IR 05000456/1998015

Insp Repts 50-456/98-15 & 50-457/98-15 on 980915-1022. Violations Noted.Major Areas Inspected:Review of Radiation Protection Program Focusing on Radiological Controls for Unit 1 Outage Activities & SG Replacement Project

ML20195G320
Person / Time
Site:	Braidwood
Issue date:	11/13/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195G286	List: IR 05000456/1998015 ML20195G281 ML20195G303
References
50-456-98-15, 50-457-98-15, NUDOCS 9811200256
Download: ML20195G320 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

- REGION lli Docket Nos: 50-456;50-457 License Nos: NPF-72; NPF-77 Report Nos: 50-456/98015(DRS); 50-457/98015(DRS)

l Licensee: Commonwealth Edison Company Facility: Braidwood Generating Station, Units 1 and 2 Location: RR #1, Box 84 Braceville,IL 60407 Inspection Dates: September 15 -October 22,1998 i

inspectors: D. Nissen, Radiation Specialist

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Approved by: G. Shear, Chief, Plant Support Branch 2

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Division of Reactor Safety i

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. EXECUTIVE SUMMARY Braidwood Generating Station, Units 1 & 2 NRC Inspection Reports 50-456/98015; 50-457/98015 This announced inspection included a review of the radiation protection program focusing on the radiological controls for Unit 1 outage activities and the steam generator replacement projec Additionally, the radiological environmental monitoring program was reviewe Plant Succort e During the Unit 1 steam generator replacement project, work planning, radiological I controls and good ALARA practices were effectively implemented. The lower than I expected steam generator replacement project and outage dose was due in part to reduced dose rates in containment, attributable to successful source term reduction efforts. The projected outage dose goal of 270 person-rem was reasonable based on the scope of work activities, and was expected to be achieved (Section R1,1),

e A lack of recognition for different evolutions and poor work group communications were common factors which led to multiple contaminations of the fuel handling building cross town area. As a result,23 low level personnel contamination events occurred which accounted for 19% of the total number of personnel contamination events for the outage as of the end of the inspection (Section R1.2).

e There was no discernable impact on the environment from plant operations. Specific l

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aspects of the radiological environmental monitoring program, including material condition of air sampling equipment, sample collection and contractor oversight were appropriately implemented (Section R1.3).

e Two examples were identified when workers failed to follow the dress requirements of their radiation work permit, in violation of station procedures. In both examples radiation protection personnel had made allowances to reduce dress requirements for the type of '

work being performed, however, the workers neglected to take advantage of the options available (Section R4.1).

• A violation of station procedures was identified for failure to ensure that all unauthorized workers were cleared from an area prior to beginning radiography. Radiography pre-job brir 9ngs conducted subsequent to the violation were clear and comprehensive, and l incLJed effective actions to prevent recurrence (Section R4.2).

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e Containment workers failed to react and radiation protection technicians failed to properly respond to a containment area radiation monitor alarm (Section R4.3).

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. l Report Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls l

R1.1 Unit 1 Steam Generator Replacement Project (SGRP) and As-Low-As-Is-Reasonablv-Achievable (ALARA) Implementation l

I inspection Scope (IP 83729)

The inspector reviewed the radiological controls implemented and the ALARA goals for the SGRP. The inspector also performed numerous walkdowns in containment as well as the auxiliary building, observed work evolutions, worker practices, and questioned workers concerning their responsibility to implement good work practices and their understanding of radiological controls and condition I

' Observations and Findinas Overall housekeeping in containment and the auxiliary building was good. Workers were aware of their dose rates and electronic dosimeter settings, and loitering was not observed. The inspector noted that radiation protection technicians (RPTs) routinely questioned workers concerning their knowledge of work area dose rates and radiation work permits and directed workers to low dose waiting areas outside the missile barrier ;

