IR 05000254/1987005

Insp Repts 50-254/87-05 & 50-265/87-05 on 870303-06.No Violations or Deviations Noted.Major Areas Inspected: Operational Radiation Protection Program,Including Organization & Mgt Controls & Exposure Controls

ML20205A925
Person / Time
Site:	Quad Cities
Issue date:	03/19/1987
From:	Greger L, Miller D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20205A901	List: IR 05000254/1987005 ML20205A897
References
50-254-87-05, 50-254-87-5, 50-265-87-05, 50-265-87-5, NUDOCS 8703270518
Download: ML20205A925 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-254/87005(DRSS);50-265/87005(DRSS)

Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Quad Cities Nuclear Power Station, Units 1 and 2 Inspection At: Quad Cities, Cordova, Illinois Inspection Conducted: March 3-6, 1987 h $ h Yh 5 7 Inspector: D. E. Miller Date

- ob 4 Approved By: L. R. Greger, Chief Facilities Radiation Protection Da te'

/fh7 Section Inspection Summary Inspection on March 3-6, 1987 (Reports No. 50-254/87005(DRSS);

No. 50-265/87005(DRSS))

Areas Inspected: Routine, unannounced inspection of the licensee's operational radiation protection program including organization and management controls, internal and external exposure controls, control of radioactive materials and contamination,' audits, and ALARA. Also reviewed were corrective actions for previous inspection finding Results: No violations or deviations were identifie PDR ADOCK 05000254 G PDR

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DETAILS 1. Persons Contacted

• R. Bax, Station Manager D. Gibson, QA Supervisor

• D. Hoogheem, Regulatory Compliance Representative

• S. Horvath, Lead Health Physicist J. Piercy, ALARA Coordinator

• R. Roby, Services Superintendent

• G. Spedl, Assistant Superintendent, Technical Services

• J. Sirovy, Rad / Chem Supervisor

• A. Morrangiello, NRC Resident Inspector The inspector also contacted health physicists, rad / chem foremen, engineering assistants, and members of the technical staf * Denotes those present at the exit meetin . General This. inspection, which began at 9:30 a.m. on March 3, 1987, was conducted to examine the licensee's operational radiation protection program. Also reviewed were corrective actions for past inspection findings. Tours of radiologically controlled areas were made; posting, access controls, contamination controls; and housekeeping appear good. In addition to contamination control and appearance improvements discussed in this report,majorappearanceimprovementshavebeenmadetothesit . Licensee Actions on Previous Inspection Findings (Closed) Open Items (254/86006-02 and 254/86006-03): Corrective actions for IRM-17 event on March 27, 1986. The corrective actions are discussed in Section 11, 4. Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection program, including changes in the organizational structure and staffing, effectiveness of procedures and other management technigues used to implement these programs experience concerningself-identificationandcorrectionofprogramimplementation weaknesses, and effectiveness of audits of these program Audits are discussed in Section Since previously reported in Inspection Reports No. 50 254/85019; 50-265/85021, several organizational changes have been made, including:

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• The Lead Health Physicist has been temporarily assigned to attend reactor operator training. He remains permanently assigned to the Rad / Chem Departmen * A health physicist has been promoted to Lead Health Physicis * A health physicist has been transferred to Byron Statio * A health physicist has been transferred to CECO headquarter * A recent graduate has been hired as a health physicis * Two rad / chem technicians have been promoted to newly created engineering assistant position The current Lead Health Physicist meets the r.quirements for Radiation Protection Manager (RPM) specified in Regulatory Guide 1.8; he is assigned as RPM. No regulatory requirements exist for other positions involved in the above organizational change Currently, four health physicists report to the Lead Health Physicis Some paperwork tasks previously performed by health physicists are now performed by engineering assistants. The licensee is redistributing task assignments so that health physicists can spend more time following radiological work being performed and planned, and can perform more indepth studies related to identified problem area During this inspection, the inspector observed that health physicists are spending an increased portion of their working hours in direct observation and oversight of radiological wor The personnel changes have not dagraded the radiation protection progra No violations or deviations were identifie . External Exposure Control and Personnel Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management technicues used to implement these programs and experience concerning self-icentification and correction of program implementation weaknesse Audits are discussed in Section The external exposure measurement and control program consists of whole body monitoring using thermoluminescent dosimeters (TLDs),. extremity monitoring using film ring badges, self-reading dosimeters.(SRDs), direct radiation surveys, radiation work permits, administrative dose limits, and a radiation dose recording syste *

