IR 05000254/1997009: Difference between revisions

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{{Adams
{{Adams
| number = ML20148R912
| number = ML20198F350
| issue date = 07/01/1997
| issue date = 08/07/1997
| title = Insp Repts 50-254/97-09 & 50-265/97-09 on 970609-13. Violations Noted.Major Areas Inspected:Review of Solid Radioactive Waste Processing & Shipping Program & Liquid Radwaste & Effluent Monitoring Program
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-09 & 50-265/97-09 on 970701
| author name =  
| author name = Grobe J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Kraft E
| addressee affiliation =  
| addressee affiliation = COMMONWEALTH EDISON CO.
| docket = 05000254, 05000265
| docket = 05000254, 05000265
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9707080045
| document report number = 50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9708130021
| package number = ML20148R869
| title reference date = 07-24-1997
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 18
| page count = 2
}}
}}


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August 7. 1997 Mr. Site Vice President Quad Cities Station Commonwealth Edison Company 22710 206th Avenue North Cordova, IL 61242
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli i
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Dockets No:
50 254: 50-265 Licenses No:
DPR-29; DPR-30 1'
Reports No:
50-254/97009(DRS); 50-265/97009(DRS)
Licensee:
Commonwealth Edison Company Facility:
Quad Cities Nuclear Power Station Units 1 and 2 Location:
22710 206th Avenue North Cordova, IL 61242 Dates:
June 9-13,1907 Inspectors:
R. Paul, Senior Radiation Specialist N. Shah, Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety i
I 9707080045 970701 PDR ADOCK 05000254 G
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==Dear Mr. Kraft:==
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SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97009(DRS);
50-265/97009(DRS))
This wM acknowledge receipt of your letter dated July 24,1997, in response to our letter dated July 1,1997, transmitting a Notice of Violation for an event where two workers were locked in the Unit 2 drywell, a poated locked high radiation area, on May 15 1997. In your response, you indicated that the affected procedures were being revised and that workers would be trained regarding the requirements. We have reviewed your corrective actions for the v!olations and have no further questions at this time. These corrective actions will be examined during future inspections.


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Sincerely, i
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original signed by J. M. Jacobson


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John A. Grobe,' Director Division of Reactor Safety Docket Nos. 50 254; 50-265
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Licenses No. DPR-29; DPR-30
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i Enclosure:
Ltr dtd 7/24/97 E. i
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Quad Cities to U';NRC See Attached Distribution DOCUMENT NAME: G:DRS\\QUA08_7.DRS To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure
"E" = Copy with attachment /encio,sure
"N" = No copy OFFICE Ritt g Rill c.,
Rlli Ag Rlli g g l
NAME NShah:Jp @)
GShear s*D 4pu JGrot$ WV M (n N fd 4 DATE 08/f/97 08/5/97 08q10,7) '
08/ /[/97
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9708130021 970807 PDR ADOCK 05000254
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EXECUTIVE SUMMARY
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Quad Cities Nuclear Power Plant, Units 1 and 2
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j NRC Inspection Reports 50-254/97009; 50-265/97009 This inspection included a review of the solid radioactive waste (radwaste) processing and shipping program, and the liquid radwaste and effluent monitoring program. Additionally, an event where a worker was locked inside the drywell (a locked high radiation area (LHRA)) and emergent work on the Unit 2 "B" recirculation (RR) pump seal were also
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reviewed.


l The licensee's investigation and immediate corrective actions following an event
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where a worker was locked in the drywell LHRA was good. The failure of the RP
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technician to verify that all personnel had exited prior to locking the drywell was
August 7, 1997 cc w/ encl:
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T. J. Malman, S4:nlor Vice President, Nuclear Operations Division D. A. Sager, Vice President,'
considered a violation of 10 CFR 20.1601(d) (Section R1.1),
- Generation Support H. W. Keiser, Chief Nuclear
i Although the Unit 2 "B" RR seal replacement occurred without mishap, the
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Operating Officer L. W. Pearce, Station Manager C. C. Peterson, Regulatory Affairs Manager
inspectors identified a weakness in the ALARA planning. Specifically, the licensee j
did not develop contingency plans, for respiratory and protective clothing
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evaluations, should radiological conditions change from those analyzed (Section
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1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing
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R1.2).
Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission J. R. Bull, Vice President, General & -
 
Transmission, MidAmerican Energy Company Distrib'ation:
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Docket File w/enct Rlli PRR w/ encl A. B. Beach, Rlil w/enct PUBLIC IE 01 w/enci
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- SRis, Quad Cities,.
 
J. L, Caldwell, Rlli w/enci
The licensee's solid radwaste transportation program was technically sound and
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implemented consistent with regulatory requirements. However, one weakness was identified in the licensee's tracking and documentation for the amount of time
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high integrity containers (HICs) were exposed to sunlight (Section R1.3).
 
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The liquid monitoring program was effectively implemented and effluent monitor
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operability was good. Some concerns were identified with outstanding work requests on the liquid radwaste control panel, but these concerns were being J
addressed by the licensee (Section R1.4).
 
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The licensee was effectively implementing the inspection program for infrequently
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entered tank rooms and was addressing deficiencies found during these inspections (Section R2.1).
 
The licensee was effectively maintaining records of spills and other abnormal
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events, where radioactive materici was reicased outside the radiological posted area (RPA), as required by 10 CFR 50.75(g). However, the inspectors were concerned that areas contaminated durirg normal reactor operation, such as the waste water and sewage treatment outdcar sludge drying areas, were not included in these records (Section R2.2).
 
The inspectors observed good procedural adherence and management oversight
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during resin transfer and routine Dry Active Waste processing. The overall exposure for these activities was low and consistent with the increase in shipping activities since 1995. One weakness was identified with the licensee's radiological controls of the radwaste storage and processing areas. Additionally, some concerns were identified with the radioactive material control and accountability in the Dry Active Waste material building and radwaste mausoleum and with the
 
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control of exposure and radioactive material during resin transfers..One concern was identified regarding the requirements for the review of vendor procedures as
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stated in the Process Control Program and in station procedures (Section R4.1).
 
