IR 05000454/1990026

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Insp Repts 50-454/90-26 & 50-455/90-26 on 901211-12 & 910107-11.No Violations Noted.Major Areas Inspected:Insp of Radiological Protection,Radwaste,Transportation Programs Including:Alara & Implementation of Program
ML20029A070
Person / Time
Site: Byron  Constellation icon.png
Issue date: 01/23/1991
From: Dan Barss, Grant W, Snell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20029A062 List:
References
50-454-90-26, 50-455-90-26, NUDOCS 9102040012
Download: ML20029A070 (9)


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U.S. liUCLEAR REGULATOR" COMl11SS10ll REG 10ll 111 Report ilos. 50-454/90026(DRSS); 50-455/90026(DRSS)

Docket flos. 50-454; 50-455 License flos. flPF-37; flPF-66 Licensee: Conaonwealth Edison Company Opus West 111 1400 Opus Place Downers Grove, IL 6W 15 facility flame:

Byron Station, Units 1 and 2 Inspection At:

Dyron Site, Byron, Illinois Inspection Conducted:

December 11-12, 1990 and January 7-11, 1991 Mb

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Inspectors:

W. B. Grent ate o bw

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o. Barss Date W

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Approved By: William Snell, Chief Radiological l 'Lkt Controls and Emergency Preparedness Date ~

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Section InspectionSunmary2 Inspection on December 11-12, 1990 and January 7-11,1991(Report flo. SD W 7E 026(Dhss); 50-455/90026TDRSS))

Areas Inspected:

Routine, unannounced,liispection of radiological protect' ion, radwaste, and transportation programs including:

aspects of the licensee's operational radiation protection program (IP 83750), liquid and gaseous radwaste management program (IP 84750), and solid radioactive waste management and transportation of radioactive materials (IP 86750),

including changes since the last inspection, audits and surveillances, exposure control, ALARA, implementation of solid, liquid and gaseous radioactive waste program and records of shipment of low-level waste for disposal. The inspector was accompanied by two inspectors from the Illinois Department of liuclear Safety on December 11, 1990, during the inspection of the licensee's program for packaging, shipment and transportation of radio-ective material.

Results:

The radiation protection and radwaste programs appear to function E and to be effective in protecting the health and safety of workers and the public.

lio violations or deviations were identified. A strength observed during the inspection was the good management support of the radiation protection program.

9102040012 910124 PDR ADOCK 05000454

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DETAIL _S 1.

Persons Contactsd H. Ahlgrim, Radiation Protection Training Coordinator

  • S. Barrett, Radiation Protection Supervisor

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S. Bell, Health Physicist

  • D. Berg, Onsite Nuclear Safety
  • D. Brindle, Regulatory Assurance Supervisor L. Bushman, ALARA/ Operations HP Group Leader W. Carl, Lead Health Physicist, Technical

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J. Capp, Health Physics Foreman A. Chernick, Training Supervisor

  • W. Grundmann, NQP Engineer
  • P. Johnson, Technical Staff Supervisor J. McLindsay, Senior Work Analyst R. Moredock, Training R. Hunson, ALARA Analyst

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C. Repass, Training

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  • K. Schwartz, Production Superintendent T. Tillman, Group Leader Radwaste/ Ventilation
  • R. Ward, Technical-Superintendent

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J. Weitzel, REP Coordinator D. Winchester, QA Superintendent

  • E. 7.ittle, Regulatory Assurance Staff
  • W. Kropp, NRC Senior Resident inspector The inspectors also contacted other licensee representatives.
  • Denotes those present at the exit meeting.

.2.

General The inspection was conducted to review routine aspects of the radiation protection, radwaste and transportation programs during power operations.

The inspection included tours of the auxiliary building, fuel handling building, turbine building, and the low-level radwaste process and storage facility; observation of work in progress; review of licensee

records and reports; and discussions with licensee and contractor personnel.

l 3.-

Changes (IP 83750,84750,86750)

The inspectors reviewed changes in personnel, facilities, equipment.

program and procedures that could affect the occupational radiation protection program.

Two additional Health Physicists (HP) have been hired.

One is a degreed HP who transferred from the Corporate Emergency Planning Group and the other has a degree in Nuclear Engineering and had been working in the L

Regulatory Assurance Group at Byron. An additicnal 12 8 Radiation l

Protection Technicians (RPTs) were added to the group.

Seven of these l

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have completed their B training and are qualified B technicians.

The remaining five have completed formal classroom studies at the Production Training Center (PTC) and are currently completing on the job training (0JT) qualifications at Byre,.

