ML20035F389
| ML20035F389 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/14/1993 |
| From: | Michael Kunowski, Schumacher M, Nirodh Shah NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20035F378 | List: |
| References | |
| 50-456-93-07, 50-456-93-7, 50-457-93-07, 50-457-93-7, NUDOCS 9304210226 | |
| Download: ML20035F389 (10) | |
See also: IR 05000456/1993007
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-456/93007(DRSS)
50-457/93007(DRSS)
Dockets No. 50-456; 50-457
Licensee: Commonwealth Edison Company
Executive Towers West III
1400 Opus Place, Suite 300
Downers Grove, IL 60515
Facility Name: Braidwood Station, Units I and 2
Inspection At:
Braidwood Site, Braidwood, Illinois
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Inspection Conducted: March 22 through 26, 1993
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Inspectors: /IN. k
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M. A. Kunowski
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Senior Radiation Specialist
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N. Shah
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D' ate
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Radiation Specialist
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Approved By:
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M. C. Schumacher, Chief
Date
Radiological ControlsSection I
Insoection Summary
Inspection on March 22-26. 1993 (Reports No. 50-456/93007(DRSS):
50-457/93007(DRSS))
Areas Insoected: Routine, announced inspection of the licensee's radiation
protection program (IP 83750) including changes in organization, training and
qualifications, audits and appraisals, external exposure control including
ALAPA considerations, internal exposure control including a specific related
concern, and control of radioactive materials and contamination. Also
reviewed were the monitoring and assessment of radioactivity released in
effluents (IP 84750) and items identified in previous inspections (IP 83750).
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Results: Observations of planning activities outside of the main
radiologically controlled area and of work activities in the Unit 2
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containment indicated that' the radiation protection program was well
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implemented. Higher area dose rates in containment have been adequately
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compensated for by the licensee. The concern related to internal exposure
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control was not substantiated. A violation for inappropriate posting of a
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9304210226 930414
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contaminated area was identified and cited because of the apparent failure of
corrective actions for another recent posting violation,
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DETAILS
1.
Persons Contacted
+K. Kofron, Plant Managtr
+J. Roth, Regulatory Assurance
+E. Roche, Health Physics Services Supervisor and Radiation Protection
Manager (RPM)
+T. Simpkin, Nuclear Licensing
+P. Zolan, Operating Experience Coordinator, Regulatory Assurance
+S. Jerz, Quality Verification
+B. McCue, Operations
+D. Miller, Technical Superintendent
R. Dralle, Master liistrument Mechanic
C. Chavan, Master Maintenance Mechanic
M. Sayers, ALARA Coordinator
R. Thacker, Lead Health Physicist, Technical Group
J. Gosnell, Radwaste Planner
+S. DuPont, NRC Senior Resident Inspector
+C. Brown, NRC Reactor Inspector
+ Attended the exit meeting on March 26, 1993.
The inspectors also interviewed other licensee personnel.
2.
Licensee Action on Previous Inspection Findinos (IP 83750)
(Closed) Inspection Follow-up Item (IFI) No. 50-456/92006-03(DRSS):
50-a57/92006-03(DRSS): The inspector will evaluate a review by the
licensee of the need to revise the Process Control Program procedure and
the Updated Final Safety Analysis Report (UFSt.R). As a result of the
review, the licensee revised both documents to delete an extensive
description of radioactive waste solidification equipment no longer in
use.
(Closed) Inspection Reports No. 50-456/93002(DRSS):
No. 50-457/93002(DRSS): The licensee agreed to review its Radiation
Protection (RP) policy and memorandum book to ensure that included
information did not more appropriately belong in station procedures.
Dur 'ag the current inspection, the inspector discussed the review with
the Radiation Protection Manager and read several policies and memoranda
from the book. The 'iicensee's determination that the book's content was
appropriate appeared reasonable.
- Open) 10 CFR Part 21 Item. Erroneous Air Flow Rate Readinas in Eberline
AMS-3 Air Samplers: The licensee has 10 of the AMS-3 and related AMS-3A
samplers, 3 of which are used, but only during refueling outages.
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samplers provide local readout and alarm only and are not used for
safety-related or emergency preparedness classification purposes.
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to correct the potential problem with erroneous air flow rate readings
have been ordered by the licensee and will be installed upon receipt.
No violations of NRC requirements were identified.
3.
Chanaes in Oraanization and Trainina and Qualifications of Personnel
(IP 83750)
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The inspectors reviewed changes in the licensee's health physics
organization, and the training of contractor radiation protection
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technicians (CRPTs). No problems were identified.
