IR 05000456/1985042

Insp Repts 50-456/85-42,50-457/85-41 & 30-17035/85-01 on 850819-23.No Violation or Deviation Noted.Major Areas Inspected:Preoperational Radiation Protection Program, Including Organizational & Mgt Controls

ML20135H774
Person / Time
Site:	Braidwood, 03017035
Issue date:	09/16/1985
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135H763	List: IR 05000456/1985042 ML20135H762
References
30-17035-85-01, 30-17035-85-1, 50-456-85-42, 50-457-85-41, IEIN-85-006, IEIN-85-042, IEIN-85-043, IEIN-85-42, IEIN-85-43, IEIN-85-6, NUDOCS 8509240213
Download: ML20135H774 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/85042(DRSS); No. 50-457/85041(DRSS); No. 30-17035/85001(DRSS)

Dockets Nos. 50-456; 50-457; 30-17035 Licenses No. CPPR-132; No. CPPR-133; No. 12-05650-17 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Nuclear Power Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL Inspection Conducted: August 19-23, 1985 Inspectors: W. de Af f Date Approved By: / /6/E$~

Facilities Radiation Protection Section Date Inspection Summary:

Inspection on August 19-23,1985 (Reports No. 50-402/85042(DRSS);

No. 50-457/85041(DRSS);No. 30-17035/85001(DRSS))

Areas Inspected: Routine, unannounced inspection of preoperational radiation protection program for Units I and 2, including: organizational and management controls; training and qualifications; external occupational exposure; internal exposure control and assessment; control of radioactive materials, surveys and monitoring; facilities and equipment; status of open items; IE Information Notices No. 85-06; No. 85-42 and No. 85-43; review of selected preoperational tests and test results; and NRC Byproduct Materials License No. 12-05650-1 The inspection involved 37 inspector-hours on site by one NRC inspecto Results: No violations or deviations were identifie DR ADOCK 05 t

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DETAILS Persons Contacted:

J. Anspaugh, Health Physicist S. Baranski, Technical Staff Engineer

• D. Cecchett, Project Licensing and Compliance D. Flynn, ALARA Coordinator

• J. Gudac, Station Superintendent S. Holm, Health Physicist

• L. Johnson, Quality Assurance

'*T. Keith, Station Health Physicist

• F. Krowzack, Rad / Chem Supervisor

• 0. O'Brien, Assistant Superintendent, Administrative and Support Services D. Shamlin, Health Physics Foreman

• T. Simpkin, Technical Staff-Licensing K. Skinner, Health Physics Foreman D. Zimmerman, Training L. McGregor, NRC Senior Resident Inspector

• Denotes those present at the exit meetin . . General This inspection, which began at 12:30 p.m. on August 19, 1985, was conducted to examine the radiation protection and radwaste programs, certain preoperational test procedures and preoperational test results, open items and NRC License No. 12-05650-17. The inspection included tours of the turbine building, auxiliary building, containment buildings, fuel handling building, and radwaste buildin . Licensee Action on Previous Inspection Findings (Closed) Open Item (456/84010-01; 457/84010-01): Implement radiation / chemical technician qualification card program. This program has been implemented and is discussed further in Section 5. No problems were note . Organization and Management Controls The inspector reviewed the licensee's organization and management

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controls for-the radiation protection and radwaste programs including:

responsibilities, authorities, and staffin Since the last radiation protection inspection in March 1985, the licensee has hired one additional health physicist, a recent graduate with a bachelors degree in Health Physics from Purdue University; a degreed chemical engineer with about one year's experience; an ALARA coordinator with about two years ALARA experience at another CECO nuclear

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plant; two chemistry engineering assistants (EA) who were experienced RCTs; one dosimetry EA who was an experienced RCT; and a TLD engineering technician. The licensee plans to add about fifteen RCTs and one health physics foreman to the Rad / Chem staff by the end of September 1985. When these positions are filled, and the RCT's are trained and qualified, the licensee's Rad / Chem shift manning needs should be satisfie The Radiation Protection Manager (RPM), who is also the Plant (lead)

