ML17328B079

Forwards Insp Repts 50-373/90-08 & 50-374/90-09 on 900422-27.No Violations or Deviations Noted.Work Scope & Practices Likely Primary Cause for High Exposures Being Experienced

ML17328B079
Person / Time
Site:	LaSalle
Issue date:	06/06/1990
From:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C COMMONWEALTH EDISON CO.
Shared Package
ML17328B080	List: IR 05000373/1990008 ML17328B079
References
NUDOCS 9006130149
Download: ML17328B079 (5)

See also: IR 05000373/1990008

Text

Docket

No, 50-373

Docket No. 50-374

Commonwealth

Edison

Company

ATTN:

Nr. Cordell

Reed

Senior Vice President

Post Office Box 767

Chicago,

IL

60690

Gertlemen:

This refers to the special

team assessment

conducted

by Nr. William Snell

and

others of this office,

NRC Headquarters,

NRC Region I, and Brookhaven National

Laboratory on April 22-27,

1990, of activities at LaSalle County Nuclear

Station, Units

1 and 2, authorized

by Operating

Licenses

No.

NPF-11

and

No.

NPF-18 and to the discussion of our findings with messrs.

D. Galle

and

G. Diederich

and others of your staff at the conclusion of the inspection.

The assessment

was conducted to evaluate

the effectiveness

of licensee

actions

to keep radiation

doses

at the LaSalle Station

as

low as reasonably

achievable

(ALARA).

The team used selective

examinations of procedures

and representative

records,

interviews with personnel,

and observations

of activities in progress

to perform the evaluation.

While Commonwealth Edison's

ALARA program

as it relates

to tIle LaSalle station

appears

to be generally adequate,

the inspection identified a number of areas

for your consideration

to improve the effectiveness

of the program.

Inasmuch

as the radiation

sour'ce

term at the LaSalle Station

appears

to be lower than

that found in comparable facilities,

we conclude that the work scope

and

practices

are likely the primary cause for the high exposures

which have

been experienced.

A number of notable strengths

and improvement

items are

'escribed

in Enclosure

1 and are discussed

in detail in the enclosed

report.

Within the scope of the assessment,

no violations or deviations

were identified.

After you have

completed your evaluation of this report,

we would like to meet

with you to discuss

your evaluations of our findings.

In accordance

with 10 CFR 2.790 of the Commission's

regulations,

a copy of

this letter and its enclosures will be placed in the

NRC Public Document

Room.

Commonwealth

Edison

Company

gUN

6 1990

We wi,ll gladly discuss

any questions

you have concerning this assessment.

Sincerely,

Enclosures:

l.

Executive

Summary

2.

NRC Inspection

Reports

No. 50-373/90008(DRSS);

No. 50-374/90009(DRSS)

cc w/enclosures:

D. Galle, Vice President -

BWR

Operations

T. Kovach, Nuclear

Licensing

Manager

G. J

~ Diederich, Station

Manager

DCD/DCB (RIDS)

Licensing

Fee

Management

Branch

Resident

Inspector,

RIII

Richard Hubbard

J.

W. McCaffrey, Chief, Public

Utilities Division

Patricia O'rien, Governor'

Office of Consumer

Services

R. Pulsifer,

NRR

LPM

bcc w/enclosures:

R.

R. Bellany,

NRC,

RI

D.

M. Collins,

NRC, RII

B. Murray,

NRC,

RIV

G.

P.

Yuhas,

NRC,

RV

C.

S. Hinson,

NRR,

PRPB

R.

L. Nimitz, NRC,

RI

B. Dionne,

BNL

J.

Baum,

BNL

Charles

E. Norelius, Director

Division. of Radiation Safety

and Safeguards

RIII

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RIII

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I

ENCLOSURE

1

Executive

Summar

During 1987 and

1988 the annual collective radiation

doses at the LaSalle

County Generatino Station exceeded

the national

average for Boiling Water

Reactors

(BWRs).

For 1987 the dose per reactor

(697 person-rem)

was

36 percent

above the national

average of 513 person-rem.

This placed LaSalle

fifth highest out of 33 U.S.

BWRs for 1987.

For

1988 the dose

per reactor

( 1236 person-rem)

was

134 percent

above the national

average of

529 person-rem.

This placed LaSalle

second

highest out of 34 U.S.

BWRs

for 1988.

During 1989 the collective dose per reactor

was

692 person-rem.

Although the

1989 national

average collective dose.was

unavailable, it appears

certain that LaSalle will again

have exceeded

the average for U.S.

BWRs. It

appears,

based

on data available

to date, that LaSalle

may be near the

national

average for 1990, which would continue the downward trend since

1988.

During the period of April 22-27,

1990,

a special

team assessment

was

conducted

by the

NRC to evaluate

the licensee's

efforts for maintaining

occupational

radiation doses

as

low as reasonably

achievable

(ALARA).

The

assessment

included

a review of the causes

of the past high radiation doses;

an"evaluation of the licensee's

current organization

and program for keeping

radiation

doses

ALARA; a review of the initiatives the licensee

has taken or

is taking to bring the radiation

doses

to within industry norms;

and

an

assessment

of licensee

management's

awareness

of, involvement in, and support,

for the

ALARA program.

The team concluded that inasmuch

as the radiation source

term at the LaSalle

plant appears

to be lower than that found in comparable facilities, the work

scope

and practices

are likely the primary cause for the high exposures

which

have

been experienced.

The team found

a high level of plant and corporate

management

awareness

and support for the

ALARA program.

Although the

licensee

has

been

implementing

a formal

ALARA program since initial plant

startup in 1982, the high annual collective dose in 1988 brought additional

attention to the program.

This additional attention

has

prompted

numerous

program changes

and upgrades,

from which tangible results

are being realized.

Recognizing the

ALARA program was still evolving, and considering

the

progress that

had

been

made over the past three to five years,

the team

concluded that many of the areas

identified as needing

improvement

may have

eventually

been

independently identified and addressed

by the licensee.

The licensee's

ALARA program was found to be generally adequate;

however,

a

number of areas

where

improvement would benefit the overall

ALARA efforts

were identified by the inspection

team.

Program strengths

and areas

where

the program

can

be significantly improved are

summarized

as follows:

~Stean

ths

Broad and effective corporate

support for the LaSalle Station

ALARA

program.

Aggressive

dose reduction program with respect

to program

and equipment

initiatives.

Items for Im rovement

Conduct continuing comparisons

of radiation

dose

data at LaSalle with

that for average

U.S.

BWRs to identify areas

where

improvement is

warranted,

and evaluate/implement

corrective actions

as appropriate

to reduce

doses.

Implement

an

ALARA suggestion/incentive

program.

Expand the training program to address:

advanced

radiation worker

training;

ALARA staff qualification and on-the-job training; and

design engineering

ALARA training.

Upgrade the quality of the mockup training to make it more realistic.

Upgrade overall quality, content

and guidance

contained in

RWP and

ALARA

procedures

to ensure

jobs are reviewed

on sub-task

bases

and to ensure

appropriate

dose

and contamination

reduction techniques

are considered.

Formalize

and upgrade

the criteria for performing

ALARA job reviews

and

post-job evaluations.