IR 05000373/1999009
| ML20206G765 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 05/03/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206G756 | List: |
| References | |
| 50-373-99-09, 50-373-99-9, 50-374-99-09, 50-374-99-9, NUDOCS 9905100137 | |
| Download: ML20206G765 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION lli Docket Nos:
50-373;50-374 License Nos:
Report No:
50-373/99009(DRS); 50-374/99009(DRS)
Licensee:
Commonwealth Edison Company Facility:
LaSalle Nuclear Generating Station, Units 1 and 2 Location:
2605 N. 21" Road Marseilles, IL. 51341-9756 Dates:
April 6-9,1999 Inspectors:
W. Slawinski, Senior Radiation Specialist A. Kock, Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
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l-9905100137 990503 PDR ADOCK 05000373
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EXECUTIVE SUMMARY LaSalle Nuclear Generating Station, Units 1 and 2 NRC inspection Report 50-373/99009(DRS); 50-374/99009(DRS)
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- This announced routine inspection evaluated aspects of the operational and outage radiation protection (RP) program, focusing on the licensee's corrective actions for previously identified problems. Specifically, the inspectors reviewed: (1) the results of recent licensee audits and
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assessments of the RP program, (2) improvement initiatives and other strategies to address identified weaknesses, (2) recent trends in radiation worker and radiation protection staff performance, and (4) radiological controls and as-low-as-is-reasonably-achievable (ALARA)
plans for selected work activities. The following conclusions were reached in these areas:
Plant Suooort An improvement strategy recently developed by the licensee to address RP program
performance deficiencies was comprehensive, well thought out, and included corrective actions for findings from licensee, NRC and industry assessments and inspections.
While initial phases of the improvement strategy were generally being implemented timely and effectively, some deficiencies in strategy implementation were identified and were being addressed by the licensee (Section R1.1).
The licensee developed new ALARA initiatives, expanded or refined existing initiatives,
and implemented improved processes for radiological work planning and work oversight.
Although it was too soon to fully assess the effectiveness of these recent efforts, positive steps were taken by the licensee to strengthen the ALARA and work control programs (Section R1.2).
Although the details of the RP program improvement strategy and other initiatives
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planned to improve program performance were not consistently conveyed to the staff as intended by RP management, information exchanged through altemative methods produced a common understanding of expectations and ensured that initiatives were effectively implemented in the field (Section R4.1).
The RP organization effectively implemented a process to proactively identify problems
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-in human performance and improvement initiatives were underway to correct identifed
- weaknesses (Section R4.2).
Preliminary data showed that human performance during radiological work was mixed.
- Initiatives to curtail RP staff human performance problems were generally successful; however, problems continued with radiation worker performance (Section R4.2).
The audit and assessment program was effectively implemented and identified common
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causes for weakncases in human performance. Audits and assessments were properly
. focused, were of sufficient scope and depth to assess the areas reviewed, and findings were adequately supported. Specific actions were developed to address all assessment and audit findings as part of a comprehsnsive RP program improvement strategy (Section R7.1).
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s Report Details IV. Plant Suncort R1 Radiobg':.al Protection and Chemistry (RP&C) Controls R1.1 Radiation Protection Proaram Imorovement Strateav a.
Insoection Scooe (83750)
The inspectors evaluated recently implemented radiation protection (RP) program improvement initiatives, which were developed by the licensee to address self-identified problerris and NRC and Institute for Nuclear Power Operations (INPO) findings. The inspectors reviewed the development and implementation of the initiatives and the licensee's mechanisms to measum and monitor its progress.
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Observations and Findinos The licensee developed an RP Program improvement Strategy (RPIS), to address continued human performance deficiencies and other RP program weaknesses identified in recent NRC inspechons, an INPO audit, and in licensee self-assessments and audits including a recent common cause self-assessment. The common cause assessment was conducted to analyze adverse trends in radiological performance and was prompted, in part, by NRC identified programmatic weaknesses with radiation worker and RP staff performance, as described in inspection Report 50-373/99005(DRS);
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374/99005(DRS).
The inspectors reviewed the RPIS. Specific tasks / actions were developed to address I
weaknesses in strategic areas of leadership / organization, training and knowledge, worker practices, and RP programs and service. The strategy delineated responsible individuals within the RP organization for each specific task in order to instill ownership in the initiatives and promote team work in achieving goals. The strategy was designed to foster improved management oversight and commitment to the RP program. Various
- -measures were used to monitor the performance of the RP program as had been the past practice; however, existing measures were expanded, tracking of these measures
~was improved, and new measures were implemented to better monitor strategy implementation and overall program effediveness.
