IR 05000456/1986002

Insp Repts 50-456/86-02,50-457/86-02 & 70-3000/86-01 on 851031-1101 & 860224-27 & 0304-05.No Violations or Deviations Noted.Major Areas Inspected:Preoperational Radiation Protection & Radwaste Programs & NUREG-0737 Items

ML20210E495
Person / Time
Site:	Braidwood, 07003000
Issue date:	03/20/1986
From:	Gill C, Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210E484	List: IR 05000456/1986002 ML20210E479
References
RTR-NUREG-0737, RTR-NUREG-737 50-456-86-02, 50-456-86-2, 50-457-86-02, 50-457-86-2, 70-3000-86-01, 70-3000-86-1, IEB-85-081, IEB-85-81, NUDOCS 8603270364
Download: ML20210E495 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/86002(DRSS); 50-457/86002(DRSS); 70-3000/86001(0RSS)

Docket Nos. 50-456; 50-457; 70-3000 Licenses No. CPPR-132; CPPR-133; SNM-1938 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: October 31 and November 1, 1985 and February 24-27 and March 4-5, 1986 Inspectors: W. B. Gra J/70/%

Date C. F _$2rl84, Da'te w

Approved By: L.R.dreger, hief d[8(p Facilities Radiation Protection Date Section Inspection Summary Inspection on October 31 and November 1, 1985 and February 24-27 and March 4-5, 1986 (Report No. 50-456/86002(DRSS); 50-457/86002(DRSS); 70-3000/86001(DRSS))

Areas Inspected: Routine unannounced inspection of preoperational radiation protection and radioactive waste programs for Units 1 and 2, including:

organization and management controls; training and qualifications; external occupational exposure; internal exposure control and assessment; control of radioactive materials, surveys and monitoring; facilities and equipment; status of open items; IE Information Notice No. 85-81; NRC Materials License No. SNM-1938, status of certain NUREG-0737 items, status of radwaste systems, ANSI /ASME N510 acceptance test program, and llVAC filter housing drain system The inspection involved 57 inspector-hours onsite by two NRC inspector Results: No violations or deviations were identifie gDR ADOCK 05000456 PDR

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DETAILS 1. Persons Contacted

+*R. Aker, Lead Health Physicist, Zion

+J. Anspaugh, Health Physicist

+*P. Barnes, Regulatory Assurance Supervisor

+ D' Antonio, Regulatory Assurance

• E. Fitzpatrick, Station Manager D. Flynn, ALARA Coordinator

• L. Hester, Quality Assurance

+J. Jasnosz, Regulatory Assurance S. Jaquez, Technical Staff J. Johnson, Health Physics Engineering Assistant

• T. Keith, Lead Health Physics

• F. Krowzack, Rad / Chem Supervisor

+ Miosi, Nuclear Licensing Administration * Obrien, Assistant Superintendent, Administrative

+H. Pontious, Regulatory Assurance and Support Services

+*C. Schroeder, Services Superintendent

.+T. Simpkin, Regulatory Assurance

+S. Stevenson, NSHP, Field Services Health Physicist C. Ross, Rad / Chem Chemical Engineer E. Shamlin, Rad / Chem Health Physics Foreman T. VanDeVort, Quality Assurance

+*T. Tongue, NRC, Senior Resident Inspector

• Denotes those present at the exit meeting on February 27, 1986.

+ Denotes those present at the exit meeting on March 5, 1986.

2. General This inspection, which began about noon on October 31, 1985, was conducted to examine aspects of the preoperational~ radiation protection and radwaste programs, licensee action on previous inspection findings, NRC Materials License No. SNM-1938, certain NUREG-0737 items, ANSI /ASME N510 acceptance test program, and HVAC filter housing drain system . Licensee Action on Previous Inspection Findings (Closed) Open Item (456/85042-01; 457/85041-01): A periodic meeting between the RPM and the Station Manager should be considered. Monthly meetings are now held to discuss matters related to radiation protectio (Closed) Open Item (456/84024-01; 457/84023-01): Post-LOCA purge filter i housing drain system valving errors and potential bypass-leakag The )

inspectors verified that the drain line water check valves have been moved so that the filter housing doors can be fully opened. In response to inspector concerns regarding the potential for bypass leakage while the filter housing is under positive pressure, the licensee-plans to install a pressure regulating valve upstream of the filter housing to maintain atmospheric pressure (14.7 psia). The licensee has not responded to l

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the inspectors' request that documentation be obtained on the water check valves to determine if they are adequate for their intended purpose; however, this concern is discussed in more general terms in Subsection 1 For tracking purposes, this item is considered close (0 pen) Open Item (456/84024-02; 457/84023-02): Instrument rack. drain system potential contamination problems. The licensee plans to complete installation of hard piped instrument rack leakoff drain lines prior to fuel loa This installation will be verified during a future inspectio . Organization and Management Controls The inspectors reviewed the licensee's organization and management controls for the radiation protection and radwaste programs including:

responsibilities and authorities; staffing; proposed system for program audits; and proposed methods concerning self-identificatior,and correction of program weaknesse Since the last radiat',on protection inspection in August 1985, several organizational changes have been made, including:

