IR 05000454/1986034

Insp Repts 50-454/86-34 & 50-455/86-29 on 860908-19.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection & Solid Radwaste Programs,Including ALARA Activities & IE Info Notice

ML20215F690
Person / Time
Site:	Byron
Issue date:	10/07/1986
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215F681	List: IR 05000454/1986034 ML20215F678
References
50-454-86-34, 50-455-86-29, IEIN-86-022, IEIN-86-22, NUDOCS 8610160327
Download: ML20215F690 (10)

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U.S. NUCLEAR REGUL'JORY COMMISSION

REGION III

Reports No. 50-454/86034(DRSS); 50-455/86029(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: September 8-19, 1982 Inspector: W. B. Grant b /8-7-84 Date Approved By: L. Robert Greger, Chief M - 7 -86 Facilities Radiation Protection Date Section Inspection Summary Inspection on September 8-19, 1986 (Reports No. 50-454/86034(DRSS);

50-455/86029(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection and solid radwaste programs including: organization and management controls; training and qualifications; exposure controls; control of radioactive material and contamination; surveys and monitoring; ALARA activities; allegation follow-ups; Unit 2 preoperational testing; solid radwaste shipments; I&E Information Notices; and status of previous inspection finding Results: No violations or deviations were identified.

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DETAILS Persons Contacted M. Bailey, Technical Staff

• W. Bielasco, Station Health Physicist

'W.' Bowman, Health Physics Consultant (ALARA)

• Burkamper, Quality Assurance Supervisor L.: Bushman, ALARA Coordinator R. Campbell, Technical Staff

• A. Chernick, Compliance Supervisor-J. Cook,-Regulatory Staff R. Flahive, Radiation / Chemistry Supervisor D. Goldsmith, Health Physics Group Leader

• T. Joyce, Assistant Superintendent Technical Services J. Langan, Regulatory Staff

• J._Pausche, Regulatory Group Leader

• R.'Querio, Station Manager-A. Slawinski, Technical StaffL . .

S. Sober, Health Physics Group Leader

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• J. Snyder, Quality Assurance Inspector

• C. Brockman, NRC Resident Inspector

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• Denotes those attending the exit meetin The inspector-also contacted members of_the training services,

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radiation / chemistry,- and engineering staff during this inspectio . General

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This inspection, which began at 10:00 a.m., on September 8, 1986, was conducted to examine the routine radiation protection and solid radwaste programs, the results of the increased management involvement.in the radiological control program,'and the preoperational status of Unit. .' (Closed) Open Item (455/83006-01): Concerning review of the location of

. area monitors to assure that each is properly located to serve its intended function. This activity h=.s been completed for all monitors involved with Unit 2. All the area monitors appear to be properly locate (Closed) Open Items (454/85022-09; 455/85020-01): Include a whole body count to MPC-hour conversion determination in the internal exposure control program. Standard Radiation Protection Procedure No. SRP 1340-2, Revision 0, August 1986, concerning this subject has been written and is in the review proces (Closed) Open Item (454/85022-12): Concerning procedures for alteration review and communication with operations personnel. A Deviation Report (DVR) was written concerning the inadvertent venting of the boric acid evaporators. The DVR was placed in Required Reading Program to alert the control room operators of the need to improve communications with radwaste operators when venting to the waste gas syste .

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(Closed) Open Item (455/85041-02): Concerning Unit 2 cross contamination from Unit 1 systems. An expanded routine survey programs of potential contaminated areas was implemented. Startup test personnel have been instructed to notify the Rad / Chem department of any test or work activities with crossover systems that may introduce contamination potentials. The inspector reviewed this program and no problems were identifie . Organization and Management Control The inspector reviewed the. licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self identification and connection of program implementation weaknesses, and effectiveness of audits of these program Since the last radiation protection inspection the following organizational and personnel changes were made:

• The Station Health Physicist (SHP) was transferred to Nuclear Services Health Physic * A Staff Health Physicist (HP) from Quad Cities Nuclear Power Station was promoted to SH * The Health Physics Group was reorganized. The duty HP, Lead Foreman, HP Group Leader-0perational Programs, and the HP Group Leader-Support Services now report directly to the SH * A Health Physics Foreman was transferred to the TLD progra * An RCT was assigned as Acting Forema The new Station Health Physicist (SHP) was appointed Radiation Protection Manager (RPM). The SHP's qualifications for RPM were reviewed and he appears to meet or exceed the ANSI N18.1-1971 qualification required by Technical Specification No. 6.3.1. The licensee continues to have regularly scheduled meetings between the RPM and the Station Manage Two audits of the radiation / chemistry program have been conducted during ,

