IR 05000456/1998006

Insp Repts 50-456/98-06 & 50-457/98-06 on 980331-0407. Violations Noted.Major Areas Inspected:Announced Review Protection Program.Insp Focused on Liquid & Gaseous Effluent Radiation Monitoring Programs

ML20217F545
Person / Time
Site:	Braidwood
Issue date:	04/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20217F526	List: IR 05000456/1998006 ML20217F521 ML20217F528
References
50-456-98-06, 50-456-98-6, 50-457-98-06, 50-457-98-6, NUDOCS 9804280190
Download: ML20217F545 (10)

Text

i U.S. NUCLEAR REGULATORY COMMISSION REGION lil

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Docket Nos: 50-456; 50-457 License Nos: NPF-72; NPF-77 l

Report Nos: 50-456/98006(DRS); 50-457/98006(DRS)

Licensee: Commonwealth Edison Company l

Facility: Brald= mod Generating Station, Units 1 and 2 l

Location: RR #1, Box 84

Braceville,IL 60407 q Inspection Dates

March 31-April 7,1998 Inspectors: D. Nissen, Radiation Specialist Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l

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a 9804280190 DR 980421 ADOCK 05000456 PDR

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EXECUTIVE SUMMARY

l Braidwood Generating Station, Units 1 & 2  ;

I NRC Inspection Reports 50-456/98006; 50-457/98006 This inspection included an announced review of the radiation protection program. Specifically, the inspection focused on the liquid and gaseous effluent and radiation monitoring program Plant Sucoort

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The effluent release program was well implemented. The total activity released and i associated doses were low and remained below regulatory limits. The inspector i identified a minor deficiency with the lack of quality verification in that station personnel did not verify that required changes to the software, which calculated dose from effluent releases, had been made. This was being addressed by the licensee. (Section R1.1)

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The gaseous and liquid radiation monitoring instrumentation was well maintained and setpoints were established and set in accordance with station procedures. The licensee was appropriately addressing recurrent problems with the Steam Jet Air Ejector radiation monitors and planned a modification to improve the detection of primary-to-secondary leakage. (Section R2.1)

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During several walkdowns of the auxiliary building, the inspector observed good housekeeping and use of appropriate radiological postings and boundaries. However, several examples where radiological postings and/or boundaries had fallen were noted, which had not been identified by the station radiation protection staff. (Section R2.2)

. The inspector observed that refresher training provided to instrument maintenance personnel regarding the calibration of plant radmonitors was comprehensive and effective. (Section R5.1)

. One procedural violation was identified concerning the failure to ensure that a workers electronic dosimetry was turned on prior to performing work on a steam generator platform during the Unit 2 outage. (Section R8.1)

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Report Details IV. Plant Sunnort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Liould and Gaseous Radioactive Effluents Insoection Scooe (84750)

The inspector reviewed the gaseous and liquid effluent release program, including the Off-site Dose Calculation Manual (ODCM), the Annual Radiological Effluent Release Report for 1996 and the data for the 1997 repor Observations and Findinas The total radiological effluent releases and associated doses for Braidwood station were low and below regulatory limits. There were no abnormal or unmonitored radiological effiuent releases for 1996 or 199 There were no significant changes in the liquid and gaseous effluent systems as described in the ODCM and the Final Safety Analysis Report. Quantification of gaseous and liquid discharges were completed in accordance with the appropriate procedures, and the inspector determined that offsite doses were calculated using ODCM methodolog The licensee used a computer program to calculate the off-site doses. This program was maintained by the corporate staff who were also responsible for changing the j program in accordance with station instructions. However, the inspector did not identify j a process where the station verified that computer software changes were appropriately made by the corporate group. Although the inspector found no problem with the computer program, this lack of quality verification was considered a weaknes Licensee management agreed with the inspector's conclusions and planned to perform these verifications in the futur Conclusions The radiological effluent release program was well implemented. The total activity released and associated doses were low and remained below regulatory limits. The lack of quality verification was identified in that station personnel did not verify that l required changes to the software, which calculated dose from effluent releases, had I been made. This was being addressed by the license !

