ML20058D596
| ML20058D596 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/16/1993 |
| From: | Loudon P, Paul R, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058B811 | List: |
| References | |
| 50-373-93-72, 50-374-93-27, NUDOCS 9312030224 | |
| Download: ML20058D596 (10) | |
See also: IR 05000373/1993027
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/93027(DRSS); 50-374/93027(DRSS)
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Dockets No. 50-373; 50-374
Licenses No. NPF-ll; NPF-18
Licensee:
Commonwealth Edison Company
Port Office Box 767
Chiugo, IL 60690
Facility Name:
LaSalle County Station, Units i and 2
Inspection At:
LaSalle County Station, Marseilles, Illinois
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Inspection Conducted:
September 27 through October 1, 1993
October 6 through 8, 1993
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October 18 through 20, 1993
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October 25 through 29, 1993
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Inspectors: (1Nhi Rf[l k
ada./f3
Patrick L. Louden ~
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Radiation Specialist
(i $0N %$$
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Ronald A. Paul
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Senior Radiation Specialist
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Accompanying Personnel:
Charles Cox
Approved By:
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William Snell, Chief
Date
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Radiological Programs Section 2
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Inspection Summary
Jnspection on September 27 through October 1: October 6 throuah 8: October 18
Jhrouah 20: and October 25 throuah 29. 1993 (Reports No. 50-373/93027(DRSS):
50-374/93027(DRSS))
Areas Inspected:
Routine, announced inspection of the licensee's radiation
protection (RP) program (Inspection Procedures (IPs) 83750 & 83729) during the
current Unit 2 refueling outage (L2R05) including changes in staffing, audits
and appraisals, radiological occurrences, licensee response to a recent
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radiological event which resulted in an Escalated Enforcement action, outage
work reviews, source term reduction etforts, and general station tours.
Results: Two violations of NRC requirements were identified.
One violation
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consisted of several examples of station personnel failing to follow radiation
protection procedures. The second violation is for failure to perform an
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adequate evaluation of the radiological hazards incident to workers performing
. 9312030224 931118
ADOCK 05000373
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work under the reacter vessel. Three inspection-followup-items were also-
identified during the inspection period and are as follows:
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(1)
monitor the implementation and responses to items identified by
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the Station Stand Down and Radiation Protection Issues Team.
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(2)
implementation on the training of and proper maintenance of
continuous air monitors.
(3)
monitor the radiation protection technician continuing training to
evaluate how the program addresses plant systems and associated
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radiological hazards.
Overall, the licensee's RP program continues to be a concern. The question
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still exists as to the depth of overall station buy-in to the requirements of
the radiation protection program, and there is still the appearance that.
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radiation workers do not adequately respect the radiological hazards
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confronted in the station.
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DETAILS
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Persons Contacted
Licensee staff
- R. Bare, Senior Quality Control Inspector
- J. Bell, Supervisor, Maintenance Support Group
- G. Benes, LaSalle Licensing Administrator
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- D. Berkman, Site Engineering and Construction
- J. Burns, Regulatory Performance Administrator, Downers Grove
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- D. Carlson, Regulatory Assurance NRC Coordinator
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- R. Crawford, Superintendent, Work Control
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- J. Fiesel, Hechanical Maintenance Staff
- M. Friedmann, Technical Lead Health Physicist
- L.
Hancin, Senior Radiation Protection Technician
- S. Harmon, Supervisor, Training Department
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- H. Kister, Business Development Team Member
- P. Knoll, Contamination Control Coordinator
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- K. Kociuba, Master Electrician, Electrical Maintenance
- J. Lewis, Operational Lead Health Physicist
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- J. Lockwood, Supervisor, Regulatory Assurance
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- G. Masters, Superintendent, Long Range Work Control
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- J. McIntyre, Superintendent, Station Quality Verification
- T. Nauman, Master Mechanic, Mechanical Maintenance
- L. Oshier, Health Physics Services Supervisor
- B. Packard, Corporate Health Physicist
- R. Ragen, Supervisor, System Engineering
- M. Santic, Superintendent, Maintenance
- J. Schmeltz, Superintendent, Operations
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- T.,
Shaffer, Administrative Assistant to the Site Vice President
- J. Terrones, Station Quality Verification Inspector
Euclear Reaulatory Commission
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- D. Hills, Senior Resident Inspector
lllinois Department of Nuclear Safety
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- J. Roman, Resident Engineer
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The inspectors also interviewed other licensee personnel-in various
departments in the course of the inspection.
