IR 05000456/1997008: Difference between revisions

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{{Adams
{{Adams
| number = ML20141J930
| number = ML20149E601
| issue date = 05/19/1997
| issue date = 07/11/1997
| title = Insp Repts 50-456/97-08 & 50-457/97-08 on 970417-30. Violations Noted.Major Areas Inspected:Plant Support Performance
| title = Ack Receipt of 970616 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/97-08 & 50-457/97-08 on 970519
| author name =  
| author name = Grobe J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
| addressee name =  
| addressee name = Stanley H
| addressee affiliation =  
| addressee affiliation = COMMONWEALTH EDISON CO.
| docket = 05000456, 05000457
| docket = 05000456, 05000457
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-456-97-08, 50-456-97-8, 50-457-97-08, 50-457-97-8, NUDOCS 9705280262
| document report number = 50-456-97-08, 50-456-97-8, 50-457-97-08, 50-457-97-8, NUDOCS 9707180241
| package number = ML20141J903
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 14
}}
}}


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f U.S. NUCLEAR REGULATORY COMMISSION l
l July 11, 1997 Mr. H. Site Vice President Braidwood Nuclear Power Station l. Commonwealth Edison Company
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REGION lli l
R.R. #1, Box 84 Braceville, IL 60407 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-456/97008(DRS); 50-457/97008(DRS))
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l Docket Nos: 50-456; 50-457 Licenses No: NPF-72; NPF-77 i
Reports No: 50-456/97008(DRS); 50-457/97008(DRS)
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Licensee: Commonwealth Edison (Comed)
Facility: Braidwood Nuclear Power Station, Units 1 and 2 l
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Location: RR #1, Box 79  1 Braceville,IL 60407 l
Dates: April 17-30,1997 Inspectors: S. Orth, Senior Radiation Specialist Approved by: T. Kozak, Chief, Plant Support Branch 2 Division of Reactor Safety


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==Dear Mr. Stanley:==
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1 This will' acknowledge receipt of your letter dated June 16,1997, in response to our letter dated May 19,1997, transmitting a Notice of Violation associated with the inadequate control of vacuum cleaners within radiologically posted areas at the Braidwood Generating Station, Units 1 and 2. In your letter, you indicated that you planned to revise the applicable procedure and to provide additional training to site personnel concerning the required controls.
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9705280262 970519 PDR ADOCK 05003456 Q PDR


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We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.
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Sincerely,
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/s/ J. M. Jacobson (for)
EXECUTIVE SUMMARY
I John A. Grobe, Acting Director Division of Reactor Safety dh-'
:
C Docket Nos. 50-456;50-457 Licenses No. NPF-72; NPF-77 Enclosure: Ltr 06/16/97, H. G. Stanley,    lllllllllllllfllllll[jjlflllj Comed, to US NRC    < ..
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DOCUMENT NAME:G:DRS\ BRA 07_7.DRS To receive a copy of thle document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure
Braidwood Nuclear Plant, Units 1 & 2
"N* = No copy
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NRC Inspection Reports 50-456/97008; 50-457/97008 i
OFFICE Rill  e RIII  C RIII  ,A) RIII A,k l NAME S0rth:jpsW  GShear 4 3  RLanskburfPJW JGrob( W W
: This announced inspection included aspects of licensee plant support performance and, I
! DATE 07/ 9 /97  07/ 9 /97  07/ll /97  07/l1 W 7 T; UH-lCIAL RLCORU COPY 970718G41 970711 PDR Al".?5 05000456 G  PDR
specifically, an evaluation of effectiveness of the radiation protection program. This report
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covers a 2-week period of inspection performed by a regional radiation specialist. Two violations were identified concerning the failure to adequately implement procedures.


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Plant Suonort i
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The licensee effectively used past performance and work estimates to prepare dose
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estimates and goals for the 1997 Unit 1 refueling outage. Although the licensee's j  reviews of outage dose performance were generally thorough, the licensee did not
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]  trend the amount of dose attributable to re-work activities. (Section R1.1)
cc w/o encl: T. J. Maiman, Senior Vice President,
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  . Nuclear Operations Division
Implementation of the ALARA program was a strength. ALARA planning and pre-job meetings were thorough; the radiation protection staff effectively communicated radiological work requirements and implemented dose reduction techniques. Planning problems were identified by the licensee concerning the installation of steam generator gallery steel. Other minor problems were identified concerning coordination of work groups and the use of low dose areas. (Section R1.2)
!   D. A. Sager, Vice President, (  Generation Support H. W. Keiser, Chief Nuclear
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!  Operating Officer
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!            i T. Tulon, Station Manager l -T. Simpken, Regulatory Assurance
The whole body counter (WBC) was properly calibrated, and the quality control ;
!  Supervisor 1. Johnson, Acting Nuclear l  Regulatory Services Manager cc w/ encl: Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State liaison Officer Chairrnan, Illinois Commerce Commission Distribution:
program for the WBC was properly implemented. Problems were identified by the inspector concerning the calculation of radioactive materialintakes. (Section R1.3)
Docket Fde- Rlli PRR w/ encl    J. L. Caldwell, Rlll w/enci-TN ~ /encim/
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  ' / enc'l SRis, Braidwood, Byron,  Rlli Enf. Coordinator w/enci
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Two violations were identified concerning the failure to adequately implement procedures. A violation was identified for not properly locking the entrance to an  i area posted as a locked high radiation area. Another violation was identified for the failure to adequately follow procedures concerning control of vacuums within the radiologically protected area. Access to safety related equipment was relatively unencumbered by radiologicalimpediments. (Section R2.1)
 