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' R2 Status of RP&C Facilities and Equipment R Radiation Monitors Insoection Scone (84750)

The inspector reviewed the licensee's radiation monitor (radmonitor) program. This included a walkdown of the radmonitors, reviewing associated maintenance records and performance data with the system engineer, and reviewing setpoints and planned

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modification Observations and Findinas During the system walkdown, the inspector observed overall good material condition and few work request tags on the effluent monitors. The associated alarm setpoints were properly established, however, one problem was identified with non-conservative setpoints on a containment area radmonitor that is discussed in section R The licensee continued to have recurrent problems with the PRO 27J steam jet air ejector (SJAE) radmonitors. The varied nature of these problems (i.e. pump problems, problems with ammonia, etc.) did not suggest a common root cause. These monitors were planned to be replaced after the upcoming steam generator replacement outag In the interim, the chemistry group was performing the necessary compensatory sampling as required by an administrative action requiremen The licensee was also considering the use of nitrogen-16 (N-16) monitors on the main steam lines to improve detection of primary-to-secondary leakage. These monitors had a detection capability of less than or equal to 5 gallons per day (leakage) versus about 80 gallons per day from the existing SJAE monitors. The monitors were in place on the Unit 1 main steam lines and the licensee was still evaluating their effectiveness if successful, the N-16 monitors would supplement the existing SJAE monitors and provide earlier indication of steam generator leakag Conclusions Overall, the gaseous and liquid radiation monitoring instrumentation was well _ !

maintained. The licensee was appropriately addressing recurrent problems with the !

steam jet air ejector radmonitors and planned a modification to improve the detection of primary-to-secondary leakag R2.2 Postings in Auxiliary Building (83750)

l During several walkdowns of the auxiliary building, the inspector observed good j

. housekeeping and use of appropriate radiological postings and boundaries. However, I several examples where radiological postings and/or boundaries had fallen were noted, I which had not been identified by the station radiation protection (RP) staff. These !

examples did not significantly impact the overall control of the affected areas and I appeared to result from softening of the fastening adhesive due to high ambient !

temperature. The licensee agreed with this conclusion and with the observation that RP personnel were not aware of the issue. Station management discussed this issue with

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members of the RP staff who were developing corrective actions. The inspector planned to review these actions in future inspections ( inspection Follow-up Item (IFI)

Nos. 50-456/98006-01 and 50-457/98006-01)

R5 Staff Training and Qualifications in RP&C R5.1 Trainina of instrument Maintenance (IM) Personnel for Calibration of Rad!ation Monitors (847505 l The inspector observed that refresher training provided to IM personnel regarding the calibration of plant radmonitors was comprehensive and effective. Various mock-ups of area and effluent radiation monitors were maintained in the training area and IM personnel were required to demonstrate at least one full monitor calibration using current station procedures. Class size was kept small and the instructors were observed to effectively address student questions. This training was offered in response to a request by the IM workers and was planned to be repeated next yea R8 Miscellaneous RP&C lasues R (Closed) Unr.esolved item Nos. 50-456/97017-04 and 50-457/97017-04: On October 10, 1997, an individual identified to the RP staff that he had performed work on the Unit 2 A/D steam generator platform the previous day without the proper dosimetry. During a prior NRC review of this event, the licensee's investigation was still ongoing. This investigation was since completed and determined that the RP technicians at the steam generator control point as well as the worker himself had failed to properly activate the l worker's electronic dosimeter (ED) or ensure that the dosimetry was operable, as l required by station procedure l Subsequently, the RP staff suspended the RP technician and supervisors access, !

conducted a stand-down with all contract RP technicians, and conducted training with !

contract RP technicians and supervisors. In addition, the RP supervisor was released from the station and the event was incorporated into station steam generator technician lesson plans. An effectiveness review was also scheduled to be performed by September 1,199 Technical Specification (TS) 6,11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. BwRP 6210-2 (rev 3), " Radiological Controls for Steam Generator Work,"

requires that a check be performed to ensure that dosimetry is present and correctly wom. Failure to follow the procedure is a violation (VIO) of TS 6.11 (VIO 50-456/98006-02 and 50-457/98006-02).