4.

Training and Qualifications of Radiation Protection Personnel (IP 83750)

Selected training records were reviewed which indicated that Radiation Protection (RP) personnel were being trained in accordance with

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established training program requirements. The training program includes several phases starting with generic initial training, llowing conducted by the licensee's PTC, for a'il new RP technicians.

Fo the generic training each candidate is provided with a series of site

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specific courses as well as a period of OJT. After successfully J

completing all generic and site specific initial training along with

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the OJT, candidates are given a job performance examination to measure competency and mastery of required knowledge and skills. Successful performance by a candidate during the job perfornance examination leads to certification as a B RPT. After two years of experience a similar multiphase training process is completed leading to certification as an A RPT.

Both A and B RPTs attend annual retraining courses as required by established program requirements.

This retraining consists of a core of required courses and other specific courses determined to be appropriate.

Input from supervisors, technicians and training personnel

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are considered in developing the full syllabus. Though not required

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by the licensee's training program, supervisory personnel also attend retraining courses.

The licensee also has a required reading program which provides

.another mechanism for ensuring RP personnel remain current in the latest developments.

Items such as a summary of recent procedure

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' changes, new equipment or procedures and recent operational events at the site or in the industry are included in the required reading

list.

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Before B RPTs are certified as A RPTs they must complete a site.

specific systems training course. Through discussion with cognizant licensee personnel it was learned that the training program is being revised to require completion of the site specific systems courses before certification as a B Technician, i.esson plans for the site specific systems training courses were reviewed and found to include-adequate scope to give a good general

It was noted that only one lesson plan included a plant overview.

terminal knowledge objective (TKO) that specifically addressed the radiological significant of the system being discussed.

It is recommended that each lesson plan should include a TKO concerning the radiological significance of the associated system. This would provide emphasis to developing an awareness of Al. ARA concerns associated with -cach system.

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j The licensee has initiated a two day training course for personnel assigned decontamination tasks.

From discussions with licensee personnel it seems this training has been ef fective in improving the

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quality of work performed and the results of decontamination efforts,

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i Interviews were conducted with twelve percent of the licensee's RPTs.

Individuals were randomly selected by the inspector. Those personnel interviewed all conveyed a positive image of competent professionals I

who were well trained and motivated to perform there assigned responsibilities.

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Information was conveyed to the inspector that some minor attitude j

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problems exist, in that some site employees feel that RP concerns are more.of a hinderance than a help.

It was not perceived by the r

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inspector that this feeling was prevalent, and probably was limited l

to only a few isolated cases.

The licensee should continue to encourage and instill in all site personnel the proper attitude

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concerning following necessary radiological safety precautions.

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No violations or dev10tions were identified.

6.

Audits and Surve111ances (IP 83750,84750,86750)

The inspectors selectively reviewed the results of Quality Assurance (QA) audits and surveillances conducted by the licensee since the last

. inspection. Also_ reviewed were the extent of the audits and surveillances, their thoroughness and the qualifications of the auditors.

One audit of radiation protection was conducted during this period.

Audit items included:

procedure issuance and control, instrement

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calibration, exposure control, contamination control, contamination and radiation surveys, radioactive source control, radiation occurrence reports, ALARA, trending, whole body counting and respirator issuance. The one observation regarding an unqualified person doing radiation surveys (Chemistry Technician) was identified and corrective action was completed.

Surveillances of radiation protection and radwaste activities were

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selectively reviewed.

Corrective actions that were required appeared

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to be timely and technically sound.

The quality assurance surveillance program enables the auditors to conduct a large number of performance cased surveillances.

The inspectors reviewed documentation of surveillances performed. No problems were noted.

No violations or deviations were identified.

6.

External Exposure Controls (IP 85750)

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The licensee's external exposure control program was reviewed, including:

changes in facilities, equipment, personnel and procedures; adequacy of dosimetry program to meet routine and emergency needs; dose tracking

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capabilities; required records, reports and notifications; ef fectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation

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weaknesses.

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The inspectors verified that there were no changes in the licensee's exposure evaluation, badge spiking QA/QC, extremity, neutron or multiple

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badge monitoring programs. No problems were noted.

l The licensee's exposure reports for 1990 were reviewed.

No exposures i

greater than 10 CFR 20.101 limits were noted. The highest annual dose i

received by a station worker for 1990 was approximately 2500 millirem.

five contractors are listed as having annual doses in excess of 3000

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millirem, the highest being 3688 millirem. According to dosimetry

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records reviewed, all five contractors were Westinghouse specialists who came in to work on the Unit 2 upper internal bent guide pins in October 1990, and all had arrived at Byron'with greater-than 2500 millirem.

