IR 05000456/1987020
| ML20235J540 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 07/02/1987 |
| From: | Grant W, Greger L, Slawinski W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235J505 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-456-87-20, 50-457-87-18, IEIN-86-107, NUDOCS 8707150632 | |
| Download: ML20235J540 (12) | |
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U.S. NUCLEAR REGULATORY COMfiISSION.
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REGION III
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Reports No. 50-456/87020(DRSS); 50-457/87018(DRSS)
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Docket Nos. 50-456; 50-457 Licenses'No. NPF-70; CPPR-133 Licensee:
Commonwealth Edison Company.
' Post Office Box 767
Chicago, IL 60690
1 Facility Name:
Braidwood Station, Units 1 and 2
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Inspection At:
Braidwood Site, Braidwood, Illinois.
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Inspection Conducted:
June 8-12, 1987 WN 7 I l
Inspectors:
W.'B. Grant Date
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Date Approved By:
L.
ober Greger, Chief
87 Facilities Radiation Protection Date'
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Section l
Inspection Summary Inspection on June 8-12, 1987 (Reports No. 50-456/87020(DRSS);
No. 50-457/87018(DRSS))
Areas Inspected:
Routine, unannounced inspection.of the operational radiation
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protection program and the solid, liquid, and gaseous.radwaste program for Units 1 and 2, including organization and management control; training and qualifications; exposure control; radiation protection procedures; ALARA activities; control of radioactive materials; status of'radwaste systems; status of certain TMI action plan items; and a review of the licensee's action-concerning IE Information Notice No.86-107.
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l Results:
No violations or deviations were identified.
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8707150692 070702 ADOCK 0500 6-gDR
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DETAILS
1.
Persons Contacted
- R. Aker, Radiation / Chemistry Supervisor M. Andrews, Station Chemist
- P. Barnes, Supervisor Regulatory Assurance S. Degarmo, Health Physicist
- E. Fitzpatrick, Station Manager J. Kielbasa, Radiological Engineer J. Petro, Operating Engineer E. Roche, ALARA Coordinator C. Schoeder, Services Superintendent D. Shamlin, Lead Foreman P. Smith, Shift Engineer
- M. Takaki, Regulatory Assurance
- M. Vonk, Station Health Physicist
K. Weaver, Start-up Health Physicist
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R. Yungk, Operating Engineer The inspectors also contacted other licensee employees and contractors including regulatory assurance, radiation protection, operations and engineering personnel.
- Denotes those present at the entrance / exit meeting.
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2.
General This inspection, which began at 11:30 a.m. on June 8,1987, was conducted j
to examine aspects of the operational radiation protection program, l
status of radwaste systems, licensee action on previous inspection findings and status of certain TMI action plan modifications.
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (456/86002-03; 457/86002-03):
A respirator issue, cleaning, and storage area needs to be built.
An adequate facility has been completed on the 426' level of the Auxiliary Building.
See Section 9.
(Closed) Open Item (456/86002-05; 457/86002-05):
Braidwood Health Physics. Space Deficiencies.
The laundry facility has been completed.
Space has been designated for the hot tool storage and dec6n and the personnel decontamination facilities.
See Section 11.
(Closed) Open Item (456/86022-09; 457/86002-09):
Complete installation, procedures, and training on use of post-accident effluent sampling per NUREG 0737 Item II.F.1.2.
Reoperation testing and calibrations have been completed, procedures and training have been completed.
Modifications necessary to demonstrate compliance with FSAR commitments to NUREG 0737, Item II.F.1, Attachment 2 have also been completed.
See Section 13.
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Organization and Management Controls
The inspectors reviewed the licensee's organization and management
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controls for the radiation protection and radwaste programs including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these
programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these programs.
Audits are discussed in Section 5.
l Since the last radiation protection inspection in October 1986, several
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organizational changes have been made, including:
I The ALARA Coordinator transferred to training.