R8.2 (Closed) Licensee Event Reoort (LER) No. 96-003: The report documented a personnel contamination from a hot particle. This LER was discussed in NRC inspection Report Nos. 50-456/96008 and 50-457/96008. One Non-Cited Violation was issued for this event for exceeding the 50-rem limit of 10 CFR 20.1201; however, the exposure was equivalent to 18.2 microcurie-hours, below the 75 microcurie-hour threshold in the NRC Enforcement Policy and consequently reducing the significance of the problem. This I item is close ,

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R8.3 (Closed) VIO No. 50-457/97016-06: The inspector reviewed the effectiveness of the licensee's corrective actions for a violation conceming the failure to post a radiation area. Corrective actions included performing radiological surveys, verifying that the area was appropriately posted, and updating survey maps to include this area in the routine RP surveillance program. A ' tailgate' session was also held with the RP technicians to raise their awareness of the area. These actions were considered effective as no subsequent, similar violations had occurred. This item is close R8.4 (Ocen)VIO Nos. 50-456/97008-02 and 50-457/97008-02: An NRC inspector identified that vacuum cleaners stored in radiologically posted areas were not maintained in accordance with procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Controlled Areas," revision 2. The licensee performed an effectiveness review of this program area in December of 1997. The review found that the corrective actions were not sufficient to prevent reoccurrence. Three problem identification forms were issued which identified vacuum cleaners with the hoses uncovered, during the last quarter of 1997. Corrective actions included revising BwRP 6210-17 to include three levels of vacuum cleaners, "Non-contaminated", " Contaminated", and " Highly Contaminated". Additionally, the requirement to cover the ends of the hoses will be removed and replaced with instructions to prevent the spread of contamination. Another eifectiveness review was scheduled to be completed by December 4,1998 after the next outage, therefore, this violation will remain open pending the results of the licensee's effectiveness revie R8.5 (Closed) Insoection Follow-uo Item Nos. 50-456/97003-05 and 50-457/97003-05: The inspector reviewed the licensees progress with the planned revision of the process and area radiation monitor alarm setpoint justification document. The inspector observed improvement in the content and condition of the document The responsible health physicist had completed the revision and it had been approved. This item is close R8.6 (Closed) LER 97-003: On October 17,1997 the licensee identified that the alert and alarm setpoints for the 2AR012J containment area radmonitor were incorrect and non-conservative. The discrepancy and the subsequent licensee investigation were documented in the above LE The root cause of the discrepancy was identified as poor procedural adherence and quality. Specifically, during reactor disassembly / reassembly and fuel movement activities from October 3-16,1997, the alert and high alarm setpoints for these monitors were changed several times in accordance with station procedures. These changes were to be communicated to the responsible System Engineer who was responsible for updating the appropriate controlling data base and documentation. However, during this period, the System Engineer was unavailable, and station procedures did not contain a contingency. As a result, data base and documentation changes were not completed as require As a further complication, on October 14,1997, monitor no. 2AR012J was declared inoperable for planned maintenance. In accordance with the maintenance procedure, the monitor was to be retumed to the "as found" setpoints (8 millirem per hour (mR/hr)

alert; 13 mR/hr alarm) after the work was completed. However, the normal practice was to return the setpoints to the values in the controlled data base (52 mR/hr alert; 65 mR/hr alarm), which as stated earlier had not been corrected by the System Enginee l

