IR 05000454/1997017
| ML20198K378 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/01/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198K369 | List: |
| References | |
| 50-454-97-17, 50-455-97-17, NUDOCS 9710240007 | |
| Download: ML20198K378 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION lli l
Docket Nos:
50-454: 50-455 l
License Nos:
NPF.37; NPF-66 l
Report Nos:
50-454/97017(DRS); 50-455/97017(DRS)
Lloensee:
Commonwealth Edison Company (Comed)
Facility:
Byron Generating Station, Units 1 & 2 Location:
4450 North German Church Road Byron,IL 61010 t
Dates:
August 25. September 12,1997 Inspectors:
R. Paul, Senior Radiation Specialist S. Orth, Senior Radiation Specialist D. Hart, Radiation Specialist Approved by:
G. Shear, Chief Plant Support Branch 2 Division of Reactor Safety Id' "1888K 374881u
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EXECUTIVE SUMMARY Byron Generating Station, Units 1 & 2 NRC Inspection Reports 50 454/97017; 50-455/97017 This inspection included an announced review of the radiation protection program and the planning for the steam generator replacement project. One violation was identified concerning the failure to follow procedures. One additional violation with two examples was identified concerning the failure to properly post radiation and high radiation areas.
Plant Sucoort The inspectors concluded that overa!!, housekeeping was good, radiological postings
were correct, and locked high radiation area (HRA) doors were locked. However, the inspectors identified a violation concoming a worker who entered a contamination area without the proper clothing. The hcensee took immediate actions to correct the violation.
(Section R1.1)
One violation with two examples was identified relating to improper movement of e
radiological post 9s resulting in the failure to properly post a radiation area and a HRA.
This violation is of particular concern because it is the third and fourth examples of posting events in the past 2 years and corrective actions taken to correct previous non-cited violations have not been effective or lasting. (Section R1.2)
The radiation protection staff provided sound radiological planning and offective e
oversight of the lubrications of the incore detector cables. With the exception of initial engineering participation, the as-low as-Is reasonably achievable briefings provided workers with a comprehensive discussion of work scope and radiological hazards.
Workers demonstrated good radiation protection practices. (Section R1.3)
The inspectors concluded that the radiation protection planning for the steam generator e
replacement project appeared to appropriately consider the radiological liabilities associated with the project. (Section H1.4)
The radiation protection staff maintained a sound quality control program for the whole
body counters. The licenseo performed calibrations in accordance with procedures.
(Section R2.1)
The radiation protection staff properly calibrated personnel contamination monitors e
(PCMs)in the Auxiliary Building and at the security exit points. However, the inspectors identified some weaknesses in PCM calibration procedures. (Section R2.2)
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Renort Details
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IV. Plant Suppsd R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 General Walkdowns of The Auxiliarv Buildina a.
Inintcilon_ Scope (IP 8375Q)
The inspectors performed severalinspections of the Auxillary Building (AB) and otuerved radiation worker (radwe.+er) practices.
b.
Observations and Findings The inspectors noted that radiological postings and boundaries were generally well maintained, locked high radiation area doors were locked, and housekeeping was good.
However, on August 25,1997, the inspectors observed a worker enter a high contamination area (CA) without the proper protective clothing. The ir;spectors immediately stopped the individual and notified a radiation protection technician (RPT)in the area. The RPT performed smears to determine if the individual had become contaminated. The contamination area was outside of the Unit 2 seal water heat exchanger room and marked with a swing gate and radiation rope as well as the three step off pads (SOP) used by the station. The station policy is that the first two SOP's are not contaminated and that a worker may step on them to hand tools in and out of a work area or for other purposes as needed. The individual stated that he was aware of the policy and had not realized how far into the area he had gone when the inspectors approached him and pointed out that he was past the third SOP in a CA. The worker was signed in on radialton work permit (RWP) 970008 which included the dress requirements for contaminated areas.
Corrective actions to prevent recurrence included, (1) the individual was escorted out of the radiologically posted area (RPA) and his access was revoked by the radiation protection (RP) department, (2) RP staff discussed the issue with the individual and his supervisor to ensuro he was aware of the stations procedures and expectations, and (3)
the health physics supervisor (HPS) indicated that the individual would be required to re-attend initial nuclear general employee training (NGET).
