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{{Adams | |||
| number = ML20149J705 | |||
| issue date = 07/24/1997 | |||
| title = 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 | |||
| author name = | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000456, 05000457 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-456-97-11, 50-457-97-11, NUDOCS 9707290057 | |||
| package number = ML20149J697 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 12 | |||
}} | |||
See also: [[see also::IR 05000456/1997011]] | |||
=Text= | |||
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j .. U.S. NUCLEAR REGULATORY COMMISSION | |||
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!' , REGION lli J | |||
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:. Docket Nos- 80-456; 50-457 | |||
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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) ;l | |||
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Facility: Braidwood Nuclear Power Station, Units 1 and 2 l | |||
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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 j | |||
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Approved by: G. L Shear, Chief, Plsnt Support Branch 2 ) | |||
: Division of Reactor Safety- i | |||
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EXECUTIVE SUMMARY j | |||
Braidwood Nuclear Plant, Units 1 & 2 i | |||
NRC Inspection Reports 50-456/97011; 50-457/97011 j | |||
1 | |||
This announced inspection included aspects of licensee p' ant support performance and, I | |||
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 I | |||
precedures used in radioactive waste activity deterrrinations. ; | |||
1 | |||
Plant Support | |||
- | |||
Weaknesses were identified in radioactive waste activity determinations. Or.e | |||
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 | |||
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 | |||
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 | |||
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) | |||
2 | |||
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I | |||
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Rep _ ort Details l | |||
1 | |||
, IV. Plant Succort | |||
! | |||
R1 Radlological Frotection and Chemistry (RP&C) Controls ! | |||
1 | |||
R I .1 Determinations of the Activity of Radioactive Waste Shioments | |||
1 | |||
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 , | |||
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 | |||
O. | |||
b. Observations and Findinas i | |||
i | |||
in accordance with 10 CFR 61.55(a)(8), the radiation protection (RP) staff used i | |||
scaling factors as an indirect method to determine radionuclide activity in ; | |||
radioactive waste shipments. This is done by inferring a concentration of hard to ' | |||
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 I | |||
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 l | |||
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 | |||
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the current scaling factors: | |||
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'In 1996, the scaling factors calculated for plutonium 239, curium-242, and | |||
(, 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 | |||
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 | |||
- for analysis. | |||
. | |||
- | |||
In 1995, the scaling factor calculated for iron-SS differed by a factor of | |||
i' = 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. | |||
, | |||
- (n mid 1994, the licensee performed a re-verification of the 1994 scaling | |||
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 | |||
' | |||
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. | |||
, | |||
, | |||
The inspector noted that the above differences between the current scaling factors ) | |||
and the individual wasta stream scaling factors were' generally conservative. l | |||
, | |||
Although the RP staff hed net adequately performed the required actions to ensure ! | |||
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. | |||
, | |||
I | |||
& 10 CFR 61.55(a)(8) requires, ir, part, that the licensee provide reaacnable assurance l | |||
- that the indirect method for determining the concentration' of a radionuclide can be | |||
correlated with actual measurements. Procedure BwRP 5600-6 provided the , | |||
, | |||
licensee's requirements for ensuring that the indirect method (i.e. scaling ftctor) l | |||
' | |||
could be correlated with actual waste stiaarr measurements. The failurt to obram | |||
additional samples of waste streams when the measurements did not correlate as | |||
l required by procedure BwRP 5600-6 is a violation of 10 CFR 61.55(a)(8). (VIO 504 4 | |||
456/97011-01(DHS); 457/97011-01(DRS)) | |||
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n The inspector also identified problems concerning the quarterly verification of waste i | |||
: strearn scaling factors. As required by procedure SwRP 5000-6, the RP ataff j | |||
~ ' | |||
, monitored the ratio of iodine-134 to cobalt 60 in reactor coo; ant to identify any | |||
potential change that might affect the distribution of radienuclides in the 'Nante ; | |||
q , | |||
streams'(i.e/ scaling factore).' . Although procedure BwRP 5600-6 recommended | |||
3 .'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 | |||
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noted that,' potentially, this would delay the identification of a change in the scaling | |||
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 | |||
. | |||
s 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 . | |||
' | |||
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. | |||
I verified that the third and fourth quarter comparisons were within the acceptance: | |||