• The Rad / Chem Supervisor, Braidwood, was reassigned to Emergency Planning Supervisor, Mazon E. * The Lead Health Physicist, Zion, was reassigned to Rad / Chem Supervisor, Braidwoo * A Health Physicist with approximately three years experience terminated employmen * Fifteen RCTs have been hired, they have completed production training center training, six weeks OJT at LaSalle Station, and are currently in Braidwood specific trainin The Plant Manager, Services Superintendent, and Radiation Protection Manager meet monthly to discuss radiation protection and related matter The apparent need for periodic meeting of this type was discussed with the licensee during the August 1985 inspectio The inspectors reviewed the results of a station Quality Assurance Audit, QAA 20-85-39 conducted December 4-10, 198 The audit included review of procedures for receipt, inspection, and storage of new fuel element QA inspectors also witnessed the unloading, inspection, surveys and storage of the first shipments of new fue No findings or observations resulte No violations or deviations were identifie .

5. Training and Qualifications The inspectors reviewed the training and qualifications. aspects of the licensee's radiation protection and radwaste programs, including:

training responsibilities, policies, goals, programs and methods; qualifications of radiation protection personnel; and the adequacy of the training for employees, contractors and visitors. Also reviewed were management techniques used to implement these programs and the licensee's completion of FSAR and other commitment There are nine RCTs who are ANSI N18.1-1971 qualifie The licensee plans to have all 30 RCTs trained and through_ qualification training by mid-1986. The licensee is pursuing the staffing of an additional ten RCTs. Round-the-clock health physics supervision by Health Physics Foremen, to direct the activities of RCTs during each shift, is planned to compensate for the overall lack of operational experience of the RCT Nuclear General Employee Training (N-GET) for CECO Braidwood and CECO project (Corporate) employees is nearly complete. Lead contractor employees are currently completing N-GET training. The licensee plans to begin N-GET training of all contractor employees and visitors during March 1986. N-GET training sessions will be given Monday through Friday each week until all of the approximately 3,000 contractors are traine The N-GET training program content will be reviewed during a future inspectio No violations or deviations were identifie . External Exposure Control and Personal Dosimetry The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: adequacy of facilities, equipment, personnel, and procedure The licensee has purchased equipment, dedicated staff, and has written and approved procedures for operation of the Braidwood Thermoluminscent Dosimeter (TLD) program for external exposure monitoring. One essential element remaining to implement the program is selection of an area for construction of a TLD calibration facilit This matter was discussed at the exit meeting and will be reviewed during a future inspectio (456/86002-01; 457/86002-01)

There are currently three areas at Braidwood which require a Radiation Work Permit (RWP) for entry. The RWPs require dosimetry to be wor The areas are: the instrument calibration room (sources used); the counting room (sources stored); and the fuel handling areas (sources stored). Dosimetry is, sued includes self-reading dosimeters and contractor supplied neutron and beta gamma film badges. No problems were note Areas where RWPs and dosimetry will be issued during operation have not as yet been designated, and therefore construction of these facilities has not starte This matter was discussed at the exit meeting on February 27, 1986 and will be reviewed during future inspections. (456/86002-02; 457/86002-02)

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7. Internal Exposure Control and Assessment The inspectors reviewed the licensee's internal exposure control and assessment programs, including: facilities and equipment, personnel, and procedures affecting internal exposure control and assessmen The licensee has-designated an area on the 426' elevation of the auxiliary building for construction of the respirator-issue, storage and cleaning facilit Thc area is currently occupied by contractors; therefore, construction has not starte The respirator facility should ba constructed, supplied, and RCTs trained to run it prior to initial criticalit This matter was discussed at the exit meeting on February 27, 1986, and will be reviewed during a future inspectio (456/86002-03; 457/86002-03)

The licensee continues to whole body count.(WBC) personnel to provide WBC base line data, and to respirator fit test personnel who will require respiratory protectio Review of the WBC procedure did not identify any problem Calibration of the whole body counter will be reviewed during a future inspectio No problems were note No violations or deviations were identifie . Radiation Protection Procedures The inspectors reviewed the following new or recently revised radiation protection procedures to determine if they are consistent with 10 CFR requirements, FSAR commitments, and good health physics practice No problems were note BWRP 1100-1, Revision 1 Radiation Occurrence Report Trending and Reporting BWRP 1120-1, Revision 1 Controlled Areas Access BWRP 1170-1, Revision 0 Administrative Controls for HP~

Instrumentation BWRP 1200-T5, Revision 3 Radiation Exposure Investigation Form BWRP 1210-5, Revision 2 Dose Equivalent Report Upon Termination BWRP 1220-1, Revision 1 Film /TLD Badge Issuance and Completion of Occupational External Radiation Exposure History BWRP 1230-1, Revision 2 Radiation Exposure Investigation Report BWRP 1250-4, Revision 1 Personnel Dosimetry Placement Guidelines