Technical Specification (TS) 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure. Failure to follow the requirements of the RWP and obey radiological postings is a violation (VIO) of TS 6.11 (VIO 50-454/97017-01; 50-455/97017-01).
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Conclusions
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The inspectors concluded that overall, housekeeping was good, radiologleal postings appeared correct, and locked high radiation area doors that were checked were locked.
However, the inspectors identified a violation concerning a worker who entered a contamination area without the proper clothing. The licensee took immediate actions to correct the violation.
R1.2 High Radiation Area Posting Controb a.
Insoection Scoce (IP 83750)
The inspectors reviewed several problem identification forms (PlFs) relating to radiation protection to determine what type of problems the licensee had been identifying at the station.
b.
Observations and Findinas The inspectors reviewed several PlFs relating to RP, On January 24,1997, a RPT performing job coverage in the 2A containment spray (CS) pump room noticed that a high radiation area (HRA) boundary had been moved. A subsequent survey of the area identified that a 130 millirem /hr (mrem /hr) radiation field existed outside of the HRA boundary RP personnel immediately corrected the boundary and verified the adequacy of other HRA boundaries.10 CFR 20.1902(b) required that a HRA be conspicuously posted with a sign bearing the radiation symbol and the words " CAUTION, HIGH RADIATION AREA" or * DANGER, HIGH RADIATION AREA', The failure to properly post the CS pump room, designated as a HRA, is a violation of 10 CFR 20.1902(b).
Another PlF reviewed indicated that on August 4,1997, a RPT identified that a HRA posting had been moved. Mechanical maintenance personnel were working in the 2B Letdown Heat Exchanger (HX) area which consists of two rooms, one is the valve aisle and the other is the Letdown HX room. The HX room was conservatively posted as a HRA due to fluctuations in dose rates from a hot spot. At the time of this incident, the survey maps indicated that the area was a radiation area (RA). The RP staff positioned a swing gate with radiological postings attached at the entrance to the HX room to control entry into the high radiation area and a high contamination area. During the course of the maintenance activity, the RP staff determined that this swing gate was moved from It's proper location to the valve alslo, so that the posting was not visible to workers entering the radiation area. Although the posting was not visible, the high contamination area was identified by the presence of step off pads. The licensee immediately corrected the problem and suspended the radiation work permit (RWP) of the workers in the area until all were counseled. The failure to properly post the Letdown HX, a RA, is a violation of 10 CFR 20.1902(a) (VIO 50-454/97017-02; 50-455/97017-02).
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The two examples above indicated that the corrective actions taken for two Non Cited Violations (NCVs) issued within the last two years have not been effective in resolving inadequate posting problems. Inspectors identified two NCVs from inspection report Nos. 97003 and 96004 associated with inadequate HRA postings. In both cases the inadequate posting was attributed to personnel moving radiological pcstings. In the radioactive waste (radwaste) building the inspectors also noticed several 55 gallon drums had been placed in such a way so that they obscured a HRA posting. There were other postings at the entrance to this area, however, the inspectors were concerned by the lack of sensitivity to the importance of these postings, c.
Conclusions l
One violation with two examples was identified relating to movement of postings resulting in the failure to properly post a RA and a HRA. This violation is of particular concem because it is the third and fourth examples of posting violations in the past 2 years and corrective actions taken to correct previous postir g violations have not been effective or lasting.
R1.3 Lubrication of Unit 1 incore Detector Cable a.
Insoection Scoce (IP 83750)
The inspectors reviewed the radiological planning for the inspection and lubrication of Unit 1 incore drive cables, including the RWP and as-low as-is-reasonably achievable (ALARA) planning. Specifically, the inspectors reviewed RWP No. 970285, revision 0,
" Clean, inspect, and Lube incore Drive Cables @ (at] power Unit 1 Containment," and ALARA action review No. 06/97/154, dated August 21,1997. The inspectors also reviewed radiological surveys, attended pre-job briefings, and observed the performance of the task, b.
