IR 05000373/1998018
| ML20237A597 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/07/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20237A586 | List: |
| References | |
| 50-373-98-18, 50-374-98-18, NUDOCS 9808140200 | |
| Download: ML20237A597 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION f
REGIONlli Docket Nos:
50-373;50-374 License Nos:
Report Nos:
50-373/98018(DRS); 50-374/98018(DRS)
Licensee:
Commonwealth Edison Company j
Facility:
LaSalle Nuclear Generating Station, Units 1 and 2
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Location:
2605 N. 21st Road Marseilles, Illinois 51341-9756 Dates:
July 13-16,1998
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inspectors:
S. Orth, Senior Radiation Specialist N. Shan, Radiation Specialist Approved by:
G. L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l
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l 9808140200 980807 DR ADOCK 05000373 PDR s
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EXECUTIVE SUMMARY
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LaSalle Nuclear Generating Station Units 1 and 2 NRC Inspection Reports 50-373/98018; 50-374/98018 This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) program. Specifically, the inspectors reviewed the extemal monitoring and air sampling programs, high radiation area control, and the testing of the standby gas treatment filtration system. Additionally, the circumstances regarding an April 1998 shipment of irradiated metal to a burial site, and two high radiation area events, occurring on March and -
May 1998, respectively, were also reviewed. This report covers a four day inspection concluding on July 16,1998, performed by a Senior Radiation Specialist and a Radiation Specialist.
Plant Support The licensee performed a thorough investigation of the source of irradiated metal found e
inside a Type B cask. Although the source of the metal and the duration that it was inside the cask were unknown, the inspectors determined that its presence woeld not have resulted in a significant health hazard during transport. (Section R1.1)
. The RP staff properly implemented the extemal dosimetry quality control program. The e
licensee maintained National Voluntary Laboratory Accreditation Program accreditation in accordance with 10 CFR Part 20. In addition, periodic thermolumiscent dosimetry (TLD) quality control tests were performed, and the results were evaluated for long term biases or trends, (Section R1.2)
The licensee maintained administrative extemal dose levels to ensure that personnel e
doses were maintained as-low-as-reasonably-achievable (ALARA). Administrative dose i
controls were effective in maint&ining personnel doses, and specified approvals were required to exceed administrative dose controls. The RP staff also effectively controlled doses to declared pregnant workers in accordance with NRC regulations and guidance.
However, the staff did not thoroughly investigate discrepancies between personal doses measured by TLD as compared to personal doses measured by electronic dosimeters
~(EDs). (Section R1.3)
High and locked high radiation areas were controlled consistent with regulatory e
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l requirements and industry practice. During walkdowns, the inspectors observed workers using proper access control and significant recovery of some contaminated areas. However, a problem was observed with radiological housekeeping in some areas. (Section R1.4)
l Air sampling was conducted consistent with industry practice and NRC regulations. Air e
sampling equipment was well maintained and air sampling activities were performed
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appropriately. However, some examples were identified where procedural guidance
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was inconsistent with management expectations or where additional information was
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needed. In addition, the inspectors identified that there was no wrmal process for tracking lapel air samplers assigned to workers and associated results. (Section R1.5)
The standby gas treatment filtration system was appropriately tested, but some e
problems were noted with the documentation of the physical examination of the filtration units. (Section R2.1)
One Non-Cited violation was identified conceming a contract engineer who failed to e
obtain RP department approval prior to moving a high radiation area barricade on the refuel floor. This non-repetitive event was identified and corrected by the licensee.
(Section R4.1)
One violation was identified conceming the entry of personnel into a unsurveyed area e
within a locked high radiation area. Specifically, RP personnel failed to establish
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appropriate controls to prevent two construction workers from entering an area within
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the Unit 2 A reactor water cleanup heat exchanger room, a locked Agh radiation area, that had not been radiologically surveyed. (Section 4.2)
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Report Details
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IV. Plant Sunnort R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Shioment of Irradiated Metal Comoonents a.
Insoection Scooe (IP 86750)
The inspectors reviewed the circumstances surrounding a shipment of irradiated metal I
components to a burial site. The inspection consisted of interviews with personnel and a f
review of applicable documentation.
b.