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- Indicates those present at the exit meeting on October 29, 1993.
2.
Audits and Appraisals (IP 83750)
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The inspectors monitored the progress of the Station Quality
Verification yearly six week audit of the radiation protection program.~
The audit findings were consistent with prior NRC concerns with respect
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to radioactive material outside the radiologically controlled area
(RCA), and general radiation worker performance problems. Additional
findings included indications of eating and chewing (gum and tobacco)
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inside the RCA and a shielding package which did not include an
engineering _ evaluation. Overall, the audit appeared to be thorough in
nature.
No violation of NRC requirements were identified.
3.
Radioloaical Occurrences (IP 83750)
The inspectors reviewed several radiological events during the
inspection period.
Some of the more significant ones are detailed
below.
Items "a" through "d" are examples of-failure to follow-
radiation protection procedures as required by Technical Specification 6.2.B.
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a.
Radioactive Material Found Outside the RCA
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The inspectors noted several events in which slightly contaminated
material was discovered outside the RCA.
Examples of such
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material included contaminated rags, tools, protective clothing,
and vacuum cleaner bags. None of the material was outside the
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restricted area. The station has had a problem with radioactive
material control as detailed in Inspection Report 50-373/93014
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(DRSS); 50-374/93014(DRSS) in which a non-cited violation was
issued for this problem. These repetitive problems indicate that
prior corrective actions were ineffective in addressing the
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problem. Radioactive material outside a controlled area is a
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violation of LaSalle Administrative Procedure 900-26,
" Unconditional Release Program", Step F.1.a.2, which requires all
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material to be surveyed for removable and fixed contamination that
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is being removed from a controlled area, including material taken
from a contaminated area. (Violation 50-373/93027-Ola; 50-374/
93027-Ola)
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b.
Reactor Buildina Ventilation Filter Chanaeout
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The inspectors also reviewed an event involving the removal 'of
reactor building ventilation exhaust filters by station mechanical
maintenance personnel on October 14, 1993. The maintenance crew
attended a pre-job meeting with a radiation protection technician-
in attendance to discuss the removal of the filters. The work
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scope was covered during the briefing and it was understood that
the maintenance crew needed to notify the RPT prior to pulling the
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filter so that the RPT could be in attendance to perform surveys.
After the briefing, the RPT went back to the RPT lunch room and
the maintenance crew departed to get their necessary equioment.
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Sometime after this the crew called the RPT and requested a survey
of their work-cart so it could be taken from the RCA to an
uncontrolled area in the auxiliary building. The RPT informed the
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maintenance individual to get the technician at the respirator
issue desk to perform the survey and call him if they had any
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further trouble.
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Later in the shift, the RPT became curious about the activities of
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the maintenance crew, since they should have been ready to pull
the filter in a relatively short time.
The RPT went to the work
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area and found that the filter had already been pulled and the
work was completed.
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A review of the event revealed that the maintenance crews thought
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they had appropriately notified the RPT when they made the earlier -
phone call. =The RPT maintained that it was understood that he
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needed to be in attendance to perform surveys during the filter
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changeout.
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This event is another' example of failure to follow LaSalle
Administrative Procedure 900-26, Step F.1.a.2, which requires all
material to be surveyed for removable and fixed contamination that
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is being removed from a controlled area, including material taken
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from a contaminated area. (Violation 50-373/93027-Olb; 50-374/
93027-Olb)
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c.
Manaaement Personnel Failure to Follow Radiation Procedures
The inspectors reviewed another event involving a station
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management individual who became contaminated after removing valve
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tags from a contaminated area without having them bagged or
surveyed.
The individual was touring various contaminated areas
with the Senior Resident Inspector on October 13, 1993. When'
exiting the outboard main steam isolation. valve room (0BMSIV) the
individual wiped off two valve tags he found while in the OBMSIV
room and carried them to the whole body frisker.
The individual
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was contaminated on his hands and the valve tags were later
surveyed and indicated 100,000 dpm/100cm' (1,667 Bq/1000;*).
