IR 05000373/1992018

Insp Repts 50-373/92-18 & 50-374/92-18 on 920824-28. Violations Noted.Major Areas Inspected: Gaseous Liquid & Solid Radwaste Program & Preparation & Planning Activities Associated W/Upcoming Refueling Outage

ML20127D922
Person / Time
Site:	LaSalle
Issue date:	09/09/1992
From:	Louden P, David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127D740	List: IR 05000373/1992018 ML20127D737 ML20127D819
References
50-373-92-18, 50-374-92-18, NUDOCS 9209150213
Download: ML20127D922 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/92018(DRSS); 50-374/92018(DRSS)

' Docket Nos. 50-373; 50-374 Licenses No. NPF-ll; NPF-18 Licensee: Commonwealth Edison Campany Post Office Box 767 Chicago, IL 60690 Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle County Station, Marseilles, Illinois Inspection Conducted: August 24 through 28, 1992 Inspectors; - - d' 8 #/V PT L. Louden U a e[ -

GO$ ~ Le0A J/J/)L D. W. Nelson /~ Date Accompanied By: T. Bohn, Senior Scientist Idaho National Engineering Laboratory

, Approved By: ( 11_, $s. ,8# _ f />/>L William Snell, Chief Date Radiological Controls Section 2-Inspection Summary

' Inspection on August 24 throuah 28. 1992 (Recort Nos. 50-373/92018(DRSS): 50-

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374/92018(DRSS))

Meas Inspected: Routine announced inspection of the licensee's gaseous, liquid, and solid radioactive waste program (IP 86750 & 84750), and the licensee's preparation and planning activities associated with the upcoming Vait_1 refueling outage (LIR05) (IP 83729). A special review of the licensee's methodology used to perform dose calculations recorded in Annual Operating Reports and Semiannual Effluent Reports using the NRC confirmation computer program PC Dose (IP 84750).

Results: One violation of NRC requirements was identified regarding a waste

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shipment sent to the Barnwell burial site without the required information entered son the Yellow-III label attached to the package (Section 8).

Additionally, one Inspector followup Item was opened to follow the completion of resolving discrepancies between information found in the radiological l

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teffluent _ technical specifications and the data used -in the licensee's effluent ,

dose calculation program ,(Section 9). - Ihe licensee has canceled the large scope.in-service-inspections-(ISI) and the recirculation system chemical Overall, decontamination originally _ scheduled for the Unit 'l refuel the licensee's: radioactive waste program is_well staffed and is per outage._ forming at acceptable levels. The general housekeeping of the station during the inspection was excellen ,

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DETAILS 1. Persons Contacted Licensee staff-

• J. Arnould, Regulatory Assurance

• J. Beke, Technical- Staff Group Leader

• J. Borm, Nuclear Quality Programs Engineer

• D. Carlson, Regulatory Assurance, NRC Coordinator

• G. Diederich, LaSalle Station Manager

• K. Francis, RadWaste Coordinator

• J. Gieseker, ENC Project Manager

• H. Hentschcl, Assistant Superintendent, Operations

• D, Hieggelke, Health Physics Services Supervisor

• J. Houston, Emergency Preparedness Coordinator

• Huntington, Superintendent, Technical Services

• P. Knoll, Contamination Control Coordinator

• J. Lockwood, Supervisor, Regulatory Assurance

• P. Nottingham, Supervisor, Chemistry

• J. Schmeltz, Superintendent, Production

• J. Shields, Nuclear Licensing Administrator Nuclear Reaulatory Commission

• D.-Hills, Senior-ResidentcInspector

• C.-Phillips, Resident Inspector-The. inspector also interviewed other licensee personnel in various departments in the course of the inspectio * Indicates those present at exit meeting on August 28, 1992.

