ML20064K464
| ML20064K464 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 11/12/1980 |
| From: | Abel J COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20064K461 | List: |
| References | |
| NUDOCS 8101090810 | |
| Download: ML20064K464 (10) | |
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[? ) ons First Nabonal Ptsra. Chicago. Ilhnois C $ %ddress Reply to Post Oihce 007 767 Chicago, Illmois 60690 Novemt>e r 12, 1960 Mr. James G. Keppler, Director Directorate of Inspection and Enforcement - deolon III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Quad Cities Station Units 1 and 2 Res n12 E%(80-ynd 50-265/80-22 pection Report Nos.
254 NRC Docket Nos. 50-254/265 Reference (a):
J. G. Keppler letter to J. J. O'Connor dated October 21, 1980
Dear Mr. Keppler:
Reference (a) transmitted the results of the special tea appraisal performed on May 5 through 16, 1980 of the Quac Cities Nuclear Power Station Units 1 and 2 health physics program.
Reference (a) indicated that six (6) signi ficant weeknesses (Appendix A) and two (2) apparent items o f noncompliance ( Appenoix B) were identified during this appraisal.
Attachment A provices our response to the two items of noncompliance and Attachment 8 addresses the six significant I
appraisal findings.
Please audress any questions concerning this matter, to this Very truly yours, J. S. Abel Director of Nuclear Licensing Attachment cc:
RIII Inspector, Quad Cities WOY ! 4 DI 8065A 8 2 010901:t6%
I D/R AD-K NRC DOCKET NO. 50-254 50-265
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ATTAC!! MENT A COM! M EALTH EDISON ATTACHMENT RESPONSE TO NOTICE OF VIOLATION i
The apparent items of non-compliance identified in Appendix B of the NRC Ict ter da ted October 21, 1980, are responded to in the following paragraphs:
1.
10 CFR 20.203(c)(2) lists three alternative requirements for control of access to high radiation areas.
Contrary to these requirements:
A.
An unposted, unbarricaded, and unchserved high radiation area existed near the sample hood on the 647' level of Unit 2 Reactor Building for several days (May 5-14) during the.;ppraisal.
B.
On May 5,1930, a ladder temporarily lashed in place gave ready access to a posted high radiation area above the Unit 2 CRD accumulators.
CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED The high radiation area on the 647' level of the Unit 2 Reactor Building was caused by deposition of particulate matter, in an overhead horizontal run of drain piping from the Unit 2 dryer / separator storage pool, during the previous Unit 2 refueling outage.
Several attempts were made to flush the contaminated material from this piping run, but the attempts were unsucccss ful.
Therefore, lead blankets were added to the piping to reduce the area dose rates and a' fence was erected and posted as a high radiation area to prevent access to the area below the pipe.
Subsequently, decontamination connections were added to that pipe run, and the line was successfully flushed.
The ladder by the Unit 2 CRD accumulators was removed and the responsible department was informed of the situation. The ladder had been removed from the south Unit 2 torus equipment hatch to prevent access to that high radiation area when work was not in progress, but its temporary storage location inadvertantly created an unauthorized access to the upper level of the CRD accunulators.
CORRECTIVE ACTION TO BE TAKEN TO AVOID WRTHER NON-COMPLIANCE The dryer / separator storage pool drain piping location will be added to those locations su rveyed during startup following a refueling outage.
A i
revision to procedure QRS 300-S4, " General Reactor Building Surveillance for Startup" hau been submitted and should be implemented prior to the Unit 1 startup following the current refueling outage.
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The placement of the ladder by the CKD accumulators is considered a unique occurrence in that the personnel involved were aware of the need to control ac' cess to high radiation areas and f t was that awa reness th at precipitated their actions of re::oving the ladder frm it-oririnal location.
C m oquently, no further correct ive act ion la deened necessary.
DATE WEN Fl!Lt. COMPLI ANCE k'ILL BE AOf f EVFD:
Full conpliance has been achieved at this t ime.
4 2
Technical Specification 6.2.B. requires adherence to station P.adiation Control Procedures.
The following instances of f ailure to neet this requirement were identified during the appraisal.
A.
Station procedures QRS 700-2 and qRS 700-3, respect ively, require quarterly calibration of "CP" and Geiger-Mueller (G:!) exposure rate instruments.