For the current outage, the two instructors responsible for RPT training
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were detailed to the RP department. This assignment is a good means to
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ensure the instructors maintain knowledge of in-plant working
conditions. Two other changes for the outage that could improve outage
efficiency were the permanent relocation of the Radiation Work Permit
(RWP) desk from the Service Building to the Turbine Building, closer to
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the maintenance shops and the main radiologically controlled area (RCA)
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entrance, and the elimination of one of the two CRPT groups. onsite for
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outages.
Previously, the contractor who did the steam generator (SG)
work provided CRPTs. This group of CRPTs was eliminated for this outage
in favor of having the other CRPT group provide SG job coverage.
The station requires CRPTs to pass a written proficiency exam covering
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basic theoretical and practical health physics concepts. This test is
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generated from a bank of questions provided by the corporate office and
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was found by the inspectors to be reasonably difficult with a good mix
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of theoretical and practical information; individuals certified by the
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National Registry of Radiation Protection Technologists (NRRPT) are
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exempt from this test. After testing, each technician receives
additional training in licensee procedures, health physics equipment and
application, and site specific information. CRPTs with previous station
experience may bypass this training if they successfully pass a
procedural proficiency test. The inspectors interviewed several CRPTs
and reviewed selected exams and exam results; no problems were
identified.
No violations of NRC requirements were identified.
4.
Audits and Appraisals (IP 84750)
The inspectors reviewed audits and appraisals performed since-the last
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inspection.
During July 13-17, 1992, the licensee's corporate group conducted a
technical assessment of the station area and process radiation
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monitoring system. The audit resulted in negative finding's concerning
system availability, communications between work groups, and worker
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training concerning system operation. A task force of work group
representatives was formed to address these findings. As a corrective
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action, a monthly report is being distributed to station management
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summarizing system availability. A review of recent reports by the
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inspectors indicate that system availability has improved to 95-100%.
The task force is also working with the training department to develop
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system training for pertinent workers. The inspectors will review
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further efforts by the task force in subsequent inspections.
No violations of NRC requirements were identified.
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5.
External Exposure Control (IP 83750)
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The inspectors reviewed several RWPs and dose and dose rate assessments,
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and overall radiological performance.
Selected RWPs were reviewed for appropriateness of RP requirements based
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on work scope, location, and radiological conditions.
In general, RWPs
clearly presented information from both ALA".A reviews and current
radiclogical surveys. A recent change to computer-generated RWPs has
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been favorably received by most workers. The inspectors observed
workers adhering to RWP requirements and discussed these requirements
with them at the job site.
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Licensee radiological postings were verified by the inspectors via
independent dose rate measurements, and a review of records indicated
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that the licensee had properly documented worker exposure on NRC Forms 4
and 5.
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During the 1992 Unit I refueling outage (AIR 03), the licensee started a
base-point survey program with Byron station.
Consisting of dose rate
trending at points common to both station containments, it supplements a
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similar program sponsored by the Electric Power Research Institute
For the ongoing Unit 2 refueling outage (A2R03),
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measured dose rates at the 401' elevation of containment are higher than
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those observed at Byron and in Braidwood's Unit I containment.
Dose
rates at the EPRI monitoring points, however, do not indicate any
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significant change from previous years. The licensee believes the
increased dose rates are from the same source producing elevated levels-
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in the steam generators (Section 8).
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To date, approximately 108 person rem have been accrued, compared to an
outage goal of 211 person rem.
Exposure is slightly elevated primarily
due to the above described elevated dose rates and emergent work. Major-
outage activities include:
inservice inspection (est:
13 person-rem)-
steam generator work (est:
47 person-rem); and miscellaneous reactor
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coolant loop resistance temperature detector (RTD) work (est:
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person-rem).
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No violations of NRC requirements were identified.
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6.
Outaae ALARA Considerations (IP 83750)
The inspectors reviewed the licensee's preparation for and control of
activities during the refueling outage with respect to ALARA.
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a.
Outaae Support
Primary responsibility for implementing ALARA programs was through
the ALARA Analyst who performed pre- and post-job reviews,
maintained job history files, and assisted in RWP development
(Section 5). Additional support was provided by the ALARA planner
for Engineering and Construction (ENC) and by contractor ALARA
specialists, as with SG work where the prime contractor provided
an ALARA assessment of planned activities.
Approximately 60 CRPTs, mostly seniors, were hired for the outage.
As in AIR 03, both station and contract RPTs shared a common
facility in order to facilitate communication. Although RP
management retained overall control of all RPTs, contract
supervisors managed daily CRPT activities.
Outage supplies, such as scaffolding and lead shielding, appeared
to be adequate based on discussions with plant personnel and in
plant observations.
b.
Outaae Controls
Daily containment work activities were controlled by a containment
coordinator, who oversaw all planned work, and an RP supervisor
(" foreman"), who coordinated RP support. Additionally, a minimum
of four RPTs were assigned to the containment access checkpoint;
three usually covered ongoing jobs, while the fourth was used as a
rover. An additional checkpoint was maintained outside the
missile barrier and was usually manned by 1-2 CRPTs.
