ML20136D931

Insp Repts 50-456/97-03 & 50-457/97-03 on 970203-07. Violations Noted.Major Areas Inspected:Plant Support

ML20136D931
Person / Time
Site:	Braidwood
Issue date:	03/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136D867	List: ML20136D862 ML20136D896 ML20136D931
References
50-456-97-03, 50-456-97-3, 50-457-97-03, 50-457-97-3, NUDOCS 9703130061
Download: ML20136D931 (15)

See also: IR 05000456/1997003

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION 111

Docket Nos:

50-456; 50 457

Licenses No:

NPF-72; NPF-77

Reports No:

BO-456/97003(DRS); 50-457/97003(DRS)

Licensee:

Commonwealth Edison (Comed)

Facility:

Braldwood Nuclear Plant, Units 1 and 2

Location:

RR #1, Box 79

Braceville,IL 60407

Dates:

February 3-7,1997

Inspectors:

S. Orth, Radiation Specialist

D. Hart, Radiation Specialist

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Approved by:

T. Kozak, Chief, Plant Support Branch 2

Division of Reactor Safety

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9703130061 970304

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ADOCK 05000456

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Report Details

IV. Plant Suonort

R1

Radiological Protection and Chemistry (RP&C) Controls

R 1.1 Plant Water Chemistrv Control

a.

Insoection Scoos (84750)

The inspectors reviewed the licensee's management of primary and secondary

water chemistry including the program to mitigate impurities in the systems.

included was a review of the licensee's trending and analysis of chemistry

parameters for the period of January 1996 through January 1997 and a review of

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the following procedures:

BwCP PD-1, "Braidwood Station Primary Chemistry Surveillance Program," Revision

5, dated April 14,1996,and

BwCP PD-4, "Braidwood Station Secondary Water Chemistry Surveillance

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Program," Revision 10, dated April 27,1996.

b.

Observations and Findinas

The licensee's procedures, BwCP PD-1 and BwCP PD-4, were consistent with the

industry guidelines in minimizing the concentration of corrosive agents and radiation

source term buildup. For example, the licensee utilized all-volatile treatments (AVT)

chemistry in the secondary system to reduce oxygen concentrations and iron

transport and to control pH, via addition of hydrazine and methoxypropyl amine

(MPA). Following the change of additives from ethanolamine to MPA in March

1996, the licensee observed a notable decrease in feedwater iron concentration.

The iron concentrations in Units 1 and 2 were decreased by a factor of about two,

resulting in about 3 and 2 parts per billion (ppb), respectively. To mitigate the

effects of caustic crevice corrosion in Unit 1, the licensee practiced " Molar Ratio

Control" (MRC) to reduce the caustic nature of sodium in the steam generator (SG)

crevices with chloride. The inspectors noted that the licensee maintained effective

control over the sodium-to-chloride ratio in the SGs.

The licensee maintained excellent control of primary and secondary water chemistry

in both units. The concentrations of chloride and flucride in the primary systems

were maintained between 3-5 ppb. With the exception of periodic, minor

circulating water leaks, the levels of impurities in the secondary system were also

well maintained. Unit 2 SG sodium and chloride concentrations were 0.5 - 1.0 ppb

and 0.5 - 2.0 ppb, respectively. As a result of the MRC, the Unit 1 SG chloride

levels were slightly higher than the levels in Unit 2, but well within industry

guidelines. The licensee experienced some circulating water intrusions in July 1996

(Unit 1) and February 1996 (Unit 2), which corresponded to minor, short term

increases in the concentrations of sodium and chloride. However, the licensee

mitigated the effects in a timely manner.

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The inspectors observed good monitoring of fuelintegrity. The licensee's data

indicated a potential fuelintegrity problem in Unit 1. The concentration of xenon-

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133 (Xe-133) increased in mid-January 1997 and had remained constant. The

licensee had not observed any increase in the activity of reactor coolant

radioiodines, nor in their ratio. Additionally, the licensee had not observed any

gross indications of a failure in fuelintegrity. Based on the Xe-133 activity, the

licensee postulated small leaks in 1-3 fuel rods.

c.