1986 by the onsite QA department since the last radiation protection inspection. Corrective action was taken on the only finding. No problems were note The inspector reviewed Radiation Occurrence Reports (ROR) fo; 1986 thrcugh Augus There were 13 R0Rs written during this period. Corrective action on 12 of them have been completed; one is still being investigate Disciplinary action was taken for three RORs to date. No significant problems were note No violations or deviations were identifie *

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5. Training and Qualification The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, and radwaste programs, including: changes in responsibilities, policies, goals, and methods; qualification of newly hired or promoted radiation protection personnel; and provision of appro-priate radiation protection and radwaste training for station personne Also reviewed, were management techniques used to implement these programs and experience concerning self-identification and correction program implementation weaknesse Licensee personnel training records were selectively reviewed. All newly hired. radiation / chemistry technicians (RCTs) have completed a reactor systems course as part of their initial qualification training. This training course was developed to broaden the RCTs overall knowledge of plant system All RCTs will complete an annual reactor systems course as part of their requalification trainin No violations or deviations were identifie . Radiation Protection Procedures The inspection reviewed the following health physics procedures to determine if they are consistent with 10 CFR, FSAR commitments, and good health physics practices. No problems were note BRP 1100-T2, Revision 3, Routine Weekly Survey checklist BRP 1100-T3, Revision 2, Routine Monthly / Quarterly Survey checklist BRP 1100-T7, Revision 0, Effluent and Waste disposal Semiannual Report for Gaseous Effluents - Summation of all Releases BRP 1150-3, Revision 0, Preparation of the Semiannual Effluent Report and

. Annual Radiological Environmental Report

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BRP 1170-1, Revision 5, Administration Controls for Health Physics i Instrumentation l BRP 1200-T5, Revision 3, Radiation Exposure Investigation Report BRP 12a0-T34, Revision 1, Badge Registration Form i

BRP 1220-1, Revision 6, Film /TLD Badge Issuance BRP 1220-3, Revision 5, Quality test and Issuance of Electronic Personnel dosimeters BRP 1250-2, Revision 3, Film Badge /TLD Spiking BRP 1260-4, Revision 1, Calibration and Use of Eberline RM-16 RD17A Radiation Monitor

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BRP 1260-5, Revision 2, Calibration and Use of High Level Exposure Probes BRP 1260-6, Revision 1, Calibration and Use of Eberline EC4-5/DAI-5 Radiation Monitor BRP 1270-6, Revision 0, Certification of DCA multiple dosimeter calibrator to NBS traceability BRP 1280-13, Revision 1, Tritium grab sampling from general atomic process radiation monitor BRP 1300-A9, Revision 3, Respiratory requirements for airborne radioactivity areas BRP 1300-T16, Revision 2, Air sample activity data sheet BRP 1300-T17, Revision 2, Atmospheric tritium calculation forms BRP 1300-T20, Revision 1,-Self-contained breathing apparatus spare cylinder checklist BRP 1300-T23, Revision 0, Daily log for MS-2 BRP 1300-T24, Revision 0, CHI square worksheet for MS-2 M P 1310-3, Revision 4, Operation and use of self contained breathing apparatus BRP 1310-4, Revision 4, Inspection of self contained breathing apparatus BRP 1340-4, Revision 0, Action levels for indirect urinalysis results from acute and chronic intake BRP 1350-1, Revision 4, Calibration and operation of portable instruments for sampling airborne radioactivity areas BRP 1350-9, Revision 0, Operation and calibration of the MS-2 portable beta gamma counter BRP 1360-1, Revision 3, Air sampling of suspected and known airborne radioactivity area-BRP 1380-2, Revision 2, Atmospheric tritiem Analysis BRP 1400-T3, Revision 2, Radiation / Contamination survey BRP 1400-T12, Revision 1, Uniform contamination survey BRP 1460-5, Revision 0, Operation and use of the Eberline Model No. 212076 laundry monitor BRP 1470-2, Revision 2, Area and equipment decontamination BRP 1500-T3, Revision 4, Radioactive material shipment form