- A training instructor was appointed ALARA Coordinator.
- An Engineering Assistant from Nuclear Services was appointed RWP
Coordinator working in the ALARA group.
The Health Physicists (HPs) meet daily to discuss problem areas and the status of various projects.
The Rad / Chem Supervisor meets every morning with the Station HP, ALARA Coordinator, Lead Foreman and others to discuss the plan of the day.
In addition, the station plan of the day meeting, during which work to be done and support services and equipment required are discussed, is attended by a Rad / Chem representative.
Due to Unit 1 startup radiation protection (RP) activities the RP staff has been augmented by approximately 26 contractor radiation protection personnel; including 20 technicians, a decontamination coordinator, a foreman, 3 engineering assistants, and a site supervisor.
The qualifications of the contractors and the training given to them at Braidwood Station is discussed in Section 7.
No violations or deviations were identified.
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5.
Audits and Appraisals
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The inspectors reviewed station Quality Assurance (QA) audits and surveillance of the radiation protection and radweste programs I
conducted since October 1986.
Extent of the audits and surveillance, qualifications of the auditors, and adequacy of corrective actions were reviewed.
QAA 20-86-47 audit conducted December 18, 1986, reviewed a shipment
of radioactive material to Byron Station which was not inspected by either the QA or Quality Control (QC) departments.
The shipment was i
of limited quar:tities of radioactive material.
The procedure for J
notification of QA and QC was misinterpreted and neither QA or QC
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departments were notified.
The procedure was changed to clarify the notification requirement.
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'I QAA 20-87-10 audit conducted during the week of March 23, 1987,
reviewed the procedures for shipment of radioactive radwaste to a burial site.
There was one open item concerning adequacy of the-information on shipping papers to be provided to the burial site.
Procedures were changed to include the additional information.
QAA 20-87-17 audit, conducted during the week of May 18, 1987,
reviewed the radiation protection program.
There were two findings and two observations concerning records.
Corrective actions were adequate and timely.
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I QAA 20-87-54-audit, conducted April 9, 1987, reviewed IRT portal i
monitor calibration.
There was one finding and two observations f'
concerning the records system and data on calibration stickers.
Corrective action is complete.
Approximately twenty-two QA surveillance performed of the radwaste and radiation protection programs since October 1986 were reviewed by the inspectors.
Most surveillance were conducted for radioactive material shipments, radiological area access controls and applicable procedural surveillance requirements.
The extent of the audits and surveillance and the qualifications of the auditors appear adequate.
In general, responses to audit and surveillance findings appear timely and technically sound.
No violations or deviations were identified.
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6.
Radiation Protection Procedures The inspector reviewed the following radiation protection procedures to determine if they are consistent with regulatory requirements and good health physics practices.
No problems were noted.