when needed. Radiation workers (radworkers) exhibited generally good work practice Work packages utilized industry lessons learned and contained good ALARA controls to minimize exposure. The resources identified in the ALARA plans (specialized radiation detection equipment, ventilation units, shielding, etc.) were utilized. The inspector noted that the ALARA controls, including radiological hold points, were discussed at pre-job briefing The inspector attended several pre-job briefings for both the SGRP and the balance of plant (BOP) operations. Sufficient information was provided to the workers at the briefings and a questior'ng attitude by the workers was prevalent. Radiation protection (RP) staff clearly communicated RWP requirements and questioned whether the workers had the proper tools and equipment available. The briefings typically included discussions by the job foreman on the work to be performed. However, the inspector attended the pre-job briefing for the final flush and rinse of the "B" steam generator and noted that the foreman assigned to the job was unaware of the job evolution. After the briefing was concluded, the inspector learned that the individual was an acting foreman, who had not reviewed the work plan for the job. RP personnelinstructed the foreman to read the plan so that he could be aware of the job evolution. In addition, the SGRP RP supervisor contacted a different foreman who had oversight on two previous steam generator flushes, and both job foremen provided oversight of the flush activitie The RP 's,servisor indicated to the inspector that station management expected that the job fowman be aware of the work scope and evolutio The inspector also attended a mockup for the pipe-end decontamination evolution. This mockup included a pre-job briefing, and a dry run through of the evolution using respiratory protection equipment. The mock-up was successful in identifying several areas for improvement, as well as identifying that a couple of the workers were not fit tested for respirator use.

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The inspector reviewed the station dose and ALARA goals for the outage. The projected doses for the SGRP and the outage were about 179 person-rem and 270 person-rem, respectively. At the end of the inspection period, the total dose accrued for the outage was 186.5 person-rem, about 30 person-rem below the projected estimate. The

inspector found that the radiation protection personnel's protocol for projecting dose was sound and that the lower than expected dose was due in part to lower dose rates in containment than had been initially projected. The lower dose rates were attributed to source term reduction efforts which included extending the cleanup of the reactor coolant system (RCS) by 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The RCS crossover piping was refilled on all four loops which provided additional shielding benefits. Also, system flushes were conducted for the RCS loop bypass lines, steam generator bowl drain lines, and RCS loop fill and drain lines. The licensee anticipated that the overall projected dose goal of 270 person-rem for the outage should be me Conclusions During the Unit 1 SGRP, work planning, radiological controls and good ALARA practices were effectively implemented. The lower than expected SGRP and outage dose was due in part to reduced dose rates in containment, attributable to successful source term reduction efforts. The overall projected dose goal of 270 person-rem for the outage was reasonably established based on the work scope and was expected to be achieve R1.2 Fuel Handiino Buildino Contamination Insoection Scope (IP 83729)

The inspector reviewed the personnel contamination events (PCEs) that occurred during the outage focusing on those resulting from the contamination of the fuel handling building (FHB) 426 foot elevation cross town are Observations and Findinas During the outage, the cross town area had become contaminated on four occasion As a result,23 low level PCEs occurred. As of the end of the inspection period, about 19% of all PCEs were caused by the contamination of the cross town area. After the initial contamination problem at the beginning of the outage, the licensee put in place a plan to replace the interlocks on the emergency hatch prior to reactor cavity drain down to better control air flow, and implemented other controls including ventilation

considerations, control of the access way to the FHB, and placement of a tarp over the equipment hatch opening. However, on October 20,1998, the cross town area was recontaminated because the licensee failed to recognize that uncovering the sandboxes in the cavity could produce an additional source of contamination. The area remained contaminated for an extended period because the emergency hatch interlocks were not established in a timely manner. Airflow from containment was not halted until three and a half hours after RP initially notified the containment coordinator of the contaminatio On October 21,1998, the cross town area was contaminated again. During the reactor head move, the FHB roll-up doors were opened and containment mini-purge was shut down without consideration of its impact on the ventilation pathwa The inspection disclased many contributing factors to these events including a lack of recognition for different evolutions and poor communications between work group While the magnitude of the area contamination and PCEs were low, over half of the outage goal for PCEs was caused by the cross town contamination proble Conclusions A lack of recognition for different evolutions and poor communications were common factors which lead to the contamination of the FHB cross town area. As a result of these contaminations,23 low level PCEs occurred and accounted for 19% of the total number of PCEs for the outage as of the end of the inspectio R1.3 Radiolooical Environmental Monitorina Proaram (IP 84750)

The implementation of the Radiological Environmental Monitoring Program (REMP)

based on requirements of the Off-site Dose Calculation Manual was reviewed. The inspector observed air and water sample collection and examined air sampling equipment. The 1997 Annual Radiological Environmental Operating Report (AOR) was reviewed to ensure that the report was submitted as required, and to evaluate the effect of plant operations on the environmen The material condition of the air sampling equipment was very good, and sampling was performed in accordance with procedures. The licensee used a contractor to collect and analyze samples as well as calibrate the air samplers and perform routine maintenanc The inspector discussed the contractors responsibilities with the individual assigned, and concluded that the worker was knowledgeable of the requirements as well as calibration and maintenance frequencies. A quarterly audit was performed by the RP staff to ensure that sample collection was performed correctly. Communications between the contract sample collector and the licensee were effective. The AOR data demonstrated that there was no discernable radiological impact on the environment due to plant operation l

