IR 05000456/1997011
| ML20217A176 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 09/12/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Tulon T COMMONWEALTH EDISON CO. |
| References | |
| 50-456-97-11, 50-457-97-11, NUDOCS 9709190089 | |
| Download: ML20217A176 (2) | |
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September 12, 1997 Mr. T.' Tulon.
Site Vice President Braidwood Station
' Commonwealth Edison Company RR #1, Box 84 Braceville, IL 60407 SUBJECT:
NOTICE OF VIOLATlON (NRC INSPECTION REPORT 50-456/97011(DRS):
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50-457/97011(DRS))
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Dear Mr. Tulon:
This will acknowledge receipt of your letter dated August 22,1997, in response to
our letter dated July 24,1997, transmitting a Notice of Violation associated with the
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failure to adequately implement radiation protection procedures which determine the activity of radioactive waste at the Braldwood Generating Station, Units 1 and 2. In this letter, you committed to review and to revise the applicable procedure, as necessary.
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Specifically, you planned to provide additional review of the implementation of the procedure. We have reviewad your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
Sincerely, Original Signed by John A. Grobe John A. Grobe, Acting Director p
.)ivision of Reactor Safety f
Docket Nos. 50-456,50-457 l
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License Nos. NPF-72, NPF-77 Enclosure:
Ltr 08/22/97, H. G. Stanley, g
Comed to USNRC See Attached Distribution DOCUMENT NAME:G:\\DRS\\ BRA 09437.DRS To,eceive a copy of thle document. indicate in the box: "C* = Copy without attachment / enclosure
"E' = Copy with attachment / enclosure
'N' = No copy 0FFICE Rlli-4 RIII W
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NAME S0rth:jppo GShear &J RLanskbury h JGrbb6'%
DATE 09//o /97 09/to /97 09/ i /97 09//p/97 UFHCIAL RLCONU CUPY 9709190089 970912 girl ltillililll$1R15111Dlll lEIN PDR ADOCK 05000456
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. September 12, 1997 cc w/o encl: R. J. Manning, Executive Vice President, Generation M. Wallace, Senior Vice Fresident, Corporate Services H. G. Stanley, Vice President PWR Operations Liaison Officer, NOC-BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory Services Manager 1. Johnson, Licensing Operations Manager i
i cc w/ encl:
Document Control Dest: Licensing i
Braidwood Station Manager
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T. Simpkin, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Distribution:
Docket File w/enci SRIs, Braidwood w/ encl R. A. Capra NRR w/enct PUBLIC IE-01 w/enct TSS w/enci Rlli PRR w/enci OC/LFDCB w/enci LPM, NRR w/enci DOCDESK w/enci DRP w/ encl A. B. Beach, Rill w/enci CAA1 w/enci DRS w/ encl J. L'. Caldwell, Rill w/enct Rill Enf. Coordinator w/enci
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Tet N1545&2H01 August 22,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D C. 20555 Subject:
Reply to Notice of Violation NRC Inspection Repon 50-456(457)/97011 Braidwood Nuclear Power Station Units I and 2 NRC Docket Numlers 50-456 and 50-4ji7 Reference.
J. A. Grobe letter to H.G. Stanley dated July 24,1997, transmitting Notice of Violation from inspection Report 50-456(457)/97011 The inspection report specified in the Reference above includes results from an inspection of Braidwood's solid radioactive waste processing and shipp',ng program which ended on June 24,1997. A Notice of Violation was transmitted with the referenced report and included one Severity Level IV Violation associat(d with procedure adherence. The attachment to this letter contains Comed's response to this violation Station Management has continued to emphasize the importance of procedure adherence during Human Performance sessions Two Human Performance sessions were conducted in 1997 and two additional sessions are scheduled to take place later in the year. In addition, a trending program on procedure adherence events has been established with classification on type of adherence issue. A team has been established at Braidwood to review a selected number of administrative procedures to determine if the instructions need to be clarified or ifincreased training is needed. The goal of this team is to improve administrative procedure compliance by clarifying the requirements to plant personnel.
These actions are being taken to improve both the awareness of procedure adherence requirements and improve Station performance.
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The following commitment was made in the attached response:
l BwRP 5600-6," Scaling Factor Determination," is being reviewed and revisions will be
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made as necessary. In addition the Station plans to enhance the procedure by adding an additional signature block for a secondary reviewer.
