IR 05000456/1988004

Insp Repts 50-456/88-04 & 50-457/88-05 on 880113-0216.No Violations or Deviations Noted.Major Areas Inspected: Operational Radiation Protection Program,Including Licensee Action on Previous Insp Findings & Organization

ML20150B959
Person / Time
Site:	Braidwood
Issue date:	03/09/1988
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20150B952	List: IR 05000456/1988004 ML20150B949
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM 50-456-88-04, 50-456-88-4, 50-457-88-05, 50-457-88-5, NUDOCS 8803170205
Download: ML20150B959 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/88004(DRSS); 50-457/88005(DRSS)

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Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-75 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: January 13 through February 16, 1988 Inspector: W. B. Grant d J- 9-#AP Date Accompanying Inspector: W. W. Ogg Approved By: L. R e d -9-#8 Facilities Radiation Protection Date Section Inspection Summary Inspection during the period January 13 through February 16, 1988 (Reports No. 50-456/88004(ORSS); No. 50-457/88005(DRSS))

Area Inspected: Routine, unannounced inspection of the operational radiation protection program including: licensee actions on previous inspection findings (IP 92701); organization and management controls (IP 83722), audits and appraisals (IP 83722) training and qualifications (IP 83723); external exposure control and personal dosimetry (IP 83724); internal exposure control and assessment (IP 83725); control of radioactive materials and contamination (IP 83726); ALARA activities (IP 83728); facilities and equipment (IP 83727);

Unit 1 startup survey data (IP 83521) and status of certain THI action plan items (IP 25401).

Results: The licensee's radiation protection program continues to be effective in protecting the health and safety of occupational workers. No violations or deviations were identifie PDR ADOCK 05000456 o nrn

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DETAILS 1. Persons Contactea

• R. Aker, Radiation / Chemistry Supervisor ~

J. Anspaugh, Health Physicist

• P. Barnes, Supervisor, Regulatory Assurance B. Benson, Engineering Assistant, Exposure Records

• F. Bevington, Quality Assurance

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• J. Burkhead, Training Department

• E. Carroll, Regulatory Assurance

• L. Davis, Assistant Superintendent, Technical Services S. DeGarmo, Health Physicist J. Jasnosz, AR/PR Coordinator J. Kielbasa, Radiological Engineer /ALARA T. O'Bert, Instrument Maintenance, Unit 2 Scheduler

• D. O'Brien, Services Superintendent E. Roche, ALARA Coordinator

• Sayers, Radiation / Chemistry Training Group Leader D. Shamlin, Lead Foreman S. Stapp, Q.A. Inspector

• Takaki, Regulatory Assurance

• Vonk, Lead Health Physicist

• K. Weaver, Startup Health Physicist

• T. Taylor, NRC, Resident Inspector The inspectors also contacted several other licensee personnel, including technicians, engineering assistants, foremen, and members of the technical staf * Denotes those present at the exit meeting on January 28, 1988.

2. General This inspection was conducted to examine the operational radiation protection program during a short maintenance / surveillance outage, Unit 1 startup survey data, licensee actions on previous inspection findings, and status of certain TMI action plan item . Licensee Action on Previous Inspection Findings (Closed) Open Item (456/86002-01; 457/86002-01): TLD irradiation facility needs to be constructe Construction of the TLD irradiation facility is under way on the 433' level of the Service Buildin Completion of the facility is scheduled for March 198 _ -

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(Closed) Open Item (457/86002-04): Complete installation, testing and calibration of Unit 2 Area Radiation Monitors (ARMS) and Process Radiation Monitors (PRM). Preoperational testing and calibrations have been completed. The item is considered closed. See Section 1 (Closed) Open Item (457/86002-10): Complete installation, procedures and training on use of post-accident containment high-range radiation monitors per NUREG-0737, Item II.F.1., Attachment 3. Preoperational testing and calibrations have been completed; procedures and training have been completed. This item is considered closed. See Section 1 (Closed) Open Item (456/87020-01; 457/87018-01): The RCT certification program requires completion of specific practical factors task demonstrations and approval sign-offs by appropriate supervisory personne During an inspection in July, 1987, the inspector noted that a large percentage of these tests were being temporarily waivered with inadequate record of same. Durir.g this inspection the inspectors found that the backlog of tests have b9en completed and that essentially all practical factors task demonstratiens are now being performed as required. See Section (Closed) Open Item (456/87034-01; 457/87032-01): Resolution of neutron streaming problem. A corporate engineering study for both Byron and Braidwood (AIR 6-85-20) was previously conducted to review reactor neutron shielding and propose design changes, if any, to reduce the neutron dose at the containment air lock and near the reactor head. The study determined that the person-rem saving of 1.5 to 6 person-rem per year did not justify the cost of reactor shielding changes; no shielding or design changes are currently planned. This item is considered close . Organization and Management Controls (IP 83722)

The inspectors reviewed the licensee's organization and management controit 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 Since the last radiation protection inspection on September 1987, several organizational changes have been made, including:

• An ALARA Maintenance Planner has been added to the ALARA staff.

