IR 05000456/1986017

Insp Repts 50-456/86-17 & 50-457/86-15 on 860422-25.No Violation of Deviation Noted.Major Areas Inspected: Radiological Environ Monitoring Program,Including Implementation & Results & Licensee Internal Audits

ML20197E666
Person / Time
Site:	Braidwood
Issue date:	05/12/1986
From:	Holtzman R, Oestmann M, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197E617	List: IR 05000456/1986017 ML20197E611
References
50-456-86-17, 50-457-86-15, NUDOCS 8605150296
Download: ML20197E666 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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Report Nos. 50-456/86017(DRSS); 50-457/86015(DRSS)

Docket Nos. 50-456; 50-457 License Nos. CPPR-132; CPPR-133 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: April 22 - 25, 1986 i)i 0.duw Inspectors: M. J. Oestmann

Date 4!Il R. B. Holtffnan 5/9/85 Da'te '

Approved By S ef $2h Radiological Effluents Date and Chemistry Section Inspection Summary Inspection on April 22-25, 1986 (Inspection Report Nos. 50-456/86017(DRSS);

50-457/86015(ORSS))

Areas Inspected: Routine announced inspection of: (1) radiological environmental monitoring program (REMP) including implementation and results, management controls, and quality assurance; (2) chemistry / radiochemistry program, including water chemistry control, procedures, facilities, management controls, training and qualifications, licensee internal audits, quality assurance and quality control; and (3) actions taken regarding previous open item Results: No violations or deviations were identified, g605150296860512 O ADOCK 05000456 l PDR

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DETAILS 1. Persons Contacted

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• E. E. Fitzpatrick, Station Manager, Braidwood (Bwd)

• C. W. Schroeder, Services Superintendent, Bwd

• L. E. Davis, Assistant Superintendent, Technical Services, Bwd

• R. D. Kyrouac, Station Quality Assurance Supervisor, Commonwealth Edison Company (CECO)

• P. L. Barnes, Regulatory Assurance Supervisor, Bwd

• R. R. Fay, Training Instructor, Bwd

• E. McGee, Training Supervisor, Bwd

• A. Hoffer, Quality Assurance Supervisor, Bwd

• E. Aker, Radiation Chemistry Supervisor, Bwd

• J. K. Jasnosz, Engineer, Regulatory Assurance, Bwd

• T. W. Simpkin, Engineer, Regulatory Assurance, Bwd

• A. D. Miosi, Nuclear Licensing Administrator, Bwd i *L. A. Literski, Emergency Plan (GSEP) Coordinator, Bwd

• M. J. Andrews, Station Chemist, Bwd

• D. E. Pravette, Assistant Superintendent, Bwd E. Carroll, Radiation Protection / Chemistry and Emergency Response Supervisor, Production Training Cen+er D. M. Keneally, Environmental Health Physicist, CECO M. E. DiPonzio, Emergency Planning Supervisor, Environmental Health Physics Section, Ceco

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T. Keith, Station Health Physicist, Bwd

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J. Burns, General Chemist, Bwd C. Ross, Chemist, Bwd R. F. Rysner, Chemistry Engineering Assistant, Bwd M. A. Melnicoff, Assistant Technical Staff Supervisor, Bwd

• C. Schumacher, NRC Region III -

i The inspectors also interviewed several other licensee personnel during the i

course of the inspection, including chemistry and health physics personne * Denotes those present at the plant exit interview on April 25, 198 . Licensee Action on Previous Inspection Findings (0 pen) Open Item (50-456/810XX-01): NRC to collect water samples from Braidwood city wells and wells from the Thelma Corbin Farm in Wilmington, Illinois, after the Braidwood Station is in operation, and to analyze for gross alpha, gross beta, gamma analysis, and tritiu In 1980 preoperational samples of the T. Corbin farm well water and-Braidwood city wells were collected and analyzed. Results indicated that levels of radioactivity were within those found in northern Illinois due to the presence of the naturally occurring radium and daughters and potassium-40. This item will remain open until samples

are collected and analyzed after the plant becomes operationa .