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l BWRP 1300-A14, Revision 2 MPC-Hour Evaluation Sequence BWRP 1300-A26, Revision 0 Inhalation Intake Data Sheets

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BWRP-1300-A27, Revision 0 Sample of MPC-H Intake and Dose

Calculated from Direct-Bioassay Results BWRP 1300-T16, Revision 1 Air Sample and Analysis Data' Sheet BWRP 1360-1, Revision 0 Air Sampling of Suspected and known Airborne Radioactivity Areas

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BWRP 1380-4, Revision 0 Atmospheric Tritium Sampling BWRP 1400-A2, Revision 0 Skin Dose' Equivalent Rates for

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Some Common Beta Emitters BWRP 1400-A4, Revision 0 General Operating Characteristics-of the IRT-Portal Monitors BWRP 1400-AS, Revision 0 Concentrations in Urine at time (t) for 40 MPC-Hour intakes i

j BWRP 1400-A6, Revision 0 Sample MPC-H Calculation for Acute Intake i

BWRP 1400-A7, Revision 0 Concentrations in Urine Resulting from Continuous Exposure to Airborne Activity Equal-to 40 MPC-H per Week BWRP 1400-A8, Revision 0 Sample MPC-H per Week Calculation for Chronic Intake f BWRP'1400-A9, Revision 0 Sample of Calculating Dose from

Urinalysis Results Following an Inhalation Intake BWRP 1400-A10, Revision 0 Inhalation Intake Parameters

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BWRP 1460-2, Revision 1 Operation and Calibration of the Eberline Model AC-3 ' Alpha :

Scintillation Probe BWRP 1460-3, Revision 0 Operation and Calibration of.the-IRT Portal ~ Monitors -

BWRP 1470-4, Revision 0 Beta Dose Equivalent Determination

from Skin Contamination BWRP 1470-6, Revision 0 Estimating from Urinalysis Results

, the Dose Due to Inhalation Intakes

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BWRP 1480-2, Revision 0

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Personal External _ Contamination Surveys BWRP 1520-3, Revision 0 Curie Content of Non-Routine Radioactive Shipping Containers BWRP 1540-1, Revision 0 Radwaste BWRP 1610-1, Revision 1 Control and. Inventory of Radioactive Sources BWRP 1610-2, Revision 3 . Leak Testing of Radioactive Sources BWPD-1, Revision 0 Braidwood Preoperational Air Sampling Program BWPD-2, Revision 0 Braidwood Preoperational Smear Survey Program The licensee has 289 radiation protection procedures written, approved, and on the books. Approximately twenty additional procedures have been written and are in the approval proces No violations or deviations were identifie . Control of Radioactive Materia'is and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of instrumentation, equipment, and procedures; and dete.cination whether provision for control of radioactive materials and contamination meet requirements and commitment The licensee has scheduled testing and calibration of Unit 1 and common Area Radiation Monitors (ARMS) and Process Radiation Monitors (PRMs)

by fuel loa The schedule slipped about one month while calibration sources were purchased and developed. This matter was discussed during the exit meeting on February 27, 1986, and will be reviewed during a future inspectio (456/86002-4; 457/86002-4)

No violations or deviations were identifie . Facilities and Equipment The inspectors reviewed the facilities and equipment used by the licensee for radiation protection activities to determine whether they are as described in the FSAR and are adequate to support the radiation protection progra During plant tours of areas related to radiation protection, the inspectors observed: that the area designated for access control (426' elevation at the entrance to the auxiliary building) appears too small to accommodate access control, RWP issue, and dosimetry issue for CECO employees and

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contractors; the personal decontamination facility has not been equipped or stocked; the laundry facility has not been completed or stocked; areas for contaminated tool decon/ storage have not been designated; a health physics instrument storage room has not been designated; and the TLD-irradiation facility has not been designate These space deficiencies and those discussed in Sections 6 and 7 were discussed at the exit meeting on February 27, 1986, and will be reviewed during a future inspectio (456/86002-05; 457/86002-05)

Maintaining Occupational Exposures ALARA

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1 The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including establishment of formal ALARA policy and procedures and worker awareness of the ALARA l progra The Station ALARA Committee has been formed, and an initial committee meeting was held on January 28, 1986. Quarterly ALARA committee meetings are planned. The ALARA Coordinator is writing procedures and developing polic No problems were note . Radiation Occurrence Report (ROR)

During receipt survey of an americium beryllium source on December 18,

1985, a health physicist and an RCT failed to recognize that the source

was also a neutron source and surveyed only for gamma radiation. ROR 86001 was written and the licensee's investigation determined that the 3.2 curie source had a dose rate on contact of 190 mrem /hr gamma and 350 mrem /hr

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neutro Dose evaluations for the RCT who smeared the source for an

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estimated 3-4 seconds were calculated to be less than one mrem whole body (WB), and nine mrem gamma plus 18 mren neutron extremity (Ext'. The calculated exposure was based on source handling time estimates and survey

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data. A vendor supplied film badge service reported "M" gamma (<10 mrem)

for both WB and Ext (no neutron film included).