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,     Report Details
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IV. Plant Sunnort j  R1 Radiological Protection and Chemistry (RP&C) Controls
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R1.1 Unit 1 Outaae Dose Estimates and Dose Control i
a. Insoection Scone (83750)
The inspector evaluated the licensee's process for developing outage dose goals for the Unit 1 re-fueling outage (A1R06). The inspector discussed the licensee's projected dose estimates with radiation protection (RP) staff, reviewed the licensee's historical data, and reviewed the licensee's current outage performanc In addition, the inspector discussed with the RP staff the oversight and control of outage dos b. Observations and Findinas The licensee maintained historical files for repetitive outage tasks and used the information as a basis for A1R06 estimates. The implementation of ALARA initiatives and lessons learned has resulted in an overall dose reduction for repetitive work activities during successive outage On March 29,1997, the licensee began a 53-day refueling outage on Unit 1. The licensee estimated an outage dose goal of 215 person-rem which included the following outage work:
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Steam Generator (SG) Tube inspections / Repairs (40.5 rem);
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Preparation Work for planned 1998 SG Replacements (29.2 rem);
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Valve No. RC8002C (Loop Stop Isolation Valve (LSIV)) Repair (15.8 rem);
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General Valve Work (10.2 rem);
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In-Service-Inspections (8.9 rem); and
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Reactor Head Work (S.5 rem).
Prior to A1R06, the plant staff submitted work duration estimates as part of the radiation work permit (RWP) requests. Based on the anticipated dose rates in the work area and the estimated work duration, the RP staff developed dose goals for non-routine outage evolutions. However, the RP staff indicated that the plant staff frequently overestimated the time required at the work site to perform the activit The RP ALARA planners compensated for the overestimates and reduced the time estimates based on a historical fraction of time at the work area versus total work crew time (i.e. preparation, meetings, etc.). RP management acknowledged the inaccuracies in the plant staff's time estimates and indicated that the staff was making improvements in this are The inspector reviewed the licensee's outage work progress and the initial work projections. With the exception of SG gallery steelinstallation (Section R1.2), the
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OC/LFDCB w/enci Zion w/ encl    R. A. Capra, NRR w/enci DRP w/enci LPM, NRR w/enci    TSS.w/ enc!   i DRS w/enci A. B. Beach, Rill w/enci  CAA1 w/enci    i DOCDESK w/enci i
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!        i licensee's outage performance was consistent with dose and time estimates. At the time of the inspection, the accumulated dose for the LSIV repair, in-service
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inspection (ISI) activities, and reactor head work was consistent or better than ;
initial outage estimate !
The licensee perform 9d daily reviews of outage dose. An ALARA planner prepared a daily report containing accumulated dose as a function of department and by each RWP. In addition, the report contained a daily dose for each individual within a '
department. The ALARA planner indicated that he used the report to identify RWPs which were at or above 70 percent of the estimated dose and to identify any <
disparities between individual doses within departments. The inspector observed !
that the report provided a good comparison of current performance data and the licensee's goals. The inspector also noted that the licensee monitored re-work activities and determined the percentage of total work that was attributed to re-work. However, the inspector observed that the RP staff did not have a measure of dose attributable to re-work activities. The licensee acknowledged that they had not separately accounted for this dose but planned on evaluating a method to perform this type of analysi I Conclusions l
The licensee effectively used past performance and work estimates to prepare dose j estimates and goals for the 1997 Unit 1 refueling outage. Although the licensee's 1 reviews of outage dose performance were generally thorough, the licensee did not trend the amount of dose attributable to re-work activitie R1.2 Unit 1 Outaae Work Performance and ALARA Imolementation Insoection Scone (83750)
The inspector reviewed aspects of the licensee's RP planning, attended pre-job meetings, observed work in progress, and reviewed licensee post-job evaluation The inspector also reviewed the 1:censee's implementation of the following procedures:
BwAP 700-1, "ALARA Policy Procedure", Revision 4, dated November 29, i 1994,and    )
BwAP 700-2, " Guidelines for an ALARA Action Review", Revision 9, dated August 27,199 Observations and Findinas
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The inspector observed some licensee initiatives in the ALARA program. During A1R06, the ALARA staff lowered the threshold for performing reviews. As required by Procedures BwAp 700-1 and BwAP 700-2, the licensee was required to perform ALARA Action Reviews if any the following conditions existed: (1) dose estimate for the work was greater than or equal to 1 rem total effective dose equivalent (TEDE); (2) working exposure rates were greater than or equal to i
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:  rem /hr; or (3) dispersable contamination ~ in the work area was greater than or equal i
to 1,000,000 disintegrations per minute (dpm) over 100 square centimeters. In
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addition to the required ALARA Action Reviews, the licensee also performed less
;  formal reviews of outage work activities which had total dose estimates between i
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0.1 and 1.0 rem TEDE. For these jobs, the licensee's objective was to better define ;
the dose goals, to increase awareness of ALARA/ dose reduction concerns, and to provide a better interface between the work group and the ALARA staff. The
  , inspector observed that the licensee achieved positive results from these reviews.
 