b. (0 pen) Open Item (50-456/84003-01; 50-457/84003-01): Establishment and implementation of generic and site specific training programs for Radiation Chemistry Technicians (RCTs). The inspectors reviewed the progress made in establishing and implementing both generic and site specific training programs for the RCTs. Twenty-nine RCTs have completed the generic training program presented by training personnel at the Production Training Center, and five of these RCTs have already completed their qualifications / certification for on-the-job training (0JT). The remainder will complete their OJT and be qualified /

certified in accordance with the RCT training manual.before the issuance of the fuel load operating license (FLOL). This item will remain open pending completion of the RCT training qualification and certification program for the 29 RCT c. (Closed) Open Item (50-456/84003-02; 50-457/84003-02): Review and approval of BwCDs and BwPDs by Bw0SR, including review of Procedure BwAP 550-3. Procedure BwAP 550-3 was reviewed and approved on March 13, 1986 by the Braidwood Station Onsite Review Board (Bw0SR)

to include the requirement that the program descriptions (BwPDs) will be reviewed and approved by Bw0SR. The licensee's Bw0SR has performed this review and approved 16 BwPDs which are now included in the Bw Chemistry Procedure (BwCPs). This item is considered close d. (0 pen) Open Item (50-456/84003-03; 50-457/84003-03): Implementation of Chemistry / Radiochemistry QC program and revision of BwPD 200-1 to include a radiochemistry QA/QC program. Procedure BwPD 200-1 was revised and included in Procedure BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 2, February 18, 1986 to include a section on radiochemistry controls relating to counting room instrumentation. A QA/QC program has been developed and partially implemented for calibration and performance checks of instruments, and evaluation of the RCTs. This item will remain open pending modification and full implementation of the program, as discussed in Section 9 of this repor e. (Closed) Open Item (50-456/84003-04; 50-457/84003-04): Licensee to correct exhaust, leakage around charcoal adsorbers, map of REMP

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stations, and lock problems on REMP air sampling stations. . During a tour of the air sampling stations, the inspectors observed that the exnaust was vented away from the intake, lock probl. ems were resolved, and the air trains around the filters were corrected to avoid leakag The charcoal adsorber holders had been removed, but they are scheduled for installation (Section 5 this report). The inspectors also noted that the map (Figure 6.1-7) in the licensee's Environmental Report -

Operating License Stage, showing the air sampling locations, had been corrected in Amendment 7 of the ER-OL. This item is considered close , , _ -

l Management Controls and Organization The inspectors reviewed the management controls and organization for implementation of the REMP and found them to be the same as described in a previous inspection .1 The Corporate Supervisor of Emergency Planning has overall responsibility for conduct of the REMP, including administering the contract with Teledyne Isotopes, Inc. Teledyne personnel collect the REMP samples and perform the necessary analyses of the various environmental media. The inspectors also observed that the weekly collection sheets for 1985 to date used by Teledyne to record sample collection information had been reviewed by plant health physics personnel and the GSEP coordinato Furthermore, the coordinator inspects quarterly each air sampling station to assure that it is operational and properly maintained. The inspectors also noted that a Station QA auditor accompanied the Teledyne sample collector periodically to assure that all samples were collected according to a prescribed schedule in accordance with licensee commitments in Table 6.1-10 of the ER-OL. No problems were noted in management controls of the REM The inspectors reviewed the licensee's management controls and organization of the Radiation-Chemistry (R/C) Group for implementing the chemistry /

