ML20149J705

Insp Repts 50-456/97-11 & 50-457/97-11 on 970618-24.No Violations Noted.Major Areas Inspected:Plant Support Performance & Evaluation of Effectiveness of Radiation Protection Program

ML20149J705
Person / Time
Site:	Braidwood
Issue date:	07/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149J697	List: ML20149J694 ML20149J699 ML20149J705
References
50-456-97-11, 50-457-97-11, NUDOCS 9707290057
Download: ML20149J705 (12)

See also: IR 05000456/1997011

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION lli

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. Docket Nos-

80-456; 50-457

Licenses Nd:

NPF-72; NPF-77 -

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' Reports No:

50-456/97011(DRS); 50-457/97011(DRS)-

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Licensee:

Cornmonwealth Edison (CorrEd)

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Facility:

Braidwood Nuclear Power Station, Units 1 and 2

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Location:

RR #1, Box 70

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Braceville,IL 60407

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Dates:

June 18-24,1907

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Inupitetor:

S. Orth, Senior Radiation Specialist

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Approved by:

G. L Shear, Chief, Plsnt Support Branch 2

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Division of Reactor Safety-

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EXECUTIVE SUMMARY

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Braidwood Nuclear Plant, Units 1 & 2

NRC Inspection Reports 50-456/97011; 50-457/97011

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This announced inspection included aspects of licensee p' ant support performance and,

specifically, an evaluation, of effectiveness -of the radiation protection program. This report

covers a one-week period of inspection performed by a regional radiation specialist. One

violation was identified concerning the failure to adequately implement radiation protection

precedures used in radioactive waste activity deterrrinations.

Plant Support

Weaknesses were identified in radioactive waste activity determinations. Or.e

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violation was identified concerning the failure to adequately implement procedures

which provide reasonable assurance of radioactive waste activity determinations in

accordance with 10 CFR 61.55(a)(8). (Section R1.1)

The licertsee properly implemented the radioactive material shipping program.

Shipping procedures were consistent with the April 1,1996, revisions to 10 CFR Part 71 and 49 CFR Parts 172 and 173. Strengths in the preparation and control of

radioactive shipments were observed. (Section R1.2)

The radiological environmental monitoring program was properly conductad as

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required by the Offsite Dosc Calculation Manual. The inspector identified some

problems concerning the content of the 1995 and 1996 Annual Radiological

Environmental Operating Reports which indicated a lack of adequate review.

Although measurable levels of tritium were detected in environmental water

samples, no regulatory limits were exceeded. (Section R1.3)

The radioactive materials shipping training was consistent with the requirements of

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NRC and Department of Transportation regulations. The licensee maintained a list

of persons authorized to release radioactive shipments and maintained the training

qualifications or those persons. (Section R5.1)

The March 1997 audit of the radioactive wstte processing and transportation

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programs was a comprehensive review of program structure and procedure content

but was not a thorough review of program implementation. Immediate corrective

actions and lon;; term programmatic corrective actions were being implemented to

resolve the audit findings. (Section R6.1)

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Rep _ ort Details

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IV. Plant Succort

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Radlological Frotection and Chemistry (RP&C) Controls

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R I .1

Determinations of the Activity of Radioactive Waste Shioments

a.

Inspection Scoce (IP 867501

The inspector reviewed the licensee's method for determining the activity of

radioactive waste shipments. The inspector reviewed the 1994,1995, and 1996

annual waste stream analyses and the 1995 and 1996 quarterly verifications to

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ensure the validity of radionuclice scaling factors used to determine the activity of

hard to detect radionuclides. The inspector also reviewed the implementation of

procedures BwAP 3/1-3, "Braidwood Station Radioactive Waste Management

Program," Revision 4, and BwRP 5600 6, " Scaling Factor Determination," Revision

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b.

Observations and Findinas

in accordance with 10 CFR 61.55(a)(8), the radiation protection (RP) staff used

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scaling factors as an indirect method to determine radionuclide activity in

radioactive waste shipments. This is done by inferring a concentration of hard to

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detect radionuclides by applying scaling factors to a known concentrstion of an

easier to detect radionuclide, provided that there is a reasonable assurance that the

indirect method can be correlated with actual measurements. As required by BwAP

3713 and BwRP 5600-6, the licens6e analyzed samples from each of its six waste

streams (i.e. primary .esin, radioactive waste resin, secondary resin, primary filter,

radioactive waste filter, and dry active waste (DAW)) on an annual frequency and

calculated a scaling factor for each hard to determine radionuclide in each sample.

