IR 05000373/1996014

Insp Repts 50-373/96-14 & 50-374/96-14 on 961015-18. Violations Noted.Major Areas Inspected:Radiological Protection & Chemistry (Rp&C) Controls & Status of Rp&C Facilities & Equipment

ML20134N328
Person / Time
Site:	LaSalle
Issue date:	11/20/1996
From:	Nirodh Shah, William G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134N188	List: IR 05000373/1996014 ML20134N186 ML20134N264
References
50-373-96-14, 50-374-96-14, NUDOCS 9611260267
Download: ML20134N328 (11)

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R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Review of Dose Performance Insnection Scone The inspectors reviewed the licensee's dose control during L2RO7, forced outages and material condition improvements. The inspectors also reviewed two at-power-entries into the drywell, on May 22 (Unit 2) and July 1-2,1996 (Unit 1), to repair intermediate range monitors (IRMs). Observations and Findinas The licensee projected an expended dose of about 953 rem for 1996 (650 rem to date), significantly above the 728 rem goal. The increased dose was attributed to emergent work / rework identified to date (about 91 rem), material condition improvement efforts added late in the year (46 rem to date) and two unplanned maintenance outages on Units 1 and 2 that were not included in the original goal (about 60 rem). This total was expected to increase given the remaining work on the material condition efforts (about 50% complete) and in L2RO The licensee made at-power entries into the drywell on two separate occasions, May 22 and July 1-2,1996, to inspect / repair IRMs. Radiation protection personnel indicated that airborne contamination sampling and analyses were conducted per station procedure LRP-1360-12 (Rev. 6) " Containment Atmospheric Analyses Required for Drywell Entry." During the May 22 entry, an RP technician (RPT)

stopped work after noting dose rates exceeded 7 R/hr (the hold point was 10 R/hr)

prior to full removal of the IRM. The higher than anticipated dose rates resulted from irradiation of the IRM which was not accounted for by the RP departmen The conditions were assessed, and the job subsequently resumed with no further radiological consequences. The licensee wrote a Problem Identification Form (PIF No. 96-1474) for the higher than expected dose rate The PIF was classified as low priority and was assigned to the work control group for resolution. At the time of the inspection, the PlF remained open with no further investigation conducte Af ter the May 22 entry, the licensee performed an additional entry between July 1-2 to inspect / repair IRMs. This entry was made without incident, but without the corrective actions developed to accurately assess the anticipated dose rates on the IRM. The inspectors evaluated the circumstances surrounding the entries and determined that a substantial potential for an overexposure did not exist primarily due to continuous surveying of the IRMs by radiation protectio Although the effects of incore irradiation of IRMs were disseminated in IN 88-63, this information was not adequately considered prior to the May 22 entry. Of

9611260267 961120 PDR 0 ADOCK 05000373 PDR

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oreateicancern was_the identificatiortothicher than nypactedJosalates dudnprthe_

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May 22 event, which were documented in a low priority PlF, and the performing of the July 12 entry prior to developing corrective actions for the May 22 event. The failure to assess the irradiation of the IRMs prior to both entries is considered an inadequate evaluation of radiological controls as required by 10 CFR 20.1501 to assure compliance with the occupational doso limits in 10 CFR 20.1201(a)

(Violation 50-373/96014-01; 50-374/96014-01).

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In addition to suggested radiological controls, IN 88-63 also discussed the l administrative controls over incore instrumentation irradiation and decay time. This was not recognized during the licensee's review of the PIF and was considered a I weakness in the problem identification process. Subsequently, the licensee reclassified the PlF as "significant" and assigned it to the RP department for l resolutio ! Conclusions Although the dose expended on emergent work / rework was reasonable for the work scope, this work has significantly increased the total station dose. The c effects of incore irradiation of IRMs were not adequately considered prior to IRM removal which resulted in one violatio R1.2 Radioloaical Plannina for the Unit 2 Refuelina Outaoe (L2RO7) Insoection Scoce (83750)

The inspectors reviewed the licensee's planning and ALARA controls for i 2RO The inspection consisted of interviews with licensee workers and RP staff and a review of applicable documentation, including: radiation work permits (RWPs);

ALARA plans; radiological surveys; and records of ALARA committee meeting Specifically reviewed were those jobs (discussed below) considered the most radiologically significant during L2R07. The inspectors also observed ongoing work in the drywell and Reactor and Turbine buildings, Observations and Findinas Outage dose to date was about 333 rem (goal = 428 rem) with about 50% of the work complete. As discussed in Section R1.1, the outage dose total was higher than anticipated owing to material condition improvement efforts and emergent work / rework. Significant work included (dose to date given in parentheses):