The inspectors determined that the improvement strategy was generally being implemented successfully and in accordance with the licensee's timetable. The inspectors noted that some of the initiatives had begun to positively impact the RP program and program ownership within the RP organization appeared to be improving.
However, deficiencies were identified in the implementation of some of the strategy
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initiatives, which the licensee recognized and was in the process of addressing. For i
example, some of the strategy's specific tas.ks/ actions were not completed by the licensee's assignc' jue dates because of other priorities, and the tracking of certain
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Initiatives was incomplete which impacted the licensee's ability to readily identify the status. Also, some initiatives were not documented to demonstrate their completion, and other initiatives in various stages of implementation were not fully assessed to evaluate their effectiveness. In particular, although a " scorecard" system that was developed to document RP supervisory field observations was being implemented as intended and worker performance deficiencies were immediately corrected when witnessed in the field, individual observations were not evaluated collectively so that generic problems could be recognized.
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Conclusions An improvement strategy developed by the licensee to address RP program performance deficiencies was comprehensive, well thought out, and included corrective actions to address findings from recent licensee, NRC and industry assessments and inspections. While initial phases of the improvement strategy were generally being implemented in a timely and appropriate manner, some deficiencies in strategy implementation were identified and were being addressed by the licensee.
R1.2 As-Low-As-Reasonably-Achievable (ALARA) Prooram and Work Controls a.
Inspection Scope (83750)
The inspectors evaluated the effectiveness of recent changes made to the ALARA program and work control process, stemming from the improvement strategy. The
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inspectors reviewed selected ALARA plans, interviewed ALARA and RP staff, and i
observed the radiological controls established for a specific job and the general l
radiological oversight of work activities throughout the turbine and reactor buildings, b.
Observations and Findinas To address necent licensee and NRC findings and as part of the licensee's improvement strategy, initiatives were developed to enhance the quality and consistency of ALARA reviews, to standardize the ALARA planning process, to expand the involvement of the
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RP group in work planning, and to improve the oversight of radiological work.
- New ALARA initiatives were developed, existing ones were refined, and other initiatives
'successfully used at other stations were adopted. The dose threshold for ALARA staff involvement in job planning was lowered, and an initiative for partial or " micro-ALARA" reviews was implemented for work activities with projected doses as low as 100 mrem.
Previously, full ALARA reviews were completed forjobs whose projected dose was 1000 mrem or greater. Although not as rigorous as full ALARA evaluations, micro-ALARA reviews allowed the RP staff to perform a limited review of a projected work
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activity to ensure dose control issues were identified and addressed in the radiation work l
permit (RWP) package. Additionally, dose development and projection activities were I
incorporated into the existing "fragnet" work planning and scheduling process to better engage the work group and the ALARA staff in job planning. As part of the "fragnet" process, radiological work activities were broken down into fragmented steps or segments, and a projected work duration and dose was assigned for each specific step.
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The inspectors reviewed RWPs and associated ALARA and micro-ALARA plans for several recently completed or ongoing jobs, and verified that the new initiatives were implemented as intended by the licensee. The licensee planned to revise its ALARA procedure to incorporate the new and revised ALARA initiatives. The inspectors determined that good ALARA initiatives were established for repair work on a waste collector tank weld connection, even though a full ALARA review was not performed for the job. A micro-ALARA review conducted for the job alerted the work group to several ALARA concerns, which were reportedly addressed by the work supervisor, work crew, and RP staff during the pre-job briefing. Inspector discussions with some of the maintenance staff involved in the repair work revealed that the staff had a good working relationship with the radiation protection technician (RPT) that provided job coverage, I
and all involved workers were cognizant of the ALARA controls required.
I The licensee recently reestablished the RP zone coverage concept and the greeter
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I program in an effort to improve the oversight of radiological work activities and to ensure worker understanding of radiological conditions in their assigned work areas, respectively. Lead RPTs were assigned responsibility for all radiological work activities i
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in the drywell and in reactor and turt>ine building zones, and roved these areas periodically to check on job progress and ensure proper job coverage and oversight.