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3. Licensee Action on Previous Inspection Findinas (867501-(Closed) Violation Nos. 50-373/91016-02: 50-373/91016-02: Inappropriate marking on an LSA radioactive waste' shipment. The incident involved an

" EMPTY" marking inadvertently left on the inside of a radioactive waste LSA~ container. The shipment was appropriately marked and labeled on the outside of.the package. The licensee revised station procedure to include reviewing all areas within a personnel barrier around a transport package to ensure all " EMPTY" or other inappropriate markings are removed prior to shipment. This item is close . Trainina and Oualificativns,(IP 84750 and-86750)'

The inspectors reviewed ,he training and qualification records of personnel ~ involved in solid radioactive waste transportation activities to verify such individuals had received training concerning waste processing-and Department'of Transportation (DOT) requirement All managers involved in the processing, packaging, and shipping of radioactive waste and materials receive vendor supplied training which covers specific requirements of DOT regulations and NRC requirements

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..z under 10:CFR 6F. Attendees include' managers from Operations, Radiation i Protection, and. Chemistry = Departments. . Radiation Protection Technicians ='

(RPTs) receive oeriodic- training in this area as part of-their continuing training program. All of the-individuals reviewed appeared to..be well; qualified for their positions, and many were noted as having previous experience as. operators or. bad nuclear training and experience

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while serving in the Nav No violations or-' deviations were identifie . Liould and G yeous Radioactive Waste (IP 8475A).

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The inspectors reviewed the licensee's liquid and gaseous radioactive effluent program including: waste system changes, waste sampling,

_ process..and effiuent monitors,-release paths, batch releases and

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procedures for waste and effluent system _The station performed one liquid _ batch release during 1992, Samples wers collected = and analyzed using a germanium detection system to Lidentify and determine the concentration of:the gamma emitting nuclide ,

Beta- emitter concentrations were determined from the vendor analysis-of

' compositell_iquid - samples . Total activity for each nuclide was

determined using.the sample analysis- and- the flow discharge rate. The batch release consisted of 7,128 gallons- and the total _ com)osite '

activity was-3.0E4 microcuries. _The inspectors reviewed tle sampling -

Land ~ analytical. methodologies and determined that all record 3 and tactivities were performed -in:accordance with procedural and-Technical -

SpecificationL(TS) requirement A review:of the gaseous radioactive waste records indicated-that

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collected samples (grab, filter and charcoal), dose updates and

' projections were performed and monitors were calibrated all within required time frames. - All gaseous' releases were well within regulatory

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limit .

No; violations = or deviations-were identifie "

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? Solid' Radioactive Waste (IP 867501-

-The inspectors; reviewed the licensee's solid radwaste management

program,- including:1 processing, control, and storage of- solid radioactive. waste; adequacy of required __ records, reports, and

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inotifications;: classification and characterization-of_ waste, preparation

of manifests, and marking'.of packages.-

-Theioperations, department maintains tha ultimate responsibility for the

implementation of'the radioactive waste processing. program. Radiation ,

-Protection:..(RP)__and Chemistry play supporting roles in providing sample-

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analyses, surveys, waste classification and characterization-information

,for radioactive waste prepared for shipment. Waste stream analysis is performed by;a vendor laboratory and is routinely cross checked by- the Chemistry Department. RP additionally performs document reviews to ensure accuracy and compliance with DOT _ regulation The inspectors noted that while the current structure of the program appeared to

. function as designed, communication problems could ' occur, and an overall

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cognizant manager to assist in the coordination of the various-departments did not exist. A specific example of the discontinuity which could occur in the program can be found in the responsibility differences regarding radioactive waste shipments and radioactive material shipments. As mentioned previously, operations maintains responsibility for waste shipments, however, RP is held responsible for the coordinating of radioactive materials shipments. Wherein this setup has not caused frequent regulatory noncompliances, the program appeared to be operating adequately mainly due to the aggressive performance of those lower. level managers involve The inspectors reviewed the circumstances surrounding a recently shipped package of filter media whose curie content was later found to be greater than originally reported to the burial sit The shipping manifests detailed the shipment as 0.333 curies of solidified filter media. The shipment was classified Low Specific Activity (LSA), and the waste classification was Type "A". Several weeks later, a station health phys'icist, while reviewing recently received vendor analyses noticed a discrepancy in the scaling factor used for current shipments compared to historical files. After researching the concern, it was determined that the vendor laboratory had performed the most recent sample analysis incorrectly and this arror was the cause of the isotopic profiles being-incorrect. Cross reference checks performed by station Chemistry staf f confirmed the error, which affected the calculations used for the shipment mentioned above. After reviewing the corrected scaling factors, the shipment should have been listed as containing 31.14 curies of total activity. The licensee immediately notified the burial site of the error with respect to the shipment. The burial site acknowledged the error, and considering that the waste classification did not change and the shipment was appropriately packaged for the revised quantity, no further concern was discussed with the burial sit In addition to the burial site notification, the station has planned to send a- Quality Assurance taam to the vender laboratory to-review their

