IR 05000456/1989006

Insp Repts 50-456/89-06 & 50-457/89-06 on 890214-17. Violations Noted.Major Areas Inspected:Changes in Personnel, Audits & Appraisals,Planning & Preparation,External & Internal Exposure Controls & Control of Radioactive Matls

ML20246L922
Person / Time
Site:	Braidwood
Issue date:	03/14/1989
From:	Caniano R, Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246L913	List: IR 05000456/1989006 ML20246L908 ML20246L916
References
50-456-89-06, 50-456-89-6, 50-457-89-06, 50-457-89-6, NUDOCS 8903240315
Download: ML20246L922 (8)

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U'. S. NUCLEAR' REGULATOR COMMISSION p REGION III

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Reports No. 50-456/89006(DRSS); 50-457/89006(DRSS)-

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Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77-

-Licensee: Commonwealth Edison Company Post Office Sox 767 Chicago, IL 60690 Facility Name: Braidwood Station. Units 1 and 2 Inspection At: Braidwood Site, Braidwood, Illinois Inspection Conducted: February 14-17, 1989

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Inspector: M. A. Kunowsk1 , 3-[V M Date Accompanying Inspector: ' Caniano 3 -/r-/f Date-Approved By: M 'c ief MN Radiological Controls and Date Chemistry Section Inspection Summary Inspection from February 14-17, 1989 (Reports No. 50-456/89006(DRSS);

50-457/89006(DRSS))

Areas Inspected: Routine, unannounced inspection of the operational radiation protection program, including: changes in personnel, audits and'

appraisals, planning and preparation, external and internal exposure control, control of radioactive materials and contamination, surveys and monitoring, and ALARA (Inspection Procedure (IP) 83750). The inspectors also reviewed radiation protection concerns contained in an allegatio Results: Tne allegation was substantiated and one procedural violation associated with it was identified (Section 6). The violation does not appear to be indi::.i.ive of a significant programmatic weakness and the licensee's radiation protection program continues to be effective in protecting the health and safety of occupational workers and the publi PDR ADOCK 05000456 Q PDC-1

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l DETAILS 3 l Persons Contacted

• E. Aker, Radiation / Chemistry Supervisor l K. Aleshire, Health Physicist {

D. Ambler, Health Physicist Group Leader, Technical K. Appel, Engineering Assistant, ALARA

• T. M. Bandura, Quality Assurance i

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• P. L. Barnes, Regulatory Assurance Supervisor B. Benson, Engineering Assistant J. Burkett, Engineering Assistant i D. Gron, Engineering Assistant

• M. J. Harper, Quality Assurance C. Ingold, Assistant ALARA Coordinator

• E. W. Carroll, Reguletory Assurance R. Legner, Assistant Superintendent, Technical Services S. Morse, Health Physicist

• D. E. O'Brien, Services Superintendent D. Poi, Health Physicist

• R. E. Querio, Station Manager

• L. W. Raney, Nuclear Safety E. Roche, Health Physicist Group Leader, Operations J. M. Watson, Quality Assurance F. Willaford, Security Administrator

• T. M. Tongue, NRC Senior Resident Inspector

• T. E. Taylor, NRC Resident Inspector The inspector also interviewed other plant personnel during the course of the inspectio * Denotes those present at the exit meeting on February 17, 1989.

2. General This inspection was conducted to review the operational radiation protection program. In addition, radiation protection aspects of an allegation were reviewe . Changes in Personnel (IP 83750)

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The inspector reviewed major changes in the radiation protection (RP)

program organization that have occurred since the previous RP inspection in August-September 1988 (Inspection Reports No. 50-456/88025(DRSS);

No. 50-457/88025(DRSS)). These changes, summarized below, apparently have not reduced the effectiveness of the RP progra _ _ - _ -

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• The radiation protection / chemistry technician (RCT) group has been eliminated with~the radiation protection and the chemistry duties now assigned to two separate. groups (Inspection Reports No. 50-456/

89002(DRP); No. 50-457/89002(DRP)). Former RCTs were assigned to one of the two groups according to personal preference and bargaining agreement seniority constraints. There are currently 25 RP technicians and 21 chemistry technicians, with an additional 15 contract RP technicians assistin * The radiation protection / chemistry. department supervisor,- who also functions as the technical specification-required radiation vrotection manager, currently supervises both RP and chemistr Tenative' plans'are to have separate supervisors for the two group * The radwaste shipping planner has been transferred to the chemistry department and will be appointed to the chemistry supervisor positio A contractor responsible for'onsite dewatering operations has been appointed the radwaste shipping planne * The RCT lead. foreman has transferred to the Training Department and a Training Department instructor has transferred to the RP group as an engineering assistant. The RCT lead foreman position (now the RP lead foreman position) was filled by promotion of a forema * An individual with a Masters of Science degree in Health Physics and experience at Clinton Power Station and the Illinois Department of Nuclear Safety has joined the RP group as a health physicis No deviations or violations were identifie . Audits and Appraisals (IP 83750)

