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Insp Repts 50-373/97-05 & 50-374/97-05 on 970224-28. Violations Noted.Major Areas Inspected:Review of Plant Chemistry & Gaseous & Liquid Radioactive Waste & Effluent Release Program
	ML20137K405
Person / Time
Site:	LaSalle
Issue date:	03/24/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20137K345	List: ML20137K343; ML20137K405; ML20140C390;
References
	50-373-97-05, 50-373-97-5, 50-374-97-05, 50-374-97-5, NUDOCS 9704070023
	Download: ML20137K405 (13)
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U.S. NUCLEAR REGULATORY COMMISSION

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REGION lli

Docket Nos: 50-373; 50-374 '

Licenses No: NPF-11; NPF-18

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Reports No: 50-373/97005(DRS); 50-374/97005(DRS) ,

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Licensee: Commonwealth Edison Company {

Facility: LaSalle County Station, Units 1 and 2

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Location: 2601 N. 21st Road ,

Marseilles, IL 61341

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Dates: February 24-28,1997

Inspectors: N. Shah, Radiation Specialist

W. G. West, Radiation Specialist l

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Approved by: T. J. Kozak, Chief, Plant Support Branch 2 1

Division of Reactor Safety '

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EXECUTIVE SUMMARY

LaSalle Nuclear Generating Station, Units 1 and 2

NRC inspection Reports 50-373/97005; 50-374/97005

This inspection included a review of the plant chemistry and gaseous and liquid radioactive

waste (radwaste) and effluent release programs. The report covered a one week

inspection concluding on February 28,1997.

Reactor water chemistry was effectively controlled and the overall analytical capability of

the laboratory was good. Chemistry sampling and analytical equipment were well

maintained. During tours, the inspectors observed station operators using appropriate

controls during radwaste tank transfers and verified that the operators were aware of

industry events involving poor control during these transfers. Effluent activity released and

associated dose was appropriately calculated and the effluent monitoring instrumentation

was well maintained. However, some problems were noted with chemistry sampling

procedures and with station audits of the chemistry program. Additionally, numerous

minor problems with the wide range gas monitors (WRGMs) have resulted in a station

operator expressing concerns with their reliability. During tours, the inspectors observed

several material condition problems and some signs of poor housekeeping in locked high

radiation areas (LH:' s). One violation was identified for three examples where radiation -

protection procedural requirements were not followed.

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Report Details

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j TR1 Radological Protection and Chemistry (RP&C) Controls l

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l R.1.'1 - Imolementation of Chemistry Pronram -

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j s. Inspection Scope j

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The inspectors' reviewed the implementation of the licensee's radiological and non- l

!- radiological chemistry program, including chemistry technician (CT) performance, l

j- ' intra:aboratory comparison checks, chemistry sampling results, and water trend i'

charts.

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b. . Observations and r.adinas

- ' Chemistry laboratory housekeeping was generally good and cts used ' good j

sampling techniques and RP practices. Additionally, the cts performed well'in j

. Interlab and intratab performance checks performed in 1996. The inspectors i

observed that chemical reagents and standards were within listed expiration dates,

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i- but observed a weakness with the storage of used sample bottles. ,The licensee 'i

recycled these bottles to minimize the generated radioactive' waste and stored them i

- adjacent to recently collected samples. Prior to storage, the cts would cross out j

the old label or replace it with a blank label and fill the bottle with domineralized :

i water. However, several of the used bottles had labels that were not clearly !

crossed out. Although this was not a procedural violation, the inspectors were j

t concerned that this practice could result in a CT confusing a used bottle with a !

