IR 05000454/1997003

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03 Issued on 970703

ML20216B093
Person / Time
Site:	Byron
Issue date:	08/28/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Graesser K COMMONWEALTH EDISON CO.
References
50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9709050227
Download: ML20216B093 (2)

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August 28, 1997 Mr. Site Vice President Byron Station l Commonwealth Edison Company 1 4450 N. German Church Road Byron, IL 61010 l

Dear Mr. Graessor:

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(DRS); 50-455/97003(DRS)) This will acknowledge receipt of your letter dated August 4,1997, in response to our letter dated July 3,1997, requesting clarification of corrective actions for a Notice of i Violation associated with activities at the Byron Generating Station, Unhc 1 and 2. ' Specifically, the second violation contained in the Notice of Violation concerned the f ailure to train chemistry personnel on the post accident sampling systern at a sb month freqJency required by chemistry procedures. In your previous response d; ed Mry 5, 1997, you stated that your staff revised the applicable procedure to clarify the training requirements and to reduce the frequency of training from six months to twelve-months, which appeared to be inconsistent with previous commitments to the NRC. We have reviewed your rnsponse dated August 4,1997, and have no further questions at this time.

In this response, you indicated that your staff had performed an evaluation to change the commitment to the NRC in 1993 but did not notify the NRC of the intended change Consequently, this response provided the notification of that change, The corrective actions for this violation and your evaluation for the change in the commitment to the NRC will be examined during future inspections,

Sincerely, Original Signed b.v John M. Jacobson (for) John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-454; 50 455 License Nos. NPF 37; NPF 66 I g Enclosure: Ltr dtd 08/04/97, K. L. Graesser, Comed, to USNRC M {\ DOCUMENT NAME:G:/DRS/BYR08287.DRS

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0FFICE. Rlli e Rlll c Rlll Rill A n,l NAME S0rth:jp D C' GShear 6 d. RLanskbury Qh t. JGrobe R F DATE 08/as/97 08/2t /97 08/2(, /97 08/4.X NU U OFF1CIAL RECORD GOPY 9709050227 970828 PDR

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K. Graesser 2 August 28,1997 cc w/o encl: T. J. Malman, Senior Vice President, Nuclear Operations Dlvision

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D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer K. Kofron, Station Manager D. Brindle, Regulatory Assurance Supervisor 1. Johnson, Acting Nuclear Regulatory Services Manager cc w/ encl: Document Control Desk Licensing Richard Hubbard Nathan Schloss, Economist Office of the Attorney General Stato Liaison Officer, Wisconsin State Liaison Officer Chairman, Illinois Commerce Commission Distribution: Docket File w/ encl SRis, Byron, Braidwood, R. A. Capra, NRR w/ encl PUBLIC IE-01 w/enci Zion w/enci TSS w/enci OC/LFDCB w/enci LPM, NRR w/encI DOCDESK w/onci DRP w/onct A. B. Beach, Rlll w/enci CAA1 w/enci DRS w/ encl J. L. Caldwell, Rlll w/enci Rill PRR w/onct Rlli Enf. Coordinator w/enct .

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, lh run, IL 610109794 101814 244%44l August'4, 1997 LTR  BYRON 97 0105 FILE: 1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention Document Control Desk
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Subject: Byron Nuclear Power Station Units 1 and 2 Response to Request for corrective Action Clarification Inspection Report No. 50-454/97003; 50-455/97003 NRC Docket Numbers 50-454, 50-455 References 1) Geoffrey E. Grant letter to Mr. Graesser dated April 4, 1997, transmitting NRC Inspection Report 50 454/97003; 50 455/97003 2) Mr. Graesser letter to NRC Document Control Desk dated May 5, 1997, transmitting Response to Notice of Violation Inspection Report No. 50-454/97003; 50 455/97003 3) John A. Grobe letter to Mr. Graesser dated July 3, 1997, transmitting request for clarifying information regarding corrective actions to findings in NRC Inspection Report 50-454/97003; 50 455/97003 - Enclosed is Commonwealth Edison Company's response to the request for corrective action clarification which was transmitted in Reference 3. Thio letter cited inconsistencies between our proposed corrective actions noted in our response to the Notice of Violation (Reference 2) and previous commitments to the NRC, and asked for clarification. Comed's response is provided in the Attachment 1. Fomal notification of changes to commitmente made in the T.R.

Tramm letter, dated January 5, 1984, is included in Attachment II.