The licensee also recently expanded RP supervisory presence in the field, an aspect of the RP program deemed unsatisfactory during recent RP self-assessments. The inspectors noted, however, that zone technicians were not readily identifiable in the field and in some instances had to be sought out by the inspectors. This observation was expressed to RP management, who agreed that zone RPT and field supervisors should be more easily recognized and accessible in the plant, and attematives to address this issue were being contemplated. The inspectors noted that most greeters positioned at the main radiologically protected area (RPA) access and egress control points sufficiently challenged workers; however, a backup greeter temporarily filling in for the primary greeter was unsure about RWP requirements and how to verify them. This observation was relayed to RP supervision who planned to review the instruction provided to the backup greeters.
f Since the ALARA and work control improvement initiatives were in the early phases of-implementation, no conclusions could be drawn regarding their effectiveness. However, j
these efforts coupled with other initiatives demonstrated that the licensee aggressively
- pursued problem resolution and initiated positive steps to improve the program. The licensee expected that these efforts would improve communications between the RP j
staff and station work groups, better engage workers in the RP program, and thereby improve program ownership throughout the station.
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Conclusions The licensee developed new ALARA initiatives, expanded or refined existing initiatives, and initiated improved processes for radiological work planning and work oversight.
These initiatives produced more consistent and better quality ALARA plans and better engaged workers in radioksical control processes. While it was too early to fully assess the effectiveness of these initiatives, positive steps were taken by the licensee to strengthen identified program weaknesses.
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i5 R4 Staff Knowledge and Performance in RP&C R.4.1 Radiation Protection Staff Performance Imorovement initiatives a.-
' inspection Scooe (83750)
The inspectors interviewed members of the RP staff and attended RP supervisor and technician shift tumover meetings to evaluate staff perspectives and the licensee's information exchange process.
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Observations and Findinas Significant changes to the RP management organization (as described in Section R6)
were made concurrent with the development of the improvement strategy. As this occurred, RP management expectathos were being developed and staff responsibilities were being redefined. To communicate the improvement initiatives and other changes to the RP staff, several written communications were issued to the staff which outlined expectations and provided guidance on a variety of lesues. These communications were clarified and reinforced during staff tailgate and shift tumover meetings. However, inspector interviews of selected RP staff revealed that not all staff was familiar with the written communications because the information was either not provided or was inconsistently conveyed to some individuals that were not present during the initial staff meetings. Nevertheless, those staff interviewed during the inspection shared a common
. understanding of the improvement initiatives, management expectations, and their responsibilities._ This was obtained through individual discussions with management, shift tumover meetings, and information exchanged with coworkers. Radiation protection management agreed that it was important to ensure that all RP staff received information consistently and from proper sources, and they planned to investigate the cause of the communication breakdown and improve future communications.
The inspectors attended RP supervisor and staff tumover meetings and determined that relevant work status and job coverage information was effectively communicated to the staff, and that information was freely exchanged. Radiation protection staff perspectives
- on the improvement strategy were generally positive and those interviewed shared the opinion that the revised responsibilities and changes to the work control and oversight
- process provided staff with an increased sense of ownership. While some staff were not familiar with the details of the improvement initiatives, information was exchanged sufficiently between peers to ensure initiatives and management expectations were properly implemented in the field. In addition, the staff was comfortable providing feedback to management on potential areas for improvement.
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Conclusions Although the details of the RPIS and other initiatives planned to improve program performance were not consistently conveyed by management to the RP staff, information exchanged through altemative methods produced a common understanding of expectations and ensured that initiatives were effectively implemented in the field.
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R.4.2 Human Performance Durina Radioloalcal Work a.
Insoection Scooe (83750)
The inspectors reviewed RP performance data for 1999 to date, independently trended problem identification form (PlF) information, and interviewed RP and Nuclear Oversight (NO) staffs to determine whether the licensee was proactively evaluating radiological issues.
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Observations and Findinas Inspection Report 50-373/99005(DRS); 50-374/99005(DRS) documented that the licensee had not proactively and collectively identified and corrected problems, resulting in continued negative trends in performance. The RPIS addressed this finding through
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the implementation of programs that better tracked human performance and other
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radiological problems and ensured proper follow up. For example, expanded
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performance metrics included PlF trending related to: (1) radiation worker performance by department, (2) the frequency with which the radiation protection department self identified problems, (3) the rate at which radiation worker noncompliance occurred, and
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(4) the types and frequency of problems identified during supervisory field observations.
Radiation protection staff tracked the status of these human performance measures and assessed the overall results. In addition, to ensure that problems identified during self assessments were addressed, the radiation protection department initiated a project to review the status of previous self assessment findings and determine whether appropriate follow up actions were completed. Nuclear Oversight also planned to rnonitor the implementation status of the RPIS in April or May 1999, and collectively assess its impact during future assessments.
