IR 05000456/1989024

Insp Repts 50-456/89-24 & 50-457/89-24 on 890703-0901. Violations Noted.Major Areas Inspected:Operational Radiation Protection Program & Radwaste Program,Including Changes in Personnel,Audits & Appraisals & Outage Planning

ML20247H840
Person / Time
Site:	Braidwood
Issue date:	09/12/1989
From:	Greger L, Holtzman R, Michael Kunowski, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20247H833	List: IR 05000456/1989024 ML20247H829 ML20247H835
References
50-456-89-24, 50-457-89-24, GL-89-01, GL-89-1, NUDOCS 8909200112
Download: ML20247H840 (15)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/89024(DRSS); 50-457/89024(DRSS)

Docket'Nos. 50-456; 50-457 Licenses No. NPF-72.; NPF-77 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: July 3 through September 1, 1289 Inspectors: 5 Kunows 1 thA p/Tg Dath

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R. B. Holtzma kh/h Dite'

f[kha v Reviewed i>~y: M. C. Schumacher, Chief Radiological Controls and f////f Date Chemistry Sectionf/pfund}- 7 Approved By: L. Robert Greger, Chief !M_ Reactor Programs Branch Date Inspection Summary Inspection on July 3 through September 1,1989 (Reports No. 50-456/89024(DRSS);

  '50-457/89024(DRSS))

Areas Inspected: Routine, unannounced inspection of the operational radiation protection program (Inspection Procedure (IP) 83750) and the radioactive waste program (IP 84750), including: changes in personnel, audits and appraisals, outage planning and preparation, internal exposure control, shipping of radioactive material, and implementation of the solid, liquid, and gaseous radioactive waste program. Also reviewed were previous inspection findings (IP 92701) and the licensee's Radiological Environmental Monitoring Program (IP 84750 and IP 80721).

Results: No major problems were identified with the licensee's overall Implementation of the radiation protection, radioactive waste (radwaste), Ndk 6 u - . _ _ - _ - _ - _ _ _ _ _ _

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L ' and radiological environmental monitoring program Planning and preparation

  'for the station's first refueling outage appear adequate. Activity of solid, l   liquid,-and gaseous radioactive waste generated by the station,is low. Two violations were identified with a shipment of radwaste (failure-to properly
,_  ' survey a radwaste shipment vehicle and failure of several oversight groups
  - to prevent shipment of radioactive material when survey results indicated a regulatory dose. rate limit was exceeded - Section 12)'. A third violation was identified as'a failure to include the results of analyses of'all radiological environmental samples in the Annual Radiological . Environmental
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Reports for 1987 and 1988 as, required by T/S 6.9.1.6 (Section 6). .A fourth

  . violation was identified by the licensee (failure to have a description of the interlaburatory comparison program in the Offsite Dose Calculation Manual as
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required by T/S 4.12.3) but it was not included in the Notice of Violation under the provisions of NRC Enforcement Policy V. A fifth violation

  .(failure to report required information in the semiannual radioactive effluent release reports - Section 11) was also identified; however, because the
  . provisions of Section V.A. of Appendix C to 10 CFR 2 have been satisfied, this violation will not be included in the Notice of Violatio ,        I l

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DETAILS + Persons Contacted C. Aleshire, Radwaste Staff K. Aleshire, Health Physicist

