ML20125B360

Insp Repts 50-373/85-14 & 50-374/85-14 on 850509-10,13-15 & 28.Violations Noted:Workers Wearing Personnel Film Badges on Trouser Pockets & Two Workers at Frisker Stations Did Not Survey Hands & Shoes

ML20125B360
Person / Time
Site:	LaSalle
Issue date:	06/06/1985
From:	Greger L, Miller D, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20125B314	List: ML20125B312 ML20125B334 ML20125B360
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-373-85-14, 50-374-85-14, NUDOCS 8506110386
Download: ML20125B360 (9)

See also: IR 05000373/1985014

Text

,

. .

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/85014(DRSS); 50-374/85014(DRSS)

~ Docket Nos.-50-373; 50-374 Licenses No. NPF-11; NPF-18

-Licensee: Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

~

Facility Name: .LaSalle County Station, Units 1 and 2

Inspection At: LaSalle County Station, Marseilles, IL

Inspection Conducted: May 9-10, 13-15 and 28, 1985

Inspectors: .D. E. Mi ler Y'h -

6/6/8f

Date

R. . A. ul d[6/ds

Date

Approved By: - L. R. rege , Chief

Facilities Radiation Protection

4/4/8

Date

Section

Inspection Summary

Inspection on May 9-10, 13-15 and 28, 1985 (Reports No. 50-373/84014(DRSS);

50-374/84014(ORSS)

Areas Inspected: Routine unannounced inspection of the operational radiation

protection program including organization and staffing, ALARA, control of

radioactive materials and contamination'and radiation occurrence reports.

Also reviewed were past. inspection findings, licensee event reports, and certain

! .NUREG-0737 task action items. The inspection involved 80 inspector-hours on site

~

i by two NRC inspectors.

'

Resultsi No violations were identified in six of the seven areas inspected.

One violation'was identified.in'one area (failure to follow procedures -

Section 7).

hN373PDR

1

<

--,

. .

DETAILS

1.- Persons Contacted

• D. Adam, Lead Health Physics Field Services Engineer, CECO

• L. Aldrich, Lead Health Physicist

• R. Bare, Quality Assurance Inspector .

• D. Berkman, Assistant Superintendent, Technical Services

• R. Bishop, Superintendent, Services

W. DeLise, Engineer, Sargent and Lundy Engineers

• D. Hieggelke, ALARA Coordinator

• F. Lawless, Rad / Chem Supervisor

• J. Lewis, Health Physics Coordinator

W. Luett, Group Leader, Technical Staff Engineering

J. Schuster, Chemist

B. Wong, SNED, CECO

T. Bjorgen, NRC Resident Inspector

The inspectors also contacted several rad / chem foremen, engineering

assistants, and technicians.

• Denotes those present at the exit meeting.

2. General

This inspection, which began at 9:00 a.m. on May 9, 1985, was conducted

to examine the licensee's operational health physics program. Also

reviewed were past inspection findings, licensee event reports, and .

certain NUREG-0737 task action items. One violation concerning failure

to follow procedures was identified.

3. Licensee Action on Previous Inspection Findings

(Closed) Open Item (373/83033-01; 374/83032-01): Concerning high background

on liquid radwaste effluent monitor. The monitor is being_ relocated to the

turbine building from its previous remote site; the background radiation is

less at the new location.

(Closed) Violation (373/84031-03; 374/84038-03): Concerning inadequate

alarm / trip setpoint on the liquid radwaste effluent monitor, the inspector

verified that the corrective actions listed in the licensee's response dated

January 25, 1985, were implemented; the corrective actions appear adequate.

(Closed) Open Item (373/84021-02; 374/84027-02): Concerning a compliance

study for portions of NUREG-0737 task item II.F.1.2, the study has been

performed; the results are discussed in Section 10.

(Closed) Open Item (373/84021-01; 374/84027-01): Concerning frequency of

contamination incidents. The licensee's corrective actions are discussed

in Section 6.

2

. .,

(Closed) Open Item (373/84031-04; 374/84038-04): Concerning training /

supervision of stationmen. The supervisory staff has been increased to

three;.most stationmen have since completed their designated training;

and special training sessions were presented to stationmen by the ALARA

Coordinator.