The inspector reviewed Quality Assurance audits and surveillance, and .i a corporate RP audit of the station RP program conducted since the .

previous NRC RP inspection. The extent of the audits and surveillance, .

the qualifications of auditors, and the adequacy of corrective actions -

were acceptabl i l

The inspector also reviewed Radiation Occurrence Reports (RORs) written *

in 1988 and 1989. The RORs were reviewed for significance, corrective actions, and trends. Several instances of individuals entering the main i radiologically controlled area of the auxiliary building without proper

' dosimetry were noted, as were an ROR written for a lost key to a high 'j l radiation area and an ROR written for several individuals not following all of the administrative requirements for access to a high radiation area. The inspector briefly discussed these items and the corrective actions taken with RP management and at the exit interview, emphasizing the importance of preventing recurrence. Another R0R, involving the contamination of several workers by a leak in the Unit 1 pressurizer

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manway cover, .is still being investigated by the: licensee. Initial information indicated that seven individuals were externally contaminated with several nanocuries of Co-58 and/or Mn-54. The licensee's final actions on this ROR will reviewed during a future, routine RP inspection (0 pen Item'456/89006-01(DRSS); 457/89006-01(DRSS)). Overall, the licensee's R0R' program. appears'to be functioning effectively as a means of oversight of radiation protection activitie No deviations or violations were identified by the inspecto . External Exposure Control and Personal Dosimetry (IP 83750)

The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: . changes in facilities, equipment and procedures; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesse No problems were identifie Licensee representatives stated that in 1988 and in 1989, to date, no administrative or regulatory exposure limits were exceeded. The highest annual dose total for any worker for 1988 was 909 mrem. The station's dose total for 1988 was 75 person-rem (the goal was 200), with the typical number of badged individuals being approximately 1500. These low dose totals reflect the station's brief operating history. Unit 1 began commercial operation on July 29, 1988, and Unit 2 began commercial-operation'on October 17, 1988. For 1989, with a 41-day surveillance outage scheduled for Unit 2 and a 70-day refuel outage scheduled for Unit 1, the licensee has established a goal for the station of 500 person-re The station has recently upgraded and expanded its electronic dosimetry program. All workers entering containment and high radiation areas are required to wear the new computer-based dos; meters. Additional dosimeters reportedly will be available for the upcoming refuel outag This program enhancement should improve the licensee's dose monitoring and tracking capabilitie Another station RP enhancement noted by the inspector was a hot spot tracking program. The program calls for identification, posting, photographing, and weekly surveying of hot spot Periodically, RP reviews hot spot status with the system engineer )

responsible for the system in which the hot spot is located in an effort to develop a system mechanical or operational modification to reduce or eliminate the hot spot. This program has the potential for significant dose savings, and its implementation, so early in the life of the plant .

shows an aggressive attitude toward dose contro !

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Discussions with the ALARA staff confirmed their involvement in job l planning,. including outage job plannin ALARA qroup representatives I

attend the plan-of-the-day meeting and the daily ::ork planning meeting (which reviews the status of work scheduled for a, rolling 3-day period).

In addition, the ALARA staff has frequent, informal contact with work planner No deviations or.viclations were identifie . Internal Exposure Control and Assessment (IP 83750)

l L The inspector. reviewed the licensee's internal exposure control and assessment programs, including: changes in facilities and equipment; determination whether engineering controls and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications, effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesse The inspector reviewed activities at the licensee's respirator cleaning, repair, and distribution facility on the 426' level of the Auxiliary Building and at the mask fit booth in the Service Building. These activities included respirator repair, distribution, storage, and fit testing. In addition, records of respirator distribution, air samples, fit testing, breathing air compressor checks, and medical certification were reviewe No problems were identifie Aspects of the licensee's whole body counting program were also reviewed. Thegrogramusesastand-up, shadow-shieldcounterequipped with two 4" x 4 NaI detectors and vendor software. The software allows for dose and MPC-hour determination based on whole-body count (WBC)

data.; however, the licensee uses corporate procedures for these determinations. Periodically, results of quality control (QC) checks and personnel WBC data are sent to the vendor for evaluation. The vendor reviews the information and makes a final determinatich on body burde Full calibration of the counter is also performed by the vendor, annually, using NBS-traceable sources in an acrylic phanto The system is calibrated relating photon energy of the sources to full-width half-maximum values, multi-channel analyzer channels, and geometry counting efficiency. Daily and weekly QC checks are performed by the licensee. A review of calibration data indicated no problems. A review of records and a discussion with licensee representatives indicated that in 1988 and in 1989, to date, WBC records and air sample records indicated that no individual had been exposed to airborne radioactivity greater than the 40 MPC-hour regulatory investigation leve _ - _ _ _ - - _ _ _ _ _ _ _ - _ _ - .

