IR 05000456/1986019

Insp Repts 50-456/86-19 & 50-457/86-17 on 860519-22.No Violation or Deviation Noted.Major Areas Inspected: Preoperational Radiation Protection & Radwaste Program, Including Organizational & Mgt Control

ML20199B518
Person / Time
Site:	Braidwood
Issue date:	06/10/1986
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199B494	List: IR 05000456/1986019 ML20199B490
References
50-456-86-19, 50-457-86-17, IEB-79-19, IEIN-85-081, IEIN-85-81, NUDOCS 8606170166
Download: ML20199B518 (7)

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U.S. NUCLEAR REGULATORY- COMISSION-

REGION III

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Reports No. 50-456/86019(DRSS); 50-457/86017(DRSS)

Docket Nos. 50-456;-50-457 Licenses No. CPPR-132; CPPR-133

' Licensee:._. Commonwealth Edison Compan Post Office Box-767 Chicago, IL -60690 Facility Name: 'Braidwood Nuclear Power. Station, Units 1 and 2 Inspection At: Braidwood Site,'Braidwood, IL Inspection Conducted: Ma

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A #y 19-22, 1986 Inspector: W. B. Grant t* L IIate i

Approved By: L. R. Gr ger, Chief 6-/8-86 Facilities Radiation Date Protection Section Inspection Summary Inspection on May 19-22, 1986 (Reports No. 50-456/86019(DRSS);

50-457/86017(DRSS))

Areas-Inspected: Routine unannounced preoperational radiation protection and radioactive waste programs-for Units 1 and 2 including: organizational and

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management control; training and qualifications; external occupational exposure;

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internal occupational exposure control and assessment; control of radioactive materials, surveys, and monitoring; facilities and equipment; IE Information

-Notice No. 85-81 and No. 85-85; and IE Bulletin No. 79-19.

! Results: No violations or deviations were identified.

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DETAILS 1. Persons Ccntacted

• R. Aker, Rad / Chem Supervisor J. Anspaugh, Health Physicist

• A. D' Antonio, Regulatory Assurance

• L. Davis, Assistant Superintendent, Technical Services

• E. Fitzpatrick, Station Manager P. Harvey, Rad / Chem Health Physics Foreman

• J. Jasnosz, Regulatory Assurance

• G. Marcus, Quality Assurance

• C. Schroeder, Services Superintendent D. Shamlin, Rad / Chem Health Physics Foreman-T. VanDeVort, Quality Assurance

• T. Tongue, NRC, Senior Resident Inspector

• W. Kropp, NRC, Senior Resident Inspector

• T. Taylor, NRC, Resident Inspector

• Denotes those present at the exit meetin . General The inspection, which began at 9:30 a.m. on May 19, 1986, was conducted to examine aspects of the preoperational radiation protection program, licensee action on previous inspection findings, IE Information Notice review, and the licensee action on IE Bulletin No. 79-1 . Licensee Action On Previous Inspection Findings (Closed) Open Item (456/84010-02; 457/84010-02): Revise radioactive shipment procedures to include 1983 NRC and DOT regulation changes. The inspector verified that revised licensee procedures for shipment of radio-active materials contain the 1983 changes in D0T and NRC regulation . Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection and radwaste programs, including: responsi-bilities and authorities; staffing; proposed system for program audits; and proposed methods concerning self-identification and correction of program weaknesse Since the last radiation protection inspection in March 1986, several organizational. changes have been made, including:

• A Health Physicist with approximately three years experience terminated. employment on May 30, 198 . :

• A Health Physicist, recently graduated with a bachelors degree in Health Physics, was hire * -An Assistant ALARA Coordinator was assigned to the Rad / Chem staf The net loss of health physics experience adds to the overall lack of both HP and operational experience of the Rad / Chem staf Licensee management apparently has authorized the hiring of three additional health physicists at Braidwood. Also, the licensee has committed to increase the experience level of the health physics staff. This matter was discussed at the exit meeting and will continue to be reviewed during future inspections (456/83003-01; 456/83003-01)

