ML20198T367

Insp Repts 50-373/97-21 & 50-374/97-21 on 971215-17. Violations Noted.Major Areas Inspected:Review of ALARA Planning,Radiological Controls & Radiation Protection Oversight for Ongoing Unit 1 RWCU

ML20198T367
Person / Time
Site:	LaSalle
Issue date:	01/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198T339	List: ML20198T334 ML20198T363 ML20198T367
References
50-373-97-21, 50-374-97-21, NUDOCS 9801270042
Download: ML20198T367 (11)

See also: IR 05000373/1997021

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U.S. NUCLEAR REGULATORY COMMISSION :i

REGION lil -

Docket Nos: 50-373; 50-37* *

, License Nos: .NPF 11; WPF ,8 *

-Report Nos: 50-373/97021(DRS); 50-374/97021(DRS)

Licensee: Commonwealth Edison Company

Facility: LaSalle County Nuclear Power Station

Units 1 and 2

Location: 2601 North 21st P.oad

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Marseilles, IL '.,1341

Dates: December 15-17,1997

-Inspector: W. Slawinski, Senior Radiation Specialist

Approved by: G. L. Shear, Chief, Plant Support Branch 2

Division or Reactor Safety

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EXECUTIVE SUMMARY

LaSalle County Nuclear Power Plant, Units 1 and 2

NRC Inspection Reports 50-373/97021; 50-374/97021

This inspection consisted of a review of the as-low-as-reasonably achievable (ALARA)

planning, radiological controls and radiation protection oversight for the ongoing Unit 1 reactor 4

water cleanup (RWCU) system modifications, and a review of two contamination incidents

associated with the project, in these areas, the following conclusions were formed:

. The ALARA plan for the RWCU system project was comprehensive and included the

extensive application of lessons teamed from previous, similar station and industry

experience. The content of the ALARA plan demonstrated effective coordination

between engineering and radiation protection (RP) staffs in the development of its scope

and in initiatives for future station dose reduction. (Section R1,1)

. Measures to control dose during the RWCU system project were effective. Overall, the

ALARA plan and associated radiological controls were generally well implemented.

Dose from rework was minimized for the project as a result of good planning and work

crew coordination. (Section R1.2)

. Radiation worker performance and radiation protection oversight of contractor activities

for the RWCU system project was generally good with some exceptions. The

exceptions involved two occasions when contract workers failed to follow the

instructions specified in the radiation work permit and contact the radiation protection

staff prior to initiating certain potential high risk evolutions. One violation was identified

with two examples for failure to follow station procedures as required by Technical

Specifications. (Section R4.1)

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Reoort Details

IV. Plant Support

R1 Radiological Protection and Chemistry (RP&C) Controls

R1.1 ALARA Plan and Controls for the Rea.ctor Water Cleanuo (RWCU) System Modifications

a. Inspection Scoce

The inspector reviewed the as-low-as reasonably-achievable (ALARA) plan and the

radiological controls developed for the RWCU system modification project. The ALARA

plan and historical information on which it was panially based, associated radiation work

permits (RWPs) and survey results were reviewed. The inspector also discussed the

plan with radiation protection (RP) personnel.

b. Observations and Findings

The station was shutdown throughout 1997 to address engineering issues related to

station conformance to its design basis, which resulted in significant dose producing

work. The RP staff estimated that this work accounted for a dose of 230 rem for 1997,

including 65 rem (original projection) for major modifications to the RWCU system. A

goal of about 52 rem was originally established for the RWCU system modifications.

The RWCU 7ystem modifications consisted of; (1) replacement of the existing three

50% capacy recirculation pumps with two 100% capacity seal-less pumps and the

installation of new piping, reconfigured to address heat exchanger voiding problems and

resultant system flow perturbations; (2) replacement of 45 of 73 filter domineralizer

system leak prone ball valves with new three-piece ball valves; and (3) instailation of

larger valve actuators and improved valve stems on the system's containment inboard

and outboard isolation valves. The licensee Intended these modifications to improve

system maintenance and reliability, which is expected to reduce worker dose,

inspector review of the ALARA plan disclosed it to be comprehensive and well thought-

out. Development of this plan and its work scope was characterized by effective

cooperation between the plant engineering and RP staffs. The plan included severcl

engineering initiatives for improved system maintenance and for future station dose

reduction. For example, system piping was redesigned to reduce the number of

corrosion product traps and was reconfigured to allow better segregation and shielding

between the two pump rooms. In addition, the replacement valves and pumps were

constructed of low cobalt bearing materials, and future maintenance activities were

simplified by installing the recirculation pumps vertically and through an improved three-

piece ball valve design. Also, a " shielded metallic reflective insulation" was developed

by the licensee for installation on the system's suction and discharge lines. Collectively,

tnese modifications were expected to lower the station's radiological source term and

result in lower dose to workers performing future maintenance on system components.