radiochemistry and health physics programs. The R/C Supervisor, who reports to the Assistant Superintendent for Technical Services, supervises the Station Chemist and Station Health Physicist. The Station Chemist, in turn, supervises four other chemists, a Chemistry Engineering Assistant, an Engineering Aide, and two Laboratory Foremen. These Foremen and the Health Physics Foremen supervise the 29 RCTs and direct the on-the-job training and job assignments of the RCTs assigned to the chemistry laboratories and health physic The licensee plans to hire 10-15 new RCTs in the near future who will begin their 14 week generic training program at the Braidwood Production Training Center on June 23, 1986. These 10-15 RCTs will not be. fully trained until 5% power is obtaine The RCTs are scheduled to rotate between the Health Physics and Chemistry Groups such that each RCT is out of the Chemistry Group for a period of 10 weeks. This absence from the laboratory results in a loss of laboratory proficiency. The licensee is attempting to minimize this problem by restricting the absence to about three weeks. A licensee representative reported that they have under consideration permanently assigning each RCT to one group or the other. As yet, no decision has been mad Each chemistry staff member has specific work assignments. The inspectors'

review of these assignments identified no problem No violations or deviations were identifie Inspection Reports No. 50-456/84003; 50-457/84003 l

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_ _ _ _ _ Training and Qualification The training and qualifications of the Chemistry Group personnel in responsible positions were reviewed. The Station Chemist and his chemistry staff each have bachelor's degrees in Chemistry. Both Chemistry Laboratory Foremen have had several years experience at other licensee operating plants. One has had only four months experience as foreman at Braidwood, while the other's experience as foremen has been several years at the licensee's Dresden Plant and two years or more at Braidwoo From the inspectors' review of their qualifications and position descriptions, and interviews with the chemistry staff, it appears that they are knowledgeable in chemistry principles and practices and meet the requirements in Section 4 of ANSI /ANS 3.1-197 No problems were noted in the qualifications of the chemistry staf Currently there are 29 RCTs, five of whom have completed both generic training at the Production Training Center (PTC) and site specific training to be qualified and certified in accordance with the RCT training manua '

The remainder have already completed the generic training and are presently completing the 0JT for certification. Details of the generic training were presented in a previous inspections . The inspectors also reviewed this program at the PTC and identified no problems. Both lectures and hands-on-experience are presented to the RCTs by qualified instructors. Each RCT has to satisfactorily pass the generic program before being eligible to start the site-specific on l The inspectors reviewed the site specific training program, which also includes OJT, supervisory observation, and a certification program to demonstrate proficiency in performing analytical measurements. The licensee established satisfactory acceptance criteria to assure that a RCT is prope.rly trained. Inspectors' discussions with different RCTs, observation of their performance in sampling and analysis, and review of selected certification records indicate that they are adequately trained for their functions. Completion of the training of the 29 RCTs for FLOL readiness will be examined during a subsequent inspection (0 pen Item No. 50-456/84003-01; 50-457/84003-01).

The licensee also plans to initiate generic training for 10-15 newly hired RCTs on June 23, 1986 and to have them certified by 5's powe No violations or deviations were identified. Radiological Environmental Monitoring Program (REMP)

The inspectors reviewed the licensee's preoperational REMP, initiated in July 1983, to assure that it met the requirements in Table 6.1-10 of the ER-OL. Monthly and annual reports for 1984-1985 to date were reviewed and all samples were accounted for. Appropriate reasons were given for missing samples. The licensee informed the inspectors on May 5, 1986 that 8 Ibid

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placement or charcoal adsorbers in the air samplers had been completed on May 2, 1986. The licensee also plans to place three additional air samplers in the field by the Fall 1986. These will not be required for the FLOL, but they will be required for 5% powe (0 pen Ite No. 50-456/86017-01; 50-457/86015-01) .

Review of data in the reports indicated no anomalous results. The inspectors also reviewed the weekly collection data sheets _ for 1985. They found appropriate explanations for problems encountered during sample collection by the licensee's contractor Teledyne Isotopes. The data sheets had been reviewed by the GSEP Coordinator and other licensee personnel to verify that all samples were collected on schedul The inspectors toured several environmental stations including air sampling, TLD, and an intake water station. No problems were noted in the operation of any of the air samplers. Calibration stickers showed that each sampler had been calibrated on a monthly schedule using a Rotameter-flowmete The inspectors also reviewed the log sheets of quarterly checks made by-the GSEP coordinator of the air samplers. Problems were promptly reported to the corporate office responsible for the conduct of the REM The inspectors also noted during review of the Teledyne monthly and annual reports that the contractor conducts his own internal QA/QC program by analyzing blind, blank, and replicate samples and participates in the EPA cross-check program. The contractor's QA manual was reviewed and no problems were identifie No violations or deviations were identified.