Because of the good results seen in AIR 03, designated tool and dry
active waste (DAW) storage areas were maintained inside-
containment. Tools were issued at the 426' elevation, painted
red, and stored at the work site in white plastic buckets. Also,
tools used in containment remained there unless they were designed
for a special purpose and were needed elsewhere. DAW was stored
in trash bags at the worksite and collected daily by station
laborers. The bags were kept in designated areas and typically
were removed from containment weekly.
c. - Outsae Performance
The licensee appeared to maintain good control over work
activities.
Both the containment coordinator and RP supervisor
appeared knowledgeable of scheduled work activities, and the
containment and missile barrier access areas were continuously
staffed. Video cameras were used at the containment access point
to monitor reactor vessel work, fuel movement, and general
activities inside the missile barrier, and were also used with
communication headsets to cover steam generator work. On several
occasions, the inspectors also noted RP management touring
containment work areas.
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ALARA planning also appeared to be well addressed during the
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outage.
Daily outage meetings were attended by RP representatives
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to keep abreast of ongoing work, and a daily list summarizing
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exposure per work group and per RWP was distributed to station
management. The inspectors observed a good discussion of
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radiological concerns during a pre-job briefing for RTD work.
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They also noted good communication between workers and RPTs during
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plant tours, and the use of mockup training and photographs / video
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mapping during pre-job planning for steam generator and RTD work.
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Although not observed by the inspectors, several workers indicated
that some contract workers appeared to have been loitering in
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radiation areas. The impression was that contract workers
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purposely extended their stay in the radiation area in order to
avoid the appearance of taking frequent breaks, and thereby incur
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criticism. Station and RP management indicated to the inspectors
that they were aware of these problems, had discussed them with
contractor management, and that the practice had been discouraged.
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At the exit meeting (Section 12), the inspectors discussed with
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the licensee the importance of maintaining good controls over
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contractor activities to keep exposures ALARA.
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No violations of NRC requirements were identified.
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7.
Jnternal Exoosure Control (IP 83750)
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The inspectors reviewed the operation of the whole body counter (WBC),
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maintenance of respirators, and internal exposure records. The licensee
has two "FASTSCAN" WBCs, which are calibrated every 18 months.
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addition, quality control checks (QCC) are performed on a daily and
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weekly basis. Through a review of records and interviews with
personnel, the inspectors verified that both calibrations and r$Cs were
performed as required, and that RPTs were knowledgeable of WBt
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operation.
For WBC calibrations, the licensee uses a mixed gamma sourc_
traceable to the National Institute of Standards and Testing (NIST); for
QCC, a mixed Co-60/Cs-137 source is used which is also NIST traceable.
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Respirator cleaning, issuance, and storage appeared to be well
maintained and RPTs appeared knowledgeable about the program in
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discussions with the inspectors. The licensee appeared to properly
assess the use of respiratory program as indicated by a review of work
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preparations and air sampling data.
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The inspectors verified that no intakes above the 40 MPC-hour control
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level had been recorded by the licensee.
The inspectors also reviewed
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station records and interviewed personnel regarding a concern about
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internal exposure control. This is discussed below in Section 8.
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No violations of NRC requirements were identified.
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8.
Radiation Protection Concern (IP 83150).
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Concern: Contamination detected during a whole-body count of a worker
at the LaSalle Station could have come from Braidwood.
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Discussion: A recent inspection at LaSalle (Inspection Reports
No. 50-373/93003(DRSS); 50-374/93003(DRSS)) determined that the
identification of contamination on the worker was in error.
During the
current inspection at Braidwood, WBC, external exposure monitoring, RWP,
and personnel contamination event records related to the worker were
reviewed. No indication that the worker was contaminated externally or
internally while at Braidwood was identified.
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Findinas: The concern was not substantiated. No violations of NRC
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requirements were identified.
9.
Control of Radioactive Materials and Contamination. Surveys and
Monitorina (IP 83750)
The inspectors reviewed the licensee's assessment of personal
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contamination events (PCEs), calibration of whole body friskers, portal
monitors and portable instrumentation, and work practices.
PCEs reviewed by the inspectors appeared to be investigated in
accordance with licensee policy. Although all PCEs- exceediag 50 cpm
above background were investigated, only those exceeding 1,000 cpm above
background were tracked. A monthly report summarizing total PCEs is
distributed to the department heads by radiation protection. To date,
35 PCEs have been recorded for the outage, compared to a goal of 118.
The inspector also reviewed the methodology used by the licensee to
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calculate skin dose; no problems were noted.
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To date, approximately 3% (9510 ft') of the plant is considered
contaminated, which is below the outage goal of 6.2%.