Observations and Findinos On August 27,1997, the licensee performed preventive maintenance on the Unit 1 incore drive cables. The general working area dose rates were expected to be less than 10 millirad /hr (mrad /hr), the dose rates on contact with incere detectors were expected to be greater than 20 rad /hr and dose rates near the detector cables were likely to be about 150 mrad /hr. Prior to the evolution, the RP staff prepared an RWP and ALARA action review. The inspectors observed that the RP staff performed an effective assessment of the radiological hazards associated with the evolution. The RWP and ALARA action review contained appropriate contingencies and radiological hold points, which were consistent with the guidance contained in NRC Information Notice No. 88-63,"High Radiation Hazards from Irradiated Incore Detectors and Cables." The RWP contained requirements for continuous communication between workers at the site and the control room staff and for continuous RP technician coverage and stop-work limitations.
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The inspectors attended meetings conducted on August 26 and 27,1997. During the meetings, the Al. ARA staff and maintenance staff discussed the scope of work and the radiological conditions. The inspectors identified some minor problems concoming the discussions of work scope. During the August 26,1997, meeting, the responsible system engineer was not present. Consequently, the maintenance staff did not have the procedure which was to be used to perform the evolution and was unaware of the procedure requirements which may have affected the manner in which the detectors were to be withdrawn, i.e., the speed, distance, and sequence of withdrawal. During the August 27,1997, meeting, the system engineer was present and discussed the procedure requirements. During both meetings, the inspectors observed excellent discussions of the radiological hazards and of the RWP and ALARA action plan requirements. The members of the RP and operations staffs stressed the requirement for continuous communications and the stop-work conditions. The RP staff also discussed previous events conceming incore detector work.
During the evolution, the inspectors noted good control and conduct of the work. RP technicians provided good oversight of the work and continuously rnonitored area dose rates. The workers demonstrated good radiation work practices, including the use of low dose waiting areas. Surveys of the areas indicated that actual dose rates v%r0 comparable to the RP staff's initial estimates. Following the activity, the licensee indicated that the cumulative worker dose was about 96 mrom as compared to a goal of 200 mrem.
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Conclusions The RP staff provided sound radiological planning and effective oversight of the lubrications of the incore detector cables. With the exception of the lack of some initial engineering participation, the ALARA briefings provided workers with a comprehensive discussion of work scope and radiological hazards. Workers demonstrated good radiation protection practices.
R1,4 Unit 1 Steam Generator Reolacement Project (SGRP) Planning a.
Insoection Scoce flP 83729)
The inspectors reviewed the radiation protection staffs advance planning and preparation for the fall 1997 Unit 1 SGRP, including: staff qualifications, training, ALARA, work planning and processes, procedure modifications, and dose estimates for several activities. The inspectors also performed walkdowns of the containment access facility built for the project as well as the mockups for the steam generator bowl and piping and the containment opening, b.
Observations and Findings A station health physicist (HP) was assigned as the SGRP RP coordinator having the responsibility for directing RP activities associated with the SGRP. The staff planned to have radiation protection coverage provided by contractors, with six site RPTs working
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at access control. The contractor RPTs were selected based on the three year experience criteria of ANS 3.1 1978," Selection and Training of Nuclear Power Personnel" and previous SGRP experience. The station had requested from the contractor that a minimum of 25% of the RPTs have prior SGRP experience. The inspectors also observed procedure training for contract RPTs. The instructor focused on procedures that the technicians will be utilizing during the outage. RPTs raised good questions, and the instructor promoted class participation in the discussion.
The inspectors also reviewed the plans for several of the high dose jobs. The inspectors observed that the RWPs for the SGRP were still being revised and the ALARA action reviews were still being written. However, the inspectors were able to review pipe end decontamination (decon) and shleiding job which was estimated for about 9.55 rom, and the pipe end work including the cutting and welding, which was estimated at about 54 rem. The inspectors also determined that the licensee identified those evolutions mosilikely to create airbome activity and were taking measures to ensure adequate control mechanisms were in place and ready to prevent internal exposures.
RP personnelidentified that there was a possibility of the containment atmosphere having positive pressure compared to the outside atmosphere when the contcinment
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roll up door is open. To address this matter the RP staff had written a procedure to evaluate and quantify any effluent material that might escape through the roll-up door in the containment wall, BRP 6110-17, * Determination of Compliance With 10 CFR 20 and 10 CFR 50 Airbome Release Limits During Steam Generator Replacement," Revision 0.