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ALARA controls and dose reduction methods incorporated into the plan included the

extensive use of lessons leamed from previous, similar work at LaSalle and the industry.

The ALARA plan included the following controls; assurances that appropriate ventilation

systems were available and operable to control contamination; the use of direct and

shadow shielding; the hydrolyzing of floor drains and systcm piping to reduce area dose

rates; sequencea pipe removal to minimize worker exposure, and strong foreign

material exclusion practices to ensure reinstalled piping and connections were free of

microscopic particulete material. However, as described in hspection Reports 50-

373/97019(DRS);50-374S7019(DRS), a proposed chemical decontamination of the

RWCU system was cance'c ~, as it could not be performed within the existing outage

schedule.

c. CDDQhtidOna

The ALARA plan for the RWCU system project was comprehensive and included the

extensive application of lessons learned from pr6vious similar station and industry

experience. The plan demonstrated effective coordinction between station engineering

and RP staffs in the development of its scope and !n initistives for future station dose

reduction.

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R1.2 ALARA Plan imolementation and Dose Controls

a. Insoection Scoce

The inspector reviewed the implementation of the licensee's ALARA plan and the

radiological controls and RP oversight for the RWCU system project. The review

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consisted of in-plant observations; attendance at a pre-job meeting; review of RWPs,

radiation surveys, logs and other records; and discuscions with workers.

b. Observations and Findings

Radiological oversight for the RWCU system project was assigned to a coordinator from

the RP staff. The individual was responsible for the development and implementation of

the ALARA plan and for ensuring that appropriate radiological controls were used and

that work group coordination was effective. The project was initiated in mid-November

1997, and involved approximately 200 contract workers.

The inspector observed the use of television cameras installed at several strategic

locations within the RWCU pump and valve rooms to allow RP personnel to continually

monitor the various work activities from a control point station. Direct radiation

protection technician (RPT) coverage was provided for certain higher risk evolutions,

and telex communication systems were used to enhance oversight of work activities.

Due to the large scope of the work and previous station problems with shift turnover,

dedicated crews were used for certain valve work.

System pipe removal was sequenced, as planned, based on dose. Piping was cut into

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pre-designated lengths to achieve maximum dose savings and for ease in handling and

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disposal. Pipe cutting was expedited considerably and significant dosa savings were ,

achieved by frequent blade changing. Additional dose savings were realized through l

the use of enhanced shielding packages; implementation of a well devised plan for 4

rigging and transporting the inboard valve actuator through the drywell; and by couplin0

work for valves in series rather than working on individual valves.

Roles and responsibilities of contractor and RP personnel were clearly discussed at the

moming shift briefing attended by the inspector, and special instructions were provided

during work crew break out sessions with RP personnel. In general, the inspector noted

, that the RP department maintained gcod oversight of project tasks, and dose was

effectively controlled as a result. However, the RP department temporarily halted

project work on two occasions as a result of separate incidents involving worker

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contaminations. These incidents are described in Section R4.

As of December 18,1997, the station had accrued a dose of about 21 rem for the

RWCU system project with roughly 65% of the scheduled work completed. This

dose expenditure was well below the licensee's originally estimated dose for the project '

at that stage. Suction line piping removal, recirculation pump replacement and ball

valve work expended less than 50% of the dose originally projected for these evolutions,

owing to time reductions, good work crew coordination and effective implementation of

the Al. ARA plan.

Work on the containment inboard and outboard RWCU isolation valves, the final two

phases of the project, was approximately 55% complete as of December 18,1997, and

had accumulated a dose of less than 30% of that projected. While a substantial

increase in efficiency related to the technique devised for rigging and transporting the

inboard valve actuator out of the drywell saved dose, the licensee appeared to have

overestimated the dose to complete certain aspects of the isolation valve work in its

original estimate. For example, the licensee identified that the original dose estimate for

the outboard isolation valve work did not take into account the reduced area dose rates

that resulted from the earlier removal of highly contaminated piping. Also, the original

dose estimate did not anticipate that the outboard valve and asscciated piping would

need to be removed from the valve room and relocated to the mechanical maintenance

shop because of valve seat problems. The removal of the valve allowed its components

to be flush .rd and cleaned further before work continued, resulting in lower doses to the

work crew,

in light of the updated dose information, on December 18,1997, the licensee reduced its

original project dose estimate from 65 to 56 rem and its goal from 52 to 45 rem. Based

on the current dose trends and work progress, the licensee expected to achieve its

lowered dose goal.

About 25 tons of concrete was generated during the demolition of the RWCU pump and

valve rooms. The licensee planned to unconditionally release the majority of this debris -

for disposal at a landfill. The station planned to handle the debris from the demolition in -

accordance with its unconditional release procedure, LAP-900-26, Revision 20, " Control

of Materials for Conditional or Unconditional Release from Radiologically Posted Areas".