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Byron Ltr. 97 01t5 August 4, 1997 Page 2' If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Reguletory Assurance Supervisor, at (815)234 5441 ext.2200.

Respectt'ully, i K. L. Gr a r , Site Vice resident Byron Nuclear Power Station K14/DB/rp

.Sttachment(s)

cci A. L. Beach, NRC Regional Administrator - RIII G. F. Dick Jr., Byron Project Manager - NRR S. D. Burgess, Senior Resident Inspector, Byron R. D. Lanksbury, Reactor Projects Chief RIII F. Nisio"ak,

 . Division of Engineering - IDNS D, L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept,-c/o Document Control Desk, 3rd Floor, Downers Grove DCD Licensing, Suite 400, Downers Grove.-
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L ATTACIDENT I In regards to your concern that the changa in post accident sampling system (PASS) training f requency, f rom 6-months to 12-nonths, may not be consistent with previous commitments to the NRC, we agree.

In an October 26, 1982 letter from T.R. Tramm of the Commonwealth Edison Ccmpany to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operacion ot' the post accident sampling system. Retraining will be given as necessary to maintain competence (ninimum yearly).

During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it difficult to a,ssure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R.

Tramm of the commonwealth Edison Company to H. R. Denton of the Office of Puclear Regulatory Regulation, commitments for periodic training and re-training of technicians on the post accident sampling system were transmitted to the NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtaining routine samples, would occur at least every 6 months.

The Radiation Chemistry Department was reorganized in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the PASS, so only annual review of non-routine activities should be required. In 1993, Byron Station believed that a change from the semi-annual review of procedures did not require a formal submittal to the NRC and could be accomplished through the 10CFR50.59 safety evaluation process. A 50.59 safety evaluation was performed for the PASS in 1993, and procedures containing training requirements changed.

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Attachment !! Dyron station wou)d like to revise NRC commitments regarding post accident sampling system (PASS) procedure review and performance requirements. Station procedures and processes have changed since the commitments were made, warranting an update to the commitments.

We are reducing the required training because technicians maintain proficiency with the sample panels by using the PASS for routine sampling. Some of the PASS procedures are nearly identical to other sampling procedures with minor valve lineup changes. We will require technicians to perform or witness the performance of those procedures that include use of non routine equipment and procedures over the course of a year. These procedures have been moved from the Byron Emergency Response (BZP series) procedures into the Byron Chemistry (BCP series) procedures and include: BCP 300 11 Post Accident Sampling of Undiluted Reactor Coolant BCP 380-12, Post Accident sampling of Diluted Reactor Coolant BCP 380 15, Stripped Gas Sampling Of Post Accident Reactor Coolant BCP 380 16, Post Accident Diluted Reactor Coolant /Radwaste Sample Disposal BCP 380-18, Post Accident sampling of containment Atmosphere We will also review required procedures annually, rather than every 6 months.

These procedures include those listed above and also: BCP 380-10, Post Accident Sampling of Reactor Coolant, Radwaste, and Containment Air General BCP 300 17, Post Accident Sample Transfer from Primary Samplu Room The following procedures were referenced in the T.R. Tramm lettor to H.R. 2 Denton dated January 5, 1984 as requiring semi-annual training. These procedures cover sampling liquid radwaste which are not requi"Sd to meet post < accident sampling as described in the UFSAR. These procedures do not require annual training.

BCF 380-13, Post Accident Sampling of Undiluted Liquid Radwaste DCP '.80-14, Post Accident Sampling of Dilute Radwaste Procedure BZP 300 A7 was also referenced .in the aforementioned letter and has been incorporated in?o BCP 300-17, Post Accident sampling Transfer from Trimary Sample Room.

In an October 26, 1982 letter from 4.R. Tramm of the Commonwealth Edison company to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operation of the post accident samplirg system. Retrai.ing will be given as necessary to maintain competence (minimum yearly).

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During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it diffleult to assure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R.

Tramm of the Commonwealth Edison company to H. R. Denton of the CfCice of Nuclear Regulatory Regulation, commitments for periodic training and re-train $ng of technicians on the post accident sampling system were transmitted to thu NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtair.ing routine samples, would occur at least every 6 months.

The Radiation-Chemisstry Department was reorganised in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the Pass, so only annual review of non-routine activities should be required.

Byron 9tation feels that revising these commitments will reduce the burden on Training and Chemistry with no reduction in capability of performing the required tasks.

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