Conclusion

The water chemistry of primary and secondary systems was well maintained and

monitored. Levels of corrosive impurities were maintained at or below industry

guidelines.

R1.2 Quality Control (QC) of Laboratory and in-line Chemistrv instruments

a.

insoection Scone (84750)

The inspectors reviewed the licensee's quality control program for both laboratory

and in-line instruments. The inspectors reviewed the licensee's implementation of

the following procedures:

BwAP 550-25, " Control of Chem Aids," Revision 2, dated February 14,1994;

BwCP 510-2, " Control of Laboratory Standards, Standard Reagents and

Chemicals," Revision 13, dated April 15,1994:

BwCP 51010, " Laboratory Instrumentation Performance Check Procedure,"

Revision 8, dated December 5,1995;

BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 10,

dated November 6,1995;

BwCP PD-7A1, " Laboratory Analytical Instrumentation Quality Control Program,"

' Revision 1, dated July 26,1994:

BwCP PD-7A2, " Process Panel Instrumentation Quality Control Program " Revision

3, dated November 6,1995; and

BwCP PD-7A3, "Radioanalytical Quality Control Program," Revision 2, dated

March 27,1996.

The inspectors also reviewed the licensee's maintenance of instrument control

charts and performance of high purity germanium (HPGe) detector calibrations.

b.

Observations and Findinas

On February 3,1997, the inspectors identified two aluminum (AI) standards which

were improperly labeled with respect to the procedure required shelf-life. Procedure

BwCP 510-2 required that standards having a concentration between 1001 ppb and

50 parts per million (ppm) be labeled for a shelf life of six months. However, the

inspectors identified that the Al standards (prepared on August 13,1996 and

September 10,1996 at 10 and 20 ppm, respectively) were labeled to expire after

one year. Following the inspectors' identification, the licensee removed and

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disposed of the standards and verified that the reagents had not been used beyond

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the procedure instructed six month shelf life,

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Technical Specification (TS) 6.8.1 requires, in part, that written procedures be

implemented covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Appendix A, Revision 2, February 1978. RG 1.33, Appendix A

recommends that procedures be implemented which specify chemistry instructions

and the calibration of laboratory instruments. BwCP 510-2 controls the standards

used in instrument calibrations, thus implements the recommendation of RG 1.33.

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The failure to control the shelf life of laboratory reagents in accordance with BwCP

510-2 is a violation of TS 6.8.1 (Violation Nos. 50-456/97003-01a and 50-

457/97003-01 a).

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The inspectors identified a problem concerning laboratory instrument performance

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checks. Procedure SwCP 510-10 directs chemistry technicians (cts) to verify that

instrument bias checks (BCs) are within the appropriate control limit. If an

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instrument does not pass the BC, the procedure instructs cts to perform additional

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OC analyses prior to proceeding with the sample analyses. Procedure BwAP 550-

25 requires " chem aids" be properly authorized, documented, and reviewed to

ensure that they were current, complete, and necessary. The inspectors observed

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cts verifying the BC for laboratory instruments with an uncontrolled aid containing

acceptance criteria. The licensee posted the aid in several areas of the laboratory

as a convenience for the cts so that they did not have to enter data into the

licensee's computer system (i.e. the controlled acceptance criteria data base) until

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later in the day. A laboratory chemist prepared this aid when he changed the

acceptance criteria in the computer data base. The inspectors did not identify any

discrepancies between the acceptance criteria in the controlled computer data base

and the posted aids. However, the inspectors identified that the licensee did not

perform a periodic review to ensure that the aid was consistent with the data base

as required in BwAP 550 25. Although the licensea's computer system provided a

final verification of the adequacy of the BC, the use of uncontrolled, unreviewed

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documents to perform procedure required verifications could lead to the CT

performing an analysis sequence without passing the required BC. In this case, the

entire analysis sequence would be re-performed, which may delay the ability to

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review system chemistry parameters.