L .cu'rrent sample. Subsequently, chemistry management replaced the used labels !

with new ones and provided clear guidance to the cts about the handling of used .

bottles. l

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,. The inspectors verified that chemistry water sampling was conducted as required l

l by station Technical Specifications (TS) and procedures. A review of water l

chemistry parameters from September 1996 through February 1997, indicated )

plant water chemistry was effectively controlled. During plant walkdowns, the ,

inspectors observed cts performing sampling at the reactor water sample panel and

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the wide range gas monitors (WRGMs). The inspectors noted that the cts used

the appropriate procedures and exhibited good radworker practices. However, the

inspectors noted a problem with the mechanism used to communicate and track

completion of sampling requirements. Specifically, each week the cts were

provided a printed list summarizing the daily sampling requirements. Each CT

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would initial a specific requirement upon completion and chemistry supervision

- would review and initial the completed daily log. The inspectors noted that the list 1

only summarized those requirements for full power operation and did not address 1

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those applicable during shutdown / refueling. These requirements were handwritten

. into the checklist, by chemistry supervision. The cts relied on this sheet to track

completion of the sampling requirements. This method of specifying which samples

were required to be obtained during shutdown conditions increased the likelihood

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that a sample could be missed. This was discussed with chemistry management

who planned to review the issue during the current procedure revision process.

The inspectors also reviewed the results of CT drills on the High Radiation Sampling

System (HRSS); no problems were identified. A mockup HRSS panel was used

during these drills which were performed in conjunction with the General Station

Emergency Plan (GSEP) exercise. In addition, the chemistry department performed ,

internal drills which used the actual HRSS panel. During discussion with the

inspectors, cts displayed good knowledge of HRSS operation.

Chemistry management was addressing several concerns with CT procedural

adherence, knowledge and intradepartment communications. These problems were

identified during department self-assessments and were similar to those

documented in station PlFs. However, the inspectors noted that although

department self-assessments identified these problems, the site quality verification

group (SOV) did not readily identify similar problems. Additionally, a review of SOV

field monitoring reports (FMRs) from January 1994 to December 1996, indicated

that SOV was focused primarily on the station chemical control process and not on

chemistry department performance. The FMRs consisted of in-field observations of

chemistry performance and were used as input into the biennial SOV audit. The

FMR process relied on SOV findings (and not PlFs or other similar outside input) to

determine the program focus. The inspectors were concerned that by not including

PlFs and other similar inputs into the FMR process and by focusing on the chemical

control process, the SOV group was not effectively auditing the chemistry program.

This problem was recognized by the SOV department and was being addressed.

c. Conclusions

Reactor water chemistry was effectively controlled and the overall analytical

capability of the laboratory was good. However, some problems were noted with

chemistry sampling procedures and with SOV audits of the chemistry program,

indicating improvement was needed in both areas.

R 1.2 Observations of Radioloaical Controls and Postinos in the Radioloaical Contro!!ed

Area (RCA)

a. Insoection Scoce

The inspectors performed a walkdown of general areas in the RCA to verify that

appropriate radiological controls and postings were used. The review included

entering severallocked high radiation areas (LHRAs) which were infrequently

entered by workers,

b. Observations and Findirigi

Overall, the inspectors observed that radiological controls and postings were

appropriate and that existing radiological conditions were as indicated on plant

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survey sheets. However, the inspectors observed the following specific problems

with contaminated area (CA) control:

e The inspectors observed two examples were RP technicians failed to ensure

reasonable efforts were made to prevent the spread of contamination from

an area and that the area be properly posted and set-up as required by

station Procedure No. LRP 57216, " Construction of Radiologically Posted

Areas and Step-Off Pad Areas" (Steps E.1 and E.3). Specifically, in the Unit

1 "A" and "B" heater drain pump rooms, the inspectors observed that the

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CA boundary did not completely enclose a plant floor drain and that no

controls were in place to prevent groundwater intruding into the work area,

from spreading into the clean areas. This area had been reviewed by an RP

technician prior to use. ,

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e The inspectors observed two examples of material crossing the CA boundary

without being properly secured, as required by station procedure no. LRP

5721-6 (Step D.1). Specifically, in the 734' elevation of the radwaste (RW)

building across from the waste concentrator tank, unsecured ropes and

chain falls were observed crossing a CA boundary. Also,in the Unit 1 "A"

heater drain pump room, an unsecured drain hose, exiting a CA boundary,

was laying atop a floor drain.

