IR 05000456/1993002
| ML20128B066 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/25/1993 |
| From: | Markley A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128B038 | List: |
| References | |
| 50-456-93-02, 50-456-93-2, 50-457-93-02, 50-457-93-2, NUDOCS 9302020390 | |
| Download: ML20128B066 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION'
REGION 111 Reports No. 50-456/93002(DRSS); 50-457/93002(DRSS)
Dockets No. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee:
Commonwealth Edison Company l
Executive Tower: West III
1400 Opus Place 3-Downers Grove, IL 60515
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Facility Name:
Braidwood Station, Units 1 and 2 Inspection At:
Braidwood Site, Braidwood, Illinois Inspection Conducted: January 5 through 8, 1993 Inspector:
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.'W. Markley -)
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Senior Emerge _ncy Preparedness I
Analyst j
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H. C. Schumacher, Chief Date Radiological' Controls and Chemistry Section IDIPJ. tion Summarl
'Jnsoection on January 5 t_hrouah G.199L(Reports No. 50-456/93002(DRSS):
50-457/93002(DRSSll
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atfLaLJnsoected:. Routine,-announced inspection:'of the radiation protection program : Including: organization, management controls, and training; audits and. appraisals; external exposure controls; and control of radioactive materials (IP 83750).
Results: During this inspection, one violation was~ identified for a failure to ensure that' controlled (contaminated). areas.were conspicuously'. posted.
.(Section 5).
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Areas for which Jmprovement appears to be merited: : continued efforts in-contamination control (Sections 5 and:6);-expanding the scope of, field monitoring reports.(Section 4);' system knowledge of radiation protection personnel (Section 3);. and noted exceptions in housekeeping and material conditions (Section'7).-
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Strengths were identifie'd in the areas of. radiation protection technician knowledge of plant conditions-. (Section.3),. improvements to the auditor--
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qualification procedure (Section 4), housekeeping (with exceptions)
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DETAllS 1.
Persons Contacted R. Fay, Lead Radiation Protection Supervisor
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P. Habel, Unit 0 Operating Engineer
- A. Haeger, Regulatory Assurance Supervisor
- F. LeSage, SQV Engineer
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- J. Lewand, Regulatory Assurance
- K. Kofron, Braidwood Station Manager
- D. Miller, Technical Services Superintendent-
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- E. Roche, Health Physics Supervisor
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- R. Rysner, SQV Inspector K. Skinner, Contamination Control Coordinator
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- R. Stols, Services Director ll
- S. G. Dupont, Senior Resident Inspector i
- R.-Roton, Resident Inspector The inspector also interviewed other licensee personnel during the course of the inspection.
- Denotes those present at the exit meeting on January 8,_1993.
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General-This inspection was conducted to review aspects of the licensea's radiation protection program. The inspection included tours of radiation controlled areas, auxiliary building, radwaste facilities, observations of licensee activities, review of representative records, and discussions with licensee personnel.
3.
Oroanization. Mangement Controls and Trainina (IP 83750)
The inspector reviewed the changes in the licensee's organizationand-management controls for the radiation protection (RP) programs, including:
organizational structure, staffing, delineation' of authority and management techniques used to implement the program, a.
Oraanization and Manaaement Controls Since the last inspection, three health physicists left the organization: one due to a reduction in force and the other two to--
resignations. A _ nuclear engineer from technical staff has filled one position. The other position was filled by an individual from-Dresden station's' nuclear quality program ' staff. This individual-
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had previous radiation protection experience'at.Braidwood station..
A radiation protection supervisor was' reassigned lto the quality control department; the position was an overage and_will not be filled. A dosimetry engineering assistant with.significant outageL
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experience has been reassigned to the ALARA group.
A general review of personnel assignments within the radiation protection department indicater that good use of personnel capabilities and experience.
Since the last inspection, five RP technicians were advanced to ANSI qualified status. Currently, 24 out of 31 RP technicians are ANSI qualified.
The inspector conducted a brief, selective review of RP policy memorandums / statements. These documents cover most areas of radiation protection activities and some of the information may be more appropriately addressed in procedures. The licensee agreed to review their policy documents. This will be reviewe6 further during a future irspection, b.
Trainina During tours of the plant, the inspector questioned two radiation protection technicians regarding various plants systems and components.
Both technicians demonstrated a good knowledge of plant conditions and ongoing activities. However, there were several instances in which the technicians were not able to identify plant systems and components.