! For example, the scope of the residual heat removal (RHR) drain valve repair was i initially to replace the valve internals. However, the increased ALARA interface
!  resulted in the complete valve replacement which eliminated a 1 rem per hour
:  (rem /hr) hot spot within the plant. The inspector also noted that the several l reviews resulted in more aggressive dose goals. In addition, the licensee identified 4  that the requirements for determining when to conduct an ALARA pre-job meeting !
t were not well defined. The licensee planned to determine if thresholds, similar to L  those used as requirements for ALARA Action Reviews, should be used as j  requirements for pre-job meetings.
 
During the outage, the licensee p rformed repairs on the loop C SG LSIV (1RC8002C). In accordance witt. Procedures BwAP 700-1 and BwAP 700-2, the
;  licensee prepared an ALARA Action Review for the activity which contained a l
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comprehensive description of the anticipated radiological conditions, lessons learned, dose reduction techniques, and contamination control practices. The licensee used cameras to reduce personnel exposures. In addition, the inspector noted that a mock-up of the valve provided excellent training for both the work crew and the radiation protection technicians (RPTs) involved in the evolution. The inspector observed personnel completing this repair and noted good radiation worker (radworker) practices and good oversight of personnel by RPTs. As of April 30,1997, the licensee had accrued about 10.3 rem of exposare and anticipated about 1 rem in additional activities as compared to the original dose estimate of 15.7 re The licenses also removed, inspected, and replaced the Unit 1 lower internals (core barrel) to perform the 10 year ISI inspections of the reactor vessel welds. The inspector reviewed the planning and ALARA Action Review for the evolution and j found it to be comprehensive. Based on 1996 data from the licensee's sister plant l (Byron Station), the RP staff identified the potential for dose rates exceeding 15 rad l per hour (rad /hr) near the internals and general area dose rates exceeding 1 rad /hr on the 426' elevation of containment. With the exception of the two necessary crane operators, all other personnel monitored the evolution via cameras and !
robotics. As documented in the ALARA review, the RP staff emphasized the use of I cameras, the required posting and control of effected plant areas, the control of reactor cavity water level, and the communications with and monitoring of the two crane operators. Within the ALARA Action Review, the staff also identified contingency actions. Prior to the removal, the licensee conducted practice manipulations of the crane to ensure the work crew was well prepare i
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On April 18,1997, the inspector attended a prejob meeting for the replacement of the core barrel and noted that there were excellent discussions among the workers i  about the evolution. The staff was well prepared for the meeting, discussed i
radiological conditions and concerns, and discussed contingency actions. In
:  . addition, the staff reviewed the lessons leamed from the original core barrel
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removal. For example, during the removal, the licensee identified problems concerning the control of personnel access to containment. Prior to the evolution, the RP staff projected the potential dose rates in the containment and required that 4  no personnel were to be allowed above the 401' elevation of containment. Once
;  the 401' elevation and upper containment elevations were evacuated, RP staff was to restrict access to containment. During the evacuation verifications, the radiation protection manager (RPM) identified personnel preparing to enter containmen Consequently, he evacuated all areas within the containment building to ensure that no further problems were encountered. The licensee determined that a misunderstanding at the RP desk contributed to the problem. During the April 18, 1997, meeting, the RP staff described the issue and clearly communicated management's expectations to the plant staff. In addition, the licensee identified the need for additional lead for the crane operator, which resulted in a reduction in worker doses. The removal of the core barrel was accomplished for about 132 millirem (mrem) of dose. As a result of the lessons learned, the core barrel was re-installed for about 26 mrem of dos The inspector also reviewed the licensee's installation of reactor head o-rings. The pre-job meeting was well conducted. The RP and maintenance representatives were well prepared for the meeting. The maint3 nance supervisor discussed the scope of the evolution, emphasizing that the area under the reactor head was of greatest dose concern. The RP representative provided a thorough discussion of the RP concerns and RWP requirements, including dosimetry alarms, protective clothing requirements, high radiation area control considerations, and dose reduction techniques. The inspector observed good job performance and radworker practices, with some minor problems. For example, the inspector observed some coordination problems between work groups. As the maintenance crew was preparing to enter containment, the staff was informed that reactor head inspections had not been completed as scheduled. Since the reactor head inspections impacted the reactor head o-ring installation, the maintenance crew left the area and postponed the evolution. In addition, the inspector observed personnel  l donning an additional level of protective clothing at the job site instead of moving  '
to a lower dose area. The health physics and chemistry supervisor indicated that the observations revealed areas that could be improve .
The licensee identified problems concerning the planning of SG gallery steel work associated with the anticipated 1998 SG replacement. Approximately 2 weeks into the evolution, the RP staff's initial dose estimate of 3.5 rem was increased to about 12.5 rem. In an April 13,1997, ALARA Job-in-Progress Review, the licensee reviewed the work activity and identified some planing weaknesses. During the planning of the evolution, the licensee did not recognize that the early reduction of  ;
SG secondary side water level to support other critical work activities would result in an increase in general area dose rates for the SG gallery steelinstallation. In
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addition, the licensee underestimated the time in the radiologically posted area
 
