ML20125B360
| 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: |
| 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
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-373/85014(DRSS); 50-374/85014(DRSS)
~ Docket Nos.-50-373; 50-374
-Licensee:
Commonwealth Edison Company
Post Office Box 767
Chicago, IL 60690
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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
Y'h
Inspectors:
.D. E. Mi ler
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6/6/8f
Date
R. . A.
ul
d[6/ds
Date
Approved By: - L. R.
rege , Chief
4/4/8
Facilities Radiation Protection
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
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.NUREG-0737 task action items.
The inspection involved 80 inspector-hours on site
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by two NRC inspectors.
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Resultsi
No violations were identified in six of the seven areas inspected.
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One violation'was identified.in'one area (failure to follow procedures -
Section 7).
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DETAILS
1.-
Persons Contacted
- D. Adam, Lead Health Physics Field Services Engineer, CECO
- L. Aldrich, Lead Health Physicist
- R. Bare, Quality Assurance Inspector
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- 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.
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(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.
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Two plant Health Physicists terminated employment with CECO.
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A recent graduate with a B.S. in Environmental Health
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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
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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.
the exit meeting.
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This matter was discussed at
No violations or deviations were identified.
5. -
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.
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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 individuals.
system which 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
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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,
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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.
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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
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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
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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.
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(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).
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(Closed) 373/85031-00.. Nonconservative liquid effluent monitor
setpoint.- This incident resulted from failure of the equipment operator
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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
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As described in Inspection Reports No. 50-373/84021; 50-374/84027,
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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,
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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
portion of Lthe Unit I reactor building air supply ductwork. These
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matters will be further reviewed during a future inspection.
(373/85014-02;'374/85014-02)
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No violations were identified.
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ill. -Exit Meetina
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' 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
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' 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:
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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)
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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)
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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
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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.
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