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OC/LFDCB w/enci Dresden, LaSalle w/onci Rlli Enf. Coordinator w/enci
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The licensee's audit of the radwaste transportation program was technically sound
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i and did not identify any significant shipping events (Section 7.1).
 
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Report Details IV PLANT SUPPORT R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Workers Locked inside Locked High Radiation Area a.
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Inspection Scope (83750)
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The inspectors reviewed the circumstances associated with a self-revealing event where a reactor operator was prevented from exiting a posted and controlled Locked High Radiation Area (LHRA). The inspection included a review of the
' licensee's investigation and a review of applicable procedures and documentation.
 
b.
 
Observations and Findinas On May 15,1997, a reactor operator entered the Unit 2 drywell (a posted and controlled LHRA) to perform work. The operator entered through the drywell personnel hatch (the normal access) and, prior to entry, had logged into a computer tracking system. Because of the extent of ongoing work, three RP technicians were assigned to the drywell. All three technicians were responsible for ensuring LHRA controls were maintained with one technician assigned sole responsibility to perform personnel tracking and timekeeping.
 
About two hours after the operator entered, all of the other workers in the drywell had exited and had been logged out of the computer. This was recorded in the drywell logbook by the timekeeping technician, who also noted that the operator was still in the drywell. Shortly afterward, the lead radiation protection technician on shift, who believed everyone had exited the drywell, received permission from the radiation protection shift supervisor (RPSS) to secure drywell access. The RPSS then contacted the senior drywell technician (not the one performing the timekeeping) and informed him to lock the drywell if everyone had exited. The senior technician then locked the drywell gate, which was subsequently verified secure by the timekeeping technician. However, prior to locking the gate, the timekeeping technician had not reviewed the computer log or entered the drywell to verify that all personnel had exited. Approximately three minutes later, the operator called the RPSS and informed him he was locked in the drywell. Subsequently, the operator was released and logged out of the drywell. The dose rates where the operator was waiting were less than 2 millirem per hour (mrem /hr) and his total exposure for the day was about 19 mrem.
 
The root cause of the event was the failure of the timekeeping technician to verify that all personnel had exitad the drywell prior to securing the drywell gate and, consequently, locking the operator in the LHRA. The failure to provide an individual an exit from the drywell LHRA is considered a violation of 10 CFR 20.1601(d)
which required that the licensee establish controls over HRA access that do not prohibit individuals from leaving an HRA (VIO 50-254/265-97009-01).


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l Immediate corrective actions taken to prevent recurrence included ensuring that no other persons were in the drywell before it was locked down and personnel disciplinary action. Long term corrective actions were still being developed by the licensee.
< omm,ou ann i a,.n i omp.m3
 
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Conclusions
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The licensee's investigation and immediate corrective action following an event where a worker was locked in the drywell LHRA was good. The failure of the licensee to verify that all personnel had exited prior to locking the drywell, was considered a violation of 10 CFR 1601(d).
 
R1.2 Emergent Work on Unit 2 "B" Reactor Recirculation Pump Seal a.
 
Inspection Scoce l
The inspectors observed the licensee's as-low-as-reasonably-achievable (ALARA)
i planning and controls for emergent work on the Unit 2 "B" reactor recirculation pump seal. The seal, which had been replaced approximately one month earlier i
during the Unit 2 refueling outage, was identified to be leaking during the early i
stages of reactor vessel hydrostatic pressure testing. The inspection included a review of the radiation work permit (RWP) and related documentation and interviews with the ALARA and work planners, b.
 
Observations and Findinos The personnel dose for this work was estimated to be about 850 mrem, consistent with the earlier seal replacement. The inspectors noted that the licensee had implemented effective controls for the entry, including continuous radiation protection coverage, the use of a high efficiency particulate air filter system, and the inclusion of lessons learned from the earlier seal replacement (primarily consisting of scaffolding location). The job was completed without mishap and for a total exposure of about 710 mrem.
 
i One weakness was identified, by the inspectors, with the licensee's ALARA planning. Specifically, the licensee had performed an evaluation to determine whether respiratory protection was required and the type of protective clothing (i.e.
 
rubber gear) needed. Based on these evaluations, the work was performed without
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respirators and without rubber gear. However, the inspectors identified that the licensee had not developed contingency plans if actual radiological conditions differed from those evaluated. The inspectors were concerned that the lack of contingency planning may result in an unplanned contamination or exposure event if radiological conditions changed. This matter was discussed with radiation protection management who verified radiological conditions remained within the analysis during the work and who planned to include contingency planning in similar future evaluations.
 
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c.
 
Conclusions Although the Unit 2 "B" reactor recirculation seal replacement occurred without mishap, the inspectors identified a weakness in the ALARA planning. Specifically, the licensee did not develop contingency plans, for respiratory and protective clothing evaluations, should radiological conditions change from those analyzed.
 
R1.3 Solid Radioactive Waste (Radwaste) and Transportation Programs a.
 
Insoection Scope The inspectors reviewed the licensee's solid radwaste and transportation programs as described in the Final Safety Analysis report (FSAR) and Process Control j
Program. The review included records of past shipments (denoted below),
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interviews with applicable plant personnel, and a review of training records and NRC guidance documents concerning radwaste shipping and transportation. The i
licensee's implementation of the following station procedures was also reviewed:
QCRP No. 5620-09 (Revision (Rev. 4)) " Administrative Package Process for
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Radioactive Material Shipments;"
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QCRP No. 5630-02 (Rev. 4) " Controls for Packaging Radioactive Material for
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Shipment;"
4)u,iit ( nin (.rns r.nine M.ition 22 io 2tu in uenue sonn i onlin.t il bil e 2 4' 4:1
QCRP No. 5620 06 (Rev. O) "10 CFR 61 Waste Stream Sampling and
'Iri 4t rust 4-2241 ESK-97-149 July 24,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
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Document Control Desk Subject:
Analysis;"
Quad Cities Station Units I and 2; l
QCAP No. 0610-02 (Rev. 3) " Radioactive Material Shipments;" and
NRC Docket Numbers 50-254 and 50-265:
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QCRP No. 5630-01 (Rev. 4) " Survey of Radioactive Material Shipments" Additionally, the inspectors reviewed radwaste shipment Nos. 96-031 (Dewatered Condensate POWDEX Resin),96-038 (Irradiated Material from Spent Fuel Pool), 97-009 (Torus Filters) and 97-001 (Dewatered Condensate POWDEX resin)
b.
 