Contrary to the above, on May 12, 1980, Victoreen 740F (CP) S/N q
109 and Eberline PRM-4 (CM) S/N 2216 located in Energency Bo:e No. I were found to last been calibrated on October 26, 1979, approxima tely six months earlier.
B.
Station procedure QRP 100-1, Section 26, specifies a limit of 3000 counts per minute on laundered protective clothing made available for reuse.
Contrary to the above, several garments taken froc reissue hins and monitored with the laundry monitor during the appraisal exceeded this limit.
CORRECTIVE ACTION TAKEN AND RESULTS AC!!IEVED:
On May 13, 1980, the uncalibrated ins truments were removed from the eme rgency box. Victorcen 740 F (CP) S/N 109 was calibrated and returned to the emergency bax.
Eberline PRM-4 (CM) S/N 2216 was removed fron service and Eberline PRM-4 (CM) S/N 2333, calibrated on April 10, 1930, was placed in the emergency box.
Subsequent to the identification of the protective clothing exceeding the specified limit, the current inventory of clothing ready for reuse was re-surveyed, and those articles with excessive contanination were removed.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER NONCOMPLIANCE:
A monthly inventory check and calibration review will be initiated for "CP" and Geiger-Mueller (GM) exposure rate instruments.
This review will be conducted by radiation protection management and will be part of the Technical Staf f Support Surveillance program, s
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1 b
A wwkly spot-check of protcctive clothing ready for reune will be irrplcmented to rnnitor tleir conformance with the station's Radiation Control Prccedures.
A change to the Ibdiation Chm.istry Technicians chif t rcutine checklict will be pado to docurent this ourveillance. Acklitionally, the statiorren will be re-instructcd in the proper uce of the laundry monitor.
DATE h11C7 IULL CGIPLINCE h'ILL BE ACilILMD:
Revisions to the Technical Staff Support Surveillance prcqram ar.d the PCT chif t checklist, will be coupleted by Dccc:rber 1,1980.
Stationmn retraining on the use of the laury.iry nonitor will be cocpleted by January 15, 1981.
l'ull compliance will t'e achiercd at that time. s 4
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ATTAO!'ff!Tr B COM".ONiiE ALTil r/JISON AT TA01:L:N r RESPON5E TO SIC';1FICror iPM:/.ISAL FINDINGS Based on the llealth Physics Appraisal perf orm. d on !!ay 5-16. 1980, the following items. appeared to require corrective a ct io ns. The steps which have been taken or which will be taken and a schedule of ca1pletion of those act ions are included below.
1.
Training:
A.
By failing to establish the relationship between low-level rad ia t ion ef fects and the various health physics practices for radiation and contamination cont rol, insuf ficient no tivation to follow these procedures is provided in general employee training.
A contributing factor appears to be overemphasis of acute radiation ef fect s relative to low-level effects. Related weaknesses appear to exist in protective clothing training f or contractors and in contamination control training for maintenance personnel.
B.
Recent (1979) Radiation Chemistry Technician (RCT) training was allowed to slip to three days for some RCT's. indicating insufficient priority given to this program.
Retraining also should caphasize be tter understanding of basic health physics concepts and practices.
C.
RCI's were not trained in interim emergency procedures, because these procedures would be performed by Radiation Chemistry (R/C) management during accident c on?.i t ions.
The assumption thtt 3/C management would always he able to respond promptly may be unrealistic.
Response
A.
The NCET course will be revised to include emphasis on low-level radiation ef fects and on proper contamination control practices.
Additional naterial will also be presented on protective clothing training for contractors, such as a video-taped demonstration.
A special training session will be held with maintenance personnel involving proper contamination control practices.
These actions should be completed by January 15, 1981. Also, the station's annual employee retraining program will be revised to include
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material on proper contamination control practices prior to its implementation during 1981.
B.
The;1980 RCT retraining consisted of five consecutive days including one day for first aid training. This does not include the time spent on fire brigade training, fire fighting school, annual retraining, CSEP training and drills, and training on specific laboratory and counting rotn equipment.
The course mateerial used during retraining included the BICR III report and the draf t regulatory guide referred to by the appraisal team.
Approximately fourteen hours of retraining were dedicated to basic health physics concepts.
Additional subj ct
material included training on post accident sanpling, including a
' walk-through of the procedures and on estinating releases during an accident.
C.
