IR 05000454/1997023

Insp Repts 50-454/97-23 & 50-455/97-23 on 971117-1218. Violations Noted.Major Areas Inspected:Radiological Protection & Chemistry (Rp&C) Controls & Staff Knowledge & Performance in Rp&C

ML20198N765
Person / Time
Site:	Byron
Issue date:	01/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198N753	List: IR 05000454/1997023 IR 07100117/2012018 ML20198N750
References
50-454-97-23, 50-455-97-23, NUDOCS 9801210207
Download: ML20198N765 (10)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 111

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Docket Nos: 50-454;50-455 License Nos: NPF-37; NPF-66 Report Nos: 50454/97023(DRS); 50-455/97023(DRS)

1 o Licensee: Commonwealth Edison Company (Comed)

Facility: Byron Generating Station, Units 1 & 2 Location: 4450 North German Church Road Byron,IL 61010 Dates: November 17-December 18,1997 Inspectors: R. Paul, Senior Radiation Specialist D. Nissen, Radiation Specialist W. West, Radiation Specialist

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Approved by: G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety 9901210207 980114 PDR ADOCK 05000454 C PDR

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EXECUTNE SUMMARY l

' Byron Generating Stat.on,' Units 1 & 2 -

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- NRC Inspection Reports 50-454/97023; 50-455/97023

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This inspection included an announced review of the radiation protection program focasing on  ;

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the radiological controls for Unit 1 outage activities and the steam generator replacement projec j -

Plant Support j e The licensee effectively implemented work planning, radiological _ controls, and as-low-as .  !

. -reasonably-achievable (ALARA ) initiatives during the Unit i steam generato .<

replacement project (SGRP). However, several problems with some survey results ,

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used at a control point were identified. This matter will be reviewed during future ,

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p L inspections.:-(Section R1.1)

-*:' Radiation protection personnel's protocol for projecting dose was sound. The lower than  !

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- expected SGRP and outage doce was due in part to lower than expected dose rates in containment. The low dose rates were attributed to successful source term reduction -

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L efforts.1The overall projected _ dose goal of 425.6 person-rem for the outage is -

reasonable and expected to be achieved. (Section R1.2)-

• - The inspectors reviewed a potentia locked high radiation aree egress incident and the i P t licensee's investigation. The licensee's investigation of this matter found that workers had not been denied egress from the area.- However, as a result of the investigation, ,

- the licensee implemented actions to avoid the potential for anyor;e to become locked ,

, within the missile barrier. (Section R1.3)

• : Due to inspector concems, the licensee r0 evaluated a personal dose assigned to a -

worker from a radioactive hot particle. As a result, the licensee found that the initial .

- -. dose assessment was incorrect. Although the initial dose assessment was conservative, the inspectors noted that it was not sufficiently thorough. (Section R1.4)

. *~ . A procedural violation w2s identified for workers that were loitering (one was sleeping) in

containment.- The inspectors expressed concem about the workers supervisor who allowed them to wait in containment for an indeterminate time. Acceptable corrective actions were taken to prevent recurrence; however, the licensee's initial review of this matter had not sufficiently considered the inappropriate performance of the supervisor

who instructed the workers to wait. - (Section R4.1) -

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Report Detalla IV. Plant Suncort

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R1 Radiological Protection and Chemistry (RP&C) Controls R Unit 1 Steam Generator Reolacement Project (SGRP) and As-Low-As-Reasonabl Achievable (ALARA) Imol6 mentation Insoection Scooe (IP B3729)

T'.s inspectors reviewed the radiological controls implemented and the ALARA goals for it's SGRP. The inspectors also reviewed ALARA plans and radiation work permits (RWPs), observed several work evolutions and worker practices, and questioned workers conceming their responsibility to implerr.ent good work practices and their understanding of radiological controls, Observations and Findinas Overall housekeeping in containment was geod. Workers were aware of their dose rates and personal dosimeter electronic se tings, and with the exception of a'few instances, loitering was not observed. The inspectors noted that radiation protection technicians (RPTs) routinely questioned workers concemine il eir knowledge of work area dose rates and RWPs and directed workers to low dose watung areas outside the missile barrier when neede Work packages utilized industry lessons leamed and contained good ALARA controls to minimize exposure. The resources identified in the ALARA plans (specialized radiation detection equioment, ventilatica units, shielding, etc.) were utilized. The inspe'ctors noted that the ALARA controls, including radiological hold points, were discussed at pre-job briefing The inspectors attended several pre-Jcb briefings for both the (SGRP) and the balance of plant (BOP) operations. The briefings for the BOP were held in the station ALARA briefing room which contained a new television system which allowed workers to see photographs of the work areas. The : team generator briefs were held in the containment access fac;lity (CAF), where there was more room available. Sufficient information was provided to the workers at the briefings; there was a questioning