  (RPA) required for the installation. The inspector noted that the licensee identified
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the problems early in the process and re-emphasized uposure reduction techniques
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: within the ALARA Job-in-Progress Review.
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; Conclusions l-
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!  Implementation of the ALARA program was a strength. ALARA planning and pre-
  * Commonwcahh Edison Company
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Braidwood Generatmg Station
  }ob meetings were thorough; the RP staff effectively communicated radiological work requirements and implemented dose reduction techniques. Planning problems i  were identified by the licensee concerning the installation of SG gallery steel. Other j  minor problems were identified concerning coordination of work groups and the use
  ,, Route el, Box 84 Braceville. IL 60407%19 Tel 814-15R2801 June 16,1997 l
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Document Control Desk      )
  ;  of low dose areas.
i U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Subject: Reply to Notice of Violation NRC Inspection Report 50-456(457)/97008  l
 
l  R1.3 Internal Dosimetry Proaram i
l Insnection Scone (83750)
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The inspector reviewed the licensee's intamal dosimetry program. The inspector aviewed the calibration and quality control of the whole body counter (WBC),
d  including the implementation of the following procedures:
a fj  BwRP 5410-7 " Quality Control Operations for Whole Body Count Systems", ;
Revision 0, dated April 22,1997;and    l
!-  BwRP 5410-8 " Canberra Fastscan Whole Body Counter Calibration", Revision 0,
],
dated December 15,1993.


i i  in addition, the inspector reviewed the licensee's April 12,1997, evaluation of
Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457 Reference: C.D. Pederson letter to dated May 19,1997, transmitting Notice of Violation from Inspection Report 50-456(457)/97008 l
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The Reference letter contains a Notice of Violatica (NOV) resulting from an
i  internal exposures of three SG workers and reviewed the licensee's implementation of procedure BwRP 5400-1 " Guidelines for a Comprehensive Bioassay Program", J Revision 1, dated December 27,199 Observations and Findinas The licensee determined personnel internal exposures via a monitoring program consisting of WBC results and alarming' portal contamination monitors. As required by procedure BwRP 5410-8, the licensee performed the WBC calibrations at an 18-month frequency. The current calibrations for the two WBCs were performed on January 1996 and March 1997. In performing the calibrations, the licensee used a tissue equivalent phantom and calibration sources traceable to the National Institute of Standards and Technology (NIST). The inspector noted that the licensee ,
  .spection of our Radiation Protection Program whi ch ended on April 30,1997.
prformed verifications to ensure that the new calibrations were acceptable. With i the cxception of some minor documentation problems, the inspector found the calibrations to the properly performe i


The licensee effectively implemented the WBC quality control (OC) program as ;
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.
defined in procedure BwRP 5410-7. The licensee maintained statistical control '
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checks of instrument p2rformance. Prior to each use and after every four hours of


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


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The following commitments were made in the attached response:
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  . BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas," will be revised.
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!  use,'the licensee performed a OC background test and a QC efficiency test. The WBC software verified that the results of the tests were within the licensee's  !
!  statistically derived acceptance criteria. A health physicist (HP) reviewed monthly  l
:  and quarterly OC data trends to identify performance biases and to identify and  i
:  reject invalid points (e.g. source not in counter or source drops during count). The  i
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inspector reviewed the monthly reports for December 1996 and January through  l
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March 1997 and did not observe any notable statistical biases. However, the  ;
l  inspector identified that the licensee's justi*ication for rejecting OC points was not l well documented, j
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;  The inspector reviewed the licensee's evaluation of intamal contaminations j
j  associated with SG work. On April 12,1997, three individuals alarmed portal . j
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contamination monitors when exiting the area. The RP staff decontaminated the  i
,  individuals and performed bioassay measurements via the WBC. The individuals'  !
l  initial results indicated intakes of about 5 25 nanocuries (nCi) of cobalt-58,3-6 nCi -
;  of cobalt-60, and 10-20 nCi of iodine-131. Subsequently, the licensee identified  l
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and corrected problems with the SG shield doors and with the high efficiency  l particulate air (HEPA) filtration unit which contributed to the unplanned  !
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contaminations. In accordance with procedure BwRP 5400-1, an HP evaluated the  i l  Intakes to determine if the intakes met or exceeded the licensee's derived  l j  investigation level (DlL), which was one percent of an annual limit of intake, if the l
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Dll was met or exceeded, the licensee was required to perform additional  i investigations and to determine and record the intamal dose. The inspector  l l  identified some errors in the licensee's calculations: (1) the licensee used the  ,
!  incorrect intake retention fractions in determining the DIL for the ingestion pathway ;
]  and (2) the licensee used the incorrect time of intake. The licensee performed  I i  additional calculations which verified that the errors had only a minor effect on the I
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l  r-mults and that the DILs were not exceeded. Although the intakes were below the
;  UA the calculational errors indicated a lack of attention to detail. The licensee  j i  discussed the matter with the HP and planned to provide additional reviews.


k Conclusions i
. Tailgates will be conducted with work groups who use vacuum cleaners in the Auxiliary Building to communicate the requirements of BwRP 6210-17.
l  The calibration of the whole body counter and the quality control program were
{  properly implemented. Problems were identified concerning the calculation of j  radioactive material intakes.