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, R4 Staff Knowledge and Performance in RP&C R4.1 . Workers Not Wearina Prooer Personal Protective Clothina Insoection Scooe UP 83729) l l

The inspector reviewed the circumstances involving a worker that RP identified as not following the dress requirements of his RWP. In addition, the inspector performed several walkdowns in containment to observe radiation worker practices as well as adherence to RWP dress requirement I

' Observations and Findinas On September 29,1998, the licensee identified a worker on the steam generator platform who had removed both his outer rubber gloves and his cotton liners. The individual was observed removing his gloves by radiation protection on the closed circuit television system. The worker was removed from containment and locked out of the radiologically posted area (RPA). A meeting was held with the work crew and RP to review the RWP dress requirements as well as RP expectation Technical Specification (TS) 6.8.1 requires that procedures be established, implemented ,

and maintained covering activities referenced in the applicable procedures I recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 197 Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, step 7 e.(1)

recommends that procedures be established goveming access control to radiation areas including a radiation work permit system. Radiation Protection Procedure BwRP 5000-7 (Revision 2), dated August 2,1996," Unescorted Access To And Conduct in Radiologically Posted Areas," implements the requirements of Technical Specification 6.8.1 and requires in step G.3.f that each person entering an RPA (radiologically posted area) is responsible to follow all applicable job related and safety related procedures and radiation work permit (RWP). Radiation Protection Procedure BwRP 6200-5 (Revision 4), dated March 10,1997, " Writing Radiation Work Permits," defines class 2 full set as coveralis, cap (optional), cloth hood, cotton glove liners, rubber gloves, cloth shoe covers, and rubber shoe Radiation work permit 984318 (Revision 0), " Cut out laser templating, machira prep, weld RCS and channel head drain piping-SGRP. Include MOB / DEMOB PCI equipment,"

states that protective clothing required for work in dry contaminated areas less than 100K dpm/100cm2 is class 2 full set. Special instructions included in the work permit include, " removal of outer rubber gloves fN making adjustments to the smail components on the OD welding head is allowed provided loose contamination levels are less than SK, surgeon gloves are worn under outer gloves, and the RP technician has been notified prior to making the adjustments". The failure to follow procedure is a violation of TS 6.8.1 (VIO 50-456/98015-01a and 50-457/98015-01a).

On October 22,1998, while observing work being performed in the Unit 1 containment, the inspector identified two workers who were not wearing outer rubber gloves as

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required by RWP 984014. The workers were gluing insulation onto a valve and indicated that the glue caused the gloves to stick together. The inspector discussed this with RP management who stated that workers had been given permission to wear cotton liners

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over the rubber gloves, however the workers indicated that this was cumbersome. RP mansgement further stated that workers that experienced problems with the RWP dress '

requirements were expected to discuss the issue with RP management so that the requirement could be re-evaluated. The job was stopped, the workers were counseled, and were required to perform 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as a greeter before being allowed back into the RPA. The failure to follow procedure is a violation of TS 6.8.1 (VIO 50-456/98015-01b

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. and 50-457/98015-01b). Conclusions

Two examples were identified when workers failed to follow the dress requirements of the RWP goveming their work activities, in violation of station procedures. In both

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l examples RP personnel had made allowances for the type of work being performed, however, the workers neglected to take advantage of the options availabl R4.2 Conduct of Plant Radioaraohv Operations Insoection Scooe (IP 83729)

The radiological controls implemented during outage radiography operations were reviewed. This review consisted of attendance at radiography pre-job briefings, observation of RP controls during the setup and performana of a radiography evolution,

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interviews with cognizant plant staff and inspection of applicable procedures and other

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relevant documents. In addition, the inspector reviewed the circumstances surrounding a licensee identified incident involving two workers inside of a radiography boundary on l October 6,1998, Observations and Findinas On October 6,1998, station RPTs were assigned the responsibility to ensure that no workers were inside of the radiation area boundary prior to beginning radiography. A RPT was assigned to verify that everyole was out of the pressurizer, the A/D steam l

generator coffin, and off the top of the coffin. The RPT failed to perform a visual i verification to ensure the pressurizer coffin was vacated and instead relied on the word ,

of another worker that the area was clear. After the first in a series of radiography shots was performed, a contract RPT found two workers climbing out of the pressurizer coffin.