- attitude by the workers, and the radiation protection (RP) staff cicarly communicated RWP requirements and questioned whether the workers had the proper tools and equipment available. The briefings included discussions by the job foreman on the work to be perfo,me Remote monitoring was used for selected evolutions, and the RP staff viewed many of the evolutions via closed circuit television. The workers proceeded with the tasks and had a good understanding of their work assignments. The ALARA personnel's evaluations of SGRP evolutions determined that respiratory equipment was not needed-3-

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for a majority of the work, which resulted in a few low level radioactive material intake The intakes resulted in less than 10 millirem committed effective dose equivalent to any worker. Loose contamination was effectively controlled resulting in reduced airbome radiation areas during the reactor coolant system (RCS) pipe cut GRP workers entered and exited containment through the CAF and were required to inform RP staff at both the CAF and the containment control point of their planned activities. The inspectors reviewed surveys that were kept at the containment contrci point and found one set of surveys of the B and D generators icbeled incorrectl Specificelly, the D generator was mislabeled as the B generator. However, the dose rates around the two areas were similar so no significaat misinformation was given to workers. A review of other similar steam generator surveys indicated this was an isolated problem. However, on December 17,1997, the inspectors identified several general area weekly surveys at the containment control point that were about one month oid. The inspectors verified that more recent surveys were performed as required by station procedure, but due to communication problems the current surveys were not transmitted from the CAF to the control point. This matter will be reviewed further duri a future inspection. (IFl 50-454/97023-01; 50-455/97023-01)

The insp0ctors reviewed the station dose and ALARA go* for the outage. The projected dose for the SGRP was about 245.2 person-rem and for the outage 42 person-rem. At the end of the inspection period, the total dose for the outage was 15 person-rem as compared to a projected dose goal of 252.8 person-rem at that stage of the outage. The inspectors found that the radiction protection personnel's pr,otocol for projecting dose was sound and that the lower than expocted dose was due in part to lower dose rates in containment than had been initially projected. The lower dose rates were attributed to source term reduction efforts which included extending the early boration of the RCS about four times longer than normal tirno of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. The RCS crossover piping was refilled on all four loops which provided additional shielding benefits. Also, system flushes were conducted for the RCS loop bypass knes, steam generator bowl drain lines, and RCS loop fill and drain lines. This was also the first outage since the resistance temperature detet: tors wwe removed, a'id although difficult to quantify, the dose reduction resulting from their removal was considered significan The licensee anticipated that the overall projected dose goal of 425.6 person-rem for the outage should be me c. Conclusions During the Unit 1 SGRP, the licensee was effective in implementing work planning, radiological controls and good ALARA practices. However several problems with survey records used at the control point were identified and will be reviewed during future inspections. To date, the outage dose was significantly less than projecte .

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R1.3 Workers Locked in Locked Hiah Radiation Area (LHRA) Insoection Scooe (IP 83750)

The inspectors reviewed the circumstances surrounding a licensee identified event concerning two workers who were thought to have been locked in an LHR Observations and Findinas On November 8,1937, two electrical maintenance workers entered the Unit 1 -

containment inside the missile barrier which was posted and controlled O an LHR Because the gate door leading into the LHRA had previously been damap, i slightly, the licensee conservatively added a chain and padlock to the gate door which had a standard lock. Before the workers entered the area, they unlocked both thc gato door and padlock, laid the cha!n on the floor, and locked the padlock through the gate doo When the workers attempted to leave the area, they discovered that the gate door had been locked with the chain they had earlier placed on the floor, and the padlock they attached to the gate door. A passerby was immediately flagged down and the gate door was unlocked by using the key in the workers possession, allowing egress. Had the passerby r,H Deen there, the workers indicated the that the chain was sufficiently loose in the gate voor to allow them to slide it through until they could have unlocked the padlock. Additionally, egress from another door inside the missile barrier about 75 feet from the locked gate was available. The workers also staLd (nat the in-house speaker system was operational and that they could have called for help. F.adiation dose rates near the 'ence were about one millirem per hou The licensee's investigation of this incident identified that a contract RPT discovered the lock and chain on the floor and replaced it to its normal position. The RPT did not think that workers were in the LHRA. As a result of this incident, the gate was repaired so that the chain and padlock were not requireo to provide adequate LHRA controls. RP personnel also held a ' tailgate' session with the maintenance department to ensure that a workers were aware of both entrances to the missile barrier, as well as general high radiation area controls and relevant procedures.

l Conclusions The inspectors concluded that the padlock and chain were capable of being pulled uto a position within the gated door such that the workers were provided egress, and egress was also available from another door inside the missile barrier. Actions taken to prevent similar incidents were implemented by the licensee and appeared adequat R1.4 Hot Perticle On Worker a, lasp_ection Scooe l

The inspectors reviewed the circumstances and dose assessment associated with a worker's exposure to a radioactive hot particl l