= criteria. The licensee also identified (Section R6.1) soma technical probleme | |||
i concerning the radionuclides used in the ratio and was oeveloping corrective | |||
. | |||
actions. | |||
J | |||
'c. 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 | |||
I | |||
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 | |||
measurements and the current scaling factors were generally conservative and | |||
< | |||
would not have changed waste classifications, in addition, the quarterly scaling | |||
factor verifications were not performed in a timely mannes. | |||
R1.2 Hansportation of Radiga.ctive M,gtarials | |||
a, 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; | |||
BwkP 5600-7, " Shipment of Radioactive Materials," Revision 3E1; and | |||
BwRP 5610-6, " Surveying Radioactive Material Shipments," Revision 3E1. | |||
F The inspector also reviewed the shipp ng documents for the following radioactive | |||
waste bbipments including the packago classifications and labeling and shipping | |||
; | |||
papers: | |||
RWS 97-001 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. | |||
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* 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 i | |||
regulations, procedure BwRP 5600-7 contained appropriate instructions for ! | |||
determinin0 the classification of shipments, inc!uding the requirements for low l | |||
* | |||
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 j | |||
the revised A1 and A2 values contained m 49 CFR 173.435. A March 1997 audit i | |||
of this area (Section R6.1) identified some discrepancies in the procedures,' which | |||
, were corrected. However, the licensee's procedures did not ccntain the ! | |||
, | |||
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 i | |||
' | |||
. addition, procedures did not contain instructions to ensure that the radioactivity . | |||
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 | |||
' | |||
rate requirement.and that the corporate RP staff was developing an LSA definitior | |||
to ensure the appropriate distribution of radioactivity within the package. . | |||
I | |||
As allowed by the licensee's procedures, the RP staff used a vendor supplied | |||
l 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 ) | |||
properly used for the activity of the shipments au requir ed by the regalations and | |||
l licensee procedures. The shipping documentation als- icluded emergency | |||
i . response information. | |||
<- | |||
! | |||
On June 18-23,1997, the inspector observed t - | |||
aparation of two containers of j | |||
[ | |||
DAW (RSW 97-006) for shipment to a waste pn assor. An RP technician l | |||
! 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 | |||
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 I | |||
of the vehicle. The RP technicians clearly communicated the radiological status of | |||
i 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 I | |||
vehicle was proper!y placarried, and the shipping papers were completed as 1 | |||
required. ' | |||
1 | |||
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 i | |||
' | |||
radioactive shiprnents were observed. | |||
R1.3 Radioloaig_aignvironmenta_I f;&on.itoripa Program (REMP) | |||
a. I,1soection | |||
f Scgce (IP 84750) | |||
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 i | |||
a technician obtaining enviror' mental water and air filter samples. ' | |||
1 | |||
b. Observations and Findinog 1 | |||
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 | |||
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 | |||
7 | |||
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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 | |||
- | |||
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, | |||
c. .CA nclusion,p. | |||
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 | |||
' | |||
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 | |||
i 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. | |||
8 | |||
._ _ | |||
. | |||
. | |||
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. | |||
c. 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 | |||
9 | |||
y c. | |||
.. | |||
, | |||
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. , | |||
. | |||
c. Conclusiong | |||
The March 1997 audit of the radioactive waste processing and transportation | |||
prograrn was a comprehensive programmatic review but did not thoroughly review | |||
. | |||
., | |||
' | |||
program implementation. Immediate corrective actions and long torm programmatic : | |||
. | |||
corrective actions were being implemented to resolve the audit findings. | |||
V. Mg_npuoment | |||
n Meetinas | |||
X1 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 | |||
, | |||
, c ' LicenqLeg | |||
. | |||
:, , | |||
, | |||
. | |||
. | |||
: SiBell, Corporate Health Physics | |||
' | |||
'M. Gierscher, Radwaste Shipping Supervisor l, | |||
. . A. Haeger, Health Physics and Chemistry Supervisor | |||
. | |||
Er Hendrix, Operations Staff Supervisor | |||
: C. Herzog, Executive Assistant- | |||
T. Meents, Radwaste Coordinator | |||
J. Meister, Engin'eering Manager | |||
R. Thacker, Lead Health Physicist | |||
. INSPECTION PROCEDURES USED . | |||
':lP 86750 - | |||
. | |||
Solid' Radioactive Wasto' Management and Transportation of Radioactive . | |||
. Materials | |||
' | |||
, :.o Tl 2515/133' implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71 | |||
' | |||
, | |||
ITEMS OPEN, CLOSED, AND DISCUSSED | |||
. Ooened | |||
. | |||
i | |||
50-456/457-970011-01 VIO Failure to adequately implement procedures j | |||
concerning the calculation of radionuclide scaling | |||
' | |||
l | |||
; | |||
factors | |||
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, Closed | |||
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Nono- | |||
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Discussed | |||
None | |||
