ML20136D931
| ML20136D931 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20136D867 | List: |
| References | |
| 50-456-97-03, 50-456-97-3, 50-457-97-03, 50-457-97-3, NUDOCS 9703130061 | |
| Download: ML20136D931 (15) | |
See also: IR 05000456/1997003
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION 111
Docket Nos:
50-456; 50 457
Licenses No:
Reports No:
BO-456/97003(DRS); 50-457/97003(DRS)
Licensee:
Commonwealth Edison (Comed)
Facility:
Braldwood Nuclear Plant, Units 1 and 2
Location:
RR #1, Box 79
Braceville,IL 60407
Dates:
February 3-7,1997
Inspectors:
S. Orth, Radiation Specialist
D. Hart, Radiation Specialist
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Approved by:
T. Kozak, Chief, Plant Support Branch 2
Division of Reactor Safety
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9703130061 970304
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ADOCK 05000456
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Report Details
IV. Plant Suonort
R1
Radiological Protection and Chemistry (RP&C) Controls
R 1.1 Plant Water Chemistrv Control
a.
Insoection Scoos (84750)
The inspectors reviewed the licensee's management of primary and secondary
water chemistry including the program to mitigate impurities in the systems.
included was a review of the licensee's trending and analysis of chemistry
parameters for the period of January 1996 through January 1997 and a review of
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the following procedures:
BwCP PD-1, "Braidwood Station Primary Chemistry Surveillance Program," Revision
5, dated April 14,1996,and
BwCP PD-4, "Braidwood Station Secondary Water Chemistry Surveillance
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Program," Revision 10, dated April 27,1996.
b.
Observations and Findinas
The licensee's procedures, BwCP PD-1 and BwCP PD-4, were consistent with the
industry guidelines in minimizing the concentration of corrosive agents and radiation
source term buildup. For example, the licensee utilized all-volatile treatments (AVT)
chemistry in the secondary system to reduce oxygen concentrations and iron
transport and to control pH, via addition of hydrazine and methoxypropyl amine
(MPA). Following the change of additives from ethanolamine to MPA in March
1996, the licensee observed a notable decrease in feedwater iron concentration.
The iron concentrations in Units 1 and 2 were decreased by a factor of about two,
resulting in about 3 and 2 parts per billion (ppb), respectively. To mitigate the
effects of caustic crevice corrosion in Unit 1, the licensee practiced " Molar Ratio
Control" (MRC) to reduce the caustic nature of sodium in the steam generator (SG)
crevices with chloride. The inspectors noted that the licensee maintained effective
control over the sodium-to-chloride ratio in the SGs.
The licensee maintained excellent control of primary and secondary water chemistry
in both units. The concentrations of chloride and flucride in the primary systems
were maintained between 3-5 ppb. With the exception of periodic, minor
circulating water leaks, the levels of impurities in the secondary system were also
well maintained. Unit 2 SG sodium and chloride concentrations were 0.5 - 1.0 ppb
and 0.5 - 2.0 ppb, respectively. As a result of the MRC, the Unit 1 SG chloride
levels were slightly higher than the levels in Unit 2, but well within industry
guidelines. The licensee experienced some circulating water intrusions in July 1996
(Unit 1) and February 1996 (Unit 2), which corresponded to minor, short term
increases in the concentrations of sodium and chloride. However, the licensee
mitigated the effects in a timely manner.
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The inspectors observed good monitoring of fuelintegrity. The licensee's data
indicated a potential fuelintegrity problem in Unit 1. The concentration of xenon-
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133 (Xe-133) increased in mid-January 1997 and had remained constant. The
licensee had not observed any increase in the activity of reactor coolant
radioiodines, nor in their ratio. Additionally, the licensee had not observed any
gross indications of a failure in fuelintegrity. Based on the Xe-133 activity, the
licensee postulated small leaks in 1-3 fuel rods.
c.
Conclusion
The water chemistry of primary and secondary systems was well maintained and
monitored. Levels of corrosive impurities were maintained at or below industry
guidelines.