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1,2,3F. Ambler, Health Physics Supervisor R. E. Andrew, Health Physicist, State of Washington 2E. W. Carroll, Regulatory Assurance 2R. Carson, EP, Corporate D. E. Cooper, Regulatory Assurance Supervisor A. D' Antonio, Quality Control (QC) Supervisor R. R. Fay, Health Physics' Scheduler 48. Ferguson, Health Physicist, Radiological Environmental Monitoring, Corporate 2R. A. Grom, Radwaste Shipping Coordinator 4,5J. C. Golden, Supervisor of Emergency Planning, Corporate 2M. J. Harper, Quality Assurance (QA) Inspector 2J. M. Hausser; QC Group Leader 1,3P. G. Holland, Regulatory Assurance D. Johnson, Radwaste Staff L. Kim, QA Inspector 2K. L. Kofron, Production Superintendent 2R. D. Kyrouac, QA Superintendent t 2R. C. Lemke, Technical Staff Supervisor 1L. A. Literski, GSEP Coordinator 2W. B. McCue, Operating Engineer S. Notter, QA Maintenance Engineer 3 D. E. - 0'Brien, Technical Superintendent 2R. E. Querio, Station Manager 2L. W. Raney, Nuclear Safety Supervisor 1F. Rescek, Radiation Protection ~ Director, Corporate 3E. Roche, Health Physics Group Leader 1,2K. T. Weaver, Health Physics (HP) Supervisor, Corporate 2D. R. Calhoun, NRC Project Inspector 2M. C. Schumacher, NRC Section Chief, Radiological Controls and Chemistry Section 2T. M. Tongue, NRC 5enior Resident Inspector The inspectors also interviewed other licensee and contractor personne enotes those present at onsite exit meeting on August 8, 1989. 2Present at telephone discussion on August 11, 198 Present at telephone. discussion on August 15, 198 Present at corporate office exit meeting on July 14, 1989. 5Present at telephone discussion on August 30,.i389.

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  .. General This was a routine inspection of the operational radiation protection program and the radioactive waste program. In addition, the licensee's Radiological Environmental Monitoring Program (REMP) was inspecte . Licensee Action on Previous Inspection Matters (IP 92701)
   (Closed) Open Item (456/89006-01; 457/89006-01): Review licensee's actions on a Radiological Occurrence Report (ROR) written for an incident where seven workers were externally contaminated by a leak in the Unit 1 pressurizer manway cover. The licensee has repaired the leak and revised a maintenance procedure (Section 8 of Inspection Reports No. 50-456/890005; 50-457/89005). In addition, training has been provided to the HP, Operations, and maintenance departments regarding the breakdown in communications that resulted in the workers entering the area and becoming contaminate (Closed) Violation (456/89006-02; 457/89006-02): An indivioual who had worked in a radioactive materials area at the station did not receive a bioassay following his work assignment and an exception had not been granted by the HP group. The station has modified its procedure to ensure that HP requirements are satisfied for terminated employee Weekly, the security department provides the HP group with a list of recently tenninated individuals. This list is used by HP to notify those individuals who have not yet received an exit whole-body count (WBC). If an initial notification is unsuccessful, a letter is sent to the individual by certified mail requesting him to return to the station and receive a WB If this means of notification is unsuccessful, the HP group will review the individual's recent work assignments to determine if it is likely that the individual received an exposure to airborne radioactive materia Inspection Reports No. 50-456/89014; 50-457/89014:

This report contains the results of an NRC Augmented Inspection Team onsite at Braidwood from April 25-28, 1989, to review two incidents of inattentive personnel. As stated in that report, the licensee has been evaluating several plans for improving working conditions at the 401' control point in the turbine building. During the current inspection, the inspector noted that the licensee has moved the HP control point from the turbine building, where the din and warm temperature are conducive to inattentiveness, to the auxiliary building, where noise and warm temperature is not a problem. The HP group is still assigning additional work to techs at the control point in order to more fully occupy their attention and forestall drowsiness. The licensee is currently evaluating a facility modification to move the whole-body friskers that are still on the turbine building side of the control point to the auxiliary buildin _ _ - _ - _ - _ _ - - _ _ _ - _

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        .I Changes in Personnel (IP 83750, 84750)

f" The inspector reviewed major changes in the radiation protection (RP) and the radwaste groups.that have occurred since the previous RP inspection in February 1989 (Inspection Reports No. 50-456/89006; O L50-457/89006). The licensee has appointed a new Radiation Protection Manager (RPM) to replace the individual who previously held that position

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and was recently transferred to the corporate office. The new RPM has a

 'B.S. degree in Environmental Health, six and a half years experience as a staff health physicist at Dresden, and approximately six months experience  l as a. lead health physicist at Braidwood. Of.these seven years experience, he has been in a supervisory position approximately four and a half year In view of his training and experience, the licensee's appointment of this individual-as RPM is in compliance with Technical Specification 6.3, which specifies the qualifications of the RPM. Other less significant
 . personnel changes are the permanent hiring of the assistant ALAR Coordinator - he previously was a contractor - and the elimination of the lead HP foreman position.' The individual formerly in that position is now in a newly created "HP scheduler" position. These changes are not expected to reduce the effectiveness of the licensee's progra ]

