IR 05000373/1997019

Insp Repts 50-373/97-19 & 50-374/97-19 on 971103-07.No Violations Noted.Major Areas Inspected:Review of ALARA Controls for Ongoing Unit 1 Forced Outage & Implementation of Respiratory Protection & Radioactive Programs

ML20203D349
Person / Time
Site:	LaSalle
Issue date:	12/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203D333	List: IR 05000373/1997019 ML20203D328
References
50-373-97-19, 50-374-97-19, NUDOCS 9712160169
Download: ML20203D349 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket Nos: 50-373;50 374 License Nos: NPF 11; NPF 18 Reports No: 50-373/97019(DRS); 50 374/97019(DRS)

Licensee: Commonwealth Edison Company Facility- LaSalle County Nuclear Power Station Units 1 and 2 Location: 2601 North 21st Road Marseilles, IL 61341

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Dates: November 3-7,1997 Inspectors: W. Slawinski, Senior Radiation Specialist N. Shah. Radiation Specialist W. G. West, Radiation Specialist Approved by: G. L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety

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9712160169 971204 PDR ADOCK 05000373 0 PDR

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EXECUTIVE SUMMARY LaSalle County Nuclear Power Plant, Units 1 and 2 NRC Inspection Reports 50-373/97019; 50 374/97019 This inspection included a review of the as-low-as-reasonably achievable (ALARA) controls for the ongoing Unit i forced outage and the implementation of the respiratory protection and radioactive contamination monitoring program * Ongoing engineering evaluations to address station conformance to the design-basis continued to result in emergent work and an associated increase in station dos Although the ALARA controls for these activities were good, there continued to be examples where problems with the station work planning and scheduling process had a negative impact on station dose (Section R1,1).

. The ALARA planning and controls for the removal of the intermediate range monitors / source range monitors (IRMs/SRMs) were good, with improvement notsJ in worker participation in the planning process. Although the root cause of a previous violation occurring during the Unit 2 refueling outage was effectively addressed, a recurrent problem was identified with the proper use of the station problem identification and resolution process (Section R1.2).

. Effective ALARA controls were used during the emergency core cooling system (ECCS)

strainer replacement with appropriate consideration given to controlling diving activities and hot particles (Section R1.3).

. Implementation of the license's radiological reF? l ratory Control program Was acceptabl Deficiencies in the respiratory protection training program were identified along with problems in the quality of the semi-annual surveillance checks of stored respirator Some examples of nrocedural deficiencies and the need for additional procedural guidance were also identified (Section R2.1).

. Implementation of the calibration and routine surveillance programs for the whole body contamination and small arucle monitors were good. Monitor alarms were set at appropriate levels and acceptable instrument sensitivity and alarm operability was demonstrated. Worker compliance with monitor use requirements was good (Section R2.2).

• Radiological controls and radworker performance were observed to be generally good during plant walkdowns. One weakness with contamination control was identified while observing station laborer activities (Section R4.1),

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Reoort Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Review of Radioloalcal Performance and ALARA Controls y Insgection Scong The inspectors reviewed the stat'on's radiological performance and the ALARA planning '

ard controls for the ongoing Unit 1 forced outage. The inspection consisted of interviews with workers, attendance at ALARA briefings, observations of activities in progress and a review of applicable documentation (i.e., Radiation Work Permits (RWPs), ALARA plans, etc). Observations and Findinah The station was shutdown throughout 1997 in order to address engineering issues '

related to the plant design basis, For most of this period, activities were of a routine