Included in the licensee corrective actions were: Procedures BWRP 1530-1 and BWRP 1500-T1, which deal with the receipt of radioactive material, were revised; a memo was sent to all department heads regarding procedures for ordering radioactive sources; an entry describing the incident made in Foreman's log; a Nuclear Services Health Physics (Corporate) investigation was made (report pending); training (tailgate) sessions were held, which stressed the radiation awareness program. No problems were noted.

l No violations or deviations were identified.

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1 NRC Materials License No. SNM-1938 The licensee has received a number of shipments of new fuel since December 1985. The inspectors verified receipt inspection and surveys were made in accordance with procedures. New fuel assemblies are stored in the new fuel storage vault and in the spent fuel poo Surveys of new fuel assemblies were selectively reviewed; no problems were note No violations or deviations were identified.

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1 Solid Radioactive Waste The licensee's facilities for collection, concentration, solidification, i packaging and shipment of solid radioactive waste are under constructio Acceptance and preoperational testing of these systems _will begin when construction is complete and the systems are turned over to the license Procedures for classification, certification and shipment of solid radwaste have been written and approve The inspectors reviewed radwaste procedures which were approved and

, revised since the last radiation protection inspection in August 198 No problems were note No violations or deviations were identifie . Gaseous Waste Systems i

Licensee facilities for the collection and storage of liquid and gaseous i radioactive waste are under construction. Acceptance and preoperational

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testing of these systems will. begin when construction is complete and the systems are turned over to the license I No violations or deviations were identifie . Status of Certain NUREG-0737 Action Items The inspectors reviewed the status of the post-accident sampling system high range noble gas effluent monitors, accident range iodine and particu-late effluent sampling system, and containment high range radiation monitor ! During discussions with licensee managers, the inspectors explained that NUREG-0737 commitments associated with these systems had become critical path licensing items on four recent Region III Near Term Operating License (NTOL) plants. In order to avoid such problems at Braidwood, the inspectors recommended that the licensee carefully review implementation / compliance approaches, identify a compliance coordinator, and prepare compliance and action plan reports for these four NUREG-0737 system In response to inspector concerns, the licensee has initiated a formal

commitment and compliance review effort and identified J. Jasnosz as the coordinator. Mr. Jasnosz will be responsible for the day to day

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coordination effort for NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3). Although the inspectors informed the licensee that the other four Region III NTOL plants found it advantageous to also appoint a

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manager-level coordinator who was responsible for assuring a timely station-wide coordination effort, the licensee did not identify such an appointment for Braidwoo During the site visit on October 31 through November 1, 1985, the inspectors recommended that the licensee prepare two documents to track commitment compliance for NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and j 3). These documents would be internal reports available for NRC revie The first report would be a NUREG-0737 commitment and compliance analysi It would provide a detailed (line-by-line) identification of each

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commitment associated with the previously listed NUREG-0737 items, ascertain compliance, identify any corrective measures needed or variance requests required, and identify actions needed to document compliance. The second report would be a detailed action plan providing a tracking system for actions needed to comply with NUREG-0737 commitments and to document compliance. This report should be detailed enough to include specific tasks, individuals assigned to each task, a schedule for completion, and a periodically-updated statu By March 4, 1986, the licensee had completed an initial commitment and-compliance review and begun the development of a computerized action plan tracking system. Although the compliance documentation was not

> sufficiently developed to warrant a detailed review by the inspectors, the format of these two documents closely follow earlier informal guidelines. It appears that the licensee made a good initial effort; however, little progress has been made towards obtaining or developing compliance documentation to demonstrate that the systems procured and installed are technically adequate to meet the licensee's commitments to NUREG-0737 Items II.B.3 and II.F.1 (Attachments 1, 2, and 3). This matter was discussed at the exit meeting on March 5, 1986, and will be reviewed further during future inspection (456/86002-06; 457/86002-06) NUREG-0737 Item II.B.3, Post-Accident Sampling System Section E.21 of Appendix E to the FSAR describes the Post-Accident Sampling System (PASS) for reactor coolant and containment atmospher The system is a modified Sentry High Radiation Sampling System (HRSS)

consisting of three subsystems: the Liquid Sample Panel (LSP), the chemical analysis panel (CAP) which is attached to the LSP, and the Containment Atmosphere Sample Panel (CASP).