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The inspectors observed two examples where CA boundaries were not

- marked using radiation rope and/or tape, as required by station procedure no.

LRP 5010 01, " Radiological Posting and Labeling Requirements" (Steps

F.2(a) and (b)). Specifically, in the chemistry laboratory, two sample sinks

were posted as " potential contaminated areas" without having the CA

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boundaries (i.e. parameter of sink top) delineated by radiation rope and/or

tape.

The problems in the Unit 1 "A" and "B" heater drain pump rooms were recurrent,

as similar observations were made by the NRC in previous inspections. The three

issues listed above are examples of a violation of TS 6.2(B) which required

adherence to RP procedures (VIO 50-373/374 97005-01). Additionally, while in

the offgas building, the inspectors observed rainwater (coming from the juncture of

the metal roof and wall) dripping down into a CA and spilling out onto the clean

area. Based on interviews with the licensee, the area was set-up prior to the

rainfall and had been there for some time. Apparently, station laborers would

periodically mop the clean area, but had not identified the problem via the station

problem identification program.

The inspectors entered the following specific LHRAs: the turbine building (TB) Unit

1 and 2 condensate polishers "A", "B" and "C"; the RB Unit 1 and 2 reactor water

cleanup (RWCU) "A" heat exchanger (HX) room; the RB Unit 2 phase separator

valve room; the Unit 0 radwaste transfer building (RWTB); and the TB Unit 2

radwaste pump aisle. Overall, the inspectors observed that appropriate radiological

postings and controls were used, that material condition was good and that existing

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radiological conditions warranted LHRA status. However, the fo!!owing specitic

problems were noted:

In the TB Unit 1 condensate polisher "A", "B" and "C" room, the inspectors

observed a pool of water underneath and leakage down the side of tank C.

Although the pool resulted from licensee identified leakage originating from a

leaking flenge, the leakage down the side of the tank had not been identified

and was believed to be originating from the tank vent header;

e in the RB U1 RWCU HX and 710' Unit 0 RWTB, the inspectors observed

generally poor housekeeping from past work activities; and

In the Unit 2 phase separator valve room, the inspectors observed two

dropped hot spot postings and the use of radiation rope to secure a catch

containment for a leaking contaminated valve. The use of radiation rope to

secure catch containments was allowed by station procedures, but was

considered inappropriate by the RP department.

The licensee was developing corrective actions for the above observations.

Specifically, a work request was developed to address the leakage from condensate

polisher tank "C" and the RP group planned to verify if the hot spot postings were

still appropriate.

c. Conclusions

Overall, appropriate radiological postings and controls were observed in the RCA,

but one violation was identified for several examples of poor control of

contaminated areas. Appropriate controls were also noted for LHRAs, but the

inspectors observed some signs of poor housekeeping and the inappropriate use of

radiation rope to secure a catch containment.

R1.3 Gaseous and Liauid Effluent Proaram

a. Insoection Scopft

The inspectors reviewed the licensee's gaseous and liquid effluent release program

including calculation of activity released and resultant dose and maintenance of the

effluent radiation monitors. The review included discussions with plant staff, a

review of records and a system walkdown. The following monitors were observed

during the walkdown: off-gas pre- and post treatment radiation monitors, WRGMs,

rnain steam line radiation monitors, reactor building (RB) and fuel pool (FP)

ventilation exhaust radiation monitors, off-gas system carbon bed vault radiation

monitors, service water radiation monitors, liquid radioactive waste effluent

monitors, residual heat removal (RHR) HX cooling water effluent monitors, and the

RB closed coc4 ling water monitor.

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b. _Qbservations and Findinas

Total gaseous effluent activity released has increased significantly from 121 curies

(Ci) in 1995 to 1220 Ci in 1996. Chemistry management attributed the increase to

minor fuel leakage occurring in January 1996, as well as to the increased counting

sensitivity of detectors acquired at that time. The inspectors verified that the

resultant dose during bo:h periods was low and was calculated in accordance with

the licensee's offsite dose calculation manual (ODCM).