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This procedure sr,ecified that only materials and objects with no detectable activity can

be unconditionally released. If contamination was detected on concrete debris, the

licensee planned to decontaminate the material by scabbling and other techniques, until

no detectable surface activity could be identifie'l before the material would be disposed.

The inspector's review of the licensee's plan for disposal of the debris identified no

problems. However, the inspector discussed with the licensee its plans for analysis of

surface contaminated porous material such as concrete, to ensure that such material

would be evaluated adequately to identify the potential of leached and occluded

contaminants into the porous surfaces. To address this issue, the licensee collected

several core bores of the RWCU pump room's demolished concrete walls and verified

the absence of leached contaminants through direct radiation surveys.

c. Conclustom

Measures to control dose during the RWCU system project were effective. Overall, the

ALARA plan and associated controls were generally wellimplemented. Lessons

learned from previous, similar jobs were judiciously applied and properly implemented.

Dose from rework was minimized for the project due to good planning and work crew

coordination.

R4 Staff Knowledge and Performance in RP&C

R4.1 Contamination incidents Durina RWCU System Prolect

a. insoection Scoce

The inspector reviewed the circumstances surrounding two incidents prompting work

stand-downs. During the incidents, workers were contaminated with radioactive material

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while performing cutting / grinding and welding activities in the RWCU valve room. The

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inspector reviewed the licensee's investigation of the incidents; applicable RWPs,

procedures and other documentation; and discussed the incidents with RP staff,

b. Observations and Findinas

incident No.1

On November 21,1997, two contract pipefitters were contaminated while conducting

weld preparation work in the RWCU valve room. The November 21,1997 work activity

involved cutting (shaving) previously cut pipe ends with a band saw and beveling the

p!pe end with an automated machine. The same two workers had conducted similar

work in the area the previous several days leading up to November 21,1997. While the

pipefitters were setting up for their work, other craft workers were also _in the room

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discussing their proposed activities with a radiation protection technician (RPT). The

RPT observed the workers in the rmm but failed to question their planned activities.

After the RPT and other craft workers left the area, the pipefitters commenced the pipe

cutting ard grinding activities. Workers were not required to wear respirators during the

work activity based on the results of an ALARA/ total effective dose equivalent (TEDE)

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review conducted earlier in the week. Proper protective clothing was worn by the

workers during the course of the work on November 21,1997, as required by the RWP.

After completing the work in about 30 to 45 minutes, both pipefitters alarmed the

personnel contamination monitors, prompting an investigation by the licensee. Small

quantities of contamination were detected on the face and neck areas of both workers.

One worker was successfully decontaminated while a whole body count (WBC) on the

other worker revealed a smallintake of cobalt-60 and manganese 54, equating to less

than one percent of the most limiting annuallimit of intake (All) specified in 10 CFR Part

20. On the following day, the licensee performed an additional WBC, which indicated a

minimal intake of radioactive material, and determined the worker'a internal dose to be

below the licensee's threshold for assignment of dose.

As a result of the incident, the licensee halted work on the RWCU project for r 7arly two

days while an investigation was completed. The inspector's independent review of the

incident agreed with the licensee's conclusion that the problem was caused by

inadequate communication between the workers and the RP staff, poor coverage by the

RPTs responsible for job oversight and poor radiation worker practices. MoNover, the

same two workers had successfully completed similar pipe cutting and beveling

activities in the valve room on several occasions earlier in the week, and may have

become complacent with the work.

The RWP for the work activity (RWP No. 970325) required that the HP staff be

contacted before cutting, grinding or welding take place. In this incident, the workers

failed to notify radiation protection prior to the cutting and grinding work. This failure

limited the RP staff's ability to identify any new radiological hazards and to identify

additional protective measures, which may have prevented this incident.

During the work stoppage, all workers involved in activities under RWP No. 970325 met

to discuss the incident and its causes. Other corrective actions included the

development of a checklist for ua as a guideline to assure that important information is

discussed during shift pre-job meetings, and the expansion of radiation protection

participation in the pre job meetings, including work crew specific break-out sessions

with the RPTs providing coverage for the pending shift work.

Incident No. 2

On the aftemoon of December 1,1997, a contract worker was externally contaminated

while performing tack welding on a valve in the RWCU valve room. The two person

work crew failed to notify iadiation protec':on prior to initiating the welding activities, as

required by the RWP for the job (RWP No. 970325). The RP staff detected and

removed a small quantity of external contamination from the face of the welder. A

helper who assisted the welder was not contaminated.