Section E.21 of Appendix E to the FSAR also makes the commitment that the system will be installed and become operational on each unit prior to initial criticality. The licensee's progress towards meeting this commitment was reviewed by the inspectors. Installation for the PASS is complete, including sample lines, heat tracing, and electrical-power. Construction has completed component checks and turned the system over to startup. Preoperational testing is expected to begin on March 10, 1986, and to continue for approximately two month By June 1986, a number of subsystems are expected to be' fully functional (such as reactor coolant and containment atmosphere sampling systems) in time for'the scheduled NRC emergency preparedness appraisal. Although the formal commitment for a fully operational PASS is prior to initial criticality, the licensee plans to reuch this milestone by fuel loa Licensee progress in completing preoperational testing, procedures, and training will be reviewed further during a future inspectio (436/86002-07; 457/86002-07) NUREG-0737 Item II.F.1.1, High Range Noble Gas Effluent Monitors Section E.30.1 of Appendix E to the FSAR describes the post-accident high range noble gas effluent monitoring systems. The system consists of a General Atomic Wide Range Gas Monitor (GA WRGM) for

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the auxiliary building vent, and area monitors (compensated for loss of low energy gamma radiation) mounted external to each of the four main steam lines upstream of the safety and relief valve During.a plant tour on March 4,1986, the inspectors noted that installation of this system, including electrical power, has not been complete Licensee progress in completing installaticn, preoperational testing, and calibration; writing procedures;

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and training personnel will be reviewed further during future inspections. (456/86002-08; 457/86002-08)

c. NUREG-0737 Item II.F.1.2, Sampling and Analysis of Iodine and Particulate Effluents Section E.30.2 of Appendix E to the FSAR describes the post-accident

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effluent sampling system and the analysis of. iodine'and particulate effluent samples. The iodine and particulate sampling system is a part of the General Atomic system described'above for Item II.F. and provides for obtaining grab samples from the auxiliary building vent. The sample media will be analyzed in the station's counting rooms by gamma ray spectrometers which utilize Ge (Li) detector The inspectors reviewed the status of the a.ccident range iodine and particulate effluent sampling system. In addition to the incomplete j installation as discussed above for Item II.F.1.1, two installation

characteristics which were found unacceptable at other Region III nuclear power plants were noted by the inspectors and discussed with 4 the license First, Section 11.5 of Supplement No. 5 to the Byron Safety Evaluation i Report states that recent research into the deposition of airborne radiciodine on metal surfaces indicates that the Byron design may not provide a representative sample. By letter dated August 17, 1984, Byron committed to resolve this matter prior to startup following the first refueling outag The Braidwood installed GA WRGM system is of the same unacceptable sample line configuration as that initially installed at Byro Second, the inspectors informed the licensee of an incident which occurred at the Callaway County Nuclear Station in which it was discovered that if the' sample line becomes disconnected from the suction of the GA WRGM sample pump, the downstream flow meter-4 would continue to register an apparent sample flow rate (Callaway LER 85-028-00 and Inspection Report No. 50-483/85017).

Licensee progress in resolving the problems noted above; completing

installation, necessary modifications, and preoperational testing; writing procedures; and training personnel will be reviewed further during future inspections. (456/86002-09; 457/86002-09)

d. NUREG-0737 Item II.F.1, Attachment 3, Containment High-Range

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Radiation Monitor j Section E.30.3 of Appendix E to the FSAR describes the Containment High-Range Radiation Monitors, contains commitments to install Containment High-Range Radiation Monitors as specified by

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Table II.F.1-3 of NUREG-0737, and provides a plant drawing indicating the location of the monitors. The monitoring system consists of General Atomic Company Model RD-23 high range radiation detectors, Model RM-80 microprocessors, and RM-23 remote display-units. Detectors 1RE-AR020 and 1RE-AR021 will be located in the Unit 1 containment at elevation 514' 8" at Azimuths 90 and 277*,

respectively. Detectors 2RE-AR020 and 2RE-AR021 will be located

'in the Unit 2 containment at elevation 514' 8" at Azimuths 90 and 263*, respectivel The inspectors reviewed the installation status of the monitors; none have been installed. The licensee was reminded that Byron procedures were required to be revised to ensure that the polar crane will not be inadvertently parked such that the monitors would be significantly shielded; it is expected that similar procedures will be necessary at Braidwoo Licensee progress in completing installation and calibration, writing procedures, and training personnel will be reviewed further during future inspections. -(456/86002-10; 457/86002-10)

No violations or deviations were identifie ,,, ANSI /ASME'N510 Acceptance Test Program The inspectors met with licensee representatives to: (1) determine the status of the ANSI /ASME N510 acceptance test program; (2) inform them of the types of documents which should be available onsite for NRC inspector review; (3) discuss programmatic deficiencies discovered recently at other NTOL plants; and (4) request that spinster carbon be laboratory retested, an ANSI /ASME N510 acceptance test compliance analysis be prepared, and the use of silicone sealant on HVAC ductwork and filter housings be evaluated, Program Status The ANSI /ASME N510 acceptance test program is still in the early planning stage and is not' scheduled to begin until April 1986; however, the test contractor has been selecte The progress made towards the successful completion of this test program will be reviewed further during future inspections. (456/86002-11; 457/86002-11) Types of Documents Subject to Review The licensee was informed that the ANSI /ASME N510 acceptance test programs at four NTOLs were recently reviewed by Region III inspectors. The types of documents which were reviewed included:

(1) acceptance test inspector qualification records; (2) licensee quality assurance vendor audits; (3) filter qualification documents; (4) licensee N510 test acceptance criteria; and (5) acceptance test procedures and report _ _ _ _ _ _ _ _ _ _ _ _ _ _

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c. Potential Programmatic Deficiency Areas Although the licensee's program was not developed sufficiently to warrant review, the inspectors met with licensee representatives to discuss programmatic deficiencies discovered recently at other NTOL Potential deficiencies discussed included: (1) performance of tests by uncertified personnel; (2) unresolved vendor audit findings and observations; (3) inadequate carbon adsorber qualification records; (4). lack of carbon adsorber batch traceability; (5) lack of a formal deficiency reporting and resolution tracking system; (6) misuse of or lack of adequate test acceptance criteria; (7) inadequate timing of visual inspections; (8) significantly degraded " spinster" carbon; (9) lack of detailed compliance with N510 test procedure and report specifications;~and (10) improper use of silicone sealant The last three items are discussed in more detail in the next three subsection d. Spinster Carbon Partly because of significant delays in the startup dates for many reactors, qualified carbon has been in storage at some sites for five years or more. This unused carbon is commonly referred to as

" spinster" carbon. Due to the lengthy storage times, spinster carbon may be significantly degraded by the time it is used and therefore may have to be retested to verify adequate retention of performance characteristic The amount of degradation depends on many factors, including: storage period; damage due to handling, moving, and storage techniques; packaging methods; and exposure to contaminants. Although no requirement for retesting spinster carbon currently exists, it appears that if the carbon has been properly stored, it probably need not be retested if the storage time is 18 months or les Retesting should be considered for longer storage times, and if storage approaches five years, retesting should definitely be performed. Batch samples should be tested with methyl iodide to Regulatory Guide 1.52, Table 2 or Regulatory Guide 1.140, Table 2 (as appropriate) acceptance criteria. The carbon should be replaced if it fails the prescribed test. This matter was discussed at the exit meeting on March 5, 1986, and will be reviewed further during a future inspection. (456/86002-12; 457/86002-12)

e. ANSI /ASME N510 Compliance Report Region III inspectors have recently noted, during review of ANSI /ASME N510 acceptance test programs at four other NT0Ls, a significant lack of detailed compliance with N510 ' test procedure and report specification Lack of detailed compliance has the potential of invalidating acceptance test Since N510 acceptance tests are often completed just before scheduled fuel load, invalidation of the test results could influence the actual fuel load dat In an attempt to preclude an occurrence of this kind at Braidwood, the inspectors recommended that the licensee prepare a line-by-line ANSI /ASME N510 compliance analysis report and make the report available for Region III review,

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In' response to inspector concerns regarding N510 compliance and other HVAC potential problem areas, the licensee has initiated a formal. commitment and compliance review effort and identified J. Jasnosz as the coordinator. Mr. Jasnosz will be responsible for the day-to-day coordination effort for N510 compliance and certain other HVAC potential problem areas, such as those discussed in Sections 16 and 17. Although the inspectors informed the licensee that the other four Region III NTOL plants found it advantageous to also appoint a manager-level coordinator who was responsible for assuring a timely station-wide coordination effort, the licensee did not identify such an appointment for Braidwood. The licensee

.is preparing a commitment and compliance report and an action plan tracking system report which are similar in purpose and format to the NUREG-0737 internal compliance reports discussed in Section 1 This matter was discussed at the exit meeting on March 5, 1986,.and will be reviewed further during future inspection (456/86002-12; 457/86002-12) Use of Silicone Sealant on HVAC Ductwork and Filter Housings The inspectors discussed with the licensee the use of silicone sealant at Braidwood on ESF and non-ESF HVAC filtration system The licensee representatives contacted indicated that all ESF and ;

non-ESF HVAC filtration systems apparently have ductwork with mechanical lock longitudinal seams on which silicone sealant is applied by construction specification; however, as of March 5, 1986, other uses of silicone sealant on HVAC filtration system ductwork and filter housings had not been ascertained by the licensee. The licensee identified ductwork construction techniques and associated use of silicone sealant appears to be contrary to FSAR Appendix A commitments regarding Regulatory Guide 1.5 Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Position states that ESF ductwork should be designed, constructed and tested in accordance with the provisions of Section 5.10 of ANSI N509-1976. In the Braidwood FSAR, Appendix A, the licensee does not take exception to this regulatory positio ANSI N509-1976, Subsection 5.10.4 states that longitudinal seams shall be either all welded, seal welded mechan-ical, or in accordance with SMACNA - High Velocity Duct Construction Standards (Pittsburgh Lock or Acme Lock Seam) as required to meet structural and leak-tightness requirements of Paragraphs 5.10.3 and 4.12, respectively. ANSI N509-1976, Subsection 4.12 states that the allowable leakage will, by reference to Paragraph 4.12.3, indicate the required type of duct construction; i.e., welded or nonwelded; however, ducts for ESF systems and all housings shall be welded. Contrary to the above, mechanical lock longitudinal seams with silicone sealant are apparently being used in the construction of ESF air cleaning system ductwor Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Position states that the use of silicone sealants or any other temporary patching material on the ESF filters, housings, mounting frames, or ducts should not be allowed. In the Braidwood FSAR, Appendix A, the