BWRP 1110-2, Revision 1, Administrative Control of Radiation Areas Greater Than 100 mR/hr BWRP 1120-2, Revision 1, Routine Plant Surveys BWRP 1150-1, Revision 1, Compilation of Radiation Reporting Requirements
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BWRP 1170-1, Revision 1, Administrative Controls for Health Physics Instrumentation BWRP 1210-5, Revision 3, Dose Equivalent Report upon Termination BWRP 1210-6, Revision 2, Personnel Neutron Monitoring BWRP 1210-9, Revision 2, Request for Radiation Dose History BWRP 1210-12, Revision 0, Radiation Protection Exposure Timecard
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l BWRP 1280-1, Revision 1, Response to Radiation Monitor Out of Service
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BWRP 1280-2, Revision 1, Response to High Radiation Monitor Alarms
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BWRP 1280-3, Revision 1, Process Radiation Monitor Gas Grab Sampling
I BWRP 1280-7, Revision 1, AR/PR Set Point and Background changes BWRP 1280-8, Revision 1, Process Radiation Monitor Liquid Grab Sampling a
BWRP 1280-11, Revision 1, Particulate and Iodine Sampling of Containment j
Airlock Monitors
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BWRP 1280-16, Revision 0, Post Accident Vent Stack Sampling of Wide-Range i
Gas Monitor BWRP 1310-2, Revision 1, Maintenance and care of Respiratory Protection Equipment j
l BWRP 1310-3, Revision 1, Operation and Use of Scott Self-Contained Breathing Apparatus j
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BWRP 1340-1, Revision 1, Personnel Monitoring for Internal Radiological Contamination BWRP 1360-1, Revision 2, Air Sampling of Suspected and Known Airborne Radiation Areas l
BWRP 1380-1, Revision 1, Assessment of Exposure to Radioactive Materials
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in Air l
BWRP 1380-4, Revision 1, Atmosphere Tritium Sampling BWRP 1410-1, Revision 1, Protective Clothing BWRP 1460-1, Revision 2, Use of G-M Instruments For Contamination Control BWRP 1460-2, Revision 2, Operation and Calibration of Eberline Model No. AC-3 Alpha Scintillation Probe BWRP 1460-3, Revision 1, Operations and Calibration of the IRT Portal Monitors BWRP 1460-4, Revision 1, Operation and Calibration of the IPM-7, Whole Body Frisking. Monitor 7.
Training and Qualifications l
The inspectors reviewed the training and qualification aspects of the licensee's radiation protection, radwaste, and transportation programs, including:
training responsibilities, policies, goals, programs and
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i methods; and the adequacy of the training for plant and contractor radiation protection personnel.
Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction or programmatic weaknesses.
The inspectors reviewed the education and experience qualifications of contractor radiation protection personnel and training provided to them.
The station plans to continue using contractor personnel to augment the
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radiation protection staff through Unit 2 startup.
Selection of l
contracted radiation protection technicians includes a review of the
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technicians' resumes to determine conformance to ANSI /ANS 3.1 criteria for responsible technicians and a telephone interview with the radiation
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protection organization of the plant where the individual previously worked.
Resumes of selected contractor Radiation Protection Technicians currently employed at the station were reviewed by the inspectors.
All senior technicians appear to meet or exceed the technician selection criteria in ANSI /ANS 3.1.
Junior technicians not meeting ANSI 3.1 appear to have training and experience commensurate with their assigned duties.
After selected technicians report onsite, they must pass (minimum
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score 80%) a radiation protection screening exam consisting of 25 multiple choice / calculational problems covering generic health physics topics.
The individuals then complete general employee and site specific training, respiratory protection training, and an overview of applicable j
station Administrative and Radiation Protection Procedures.
Procedure overview training lasts about one day and is presented by the station's
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training department.
Inspectors selectively reviewed training and exam records; no problems were noted.
J The inspectors reviewed the Rad / Chem (RCT) training, retraining and certification programs.
Initial RCT training consists of 18-weeks of classroom and on-the-job (0JT) training conducted at the licensee's Production Training Center and at the station.
The station training department tentatively plans on expanding the 0JT aspects of the training
a couple weeks.
During 1987, the station established and began l
implementation or a contjnuing training program for RCTs.
Each RCT is j
scheduled for 40 weeks t>f continuing training per year which consists of j
informal 1-3 hour duration sessions covering various radiation protection
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related topics.
The station is developing lesson plans and procedure based instruction guides to improve and efficiently track the program's implementation.
In addition, the station recently initiated a required j
reading program for all RCTs covering various subjects of interest including NRC Information Notices, INP0 good practices, and licensee procedures.
Required readings are usually recommended by the training j
department or RCTs and must be approved by the Rad / Chem Supervisor.
New topics on the reading list must normally be completed by all RCTs within 30 days.
Reading list completion is audited by the station's training department on a quarterly basis.
No problems were noted.
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The RCT certification program requires completion of specific practical
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factor task demonstrations and approval siga-offs by appropriate supervisory personnel.