Based on the cumulative average of the scaling factors for each radionuclide, the

RP staff calculated a single set of current scaling factors for the hard to detect

radionuclides. The single set of current scaling factors was used to represent all of

the radioactive waste streams.

The inspector identified discrepancies concerning the scaling factor evaluations of

the annual weste stream sample results. Consistent with guidance contained in

NRC Information Notice No. 86-20, " Low-level Radioactive Waste Scaling Factors,

10 CFR Part 61," the licensee's procedures required the staff to compare the

scaling factors for each waste stream with the current scaling factors for each

radionuclide on an annual frequency. If any of the scaling factors calculated for an

individual waste stream differed from the current scaling factor by a factor of 10 or

more, step F.2.c of procedure BwRP 5600-6 required the licensee to note the result

as an outlier. In addition, the staff was required to remove the result from the

current scaling factor calculation and to obtain additional samples of the waste

stream for analyses. Hnwever, the inspector identified that additional samples

had not been obtained in 1996,1995, and 1994 for those waste streams which

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- had radionuclide scaling factors which differed by more than a factor of ten from

the current scaling factors:

'In 1996, the scaling factors calculated for plutonium 239, curium-242, and

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curium-244 differed by a factor of greater than ten from the' current scaling

factors for Primary Filter A and were denoted as outliers, in addition, the

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scaling factor calculated for carbon-14 differed fram the current scaling.

f actor by a factor of greater than ten for Primary Filter B and was noted as

an outlier. However, the staff did not obtain an additional sample of each

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In 1995, the scaling factor calculated for iron-SS differed by a factor of

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= greater than ten from the current scaling factor for radioactive waste resin A

and was noted as an outlier. 'However, the staff did not obtair an additional

sample for offsite analysis.

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(n mid 1994, the licensee performed a re-verification of the 1994 scaling

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factor analyses to ensure that fuelintegrity problems had ncit altered the

scaling factors for the waste streams. Hewever, the scaling factors

calculated for carbon 14, iron 55, nickel-3, and strontium-90 in secondary

. resin were not within a factor of tan of the current scating factors. In

addition, the scaling factors calculated for strontium-SO in both radioactive

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waste filter samplea and for nickel-63 in DAW were not within a factor of

ten of the current scaling factors. However, the staff did not obtain an

additicnal sample of each waste stream for offsite analysis.

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The inspector noted that the above differences between the current scaling factors

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and the individual wasta stream scaling factors were' generally conservative.

Although the RP staff hed net adequately performed the required actions to ensure

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that the current scaling factors were acceptable for the individual waste streams

described above, the inspector concluded that the differences would not have

caused the waste classifications to have been incorrect.

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10 CFR 61.55(a)(8) requires, ir, part, that the licensee provide reaacnable assurance

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- that the indirect method for determining the concentration' of a radionuclide can be

correlated with actual measurements. Procedure BwRP 5600-6 provided the

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licensee's requirements for ensuring that the indirect method (i.e. scaling ftctor)

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could be correlated with actual waste stiaarr measurements. The failurt to obram

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additional samples of waste streams when the measurements did not correlate as

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required by procedure BwRP 5600-6 is a violation of 10 CFR 61.55(a)(8). (VIO 504

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456/97011-01(DHS); 457/97011-01(DRS))

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The inspector also identified problems concerning the quarterly verification of waste

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strearn scaling factors. As required by procedure SwRP 5000-6, the RP ataff

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, monitored the ratio of iodine-134 to cobalt 60 in reactor coo; ant to identify any

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potential change that might affect the distribution of radienuclides in the 'Nante

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streams'(i.e/ scaling factore).' . Although procedure BwRP 5600-6 recommended

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.'that the quarterly verification be performed within six weeks of the end of the -

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quarter, the inspactor noted that the RP staff routinely did not perfrvm the

verification antil ten to twelve weeks after the end of the quarter. The inspector

noted that,' potentially, this would delay the identification of a change in the scaling

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factors. The HP staff attributed the delay to an error in the surteillance scheduling

program, which was corrected, in addition, RP personnel noted a calculation error

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for the second quarter of 1936. In March of 1997, a member of the RP staff was

reviewing the 1996 data and noticed that incorrect data had been used in the

secono quarter calculation. The individual re-performed the calculation and .

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obtained the correct result, & L was outside of the required acceptance criteria.

Since the calculation was initiady in error, the licensee had not taken actions

recornmanded by the procedure to investigate the discrepancy. The inspector.

