ML19354D410

Responds to NRC 890912 Ltr Re Violations Noted in Insp Repts 50-456/89-24 & 50-457/89-24 on 890703-0901.Corrective Action:Bwrp 1520-4, Surveying Radioactive Matl Shipments, Revised to Ensure Reading Taken 2 Meters from Vehicle

ML19354D410
Person / Time
Site:	Braidwood
Issue date:	10/12/1989
From:	Kovach T COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
0330T, 330T, NUDOCS 8911080331
Download: ML19354D410 (6)

Text

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' } Commonwealth Edison 72 West Adams Str001, Chic: , Ilkncis

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October 12, 1989 '"

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/ PA. p Mr..A. Bert Davis Regional Administrator  !

U. S. Nuclear Regulatory Commission Region III ,

799 Roosevelt Road Glen Ellyn, IL 60137  :

SUBJECT:

Braidwood Station Units 1 fx 2 l Response.to Inspection Report i Nos. 50-456/89-024 and 50-457/89-024, -

NRC Docket Nos. 50-456 and 50-457 f

REFERENCE:

(a).C. E. Norelius Letter to C. Reed Dated (

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September 12, 1989

Dear Mr. Davis:

This letter is in response to the inspection conducted by Dr. R. B. Holtzman, and Mr. M. A. Kunowski on July 3 through  !

September 1, 1989 of activities at Braidwood Station. Reference (a) J indicated that certain activities appeared to be in violation of NRC 7 requirements. The Commonwealth Edison (Edison) response to the  !

Notice'of Violation is provided in the enclosure.

If you have any questions regarding this response please i direct them to this office.  !

C. _ = =!" -

T. J. Kovach Nuclear Licensing Manager i e Enclosure cc: NRC Resident Inspector - Braidwood I. NRC Document Control Desk  ;

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ENCLOSURE [

COMMONMEALTil EDISON COMPANY' S RESPONSE TO INSPECTION REPORT Hns. 456/89024 and 457/89024 VIOLATIDH: (456/89024-03; 457/89024-03)

Technical Specification 6.11 requires that procedures for personnel radiation protection be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

Braidwood procedure, BwRp 1520-4, requires that a survey be performed at 2 meters from the sides of the transport vehicle and the results of that survey be documented before the vehicle is ,

released from the site.

Contrary to the above, on April 3, 1989, a survey was not performed at 2 meters from the sides of the transport vehicle before it was released from the Braidwood site. Specifically, the survey was performed at 2 meters from a package on the vehicle.

RESP _QNSE:

Edison acknowledges that a survey was not performed at 2 meters from the sides of a transport vehicle before it was released from the Braidwood site.

The Radiation protection Technician (RPT) who performed the survey surveyed the shipment 2 meters from the cask rather than 2 meters from the vehicle. Calculations to determine the dose rate at 2 meters from the trailer have confirmed that the dose rate at that distance from the vehicle did not exceed the federal limit.

s Upon identification of the failure to obtain the proper 2 meter dose reading, the burial site to which to shipment was sent and the state agency governing the burial site were contacted to obtait. their shipment receipt records. These records were reviewed and the results indicated that the trailer met all the inspection requirements of the burial site and the State of Washington. Also, surveys performed at the burial site by these personnel as well as representatives from the State of Washington receiving the shipment did not show any dose rates in excess of Braidwood Station's procedural limits.

Edison's review of this event determined that there had been no negative impact on the health and safety of the public.

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$ CORRECT 1YlLACTION TAKEN_AND RESJL.TS_AC111 EYED:  ;

1 Braidwood Station Health Physics Supervision has discussed this l incident with Radiation Protection Department personnel. Attention

.to detail along with the importance of taking the reading 2 meters from the vehicle was emphasized.

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A 2 meter stick has been provided to the RPTs for use during surveys to ensure that readings are taken at the required 2 meter distance. )

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CDRRECIlV_ELACIl0N__TAKEtLIQ AY.01D_IEURT11ER VIOLATION:  ;

The personnel involved in this event were included and participated j in a Braidwood Station Error Evaluation Presentation in order to  !

identify the root and contributing causes of the event. Based on the conclusions of this presentation, the following corrective ,

actions are being initiated to prevent recurrence. I 1

1. BwRP 1520-4, " Surveying Radioactive Material Shipments", will be revised to ensure the reading is taken 2 meters from the vehicle by incorporating the use of a 2 meter stick into the procedure.

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2. A required. reading package describing this event and detailed I requirements for shipping of radioactive material will be provided to all Radiation Protection Department personnel.

3. Additional training on radioactive material shipping will be given to the RPTs during their annual continuing training.

This training will include the purpose of the vehicle survey requirements and the 10 mR/ hour at 2 meters limit.

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DATE OF FULL COMPLIANCE:

Procedure DwRP'1520-4 is expected to be revised by December 31, 1989. The required reading is expected to be rc;opleted by December 1, 1989. The RPT training will be conducted during the annual RPT continuing training which is expected to be completed by March 31, 1990.

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f. " klOLAIIDH: (456/89024-04; 457/89024-04) f 10 CPR 50, Appendix D, Criterion V, requires that activities affecting quality be accomplished in accordance with documented

instructions, procedures, or drawings that include appropriate

f. quantitative or qualitative acceptance criteria for determining that s

important activities have been satisfactorily accomplished. .

Braidwood Procedure, BwOP WX-219, requires that a shipment that does ,

not meet the criteria of quality Procedure 13-52, must not leave the site.  ;

Quality Procedure 13-52 states that the dose rate limit measured at 2 meters from the side of a trailer carrying radioactive material'is 10 mrem / hour.