. R2 Status of RP&C Facilities and Equipment
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I R2.1 Control and Postino of Radioloaically Posted Areas (RPAs)
l insoection Scone (83750)
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I / U W 68/QVs enu...a W #
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; The inspector reviewed the radiological conditions in the Auxiliary Building (AB), l
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!  Containment Building (CB), and the Turbine Building (TB). The inspector reviewed  ;
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j the identification, posting, and control of radiological hazards as required by the  i i  following procedures:
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Document Control Desk. 6/16/97 '    Page 2
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If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.
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H. ene Stanley Site Vice President Braidwood Nuclear Generating Station Attachment cc: A.B. Beach, NRC Regional A6ninistrator, Regim III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS o.bnfidadmasst'S7108ntdoc
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ATTACHMENT 1
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l REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(4571/97008-02)
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BwRP 5010-1 " Radiological Posting and Labelling Requirements", Revision 5, dated !
l Technical Specification 6.8.1.a requires that procedures be implemented for l  activities covered in Appendix A of Regulatory Guide 1.33.
;  November 12,1996; and    l
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BwRP 5310-2 " Control and Access to High Radiation Areas and Very High I Radiation Areas", Revision 1, dated February 27,1996.


. In addition, the inspector reviewed the control of radiological vacuum cleaners
l  Appendix A of Regulatory Guide 1.33 recommends that radiation protection procedures be implemented for contamination control.
!  within the RPAs which is required by procedure BwRP 6210-17 "Use of Vacuum
;  Cleaners and Fans in Radiologically Posted Areas", Revision 2, dated September 16, J  1996.


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Procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Controlled Areas", Revision 2, requires, in part, that vacuums '
        ! _ Observations and Findinas
used in radiologically posted areas shall be controlled (i.e. locked) when l needed beyond the end of the work shiR and that openings on the suction line and hose ends be covered aRer each use to prevent the spread of contamination.
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}  The inspector cbserved that the licensee maintained good access to safety related ;
i equipment with minimal radiological impediments. Based on licenses survey data i i and independent measurements, the inspector verified that the licensee properly 1  posted areas within the AB, CB, and TB as required by procedure BwRP 5010-1. In
:-  addition, the licensee posted surveys on each floor of the AB to ensure that i i
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workers were aware of the radiological conditions. The inspector observed that individuals working in those areas were knowledgeable of radiological conditions
!  and RWP requirements.


i j  On April 17,1997, the inspector identified that a door posted sa a locked high
Contrary to the above, an inspector identified that:  )
!  radiation area (LHRA) was not locked. The door provided access to the high  l
a. On April 23 - 29,1997, vacuum cleaners used in radiologically posted areas on the 364' and 401' elevations of the Auxiliary Building and needed beyond the end of the work shiR were not locked.
:
'
integrity container (HIC) storage area in the Radwaste Building (RB) and was posted as " DANGER, LOCKED HIGH RADIATION AREA, > 1000 MREM /HR". The licensee
;  immediately secured the door and corrected a problem with the locking mechanism.


;  On April 21,1997, the licensee conducted a survey of the storage area and j  measured dose rates of 200-250 mrom/hr at contact with the only HIC in storag ,
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 aner each use.


Since dose rates in the area routinely exceeded 1000 mrem /hr when HICs were ;
REASON FOR THE VIOLATION l BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"
!  loaded, the licensee maintained the LHRA posting and control as a precautionary l 7  measure. Step G.2.c.1 of Procedure BwRP 5310-2 requires that radiation  !
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.
j  protection technicians post areas as " DANGER, LOCKED HIGH RADIATION AREA, j  > 1000 mrem /hr" when dose rates exist or potentially exist which are in excess of l_  1000 mrom/hr and less than 15000 mrom/hr. Step G.2.a.1 of procedure BwRP  :
]  5310-2 requires that when a normally locked high radiation area or very high
!  radiation area remains temporarily unlocked, additional positive controls shall be j  established to prevent unauthorized entry.


'
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
Technical Specification (TS) 6.12.2 requires, in part, that areas accessible to l personnel with radiation levels greater than 1000 mR/h at 45 cm from the radiation !
,
the requirement to lock vacuums or keep them in a locked area in the radiologically l posted area (RPA).


source or from any surface which radiation penetrates shall be provided with locked i  doors to prevent unauthorized entry. Procedure BwRP 5310-2 provides controls for l
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'
'
storage cage. Since this vacuum was not issued from the 364' radiation protection l
,  areas controlled as LHRAs. The failure to adequately implement procedure BwRP ;
5310-2 is a violation of TS 6.12.2. (50-456/97008-01 and 50-457/97008-01)
{  The licensee conducted a thorough investigation of the event and concluded that 1  there were no unauthorized entries into the area. Based on the resu!ts of the
;  investigation, the licensee (1) repaired the locking mechanism on the door to the l-,
l     9
.
i j
      '
a
    ,6-e,e e e v--  -