This procedure stated that any activities that may lead to high airbome concentrations shall be evaluated during the plan of the day meeting to ensure proper controls prior to opening the door. The RP coordinator indicated to the inspectors that there will be two AMS 3 air monitors at the containment opening with remote cameras feeding Images back to the containment access facility.
Personnel dose measurement would be made through the use of thermoluminescent dosimeters and electronic and remote dosimetry systems, and a computerized information management system will be used to track and control individual personal exposures. The target dose for the SGRP is about 234 person-rem.
Dedicated ALARA planners were named to prepare ALARA plans and radiation work permits (RWPs). Several mockups such as the pipe end decontamination, temporary lead shielding, RCS nozzle cover installation, and the containment opening were planned and used to maintain strong ALARA controls and to minimize exposure.
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fanclusions The inspectors concluded tut the radiation protection planning for the SGRP appeared to appropriately consider the radiological liabilities associated with the project.
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R1.5 Administrative Dose Controls a.
Insoection Scone (IP 83750)
The inspectors reviewed the RP programs for administrative dose controls related to the workers coming on site for the SGRP and also the program for declared pregnant women (DPWs),
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Observations and Findinos The inspectors reviewed the licensees program for tracking the dose history for the contract workers that arrived for the SGRP. The station had an administrative limit of 3 rem for the year. When new workers arrived at the station, RP personnel took personal dose history from them to determine what dose to assign for the year. The RP management recognized that the SGRP will occur at the end of the year (Nov. Dec.)
and that several contractors may have annual doses of 3 rem for the year.
Consequently, the RP Supervisor had decided that they would approve certain people up to 3.5 rem on a case by case basis with Plant Manager approval, in addit!9n, the station had set a goal to have only 35 people receive between 1 to 2 rem total effective dose for the year, this includes the SGRP.
The inspectors also reviewed the licensees program for declared pregnant women (DPWs). Part of the policy included that when a woman indicated that she wanted to declare her pregnancy, the Radiation Protection Manager (RPM) discussed with the woman what her choices were. Together the worker and the RPM arrived at an ' action plan' to limit the workers dose. The inspectors interviewed nine women working in various areas of the plant to determine if the women understood the stations policy. All the women interviewed clearly understood the right to declare or not declare and understood that the station offered the option of not entering the RPA to a DPW The inspector also questioned the women about the training they had received and it was indicated to the inspector that this topic was covered during the initial NGET.
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Conclusions No problems with the dose control program or the DPW program were identified.
R2 Status of RP&C Facilities and Equipment R2.1 Whole Body Counter Calibrations and Qualltv Control a.
insoection Scoce (IP 83750)
The inspectors reviewed the quality control program for the whole body counter, including calibration and performance test records, required by the following licensee procedures:
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BRP 5410-8, 'ABACOS Plus Whole Body Counter Calibration," revision 2; and BRP 541010, *Whole Body Count Data Review," revision 1.
The inspectors also verified that the lower limit of detection (LLD) for the whole body counter would enable the licensee to detect radionuclides above an applicable action level.
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Observations and Findings The licensee determined personnel internal exposures via a monitoring program consisting of whole body counting and alarming portal monitors. The inspectors reviewed the most recent calibration reports for the licensee's two whole body counters, which were performed on June 11 and 12 of 1996. The licensee's corporate staff had performed the calibrations in accordance with procedure BRP 5410-8. Although the current calibrations had not t,xceeded the licensee's 18 month requirement, the inspectors noted that the calibrations were beyond the annual goal stated in BRP 5410-8. A member of the RP staff indicated that the calibrations were routinely performed at the 18-month frequency and planned to evaluate the basis for the annual goal. The inspectors noted that the whole body counters' radionuclide library adequately represented the pctential mixture found in plant radioactive contamination and that the LLDs were below the action lovels stated in procedure BRP 5400-1.
The RP staff performed routine efficiency, energy, and background tests for each detector as required by procedure BRP 5410-7. The inspectom reviewed data recorded from 1997 tests and noted that the data was statistically distributed and that the staff had performed the required corrective actions for data which had exceeded an action level. The RP staff performed monthly and quarterly reviews of quality control data, as required, and properly resolved data biases, c.
Conclusions The RP staff maintained a sound quality control program for the whole body counters.
The licensee performed calibrations in accordance with procedures.
