IR 05000456/1996015

Insp Repts 50-456/96-15 & 50-457/96-15 on 960916-1018.No Violations Noted.Major Areas inspected:mid-cycle Outage Activities Including SG Work,Pressurizer Manway Cover/Diaphragm Removal & Review of Work Control Process

ML20134M248
Person / Time
Site:	Braidwood
Issue date:	11/15/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134M240	List: IR 05000456/1996015 ML20134M237
References
50-456-96-15, 50-457-96-15, NUDOCS 9611220287
Download: ML20134M248 (7)

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, U. S. NUCLEAR REGULATORY COMMISSION

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I Docket Nos: 50-456, 50-457 Licenses No: NPF-72, NPF-77 Reports No: 50-456/96015(DRS); 50-457/96015(DRS)

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l Licensee: Commonwealth Edison Facility: Braidwood Nuclear Piant, Units 1 and 2

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l Location: RR #1, Box 79 Braceville,IL 60407 i

Dates: September 16 through October 18,1996 i

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l Inspectors: Patrick Louden, Senior Radiation Specialist Diana B. Hart, Radiation Specialist

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Approved by: Thomas Kozak, Chief, Plant Support Branch 2 Division of Reactor Safety l

I 9611220287 961115 PDR ADOCK 05000456 G pm

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Reoort Details R1 Radiological Protection and Chemistry (RP&C) Controls R 1.1 Unit 1 Mid-Cvcle Outaae Work and ALARA Imolementation Insoection Scoce(83750)

The inspectors conducted a routine review of the Unit 1 mid-cycle outage activit:es including steam generator work, pressurizer manway cover / diaphragm removal, and a review of the work control proces Observations and Findinas The inspectors attended a pre-job briefing for the removal of the Unit 1 pressurizer manway cover and diaphragm. All personnelinvolved with the evolution from various organizations were in attendance at the meeting. The inspectors noted that the nature of the questions raised during the meeting was appropriate; however, I some of the items discussed were presented and evaluated late in the work control process. Examples of such items included the specific amount of grinding activities to be undertaken, foreign material exclusion controls, and fire protection considerations. Based on the inspectors observations, it was clear that such items should have been identified and addressed earlier in the planning process. For example, the discussion of more extensive grinding activities than anticipated prompted the ALARA staff to revisit the appropriateness of the originally developed engineering controls and respiratory protection requirements for the jo A followup review of the wo;k control process performed by the inspectors noted that although interaction between maintenance and RP may occur at any time throughout the work planning process, formalinteraction is not required until the pre-job meeting just prior to the initiation of work. For short lead time jobs, this l lack of formalinteraction prior to the ALARA pre-job meeting leads to specifics of certain issues not being evaluated or discussed until the final stages of the planning !

process. The inspectors discussed this vulnerability in the current work control process with station management at the Exit Meeting (Sec. X1).

The inspectors observed work in the RPA and Unit 1 containment and noted l

appropriate radiation worker practices. Controls for containment access and high radiation areas were observed to be effectively implemented. During interviews, the containment coordinators conveyed a good understanding of ongoing work activities within containment. Likewise, inspector observed briefings conducted by RFTs at the Radiation Protection Office were thorough and provided current radiological conditions and precautions for areas within the RPA and containmen .

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A vulnerability noted by the inspectors in the work control process contributes to l issues not being evaluated or discussed until the final stages of the planning process, especially for short lef J time activities such as the pressurizer manway r

cover removal job during the mid-cycle outage. Appropriate radiological work practices were observed during inspector observations of work activities in the RPA l and containmen !

l R2 Status of the RP&C Facilities and Equipment I l

R 2.1 Radiation Monitorina System  ! insoection Scooe (84750)

l The inspectors conducted a review of the station's radiation monitoring syste '