Observations and Findinas There were no significant changes in the solid radioactive waste processing program as described in the process control program and FSAR. Since 1995, the licensee has taken several steps to reduce waste generation including the use of recyclable (i.e. launderable) materials and increased worker training. However, continued station efforts to reduce the amount of radioactive material stored onsite has resulted in an increase in the volume and number of radwaste shipments. For example, as of June 1997, the licensee had made 145 shipments (about 37,000 ft ) compared to 287 shipments (about 88,247 ft ) total for 1996. The licensee expected these numbers to decline as the backlog of stored material was reduced.
 
The inspectors verified that the licensee maintained current copies of NRC, Department of Transportation (DOT) and applicable burial site regulations. Licensee personnel responsible for the transfer, packaging and transport of radwaste were delineated in writing, were trained (within the last two years) and were knowledgeable of the new DOT rules. These DOT requirements were also appropriately referenced in the aforementioned procedures. In particular, the inspectors noted that Procedure Nos. QCRP 5630-02 and QCRP 5620-09 correctly
 
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stated the requirements for classifying shipments as Low Specific Activity (LSA)
Types I and 11 and Surface Contaminated Objects (SCO) Types I and ll, and for the use of system international (SI) units after April 1,1997 The licensee did not plan to make waste shipments classified as either LSA Type til or fissile material.
 
The licensee used a vendor computer program (i.e. RADMAN) to classify waste, determine if any reportable quantity (RO) limits were exceeded and to generate shipping papers. The inspectors verified that the program database contained the correct RO and radwaste activity limits for waste classification and, through independent calculation, that Shipment No. 96-031, had been appropriately characterized. For the other mentioned shipments, the inspectors verified that the shipping papers were consistent with the regulations, that SI units were used (if applicable), and that the shipments were appropriately tracked and logged.
 
Additionally, the inspectors verified that valid licenses and certificates of compliance were used for shipping casks and high integrity containers (HICs).
 
During this review, the inspectors identified that the licensee had been incorrectly recording the time that HICs were exposed to sunlight. This time was tracked to determine if a HIC had suffered potential degradation due to exposure to ultraviolet radiation, but was not a regulatory requirement.' The licensee determined that no HIC had received a significant amount of exposure and counseled radwaste personnel on the tracking expectations.
 
Scaling factors for 10 CFR Part 61 waste characterization analyses were generated as described in Procedure No OCRP 5620-06. This procedure contained provisions for licensee review of scaling factor results from routine sampling and/or after significant changes in reactor water chemistry. The inspectors' review determined that the scaling factors were determined consistent with the guidance contained in the NRC Branch Technical Position on waste classification and waste form and that the scaling factors being used as of June 1997, agreed with past results.
 
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NRC Inspection Report Numbers 50-254/97009
 
Conclusions i
The licensee's solid radwaste transportation program was technically sound and implemented consistent with regulatory requirements. One weakness was identified in the licensee's tracking and documentation for the amount of time HICs were exposed to sunlight.
 
R1.4 Liquid Effluent Program a.
 
Inspection Scoce (84750)
The inspectors reviewed selected portions of the licensee's liquid effluent control program inc!uding effluent results, effluent control instruments, monitor calibrations and alarm set points, monitor operability, and several effluent discharge releases.
 
b.
 
Observations and Findinas There were no significant changes in the licensee's liquid effluent systems as described in the Off-Site Dose Calculation Manual (ODCM) and the FSAR.
 
Quantification of liquid discharges was completed in accordance with the
 
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appropriate procedures, and the inspector verified that offsite doses and effluent release monitor setpoints were calculated using ODCM methodology. As described a the FSAR, plant liquids, including chemical waste liquids, were primarily processed and reclaimed by the use of filters and resin beds. Liquid releases consisted primarily of batch releases of laundry and floor drain water.
 
The inspectors observed work request tags on various components on the liquid radwaste control panel, some of which were over a year old. Although none of the components needing repair were associated with safety related systems, in some j
cases the operators had to work around the equipment to complete their work. In two cases the repairs were required for systems that were important in preventing radwaste tank overflows, a condition that could cause unnecessary personnel radiation exposure during cleanup. The licensee indicated they were aware of the j
work requests and were in the process of addressing the problems.
 
Records of radwaste monitoring equipment availability indicated that with the exception of the Units 1 and 2 service water monitors, all other process monitors i
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had few operability problems and good availability. The service water monitor availability was affected by problems with the loss of domestic water (needed for the operability of the monitors) and recent station construction modifications in the area of the monitors. However, the inspectors verified that the licensee had implemented the appropriate compensatory measures when these monitors were inoperable.
and 50-265/97009.
 
c.
 
Conclusions The liquid monitoring program was effectively implemented and effluent monitor operability was good. Some concerns were identified with outstanding work requests on the liquid radwaste control panel, but these concerns were being addressed by the licensee.
 
R2 Status of RP&C Facilities and Equipment R2.1 Condition of Radwaste Tank Rooms a.
 
inspection Scope The inspectors reviewed the results of the licensee's annual inspection of the radwaste tank rooms, as required by station Procedure No. OCRP 6020-03 (Rev. 4)
" Radiological Surveys." As listed in Attachment E to this procedure, the rooms inspected included the Units 1 and 2 reactor water cleanup (RWCU) phase separator pump and tank rooms, and the waste sludge tank, condensate phase separator tank and waste collector tank rooms (which included the floor drain collector and chemical waste tanks). These tanks were all controlled as locked high radiation areas.
 
b.
 
Observations and Findinas This inspection program was started in 1996 in response to severalindustry findings regarding the degradation of radwaste tanks. As of June 1997, the
 
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l licensee had made three entries into these rooms (in February 1996, September 1996 and April 1997) and had planned another entry in late M97. The tank room condition was initially verified by persoanel entries, but later a remote robot (with a camera attachment) was used to reduce worker exposure. The total exposure for the above three entries was about 160 mrem.
 
