IR 05000456/1986044

Insp Repts 50-456/86-44 & 50-457/86-32 on 860818-22 & 27-28. No Violation or Deviation Noted.Major Areas Inspected: Radiation Protection & Radwaste Programs,Ie Info Notice 86-022 & Status of Certain TMI Action Plan Items

ML20209G879
Person / Time
Site:	Braidwood
Issue date:	09/09/1986
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209G871	List: IR 05000456/1986044 ML20209G868
References
TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-456-86-44, 50-457-86-32, IEIN-86-022, IEIN-86-22, IEIN-86-222, NUDOCS 8609150095
Download: ML20209G879 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-456/86044(DRSS); 50-457/86032(DRSS)

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Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: August 18-22 and August 27-28, 1986

/A Inspector: W . r nt Y-kM Date r

ify Approved By: . . reger, Chief 9-8-84 Facilities Radiation Protection Section Date Inspection Summan Inspection on August 18-22 and August 27-28, 1986 (Report Nos. 50-456/86044(DRSS);

50-457/86032(DRSS))

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

organization and management control; training and qualifications; external occupational exposure control; internal exposure control and assessment; control of radioactive materials and contamination, surveys and monitoring; .

facilities and equipment; the solid, liquid, and gaseous radwaste program; IE Information Notice No. 86-22; status of certain TMI action plan items; and status of licensee action on previous inspection finding Results: No violations or deviations were identifie {DR ADOCK 05000456 =

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DETAILS Persons Contacted

• W. Schroeder, Station Services Superintendent

• E. Groth, Assistant Construction Superintendent

• L. M. Kline, Regulatory Assurance Group Leader

• D. Paquette, Maintenance Assistant Superintendent

• R. Aker, Radiation-Chemistry Supervisor J. Anspaugh. Health Physicist, Group Leader D. Cecchett, Regulatory Assurance

• A. D' Antonio, Regulatory Assurance

• L. Davis, Assistant Superintendent, Technical Services

• K. Hall, Nuclear Services, Health Physics

• J. Huffman, Master Mechanic

• J. Jasncsz, Regulatory Assurance

• B. Kulik, Senior Quality Assurance Inspector

• T. Lewis, Startup Staff J. Petro, Radwaste Coordinator S. Stevenson, Nuclear Services, Health Physics J. Testa, Radwaste Coordinator

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• T. W. Simpkin, Regulatory Assurance

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• R. Kyrouac, Quality Assurance Supervisor

• T. Tongue, NRC, Senior Resident Inspector

• T. Taylor, NRC, Resident Inspector

• Denotes those present at entrance / exit meetin . General This inspection, which began at 8:15 a.m. on August 18, 1986, was conducted to examine aspects of the preoperational radiation protection and radwaste programs. Licensee action on previous inspection findings, 3 status of certain TMI action plan items and IE Information Notice revie , Licensee Action on Previous Inspection Findings (Closed) Open Item (456/83-03-01; 457/83-03-01): Rad / Chem staffing and training levels in question to meet fuel load dat By letter, dated r July 11, 1986, the licensee outlined actions that had been taken to strengthen the Braidwood health physics staff. See Sections 4 and (Closed) Open Item (456/86002-06; 457/86002-06): Complete compliance action plan reports for NUREG-0737, Items II.B.3 and II.F.1 (attachments 1, 2, and 3). See Sections 15, 16 and 1 (Closed) Open Item (456/86002-02; 457/86002-02): RWP and dosimetry

, areas need to be designated. An area for RWP and dosimetry issue has

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been designated on the third floor of the Service Building. The inspector verified that the designated space is adequate and it will be available when require (

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(0 pen) Open Item (456/86002-05; 457/86002-05): Braidwood Health Physics space deficiencie See Section 7 and 1 (0 pen) Open Item (456/86002-04; 457/86002-04): Calibration and testing of ARM /PRM needs to be complete See Section 1 . Organization and Management Controls The inspector 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-identification and

correction of program weaknesse '

Since the last radiation protection inspection in May 1986, several organizational charges have been made, including:

• Three health physicists were added to the Braidwood staff. Two of

, these individuals are recent graduates with bachelor degrees in

! Health Physics. The third individual has a masters degree in

] Environmental Health and has been employed by Commonwealth Edison for approximately two years with other responsibilitie * An experienced Health Physicist (HP) was temporarily assigned to supplement the Braidwood HP staff. Corporate Nuclear Services Health Physics assigned this individual on September 2, 1986, and the assignment will continue through the Unit 1 startup test progra ,

• An experienced Health Physics Foreman was named lead forema '

The inspector reviewed the results of station Quality Assurance Audits

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conducted since the last radiation protection inspection in May 198 ,

• QAA 20-86-14 audit, conducted May 9-16, 1986, reviewed station *

procedure adherence / control. One finding in the radiation protection area regarding acceptance criteri Corrective action has been completed; no problems were note * QAA 20-86-16 audit, conducted May 9-16, 1986, reviewed radiation .

protection surveys and records. One observation concernir.g the  !

lack of a procedure controlling the frequency of re-surveys of  !

