ML20127H648
| ML20127H648 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 01/18/1993 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301250013 | |
| Download: ML20127H648 (9) | |
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1)f C:mmenwealth Edis:n 1400 Opus Place Downers Grove, Illinois 60515 January 18, 1993 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Documtnt Control Desk
Subject:
Braidwood Nuclaar Power Station Units 1 and 2 Response to Hotice of Violation Inspection Report Hos. 50-456/92023; 50-457/92023 NRC Docket Numberc 50-456 and-50-457 Referchr.e: B. Clayton letter to C. Reed, dated Decsmber 18,-1992, transmitting NRC Inspection Report 50-456/92023;50-457/92023 Enclosed is Commonwealth Edison Company's (CECO) respen.se to the Notice of Violation (NOV) which was transmitted with the referenced letter and Inspection Report.
The NOV cited three Severity Level IV violaticns requiring a written respcnse.
Ceco's response is provided in tt:a attachment.
If your staff has any questions or comments concerning this letter, please refer thom to Denise Saccomando, Compliance Engineer at (708) 663-7285.
Sincerely.
[ [.
7&av T. J. Kovach Nuclear Licensing Manager 4
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Attachment cc:'
A. Bert Davis, NRC Regior.a1 Administrator - RIII J. Hickman, Project Manager
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S. D( Pont, Senior Resident ~ Inspector l q ZNLD/2464/L 9301250013 930118
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P ATTACl! MENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT 50-456/92023:50-457/92023 VIOMTION 436(457)/92023-01:
Braidwood Technical Specification 6.11. " Radiation Protection Program " states:
" Procedures, for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure."
Braidwood Radiation Protection Procedure 1110-3, " Radiological Postings, Labels, and Controls," detAlls the requirements for proper postir.gs and demarcation of ~Jiologically controlled areas and the requirement that personnel shall read and comply with all radiological postings.
Contrary to the abova:
a.
On July 15, 1992, a Radiation Protection Technician (RPT) removed the posting for the IA Letdown Heat Exchanger Room without adhering to the requirement to verify the rooni had been decontaminated, b.
On July 29, 1992, a RPT failed to adhere to the posted requirements for whole body frisking prior to exiting a contaminated area.
c.
On October 16, 1992 Two Mechanical Mainttnance Department personnel entered the contaminated Auxiliary Building Hot Shop and failed to adhere to the posting requirements for protective clothing.
REASON FOR THE VIO MTION The RPT Inappropriately removed the posting for the 1A Letdown Heat Exchanger room without reviewing proper documentation or performing a releate survey.
The RPT had overheard a conversation earlier in the day regarding the room's conditions and subsequantly made a wrong assumption that the room was not contaminated.
Additionally, the RPT failed to apply self checktag practices to ensure his actions were correct prior to performing the action.
These circumstances resulted in contamination events for the RPT and an elec+rician.
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j-i CORRECTIVE STEPS-TAKEN AND RESUL1S ACHIEVED:
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The individuals were decontaminated. The 1A Letdown Heat j
Exchanger ioom was reposted as a contaminated area on July 15, 1992.
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The RPT was counseled by the Health Physics Services Supervisor 4
with regards to the significance of this event.
The need to apply a
self checking and to pay attention to detall was emphasized.
5 Appropriate disciplinary action was taken.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
1 l-Radiation Protection management held discussions with all i
Radiation Protection personnel concerning the significance of the i
1 event and the need for attention to detall.
Additionally. the RFT reviewed this incident with the other RPTs to share the lessons j
learned from the event.
i DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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Full-compliance was achieved on-July 15, 1992, when the 1A t.etdown Heat Exchanger room was reposted as a contaminated area.
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REASON FOR THE VIOLATION 456(457)/92023-Olb:
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CECO acknowledges that a RPT failed to follow a step-off pad instruction requiring a whole body frisk before exiting the immediate area.
i The change area was not equipped with a frisker because background t
I radiation levels at the time prevented a frisker from being i
effectively used.
It was intended that personnel would use a i
i frisker in an adjacent low background area.
The step-off pad which stated the requirement to fr!sk had not been removed. On July 29, 1992, the RPT exited the area and used the frisker in the adjacent area to perform a whole body frisk.
Radiological change areas are set up in accordance with Braldwood i
Radiation Protection Procedure (DwRP) 1110-3, " Radiological l
Postings, Labels. and Controls." This procedure specifies that 4 4
" Perform Whole Body Frisk Sefore Stepping Here" step-off pad be-used or instructions be posted to proceed to a designated whole body frisk location.