Requests for increased administrative exposure limits were reviewed for approval status and contrul.

No problems were noted.

The inspectors selectively reviewed Radiation Work Permits (RWPs) and

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associated radiation surveys, observed prejob briefings and ALARA briefings and observed work being performed under selected RWPs.

No significant problems were noted.

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No violations or deviations were identified, d

7.

Internal Exposure Control (IP 83750)

The licensee's internal exposure control and assessment program was reviewed, including: changes in facilities, equipment, personnel, respiratory protection training; and procedures affecting internal exposure control and personal assessuent; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; 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-indentification and correction of program implementation weaknesses.

The licensee's control program for internal exposure includes use of engineering controls, surf ace and airborne survey data, respiratory protection equipment and direct surveillance of selected work activities. A selected review of air sample data and smear survey results was made.

No problems were noted. The licensee has purchased

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-six-lapel air samplers and will investigate their usefulness on different jobs.

A review of the licensee's whole body count records indicated that no-exposures in excess of the 40 HPC-hour control measure occurred during 1990. MPC-hour determinations were being tracked.

No problems were noted.

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The inspectors reviewed the performance test (calibration) results for the f astscan Whole Body Counter (WBC) at the Byron Station.

The Fastscan WBC was tested on November 29, 1990 to evaluate counting system perf oruance.

Fastscan system testing was performed using procedures developed by Canberra in accordance with ANSI N13.30 standard specifications. Test counts were performed to evaluate WBC measurement accuracy, precision and sensitivity. Special radioactive sources and reference phantoms were used for replicate measurements of test nuclide activity in the lung, whole body and thyroid source distributions.

No problems were noted.

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No violations or deviations were identified.

8.

Control of Radioactive 14aterial and Contamination, Surveys and lionitoring (IP 83750)

The inspector reviewed the licensee's program for control of radioactive materials and contamination, surveys and monitoring, including:

adequacy of supply, maintenance and calibration of contamination survey and monitoring equipment; effectiver. css 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.

There were about 500 Personnel External Contaminations (PECRs)

reported in 1990. Of these 47% (234) were shoes, 21% (106) were other clothing, and 38% (157) were skin. Of the 500 PECRs, 362 were below 10K dpm.

Seven personnel contaminations have been recorded in 1991, to date. The licensee tracks personnel contaminations to determine problem areas and repeat offenders. No specific cause has been determined for the increase in PECRs in 1990.

The inspectors observed the removal of the Burnable Poison Rod Assembly (BPRA) from the Spent Fuel Pool prior to returning it to the vendor.

The operation was performed using procedures for handling highly contaminated, possibly highly radioactive equipment probably containing hot particles. An RPT was in constant attendance, hot particle procedures were in effect and were observed. The transfer went smoothly with a few minor problems. The assembly read 140 mR/hr contact on the bottom end.

During a tour of the Auxiliary Building, the inspectors observed an The area apparent housekeeping problem in a contractor storage area.

was being used to store the contractor's tools and equipment some of which had fixed contamination. The housekeeping was poor.

Radwaste shipping drums were used to store what appeared to be bagged contaminated Bagged, equipment on which wood and metal scrap had been piled.

apparently contaminated, chain hoists were hanging on a rack with apparently clean chain hoists. There was also an electric grinder in the room with indications it had been used in this radiologically l

A subsequent survey of the grinding wheel by radiation controlled area.

protection found no detectable contamination on the wheel; however, it i

is a poor radiological practice to have a grinding wheel within a l

radiologically controlled area, considering the wheel was not posted l

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"Do not use-on contaminated equipment" or in any other manner. This matter was discussed at the exit meeting and will be reviewed during a future inspection.

l No-violations or deviations were identified.

Maintaining Occupational Exposures ALARA (IP 83750)

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The inspectors reviewed the licensee's program for maintaining occupational exposure ALARA, including: ALARA grosp staffing and qualifications; changes in ALARA policy and procedures, and their implementation; ALARA considerations for maintenance and refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them.

The total station dose for 1990 was 432 person-rem, of which about 256 person-rem was attributed to the Unit I refueling / maintenance

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outage and 129 person-rem was attributed to the Unit 2 refueling /

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r maintenance outage. The licensee's goal for 1990 was 510 person-rem, It was learned through discussions with cognizant licensee personnel

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that-there-is no current on going mechanism for general plant workers to provide input for improvements in ALARA considerations.