6. Water Chemistry Control Program The inspectors reviewed the licensee's PWR Water Chemistry Control Program (Nuclear Stations Division Directive [NSDD-501] issued on September 9, 1983). This program adequately addresses management' policies, assignments of authority and responsibilities to implement the program, and'provides appropriate guidance on operational chemistry limits designed to minimize localized corrosion in steam generators and turbines. An analytica measurements program, performance monitoring of the program, data' manage-ment and trending, and training requirements are include Management responsibilities described in the directive include providin adequate resources of staff equipment, funds, and organi:ation to implement the program to avoid corrosion of the secondary system. Action levels are to be implemented whenever an off normal value-is detecte The inspectors confirmed that the station plans to implement.this directive through Procedure BwCP PD-4, "Braidwood Station Secor.dary Water Chemistry Control," Revision 0, approved by Bw0SR on February 22, 1985. The licensee'

has established action levels for off-normal conditions and plans to plot trends of key chemical parameters once the plant is operational. The procedure is consistent with the PWR Owners' Group Guideline _ _._--_ _ __ _

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The inspectors determined that the licensee is just initiating this program. Hot functional tests have been completed on Unit 1 and the plant construction is being completed in preparition for the FLOL. The full implementation of the licensee's secondary water chemistry control program will be examined in subsequent inspection .

No violations or deviations were identifie . Other Management Programs The inspectors reviewed the licensee's program to restrict and control the use of chemicals throughout the plant to maintain system integrit The program is outlined in BwAP 550-15, "Braidwood Station Chemical Control program," Revision 0, approved by Bw0SR on January 14, 1986. This vocedure follows guidance from INPO CY-703, " Good Practices for the Control of Chemicals in Nuclear Power Plants." Another procedure, BwAP 550-14, "Braidwood Station Product / Chemical Usage," Revision 0, approved January 14, 1986, is also useful for controlling the use of chemicals in the plant. These procedures will be helpful in maintaining long-term preservation and safety of the plant, and to assure the safety of the workers involved in handling the chemicals use No violations or deviations were identifie . Implementation of the Chemistry and Radiochemistry Program The inspectors reviewed the primary and secondary chemistry programs including the physical facilities, laboratory operations, counting room, procedures, and practices followed in the cold and hot laboratories and counting roo Laboratory space, including fume hood space in both the hot and cold laboratories, appeared to be adequate. Ventilation in the laboratories and the hoods was adequate. The hoods are checked daily to assure that adequate ventilation is available during chemistry operation Housekeeping was goo The laboratories are well supplied with modern computerized instrumentatio Each instrument was found to be well-

, maintained, operable, and calibrated with current calibration sticker Chemical balances are calibrated every six months by a vendor. Reagent bottles were found to be properly labeled. No solutions or chemicals were found to have passed their posted expiration date New instruments with improved sensitivities include the Perkin-Elmer Model 5000 atomic absorption spectrophotometers with graphite furnaces, two Hitachi 110 uv/ visible spectrophotometers, automatic boron titration instruments, gas and ion chromatographs, pH and specific ion probes, conductivity meters, and total organic carbon analyzers. The instruments were used during the hot functional tests to measure key chemical pa rameters. Review of log sheets for the tests indicated no problem e Thecountingroomhasradiochemistryequipmentofhighquafity,, Each of four shielded high purity Ge detectors was controlled by one of two ORTEC

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multichannel analyzers and their associated PDP 11/44 computers. The room also contains three Canberra alpha-beta multi-sample proportional counters and two Packard TriCarb liquid scintillation counters. The only opera-tional systems are two of-the Canberra counters. The licensee plans to calibrate two gamma detectors and the. liquid scirtillation counters by July 1, 1986. At that time the licensee will be ready to accept spiked radioactive samples for the confirmatory measurements inspection program