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licensee does not take exception to this regulatory position. Contrary to the above, mechanical lock longitudinal seams with silicone sealant are apparently being used in the construction of.ESF air cleaning system ductwor Regulatory Guide 1.140, Revision 0 (March 1978), Regulatory Positions 3.f and 5.c have the same wording as Regulatory Guide 1.52, Revision 2 (March 1978), Regulatory Positions 3.n and 5.c,.respectively (which are discussed above). In the Braidwood FSAR, Appendix A, the

. licensee does not take exception to these regulatory positions which state, in part, that all housings shall be welded and the use of silicone sealant or any other temporary patching material on the welded housing should not be allowed. The inspectors requested the licensee to verify that, in accordance with the FSAR commitments to Regulatory Guide 1.140, all non-ESF filter housings are of all-welded construction without the use of silicone sealant or any other temporary patching materia During the exit meeting on March 5, 1986, the inspectors informed the licensee that NRR, on a case-by-case basis, ascertains the acceptability of silicone sealants on HVAC ductwork and filter housings when its use is identified by the NRC or the licensee The licensee was also

, informed that Region III obtained guidance from the Director, Division of Licensing, NRR (memorandum dated August 26, 1985) concerning the acceptability of sealant applied to the Zion control room emergenc air cleaning system during 1983 repairs and modifications. That memorandum, with the attached NRR generic position statement on the use of silicone sealants and other temporary patching material, was attached to Zion Inspection Reports No. 50-295/85040; No. 50-304/8504 The inspectors requested the licensee.to notify NRR'of the specific uses of silicone sealant or other temporary patching material at Braidwood on ESF and non-ESF air cleaning system ductwork and filter housings. This matter is considered an unresolved item, pending the identification by the licensee of how and where this material was used on air cleaning systems, notification of NRR by the licensee, and resolution of this issue by NRR. (456/86002-013; 457/86002-013)

No violations or deviations were identifie . HVAC Filter Housing Drain Systems-Several ESF and non-ESF HVAC fiiter housings were inspected to ascertain if the design and construction commitments made in Appendix A to the Braidwood FSAR for filter housing drain systems have been met. The air cleaning systems reviewed were the Technical Support Center (TSC) emergency makeup, the Control Room emergency makeup, the offgas exhaust, the post-LOCA purge exhaust, and the auxiliary building filtered tank vent exhaus Regulatory Guide 1.52, Revision 2, March 1978, (Regulatory Position 3.h) and Regulatory Guide 1.140, Revision 0, October 1978, (Regulatory Position 3.e) state that the filter housing water drains should be designed and constructed in accordance with the recommendations of Section 4.5.8 of ERDA 76-21 and Section 5.6 of ANSI N509-1976, respectively. These recommendations include individually valving, sealing,

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or otherwise protecting drain lines from individual chambers of the housing to prevent bypassing of contaminated air around filters or adsorbers through the drain system. The licensee did not take exceptions to these regulatory positions in Appendix A to the FSA During the plant tour of these filter housings, a number of inspector concerns were raised regarding licensee compliance with the above regulatory positions, including:

(1) the installed drain line configuration for the offgas exhaust filter housing appears unacceptable: (2) administrative controls are apparently needed for the isolation valves; (3) air leak-tightness of isolation valves should be verified; (4) the acceptability of installed water check valves should be substantiated; and (5) fire protection system potential leakage may damage carbon adsorbers. These concerns are discussed in the following five subsection Offgas Exhaust Filter Housing Drain System The offgas exhaust filter housing has three drain lines which tie into a common header with a water check valve before each cross-ti ,

This design violates the criterion of individual line valving as i specified in the licensee's commitment to Regulatory Position of Regulatory Guide 1.140, Revision 0 (October 1978). This same drain line configuration was found unacceptable at Byron as documented in Inspection Reports No. 50-454/84033; 50-455/84026 (0 pen Items No. 454/84033-01; 455/84026-01). At Byron, the offgas exhaust filter housing drain line valving was rearranged such that the check valves were installed in individual drain lines before the common header cross-ties (Section 3 of Inspection Report No. 50-454/84066; 50-455/84044). This matter was discussed at the exit meeting on March 5, 1986, and will be reviewed further during a future inspection. (456/86002-14; 457/86002-14) Filter Housing Drain Line Isolation Valve Administrative Controls The TSC emergency makeup air cleaning system has a positive pressure filter housing which has manual isolation valves installed in individual drain lines to prevent filter bypas In order for these valves to serve their intended function, the position (open or closed) of HVAC filter housing drain line isolation valves must be procedurally controlled to ensure that these valves are closed during filter operation to preclude filter bypas The licensee