R1.2 Quality Control (QC) of Laboratory and in-line Chemistrv instruments
a.
insoection Scone (84750)
The inspectors reviewed the licensee's quality control program for both laboratory
and in-line instruments. The inspectors reviewed the licensee's implementation of
the following procedures:
BwAP 550-25, " Control of Chem Aids," Revision 2, dated February 14,1994;
BwCP 510-2, " Control of Laboratory Standards, Standard Reagents and
Chemicals," Revision 13, dated April 15,1994:
BwCP 51010, " Laboratory Instrumentation Performance Check Procedure,"
Revision 8, dated December 5,1995;
BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 10,
dated November 6,1995;
BwCP PD-7A1, " Laboratory Analytical Instrumentation Quality Control Program,"
' Revision 1, dated July 26,1994:
BwCP PD-7A2, " Process Panel Instrumentation Quality Control Program " Revision
3, dated November 6,1995; and
BwCP PD-7A3, "Radioanalytical Quality Control Program," Revision 2, dated
March 27,1996.
The inspectors also reviewed the licensee's maintenance of instrument control
charts and performance of high purity germanium (HPGe) detector calibrations.
b.
Observations and Findinas
On February 3,1997, the inspectors identified two aluminum (AI) standards which
were improperly labeled with respect to the procedure required shelf-life. Procedure
BwCP 510-2 required that standards having a concentration between 1001 ppb and
50 parts per million (ppm) be labeled for a shelf life of six months. However, the
inspectors identified that the Al standards (prepared on August 13,1996 and
September 10,1996 at 10 and 20 ppm, respectively) were labeled to expire after
one year. Following the inspectors' identification, the licensee removed and
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disposed of the standards and verified that the reagents had not been used beyond
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the procedure instructed six month shelf life,
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Technical Specification (TS) 6.8.1 requires, in part, that written procedures be
implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, Revision 2, February 1978. RG 1.33, Appendix A
recommends that procedures be implemented which specify chemistry instructions
and the calibration of laboratory instruments. BwCP 510-2 controls the standards
used in instrument calibrations, thus implements the recommendation of RG 1.33.
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The failure to control the shelf life of laboratory reagents in accordance with BwCP
510-2 is a violation of TS 6.8.1 (Violation Nos. 50-456/97003-01a and 50-
457/97003-01 a).
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The inspectors identified a problem concerning laboratory instrument performance
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checks. Procedure SwCP 510-10 directs chemistry technicians (cts) to verify that
instrument bias checks (BCs) are within the appropriate control limit. If an
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instrument does not pass the BC, the procedure instructs cts to perform additional
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OC analyses prior to proceeding with the sample analyses. Procedure BwAP 550-
25 requires " chem aids" be properly authorized, documented, and reviewed to
ensure that they were current, complete, and necessary. The inspectors observed
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cts verifying the BC for laboratory instruments with an uncontrolled aid containing
acceptance criteria. The licensee posted the aid in several areas of the laboratory
as a convenience for the cts so that they did not have to enter data into the
licensee's computer system (i.e. the controlled acceptance criteria data base) until
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later in the day. A laboratory chemist prepared this aid when he changed the
acceptance criteria in the computer data base. The inspectors did not identify any
discrepancies between the acceptance criteria in the controlled computer data base
and the posted aids. However, the inspectors identified that the licensee did not
perform a periodic review to ensure that the aid was consistent with the data base
as required in BwAP 550 25. Although the licensea's computer system provided a
final verification of the adequacy of the BC, the use of uncontrolled, unreviewed
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documents to perform procedure required verifications could lead to the CT
performing an analysis sequence without passing the required BC. In this case, the
entire analysis sequence would be re-performed, which may delay the ability to
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review system chemistry parameters.