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• An Engineering Assistant with approximately six years U. S. Navy ELT l

experience was hire * Six additional contract radiation protection technicians were hired for the current mini-outag L

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The inspectors reviewed Radiation Occurrence Reports (R0Rs) which were written in 1988. There have been 10 RORs written to date in 1988. RORs were reviewed for significance, corrective actions and timeliness of corrective actions; no problems were noted. The licensee appears to provide sufficient management attention to followup and investigation of ROR No violations or deviations were identifie . AuditsandAppraisals(IP83722}

The inspectors reviewed station Quality Assurance (QA) audits and surveillances of the radiation protection arid radwaste programs conducted since the last radiation protection inspectio Extent of the audits and surveillances, qualifications of the auditors, and adequacy of corrective actions were reviewe Quality Assurance Department surveillances of radiation protection activities during the previous quarter found few deficiencies. The following is a_ partial listing of surveillances where no deficiencies were foun * Radioactive Material Shipment

• Routine Area Survey

• Source Check of the IRT Monitor, Main Access

• Unit Two Nuclear Fuel Transfer and Core Alteration

• Corrective Action Commitments The following two listings comprise one audit and one surveillance made by QA where deficiencies were foun * On October 7,1987, QA inspected NUCON (Nuclear Consulting Services) who supply impregnated charcoal. A deficiency was found in that persons performing activities affecting quality were not being trained in the revisions to the QA Manual and o'.her procedures. The vendor conducted a training course for workers, revised the training p ogram and sent QA a copy of the revised training program. QA closed the matte * In late December, 1987, QA reviewed respirator issuance / control and whole body count practices. Respiratory equipment was verified to have been properly issued to qualified individuals and recorded on the log sheet. The full face respirator cleaning /re qualifying facility was a'.so field inspected and found properly controlle However, it was noted that the second semi-annual inspection of rubber on stored respirator equipment (BwRP 1310-8, Step 3) had not been timely performed. When informed Rad / Chem completed the second inspection within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Also, the whole body counter facility was inspected; QA observed that calibration had been timely performed, and current revisions of procedures and log forms were being use No violations or deviations were identified by the inspector _ _ _ _ - - _ - _ - - -

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6. Training and Qualifications (IP 83723)

The inspectors reviewed the training and qualifications aspect of the licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, programs, and methods; qualifications of newly hired or promoted' radiation protection personnel; and provision'of appropriate radiation protection, radwaste and transportation training for station personne Also reviewed were management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The Radiation / Chemistry Training Group Leader informed the inspector that in October 1987, three radiation protection instructors were added to the staff and two specialists were recently contracted to assist in evaluating and revising twelve chemistry and fourteen radiation protection lesson plans. One of these specialists is a licensed senior reactor operator with a B.S. in chemistr She is assisting with plant chemistry training evaluations toward INP0 accreditatio The other specialist has six years of commercial power plant health physics experience. The licensee will submit a Training Self-Evaluation Report to INP0 in March 1988, and expects accreditation during this yea The resumes of the three new instructors indicate that they have qualifications which exceed the referenced ANSI requirements of Regulatory Guide 1.8. Revision 2, for "technicians in responsible positions," and in addition these individuals have had formal training and experience in teaching radiation protection. The licensee appears to have recruited well qualified additional training staf The licensee representative also described a recent advanced radiation protection refresher course conducted for all three maintenance groups (mechanical, electrical and instrument). The training was a consolidated effort with Byron Nucleaa Plant and used the assistance of a nationally known training vendor witu whom the licensee collaborated to produce the desired curriculum. Both maintenance managers and union members were traine For this surveillance outage the licensee contracted for six additional junior radiation protection technicians who are performing servica under supervision and at control points. The inspectors reviewed the qualifications and experience of these technicians and noted that they appear to meet the referenced ANSI requirements of Regulatory Guide The licensee RCT field qualification / certification program is based on INP0 guidelines and site specific radiation work. The NRC inspection in June 1987 identified a weakness in the program due to the licensee's apparent use of waivers for approximately 30% of all tests. During this inspection the inspectors found that essentially all qualification tests are completed; the few not completed are for new equipment not yet in servic No violations or deviations were identifie I