Observations and Findinas On May 11,1998, an NRC reactor licensee (i.e., the Enrico Fermi, Unit 2 staff) notified officials at a burial site of a small piece of irradiated metal tubing, that had been found inside a Type B cask (model TN-RAM) during a receipt survey. The cask had last been l
used to ship irradiated metal hardware from the LaSalle facility to the burial site on April l
27,1998, and had been unloaded by burial site personnel prior to being transported to the Fermi site. The metal tube found by the Fermi staff was approximately 4 inches in length and had contact radiation levels of about 35 rem per hour (rem /hr). The cask was subsequently retumed to the burial site for inspection and a root cause determination.
The inspectors reviewed the licensee's procedures for loading and inspecting the cask, the associated shipping papers, the burial site's and the licensee investigative results,
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and interviewed several workers regarding this process. Portions of the licensee's cask loading had also been observed during an earlier NRC inspection documented.in NRC Inspection Report Nos. 50-373/98006(DRS) and 50-374/98006(DRS). The inspectors concluded that the cask loading and inspection was properly performed.
The licensee and burial site's staffs reviewed the circumstances and concluded that the burial site personnel failed to properly survey the cask. After unloading the LaSalle shipment and prior to transporting it to another NRC licensee, the burial site staff did not adequately inspect the intemals of the cask. However, the investigation could not determine the origin of the material. The TN-RAM cask had been used by many nuclear facilities to ship radioactive materials (e.g., irradiated metal hardware), similar to that
, shipped by the licensee. In accordance with 10 CFR 20.1906 and consistent with industry practice, the licensee's staff performed a visual and radiological survey of the extemal surfaces of the cask prior to loading; however, the staff did not inspect the cask's intemals. The licensee relied on the burial site to perform a survey of the cask
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interior after unloading and prior to transporting the cask to the next authorized user.
l Consequently, the licensee's staff was not confident of the content of the cask prior to
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loading it.
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l 1-i Neither the inspectors nor the licensee could determine the origin of the tubing or how
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long it had been inside the cask. Since the licensee was the last user of this cask, the inspectors concluded that it was possible that the tubing was inside the cask, during the licensee's shipment of the cask to the burial site. However, the licensee's staff indicated I
that there was a credible potential for the tubing to have originated at the burial site.
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Based on the inconclusive origin of the tubing, the inspectors could not conclude that the piece of tubing was present in the cask when the licensee shipped it and, therefore, did not conclude that the licensee violated the cask's Certificate of Compliance (CofC no. 9233), which requires that allirradiated material be shipped inside a secondary container (i.e., liner). As a precaution, licensee personnel revised station procedures to include a visual and radiologicalinspection of the inside of this type of cask during future
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Conclusions The licensee performed a thorough investigation of the source of irradiated metal found inside a Type B cask. Although the source of the metal and the duration it was inside
the cask was unknown, the inspectors determined that its presence would not have
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resulted in a significant health hazard during transport.
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R1.2 Thermoluminescent Dosimetrv Quality Control Procram
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a.
Insoection Scoce (IP 83750)
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The inspectors reviewed the licensee's thermoluminescent dosimeter (TLD) processing and quality control testing.
b.
Observations and Findinas The licensee's corporate staff maintaineci an offsite, central processing facility, which had processed TLDs for the licensee sir,ce January of 1997. In accordance with 10 CFR Part 20, the facility was accreditec under the National Voluntary Laboratory Accreditation Program (NVLAP) through December 31,1998. The facility staff also conducted a quality control program consistent with its quality control program manual.
For example, the inspectors reviewed the quarterly analysis results of irradiated TLDs which had been prepared by the facility and by a vendor to ensure that the TLD processing instruments were operating properly. Per this program, the facility staff established an acceptance criteria (i.e., tolerance guideline) of 0.10 and 0.20 for gamma and beta TLD results (respectively), which was more conservative than the 0.50 guideline designated by NVLAP. The facility staff defined the tolerance as the sum of the mean bias of the measurements and the measurements standard deviation from the mean. The inspectors noted that the results of the analyses were generally within the facility's tolerance guideline and that the results of these analyses were graphed to identify any long-term biases. However, the results for the analysis of TLDs irradiated with thallium-204 had been frequently greater than the 0.20 guideline established by the
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facility but within the 0.5 NVLAP guideline. At the time of the inspection, the facility staff
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indicated that they had implemented a lower beta correction factor (revised from 1.835 to 1.620), which they beileved would improve their analyses.