Although the
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contaminated, an informal level of 100 dpm/100 cm*/100 cm* as
licensee officially posts areas exceeding 1000 dpm
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is used for tracking.
In accordance with corporate policy, areas considered " permanently"
contaminated are not tracked. While accompanying a plant operator on
daily rounds, the inspector noted that only minimal protective clothing,
i.e., shoe covers and gloves, was needed to perform required
surveillances.
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Monitor alarm methodology, functional tests, and calibration procedures
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were reviewed by the inspector for whole body friskers (WBF) and portal-
monitors.
Required tests and calibrations were performed in accordance
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with station procedures, and WBF alarm setpoints appeared consistent
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with guidance contained in IE Circular 81-07, " Control of Radioactively
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Contaminated Material." Both portal monitors and WBFs were functionally
checked daily using a 200 nCi Cs-137 and 3 nCi Tc-99 source,
respectively.
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Portable instrumentation examined during inspector plant tours were
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maintained and calibrated in accordance with licensee policy; also; 0;'Ts
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and workers were observed using instrumentation appropriate to the
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expected dose rate and contamination levels.
In interviews with the
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inspectors, RPTs appeared knowledgeable of the calibration and
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maintenance programs.
The licensee has experienced a number of contamination control problems
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during steam generator work. Both contamination levels inside glove
bags used to maneuver eddy current probes, and dose rates on HEPA
filters inside portable ventilation units, were higher than in previous
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outages. While retracting eddy current probes, it was also noticed that
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a rust colored film had apparently formed inside the generators. A
sample of the film, approximately the size of a quarter, read 4 R/hr on
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contact.
The licensee is investigating the film, and believes that it
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is also the cause of the higher containment dose rates (Section 5). The
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inspectors will review licensee progress in future inspections (IFIs
No. 50-456/93007-Ol(DRSS); No. 50-457/93007-01(DRSS)).
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No violations of NRC requirements were identified.
10.
Gaseous and Liouid Radioactive Effluents (IP 847'iOl
Discussions with licensee representatives indicated that a utility-wide
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review of gaseous tritium and noble gas sampling methodologies had been
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conducted in 1992.
Recommendations from this study have been
implemented at Braidwood and may result in fewer curies of noble gas and
more curies of tritium being reported in future effluent reports,
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relative to previous, comparable operational periods.
In addition, the
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inspectors noted that in 1992 the amount of tritium released in liquid
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effluents was about 3 times the amount estimated in the UFSAR;
calculated offsite dose from tritium remained well below TS limits. The
licensee agreed to evaluate this discrepancy. The changes in gaseous
effluent sampling methodologies and the resolution of the liquid tritium
discrepancy will be reviewed during a future inspection (IFIs
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No. 50-456/93007- 4DRSS); 50-457/93007-02(DRSS)).
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No violations of NRC requirements were identified,
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Plant Tours
While touring containment, the inspectors noted that work areas were
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well maintained primarily due to the DAW and tool controls used
(Section 6b) by the licensee. They also noted that workers were
generally using good radiological work practices, but were leaving face-
shields at the work site. This practice could increase the probability
of facial contaminations. The matter was discussed at the exit meeting
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(Section 12).
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The inspectors also identified a contaminated area posting, located
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inside the filter valve aisle on the_383' elevation of the auxiliary
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building, that was laying on the floor. An RPT indicated to the
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inspectors that the area was still contaminated and immediately replaced
the posting. The area's status was later verified by the inspectors by
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reviewing licensee survey results.
Licensee procedure BwRP 1110-3,
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" Radiological Postings, Labels, and Controls," requires each controlled
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area to be posted so as to warn personnel approaching the area from any
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direction.
Failure to comply with the procedure is a violation of
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Because of'the failure of corrective
actions for a similar, previous violation (Inspection Reports
No. 50-456/93002; No. 50-457/93002), this violation does not meet the
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criteria specif'9d in Section VII.B of the " General Statement of Policy
and Procedures for NRC Enforcement Actions," (Enforcement-Policy,
10 CFR 2, Appendix C) and is being cited (Violations No.
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50-456/93007-03(DRSS); 50-457/93007-03(DRSS)). This violation was
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discussed at the exit meeting (Section 12).
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One violation was identified.
12.
Exit Interview
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The scope and findings of the inspection were reviewed with licensee
representatives (Section 1) at the conclusion of the inspection on
March 26, 1993. The licensee did not identify any documents as
proprietary. The following matters were specifically discussed by the
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inspectors.
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Process and area radiation monitoring system audit (Section 4);
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Containment dose rates and steam generator contamination
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(Sections 5 and 9);
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Contractor worker practices (Section 6c);
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Face shields in containment (Section 11); and
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Posting procedure violation (Section 11).
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