ML20133B672

Responds to NRC Re Violations Noted in Insp Repts 50-373/96-14 & 50-374/96-14.Corrective Actions:Review of procedure,LFP-600-3, IRM & SRM Handling Was Performed & Procedure Was Found to Be Inadequate.Procedure Revised

ML20133B672
Person / Time
Site:	LaSalle
Issue date:	12/20/1996
From:	Subalusky W COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701060076
Download: ML20133B672 (8)

Text

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. Commonucalth lilisoq Company

. lealle Generating Station

, 2601 North list Itoad

. Marwilles,11. 613 ii C57 TelHI4 M7 & 61 i

i December 20,1996 United States Nuclear Regulatory Commission Attention: Document Control Desk

, Washington, D.C. 20555

Subject:

REVIEW OF AUGUST 20,1996, ADMINISTRATIVE OVEREXPOSURE AND RESULTS OF THE OCTOBER 15-18,1996, RADIATION PROTECTION

'RP) INSPECTION

Reference:

G. E. Grant letter to W. T. Subalusky, dated November 20,1996, Transmitting NRC Inspection Report 373/374-96014 {

, The enclosed attachment contains LaSalle County Station's response to the Notice of Violation, that was transmitted in the Reference letter. i i

The letter transmitting the referenced Notice of Violation contained a statement that needs clarification. The replacement of the Intermediate Range Monitors was performed during two separate forced outages.

Replacement required two entries into the drywell in a Hot Shutdown condition and not at power as stated in the report.

If there are any questions or comments concerning this letter, p! ease refer them to me at (815) 357-6761, extension 3600. ,

. Respectfully, k

^

W. T. Subalusky

, Site Vice President LaSalle County Station Enclosure '

9701060076 961220 PDR GQU l G ADOCK 05000373

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j cc: A. B. Beach, NRC Region Ill Administrator M. P. Huber, NRC Senior Resident inspector - LaSalle l i

D. M. Skay, Project Manager - NRR - LaSalle  !

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96-014 VIOLATION: 373/374-96-014-01 ,

i 10 CFR 20.1501 requires that each licensee make or cause to be made surveys that )

may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, l concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present.

Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

Contrary to the above, on May 22,1996, and July 1-2,1996, the licensee did not make l surveys to assure compliance with 10 CFR 20.1201(a), which limits radiation exposure l to 5 rem total effective dose equivalent (TEDE). Specifically, the licensee did not adequately consider the effects of incore irradiation of intermediate range monitors (IRMs), as disseminated in NRC Information Notice 88-63, during the preparation for removal of IRMs on May 22,1996, and July 1-2,1996.

This is a Severity Level IV violation (Supplement IV).

REASON FOR VIOLATION: 373/374/96-014-01 On May 22,1996, an entry was made into the Unit Two Drywell with the reactor in a Hot Shutdown condition. The purpose of this entry was to replace the 'D'IRM Normal station practice is to allow a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> decay time after reactor shutdown prior to removing in-core detectors. Due to the scheduled short duration of the forced outage, the 'D' IRM was replaced within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of reactor shutdown. The ALARA analyst considered the short time after reactor shutdown as he was preparing the ALARA plan for the activity. Lessons learned from an event at Quad Cities Station involving a detector that was stuck in the core and read approximately 200 R/Hr was included in the ALARA review. Due to inadequate communications between the ALARA analyst, Operations and the Nuclear Engineering group, the ALARA analyst calculated an expected dose rate using the assumption that the detector had been placed out of service for over a month, thereby precluding exposure to neutron flux. In fact, the detector had been declared inoperable due to high noise, but had not been tagged out of service, and had been inserted into the core during the reactor shutdown.