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Conclusions The RP staff properly implemented the extemal dosimetry quality control program. The licensee maintained NVLAP accreditation in accordance with 10 CFR Part 20. In addition, periodic TLD quality control tests were performed, and the results were evaluated for long term biases or trends.
R1.3 Administrative External Dose Controls and Evaluations a.
Insoection Scoce (IP 83750)
The inspector reviewed the licensee's administrative external exposure controls, the 1997 personnel dose reports, the RP staff's evaluations conceming unexpected differences between TLDs and electronic dosimeter (ED) results and the implementation of the following procedures:
LRP 5200-7 (revision (rev. 2)), " External Radiation Exposure Investigations;"
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LRP 5200-8 (rev. 2), "TLD lssuance, Assignment, Storage, and Collection;"
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LRP 5210-3 (rev. 0)," Comparison of Personal Dosimeter Results;"
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LRP 5300-2 (rev.1)," Exposure Review and Authorization;"
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LRP 5300-3 (rev.1)," Administration of the Radiation Aspects of Comed's Fetal
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> Protection and Postnatal Programs;" and LRP 5300-3 (rev.1),"Special Instructions Concerning Female Radiation
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Workers."
b.
Observations and Findinas The licensee maintained administrative dose levels to ensure that personn*l doses at the site were maintained as-low-as-is-reasonably-achievable (ALARA). For example, procedure LRP 5300-2 established the following administrative control levels: (1) an annual total effective dose equivalent (TEDE) of 3 rem and (2) a daily deep dose equivalent (DDE) of 0.300 rem. In order for an individual to exceed these control levels, the procedure delineated the review and approval process. For example, the approval of the station manager, health physics supervisor, and department head were required for an individual to exceed the annual control level of 3 rem. The inspector reviewed the licensee's 1997 personnel dose records and found that all individuals were maintained
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below the annual control level. In addition, the inspectors noted that the licensee also
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provided additional monitoring of individuals with high lifetime doses (i.e., doses within 3
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rem of the individual's age in ycars), individuals whose annual dose exceeded 1 rem, and female workers' doses.
The inspectors also observed effective controls for radiation workers who voluntarily declared pregnancies to the licensee. The inspectors verified that the licensee's
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procedures were consistent wah the requirements of 10 CFR Part 20 and noted that the
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' procedures were also consistent with NRC guidance. In accordance with the above procedures, the licensee closely monitored the doses of declared pregnant workers.
The inspectors reviewed 1997 and 1998 exposure records and verified that doses to these workers were maintained below the 10 CFR Part 20 limits. In most cases, the individuals opted not to continue working in the radiologically restricted areas (RRAs)
during the gestation period; therefore, no additional radiation dose was obtained following the pregnancy declaration. However, in one case, an individual continued to work within the RRA. In this case, the inspectors verified that the licensee's dose restrictions would have prevented the embryo / fetus from obtaining a radiation exposure above the regulatory limits (10 CFR 20.1208). For example, the licensee placed a 100 '
i..illirem annual dose restriction on the access control system for the individual, and the lead health physicist monitored the individual's dose on a weekly basis. During the 45
' days of employment at the licensee's facility, the individual did not obtain any measurable dose following the declaration of pregnancy.
The inspector reviewed routine personnel dose investigations and observed that.
unacceptable discrepancies between TLD and ED results were reviewed, as required by procedures. Following each calendar quarter, the dosimetry supervisor reviewed the computerized comparison of individual doses rneasured via TLD to the dose measured by ED.' From January 1,1997, to date, the licensee had identified only three incidents in which the dose measured by ED was not within 25 percent of the personal dose measured by TLD. In each of these cases, the dosimetry supervisor reviewed the individual's dose history for the quarter and ensured that the TLD results were not suspect. However, the licensee did not record / document any conclusions conceming the cause of the discrepancy (e.g., whether an ED had malfunctioned, individual hed improperly used an ED, etc.). The inspectors discussed this with members of the RP
- staff, who acknowledged that this information would have been useful in identifying any potential performance or instrumentation problem and indicated that they planned to review the thoroughness of these investigations. Annually, the staff also reviewed the cumulative comparison of TLD-to-ED results. The inspectors noted that these results indicated that ED's responded in a conservative manner with respect to TLDs (i.e.,
about 10 to 20 percent higher than TLDs).