The RCTSs have been trained on the int e rim energency procedures during their 1930 retraining sessions.
m.
2.
Ty.nnsu re cont rol and ALARA A,
Inadequa te control eier respi rctor issuance on the '-ack.chif ts pe rmits unauthorized respirator uc.c.
Fa ilu re to require their return and the entering.of duration-of-wear inf o rma t ion undernines caposu re cont rol based on MPC-hours.
B.
Approxi:.ately 5000 man-rens are projected for the year 1980.
Significant dose savings should be achievable by a strong, conprehensive ALARA pr og ram.
Response
A.
The control over respirator use has been significantly L, proved since the Health Physics Appraisal was conducted.
A new systen of mask issue and return has been ins tituted whien requires the use of NCET cards. The NCET cards are coded with the cedical approval date, the mask fit. results, and the level of respiratory equipment training.
Hence, when a mask is issued, the RCT can ensure that all requirenents are met at a glance.
The individual is required to leave his NCET card when he receives his respirator, and it is given back when he retu rns the' respirator.and comple tes the respirator log. Access to 1
the mask issue roon has' been restricted by installation of a radiation chemistry department lock on the door.
B.
Scientific Applications, Inc. is currently developing a formal ALARA progran for use at all of the Commonwealth Edison nuclear stations.
The implementation of the formal progran is expected during early 1981.
In the interim, an ALARA coordinator has been designated to enhance the station's informal ALARA ef forts.
3.
Aa. cess Cont rols High radiation area (HRA) access controls do not ensure that entries are made with adequate knowledge of dose rate or that everlong entries will be promptly recognized. Controls on contractor work in the torus may be insufficiert to prevent unexpected exposures, because of field variations between different areas of this extensive high r.uiiation area.
Response
i We belf eve that access controls for high radaition areas (HRA's) do in fact provide suf ficient assurance that HRA entries are cade with adequate knowledge of dose rates for the following reasons:
l A.
Quad-Cities Administrative procedures QAp 1120-5, " Entering a Locked I
High Radiation Area With A Timekeeper" and QAp 1120-6, " Entering a
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Locked High Radiation Area '.;ithout A Tinekeeper", require that rad i a tion protection be natified prior to entry in order to obtata all availabic inf orma tion pe rtaining to dose rates, dosime try required, and other related requirements.
Entries into HRA's for purposes of perf oming a work function, such as B.
pump repair or m.odification work, routinely require prior radiation protection survey information, and the work will be performed either with a timekeeper present or under the specifications of a special wo rk pe rmit wh ich explicitly defines the radiological conditions unde r which work will be performed.
Entries into HRA's by personnel such as operators and operating shif t C.
forcaen are extremely brief in nature and prior surveys before cach These individuals are entry to any area are not de(ned necessary.
instructed in their respective training and re-training programs of the importance of re/tewing the latest su rvey inf orma tion availabic in the Radiation Protection of fice prior to initiating rounds.
Licensed senior reactor operators are also trained in the use of survey equipment and may use that equipment when entering HRA's.
Additionally, electronic dosimeters have been made available to operators to use on their high radiation area inspections along with their self-reading dosimeters.
k'c recognize the need to take further steps in ensuring that overlong entries into URA's will be promptly recognized. Consequently, a revision to station procedures will be made so that the NSO must verif y, at the completion of each shif t, that all workers who have been alloyed access to any HRA during that shif t, without the use of a timekeeper or safety nan, have either checked out or will be continuing work in that area.
The revision to station procedures should be implemented by Decec.ber 15, 1930. On an interim basis, a management representative will periodically reivew the R-Key log for completeness of infornation until improvement is noted.
Controls over contractor work in the torus area have been improved by locking the access to the Reactor Building Equipment Drain Tank area.
Additionally, radiation area signs with pockets for adding supplemental infornation have been obtained are are being used in the torus arca to better define the dif ferent working conditions.
4.
Contamination Controis i
Several weaknesses were noted with respect to contamination cont rol.
I A.
Movenent of contaminated tools and equipment from the controlled area for maintenance work or surveys.
B.
Reduced surveillance in the maintenance shop and laundry.
Questionable protective clothing requirements in portions of radwaste.
C.
D.
Proliferation and prolonged duration of temporary d. contanination sites.
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E.
Widespread occurrence of contaminated trash.
F.. Inappropriate contamination control practices in the laundry and elsewh e re.