The inspectors independently reviewed and trended more than 70 PlFs generated in 1999. This review showed a decrease in the significance of radiological problems compared to 1998. In addition, previous RP staff performance problems related to non-conservative decisions, poor communications between the radiation protection staff and workgroups, and inadequate oversight of work noted in inspection
- Report 50-373/99005(DRS); 50-374/99009(DRS) were not evident. However, performance problems related to radiation worker practices were apparent and included j
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inappropriate use of protective clothing l personal contamination events during work in non contaminated areas of the plant, and radiation work permit usage problems. These issues were recognized by the licensee and were being evaluated to determine if initiatives needed to be altered.
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Conclusions The RP organization effectively implemented a process to proactively identify problems
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- weaknesses. Preliminary data showed that initiatives to curtail RP staff human performance problems were generally successful, while problems continued with
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R6 RP&C Organization and Administration The licensee recently made several management changes to the RP organization as part of an overall effort to improve the performance of the RP program. The inspectors
. reviewed the qualifications of the new radiation protection manager (RPM) appointed in January 1999, and determined that the individual's qualifications met the requirements of Technical Specification 6.1.D. In addition, the radiation protection department replaced several supervisors with experienced staff from LaSalle and sister stations, to provide stronger leadership and new perspectives on radiation safety standards. In addition, to increase supervisory oversight in the field, the new RPM mandated that department supervisors increase field monitoring and presence and coach field activities.
- To ensure prompt and appropriate response to radiological problems, the RPM provided the staff with pertinent questions to consider during oversight of work activities and written guidance regarding proper response and notification during incidents. Inclusion of the radiation protection improvement strategy initiatives into supervisory performance reviews maintained accountability in accuTipiishing these goals. According to the RPM, these revised expectations and heightened interactions with the radiation protection staff resulted in a marked improvement in radiation protection staff performance.
R7 Quality Assurance in RP&C Activities R7.1 Audits and Self-Assessments a.
Insnadian Scooe (83750)
The inspectors reviewed the results of recent assessments and audits of the RP program, which the licensee performed concurrent with and following an NRC inspection that identified a programmatic weakness with aspects of radiological performance.
Assessment and audit reports were reviewed, findings were discussed with involved RP and NO staffs, and actions developed to address assessment findings were evaluated, b.
Observations and Findmgs Between January 18 and February 5,1999, the station's NO organization performed a
- review of the RPeprogram focusing on RP staff and radworker performance, organization
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and administraton, and instrumentation calibration and controls. The inspectors reviewed the audit plan and audit report, reviewed supporting fisid monitoring reports, and discussed the assessment findings with one of the auditors. The audit identifed weaknesses in communication and enforcement of standards and expectations within
- ths RP organization, which resulted in poor RP staff and radworker performance.
In March 1999, the licensee concluded an assessment to identify common causes for NRC and NO identified problems related to radworker and RP staff human performance, as documented in inspection Report 50-373/99005(DRS); 50-374/99005(DRS) and the aforementionad licensee audit report. A three-person team of licensee and contractor experts independent of the station's RP organization identified several common causes which contributed to the known performance problems, and also identified other adverse performance trends. The inspectors reviewed the assessment results, discussed the
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E assessment methods with one of the team members involved in the review, and determined that assessment conclusions were on target and were supported by factual information gathered from PlFs and follow-up licensee investigations.
The inspectors confirmed that the RPIS described in Section R1 of this report included specific tasks / actions that addressed each of the findings from the common cause assessment, the recent NRC inspection, the NO assessment, and recent observations made by the new RP management team.
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Qgrg;lygieng
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Audit and assessment activities recently conducted to evaluate licensee defined critical attributes of the RP program and to identify common causes for weaknesses in human performance was effectively implemented. Audits and assessments were properly focused, were of sufficient scope and depth to assess the areas reviewed, and findings were adequately supported. Specific actions were developed to address all assessment and audit findings as part of a comprehensive RPIS.
R8 Miscellaneous RP&C lasues R8.1 RP Suooort for Unit-2 Startuo (83750)
The inspectors selectively reviewed records and discussed with the RP staff those radiological activities performed to support Unit 2 restart, as specified in special licensee procedures for restart certificaticn and power ascension. The inspectors determined that the RPM was cognizant of procedure specified RP program prerequisites for startup, that radiological conditions in the plant were reviewed by the RP staff as specified by the procedure, and that no outstanding radiologicalissues precluded startup. In particular, the inspectors reviewed documentation and selectively verified that Unit-2 locked high radiation areas were properly posted, controlled and secured, and that the licensee's RP staff double verified that the locked high radiation area requirements of LLP-98-33
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(Rev 0), "L2R07 Power Ascension Special Procedure," were met prior to startup.