The inspectors observed videotapes and photographs documenting the results of these walkdowns. Most of the rooms were in good condition, although there were some examples of poor housekeeping primarily from past jobs. However, there were signs of corrosion and leakage in the floor drain collector tank and the chemical waste tanks. Specifically, a small 6-8" stalactite was observed near the bottom of the floor drain collector tank and significant through-wall corrosion was observed on a Y-junction with the chemical waste tanks overflow and unknown system piping (this line was not documented in plant drawings). The licensee identified the problems during the 1996 inspections and verified, in 1997, that the tanks' condition had not deteriorated. The licensee was developing a plan to address the identified deficiencies.
 
c.
 
Conclusions The licensee was effectively implementing the inspection program for infrequently entered tank rooms and was addressing deficiencies found during these inspections.
 
R2.2 Documentation of Past Radiological Events Per 10 CFR Part 50.75(g)
a.
 
Inspection Scope
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The inspector reviewed the licensee's documentation of spills or unusual occurrences involving the spread of contamination in or around the facility as required by 10 CFR Part 50.75(g). The licensee's program was administered under station Procedure No. QCRP 6100-01 (Rev. O) "10 CFR 50.75'g) Documentation."
 
b.
 
Observations and Findinas The licensee's radiation protection group maintained an index of events (including those addressed under the former 10 CFR 20.302) that required documentation under 10 CFR 50.75(g). This index summarized the date of the occurrence, the associated system, the event synopsis, the contamination location and the resolution (i.e. if decontaminated). The supporting data for each event (such as disposal records and isotopic sampling and analysis results) were maintained in a separate file in the radiation protection office. As of June 1997, a total of 32
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events was documented with the first instance occurring in April 1974. The


inspectors selectively verified these entries through interviews with several employees having a long-term association with the site and by reviewing past NRC
Reference:
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M. Leach to E. S. Kraft, Jr. Letter dated July 1,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning inadequate Radiological Controls.
inspection reports.


However, the inspectors identified that documentation for the waste water and sewage treatment outdoor sludge drying areas was not included in the 10 CFR 50.75(g) decommissioning file. These areas had uniform, low levels of contamination and were being controlled as satellite radiation protection areas.
This letter contains the following commitments:
1. Incorporate in QCAP 0620-01,"High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area. The procedure will be revised by August 29, 1997. (NTS # 254-100-97-00901.01)
2. As a result of the discussion in Attachment B (inspector request for additional information), any reference to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area Access. (NTS # 254-100-97-00901.02)
Ju'l o'O r i nicom comrun)
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Although these areas were contaminated through normal reactor operations and not from spills or other abnormal events, they would still be considered for cleanup during site decommissioning. The licensee planned to evaluate these items for inclusion into the decommissioning files.
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ESK 97149
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Conclusions The licensee was effectively maintaining records of spills and other unusual occurrences involving the spread of radioactive contamination, as required by 10 CFR 50.75(g). The licensee was considering for inclusion in the decommissioning files areas contaminated during normal reactor operation, such as the waste water and sewage treatment outdoor sludge drying areas.
 
R4 Staff Knowledge and Performance in Radiation Protection and Chemistry i
R4.1 Solid Radwaste Processing Activities a.
 
Inspection Scope The inspectors observed the condition of the solid radwaste processing and radioactive material storage areas including the Radwaste Mausoleum, Interim Radwaste Storage Facility and the Radwaste, Laundry-Tool-Decon (LTD) and Dry Active Waste buildings. During the walkdown the inspectors observed the transfer and subsequent dewatering of resin from the max-recycle spent resin tank and routine DAW sorting and handling activities. There were no licensee shipments occurring during this inspection. Additionally, the inspectors interviewed workers regarding procedural and RWP requirements, and reviewed the routine exposures from radwaste activities since 1995 and the licensee's records of HAZMAT training (including the lesson plans) required by 49 CFR Part 173, Subpart H.
 
Specific documents reviewed during this inspection included:
RWP Nos. 974002 (Rev. 0) "Radwaste and Radioactive Material Shipping
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Activities" and 973003 (Rev.1) " DAW Reduction: Sort / Compact High Radiation / Contaminated Material;" and Station Procedures No. OCOP 2099-6 (Rev.11) " Transfer and Dewatering of
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Max-Recycle Spent Resin Tank via "B" Transfer Header," QCAP 100-15 (rev 1) " Review and Acceptance of Contractors' and Subcontractors'
Procedures," CNSI FO-OP-033-44506 (Rev.1) " Set-Up and Operating
 
Procedure for the RDS-1000 Unit at Quad Cities," and CNSI FO-AD-002 (rev l
24) " Operating Guidelines for Use of Polyethylene High Integrity Containers."
 
The CNSI procedures were vendor procedures developed by the radwaste contractor.
 
b.
 
Observations and Findinas
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During the walkdowns, the inspectors identified continuing problems with the posting and labeling of radiological areas and radioactive materials, respectively, j
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July 24,1997 If there are any questions or comments concerning this letter, please refe them to t
Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, ext. 3609.


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Respectfully, b'
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E. S. Kraft, r
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and with radiological housekeeping of work areas. Specifically, the following was I
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Site Vice President l
observed:
Quad Cities Station l
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Attachments: (A) " Response to Notice of Violation" l
e in the Radwaste Mausoleum the inspectors observed a contaminated ares
(B) " Request for AdditionalInfonnation" i
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A. B. Peach, Regional Administrator. Region III cc:
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R. M. Pulsifer, Project Manager, Nr.R
boundary (i.e. rope and posting) which did not clearly delineate the affected
- C. G. Miller, Senior Resident Inspector, Quad Cities W. D. I.eech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center
. Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)
M.- E. Wagner, Licensing, Comed ram


area. Although the RP group subsequently determined the area was not i
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contaminated, they were not aware of this posting until notified by the
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in the Radwaste Mausoleum and DAW and LTD buildings, the inspectors
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observed carts (having fixed contamination) and drums (containing l
radioactive material) where older radioactive materiallabels had not been
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removed, which could confuse workers regarding the actual contents or
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radiological conditions of the package; and
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in the LTD building, the inspectors observed poor radiological housekeeping e
i of the mechanical and electrical maintenance work areas.~ Although this problem was partially attributed to outage recovery activities, these areas
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have been of recurring concern in previous NRC intpections.
ATTACHMENT A Response to Notice cf VI:liti:n ESK 97-149 Page1 of1 STATEhENT OF VIOLATION (NRC IR 97-009-01):
:
NOTICE OF VIOLATION 10 CFR 20.1601(d) requires that the licensee establish the controls required by paragraphs (a) and (b) of this section in a way that does not prevent individuals from leaving a High Radiation Area.
The inspectors also questioned the adequacy of the licensee's controls over
,
!
radioactive material stored in the mausoleum and DAW building. Poor control of l
[
stored radioactive material was one of the contributing causes identified by the
;
licensee for several events where such material was found outside the RPA.