R2.2 Personnel Contamination Monitors and Portable Instruments a.
Scoce (IP 83750)
The inspectors reviewed the calibrations and quality control testing of personnel contamination monitors (PCMs) used in the Auxiliary Building and at the security exit.
The inspectors observed RP staff performing daily quality control testing of the PM 7 monitors and a calibratbn of an IPM 9D. The PM 7 monitors are sensitive to gamma
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radiation and the IPM monitors are sensitive to beta radiation. The inspectors also observed calibration of various portable instruments.
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Observations and Findings An inspector observed the RP staff calibrating an IPM 9D whole body frisking monitor.
The RP staff properly followed procedure BRP 582214 " Calibration, Maintenance and Operation of the IPM 9D Whole Body Frisking Monitor," Revision 0. The IPM 9Ds were the newest whole body frisking monitors at the station, which were purchased for the SGRP and were only being used at select locations throughout the plant. The licensee maintained IPM 7s and IPM 8s for the balance of the plant. The inspectors reviewed calibration records which indicated that the remaining IPMs were properly calibrated at the required frequencies. Although the inspectors did not identify any problems concerning the calibration data, the inspectors observed that procedure BRP 5822 7,
" Operation and Calibration of the IPM 7/IPM-8 Whole Body Frisking Monitor," does not require that an alarm test be performed following calibration. The inspectors noted that a RPT performed a daily alarm test on each PCM. However, the RP staff indicated that following a calibration an alarm check wnuld not be performed until the next day. The RP supervisor acknowledged that performing an alarm test following a calibration was a conservative RP piactica.
The inspectors noted that the RP staff calibrated PM-7 monitors every 6 months and performed daily alarm tests as required by BRP 5822-10, " Operation and Calibration of The Eberline PM-7 Portal Monitors " Revision 2. In accordance with the procedure, the RP staff used a source designated by RP t,upervision for the daily alarm tests, (700 nCl of cesium (Cs)-137) which is equivalent to approximately 170 nCi of cobalt (Co)-60. The monitors at the security gate house were calibrated to have a reliably detectable activity of 50 nCI of Co-60. The inspectors questioned whether 170 nCi was an appropriate test for these rnonitors, given that the monitors should have alarmed at 50 nCl (3 times lower). RP supervision indicated that 1.5 times the detection limit was their expectation and that a more reasonable source will be found to be used for these detectors (approximately 75 nCl). The inspectors reviewed the calibration data and no problems were identified. However, the inspectors had similar observations as with the IPM monitors, conceming the lack of a. alarm test following calibration.
During in-plant observations, the inspectors verified that portable radiation instruments were in good condition and calibrated. Overall, the licensee maintained effective tracking / trending of instrument maintenance and calibration histories. Radioactive sources used during the cailbrations were secured and properly inventoried. The calibration laboratory was in good condition and the inspectors observed an RP technician successfully perform an instrument calibration using the licensee's Shepard calibrator.
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Conclusions The RP staff properly calibrated PCMs in the Auxiliary Building and at the security exit points. However, the inspectors identified some weaknesses in PCM calibration procedures.
R2.3 Extemal Dosimetry Calibration and Quality Control The inspectors reviewed the licensee's procedure BRP 5824-3," Calibration of Merlin Gerin Electronic Dosimeter"(ED), revision 5 and the quality control data relating to the calibrations. The calibrations were done automatically using robotics and a computer.
The results were printed out and reviewed by a RPT and the instrumentation health physicist. The ED's were calibrated for dose, dose rate, and to ensure operability. A 1 Cl Cs 137 source is used for the calibration, acceptance criteria for dose rates were measured at approximately 50,400, and 6100 mrom/hr. No problems with the calibrations were identified, and comparisons between the EDs and the l
thermoluminesence dosimeter measurements had good results.
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R8 Miscellaneous RP&C lssues R8.1 fClosed) Violation No. 50-454/95011-01 and 50-455/95011-0j; The chemistry department personnel failed to follow chemistry procedures which contained the requirements for rinsing sample containers, utilizing proper Chemet test kits, and performing radiological surveys. The corrective actions for this violation had been completed; however, the inspectors observed chemistry technicians take samples and I
observed minor procedure adherence problems. Further licensee performance in this
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area will be tracked under VIO 50454/455-97003-02(b). This item is closed.