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b. Observations and Findings On November 23,1997, the su veys by RP ntaff detected a radinactive bot partic;e on the outside of a worker's modesty undershorts. Using gama spectroscopy, the particle was initially assessed to be about 1,53 microcuries of primarily cerium-144, praseodymlum-144, hafnium-181, and zirconium-95. The dose assigned based on the licensee's assessment was about 19 rem over ora square centimeter of the .xin and about 78 millirem deep dose equivalent for the same area. During a review of the licensee's dose assessment, the inspectors raised several questions about the evaluation concerning the isotopic mix of the particia and the thickness of the workers undershorts used for the dose assessment. As a result, the licensee performed another evaluation which included an isotopic recount and a measurement of the undershorts to determine the actual thickness of the garment. The results of this investigation indicated that the original undershort thickness used in the calculation was incorrect and that there was no cerium-144 and praseodymium-144 present in the particle. These isotopes were originaily identified due to a misinterpretation of the initial gNma spet,trometry data. As a result of the reevaluation, the licensee assigned the worker a skin dose of about 1.9 rem and a deep dose of about 86 millirem. The inspectors reviewed the final evaluation and found that the re-assigned dose was more accurate and technically correct, c. Conclusions The inspectors concluded that althcugh the original assigned dose was conservative, the original assessment was not thc ough and was not based on the most technically sound information availabl R4 Staff Knowledge and Performance in RP&C M ,1 Workers Loitering in Containment a. Insoection Scoce (83729)

The inspectors performed severalinspections of containment and observed radiation worker (radworker) practice b. Observations and Findinus During a routine inspection within Unit 1 containment, the inspectors and the radiation protection manager (RPM) found a group of workers sitting down idle on the 426'

elevation waiting for crane availability. One of the workers was asleep and the RPM escorted him out of containment and instructed the other workers in the group to leave containment. The workers indicated to the inspectors that they had been Instructed by_

the job foreman to wait for the crane to become available which might be anywhere from -

ten minutes to one hour. The workers also stated they had been in containment waiting for about a half an hour when the RPM asked them to exit. Although the workers were in radiation fields of approximately 1 milliroentgen per hour (mR/hr), the inspectors

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expressed concem that the foreman instructed ' hem to wait inside containment rather than the CAF, which has easy access to containmen Corrective actions to prevent recurrence included: (1) the individual that was sleeping was escorted out of containment and his access to radiological areas at Byron was revoked; (2) the rernaining workers in the work crew were reminded of the rules of conduct in a radblogically posted area; and (3) all job supervisors were reinstructed in the stations policy to prevent loiterin 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. BRP 5000-7," Unescorted Access To And Conduct in Radiologically Posted Areas," requires that workers not loiter in radiation fields. Failure to follow the procedure is a violation (VIO) of TS 6.11 (VIO 50-454/97023-02 and 50-455/97023-02).- Conclusions The inspectors concluded that workers were loitering (one was sleeping) in containment which is a procedural violation. The inspectors er: pressed concern about the supervisor allowing them to wait in containment for an indeterminate time. Acceptable corrective

, actions were taken to prever t recurrence, however, the license 6's initial review of this matter had not sufficiently considered the inappropriate actions of the supervisor who Instructed the workers to wai V.. MANAGEMENT MEETINGS X1 Exit Meeting Summary

- On December 18,1997, the inspectors presented the inspection results to licensee .,

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management. The licensee acknowfodged the findings presente !

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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- PARTIAL LIST OF PERSONS CONTACTED

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iJ Bauer Health Physics Supervisor ._

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L'. Bushman, SGRP Radiation Protection . Supervisor

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R. Colgiazier, NRC Coordinator

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T. Gierich, Operations Manager -

W. Grundmann, Chemistry Superviso K. Kofron, Station Manager M. Marchionda, Technical Lead Health Physicist

__ W. McNeill, ALARA/ Operations Lead Health Physicist INSPECTION PROCEDURE USED IP 83750; Occupational Radiation Exposure IP 83729: Occupational Exposure During extended Outages LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

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Oneiled 50-454/455-97023-01 IFl Problems with survey information and communication 50-454/455-97023-02 VIO 'Woricer sleeping in containment

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LIST OF ACRONYMS USED ALARA As-Low-As-Is-Reasonably-Achievable BOP Balance Of Plant CAF' Containment Acuss Facility CFR Code of Federal Regulations IFl Inspection Follow-up Item LHRA Locked High Radiation Area MR/HR Milliroentgen per hour PDR Public Document Room-RCS Reactor Coolant System RP Radiation Protection RPM Radiation Protection Manager RPT Radiation Protaction Technician RP&C- Radiation Protection and Chemistry i RWP Radiation Work Permit

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SGRP Steam Generator Replacement Project

- TS Technical Specification VIO Violation

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LIST OF DOCUMENTS REVIEWED

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f f RWP 971881 RWP 97188 RWP 971884 PlF B1997-04397

= PlF B1997-01929

. PlF B1997-04035

. . PlF B1997-04409 Root Cause Report 454-200-97-CAQS00084

. BAP 330-5 " Lock and Key Control," Rev.12 BAP 1450-2 " Control of Access to High Radiation Areas, Locked High Radiation Areas, >15,000 MREM /HR Areas and Very High Radiation Areas," Rev. 9

- BRP 5000-7 " Unescorted Access to and Conduct in Radiologically Posted Areas," Rev. 7

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