'
Contrary to the above, on May 15, 1997, the licensee failed to provide an individual an exit from the Unit 2 Drywell, which was a posted Locked High Radiation Area controlled per 10 CFR 20.1601(a) and (b).
Although no regulatory violations were identified, these observations were considered a weakness in the licensee's radiological controls of these areas. The licensee planned to evaluate these observations and develop corrective actions.


*
This is a Severity Level IV violation (Supplement IV).


'
Based on the work observations and personnel interviews, the inspectors concluded
:
'
that the resin transfer / dewatering and the DAW sorting / handling activities were well
;
conducted and that personnel were knowledgeable of procedural and RWP
:
requirements. In particular, the inspectors obsarved good licensee oversight of i -
contractor activities and communication between the radwaste and main control rooms during the resin transfer. However, the inspectors did identify some
[
concerns regarding exposure and contamination control. Specifically:
a d
l
l
*
Step D.3 of Procedure No. OCOP 2099-66 warned operators of possible increased dose rates in the max-recycle rooms during the resin transfer.
i l
However, there were no formal controls over perst inel access to this area i
nor was radiation protection aware of this procedu.al step.
e The resin transfer line was located near the control panel for the resin dewatering system. Normal dose rates in this area were between 1-2
mrem /hr and the transfer process required that an operator be near the panel
,.
;
for several hours a day for 1-3 days. The licensee had established compensatory actions for the transfer of RWCU resin, which raised dose
'
rates near the operator to 30-50 mrem /hr, but had not considered other resin transfers which could also raise dose rates. These elevated dose rates could i
result in high aggregate dose to the operator, given the time spent in the
,
;
area.
,
i
2
.. - -. - -
- -..
. - -
-. -.
.. -. -. -
. -. - -
..
.
t
.
!
.
^
f During interviews, licensee personnel stated that the most likely problem e
during resin dewatering was plugg?ng of the transfer hoses, and described
-
I the corrective actions that would be taken. However, the inspectors i
observed that this problem and the associated corrective actions were not
-;
L addressed in the resin dewatering procedure (No. CNSI FO-OP-032-44506).
i A similar problem had resulted in a worker receiving a significant
!
,
contamination, during resin transfer activities at another industry site.
o
.,
Additionally, the inspectors identified a discrepancy in the licensee's process for
;
j.
reviewing vendor procedures. Specifically, the process control program required
'
'
i that vendor procedures be submitted to an onsite review prior to use. Based on
REASON FOR VIOLATION:
!
The cause of the event was determined to be a personal performance problem on the past of the Contract RFr (CRPT), who as the LHRA Timekeeper, failed to verify all personnel had exited the LHRA prior to locking it down.
discussions with radiation protection and radwaste operations management, this
;,
requirement meant a formal review by the station onsite review committee (ORC).


However, the station's procedure for reviewing vendor documents (No. OCAP E
ACTIONS TAKEN:
1100-15) did not require ORC review. The inspectors noted that the i
1.
aforementioned vendor procedures (Nos. CNSI FO-OP-032-44506 'and FO-AD-002)
were reviewed by the ORC. The licensee planned to evaluate the discrepancy and to determine whether vendor procedures had been appropriately reviewed for i
technical concems.


!
The Timekeeping CRPT was notified and released the Operator from the U2 Drywell/ Bull Pen.
'
l=
Radiation exposure for radwaste activities was low and was consistent with the increase in process'ng and shipping activities as discussed in Section R1.3.


!
2.
j Specifically, the exposure totals were (as of June 1997):
'
l
)
1995
.1116
.1212
,
DAW Sorting / Compacting:
2.00 rem 2.17 rem-0.78 rem
,
l Radioactive material shipping:
4.37 rem 6.08 rem 1.36 rem
!
!.
For the 1997 data, the individual dose totals ranged from 52-460 mrem and were j
distributed among workers having average lifetime dose totals (about 2-5 rem) in L
the station laborer group. Through discussions with the workers and a review of j
station records and lesson plans, the inspectors verified that personnel involved in
;
radwaste shipping and transportation activities (i.e. radwaste shipment i
coordinators, station laborers and radiation protection technicians) had received


required DOT HAZMAT training consistent with their assigned responsibilities.
The two CRIrrs involved in the event were denied access to RPAs until the investiga-tion could be completed.


,
3.
c.


Conclusions g.
The CRFrs involved were disciplined, with one being released from duties at the sta-tion.


i
4.
}
The inspectors observed good procedural adherence and manapsment oversight
[
. during resin transfer and routine DAW processing. The overall exposure for these activities was low and consistent with the increase in shipping activities since i
!
1995. One weakness was identified with the licensee's radiological controls of the l.


radwaste storage and processing areas. Additionally, some concerns were identified with the radioactive material control and accountability in the DAW
Other LHRAs were evaluated for egress capability.


building and radwaste mausoleum and with the control of exposure and radioactive
- ACTIONS TO PREVEh"r FURTHER OCCURRENCE:
Incorporate in QCAP 0620-01, "High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area.


material during resin transfers. One discrepancy was identified regarding the
The procedure will be revised by August 29,1997. (NTS # 254-100-97-00901.01).


j requirements for the review of vendor procedures as stated in the process control program and in station procedures.
DATE WHEN FULL COMPLIANCE WILL BE MET:
Full compliance was met on May 15,1997 when the individual was released from the Drywell.