R8.2 -Open item Follow Uo (92904)
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. (Closed) Violation 50-373/96014-01(DRS): 50-374/96014-01(DRS): Failure to
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conduct an adequate evaluation prior to removal of intermediate range monitors on two occasions. As documented in Inspection Report 50-373/97019(DRS);
50-374/97019(DRS); the licensee implemented corrective actions which addressed the root cause of the violation, but a recurrent issue occurred with the use of the station problem identification and resolution process and a PIF was not issued to document a similar event. Since that time, the licensee made significant changes to its problem identification and corrective action program which included enhancements to the Event Screening Committee process and membership, and development of a Corrective Action Program procedure which addressed PIF initiation, screening and evaluation.
Additionally, the licensee's corrective action program was recently evaluated by the NRC and determined to be acceptable (Inspection Report 50-373/98012(DRS);
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50-374/98012(DRS)), with improvements noted in identification, resolution and prevention of problems. Based on these improvements and the recent inspection findings re!ative to the corrective action program, this item is closed.
(Closed) Violation 50-373/97021-01(DRS): 50-374/97021-01(DRS): Failure to contact the RP staff prior to commencing high risk work during the Unit-1 reactor water cleanup system modification project. Corrective actions included development of a checklist to assure that important information is discussed with contract workers during pre-job l
briefings, expanded RP participation in pre-job meetings and work crew breakout sessions, and disciplinary action for certain individuals. Based on these specific
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corrective actions and those implemented as part of the RPIS discussed in Section R1.1
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of this report, this item is closed.
(Closed) Violation 50-373/98018-02(DRS): 50-374/98018-02(DRS): Failure to establish appropriate controls to prevent workers from entering unsurveyed portions of high radiation areas. As described in the inspection report which opened the violation, adequate corrective actions were taken to correct the problem and prevent recurrence.
These corrective actions included establishing barricades at all unsurveyed areas in the RPA and tailgate meetings with RP and construction laborer staff. No similar problems have occurred to date and these corrective actions appear adequate; consequently, this item is closed.
V. Management Meetings X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 9,1999. The licensee acknowledged the findings presented and identified no proprietary information.
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PARTIAL LIST OF PERSONS CONTACTED B. Blaine, Radiation Protection Operations Supervisor
. E. Carroll, Regulatory Assurance R. Flahlve, Nuclear Oversight K. Hedgspeth, Work Scheduler D. Hieggelke, Nuclear Oversight S. Lorenz, Contamination Control Coordinator P. Lucky, Corrective Actions Program Manager J. Place, Radiation Protection Manager P. Quealy, Technical Support Supervisor B. Riffer, Manager, Nuclear Oversight INSPECTION PROCEDURES USED IP 83750:
Occupational Radiation Exposure IP 92904:
Follow Up-Plant Support ITEMS OPENED AND CLOSED Opened None Closed 50-373/96014-01 VIO Failure to adequately evaluate radiological conditions prior to IRM 50-374/98014-01 removal.
50-373/97021-01 VIO Failure to contact RP prior to commencing high risk radiological 50-374/97021-01 work.
50-373/98018-02 VIO Failure to establish appropriate controls to prevent workers from 50-374/98018-02 entering un-surveyed high radiation areas.
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LIST OF ACRONYMS USED l
ALARA As-Low-As-Is-Reasonably-Achievable INPO Institute for Nuclear Power Operations
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PIF Problem identification Form Radworker Radiation Worker i
RP Radiation Protection RPA Radiologically Protected Area RPIS Radiation Protection Program improvement Strategy RPT Radiation Protection Technician RWP Radiation Work Permit
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VIO Violation
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PARTIAL LIST OF DOCUMENTS REVIEWED Station Procedures LLP-98-033 (Rev 0)
L2R07 Power Ascension Special Procedure
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LLP-99-033(Rev 0)
Restart Certification Special Procedure I
RWPs and Al. ARA Plans
RWP #990223 (Rev 0)
Approved Maintenance; Radwaste Pump Aisle RWP #990219 (Rev 0)
Disassemble and Repair Various FC and SA Valves
& associated ALARA plan RWP #990232 (Rev 0)
Sump Cleaning and Sludge Judging Contaminated Sumps
& associated ALARA plan Investiaation Reports and PlFs Report No ATM 1907-01 Radiation Protection Requests Common Cause (Rev 0),3/17/99 Analysis for Radiological Events.
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LaSalle County Station Radiation Protection Program improvement Strategy (Rev 1),03/14/99 Nuclear Oversight Radiation Protection Assessment #01-99-004 13