TS 6.8.1 requires, in part, that written procedures be implemented covering the

applicable procedures recommended in RG 1.33, Appendix A, Revision 2, February

1978. RG 1.33, Appendix A recommends that procedures be implemented which

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specify laboratory instructions and calibration of laboratory instruments. BwAP

550-25 requires specified control and review of aids used in the laboratory to

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supplement procedures. The failure to control and review the aid used in

performing the instrument performance checks in accordance with BwAP 550-25 is

a violation of TS 6.8.1 (Violation Nos. 50-456/97003-01b and 50-457/97003-01b).

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The inspectors observed that the licensee's QC program for in-line instruments was

well maintained. However, the inspectors reviewed the licensee's control charts for

several laboratory instrument analyses and identified some problems concerning the

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identification and resolution of instrument blases and a lack of documentation of

corrective actions. The inspectors observed that analytical instrument and

radiochemical control charts were prepared and maintained as required by

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procedures BwCP PD 7A1 and BwCP PD-7A3, respectively. However, the

inspectors identified the following unresolved biases in the performance check data:

(1) a low bias was evident in gas chromatograph C data since October 1996 for

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hydrogen analysis; (2) a low bias was evident in ion chromatograph 3 sulphate

analysis since November 1996; and (3) a high bias was evident in ion

chromatograph 3 fluoride analysis since December 1996. The responsible

instrument chemists indicated that they were in the process of resolving the biases,

but had not recorded their actions. Although there did not appear to be an

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analytical problem with the accuracy of data produced by these instruments, the

long term biases may indicate some minor errors in the preparation of standards or

in the calibration of the instruments. The inspectors also identified that

documentation to support the changing of test acceptance criteria was not always

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maintained. The instrument chemists appeared to be properly changing the

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acceptance criteria in accordance with changes in instrument performance, but the

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rationale and calculation of the new criteria were not always formally recorded.

BwCP PD-7A1 indicated that the control limits should be reset at the discretion of

the instrument chemist and any actions taken should be recorded. The licensee

planned to improve the control of QC records.

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c.

Conclusion

The quality control of laboratory instruments ensured the overall accuracy of

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required analyses. However, problems were identified concerning the resolution of

biases in chemistry instrument control chart data. Examples of violations were

identified for the failure to follow procedures concerning (1) the assigned shelf life

of laboratory standards and (2) the control of chemistry aids.

R3

RP&C Procedures and Documentation

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R3.1

Chemistry Laboratorv Quality Control and Post Accident Samolino System Quality

Control and Surveillance Procedures

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a.

Insoection Scone (84750)

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The inspectors reviewed the adequacy and the licensee's implementation of the

following procedures:

BwCP 210-14, " Geometry Efficiency Standardization of Intrinsic Gerrr anium

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Detectors on the ND 9900 Counting Room System," Revision 2, Feoruary 21,

1996:

BwCP 323-13, "High Radiation Sampling System Surveillance Procedure," Revision

7, dated January 21,1997;-

BwCP 7031, " Initial Requirements for Post Accident Sampling of Reactor Coolant,

Radwaste, and Containment Air," Revision 6, dated January 21,1997;

BwCP 703-2, " Post Accident Sampling of Diluted Reactor Coolant (Cold or Hot

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Leg)," Revision 5, dated September 25,1995;

- BwCP 703-6, " Post Accident Sampling of Diluted Containment Floor Drain Sump,"

Revision 4, dated September 25,1995:

BwCP 70313, " Post Accident Sampling of Undiluted Containment Floor Drain

Sump," Revision 4, dated September 25,1995;

BwCP 703-17, " Stripped-Gas Sampling of Post Accident Reactor Coolant," Revision

5, dated September 25,1995:

BwCP 703-21, " Post Accident and Normal Sampling of Containment Atmosphere in

the Manual Mode of Operation," Revision 2, dated April 11,1996;

BwCP PD-7, "Braidwood Station Chemistry Quality Control Program," Revision 10,

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dated November 6,1995;

BwCP PD-7A1, " Laboratory Analytical Instrumentation Quality Control Program,"

Revision 1, dated July 26,1994;

BwCP PD-7A2, " Process Panel Instrumentation Quality Control Program," Revision

3, dated November 6,1995; and

BwCP PD-7A3, "Radioanalytical Quality Control Program," Revision 2, dated

March 27,1996.