The licensee does attempt to conduct post-job debriefings to obtain suggestions for improvements to work practices which would help reduce exposures and waste.

However, these debriefs are occasionally somewhat less effective because of other pressing requirements. The licensee should consider establishing a mechanism to encourage all employees to evaluate and recommend improvement in work practices which will lead to reaching ALARA goals.

The ALARA/ Operation HP Group Leader was called to active military duty on January 9,1991. The ALARA Engineer will be acting grcup leader until his return.

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No violations or deviations were identified.

10.

Plans and Preparations (IP 83750)

The inspectors reviewed the licensee's planning-and preparation for the Unit I refueling / maintenance outage scheduled for September 1991.

The licensee has plans to purchase a reactor head flange decontamination machine which is intendeo to reduce the dose-required to clean the reactor head flange. There are also plans to replace the old IRT Portal monitors-at access control and in the guard house with state of the art PM-7 Portal monitors.

No violations or deviations were identified.

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Solid Radioactive Waste (IP 86750 The licensee's solid radioactive waste management program was reviewed, including:

determination whether changes to equipuent 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 weaknesses.

According to licensee representatives and licensee records, there were 31 shipments of dry active waste (OAW), filters and dewatered resins

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Twenty one shipments were directly to the burial sites i

during 1990.

and 10 were to the licensee's vendor for future shipment to a burial An onsite vendor representative performs dewatering of filters site.

and demineralizer resins and sludge in vendor supplied steel liners and high integrity containers (HICs).

Licensee QA/QC personnel verify that the dewatering / solidification meets llRC and burial site requirements.

The inspectors verified that classification, characterization and shipping of solid radwaste were performed in accordance with regulatory requirements and licensee procedures.

110 violations or deviations were identified.

Process Radiation Area Radiation and Effluent Radiation Monitors (IP 12.

M7%)

Calibration (surveillance) records and procedures for area, process and effluent monitors were selectively reviewed. The inspectors verified that the containment and auxiliary building monitors, the

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pipe tunnel radiation monitors, the high range containment monitors and the main steam line monitors for Units 1 and 2 had been checked, calibrated and maintained as required. Alarm / trip setpoints were verified as properly set to meet design objectives.

110 violations or deviations were identified.

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13, Engineered-Safety-Feature Filtration and Control Room Habitability Systems (IP 84750)

Technical Specifications require filter testing of the control room makeup filter system, the non-accessible exhaust system and the fuel building exhaust ventilation system. The inspectors reviewed records of tests performed on these systems and discussed testing procedures The review included with the System Engineer responsible for the tests.

both in-place tests of HEPA filters and iodine absorber units as well as laboratory tests of activated carbon samples.

Surveillance testing has been timely and test results have met acceptance criteria.

No problems were noted.

110 violations or deviations were identified.

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o 14, Transportation of Radioactive Materials (IP 86750_)

The licensee's transportation of radioactive _ materials program was reviewed, including: determination whether written implementing precedures were adequate, maintained current, properly approved and acceptably implemented; determination whether shipments were in compliance with HRC and 00T regulations and the licensee's quality assurance program;-determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notification; and experience concerning identification and correction of programmatic weaknesses.

Selected records of radioactive material shipuents made in 1990 were (

reviewed. The. shipments appeared to have been made in accordance and the with the requirements of 10 CFR 61 and 71, 49 CFR 170-179, licensee's procedures. The. licensee QA and QC_ groups provide good oversite of shopping activities.

Ho violations or deviations were identified.-

15.

Exit Interview-(IP 30703)

The inspector _ met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on January 11,1991, to discuss the scope and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.

The licensee did not identify any such documents / processes as proprietary.

The following matters were discussed specifically by the inspector.

The-housekeeping and'the electric grinder in the storage area in a.

the auxiliary building (Section 9).

b.

The additions of two HPs and twelve technicians to the Radprotection staff-(Section 3).

The apparent lack of a-formal ALARA_ suggestion program (Section 5).

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I UNITED STATil p.* t8 009

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NUCLE AR REGULATOAY COMMissl0N

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JAN 2 41931

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Docket No. 50-454 Docket No. 50-455 Commonwealth Edison Company ATTH: Mr. Cordell Reed

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Senior Vice President Opus West 111 1400 Opus Place - Suite 300 Downers Grove, 11 60515 Gentlemen:

This refers to the routine safety inspection conducted by Messrs. W. B. Grant and D. Barss'of this office on December 11 and 12,1990, and January 7-11, 1991, of activities at the Byron Station, Units 1 and 2, authorized by NRC Operating Licenses No. NPF-37 and No. NPF-66, and to the discussion of our findings with Messrs. R. Ward and K. Schwartz and others of your staff at

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j the conclusion of the inspection.