' :ture with the only significant exposure resulting from Unit 2 refueling outage work Mding in the first quarter of 1R7, Prior to the start of the Unit 1 outage, about 230 rem was accrued by the station For the remainder of the year, the station was addressing issues identified by the engineering reviews. This work was estimated to account for an additional 230 rem, but may increase as more work was identifie As of November 7,1997, about 30% (65 rem) of this work had been completed. The nost significant of these activities included: Reactor Water Cleanup (RWCU)

modification and valve work; Residual Heat Removal (RHR) System valve work; drywell chiller modification and relief valve work; safety relief and motor operated (SRV and MOV) valve work; intermediate range and source range monitor (IRM and SRM) work; and replacement of the emergency core cooling system (ECCS) suction strainer Sections R1.2 and R1.3 discuss the IRM/SRM and ECCS work in greater detai The RWCU modification had the singlo greatest impact on station dose. The existing scope consistad of: replacing the existing three recirculation pumps; changing the piping ccnfiguration to take suction from the hot leg of the reactor vessel, rather than the cold leg, to prevent volding of the heat exchanger; and addressing recurrent valve problems. Essentially, the RWCU syste,n was to se restored to that conceptualized in the original reactor design. Because the work was stillin the engineering phase, it had a high probability of exceeding the current 76 rem estimate, owi. g to scope growt During plant walkdowns, the inspectors observed continued good use of ALARA controls such as remote cameras and dosimetry, lead shielding and hydrotazing of high dose rate piping. Workers were observed to be aware of these initiatives, including 6mphasizing smal'er crew sizes and utilizing low dose areas. For those jobs requiring dgnificant engineering (primarily the RWCU and drywell chiller modifications), the

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! Inspectors noted that iho respective RP planners had developed ALARA initiatives to

! reduce future station dose. For example, in both modifications, the associated piplog was designed to minimize the number of crud traps (i.e., sharp piping bends) and the use of high cobalt containing components. For the RWCU modification, the new pumps were being installed in a vertical configuration partially to make future maintenance activities easie However, there continued to be examples where problems with the station work planning and scheduling process had a negative impact on station dose. For example, owing to several roovaluations of the scope of the RWCU modifications, a propostsd chemical decontamination of the RWCU system was canceled, as it could not be performed within the existing outage schedule. This initiative could have saved A calculated 66 rom based on the existing scope. Another example, was the failure of the operations department to adequately drain associated piping during work on the *A*

RHR 1E12 F003 valvo. This resulted from a failure of the operations group to recognize, during the job planning process, that the existing procedure for draining the RHR system would not affect this valve. These and other similar issues were being addressed by the licensee as outage lessons leame For those activities reviewed, the inspectors verified that the ALARA plans were performod in accordance with station procedure no. LAP 2200 7 (revision (rev.) 0)

• ALARA Plan," including review, as applicable, by the station ALARA committee, Conclusions Ongoin0 engineering evaluations to address station conformance to the design-basis continued to result in emergent work and an associated increase in station dos Although the ALARA controls for these activities were good, there continued to be examples where problems with the station work planning and scheduling process had a negative impact on station dos R1.2 ObscIyations of IRM/SRM Removal lasocction Scoge The inspectors reviewed the removal of IRMs/SRMs, focusing on those ALARA contrcls documented in NRC Information Notice (IN) no. 88-63 and associated supplement The inspection consisted of interviews with workers, a review of applicable documents, attendance at ALARA briefings, and observations of IRM/SRM removal on November 3 and 6,1997. Included in this review was a follow-up of Violation no. 50 373/374 96014-01, regarding an inadequate survey during similar Unit 2 refueling outage wor Qhservations and Findinas The job ccope consisted of removing and replacing seven IRMs/SRMs. The expected dose was about 12 rem and as of November 6,1997, about 10 rem was accrued with 95% of the re. ope completed. The ALARA plan addressed the issues documented in IN 4 -