Health Physicist, reports administratively to the Radiation / Chemistry (Rad / Chem) Supervisor who in turn reports to an Assistant Station Superintendent who reports the Station Superintendent. When questioned about his direct access to the Station Superintendent on radiation protection matters the RPM said he has direct access to the Station Superintendent for matters related to radiation safety when necessar The inspector suggested that periodic, monthly or bimonthly meetings, be considered between the RPM and the Station Superintenden This was discussed at the exit meeting and will be reviewed during a future inspection. (50-456/85042-01; 50-457/85051-01).

The inspector reviewed the results of a station quality assurance audit (No. 20-85-26) conducted July 29, 1985. There were two observations concerning leak tests of radium sources. Corrective actions for these non-NRC licensed sources appeared to be adequate and timel No violations or deviations were identifie . Training and Qualifications The inspector reviewed the training and qualification aspects of the licensee's radiation protection and radwaste programs, including: training responsibilities, policies, goals, programs and methods; qualifications of radiation protection personnel; and the adequacy of the training for employees, contractors and visitor Site specific RCT qualification card training began in July 1985. The

, first class ~ of five RCTs will complete this portion of their training in September 1985. The licensee intends to have all RCTs qualified prior to fuel load. The inspector selectively reviesed the qualification card training course lesson plans; quizzes, and exams. No problems were note Nuclear General Employee Training (N-GET) for Contract Security guards is in progress. N-GET for plant employees. contractors, and visitors-is expected to begin in early 1986. The N-GET training program content will be reviewed in detail during a future inspectio No violations or deviations were identifie . External Exposure Control and Personal Dosimetry The-inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: adequacy of facilities, equipment, personnel and procedure m

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The instrument calibration facility has recently been vacated by construction personnel and has been turned over to the Rad / Chem Department. Calibration of portable radiation detection instruments is planned upon the receipt of the Shepard Calibrato The inspector reviewed the following new or recently revised radiation protection procedures for controlling external exposures to determine if they are consistent with 10 CFR, FSAR commitments, and good radiation protection practices. No problems were note BWRP 1100-1 Revision 0 Radiation Occurrence Report Trending and Reporting BWRP 1100-Al Revision 0 Examples of Radiation Occurrences BWRP 1200-A3 Revision 0 Dose Calculation Tables BWRP 1470-3 Revision 0 Trending of Personnel Contaminating Events BWRP 1610-3 Revision 0 Access to Containment No violations or deviations were identifie . Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment programs, including: facilities, equipment, personnel, and procedures affecting internal exposure control and personal assessmen The licensee has started whole body counting (WBC) station personnel to provide WBC base line data. Whole body counting is conducted by Braidwood Rad / Chem health physicists using a Canberra Fast Scan WBC which is located in a trailer near the training building. Review of the Fast Scan WBC procedure did not identify any problems. Calibration-of the WBC will be reviewed during a future inspectio A respirator test booth has been installed in the training building for initial respirator fit testing. There have been some equipment problems

. which has limited the numbers tested. The initial group being fit tested is the Operations Department-Fire Brigade. Respirator fit-test procedures will be reviewed during a future inspectio The inspector reviewed the following new or recently revised radiation protection procedures for controlling internal e,posures to determine if they are consistent with 10 CFR, FSAR commitments and good radiation protection practices. No problems were note L

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BWRP 1310-4 Revision 1 Inspection of Self Contained Breathing Apparatus (SCBA)

BWRP 1310-7 Revision 0 Charging of Self Contained Breathing Apparatus (SCBA)

