ML20141A460

Responds to NRC Re Violations Noted in Insp Repts 50-456/97-08 & 50-457/97-08.Corrective Actions:Verified That All Vacuums in Auxiliary Bldg Were Properly Stored & Excess Vacuum Cleaners Removed from General Rpa

ML20141A460
Person / Time
Site:	Braidwood
Issue date:	06/16/1997
From:	Stanley H COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-456-97-08, 50-456-97-8, 50-457-97-08, 50-457-97-8, NUDOCS 9706230006
Download: ML20141A460 (5)

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Commonwealth Edimo Com1uny Draidw oud Generating bution

,. , Route al, liox 81 y Ilraceville,11. NH07%I9 l Tel 81 %H8 2801 ,

j June 16,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Reply to Notice of Violation NRC Inspection Report 50-456(457)/97008

~Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457

Reference:

C.D. Pederson letter to H.G. Stanley dated May 19,1997, transmitting Notice of Violation from Inspection Report 50-456(457)/97008 l

l The Reference letter contains a Notice of Violation (NOV) resulting from an l inspection of our Radiation Protection Program which ended on April 30, 1997.

During the inspection period, two violations were identified; however a response was required for only one of the issued violations. The attachment to this letter contains Comed's response to this violation.

Braidwood Station has worked hard to effectively plan radiological work and ensure l good radiation worker practices. These efforts resulted in the Station achieving a 1 l record low accumulated dose incurred during a Unit One refueling outage. We are l encouraged by these results and will continue to look for ways to improve.

l The following commitments were made in the attached response:

• BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically 1 Posted Areas," will be revised. FD e Tailgates will be conducted with work groups who use vacuum cleaners in i the Auxiliary Building to communicate the requirements of BwRP 6210-17.

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l Document Control Desk. 6/16/97 Pane 2 If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood P.-,ulatory . Assurance Supervisor, at (815) 458-2801, extension 2980.

ss H. ene tanley Site Vice President of>

l Braidwood Nuclear Generatir.g Station Attachment cc: A.B. Beach, NRC Regional Administrator, Region III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Oflice of Nuclear Safety, IDNS ohnfidadmasst 97108mt. doc t

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97008-02j Technical Specification 6.8.1.a requires that procedures be implemented for activities covered in Appendix A of Regulatory Guide 1.33.

Appendix A of. Regulatory Guide 1.33 recommends that radiation protection procedures be implemented for contamination control.

l l Procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in l

l Radiologically Controlled Areas", Revision 2, requires, in part, that vacuums i used in radiologically posted areas shall be controlled (i.e. locked) when l needed beyond the end of the work shift and that openings on the suction line l and hose ends be covered after each use to prevent the spread of I contamination. l l

Contrary to the above, an inspector identified that: I

a. On April 23 - 29,1997, vacuum cletners used in radiologically posted areas on the 364' and 401' elevations of the Auxiliary Building and needed beyond the end of the work shift were not locked.

b. On April 23 - 29,1997, vacuum cleaners located on the 401' elevation of the Auxiliary Building did not have the suction line and hose ends covered after each use.

REASON FOR THE VIOLATION BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"

requires vacuums to be controlled by keeping them locked and also requires the openings on the suction line and hose ends to be covered to prevent the spread of contamination. Vacuum cleaners in the Auxiliary Building were not stored in accordance with these procedure requirements. Once this concern was identified, an investigation was conducted to evaluate the potential causes.

In one case, a vacuum cleaner was found unlocked at the boric acid mixing area on the 401' elevation. This vacuum was permanently issued to Operating for non-contaminated boric acid cleanup. Individuals who used this vacuum were unaware of the requirement to lock vacuums or keep them in a locked area in the radiologically posted area (RPA).

Another vacuum cleaner was found unlocked in the Unit One 364' steam generator blowdown condenser room. This was an extra vacuum cleaner obtained from a 346' l storage cage. Since this vacuum was not issued from the 364' radiation protection i

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ATTACR\ TENT I REPLY TO NOTICE OF VIOLATION i

VIOLATION (50-456(457)/97008-02) zone, it is not known who used the vacuum and failed to follow the established storage requirements.

Similarly, for the case where a vacuum cleaner located on the 401' elevation of the Auxiliag Building did not have the ends covered, it is unclear what the hose had been used for and why the ends were left uncovered. Vacuum cleaners issued by Radiation Protection (RP) Technicians at that elevation are primarily used for vacuuming the IPM-8 monitors and general work.

Common causes for the above instances were determined to be the following:

1. An excessive number of vacuum cleaners are in the RPA making control more

. difficult.

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2. The procedure was overly restrictive. The requirement to lock vacuum I cleaners originated when Station Laborers controlled the vacuum program.

Once the program was transferred to Radiation Protection, the need to control the vacuum cleaners by locking them was no longer necessary; however the procedure requirement was not updated to reflect this.

3. Not all station work groups who use the vacuum cleaners were aware of the storage requirements. )

i C_ORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED 3

After this problem was identified, the Station had verified that all vacuums in the I Auxiliary Building were properly stored. In addition, excess vacuum cleaners have been removed from the general RPA.

ACTIONS TO BE TAKEN TO PREVENT RECURRENCE  :

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} Radiation Protection will maintain direct control over the vacuum cleaners stored in l the Auxiliary Buildmg.  !

l BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"  ;

will be revised. The procedure revision will provide guidance on new storage requirements. Vacuums will be separated into two categories: clean (non-i contaminated) RPA use or contaminated RPA use. Since the vacuum cleaners 4

designated for clean areas will not be used in centaminated areas, the requirement to cover the hose ends and suction line openings will no longer be necessary. This storage requirement will remain for the vacuums designated for use in contaminated areas, bowever. In addition, the requirement to lock the vacuums or keep them in a ,

locked area in the RPA will be removed.

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ATTACHMENT 1 REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97008-02)

Tailgates will be conducted with work groups who use vacuum cleaners in the Auxiliary Building to communicate the requirements of BwRP 6210-17.

DATE WHEN FULL COhfPLIANCE WILL BE ACHIEVED The procedure revisions and tailgates will be completed by July 15,1997.

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