IR 05000456/1997008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/97-08 & 50-457/97-08 on 970519

ML20149E601
Person / Time
Site:	Braidwood
Issue date:	07/11/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Stanley H COMMONWEALTH EDISON CO.
References
50-456-97-08, 50-456-97-8, 50-457-97-08, 50-457-97-8, NUDOCS 9707180241
Download: ML20149E601 (2)

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l July 11, 1997 Mr. H. Site Vice President Braidwood Nuclear Power Station l. Commonwealth Edison Company

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R.R. #1, Box 84 Braceville, IL 60407 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-456/97008(DRS); 50-457/97008(DRS))

Dear Mr. Stanley:

1 This will' acknowledge receipt of your letter dated June 16,1997, in response to our letter dated May 19,1997, transmitting a Notice of Violation associated with the inadequate control of vacuum cleaners within radiologically posted areas at the Braidwood Generating Station, Units 1 and 2. In your letter, you indicated that you planned to revise the applicable procedure and to provide additional training to site personnel concerning the required controls.

We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

/s/ J. M. Jacobson (for)

I John A. Grobe, Acting Director Division of Reactor Safety dh-'

C Docket Nos. 50-456;50-457 Licenses No. NPF-72; NPF-77 Enclosure: Ltr 06/16/97, H. G. Stanley, lllllllllllllfllllll[jjlflllj Comed, to US NRC < ..

DOCUMENT NAME:G:DRS\ BRA 07_7.DRS To receive a copy of thle document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure

"N* = No copy

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OFFICE Rill e RIII C RIII ,A) RIII A,k l NAME S0rth:jpsW GShear 4 3 RLanskburfPJW JGrob( W W

! DATE 07/ 9 /97 07/ 9 /97 07/ll /97 07/l1 W 7 T; UH-lCIAL RLCORU COPY 970718G41 970711 PDR Al".?5 05000456 G PDR

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cc w/o encl: T. J. Maiman, Senior Vice President,

. Nuclear Operations Division

! D. A. Sager, Vice President, ( Generation Support H. W. Keiser, Chief Nuclear

! Operating Officer

! i T. Tulon, Station Manager l -T. Simpken, Regulatory Assurance

! Supervisor 1. Johnson, Acting Nuclear l Regulatory Services Manager cc w/ encl: Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State liaison Officer Chairrnan, Illinois Commerce Commission Distribution:

Docket Fde- Rlli PRR w/ encl J. L. Caldwell, Rlll w/enci-TN ~ /encim/

' / enc'l SRis, Braidwood, Byron, Rlli Enf. Coordinator w/enci

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OC/LFDCB w/enci Zion w/ encl R. A. Capra, NRR w/enci DRP w/enci LPM, NRR w/enci TSS.w/ enc! i DRS w/enci A. B. Beach, Rill w/enci CAA1 w/enci i DOCDESK w/enci i

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• Commonwcahh Edison Company

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Braidwood Generatmg Station

,, Route el, Box 84 Braceville. IL 60407%19 Tel 814-15R2801 June 16,1997 l

Document Control Desk )

i U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Subject: Reply to Notice of Violation NRC Inspection Report 50-456(457)/97008 l

Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457 Reference: C.D. Pederson letter to dated May 19,1997, transmitting Notice of Violation from Inspection Report 50-456(457)/97008 l

The Reference letter contains a Notice of Violatica (NOV) resulting from an

.spection of our Radiation Protection Program whi ch ended on April 30,1997.

During the inspection period, two violations were identified; however a response was required for only one of the issued violations. The attachment to this letter contains Comed's response to this violation.

Braidwood Station has worked hard to effectively plan radiological work.and ensure good radiation worker practices. These efforts resulted in the Station achieving a record low accumulated dose incurred during a Unit One refueling outage. We are enccuraged by these results and will continue to iook for ways to improve.

The following commitments were made in the attached response:

. BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas," will be revised.

. Tailgates will be conducted with work groups who use vacuum cleaners in the Auxiliary Building to communicate the requirements of BwRP 6210-17.

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Document Control Desk. 6/16/97 ' Page 2

If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.