The inspectors reviewed the procedures to determine if the procedures met the

recommendations of RG 1.33 as required by TS 6.8.1 and were prepared and

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implemented in accordance with the licensee's procedure BwAP 100 20

" Procedure Use and Adherence," Revision 5, dated February 16,1996.

b.

Observations and Findinos

The licensee conducted a nonradiological interlaboratory program as required by

procedure BwCP PD-7A1. The licensee's 1995 and 1996 results were excellent.

However, the inspectors identified some problems concerning the conduct of the

program and the licensee's corrective actions for results which were outside of the

stated acceptance criteria. For example, the inspectors identified problems

concerning the timely reporting of some licensee results, in reviewing the

licensee's non radiological analytical results, the inspectors noted that the overall

results for the third quarter of 1995 and the first quarter of 1996 were identical.

Subsequently, the licensee determined that the results for the first quarter of 1996

had not been reported. Although the licensee had analyzed unknowns for the first

quarter of 1996, the licensee's corporate group, which administrated the program,

had re-reported the results of the third quarter of 1995 instead of reporting the

results for the first quarter of 1996. On February 6,1997, the licensee obtained

the results for the first quarter of 1996 and found them to be in excellent

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agreement. The inspectors also observed that the licensee did not always take

corrective actions for sample results which were not found to be within acceptable

ranges and that, when re-analyses were performed, the licensee did not have

documentation which provided results or conclusions. In the case of silica, a

number of the licensee's results were outside of the acceptance range in both the

first quarter and third quarter of 1995. The licensee performed additional analyses,

but did not have an evaluation of the results.

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The inspectors identified problems concerning the adequacy of OC procedure BwCP

PD 7A1 in implementing the recommendations of RG 1.33, Appendix A.

Specifically, procedure SwCP PD 7A1 required that the licensee have an

interlaboratory program and that the licensee analyze unknown samples semi-

annually. However, the procedure BwCP PD-7A1 did not provide adequate

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instructions for the implementation of the program, the applicable acceptance

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criteria for sample results, and the actions to be taken to resolve unacceptable

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analytical results. As described above, the inspectors identified performance

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problems concerning certain elements of the semi-annualinterlaboratory program.

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The interlaboratory program is used to verify laboratory equipment is properly

controlled and calibrated.

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TS 6.8.1 requires, in part, that written procedures be established covering the

applicable procedures recommended in RG 1.33, Appendix A. Revision 2, February

1978. RG 1.33, Appendix A recommends that procedures be implemented to

ensure that laboratory equipment are properly controlled, cali 3 rated, and adjusted at

specified periods to maintain accuracy. The failure to provide adequate instructions

in procedure BwCP PD-7A1 to ensure that laboratory equipment is properly

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controlled and calibrated is a violation of TS 6.8.1 (Violation Nos. 50-456/g7003-

01c and 50-457/97003 01c).

The inspectors also identified deficiencies in the licensee's procedure (BwCP 210-4)

for the calibration of the high purity germanium (HPGe) detector, which the licensee

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used to analyze radioactive affluents for release to the environment and to analyze

potentially radioactive material for unrestricted release. Specifically, procedure

BwCP 210-4 did not specify instructions to ensure the validity of calibration

techniques. As required by the procedure, the licensee performed annual

calibrations for each HPGe detector and calculated new efficiency v. energy

standardizations. Following a calibration, the licensee compared the resulting

standardization to the previous calibrations to identify unexpected changes in the

detector's efficiency. The licensee also analyzed calibration standards (from

previous annual calibrations) to further ensure that the new calibrations were

acceptable, A member of the chemistry staff made a subjective judgement as to

the acceptance of these comparisons. Generally, the individual attempted to

investigate and resolve any comparisons of the above data which differed by more

than ten percent, indicating a potential problem with the new standardization.

Although the licensee's methods appeared acceptable, procedure BwCP 210-4 did

not direct these tests nor did it contain acceptance criteria to ensure that the new

calibrations were acceptable.