No deviations or violations'of NRC requirements were identifie l Audits and Appraisals (IP 83750, 84750) The inspectors reviewed Quality Assurance audits and surveillance conducted since mid-198 Overall, the extent of the audits and surveillance,.the qualification of the auditors, and the adequacy of corrective actions ware generally good. One apparently isolated, but

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egregious lapse _of the licensee's quality assurance / quality control program is discussed in Section 12. The inspectors also noted a recent positive change to QA activities. The licensee has conducted two." extended" surveillance in the HP and chemistry areas. These surveillance extend over several weeks unlike a~ typical audit, which is limited to five days, and focus on one area in greater detail than is allowed in a typical' surveillance. Additional extended surveillance are planne The inspectors also reviewed RORs written since the previous NRC RP inspecticn. The RORs were reviewed for significance, corrective actions, and trends. No problems.were noted with the licensee's implementation of the ROR progra No deviation or violations of NRC requirements were identified by the inspectors.

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  : Radiol'ogical' Environmental Monitoring Program (REMP) (IP 84750, IP'80721)
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a : Plant Site Visit' The inspector reviewed the REMP', including the 1987 and 1988 Annual Environmental Report, 1988 monthly environmental reports,-QA audits _ of.the program, some air sampling stations, maintenance records, and the Offs,ite Dose Calculation Manual-(0DCM).

The inspector identified a violation of Technical Specification 6.9.1.6, l- which states that the Annual Radiological Environmental Report shall L include the results of analyses of all radiological environmental ' samples and of all environmental radiation measurements.' Contrary to .

  'this, although the 1987 and 1988 reports contained summaries of-the l

results. of analyses, they did not include the results themselves. A w licensee representative agreed to correct this by adding the results of the analyses to the reports. This failure to. follow this Technical Specification is a violation of NRC requirements (Violation 456/89024-01; 457/89024-01). This is given a Severity Level IV because of poor programmatic oversight of REMP T/S requirements in which it' appears

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that corporate and licensee managements have been. slow to catch and correct this and the related deficiency in the QA Audit noted belo The Annual Environmental Reports appeared to meet the other requirements of a list of the environmental radiation measurements and~ summaries and tabulations of the results of the analyses made during the respective periods. All of the required swnples were collected.and analyzed, except as noted in the report. A review of the detailed results reported in the 1988 cumulative monthly reports

  .(January-December) appeared to be acceptabl .

The test and maintenance' records of the air sampling stations in 1988 showed.the systems to be maintained within specifications, and the records' appeared to be' complete. The inspector toured and inspected nine air-sampling stations around the plant for

  , operability and leakage of the sampling train. He noted inleakage-through one' filter train; this problem appeared to be due to a faulty
  . Quick-Disconnect fitting. The liccnsee representative noted that this will be corrected at the time of the next sample collectio The vendor's test procedure (TIML Procedures, Section 5, " Sample Collection Procedures," Revision 1, 1986, Appendix A,'" Servicing
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and checking of air sampling equipment," Revision 0, January 20, , 1981.) appears to be adequate in requiring the testing of the filter i train by blocking the filter fac A review of the Corporate QA audits and surveillance of the REMP found a few problems with the meteorological' instrument calibration Audit QAA 20-88-31 of October 21-28, 1988, reported that, contrary to the Technical Specification.4.12.3, the-Interlaboratory Comparison Program was not described in the ODCM. The licensee corrected the ODCM; the change was approved and placed in the site-specific section l l '

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 ~for Braidwood on December 30,198 This'is a violation, but:it is T not cited under the provisions of NRC Enforcement Policy V. (53 FR 40019(1988)). Corporate Office Visit The inspector also reviewed the REMP at the corporate office, the organization responsible for the REMP operation. The ODCM, as
 ' Revision 0, has been rewritten and officially distributed as of
 ' August 11, 198 It.is designed to clarify the text, and to address NRC Generic Letter 89-01 and various minor problems that have arisen
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over the years. The T/S omission will be incorporated into a generic 'section'to conform to the requirements of other plants, especially that of Byron. The description appears to satisfy the T/S requirement, especially when combined with the details in the Annual Environmental Report. They believe that the changes are not