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The workers electronic dosimetry only showed 2 millirem, which was consistent with

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work area dose rates.

! Tech.nical Specification 6.11 requires, in part, that procedures for personnel radiation l protection be prepared consistent with the requirements of 10 CFR Part 20 and be approved, maintained and adhered to for all operations involving personnel radiation

exposure. Radiation protection procedure BwRP 6210-6 (Revision 3), dated

}' December 15,1993, "Use of X-ray or sealed gamma radiation sources for the purpose of L

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. industrial radiography," states in step E.5, ensure that all unauthorized personnel are cleared from the posted radiography area prior to exposing the source and that they remain outside the area during the evolution. Contrary to this, on October 6,1998, the licensee failed to ensure that two workers, not authorized to be in a posted radiography area, were cleared from the area prior to exposing the source. Failure to follow the 4 procedure is a violation of TS 6.11 (VIO 50-456/98015-02 and 50-457/98015-02).

Corrective actions included stopping all radiography, and initiating a root cause

' investigation The RPT was disciplined and counseled The procedure will also be

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revised to instruct the RPT to perform a visual verification to ensure unauthorized I workers are cleared from the area. RP management also instituted a policy including 8 actions to prevent a recurrence. The actions include:

The Byron /Braidwood radiography events were to be covered in each briefin Notification will be made to station RP and Numanco BOP RP along with maps indicating radiography boundarie The need to visually verify thet no unauthorized personnel are inside the radiography boundaries will be communicated during the radiography brie The RP supervisor assigned to cover the radiography will be required to attend the briefin SGRP RP will be notified of radiography locations 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to starting the sho Bechtel supervision will be notified of radiography information following the briefing. Bechtel workers will be reminded to leave the area as requested by RP ;

when setting up for radiograph j The SGRP RP personnel will establish the minimum number of technicians required to cover each radiography situatio include in the pre-job briefing the proper method and personnel assignments for j clearing the areas affected by radiograph l

The inspector attended two pre-job briefings for radiography operations to observe implementation of the above mentioned actions. The briefings were comprehensive and clear. The applicable RWPs were discussed, as were the Al ARA plan and the station's !

radiography procedure. Individualjob responsibilities were well-defined, as were posting I and surveillance activities. A clear path for ensuring that workers were out of the area l was discussed with the RPTs and all questions were resolved prior to the end of the i briefing. The corrective actions were implemented and effectiv l

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. Conclusions A violation of station procedures was identified for failure to ensure that all unauthorized

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workers were cleared from an area prior to beginning radiography. Radiography pre-job l briefings conducted subsequent to the violation were clear and comprehensive, and included effective actions to prevent recurrenc R4.3 Area Radiation Monitor Alarm Resoonse (IP 83729)

l During a walkdown in containment the inspector heard an area radiation monitor !

alarming. The inspector questioned workers in the area as well as contract RPTs about the alarm and what should be done. A RP foreman who was in containment at the time ,

heard the alarm, acknowledged it, and called the operations department to determine if I the monitor had received a valid signal or not. The monitor was undergoing testing at the time and was out of service, the alarm was not caused by a valid high radiation signal. The inspector was concerned that the workers did not properly respond to the alarm, and the contract RPTs at the control point did not know to acknowledge the alarm j or who to call. The inspector discussed this event with RP management, a problem identification form (PIF) was generated and an article was placed in the daily newsletter on October 20,1998, regarding the proper response of individual workers to an area radiation monitor alarm. The workers are instructed to immediately leave the area and contact rsdiation protection should a radiation monitor alarm. In addition RP management reviewed the proper response and expectations with the RPT R8 Miscellaneous RP&C lssues R (Closed) VIO 50-456/98006-02: 50-457/98006-02: The violation involved RP technicians at the steam generator control point as well as a worker who had failed to properly activate the worker's electronic dosimeter or ensure that the dosimetry was operable, as required by station procedures. RP management 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. The inspector observed workers on the steam generator platforms, and identified no additional examples of workers on the platforms without the proper dosimetry. This item is close R8.2 (Closed) VIO 50-456/97017-01: 50-457/97017-01: An NRC inspector observed work performed on a valve and identified an instance where a worker failed to follow a radiological posting. The worker was inside of a posted high contamination area in the Unit 2 Containment Building and was required to remove outer protective clothing at the designated step-off-pad, when exiting. Instead of exiting at the step-off-pad, the worker stepped over the high contamination area boundary rope and left the area without removing his outer boots and gloves. The inspector reviewed the corrective actions which included sending the worker to refresher training, counseling the individual, and a tailgate session conducted by radiation protection personnel which included this even '

