Text

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-373/96-14 & 50-374/96-14 on 961120
	ML20133E603
Person / Time
Site:	LaSalle
Issue date:	01/08/1997
From:	Grant G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Subalusky W; COMMONWEALTH EDISON CO.
References
	NUDOCS 9701130078
	Download: ML20133E603 (3)
	v • d • e

l

.

1

January 8, 1997

Mr. W. T. Subalusky, Jr

Site Vice President

LaSalle County Station

Commonwealth Edison Company

2601 North 21st Road

Marseilles, IL 61341

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS

NO. 50-373/96014(DRS); 50-374/96014(DRS))

Dear Mr. Subalusky:

This will acknowledge receipt of your letter dated December 20,1996,in response to our

letter dated November 20,1996, transmitting a Notice of Violation associated with the

failure to adequately consider the effects of incore irradiation of intermediate range

monitors (IRMs) during the preparation for removal of IRMs on May 22 and July 1-2,

1996, and the failure to follow the requirements of the radiation work permit (RWP) during

radwaste pump aisle work on August 20,1996. In your response to the violations, you

indicated that the replacement of the IRMs was performed during two separate forced

outages and that the replacement required two entries into the drywell in a Hot Shutdown

condition and not at power as stated in the subject report. We acknowledge that the IRMs

were removed during Hot Shutdown conditions and not at power. We have reviewed your

corrective actions for the violations and have no further questions at this time. These

corrective actions will be examined during future inspections.

Sincerely,

/s/ M. Icach (for)

Geoffrey E. Grant, Director

Division of Reactor Safety 1

i

Docket Nos. 50-373; 50-374 l

Licenses No. NPF-11; NPF-18

Enclosure: Ltr 12/20/96 W. T. Subalusky,

Comed to US NRC, w/ enc!

See Attached Distribution

1

'

SEE ATTACHED CONCURRENCES

I

DOCUMENT NAME: G:DRS/LAS010_7.DRS

1. .e. .. . con ' o'i. d-e - a'. * 'ica'- 4a c - corr -/ " i. ci r . c. ,, .f. u f. ,i n - n. .,,

OFFICE Rill l Rill l Rlll l#

NAME NShah:jp TKozak MLeach/GGrantM

DATE 01/ /97 01/ /97 01/ 8 /97

0FFICIAL RECORD COPY

9701130078 970108

PDR ADOCK 05000373

O PDR

. _ _ _ . . . _-.-. - -

_ . .- - _ . - _ - - - .--- .- _ - .-

.

l

i *

.

Mr. W. T. Subalusky, Jr

Site \nce President

LaSalle County Station

Commonwealth Edison Company .

2601 North 21st Road

Marseilles, IL 61341

Dear Mr. Subalusky:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-373/96014

(DRS); 50-374/96014(DRS)

r

l This will acknowledge receipt of your letter dated December 20,1996,in response to our

!

letter dated November 20,1996, transmitting a Notice of Violation associated with the

l failure to adequately consider the effects of incore irradiation of intermediate range

'

monitors (lRMs) during the preparation for removal of IRMs on May 22 and July 1-2,

l 1996, and the failure to follow the requirements of the radiation work permit (RWP) during

radwaste pump aisle work on August 20,1996. In your response to the violations, you

! indicated that the replacement of the IRMs was performed during two separate forced

outages and that the replacement required two entries into the drywellin a Hot Shutdown

condition and not at power as stated in the subject report. We acknowledge that the IRMs

were removed during Hot Shutdown conditions and not at power. We have reviewed your

corrective actions for the violations and have no further questions at this time. These

corrective actions will be examined during future inspections.

l

Sincerely,

Geoffrey E. Grant, Director

Division of Reactor Safety .

Docket Nos. 50-373; 50-374

Licenses No. NPF-11; NPF-18

Enclosure: Ltr dtd 12/20/96

See Attached Distribution

DOCUMENT NAME: G:DRS/LAS010_7.DRS

g g .i..

