IR 05000454/1999016
| ML20217B310 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/01/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217B303 | List: |
| References | |
| 50-454-99-16, 50-455-99-16, NUDOCS 9910120205 | |
| Download: ML20217B310 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lli Docket Nos:
50-454;50-455 License Nos:
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Report No:
50-454/99016(DRS); 50-455/99016(DRS)
Licensee:
Commonwealth Edison Company (Comed)
i Facility:
Byron Generating Station, Units 1 & 2 Location:
4450 North German Church Road Byron,IL 61010 i
Dates:
September 7-10,1999 f
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Inspectors:
J. House, Senior Radiation Specialist
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K. Lambert, Radiation Specialist Approved by:
Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
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EXECUTIVE SUMMARY
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Byron Generating Station, Units 1 & 2 NRC Inspection Report 50-454/99016(DRS); 50-455/99016(DRS)
'This routine inspection of the radiation protection and chemistry program included the water chemistry control program, the chemistry instrument quality control program, the inter-laboratory comparison program, and the engineered safety feature filtration system. The
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inspection also consisted of a review of chemistry quality assurance, chemistry technician training and performance, area radiation monitors, and a spent resin radioactive waste shipment.
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The primary and secondary water quality was well maintained and monitored. The chemistry staff and plant management performed well and took appropriate actions to reduce the Unit 1 steam generators' sulfate concentrations to normal operating parameters following a condenser tube rupture (Section R1.1).
Required surveiNances and tests of the control room engineered safety feature filtration
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system were well implemented and performed in accordance with station procedures.
Test results indicated that the Technical Specification acceptance criteria were met.
Material condition of the ventilation system was good (Section R1.2).
The area radiation monitor calibration and maintenance program was effectively
iraplemented. Personnel were knowledgeable regarding the instrumentation and calibration procedures (Section R2.1).
The chemistry technician employed good radiation work practices during primary coolant
sampling and was knowledgeable of the sampling procedure (Section R4.1).
The ctation's continuing training program for chemistry personnel was effective in
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providing technicians with necessary skills and knowledge. The program was generally comprehensive, and well structured. The materials and presentations were effective (Section R5.1).
The laboratory instrument quality control program was effectively implemented.
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Instrument verification initiatives and gamma spectroscopy lower limit of detection analysis were performed as required and analytical instruments generally operated within statistical control limits (Section R7.1).
Assessments of the chemistry program were of s'Geient sc@ and depth to identify
deficiencies and covered areas where corrective act.4,5 had been warranted in the past. Findings were adequately documented and corrective actions were in progress or had been completed (Section R7.2),
The September 9,1999, shipment of spent resin was in compliance with Nuclear a
Regulatory Commission and Department of Transportation regulations. Personnel involved with the shipment were knowledgeable of the procedures and their role in preparing the shipment for transportation (Section R8.1).
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Report Details
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IV, Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Water Chemistry Control Proaram a.
Insoection Scooe (84750)
The inspectors reviewed the licensee's water chemistry control program for the control and mitigation of chemical contaminants in the primary and secondary water systems.
This included a review of chemistry parameter data for the previous eighteen months and discussions with cognizant individuals.
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Observations and Findinos The licensee's water chemistry control program was consistent with the Electric Power Research Institute (EPRI) pressurized water reector guidelines. The inspectors reviewed selected trend records and noted that the licensee effectively controlled
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primary and secondary water chemistry in both units. The concentration of chloride and sulfate in the primary systems was less than five parts per billion (ppb). Fluoride was
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generally less then five ppb. Control of dissolved hydrogen was also good, with levels j
averaging 35 cubic centimeters per kilogram of water at standard temperature and pressure.
Steam generator (SG) sodium, sulfate and chloride concentrations were generally 1-3 ppb. The concentration of feed water iron was maintained below the Action Level 1 concentration of five ppb with levels averaging approximately two ppb. Occasional spikes in the secondary chemistry parameters of both units resulted from circulating water in-leakage.
On December 23,1998, an intermittent condenser tube leak (Unit 1) in the 1C water box developed into a continuous leak, that in five hours msulted in the reactor coolant sulfate level reaching 478 ppb. This placed the unit in EPRI Action Level 3. Station procedures, at that time, required Mode 3 shutdown within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of reaching Action Level 3. The licensee formed a chemistry management team that evaluated the j
situation and concluded that reducing power, but remaining on line, would result in faster cleanup of the Unit i steam generators. The Unit i hot well was directed to the B condensate polisher and the 1C water box was isolated. The combination of isolation of the water box containing the leaking tube, hot well cleanup using the condensate polishers, and operation at reduced power (27%) was successful in system cleanup.