.
.
:
a
_ _
_ _
. __
_
_
.._
.
..
_
_
___.__
_
_ _
._
'
.
.
;
R7 Quality Assurance in RP&C Activities
;
R7.1 Solid Radwaste and Transportation Audits a.
Insoection Scoos The inspectors reviewed licensee actions following several violations identified by
'
the NRC during a January 1997 inspection of the radwaste transportation and shipping program (Inspection Report No. 50-295/304-96021) at the Zion nuclear station. In response to these issues, the licensee initiated PIF No. 97-1258 (dated March 31,1997) and conducted a corporate audit (concluding on April 11,1997)
of this program, j
.
b.
Observations and Findinas e
'
The licensee's self-assessments concluded that the shipping and transportation program was technically sound and had not resulted in any significant shipping events. However, there were several concerns identified regarding the accuracy of shipping procedures, the adequacy of HAZMAT training, the implementation of the
,
10 CFR part 61 program, the use of the interim radwaste storage facility and DAW
'
storage buildings and the description of the shipping program pertaining to job positions and responsibilities. For example, the auditors identified that the licensee's use of the interim radwaste storage facility and DAW buildings was
>
inconsistent with the associated 10 CFR 50.59 safety evaluations. These evaluations were performed with the intent to use these buildings for the extended i
storage of radwaste following the 1994 closure of the burial sites. When the burial site access was reinstated in 1995, the licensee shipped all previously stored
,
material and began using the buildings as radioactive material storage areas.
However, the subsequent stored material was not packaged in a form ready for
,
shipment nor free of surface contamination as stated in the safety evaluation. The i
auditors were concerned that this practice resulted in a regulatory violation.


The inspectors independent review concluded that the audit was thorough and
.
effectively addressed those areas found deficient during the above Zion inspection.
The identified findings were not of a significant regulatory nature and, based on discussions with the licensee, were being effectively resolved. For the above example, NRC guidance has been that a safety evaluation was not required for the above buildings nor for the storage of radioactive materialin satellite radiation i
protection areas. Although the licensee's failure to mect the safety evaluation requirements was not considered a violation, the inspectors agreed with the auditors' conclusion that the failure to revise the safety evaluation was a weakness in the management oversight of these buildings. The licensee planned to revise the safety evaluations for the above buildings and to develop corrective actions for the other findings.
c.
Conclusions The licensee's audit of the radwaste transportation program was technically sound and did not identify any significant shipping events.
.
. _._.. _ _
__
. _ - _ _. _..
_. _ _ -_
.- _ _.- -
...
._
_
_
_
-- _ __
.
.
:
;
R8 Miscellaneous RP&C lasues
 
The following items identified in previous inspection reports were reviewed by the
;
inspectors:
 
'
'
(Closed) VIO 50-254/265 97003-01: Violation for failure to follow RP procedures.
*
 
The licensee reposted the Unit 2 "A" residual heat removal drainage trough and
;
 
relabeled the check sources on the service and radioactive waste affluent monitors.
 
Other, similar controls were also verified in the remaining Units 1 and 2 corner
-
rooms and radiological monitors, respectively. The applicable station Procedure, i
No. OCRP 5010-1 " Radiological Posting and Labeling" was also revised to clarify posting and labeling requirements for radioactive material. Based on these actions, this item is closed.
 
X1 Exit Meeting Summary
!
The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 13,1997. The licensee acknowledged the findings i
presented and did not identify any of the documents listed as proprietary. A partial listing of those attending the exit included:
.
,
!
P. Bherins, Chemistry Supervisor
!
D. Cook, Operations Manager
:
E. Kraft, Station Vice-President
 
W. Lipscomb, Work Control Superintendent l
L. W. Pierce, Station Manager a
G. Powell, Radiation Protection Manager
)
W. Schmidt, ALARA Supervisor i
R. G. Svaleson, RP/ Chemistry Superintendent i
M. B. Wayland, Maintenance Manager A. Williams, Radwaste shipment coordinator
&
i
,
;
.
:
 
<
 
l
 
.-
-
_..
..
_.-_
-...
.. _ _ _ -. -.
.
.
.
INSPECTION PROCEDURE USED IP 83750 OCCUPATIONAL RADIATION EXPOSURE IP 84750 REACTOR WATER CHEMISTRY AND GASEOUS AND LIQUID EFFLUENT RELEASE PROGRAM lP 86750 SOLID RADIOACTIVE WASTE AND TRANSPORTATION PROGRAM
,
i ITEMS OPENED, CLOSED or DISCUSSED 99AG i
VIO 50-254/265-97009-01 Individual locked inside an LHRA (Section R1.1)
Closed i
VIO 50-254/265-97003-01 Failure to follow RP procedures (Section R8)
Discussed None
 
.
._
_.
 
_...
__
.__
. _ _..-__. _ _. _. _ - _.
_ _
_. _ -
.. - _..
.
.
LIST OF ACRONYMS USED
[
ALARA As-Low-As-Reasonably-Achievable
:
RWP Radiation Work Permit
!
ODCM Offsite Dose Calculation Manual FSAR Final Safety Analysis Report i
Rev.
 