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TS 6.8.1 requires, in part, that written procedures be established covering the

applicable procedures recommended in RG 1.33, Appendix A, Revision 2, February

1978. RG 1.33, Appendix A recommends that procedures be implemented that

specify laboratory Instructions and calibration of laboratory equipment and

specifically states that extreme importance must be placed on laboratory

procedures used to determine concentration and species of radioactivity in liquids

and gases prior to release, including the validity of calibration techniques used in

these analyses. The failure to provide adequate instructions in procedure BwCP

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210-14 to ensurs the validity of the HPGe detector calibrations is a violation of TS

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6.8.1 (Violation Nos. 50-456/97003-01d and 50-457/97003-01d).

The inspectors also identified problems concerning the post accident sampling

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system (PASS) OC surveillance procedure and the PASS sampling procedures.

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Table i of procedure BwCP 323-13 contained the required frequency of PASS

performance checks. Procedure BwCP 323-13 required that the licensee perform

an isotopic analysis of identified PASS samples and compare the results to routine

sample results, if applicable. With some exceptions (Section R7), the inspectors

verified that the licensee had obtained PASS samples at the frequency defined in

BwCP 323-13. However, SwCP 323-13 and its implementing procedures did not

contain acceptance criteria for performing these comparisons or actions to take if

results were unacceptable. For example, the licensee's procedure did not contain

formal acceptance criteria to ensure that the dilution factor for the reactor coolant

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diluted sample was constant and to ensure that reactor coolant sample taken at the

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PASS were representative of primary coolant. The chemistry supervisor indicated

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that obtaining a volume of liquid or gas was an acceptable means of ensuring

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system capabilities. However, without analyzing and comparing the sample one

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could not be assured that the sample accurately represented the reactor coolant or

containment atmosphere at the proper dilution.

TS 6.8.4.d requires that a program be implemented which will ensure the capability

exists to obtain and analyze reactor coolant samples, radioactive iodine and

particulate samples in plant gaseous effluents and containment atmosphere samples

under accident conditions. Procedure BwCP 323-13 specified the required

frequency of PASS performance checks to ensure the capability of the system but

did not specify acceptance criteria for comparing isotopic analyses of the samples.

The lack of acceptance criteria in BwCP 323-13 to ensure the capability of the

system to obtain representative post accident samples is a violation of TS 6.8.4.d

(Violation No. 50-456/97003-02 and 50-457/97003-02).

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The inspectors identified that the licensee had designated procedures for obtaining

PASS samples (i.e. BwCP 703-2, 703-6, 703-9, 703-13, 703-17, and 703-21) as

" Reference Use". As defined in BwAP 100 20, " Reference Use" procedures were

procedures which have a routine impact on nuclear and personnel safety, and

" Continuous Use" were procedures which involve a high level of risk for nuclear

and personnel safety. Each step of " Continuous Use" procedures were to be read

prior to the performance of the step, whereas " Reference Use" procedures could be

referred to as needed. BwAP 100 20 also allowed for multiple steps to be

performed prior to completing " Reference Use" procedure signoffs. However,

BwCP 703-1 required that each post accident procedure be initialed at each step

performed by the sample team. Although designated as " Reference Use", the

PASS procedures directed personnel to handle highly radioactive samples under

accident conditions, which could potentially result in significant radiological

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consequences to personnel performing the sampling and which could potentially

provide a release path of highly radioactive gases and liquids. Based on the

procedure use definitions in BwAP 100-20, the directions for PASS procedure

usage in BwCP 703-1, and the potential safety significance of obtaining PASS

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samples during accident conditions, it did not appear that the designation of PASS

sampling procedures as " Reference Use" met the intent of the licensee's

requirements for the use of procedures.

c.

Conclusion '

Problems were identified concerning the adequacy of QC and PASS surveillance

procedures and the implementation of the interlaboratory program. Examples of

violations for inadequate procedures were identified concerning the lack of

acceptance criteria in the chemistry laboratory OC program and in the PASS QC

surveillances. The designation of procedural usage for PASS sampling procedures

did not appear to meet the licensee's procedure usage requirements.