The inspector reviewed the results of station Quality Assurance Audits and Surveillances conducted to date during 198 * QAA 20-86-02 audit, conducted January 14-17, 1986, reviewed calibration of laboratory equipment, RCTs test results, capability of cleanup of radioactive contamination, and radiation source inventor Two observations and one open item resulte No problems were note * QAA 20-86-09 audit, conducted March 10-14, 1986, reviewed license for Special Nuclear Material (SNM), license for Byproduct material, procedures for control of radioactive material, records of receipt, inventory, and transfer of SNM, and procedures for inventory of SN No findings or observations resulte * QAS 20-86-031 and 032 surveillance, conducted January 29, 1986, reviewed radiation area access controls and radiation protection activitie One minor deficiency involving review of surveys

'resul ted. The deficiency has been corrected. No problems were note * QAS 20-86-050 surveillance, conducted February 27, 1986, reviewed radiatio.n area access controls and radiation protection activitie One minor deficiency, involving RWP-I review resulte The deficiency has been corrected. No problems were note * QAS-20-86-068 surveillance, conducted March 27, 1986, reviewed radiation area access contro No deficier cies resulte * QAS-20-86-069 surveillance, conducted March 27, 1986, reviewed radiation protection activitie No deficiencies resulte * QAS-20-86-086 survei_llance, conducted April 29, 1986, reviewed radiation protection activitie No deficiencies resulte * QAS-20-86-087 surveillance, conducted April 29, 1986, reviewed radiation area access control. One deficiency involving RWP review resulted.' Corrective action has been completed; no problems were note No violations or deviations were identifie .

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5. Training and Qualifications The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation 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 was management techniques used to implement these programs and the licensee's completion of FSAR and other commitment Nuclear General Employee Training (NGET) for CECO employees has been completed. Contractor NGET training sessions are currently given Monday through Friday each week. Over half of the 3,000 contractors onsite have received this training. NGET contractor training is expected to be completed in July 1986. The inspector attended a portion of the contractor NGET clas The classroom was of adequate size and well equipped. In general, the presentation was of good quality and students participate NGET course outlines and copies of the radiation protection portion the NGET exam were reviewed by the inspecto No problems were note In addition to the nine RCTs who are ANSI N18.1-1971 qualified, the licensee plans to have 29 RCTs trained and through Braidwood qualification card training by July 1986. RCT qualification training results will be reviewed during a future inspectio . External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: adequacy of facilities, equipment, personnel and procedures; adequacy of the dosimetry program to meet routine and emergency needs; and completion of requirements and FSAR commitment The licensee has selected an area for the TLD calibration facilit The facility will be built as other construction priorities permit.

The inspector selectively reviewed active RWPs for accuracy, survey data l

and approvals. No problems were noted. There are currently four active i RWPs requiring dosimetry. Dosimetry is issued to and other RWP require-i ments are discussed with workers by rad / chem personnel at access contro The inspector selectively observed a health physics foreman and RCT issue

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dosimetry and discuss RWP requirements with workers. Procedures for using RWPs and for issuing dosimetry were followed. Rad / chem personnel acted in a professional manner and displayed understanding, tact, and patience. No

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No violations or deviations were identified.

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, : Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: facilities equipment, personnel and procedures affecting internal exposure control and personal assessment; and determination whether administrative control, engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements and FSAR commitment The licensee continues to whole body count (WBC) personnel to provide WBC baseline data, and to fit test personnel who will rd:uire respiratory protectio The inspector reviewed the vendor calibration of the whole body counter; no problems were note The licensee performs daily source checks to demonstrate that the counter is calibrate The licensee has implemented a preoperational air sampling program to determine baseline levels for alpha, beta, and gamma radioactive airborne activit The preoperational air sampling program is reviewed monthly by the Lead Health Physicist to determine that all points are being properly sampled, and that all results are correctly calculated and tabulate No problems were note . Radiation Protection Procedures The inspector 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 WRP 1120-1, Revision 2, Controlled Area Access BWRP 1200-TS7, Revision 3, Multiple Dosimetry Log Sheet BWRP 1210-7, Revision 1, Personnel Monitoring for External Exposures BWRP 1220-1, Revision 2, Film /TLD Badge Issuance and Completion of i Occupational External Radiation Exposure History Form