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H. ene Stanley Site Vice President Braidwood Nuclear Generating Station Attachment cc: A.B. Beach, NRC Regional A6ninistrator, Regim III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS o.bnfidadmasst'S7108ntdoc

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ATTACHMENT 1

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l REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(4571/97008-02)

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l Technical Specification 6.8.1.a requires that procedures be implemented for l activities covered in Appendix A of Regulatory Guide 1.33.

l Appendix A of Regulatory Guide 1.33 recommends that radiation protection procedures be implemented for contamination control.

Procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Controlled Areas", Revision 2, requires, in part, that vacuums '

used in radiologically posted areas shall be controlled (i.e. locked) when l needed beyond the end of the work shiR and that openings on the suction line and hose ends be covered aRer each use to prevent the spread of contamination.

Contrary to the above, an inspector identified that: )

a. On April 23 - 29,1997, vacuum cleaners used in radiologically posted areas on the 364' and 401' elevations of the Auxiliary Building and needed beyond the end of the work shiR were not locked.

b. On April 23 - 29,1997, vacuum cleaners located on the 401' elevation of the Auxiliary Building did not have the suction line and hose ends covered aner each use.

REASON FOR THE VIOLATION l BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"

requires vacuums to be controlled by keeping them locked and also requires the openings on the suction line and hose ends to be covered to prevent the spread of contamination. Vacuum cleaners in the Auxiliary Building were not stored in accordance with these procedure requirements. Once this concern was identified, an investigation was conducted to evaluate the potential causes.

In one case, a vacuum cleaner was found unlocked at the boric acid mixing area on the 401' elevation. This vacuum was permanently issued to Operating for non-contaminated boric acid cleanup. Individuals who used this vacuum were unaware of

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the requirement to lock vacuums or keep them in a locked area in the radiologically l posted area (RPA).

Another vacuum cleaner was found unlocked in the Unit One 364' steam generator blowdown condenser room. This was an extra vacuum cleaner obtained from a 346'

storage cage. Since this vacuum was not issued from the 364' radiation protection l

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l, A'ITACHMEfff I i i

! REPLY TO NOTICE OF VIOLATION l l. VIOLATION (50-456(457)/97008-02) l

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zone, it is not known who used the vacuum and failed to follow the established storage requirements.

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'Similarly, for the case where a vacuum cleaner located on the 401' elevation of the l Auxiliary Building did not have the ends covered, it is unclear what the hose had been i. used for and why the ends were left uncovered. Vacuum cleaners issued by Radiation Protection (RP) Technicians at that elevation are primarily used .for vacuuming the ,

IPM-8. monitors and general work. )

l Common causes for the above instances were determined to be the following:

1. An excessive number of vacuum cleaners are in the RPA making control more difficult.

2. The procedure was overly restrictive. The requirement to lock vacuum cleaners originated when Station Laborers controlled the vacuum program.

Once the program was transferred to Radiation Protection, the need to control the vacuum cleaners by locking them was no longer necessary; however the procedure requirement was not updated to reflect this.

3. Not all station work groups who use the vacuum cleaners were aware of the

! storage requirements.

CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED After this problem was identified, the Station had verified that all vacuums in the Auxiliary Building were properly stored. In addition, excess vacuum cleaners have been removed from the general RPA.

ACTIONS TO BE TAKEN TO PREVENT RECURRENCE ,

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Radiation Protection will maintain direct control over the vacuum cleaners stored in the Auxiliary Building. l l

BwRP 621017, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"

will be revised. The procedure revision will provide guidance on new storage l

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. requirements._ Vacuums will be separated into two categories: clean (non-contaminated) RPA use or contaminated RPA use. Since the vacuum cleaners  !

L designated for clean arnas will not be used in contaminated areas, the requirement to i cover the hose ends and suction line openings will no longer be necessary. This l storage requirement will remain for the vacuums designated for use in contaminated j I

areas, however. In addition, the requirement to lock the vacuums or keep them in a (

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locked area in the RPA will be removed.

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ATTACHMENT 1 1 i

l REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97008-02)

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Tailgates will be conducted with work groups who use vacuum cleaners in the Auxiliary Building to communicate the requirements of BwRP 6210-17. I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l i

The procedure revisions and tailgates will be completed by July 15,1997,

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