• Inservice Inspection (ISI): (32 rem; about 85% complete)

• Control Rod Drive (CRD) Work: (22 rem; about 85% complete)

• OWZ Evaporator Repair: (24 rem; about 90% complete)

• Neutron Instrumentation Modification: (6 rem; 25% complete)

• Reactor Vessel Disassembly: (4 rem; disassembly complete)

• Motor Operated Valve Work: (3 rem; 30% complete)

• Safety Relief Valve Work: (7 rem; 75% complete)

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In particular, the reactor _disas_sernblyJ34 remland_ average.CBRDiosej0A __ ___

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rem /CRD) totals were the lowest for these tasks in the licensee's histor The inspectors noted good use of ALARA controls to reduce worker exposure, including: increased use of lead shielding, remote monitoring via cameras and teledosimetry, hydrolyzing of high dose rate piping, and dedicated ALARA managers. The inspectors verified that these managers were knowledgeable of the status of their assigned jobs, had developed contingency plans, had stop work authority and, in the case of contractors, had appropriate station management oversight. The inspectors noted good use of portable ventilation and increased air sampling equipment to control internal exposure. The inspectors also determined that the above jobs were reviewed by the station ALARA committee and that lessons learned (industry or station) were considere However, several discrepancies were identified during the inspectors' review of A.LARA plans and associated RWPs. Specifically:

e RWP radiological hold points were sometimes less conservative than that stated in the associated ALARA plan. For example, the RWPs (Nos. 9622F and 962265) for working on the reactor recirculation (RR) suction and discharge valves, respectively, both had electronic dosimetry (ED) dose rate alarm setpoints (500 mrem /hr) exceeding their recpactive ALARA plan radiological hold points (3*/5 mrem /hr).

e information provided on both ALARA plans and RWPs were often unclear or not applicable, confusing the workers. For example, these documents generically stated " assess ventilation flow in the work area for the primary and contingency plans. Make adjustments as necessary." Neither ALARA planners or workers knew how to implement this requirement. Additionally, this requirement also appeared on jobs where ventilation flow was not a concer e For some jobs, a single RWP was used to control several activities associated with one job, when multiple RWPs would be more consistent with ALARA principles. For example, RWP No. 962251 (Rev. 0) had an ED dose rate setpoint of 500 mrem /hr and covered many support activities (with individual ALARs. plans) associated with SRV work. However, the ALARA plan for the instrument maintenance (IM) portion of the SRV work, had a hold point of 187 mrem /hr. Therefore, under the above RWP, the IM's could receive exposure above the ALARA plan estimat These discrepancies were not identified by the job ALARA planner or the RP planner in the work control group and resulted from a weakness in the work control process. Specifically, station procedures did not specify which of the above individuals were responsible for reviewing the ALARA plan and RWP nor required that the two documents be in agreement. The use of non-conservative radiological hold points or the use of a single RWP for many

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activities, may accrue additional exposure. The l_icense.e_wa_s_ developing _

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corrective actions for this issu _ Conclusions i- The inspectors noted good ALARA controls for exposure reduction, but identified several weaknesses in the work control process regarding review and implementation of ALARA plans and RWPs. These weaknesses may result in I

additional worker exposur R2 Status of RP&C Facilities and Equipment R Maintenance of Whole Body Counter (WBC) and Portable Instrumentalign Insoection Scoce (83750)

The inspectors reviewed the licensee's oversight of the WBC and portable

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instrumentation. The inspection consisted of a review of station procedures and WBC maintenance and calibration records, plant tours, and interviews with licensee staff.

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Observations and Findincs

~ ~' ~ ~ - ^ The licensee's WBC procedures appeared complete and appropriate. The WBC was

serviced quarterly by the vendor, was verified operationa: and the appropriate  !

j calibration and functional tests were performed per station procedures. Radioactive j

. sources used during these tests were well-labeled and secured and were properly

) leak-tested (6 month frequency). During interviews, the inspectors found that RP i technicians were familiar with WBC operation and observed a successful j performance of a quality control and functional check of the WBC by an RP l

. The inspectors also selectively reviewed worker WBC records and the assignment J of internal dose; no problems were identifie During in-plant observations, the inspectors verified that portable radiation instruments were in good condition and calibrated. Overall, the licensee maintained effective tracking / trending of instrument maintenance and calibration historie l Radioactive sources used during the calibrations were secured, properly inventoried, I

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and were appropriately leak tested. The calibration laboratory was in good condition and the inspectors observed an RP technician successfully perform an

instrument calibration using the licensee's deep well system.