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BRP 1500-T6, Revision 1, Radioactive waste box survey worksheet BRP 1620-2, Revision 2, Radiological controls for steam generator work BRP 1740-1, Revision ~1, Radiation protection practices during accident conditions BRP 1740-2, Revision 4, Field operations of the Eberline SAM-2' stabilized assay meter i

i BRP 1750-2, Revision 1, Determination of compliance with 10 CFR 20 airborne release limits BRP 1750-3, Revision 1, Determination of compliance with 10 CFR 50, Appendix I, design objectives for liquid releases

, BRP 1750-4, Revision 1, Determination of compliance with 10 CFR 50, Appendix I, design objectives for gaseous releases BRP 1900-A1, Revision 1, Radiation protection training for escorted visitors

7. External Exposure Control and Personal Dosimetry

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The inspector reviewed the licensee's' external exposure control and

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personal dosimetry programs, including: changes in facilities, equipment, i- personnel, and procedures; adequacy of the dosimetry program to meet routine

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and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifi-cations; effectiveness of management techniques used to implement these programs, and experience concerning self identification and correction of program implementation weaknesses.

The inspector reviewed exposure results for 1986 to date; no exposures i exceeding NRC limits were identified. Approximately 2800 individuals are currently whole body film badged with some of these individuals also having extremity and multiple badging. The licensee has reduced the number of ,

people requiring film badges from a December 1985 high of 3700. This f- reduction effort is continuing. The total dose for 1986 through August was about 54 person-rem This period included two short maintenance outages ,

j of-2-3 weeks duration each.

L The HP staff reviews daily exposure updates to identify individuals I

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approaching their limit, and to contact the appropriate work supervisor and access control personnel when limits are approache Updates are

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maintained at access control. No problem were noted.

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No violations or deviations were identifie "

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. . Internal Exposure Control The inspector reviewed the licensee's internal exposure control and assessment program, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment; determination whether engineering control, respiratory' equipment, and assessment of individual intakes meet regulatory requirement; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs; and experience concerning self identification and correction of program implementation weaknesse Whole Body Count (WBC) results from March 1986, to date, were receive No results approaching the 40 MPC-hour evaluation level were note Reports generated by the WBC contractor are reviewed by the HPs to assure abnormalities and results exceeding the license's investigation level are identifie Calibration data of the standup Canberra Fast scan WBC indicated no problems; nor have daily check source readings (Co-60 and Cs-137) identified instrument drift or abnormalitie The WBC _ computer converts Maximum Permissible Body-Burdens (MPBB) to MPC-hours when the prescribed investigation level (3% MPBB for a single isotope; 5% MPBB total) is reached. The conversion has been proceduralized and will be included in Ceco's Standard Radiation Protection Procedures (SRP).

Air sample data for 1986 to date were selectively reviewed; no problems were noted. During plant tours, filtered auxiliary ventilation systems were observed in use in various cubicles where maintenance work was on goin No violaticas or deviations were identified.

, Control of Radioactive Materials and Contamination, Surveys and Monitoring The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: change in instrumentation,

equipment, and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; management techniques used to implement the program; and experience concerning self identification and correction of program implementation weaknesse The inspector reviewed records of routine and special radiation and contamination surveys conducted since April 1986. All surveys, routine and special, are reviewed by an HP foreman for completeness and any unusual conditions. No problem were note The inspector selectively reviewed survey instrument, portal monitor and an sampler calibration records. Instruments, monitors, and samplers appeared to be calibrated in accordance with procedures. Calibration

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ranges reflected applicable ranges encountered in the field. Responses were within tolerance levels. A computer tracking system is used to identify instruments and samplers requiring calibration within the upcoming mont No problems were note The active RWPs were selectively reviewed. RWPs contained current survey information. Approvals and ALARA reviews were included where require Administrative exposure limits are use Personnel contamination reports (PCR) were reviewed for 1986 to dat Personnel contaminations have not been extensive, 36 have been recorded in 1986 through August. PCRs are tracked. Beta dose equivalents are estimated for skin exposur On September 15, 1986, the license installed Nuclear Enterprises IPM-7, whole body friskers (Portal Monitors) at the exits from the Auxiliary Building on the 401' and 426' elevations. The monitors require a front and back frisk of about 20 seconds each. The time delays and some minor instrument problems appeared to cause backups during high egress times such as break time and lunch time. No other problems were note . Solid Radioactive Waste The inspector reviewed the licensee's solid radioactive waste management program, including: determination whether changes to equipment and procedures were in accordance with 10 CFR 50.59; adequacy of implementing procedures to properly classify and characterize waste, prepare manifests, and mark packages; overall performance of the process control and quality .

assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse Solid radwaste records were reviewed for 1986 to date. Radwaste shipments totaled about 7600 cubic feet and contained about 43 curies. No problems were note The licensee uses a contracted mobile solidification service for the packaging of spent resins as radwaste. All other solid dry active waste (DAW) is sorted in a HEPA filtered hood, and designated as compressible, noncompressible, combustible, noncombustible, or wet waste. -The combusti-ble material, which must contain no vinyls, is set aside for volume reduction (VR) when that system becomes operational. According to the licensee, 55 gallon drums of combustible DAW are in storage for VR. The wet DAW is dried and stored for VR if it is combustible. Noncombustibles and noncompressibles are packaged and shipped to a licensed burial sit No violations or deviations were identifie . I&E Information Notice IE Notice No. 86-22: Underresponse of Radiation Survey instrument to High Radiation Fields. Byron does not have any Eberline ESP-1 instruments discussed in this notic No violations or deviations were identifie '

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.1 Unit 2 Preoperational Tests The inspector reviewed portions of three preoperational tests of radiation monitors exclusive to Unit 2 operation AR 2.60.61 Area Radiation Monitoring Loop 1. The test was completed in August 1986. Test discrepancies have been completed or are in the process of being correcte PR 2.60.64 Process Radiation Monitoring Loop 4 gross failed fuel liquid radiation monitor. Test results were reviewed; no problems were note Test discrepancies have been or are being correcte PR 2.6065 Process Radiation Monitoring, Loop 5, containing seven process monitors. Test'results were reviewed; no problems were noted. Test discrepancies have been or are being complete No violations or deviations were identifie . Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including: changes in ALARA policy and procedures; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed were manage-ment techniques used to implement the program and experience concerning self identification and correction of program implementation weaknesses.

The ALARA group consists of the ALARA coordinator and a consultant health physicist. A representative of the ALARA group attends outage planning meetings preparing for the upcoming February 1986 outage. The station ALARA committee meets quarterly to discuss ALARA goals and activities, and the refueling outage preoperations. The inspector reviewed minutes of the ALARA committee for 1986. No problems were note No violations or deviations were identifie . Blowdown Line Leak On April 11, 1986, the licensee reported a leak from the blowdown line going to the Rock River. A leak developed in the 3 1/2 mile line near the river and saturated the ground at the leak site. Since the blowdown lino is occasionally used to discharge liquid radwaste, soil removed while repairing the pipe was sampled and sent to a contractor for analysis. The analysis showed the soil contained no detectable radioactivit No violations or deviations were identifie ,,

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15. Allegation (Closed) Allegation: Radiation protection at Byron Station (AMS No. RIII 85-A-0188). This allegation concerning denial of lead shielding requested by a welder was reviewed onsite on April 16, 1986. The welder was denied the use of a lead blanket for shielding a pipe reading 8 mR/hr on which he was going to sit. RCTs reportedly informed the welder it would take two days to do a stress analysis on the pipe before they would be allowed to put a lead blanket on it, and that 8mR/hr was not enough radiation to justify the effor According to radiation protection management personnel the use of the temporary shielding would require a stress analysis as would the addition of other weight, such as scaffolding, to piping. Radiation protection management stated that the RCTs should have; however, more fully explained shielding requirements and ALARA to the welder, and that their failure to do so was discussed with RCT The inspector discussed ALARA, pipe stress requirements, and the RCT's apparent insensitivity to the welder's request with the alleger, who appeared to be satisfied with the information. Although the allegation that lead shielding requested by a welder was not provided was substan-tiated, there are no regulatory requirements necessitating the provision of such shielding under the circumstances which existed. The major problem appeared to be the insensitivity of the RCTs to the welder's request; this problem.has been addressed by the license This allegation is considered close . Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection. The scope and findings of the inspector were summarized. The inspector also discussed the likely information content of the inspection report with regard to documents and processes reviewed during the inspection. The licensee identified no such documents / processes as proprietary.

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