_ ___._ _____ _ - -
.,
  .
  .
HIC storage area and inspected / repaired all other LHRA door locks, (2) added preventative maintenance tasks to inspect / repair LHRAs on a six month frequency,
- and (3) reviewed the event with RPTs to reinforce the need to inspect the LHRA doors after a door has been operated. The licensee also revised procedure BwRP 5310-2 to require an independent verification of locked doors after any access to an LHR On April 23 - 29,1997, the inspector identified problems concerning the control of vacuum cleaners within the RPA. RP procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas", Revision 2, contained the following requirements: (1) "If the vacuum cleaner will be needed beyond the end of the work shift, the responsible department shall be responsible for controlling the vacuum (i.e. locked)" and (2) "After each use, the openings on the suction line and hose ends SHALL be covered to prevent the spread of contamination." On  i April 23,1997, the inspector and a licensee representative identified the followmg problems: (1) a vacuum cleaner stored for over one shift on the 401' elevation of the AB near the boric acid batch tanks was not locked and (2) the openings on l vacuum hoses were not covered in the 401' elevation RP storage area. On April 25 I and 29,1997, the inspector identified additional problems: (1) vacuuma stored for in excess of one shift in the 1 A residual heat removal (RHR) and in the Unit 1 blowdown condenser rooms were not locked and (2) the openings on vacuum hoses were not covered on vacuum cleaners stored in the 401' elevation RP storago area and in the 401' elevation scaffolding storage area. The inspector reported these problems to RMs who corrected each of the problem i Technical Specification (TS) 6.8.1.a requires that procedures be implemented for ,
activities covered in Appendix A of Regulatory Guide (RG) 1.33. Appendix A of RG !
1.33 recommends that RP procedures be implemented for contamination contro l Procedure BwRP 6210-17 provides controls for vacuums within RPAs to prevent l the spread of contamination. The failure to adequately implement procedure BwRP l 6210-17 is a violation of TS 6.8.1.a. (50-456/97008-02 and 50-457/97008-02). l The inspector noted that a number of problem identification forms (PIFs) concerning the implementation of the vacuum cleaner control program were initiated between l March and August of 1996 and observed that the licensee had completed  ;
corrective actions for the PIFs. The inspector noted that the initial PIFs were immediately corrected and the work group supervisor was notified. However, the {
licensee identified that the initial corrective actions had not resolved the issu During June and August of 1996, the licensee's corrective actions became more i comprehensive. The licensee revised the program, including the governing procedure, the responsibilities of each departinent, and the system by which :
vacuum cleaners were issued. The licentas did not fully complete all of the corrective actions until late September 1996. However, the inspector's observations indicated that the licensee's corrective actions were not fully :
effectiv !
l
      ,


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l, A'ITACHMEfff I i        i
      ,
!  REPLY TO NOTICE OF VIOLATION    l l. VIOLATION (50-456(457)/97008-02)    l
Two violations were identified concerning the failure to adequately implement j procedures. A violation was identified for not properly locking the entrance to an area posted as a LHRA. Another violation was identified for the failure to adequately follow procedures concerning control of vacuums within the RP Access to safety related equipment was relatively unencumbered by radiological impediment R6 Quality Assurance in RP&C Activities The inspector assessed the effectiveness of the licensee's identification and resolution of problems. The inspector reviewed PIFs generated by the licensee over -
        ,
the previous 12 month period to assess the licensee's evaluation of RP issues and to determine the effectiveness of the licensee's corrective actions. The inspector observed that the licensee's trending and analysis of personnel contamination events (PCEs) was thorough. The RP staff maintained a data base indicating the PCE and assigning a root cause, in addition, the licensee correlated the PCEs to significant plant events, i.e. refueling outages, SG work activities, etc. A licensee representative indicated that a number of recent PCEs had been attributed to contaminated protective clothing received from its laundry service. The inspector observed that the licensee was in the process of investigating the issue and developing corrective actions. The inspector noted that the actions taken by the licensee were appropriate. However, as described in Section R2.1, licensee's corrective actions for problems controlling vacuum cleaners within the RPA were not as effectiv V. Manaaement Meetinas X1 Exit Meetino Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on April 30,1997. The licensee acknowledged the findings presented. No proprietary information was identifie _ -. _ -. - - -- - -
zone, it is not known who used the vacuum and failed to follow the established storage requirements.
.
.
PARTIAL LIST OF PERSONS CONTACTED Licensee M. Cassidy, NRC Coordinator A. Creamean, Lead Radiation Protection Supervisor M. Finney, Lead Health Physicist - Operations A. Haeger, Health Physics and Chemistry Supervisor  l T. Simpkin, Regulatory Assurance Supervisor - Technical  '
R. Thacker, Lead Health Physicist T. Tulon, Station Manager l
      <
INSPECTION PROCEDURES USED IP 83750 Occupational f(adiation Exposure ITEMS OPEN, CLOSED, AND DISCUSSED Ooened 50-456/457-97008-01 VIO Failure to lock the entrance to an area posted as a I locked high radiation area  ,
l 50-456/457-97008-02 VIO Failure to follow procedures concerning the control of vacuum cleaners within the radiologically protected area l Closed      l None Discussed None


_ _ _ _ __ _ _ _ __  .
i
_ - . . _ __ .
  'Similarly, for the case where a vacuum cleaner located on the 401' elevation of the l Auxiliary Building did not have the ends covered, it is unclear what the hose had been i. 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.    )
  .
l 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.
    .
.
LIST OF ACRONYMS USED AB Auxiliary Building Dil Derived investigation Limit
'
DPM Disintegrations Per Minute HEPA High Efficiency Particulate Air
, HIC High integrity Container
'
HRA High Radiation Area
'
ISI in service inspection LHRA Locked High Radiation Area  '
LSIV Loop Stop Isolation Valve MREM Millirem MREM /HR Millirem per hour   ,
NCI nanocuries    '
NIST National Institute of Standards and Technology
. PCE Personnel Contamination Event PlF Problem Identification Form l QC Ouality Control i Radwaste Radioactive Waste RB Radwaste Building i
RG Regulatory Guide j RHR Residual Heat Removal RP Radiation Protection