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i 7. External Exposure Control and Personal Dosimetry (IP 83724)

The inspectors reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; required records,_ reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesses, The licensee curre,itly uses both vendor-supplied film badges and an in-house TLD system for personal dosimetry. Whole-body TLD badges are assigned to. station personnel and selected contractors. Vendor-supplied film badges are assigned to non-CECO personnel for whole-body monitoring, and to CECO and non-CECO personnel, as needed, for extremity monitoring and for whole-body neutron monitoring. In addition, for each two-week badge period, the licensee exposes 17 TLD badges and 17 whole-body film badges to specified doses of gamma and beta radiation. The 34 badges are then processed with the badges assigned to persons onsite during the badge period. After the badges are processed, the reported doses for the spiked badges are statistically compared to the administered doses. The inspectors reviewed selected records of the comparisons; no significant problems were note Self-reading pencil dosimeters are used for secondary whole-body dosimetr The range of most of the dosimeters is 0-200 mR, but dosimeters with wider ranges are available. After receipt of dosimeters from the vendor or before use of dosimeters that have been in storage for more than six months, the licensee subjects them to six acceptance tests designed to identify !

defective dosimeters. Every six months thereafter, the performance of !

the dosimeters is verified with a check of drif t and a check of accuracy .

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usicg a sealed source of cesium-137. The inspectors reviewed selected records of acceptance tests and performance verifications; no problems were note An electronic, alarming dosimetry system is currently in place at the

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station for use during entry into high radiation areas. The inspectors reviewed selected records of calibrations of these dosimeters; no problems were note Approximately 1350 TLDs were issued for the first badge period in 198 !

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Exposure records of plant, contractor, CECO and non-CECO personnel were reviewed for CYs 1987 and 1988 to date. No exposures greater than 10 CFR 20.101 or licensee administrative limits were note Licensee administrative limits are 50 mrem / day for type-one RWPs and 100 mrem / day for type-two RWPs. Approval for doses in excess of 100 mrem per day or 300 mrem per week require the signature of the Rad / Chem Superviso ,

No violations or deviations were note ,

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8. Internal Exposure Control and Assessment (IP 83725)

The inspectors reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures af fecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for surveillance outage tasks including ALARA considerations; required records, reports, and notifications, and effectiveness of managen.ent techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse Several of the licensee's internal exposure control and assessment procedures have been revised since the last inspection. These revisions, including several practical forms attached as appendices to the procedures, appear good. The licensee's use of computerization for whole body count data will apparently further facilitate implementation of those procedure The licensee's administrative program to control internal exposure during EMERGENCY OPERATIONS was described in inspection reports No. 50-456/87034(DRSS); No. 50-457/87032(DRSS). While there has been no significant change to that basic program, the license significantly increased the number of SCBA units and GSEP kits available for this surveillance outage. Also the licensee stated that state-of-the-art apparatus for making tent or glove-box type enclosures, both large and small, for better containment of hazardous contamination repair work had been purchased recently. This appears to be good practic The inspectors inspected the quality of supplied breathing air relative to proper filters and monitors in the system and determined that the licensee's breathing air has a C0 monitor, Cuno and oil filters, and organic plus HEPA filter in the distribution box. The system qualifies ,

to grade "E". Appendix 6A3 was added to procedure BwRP No. 1310 which mandates regulator setting based on breathing air hose lengths. This is a good practice. The inspectors examined the licensee's newly implemented full facepiece respirator program which includes a large and orderly respirator clean-up and requalification room. No problems were foun The inspectors reviewed thc annual calibration of the whole body counter and confirmed the traceability of the calibration sources to the National Bureau of Standards. No problems were identified. An ROR documenting the inadvertent spraying of four workers with reactor coolant water was reviewed. The procedurally required followup whole body counts were made; only external contamination exicted. No problems were identified with the licensee's handling of the inciden l

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i The licensee's procedure BwRP 1340-2A1 schedules most radiation workers to be whole body counted three times per year. The inspectors reviewed the whole body count records of stationmen who have been routinely assigned to laundry sortin The records indicated no detectable activity. Since the last inspection, there has been no whole body count equal to or greater than 1% MP88 or equal to or greater than 2 MPC-hour exposure. To date, bonafide trace-levels of internal radioactivity have been seen only in a few visiting radiation workers from other nuclear power plants, and in a few Braidwood plant workers who regularly eat venison, which frequently contains higher levels of fallout radioactive material than domestic animal The inspectors reviewed the records of both routine and special (e.g. RWP) air sampling. It was apparent that the licensee's measurement !