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no. 88-63 and, the failure to adequately determine the detectors' irradiation history, which resulted in the inadequate evaluation violation in 199 During the ALARA briefings, the inspectors observed good worker participation including questioning of the RP department controls. In similar prior briefings during the Unit 2 refueling outage, the inspectors had noted that workers were less participatory and did not question the RP department. The inspectors observed that RP technicians were appropriately monitoring dose rates while the IRM/SRMs were being removed and that workers remained cognizant of the contingency actions discussed in the Al. ARA briefing. Although not considered ALARA, respirators were ust.J dunng this job owing to industrial safety concerns. The inspectors verified that those workers assigned respirators had received the necessary training and fit testing, and were aware of their proper us However, the inspectors identified a weakness with the licensee's follow-up actions for an unexpected occurrence during the job. Specifically, while removing the *C" IRM on October 26,1997, highar than expected dose rates (20 rem per hour (rem /hr) at contact) were encountered prompting ctoppage of the job and evacuation of the undervessel area. The expected dose rates were 50100 millirem (mrem)/hr (contact),

given that the IRM had been in storage (i.e out of the core) for several months. The cause of the higher dose rates was being evaluated, but was believed to be activated corrosion products on the IRM cabling from reactor coolant leakage. Although the RP staff halted further removal of IRMs until more stringent ALARA controls were established, the event was not documented in a station problem identification for While not specifically a violation, the failure to use the formal problem identification and resolution procers was a contributing cause to violation no. 50-373/374-96014-01. At the exit meeting. station management agreed with the inspectors' conclusions and were planning to evaluate the issue, ConcluS1001 The ALARA planning and controls for the removal of IRMs/SRMs were good, with improvement noted in worker participation and with the planning process. Although the root cause of a previous violation occurring during the Unit 2 refueling outage was effectively addressed, a recurrent problem was identified with the proper use of the station problem identification and resolution proces R1.3 ECCS Suction Strainer Work Insacrit003r&no The inspectors reviewed the perioimance of the ECCS suction strainer replacement work. The insnection consisted of interviews with workers, a review of applicable documentation and observations of work. Because the work involved extensive diving operations and had a high probability of hot particle intrusion, the implementation of station procedure nos. LRP 2100-12 (rev. 3) * Radiation Protection Practices for Divers

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used for Underwater Maintenance or inspections * and LRP 1470-5 (rev 5) * Hot Pa ticle Control' were specifically reviewe Observations and Findinoa The ECCS suction strainer replacement job involved the replacement of six suction strainers in the Unit 1 suppression pool. This replacement addressed strainer clogging issues discussed NRC Bulletin no. 96-03 and was the first such replacement for a Mark 11 type bolling water reactor including the strainer replacement, the job entailed destudging of the suppression pool walls and floor to reduce area dose rates. There were five divers (two in the pool at any o 1e time) assigned to the activity and the job dose goal was 8.5 ro Destudging was performed using two diver held vacuum hose units connected to an underwater pump with in line filtration. This manual desludging was considered more effective than previous, similar work using robotics. Because of the high dose hazards associated with the filters, specific ALARA controls were established for the filter changeouts, such as changing the filters when contact dose rates exceeded 10 rem /hr (contact) on the filters prior to replacement. The old filters were stored in designated storage areas until dose rates er.ceeded a specified va!ue. According to the RP staff, filters were changed out, depending on volume flow rate, between overy six hours to weekl By November 6,1997,40% of the work was completed with about 3 rem expende The inspectors observed that the provisions of LRP nos. 2100-12 and 1470-5 were appropriately implemented. Specifically, the inspectors observed the use of dosimetry multibadging, remote communication, cameras and teledosimetry, underwater dose monitoring, and the set up of a hot particle control zone within the larger contaminated area. These controls were developed during an August 1997, two day simulation involving two of the assigned divers. Typical diver dose rates ranged between 30 mrem /hr (stop work if 21.25 rem /hr) for the whole body and 3.9 rem /hr for the extremities (during the filter changeouts).