The enclosed copy of our inspection report identifies areas examined during the inspection. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personnel.

No violations of NRC requirements were identified during the course of this inspection.

In accordance with 10 CFR E.790 of the Commission's regulations, a copy of

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this letter and the enclosed inspection _<eport will be placed in the NRC Public Document Room.

We will gladly discuss any questions you have concerning this inspection.

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Sincerely, l.

L. Robert Greger, Chief

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Reactor Programs Branch

Enclosure:

Inspection Reports No. 50-454/90026 DR$5 ;

L No. 50-455/90026 DR$5 See Attached Distrubition S

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2JAN 2 41991 Commonwealth Edison Company

Distribution

REGION III==

Report Hos. 50-454/90026(DRSS);50-455/90026(DRSS)

Docket Nos. 50-454; 50-455 License Nos. NPF-37; NPF-66 i

Licensee:

Commonwealth Edison Company Opus West 111 1400 Opus Place Downers Grove, IL 6G15 Facility Name: Byron Station, Units 1 and 2 Inspection At:. Byron Site, Byron, Illinois Inspection Conducted:- December 11-12, 1990 and January 7-11, 1991

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Inspectors:

W. B. Grant ate

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D. Barss Date W

Approved By: William Snell, Chief Radiological I 'A

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Controls and Emergency Preparedness Date

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Section

Inspection Summary:

Inspection on December 11-12, 1990 and January 7-11, 1991 (Report

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ho. 50-454/9F026(DRSS); 50'-455/90026(ORSS))

_ Routine, unannounced, inspection of radiological Areas Inspected:

protection, radwaste, and transportation programs including:

aspects of the licensee's operational radiation protection program (IP 83750), liquid and gaseous radwaste management program (IP 84750), and solid radioactive waste management-and transportation of-radioactive materials (IP 86750),

including changes since the last inspection, audits and surveillances, exposure: control,:ALARA, implementation of solid, liquid and gaseous radioactive waste program and records of shipment of-low-level waste for disposal. 'The inspector was accompanied by two inspectors from the Illinois Department of Nuclear Safety on-December 11, 1990, during the inspection of the licensee's program for packaging, shipment and transportation of radio-active material.

The radiation protection and radwaste programs appear to function

.Results:

well and to be effective in protecting the health and safety of workers and

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the public. No-violations or deviations were identified. A strength observed

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during the inspection was the good management support of the radiation protection program.

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DETAILS 1.

Persons Contacted M. Ahlgrim, Radiction Protection Training Cooriinator

  • S. Barrett, Radiation Protection Supervisor S. Bell, Health Physicist
  • D. Berg, Onsite Nuclear Safety
  • D. Brindle, Regulatory Assurance Supervisor L. Bushman, ALARA/ Operations HP Group Leader W. Carl, Lead Health Physicist, Technical J. Capp, Health Physics Foreman A. Chernick, Training Supervisor
  • W. Grundmann, NQP Engineer
  • P. Johnson, Technical Staff Supervisor J. McLindsay, Senior Work Analyst R. Moredock, Training R. Munson, ALARA Ana.j:,t C. Repass, Training
  • K. Schwartz, Production Superintendent T. Tillman, Group Leader Radwaste/ Ventilation
  • R. Ward, Technical Superintendent J. Weitzel, REP Coordinator D. Winchester, QA Superintendent
  • E. Zittle, Regulatory Assurance Staff
  • W. Kropp, NRC Senior Resident Inspector The inspectors also contacted other licensee representatives.
  • Denotes those present at the exit meeting.

2.

General The inspection was conducted to review routine aspects of the radiation protection, radwaste and transportation programs during power operations.

The inspection included tours of the auxiliary building, fuel handling building, turbine building, and the low-level radwaste process and storage facility; observation of work in progress; review of licensee records and reports; and discussions with licensee and contractor personnel.

3.

Changes (IP 83750,84750,86750)

The inspectors reviewed changes in personnel, facilities, equipment, program and procedures that could affect the occupational radiation protection program.

Two additional Health Physicists (HP) have been hired. One is a degreed HP who transferred from the Corporate Emergency Planning Group and the other has a degree in Nuclear Engineering and had been working in the An additional 12 B Radiation Regulatory Assurance Group at Byron.

