ML20133E603
| 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) | |
See also: IR 05000373/1996014
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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
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Docket Nos. 50-373; 50-374
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Enclosure: Ltr 12/20/96 W. T. Subalusky,
Comed to US NRC, w/ enc!
See Attached Distribution
SEE ATTACHED CONCURRENCES
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DOCUMENT NAME: G:DRS/LAS010_7.DRS
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DATE
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01/
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01/ 8 /97
0FFICIAL RECORD COPY
9701130078 970108
ADOCK 05000373
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Mr. W. T. Subalusky, Jr
Site \\nce President
LaSalle County Station
Commonwealth Edison Company
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2601 North 21st Road
Marseilles, IL 61341
Dear Mr. Subalusky:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-373/96014
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This will acknowledge receipt of your letter dated December 20,1996,in response to our
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letter dated November 20,1996, transmitting a Notice of Violation associated with the
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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,
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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
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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.
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Sincerely,
Geoffrey E. Grant, Director
Division of Reactor Safety
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Docket Nos. 50-373; 50-374
Enclosure: Ltr dtd 12/20/96
See Attached Distribution
DOCUMENT NAME: G:DRS/LAS010_7.DRS
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NAME
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DATE
01/7 /97
01/ 1 /97
01/
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OFFICIAL RECORD COPY
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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
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Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
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cc w/ encl:
Document Control Desk - Licensing
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Richard Hubbard
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Nathan Schloss, Economist,
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Office of the Attorney General
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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
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December 20,1996
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United States Nuclear Regulatory Commission
Attention: Document Control Desk
Washington, D.C. 20555
Subject:
REVIEW OF AUGUST 20,1996, ADMINISTRATIVE
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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
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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.
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,
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W. T. Subalusky
Site Vice President
LaSalle County Station
Enclosure
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/B. Beach, NRC Region 111 Administrator
cc:
M. P. Huber, NRC Senior Resident inspector - LaSalle
p. M. Skay, Project Manager - NRR - LaSalle
DCD - Ucensing (Hardcopy:
Electronic:
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Central File
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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
adequately consider the effects of incore irradiation of intermediate range monitors
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(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 forceioutage,
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 shuidown. The ALARA analyst
considered the short time after reactor shutdown as he was preparing the ALARA plan
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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.
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ATTACHMENT
RESPONSE TO NOTICE OF VIOLATION
NRC INSPECTION REPORT
373/374-96-014
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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
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additional controls were put in place before the work was resumed. The detector
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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._
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On July 1 another replacement of the 'D' IRM was performed on Unit 2. The same
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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
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accordance with normal station practices the reactor was shutdown greater than
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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
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expected to be minimal. This detector replacement was completed with no radiological
concems.
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The primary cause of the May 22,1996, event was inadequate communications
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between Operations, Radiation Protection, and System Engineering. This resulted in a
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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
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adequate controls to ensure irradiation of detectors was properly evaluated prior to
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detector removal. This was identified in May and documented on a Problem
identification Form (PlF). This PlF was given a low priority and assigned incorrectly to
the Work Control Department. Untimely corrective actions allowed a seconoTncore
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detector to be removed without addressing the concems 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:
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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
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exposure history at the detector and, in addition, there were extensive references to
equipment / tools rto longer in use.
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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
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detector exposure history to Radiation Protection for determination of anticipated dose
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rates. An exposure history and dose calculation was included in the ALARA plan for
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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
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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Full compliance was achieved with the revision of procedures LFP-600-3 and
LFP-600 4.
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ATTACHMENT
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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
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maintained, made available to all station personnel, and adhered to.
Station procedure LAP-100-22 (Revision No.18), " Radiation Work Permit (RWP)
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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
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prior to starting work.
Contrary to the above, on August 20,1996, a radwaste operator performed work in the
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radwaste pump aisle, without contacting the RP department as required by
RWP No. 960027
This is a Severity Level IV violation (Supplement IV).
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REASON FOR VIOLATION: 373/374/96-01443
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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
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radwaste filter elements. This task involved removing all water and performing a visual
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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
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expected 20 to 35 mrem /hr dose rate.
Although the Radwaste Group, Radiation Protection (RP), and the ALARA Group were
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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)
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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
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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
Pump Aisle.
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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.
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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
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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 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.
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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.
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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
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throughout the day. His discussions include related Radiation protection information
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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.
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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.
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