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Document Control Desk. 8/22/97 Pagg_2 If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (315) 458-2801, extension 2980.
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/k ene tanley Site Vice President Braidwood Nuclear Generating Station H & dNhidos Attachment cc:
A.B. Beach, NRC Regional Administrator, Region !!!
G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident inspector F. Niziolek, Division of Engineering, Omce of Nuclear Safety, IDNS
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ATTACIDAENT I a
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REPLY TO NOTICE OF V10LATION VIOL ATION (Sn-456(457)/97011-01)
10 CFR 61.55(a)(8) requires, in part, that if the licensee determines the concentration of a radionuclide in wastes via indirect methods such as the use of scaling factors, the licensee provide reasonable assurance that the indirect method can be correlated with actual measurements.
Procedure BwRP 5600-6, " Scaling Factor Determination," revision 0, was prepared by the licensee to ensure that indirect methods, i.e. scaling factors, can be correlated with actual sample measurements.
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Step F.2 e of procedure BwRP 5600-6 required that if any of the radionuclide scaling factors calculated for an individual waste stream sample differed from the l
current scaling factor by a factor of 10 or more, an additional sample of the waste stream be sent to an off site laboratory for analysis.
Contrary to the above, the inspector identified that on August 12,1994, March 28, 1995, and June 5,1996, the licensee did not provide reasonable assurance that
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indirect methods could be correlated with action measurements. Specifically, the licensee did not re sample waste streams which differed from current scaling factors by a factor of ten or greater.
REASON FOR THE VIOLATION BwRP 5600-6," Scaling Factor Determination" Procedure, pertains to the analysi: of radiological waste streams at Braidwood Station and is performed on an annual basis. The procedure, classified as " Reference Use", is used to perform statistical analyses of waste stream samples. Sample results that fall outside of a predetermined range are considered
" outliers." Step F.2.c. I I in the procedure requires that these " outlier" samples be analyzed offsite.
During a recent inspection, no records could be found to show that the outlier samples had been sent otTsite for analysis as required in 1994,1995, and 1996. Personnel who performed BwRP 5600-6 during those years failed to complete the step in the procedure requiring this action. Although the individual responsible for performing the procedure in 1994 and 1995 is no longer a Comed employee, the individual was contacted to deterrnine why he did not satisfy the procedure requirement. As the original author of the procedure.
the individual assumed that he was aware of all of the procedure requirements. Therefore, when the outliers were discovered, he did follow up with the olTsite analysis vendor to discuss the results. The individual rationalized that the follow up actions taken were appropriate, however these actions did not satisfy the requirements stated in the procedure The individual responsible for performing the procedure in 1996 was also interviewed to determine why he did not adhere to the procedure. This individual I
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e ATTACHMENT I
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REPLY TO NOTICE OF VIOLATION V10L ATION (50-456(457)M7ni 1 n D communicated that he reviewed the entire procedure prior to executing the steps as required for procedures classified as" Reference Use" While performing the procedure, the individual was focused on complicated data analysis sections of the procedure, which
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were executed over a several day period, and through inattention to detail, he failed to satisfy the requirement to send additional camples offsite for analysis as required for outlier samples.
CORRECTIVE A.C.TIONS TAKEN AND RESULTS ACHIEVED The individual who performed the DwRP 5600-6 in 1996 was counseled on procedure adherence expectations The Station performed a technical evaluation of the procedure adherence deficiency.
Based on a review of the source document which was used as a reference when the procedure was initially written and a discussion with the author of the source document, the Station concluded that the circumstances would have had no impact on waste classifications.
ACTIONS TAKEN TO PREVENT RECURRENCE l
Braidwood Station has continued to reinforce expectations associated with procedure
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adherence during quarterly Human Performance sessions. These meetings have served to heighten awareness levels of Station personnel of their responsibilities when following procedures.
The requirement of performing additional analyses of outlier samples is being reviewed and revisions will be made as necessary. In addition to revising the outlier sampling requirement, the Station plans to enhance the procedure by adding an additional signature block for a secondary reviewer This change will provide additional assurance that the procedure was completed as required.
DATE WHEN FULL COMPLI ANCE WAS ACHIEVED Full compliance was achieved when the individual who failed to perform the procedure as required was counseled on procedure adherence expectations.
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