 : extensive enough to warrant prior NRC review; it is being submitted to the NRC after. corporate acceptance. Further, they are planning and are presently drafting several additional revisions that will address (1) removal of the RETS from the T/S and the resultant revised T/S, (2) the' Clean Air Act (U.S. EPA), and (3) the NRC's revised 10 CFR Part 2 Several substantial changes will be made to the ODCM dose calculations, including the substitution of child thyroid as an organ that is more critical than the presently-used infant thyroid, and the site-specific radiation effects of N-16 skyshine in BWRs due to the use of. Hydrogen Water Chemistry (HWC). The calculations for the HWC effects will be extended beyond 1100 m from the plant and terrain correction factors will be adde The TLD environmental monitoring program is being expanded, on an experimental basis, to include owner controlled areas outside the protected area that may have the presence'of members of the public or worker The inspector noted to the corporate representatives weaknesses in the REMP. The-results for environmental samples are reported only for potential contaminants from plant operations, which are generally below detectio'n limits. Reporting of naturally-occurring nuclides, such as K-40 or Ra-226, which often have measurable specific activity values would allow better assessment of the results. Secondly,'some sampling sites, such as sediment analyses upstream of the cooling water blowdown location were dropped from the progra While the changes in the program and the ODCM conformed to the T/S, and notification was made of the ODCM revision
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in the plant's monthly operating report, the report might have been improved with the explanations of these changes along with the changes themselve The representative noted the concerns and stated that the reports met the NRC requirements and they were not contemplating change One violation was identifie _ - - _ .

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,        l 1 Outage Planning and Preparation (IP 83750)

m The inspector reviewed.the HP group's planning and preparation for the upcoming refueling outage, the station's first refuel outage. . The 25  ;

 " house" RP technicians will be supplemented with approximately 70  '

contractor technicians and several of the house chemistry technician The inspector noted that a plan by the licensee to use exclusively contractor (Westinghouse) RP technicians to cover steam generator work may result in the licensee ~ missing a valuable training opportunity for the house tech i Each of the station's four health physicists have been assigned responsibility for major outage activities, such as reactor head work, snubber work, reactor coolant pump seal work, and steam generator wor The inspector noted that the health physicists have been in contact with the HP staf fs at_ Byron and Zion to obtain information on how these stations handled the same work during recent outage The inspector also reviewed the adequacy of certain radiation protection equipment, including protective clothing, self-reading and thermoluminescent dosimetry, and survey meter The licensee appeared

 - to be well-stocked with such equipmen Finally, the inspector observed.that the. licensee has recently
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implemented a plant equipment and facility layout photograph librar The photographs in the library are stored on optical: disks and can be viewed from a personal computer set up in the HP departmen The system will be used for training and' job planning, and has the potential for significant long-term dose saving No deviations or violations of NRC requirements were identifie . Solid Radwaste (IP 84750) The inspector reviewed records and procedures', interviewed personnel, and inspected facilities and equipment associated with the licensee's solid radwaste management program. No problems were identified. Waste dewatering and solidification is provided by an onsite vendor. The solidification systwa originally installed at the station was removed prior to its use because of operational problems with the system at other nuclear station Currently, the licensee is aggressively reducing the volume of dry-active waste (DAW) shipped from the statio A state-of-the-art sorting table equipped with 18 plastic scintillation detectors, having a sensitive area of approximately 420 cm2/ detector, was recently installed and is being

 ,used to monitor trash from the auxiliary building. Contaminated trash is compacted if possible and may be sent to a waste processor for

' additional compaction. For 1988, the volume of solid radwaste shipped offsite for burial or reprocessing was low, 83 m3 (2938 ft3), reflecting the age of the plant and the DAW reductiors effort No deviations or violations of NRC requirements were identifie _ _ _ - _ _ - _ - _