Routine radioactive liquid discharges were discontinued in 1991. However, owing

to the extended shutdown, the licensee was unable to operate the radwaste

evaporators which severely limited the ability to process the liquid radwaste

generated. Therefore, liquid radioactive waste discharges were resumed in late

1996. The inspectors verified that the activity and dose totals were low and were

calculated as described in the ODCM.

In early 1996, the licensee was made aware (via the corporate office) of an error in

the computer software used to calculate dose to the public from radioactive

effluents. Specifically, since January 1,1994, the software had been calculating

dose using only one non-noble gas pathway (i.e. through the ingestion of meat

products). The licensee has since corrected the software and recalculated the dose

reports. In all cases, the recalculated dose was a small fraction of the applicable

limit.

During plant walkdowns, the inspectors verified the gaseous and liquid effluent

monitors were maintained in good operating condition, were within calibration and

had appropriate alarm setpoints. A review of outstanding work requests on these

monitors also identified no problems. However, during this inspection, a concern

was identified regarding the operability of the W~RGMs. Specifically, there were

numerous, recurront, minor problems with the monitors that have resulted in

spurious alarms and the occasional need to perform compensatory sampling. The

system engineering group was aware of these problems and had addressed them

individually. However, the recurrent nature of these problems has resulted in one

control room operator expressing a lack of confidence in the reliability of the

WRGMs. Station management was reviewing this concern and developing

corrective actions.

While in the off-gas building, the inspectors observed rainwater (leaking from the

juncture of the metal roof with the building wall) falling on the gauge / indicator (a

high voltage system) for the charcoal bed area radiation monitor (ARM). Also, a

female connection was observed to be uncapped, which was inconsistent with the

other connections. Although the ARM was observed to be operable, these

problems appeared to have existed for some time and were not documented in

station PlFs. This was discussed with the appropriate SE who indicated that

corrective actions would be taken.

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c. Conclusions

Overall, the gaseous and liquid effluent release program was effectively

implemented. However, numerous, minor problems occurred with WRGMs,

resulting in a station operator having concerns with their operability. Additionally,

some material condition problems with the off-gas charcoal vault ARM were

identified by the inspectors.

R2 Status of RP&C Facilities and Equipment

R 2.1 Chemistrv Instrumentation and Eouioment

a. Insoection Scoce

The inspectors reviewed the maintenance of the licensee's chemistry sampling and

analytical equipment, including the HRSS panel.

b. Observations and Findinos

The inspectors observed that laboratory analytical equipment was maintained in

good operating condition. Chemistry instrument calibrations and quality control

(OC) performance checks were correctly performed and documented. A review of

control charts indicated that the instruments remained within statistical control.

Recently, the licensee installed more efficient High Purity Germanium Detectors

(HPGe) which have significantly lowered the lower limits of detection (LLDs) for

effluent sample analysis. During walkdowns of the counting laboratory, the

inspectors verified that these detectors were also well maintained and properly

calibrated.

Chemistry management was addressing concerns regarding the material and

radiological conditions of the reactor, turbine and radwaste building sampling

stations. Specifically, several of the stations contained numerous abandoned

equipment and were located near high dose rate piping. For example, average dose 1

rates near the Unit 1 and 2 reactor building sample panels ranged between 10-13

mrem /hr, with some localized hot spots up to 25 mrem /hr. The chemistry group i

was developing a plan to improve the material condition of the panels and was l

emphasizing good ALARA practices during sample rounds. In particular, the

increased emphasis on ALARA has resulted in decreasing department dose from 6

rem in 1994 to about 3 rem in 1996. l

Through a review of outstanding work requests, direct observation, and interviews

with cts, the inspectors determined that no significant operability concerns existed l

with the in-line monitoring instruments or the HRSS. However, the inspectors I

noted that the ion and gas chromatographs on the HRSS (described in Section '

11.5.5.3 of the Unified Final Safety Analysis Report (UFSAR)) were inoperable.