TS 6.8.1 requires, in part, that written procedures be implemented covering the
applicable procedures recommended in RG 1.33, Appendix A, Revision 2, February
1978. RG 1.33, Appendix A recommends that procedures be implemented which
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specify laboratory instructions and calibration of laboratory instruments. BwAP
550-25 requires specified control and review of aids used in the laboratory to
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supplement procedures. The failure to control and review the aid used in
performing the instrument performance checks in accordance with BwAP 550-25 is
a violation of TS 6.8.1 (Violation Nos. 50-456/97003-01b and 50-457/97003-01b).
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The inspectors observed that the licensee's QC program for in-line instruments was
well maintained. However, the inspectors reviewed the licensee's control charts for
several laboratory instrument analyses and identified some problems concerning the
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identification and resolution of instrument blases and a lack of documentation of
corrective actions. The inspectors observed that analytical instrument and
radiochemical control charts were prepared and maintained as required by
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procedures BwCP PD 7A1 and BwCP PD-7A3, respectively. However, the
inspectors identified the following unresolved biases in the performance check data:
(1) a low bias was evident in gas chromatograph C data since October 1996 for
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hydrogen analysis; (2) a low bias was evident in ion chromatograph 3 sulphate
analysis since November 1996; and (3) a high bias was evident in ion
chromatograph 3 fluoride analysis since December 1996. The responsible
instrument chemists indicated that they were in the process of resolving the biases,
but had not recorded their actions. Although there did not appear to be an
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analytical problem with the accuracy of data produced by these instruments, the
long term biases may indicate some minor errors in the preparation of standards or
in the calibration of the instruments. The inspectors also identified that
documentation to support the changing of test acceptance criteria was not always
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maintained. The instrument chemists appeared to be properly changing the
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acceptance criteria in accordance with changes in instrument performance, but the
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rationale and calculation of the new criteria were not always formally recorded.
BwCP PD-7A1 indicated that the control limits should be reset at the discretion of
the instrument chemist and any actions taken should be recorded. The licensee
planned to improve the control of QC records.
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c.
Conclusion
The quality control of laboratory instruments ensured the overall accuracy of
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required analyses. However, problems were identified concerning the resolution of
biases in chemistry instrument control chart data. Examples of violations were
identified for the failure to follow procedures concerning (1) the assigned shelf life
of laboratory standards and (2) the control of chemistry aids.
R3
RP&C Procedures and Documentation
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R3.1
Chemistry Laboratorv Quality Control and Post Accident Samolino System Quality
Control and Surveillance Procedures
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a.
Insoection Scone (84750)
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The inspectors reviewed the adequacy and the licensee's implementation of the
following procedures:
BwCP 210-14, " Geometry Efficiency Standardization of Intrinsic Gerrr anium
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Detectors on the ND 9900 Counting Room System," Revision 2, Feoruary 21,
1996:
BwCP 323-13, "High Radiation Sampling System Surveillance Procedure," Revision
7, dated January 21,1997;-
BwCP 7031, " Initial Requirements for Post Accident Sampling of Reactor Coolant,
Radwaste, and Containment Air," Revision 6, dated January 21,1997;
BwCP 703-2, " Post Accident Sampling of Diluted Reactor Coolant (Cold or Hot
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Leg)," Revision 5, dated September 25,1995;
- BwCP 703-6, " Post Accident Sampling of Diluted Containment Floor Drain Sump,"
Revision 4, dated September 25,1995:
BwCP 70313, " Post Accident Sampling of Undiluted Containment Floor Drain
Sump," Revision 4, dated September 25,1995;
BwCP 703-17, " Stripped-Gas Sampling of Post Accident Reactor Coolant," Revision
5, dated September 25,1995:
BwCP 703-21, " Post Accident and Normal Sampling of Containment Atmosphere in
the Manual Mode of Operation," Revision 2, dated April 11,1996;
BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 10,
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dated November 6,1995;
BwCP PD-7A1, " Laboratory Analytical Instrumentation Quality Control Program,"
Revision 1, dated July 26,1994;
BwCP PD-7A2, " Process Panel Instrumentation Quality Control Program," Revision
3, dated November 6,1995; and
BwCP PD-7A3, "Radioanalytical Quality Control Program," Revision 2, dated
March 27,1996.