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ATTACHMENT

' RESPONSE TO NOTICE OF VIOLATION '

NRC INSPECTION REPORT 373/374-96-014 4

The ALARA plan for the work required a continuous survey by a Radiation Protection 3

Technician (RPT) during detector removal. The RPT was to stop work if a 10R/Hr contact dose rate was observed on the detector. The RPT actually stopped work after

, identifying a dose rate of 7 R/Hr. The radiological conditions were assessed and additional controls were put in place before the work was resumed. The detector replacement continued without any additional radiological concerns. The estimated exposure for the work was 270 mrem. The actual exposure for the detector j replacement was 199 mrem. The ALARA Analyst documented the unexpected dose i

rate on a Problem Identification Form (PIF). This PIF was reviewed by the Event Screening Committee and assigned to the Work Control Department with a non-significant status.

l' On July 1 another replacement of the 'D'IRM was performed on Unit 2. The same ALARA Analyst prepared the ALARA plan for this activity. He verified that this IRM had been removed from the core and taken out of service in late May. Additionally, in

accordance with normal station practices the reactor was shutdown greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before the detector was removed. Based on this information, dose rates were expected to be minimal. This detector replacement was completed with no radiological

concerns. i

. The primary cause of the May 22,1996, event was inadequate communications between Operations, Radiation Protection, and System Engineering. This resulted in a lack of clear understanding of when the Intermediate Range Monitor (IRM) detector had c

last been exposed to neutron flux. A contributing cause of this violation was that station

procedures and the travelers used to generate work packages did not contain adequate controls to ensure irradiation of detectors was properly evaluated prior to detector removal. This was identified in May and documented on a Problem ,

t identification Form (PIF). This PlF was given a low priority and assigned incorrectly to

, the Work Control Department. Untimely corrective actions allowed a second incore detector to be removed without addressing the concerns identified in the PIF.

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96-014 CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

The PIF generated as a result of these higher than anticipated dose rates was reclassified as significant and reassigned to the Radiation Protection Department for resolution. The Radiation Protection Manager now reviews all PIF's generated to identify any that involve the RP Department or Rad Worker practices. The RPM then ensures that the proper level of attention is given to resolving the identified issues. A review of the procedure, LFP-600-3, "lRM and SRM Handling" was performed and the procedure was found to be inadequate in several areas including no reference to incore  ;

exposure history at the detector and, in addition, there were extensive references to equipment / tools no longer in use.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

LFP-600-3 "lRM and SRM Handling" and LFP-600-4 "TIP Removal" have been revised to include references to IN 88-63. A requirement was added for Operating to provide detector exposure history to Radiation Protection for determination of anticipated dose rates. An exposure history and dose calculation was included in the ALARA plan for each detector removal. This information will be reviewed by the ALARA Planner prior to the commencement of work. The procedures were revised to include the requirement that an RPT be in continuous attendance during detector removal to perform surveys.

The travelers that are used to develop the work packages for removal of SRM's, IRM's, and TIP's were revised to include a sign-off for the Operating Engineer and Radiation Protection Supervision before work is begun. This signature is to ensure that irradiation ,

of the detectors is taken into consideration when developing the ALARA plan i

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved with the revision of procedures LFP-600-3 and LFP-600-4.

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. l ATTACHMENT l

' RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374-96-014  !

VIOLATION: 373/374-96-014-03 Technical Specification 6.2(B) states that radiation control procedures shall be f maintained, made available to all station personnel, and adhered to.

Station procedure LAP-100 22 (Revision No.18), " Radiation Work Permit (RWP)

Program," Step e(4), requires that workers comply with the requirements of the RWP and all associated documents.

i RWP No. 960027 reouired that the radiation protection (RP) department be notified l prior to starting work. l 1

J Contrary to the above, on August 20,1996, a radwaste operator performed work in the radwaste pump aisle, without contacting the RP department as required by RWP No. 960027 This is a Severity Level IV violation (Supplement IV).

l REASON FOR VIOLATION: 373/374/96-014-03  !

A Radwaste Supervisor was tasked to determine if the waste collector and waste surge tanks needed to be cleaned of solids / sludge as a part of a larger project to replace the

radwaste filter elements. This task involved removing all water and performing a visual

inspection of those tanks. The tanks are in a high radiation area; not frequently accessed.