R4

Staff Knowledge and Performance in RP&C

R4.1 33molina and Analysis of Primary Coolant

The inspectors observed a CT sample primary coolant and obtain stripped gas

samples. The CT demonstrated good analytical techniques and knowledge of

procedure requirements and references. The CT was also knowledgeable of the

expected concentrations found in the coolant and the licensee's limits for a variety

of specific analyses. The CT properly used an ion chamber to monitor the ambient

radiation dose rates in the sampling room and the dose rates of samples. The CT

demonstrated acceptable contamination control practices, with some minor

exception. The inspectors observed that the CT frequently manipulated highly

contaminated process sample lines then handled potentially uncontaminated items

(i.e. pens, instruments, test kits) without changing gloves. Although no violations

of procedures were identified, this practice increases the probability of spreading

contamination.

R4.2 Processina and Shioment of lon Exchance Resins

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a.

Insnection Scone (86750)

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The inspectors reviewed the licensee's actions concerning the deformation of an ion

exchange resin liner. The inspectors reviewed the licensee's investigation of the

demeged liner and discussed the event with the radweste shipping supervisor. The

inspectors also reviewed the resin dewatering evolution and procedure FO-OP-032,

" Setup and Operating Procedure for the RDS-1000 Unit," Rev.11.

b.

Observations and Findinas

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On January 22,1997, the licensee was preparing a shipment of radioactively

contaminated ion exchange resin for offsite burial. 'As the liner was lifted from the

process shield, the operator noted some resistance and identified deformation of

the sides of the liner. The licensee suspended the evolution and secured the liner

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within the shield. The liconsee also ensured that the contents of the liner were well

contained and had not leaked.

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The licensee performed a comprehensive review of the event and identified that an

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abnormality occurred during the dewatering of the resins. The vendor equipment

had lost power when the power cord was accidently unplugged by a station

laborer. After noticing the loss of power, the contractor performed a partial system

verification and restored power to the equipment. However, the system vent valve

automatically closed, per design, as power was restored to the unit and remained

closed during the remainder of the process. The licensee hypothesized that due to

a loss of the vent path, a vacuum resulted and the liner was subsequently

damaged.

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The licensee and the vendor notified other users of the problem. The licensee

suspended the use of the equipment and provided trcining of vendor personnel

regarding management expectations concerning abnorrnal occurrences. The

licensee also transferred the resins to a different liner for transport. At the time of

this inspection,- the licensee was evaluating potential changes to the vendor's

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equipment and to the applicable operating procedures.

The licensee and inspectors identified that procedure FO-OP-032 required a syt sm

verification prior to starting the unit. As part of the verification, the system vem

valve was to be in the open position. The licensee identified that the operator did

not perform the complete system verification in accordance with procedure FO-OP-

032. In addition, the licensee attributed the design function of the valve to the

occurrence.

TS 6.8.1 requires that process control program procedures be implemented. The

failure to properly implement procedure FO-OP-032 is a violation of TS 6.8.1.

However, this licensee-identified and corrected violation is being treated as a Non-

Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

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(NCV 50-456/97003-03 and 50-457/97003-03).

c.

Conclusions

The licensee conducted a thorough review of the events which lead to the damage

of a container of ion exchange resins. One non-cited violation was identified

concerning the lack of adherence to process control program procedures.

R5

Staff Training and Qualification in RP&C

R5.1 Post Accident Samolina Svstem Trainino

The inspectors observed CT training on the PASS. During the training, the

instructor and participants discussed and demonstrated the use of procedure BwCP

703 21, " Post Accident and Normal Sampling of Containment Atmosphere in the

Manual Mode of Operation," Revision 2. The inspectors observed that the training

was very interactive and the discussions were thorough. The trainer emphasized

the potential radiological conditions of a PASS sample and the sample system. He

also stressed the importance of radiation exposure reduction techniques, e.g.

distance and time. The licensee performed the training on a mockup in the

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licensee's training center. Although the use of the mockup was a good initiative in

that it provided a simulation without dose consequences or potential operations

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consequences, the training system differed from the actual configuration concerning

the layout and labeling of certain valves and gages. The licensee indicated that an

evaluation would be conducted to determine how the mockup could better

represent the field conditions. Additionally, the trainer mentioned the use of remote