Revision DAW Dry Active Waste
,
i DOT U. S. Department of Transportation LSA Low Specific Activity I
SCO Surface Contaminated Object i
SI System International
 
RO Reportable Quantity HIC High integrity Container 3~
RWCU Reactor Water Cleanup j
LTD Laundry-Tool-Decon mrem /hr Millirem per hour
.,
RP&C Radiation Protection and Chemistry
-
 
i i
.
'
'
l l
*
!
ATTACHMENT B t
j i
Request fsr Additi:n:1 Infarm ti:n ESK 97-149 Page1 of1 In the evaluation for compliance of other LHRAs with the requirements of 10 CFR 20 1601(d), the controls used at the IB RHR room during HPCI operation were found to be incorrect. During HPCI operation, the Reactor Building Basement area on the affected unit is normally controlled as a LHRA. The egress point used was formerly controlled with a chain and pad lock. The RIrr would lock himself in the area with the key. The RP department concluded that this practice could lead to personnel being locked in the area if the PET lost the key or was injured. Dead bolts with latches that allow opening from the inside without a key were ordered. Until the dead bolts could be installed, RP decided to use a flashiag light and posting to control the IB RHR room entrance. Th4 decision was based upon the in-
 
;
!
,
 
1 i
I d
;
;
:
 
.-. -
- - -... - -
_
.- -
-
-. -.
--_ -.
.
,
,
.
.
'
l LIST OF DOCUMENTS REVIEWED
:
NRC Waste Technical Position, Revision 1 (dated January 24,1991)
NRC Final Waste Classification and Waste Form Technical Position Papers (dated May 11, 1983)
)
-
l NRC Final Branch Technical Position on Concentration Averaging and Encapsulation (dated i
;
April 12,1994)
j NRC Supplemental Guidance on the Implementation of 10 CFR part 61 (dated January 30,
'
'
i 1994)
terpretation of the procedure that RP could control this LHRA with a flashing light and post-ing. RP did not want to lock the area because of the safety concern. This interpretation lead to the incorrect usage of the flashing light to control the LHRA.
NRC IE Bulletin No. 79-19 " Packaging of Imw-I2 vel Radioactive Waste for Transportation
,
and Burial" (dated August 10, 1979)
NRC Generic letter No. 95-09 (and supplements) " Monitoring and Training of Shippers and l=
Carriers of Radioactive Materials" (dated November 3,1995).
 
l
-
)
!
Station Procedure Nos:
,
)
QCRP 5620-09 (Rev. 4)
Administrative Package Process for Radioactive Material Shipments
,
QCRP 5630-02 (Rev. 4)
Controls for Packaging Radioactive Material for
.
j Shipment
;
QCRP 5620-06 (Rev. 0)
10 CFR 61 Waste Stream Sampling and Analysis
',
QCAP 0610-02 (Rev. 3)
Radioactive Material Shipments QCRP 5630-01 (Rev. 4)
Survey of Radioactive Material Shipments
!
QCOP 2099-6 (Rev.11)
Transfer and Dewatering of Max-Recycle Spent Resin i
Tank via "B" Transfer Header i
QCAP 100-15 (Rev.1)
Review and Acceptance of Contractors' and
;
Subcontractors' Procedures
,
QCRP 6100-01 (Rev. 0)
10 CFR 50.75(g) Documentation QCRP 5010-01 (Rev. 6)
Radiological Posting and Labeling


i QCRP 6020-03 (Rev. 4)
I l
Radiological Surveys
No unauthorized access to the LHRA had occurred during the usage of the Dashing light.
'
QCCP 0400-09 (Rev. 2)
Fe-55, Sr-89, Sr-90, and Gaseous Alpha Release QCCP 0300-02 (Attachment A)
Liquid Waste Worksheet QCCP 0300-02 (Attachment B)
Calculation of Liquid Waste Activity QCCP 0300-02 (Attachment C)
Calculation of Liquid Waste Activity CNSI FO-OP-033-44506 (Rev.1) Set-Up and Operating Procedure for the RDS-1000 Unit at Quad Cities CNSI FO-AD-002 (Rev. 24)
Operating Guidelines for Use of Polyethylene High Integrity Containers


.
RP came to this conclusion due to a seal being placed on the door, indicating that no one had attempted to or accessed the area.
.
Radiation Work Permits mWPs) Nos:
974002 (Rev. 0) "Radwaste and Radioactive Material Shipping Activities" 973003 (Rev.1) " DAW Reduction: Sort / Compact High Radiation / Contaminated Material" 972082 (Rev. 0) "2B Recirculation Pump: Remove / Replace / Test Seal" PIF No. Q1997-02321 (dated 5/15/97) " Worker locked in a Locked High Radiation Area" PIF No. 97-1258 (dated 3/31/97) Review of Radwaste Shipping Program Corporate Audit Report No. DG-97-13/QDC (dated April 4,1997) Radioactive Waste Management / Radioactive Material Transport and Quad Cities Station l
i


,
To prevent the incorrect usage of a flashing light to control LHRAs in the future, any refer-l ence to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area j
,
Access. (NTS # 254-100-97-00901.02).
__
}}
}}

Latest revision as of 04:54, 24 May 2025

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-254/97-09 & 50-265/97-09 on 970701
ML20198F350
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 08/07/1997
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Kraft E
COMMONWEALTH EDISON CO.
References
50-254-97-09, 50-254-97-9, 50-265-97-09, 50-265-97-9, NUDOCS 9708130021
Download: ML20198F350 (2)
v • d • e


Text

+

.

August 7. 1997 Mr. Site Vice President Quad Cities Station Commonwealth Edison Company 22710 206th Avenue North Cordova, IL 61242

Dear Mr. Kraft:

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-254/97009(DRS);

50-265/97009(DRS))

This wM acknowledge receipt of your letter dated July 24,1997, in response to our letter dated July 1,1997, transmitting a Notice of Violation for an event where two workers were locked in the Unit 2 drywell, a poated locked high radiation area, on May 15 1997. In your response, you indicated that the affected procedures were being revised and that workers would be trained regarding the requirements. We have reviewed your corrective actions for the v!olations and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, i

original signed by J. M. Jacobson

John A. Grobe,' Director Division of Reactor Safety Docket Nos. 50 254; 50-265

'

Licenses No. DPR-29; DPR-30

'

i Enclosure:

Ltr dtd 7/24/97 E. i

!

Quad Cities to U';NRC See Attached Distribution DOCUMENT NAME: G:DRS\\QUA08_7.DRS To receive a copy of this document, Indicate in the box: "C" = Copy without attachment / enclosure

"E" = Copy with attachment /encio,sure

"N" = No copy OFFICE Ritt g Rill c.,

Rlli Ag Rlli g g l

NAME NShah:Jp @)

GShear s*D 4pu JGrot$ WV M (n N fd 4 DATE 08/f/97 08/5/97 08q10,7) '

08/ /[/97

~

9708130021 970807 PDR ADOCK 05000254

.

ll gp/

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ - _ - _ _ _, _ _ - _.