Seven of these Protection Technicians (RPTs) were added to the group.

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The have completed their B training and are qualified B technicians.

remaining five have completed formal classroom studies at the Production

Training Center (PTC) and are currently completing on the job training (0JT) qualifications at Byron.

Training and Qualifications of Radiation Protection Personnel (IP 83750)

4.

Selected training records were reviewed which indicated that Radiation Protection (RP) personnel were being trained in accordance with established training program requirements. The training program includesseveralphasesstartingwithgenericinitialtrainingfollowing conducted by the licensee's PTC, for all new RP technicians.

the generic training each candidate is provided with a series of site After successfully

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specific courses as well as a period of 0JT.

completing all generic and site specific initial training along with-

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the OJT, candidates are given a job performance examination to measure Successful competency and mastery of required knowledge and skills.

performance by a candidate during the job performance examination leads to certification as a B RPT. After two years of experience a similar multiphase training process is completed leading to certification as an A-RPT.

Both A-and B RPTs attend annual retraining courses as required by established program requirements. This retraining consists of a core-of required courses and other specific courses determined to be Input from supervisors, technicians and training personnel appropriate.

Though not required are consider d in developing the full syllabus.

by the licensee's training program, supervisory personnel also attend i

retraining courses,

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The licensee also has a required reading program which provides another mechanism for ensuring RP personnel remain current in the o

items such as a sumary of recent procedure

-latest developments.

changes, new equipment or procedures and recent operational events e

at the site or in the industry are included in the required reading list.

j Before B RPTs are certified as A RPTs they must complete a site Through ditcussion with cognizant specific systems training course.

licensee personnel it was learned-that the training program is being ems courses

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revised to require completion of the site specific

.before certification as a B Technician.

Lesson plans for the site specific systems training courses were reviewed and found to include adequate _ scope to give a good general plant overview.

It was noted that only one lesson plan included a terminal knowledge objective (TK0) that specifically addressed the It is radiological significant of the system being discussed.

recommended that each lesson plan should include a TKO concerning

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This would the radiological significance of the associated system.

provide emphasis to developing an awareness of ALARA concerns associated i

j, with each system.

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The licensee has initiated a two day training course for personnel

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assigned decontamination tasks. From discussions with licensee personnel it seems this training has been effective in improving the quality of work performed and the results of decontamination ef forts.

Intervie'

were conducted with twelve percent of the licensee's RPTs.

Individuais were mndomly selected by the inspector. Those personnel interviewed all conveyed a positive image of competent professionals who were well trained and motivated to perform there assigned responsibilities.

Information was conveyed to the inspector that some minor attitude problems exist, in that some site employees feel that RP concerns are more of a hinderance than a help.

It was not perceived by the inspector thtd this feeling was prevalent, and probably was limited to only a few isolated cases. The licensee should continue to encourage and instill in all site personnel the proper attitude concerning folicwing necessary radiological safety precautions.

No violations or deviations were identified.

5.

AuditsandSurvepl,ances(IP 83750,84750,86750)

The inspectors selectively reviewed the results of Quality Atsurarce (QA) audits and surveillances conducted by the licensee since the last inspection. Also reviewed were the extent of the audits and surveillances, their taoroughness and the qualifications of the auditors.

One audit of radiation protection was conducted during this period.

Audit items included:

procedure issuance and Control, instrument calibration, expocure control, contamination control, contamination and radiation surveys, radioactive source control, radiation occurrence reports, ALARA, trending, whole body counting and respirator issuance. The 7:e observation regarding an unqualified person doing raciation surveys (Chemistry Technician) was identified

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and corrective tction was completed.

Surveillances of radiation protection and radwaste activities were selectively rev f ewed.

Corrective actions that were required appeared to be timely and technically sound.

The quality assurance surveillance program enables the auditors to conduct a large number of performance based surveillances. The inspectors reviewed documentation of surveillances performed.

No

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problems were noted.

No violations or deviations were identified.

6.

External Exposure Controls (IP-85750)

The licensee's external exposure control program was reviewed, including:

changes in facilities, equipment, personnel and procedures; adequacy of dosimetry program to meet routine and emergency needs; dose tracking

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capabilities; required records, reports and notifications; effectiveness

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of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.

The inspectors verified that there were no changes in the licensee's exposure evaluation, badge spiking QA/QC, extremity, neutron or multiple badge monitoring programs.- Ho problems were noted.

The licensee's exposure reports for 1990 were reviewed.

No exposures greater than 10 CFR 20.101 limits were noted. The highest annual dose-received by a statipn worker for 1990 was approximately 2500 millirem.