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Conclusions 1 e 1 I

The licensee maintained effective oversight of the whole body counter and portable instrumentation. Internal exposure was properly assigned as require l l

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,' R4 Staff Knowledge and Performance in RP&C  !

R Review of Radworker Performance and Administrative Overexoosure

, Insoection Scooe (837521

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The inspectors reviewed worker performance in the radiological posted area (RPA).

The review consisted of in-plant observations, interviews with licensee staff and a )

3 review of PlFs. Specifically reviewed was an administrative overexposure to a J

. radwaste (RW) operator during the draining of the Unit 2 waste evaporator (WE)

surge tan Observations and Findinos

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(1) L2RO7 performance L 1 j During the inspection, station management initiated a work stand down for a

declining trend in human performance events. Some of these events were i

caused by continuing weaknesses with contractor oversight, work control

! and planning and poor self-check. Some examples included:

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A station RPT failed to post the reactor watercieanup-(RWCU)~ room ~ ~~ --~ --

as a high radiation area (HRA). The room had previously been part of

a larger HRA boundary (to accommodate ongoing work) and was not individually posted. The RPT was in the process of reducing the HRA

boundary and forgot to individually post the RWCU room. General

! area dose rates in the room were 5-20 mrem /hr with four, locally ;

posted hot spots between 100-600 mrem /hr (at 30 cm). The '

j licensee verified that no one had entered the room, reposted the area, and counseled the technician. Although this was a violation of 10 i

CFR 20.1902(b), which required posting of high radiation areas, this licensee-identified and corrected violation is being treated as a Non-Cited Violation (NCV), consistent with Section Vll.B.1 of the NfLQ

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Enforcement Policy (NCV 50-373/96014-02; 50-374/96014-02).

' * Unnecessary dose was expended during the installation of bladders (which were inflated with air) to control RR piping leakage identified

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during valve work. The workers initially brought improperly sized

bladders to the work site and spent extra time procuring replacement

bladders. When the new bladders were later found to be leaking, the '

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workers periodically reentered the area to reinflate the bladders rather

than replace them. Area dose rates were about 30 mrem /hr and the l l workers accrued 500 mrem additional exposure performing this tas The ALARA manager subsequently stopped work, discussed this J problem with the workers, and documented the event in a PlF.

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The inspectors identified a radworker performance event that was not

. documented in a PlF. During OWZ evaporator work, two contractors

- received facial contamination while traversing an area outside their work area. Although the area traversed was surveyed by RP, it was outside the control boundary established during the prejob planning. The licensee

. verified through a whole body count that the workers had not received an

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appreciable intake and took appropriate disciplinary action. This event ;

resulted from poor communications during the prejob briefing and was not a violation of station procedures. However, the job ALARA manager had not

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! documented the event in a PlF, preventing it from being tracked / trended via i

the station problem identification process. .This was discussed with RP

management who agreed that the event should have been documented as a PlF.

l 3 (2) Auaust 20,1996. Administrative Overexoosigtt a

1 On August 20,1996, the Unit 2 WE surge tank was drained to allow for an inspection of the tank internals. Because the inspection required that the

tank be drained below the normal pump trip setpoint (about 3 inches j indicated tank level), a RW operator was stationed in the RW pump aisle (a i posted HRA) while the tank was drained to alert radwaste control room operators if the WE pump cavitated. This work was performed under general RWP No. 960027 which required RP be notified prior to starting work. . Although the RW group had informed RP about the tank draining, the need for an operator in the pump aisle was not communicate The tank draining increased working area dose rates in the pump aisle from about 20-35 mrem /hr to 200-400 mrem /hr (about 400-1800 mrem /hr near ,

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the WE pump). The RW operator was aware of the potential for increasing dose rates during the draining and stood in a low dose area (as indicated in RP radiological survsys) well away from the pump. The operator was in the RW pump aisle for about lii-20 minutes and, upon exiting, noted that his electronic dosimeter (ED) was alarming in both the accumulated dose and ,

dose rate alarm modes (the setpoints were 40 mrem and 300 mrem /hr, respectively). Because of high noise levels, he was unable to hear his ED in ;

the pump aisle. His ED had measured an exposure of 52.7 mrem and ,

indicated that the highest radiation field he had entered was about 616

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mrem /hr. This exceeded his RWP administrative exposure limit of 50 mre Subsequent processing of the operators thermoluminscent dosimeter (TLD)

indicated that his actual exposure was comparable to the ED result TS 6.2(B) required that radiation control procedures be adhered to. Station Procedure LAP 100-22, " Radiation Work Permit Program" (Step e(4))

required that workers adhere to RWP requirements. The failure of the RW operator to notify RP of the need to be in the RW pump aisle during the tank draining was a violation of the RWP requirements. (Violation 50-373/

96014-03; 50 374/96014-03). This violation is being cited because it is a repetition of a previous event (Inspection Report (IR) No. 96006), where RP 7 .