4. ' Organization and Staffing

Since reported in Inspection Reports No. 50-373/84031; 50-374/84038, the

following organizational changes have been made or are planned.

l

. Two plant Health Physicists terminated employment with CECO.

. A recent graduate with a B.S. in Environmental Health

was hired to fill one of the vacated Health Physicist positions; he

began employment in January 1985.

. A second.recent graduate is to begin employment as a health

physicist.during June 1985.

There are no specific ANSI N18.1-1971 qualification requirements for the

health physicist position.

The two new degreed professional health physicists, who work for the Lead

Health Physicist, have less than one year each practical experience at

power reactors. According to licensee personnel, this lack of experience

has negatively impacted the direct surveillance of work activities in

controlled areas by the management / professional staff and has required _

other health physics supervisors / professionals to assist in the workload,

thereby reducing time available to perform their own functions. (See

Section 7 for further information.) The shortage of experienced health

physics professionals at LaSalle County Station has necessitated that

pre-procurement testing of portal monitor equipment be performed at

another CECO station.

Since August 1983, three health physicists have terminated employment and -

one was promoted to the ALARA Coordinator position. The lack of health

physics staff stability appears to have impacted negatively on the

licensee's radiation protection program. This matter was discussed at

the exit meeting.

_

No violations or deviations were identified.

5. - ALARA

The inspectors reviewed the licensee's program for maintaining occupational

exposures ALARA, including: changes in ALARA policy and procedures; worker

awareness and involvement in the ALARA program; establishment of goals and

objectives, and effectiveness in meeting them. Also reviewed were manage-

ment techniques used to implement the program and experience concerning

self-identification and correction of program implementation weaknesses.

3

F 1

1

'

.

I

!

The ALARA program establishes goals and sets measured standards for use by

ALARA management. Station goals for 1985 include: setting an adminis-

trative limit of five rems for any individual; improving station awareness

of ALARA; saving approximately 150 person-rems through ALARA activities;

and maintaining annual radiation exposures to approximately 650 person-

rems (this includes two outages during the year). ALARA activities to

save personal exposure include use of temporary shielding, flushing of

hot lines, use of extendable tools and improvement of worker knowledge of

ALARA through mock-up training and pre-job briefings. In addition, the

licensee has initiated a station contamination control program and

continues to use the Radiation Evaluation Program (REP). Radiation-

Chemistry Department goals for 1985 include: reduction and maintenance

of radiologically contaminated general access areas; reducing the number

of personal contamination events; maintaining Department individual radiation

exposures below 4 rems, and increasing management time in the plant.

The licensee has a Radiation Evaluation Program (REP) which tracks radia-

tion dose for the station, individual tasks, work grou

This program uses the dose accountability (white card)ps and which

system individuals.

results

in more accurate and thorough dose tracking and aids in the retrieval of

ALARA records including radiation exposure and RWP data for individual

work tasks performed.

Overall trends are recorded for individual and collective doses, number of

persons exceeding regulatory standards, internal and external contamination

instances, extent of contaminated areas, and the extent of low level radio-

active waste reduction. ALARA is discussed in the NGET and retraining

programs. The ALARA coordinator intends to review the NGET program to

determine if sufficient emphasis is given to ALARA. The licensee currently

,

has no plans to give additional training to RCT's and there are no

immediate plans to develop a formal ALARA program for workers.

The ALARA coordinator is involved in the planning and assessment of work

as outlined in Procedure LRP-1300-1 and LRP-1160-4. The use of the REP

system fn conjunction with the ALARA review is one of the major ways the

ALARA coordinator identifies and corrects ALARA concerns. In addition

to the formal audits of the radiation protection program conducted by the

QA department, the radiation protection staff and the ALARA coordinator

conduct reviews to identify problems which may involve ALARA.

No violations or deviations were identified.

6. Control of Radioactive Materials and Contamination

The inspectors reviewed the licensee's program for control of radioactive

materials and contamination, including: adequacy of supply, maintenance,

and calibration of contamination survey and monitoring equipment; effective-

ness of survey methods, practices, equipment, and procedures; adequacy of

review and dissemination of survey data; and effectiveness of methods of

control of radioactive and contaminated materials.