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verified that the third and fourth quarter comparisons were within the acceptance:

= criteria. The licensee also identified (Section R6.1) soma technical probleme

concerning the radionuclides used in the ratio and was oeveloping corrective

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actions.

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Conclusions

Weaknesses were identified in.the radioactive waste activity determir..tions. One

violation was identified conceming the failure to adequately implement procedures

which provide reast,nable assurance of radioactive waste activity determinations in

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accordance with 10 CFR 61.55(a)(8). Although the licensee did not perform

required actions to investigate discrepancies between the' annual scaling factor

determinations and the current scaling factors, the differences between the actual

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measurements and the current scaling factors were generally conservative and

would not have changed waste classifications, in addition, the quarterly scaling

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factor verifications were not performed in a timely mannes.

R1.2 Hansportation of Radiga.ctive M,gtarials

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jnspection Scope (IP 86750 and Tl 2515/133_1

The inspector reviewed the following procedures to ensure that they were

consistent with the April 1,1996 revisions to 10 CFR Part 71 and 49 CFR Parts

172 and 173:

BwRP 5600 4. " Completion of Radioactive Material Shipping Record,"

Revision 4E2;

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BwkP 5600-7, " Shipment of Radioactive Materials," Revision 3E1; and

BwRP 5610-6, " Surveying Radioactive Material Shipments," Revision 3E1.

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The inspector also reviewed the shipp ng documents for the following radioactive

waste bbipments including the packago classifications and labeling and shipping

papers:

RWS97-001 De-watered son Exchange Resins (2/11/97);

RWS 97 004 DAW (4/23/97); and ~

RWS 97 005 De-watered lon Exchange Resins (5/30/97).

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The inspector also observM Ge preparation of two containers of DAW (RSW 97-

006) for shipment to a < sctive waste processor.

b.

Qbservations and Findings L

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The licensee's procedures properly reflected the requirements of 10 CFR Part 71

and 49 CFR Parts 172 and 173. In accordance with the revisions to the

regulations, procedure BwRP 5600-7 contained appropriate instructions for

determinin0 the classification of shipments, inc!uding the requirements for low

specific activity (LSA-l, LSA-II, and LSA-Ill) materials and surface contorninated

objects (SCO-1 and SCO-II). The inspector also noted that the procedure contained

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the revised A1 and A2 values contained m 49 CFR 173.435. A March 1997 audit

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of this area (Section R6.1) identified some discrepancies in the procedures,' which

, were corrected. However, the licensee's procedures did not ccntain the

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requirement that the external dose rate at three meters from unshielded material-

must not exceed 1 rem /hr for LSA materials and SCOs (49 CFR 173.4.27(a)(1)). In

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addition, procedures did not contain instructions to ensure that the radioactivity .

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within LSA materials was adequately distributed. Members of the RP staff

indicated that a procedure revision was in progress to insert the three meter dose

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rate requirement.and that the corporate RP staff was developing an LSA definitior

to ensure the appropriate distribution of radioactivity within the package.

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As allowed by the licensee's procedures, the RP staff used a vendor supplied

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ccmputer program to classify the snipment and prepare the required shipping

documents. The inspector reviewed the classification of the shipments and did not

identify any problems and noted that the shipping documents were properly

prepared. However, certain documents contained severalline-out corrections which

affected the legibility of the documents, The International System of Units (SI) was

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properly used for the activity of the shipments au requir d by the regalations and

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licensee procedures. The shipping documentation als-

icluded emergency

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On June 18-23,1997, the inspector observed t

aparation of two containers of

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DAW (RSW 97-006) for shipment to a waste pn assor. An RP technician

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conducted a survey of the package and transpon vehicle in accordance with

procedures and properly posted the surrounding area as a radiation area. The .

insoector performed confirmatory surveys 'which were in good agreement with the

licensee's results. Based on the dose rate measurements and the scaling factor

analysis, the RP staff calculated the activity of the shipment and classified the

shipment as LSA-II. The inspector noted that the licensee performed a thorough

inspection of the intended transport vehicle, which had incurred an accident enroute

to the station. Based on questionable, physical damage to the vehicle and a visible

oil leak, the vehicle failed the insoection, and the shipment was postponed until an

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additional vehicle arrived at the site. Prior to securing the containers on the vehicle,

the inspector observed good communications between the RP staff and the driver

of the vehicle. The RP technicians clearly communicated the radiological status of

the packages and requirements, in addition, the RP technicians closely monitored

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the driver and infortned him of dose rates. The package was propstly marked, the

vehicle was proper!y placarried, and the shipping papers were completed as

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required.

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b.

CondyMons

The licenseo properly implemented the radioactive material shipping program.