The licensee had backup analysis capability as required by UFSAR Section 11.5.5.6

and had scheduled work requests for the instruments for later in 1997. Overall, the

in-line instruments and HRSS panel appeared well maintained.

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c. Conclusions

The licensee was effectively maintaining chemistry sampling and analytical

equipment and had implemented effective ALARA measures to control dose from

the sample panels.

R2.2 Walkdown of Liould Radioactlye Waste (Radwaste) Processina Areas

a. Insoection Scoce

The inspectors performed a walkdown of the general areas of the liquid radwaste

processing system including the radwaste control room. The review included

discussions with the appropriate SEs, control room operators and a selective review

of records,

b. Observations and Findinas

During the tour, the inspectors observed several examples of poor material

condition, including: bottles of sulfuric acid (having signs of leakage)inside a

storage cabinet in the make-up demineralizer (MUDS) room; significant corrosion of

the radwaste acid day tank in the 692' elevation of the TB; and numerous work

requests and caution tags on the radwaste control panel. In particu!ar, the

observation concerning the sulfuric acid had not been identified by the licensee's

chemical control process. The licensee verified that the bottles of sulfuric acid I

were not leaking and had documented the corroding day tank in a station PlF.

Although the cause of the corrosion was still being evaluated, this tank was not in

use and will be abandoned in place. Regarding the control panel tags, the SE and

radwaste operators stated that there were several minor problems with various

valves and with tank system alarms occurring before the pre-set alarm setpoints.

Based on discussions with operators and a review of station PIFs, these problems l

had not significantly impacted system operation. Radwaste management was

developing a plan to address matsrial condition problems with the radwaste system,

and in particular with the radwaste control panel, as part of the overall station

improvement process.

The inspectors verified that the radwaste operators were familiar with a recent

industry event where operator inattention to detail resulted in a significant

overpressurization of a radwaste tank. The operators stated that they were {

expected to monitor the tank levelindications during transfers and not to rely on j

the alarms. Additionally. radwaste transfer procedures contained hold points and

caution statements to stop the transfer prior to the high alarm setpoint. While

observing a radwaste transfer to the waste sludge tank, an inspector noted an

operator using the correct procedure and monitoring the levelinstrumentation. The

procedure used, LRP-WF-06 " Floor Drain Concentrator Feed Tank Sludge Transfer

to the Waste Studge Tank," contamed a caution statement and hold point to stop

processing prior to reaching the high level alt.m. .

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c. Conclusions

The inspectors identified several examples of material condition problems. These

problems did not appear to significantly impact radwaste system operation and

were being addressed by radwaste management. The inspectors observed a -

radwaste operator appropriately monitoring levelinstrumentation during radwaste

tank transfers and verified that operators were aware of industry events involving

poor control during these transfers.

R8 Miscellaneous RP&C lasues i

The following items identified in previous inspections were reviewed by the

inspectors:

R8.1 (Closed) Unresolved item (URI) No. 50-373/374 96002-02: Apparent issuance of

respirators to workers who had not had the appropriate training. The licensee

corrected the computer database error that had produced this problem and

identified no workers who had been issued a respirator that had not had the

appropriate training. This item is closed. -

R8.2 (Closed) URI No. 50-373/374 96004-02: Several station management individuals

and their escorts entered the refueling floor, a posted HRA, in violation of their

radiation work permit (RWP). A Non-Cited Violation was issued for this item in

inspection Report (IR) No. 96005(DRP). This item is closed.

R8.3 (Closed) Insoector Follow-uo item (IFI) No. 50-373/374 96006-05: Licensee was

investigating cause of evaporator gasket failure and was developing appropriate

storage period for replacement gaskets. The licensee could not verify if the

evaporator gasket failed due to radiological degradation owing to a lack of definitive

industry data. However, based on corporate engineering recommendations, the

licensee now requires that each new gasket be visually inspected every 12 months

following installation. Additionally, the licensee specified that each replacement

gasket can be stored for a maximum of 10 years prior to use. This item is closed.