The inspectors observed good job coverage and ALARA controls by the RP technicians monitoring the job, in particular, after an intermittent problem occurred with communications between the divers' dosimeters and the remote computer readout at the dive station, the 'echnicians entered the contingency plan for this occurrence,

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consisting of more frequently monitoring the divers' dosimetry readouts and pool location. Additionally, the technicians appropriately considered ALARA controls during the vacuum filter change out, by having the divers use rope to maneuver the filters and informing them of their proximity to the filters. Overall, the RP controls and planning for this job were considered good, Conclusions Effective ALARA controls were used during the ECCS strainer replacement with appropriate consideration given to controlling diving activities and hot particle I

- - _ _ _ _ _ _ _ _ _ _ _ R2 Status of RP&C Facilities and Equipment R2.1 Ecsolratorv Protection Program .d 29 lataection Scoce @)

The inspectors reviewed the radiological respiratory control program including respiratory user training, medical certification and fit testing, and the selection, use and maintenance of respiratory protection equipment. The inspection focused on air

{G purifying respiratory protection equipment issued for routine radiological concerns and excluded self contained breathing apparatuses (SCBAs) used for emergencies. The following procedures were reviewed:

. LRP 55001 (rev. 3), * Radiological Respiratory Control Program;"

. LRP 1310-1 (rev. 8), * Maintenance and Care of Respiratory Protective Equipment;"

. LRP 131011 (rev. 5), *Ruspiratory Protective Equipment Quality Inspections;"

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. l.RP 131019 (rev. 2), " Operation of the Model 8010 TSI Porta cour1 Respiratory Fit Tester." Qbiervations and Findings Respiratory protection training lesson plans were of sufficient depth and scope to provide workers the necessary information to safely use this equipment. Material provided to the students included policy statements on the use of process or other engineering controls and the routine /non routine use of respirators. However, the inspectors identified a deficiency with the respiratory training in that the trainees were not fully advised when they may seek relief during respirator use. The licensee planned to revise the lesson plans to address this deficienc Quantitative fit testing was performed by the radiation protection staff using a commercially available fit testing device and testing was conducted consistent with Industry practice. Soft or gas permeable contact lenses were allowed with respiratory protection equipment, provided the user documented as part of the fit test procedure that they had successfully morn the lenses for at least 30-days. Those fit test records reviewed by the inspectors documented that the workers had successfully completed the required training, that initial physician certification was on file and as applicable, that they had successfully worn soft or gas permeable contact lenses for 30 day The inspectors discussed respirator issuance, tracking, cleaning and quality control with RP personnel. Adequate mechanisms were in place to ensure that prior to respirator issuance workers had completed the required training, medical certification and fit tutin The licensee completed a semi-annual quality surveillance of respiratory protection equipment stored in the Turbine Building, Technical and Operational Support Centers,

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and General Site Emergency Program boxes on October 6,1997. This chock, which.

Identified no problems, was rquired by prooHjure no. LRP 131011 to ensure the  !

integrity of respirator face pieces, valves, seals, and the condition of lenses, straps,  !

o clamps and connections. However, the inspectors found several full face respirators in l

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poor condition including one with a deteriorated valve gasket and another with a wom -

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facial seal surface in the Turbine Building storage area. The licensee planned to rept!r/ replace the affected respirators and to reinspect the storage areas.

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During a review of procedures, the inspectors identified some minor problems and

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inconsistencies. For example, LRP 55001 did not provide clear direction for the frequency of medical re evaluations for respirator users. This procedure also contained incorrect instructions or needed additional guidance for performing respiratory ALARA reviews. For example, steps F.2 (c,d and h) incorrectly referenced its attached flow- I chart. Also of note, step F.2(g) required that process and/or other engineering controls be evaluated prior to issuing respirators, but did not specify how these evaluations were to be performed or documented. For example, several of those jobs discussod in section R1.1 were evaluated for process and/or engineering controls, but the evaluation was not documented. The licensee acknowledged the proceduralinconsistencies and '

was planning to revise the procedure, Conclusions implementation of the' license's radiological respiratory control program was acceptabl Deficiencies in the respiratory protection training program were identified along with problems in the qualty of the semi annual surveillance checks of stored respirator Some examples of procedural deficiencies and the need for additional procedural guidance were also identifie R2.2 Personnel and Small Article Contamination Monitorina Eauloment insoection Scoce The inspectors reviewed the operability of the whole body contamination monitors located at tho egress from the radiologically protected area (RPA) and at the main access facility (gatehouse). The review included a walkdown of the whole body