! radiologically controlled areas was identified. RWP procedure  :

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! BwRP 1140-1, Revision 0, which specifies re-survey frequencies,

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was issued July 11, 198 ;

The Health Physicists (HP) meet daily to discuss problem areas and the status of various project At 8:30 every morning, the Rad / Chem t Supervisor meets with Station HP, ALARA Ccordinator, lead foreman and others to discuss the plan of the da In addition, the station plan of '

the day meeting, which discusses work to be done, and support services ,

and equipment that will be required, is attended by a Rad / Chem i

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representative. According to licensee representatives, this meeting has helped coordinate work group activities and more effectively allocate resource There are no items remaining open in this are . 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 ccmpletion of FSAR and other commitment The inspector selectively reviewed the qualifications of persons filling positions within the health physics and radwaste organizations to determine if they are consistent with the Final Safety Analysis Report (FSAR). Based on this review, it appears the licensee's FSAR commitments in this area have been me The health physicists (HP) attend weekly seminars on operational health physics intended to strengthen the health physics program and to broaden the operational experience base of the HP staf The RCT qualification card program was implemented in July 1985. Record review revealed that 26 RCTs have completed their qualification card sign-offs and about 30 are expected to complete qualification and sign-off by September 30, 1986. A sufficient number of RCTs have completed qualification training to satisfy shift manning requirement 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 Since August 1, 1986, all personnel required to enter the plant restricted areas have received Nuclear General Employee (NGET) training to meet 10 CFR 19.12 requirements. NGET training for persons requiring unescorted access is about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> of classroom lectures and requires

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a 70% grade on each of two exam There are no items remaining open in this are . 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 , _ _ . - - - , - .-- .-- - .-

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The licensee currently is issuing vendor supplied film badges as primary dosimetry for RWPs requiring dosimetry. Procedure BwRP 1140-1, Revision 0, Radiation Work Permit Program, which was issued July 11, 1986, is followed for issuing dosimetry. Plans call for a station TLD program to be implemented in late 198 The only items remaining open in this area are construction of the TLD calibration facility and completion of the RWP/ dosimetry issue facilit . 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 A second whole body counter (WBC) and the mask fit test booth have been installed in the rad / chem office area on the third floor of the Service Buildin The respirator issue, cleaning, and storage facility is being constructed on the 426' level of the Au~xiliary Building. The adequacy of this facility will be reviewed during a future inspection (456/86002-03; 457/86002-03).

Items remaining open in this area are completion of respirator issue, cleaning and storage are . Control of Radioactive Materials and Contamination, Surveys, and Monitoring 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 inspector selectively reviewed calibration records for portable survey instruments and air samplers. 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 calibration date The personnel decontamination room and the station laundry facility are being constructed on the 426' level of the Auxiliary Buildin The items remaining open in this area are completion of the laundry, the personnel decontamination area, and the instrument storage room.

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. 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 BwRP 1220-5, Revision 2, Comparison of Personnel Dosimetry Results BwRP 1220-6, Revision 0, Film Badge /TLD Spiking BwRP 1270-4, Revision 1, Operation and Use of the Dosimeter Corporation Multiple Dosimeter Calibration BwRP 1480-1, Revision 2, Contamination Surveys BwRP 1520-1, Revision 1, Offsite Shipment of Radioactive Material BwRP 1740-1, Revision 1, Radiation Protection Practices During Accident Conditions There are no items remaining open in this are . 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 made significant progress toward calibration of ARM /PRMs required by fuel load. According to the licensee, approximately 83 monitors are required by fuel load and 69 of these have been calibrated and are operational. Records of calibrations were reviewed; no problems were noted.'