In early 1986, the station waived or deleted several RCT certification tasks because of plant operational status, limited equipment availability or task redundancy, as appropriate.
Certain task certifications were temporarily waived with the intent they
would be subject to completion within three months after Unit 1 i
l commercial operation (i.e., late in 1987).
The station does not maintain a list of previously waived or deleted tasks; however, inspector review of chemistry and radiation protection RCT certification task-records determined that approximately 30% of all tasks were waived and a small i
percentage were deleted.
The station plans to increase emphasis in this
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area, especially with Unit 1 approaching commercial operation.
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status of the RCT certification program was discussed at the exit meeting and will be reviewed during future inspections (456/87020-01; 457/87018-01).
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8.
External Exposure Controls The inspectors 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 required records, reports, and notifications.
The licensee currently uses both vendor supplied film badges and an in-house TLD system for personal dosimetry.
The in-house TLD system was
made operational for CECO station personnel and selected contractors in November 1986.
Currently, about 1400 individuals are assigned TLDs.
The station plans to discontinue vendor dosimetry services when the plant staff stabilizes after commercial operation.
No exposure significantly above minimum detectable levels has been reported thus far.
j Engineering drawings for construction of an onsite TLD calibration facility are nearly complete.
Construction will commence after final drawings are approved.
The irradiator for the station's TLD facility is currently in storage at the Dresden station.
The inspectors reviewed the licensee's dosimetry program to verify.
compliance with NRC requirements (Form NRC-5) which specify that whole body doses be determined using a maximum absorber thickness of 1000 mg/cm2 when eye protection ( > 700 mg/cm2) is provided and a maximum of 300 mg/cm2 without eye protection.
The licensee's dosimetry program employs the use of a 4-element TLD system; one element with a tissue equivalent absorber thickness of seven mg/cm2 plus a seven mg/cm2 TLD holder thickness, two elements at 300 mg/cm2 including the holder, and one element at 1000 mg/cm2 including the holder.
The station's official record of whole body exposures is determined and reported through a tissue equivalent absorber of seven mg/cm2 Eye protection is not routinely required for access into radiologically controlled areas.
No violations or deviations were identified.
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Internal Exposure Control and Assessment The inspectors reviewed the licensee's internal exposure control and assessment programs, including:
changes in facilities', equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment;' determination whether engineering controls, respiratory equipment, and assessment of individuals intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications, and
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l effectiveness of management techniques used to implement these programs
and experience concerning self-identification and correction of program l
implementation weaknesses.
A respirator issue, cleaning, and storage, facility has been completed.on
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the 426' level of the Auxiliary Building near the entrance to the Fuel
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Handling Building.
The facility contains about 200 respirators of various sizes ready for issue.
Sinks, a dishwasher, and drying cabinets for cleaning and decontaminating respirators are installeC and
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operational.
A supply of hoses, regulators, filters and spare parts
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that appear adequate to run a respirator program are on hand.
No
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problems were noted.
Baseline Whole Body Counts (WBC) for CECO employees and contractors have been completed.
The WBC computer converts maximum permissible body burden (MPBB) to MPC-hours when the prescribed investigation level (3%
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MPBB for a single isotope; 5% MPBB total) is reached.
The conversion has l
been proceduralized and will be included in CEC 0's Standard Radiation i
Protection Procedures.
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No violations or deviations were identified.
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IE Information Notice No.86-107 l
IE Information Notices No. 86-44 and No.86-107 address potential radiological hazards associated with entry into TIP rooms and cavities beneath reactor vessels.
Braidwood Station has two areas for each unit similar to those described in the Information Notices, the seal table and incore reactor cavity areas.
Both areas are potential very high
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radiation areas ( > 1R/hr), depending on operational mode and location of incore detectors and thimbles.
Administrative Procedure No. BwAP 1440-1, " Access to Rx Cavity Incore Area" outlines, the access controls for entry into the reactor cavity area.