. analytical procedures and uiscuss the_ event in detail with laboratory managemen The licensee was in the process of implementing the radioactive waste-mancgement computer program (RADMAN). RADMAN is capable of detecting

' differences between vendor supplied and licensee generated analysis data, whichshould help alleviate the problem encountered in the above mentioned event. This program will also help reduce time in generating required paperwork and will- provide an easily accessible database for historical review No violations or deviations were identifie .- ' Calibrations of Gaseous and Liould Monitors (IP 84750)

The' inspectors reviewed the calibration and set point records and

- procedures for all of the gas and liquid process monitors. The-liquid monitors include: radioactive waste discharge, service water discharge for each unit and the two residual heat removal system service water -

monitors for each unit. The gaseous monitors include: standby gas treatment' system and reactor building vent exhaust; pre- and post-offgas;- fuel pool exhaust; and several area continuous air monitors

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(CAMS). All monitors are source checked for energy response, efficiency, and linearity. The calibrations appear to be performed in-accordance with procedural and Ti requirement No violations or deviations were identifie . Transoortation of Radioactive Materials (IP 86750)

The inspectors reviewed the licensee's transportation and radioactive material programs, including: changes in procedures; adeqmcy of

,~ required records, reports,-and shipment documentation; and compliance with applicable NRC and DOT regulations, General Activities The licensee has-made approximately 200 non-waste radioactive materials shipments as of the time of the inspection. As discussed in Section 6, RP-is respensible for all non-waste

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radioactive materials shipments, and a health physicist is assigned to manage the program and is responsible for assuring-that all shipping documents are properly completed and signed; all containers are properly marked and labeled; and the vehicles are properly placarded. -The inspectors reviewed several selected .

procedures. addressing radioactive materials' shipments and found them to be well writter.,-easy to follow and technically accurat RP personnel involved in the program are qualified and receive annual off-site-radioactive materials transportation-trainin The licensee has made approximately 75 radioactive waste shipments during 1992 to date, to processing and/or waste burial facilities and sites. Unlike radioactive materials shipments, operations-is responsible for the transportation of all radioactive waste. Each shipment requires input from four separate groups; -RP,-Chemistry, Quality Cor, trol and the radioactive waste group. Quality Control-provides hold-and stop c points,. audits each shipments, signs the appropriate 10 CFR 71-Quality _ Assurance docur:entation. Radioactive waste persannel complete all of the required documents and assures that each shipment meets 00T and NRC requirement Transportation Event of August- 13, 1992 The-licensee was notified on August 13, 1992, that a shipment-of resins sent to the Barnwell, S.C. burial site arrived without the Department of Transportation Yellow-III label being appropriately

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filled out, as required by 49 CFR 172.403. The licensee reviewed the circumstances which led to the error =and determined that the

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procedures-which detailtthe' process for preparing a shipment containing. quantities requiring'a Yellow-III label were inadequate in addressing all the requirements necessary to perform such a shipment. On August 27, 1992, the licensee received a letter dated. August 17, 1992, from the State of South Carolina detailing-the violation and containing a warning that further violations of this type Would lead to more severe enforcement actions. The

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inspector discussed this event with all personnel involved, and

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indicated to station management that failure to appropriately complete a Yellow-fl! label with the required, content, activity, and transport index information was a violation of 49 CFR 172.402 (Violation 373/92018-01; 374/92018-01). The inspectors discussed this event at the exit meeting and detailed the apparent inadequacies in procedures which led to the violation. Licensee staff M icated that corrective actions were underway and proced.m a would be amended to include all the detailed requireiaents to comply with 00T regulation One violation of NRC requirements was identifie . PC Dose Comparative Calculations (IP 84750). ,