The procedure does not specify conditions in which the stop-off pad should not be used.
Normal station practice at the time of this event was to routinely place this step-off pad at every change area.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
l The step.off pad was removed.
Upon completion of the work in the i
contaminated area, the area was decontaminated and the radiation l
boundarles were removed.
A plant walkdown was performed by Radiation Protection personnel ensuring that step-off pads requiring a whole body frisk were.used i
in appropriate areas' All deficiencies were corrected, i
i Discussions were held with Radiation Protection personnel l
concerning-this event and_tts. significance. Additionally, the l
Intent of BwRP 1110-3 and the importance of the need for attention
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to detail were reviewed.
'ColiRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION:
i BwRP 1110-3, "Radiclogical Postings, Labels, and Controls," will be revised _to clarify conditions in which remote frisking is required.
This. procedure will be revised by March 1,1997,.
DATE WHEN FULL. CONFLIANCE WILL BE ACHIEVED:
Full compliance was achieved upon removal of the step-off pad.
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REASON FOR THE VIOLATION 456(457)/92023-Olt; The two Mechanical Maintenan;e personnel failed to adhere to the posting requirements for protective clothing when entering the Auxiliary Building Hot Shop due to a lack of understanding of postings and contaminated area boundartes. The workers had entered the Hot Shop on other occasions when a small area within the room had been designated as a contaminated area. On October 16, 1992, the workers read the " Contaminated Area" posting, incorrectly assuming that it pertained to a limited area within the room, they entered the room without protect've clothing and thus, became contaminated.
00RRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Both workers were counseled by Mechanical Maintenance supervistan who clarified that radiological postings appiy to the entire area unless otherwise specified. Management's expectation on the importance of reading, understanding and adhering to radiological postings was stressed.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHrR VIOLATION:
This event was discussed with Mechanical Maintenance Department personnel to emphasize the importance of adhering to radiological postings and the need for attention to detail.
This event and lessons learned were summarized in Braidwood Station General-Information Notice (GIN) 94-01.
The GlH has been distributed to all departments and posted appropridtely.
Radiation Protection Technicians will be reviewing this event with the working departments during weekly safety meetings.
During this meeting, station personn11 will be instructed on the importance of reading and adhering to radiologir.a1 postings.
Various situations involving postings that require increased attention will be discussed.
Emphasis will be placed on worker accountability for adherer.ce to rsdiological postings.
These meetings watch will be completed by March 1, 1993.
DATE WHEN FULL CDMPLIANCE WILL DE ACHIEVED:
Full compliance was achieved when the Mechanical Maintenance personnel were counseled by their supervisor.
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f VIOLATION 456(457)/92023-02:
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i Braidwood Technical Specification 6.8.1, " Procedures and l
Programs," states:
" Written procedurus shkil be established, Implemented, and maletained covering activities referenced in j
Appendix A of Regulatory Guide 1.33."
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Contrary to the above, on November 6, 1992, the Chemistry Department added sulfur hexafluoride to the Unit I condensate d
l system without establishing a written procedure.
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RU,$0N FOR THE VIOLATION:
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As Unit 1 secondary systems were starteo up at the end of refueling outage AIR 03, elevations in Unit 2 steam generator J
l-chemistry values were observed.
The Chemistry Department, with
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the Operating Department's approval, decided to inject sulfur hexafluoride gas into the Unit 1 condensate system for the purpose l-of rietermining if there wat any leakage from Unit 1 into the Unit 2 condensate system.
Chemistry Department personnel chose to use sulfur hexafluoride i
for identifying potential. leakage between Unit I and Un?t 2 l
condensate systems based on their experience in finding circulating water to condensate water leaks using Braidwood f
Chemistry Procedure (DwCP) 310-1, "Use of Sulfur Hexafluoride and i
Associated Equipment for Waterbox to Condensate Leak-Detection."
At the time of this event. Chemistry personnel were relying on l-past experience and vendor information whir.h included awareness i
that sulfur hexafluoride is a tracer gas that is only slightly soluble in water and is easily removed by the off gas system.
j Above 2240 Degrees F, sulfur hexafluoride thermally decomposes in water. The reactivity of the gas was not known to be a.
significant issue. Based on this information~, Chemistry personnel proceeded with their leak determination.
l There was no approved writteh procedure for identifying leakage i-between the Unit I and Unit 2 condensate' systems. Chemistry t
Department personnel did not recognize that an approved written procedure was appropriate for this particular evolucion.
, CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:-
i' Injection of sulfur hexafluoride into the condensate system was halted after Chemistry personnel recogn_ized a fluoride excursion i
in the Unit 1 Steam Generators.
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CORRECTIVE STEPS TilAf HILL BE TAKEN TO AVOID FUATilER VIOLATION:
A temporary procedure change whs made to BwCP 310-1, to alert personnel of the adverse effects that excessive amounts of sulfur hexafluoride have on the conder. sate and feedwater systems.
The event was also referenced in the procedure.
This temporary change will become a permanent change by June 1, 1993.
Braidwood Station will not inject sulfur hexafluoride into the condcnsate or feedwater systems; therefore, no written procedure is required.
The Chemistry Supervisor and Chemistry personnel have dis:Lssed this event and Braidwood Technical Specification 6.8.I, which requires that written procedures be established, implemented and msintained covering activities referenced in Appendix A of Regulatory Guide 1.33.
Existing g,idance will be reviewed for determining what types of activities should be incorporated into approved written procedurss. All departments will be requested to review activities based on this guidance to ensure approved procedures exist as apprcpriate.
This review wiii be complete by June 1, 1993.
DATE MIEN TULL COMPLIANCE HILL BE ACHIEVED:
Full compliance was achieved on November 6, 1992, when additions of sulfur hexafluoride gas into the Unit 1 and Unit 2 condensate systems were suspended.
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e VIOLATIGd 456(457)/92023-03:
10 CFR 50.59(b)(1), " Changes, Tests, and Experimeats," re:;uires that records of tests and experiments shall be maintained and that these records must include a written safety evaluation which provides the bases for the determination tn6t the test or exportment does not involve an unreviewed safety question.
l Contrary to the above, on November 6, 1792, the Chemistry Department added sulfur hexafluoride to the Unit I steam i
generators as an ex)eriment without performir.g a sefety evaluation 1
to determine that tie experiment ldid not involve a safety question.
REASON FOR THE VIOLATION:
Changes to the plant, changes to procedures, tests, and experiments are normally accomplishco through written approved documents. As part of the documentation, a 10 CFR 50.59 review is performed.
Because Chemistry personnel dere adding sulfur hexafluoride to the Unit I condensate system without en approved wiltten procedure, there was no formal mechanism to prompt a 10 CFR 50.59 review.
If an approved written procedure is neenssary, Braidwood Administrative Proceaure (EwAP) IJ00-2, " Permanent Procedure Preparation, Revision Deleticn and Approval," or BwAP 1200-6, "Special Procedures, Tests, or Experiments," would be used.
Both procedures require a 10 CFR 50.59 review-Chtmistry pe'.sonnel did not recognize the rieed to perforn u safety evaluation for the addition of sulfur hexafluoride.
Because Chisistry personnel routinely used sulfur hexafluorlds in acrordance with BwCP 310-1 to-locate leaks frcm the circulating water-system to the condensate. water system, it was detmed suitable for other applications.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Braidwood Station performed an engineering evaluation-which indicated that the chemical excursion caused by the sulfur hexafluoride injection did not adversely impact plant' systems.
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-CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOIU FURTHEP. VIOLA 110M:
The Chemistry Supervis,or and appropriate Chemistry personnel have-discussed this event,-the need to have established written procedures and_to adhere _to'10 CFR 50.53 requirements.
Specifically addressed was'the applicability cf performing a-safety review for. changes.. tests and experiments to ensure-that nc unreviewed safety _ questions exist.
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This event, the need to have written procedures, and a 10 CFR 50.59 safety evaluation will be cddressed in a Chemistry Department memo.
This memo dill be distributed by February 1 1993.
Existing guidance for all station personnel regarding 10 CFR 50.59 requirements will be reviewed for adeuuacy.
Revisions will be made to the appropriate station procedures as necessary. This action will be complete by June 1, 1993.
Braidwood Station is in the process of developing a Chemistry Departnent Job Qualification 'l raining Program for Chemistry management personnel. The applictbility of performing a safety evaluation for chang 9s. test and experiments will be included in this program, this program will be in plar.e by Dccember 31, 1993.
DATE WHEW FULL COMPLIANCE HILL DE ACHIEVED:
full compliance was achieved with the completion of the engineering evaluation.
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