'
2. The procedure was overly restrictive. The requirement to lock vacuum cleaners originated when Station Laborers controlled the vacuum program.
RPA Radiologically Posted Area RPT Radiation Protection Technician RP&C Radiation Protection and Chemistry
      '
RWP Radiation Work Permit SG Steam Generator 4 TEDE Total Effective Dose Equivalent


TS Technical Specification VIO Violation
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.
, WBC Whole Body Counter
,


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


i    13
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED After this problem was identified, the Station had verified that all vacuums in the Auxiliary Building were properly stored. In addition, excess vacuum cleaners have been removed from the general RPA.


_. _ . .._. _ - . . .. . . _ . . _ . _ _ _ _ . _ _ _ _ _ . _ _ . _ _ _ _ _ . . . _ _ _
ACTIONS TO BE TAKEN TO PREVENT RECURRENCE    ,
  ; * i        i
l
  *
        ,
        !
Radiation Protection will maintain direct control over the vacuum cleaners stored in the Auxiliary Building. l l
l J
BwRP 621017, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"
 
will be revised. The procedure revision will provide guidance on new storage l
        ;
'
;
. requirements._ Vacuums will be separated into two categories: clean (non-contaminated) RPA use or contaminated RPA use. Since the vacuum cleaners !
PARTIAL LIST OF DOCUMENTS REVIEWED
L designated for clean arnas will not be used in contaminated areas, the requirement to i  cover the hose ends and suction line openings will no longer be necessary. This l storage requirement will remain for the vacuums designated for use in contaminated j I
areas, however. In addition, the requirement to lock the vacuums or keep them in a (
.
.
ALARA Action Review Plans-      -
locked area in the RPA will be removed.
. Installation of Unit 1 Lower Internals (Core Earrel),
}  Addendum to Installation of Unit 1 Lower Internals (Core Barrel), and  !
        '


{  Disassemble / inspect / Repair / Reassemble 1RC8002 l i        l i  ALARA Job-in-Progress Review for RWP 97-4032, dated April 14,199 f i  Problem identification Forms (PIFs) Nos. 456 201-96-042900,456-201-96-143400,456-  1
,


!  201-96-143401,456-201-97-1120,456-201-97-1184, and 456-201-97-123 I
l
:.
j  Problem investigation Report No. 456-200-040, " Required Locked High Radiation Area
>
Door Found Unlocked"
!
:
:
.;
>-- -- , ,,  .-. .- . - - . - . . -


3 i
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a
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ATTACHMENT 1    1 i
l 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. I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED  l i
The procedure revisions and tailgates will be completed by July 15,1997,
      !
      !


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Revision as of 20:27, 26 October 2020

Ack Receipt of 970616 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-456/97-08 & 50-457/97-08 on 970519
ML20149E601
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 07/11/1997
From: Grobe J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Stanley H
COMMONWEALTH EDISON CO.
References
50-456-97-08, 50-456-97-8, 50-457-97-08, 50-457-97-8, NUDOCS 9707180241
Download: ML20149E601 (2)
v • d • e


Text

- --- .- -. -- . - . . . . . . -_-

O l

l July 11, 1997 Mr. H. Site Vice President Braidwood Nuclear Power Station l. Commonwealth Edison Company

!

R.R. #1, Box 84 Braceville, IL 60407 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-456/97008(DRS); 50-457/97008(DRS))

Dear Mr. Stanley:

1 This will' acknowledge receipt of your letter dated June 16,1997, in response to our letter dated May 19,1997, transmitting a Notice of Violation associated with the inadequate control of vacuum cleaners within radiologically posted areas at the Braidwood Generating Station, Units 1 and 2. In your letter, you indicated that you planned to revise the applicable procedure and to provide additional training to site personnel concerning the required controls.

We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

/s/ J. M. Jacobson (for)

I John A. Grobe, Acting Director Division of Reactor Safety dh-'

C Docket Nos. 50-456;50-457 Licenses No. NPF-72; NPF-77 Enclosure: Ltr 06/16/97, H. G. Stanley, lllllllllllllfllllll[jjlflllj Comed, to US NRC < ..

DOCUMENT NAME:G:DRS\ BRA 07_7.DRS To receive a copy of thle document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure

"N* = No copy

,

OFFICE Rill e RIII C RIII ,A) RIII A,k l NAME S0rth:jpsW GShear 4 3 RLanskburfPJW JGrob( W W

! DATE 07/ 9 /97 07/ 9 /97 07/ll /97 07/l1 W 7 T; UH-lCIAL RLCORU COPY 970718G41 970711 PDR Al".?5 05000456 G PDR

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c.._->__._._.__ . - . . - . . . _ _ . _ . _ . . . . _ _ . _ . _ _ _ _ . _ . . . _ . _ . . _ _ . . . . _ _ . . . . _ _ . .