The time spent above Action Level 3 (6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) was less then the 8-hour shutdown requirement. On December 24,1998, at 1436 hours0.0166 days <br />0.399 hours <br />0.00237 weeks <br />5.46398e-4 months <br />, the plant exited Action Level 1 for sulfates (<10 ppb). Continued operation enabled the steam generators to maintain full blow down capacity which would not have happened in shutdown conditions.
Additionally, by reducing power, the percentage of feed water flow being cleaned up
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through the condensate polishers was higher than it would be at full power operation.
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The licensee's justification for their actions was well documented and technically sound.
The licensee performed well during this excursion.
The inspectors reviewed the boron level of the spent fuel pool (SFP) and the
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accumulator boron concentrations, both Technical Specification (TS) requirements. The i
. SFP boron met the TS limit of 2000 parts per million (ppm) and the plant administrative
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limit of 2300 ppm. The boron level in the accumulators was in the required range of.
2200-2400 ppm.
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Conclusions The primary and secondary water quality was well maintained and monitored. The chemistry staff and plant management performed well and took appropriate actions to reduce the Unit 1 steam generators' sulfate concentrations to normal operating parameters following a condenser tube rupture.
R1.2 Control Room Enaineered Safetv Feature Filtration System a,
. Inspection Scooe (84750)
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR) and TS for the control room engineered safety feature filtration system. This review included the results of the TS required monthly ventilation system surveillance, and filtration and adsorber units' performance tests. In addition, the inspectors discussed the system with the cognizant engineer and performed a walk down of the filtration system to observe the material condition.
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Observations and Findinos The UFSAR and TS required that the control room engineered feature filtration system operate monthly with flow through the makeup system filters for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> and flow through the recirculation charcoal adsorber for at least 15 minutes. Additional system tests (18 month frequency) included an air flow rate test, an in-place high efficiency particulate air (HEPA) filter efficiency test, an in-place charcoal adsorber efficiency test, and a laboratory charcoal adsorber test for iodine removal efficiency.
The inspectors reviewed the monthly control room ventilation surveillances, and the -
HEPA filter and charcoal adsorber test results for 1997 and 1998. The inspectors concluded that the tests were performed at the frequency specified in the TS, the test results were within the TS limits, and the tests were performed using proper industry standards, in addition, the inspectors noted that the charcoal adsorber tests were performed using the most recent American Society for Testing and Materials (ASTM),
D 3903-89," Standard Test Method for Nuclear-Grade Activated Carbon" and that the
. TS correctly referenced this version of the test method.
The inspectors performed a walk down of the control room ventilation system including duct work, filter housings, and the control room ventilation panel and noted that the ventilation system was maintained in good material condition.
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Conclusions Required surveillances and tests of the control room engineered safety feature filtration system were well implemented and performed in accordance with station procedures.
. Test results indicated that the Technical Specification acceptance criteria were met.
Material condition of the ventilation system was good.
R2 Status of Radiological Protection and Chem!stry Facilities and Equipment R2.1 Ama Radiation Monitor Calibration and Operability a.
Inspection Scope (83750)
The inspectors reviewed the calibration and operability of the area radiation monitors (ARMS). The review included selected calibration and maintenance records, in-field observations, interviews with applicable personnel, and the applicable requirements in the UFSAR and Technical Specifications.
Observations and Findinas The ARMS monitor plant radiation levels and provide notification of abnormal gamma radiation levels in areas where radioactive materials may be used, stored, or handled, and provide indications of radiation levels in specific areas of the plant. The
' instrumentation and Control (l&C) group performed calibrations and routine maintenance of the monitors. Readouts were provided in the control room for the ARMS, with selected monitors providing local readouts.
The inspectors reviewed ARM calibration data for 1998 and 1999. Calibrations were performed at the required frequencies and calibrations were appropriately documented on calibration forms. Monitor alarm set points were also appropriately set for those monitors with alarm functions. The system engineer indicated that those monitors required for TS compliance were monitored for operability under the maintenance rule and the station maintained a formal program to track operability. For the remaining ARMS, the system engineer maintained an informal program for monitoring performance and operability. The system engineer also indicated that monitor failures were rare and generally the result of a degraded detector or power supply. The system engineer was knowledgeable of the area radiation monitoring system and applicable calibration and maintenance procedures.
