IR 05000454/1998010
| ML20248C059 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 05/28/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20248C016 | List: |
| References | |
| 50-454-98-01, 50-454-98-1, 50-455-98-10, NUDOCS 9806020053 | |
| Download: ML20248C059 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lll Docket Nos:
50-454;50-455 License Nos:
50-454/98010(DRS); 50-455/98010(DRS)
Licensee:
Commonwealth Edison Company (Comed)
Facility:
Byron Generating Station, Units 1 & 2 Location:
4450 North German Church Road Byron,IL 61010 Dates:
April 3 and April 27 - May 6,1998 Inspectors:
W. Slawinski, Senior Radiation Specialist D. Nissen, Radiation Specialist W. West, Radiation Specialist A. Kock, Radiation Specialist Approved by:
G. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l
9806020053 990528 PDR ADOCK 05000454 G
PDR m
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EXECUTIVE SUMMARY Byron Generating Station, Units 1 & 2 NRC Inspection Reports 50-454/98010; 50-455/98010 This inspection included an announced review of the radiation protection program. Specifically, the inspection focused on the Unit 2 refueling outage.
i Plant Suonort The moisture carryover test was well implemented. Workers used good radiation
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protection practices and dose was kept low. However, one violation for a failure to l
properly post a radiation area was identified. (Section R1.1)
Two instances of radioactive material being shipped offsite as non-radioactive material
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were identified by another NRC licensee when a survey was performed on the incoming shipments. One violation conceming the failure to properly implement the procedure for unconditional release of radioactive material was identified. (Section R1.2)
The licensee had established an aggressive goal of 130 person-rem for the outage.
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Source term reduction efforts contributed to keeping doses low, and as-low-as-is-reasonably-achievable (ALARA) pre-job briefings were well implemented. The inspectors identified that there were no low dose waiting areas posted in containment; however, once pointed out to radiation protection supervision this was corrected.
(Section R1.3)
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. While performing a turbine lube oil flush, the hose that was transporting oil disconnected '
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and sprayed oil onto alllevels of the turbine building. About 500 gallons of oil went into the condenser. Chemistry personnel performed a thorough assessment to determine how to remove the oil and to establish oil levels that would be acceptable for startup.
(Section R2.1)
One violation conceming the failure to properly implement the procedure for conduct
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in a radiologically posted area was identified. Multiple examples of poor radiation
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worker practices were observed by the inspectors. These poor practices resulted in a higher number of personnel contamination events than in previous outages.
Additionally, the inspectors were concemed that radiation protection supervision had not
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l taken a more critical view of radiation worker practices and the resulting contaminations, j
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and that radiation protection technicians in containment had not identified this problem.
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(Section R4.1)
The recent self assessment performed by the quality and safety assessment department
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was thorough and provided good recommendations. Additionally, observations made by the auditor during the Unit 2 outage had identified similar problems with radiation worker practices as documented in Section R4.1. (Section R7.1)
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Emport Details IV. Plant Sunnort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Sodium-24 (NA-24) Moistura Carrvover Test a.
Insoection Scoce (IP 83750)
The inspectors observed the moisture carryover test which used a Na-24 source, reviewed the procedure used, and attended the as-low-as-is-reasonably-achievable (ALARA) prejob briefing.
b.
Observations and Findinas
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The inspectors attended the ALARA prejob briefing and noted that there was good discussion of contingencies as well as past industry events. The licensee's review included changes that had been made to address lessons leamed from the dry run earlier in the week. The inspectors observed the receipt of the shipment of the Na-24 and movement to the injection location. The receipt of the shipment was completed in accordance with procedures and good radiation protection controls were implemented when moving the source. Prior to the source arriving on site, an area had been established with the necessary postings and ropes staged. The RP staff performed surveys of the shipment cask, and measured dose rates of about 40 millirem per hour (mrem /hr) on contact with the cask,10 mrem /hr at 30 centimeters, and 2 mrem /hr at 1 meter. The surveys were documented appropriately, however, the inspectors questioned the radiation protection technician (RPT) as to why the area had not been posted as a radiation area (RA) based on the dose rates measured. The technician indicated that the area was posted as a radioactive materials area and that this was sufficient. The inspectors were concemed that the RPT did not understand the posting requirement. This was discussed with the radiation protection manager who proceeded to review the survey document and instructed the RPT to post the area as a RA.10 CFR 20.1902(a) requires that the licensee post each RA with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." The failure to properly post the area as a RA is a violation (VIO) of 10 CFR 20.1902 (a) (VlO Nos. 50-454/98010-01 and 50-455/98010-01).