O

.

l 1 l

-

t l H. July 11, 1997' l t

!

l l

cc w/o encl: T. J. Maiman, Senior Vice President,

. Nuclear Operations Division

! D. A. Sager, Vice President, ( Generation Support H. W. Keiser, Chief Nuclear

! Operating Officer

! i T. Tulon, Station Manager l -T. Simpken, Regulatory Assurance

! Supervisor 1. Johnson, Acting Nuclear l Regulatory Services Manager cc w/ encl: Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State liaison Officer Chairrnan, Illinois Commerce Commission Distribution:

Docket Fde- Rlli PRR w/ encl J. L. Caldwell, Rlll w/enci-TN ~ /encim/

' / enc'l SRis, Braidwood, Byron, Rlli Enf. Coordinator w/enci

,

'

OC/LFDCB w/enci Zion w/ encl R. A. Capra, NRR w/enci DRP w/enci LPM, NRR w/enci TSS.w/ enc! i DRS w/enci A. B. Beach, Rill w/enci CAA1 w/enci i DOCDESK w/enci i

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I i

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!

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. . _ . . _ . . _ . . - - _ _ . . . . . . , , . _ . - . . . - , ,_ _ .

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.,

  • Commonwcahh Edison Company

"

Braidwood Generatmg Station

,, Route el, Box 84 Braceville. IL 60407%19 Tel 814-15R2801 June 16,1997 l

Document Control Desk )

i U.S. Nuclear Regulatory Conunission Washington, D.C. 20555 Subject: Reply to Notice of Violation NRC Inspection Report 50-456(457)/97008 l

Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457 Reference: C.D. Pederson letter to dated May 19,1997, transmitting Notice of Violation from Inspection Report 50-456(457)/97008 l

The Reference letter contains a Notice of Violatica (NOV) resulting from an

.spection of our Radiation Protection Program whi ch 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 good radiation worker practices. These efforts resulted in the Station achieving a record low accumulated dose incurred during a Unit One refueling outage. We are enccuraged by these results and will continue to iook for ways to improve.

The following commitments were made in the attached response:

. BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas," will be revised.

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

,

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I / U W 68/QVs enu...a W #

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Document Control Desk. 6/16/97 ' Page 2

If your staff has any questions or comments concerning this letter, please refer them to Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, extension 2980.

e g ./

H. ene Stanley Site Vice President Braidwood Nuclear Generating Station Attachment cc: A.B. Beach, NRC Regional A6ninistrator, Regim III G.F. Dick, Jr., Project Manager, NRR C.J. Phillips, Senior Resident Inspector F. Niziolek, Division of Engineering, Office of Nuclear Safety, IDNS o.bnfidadmasst'S7108ntdoc

. _ _ _ _ . . ._ _ _ . . . _ -

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ATTACHMENT 1

,

l REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(4571/97008-02)

i I

l Technical Specification 6.8.1.a requires that procedures be implemented for l activities covered in Appendix A of Regulatory Guide 1.33.

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

Procedure BwRP 6210-17, "Use of Vacuum Cleaners and Fans in Radiologically Controlled Areas", Revision 2, requires, in part, that vacuums '

used in radiologically posted areas shall be controlled (i.e. locked) when l needed beyond the end of the work shiR and that openings on the suction line and hose ends be covered aRer each use to prevent the spread of contamination.

Contrary to the above, an inspector identified that: )

a. On April 23 - 29,1997, vacuum cleaners used in radiologically posted areas on the 364' and 401' elevations of the Auxiliary Building and needed beyond the end of the work shiR 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 aner each use.

REASON FOR THE VIOLATION l 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 l 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'

storage cage. Since this vacuum was not issued from the 364' radiation protection l

.

. , _ . - _ . . - _ _ . . . .

. ... .

  • +

.

l, A'ITACHMEfff I i i

! REPLY TO NOTICE OF VIOLATION l l. VIOLATION (50-456(457)/97008-02) l

,

zone, it is not known who used the vacuum and failed to follow the established storage requirements.

i

'Similarly, for the case where a vacuum cleaner located on the 401' elevation of the l Auxiliary Building did not have the ends covered, it is unclear what the hose had been i. 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. )

l 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.

2. The procedure was overly restrictive. The requirement to lock vacuum 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.

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

ACTIONS TO BE TAKEN TO PREVENT RECURRENCE ,

l

,

Radiation Protection will maintain direct control over the vacuum cleaners stored in the Auxiliary Building. l l

BwRP 621017, "Use of Vacuum Cleaners and Fans in Radiologically Posted Areas,"

will be revised. The procedure revision will provide guidance on new storage l

'

. requirements._ Vacuums will be separated into two categories: clean (non-contaminated) RPA use or contaminated RPA use. Since the vacuum cleaners  !

L designated for clean arnas will not be used in contaminated areas, the requirement to i cover the hose ends and suction line openings will no longer be necessary. This l storage requirement will remain for the vacuums designated for use in contaminated j I

areas, however. In addition, the requirement to lock the vacuums or keep them in a (

.

locked area in the RPA will be removed.

,

l

>-- -- , ,, .-. .- . - - . - . . -

-

-

%.

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e .

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ATTACHMENT 1 1 i

l 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. I DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l i

The procedure revisions and tailgates will be completed by July 15,1997,

!

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