All workers involved with the RWCU project had attended the morning shift briefing on

December 1,1997, and work crew break-out sessions which were held with RP staff as

part of the effort to improve communications resulting from the November 21,1997

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incident. During the break-out session, the work crew was reminded to contact RP

personnel at the control point desk prior to flapping and welding. At about 1:00 p.m., the

crew notified radiation protection personnel at the control point desk that they were

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prepared to complete final weld preparations. They were then assisted by an RPT in

setting-up the work area. Pipe flapping and cleaning operations were successfully

completed about 2:30 p.m. Welding was to take place after completion of the flapping

and an air sampler was positioned in the work area by RP staff in preparation for this

evolution. The welding, however, was delayed for about two hours while other craft

workers removed scaffolding from the area and a quality control inspection was

performed of the work site. During the two hour delay, RPTs conducted hourly work site

inspections and confirmed that no work was taking place. However, the welding crew

returned to the work area and reportedly were asked by the quality control inspector to

fit-up and tack weld the valve in place. Moments later, an RPT at the control point desk

observed an arc strike on the video monitor, which was positioned to observe work

activities in the room. Another RPT responded, observed the welding in progress, and

stopped the work.

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Following this incident, the licensee halted work on the RWCU project for approximately

eight hours while an investigation took place. The licensee's staff attributed the problem

to inadequate use of the stop/think/act/ review (STAR) process by the work crew and

poor radiation worker practices. Since the welder's facial contamination levels were

consistent with the general area levels and not the higher contamination levels inside

the valve piping, the RP department concluded that the welder likely brushed his face

with a contaminated, gloved hand. The licensee's investigation also concluded that the

welding crew was aware of the expectation to contact radiation protection prior to

initiating the welding. However, in the crews haste to complete the job prior to the end

of their shift, the workers forgot to make the notification to the RP staff as required.

Licensee corrective actions included termination of the welder and helper and

communication of the event to all appropriate contractor personnel.

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

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

LAP-100-22 (Revision No. 20), " Radiation Work Permit (RWP) Program," requires, in

part, that workers comply with the requirements of the RWP and all associated

documents. The failure of the workers to notify RP before conducting pipe cutting and

grinding on November 21,1997, and welding on December 1,1997, as required by

RWP No. 970325, are examples of a violation of TS 6.2(B) (Violation Nos.

50-373/97021-01(DRS); 50-374/97021-01(DRS)).

c. Conclusions

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Radiation worker performance and radiation protection oversight of contractor activities

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for the RWCU system project was generally good; however, isolated problems were

identified. Specifically, on two occasions, contract workers failed to contact RP staff

prior to initiating certain potential high risk evolutions, as specified in the RWP governing

the work activity. One violation was identified with two examples for failure to follow

station procedures as required by Technical Specifications.

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V. Management Meetings -

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X1.- ' Exit Meeting Summary .

The lnspector presented the preliminary litspection results to members of licenseo management

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on December.16,1997. The licensee acknowledged the findings presented and did not identify

, any of the documents reviewed as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED

B Blaine, Source Term Coordinator

F. Dacimo, Plant General Manager .

. N.- Hightower, Radiation Protection Manager

C. Kelley, Lead Health Physicist Operational ~

S. Kovail, Lead Health Physicist Technical

H. Pontious, Regulatory Assurance

INSPECTION PROCEDURES USED *

IP 83750 - Occupational Radiation Exposure

ITEMS OPENED AND CLOSED

Qoened

50-373/374-97021-01 VIO Failure to contact radiation protection prior to performing

potential high risk evolutions.

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LIST OF ACRONYMS USED

ALARA As-Low-As-Reasonably-Achievable

Ml Annual Limit of !ntake

DAC Derived Air Concentration

RP Radiation Protection

RPA Radiologically Protected Area

RPT Radiation Protection Technician

RWCU Reactor Water Cleanup

RWP Radiation Work Permit

TS Technical Specification

WBC Whole Body Count

PARTIAL LIST OF 00CUMENTS REVIEWED

ALARA Plan For RWCU Modifications

RWP No. 970325 (Rev 3) Set-up, Remove Old Pumps / Piping, Reinstall New Design

Pumps / Pipes and Clean-up of Area

RWP No. 970326 (Rev 1) Remove Pipes and Vsives as Required

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PlF No. L1997-07484 and Poor Radiation Worker Practice on RWCU Project by

Prompt Investigation Report Construction Not Following RP instruction

PlF No. L1997-07351 and Contaminated Workers on RWCU Project

Prompt investigation Report

Station Procedure No. LAP-100-22 (Rev 20) " Radiation Work Permit Program'

Station Procedure No. LAP-900-26 (Rev 20) " Control of Materials for Conditional or

Unconditional Release From Radiologically

Posted Areas'

Station Procedure No. LAP-2200-7 (Rev 0) "ALARA Plan"

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