The inspectors reviewed the procedures to determine if the procedures met the
recommendations of RG 1.33 as required by TS 6.8.1 and were prepared and
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implemented in accordance with the licensee's procedure BwAP 100 20
" Procedure Use and Adherence," Revision 5, dated February 16,1996.
b.
Observations and Findinos
The licensee conducted a nonradiological interlaboratory program as required by
procedure BwCP PD-7A1. The licensee's 1995 and 1996 results were excellent.
However, the inspectors identified some problems concerning the conduct of the
program and the licensee's corrective actions for results which were outside of the
stated acceptance criteria. For example, the inspectors identified problems
concerning the timely reporting of some licensee results, in reviewing the
licensee's non radiological analytical results, the inspectors noted that the overall
results for the third quarter of 1995 and the first quarter of 1996 were identical.
Subsequently, the licensee determined that the results for the first quarter of 1996
had not been reported. Although the licensee had analyzed unknowns for the first
quarter of 1996, the licensee's corporate group, which administrated the program,
had re-reported the results of the third quarter of 1995 instead of reporting the
results for the first quarter of 1996. On February 6,1997, the licensee obtained
the results for the first quarter of 1996 and found them to be in excellent
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agreement. The inspectors also observed that the licensee did not always take
corrective actions for sample results which were not found to be within acceptable
ranges and that, when re-analyses were performed, the licensee did not have
documentation which provided results or conclusions. In the case of silica, a
number of the licensee's results were outside of the acceptance range in both the
first quarter and third quarter of 1995. The licensee performed additional analyses,
but did not have an evaluation of the results.
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The inspectors identified problems concerning the adequacy of OC procedure BwCP
PD 7A1 in implementing the recommendations of RG 1.33, Appendix A.
Specifically, procedure SwCP PD 7A1 required that the licensee have an
interlaboratory program and that the licensee analyze unknown samples semi-
annually. However, the procedure BwCP PD-7A1 did not provide adequate
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instructions for the implementation of the program, the applicable acceptance
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criteria for sample results, and the actions to be taken to resolve unacceptable
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analytical results. As described above, the inspectors identified performance
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problems concerning certain elements of the semi-annualinterlaboratory program.
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The interlaboratory program is used to verify laboratory equipment is properly
controlled and calibrated.
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TS 6.8.1 requires, in part, that written procedures be established covering the
applicable procedures recommended in RG 1.33, Appendix A. Revision 2, February
1978. RG 1.33, Appendix A recommends that procedures be implemented to
ensure that laboratory equipment are properly controlled, cali 3 rated, and adjusted at
specified periods to maintain accuracy. The failure to provide adequate instructions
in procedure BwCP PD-7A1 to ensure that laboratory equipment is properly
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controlled and calibrated is a violation of TS 6.8.1 (Violation Nos. 50-456/g7003-
01c and 50-457/97003 01c).
The inspectors also identified deficiencies in the licensee's procedure (BwCP 210-4)
for the calibration of the high purity germanium (HPGe) detector, which the licensee
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used to analyze radioactive affluents for release to the environment and to analyze
potentially radioactive material for unrestricted release. Specifically, procedure
BwCP 210-4 did not specify instructions to ensure the validity of calibration
techniques. As required by the procedure, the licensee performed annual
calibrations for each HPGe detector and calculated new efficiency v. energy
standardizations. Following a calibration, the licensee compared the resulting
standardization to the previous calibrations to identify unexpected changes in the
detector's efficiency. The licensee also analyzed calibration standards (from
previous annual calibrations) to further ensure that the new calibrations were
acceptable, A member of the chemistry staff made a subjective judgement as to
the acceptance of these comparisons. Generally, the individual attempted to
investigate and resolve any comparisons of the above data which differed by more
than ten percent, indicating a potential problem with the new standardization.
Although the licensee's methods appeared acceptable, procedure BwCP 210-4 did
not direct these tests nor did it contain acceptance criteria to ensure that the new
calibrations were acceptable.