and evaluation of concentrations of airborne radioactivity and the use of respiratory protective equipment meet the requirements of 10 CFR 20.10 The inspectors also reviewed the daily continuous CONTAINMENT air sampling

progra During the three-month period, October through December 1987, l

iodine and noble gas activity was observed when operating at power. The

, licensee apparently allowed some system leaks to continue unrepaired. In a tour of Unit-1 containment the inspectors observed several cases of i buildup of borate crystals at leak sites. One such site was the outlet from the regenerative letdown heat exchanger 414-foot elevation, where perhaps 100 pounds of crystals were seen. Based on several inquires, it appears that no policy has been established as to how long and to what extent such leakage will be tolerated. At this stage, reactor streams are

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relatively low in radioactivity conten However the licensee will have '

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to deal with this matter in the near future in order to minimizo contamination sprea This matter was discussed with an RP staff member during the inspection and will be reviewed further during a future .

j inspectio (0 pen Item 456/88004-01; 457/08005-01)

There were no violations or deficiencies noted during this inspection of internal exposure control and assessment. One Open Item was identified for further review.

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9. Control of Radioactive Materials and Contamination (IP 83726)  !

i The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effectiveness of survey methods, practices, equipment and procedures; l

adequacy of review and dissemination of survey data; and effectiveness of

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methods of control of radioactive and contaminated materials.

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Personnel contamination reports (PCRs) were reviewed for 1988 to date.

j Due to the outage, there has been an increase in personnel contaminations, 32 have been recorded in 1988 through January 26; however, a significant number (about 24) were from radon / noble gas daughter contamination of security personnel. No problems were noted,

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l The inspectors conducted numerous and frequent plant tours in the ,

auxiliary, fuel handling, radwaste buildings and in containment for the purpose of examining the licensee's performance of radiation protection and contamination control practices, observing work activities performed under the requirements of ten RWPs, and interviewing workers who performed tasks authorized by other RWPs. The inspectors conducted radiation and contamination surveys of selected plant areas using NRC and licensee ,

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survey instruments; readings were in general agreement with posted licensee data. Housekeeping generally appeared adequate; however, during the-tours the inspectors noted isolated incidents of poor housekeepin Relevant observations are discussed belo * The inspectors found no nonconformance with RWP protective .

clothing / equipment requirement * The inspectors noted that the posting of areas in the Auxiliary '

Building appeared prope * Inside containment on January 21 at the IB residual heat removal heat exchanger (HX) the inspector observed an area loosely roped off and posted with a sign which stated "Potentially Airborne

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Radioactivity Area;" the area was roped off to prevent inadvertent contact with leakage evidenced by a large amount of borate crystal

, buildup (see also Section 8). A smear of the white powder counted 1

! 140K dpm per 100cm2 . The licensee representative accompanying the  !

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inspector stated that the reason there was no "Contamination Area"

] insert included in the posting was in conformance with a corporate

! directive not to establish a contamination area within another  ;

contamination area (the entire containment is posted as a

contaminated area). Before the end of the inspection the licensee I representative stated that the corporate directive may havc been

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misleading. On January 27 the inspector again inspected the 18 residual heat removal HX area and noted that borate crystals had been removed by decontamination efforts and the roped off area was enlarged and appeared adequate. This matter was discussed during

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the axit interview, and the licensee stated that future posting of areas within containment will contain all posting inserts >

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necessary. The matter is considered closed.

• The inspectors determined that the licensee has an apparently adequate program to survey for, identify, evaluate dose from and ,

! remove hot particles. The licensee stated that the corporate j directive on contamination control has been submitted to the RP supervisor and an active program is underway to respond in all

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facets require ,

There were no violations or deviations found in the licensee program j for control of radioactive materials and contaminatio i P

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10. Maintaining Occupational Exposures ALARA (IP 83728)

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 pregram; establishment of goals and objectives, and effectiveness in meeting the Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse One contractor ALARA maintenance planner has been added to the ALARA staf The maintenance planner is experienced in nuclear plant system maintenance and therefore should provide valuable and needed expertise to the ALARA grou The collective dose for CY 1987 was 3 person-rem. The ALARA goal for CY 1988 is 200 person-rem including a goal of 65 person-rem for the current mini-mairtenance/ surveillance outage. The dose for CY 1988 through January 21, 1988, was approximately 31 person-re No violations on deviations were identifie . Facilities and Equipment (IP 83727)