An area for the storage of Health Physics instruments has been designated but construction has not been complete Items remaining to be completed in this area include completion of the calibration and testing of the ARM /PRMs, completion of the health physics instrument storage room and completion of the tool and equipment decon and storage facilit . Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: established formal ALARA policy and procedures; and worker awareness of the ALARA progra The following recently issued ALARA procedures were reviewed to determine if they are consistent with FSAR commitments and good health physics practic BwRP 1140-1, Revision 0, Radiation Work Permit (RWP) Program BwAP 700-1, Revision 0, ALARA Policy Procedure BwAP 700-2, Revision 0, Guidelines for an ALARA Review BwAP 700-3, Revision 0, ALARA Suggestion Program

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The licencee has 5mplemented what appears to be a strong ALARA progra The station ALARA Review Committee has been formed and meets once a month. An ALARA evaluation procedure policy has been established and has been implemented in a few instances to date. The licensee has developed a Radiation Evaluation Program (REP) and is developing a plant equipment photofil Items remaining to be completed are the plant photofile, an ALARA awareness program, and ALARA training for radiation protection foreman and shift qualified technician . Solid Radioactive Waste The licensee's facilities for collection, concentration, solidification, packaging and shipment of solid radfoactive 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 in March,198 No problems were note The licensee is planning to use a vendor supplied solidification system until the Stock solidification and volume reduction system is complete, preoperationally tested and accepte Items remaining to be completed in this area are the radwaste volume reduction and solidification syste . Liquid Waste System Licensee facilities for the collection and storage of liquid radioactive waste have been completed and testing of these systems is in progres The licensee is currently cleaning and hydrolozing all the Unit 2 floor drains to reduce the spread of contamination when the unit is operationa Items remaining to be completed in this area are completion of the testing and operation of the radwaste evaporation and demineralizer . Gaseous Waste Systems Construction of licensee facilities for the collection and storage of gaseous radioactive waste has been complete Acceptance and preoperational testing of these systems is in progress. Procedures for processing gaseous radwaste are in various stages of approva Items remaining to be completed in this area are completion of the testing of the gaseous systems and completion of the procedure *

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15. 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 system. The system consists of a General Atomic Wide Range Gas Monitor (GA WRGM) for 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 The inspector reviewed the status of the high range noble gas effluent monitors and their commitment compliance documentatio The monitors were turned over to the system test engineer in August 198 Preoperational testing, calibration, and procedures are expected to be completed by mid-3eptember. All of the 29 compliance action plan items have been completed. Thus, the applicant appears able to adequately demonstrate compliance with FSAR commitments to NUREG-0737, Item II.F.1, Attachment 1. Completion of RCT training, including the operation of these monitors, is being tracked by Open Item No. 456/84-03-01; 457/84-03-01. This matter remains open pending completion of calibration and procedure . 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 effluent sampling system and the analysis of iodine and particulate effluent samples. The iodine and particulate sampling oystem is a part of the General Atomic system described above for Item II.F.1.1 and provides for obtaining grab samples from the auxiliary building ven The sample media will be analyzed in the station's counting rooms by gamma ray spectrometers which utilize Ge (Li) detector The inspector reviewed the status of the accident range iodine and particulate effluent sampling system. The sampling system was turned over to the system engineer in August 1986. Preoperational testing and procedures are expected to be completed by mid-September. All of the 30 compliance action plan items have been completed; thus, the dpplicant appears able to adequately demonstrate compliance with FSAR commitments to NUREG-0737, Item II.F.1, Attachment 2. Completion of RCT training, including the operation of this system and sample analysis equipment, is being tracked by Open Item No. 456/84-03-01; 457/84-03-0 This matter remains open pending completion of calibration and procedure . NUREG 0737 Item II.F.1, Attachment 3, Containment High-Range Radiation Monitor 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 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 RD-23 high range radiation detectors, Model RM-80 microprocessors, and RM-23 remote display units. Detectors 1RE-AR020 and 1RE-AR021 are

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located in the Unit 1 containment at elevation 514' 8" at azimuths 90 and 277*, respectively. Detectors 2RE-AR020 and 2RE-AR021 are located at elevation 514' 8" at azimuths 90* and 263 , respectively. Appropriate procedures have been revised to ensure that the polar crane will not be inadvertently parked such that the monitors would be significantly shielde The inspector reviewed the status of the containment high-range radiation monitors and their commitment compliance documentation. The monitors were turned over to the system test engineer in August 1986. Preoperational testing, calibration, and procedures are expected to be completed by mid-Septembe All of the 14 compliance action plan items have been completed; thus, the applicant appears able to adequately demonstrate compliance with FSAR commitments to NUREG-0737, Item II.F.1, Attachment This matter remains open pending completion of calibration, training, and procedure . NUREG-0737 Item III.D.3.3, Inplant Iodine Radiation Monitoring The inspector reviewed the licensee's capability to sample iodine in the presence of noble gases. Appropriate air samples and silver zeolite cartridges are available. No problems were noted. This item is considered close . Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspectio The scope and findings of the i inspection were summarized. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee identified no such documents / processes as proprietar l

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