Overall, with respect to radiation protection concems, the test was well implemented.
Chemistry technicians performed the sampling and the inspectors observed good radiation protection practices. The workers who injected the sample also demonstrated good radiation protection practices and were aware of previous industry events.
Communications between the different work groups were well coordinated. Since timing for this evolution was important, the importance of worker coordination was fully l
discussed in detail during the prejob briefing. The evolution was executed as planned and the total dose.o the workers involved with this evolution was 19 mrem.
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Conclusions Overall, the moisture carryover test was well implemented. Workers used good radiation protection practices and dose was kept low. However, one violation for failure to properly post a radiation area was identified.
R1.2 Radioactive Material Control a.
Insoection Scooe (IP 83750)
The inspectors reviewed several occurrences of radioactive material (rad material)
found outside of the radiologically posted area (RPA).
b.
Observations and Findinos Since January 1,1998, the licensee has identified several examples of rad material outside of the RPA. During shipments of the steam generator replacement equipment, two incidents resulted in rad material being unconditionally released and transported offsite to the Braidwood station. On February 19,1998, the licensee shipped the containment access facility building to Braidwood which was later found to contain radioactive material. The material was protective clothing which was found in a biohazard bag that when opened had a radioactive material bag inside. This was identified by Braidwood RP personnel and placed into the small article monitor (SAM)
which found the clothing to have 128,000 disintegrations per minute (dpm) of contamination. When this material was shipped, Byron station RP personnel had not been aware that it was inside of the access facility; therefore, no survey to unconditionally release this material was performed.
The other instance was also part of a shipment of steam generator replacement materials shipped to Braidwood on February 25,1998. A 480 Volt panel was identified by Braidwood RP personnel on April 15,1998, to have 4,500 dpm of smearable contamination in it. When this material was released by Byron RP personnel. the contamination had not been identified. The specific activity and levels of the I
contamination do not meet the definition of radioactive material as defined in 49 CFR Part 173.403 and as such are not subject to these transportation regulations.
However, Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved,
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maintained and adhered to for all operations involving personnel radiation exposure.
Byron Administrative Procedure BAP 720-3, Revision 18, dated October 27,1997, j
" Control of MMerials For Conditional or Unconditional Release from Radiologically l
Posted Areas," requires in step C.4 that allitems having the potential to be contaminated be unconditionally released or meet the conditional release requirements.
Additionally, the procedure defines unconditional release as the release of an
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article / material that has no detectable licensed radioactive material above background and defines conditional release as an article / material that is contaminated, or suspected to be contaminated, and is logged and controlled to prevent unauthorized use or
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removal and is retumed to a permanent RPA within one shift unless appropriate controls are established. The failure to release radioactive material in accordance with this procedure is a violation of TS 6.11 (VIO 50-454/98010-02 and 50-455/98010-02).
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Conclusions Two instances of radioactive material being shipped offsite as non-radioactive material were identified by Braidwood station RP personnel resulting in two examples of a violation conceming the failure to properly implement the procedure for unconditional-release of radioactive material.
R1.3 Refuelina Outaae Radiological Controls (Unit 2) and ALARA Proaram a.
Insoection Scone (IP 83750)
The inspectors reviewed the dose goals established for the Unit 2 outage as well as source temi reduction efforts and other ALARA practices. Walkdowns were performed to observe ALARA practices in containment.
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Observations and Findinas The inspectors reviewed the station dose and ALARA goals for the outage. The dose
goal for the outage was about 130 person-rem. At the end of the inspection period (day 19 of a planned 38 day outage), the total dose for the outage was 101.4 person-rem.
The goal had been based on previous outage history, work scope, and planned source term reduction efforts. In addition to the total goal for the outage, each radiation work permit (RWP) was assigned an estimate for the work to be performed. The inspectors noted that the total dose for all of the RWPs was 194.5 person-rem. Each RWP estimate was based on previous work experience, job supervisor estimates of the time
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required for each evolution of the job, and expected dose rates in containment. The
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inspectors found that the radiation protection personnel's protocol for projecting dose was sound, however, the outage goal of 130 person-rem was very aggressive when compared to the RWP estimates. The inspectors discussed this observation with the licensee who indicated that the outage goal had been set low in order to be aggressive
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The source term reduction efforts included implementing actions that had been successful during the last Unit 1 outage as well as an effort to improve and to try new methods to reduce the source term. Actions taken included refilling the reactor coolant system (RCS) crossover piping on all four steam generator loops which provided additional shielding benefits and included system flushes of the RCS loop bypass lines, steam generator bowl drain lines, and RCS loop fill and drain lines. Additionally, the pressurizer surge line was flushed and the lines associated with the 2RC8042A/B/C/D check valve work were also flushed to minimize dose when these valves were worked on. The licensee had also installed 26 temporary shielding installations.