Shipping procedures were consistent with the April 1,1996, revisions to 10 CFR 1

Part 71 and 49 CFR Parts 172 and 173. Strengths in the preparation and control of

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radioactive shiprnents were observed.

R1.3 Radioloaig_aignvironmenta_I f;&on.itoripa Program (REMP)

I,1soection Scgce (IP 84750)

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The inspector reviewnd the implementation of the radiological environmentat

monitoring program (REMP) including the tesults contained in the 1995 and 1996

Annual Radiological Environmental Operating Reports. The inspector also observed

a technician obtaining enviror' mental water and air filter samples.

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Observations and Findinog

The inspector compared the requirements of the Offsite Dose Calculation Manual

(ODCM) to the 1995 and 1996 Annual Radiutogicai Environmental Operating

Reports ared identified sorna problems with information in 1he reports. For example,

the ODCM required thermolumine.nent dosimeters (TLDs) in each meteorologica'

sector. However, the annual roports were in error concerning the location of two

TLDs and indicated that TLDs were not located in the northeast sector of the inner

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ring and the southeast sector of the outer ring. The inspector verified via the

licensee's sample location map that TLDs were loca'.ed in all meteorological sectors.

In addition, the ODCM required a land use census be performed which includes an

enumeration nf fivestock within a distance of 10 kilometers of the site. Although

the land use census information was contained in the annual reports, the reports

did not contain any enumeration of the livestock. The inspector found additional

minor errors in the reports and a lack of information regarding certain sample

anomalies.

The sample results of the 1995 and 1996 REMP were below the reporting limits

contained within the ODCM, With the exception of tritium in water samples, there

was no measurable amount of radioactivity found in environmental samplos

attributable to plant operations. However, the licensee detected tritium in samples

obtained from offsito wells and from the Kankakee River a*. activities of 250 to

1500 picocuries per liter (pCill). At the intake to the Wilmington water intake

facility, tritium was detected at concentrations of 500 to 750G pCi/l Although the

tritium activity was below the ODCM reporting levels and 40 CFR Part 141 drinking

water standards, the licensee was taking measures to minimize the levels at

Wilmington. For example, the operations strff was attempting to conduct liquid

releases from the site so that the releases would pass the W!!mington facility when

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it was not processing water. The staff was also evaluating the effects of Kankakee

River flow and love! on transit times from the station to the Wilmington facility.

On June 20,1997, the inspector observed the routine, weekly colleution of

environmental ' water and air filter samples. The technician demonstrated good

analytical technique. Prior to collecting a surface water sample, the technician pre-

rinsed the sample containers with the intended sample to limit the potential of

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chernicd contamination. The technician also tested the ali sample trains to ensure

that in-leakage (l.a. particulate / charcoal filter bypass) was minimized. The air

sample equipment was in good rnaterial condition,

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The REMP was properly conoucted as required by the ODCM. The inspector

identified some problems concerning the content of the 1995 and 1996 Annual

Radiological Environmental Operating Reports which indicated a lack of adequate

review, Although measurable levels of tritium were detected in environmental

water samples, no regulatory limits were exceeded.

lR5

Staff Training and Qualification in RP&C

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115.1 Radioactive Materials Transoortation Training

a.

Inspection Scone (IP 8_6750 and Tl 2515/133)

The inspector reviewed the licensee's radioactive material training program

including ncrsonnel training records and training lesson plans. The inspector also

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reviewed the following training lesson plans with respcot to the April 1,1996,

revision to NRC and Department of Transportation (DOT) regulations:

Rcdioactive Material Shipping, Initial Training, Revision 1;

Level 11 Radioactive Materials Shipping Training, Fuel Handler / Station Laborer

Personnel, Revision 2; and

Level ll Radioactive Materials Shipping Training, Quality Control Personnel,

Revision 2.

In addition, the inspectors observed portions of training.

b.

Observationa and Findinas

The licensee listed those persons authorized to release radioactive material

shipments in Radiation Protection Policy Memorandum No. RAS-04, Revision 5.

Based on training records, the inspector verified that those persons listed on the

memorandum had successfully completed training, in addition, each person on the

authorization list had completed training as of March 1996, which reflected the

April 1,1996, revision to the NRC and DOT regulations.

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The inspector reviewed the training lesson plans, which were consistent with the

NRC and DOT regulations. The lesson plans included information on NRC and DOT

regulations, the NRC Technical Position on weste form, and burial site disposci

criteria. Lesson plans also contained infornmtion concerning LSA and SCO package

classifications. On June 18,1997, the inspector observed a segment of a training

session and observed good discussions concerning burial site disposal citeria.