During plant walk downs, the inspectors observed that the ARMS were in good operating condition. For selected monitors, the inspectors verified that the location, and remote
. (control room) and local (if applicable) indications were as described in the UFSAR.
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Conciusiontt The area radiation monitor calibration and maintenance program was effectively implemented. Personnel were knowledgeable of the instrumentation and calibration
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Staff Knowledge and Performance in Radiological Protection and Chemistry
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R4.1 Staff Performance Durina Samole Collection and Analysis (84750)
The inspectors evaluated the chemistry staff's knowledge of sample collection by observing a technician collect a sample of reactor coolant from each Unit. The technician was knowledgeable of applicable procedures and techn! ques as evidenced by using appropriate collection methods, including rinsing the bottles prior to obtaining each sample and wearing required protective clothing. The technician had a copy of the
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sampling procedure and adhered to it, and performed a radiological survey of the reactor coolant sample container for dose rates. The chemistry technician employed good radiation work practices during primary coolant sampling and was knowledgeable of the sampling procedure.
R5 Staff Training and Qualification in Radiological Protection and Chemistry R5.1 ~ Trainina of Chemistry Personnel a.
Insoection Scoce (84750)
The inspectors interviewed the chemistry training coordinator, reviewed training documentation for two chemistry continuing training modules and observed portions of this training to assess the adequacy of the licensee's chemistry training program.
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Observations and Findinas The licensee had a well developed continuing education program. The program was owned by the Chemistry Managers and was govemed by the Chemistry Technician Training Program's Training Advisory Committee (TAC) and Curriculum Review Committee (CRC). Continuing training was designed to maintain and improve the performance level of personnel who had been qualified to perform specified tasks, independently. Continuing training topics were selected by the chemistry program's CRC Training topics were repeated every 1-4 years depending on the subject matter.
The inspectors attended two training sessions and reviewed two sections of Continuing Training Module #3: The Chemical Volume Control System (CVCS); and Radiochemistry / Isotopic Review. Both sections were well organized, providing sound technical information for the topics covered and insights to system operation. The instructors were well prepared and were very knowledgeable of their respective subjects. The training room was well equipped, use of audio / visual equipment was good and each technician had a package of training materials. The instructors used industry events to emphasize technical points. These events were included in the training manual. Good interaction was observed between the instructors and technicians, and included question and answers during the training sessions.
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The CVCS presentation stressed system design and operation, and how sampling was
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isotopic presentation covered isotope production, sample analysis and data review.
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Activation products (coolant, corrosion and wear) and their impact on radiological dose were also discussed. The presence of fission products in the reactor coolant system, especially lodines and fission gases, was related to fuel damage. The sections on analysis of samples by gamma spectroscopy and interpretation of the data were very well prepared.
The continuing training program was technically strong. The instructors stressed the
'importance of chemistry functions to plant operations and the role of the chemical techniciano as first line observers of abnormal operating conditions. During a discussion with the Chemistry Manager, the role of the department and its relationship with the Operations Department was discussed. The manager stated that a department goal was to continue emphasizing that relationship. The inspectors noted that this had been a strength of the station in the past and was discussed in the continuing training program.
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Conclusions The station's continuing training program for chemistry personnel was effective in providing technicians with necessary skills and knowledge. The program was generally comprehensive, and well structured. The materials and presentations were effective.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Laboratory and instrument Quality Control Proarams a.
Inspection Scoce (84750)
The inspectors reviewed the laboratory quality control programs for analytical and radioanalytical instrumentation, including the inter-laboratory comparison programs.
The review included quality control records and discussions with chemistry technicians and cognizant chemistry personnel.
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Observations and Findinog The chemistry staff used quality control checks to monitor the daily performance of chemistry analytical and radioanalytical instrumentation. The inspectors reviewed selected 1999 quality control data and concluded that quality control initiatives were performed at the required frequency in accordance with chemistry procedure BCP 520-7 Revision 1," Preparation and Interpretation of Quality Control Charts." The inspectors noted that the quality control data was being entered in the computer-based instrument control program, which indicated whether instruments passed or failed the daily control checks. Quality control data reviewed indicated that laboratory instruments generally performed within the control limits. However, the inspectors noted instances when quality control limits were exceeded and there was no documentation of corrective actions, either in the computer data base or in the weekly review of quality control data performed by the responsible chemist. While the procedures required that control charts be reviewed and corrective actions implemented, the procedure did not require
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documentation of corrective actions er investigations into performance problems.