R8.2 (Closed) Violation No. 50-454/95011-07(DRP) and 50-455/9501107(DEPJ The licensee failed to properly implement procedure BTP 300-5, " Nuclear General Employee Training," revision 8, which required initial training for persons not having current training. The inspectors verified that the licensee had completed corrective actions for the violation. Specifically, the RP staff had prepared training waivers for personnel requiring access to the radiologically posted areas for short durations, as required by BRP 5000-5, ' Radiation Protection Training for Escorted Visitors," revision 5. The inspectors noted that the staff used the waivers on an infrequent basis (i.e., nine waivers were prepared between June 1995 and August 1997) and that the staff documented the training administered to the iridividuals on the waiver. In addition, the inspectors noted that procedure BTP 5000-5 had been revised to include clear instructions on the training requirements based on an individua!'s training history.
The inspectors also reviewed the topics covered in initial and requalification nuclear general employee training. Training contained elements required by licensee procedures and informed plant personnel of the radiological hazards present. The training subjects presented a broad range of information concerning radiation worker practices and the effects of lonizing radiation. D% item is closed.
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R8.3 (Closed) Violation No. 50-454/96008-01 and 50-455/96008-01: The licensee failed to post a radiation area near the outside of the high level tool storage area on the 346'
elavation of the Auxiliary Building. This was immediately posted correctly, and a survey of all tool and equipment cages was performed. The inspectors reviewed the corrective i
actions and determined that they were adequate. This item is closed.
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R8.4 (Ocen) Violation No. 50-454/97003-02 and 50-455/97003-02: The inspectors reviewed
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this failure to follow pro edures which had three examples. The first was a failure to
post a contaminated area. The radiation protection personnel posted the contaminated pumps with signs which stated that there was contamination on the pump seats. The
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RP supervisor also reviewed department expectations during continuing training i
j sessions. The corrective actions for this example were adequate and complete.
The second example was a failure to follow chemistry procedures. The inspectors observed chemistry technicians tab and analyze samples, there were still examples j
where the procedures were not being followed correctly, the examples witnessed by the
inspectors were minor and would not have affected any analysis results. Site quality
verification had o%erved chemistry technicians take samples on several occasions and
had identified numerous procedure adherence problems. This has been an ongoing I
problem for about two years it does not appear that all corrective actions had been completed or were effective. Th!s item will remain open.
i The third example for failure to have a procedure which covered adherence to chemistry
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procedures. This procedure was written, BAP 131010,' Procedure Use and
Adherence", revision 0. This procedure effectively completes the corrective actions for this item.
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l R8.5 (Closed) Violation No. 50-454/97003-04 and 50-45L ';7003-04: The failure to follow
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procedure BAP 50010," Byron Chemistry Post Accident Program Description," revision
2, dated December 2,1996, which required, in part, that chemistry technicians receive semlannual training on the post accident sampling system (PASS) and receive training j
on PASS procedures at least every six months. This procedure was revised to reflect
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that training would be completed annually. Also a 10 CFR 50.59 evaluation was
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completed which stated that the change did not require a TS revision and did not result in an unreviewed safety question. This item is closed,
i R8.6 (Closed) Unresolved item No.50-454/97014-01 and 50-455/97014-01: The licensee l
used a global positioning unit to determine the exact locations of all of their environmental monitor stations. This analysis showed that all meteorological sectors
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l were monitored as required by the Off site Dose Calculation Manual. This item is closed.
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V. MananamenLMeetings X1 Exit Meeting Summary
On September 12,1997, the inspector presented the inspection results to licensee management. The licensee acknowledged the findings presented.
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The inspectors asked the licensee whether any materials examined dudng the inspection j
should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST CF PERSONS CENTACTED J. Bauer, Health Physics Supervisor L. Bushman, SGRP Radiation Protection Supervisor R. Colglazier, NRC Coordinator W. Grundmann, Chemistry Supervisor K. Kofron, Station Manager M. Marchionda, Technical Lead Health Physicist W. McNeill, ALARA/ Operations Lead Health Physicist INSPECTION PROCEDURE USED IP 83750:
Occupational Radiation Exposuro
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IP 83729; Occupational Exposure During extended Outages IP 92904 Followup Plant Support LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50 454/455-97017-01 VIO Failure follow procedures for proper dress requirements in contaminated areas.