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l BWRP 1230-1, Revision 3, Radiation Exposure Investigation Report BWRP 1340-3, Revision 1, Fastscan Whole Body Counter Routine Operation l

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BWRP 1360-1, Revision 1, Air Sampling of Suspected and Known Airborne Radioactive Areas BWRP 1520-4, Revision 2, Surveying Radioactive Material Shipments BWRP 1610-2, Revision 3, Leak Testing of Radioactive Sources BWRP 1900-A1, Revision 1, Radiation Protection Training Items for Escorted Visitors

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, 'i BWRP 1900-T1, Revision 1, Radiation Protection Training Checklist BWRP 1910-1, Revision 1, Radiation Protection Training _for Escorted Visitors

No violations or deviations were identifie l Control of Radioactive Materials and Contamination The. inspector reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of instrumentation, equipment, and procedures; and determination whether provision for control of radioactive materials and contamination meet requirements and commitment The licensee has implemented a preoperational smear. sampling program to l establish baseline data on natural background. Smears are taken in general access areas and work area surfaces and equipment. No problems were note The inspector witnessed the calibration of the fuel building area radiation monitor (ARM). The ARM was calibrated by instrument mechanics using a 10 mci Cs-137 source and assisted by RCTs. RWP 86005 authorized calibra-tion of the ARMS using radioactive sources. The inspector verified that calibration procedures, the RWP, and good health physic practices were followed. ARM /PRM are calibrated after they are turned over to the plant by construction. According to the licensee, approximately 81 monitors'are required to be operable by fuel load and about 20 of these have been turned over to the plant and are calibrate The inspector selectively reviewed survey instrument calibration record Survey instruments are calibrated quarterly. Calibration ranges reflected applicable ranges encountered in the field. Responses were within tolerance levels. A computer tracking system is used to identify upcoming calibra-tion dates. No problems were note No violations or deviations were identifie Facilities and Equipment The inspector 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 ,

The licensee has designated ade tional areas on the third floor of the service building to' rad / chem for use in RWP and dosimetry issue and additional office space. This is a response to inspector concerns regarding the amount of area designated for access control. This newly designated. area and the space deficiencies discussed in In3pection Reports No. 456/86002; No. 457/86002 will continue to be reviewed during future inspec.tion (456/86002-05; 457/86002-05)

No violations or' deviations were identifie (

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10. IE Bulletin No. 79-19 The inspector reviewed licensee action taken in response to IE Bulletin No. 79-19 " Packaging of Low Level Radioactive Waste for Transport and Burial." The inspector verified that the licensee has current copies of NRC and DOT regulations; a copy of the Barnwell license; written designation of personnel responsible for safe transfer, packaging, and transport of low level radioactive material; approved procedures and instructions for handling radioactive waste; a personnel training, and retraining program; and an audit program for radwaste activities in accordance with this bulletin. No problems were noted; action on this bulletin is considered close . IE Information Notice IE Information Notice 85-81 - Problems Resulting in Erroneously High Reading with Panasonic 800 Series Thermoluminescent Dosimeters (TLD):

Braidwood does not use TLDs for personnel monitoring at this time. When a TLD program is used at Braidwood it will be part of a corporate functio A corporate response to this notice dated November 7, 1985, contains proper corrective actions.

$ 12. Exit Meeting The inspector met with licensee representatives (denoted in Paragraph 1)

on May 22, 1986. The inspector 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 proprietar The licensee acknowledged the inspector's comments about the radiation protection staffing and space deficiencie ,

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