Removing items from a controlled area to an uncontrolled area
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without a survey for fixed and removable contamination is a
violation of LaSalle Administrative Procedure 900-26, F.1.a.2,
which requires such items to be surveyed prior removing material'
from a contaminated area.
(Violation 50-373/93027-01c; 50-
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d.
"K"
Safety Relief Valve (SRV) Flance Removal
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The inspectors reviewed another event which involved contract
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workers removing the discharge flange from the "K" SRV in the
drywell on October 14, 1993, without having a radiation protection.
technician present.
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A work crew entered the drywell under RWP 930572A, which-was-the
appropriate work permit for their activity. The RWP stated that
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attendance of an RPT was required when opening a process line and
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respiratory protection may be required when the process line is
-breached. The workers went up to the SRV area of_ the drywell and
began their work to cut the flange on the "K" SRV. The workers
assumed based on earlier briefings and that the nuts had been -
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loosened on the flange that the line was already breached and
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surveyed.
Adding to the confusion was that another worker near
the job site was wearing a hard hat with the letters "HP" on it=
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(the individual was not an HP).
The workers finished their work
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and exited the drywell. One of the crew members alarmed the whole
body frisker which indicated he had 5,000 dpm/100cm' on his face.
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An RPT in the decontamination room called the RPTs at the drywell
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hatch to inform them of the contamination so that they would begin
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investigatory surveys. The RPT sent to the jobsite discovered the
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flange had been removed and was laying on the grating without
Surveys results indicated 500,000 dpm/100cm' (8,333
being bag)ged.
Bq/100cm' on the flange which was cut, 250,000 dpm/100cm' (4,167
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Bq/100cm'
Bq/100cm') on the discharge pipe, and 70,000 dpm/100cm' (1,167
) on a nearby catch containment.
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Failure to notify RP prior to opening a process line is a
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violation of the Radiation Work Permit.
LaSalle Administrative
Procedure 100-22, " Radiation Work Permit Program", step F.2.e.4,
states that it is the responsibility of the individual worker to.
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comply with the requirements of the RWP and all associated
documents.
(Violation 50-373/93027-Old; 50-374/93027-Old)
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e.
Low Power Ranae Monitor (LPRM) Manioulation
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Another event reviewed by the inspectors was the inadvertent
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creation of a 100 rem / hour (1 Sv/hr) hot spot under the reactor
vessel due to fuel handlers performing work on an LPRM from the
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refuel floor on September 29, 1993.
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During the day shift'on September 29, 1993, a fuel handling crew
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was attempting to secure a modified lifting rig to an LPRM which
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had a broken plunger assembly and could not be removed. While
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attempting to secure the rig the feel handlers bumped the LPRM
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which prompted them to call the RPT at the drywell hatch to inform
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him that they might see a change in radiological conditions under
the vessel by the standpipe. The RPT assumed that the standpipe
being referred to was located in the sump area and did not
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immediately verify the dose rates in the area.
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About a half an hour later a crew of millwrights returned from
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lunch to resume control rod drive transfer cart track work under
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the reactor vessel. Within a few minutes one of the workers
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exited the area with his electronic dosimeter in alarm.
The RPTs
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present suspected a problem because the workers dose allowance
should have permitted him to work for the remainder of the shift
under the vessel (based on known radiological conditions). An RPT
noticed that the wireless remote dosimeters the workers were
wearing showed dose rate fields higher than anticipated in the
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area.
Another RPT surveyed the under vessel area and the LPRM
drain standpipe and noted a 100 rem /hr (1 Sv/hr) hot spot by the
drain tube stop valve.
RP immediately secured the drywell from
access and a meeting was held to discuss the occurrence and
establish a plan to flush the hot spot.
As a result of the event no workers received any exposure in
excess of administrative limits and the dose rate quickly fell off
about four inches from the hot spot source.
The root causes for
the event were fuel handlers not having the drain stop valve open
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prior to performing work; failure of the fuel handling crew to
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communicate their plans for work to the LPRM immediately prior to
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starting such activities (as opposed to once they realized they
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might have created a radiological exposure hazard); and a lack of
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system knowledge by the RPTs covering the under vessel drywell
work to fully comprehend the potential radiological problems which
could be created when LPRM work is being done.
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The failure to evaluate radiological hazards incident to workers
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is a violation of 10 CFR 20.201(b).