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q( ~ . Liquid Radwaste'(IP84750) The inspector reviewed the licensee's liquid radwaste management program to determine compliance with effluent requirements. No major problems were identified,- Liquid radwaste is released from the station in batches from one of two 30,000 gallon capacity release tanks. Each batch is

 . sampled and the sample is isotopically analyzed prior to release of the batch. In 1988, the licensee released approxir.iately 11.5 curies activation
 - and-' fission. products (excluding tritium) and 518 curies of tritiu;n. For the first six months of 1989, the licensee released approximately 2.8 curies of activation and fission products (excluding tritium) and 782 curies of tritium. The concentration of radioactive material in the liquid effluents and the offsite dose for 1988 and 1989, to date, was within regulatory limits; however, the 11.5 curies (for both reactors) of activation and fission products (excluding tritium) released in 1988 was over the 5 curies per year per reactor at a site design objective in Appendix I of 10 CFR 50. The licensee .ittributed the relatively high quantity released to maintenance on Unit 1 and startup of Unit 2 (Inspection Reports No. 50-456/88025; 50-457/88025). In 1989, the licensee has' reduced the quantity released and should meet the 5 Ci design objective. ~The licensee's efforts to reduce the quantity of radioactive material released in liquid effluents will be reviewed further at future inspection No deviations or violations were identifie . Gaseous Radwaste (IP 84750)

The' inspector reviewed the licensee's gaseous radwaste management prograin to determine compliance with effluent requirements. No problems were

 . identified. Gaseous radwaste is released from the two unit stacks and consists of mainly batch releases from the waste gas decay tanks, and containment atmosphere purge Each batch is sampled and the sample is isotopically analyzed prior to release of the batch. In 1988, the licensee' released approximately 80 curies of fission and activation gas products, 24 millicuries of 1-131 and I-133, and 5.4 curies of tritiu In the first'six months of 1989', the lice'nsee released approximately
 '132 curies of fission and activation gas products, 0.4 mci of I-131 and I-133, and 8.9 curies of tritium. The concentrations of radioactive material in the gaseous effluents for 1988 and 1989 to date, were within regulatory' limit No deviations or violations were identifie . -Effluent Reports-(.P 84750)

The inspector select vely reviewed radiological effluent analysis results, solid radwas i shipment inform: tion, and the Semiannual Radioactive Effluent Rt m se Reports for 1988 to determine accuracy of dat Analysis results Tnd shipment information were accurately compiled in the Reports. However, contrary to Technical Specification 6.9.1.7, data summarizing liquid ant.' gaseous effluents and reported in the two reports for 1988 were not reported in the format of Appendix B of

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rq x C Revision 1 of Regulatory Guide 1.21, " Measuring, Evaluating, and Reporting Radioactivity.in Solid Wastes and Releases of Radioactive Materials in

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i Liquid and Gaseous Effluents from the Light-Water-Cooled Nuclear Power Plants." Specifically, supplemental.information on measurements and approximations of total radioactivity, and on batch and abnormal releases was not provided; and mode of. release of liquid and gaseous radwaste was not specified.'. The Technical Specification-also requires the licensee to submit information on class'of solid waste, type of shipment container, and solidification agent or absorbent. Contrary to this requirement, this information was not included in the two reports submitted for 198 ,, . When told by the inspector of the missing information, the licensee T immediately initiated appropriate corrective action. Consequently, pursuant to Section V.'A of Appendix C to 10 CFR Part 2, a Notice of Violation will not be-issued for this isolated Severity Level V violation (Violation 456/89024-02; 457/89024-02).

One violation was identified; however, a Notice of Violation will not be issue . Transportation of Radioactive Material (IP 83750) The inspector reviewed the licensee's program for transportation of radioactive material, including radwaste. In 1988, the licensee made approximately 30 shipments of radioactive material. In 1989, to date,

 .the licensee made approximately 40 shipment Most of the shipments consisted of contaminated protective clothing, sent to a nearby laundry, and radwaste, sent to the low-level burial site near Richland, Washingto 'The inspector reviewed paperwork for radwaste shipment RWS 9004, shipped from the licensee's facility on April 3,198 The shipment consisted of 602 radwaste system filters and 16 primary system filters packaged in a rigid-fcam lined, polyethylene liner which was secured within a lead and stainless steel shield cask. The total activity of the filters was estimated as 18.17 curies, with the predominant isotopes being Co-58, Co-60, Mn-54,'Fe-55, and Fe-59. The record of the survey performed prior to the shipment leaving the site indicated that a dose rate measurement of 16 mrem / hour was obtained for one of several measurements made at two