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TS 6.8.1 requires, in part, that written procedures be established covering the
applicable procedures recommended in RG 1.33, Appendix A, Revision 2, February
1978. RG 1.33, Appendix A recommends that procedures be implemented that
specify laboratory Instructions and calibration of laboratory equipment and
specifically states that extreme importance must be placed on laboratory
procedures used to determine concentration and species of radioactivity in liquids
and gases prior to release, including the validity of calibration techniques used in
these analyses. The failure to provide adequate instructions in procedure BwCP
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210-14 to ensurs the validity of the HPGe detector calibrations is a violation of TS
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6.8.1 (Violation Nos. 50-456/97003-01d and 50-457/97003-01d).
The inspectors also identified problems concerning the post accident sampling
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system (PASS) OC surveillance procedure and the PASS sampling procedures.
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Table i of procedure BwCP 323-13 contained the required frequency of PASS
performance checks. Procedure BwCP 323-13 required that the licensee perform
an isotopic analysis of identified PASS samples and compare the results to routine
sample results, if applicable. With some exceptions (Section R7), the inspectors
verified that the licensee had obtained PASS samples at the frequency defined in
BwCP 323-13. However, SwCP 323-13 and its implementing procedures did not
contain acceptance criteria for performing these comparisons or actions to take if
results were unacceptable. For example, the licensee's procedure did not contain
formal acceptance criteria to ensure that the dilution factor for the reactor coolant
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diluted sample was constant and to ensure that reactor coolant sample taken at the
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PASS were representative of primary coolant. The chemistry supervisor indicated
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that obtaining a volume of liquid or gas was an acceptable means of ensuring
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system capabilities. However, without analyzing and comparing the sample one
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could not be assured that the sample accurately represented the reactor coolant or
containment atmosphere at the proper dilution.
TS 6.8.4.d requires that a program be implemented which will ensure the capability
exists to obtain and analyze reactor coolant samples, radioactive iodine and
particulate samples in plant gaseous effluents and containment atmosphere samples
under accident conditions. Procedure BwCP 323-13 specified the required
frequency of PASS performance checks to ensure the capability of the system but
did not specify acceptance criteria for comparing isotopic analyses of the samples.
The lack of acceptance criteria in BwCP 323-13 to ensure the capability of the
system to obtain representative post accident samples is a violation of TS 6.8.4.d
(Violation No. 50-456/97003-02 and 50-457/97003-02).
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The inspectors identified that the licensee had designated procedures for obtaining
PASS samples (i.e. BwCP 703-2, 703-6, 703-9, 703-13, 703-17, and 703-21) as
" Reference Use". As defined in BwAP 100 20, " Reference Use" procedures were
procedures which have a routine impact on nuclear and personnel safety, and
" Continuous Use" were procedures which involve a high level of risk for nuclear
and personnel safety. Each step of " Continuous Use" procedures were to be read
prior to the performance of the step, whereas " Reference Use" procedures could be
referred to as needed. BwAP 100 20 also allowed for multiple steps to be
performed prior to completing " Reference Use" procedure signoffs. However,
BwCP 703-1 required that each post accident procedure be initialed at each step
performed by the sample team. Although designated as " Reference Use", the
PASS procedures directed personnel to handle highly radioactive samples under
accident conditions, which could potentially result in significant radiological
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consequences to personnel performing the sampling and which could potentially
provide a release path of highly radioactive gases and liquids. Based on the
procedure use definitions in BwAP 100-20, the directions for PASS procedure
usage in BwCP 703-1, and the potential safety significance of obtaining PASS
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samples during accident conditions, it did not appear that the designation of PASS
sampling procedures as " Reference Use" met the intent of the licensee's
requirements for the use of procedures.
c.
Conclusion '
Problems were identified concerning the adequacy of QC and PASS surveillance
procedures and the implementation of the interlaboratory program. Examples of
violations for inadequate procedures were identified concerning the lack of
acceptance criteria in the chemistry laboratory OC program and in the PASS QC
surveillances. The designation of procedural usage for PASS sampling procedures
did not appear to meet the licensee's procedure usage requirements.