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requirements were not followed. Additionally, this violation documents

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another example of inadequate communication to the RP group, of ongoing work in radiological areas (IR Nos. 96002 and 96004).

In addition to the above violation, ineffective corrective actions were used to address the use of EDs in high noise areas. This was identified as a potential problem during a previous administrative overexposure event in 1993 (IR No. 93034), and in an NRC Health Physics Position no. 328 (NUREG/CR-5569). It is of concern because the inability to hear ED alarms may prevent a worker from becoming aware of significant changes in radiological conditions, and therefore, is a potentially significant safety proble Conclusions The licensee initiated a stand down for recurrent human performance events involving continued problems with contractor oversight, work control and

. planning, and worker self-check. One event, concerning unplanned contamination received during OWZ evaporator work, was not documented in a PIF, contrary to station management expectation One violation was identified for the failure to follow station procedures as required by TS. This violation is of concern because it is a repetitive event where the RP requirements were not followed. Ineffective corrective actions were also used in establishing radiological work controls during the draining of the Unit 2 WE surge tank. Specifically, the use of EDs in high noise areas was not effectively addressed which prevented a worker from noting a significant change in area radiological condition R8 Miscellaneous RP&C lssues

. R 8.1 (OPEN) Followuo on Evaoorator IFl Nos. 50-373/96006-05(DRS): 50-374/96006-05(DRS) Insoection Scone The inspectors reviewed the licensee's investigation regarding the root cause of the OWZ evaporator failure, Observations and Findinas The licensee determined that the evaporator failure was due to degradation of a gasket located between the flanges of the liquor box and the shell of the heating element. This gasket had been in service since May 1994, and was made of Viton, a nylon reinforced materia A review of the gasket by the licensee's System Materials Analysis Department (SMAD) indicated that the gasket had signs of cracking with a significant loss in

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elasticity. . The gasket had also delaminated, exposing the fiber reinforcement.

i Although still being evaluated, the licensee believed the gasket degradation was due to the high radiation levels exparienced during evaporator operation. Based on this information, the licensee planned to perform a visual inspection of the 2WF '

evaporator to determine if similar degradation had occurre The licensee also identified a discrepancy regarding the gasket's inventory shelf lif I in a letter dated March 15,1989, the gasket manufacturer stated an inventory shelf life of 3-5 years before any elastomeric degradation would take plac However, the licensee's stores department had an indefinite storage period specified for the gasket. This issue was still being resolved by the license X.O Manaaement Meetinos X.1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee staff at the conclusion of the inspection on August 20 (denoted by "*") and October 18, 1996 (denoted by "+"). The licensee acknowledged the findings presented and did not identify any of the documents reviewed as proprietar I I

+ D. Ray, Station Manager 1

+ J. Drago, NRC Coordinator j

+ M. Oclon, Mechanical Maintenance Department Head )

+ A. Magnafici, Superintendent, Maintenance

+ P. McConnaughay, RP Instructor

+ N. Hightower, RP Supervisor

, + D. Boone, Superintendent, Health Physics ,

, + F. Houge, Lead Operational Health Physicis l C. Jeanblanc, Radwaste Operations Supervisor i

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PARTIAL LISTING OF DOCUMENTS REVIEWED

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e Health Physics Standard (HPS) No. N13.30-1996, Performance Criteria for Bioassav (approved May 1996). '

e Station ALARA Committee meeting minutes dated September 18,199 e Problem Identification Form (PIF) No. 96-1474 (dated May 22,1996) regarding removal of Unit 2 D Interim Range Monitor (IRM).

e Licensee root cause evaluation Report No. 373-200-96-00131.00 for PlF No. 26-i 2334 (dated August 20,1996) regarding administrative overexposure during l draining of Unit 2 WE surge tank, o Report No.- M-05923-96: Systems Materials Analysis Department (SMAD) Reoort on the insoection of a Radwaste Evaoorator Heatino Element Gasket at LaSalle Station (dated 9/13/96).

e Letter dated March 15,1989, from Dearborn Rubber Corporation concerning inventory shelf life of Viton/Nomex Gasket l l

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INSPECTION PROCEDURES USED

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IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 83750: Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-373,374/96014-01 VIO Inadequate Survey Prior to Performing IRM Work 59-373,374/96014-03 VIO Failure to Follow RP Requirements Closed 50-373,374/96014-02 NCV Failure to Post a HRA l

Discussed 50-373,374/96006-05 lFI Evaporator Spill incident l

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