(Violation 50-373/93027-02;
50-374/93027-02)
As mentioned above the event indicated a potential weakness
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concerning RPT radiological systems knowledge.
Licensee actions
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to address this concern will be tracked as an Inspector Followup
Item (IFI 50-373/93027-03; 50-374/93027-03).
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Two violations of NRC requirements were identified. One inspection-
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followup-item regarding RPT radiological systems training was also
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identified. An overall stationwide weakness with respect to radioactive
material control was associated with one of the two violations
discussed.
4.
Licensee Actions Taken in Response to the September 7. 1993 Refuel Floor
Intake Event
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The inspectors reviewed the implementation of planned corrective actions
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that the station took in response to an event which occurred on the
refuel floor on. September 7,1993, and were presented to NRC management
during an exit meeting held on September 14, 1993.
This event is
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discussed in Inspection Report 50-374/93025 and is part of a recent
Escalated Enforcement action.
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The station assigned a radiation protection shift supervisor (RPSS) sole
responsibility of activities on the refuel floor.
This was not well
established during the event on September 7, 1993, and was a
contributing root cause which led to the creation of the airborne
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conditions and subsequent intakes of radioactive material.
The station received support from Dresden and Braidwood stations with.
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personnel to assist the RP department in providing supervision in the
plant and interfacing with the mechanical maintenance department.
The Health Physics Services Supervisor (HPSS) was holding one-on-one
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communication sessions with each of the RPTs to emphasize performance
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expectations.
These communications sessions were also conducted with
each RPSS and RP professional staff personnel.
A contributing factor which led to the September 7, 1993 event was an
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inattentiveness of the RPTs on the refuel floor to the alarming
conditions of the continuous air monitor on the refuel floor.
Apparently, the RPTs had become de-sensitized to the monitors response-
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due to erratic alarms and overall sporadic operability.
Licensee
improvements in the RPT continuing training to address expected actions
when the monitors alarm and enhancements to the maintenance of these
monitors to increase their reliability will be tracked as an Inspector
Followup Item (IFI 50-373/93027-04; 50-374/93027-04).
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A special team was assembled to review items discussed during the recent
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station stand down following the September 7, 1993 event and to review
general RP issues. A discussion of the results of this team's effort
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will be discussed in a later section (Section 6).
The site Engineering and Construction Manager was assigned as the
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Corrective Action Manager (CAM) for the duration of the refuel outage.
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This program was established to focus management activities in the plant
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to address radiation worker practices, housekeeping, procedural
compliance, and material condition. The program designated two
management individuals from various departments to spend two days in the
plant focusing on these corrective ac' ion issues. The managers reassign
their normal duties for those days so that they were free to be in the
plant the entire two days. The inspectors discussed the initial
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findings of the CAM program ano what plans the station had to effect
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repair of the ider.tified items. The CAM stated that a minor maintenance
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group would be formed to address the findings identified by the managers
which would allow for timely repairs of these items. After the outage
the licensee planned to establish a mechanism to continue this effort
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for long term results.
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The Station Quality Verification (SQV) department received assistance
from two other Commonwealth Edison stations with two QA inspectors who
were assigned full time duty to tour and monitor in-plant activities.
This effort increased SQVs field monitoring by about 2.5 times normal
review rates.
Overall, the corrective actions presented to NRC management during an
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exit ir'.crview held on September 14, 1993, were in place and being
implemented. However, based on the many radiological events reviawed
during this inspection period, a concern remains with respect to the
long term effectiveness of the above mentioned corrective actions.
No violations of NRC reqcirements were identified. One IFI was
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initiated to track licensee actionr to improve training on the use _and
maintenance of continuous air monitors.
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5.
Unit i Refuelina Outaae Activities (L2R05)
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The inspectors reviewed several work activities ongoing for the~ current
Unit 2 refueling outage during the inspection period.
The inspectors attended pre-job briefings and monitored _ work on.the
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reactor core isolation cooling system "63" valve and for control rod
drive changeout work.
In general the briefings were well executed and -
included good discussions of the work to be performed. During the.
actual work, the inspectors observed adequate job coverage of the'
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activities by the RPTs and the job foremen.
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The inspectors reviewed mesf work activities in the drywell which was
being supervised and controlled by the RPTs. Two Senior RPTs have been-
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upgraded as leads for coordination of all in field drywell activities.