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This normai practice had existed for some time and the appropriate procedure had not been change As a result of the appropriate changes not being made to the database and of the normal practice of using the database rather than the "as found" value (as required by procedure) for the monitor alarm setpoints, the 2AR012J monitor was returned to service (i.e., declared operable) having incorrect, non-conservative alarm setpoint This discrepancy was identified on October 17,1997, after two containment releases had already occurred with a third in progres The containment release was secured immediately upon detection of the discrepancy in the setpoints. Subsequently, the affected procedures were revised and the workers were counseled on the even The other containment area radmonitor (2AR011J) had the correct alarm and alert setpoints and was operational during the containment releases. The containment effluent purge monitor, the auxiliary building vent stack effluent monitor, and the wide range gas monitor were also operational during the releases. Each monitor would have alarmed in the event of an abnormal release. However, technical specifications 3.3. requires that if both the 2AR011J and 2AR012J are not operable the containment purge valves are maintained closed. This non-repetitive, 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 No. 50-457/98006-03).

R8.7 (Closed) LER 97-004: On October 14,1997 a nuclear station operator changed the alarm setpoints for the containment area radiation monitors (2AR011J and 2AR012J)in preparation for the core reload into Unit 2. When the operator input the setpoints for the 2AR011J to the computer he entered 1.30E-1 mR/hr instead of 1.30E+1 mR/hr, this resulted in a more conservative setpoint and an alarm on the monitor. The containment vent isolation valves closed and the containment release in progress was secured. The operator recognized his error and the correct setpoints were immediately entered. The setpoint for this monitor was set more conservatively so the release was isolated and no additional radioactive material released to the atmosphere. This item is close V. Management Meetings X1 Exit Meetina Summarv The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on April 7,1998. The licensee acknowledged the findings presented. No proprietary information was identifie I i l

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d PARTIAL LIST OF PERSONS CONTACTED S. Erant, Chemist M. Cassidy, Regulatory Assurance -

M. Finney, Lead Health Physicist T. Meents, Radwaste Supervisor T. O'Brien, System Engineer G. Schwartz, Plant Manager R. Thacker, Lead Health Physicist T. Tulon, Site Vice President INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904 Followup - Plant Support ITEMS OPEN, CLOSED, AND DISCUSSED Ooened I

50-456/457-98006-01 IFl Licensee to review several problems with postings falling dow /457-98006-02 VIO Failure to ensure electronic dosimetry was tumed o Closed 50-456/457-97017-04 URI RP technicians failed to ensure that worker's dosimetry was activate /96003 LER Hot particle contaminatio /97016-06 VIO Failure to properly post a radiation are /457-97003-05 IFl Licensee progress in establishing a basis document for process and area radiation monitor alarms setpoint /98006-03 NCV Failure to follow Technical Specifications for radiation monitor setpoint /97004 LER Radiation monitor setpoints set conservatively incorrec Discussed 50-456/457-97008-02 VIO Failure to properly control radioactively contaminated vacuum cleaner l

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LIST OF ACRONYMS USED ED Electronic Dosimetry -

! IFl inspection Follow-up Item IM Instrument Maintenance IP Inspection Procedure LER Licensee Event Report mR/hr millirem per hour N-16 Nitrogen -16 NCV Non-cited Violation ODCM Offsite Dose Calculation Manual RP Radiation Protection RPT Radiation Protection Technician SJAE Steam Jet Air Ejector TS Technical Specifications URI Unresolved item VIO Violation

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PARTIAL LIST OF DOCUMENTS REVIEWED PIF A1997-03994

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PIF A1997-04317 PlF A1997-04668 PlF A1997-05327 LER 96-003 LER 97-003

LER 97-004 RWP 976214 Annual Effluent Report 1996 Annual Effluent Report Data 1997 i Setpoint Justification Document j BwRP 5820-5 (rev 5), "AR/PR Setpoint Changes" i

BwlS RETS 2.1 B-201 (rev 1), " Surveillance Calibration of GA Liquid Effluent Radiation J Monitors" Offsite Dose Calculation Manual Technical Specifications NRC Inspection Report Nos. 50-456/96008 and 50-457/96008 NRC Inspection Report Nos. 50-456/97017 and 50-457/97017 l

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