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Conclusions
' The licensee maintained administrative extemal dose levels to ensure that personnel doses were maintained ALARA. Administrative dose controls were effective in
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maintaining personnel doses, and specified approvals were required to exceed administrative dose controls. The RP staff also effectively controlled doses to declared L
pregnant workers in accordance with NRC regulations and guidance. However, the staff L
did not thoroughly investigate discrepancies between personal doses measured by TLD as compared to personal doses measured by EDs.
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R1.4 Control of Hiah Radiation Areas (HRAs)
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Insoection Scoce (IP 8375G)
The inspectors reviewed the licensee's control of HRAs, including locked (LHRA) and very high (VHRA) radiation areas. The inspection consisted of a review of station procedures, interviews with personnel and a walkdown of selected HRAs and LHRAs.
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Observations and Findinas.
The inspectors reviewed the licensee's procedures for HRA, LHRA, and VHRA access and verified that the stated controls were consistent with regulatory requirements and industry practice. At the time of this inspection, the licensee did not control any plant areas as a VHRA. During walkdowns, the inspectors observed RP technicians properly issuing LHRA keys and challenging workers regarding LHRA entries. Through j
interviews, the inspectors verified that workers were aware of proper methods for accessing and working in HRAs and LHRAs.
The inspectors observed the condition of the following LHRAs: Unit 1 phase separator room; Unit 2 reactor water cleanup valve aisle, reactor water cleanup heat exchanger rooms, reactor building equipment drain tank and pump rooms; and the radwaste building WF, OWX, OWZ, OWX07TA and 2WF pump and evaporator rooms, lower radwaste tunnel (677' elevation), and the "B" DPU area. These areas were observed te be well controlled. In some locations, contamination levels had been significantly reduced which improved access to the areas. However, a problem was noted with radiological housekeeping, in that tools and materials from prior work activities were not removed from LHRAs. Station management agreed with these observations and planned to address the problems.
A review of Problem Identification Forms (PlFs) and discussions with workers indicated that other than the two events discussed in section R4.1 and R4.2, there have been no recurring problems with HRA/LHRA control.
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Conclusions High and locked high radiation areas were controlled consistent witn regulatory requirements and industry practice. During walkdowns, the inspectors observed workers using proper access control and significant recovery of some contaminated areas. However, a problem was observed with radiological housekeeping in some areas.
R1.5 Conduct of Air Samolina a.
Insoection Scoce (IP 83750)
The inspectors reviewed the licensee's air sampling program through a review of station procedures, interviews with workers, and observations of routine air sampling.
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b.
Observations and Findinas
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Station procedures were consistent with industry practice and NRC regulations but were not always consistent with management expectations. For example, some procedures contained provisions for performing derived air concentration (DAC)-hour tracking for workers, even though RP management prohibited this practice, in addition, certain procedures did not provide clear instructions. For er. ample, procedure LRP 6020-2 (rev.
2), step F(3)(k), listed how to perform an optional field check of air samples, but did not explain how this field check was to be used. Many RP technicians believed it was a
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requirement (i.e., not optional) but were not sure how to use the data. The inspectors
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also identified several minor exarnples of inconsistency among procedures.
The inspectors noted a lack of formal guidance for tracking the assignment of lapel air samplers and associated sample analysis results. Specifically, RP technicians assigned lapel samplers and associated results to radiation work permits (RWPs) and not to specific individual workers. The inspectors noted that this practice was not described in the applicable RP procedures. After interviewing RP personnel and reviewing selected, applicable records, the inspectors concluded that the lack of procedural guidance had not resulted in any significant problems. However, the RP staff acknowledged that the lack of formal guidance could result in difficulties identifying the affected individuals
should a positive air sample result be obtained.
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Licensee RP management agreed with the overall problems identified by the inspectors with the air sampling procedures and was planning corrective actions, including procedural revisions as applicable.