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m, LIST OF ACRONYMS USED | |||
. | |||
' | |||
. | |||
;DdW; ' fDry Act!ve Waste. ,. :n | |||
. | |||
" ' | |||
IP 1. Inspection Procedure. | |||
LSA: . Low Specific Activity. r | |||
1 | |||
ODCM . Offsite Oose Calculation Msnuan | |||
'REMP : Radiological Environmental MonitoCng Program: | |||
RP | |||
' | |||
Radiation Protection'- | |||
' SCO Surface Contaminatod Object | |||
- | |||
SI .intemationel System of Units - | |||
TI . | |||
c Temporary instruction . | |||
"TLD - Thermoluminescent Dosimeter | |||
, | |||
s VIO . LViciation | |||
PARTIAL LIST OF DOCUMENTS REVIEWED - | |||
' | |||
Annual Scating Factor Determinations for 1994 1995, and 1996. | |||
Draidwood Station Annual Radiological Environmental Operating Reports for 1996 and. ' | |||
' | |||
1996, | |||
Ouality Services Audit Report DG-97-13/BWD, dated March 10,1997.' | |||
. | |||
, | |||
: 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. | |||
, | |||
, | |||
I.' | |||
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1 | |||
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J{ e .,b .- | |||
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, , , r., . . . . .,, e s -- . - | |||
}} |
Latest revision as of 17:22, 7 August 2022
ML20149J705 | |
Person / Time | |
---|---|
Site: | Braidwood ![]() |
Issue date: | 07/24/1997 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20149J697 | List: |
References | |
50-456-97-11, 50-457-97-11, NUDOCS 9707290057 | |
Download: ML20149J705 (12) | |
See also: IR 05000456/1997011
Text
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j .. U.S. NUCLEAR REGULATORY COMMISSION
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- . Docket Nos- 80-456; 50-457
Licenses Nd: NPF-72; NPF-77 - )
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Licensee: Cornmonwealth Edison (CorrEd) ;l
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Facility: Braidwood Nuclear Power Station, Units 1 and 2 l
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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 j
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Approved by: G. L Shear, Chief, Plsnt Support Branch 2 )
- Division of Reactor Safety- i
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EXECUTIVE SUMMARY j
Braidwood Nuclear Plant, Units 1 & 2 i
NRC Inspection Reports 50-456/97011; 50-457/97011 j
1
This announced inspection included aspects of licensee p' ant support performance and, I
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 I
precedures used in radioactive waste activity deterrrinations. ;
1
Plant Support
-
Weaknesses were identified in radioactive waste activity determinations. Or.e
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
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
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
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)
2
.
I
.
Rep _ ort Details l
1
, IV. Plant Succort
!
R1 Radlological Frotection and Chemistry (RP&C) Controls !
1
R I .1 Determinations of the Activity of Radioactive Waste Shioments
1
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 ,
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
O.
b. Observations and Findinas i
i
in accordance with 10 CFR 61.55(a)(8), the radiation protection (RP) staff used i
scaling factors as an indirect method to determine radionuclide activity in ;
radioactive waste shipments. This is done by inferring a concentration of hard to '
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 I
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 l
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
3
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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
(, 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
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
- for analysis.
.
-
In 1995, the scaling factor calculated for iron-SS differed by a factor of
i' = 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.
,
- (n mid 1994, the licensee performed a re-verification of the 1994 scaling
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
'
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.
,
,
The inspector noted that the above differences between the current scaling factors )
and the individual wasta stream scaling factors were' generally conservative. l
,
Although the RP staff hed net adequately performed the required actions to ensure !
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.
,
I
& 10 CFR 61.55(a)(8) requires, ir, part, that the licensee provide reaacnable assurance l
- that the indirect method for determining the concentration' of a radionuclide can be
correlated with actual measurements. Procedure BwRP 5600-6 provided the ,
,
licensee's requirements for ensuring that the indirect method (i.e. scaling ftctor) l
'
could be correlated with actual waste stiaarr measurements. The failurt to obram
additional samples of waste streams when the measurements did not correlate as
l required by procedure BwRP 5600-6 is a violation of 10 CFR 61.55(a)(8). (VIO 504 4
456/97011-01(DHS); 457/97011-01(DRS))
l
4 1
j
n The inspector also identified problems concerning the quarterly verification of waste i
- strearn scaling factors. As required by procedure SwRP 5000-6, the RP ataff j
~ '
, monitored the ratio of iodine-134 to cobalt 60 in reactor coo; ant to identify any
potential change that might affect the distribution of radienuclides in the 'Nante ;
q ,
streams'(i.e/ scaling factore).' . Although procedure BwRP 5600-6 recommended
3 .'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
- -
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noted that,' potentially, this would delay the identification of a change in the scaling
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
.
s 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 .