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The inspector selectively reviewed direct radiation survey records, radiation work permits, ALARA review records, and dosimetry reports for selected tasks performed during the last refueling outage. No problems not previously identified by the licensee were found. Hot particles are discussed in Section The inspector selectively reviewed exposure records including TLD and self-reading dosimetry results. The records indicate that no person exceeded regulatory limits. The occu)ational external dose for the station in 1986 was 949 person rem; t1e established goal for 1986 was 1120 person-rem. The goal for 1987 is 700 person-re An overall downward trend in station person-rem began in 1981. Station person-rem in 1986 was the lowest since 1974 (commercial operation began in 1972). The continued downward trend is apparently the result of an aggressive ALARA program which has strong management support and backing. The ALARA program is discussed in Section No violations or deviations were identifie . Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; required records, reports, and notifications, and effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section The licensee's program for controlling internal exposures includes the use of protective clothing, respirators and equipment, and control of surface and airborne radioactivity. A selected review of air sample and survey results was made. No significant problems were note Whole body count data was reviewed for counts performed during the period September 1986 through January 1987 on company and contractor personne Several followup counts were performed on persons who showed elevated initial counts. Followup counting was adequate to verify that the 40 MPC-hour control measure was not exceede No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey

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data, effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses. Audits are discussed in Section The licensee has instituted a contamination reclamation progra Contaminated areas are being cleaned to " clean" status or the contamination concentration reduced. Several areas are being painted to improve the appearance of the facility and to make future decontamination efforts easier. Concrete block frisking booths have been constructed in various building locations; the background radiation levels within the booths appears low enough to permit proper friskin The licensee has increased the number and location of whole body friskers. In addition, if possible, the licensee places a whole body frisker near work locations where extensive temporary work on highly radioactive systems or areas is undertake The licensee does not segregate )otentially clean from potentially contaminated refur material witlin controlled areas. All refuse material is packaged for radwaste burial. Efforts have been directed at not taking unneeded material into controlled areas. The licensee is now gathering materials and equipment to initiate a segregation and monitoring 3rogram for potentially clean materials. No firm implementation date has

)een establishe The licensee is experiencing incidents where hot particles are detected on the skin or )ersonal clothing of workers. The occurrences are infrequent, wit 1 seven particles detected in the ten-month period ending January 31, 1987. The particles are recovered and analyzed for isotopic content when possible. The analysed particles show Co-60 to be the predominant isotope; the particles were about 0.1 microcuries or less in activity. The licensee investigates each event and calculates skin doses. According to the licensee's calculations, no 10 CFR 20.101 limits were exceeded. The licensee has been unable to positively identify the source of the hot particles or the mechanism of transfer to the worker's skin or personal clothing. The licensee is investigating operation of the protective clothing laundry to see if improvements in laundering techniques and monitoring ca) abilities should be made. Also, the licensee continues to seek tie source of the particle There were 394 personal contamination incidents in 1986 that met INP0 reporting criteria. Twenty-two percent of the incidents involved the skin, 70 percent )ersonal clothing, and eight percent both skin and personal clotling. The eight skin contamination incidents that intolved hot particles are discussed above. Several skin contaminations that involved the face were identified; followup whole body counts were performed on these individuals. The licensee maintains records of each contamination incident, followup investigations, associated whole body counts, and any associated dose calculations. No problems were noted during the inspector's review of these records. The licensee's proposed goal for total reportable personal contamination events in 1987 is 30 .

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Management support for the contamination control and contamination reduction programs appears goo No violations or deviations were identifie . Audits The inspector reviewed onsite and offsite audits of the radiation protection program conducted since May 1986. Extent of audits, qualifications of auditors, and adequacy of corrective actions were reviewe One onsite quality assurance audit was perform: the audit was an in-depth review of the radiation protection department's compliance with established procedures with major emphasis placed on the ALARA 3rogra One open item and five observations resulted from the audit. Tie open item concerned needed revision of the ALARA manual to reflect job title and assignment changes; this item is not yet corrected and reviewed. The observations concern mainly minor, non-repetitive, procedural violations of which all but one have since been closed during QA auditor followu In addition to routine audits, the lice isee conducts audits of licensee actions taken to implement commitments aiade to the NRC; an audit of actions