Subsequent discussions regarding plant systems with RP management personnel indicated similar knowledge weaknesses.
System training had recently been added to the annual RP technician retraining program. Continuing efforts to improve plant and system knowledge as well as the radiological implications of these systems is encouraged.
The inspector observed an apparent weakness in the security of Nuclear General Employee Training (NGET) tests. Tests and answer keys were being kept in an unlocked and unattended' file cabinet in an office adjacent to the NGET classroom. The material was unguarded while an instructor was in the classroom and not in a position to observe possible entrie's to the office through a propped open door leading directly to a hallway.
Procedure BwTP 600-25 requires locked storage for operations, maintenance, and other designated training program tests but not for NGET.
The matter was discussed with the training supervisor who indicated his satisfaction with the security.
This matter will be reviewed in subsequent inspections.
No violations or deviations were identified.
4.
Audits. Surveillances and Self-Assessments (IP 83750)
The inspector reviewed the results of Quality Assurance audits and surveillances conducted by the licensee.
Also reviewed the extent and thoroughness of the audits and surveillances.
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The licensee uses Field Monitoring Reports (FMRs) for the performance.of quality-assurance surveillance activities, FMRs are intended to be-performance-based evaluations of ongoing plant activities. A review of~
FMRs performed during 1992 indicated that the-Nuclear Quality Programs
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group has~been' actively observing plant activities.
However, in the area of radiation protection program, the FMRs_ performed-appeared to stress operational activities,- such as contamination and exposure control, use of calibrated instrumentation, radiation work permit (RWP) compliance, and radioactive waste shipping activities.
There wt less emphasis on other RP program features such as the bioassa,. respiratory protection, and Al. ARA programs. The licensee agreed to review the scope of the FMR program.
RP program audits are conducted once every two years, The last RP program audit was conducted in 1991. An audit of the RP program is scheduled for the first quarter of 1993. A review of the 1991 audit found that the RP program was generally functioning effectively.
Some problems were noted with closcout and tracking of radiation occurrence reports (R0R) and with confined space atmosphere checks..The ROR system has since been replaced with an inte. grated reporting system for the plant.
This system captures and tracks problems from all disciplines.
A review of auditor qualifications found that the lead auditor and most of the other team members had been suitably qualified as auditors in accordance with ANSI N45.2.23.
However, the inspector noted that the audit team's expertise in radiation protection was somewhat limited.
Since the last audit, the licensee had revised the procedure governing auditor and audit team qualifications. This revision appeared to address the weaknecces noted in the composition of the previous team.
No violations or deviations were identified.
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External Exposure Control (IP 83750)
The inspector examined the external exposure controls during tours of the plant on January 5-6, 1993. Observations and : independent dose rate measurements were used to determine the adequacy of radiological postings and ether controls. The inspector noted several examples of control weaknesses in addition to a licensee example. The safety significance of each of these occurrences was minor but together they indicated a lack of attention to detail and the need for improvements.
During tours of the plant on January 5-5, 1993, the inspector identified three controlled (contaminated) areas that were not conspicuously posted so as to warn personnel approaching the area.
In each case, the radiological postings were found face down on the floor and the area was.
not barricaded as delineated by procedure BwRP 1110-3, Radiological Postings, Labels, and Controls. These areas were located on the 383'-
elevation in the Unit'l curved wall room and above the steam generator valve isle.
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The inspector also identified other examples in which contaminated areas boundaries were not wel1 defined. Most examples were characterized by radiological rope boundaries not matching-radiological tape bouciaries on the floor.
These areas were located in the OB gas compressor room, Unit 1383' curved wall room, and on the 346' at Q-24.
Inconsistent practice was also noted in the use of _ barriers around contaminated areas.
Some areas had radiological rope and tape boundaries while others had only radiological rope boundaries.
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The inspector also found a high radiation area posting on the floor behind the cage door at the entrance to the high level drum storage area in the radwaste building. Although this posting was on the floor, it was lying face up with the warning information visible.
On January 6, 1993, the licensee identified an event in which a worker unknowingly entered a contaminated area and became contaminated.
The worker did not recognize the area because the radiological rope that marked the contaminated area boundary had fallen and the-contaminated area posting was not visible to personnel entering the Unit 2 B residual heat removal (RHR) pump room. Contamination levels in this room ranged from 2-20 kdpm.