The inspectors observed that air sampling was well conducted; that air sampling equipment was operational and calibrated; and through interviews, that RP technicians were familiar with industry practices and NRC regulations. The licensee routinely analyzed air samples for gamma and beta emitting radionuclides, but did not perform routine analyses for alpha emitting radionuclides. However, the licensee indicated that alpha contamination had not been an issue based on good historical fuel performance and routine surveys of potential areas such as the refuel floor. An inspector also observed an RP technician using the proper procedure and method for calibrating a RADECO model H809V air sampler. Overall, the inspectors concluded that the air sampling program was well implemented.
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Conclusions Air sampling was conducted consistent with industry practice and NRC regulations. Air sampling equipment was well maintained and air sampling activities were performed appropriately. However, some examples were identified where procedural guidance was inconsistent with management expectations or where additional information was needed, in addition, the inspectors verified that there was no formal process for tracking lapel air samplers assigned to workers and associated results.
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R2 Status of RP&C Facilities and Equipment
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R2.1 Testing of the Standbv Gas Treatment System Filtration Units (IP 84750)
The inspectors reviewed the testing of the high efficiency particulate air (HEPA) and charcoal filters associated with the standby gas treatment system (SGTS). Since the identification and correction of a problem with the testing methodology (NRC Inspection Report Nos. 50-37598015(DRP) and 50-374/98015(DRP)), the licensee had revised the associated procedures to be consistent with the methodology required by Technical Specification (TS) 6.2.F.8, " Ventilation Filter Testing Program." The inspectors reviewed the results of HEPA and charcoal testing completed on June 3,1998, and observed that the testing was performed as required and that the testing was consistent with the above requirements. Although the testing results indicated satisfactory component performance, the inspectors noted some problems in the documentation of the physical examination of the filtration units. For example, the record of the Unit 1 HEPA filtration unit testing indicated that damage was observed on the pre-filter and that the moisture separator looked " bad"; however, no corrective actions were noted for the observed deficiencies. A system engineer indicated that these issues did not affect the operability of the system, and, in the case of the moisture separator, the system engineer verified that the unit looked normal and functioned properly. At the time of this inspection, the engineer initiated an action request to repair the pre-filter, since one had not been initiated. The system engineer also acknowledged that the documentation was not clear as to the extent of the problems and the corrective actions taken. The inspectors also walked down the SGTS filtration units, noted the issues documented in the above testing, but did not observe any significant material condition problems.
R4 Staff Knowledge and Performance in RP&C R4.1 Refueling Floor Hiah Radiation Area Control and Contamination Event a.
Insoection Scooe (IP 83750)
The inspectors reviewed an event where a contract worker improperly accessed the refuel floor, a posted high radiation and contamination area. The inspection consisted of interviews with personnel, a walkdown of the area, and a review of applicable records.
b.
Observations and Findinas.
On March 27,1998, a contract design engineer improperly accessed the refuel floor, a posted high radiation and contamination area, by moving a radiological barricade and entering the area via a gap between the outer wall and rope stanchion on the Unit i side. Although not warranted by radiological conditions, the refuel floor was controlled as an HRA, owing to the potential for changing conditions due to work activities. The engineer, who was dressed in minimal protective clothing (i.e., shoe covers and gloves),
was inspecting the refuel bridge wheel bearings. Following his inspection, the engineer also exited the area at a point and in a manner (i.e., failed to utilize the step-off pads)
that was not appropriate, which resulted in the spread of contamination. Subsequently,
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the engineer performed a contamination survey and received an alarm on a personnel
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contamination monitor (about 5-15,000 disintegration per minute on his clothing; no skin contamination). During the RP staff's response, the licensee identified the inappropriate entry and, subsequently, suspended the engineer's RRA access. The individual later resigned.
The licensee attributed the root cause to the failure of the engineer to perform a self-check prior to the entry. The engineer, who was unfamiliar with the station layout, was instructed by the RP technician to enter the refuel floor via the Unit 2 side, where he would have found a step-off pad. Although there was no step-off pad near the Unit 1 side, the engineer assumed that he was allowed to move the barrier and enter the area.