50-454/455 97017-02 VIO Failure to post radiation and high radiation areas in accordance with 10 CFR 20.
Closed 50-454/455-95011-01 VIO Failure to follow chemistry procedures 50-454/455 95011 07 VIO Failure to folle v training procedures regarding access.
50-454/455-96008-01 VIO Failure to post a radiation area in accordance with 10 CFR Part 20.
50-454/455-97003-04 VIO Failure to provide PASS training in accordance with procedure BAP 560-10.
50-454/455-97014-01 URI Environmental TLD's are not in all meteorological sectors as stated in the ODCM.
Discussed 50-454/455-97003-02(a c)
VIO Failure to follow procedures
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LIST OF ACRONYMS USED i
- Auxiliary Building ALARA As Low-As Is Reasonsbiv-Achievable CA Contaminated Area CFR Code of Federal Regulations Cl Curie CS.
Containment Spray DPW-Declared Pregnant Woman -
ED Electronic Dosimeter HP Health Physicist l
HPS-Health Physics Supervisor -
l HRA High Radiation Area HX Heat Exchanger-
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LLD_
_ Lower Limit of Detection
- MRAD /HR Millired por hour MREM /HR Millirem per hour NCV Non-Cited Violation
~NGET Nuclear General Employee Training
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PASS-Post Accident Sampling System PCM Personnel Contamination Monitor-PDR Public Document Room PlF Problem identification Form RA Radiation Area
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-RP Radiation Protection RPA Radiologically Posted Area RPM Radiation Protection Manager RPT Radiation Protection Technician RP&C Radiation Protection and Chemistry RWP Radiation Work Permit SGRP Steam Generator Replacement Project -
-SOP-Stop Off Pad--
.SQV Site Quality Verification TS-Technical Specish URI Unresolved item =
VIO Violation
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LIST OF DOCUMENTS REVidWED
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BAP 56010 Byron Chemistry Post Accident Program Description, revision 3 a
j BAP 1310-10 Procedure Use and Adherence, revision 0
BRP 5000 7 Unescorte Acess To And Conduct in Radiologically Posted Areas,
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revision 7 BRP 5300 3 Administration Of The Radiation Protection Aspects Of Comed's Fetal Protection and Postnatal Programs, revision 4 BRP 54001 Guidelines for a Comprehensive Bloassay Program, revision 6 BRP G410-6 -
Routino Operation of the Canberrt. Fastscan Whole Body Counter, revision 10 BRP 5410 7 Quality Control Operations for Whole Body Counting, revision 2 BRP 5410-8 ABACOS Plus Whols Body Counter Calibration, revision 2 BRP 541010 Whole Body Count Data Review, revision 1 BRP 5800 7 Radiation Protection Instrumentation Test and Calibration, revision 3 BRP 5822 7 Operation and Calibration of the IPM 7/IPM 8 Whole Body Frisking Monitor, revision 2 BRP 582210 Operation and Calibration of The Eberline PM 7 Portal Monitors, revision 2 BRP 582214 Calibration, Maintenance and Operation of the IPM 9D Whole Body Frisking Monitor, revision 0 BRP 5824 3 Calibration of Merlin Gerin Electronic Dosimeter (ED), revision 5 BRP 611017 Determination of Compilance With 10 CFR 20 and 10 CFR 50 Alrbome Release Limits During Steam Generator Replacement, revision 0 RWP No. 970008 Routine IM Activities, Non Outage,' revision 0
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RWP No. 970285 Clean, inspect, and Lube incore Drive Cables @ (at) power Unit 1 Containment, revision 0 ALARA action review No. 06/97/154 PlF No. B1997-02935 PIF No. B1997-02650 Root cause report No. 455 200-97-CAQS00021 Problem investigation report No. 6 2-97-002 SGRP Interface Agreement revision 0, with Addendum LTR Byron 97-5156 Reactor Coolant System Pipe End Decontamination Process, dated July 3,1997 SGRP Radiation Protection Plan revision 0, with Addendum Technical Specification 6.8 & 6.11 NRC Information Notice No. 88-63, High Radiation Hazards from Irradiated Incore Detectors and Cables.
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