Five-cr a ractors are listed as having annual doses'in excess of 3000 the highest being 3688 millirem. According to dosimetry-mill v a, records reviewed, all five contractors were Westinghouse specialists who came in to work on the Unit 2 upper internal bent guide pins in October 1990, and all had erhed at Byron with greater than 2500 millirem.

Requests for increased administrative exposure limits were reviewed for approval status ard control. No problems were noted.

The inspectors sabethely reviewed Radiation Work P2rmits (RWPs) and associated radiation surntyr, 9bserved prejob briefings and ALARA No briefings and oLacrved work owing perfo~med under selected RWPs.

significant problems were noted.

No violations or deviations were identified.

Internal Exposure Control (IP 83750)

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-The licensee's internal exposure control and assessment program was changes in facilities, equipment, personnel, reviewed, including:

respiratory protection training; and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements;- planning and preparation'for maintenance and refueling tasks including ALARA considerations; required records, reports and notifications,

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effectiveness of. management techniques used to implement these

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programs; and experience concerning self-indentification and correction of program implementation weaknesses.

The' licensee's control program for internal exposure includes usa

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of engineering: controls, surf ace and airborne survey data, respiratory protection equipment.and direct surveillance of selected work

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activities. A selected review of air sample data and smear survey

--results was made.

No problems were noted. The licensee has purchased six lapel air samplers and will investigate their usefulness on different jobs.

A review of the licensee's whole body count records indicated that no exposures in excess of the 40 MPC-hour control measure occurred during 1990. MPC-hour determinations were being tracked. No problems were noted.

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The inspectors reviewed the performance test (calibration) rest tsThe

for the Fastscan Whole Body Counter (WBC) at the Byron Station.

29, 1990 to evaluate counting Fastscan WEC was tested on NovemberFastscan system testing was performed using system performance.

procedures developed by Canberra in accordance with ANSI N13.30 Test counts were performed to evaluate WBC standard specifications.

measurement accuracy, precision and sensitivity. Special radioactive sources and reference phantoms were used for replicate measurements of test nuclide activity in the lung, whole body and thyroid source distributions. No problems were noted.

No violations or deviations were identified.

Control of Radioactive Material and Contamination, Surveys and 8.

Monitoring (IP 83750)

The inspector reviewed the licensee's program for control of radioactive adequacy materials and contamination, surveys and monitoring, including:

of supply, maintenance and c.alibration of contamination survey and monitoring equipment; 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.

There were about 500 Personnel External Contaminations (PECRs)

Of these 47% (234) were shoes, 21% (106) were reported in 1990.

Of the 500 PECRs, 362 were other clothing, and 38% (157) were skin.

Seven personnel contaminations have been recorded below 10K dpm.

The licensee tracks personnel contaminations to in 1991, to date.

determine problem areas and repeat offenders.

No specific cause has been determined for the increase in PECRs in 1990.

The inspectors observed the removal of the Burnable Poison Rod Assembly (BPRA) from the Spent Fuel Pool prior to returning it to the vendor.

The operation was performed using procedures for handling high An RPT was in constant attendance, hot particle hot particles.

The transfer went smoothly procedures were in effect and were observed.The assembly read 140 mR/hr contact on t with a few minor problems.

bottom end.

During a tour of the Auxiliary Building, the inspectors observed an The area apparent housekeeping problem in a centractor storage area.

was being used to store the contractor's tools and equipment some of which had fixed contamination. The housekeeping was poor. Radwaste y

shipping drums were used to store what appeared to be bagged contaminated Bagged, equipment on which wood and metal rcrap had been piled.

apparently contaminated, chain hoists were hanging on a rack withThere was a apparently clean chain hoists.the room with indications it had been used in this rad A subsequent survey of the grinding wheel by radiation controlled area.

protection found no detectable contamination on the wheel; however, it is a poor radiological practice to have a grinding wheel within a radiologically controlled area, considering the wheel was not posted

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"Do not use on contaminated equipment" or in any other mancer.

matter was discussed at the exit meeting and will be reviewed during a future inspection.

No violations or deviations were identified.

Maintaining Occupational Exposures ALARA (IP 83750)

9.

The inspectors reviewed the licensee's program for maintaining ALARA group staffing and occupational exposure ALARA, including:

qualifications; changes in ALARA policy and procedures, and their implementation; ALARA considerations for maintenance and refueling outages; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them.