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monitors, observations of use, and a review of calibration procedures, monitor operability history and surveillance test results for 1997. The inspection also reviewed the operability of the small article monitors (SAMs) used for surveying small articles and +

tools leaving the RPA Specific procedures reviewed, included:

• LRP 5822-10 (rev,0)," Calibration of PM 7s;"

• LRP 5822-41 (rev.1), "PCM 2 Calibration;" and e LRP 5822 7 (rev. 2), " Calibration of IPMs."

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b. Observations and Findinos The whole body monitors (RPA and gatehouse) and SAMs were calibrated at six month intervals using cobalt-60 sources traceable to the NationalInstitut if Standards and Testing (NIST). Detector efficiency for cobalt-60 response rangec n 10-20 percent for the RPA monitors and 17 20 percent for the SAMs. Alarm setpe... were 5,000 disintegrations per minute (dpm) for both the RPA monitors and the SAMs, and 50 nanoCuries for the gatehouse monitors. Alarm functional checks were oerformed three times a week for the RPA monitors using a technetium-99 source ranging in activity from 7500-10,000 dpm, and daily for the SAMs using a 5,000 dpm smear of mixed Isotope Functional checks were also performed daily for the gatehouse monitors, but using a 125 nanoCurie cobalt-60 source. This was discus:ed with the RP staff, who agreed that using a source of similar activity to the gatehouse monitor alarm setpoint would be a more appropriate functional chec The inspectors verified that the detector efficiency and alarm set point calculations were accurate for the most recent calibration of selected whole body contamination monitors and SAMs. The respective calibration and surveillance test methodologies were technically sound and appropriately implemented. At inspector request, the licensee demonstrated the alarm check procedure for one of the RPA whole body contamination monitors. The check employed use of a nominal 7900 dpm technetium-99 source, and activated foot, hand and chest array detector alarms as require Because the gatehouse monitors were located in an area not routinely occupied by plant security personnel, a camera having audio capability, continuously monitored this location. The camera signal was sent to a television screen located at the main RP desk in the Service Building. All personnel were required to use the gatehouse monitors prior to leaving the plant, and RP personnel periodically venfied that this was occurring via the remote camera. However, RP personnel were not required to continuously monitor the television nor were security guards, stationed inside the gatehouse, required to respor"J to a monitor alarm. As stated in station procedures and as directed by labels affixed to the gatehouse monitors, workers receiving an alarm were required to remain in the area and contact RP for assistance. Based on selected RP and security staff interviews and observations of portal monitor usage, the inspectors determined that worker compliance with these requirements was good, c. Conclusl0DS Implemcntation of the calibration and routine surveillance programs for the whole body contamination and small article monitors were good Monitor alarms were set at appropriato levels and acceptable instrument sensitivity and alarm operability was demonstrated. Worker compliance with monitor use requirements was goo .. -_ - - - - . - -- - _ _ _ _ - - - - _ . - _ _ . - _ _ _

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R4 Staff Knowledge and Performance in RP&C R Plant Walkdown and Observations of Work The inspector performed a walkdown of the Units 1 and 2 Turbine and Reactor Buildings and observed the implementation of radiological controls and radworker performanc There were no significant problems observed with radiological controls (i.e., postings, labelings, etc), radiological housekeeping or radworker practices. Workers generally used good contamination control practices (such as securing hoses and other items

, crossing a contaminated area boundary) and were knowledgeable of RWP and ALARA '

plan requirements. However, while observing routine station laborer activities, an inspector noted a weakness with a workers contamination control practice Specifically, after mopping in the general area (i.e., potentially contaminated) floor of the Unit 2 reactor building, a laborer, who was not wearing gloves, grasped the bottom of ,

the mop and removed it from the handle prior to storage. The inspector was concerned that this practice presented an Industrial and radiological hazard to the laborer given the potential concentration of cleaning solvents and radioactive material on the mo Licensee RP representatives agreed with the inspector's observation and planned to counsel the station laborer group.