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X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management

(denoted by "*") at the conclusion of the inspection on February 28,1997. The licensee

acknowledged the findings presented and did not identify any of the documents reviewed

as proprietary. l

'W. Subalusky, Site Vice President

F. R. Ducino, General Plant Manager

'L. Guthrie, Unit 2 Plant Manager

'N. Hightower, Radiation Protection Manager

'D. Rhoades, Chemistry Supervisor

M. R. Dougherty, Construction Superintendent

R. Roby, Director, Support Services

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P. Manning, Support Engineering

'L. Spiers, Director, Site Quality Verification

'M. J. Oclon, Unit 1 Mechanical Maintenance Supervisor

'R. Williams, Site Quality Verification Supervisor

'R. Varju, Chemistry Laboratory Supervisor

'S. Tutoky, Counting Room Chemist

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' B. Buinickas, System Engineer

'R. G. Heisterman, Maintenance Manager

'J. Harrington, Radweste Supervisor

'J. Schuster, Lead Chemist

= "J. Theen, Analytical Chemist

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INSPECTION PRCCEDURES USED i

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lP 83750 OCCUPATIONAL RADIATION EXPOSURE

IP 84750 RADIOACTIVE EFFLUENT MONITORING AND RELEACE, PLANT WATER !

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CHEMISTRY AND RADIOLOGICAL ENVIRONMENTAL MONITORING

PROGRAMS

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ITEMS OPENED, DISCUSSED OR CLOSED

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Vif, .Jo. 50-373/374 97005 01: Several examples of the failure to follow RP procedures ,

(Section R1.2)

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Discussed or Closed

Closed ,

URI No. 50-373/374 96002-02: Apparont issuance of Respirators to workers who had

not had the appropriate training. (Section R8)

URI No. 50-373/374 96004-02: Several station management individuals and their

escorts entered the refueling floor, a posted HRA, in

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violation of their radiation work permit (RWP). (Section

R8)

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IFl No. 50-373/374 96006-05: Failure of th3 OWX evaporator. (Section R8) !

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PARTIAL LISTING OF DOCUMENTS REVIEWED

Corporate Memorandum summarizing 1996 Analytical Chemistry interlaboratory

- Comparison Results (dated 2/21/97)

LaSalle Chemistry Technician Proficiency Test Results (dated 12/27/96)

Semi Annual Effluent Reports (7/9612/96,1/96-6/96,1/95-12/95,1/95-6/95)

Unified Final Safety Analysis Report (UFSAR) sections:

11.2 " Liquid Waste Management System"

11.3 " Gaseous Waste Management System" ,

11.5 " Process and Effluent Radiological Monitoring and Sampling Syutems"

Regulatory Guides: !

1.109 " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents

for the Purpose of Evaluating Compliance With 10 CFR 50, Appendix 1" ;

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1.111 " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous l

. Effluents in Routine Releases from Light-Water-Cooled Reactors"

1.113 " Estimating Aquatic Dispersion cf Effluents frorn Accidental Reactor Releases for '

the Purpose of implementing Appendix I"

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Station Procedures:

LAP 1800-8 " Chemistry Surveillance Guide"

LAP 1800-7 "BWR Water Chemistry Control Program"

LL 9112 20 " Determination of Conductivity (Flow-Thru Cell)"

LCo-AA S1 "Shiftly Check of Wide Range Gas Monitors" -

LRP 5800 3, " Radiation Monitoring Alarm / Trip Setpoint Determination" ,

LRP 5820-3, "Linearity Check of the Reactor Building and Fuel Pool Exhaust Vent Process

Radiation Monitors"

LRP-WF-06 " Floor Drain Concentrator Feed Tank Sludge Transfer to the Waste Sludge .

Tank" l

LRP-5010-1 " Radiological Posting and Labeling Requirements" *

LRP 5721-6 " Construction of Radiologically Posted Areas and Step-Off Pad Areas" ;

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ML20137K405

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