R4
Staff Knowledge and Performance in RP&C
R4.1 33molina and Analysis of Primary Coolant
The inspectors observed a CT sample primary coolant and obtain stripped gas
samples. The CT demonstrated good analytical techniques and knowledge of
procedure requirements and references. The CT was also knowledgeable of the
expected concentrations found in the coolant and the licensee's limits for a variety
of specific analyses. The CT properly used an ion chamber to monitor the ambient
radiation dose rates in the sampling room and the dose rates of samples. The CT
demonstrated acceptable contamination control practices, with some minor
exception. The inspectors observed that the CT frequently manipulated highly
contaminated process sample lines then handled potentially uncontaminated items
(i.e. pens, instruments, test kits) without changing gloves. Although no violations
of procedures were identified, this practice increases the probability of spreading
contamination.
R4.2 Processina and Shioment of lon Exchance Resins
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a.
Insnection Scone (86750)
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The inspectors reviewed the licensee's actions concerning the deformation of an ion
exchange resin liner. The inspectors reviewed the licensee's investigation of the
demeged liner and discussed the event with the radweste shipping supervisor. The
inspectors also reviewed the resin dewatering evolution and procedure FO-OP-032,
" Setup and Operating Procedure for the RDS-1000 Unit," Rev.11.
b.
Observations and Findinas
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On January 22,1997, the licensee was preparing a shipment of radioactively
contaminated ion exchange resin for offsite burial. 'As the liner was lifted from the
process shield, the operator noted some resistance and identified deformation of
the sides of the liner. The licensee suspended the evolution and secured the liner
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within the shield. The liconsee also ensured that the contents of the liner were well
contained and had not leaked.
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The licensee performed a comprehensive review of the event and identified that an
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abnormality occurred during the dewatering of the resins. The vendor equipment
had lost power when the power cord was accidently unplugged by a station
laborer. After noticing the loss of power, the contractor performed a partial system
verification and restored power to the equipment. However, the system vent valve
automatically closed, per design, as power was restored to the unit and remained
closed during the remainder of the process. The licensee hypothesized that due to
a loss of the vent path, a vacuum resulted and the liner was subsequently
damaged.
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The licensee and the vendor notified other users of the problem. The licensee
suspended the use of the equipment and provided trcining of vendor personnel
regarding management expectations concerning abnorrnal occurrences. The
licensee also transferred the resins to a different liner for transport. At the time of
this inspection,- the licensee was evaluating potential changes to the vendor's
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equipment and to the applicable operating procedures.
The licensee and inspectors identified that procedure FO-OP-032 required a syt sm
verification prior to starting the unit. As part of the verification, the system vem
valve was to be in the open position. The licensee identified that the operator did
not perform the complete system verification in accordance with procedure FO-OP-
032. In addition, the licensee attributed the design function of the valve to the
occurrence.
TS 6.8.1 requires that process control program procedures be implemented. The
failure to properly implement procedure FO-OP-032 is a violation of TS 6.8.1.
However, this licensee-identified and corrected violation is being treated as a Non-
Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy
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(NCV 50-456/97003-03 and 50-457/97003-03).
c.
Conclusions
The licensee conducted a thorough review of the events which lead to the damage
of a container of ion exchange resins. One non-cited violation was identified
concerning the lack of adherence to process control program procedures.
R5
Staff Training and Qualification in RP&C
R5.1 Post Accident Samolina Svstem Trainino
The inspectors observed CT training on the PASS. During the training, the
instructor and participants discussed and demonstrated the use of procedure BwCP
703 21, " Post Accident and Normal Sampling of Containment Atmosphere in the
Manual Mode of Operation," Revision 2. The inspectors observed that the training
was very interactive and the discussions were thorough. The trainer emphasized
the potential radiological conditions of a PASS sample and the sample system. He
also stressed the importance of radiation exposure reduction techniques, e.g.