'
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.
I verified that the third and fourth quarter comparisons were within the acceptance:
= criteria. The licensee also identified (Section R6.1) soma technical probleme
i concerning the radionuclides used in the ratio and was oeveloping corrective
.
actions.
J
'c. 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
I
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
measurements and the current scaling factors were generally conservative and
<
would not have changed waste classifications, in addition, the quarterly scaling
factor verifications were not performed in a timely mannes.
R1.2 Hansportation of Radiga.ctive M,gtarials
a, 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;
BwkP 5600-7, " Shipment of Radioactive Materials," Revision 3E1; and
BwRP 5610-6, " Surveying Radioactive Material Shipments," Revision 3E1.
F 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
, 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 i
regulations, procedure BwRP 5600-7 contained appropriate instructions for !
determinin0 the classification of shipments, inc!uding the requirements for low l
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 j
the revised A1 and A2 values contained m 49 CFR 173.435. A March 1997 audit i
of this area (Section R6.1) identified some discrepancies in the procedures,' which
, were corrected. However, the licensee's procedures did not ccntain the !
,
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 i
'
. addition, procedures did not contain instructions to ensure that the radioactivity .
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
'
rate requirement.and that the corporate RP staff was developing an LSA definitior
to ensure the appropriate distribution of radioactivity within the package. .
I
As allowed by the licensee's procedures, the RP staff used a vendor supplied
l 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 )
properly used for the activity of the shipments au requir ed by the regalations and
l licensee procedures. The shipping documentation als- icluded emergency
i . response information.
<-
!
On June 18-23,1997, the inspector observed t -
aparation of two containers of j
[
DAW (RSW 97-006) for shipment to a waste pn assor. An RP technician l
! 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
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 I
of the vehicle. The RP technicians clearly communicated the radiological status of
i the packages and requirements, in addition, the RP technicians closely monitored
6
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b
the driver and infortned him of dose rates. The package was propstly marked, the I
vehicle was proper!y placarried, and the shipping papers were completed as 1
required. '
1
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 i
'
radioactive shiprnents were observed.
R1.3 Radioloaig_aignvironmenta_I f;&on.itoripa Program (REMP)
a. I,1soection
f Scgce (IP 84750)
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 i
a technician obtaining enviror' mental water and air filter samples. '
1
b. Observations and Findinog 1
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
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
7
.
.
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
-
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,
c. .CA nclusion,p.
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
'
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
i 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.
8
._ _
.
.
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.
c. 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
9
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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. ,
.
c. Conclusiong
The March 1997 audit of the radioactive waste processing and transportation
prograrn was a comprehensive programmatic review but did not thoroughly review
.
.,
'
program implementation. Immediate corrective actions and long torm programmatic :
.
corrective actions were being implemented to resolve the audit findings.
V. Mg_npuoment
n Meetinas
X1 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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, c ' LicenqLeg
.
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.
.
- SiBell, Corporate Health Physics
'
'M. Gierscher, Radwaste Shipping Supervisor l,
. . A. Haeger, Health Physics and Chemistry Supervisor
.
Er Hendrix, Operations Staff Supervisor
- C. Herzog, Executive Assistant-
T. Meents, Radwaste Coordinator
J. Meister, Engin'eering Manager
R. Thacker, Lead Health Physicist
. INSPECTION PROCEDURES USED .
':lP 86750 -
.
Solid' Radioactive Wasto' Management and Transportation of Radioactive .
. Materials
'
, :.o Tl 2515/133' implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
'
,
ITEMS OPEN, CLOSED, AND DISCUSSED
. Ooened
.
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50-456/457-970011-01 VIO Failure to adequately implement procedures j
concerning the calculation of radionuclide scaling
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factors
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Discussed
None
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m, LIST OF ACRONYMS USED
.
'
.
- DdW; ' fDry Act!ve Waste. ,.
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.
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IP 1. Inspection Procedure.
LSA: . Low Specific Activity. r
1
ODCM . Offsite Oose Calculation Msnuan
'REMP : Radiological Environmental MonitoCng Program:
'
Radiation Protection'-
' SCO Surface Contaminatod Object
-
SI .intemationel System of Units -
TI .
c Temporary instruction .
"TLD - Thermoluminescent Dosimeter
,
s VIO . LViciation
PARTIAL LIST OF DOCUMENTS REVIEWED -
'
Annual Scating Factor Determinations for 1994 1995, and 1996.
Draidwood Station Annual Radiological Environmental Operating Reports for 1996 and. '
'
1996,
Ouality Services Audit Report DG-97-13/BWD, dated March 10,1997.'
.
,
- 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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