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to be completed prior to FLO Selected chemistry procedures (BwCPs) for various analyses and surveillances (listed below) were being implemented. They had been approved by the Bw0SR Board during 1985 and 1986. No technical problems were noted during a review of the following procedures:

BwCP 103-12 Total Organic Carbon Determination BwCP 110-2 Nitrate Determination'Using Hitachi Spectrophotometer BwCP 110-5 Hydrogen Determination Using Hitachi Spectrophotometer BwCP 120-1 Fluoride Determination BwCP 120-2 pH Determination - Altex 5000 BwCP 120-4 Low-Level Chloride Determination - Altex 5000 BwCP 120-5 Dissolved Oxygen Determination - Altex 5000 BwCP 130-2 Automatic Determination of Metals by Flame

', Ionization (Perkin-Elmer 5000)

BwCP 130-4 Automatic Determination of Low-Level Metals Using

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the HGA Graphite Furnace (Perkin-Elmer 5000)

BwCP 140-2 Anion Determination Using the Dionex 20201 Ion Chromatograph BwCP 140-4 Hydrogen Determination Using the Tracor 565. Gas Chromatograph BwCP 300-1 Primary System Surveillance Procedure BwCP 310-1 Secondary System Surveillance Procedure BwCP 310-4 Steam Generator - Primary to Secondary Tube Leak Rate BwCP 323-4 Makeup Demineralizer Surveillance Procedure BwCP PD-1 Braidwood Station Primary Chemistry Program BwCP PD-5 Braidwood Station Chemistry Hot Functional ,

Test Program c l The licensee is preparing Technical Specification requirements for primary and secondary chemistry systems. Review of wiected log sheets, such as for the hot functional tests, indicate that the licensee has been analyzing for pH, specific conductivity, cation conductivity, dissolved oxygen, chloride, fluoride, boron, hydrogen, and' other key chemical parameter No problems were identifie ,

Based on observations of RCTsa cerforming chemical analyses and discussion with licensee representatives, the licensee appears knowledgeable in performing nonradiological chemistry analyses. However, the licensee has yet to demonstrate capability of working with radioactive samples. This

, item will be reviewed in a future inspection under Open Item 50-456/84003-01; 50-457/84003-0 '

No violations or deviations were identified,

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9. Implementation of the QA/QC Program in the Chemistry and Radiochemistry Laboratory The inspectors reviewed the Chemistry and Radiochemistry QA/QC program described in BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 2, February 18, 1986, relating to instrumentation calibration and instrument performance, and BwCP PD-8, "Braidwood Station Chemistry Performance Evaluation Progiam," Revision 0, January 9, 1985, which describes the testing of techrician analytical performance. More detailed aspects of the program a t presented in the BwCP 500 series procedures, with schedules for instrument calibration in BwCP 500-1 and for performance checks in BwCP 500-2. Other procedures refer to the quality and labeling of chemicals and reagents. Instructions for calibrations and performance checks are ;iven in procedures for specific analyses. Daily performance checks are required only for counting instruments. The check data for the Canberra proportional counters, the only radiological instruments presently operational, were logged on Form BwCP 433-1T3. However, these data were not suitable for control because only the acceptable (pass) values were retained. The licensee has agreed to record and maintain all the data on the performance checks for the counting instrument At present, tests referred to as " performance checks" are required for the nonradiological instrumentation only at infrequent intervals, weekly, monthly, or quarterly. However, the procedures for various analyses require that the RCT run a known standard, and that it be within acceptance limits, usually within 10% of the known value (1% for boron), prior to