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tools to reduce dose in the field, but he did not indicate specifics as to what tools

were available, how they were to be used, or when they were to bo used. The

licensee also planned to better evaluate the use of remote tools and instruction in

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their use,

Ducing performance of procedure BwCP 703-21, the training system failed to

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properly operate. The trainer indicated that the system in the field had also

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responded in the same manner and that he and the system chemist were evaluating

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the adequacy of certain procedure steps. However, the inspectors discussed this

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with the system chemist who was unaware of the training problem and indicated

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that no such problem existed in the field. Although an operabi!!!y issue did not

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exist, a communications problem appeared to exist between plant pesonnel and

training personnel which could have confused the training participants. Following

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the training, the licensee discussed these issues with the cts to ensure that there

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was not any confusion.

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R7

Quality Assurance in RP&C Activities

The inspectors reviewed the licensee's most recent audit conducted by tho site

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quality verification (SOV) staff in September of 1995 and the chemistry staff's

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quarterly self assessments. Both self assessment activities were of good scope and

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were effective in identifying performance problems withirs the chemistry program,

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The inspectors observed that problems concerning the material condition cf the

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PASS and the conduct of PASS surveillances had been identified by the licensee

'

and by NRC inspectors (NRC inspection Reports No. 50-456/96002 and 50-457/

96002). The inspectors observed some improvements in the area, but continued to

observe problems concerning the adequacy of procedures (Section R3.1) and in the

)

,

maintenance of the system. In June 1995, the licensee identified a problem with

a

the containment air sampling panel (CASP) circuitry which had sometimes resulted

{

in the disablement of a radiation monitor. When the gas partitioner module was

'

connected to the AC outlet within the CASP (as directed by procedure) or the light

within the CASP panel was activated, radiation monitor 1PR11J (containment

,

atmosphere) was disabled. However, as of the time of the inspection, the licensee

4

had not resolved the issue. The licenses had instncted personnel to power the gas

partitioner via an altemate receptacle, had placed a caution tag on the receptacle,

,

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and had tentatively planned on working the item in late February 1997. The

inspectors observed that this material condition problem created an impediment for

the chemistry staff and potentially effected the operability of a TS required radiation

monitor.

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R8

Miscellaneous RP&C lasues

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R8.1

(Closed) Insoection Follow-uo item No. 50-456/96015-02 and 50-457/96015-02:

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The licensee planned to update section 11.2 of the Updated Final Safety Analysis

Report (UFSAR) to be consistent with current radioactive waste system status.

The inspectors reviewed section 11.2 and found the information to have been

updated and consistent. This item is closed.

!

R8.2 (Closed) Licensee Event Reoort (LER) 96-013: On December 5,1996, the licensee

>

identified that the alarm setpoints for containment fuel handling incident radiation

monitors (1/2AR011J and 1/2ARO12J) were not in accordance with TS Table 3.3-

,

!

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6. Table 3.3-6 requires the trip setpoint to be set at a level such that the actual

submersion dose in the containment building would not exceed 10 millirem per hour

!

(mrem /hr). The as found setpoints were 100 mrem /hr (alert) and 2000 mrem /hr

3

(high alarm). After identifying the problem, the licensee removed the monitors from

operation and redetermined the setpoints as required by TS Table 3.3-6. The

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licensee also indicated that the containment purge radiation monitors had setpoints

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which would have alarmed if radiation levels exceeded 10 mrem /hr above

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background. The failure to adhere to TS Table 3.3-6 is a TS violation. However,

this licensee-identified and corrected violation is being treated as a Non-Cited

Violation, consistent with Section Vil.B.1 of the NRC Enforcement Policy (NCV 50-

,

,

456/97003-04 and 50-457/97003-04)

As additional corrective actions, the licensee verified that other radiation monitor

setpoints required by TS were consistent with the UFSAR descriptions and planned

to revise the UFSAR description of radiation monitors 1/2AR011J and 1/2ARO12J

to be consistent with the TS requirements. In addition, the licensee planned to

prepare setpoint justification documents for all area radiation monitors. The

inspectors planned to review these actions in future inspections (Inspection Follow-

'

up item Nos. 50-456/97003-05 and 50-457/9'/003-05).