, meters from the sides of the shipment vehicle. This exceeded the limit I of 10 mrem / hour specified by U.S. Department of Transportation (DOT) regulations in 49 CFR 173.441(b)(3). Shipment of the package with the dose rate exceeding the limit of 49 CFR 173.441(b)(3) would be a violation , of 10 CFR 71.5(a), which requires each licensee who delivers licensed I material to a carrier for transport to comply with the applicable i requirements of the DDT in 49 CFR Parts 170 through 189. The inspector i informed the licensee of the problem with the shipment and the licensee l immediately began an investigation. The licensee obtained a copy of the , survey performed of the shipment by the burial site operator upon arrival I of the transport vehicle. This survey was reviewed by the NRC inspector and indicated that the highest reading obtained at 2 meters from the vehicle was 3 mrem /hr, well within the DOT limit. The licensee also stated that followup with the State of Washington, whose personnel also l inspect incoming shipments at the site, indicated that the state inspector who surveyed the shipment found no excessive dose rate '

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['. L , , [; ' ..  :. - yJ ' P Further review by the NRC inspector of the circumstances of the licensee's .. initial survey included interviews of plant personnel and record review The. inspector interviewed the technician who performed the survey, however, the technician'did not remember the' specific values obtained during the survey. The licensee's radwaste shipping coordinator wy, interviewed and.

y ' stated.to the inspector that during the survey of.the vehicle he asked the technician what was the highest dose rate reading on contact with the cask and at two meters. The coordinator stated that the technician informed him j of both readings, and the coordinator specifically remembered that the h highest contact reading was 60 mrem / hour (compared to a limit of

.. 200 mrem / hour),lbut could not remember the highest'2-meter readin However, he stated t_ hat he remembers that the 2-meter reading was definitely kl .

less than 10 mrem /hrh , possibly 2-3 mrem / hour. The coordinator stated that'the technician e owed him where the the 60 mrem / hour reading was taken, and remembered that it was essentially a hotspot. The coordinator also stated that just prior to departure of the shipment, he took the survey record to a Jtaff health physicist for her review and signatur Review of shipment survey records by a staff health physicist--for purposes of oversight--is: required by Cation procedure before radioactive material can be shipped offsite. The survey was signed by the health physicist, indicating that. survey results were acceptable. The coordinator stated that he then met with the driver of the vehicle, a QC inspector, and a QA' inspector to review shipment documents and to obtain signature After a review of detuments, the coordinator and the QC and QA inspectors signed off on Radwaste Shipment Checklist, Bw0.P WX-218, Revision 4, indicating that the shipment was authorized for release from the statio In addition, as required by Quality Procedure Q.P. No. 13-52, the. survey data from the survey record had been copied to a checklist, Form 13-52.2, and the checklist was signed by the QC and QA inspectors,

  ' indicating that the shipment was released. The NRC inspector reviewed both checklists, and noted the signatures and that the 16 mrem / hour value had been copied onto the Q.P.13-52.2 checklist and the 10 mrem / hour limit was pre printed on the checklis This incident, including the possibility for escalated enforcement because a DOT dose rate limit was apparently exceeded, was discussed with the licensee at the onsite exit n.eeting on August 8,1989 (Section 14).

On August 11, 1989, the NRC inspector telephoned the State of Washington inspector who had surveyed the shipment when it arrived at the burial sit He stated that the highest contact reading on the liner was 25 mrem / hour and the highest 2 meter reading from the sides of the vehicle was 2 mrem / hot.r. Also on August 11, the licensee telephoned the NRC inspector and his supervisor with additional information that came out the licensee's