, . .,, ., ini. . . . ..... . i in. n . c c.,, iin.. .ti.cnt..ci r - c.,, iin .ti.cnf...i n-

0FFICE RIII C RIII /] RIII

NAME NShah:jp @ TKozakY MLeach/GGrant

DATE 01/7 /97 01/ 1 /97 01/ /97

'

l OFFICIAL RECORD COPY

.. - - - _ -- -

__ _ __ ____ _

4

.

W. T. Subalusky -2- January 8 1997

cc w/o encl: T. J. Maiman, Senior Vice President

Nuclear Operations Division

D. A. Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

D. J. Ray, Station Manager

J. Burns, Regulatory Assurance

i

Supervisor

1. Johnson, Acting Nuclear

Regulatory Services Manager

f cc w/ encl: Document Control Desk - Licensing

i Richard Hubbard i

! Nathan Schloss, Economist, i

Office of the Attorney General

l State Liaison Officer

Chairman, Illinois Commerce Commission

Distribution:

Docket File w/enci Rlli PRR w/enci W. L. Axelson, Rlll w/enci

PUBLIC IE-01' w/ encl SRis, LaSalle, Dresden, RAC1 w/ encl (E-mail)

OC/LFDCB w/enci Quad Cities w/enct Enf. ' Coordinator, Rlli w/enci

DRP w/enct LPM, NRR w/enci

DRS w/enct A. B. Beach, Rlli w/enci

1

130037

.o

-

1

. . O mnu,nucahh tihmin Compan3 '

<

ie inc c.cocraiinoiainin

2(d i %,rth 21 i Hii.iti

. Wrs illev 11.(if 4 e i4'i' )

l

wi xn <s .<, ,.

!

s

i

December 20,1996

^

i

United States Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, D.C. 20555 I

s

Subject: REVIEW OF AUGUST 20,1996, ADMINISTRATIVE

-

i

OVEREXPOSURE AND RESULTS OF THE

OCTOBER 15-18,1996, RADIATION PROTECTION

(RP) INSPECTION

Reference: l

G. E. Grant letter to W. T. Subalusky, dated l

November 20,1996, Transmitting NRC Inspection

Report 373/374-96014 f 1

The enclosed attachment contains LaSalle County Station's response to the

Notice of Violation, that was transmitted in the Reference letter.

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 therq.are any questions or comments conceming this letter, please Tdfer

them to me at (815) 357-6761, extension 3600.

Respectfully,

h ^

W. T. Subalusky

Site Vice President

LaSalle County Station

Enclosure

'DD \ D LO

. .. . ._- . . .. -. . . _ . .

- - - - .. . . . -.. . - _ - - - . . . . - . .

.-

.

. . .

.

cc: /B. Beach, NRC Region 111 Administrator

M. P. Huber, NRC Senior Resident inspector - LaSalle

p. M. Skay, Project Manager - NRR - LaSalle

DCD - Ucensing (Hardcopy: Electronic: )

Central File

i

l

i

. _.

l

- -

- _ .. -. .- -- . .-- . - -

..

.

e

.

ATTACHMENT

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-96-014

VIOLATION: 373/374-96-014-01

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,

concentrations or quantities of radioactive materials, and the potential radiological

hazards that could be present.

Pursuant to 10 CFR 20.1003, surveymeans 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

surveys to assure compliance with 10 CFR 20.1201(a), which limits radiation exposure

to 5 rem total effective dose equivalent (TEDE). Specifically, the licensee did not

y

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

l

On May 22,1996, an entry was made into the Unit Two Drywell with the reactor in a Hot l

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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months decay time after reactor shutdown prior to

removing in-core detectors. Due to the scheduled short duration of the forceioutage,

the 'D' IRM was replaced within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of reactor shuidown. The ALARA analyst

considered the short time after reactor shutdown as he was preparing the ALARA plan '

for tne 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 inserteo into the core during the reactor shutdown.

1

- - -.- -.. - . _ - - - . - - . . . . . - - - - --.-.-

..

, .

l* .

-

,

1

i l

l

ATTACHMENT

!

RESPONSE TO NOTICE OF VIOLATION !