The focus was on operability and reliability of liquid and gaseous effluent monitor Alarm set-point calculations and basis methodologies were also reviewed during the inspectio Observations and Findinas l The inspectors reviewed the basis document referenced for the calculation of alarm set-points for effluent radiation monitors. No technical problems were identified regarding the methodology used to calculate the set-points. However, the !

inspectors noted that the basis document for the calculations was informally controlled. This lack of formal control has led to the document containing several handwritten changes which could only be followed and understood by the cognizant health physicist who performs the alarm set-point calculations. Even though the basis document is not required to be controlled, the inspectors discussed this observation at the Exit Meeting (Sec. X1) with station managemen Station management acknowledged that a more formal method of controlling the document would be devise A review of radiation monitor operability indicated that recurring problems occurred with the Unit 1 Steam Jet Air Ejector (SJAE) monitor (1PR27J), the waste gas monitor (OPR02J), and the liquid radioactive waste effluent monitors (0PR01J &

OPR10J). Of the four, only the SJAE monitor had continued to be frequently out-of-service. The responsible system engineer has attempted to address the recurring spiking noted from this monitor; however, effective corrective actions to address the problem had not been developed. Compensatory actions required when monitors were out-of-service (grab samples) were appropriately collected during times when the monitors were inoperabl The liquid radioactive waste effluent monitor required periodic decontaminating of the sample volume chamber. This was due to the frequency and activity levels of the water discharged through the monitor rather than the performance of the equipment. The system engineer and the cognizant health physicist for the system

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had ii .plemented a corrective action which involved the replacement of the sample

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volume chambeis with a tefton coated chamber. The effectiveness of this

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One effective ongoing programmatic improvement for the system has been the replacing of sample skid pumps for many of the radiation monitors from positive

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displacement pumps to centrifugal force pumps. This replacement has increased

} reliability for the effected monitors. No pump failures have occurred for those monitors which have received the replacements. Previously, the positive displacement pumps required replacing every six to nine month Conclusions The basis document for radiation monitor alarm set-points lacked formal control which has led to the document containing several handwritten changes which could only be followed and understood by the cognizant health physicist. Overall, the radiation monitoring system was found to provide appropriate operability and reasonable reliabilit R 2.2 Insoection of Radioactive Waste Tanks Rooms The inspectors performed a material condition inspection of the equipment in several radioactive waste system rooms. Other than minor housekeeping items, the inspectors found the rooms and equipment to be in good condition. Adequate lighting was noted in the rooms and few action request items were pending for the equipment inspected. Overall, the inspectors determined that the material condition of the radioactive waste system equipment and rooms was goo R 2.3 Control Room and Auxiliary Buildino Filtered Heatino, Ventilation, and Air-Conditionino Systems The inspectors conducted inspections'of the control room and auxiliary building filtered HVAC systems and reviewed recent in-place filter testing results for the control room HVAC system. No problems were noted during the walkdowns and the systems were found to'be in good condition, A review of recent in-place filter testing results for the control room HVAC indicated that the testing was appropriately conducted and that the system was meeting applicable performance requirement R8 Miscellaneous RP&C lssues (84750)

R8.1 (Closed) LER 50-457/96-008: Technical Specifications 3.3.1 1 A and 4.6.1 1 A Violation due to an inoperable Containment Atmospheric Radiation Monitor resulting from an equipment failure. On July 5,1996, after maintenance and surveillance testing the Containment Atmospheric Radiation monitor was returned to servic Operability was not adequately verified and on July 15,1996, a Radiation Protection individual noted that the noble gas and lower explosive limit readings obtained from the Unit 2 Containment Atmospheric Radiation Monitor were