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R8 Miscellaneous RP&C losues t

The following items identified in previous inspection reports were reviewed by the inspectors:

(Ocen) 50-373/374 96014-01: Violation for failure to perform an adequate survey prior to performing IRM/SRM removal. As discussed in section R1.2 the licensee addressed the root cause of the violation but had a recurrent issue with use of the station problem identification and resolution process. This item will remain open pending further licensee review and corrective action X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on November 7,1997. The licensee acknowledged the findings oresented and did not identify any of the documents listed as proprietary. A partiallisting of ,

those attending the exit included:

N. Hightower, Radiation Protection Manager C. Kelly, Lead Health Physicist--Operations S. Kovall, Lead Health Physicist-Technical J. Schuster, Lead Chemist S. Smith, Acting Plant Manager W. Subalusky, Site Vice-President

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i INSPECTION PROCEDURE USED IP 83750 OCCUPATIONAL RADIATION EXPOSURE

ITEMS OPENED, CLOSED OR DISCUSSED THERE WERE NO ITEMS OPENED OR CLOSED IN THIS REPORT Djasunsed 50 373/374 96014 01 VIO Failure to make an adequate survey prior to removing

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SRMs/lRMs (section R8)

LIST OF ACRONYMS USED l

'ALARA As Low As Reasonably Achievable RWP Radiation Work Permit re revision mrem /hr millirem per hour RP&C Radiation Protection and Chemistry dpm disintegrations per minute RHR Residual Heat Removal System ECCS Emergency Core Cooling System -

MOV Motor Operated Valve SRV Safety Relief Valve

, SRM/lRM Source (Intermediate) Range Monitor RWCU Reactor Water Cleanup System VIO Violation

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LIST OF DOCUMENTS REVIEWED  !

Badiation Work Permit (RWP) Nos:

NOTE: THE ALARA PLANS, RP LOGBOOK ENTRIES, ETC ASSOCIATED WITH THE SPECIFIO RWP WERE ALSO REVIEWED 971052 (rev. 0) U 1 Suppression Pool- Remove and Install New ECCS Suction Strainers 970302 (rev. 2) Disassemble / Reassemble Valve, Upgrade / Replace Reducers Downstream of Valve and Associated Work 971051 (rev. 0) Remove / Replace Various SRVs; includes Support Work 971044 (rev. 0) SRM/lRM Cable Replacement Modification and Testing (undervessel)

970145 (rev.1) Nuclear Instrumentation Cable Modification (non-undervessel)

970307 (rev.1) Disassemble and Rebuild RHR 1E12F003 A/B Valves 971017 (rev.1) Unit 1 Drywell MOV Work 971018 (rev.1) Unit 1 Reactor Building MOV Work 971005 (rev.1) Unit i Drywell Chiller Flowrate Modification 971056 (revs. 0 81) lRMs, SRMs, Low Power Range Monitors (LPRMs), and Neutron Monitoring Work Undervessel Etoblem.lden!!!ication Forms (PlFs) nos:

L1997-06787 Rework Dose from Questionable Connector Assembly for SRM and IRM Preamplifier input Cables L1997-06721 Additional Dose from Routine Maintenance on MOV 1E12 F087B December 20,1996, letter from W. Subalusky to NRC Region 111 regarding station response to Violation no. 50 373/374-96014 01 August 21,1997, minutes of Station ALARA Committee Meeting Station Procedure no. LFP 600-4 (rev. 4) " Traversing incore Probe (TIP) Removal / Disposal"

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