A contributing cause was also poor communications, in that neither the RP staff nor the worker discussed how the engineer's inspection would be performed. The engineer's inspection required that he crawl undemeath the wheel housing while inside the contaminated area. Had this been known beforehand, the RP technician indicated that he would have instructed the worker to wear full protective clothing, which would have prevented any spread of contamination to the worker.
The inspectors' review concluded that this was an, isolated event resulting from personnel error by the worker. In addition to the immediate actions listed above, the licensee discussed the event with the RP staff and engineering work groups. A review
of station PlFs did not identify a similar event occurring this year.
Technical Specification 5.2A(a) requires that procedures recommended by Appendix A to NRC Regulatory Guide 1.33 (rev. 2), dated February 1978, be implemented. Section
' 7(e)(1) of Appendix A to Regulatory Guide 1.33 recommends that procedures for access control to radiation areas be implemented. Step D.4 of station procedure LRP 5310-2 (rev. 3), " Control of Access to HRAs and VHRAs," which addresses access control to radiation areas, requires that RP approval be obtained prior to moving a barricade. The engineer's failure to obtain RP approval prior to moving the refuel floor barricade was contrary to the above procedure and a violation of TS 5.2(A)(a). However, this non-.
repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50 -
373/98018s01 and 50-374/98018-01).
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' Conclusions One Non-Cited violation was identified when a contract engineer failed to obtain RP L
department approval prior to moving an HRA barricade on the refuel floor. This event was non-repetitive and was identified and corrected by the licensee.
R4.2 Workers Enter Unsurveved Area While inside an LHRA-a; Insoection Scone (IP 83750)
The inspectors reviewed an event where two construction laborers entered the Unit 2
"A" reactor water cleanup heat exchanger (RWCU HX) area, an LHRA, without the area
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having been surveyed by the RP group. The inspection consisted of interviews with
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workers, a walkdown of the area, and a review of applicable documents.
b.
Observations and Findinas The workers entered the area on May 26,1998, in order to perform decontamination
activities. Both workers were wearing ED's having dose and dose rate alarm settings of
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160 millirem and 250 millirem /hr, respectively. After receiving a dose rate alarm, the
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workers exited the area. In accordance with station procedures, the workers contacted the RP department, who subsequently determined that one of the workers had entered an area that had not been radiologically surveyed. The highest dose rate encountered by the workers was 350 millirem /hr, and the highest dose received by either worker was
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72 millirem.
Prior to the workers' entry into the area, the RP group had surveyed those areas within the LHRA to be deconned, based on the known work scope at the time. The remaining areas were not surveyed, in order to minimize RP technician exposure. However, no postings and/or barricades were installed to prevent entry into the unsurveyed areas.
Following the May 26,1998 entry, RP personnel verified that dose rates in the unsurveyed areas did not exceed 1000 millirem /hr.
The inspectors and licensee independently concluded that the root cause was a failure by the RP department to adequately implement controls over the job. A contributing cause was poor communications between the work group and RP personnel. Prior to the job, the workers had reviewed the survey data and discussed the job entry requirements with RP personnel. The desk RP technician discussed the specific RWP requirements, but not the scope of work or those areas in the Unit 2 "A" RWCU HX which had not been surveyed. Additionally, those areas were not clearly marked on the associated radiological survey map, and, as described above, no postings and/or barricades were established.
An additional error occurred in that the workers were not on the proper RWP, as determined by the RP technician, for the job. The RP desk technician noted that the workers' routine RWP (no. 980512, rev.1) had an ED dose rate alarm setpoint of 250 millirem /hr and required a pre-job briefing. The technician noted that the dose rate alarm needed to be increased and that the workers did not require a pre-job briefing, since the workers had previously performed a similar decontamination of the Unit 1 RWCU HX room. Consequently, the technician instructed the workers to use RWP no.
980150, rev. O, which had a dose rate alarm setpoint of 500 millirem /hr and did not require a briefing. However, the actual RWP used by the workers and entered into the LHRA access log by the RPT was no. 980512 instead of no. 980150. The inspectors verified that, with the exception of the lower ED alarm setpoints, other ALARA controls implemented by RWP 980512 were appropriate.