V. Manaaement Meetinas

X1

Exit Meetina Summarv

The inspectors presented the inspection results to members of licensee management at the

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conclusion of the inspection on February 7,1997. The licensee acknowledged the

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findings presented. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

M. Cassidy, NRC Coordinator

A. Haeger, Hesith Physics and Chemistry Supervisor

M. Holmes, Lead Chemist

M. Gierscher, Radioactive Waste Shipping Supervisor

J. Kinsella. Site Quality Verification

T. Meents, Radioactive Waste Coordinator

T. Simpkin, Regulatory Assurance Supervisor

H. Stanley, Site Vice President

R. Thacker, Lead Health Physicist

T. Tulon, Station Manager

M. Vonk, Emergency Preparedness Director

INSPECTION PROCEDURES USED

IP 84750

Radioactive Waste Treatment, and Effluent and Environmental Monitoring

IP 86750

Solid Radioactive Waste Management and Transportation of Radioactive

Materials

IP 92904

Followup - Plant Support

ITEMS OPEN, CLOSED, AND DISCUSSED

Ooened

50-456/457-97003-01(a d)

VIO Failure to establish, maintain, and implement

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procedures recommended by Appendix A of Regulatory

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Guide 1.33.

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50-456/457-97003-02

VIO

Failure to establish adequate PASS procedures

50-456/457-97003-05

IFl

Licensee planned to revise UFSAR to be consistent with

Technical Specification Table 3.3 6 and planned to

create an area radiation monitor Justification document

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Closed

50-456/457-96015-02

IFl

Updating of UFSAR Section 11.2

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50-456/457-97003-03

NCV Failure to follow process control program procedures

50-456/457-97003-04

NCV Failure to follow Technical Specifications for radiation

monitor setpoints

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LIST OF ACRONYMS USED

AVT

All-Volatile Treatment

CASP

Containment Air Sampling Panel

CFR

Code of Federal Regulations

CT

Chemistry Technician

HPGe

High Purity Germanium

LER

Licensee Event Report

IFl

Inspection Follow-up item

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MREM /HR

Millirem per hour

MRC

Molar Ratio Control

NCV

Non-Cited Violation

PlF

Problem Identification Form

PPB

Parts Per Billion

PPM

Parts Per Million

OC

Quali y Control

t

Radwaste

Radioactive Waste

)

RG

Regulatory Guide

RP

Radiation Protection

RPA

Radiologically Posted Area

RPT

Radiation Protection Technician

RP&C Radiation Protection and Chemistry

SG

Steam Generator

SOV

Site Quality Verification

TS

Technical Specification

,

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UFSAR

Updated Final Safety Analysis Report

VIC

Violation

,

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Partial List of Documents Reviewed

BwCP 600-1, " General Sampling Procedure," Revision 5, dated September 28,1995.

BwCP 600 3, " Sampling of Potentially Contaminated Liquids," Revision 2, dated

October 25,1996.

i

BwCP 613-9, "CVCS Letdown Heat Exchanger Grab Sample," Revision 5, dated April 15,

1994.

'

BwCP 613-19, " Reactor Coolant Activity and Gaseous Samples," Revision 4, dated

October 5,1996.

BwRP 5820-5T1, "AR/PR Setpoint and Background Change Record," Revision 0 for

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1 ARO11 and 1 AR012 dated December 9,1996.

,

BwRP 5820 5T1, "AR/PR Setpoint and Background Change Record," Revision O for

2ARO11 and 2ARO12 dated December 9,1996.

" Prompt Investigation of Chem-Nuclear Systems, Inc.14-195FR Carbon Steel Liner

4

Collapse at Braidwood Station," prepared on January 25,1997 (Problem identification No.

d

456 201 97-0194).

" Recommended Practices for Nuclear Stations Chemistry Quality Control Program,"

November 1,1993,

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