distance and time. The licensee performed the training on a mockup in the
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licensee's training center. Although the use of the mockup was a good initiative in
that it provided a simulation without dose consequences or potential operations
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consequences, the training system differed from the actual configuration concerning
the layout and labeling of certain valves and gages. The licensee indicated that an
evaluation would be conducted to determine how the mockup could better
represent the field conditions. Additionally, the trainer mentioned the use of remote
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tools to reduce dose in the field, but he did not indicate specifics as to what tools
were available, how they were to be used, or when they were to bo used. The
licensee also planned to better evaluate the use of remote tools and instruction in
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their use,
Ducing performance of procedure BwCP 703-21, the training system failed to
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properly operate. The trainer indicated that the system in the field had also
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responded in the same manner and that he and the system chemist were evaluating
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the adequacy of certain procedure steps. However, the inspectors discussed this
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with the system chemist who was unaware of the training problem and indicated
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that no such problem existed in the field. Although an operabi!!!y issue did not
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exist, a communications problem appeared to exist between plant pesonnel and
training personnel which could have confused the training participants. Following
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the training, the licensee discussed these issues with the cts to ensure that there
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was not any confusion.
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R7
Quality Assurance in RP&C Activities
The inspectors reviewed the licensee's most recent audit conducted by tho site
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quality verification (SOV) staff in September of 1995 and the chemistry staff's
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quarterly self assessments. Both self assessment activities were of good scope and
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were effective in identifying performance problems withirs the chemistry program,
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The inspectors observed that problems concerning the material condition cf the
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PASS and the conduct of PASS surveillances had been identified by the licensee
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and by NRC inspectors (NRC inspection Reports No. 50-456/96002 and 50-457/
96002). The inspectors observed some improvements in the area, but continued to
observe problems concerning the adequacy of procedures (Section R3.1) and in the
)
,
maintenance of the system. In June 1995, the licensee identified a problem with
a
the containment air sampling panel (CASP) circuitry which had sometimes resulted
{
in the disablement of a radiation monitor. When the gas partitioner module was
'
connected to the AC outlet within the CASP (as directed by procedure) or the light
within the CASP panel was activated, radiation monitor 1PR11J (containment
,
atmosphere) was disabled. However, as of the time of the inspection, the licensee
4
had not resolved the issue. The licenses had instncted personnel to power the gas
partitioner via an altemate receptacle, had placed a caution tag on the receptacle,
,
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and had tentatively planned on working the item in late February 1997. The
inspectors observed that this material condition problem created an impediment for
the chemistry staff and potentially effected the operability of a TS required radiation
monitor.
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R8
Miscellaneous RP&C lasues
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R8.1
(Closed) Insoection Follow-uo item No. 50-456/96015-02 and 50-457/96015-02:
'
The licensee planned to update section 11.2 of the Updated Final Safety Analysis
Report (UFSAR) to be consistent with current radioactive waste system status.
The inspectors reviewed section 11.2 and found the information to have been
updated and consistent. This item is closed.
!
R8.2 (Closed) Licensee Event Reoort (LER) 96-013: On December 5,1996, the licensee
>
identified that the alarm setpoints for containment fuel handling incident radiation
monitors (1/2AR011J and 1/2ARO12J) were not in accordance with TS Table 3.3-
,
!
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6. Table 3.3-6 requires the trip setpoint to be set at a level such that the actual
submersion dose in the containment building would not exceed 10 millirem per hour
!
(mrem /hr). The as found setpoints were 100 mrem /hr (alert) and 2000 mrem /hr
3
(high alarm). After identifying the problem, the licensee removed the monitors from
operation and redetermined the setpoints as required by TS Table 3.3-6. The
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licensee also indicated that the containment purge radiation monitors had setpoints
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which would have alarmed if radiation levels exceeded 10 mrem /hr above
i
background. The failure to adhere to TS Table 3.3-6 is a TS violation. However,
this licensee-identified and corrected violation is being treated as a Non-Cited
Violation, consistent with Section Vil.B.1 of the NRC Enforcement Policy (NCV 50-
,
,
456/97003-04 and 50-457/97003-04)
As additional corrective actions, the licensee verified that other radiation monitor
setpoints required by TS were consistent with the UFSAR descriptions and planned
to revise the UFSAR description of radiation monitors 1/2AR011J and 1/2ARO12J
to be consistent with the TS requirements. In addition, the licensee planned to
prepare setpoint justification documents for all area radiation monitors. The
inspectors planned to review these actions in future inspections (Inspection Follow-
'
up item Nos. 50-456/97003-05 and 50-457/9'/003-05).