Access to the area requires unique dual key issuance by the Plant l
Manager and Rad / Chem Supervisor after several additional administrative controls have been implemented, including RWP controls and verification of incore detector and thimble locations and prohibitions (drive unit-l tag-outs) on their remote movement.
The procedure applies to all j
operational modes after initial criticality is achieved.
Access controls
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and restrictions on detector / thimble locations and movement appear j
adequate for the reactor cavity.
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Seal table area access is controlled via Administrative Procedure No. 1450-1, " Access to Containment." Once in containment, a high radiation area key is required for access into the seal. table area.
Procedure No. 1450-1, which applies to all operational modes other than shutdown and refueling, together with incore detector system operational procedures (Bw0Ps), appear to adequately control access to the seal table area including restrictions on remote incore detector movement.
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i The inspectors discussed IE Information Notice No.86-107 with an
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Operations Shif t Engineer and Shift Foreman.
The individuals are aware of the problems described in the notice including the potential radiological hazard, esociated with incore detectors and thimbles.
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notice has been reviewed by all licensed operaters and is maintained on
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the station's required reading list.
No problems were identified.
l No violations or deviations were identified 11.
Control of_ Radioactive Materials and Contamination The inspertars reviewed the licensee's program for control of
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radioactive materials and contamination, including:
changes in
instrumentation, equipment, and procedures; effectiveness of survey i
methods, practices, equipment and procedures; adequacy of review and i
dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesses.
l The licensee has an adequate number of whole body friskers (IPM-7)
located at the exits of the Auxiliary Building 401' and 426' levels, exit from Unit 1 Fuel Handling Building and at the exit from the Radwaste Building.
Locations for the contaminated tool storeroom, the contaminated tool and
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equipment decontamination room, and the personnel decontamination room have been designated.
I No violations or deviations were identified.
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Maintaining Occupational Exposures ALARA
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The inspectors reviewed the licensee's program for maintaining occupational exposures ALARA, including:
changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; and establishment of goals and objectives, and effectiveness in meeting
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them.
Also reviewed were management techniques used to implement the j
program and experience concerning self-identification and correction of I
program implementation weaknesses.
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ALARA awareness meetings have been he'd with.all station work groups and!
contractor supervisors.
The Station ALARA Review Committee has been d
meeting biweekly instead of monthly during startup of Unit 1; committee
minutes were reviewed from October 1986 to date; no problems were noted.
'l The photofile of plant systems and equipment is nearing completi.on.
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photofile is to be indexed and stored on a laser disc for use.in maintenance and repair activities.
Simulated radiological jobs have been conducted using step off~ pads, protective clothing and simulated external radiation and contamination.
Some minor problems were noted and corrected by the licensee.
Future radiological practice jobs will be video taped for use during subsequent training sessions.
l No violations or deviations were identified.
13.
NUREG 0737 Item II.F.1.2, Sampling and Analysis of Iodine and Particulate Effluents The inspectors reviewed the status of the modifications required to
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demonstrate compliance with FSAR commitments to NUREG 0737, Item II.F.1, j
Attachment 2.
Modification of the Wide Range Gas Monitor (WRGM) sample lines on
both Unit 1 and 2 Vent Stacks.
The previous WRGM design used a 3/4" heat-traced sample line for normal sampling by the.high-flow
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sample path at a flow rate of 1.67 SCFM and a 1/4" heat-traced sample line for accident sampling by the low-flow sample path at'a flow rate of 0.06 SCFM.
The new design and modification will allow
Auxiliary Building vent stack samples to be drawn through one set of
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isokinetic nozzles, one 3/4" heat-traced sample line and a flow splitter manifold for both low and med/high range operation.-
conditions at a constant flow rate of 1.67 SCFM.
The modification to the WRGM sample lines allows a single 3/4" I
sample line to be used under all conditions thereby eliminating the
1/4" sample line from the stack; leaving only a short section to the low flow sampler.