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Documenting corrective actions can lead to earlier identification of repetitive problems, and therefore, earlier resolution of instrumentation degradation and performance.
Chemistry management indicated it would review the documentation practices and implement corrective actions as warranted.
The inter-laboratory cross check program was implemented in accordance with station procedures. The analytical cross check program was performed twice per year, during the first and third quarters, while the radioanalytical program was performed quarterly.
The corporate chemistry group provided analytical unknowns to be analyzed, while a contract vendor provided radioanalytical unknowns. This inter-laboratory program tested the overall laboratory analytical capability. The inspectors noted generally good agreement between the licensee results and the known values of the inter-laboratory comparison samples. When the analytical results were outside the acceptable range, the cause was evaluated and corrective actions were implemented. In addition, the chemistry department would analyze' additional samples of that type the following quarter. Chemistry technicians also analyzed unknowns on a quarterly basis as part of an intra-laboratory cross check program. The inspectors review of the chemistry technicians' performance indicated that the technicians determined the unknown concentrations accurately in most instances. For those analyses where there were disagreements, the causes were identified and resolved.
The inspectors reviewed the licensee's most recent E-BAR calculations to determine reactor coolant activity limits as defined by BCP 230-3, Revision 6, " Determination of E-BAR." E-BAR is the average disintegration energy of the reactor coolant's isotopic mixture, and 100/E-BAR in microcuries per gram the TS reactor coolant activity limit.
The E-BAR calculations for each unit appeared to have been adequately performed.
The licensee was also required to perform a Lower Limit of Detection (LLD) analysis for each germanium detector system used for gamma spectroscopy. ' These determinations were required annually. A review of the most recent LLD determinations indicated that they had been performed as required and the appropriate LLD's were met by the germanium detector systems.
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Conclusions The laboratory instrument quality control program was effectively implemented.
Instrument verification initiatives and gamma spectroscopy lower limit of detection analysis were performed as required and analytical instruments general!y operated within statistical controllimits.
R7.2 Quality Assurance Proaram implementation a.
Insoection Scooe (84750)
The inspectors reviewed assessments of the chemistry organization, performed by the nuclear oversight group, to evaluate whether the independent assessments of the
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chemistry program effectively identified and resolved problems. Specifically, this included three assessments of chemistry operations and technician performance from
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November 16,1998 through July 2,1999. In addition, an internal assessment
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performed by the chemistry staff for the second quarter of 1999 was reviewed.
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Observations and Findinos The nuclear oversight group assessments addressed specific areas, were thorough and probing, and of sufficient depth to identify deficiencies. Areas reviewed included chemistry responsibilities for selected system operations and system chemistry, adherence to EPRI Guidelines, technician knowledge, chemistry organization structure, and field observations of technician performance. Field observations stressed
. procedure compliance, an area where problems were noted in the past. Two examples of a lack of procedure adherence were identified in the assessments.
Findings were documented in the assessments, and significant issues which involved procedure adherence problems were documented in the Problem Identification Form system. Licensee representatives indicated that the assessment findings were being addressed. The inspectors confirmed, during an observation of a technician sampling primary coolant, that one finding related to radiation worker practices had been corrected. The inspectors observed that another finding, related to communication enhancements (use of the phonetic alphabet), was being addressed during technician refresher training.
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Conclusions Assessments of the chemistry program were of sufficient scope and depth to identify deficiencies and covered areas where corrective actions had been warranted in the past. Findings were adequately documented and corrective actions were in progress or had been completed.
R8-Miscellaneous Radiological Protection and Chemistry issues R8.1 Radioactive Waste Transoortation a.
Inspection Scope (86750)
The inspectors reviewed the September 9,1999, shipment of spent condensate resin from the site to a licensed low-level waste disposal facility. This included a review of shipping documents, observation of radiological surveys of the shipping cask and transport vehicle, and discussions with cognizant health physics staff.
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Observations and Findinos On September 9,1999, the licensee shipped approximately 135 cubic feet of spent condensate resin to a licensed low-level waste disposal site (Shipment No. RMS99-080). The inspectors observed that radiological surveys of the shipping cask and transport vehicle were properly performed in accordance with regulations and station procedures. The survey included direct measurements and smears for removable contamination. Discussions with the technicians revealed that the technicians were
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knowledgeable of shipment survey requirements and appropriately documented the
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survey results.