  " personnel error evaluation program" meeting which was convened to review this incident. According to the licensee, the technician remembers that the'2-meter readings were taken at 2 meters from the cask, out from the highest contact readings, and not'2 meters from the sides of the vehicle, but still could not remember the specific values for the measurements or his position in relation to the sides of the vehicle during the measurement In adJition, during'the licensee's formal review, the radwaste shipping coordinator, W when interviewed by the NRC inspector renembered the 60 mrem / hour contact reading, also remembered that the 60 mrem / hour hotspot

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was oriented more toward the back of the trailer (at about the seven o' clock position) than to the sioe. With the additional information provided by the technician and the shipping coordinator, the licensee performed a conservative evaluation that indicated that the maximum dose rate reading at 2 meters from the side of vehicle nearest the 60 mrem / hour hotspot would have been about 9 mrem / hour. A copy of this evaluation was reviewed by the NRC staf On August 14, 1989, an Enforcement Board was convened in Region III to review this incident. Based on the fact that two independent surveyors at the burial site found no dose rate readings above DOT limits and i considering the recollections of the technician and the radwaste shipping coordinator, the Board concluded that it was unlikely that a D0T limit was , exceeded and that consequently, escalated enforcement will not be pursue ' However, two violations were identified during the review of this event: Section F.3.a. and the Radioactive Shipment Survey Form of Braidwood Procedure, EwRP 1620-4, Revision 5, Surveying Radioactive Material Shipments, require that a survey be performed at 2 meters from the sides.of the transport vehicle and the results .of that survey be documented on.the Form before the vehicle is released from the sit Contrary to this requirement, on April 3, 1989, a survey was not performed at 2 meters'from the sides of the transport vehicle before it was released from"the Braidwood site. A survey had been performed and documented several days earlier, on March 29, 1989, but the survey was performed at 2 meters from the shield cask and not from the sides of the; vehicl The failure to follow procedure BwRP 1520-4 is 'a violation.of T.echnical Specification 6.11, which requires that procedures for personnel radiation protection be adhered to for all operations involving personnel radiation exposure (Violation 4 % /89024-03; 457/89024-03). Braidwood Procedure Bw0P WX-219, Revision 4, Shipping of Radioactive Waste, states that a shipment that does not meet the criteria of Q.P. 13-52, must not leave the site. Quality Procedure Q.P. No. 13-52, Preparation and Shipment of Radioactive Material, included within the Commonwealth Edison Company Quality Assurance Manual, establishes the requirements for the preparation and transportatica of licensed radioactive material in order to ensure compliance with Titles 10 and 49 of the Code of Federal Regulations, Verification of compliance with these requirements.is made by a Quality Assurance and/or Quality Control Inspectar and indicated on Q.P. Form 13-52.2, Radioactive Material Shipment Checklis The 00T limit of 10 mrem / hour at 2 meters from the side of the shipment vehicle is listed on the checklist. Acknowledgement that a shipment is in compliance with Titles 10 and 49 and can be released offsite is indicated by the signatures of the quality inspectors on the cacklist. On April 3, 1989, a value of 16 mrem / hour, a value in exetus of the 10 mrrm/ hour limit listed on the checklist, was entered on the checklist by a QC inspector and the checklist was subsegunntly signed by that inspector and by a QA inspector releasing the shipment for offsite transportatio The release of the vehicle with a dose rate reading apparently in excess of the 10 mram/ hour limit is contrary to Bw0P WX-219 and

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[,   Q.P."13-52 and as such is a violation of 10 CFR 50, Appendix B, Criterion V, which requires that activities affecting quality be. accomplished.in.accordance with' documented instructions, P   procedures, or drawings that include appropriate quantitative or
  . qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished (Violation   i
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456/89024-04; 457/89024-04).  ! c l

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As stated earlier, the licensee promptly investigated the problem when informed of it by the inspector. The licensee also' instituted corrective actions, including the counseling of the individuals involved, the temporary requirement to have two HPs review shipment survey records, the review of the generic shipment survey form for L possible revision,. the revision of. a QA checklist to include the DOT g limits, highlighting of the D0T limits on the Q.P.13-52 checklist, f

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and providing of. training within the QA department on the inciden ! A review of records by the NRC inspector for the other radwaste' shipments in 1988 and 1989 identified no similar problems. Apparently, the.violat, ions identified with shipment RWS 9004 are isolated, and may have resulted from complacency, engendered by the licensee's oversight system for radwaste shipments in which there are 3-4 possible reviewers of.the shipment survey recor Two violations were identifie . Internal Exposure Control (IP 83750) Discussions with' licensee representatives and a review of records