.:

.-

-,

E. Kraf t

August 7, 1997 cc w/ encl:

T. J. Malman, S4:nlor Vice President, Nuclear Operations Division D. A. Sager, Vice President,'

- Generation Support H. W. Keiser, Chief Nuclear

Operating Officer L. W. Pearce, Station Manager C. C. Peterson, Regulatory Affairs Manager

,

-

1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing

Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission J. R. Bull, Vice President, General & -

Transmission, MidAmerican Energy Company Distrib'ation:

Docket File w/enct Rlli PRR w/ encl A. B. Beach, Rlil w/enct PUBLIC IE 01 w/enci

- SRis, Quad Cities,.

J. L, Caldwell, Rlli w/enci

,

OC/LFDCB w/enci Dresden, LaSalle w/onci Rlli Enf. Coordinator w/enci

'

LPM, NRR w/enci TSS w/enci R. A, Capra, NRR w/ encl.

DRP w/enci DRS w/ encl CAA1 w/enci

DOCDESK w/ encl

~

,

-

,.

a

.-

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-._n,

.

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_,

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.

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< omm,ou ann i a,.n i omp.m3

4)u,iit ( nin (.rns r.nine M.ition 22 io 2tu in uenue sonn i onlin.t il bil e 2 4' 4:1

'Iri 4t rust 4-2241 ESK-97-149 July 24,1997 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:

Document Control Desk Subject:

Quad Cities Station Units I and 2; l

NRC Docket Numbers 50-254 and 50-265:

NRC Inspection Report Numbers 50-254/97009

'

and 50-265/97009.

Reference:

M. Leach to E. S. Kraft, Jr. Letter dated July 1,1997 Enclosed is Commonwealth Edison's (Comed's) response to the Notice of Violation (NOV) transmitted with the referenced letter. The report cited a Severity Level IV violation concerning inadequate Radiological Controls.

This letter contains the following commitments:

1. Incorporate in QCAP 0620-01,"High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area. The procedure will be revised by August 29, 1997. (NTS # 254-100-97-00901.01)

2. As a result of the discussion in Attachment B (inspector request for additional information), any reference to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area Access. (NTS # 254-100-97-00901.02)

Ju'l o'O r i nicom comrun)

S7 O bCk C b

_

___.___ _

.,.

,:

ESK 97149

July 24,1997 If there are any questions or comments concerning this letter, please refe them to t

Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654 2241, ext. 3609.

Respectfully, b'

-

E. S. Kraft, r

,

Site Vice President l

Quad Cities Station l

Attachments: (A) " Response to Notice of Violation" l

(B) " Request for AdditionalInfonnation" i

A. B. Peach, Regional Administrator. Region III cc:

R. M. Pulsifer, Project Manager, Nr.R

- C. G. Miller, Senior Resident Inspector, Quad Cities W. D. I.eech, MidAmerican Energy Company D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center

. Office of Nuclear Facility Safety, IDNS DCD License (both electronic and hard copies)

M.- E. Wagner, Licensing, Comed ram

-

ATTACHMENT A Response to Notice cf VI:liti:n ESK 97-149 Page1 of1 STATEhENT OF VIOLATION (NRC IR 97-009-01):

NOTICE OF VIOLATION 10 CFR 20.1601(d) requires that the licensee establish the controls required by paragraphs (a) and (b) of this section in a way that does not prevent individuals from leaving a High Radiation Area.

Contrary to the above, on May 15, 1997, the licensee failed to provide an individual an exit from the Unit 2 Drywell, which was a posted Locked High Radiation Area controlled per 10 CFR 20.1601(a) and (b).

This is a Severity Level IV violation (Supplement IV).

l

'

REASON FOR VIOLATION:

The cause of the event was determined to be a personal performance problem on the past of the Contract RFr (CRPT), who as the LHRA Timekeeper, failed to verify all personnel had exited the LHRA prior to locking it down.

ACTIONS TAKEN:

1.

The Timekeeping CRPT was notified and released the Operator from the U2 Drywell/ Bull Pen.

2.

The two CRIrrs involved in the event were denied access to RPAs until the investiga-tion could be completed.

3.

The CRFrs involved were disciplined, with one being released from duties at the sta-tion.

4.

Other LHRAs were evaluated for egress capability.

- ACTIONS TO PREVEh"r FURTHER OCCURRENCE:

Incorporate in QCAP 0620-01, "High Radiation Area Access", that the independent verifier, who ensures the area is locked, will initial a log to verify that everyone is out of the area.

The procedure will be revised by August 29,1997. (NTS # 254-100-97-00901.01).

DATE WHEN FULL COMPLIANCE WILL BE MET:

Full compliance was met on May 15,1997 when the individual was released from the Drywell.

_

_

_

-- _ __

'

'

ATTACHMENT B t

Request fsr Additi:n:1 Infarm ti:n ESK 97-149 Page1 of1 In the evaluation for compliance of other LHRAs with the requirements of 10 CFR 20 1601(d), the controls used at the IB RHR room during HPCI operation were found to be incorrect. During HPCI operation, the Reactor Building Basement area on the affected unit is normally controlled as a LHRA. The egress point used was formerly controlled with a chain and pad lock. The RIrr would lock himself in the area with the key. The RP department concluded that this practice could lead to personnel being locked in the area if the PET lost the key or was injured. Dead bolts with latches that allow opening from the inside without a key were ordered. Until the dead bolts could be installed, RP decided to use a flashiag light and posting to control the IB RHR room entrance. Th4 decision was based upon the in-

'

terpretation of the procedure that RP could control this LHRA with a flashing light and post-ing. RP did not want to lock the area because of the safety concern. This interpretation lead to the incorrect usage of the flashing light to control the LHRA.

I l

No unauthorized access to the LHRA had occurred during the usage of the Dashing light.

RP came to this conclusion due to a seal being placed on the door, indicating that no one had attempted to or accessed the area.

To prevent the incorrect usage of a flashing light to control LHRAs in the future, any refer-l ence to the use of flashing lights will be deleted from QCAP 0620-01, High Radiation Area j

Access. (NTS # 254-100-97-00901.02).

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