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The inspectors attended the pre-job briefings for the moisture carryover test, the core barrel lift, and the removal and replacement of the 2RC8029B valve and observed the conduct of these evolutions. The briefings were well coordinated, and there was good participation and communication between the work groups. There was good discussion of contingencies and lessons leamed during the briefings. The core barrel lift evolution was well performed and doses for the workers involved were low. The licensee had established a viewing area outside of containment in a low dose waiting area. RPTs maintained control of entry into the spent fuel pool area, and additional technicians were staged within the contaminated area but in a low dose area so that, if needed, they would be ready to enter containment. ALARA practices implemented for the valve work were good. Workers were instructed during the briefing of where to wait and when and whom would be working on the valve itself. Although worker briefings discussed low dose areas the inspectors identified that there were no postings in containment to identify low dose waiting areas. The inspectors discussed this with RP supervision who indicated that this was an oversight, and the informational postings were put in place.
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Conclusions The licensee had established an aggressive goal of 130 person-rem for the outage.
Source term reduction efforts contributed to keeping doses low, and ALARA pre-job briefings were well implemented. However, the inspectors identified that there were no
low dose waiting areas posted in containment. Once pointed out to RP supervision this l
was corrected.
R1.4 Shutdown Chemistry (IP 83750)
i During the Unit 2 shutdown, when the reactor cavity was being flooded, the area
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radiation monitors alarmed on a high radiation signal. Dose rates peaked at about 550-650 milliroentgen per hour (mR/hr) at the surface of the cavity due to high levels of cobalt-58 (Co-58). The licensee had implemented the routine shutdown template that had been devised by Byron and Braidwood stations. The template included direction for j
the addition of hydrogen peroxide to initiate a crud burst and a cleanup regime that l
removed the crud from the system. The licensee's investigation identified that low letdown flow during the cleanup (after the crud burst) was a contributor to the high radiation dose rates. The letdown flow was only at a rate of about 50 gallons per minute l
(gpm). However, letdown flow rates had historically been about 80 gpm or higher. The inspectors discussed this event with chemistry personnel who indicated that during the
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i cleanup they had requested maximum flow from operations who had responded that approximately 50 gpm was maximum flow. The preliminary investigation identified four contributors to the event. The first was a failure to incorporate lessons leamed from a similar event that occurred at the Quad Cities station in 1996. The second was poor communications between chemistry and operations. Third, chemistry failed to escalate their concerns about the low letdown flow and fourth, the low flow itself. The licensee planned to issue an event report to the NRC regarding the event and to document any (
corrective actions which will be followed-up in a future inspection (inspection follow-up item (IFI) 50-455/98010-03).
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R2 Status of RP&C Facilities and Equipment R2.1 Oilin Condenser (IP 84750)
On April 27,1998, while performing a turbine lube oil flush, a hose that was transporting oil disconnected. Oil was subsequently identified on alllevels of the turbine building and in the condenser. Of the approximately 500 gallons of oil that was determined to be in the condenser, the licensee initially removed about 250 gallons. Steam cleaning of the condenser was performed and the licensee planned to add methoxypropyl amine, fill the condenser up and then perform additional fill and drains as needed until the oil and grease results were less than 1 part per million (ppm). The licensee evaluated the effect of the intrusion and concluded that every gallon of oil could potentially result in 4.5 parts per billion (ppb) of sulfur which could then form sulfates and increase the rate of intragranular stress corrosion cracking. Based on the above actions the licensee planned to maintain the oil and grease concentration below 1 ppm, which would not exceed the Electric Power Research Institute action level 2 values for sulfates. The success of the cleanup and resulting startup chemistry will be reviewed in a future inspection (IFl 50-455/98010-04).
R4 Staff Knowledge and Performance in RP&C R4.1 Radiation Worker (Radworker) Practices a.
Insoection Scoce (IP 83750)
The inspectors performed several walkdowns of containment to observe radworker i
practices. Additionally, the inspectors reviewed problem identification forms (PlFs)
which documented personnel contamination events (PCEs).
b.
Observations and Findinas During inspections performed inside the Unit 2 containment the inspectors identified poor housekeeping. There were extra protective clothing, rags, and other miscellaneous items throughout containment. The inspectors discussed this with RP management, and throughout the week of the inspection a significant improvement in housekeeping was observed. The inspectors were concemed however, that the effort had not been made until it was identified by the NRC.