Corrective actions included discussing the event with construction and RP personnel and establishing barricades at all other unsurveyed areas in the RRA. Additionally, management expectations regarding proper communications were discussed with RP
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technicians and construction laborers. The event was also discussed in the station
newsletter.
Technical Specification 6.1.1.1 states, in part, that each high radiation area in which the intensity of radiation is greater than 100 millirem /hr, but less than 1000 millirem /hr shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by requiring issuance of an RWP. In addition TS 6.1.1.1 states that any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following: (1) A radiation monitoring device which continuously indicates the radiation dose in the area; (2) A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a present integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levelin the area has been established and personnel have been made knowledgeable of them; or (3) A health physics qualified individual, i.e., qualified in radiation protection procedures, with a radiation dose rate monitoring device, who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Health Physicist in the RWP. As described above, the workers were not provided with either a. monitoring device that continuously indicated the radiation dose in the area nor a health physics qualified individual. Since a completed survey of the area was not completed and the workers were not knowledgeable of the dose rates in the area, the workers had not satisfied the above requirement for entry into an HRA, which is a violation of TS 6.1.1.1 (VIO 50-373/98018-02 and 50-374/98018-02).
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Conclusions One violation was identified conceming the entry of personnel into a unsurveyed area within a locked high radiation area. Specifically, RP personnel failed to establish appropriate controls to prevent two construction workers from entering an area within the Unit 2 A RWCU HX room, an LHRA, that had not been radiologically surveyed.
V.
Manaaement Meetinos X.1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on July 16,1998. The licensee acknowledged the findings presented and identified no proprietary information.
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PARTIAL LIST OF PERSONS CONTACTED
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C. Berry, Chief of Staff F. Dacimo, Site Vice-President N. Hightower, Health Physics Manager i
i T. O'Connor, Station Manager
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H. Pontious, Acting Regulatory Assurance Manager B. Riffer, Quality and Station Assurance Manager R. Stachniak, CAP Program Manager INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure
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IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring
IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED AND CLOSED f
Opened 50-373/98018-01 NCV Failure to obtain RP approval prior to moving HRA 50-374/98018-01 barricade (Section R4.1).
50-373/98018-02 VIO RP personnel failed to establish appropriate I
50-374/98018-02 controls prior to permitting access to the Unit 2 RWCU HX, an LHRA (Section R4.2).
Closed
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None.
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LIST OF ACRONYMS USED
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ALARA As-Low-As-Reasonably-Achievable DDE Deep Dose Equivalent ED Electronic Dosimeter HEPA High Efficiency Particulate Air HRA High Radiation Area LER Licensee Event Reports LHRA Locked High Radiation Area NVLAP National Voluntary Laboratory Accreditation Program rev.
Revision RP&C Radiation Protection and Chemistry RRA Radiologically Restricted Area RWP'
Radiation Work Permit SGTS Standby Gas Treatment System
TLD Thermolumiscent Dosimeter TS.
Technical Specification VHRA Very High Radiation Area i
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LIST OF DOCUMENTS REVIEWED
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Station Procedures Nos.
LAP 820-7 (rev.14) Cask Handling and Loading for Fuel Pool Cleanout Project LRP 1370-1 (rev. 6) Calibration of Air Sampling Equipment LRP 6020-3 (rev. 8) Radiological Surveys LRP 5821-47 (rev.1) Operation of the RADECO H809V and H-810 High Volume Air Samplers LRP 6020-2 (rev. 2) Radiological Air Sampling Program LRP 5821-36 (rev.1) Calibration and Operation of the GILIAN Personal Sampling System
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LRP 5000-7 (rev. 6) Unescorted Access to and Conduct in Radiologically Posted Areas LAP 300-45 (rev. 0) Ventilation Filter Testing Program (VFTP)
LES VG-01 (rev. 2)
Heating Coil Performance Test for Standby Gas Treatment System LRP 5200-7 (rev. 2) External Radiation Exposure Investigations LRP 5200-8 (rev. 2) TLD lssuance, Assignment, Storage, and Collection j
LRP 5210-1 (rev. 0) Annual Dose Report to the NRC and to Monitored Individuals l
LRP 5210-3 (rev. 0) Comparison of Personal Dosimeter Results j
LRP 5300-2 (rev.1) Exposure Review and Authorization
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LRP 5300-3 (rev.1) Administration of the Radiation Aspects of Comed's Fetal Protection and l
Postnatal Programs LRP 5300-3 (rev.1) Special instructions Concerning Female Radiation Workers LTS 400-1 (rev. 7)
Standby Gas Treatment HEPA Filter Test J
LTS 400-2 (rev. 8)
Standby Gas Treatment Charcoal Filter Test LTS 400-16 (rev.11) Charcoal Adsorber Laboratory Testing
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Test and Surveillance Results LST-98-006 (rev. 0) Standby Gas Treatment HEPA Filter Leak Test," completed on June 3, 1998 LST-98-007 (rev. 0) Standby Gas Treatment Charcoal Filter in-Place Leak Test," completed j
on June 3,1998.