The licensee has a program for identifying, documenting and tracking

personal contamination events. Reports to management detailing the total

number of contamination events and whether the contamination was on clothing,

4

. .

skin or both are listed. Because of the number of personal contamination

events and repeat violations found as a result of this program, the

licensee increased management attention and has taken the following actions

to correct the problem: (1) Department Heads will personally. interview all

persons who had more than one contamination event during the period May 1984

through February 1985, and beginning April 1985 each contamination event

will be investigated by the Department Head. The purpose of the meeting

and investigation is to identify the cause of the contamination and the

steps taken to prevent recurrence, and to emphasize the importance of

following radiation protection requirements. In addition, each Department

Head was instructed that in the case of procedural violations, discipline

should be considered. These investigations are documented and status

reports discussing the investigation, cause of the contamination, and

corrective actions are sent to the appropriate Assistant Superintendent

with copies to the Radiation Chemistry Supervisor, Superintendents, and

Station Manager. (2) Procedure LRP-1410-1 " Protective Clothing" and

LRP-1410-2 " Minimal Protective Clothing" are in the process of being

revised to require two pairs of gloves instead of one as the minimum hand

protection when entering a contaminated area.

Some of the major causes of personnel contamination were equipment malfunction

which resulted in floor contamination, inadequate protective clothing

prescribed for various jobs, and improper removal of respiratory protective

equipment and/or protective clothing.

The licensee has initiated a radiological housekeeping and contamination

control program as part of the station ALARA Program. The purpose of the

program is to provide radiological support for housekeeping, maintaining

general access areas free of contamination, and reducing the square

footage in the plant designated and controlled as contamination areas

(reclamation) and maintaining those areas clean. The program is managed

by the ALARA coordinator, four stationmen and one RCT, (who rotates

weekly). A program to trend the effectiveness of the contamination

control program has been developed and implemented.

During the period January 1984 through January 1985, the total plant

area which is controlled as contaminated rose from 171,00 fte to

268,000 fta; and from January through April 1985, the total declined from

268,000 fta to 230,000 fta. Of the 230,000 ft2, 20 per cent was greater

than 22,000 dpm/cm2 Most of the contaminated areas are in the turbine

and reactor buildings (85 per cent). The licensee indicated that some of

the areas are controlled because of the potential for contamination while

others, which are only slightly contaminated, are not reclaimed because the

decontamination effort may not be worth the dose expenditure. To date, it

appears the licensee's major effort in contamination control has been

directed to general area decontamination and not in actively pursuing a

reclamation program of reducing total contaminated areas. This matter was

discussed at the exit meeting.

5

.. .-

7. Surveillance-Plant Tours

The following problems were identified during tours of the plant:

(1)'Several persons were wearing personal film badges on the hip section

of their trousers and on their trouser pockets. Failure to wear personal

dosimeters near each other on the front part of the body at or above waist

-level is. considered a violation of the licensee's procedures (LRP-1250-3).

These procedures are intended to ensure representativeness of personal

' dosimeters. (373/85014-01a; 374/85014-01a)- (2) On two occasions, workers

.who had removed their protective clothing in accordance with the step-off

. pad instructions, exited from the step-off pad area without first performing

a personal contamination survey. The failure to make a personal contamination

survey (whole body frisk) after exiting from a step-off pad is a violation

of the_ licensee's procedures (LRP-1410-1 and LRP 1480-4). (373/85014-01b;

374/85014-01b). Related to this violation are an inspector's findings

during a previous inspection in which the inspector noted that most friskers

at step-off pads (SOPS) in the Unit I reactor building were switched to the

'" times 10" scale because of high background levels, which diminishes frisker

sensitivity. The Ifcensee stated, at that time, that methods of providing

shielding were being investigated. During this inspection, the inspectors

.found no shielded friskers; in fact, the friskers and been removed and an

' instructional sign was placed at some of the SOPS directing people to

survey at friskers located in another area. These friskers were frequently

several floors distant from the SOP. (373/84031-01; 374/84038-01) (3) On

two occasions, workers were observed exiting frisking stations without

frisking.their hands and only superficially frisking their shoes. The

failure to survey their hands and to adequately frisk their shoes is a

violation of the licensee's procedures (LRP-1480-4). The licensee has

been aware of. poor personal frisking habits, and as a result, the station

manager issued a memo to all workers requesting strict adherence to procedural

requirements, and instructed supervisors to enforce the requirements. Based

on the above violation, and the inspectors' observations, it appears this

corrective action has not been effective. It further appears that the

,

continuation of procedural adherence problems is indicative of management

weakness in aggressively pursuing corrective actions for this problem.