The inspectors observed multiple examples of poor radworker practices. Examples included a worker who opened his protective clothing to read his beeper without removing his outer rubber gloves, several workers who were observed using the phone without removing their outer gloves, and a worker who dropped a level into a catch basin and reached into the basin to remove the level (the catch basin had about 1,000 dpm smearable contamination). The inspectors identified a worker that had his foot i
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and workers who were not aware of the dose rates in their work area. Multiple examples of hoses and cables which were not secured at the boundary of a HCA were l
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identified. Also, several instances of tygon tubing from catch basins were not secured at the drains. Additionally, several workers were observed to adjust their glasses and touch their face with their potentially contaminated outer rubber gloves on.
The inspectors di:, cussed their observations with RP management. In response to the inspectors concems, from April 29-30,1998, RP supervisors and management talked to several other departments regarding radworker practices. Several workers who were observed using poor radworker practices were instructed to leave containment and
- counseled. Furthermore, the RP department issued a letter (Byron letter 98-0143)
which described a program for improvement in radworker practices. This program included the steps taken if a worker is observed using poor practices: the worker will be locked out of the RPA, and a PlF will be initiated. The worker will not be able to gain access to the RPA until the PlF is complete and RP has concurred.
In the cases mentioned above, the instances of the workers touching their faces, adjusting their glasses and reaching into their protective clothing are specific examples of the failure to follow Radiation Protection Procedure BRP 5000-7, Revision 7, dated June 28,1996 " Unescorted Access To And Conduct in Radiologically Posted Areas," a -
procedure required by Technical Specification (TS) 6.11. This procedure states that each person entering a RPA is responsible to adhere to the rules. Step 3.z states in part that workers avoid bad rad practices; do not adjust glasses with outer rubber gloves, do not touch your face while in protective clothing, do not wear protective clothing partially unzipped. The failure to use proper radioactive worker practices as described in the procedure is a violation of TS 6.11 (VIO 50-454/98010-05 and 50-455/98010-05).
During the outage the licensee had experienced a higher number per day of PCEs than in previous outages. As of day 20 of the outage, the licensee had approximately 2.9 PCEs/ day. Of these,20 were attributed to radworker practices. During the Unit 1 steam generator outage, which lasted over 100 days, there were only 11 PCEs attributed to radworker practice problems. The activity of the contaminations during this outage, excluding individual radioactive particles, was higher. There were two workers sent home with gloves on to sweat out the Co-58 which was the main contributor to the contamination. The inspectors were concemed that RP and plant management had not taken a more critical view of radworker practices and the resulting contaminations. Also of concem was that RP technicians in containment had not identified poor radworker practices as a problem until the inspectors brought it to their attention.
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Conclusions One violation conceming the failure to properly implement the procedure for access to the radiologically posted area was identified. Multiple examples of poor radiation worker practices were observed by the inspectors. These poor practices resulted in a higher number of personnel contamination events than in previous outages. Additionally, the inspectors were concemed that radiation protection supervision had not taken a more critical view of radiation worker practices and the resulting contaminations. Also,
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radiation protection technicians in containment had not identified this problem until the inspectors brought it to their attention.
R7 Quality Assurance in RP&C Activities R7.1 Quality and Safety Assessment Radiation Protection Audit (IP 83750)
The inspectors reviewed the recent self assessment performed by the Quality and Safety Assessment (Q&SA) department, riocumented in audit report No. Comed 98-02.
The Q&SA audit was thorough and provided good recommendations. For example, the auditor identified that a tool box had been staged in containment directly next to a posted hot spot, also identified were several problems with labeling. In addition, a repeat finding in the area of contamination control was identified. Q&SA personnel indicated that they had also made observations throughout the Unit 2 outage and found problems with radworker practices. These problems had been communicated to the RP departmer.t. The RP personnel had addressed each finding as an individual problem, but no actions had been implemented to address the problems as a whole, until the inspectors made similar observations (Section R4.1).
R8 Miscellaneous RP&C issues R8.1 (Ocen) VIO Nos. 50-454/97023-02 and 50-455/97023-02: A work crew was found loitering with one worker sleeping in Unit 1 containment during the steam generator replacement outage. On April 25,1998, during the Unit 2 outage, two workers involved in the steam generator eddy current testing were identified by the containment coordinator to be inattentive to duty. The workers were found at their job location with their eyes closed. Although the workers were not sleeping the similar nature of this event is of concern, this item will remain open and be reviewed during future inspections.