While assisting the removal of water operation from the Equipment Drains (WE) Surge l

1 Tank, an operator received a total whole body exposure of 52.7 mrem as determined by  !

his electronic dosimeter (ED). He was authorized to receive 50 mrem in accordance with the Radiation Work Permit (RWP) he was using. Following the event, a survey determined the working dose rates were 200 to 400 mrem /hr. This exceeded the i expected 20 to 35 mrem /hr dose rate.

i Although the Radwaste Group, Radiation Protection (RP), and the ALARA Group were aware of the work that was to be performed, the potential for elevated dose rates in the

Radwaste Pump Aisle was not identified. This was a result of inadequate supervisory

, methods and failure to communicate expectations. Neither the Radwaste Shift Supervisor leading the job briefing, nor the Radiation Protection Technician (RPT) 4 s

ATTACHMENT l

RESPONSE TO NOTICE OF VIOLATION j NRC INSPECTION REPORT '

373/374-96-014 i 1

I attendir.g the briefing, specifically reminded the operator entering the Radwaste Pump A!sie to frequently check his digidose readings while in the Radwaste Pump Aisle. The l, '

writers and reviewers of the special procedures did not identify the potential for changing dose rates, even though the purpose of the special procedures was to allow the water level to drop down lower than normal to observe the sludge layer in the tanks.

l The general RWP used by the operator entering the Radwaste Pump Aisle did not allow draining of any system that could result in changing the radiological conditions of i

an area without RP approval. Inadequate communication between the Operator and the RPT resulted in a " key" being issued for entry into the Radwaste Pump Aisle without

, the RPT having a clear understanding of the scope of work planned in the Radwaste Pump Aisle.

f The operator did not period!cally review his ED status to verify his accumulated dose.

The RPT attending the pre-job briefing did not question the duties of the individual in the Radwaste Pump Aisla.

f The ALARA review performed the day of the work did not include review of the special procedures portion because the focus was on the non-routine entry of the tank room and because the Radwaste Pump Aisle operator work was thought to be routine. The ALARA review did not include all personnel involved in the work since the inspection of the tank was handled as a separate RWP and separate task from the pump down of the tanks. There was no separate job specific RWP for the Radwaste Pump Aisle work to perform the special procedures to pump down the tanks because Operating believed the work to be routine.

A RWP request submitted by the supervisor of the work did not relate the full scope of the work being performed. Per the RWP request, only a tank inspection was to be completed. During the planning process, RP was informed of the entire project scope of the tank inspection. No discussion was held regarding the potential for changing area dose rates in the Radwaste Pump Aisle.

I CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED:

A chain and lock were installed to secure the door until the investigation was completed.

An investigation survey was conducted, identifying the hot lines. A flush was completed

to reduce the general area dose rates back to normal levels.

l The individual's TLD was pulled for processing and the individual was denied access to the RPA pending a review of the event.

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION <

NRC INSPECTION REPORT 373/374-96-014 i

The operating department individual and his supervisor were counseled regarding the responsibility of the individuals when in a High Radiation Area. The non-licensed ,

, operator and the Radwaste Supervisor received appropriate discipline. To help the individuale involved to fully understand the event, the Radwaste Supervisor was assigned to lead the Root Cause Evaluation Team.

An cricle was placed in the plant newsletter describing the event, highlighting several areas 7.eeding improvements, which may have prevented this event. This event was communicated in two successive Plan of the Day Meetings to station departments. This event is also currently communicated in NGET Training classes.

2 The details of this event were reviewed with the entire Radwaste Staff and the Radiation Protection Department.

. Communications within the Radwaste Department has been improved. The Radwaste '

Shift Supervisor now meets each weekday prior to day shift, with the Radwaste Operators. During this meeting, the supervisor discusses all work to be performed throughout the day. His discussions include related Radiation protection information l and status and Radiation Standards and Expectations.

CORRECTIVE ACTIONS TO BE TAKEN TO PREVENT FURTHER VIOLATIONS:

All 1997 RWPs have been written to require an electronic dosimeter with ear piece when accessing the Radwaste Pump Aisle or other High Rad /High Noise area.

The Radiation Protection Department will perform a review of the time keeping functionality of the electronic dosimeter in high noise areas of the plant. Areas exceeding the recommended ambient noise level as set forth by the manufacturer will be evaluated for further controls. This will completed by April 1,1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance was achieved on October 21,1996, when Radwaste Operations began meeting with the shift personnel prior to any work beginning in an RPA.

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