• Contrary to tne above, on April 3, 1989, activities involving a '

shipment of radioactive waste were not accomplished in accordance with quantitative acceptance criteria of a documented procedure.

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Specifically, a shipment of radioactive waste was released trom the i site and a survey record indicated that the dose rate measured at 2 meters from the side of the trailer carrying the shipment exceeded the limit specified in Quality Procedure 13-52.

REFEQNSE:

Edison acknowledges that a transport vehicle left the site with a survey record' indicating that the dose rate measured at 2 meters from the side of the trailer carrying the shipment exceeded the limit specified in Quality Procedure 13-52.

.Following a thorough review of this incident and subsequent calculations, it was determined that the documented 2 meter reading on the survey form was in reality, a 2 meter reading from the side of the cask and not a 2 meter reading from the plane of the vehicle. Calculations to determine the dose rate at 2 meters from the vehicle have confirmed that the dose rates at that distance drd not exceed the federal limit.

As indicated in the inspection report, a review of 1988 and 1989 radwaste shipments found no other occurrence of a similar nature. +

As such Draidwood Station's radioactive material shipping program continues to be effective in making shipments in accordance with requirements to protect the health and safety of the public.

CORRECTIVE ACTION TAKEN AMD_RESULTS ACljlEYER:

A memorandum has been written by the llealth Physics Supervisor to Health Physics Staff requiring a second independent verification of the actual survey results against the appropriate limits. This memorandum will be in effect until the proper station procedures can be revised.

Ilealth Physics Supervision has discussed this incident with Radiation Protection Department personnel. Attention to detail was emphasized.

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, ' Th3 ch:cklict uccd by Quclity'Assurcncs (QA) to inep;ct radioactiva i material shipments has been revised to include verification that F

dose rates are not exceeded.

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! CORRECTIVE __ ACTION TAKEN TO AVOID FURTliER VIOLATION:

I The personnel involved in this event were included and participated I in a Braidwood Station Error Evaluation presentation in order to

! identify the root and contributing causes of the event. Based on the conclusions of this presentation, the following corrective  !

actions are being initiated to prevent recurrence.

1. BwRP 1520-4, " Surveying Radioactive Material Shipments", will be revised to enhance the ability to better identify regulatory l limits. Specifically BwRp 1520-4T1, " Radiation Survey Shipment Form", will be revised to incorporate a comparison of results with limits and documentation that the results are acceptable.

2. Additional training on radioactive material shipping will be given to the RpTs during their annual continuing training, j Along with this additional training a required reading package describing this event, including corrective actions taken, and  ;

detailed requirements for shipping of radioactive material will 4 be provided to the Radiation protection Department personnel. 1

3. Quality Control (QC) personnel who are certified to review I radioactive material shipping documents will receive additional training on radioactive material shipping requirements and 4 proper review techniques. This event, and its corrective l actions will also be included in the training.

4. The QC Department will review all checklists and associated j documents that are utilized by the QC Department for radioactive material shipments in order to ensure they are appropriate for their intended use. Any required enhancements to these documents will be made and the required training will be administered to the appropriate QC personnel.

5. Sample QC checklists for each type of radioactive material shipments will be included as reference documents in the Quality Control Log for Radioactive Shipments to ensure that the proper checklists are being utilized for each type of shipment.

6. QA personnel who are qualified to review radioactive material  !

shipments have received training on this incident. The train'.ng included a review of dose rate requirements, QA i responsibilities for the Leview process and training on the use l of the new checklist. i l

DATE_QE._EULL COMI11ARCE:

procedure BwRp 1520-4T.1 is expected to be revised by December 31, ,

1989. The require reading for the Radiation protection Department personnel is expected to be completed by December 1, 1989. The i review of the QC documents and the related training is expected to I be completed by December 31, 1989. The RpT training is expected to be completed by March 31, 1989. The treining of the QA personnel  :

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. . *YIOLAIION: (456/89024-Oli 457/89024-01) '

Technical Specification 6.9.1.6 requires that the Annual i Radiological Environmental Operating Report include the results of i the analyses of all radiological environmental sample taken during ,

I the period at all the locations specified in the tables and figures specified in the ODCM.

Contrary to the above, although the two Annual Radiological Environmental Operating Reports covering the year 1987 and 1988 included summaries, they did not contain the results of the analyses of the radiological environmental samples taken during the respective periods.

I RESEQESE: -

Edison acknowledges that the 1987 and 1980 Annual Environmental Report did not contain the results of the analyses of the radiological environmental samples taken during the respective periods. Rather than including the individual data points in the i

report, a summary of the individual data points was included and the individual data points were available for review. ]

4 The 1985 and 1986 Annual Environmental Report contained the required data, in an attempt to standardize the Annual Environmental Report l for all of Edison's nuclear stations the data were inadvertently 1 deleted from Braidwood Station's 1987 and 1988 Report.

J Braidwood Station's environmental monitoring program continues to function within the legal requirements and administrative guidelines i to ensure the health and safety of the public. j I

CORRECTIVE ACTIOliS TAKEN AND RESULTS ACHIEVED:

1 The results of sample analyses, excluded from the 1987 and 1988 Braidwood Reports are being collected and are expected to be submitted to the NRC by October 31, 1989.  ;

CORRECTIVE ACTIONS TO AVOID FURTJlER VIOLATIQNS:

A corporate procedure Ep-ADMIN-7, " Review and Distribution of Contractors Radiological Monitoring Report", will be developed which will include a station specific checklist delineating the technical specification requirements for report content. The checklist will be reviewed and approved by Braidwood Station prior to generation of the Annual Report to ensure all technical specification requirements are being met.

DATE.__ OF FULL __COMELIANCE :

Corporate procedure Ep-ADMIN-7 is expected to be issued by December 31, 1989.

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