R8.2 (Closed) VIO Nos. 50-454/97017-01 and 50-455/97017-01: The inspectors identified a worker who crossed the step-off-pad into a contaminated area without protective clothing as required. Corrective actions to prevent recurrence included (1) revoking the worker's access, (2) RP staff discussed the issue with the individual and his supervisor
to ensure he was aware of the stations procedures and expectations, and (3) the worker
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attended the radiation worker part of initial nuclear general employee training. These actions were considered effective as no subsequent, similar violations had occurred.
This item is closed.
R8.3 (Closed) VIO Nos. 50-454/97017-02 and 50-455/97017-02: The licensee had identified one example of a failure to post a radiation area and one example of the failure to post a high radiation area, in both cases the inadequate posting was attributed to personnel moving radiological postings. Corrective actions to prevent recurrence included, discussing the expectation that barriers and postings not be moved at the kicko'f for the steam generator replacement outage, presenting a video on high radiation area control to appropriate departments, distributing the radiation worker handbook, and training for j
all RPTs regarding the proper response to a request to move postings or boundaries.
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No additional occurrences of workers moving postings or boundaries had been identified. This item is closed.
V. Manaaement Meetinas
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X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the l
conclusion of the onsite inspection on May 1,1998. On May 5-6,1998, an inspector discussed
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additional events with Mr. J. Bauer and Mr. W. Grundmann of the licensee's staff. The licensee acknowledged the findings presented and did not identify any proprietary information.
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PARTIAL LIST OF PERSONS CONTACTED J. Bauer, Health Physics Supervisor R. Colglazier, NRC Coordinator W. Grundmann, Chemistry Supervisor K. Kofron, Station Manager M. Marchionda, Technical Lead Health Physicist W. McNeill, Operational Lead Health Physicist INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure
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Radioactive Waste Treatment, and Effluent and Environmental Monitoring IP 92904 Follow-up-Plant Support ITEMS OPENED, CLOSED OR DISCUSSED
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Daen 50-454/455-98010-01 VIO Failure to Post a Radiation Area 50-454/455-98010-02(a-b)
VIO Radioactive material offsite
50-455-98010-03 IFl Shutdown chemistry alarmed radiation monitors 50-455-98010-04 IFl Oilin the condenser 50-454/455-98010-05(a-c)
VIO Poor radworker practices Closed 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 Discussed 50-454/455-97023-02 VIO Worker sleeping in containment l
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LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable Co-58 Cobalt 58 DPM Disintegrations per Minute GPM Gallons per Minute HCA High Contamination Area HRA High Radiation Area IFl Inspection Follow-up item MR/HR Milliroentgen per Hour MREM /HR Millirem per Hour Na-24 Sodium 24 NCV Non-Cited Violation PCE Personnel Contamination Event PIF Problem identification Form PPB Parts per Billion PPM Parts per Million PWR Pressurized Water Reactor Q&SA Quality and Safety Assessment RA Radiation Area Radmaterial Radioactive Material Radworker Radiation Worker RP Radiation Protection RPA Radiologically Posted Area RP&C Radiation Protection and Chemistry RPT Radiation Protection Technician RWP Radiation Work Permit SAM Small Article Monitor TLD Thermoluminescence Dosimeter TS Technical Specifications VIO Violation i
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LIST OF DOCUMENTS REVIEWED RWP 982588 " Lower Internals Removal and Reinstallation" RWP 980228 "U-1 S/G Moisture Carryover Testing Utilizing Sodium-24 as a Radioactive Tracer incl Activities Performed as Prerequisite" RWP 982829 "2RC8029 A-D: Grind, Cut Out and Replace" ALARA Action Review 0698009 BAP 720-3 Revision 19, " Control of Materials For Conditional or Unconditional Release From Radiologically Posted Areas" BRP 5000-7 Revision 7, " Unescorted Access to and Conduct in Radiologically Posted Areas" SPP 97-051 Revision 0, " Steam Generator Moisture Carryover" Quarterly PCE Analysis Report, April 1998 Letter Byron 98-0143 " Rad Worker Practice improvements" PIF B1997-04132 PIF B1997-04209 PlF B1997-04400 PlF B1997-05165 PlF B1998-00055 PIF B1998-00477 PIF B1998-00562 PIF B1998-00574 P!F B1998-01141 PIF B1998-01227 PIF B1998-01531 PlF B1998-01553 PIF B1998-01605 PIF B1998-01670 PIF B1998-01693 PIF B1998-01783 PlF B1998-01805 PlF B1998-01827 PIF B1998-01029 PlF B1998-01847 PlF B1998-01848 PIF B1998-01857 PlF B1998-01871 PIF B1998-01881 PIF B1998-01970 PlF B1998-02051 PIF B1998-02053 PIF B1998-02114 PIF B1998-02146 PlF B1998-02361
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