NRC INSPECTION REPORT

373/374-96-014 I

l

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

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 t

replacement continued without any additional radiological concems. The estimated

exposure for the work was 270 mrem. The actual exposure for the detector

replacement was 199 mrem. The ALARA Analyst documented the unexpected dose :

rate on a Problem Identification Form (PlF). This PlF was reviewed by the Event

Screening Committee and assigned to the Work Control Department with a non-

significant status._ ;

i

' 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

i

been removed from the core and taken out of service in late May. Additionally, in

l ;

accordance with normal station practices the reactor was shutdown greater than j

l 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months before the detector was removed. Based on this information, dose rates were

! expected to be minimal. This detector replacement was completed with no radiological

concems. :

,

l

The primary cause of the May 22,1996, event was inadequate communications

!

between Operations, Radiation Protection, and System Engineering. This resulted in a

l lack of clear understanding of when the Intermediate Range Monitor (IRM) detector had

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

~

i

l

'

adequate controls to ensure irradiation of detectors was properly evaluated prior to

detector removal. This was identified in May and documented on a Problem l

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

the Work Control Department. Untimely corrective actions allowed a seconoTncore -

detector to be removed without addressing the concems identified in the PIF.

l

I

!

'

l

,

2

.

. 1

.

..

-

.

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 1

exposure history at the detector and, in addition, there were extensive references to l

equipment / tools rto 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 q

,

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.

1

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

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED: .,_

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

LFP-600 4.

3

..

- . .

!" ATTACHMENT '

!

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-96-014

VIOLATION: 373/374-96-014-03

i

Technical Specification 6.2(B) states that radiation control procedures shall be

maintained, made available to all station personnel, and adhered to.

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

,

l

Program," Step e(4), requires that workers comply with the requirements of the RWP

and all associated documents.

RWP No. 960027Jequired that the radiation protection (RP) department be notified i

l prior to starting work.

,

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: 373/374/96-01443

'

l

A Radwaste Supervisor was tasked to determine if the waste collector and waste surge i

i

tanks needed to be cleaned of solids / sludge as a part of a larger project to replace the I

i

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

irispection 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

Tank, an opwator 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

j expected 20 to 35 mrem /hr dose rate.

Although the Radwaste Group, Radiation Protection (RP), and the ALARA Group were

i

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

l

Supervisor leading the job briefing, nor the Radiation Protection Technician (RPT) l

i

!

l

4

- _ _ . . . . _ - _

.

., -

.

ATTACHMENT

RESPONSE TO NOTICE OF VIOLATION

NRC INSPECTION REPORT

373/374-96-014

attending the briefing, specifically reminded the operator entering the Radwaste Pump

Aisle to frequerstly check his digidose readings while in the Radwaste Pump Aisle. The

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.

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

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 i

Pump Aisle.

The operator did not periodically review his ED status to verify his accumulated dose.

The RPT attending the pre-job briefing did not question the duties of the individualin

the Radwasto Pump Aisle.

\

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

,

I

the tanks. There was no separate job specific RWP for the Radwaste Pump Aisle work i

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 projecTscope

of the tank inspection. No discussion was held regarding the potential for changing

area dose rates in the Radwaste Pump Aisle.

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 normallevels.

The individual's TLD was pulled for processing and the individual was denied access to

the RPA pending a review of the event.

5

-. __ _ -__.

..

'

' '

o .

.

ATTACHMENT

RESPONSE TO NOTICE OF VIOLATIO:J

NRC INSPECTION REPORT

373/374-96-014

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

individuals involved to fully understand the event, the Radwaste Supervisor was

assigned to lead the Root Cause Evaluation Team.

An article was placed in the plant newsletter describing the event, highlighting several

areas needing improvements, which may have prevented this event. This event was

communicated in two successive Plan of the Day Meetings to statien departments. This

event is also currently communicated in NGET Training classes.

~

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 m5eting, the supervisor discusses all work to be performed C

throughout the day. His discussions include related Radiation protection information

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'o any work beginning in an RPA.

!

i i

6

ML20133E603

Text

Navigation menu

Search