The inspectors also interviewed the individual responsible for the shipment and reviewed the completed shipping documents prior to the shipment leaving the site. The document review indicated that the proper preshipment burial site notifications had been made, and that the analysis of the spent resin had been performed in accordance with 10 CFR Part 61 and station procedures. In addition, the inspectors noted that the shipping documents contained all of the information required by the Department of Transportation in 49 CFR Part 172. Discussion with the responsible individual revealed that the individual was knowledgeable regarding NRC and DOT shipping regulations, and burial site requirements.
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Conclusions The September 9,1999, shipment of spent resin to a low-level waste disposal site was in compliance with NRC and Department of Transportation regulations. Personnel involved with the shipment were knowledgeable of the procedures and their role in preparing the shipment for transportation.
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- Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on September 10,1999. The licensee acknowledged the findings presented.
The licensee did not identify any information discussed as being proprietary.
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-t PARTIAL LIST OF PERSONS CONTACTED Licensee B. Adams, Regulatory Assurance Manager S. Ann, System Engineer R. Colglazier, NRC Coordinator
' Z. Cox, Administrative Specialist B. Kowba, Engineering Manager R. Lopriore,' Station Manager K. Moser, Regulatory Assurance.
i R. Roton, Assessment Manager T. Schuster, Chemistry Manager D. Thompson, Health Physicist NRQ G. Cobey, Senior Resident inspector B. Kemker, Resident inspector i
i INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure
' IP 84750 Radioactive Waste Treatment, and Effluent and Environmental -
Monitoring IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials LIST _ OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened-None
.Q!QlHtd None Discussed None
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LIST OF ACRONYMS USED
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ARM Area Radiation Monitors EPRI Electric Power Research Institute -
CFR Code of Federal Regulations CRC Curriculum Review Committee CVCS Chemical Volume Control System HEPA High Efficiency Particulate Air 1&C Instrument and Control LLD Lower Limit of Detection NRC Nuclear Regulatory Commission ppb Parts per Billion ppm Parts per Million SG Steam Generator TAC Training Advisory Committee TS Technical Specifications UFSAR Updated Final Safety Analysis Report i
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LIST OF DOCUMENTS REVIEWED Procedures BAP 560-13, Revision 3, Byron Station Chemistry Unknowns Test Program Description
. BCP 230-3, Revision 6, Determination of E-BAR BCP 300-23, Revision 18, Reactor Coolant or Pressurizer Liquid and/or Pressurized Grab Sample.
BCP 520-5, Revision 5, Quality Control for Radiochemistry Instruments BCP 520.7, Revision 1, Preparation and Interpretation of Quality control Charts BIP 2500-142, Revision 3, Calibration of Area Radiation Monitor (AR)
BRP 5820-13, Revision 6, Response to High Radiation Monitor Alarms Audits NOA-06-98-030; Closed Cooling Chemistry and Fundamental Chemistry Technician Knowledge, November 16,1998 NOA-06-99-016; Chemistry Organization and Work Practices, March 19,1999 NOA-06-99-017: System Chemistry Maintenance and EPRI Guidelines, July 2,1999 Byron Station Chemistry, Radwaste, & Environmental Areas, Second Quarter 1999 Miscellaneous Guidelines for Use of Quality Control Charts Instrument Quality Control Charts,1999 Comed Nuclear Station Analytical Chemistry Interlaboratory Program,1999 data Radwaste Shipment RMS99-080 Documentation Control Room HEPA Filter Tests,1998 and 1999 Control Room In-place Charcoal Tests,1998 and 1999 Control Room Laboratory Charcoal Tests,1998 and 1999 Control Room Ventilation Monthly Surveillances,1998 and 1999 Area Radiation Monitor Calibrations,1998 and 1999 Byron Station Chemistry Technician Continuing Training Module #3,1999: The Chemical Volume Control System; and Radiochemistry / Isotopic review Unit 1 Primary and Secondary Chemistry Parameters Unit 2 Primary and Secondary Chemistry Parameters HpGe Calibrations for 1998 1998 A Priori LLD Checks Byron Units 1 & 2 Technical Requirements Manual, Rev.1 Byron Unit 1 Steam Generator Chemistry Excursion Event, December 23,1998 Byron Nuclear Power Plant Recommended Practices for Nuclear Chemistry
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