits (RWPs) for appropriateness of the radiation protection
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requirements based on work scope, location, and radiological conditions.
All RWPs revi3wed conveyed accurate information regarding radiological information based on recent survey results and had undergone appropriate supervisory review.
The licensee again used top reading electronic dosimetry for entry into the drywell.
These dosimeters allow for easier reading of the individuals dose and dose rate while working in contamiaated areas.
Good access control was also observed at the drywell hatch.
Workers preparing to enter the drywell were questioned by station and contract RPTs on the nature of their work and the location of the jot.
The RPTs provided radiological condition -information and verified appropriate dosimetry placement for the areas to be accessed.
No v1olations or deviations were identified.
6.
Contamination Control (IP 83729)
The station contaminated area during the outage rose to 45 percent of the plant due to the partitioning of part oi.hs Unit 2 reactor building to serve as an access point to the Unit I drywell and the controlling of various Unit 1 areas to support work for the outage.
One hundred seventy three personnel contonination events (PCEs) had been recorded at the time of the inspection.
PCEs were trending slightly higher than established goals partially due to an incident on October 27, 1992 in which low level contamination was spread throughout walkway areas of a few elevations in the Unit I reactor building. The 15 PCEs recorded during this time frame were all shoe contaminations and investigations into the cause of the contamination were still ongoing during the inspection.
No violations or deviations were identified.
7.
Maintainina Occupational Exposures ALARA (IP 837291 a.
Station ALARA Committee tieeting The inspector attended a station ALARA committee meeting (SAC)
held to review the progress of higher dose jobs ongoing during the refueling outage. The exposure goal for the outage was 392 person-rem and the station had recorded 142 perrm-rem for the outage at the time of the inspection. The yearly goal for the station is 1213 person-rem with 912 person-rem recorded to date.
Representatives for major jobs including motor operated valves, in-service-inspections, under vessel work, and shielding presented updates on the status of their respective jobs versus the planned exposure for the job's completion. All jobs discussed appeared to be meeting exposure goals or were being performed for less than the goal. One area which attributed to higher doses curing the spring 1992 Unit 2 outtge was under vessel work. The station inserted a mechanical filterin; astem which filters and recirculates water in the sump and has appeared to be a significant csatributor to the reduction of under vessel general
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area doso rates.
Control rod drive removals were performed at-an
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average of 925 mrem per drive compared to the average historical rate of 1300 mrem per drive.
Following the presentations by the job representatives,
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discussions ensued pertaining to assorted problems / accomplishments encountered during the outage. Good managercent interaction was observed throughout the entire meeting.
b.
Source Term Reduction The station has developed and implemented a source term reduction plan which includes both short and long term action items to reduce radiation levels throughout the plant. The plan' assigns responsible organizations and due dates for the completion of the designated action. The plan includes thirty-eight action items some having several sub-elements.
Effected station departments include operations, maintenance, engineering, chemistry, ed radiation protection.
At the time of the inspection all source term reduction activities were being accomplished within their-respective due dates.
Noteworthy efforts includM hydrolazing activities conducted during this outage. During the spring 1992 Unit 2 refueling outage, enly two lines were hydrolazed with slightly successful results.
During this outage, twenty lines were identified for hydrolazing with all being completed at the time of the inspection.
Licensee staff indicated that goed decontamination factors were being achieved for the lines hydrolazed.
No violations or deviations were identified.
8.
ILadioloolcal Event _g The inspector reviewed the licensee's logs of recent Radiological Occurrence, Radiological Incident, and Licensee Event Reports (RORs, RIRs, and LERs), two of the more significant events are detailed below.
a.
LER 92-011-00 Unlocked High Radiation Area Door On October 15, 1992, the licensee was preparing to perform work in the Unit 1 A/B/C Condensate Polisher (CP)' vessel room which is a normally locked high radiation area. The dose rates in this room.
were reduced to allow for the room to be down graded to " Radiation Area". However, due to an error in the high radiation door numbering log, the door which was actually down graded was the Unit 1 D/E/F/G CP vessel room whose inner dose rates ranged as high as 2.2 R/hr. A radiation protection shift supervisor noted
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the error while tka work crews were preparing to enter the radiologically controlled area to begin the planned work in the Unit 1 A/B/C CP vessel room. The supervisor took immediate action by going to the location of the down graded door and guarding it until proper postings and access controls were in-place. Another immediate corrective action included verifying through the access-control system that no individuals had entered the room while the area was inaccurately posted.
Long term corrective actions
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include a reylew of the high radiation area database to ensare no
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other such errors exist, evaluate placing door numbers on survey forms, and revise station procedure LAP-1100-13, which documents high radiation area door status changes to include both the door number and a description of the door.
The inspector informed the licensee that due to their icentification of the violation and prompt and long term corrective actions that the event would not be cited as the criteria in Section VII.B of the Enforcement Policy had been satisfied, b.
Radiation Worker Performance and Practices The inspector reviewed the circumstances surrounding an event observed by the resident inspector on October 29, 1992.
While performing a routine walkdown of the auxiliary building, the resident inspector accompanied by a station quality verification inspector observed two operators placing out-of-service (005)
cards on Unit I reactor core isolation cooling system valves in a contaminated area. The individuals were wearing minimal protective clothing (booties and gloves), and one worker was observed climbing above the platform to hang the 00S card. The individuals were asked what RWP they were working under, and further review indicated that the RWP for their-entry into the contaminated area specifically prohibited climbing, kneeling, or crawling of any kind while in minimal protective clothing.
The inspector informed the licensee that this was a violation of Technical Specification 6.2.B which requires adherence to radiation protection procedures and specifically a violation of LaSalle Administrative Procedure j AP) 100-22, " Radiation Work Permit (RWP) Program" (Violation 373/92026-01).
The inspector discussed this event with the licensee-and the history of NRC concerns v'th poor radiation worker practices at the station based on previous inspection reports and observations by the resident inspectors and region based radiation specialists.-
Station management was informed during the exit meeting (Section 10) that some improvements in radiation worker practices had been-noted earlier in the year, however, management emphasis on proper radiation work practices needs to continue to ensure that a negative trend in this area does not develop.
One violation for failure to follow RWP limitations-and one non-cited violation for -inappropriate posting and control of a high radiation area door were identified.
9.
Tours During the course of the inspection the inspector made several tours of the radiologically controlled area including the Unit I drywell. The inspector also observed several ongoing work activities during the inspection. All radiation monitoring equipment observed during the tours were in good working order and current calibration. Minor posting and housekeeping problems observed by the inspector were immediately.
resolved by licensee staff.
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No violations or deviations were identified.
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10.
EKit Meetina The scope and findings of the inspection were discussed with licensee representatives (Section 1) at the conclusion of the inspection on November 6, 1992.
Licensee representatives did not identify any Occuments or processes reviewed during the inspection as proprietary.
Specific items discussed at the meeting were as follows:
The violation involving an operator failing to follow RWP
requirements and the trend at the station of poor radiological work practices, j
The non-cited violation associated with the inadvertent downposting
of a required locked high radiation area door and the licensee's j
corrective actions upon discovering the problem.
The station's current good performance with respect to work scope
timeline and meeting exposure goals thus far for the refueling outage.
The implementation of short and long term source term reduction
initiatives and accomplishments to date.
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