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Technical Specification 6.11 requires the licensee to prepare procedures for personnel radiation protection consistent with the requirements of 10 CFR 20, and to approve, maintain, and adhere to these procedures for all operations involving personnel radiation exposure. Licensee procedure, " Radiation Chemistry Exit Interiew," BwRP 1210-4, Revision 3, requires that any employee who works in a radioactive materials area or an airborne radioactivity area will receive a bioassay upon terminatio In response to an allegation (discussed in Section 7), the inspector reviewed records of WBCs given to selected personnel upon termination of employment at the station. This review indicated that contrary to procedure BwRP 1210-4 an individual who had worked in a radioactive materials area did not receive a WBC upon termination of employment on July 20, 1988, and no exception hd been granted by RP supervision. The failure.to adhere to the requirements of the procedure is a violation of Technical Specification 6.11. (Violation 456/89006-02(DRSS);

457/89006-02(DRSS)).  ;

An evaluation by the licensee was performed during the inspection after the problem was identified by the inspector. This evaluatior,which included a review of personnel contamination reports, RWPs, dosimetry records, and air samples pertinent to the individual's work indicated that the individual was not exposed beyond regulatory limits while at the station .

One violation was identifie . Allegation Followup (AMS No. RIII-88-A-0147)

Discussed below is a concern contained in an allegation received by the NRC Resident Inspector's Office, relating to the radiation protection program at Braidwood, which was evaluated during this inspection. The evaluation consisted of record and procedure review and discussions with licensee technical and management personne Concern: In July 1988, a named worker did not receive a whole-body count (WBC) upon termination of employmen Discussion: The review of records and discussions with licensee representatives established that the individual's employment at Braidwood was abruptly terminated by the licensee in July 198 No WBC was performed on the individual prior to his leaving the sit By procedure, the station does not have to perform a WBC if a waiver. is granted by a member of health physics wervisio However, a waiver was not granted in this cas Findings: The allegation is substantiated. One violation was identified (see Section 6). The allegation is considered open, pending resolution of additional concerns related to securit _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ - _ _ _ -

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. Controls of Radioactive Materials and Contamination, Surveys, and Monitoring (IP 83750)

The inspector reviewed aspects of the licensee's program for control of radioactive materials and contamination, surveys, and monitorin The inspector reviewed the circumstances surrounding the apparently unauthorized removal from the site of a large number of hand-tools by a contract employee. Some of these tools had been taken from the auxiliary building, and, as such, were potentially contaminated. The tools were recovered and returned to the station during the inspection. The licensee performed several surveys of the recovered tools and determined that except for 2000 dpm of fixed contamination (mainly C0-58) localized on the handie of a crescent wrench and 3000 dpm of fixed contamination localized in a small area on an electrical cord the tools were not contaminated. A review by the inspector confirmed that the licensee has a generally adequate contaminated tool control program. The industrial security aspects of this incident are still being reviewed by the license The inspector also briefly reviewed the licensee's personnel contamination tracking program. In 1988, the-licensee documented 115 personnel contaminations, using 100 cpm above background as detected with a hand-held frisker as the lower limit for tracking contamination Of the 115 contamination events, nearly 70% involved only personal clothing. The predominant isotope of all the contaminations was Co-5 For 1989, based on planned outage work and experience at other stations, the licensee is estimating 300 personnel contaminations will occur. The inspector noted that the station is still developing a hot particle procedure; hot particles have not been a problem to date, and ample guidance is available from the corporate RP staff if a problem develops before the procedure is approved and implemente The inspector reviewed the licensee's contaminated system leak tracking program. As part of the program, RP issues work requests for leaky components identified during RP work activities and leaky components are regularly surveyed before and after the leak is fixed. Reportedly, on several occasions, contamination surveys performed after repair have indicated that the components needed additional repair. As with the hot spot program discussed in Section 5, the leak program exhibits an aggressive attitude toward contamination contro No deviations or violations were identifie . Plant Tours (IP 83750)

Several tours of station facilities were made to review postings, access l control, contamination control, housekeeping, and radiation worker

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! practices. No problems were noted. Results of independent surveys conducted by the inspector indicated no radiological conditions outside of station or regulatory limit No deviations.or violations were identifie . Exit Meeting (IP 30703)

The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on February 17, 1989. The inspector summarized the scope and findings of the inspection, and the likely informational content of the inspection report. The licensee did not identify any of the information as proprietar !

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