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The inspectors discussed this mechanism with the RPTs and RP management
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and concluded that the change in drywell control. has had.no detrimental
effect on appropriate job coverage and control.
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The station had recorded a total dose of 657 person-rem (6.57 person-
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Sieverts) for-the year which is higher than the year-to-date goal of 629
person-rem (6.29 person-Sieverts). Most of this overage can be
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attributed to the Unit I SCRAM in September which required extensive
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r? circulation pump seal work.
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No violations of NRC requirements were identified.
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6.
Station Stand Down and Radiation Protection issues Team Results
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The inspectors reviewed the final report of the special team assembled
to review information gathered during a racent station stand down and-
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specific radiation protection issues which have been previously
identified by various sources.
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The team was comprised of nine individuals drawn-from each of the
various departments at the station from union and management ranks. The
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team held interviews and plant inspections throughout.the two week
period in which they gathered and assessed information relative to the
issues to be evaluated. The effort also included a day trip to the Quad -
Cities power plant to identify different approaches to addressing
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problems and compare Quad Cities day-to-day business with that of
LaSalle Station.
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At the conclusion of the team effort, more than fifty. action items were
identified and assigned to various departments with due dates. A
majority of the problems were assigned to.the radiation protection
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department. The items span RP procedures, personnel relation issues,
and overall interdepartmental perceptions of the RP department.
The
inspectors noted the effort as a good mechanism to focus on many
problems which have contributed to ongoing radiation worker performance
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prob 1 cms. However, the effectiveness of these findings have yet to be
determined. Therefore, an Inspection Followup Item was ir.itiated to
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monitor the progress on the resolution of the findings in a timely-
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fashion (IFI 50-373/93027-05; 50-374/93027-05).
No violations of NRC requirements were identified.
One IFI was
initiated to monitor the effectiveness of the Station Stand Down and
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Radiation Protection Issues Team and the station's timely response to
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their findings.
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7.
Source Term Reduction Proaram
The inspectors reviewed current station plans to address the continuing
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source term problem at the station.
Based on recommendations by.the
source term reduction manager and corporate personnel, the station has
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changed the condensate / polisher cation resin to low cross link macro
porous cation resin which is more effective in removing iron thus
lowering the total- feedwater' iron. content.
Initial results of the
effectiveness-of this resin was pending at the end of the inspection and
will be reviewed in future inspections.
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The station plans to begin depleted zinc injection in the Spring of 1994
in Unit 1.
While zinc injection is not a totally new technology, the
use of depleted zinc (less than 1 % Zn") is new within the industry.
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The set up for the temporary injection system will begin by the end of
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1993, with current plans for permanent installations during the Unit 1
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spring refueling outage (LIR06).
The station also plans to perform a chemical decontamination of the
recirculating system (RR) piping during L1R06. . This process will be
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performed by a vendor and should help to reduce RR dose rates for
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upcoming outages.
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Overall, the source term reduction program is still in the developmental
stages at the station and consider ale management attentian is required'_
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to effect long lasting changes to reduce the station's high dose rates.
No violations of NRC requirements were identified.
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8.
Station Tours
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During tours of the turbine and reacter buildings, the inspectors noted
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that radiological housekeeping within certain areas of the turbine
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building was poor.
Following the implementation of the CAM program, the
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housekeeping of the RCA improved.
However,_long term improvement on
radiological housekeeping is a continuing concern.
No violations of NRC requirements were identified.
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Exit Meetina
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The scope and findings of the inspection were discussed with licensee
representatives (Section 1) at the conclusion of the inspection on
October 29, 1993.
Licensee representatives did not identify any
documents or processes reviewed during the inspection as proprietary,
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Specific items discussed at the meeting were as follows:
The many examples of failure to follow radiation protection procedures.
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The concern with the evolution which led to the creation of a 100
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rem / hour (1 Sv/hr) hot _ spot during LPRM work, and the subsequent. failure
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to evaluate radiological hazards incidentLto workers.
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The IFI to monitor the implementation of the findings by the Station-
Stand Down and Radiation Protection Issues Team.
The Ifl to track the implementation of training on and proper
maintenance of CAMS.
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The IFI to evaluate RPT radiological systems training.
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Observations of the improvement in RCA housekeeping after the
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implementation of the CAM program.
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