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The inspector also observed work performed in a high contamination area and watched workers properly exit the area. No new examples had been identified, this item is close R8.3 (Closed) VIO 50-456/97017-02: 50-457/97017-02: A violation was identified that involved the failure by radiation protection technicians to properly post and control a locked high radiation area (LHRA). Corrective actions included posting the area .

properly, discipline of the involved RPTs, and training for all RPTs on conservativo decision making and communications. No new examples of problems with posting or control of LHRAs had been identified.' This item is close !

R8.4 (Closed) VIO 50-456/97008-02: 50-457/97008-02: An NRC inspector identified that vacuum cleaners stored in radiologically posted areas were not maintained in I accordance with procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in l

Radiologically Controlled Areas," revision 2. The licensee performed an effectiveness j

review of this program area in December of 1997, and found that the corrective actions I were not sufficient to prevent reoccurrence. Additional corrective actions included revising BwRP 6210-17 to include three levels of vacuum cleaners, "Non-contaminated",

" Contaminated", and " Highly Contaminated". The requirement to cover the ends of the hoses was removed and replaced with instructions to prevent the spread of contamination. Sirice the revisions to the procedure had been implemented, no new examples of problems controlling vacuum cleaners had been identified. This item is close V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on October 22,1998. The licensee acknowledged the findings presented. No proprietary information was identifie . _ ~ , - . ..- . . _ - . - . .

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PARTIAL LIST OF PERSONS CONTACTED M. Cassidy, Regulatory Assurance M. Finney, Lead Operational Health Physicist M. Sayers, SGRP Radiation Protection Supervisor l B. Schramer, Chemistry Manager -

G. K. Schwartz, Plant Manager

- R Thacker, Lead Technical Health Physicist INSPECTION PROCEDURES USED IP 83729 Occupational Exposure During Extended Outages

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IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904 Follow-up - Plant Support ITEMS OPEN, CLOSED, AND DISCUSSED Opened i

50 456/457-98015-01(a-b) VIO Failure of workers to follow RWP dress requirements 50-456/457-98015-02 VIO Failure to ensure that all unauthorized workers were cleared from the area prior to beginning radiography Closed l 50-456/457-98015-01(a-b) VIO Failure of workers to follow RWP dress requirements 50-456/457-98015-02 VIO Failure to ensure that all unauthorized workers were i cleared from the area prior to beginning radiography 50-456/457-98006-02 VIO Failure to ensure electronic dosimetry was turned o /457-97017-01 VIO Failure to adequately implement radiation protection procedures concerning the adherence to postings.

[ 50-456/457-97017-02 VIO Failure to comply with TS 6.12.2. regarding locked high rad t

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50-456/457-97008-02 VIO Failure to follow procedures concerning the control of vacuum cleaners within the radiologically protected area

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. LIST OF ACRONYMS USED ALARA' As-Low-As-Reasonably-Achievable AOR Annual Operating Report  !

BOP Balance Of Plant FHB Fuel Handling Building l IFl Inspection Follow-up Item l lP inspection Procedure  ;

LHRA Locked High Radiation Area l PCE Personnel Contamination Event PIF Problem identification Form RP Radiation Protection l

~ RP Radiation Protection Technicion Radworker Radiation Worker RWP Radiation Work Permit REMP Radiological Environmental Monitoring Program RPA Radiologically Posted Area RCS Reactor Coolant System ,

SGRP Steam Generator Replacement Project I TS Technical Specifications I VIO Violation

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LIST OF DOCUMENTS REVIEWED Procedures I

BwRP 5720-5 Revision 1, " Protective Clothing"

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BwRP 6210-17 Revision 4E2,"Use of Vacuum Cleaners and Fans in Radiologically Posted '

Areas" BwRP 50101 Revision 8E1," Radiological Posting and Labeling Requirements" BwRP 5000-7 Revision 2," Unescorted Access to and Conduct in Radiologically Posted Areas" '

BwRP6210-6 Revision 0, "Use of X-ray or Sealed Gamma Radiation Sources for the Purpose of Industrial Radiography" Problem Identification Forms A1998-03849 A1998-03869 A1998-03857 A1998-03725 A1998-03603 A1998-03487 Radiation Work Permits 984318 Revision 0 984014 Revision 0 984312 Revision 0

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