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running the analyses. The results are reviewed by Chemistry Supervision for pass-fail criteria after which the results are destroyed. The licensee recognized that these are useful control data and plans in the future to record and maintain them as performance control parameters. These data will also be used on control charts for the various analyse Testing of the RCTs' abilities to analyze an unknown sample is described in BwCP PD-8, which states that approximately twice a year each RCT will be tested on three to six analyses. Chemistry Group staff may also be asked to participate in some aspects of the program. This general program appears to be good, but its adequacy can be judged only^when it is fully implemented. At present only two RCTs have started the tests. The licen ee will implement this program with tests of at least 14 of the RCTs prior to fuel loa Four or more analyses will be done, of which one will be boron. The importance of tracking individual RCT performance was discussed at the exit intervie The laboratory participated in the recently instituted corporate interlaboratory comparison program for nonradiological analyses. The results of this first set were not yet availabl The inspectors observed an RCT direct a trainee RCT in the collection and analyses of environmental samples. The RCT appeared knowledgeable in following the proper sampling and sample-handling procedures and followed the appropriate procedures with no difficulty. He seemed to thoroughly understand the analyses performed and he satisfactorily logged the information on log sheets and prepared the samples for shipping for further analyse _

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Licensee management appears to be cognizant of and supportive of a good *

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QA/QC program, as represented in the chemistry procedures and Program Descriptions and statements in various procedures relating to such a program. However, the operational program has been only minimally developed and implemented in the laboratory. This program will be followed in subsequent inspections under the existing Open Item (50-456/84003-03; 50-457/84003-03) in Section No violations or deviations were identifie '

10. Water Sampling, Monitoring, Processing The inspectors reviewed the water troatment, sampling, and monitoring programs and observed related equipment during a plant tour. The licensee has adequate sampling capabilities-in both the Primary and Secondary Sampling Rooms and in the SG blowdown facility in the hot laboratory to perform the necessary chemistry functtens for the plan In the Primary Sampling Room, the licensee will utilize the Sentry High '

Radiation Sampling System to collect routine reactor coolant sample Blowdown grab samples and in-line monitors will be used to analyze and monitor for conductivity, cation conductivity, reboiled cation conductivity, dissolved oxygen, sodium, hydrogen, and p During this inspection the SGs were drained to repair several isolation valves, so it was not possible to observe the collection and analysis of grab samples, or to perform checks of in-line monitors. The inspectors also observed a portable in-line monitor that can be used to measure a number of the above parameter ,

The inspectors also observed secondary sample room containing grab-sampling points and in-line monitors for a condensate pump discharge header, feedwater pump suction header, and main steam and condensate makeup. pump discharge. The licensee representative stated that grab samples were taken and the monitors were used to measure key chemical parameters from the different systems during hot functional test During the tour, the inspectcrs also. observed the condensate polishers and the makeup demineralizer water system. .The collection of samples and the operation and calibration of on-line monitors will.be observed in a future inspection when these systems are operational (0 pen Item No. 50-456/86017-02; 50-457/86015-02).

The inspectors confirmed that tha licensee is aware of the need to closely monitor key parameters of each system and appears willing to expend the necessary efforts and resources to obtain good chemistry control of each I syste No violations or deviations were identifie '

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11. Licensee Internal Audits The inspectors reviewed'the audits of the Chemistry Group, QAA 20-85-04 (January 15-21, 1985); QAA 20-85-13 (April 9-15, 1985); and QAA 20-86-02 (January 15-21,1986) performed by the licensee's Quality Assurance Department. All audits concerned chemistry and radiochemistry control, calibration of instruments, preparation and storage of chemical reagents and solutions, and glassware. All findings, comments, and observations have been closed out. No significant problems were identifie The inspectors also discussed the background and qualifications of the auditors involved. From discussions with licensee representatives, it appears that the auditors were qualified and had developed an adequate checklist prior to conducting each audi No violations or deviations were identifie . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action by the NRC or licensee or both. Open items are discussed in Sections 5 and 1 . Exit Interview

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The inspectors reviewed the scope and findings of the inspection with licensee representatives (Section 1) at the conclusion of the inspection on April 25, 1986. The licensee acknowledged the inspectors' concerns and agreed to improve the quality control programs as discussed in Section 9, and.to test the analytical qualifications of at least 14 individual RCTs by FLO During the interview, the inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectors. Licensee representatives did not consider the proposed content as proprietar .

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