The total station dose for 1990 was 432 person-rem, of which about 256 person-rem was attributed to the Unit I refueling / maintenance outage and 129 person-rem was attributed to the Unit 2 refueling /

The licensee's goal for 1990 was 510 person-rem.

maintenance outage.

It was learned through discussions with cognizant licensee personnel that there is no current on going mechanism for general plant workers The licensee to provide-input for improvements in ALARA considerations.does attem improvements to work practices which would help reduce exposur waste.

The licensee should consider because of other pressing requirements.

establishing a mechanism to encourage all employees to evaluate and recommend improvement in work practices which will lead to reaching ALARA goals.

The ALARA/ Operation HP Group Leader was called to active military duty on January 9,1991. H e ALARA Engineer will be acting group leader until his return.

No violations or deviations were identified.

10. Plans and Preparations (IP 83750)

The inspectors reviewed the licensee's planning and preparation for Unit I refueling / maintenance outage scheduled for September 1991.

the The licensee has plans to purchase a reactor head flange decontamination machine which is intended to reduce the dose required to clean the There are also plans to replace the old IRT Portal reactor head flange.

monitors at access control and in the guard house with state of the art PM-7 Portal monitors.

No violations or deviations were identified.

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.11.

Solid Radioactive Waste (IP 86750

The licensee's solid radioactive waste management program was reviewed, determination whether changes to equipment and procedures-including:

were in _accordance with 10 CFR 50.59; adequacy of implementing procedures to-properly classify and characterize waste, prepare manifets,.and mark packages; overall performance of the process control and qwlity assurance prograus; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic wea knesses.

According to-licensee representatives and licensee records, there were 31 shipments of dry active waste (DAW), filters and dewatered resins Twenty one shipments were directly to the burial sites t

during 1990.

licensee's vendor for future shipment to a burial and 10 were to thf An onsite vendor representative performs dewatering of filters and demineralizer resins and sludge in vendor supp!ied steel linersLicense site.

and high integrity containers (HICs).

that the dewatering / solidification meets NRC and burial site requirements.

The inspectors verified that classification, characterization and shipping of solid radwaste were performed in accordance with regulatory requirements and licensee procedures.

No violations or deviations were identified.

Process Radiation Area Radiation and Effluent Radiation Monitors (

12.

B4750)

_. Calibration (surveillance) records and procedures for area, process The inspectors and effluent monitors were selectively reviewed.

verified that the containment and ' auxiliary building monitors, the

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pipe tunnel radiation monitors, the high range containmen a

calibrated and maintained as required. Alarm / trip setpoints were verified as properly set to meet design objectives.

-No violations or deviations were identified.

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13.- Engineered-Safety-Feature Filtration and Control Room Habitability Systems (IP 84750)

-Technical Specifications require filter testing of the control room makeup filter system, the non-accessible exhaust syste

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of tests performed on these systems and discussed testing proceduresThe review

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with the System Engineer responsible for the tests.

both in-place tests of HEPA filters and iodine absorber units as well as Surveillance. testing has-laboratory tests of activated carbon samples.

been timely and test results have met acceptance criteria. No problems were noted.

No vio'ations or deviations were identified.

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14.

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The licensee's transportation of radioactive materials program was-reviewed, including:- determination whether written implementing =

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procedures were adequate, maintained current, properly approved and acceptably implemented; determination whether shipments were in compliance with NRC and. DOT regulations and the licensee's quality

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assurance program; determination if there.were any transportation incidents: involving licensee shipments; adequacy of required records,

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-reports, shipment documentation, and notification; and experience concerning identification and correction of programmatic weaknesses.

Selected records of radioactive material shipments made in-1990 were reviered. The-shipments appeared to have been made in accordance and the with the reg Jirements of 10 CFR 61 and 71, 49 CFR 170-179, licensee's procedures. The licensee QA and QC groups pro' ide good v

oversite of shopping activities.

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No violations or deviations were identified.

15. ExitInterview(IP-30703)

'Theinspectormetwithlicenseerepresentatives(denotedinSection1)

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at the conclusion of the inspection on January 11,1991, to discuss the The inspector also discussed the scope and findings of the inspection.

likely informational content of the inspection report with regard to documents-or processes-revieweo / the inspector during.the inspection.

The licensee did not identify i.ay such documents / processes as proprietary.

The following matters were discussed specifically-by the inspector.

The housekeeping and the electric grinder in the storage area in a.

the auxiliary building (Section 9).

,t The-additions of two HPs and twelve technicians _to the Radprotection b.

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staff (Section 3).

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- TheapparentlackofaformalALARAsuggestionprogram(Section5).

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