(373/84014-01c; 374/85014-01c) These violations were discussed at the exit

interview.

The-following observations were made during plant tours: (1) RCT's were

smearing and surveying rad waste barrels on the dock in the rad waste

building. Although the facility has an installed shielded location to

perform survey functions, it is not being used because the licensee has

not installed a remote readout monitoring system for which the system was

desigwd. The current method of surveying rad-waste barrels for shipment

is not consistent with ALARA. The failure to obtain and install the

correct monitors-indicates possible management weaknesses in this area.

This matter was discussed at the exit interview. (2) Film badge racks

for ifcensee, contractor and security personnel are located in three

different areas. Film badges are not issued with the workers security

badge in the gate house. The practice of not issuing film badges in the

gate house has caused Ceco stations and other utilities problems concerning

employee misuse of the film badge. This matter was discussed at the exit

6

,

. .

!

interview. (3) Two Constant Air Monitors (CAN's) located on the refueling

floor were inoperable. The licensee indicated they were aware of this

condition; and work orders had been issued for their repair. (4) Other

than the two portal monitors (IRT's) located in the guardhouse, the licensee

currently does not use portal monitors at locations within the controlled

area to supplement the portable frisking stations for personnel monitoring.

This matter was discussed at the exit interview. (5) At most frisker

stations, instructions are posted that require persons who have detected

personnel contamination to go to the nearest telephone and notify the

Rad / Chem department. However, protective shoe covers and gloves to minimize

the potential spread of contamination are not provided at the frisker

station. This matter was discussed at the exit meeting.

8. Radiation Occurrence Reports

Radiation Occurrence Reports (R0Rs) for the period January through April

1985 were reviewed. The licensee continues to trend occurrences to

determine repetitive violations and violators. Occurrence report

summaries are issued monthly. No obvious indications of repeat

violators was noted; however, repeat violations of high radiation area

controls apparently remains a problem. A CECO corporate task force has

been reviewing high radiation area controls at all CECO plants. The task

force study is expected to be completed by mid-1985, including

recommendations for improving high radiation area controls.

The inspectors noted that followup of RORs is being given greater

management attention and investigation. It appears that management

support for the R0R system has been strengthened. The inspectors noted

that a technical staff engineer who violated radiation protection

procedures / practices was assigned to radiation protection surveillance

duties for one week, including one day without pay, to increase his

awareness and understanding of the intent of radiation protection

procedures and practices. However, based on inspector observations

discussed in Section 7, it appears that either the licensee is not

adequately identifying such problems or that RORs are not being written

for identified problems. This matter was discussed with licensee

personnel, and at the exit meeting.

No violations or deviations were identified.

9. Licensee Event Reports Followup

Through direct observation, discussions with licensee personnel, and

review of records, the following event reports were reviewed to determine

that reportability requirements were fulfilled, immediate corrective

action was accomplished, and corrective action to prevent recurrence had

been taken in accordance with technical specifications.

'

(Closed) 373/84086-00. Nonconservative liquid effluent monitor

setpoint. This item was identified during licensee review of violation

373/84031-03; 374/84038-03. The corrective actions were presented in the

,

licensee's response to the violation (Section 3).

7

, . - -- - - -- - - - . -- .

.

1. 3 ,n

t -

(Closed) 373/85031-00.. Nonconservative liquid effluent monitor ,

setpoint.- This incident resulted from failure of the equipment operator

to properly read the chart' recorder setpoint. The operator was

instructed in the proper method, and additional training has been

included in.the Equipment Attendant Continuing Training Program.

No. violations.or deviations were identified.