  ' indicated that the licensee has identified a problem with an unknown worker (s) eating in the auxiliary building radiological contrnlled area (RCA). In addition, a recent incident occurred in which human excrement was found in a " clean" trasn container in the auxiliary building RC 'In response to these problems, the licensee sent to a memo to all plant staff, posted signs in the RCA regarding the prohibition against food in  !
 'the RCA, and instituted searches of workers entering the RCA at the main

> contractor entrence on the'401 elevation. Except for two discarded h cigarette. butts found on-the floor. in the RCA, the NRC inspector did not identify any similar problems' during severals tours of the RCA. The licensee's actions on the problems of eating in the RCA were notably prompt and extensive Nodeviations~orviolationswereidentifiedbytheNRCinspecto . Exit Meetings (IP.30703) F The scope and findings of the REMP inspection as described in Section 6 of this report were reviewed with corporate representatives (Section 1)

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at the conclusion of the inspection on July 14, 1989, and with station and corporate representatives onsite on August 8,1989. A telephone discussion was held with J. C. Golden on August 30, 198 _ = _ _ ___ _ _ _ _ _ . ._ _ _ _ . . _ 1

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

 .at the conclusion'of the onsite RP and radwaste inspection on August 8,

1989, and summarized the scope and tentative findings of the inspectio Specifically, the following.. items were discussed by the inspector

 ' The extent of QA activities and the licensee's responses to audit findings / observations was generally good. The " extended surveillance" innovation was.also good (Section 5). The station's DAW reduction effort is good, including the use of a
. state-of-the-art' sorting table (Section 8).

. . Placement of the' auxiliary building main control point in the

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auxiliary building- .,.as part of a licensee plan to. improve working conditions atlthe control point (Section 3).

. Net'able efforts of the HP staff in preparation for the upcoming outage, including contacts made with Byron and Zion to review how

   'those stations handled major outage jobs (Section 7). .The licensee's aggressive handling of a problem with workers eating in the auxiliary building RCA (Section 13). The violation involving the Semiannual Effluent Reports (Section 11).

g .- Possible escalated enforcement involving a shipment of radwaste (Section 12). The vio'lation involving completeness of the. annual Radiological

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Environmental Report (Section 6).

The licensee acknowledged the inspector's coaments and described

 'the tentative results of their review of the shipaent proble On August 11, 1989, licensee representatives (Section 1) informed kegion III of the ~ results of their formal review of the matter, specifically that the technician measured dose rates at two meters from the shield cask and not V.. '  from the sides of the vehicle, and the hotspot associated with 16 mrem / hour reading was oriented more toward the rear of the trailer not the side. The licensee discussed results of their evaluation, performed _after additional information was obtained from the technician and the coordinator, that indicated that the dose rate at 2 meters frora the side of the traile* was less than 10 mrem / hou The NRC representatives acknowledged the licensee's information and, in return, noted that the surveyor's apparent lack of
 . understanding of the intent of the vehicle survey indicated a training-weaknes The licensee representatives acknowledged this comment, On August 15, 1989, the inspector discussed with licensee representatives g  (Section 1) the results of the Region III Enforcement Board review of the shipping proble Specifically, the inspector stated that in view of the information presented by the licensee regarding the original survey and the survey results of the burial site operator and state inspector,
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a. . . . - ' escalated enforcement was not being pursued;'however, the licensee will be cited for a failure to' follow the survey procedure and a failure of the. oversight mechnis The inspector observed that a potential hazard of too much oversight:is that individuals may lose a. sense of responsibility for their work and become complacent, assuming that the

 .next person will catch.any mistake. The licensee acknowledged the inspectoP s statement and expressed their concern with the shipping  i problem, notwithstanding the decision that escalated. enforcement was not
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being pursue During the exit interviews, the inspectors discussed the likely information content of the inspection report with regard to documents or processes reviewed during the. inspection. Licensee representatives did not identify any such documents or processes as proprietar , . - l l'

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