LST-98-011 (rev. 0) Remcval of Carbon Test Canisters From Filtration Trains for Analysis,"
completed on June 3,1998.
Dosimetrv Reoorts
- Average Percent Disagreement Dosimetry Comparison Report for Quarter 1 Year 97, LaSalle,"
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(dated 5/13/97)
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" Average Percent Disagreement Dosimetry Comparison Report for Quarter 2 Year 97, LaSalle,"
(dated 9/2/97).
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" Average Percent Disagreement Dosimetry Comparison Report for Quarter 3 Year 97, LaSalle,"
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(dated 10/ 22/97).
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" Average Percent Disagreement Dosimetry Comparison Report for Quarter 4 Year 97, LaSalle,"
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" Average Percent Disagreement Dosimetry Comparison Report for Quarter 1 Year 98, LaSalle,"
(dated 4/23/98).
" Dosimetry Comparison Investigation List for Quarter 1 Year 97, LaSalle," (dated 5/13/97).
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" Dosimetry Comparison Investigation List for Quarter 2 Year 97, LaSalle," (dated 9/2/97).
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" Dosimetry Comparison Investigation List for Quarter 3 Year 97, LaSalle," (dated 10/22/97).
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- Dosimetry Comparison Investigation List for Quarter 4 Year 97, LaSalle," (dated 2/14/98 and
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3/2/98).
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" Dosimetry Comparison investigation List for Quarter 1 Year 98, LaSalle," (dated 4/23/98).
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" Percent Personnel Out-Of-Tolerance Dosimetry Report for Quarter 1 Year 97, LaSalle,"(dated 5/13/97).
" Percent Personnel Out-Of-Tolerance Dosimetry Report for Quarter 2 Year 97, LaSalle," (dated 9/2/97).
" Percent Personnel Out-Of-Tolerance Dosimetry Report for Quarter 3 Year 97, LaSalle," (dated 10/22/97).
" Percent Personnel Out-Of-Tolerance Dosimetry Report for Quarter 4 Year 97, LaSalle," (dated 2/14/98 and 3/2/98).
" Percent Personnel Out-Of-Tolerance Dosimetry Report for Quarter 1 Year 98, LaSalle," (dated 4/23/98).
"LaSalle Alert List 'S'," (dated 7/15/98).
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"LaSalle Station Secondary Dose Records with DDE Greater than 999 Millirem,"(dated
7/15/98).
l Problem Identification Forms (PIFs) Nos.
L1998-03591 (dated 5/14/98)
Fuel Handling idsntified shipping concerns with activated hardware Miscellaneous
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Memorandum (dated 6/8/98) from C. Chan, Comed, to M. Friedman, et al., Comed, " Quarterly High Energy Gamma Blind Spike" Memorandum (dated 6/17/98) from M. Azar documenting audit results of the Barnwell Waste Disposal Facility regarding the April 1998, transportation event Memorandum (dated 6/5/98) from Chem-Nuclear Systems regarding results of investigation of April 1998 transportation event and corrective actions.
Shipping papers for Shipment No. 98-32 to Barnwell Burial Site l
Certificate of Compliance No. 9322 (dated 12/19/97) for Type B Cask Model No. TN-RAM.
Weekly Reactor Water Alpha Analysis Results from 7/7/98 to 7/16/98 i
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US NRC Regulatory Guide No. 8.25 (rev.1), " Air Sampling in the Workplace" l
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