BWRP 1340-3 Revision 0 Routine.Whole Body Counting with Fast Scan BWRP 1350-6 Revision 1 Calibration and Operation of the Gas Technical GX-82 Portable Gas Detection BWRP 1300-T1 Revision 1 Whole Body Counting Log BWRP 1300-T4 Revision 2 RCT Investigation of Whole Body Count BWRP 13C0-T7 Revision 0 Respiratory Equipment Log BWRP 1300-T17 Revision 0 Rad / Chem Breathing Air Compressor Log No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of instrumentation, equipment, and procedures and determination whether provision for control of radioactiva materials and contamination meet requirements and commitment Most of the health physics monitoring and measurement equipment remains in onsite storage. Licensee training and calibrations have not been completed for most instrumentatio No violations or deviations were identifie . Facilities and Equipment

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The inspector toured selected areas of the plant related to radiation protection, chemistry, and radwaste, including: the access control area; laboratories; counting room; office areas; radwaste building, and control room. Completion of equipment installation in the counting room and the high level chemistry lab is being delayed by construction modifications to those rooms. Installation, testing and calibration of equipment in the counting room and the high level chemistry is expected to continue after modifications are complete The inspector noted that'the area designated by the licensee as " access control" was small and would probably become very congested during startup and refuelings. This was' discussed at the exit interview. No other problems were note No violations or deviations were identifie e- _ -

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1 IE Information Notices The inspector reviewed licensee actions taken in response to selected IE Information notice IE Information Notice No. 85-42: Loose phosphor in Panasonic 800 Series Badge Thermoluminescent Dosimeter (TLD) Elements. Procedure NSTLD-1400-1 defines acceptance criteria for Panasonic dosimeters and will be used to accomplish that task. The procedure includes precautions and checks for

' loose phosphor. The licensee believes potential problems can be controlled or avoide IE Information Notice No. 85-43: Radiography Events at Power Reactor Radiation protection personnel were aware of the contents of this notice and stated necessary administrative control of radiographic activities are required by radiation protection procedures. All radiography is conducted on the back shifts and Braidwood radiation protection procedures are enforce . Preoperational Test Procedure Review The inspector reviewed portions of the following preoperational test procedures against the FSAR, SER, and Regulatory Guide 1.68:

BWPT-AR-10, Revision 0, Area Radiation Monitor BWPT-AR-10 is written to demonstrate operational capability of RM-11 radiation monitors, to verify alarm functions and check source activation. No problems were note BWPT-GW-10, Revision 0,-Braidwood Gaseous Waste System BWPT-GW-10 is written to demonstrate the operational capability of the Gaseous Waste system to perform its design function, to verify operation of automatic controls, set points, interlocks and alarms. No problems were note . Preoperational Test Review The inspector reviewed portions of the following preoperational test results in order to verify that testing is conducted in accordance with approved procedures and to independently verify the acceptability of test result BWSD-WZ 20, Revision 0, Chemical Waste Drain Syste The test was conducted during the period April to July 1985. No problems were noted with this tes No violations or deviations were identifie '

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13. Byproduct Material License No. 12-05650-17 The inspector reviewed the licensee's activities under NRC Byproduct Material License No. 12-05650-17 including: authorized material and use, exposure control, personal monitoring, and leak tests. Two 5 millicurie cesium-137 sealed sources are the only radioactive material on han They are in storage in their original shipping containers. No problems were note No violations or-deviations were identifie . Special Nuclear Material License No. SNM-1938 The inspector attempted to review the licensee's activities under this license. However, since no material has been received, this inspection has been reschedule . Exit' Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on August 23, 1985. The inspector summarized the scope and findings of the inspection and discussed the likely content of this inspection repor The licensee did not indicate that any of the information disclosed during the inspection could be proprietar In response to certain matters discussed by the inspection the licensee: dcknowledged the inspector's comment that because of the intervening management personnel between the Plant Superintendent and the RPM, it appears that periodic meetings between the two would be beneficial. (Section 4). Acknowledged the inspector's comment about the size of the area designated for access control. (Section 9).

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