The inspectors verified that the modification has been completed for both Units 1 and 2 vent stack sampling systems.
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Inspection Report No. 50-456/86026; 50-457/86021 listed a
l modification which appeared to be necessary before the post-accident sampling system may be considered acceptable.
The licensee reviewed the referenced Callaway LER 86-011-00 and determined that the Braidwood system functions in a different manner than Callaway.
A modification similar to that performed at Callaway was determined not to be necessary at Braidwood.
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Inspection Report'No. 50-456/86002; 50-457/86002 listed an apparently
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LER 85-028-00.
The license reviewed the subject Callaway LER for
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impact at Braidwood and determined that some of the same conditions would exist at Braidwood.
Specifically, if the sample line is disconnected from the sample pump, the downstream flow meter will register an apparent sample flow.
The problem at Callaway.was determined to be.. caused by maintenance personnel's failure to reconnect the sample line to the sample pump after maintenance activities.
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At Braidwood Station the existing maintenance procedures would I
preclude.this situation from. occurring.
Procedure BWAP 400-9
" Maintenance Alterations" requires that an alteration log be completed whenever equipment is disassembled during the course of repair or replacement.
This log documents the equipment alteration
and restoration.
Also included is a second verification (witness)
that the restoration has been completed as required.
These controls should preclude an event similar to that described in LER 85-028-00.
In addition, Braidwood has redundant. systems that sample the Auxiliary Building vent stack the WRGMs and the vent stack monitors.
Therefore, j
if one sample line was inadvertently not reconnected, the other system would still' sample stack effluents.
The modification made at Callaway was determined not to be required at Braidwood.
This item is considered closed.
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14.
Solid Radioactive Waste The licensee's facilities for collection, concentration, solidification, packaging and shipment of solid radioactive waste are nearly complete and i
testing of these systems is in progress.
Due to operational and I
maintenance problems, the Stock solidification and volume reduction system will be abandoned in place until proven to be reliable.
The station plans on utilizing contractor services to process (dewater) spent resins and forego solidification.
The licensee ~ anticipates revising their Process Control Program to incorporate the planned program modifications.
The station is establishing a DAW sorter program to segregate " clean" DAW.
A sorting table monitor will be located at the 383-foot elevation of the Auxiliary Building in the drumming area.
Solid radwaste generated
in the plant will be transported to the radwaste building through the
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tunnel trackway using modified rail carts.
No violations or deviations were identified, 15.
Liquid Waste System i
Licensee facilities for the collection and storage of liquid radioactive waste is essentially. complete and testing of these systems is in progress.
The boric acid evaporators were recently tested satisfactorily.
and should be operational in a few weeks.
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The' licensee has cleaned and hydrolyzed all Unit 2 floor drains to reduce the spread of contamination when..the unit is.; operational.
Floor drain screens were added to limit introduction of solid material into the drain system and thereby minimize the potential for plugging.
The licensee plans.to replace.their four spent resin storage tank. pumps with two screw-feeder type pumps to facilitate maintenance activities in the pump room and improve sampling ability.
Also, an additional spent resin storage tank will be added to the system to allow steam generator
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and chemical and volume control system blowdown demineralized beds to be
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segregated.
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'l No violations or deviations were identified.
l 16. Gaseous Waste System l
Construction of licensee facilities for the collection and storage of
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gaseous. radioactive waste'have been completed and testing of these systems is in progress.
Procedures for processing gaseous radwaste are essentially complete.
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The licensee is experiencing operational problems with their waste gas air compressor oxygen analyzer; actions to. improve the system are in progress.
No gaseous radwaste releases have been made to date.
No violations or deviations were identified.
17.
Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)'at l
the conclusion of the inspection on June 12, 1987.
The scope and the
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findings of the inspection were summarized.
The inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors'during the
inspection.
The licensee identified no such documents / processes as proprietary, l
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