The licensee completed the following corrective actions for the posting problems.
Corrected all NRC identified weaknesses.
- Completed a walk down of the entire radiologically-controlled area
(RCA) by both RP technicians and management personnel with
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particular attention to postings, step-off pads, and contamination l
area boundaries.
Corrections were made on the spot for inconsistencies or problems.
Held discussions with all RP personnel concerning problems found,
their significance, and the need for attention to detail to
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prevent recurrence.
l Conducted an immediate investigation-of the contamination event in
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a missing portion of the original contamination boundary.
The following additional corrective actions were initiated during the inspection.
RP will continue to evaluate contaminated area access control
needs as well as facilitating operator access by reducing the frequency of donning of protective clothing for operators on rounds.
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RP technicians and/or supervisors will conduct weekly, routine
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walk downs during the next several-months to evaluate contaminated
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area barriers, step-off-pads, postings, and to ensure that'
communicated expectations are being implemented in the field.
During subsequent tours of the plant, the inspector _ found that corrective actions implemented for identified problems to be acceptable.
The safety consequences to personnel were minor.
However, because th9re were multiple examples of improperly maintained contaminated area boundaries and poorly defined contaminated areas, these violations are
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of concern because collectively they represent a lack of attention to detail and poor exercise of care to ensure that radiological areas are
properly posted and controlled.
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Technical Specification 6.11 requires that radiation protection procedures be approved, maintained, and r.dhered'to for all operations involving personnel radiation exposure.
Procedure BwRP 1110-3, Radiological Postings, labels, and Controls, Section C.3 requires. that each controlled area shall be conspicuously posted so as to warn personnel approat," e the area from any direction. Failure to conspicuously post controlled areas so-as to warn personnel approaching the area is a violation (Violation No. 456/93002-01).
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One violation was identified.
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Control of Radioactive Material (IP 837501 The inspector 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; adequacy of review and dissemination of survey data; effectiveness of
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radioactive and contaminated material controls.
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Instrumentation During tours of the plant, the inspector observed that contamination monitoring, portable survey, area radiation monitoring instrumentation in use throughout the-plant had been-recently source checked and had current calibrations, as appropriate. A minor inconsistency was noted with the documentation of the source calibration date on the calibration stickers attached to the instruments. This was discussed with the licensee.
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Contamination Control l
The inspector evaluated licensee personnel contamination event (PCE) data for 1991 and 1992.
In 1991, there were 334 PCEs.
In 1992, there were 139 PCEs.
Significant improvement was attributed
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to the reduction of plant spills caused by operating and maintenance activities.
The licensee has gathered a significant amount of data regarding the PCEs.
However, from discussions with licensee personnel and review of PCE data, there was no indication that the licensee had determined the significance or meaning of the collected data.
Evaluation of this data could provide information regarding the effectiveness of survey methods, radioactive material controls, and decontamination techniques. Continued efforts to control contamination and its sources are encouraged.
No violations or deviations were identified.
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Elgnt Tours (IP 8375Q).
The inspector performed several tours of radiologically controlled areas.
These included walk downs of the auxiliary building, yadwaste
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facilities, and spent fuel pool facilities.
The inspector observed the following:
Housekeeping conditions were generally good in most areas of the
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plant.
Problems were noted in the hot machine shop, 426' laundry waste tank room, auxiliary building floor drain tank room, and the auxiliary building above the 426' elevation.
Long term accumulation of dirt, tools, matarials, and debris were noted in most of these areas.
Material conditions were generally good in most areas of the
plant.
Significant problems were identified with three out of four RHR pump seals, the 330' Unit 1 auxiliary building floor drain room water tight door, and a missing damper over the 383'
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chemical drain tank room door. Other minor equipment and material condition problems were also identified to the licensee.
No violations or deviations were identified.
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Exit Interview (IP 307031 The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on January 8, 1993, to discuss the scope and findings of the inspection.
During the exit interview, the inspector discussed the likely-informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
Licensee representatives did not identify any such documents or processes as proprietary. The following matters were specifically discussed:
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The identified violation (Section 5).
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Inspector concerns' regarding weaknesses in contamination control-and posting (Sections 5 and 6).
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Ir,spector concerns regarding the scope ~of'FMRs (Section 4) and-system knowledge of RP personnel (Section 3).
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Inspector co.ncerns regarding housekeeping and material conditions (Section 7).
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