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Conclusions

The radioactive materials shipping training was consistent with the requirements of

NRC and DOT regulations. The licensee maintained a list of persons authorized to

release radioactive shipments and maintained the training qualifications of those

persons.

R6

Quality Assurance in HP&C Activities

R6.1 Audits of the Radioactive Material Shiocina Proaram

a.

Lnapection Scope (IP 86750 and Ti 2515/133)

The inspector reviewed the results of a March 1997 audit of the radioactive waste

mana0ement and radioactive material transport program. The inspector reviewed

the scope of the audit observations and the effectiveness of the licensee's

corrective actions.

b.

Observations and Findinas

Following NRC findings at a different licensed site, the licensee conducted a week-

long review of the Braidwood Station program to ensure that similar problems were

identified and corrected. The audit team consisted of experienced corposte and

contract personnel.

The audit team found the radioactive waste management and radioactive shipp;ng

programs to function as intended. However, the audit documented a number of

weaknesses and areas for improvement including training, content of procedures,

site quality assurance oversight, and waste activity characterization. For example,

the auditors found that personnel had received the applicable training but the

licensee did not have a clear policy for hazardous material training, in addition, the

auditors identified a number of procedure errors. The auditors also reported that

the station's quality assurance oversight of the program was limited. The inspector

noted that the licensee had taken immediate corrective actions and had planned

programmatic corrective actions to resolve the audit findings.

The inspector noted that the March 1997 audit was focussed on programmatic

issues and lacked a review of performance based issues. For example, the audit did

not identify the procedure adherence problems concerning scaling factor

determinations (Section R1.1) identified by the inspector. Although the audit raised

good technical questions regarding the program's stn.cture, the auditors did not

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appear'to comprehensively review the implementation of the program. A corporate

RP representative ' acknowledged the inspector's observations and indicated that the

objective of the audit was to ensure that programmatic issues did not exist, and

that program implementation was planned to be reviewed in subsequent audits.

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Conclusiong

The March 1997 audit of the radioactive waste processing and transportation

prograrn was a comprehensive programmatic review but did not thoroughly review

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program implementation. Immediate corrective actions and long torm programmatic :

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corrective actions were being implemented to resolve the audit findings.

V. Mg_npuoment Meetinas

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Exit Meetina Summary

The inspector presented,the inspection results to members of licensee management at the

conclusion of the inspection on June 24,1997. The licensee acknowledged the findings

presented.' No proprietPry information was identified.

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. PARTIAL LIST OF PERSONS CONTACTED

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SiBell, Corporate Health Physics

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'M. Gierscher, Radwaste Shipping Supervisor l,

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. A. Haeger, Health Physics and Chemistry Supervisor

Er Hendrix, Operations Staff Supervisor

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C. Herzog, Executive Assistant-

T. Meents, Radwaste Coordinator

J. Meister, Engin'eering Manager

R. Thacker, Lead Health Physicist

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INSPECTION PROCEDURES USED

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':lP 86750 -

Solid' Radioactive Wasto' Management and Transportation of Radioactive

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. Materials

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Tl 2515/133' implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71

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ITEMS OPEN, CLOSED, AND DISCUSSED

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50-456/457-970011-01

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Failure to adequately implement procedures

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concerning the calculation of radionuclide scaling

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LIST OF ACRONYMS USED

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DdW; '

fDry Act!ve Waste.

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1. Inspection Procedure.

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LSA: .

Low Specific Activity.

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ODCM

. Offsite Oose Calculation Msnuan

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'REMP

Radiological Environmental MonitoCng Program:

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Radiation Protection'-

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Surface Contaminatod Object

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.intemationel System of Units -

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"TLD -

Thermoluminescent Dosimeter

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LViciation

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PARTIAL LIST OF DOCUMENTS REVIEWED -

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Annual Scating Factor Determinations for 1994 1995, and 1996.

Draidwood Station Annual Radiological Environmental Operating Reports for 1996 and.

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1996,

Ouality Services Audit Report DG-97-13/BWD, dated March 10,1997.'

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Radiation Protection Pflicy Memo No. RAS-02, Revision 4.

Radiation Protection" Policy Memo No. RAS-04, Revision B.

. Waste Stream' Character Verification Worksheets (BwRP 5600-6T6 arid BwRP 56004T7),

. dated April 17,1995, July 28,1995, November 17,1995, March 13,:1996, M,sy 22,

1996, Docsmber 20,1996, and March 4,1997.

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