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unexpectedly low. Troubleshooting on July 17,1996 identified that a leaking air dryer was the cause for the low readings. The licensee subsequently determined that the monitor was inoperable for eleven days prior to the troubleshootin Technical specifications require that the radiation monitor to be operable having alarm set-points within specified limits. If the monitor becomes inoperable, compensatory action-s are to be taken via the collection of grab samples every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These samples were not collected during the time period the monitor was determined to be inoperable. Corrective actions included correcting the containment release documentation to reflect the actual activity released for July 5,1996 through July 17,1996 and revising the criteria for returning the air monitoring skid to service following maintenance and surveillance to assure operability. A review was also planned for the evaluation of other air monitoring skids maintenance and surveillance procedures to identify similar procedural weaknesses. This review was scheduled to be completed by December 31,1996. The inspectors determined that the corrective actions taken by the licensee were appropriate. This licensee-identified and corrected violation is being treated as a Non-Cited Violation, consistent with section Vll.B.1 of the NRC Enforcement Policy. (NCV 50-457/96015-01)

R8.2 Review of Updated Final Safety Analysis Report (UFSAR) Commitments A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR descriptions. While performing the inspection the inspectors reviewed the applicable sections of the UFSAR that related to the inspection areas discussed in this report. The following inconsistency was noted between the wording of the UFSAR and the plant  ;

practices, procedures, and/or parameters observed by the inspector l UFSAR section 11.2 discusses the radioactive waste system. There were several l discrepancies identified throughout this section. The licensee is in the process of updating this and several other sections of the UFSAR to reflect current plant configurations. The inspectors verified that the updates are in place and are due to be submitted by December 16,1996. The updating process of items for section 11.2 will be tracked via an inspection followup item (IFI). (IFl 50-456/96015-02; 50-457/96015-02)

X1 Exit Meeting Summary The inspectors presented the inspection results on October 18,1996, to inembers of licensee managernent after the conclusion of the inspection. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie .- . ._ - - -_ - . - . .. . . _ _ . . - - - . . .. - - - .

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, PARTIAL LIST OF PERSONS CONTACTED

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j Commonwealth Edison H. Stanley, Site Vice President T. Tulon, Station Manager i A. Haeger, Health Physics and Chemistry Supervisor H. Cybul, System Engineering Supervisor T. O'Brien, System Engineer R. Thacker, Radiation Protection Manager, Lead Technical HP ,

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M. Finney, Lead Operational HP l T. Meents, Radioactive Waste Coordinator l

M. Cassidy, NRC Coordinator 1

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~ l C. Phillips, Senior Resident inspector  !

J. Adams, Resident Inspector

D. Rich, Resident inspector )

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INSPECTION PROCEDURES USED

IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment, and Effluent and Environmental Monitoring

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LIST OF ITEMS OPENED AND CLOSED

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50-456/96015-02 IFl Followup Review of Correction Made to

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50-457/96015-02 Section 11 of the UFSAR.

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50-457/96015 LER Technical Specification 3.3.1-1 A and 4.6.1-1 A l Violation due to an Inoperable Containment l

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Atmospheric Radiation Monitor Resulting from j an Equipment Failur I 50-456/96015-01 NCV Technical Specification 3.3.1-1 A and 4.6.1-1 A

. 50-457/96015-01 Violation due to an inoperable Containment

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Atmospheric Radiation Monitor Resulting from

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DOCUMENTS REVIEWED Radiation Protection Calculation Document " Set point Justification For Revised 10 CFR 20"(1994)

LER 50-457\96-008 " Technical Specification 3.3.1-1 A and 4.6.1-1 A Violation due to an Inoperable Containment Atmospheric Radiation Monitor resulting from an equipment f ailure".

Braidwood Radiation Protection Procedure 6200-5 Rev. 3 " Writing Radiation Work Permits", dated July 199 RWP 964532, " Remove / Replace Pressurizer Manway Cover" Revisions 0,1,2, and 3 RWP 964529, " Insert / Remove Nozzle Dam Covers" Work Request Task 950060248, " Control Room Recirc Charcoal Adsorber Bank Operability Train B".

Work Request Task 950060247, " Control Room Makeup System Operability Train B".

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