10. Followup-of Postimplementation Review of NUREG-0737 Task Item II.F.1.2 i

As described in Inspection Reports No. 50-373/84021; 50-374/84027,  !

the inspectors had discussed the need .to perform necessary studies to show

compliance with certain Task Item II.F.1.2 matters. The study results

are discussed below.

Science Applications International Corpocation evaluated the main

ventilation stack and the' standby. gas treatment system (SGTS) effluent

' sampling lines for transmission of radiofodines and particulates. They

concluded that:

Iodine transmission (main ventilation stack) to the nornal sampler

-would be approximately 50 pe'/ cent for elemental fodine and nearly

100 percent for other gaseous species at two hours after an activity

. inc rease. Equilibrium trar.smission for elemental fodine would occur

at about 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />; .the elamental fodine transmission would then be

about 85 percent. ;The high range segment of the stack sample line.

shows good transmission, even for elemental iodine at two hours

following an increase.

Iodine transmission to the SGTS normal range sampler is similar to

the main ventilation stack normal range sampler. However, r

transmission of elemental . iodine to the SGTS high activity range

sampler. would be very low due to the low flow rate and long sample

lines; transmission of other gaseous species would be adequate.

According to the study, addition of heat-tracing to the sample Ifnes

would not appreciably increase transmission of elemental iodine.

. Sargent and Lundy. Engineers evaluated the source terms used for the

iodine and particulate high range samplers, and evaluated compliance with

GDC-19. requirements. The study indicted that proper source terms were

used, and that although not needed to meet specific GDC-19 requirements,

addition of one foot of concrete shadow shielding near a portion of the

Unit I reactor building air supply ductwork would reduce the dose during

sample collection by 50 mrem.

During discussions, the licensee stated that change requests have been

written to alter the SGTS sampling lines to increase elemental iodine

transmission, and that additional shielding would be provided for a

r portion of Lthe Unit I reactor building air supply ductwork. These

l matters will be further reviewed during a future inspection.

,

l

(373/85014-02;'374/85014-02)

l

j No violations were identified.

!

i

8

-, ._ _ _ _ _ _ _ . _ _ _ _ _.___ _ . . - . _ _ . _ _ . _ _ _

w

z,~ ,.s

I

ill. -Exit Meetina

'

' "

' The inspectors _ met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on May 15, 1985; The inspectors

summarized the scope and findings of the inspection, including the

'

' violation-(Section 7). The-inspectors also discussed the_likely infor-

mation content ~of.the inspection report with regard to documents or

.p ocesses reviewed by,the inspectors during the inspection. The licensee

did not identify'.any such documents / processes. as proprietary. In response

.to certain items discussed by the inspectors, the. licensee:

s

J a. Acknowledged the inspectors' comment about apparent lack of stability

of the health physics staff, and stated they are actively trying to

- hire more health physicists. (Section 4)

b.  ; Stated that the station is investigating what additional resources,

-if any, will be employed for the reclamation of contaminated areas.

.(Section 6)

'c. Stated that one of maintenance department ALARA goal _s for 1985 is

to install a remote readout monitoring system-for radwaste barrels.

(Section 7)

d. . Stated that TLDs (along with security badges) will be maintained at

the security facility after January 1986. Alternate control methods

may be employed for contractors. (Section 7)

e. Stated that additional portal monitors, for controlled area use,

will be purchased upon completion of Ceco corporate vendor

evaluation.'(Section 7)

f. Stated that SGTS sampling lines would be altered to increase iodine

'

transmission, and a shadow shielding wall would be provided for a

portion of the Unit l' reactor building to decrease doses during post

accident sample collection. (Section 10).

g. Stated that they no longer intend to report high radiation area

technical specification violations as licensee event reports. Instead,

such violations will be documented in radiation occurrence reports.

The inspectors agreed with this practice.

h. Stated that' protective shoe covers and gloves will be provided at

all frisker stations. (Section 7)

12. Management Meeting

During a management meeting with Ceco personnel on May 28, 1985, the

licensee was informed that their performance in the radiation protection

'

area was worsening. This evaluation was based on observations during

this and previous inspections concerning continuing procedural adherence

. problems, apparent management weaknesses, and radiation protection staff

losses. The licensee stated that they were aware of several of these.

problems and were evaluating appropriate corrective action.

9-