V. Manaaement Meetinas
X1
Exit Meetina Summarv
The inspectors presented the inspection results to members of licensee management at the
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conclusion of the inspection on February 7,1997. The licensee acknowledged the
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findings presented. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
M. Cassidy, NRC Coordinator
A. Haeger, Hesith Physics and Chemistry Supervisor
M. Holmes, Lead Chemist
M. Gierscher, Radioactive Waste Shipping Supervisor
J. Kinsella. Site Quality Verification
T. Meents, Radioactive Waste Coordinator
T. Simpkin, Regulatory Assurance Supervisor
H. Stanley, Site Vice President
R. Thacker, Lead Health Physicist
T. Tulon, Station Manager
M. Vonk, Emergency Preparedness Director
INSPECTION PROCEDURES USED
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
Followup - Plant Support
ITEMS OPEN, CLOSED, AND DISCUSSED
Ooened
50-456/457-97003-01(a d)
VIO Failure to establish, maintain, and implement
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procedures recommended by Appendix A of Regulatory
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Guide 1.33.
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50-456/457-97003-02
Failure to establish adequate PASS procedures
50-456/457-97003-05
IFl
Licensee planned to revise UFSAR to be consistent with
Technical Specification Table 3.3 6 and planned to
create an area radiation monitor Justification document
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Closed
50-456/457-96015-02
IFl
Updating of UFSAR Section 11.2
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50-456/457-97003-03
NCV Failure to follow process control program procedures
50-456/457-97003-04
NCV Failure to follow Technical Specifications for radiation
monitor setpoints
1
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LIST OF ACRONYMS USED
AVT
All-Volatile Treatment
CASP
Containment Air Sampling Panel
CFR
Code of Federal Regulations
Chemistry Technician
High Purity Germanium
LER
Licensee Event Report
IFl
Inspection Follow-up item
i
MREM /HR
Millirem per hour
Molar Ratio Control
Non-Cited Violation
PlF
Problem Identification Form
PPB
Parts Per Billion
Parts Per Million
OC
Quali y Control
t
Radwaste
Radioactive Waste
)
Regulatory Guide
Radiation Protection
RPA
Radiologically Posted Area
Radiation Protection Technician
RP&C Radiation Protection and Chemistry
Site Quality Verification
TS
Technical Specification
,
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Updated Final Safety Analysis Report
VIC
Violation
,
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Partial List of Documents Reviewed
BwCP 600-1, " General Sampling Procedure," Revision 5, dated September 28,1995.
BwCP 600 3, " Sampling of Potentially Contaminated Liquids," Revision 2, dated
October 25,1996.
i
BwCP 613-9, "CVCS Letdown Heat Exchanger Grab Sample," Revision 5, dated April 15,
1994.
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BwCP 613-19, " Reactor Coolant Activity and Gaseous Samples," Revision 4, dated
October 5,1996.
BwRP 5820-5T1, "AR/PR Setpoint and Background Change Record," Revision 0 for
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1 ARO11 and 1 AR012 dated December 9,1996.
,
BwRP 5820 5T1, "AR/PR Setpoint and Background Change Record," Revision O for
2ARO11 and 2ARO12 dated December 9,1996.
" Prompt Investigation of Chem-Nuclear Systems, Inc.14-195FR Carbon Steel Liner
4
Collapse at Braidwood Station," prepared on January 25,1997 (Problem identification No.
d
456 201 97-0194).
" Recommended Practices for Nuclear Stations Chemistry Quality Control Program,"
November 1,1993,
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