Re s pons.a :
4, A permanent area will be designated in the maintenance shop for the purpose of performing radiation surveys on contaminated too!s and equip:ent. This area should be empleted by Jamnrv 1, 1Hil.
The additional t rait.ing given te the mitntenance persennel as described in the response to i te,1.a. o f At tachnent E should resolve the probler.s currently identified pertaining to movenent nf contaninated tools and equipment.
B.
The station has re-established routine surveys in the laundry and maintenance shop areas at the specified frequencies.
C.
We believe that the RCT on a job is the best individual for de termining the proper protective clothing requirements.
Our experience to date has not demonstrated the need to require full SRP clothing for the type of work referred to by the appraisal team.
It should be noted that' the time saved by the individuals working in the radusste area not having to don full protective clothing results in an exposure savings that in our judgement of fsets any small risk of contamination.
This ALARA ef fort is magnified when considering the number of dif ferent areas the operators must access during barrel handling operations and the crews rotation between dif ferent task assignments.
D.
In order to better control the use of temporary decontamination sites, the following actions have been or will be taken:
(1) The onsite cognizant CECO personnel responsible for contractor work have been informed of the need to obtain prior approval from radiation protection supervision before establishing a temporary decon area.
(2) A health physics review of the area being set up will be conducted.
(3) A periodic inspection of the decon sites in use will be instituted by Decenbe r 15, 1980.
(4) A major decontaminatien area will be designated following refueling outages to facilitate the large amount of contaminated tools and equipment generated during such outages, if needed.
E.
The observation of widespread contaminated trash during the appraisal was a result of two major factors.
The first was the conclusion of a major refueling outage which had taken over four months to complete and which had included nany major plant modifications.
The second factor was the closing of radwaste disposal sites for several nanths in 1979 prior to the refueling outage. The backlog of radwaste drinns made the processing of an even heavier load of contaminated trash during the refueling outage an alnost bnpossible task.
Ef forts by the operating department helped improve the situation prior to the current _
O refueling outage.
Addi tional cont ractor labor f s being uned during this outage to aur,nent the st itionnan work force to allow better processing of DAW and laundry.
Conseque ntly, the amount of contaminated trash is not an extensive as it had been previously.
F.
Improved ' training on contamination cont rol practices for maintenance personnel was discussed in our response to item 1.a. of Attachment B.
-. Additional training will be given to stationnen pertaining to the proper use of the laundry conitor and proper contanination control practices. This training should be ca,pleted by January 15, 1981.
5.
Instrunents A.
There is an insufficient supply of portable su rvey ins truments with adequate range (1000 R/hr or greater) for use during a serious accident.
There is also inadequate assu rance of ready availability of portable survey instruments, owing to lach of secure storage space and weak ins t rtraent ac count abili ty.
B.
Area monitor charts are not legible enough to permit.tfter-the-fact unraveling of an event with any confidence. Date and time annotations ende by operator and reviewers are also frequently deficient.
C.
Excessive chimney sample line fittings makes representative sampling ques tionab le.
It also indicates piping changes made without knowled ge ab le review and approval.
Response
A.
Additional high range portable su rvey instruments will be purchased.
The RCT's have been instructed to store the instrunents in the designated storage area when not using them and not to keep them in their lockers.
Improved instrument accountability will be achieved as described in our response to item 2 in At tachment A.
A secure storage space for instruments will be provided when the health physics facilities are moved to the new service building addition in the fall of 1981.
B.
Stone and Webster, Inc., is currently reviewing the process radiation instrumentation at Quad-Cities Station, including the area radiation monitoring system.
Their recomnendations will be reviewed by the station and a course of corrective action will be developed.
Co rrect ive actions should bc initialed by January 1,1931.
Operating personnel were informed at the time of the appraisal to make a nark on the charts corresponding to midnight, in addition to stamping the date on the charts.
The need to ma r' and date charts was re-emphasized.
C.
The addition of several fittings to the.himney sample line was apparently done to facilitate removal of the charcoal and particulate filter holder which is in close proximity to the cample house west wall. The RCT's have been inforned that this change was 1.. proper and that it could have affected isokinetic sanpling. The fittings were renoved shortly af ter their disc ove ry.
Addi tionall y, a consult. int, Quad re..,
has been contracted to review the isokinetic sampling capabilities of the existing sample rs..