The inspectors reviewed the facilities and equipment used by the license for radiation protection activities to determine whether they are adequate to support the radiation protection progra The licensee has completed calibration and testing of ARM /PRMs for Unit 2 required by fuel load. Records of calibration were reviewed; no problems were note No violations or deviations were identifie . Unit 1 Area Radiation / Process Radiation Monitors (IP 83726)

Recently, the licensee has experienced spurious spikes on control room ventilation monitors and containment fuel handling area radiation monitors (LER. Nos 87-031-00, 87-051-00, 87-053-00, 87-055-00, 87-056-00 and 88-03-00). The monitors are intended to respond to high radioactivit In the case of the control room (CR) ventilation monitor, a high radiation signal switches the CR ventilation to the emergency mode. A high radiation signal on the containment fuel handling monitor results in containment isolation. A license investigation determined the spurious spikes are not caused by the use of radios or from arc welding in the area. The

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investigation did identify arcing of the Barksdale pressure switches as one apparent caus Some of these switches have been replaced but as the switch ages the breaker points become pitted and arcing occurs again. The licensee has installed a capacitor circuit "electro cube" designed to l

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suppress the electronic spiking on selected monitors. No further spiking has occurred on the monitors with the electro cube. The licensee's investigation into the cause of the spikes is continuin This matter will be reviewed during a future inspectio (0 pen Item 456/88004-02; 457/88005-02)

No violations or deviations were identifie . Unit 1 Startups Tests (IP 83521)

The inspectors reviewed the result of a startup survey for Unit 1 which was conducted September 28-29, 198 BWSU-PS-33 Radiation Surveys during Power Ascension conducted at 49% powe Test results were reviewed. Two radiation base point (RBP) levels exceeaed test acceptance criteria: RBP 1C6-7, @ the spent fuel pool in containment, measurement was 46 mR/hr; acceptance criteria was 20 mR/h RBP 1A2-2A, RHR pump room cubicle entrance, measurement was 3.2 mR/hr; acceptance criteria was 2 mR/h Both areas are radiologically controlle The Project Engineering Department (PED) will evaluate and resolve this matte This was discussed at the exit meeting and will be reviewed

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One open item was identified for further revie . NUREG 0737 Item II.F.1, Attachment 3, Containment High-Range Radiation Monitor (IP 25401)

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

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RM-23 remote display units. Detectors 2RE-AR020 and 2RE-AR021 are located in Unit 2 containment at elevation 514' 8" at azimuths 90 and

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263 , respectively. Appropriate procedures have been revised to ensure

that the polar crane will not be inadvertently parked such that the i monitors would be significantly shielded.

~I The inspector reviewed the status of the Unit 2 containment high-range radiation monitors and the licensee's commitment compliance documentation. All of the 14 compliance action plan items have been j completed; thus, the applicant appears able to adequately demonstrate i compliance with FSAR commitments to NUREG-0737, Item II.F.1, Attachment 3. The inspector selectively reviewed records of calibration and testin Calibrations and testing were conducted in accordance with Procedure BWIS 3.3.6-210, Revision 1, Surveillance Calibration of l Accident Area Radiation Monitors. No problems were noted. Records of

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RCT training in response to alarms of these monitors were also reviewed;

) no problems were noted. This item is considered closed.

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15. Conformance to Regulatory Guide (RG) 1.97, Revision 3 (IP 92705)

A Technical Evaluation Report EGG-NTA-7643 published in August 1987 by the Idkio National Engineering Laboratory (EG & G Idaho, Inc.) reviewed Commonwealth Edison's (CECO) response to Revision 3 of Regulatory Guide 1.97 (RG) for Unit Nos. 1 and 2 for Byron and Braidwood Station The report identified one area of possible nonconformance concerning the radiation protection progra RG 1.97 recommends radiation exposure rate instruments in areas where access is required to service equipment important to safet CECO's preliminary evaluation of conformance with RG 1.97, submitted in February 1987, stated that current locations of radiation exposure instruments might not be adequate for conformance with the recommendations of RG 1.97. CECO committed to identify the areas which might require access to service equipment important to safety and to evaluate those areas for conformance. CECO's final report dated September 1, 1987, included an evaluation of all areas requiring access to service and equipment important to safety concluded that all were in compliance with the intent of Regulatory Guide 1.97, Revision No problems were note Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

on January 28, 1988. The scope and 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 proprietar