The inspectors performed a special review of the licensee's methodology in calculating offsite doses from liquid and gaseous releases to verify compliance with 10 CFR 50 Appendix I limits. The calculations were verified using the NRC PC Dose program, which uses Regulatory Guide 1.109 technique Reviews of parameters used in the calculation compared with information provided in the Offsite Dose Calculation Manual (0DCM) resulted in the identification of some half-life discrepancies for a few of the isotopes as listed in the ODCH. These minor differences or typographical errors

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were-quickly corrected by licensee staf Comparati.:' runs were performed of liquid and gaseous releases for predominate-pathways for a number of radioisotopes. Liquid release results compared very well with most the isotopes compared, falling within '2 percent of the PC Dose results. Gaseous calcudtions compared

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favorably for most isotopes, however, a considerable error-(+99%) was observed between the programs when _ calculating Iodine 131 doses. The doses-' appeared to be consistently two times creater When using the licensee's program than with the PC Dos; frc ,'am. Further investigation-revealed that the reason for the conservative error was due to the licensee using a factor of "1" for elemental iodine fractions, as opposed to the "1/2" value stated in the ODCM. The inspectors informed-the licensee of the disagreement between the program parameters and what is stated in the ODCM, and that the resolution of the inconsistency would be tracked as an Inspector Followup Item (IFI 373/92018-02; 374/92018-02).

No violations of.NRC requirements were identifie One Inspector Followup Item was identifie . Preparation fer Unit 1 Outaae (LIR05)

The' inspectors reviewed the licensee's work scope, ALARA initiatives, and dose goals for the upcoming Unit 1 outag The current dose goal for the outage is 392 person-rem. This revised figure has been reduced due to the station's decision to cancel the-originally planned recirculating system decontamination and the large scope of in-service inspections (ISI). The originally planned ISI alone was projected to be about 290 person-rem. Station staff indicated that

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this ISI and decontamination would be performed during the next Unit I refuel outag The higher dose jobs for-the outage are similar to those performed in previous outages: under vessel work; control rod drive repairs; local power range monitor repairs; safety relief valve work; and miscellaneou valve work. The balance of the-work activities are a number of miscellaneous routine jobs in the 3 person-rem and lest range. Licensee staff-indicated that departmental cooperation was continuing to improve, and that several lessons learned from past outages were discussed at various planning meetings. The station will continue to use a central

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operations room for outage activities to assist in planning and coordination. This center was used during the previous outage and received many complements from workers and management staf To assist in reducing dose rates in the recirculation piping, the plant will again perform a soft shutdown, and as a result of efforts by the source term reduction task force, operations will keep the reactor water cleanup system (RWCU) running about four times longer than in the pas The task force believed that a significant amount of residual crud would be removed from the system if RWCU was left operational for a longer period of time following shutdown. The inspector indicateo at the exit meeting that this initial recommendation and the cooperation from the operations department was an improvement in addressing previously identified concerns with the station's overall approach to source term reduction. The results of these activities will be reviewed durino future inspection No violations or deviations were identifie . - Toun During the course of the inspection the inspectors made several tours of the radiologically contra'. led area and the radioactive waste areas. A few radiation material hbeling problems-were discovered during the tours and,each item was promptly corrected by radiation protection staf Overall the radiological and general housekeeping of the station was excellent. All personnel observed working in the RCA appeared to be following good radiation protection practice No violations or deviations were identifie . Exit Meeting The scope and findings of the inspection were discussed with licensee representatives (Section 1) at the conclusion of the inspection on

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August 28, 1992. Licensee representatives did not identify any documents or processes reviewed during the inspection as proprietar Specific items discussed at the meeting were as follows:

- The violation of transportation requirements associated with the August 1992 shipment of resins to the Barnwell sit _ - . _ , _ _ . _ _ . _ _ . . _ .

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- The 'results of' the comparative calculations of the licensee's dose

- commitment program and the NRC PC Dose program. One IFI-was identified during these calculation regarding the fractional allowance for elemental ; iodine in_ gas particulate calculation _-The reduction in the scope of-the Unit 1 outage scheduled to begin at

- the end of September 1992, and:the implementation of recommendations provided by the source term reduction task forc The observed excellent housekeeping of the RCA and radioactive waste

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