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taken to implement commitments made ccicerning the IRM-17 event was performe One offsite quality assurance audit .as performed: the audit included selected radiation protection subjects and related technical specification surveillance requirements. No significant findings resulte In addition to formal audits, the licensee's quality assurance group performed and documented surveillances of radiological controls for work in the controlled area, compliance with RWP requirements and associated records, in-de housekeeping; suchpth reviews of surveillances areselected performedrecords and per at least once reports, month.and plant These surveillances appear valuable; several problems were identified and correcte The extent of audits, qualifications of auditors, and adequacy of corrective acticns appear goo No violations or deviations were identifie . ALARA The ALARA Inspection aspects Reports of planning /86004; 50-265/86004.and No. 50-264 preparation for ou The ALARA program remains essentially as previously describe Enhanced efforts are being made in the following areas:

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• More direct oversight of radiological work is being performed by health physicists and radiation protection foreme * Greaterattentionisbeinggiventoplanningdetails, pre-job discussions with persons who perform work and provide monitoring, andpost-jobcritique * ALARA reviews are being performed for selected tasks with projected total doses of less than 10 person-rem. At 10 person-rem or greater, the reviews are require * Personal dose cards are being routinely reviewed to identify unexpected doses which may indicate changing conditions or improper work practice * Use of automatic welding equipment to perform future recirculating and cleanup system weld overlays is being investigate The licensee normally performs recirculating system decontaminations at the beginning of refueling and maintenance outages even though cost benefit analyses may not conclusively show sufficient person-rem benefi The overall downward trend in station person-rem discussed in Section 5, the manpower and effort expended in the ALARA program, and the efforts taken to reduce contamination and direct radiation levels at the station are evidence of strong management support for the station's ALARA progra No violations or deviations were identifie . Radiation Occurrence Reports

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Radiation Occurrence Reports (R0Rs) for the period April 1986 through January 1987 were reviewe There were 25 RORs written during this period. No repetitive violations or incidents were a) parent except for seven personal contamination hot particle incidents w1ich are discussed in Section The-licensee investigates each ROR and assembles a package of pertinent data concerning the violation or incident. Each investigation goal is to establish root cause(s) and effect appropriate corrective actions to prevent recurrence. The investigations appear good and meet the intended goals. The investigation packages are complete and comprehensiv No inspector identified violations or deviations were foun . Corrective Actions for IRM-17 Removal Incident

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In response to violation 254/86006-01 concerning removal of IRM-17 on March 27, 1986 the licensee committed to perform the corrective actions listedinSectIon8and9ofInspectionReportNo. 50-254/86008(DRSS).

The licensee has implemented the corrective action The corrective actions are summarized in the following paragraph . t ThelicenseehasrevisedProcedureNo.QFP600-3"IRMandSRMHandling" and established Procedure No. QRP 1610-7 "Radiolog"ical Protection Requirements for SRM and IRM Detector Replacemen Included in the new and revised procedures are the following corrective actions for the IRM removal even * To^ improve communications, the drywell fans are to be shut off or

, amplifying devices are to be worn in respirators while performing

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! * - The RCT assigned to the removal task must be appropriately trained and not assigned additional tasks while monitoring an IRM and SRM removal.

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l * A fuel handling foreman must be present in the drywell during IRM or l SRM removals to provide management direction and supervision.

l * All personnel not directly involved in pulling the detector from the

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guide tube must be stationed in the anteroom when efforts to pull the detector begin, unless directed otherwise by the fuel handling forema * Several specific handling recuirements and dose rate action levels (which require regrouping anc further planning) have been added.

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ThelicenseehasestablishedastandardizedRadiationWorkPermit(RWP)

and a history file for IRM and SRM removal The RWP requires that for all removals:

l * An ALARA review be 3erformed.

* A planning meeting 3e held.

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• Upper dose rate limit be set.

l * A review of the history file be performed.

l * The operational history of the detector to be removed be obtained so that abnormal conditions can be anticipated for detectors that had abnormal historie The RCT training guide for IRM/SRM removals has been revised to include additional information and precautions to preclude future incident '

Also, tailgata sessions were held with RCTs and fuel handling personnel to further instruct them concerning contact dose rates and reduction of dose rates with distanc The licensee has contacted INP0 and General Electric Company representatives to seek information concerning history of problems with detector removals or removal equipmen Little information appears l available. The licensee is continuing to seek available information.

l The licensee has reinstructed RCTs concerning their authority and l responsibility to terminate work when unpredicted radiological conditions

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are encountered that could result in unplanned internal or external exposures.

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The licensee's corrective the commitment actions To preclude were future appropriate,isions procedural rev which couldtimely, and add alter the corrective actions, the licensee has included the NRC open item number in the appropriate procedural paragraph No additional concerns were identifie No violations or deviations were identifie . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on March 6, 1987. The inspector discussed the scope and findings of the inspection. The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee identified no such documents / processes as proprietar .