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should perform a review to identify procedures needed to ensure that specific instructions are provided on controlling filter housing drain line isolation valves and revise the procedures, as appropriate, to incorporate the specific instructions prior to the associated systems being released to the plant staff for operatio This matter was discussed at the exit meeting'on March 5, 1986, and will be reviewed further during a future inspectio (456/86002-15; 457/86002-15)

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c. Filter Housing Drain Line Isolation Valve Leakage Determination

Even if proper administrative control is established to ensure

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that filter housing drain line isolation valves are closed during filtration train operation, filter bypass via the drain lines is not precluded unless the isolation valves are leak tight. The licensee should verify air leak tightness for all filter housing drain line isolation valves as part of the preoperational test progra This matter was discussed at the exit meeting on March 5, 1986, and will be reviewed further during a future inspection. (456/86002-16; 457/86002-16)

d. Filter Housing Drain Line Water Check Valves During the plant tour of the station HVAC filter housings, the inspectors noted there were water check valves installed in each of the drain lines to prevent water backup into the housings. At the exit meeting on August 23, 1984, (Inspection Reports No. 50-456/84024; 50-457/84023), the inspectors requested that the licensee obtain adequate documentation on the filter housing drain line water. check valves installed at Braidwood, if different that those used at Byron, to determine if they are suitable for their intended purpose (0 pen Items No. 456/84024-01; 457/84023-01). The licensee has addressed the other aspects of these open items, but not this specific issu Leakage tests at Byron verified that the standard make and model filter housing drain line water check valves at that facility provides an adequate air tight barrier for the negative pressure filter housings (Section 3 of Inspection Reports No. 50-454/84066; 50-455/84044, Open Items No. 454/84033-01; 455/84026-01). Because the water check valves at Braidwood are apparently of a different make and model than those used at Byron, it appears necessary for the licensee to verify air-leak tightness for all filter housing drain line water check valves as part of the Braidwood preoperational test program. This matter was discussed at the exit meeting on March 5, 1986, and will be reviewed further during a future inspectio (456/86002-17; 457/86002-17)

e. Fire Protection System Potential Leakage Problems The inspectors briefed licensee representatives on problems other nuclear power plants have had with filter damage due to fire protection system leakage, and system modifications those plants are considering to preclude recurrence. During the plant tour, the inspectors noted that the filter housing fire protection deluge systems are of a design similar to those which reportedly have led to instances of filter damage due to valve leakage problems at other nuclear power plants. The inspector informed the licensee of an incident at Hatch, Unit 1 (LER 85-018-00 and IE Information Notice No. 85-85) where inadvertently flooded ductwork leaked water onto an Analog Transmitter Trip (ATTS) panel. This introduced moisture into the ATTS panel which, in turn, resulted in the malfunction of a safety relief valve and the High Pressure Coolant Injection Syste The inspectors discussed with the licensee how several other licensees

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have responded to the Hatch Plant incident by design modifications, a'dministrative procedures, and revision of fire preplans. In addition to the internal response to IE Information Notice No. 85-85, the~

licensee should perform a review of the charcoal filter fire protection

isolation provisions to ensure that there are adequate provisions to prevent leakage through the Fire Protection System from wetting filter charcoal. 'This matter was discussed at the exit meeting"on March 5, 1986, and will be reviewed further during a future inspectio (456/86002-18; 457/86002-18)

During the plant tour, the inspectors noted that the manual fire protection deluge isolation valves appear to be mounted too close to the filter housings to be readily accessible under predicated elevated charcoal temperatures for the control room emergency makeup,

. post-LOCA purge, and the auxiliary building filtered tank vent exhaust air cleaning systems. It was also noted that the location of the TSC

. emergency makeup air cleaning system filter housing fire protection

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deluge isolation valves, although well away from the housing, are too high above~the floor for ready access. This matter was discussed at the exit meeting on March 5, 1986, and will be further reviewed during a future inspectio (456/86002-19; 457/86002-19)

No violations or deviations were identifie . Exit Meeting The inspectors met with licensee representatives denoted in Paragraph 1 on February 27 and March 5,1986. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature. In response to certain item discussed by the inspector, the licensee:

' Acknowledged the inspectors comments about radiation protection

, related facility space deficiencie The licensee stated that a schedule for desigr.ating facility space, and construction and equipping the facility will be developed soon.

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. Acknowledged the inspectors comments about meeting the schedule for completion of testing and calibration of ARMS and PRMs.

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