ML20137C548
| ML20137C548 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/21/1985 |
| From: | Reed C COMMONWEALTH EDISON CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 0890K, 890K, NUDOCS 8511260530 | |
| Download: ML20137C548 (25) | |
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Commonwealth Edison
.C one First Nabonal Plaza. Chicacjo. Ilkno's Q Address Reply to Post Office Box 767 Chicago, lihnois 60690 November 21, 1985 Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Byron Station Units 1 and 2 Proposed Imposition of Civil Penalty IE Inspection Report Nos. 50-454/85-022 and 50-455/85-020 References (a): August 8, 1985 letter from J. A. Hind to Cordell Reed (b): October 2,1935 letter from J. G. Keppler to J. J. O'Connor
Dear Mr. Taylor:
Reference protection programat(a) provided Byron Station thebetween results May of inspections 6 and July of 22,the radiation 1985. As a result of these inspections and further Jiscussions during Enforcement Conferences on June 27 and July 22, 1985, certain activities were found to be in violation of NRC requirements. Reference (b) transmitted a Notice of Violation and Proposed Imposition of Civil Penalty related to the violations identified in reference (a). Attachment A to this letter contains Commonwealth Edison's response to the Notice of Violation enclosed with reference (b). On October 29, 1985, Commonwealth Edison was granted a fourteen day extension on the due date for the response to the Notice of Violation and Proposed Imposition of Civil Penalty. An additional seven day extension was granted on November 15, 1985.
Commonwealth Edison does not believe that the violations described in reference (b) were properly categorized as a Severity Level III problem, collectively or in any other manner. Reference (b) states that the three radiological events at issue indicate a lack of management attention which is cognizable under Supplement I of the NRC Enforcement Policy. A review of paragraph C of Supplement I shows that the only example applicable to these events is example C.2. We believe that these events do not rise to the level of significance contemplated by that example. As we show below, these three events did not result in "a (management) system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions".
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J. M. Taylor November 21, 1985 None of these exposures constituted serious safety events. Because these events involved occupational radiation exposures, a " serious safety event" for the purposes of this example must be an occupational radiation exposure as defined in the Health Physics Supplement (IV) under Severity Level III examples.
The term " serious safety event" is not self-defining but must take its content from the physical nature of the events. In this case, the events were radiation exposures. The only measure of the Commission's assessment of the seriousness of such exposures for enforcement purposes is provided by the Commission's Enforcement Policy. Therefore, under these circumstances, the examples in Severity Level III of Supplement IV provide the only way to determine whether a radiation exposure constitutes a serious safety event for the put soses of enforcement. For these reasons, cross-reference to Severity Le /el III of Supplement IV is not a comparison of significance between activity areas. The examples of occupational exposures in Supplement IV involve either a significant exposure, example 1, exposures in excess of regulatory limits, examples 7 and 9, or a substantial potential for exposure in excess of regulatory limits, example 4. None of the Byron events rise to those levels of safety significance. No finding was made of a substantial potential for exceeding regulatory limits.
The " system" under consideration here is the Byron radiation protection program which includes administrative and managerial controls.
At no time was this system unable to perform its intended function. At worst, elements of that system failed under very limited circumstances.
However, many elements of the Byron radiation protection program did function to prevent or mitigate a serious safety event from occurring as a result of these incidents. Each event is discussed individually below.
April 17, 1985 Event With respect to the April 17, 1985 event, the following elements of the radiation protection program were present and effective in preventing a serious safety event.
This event involved a containment entry during plant operation by a shift foreman, equipment attendant, and radiation chemistry technician (RCT).
The purpose of the containment entry was to locate and quantify the source of some reactor coolant system leakage. Pre-planning of the containment entry took place. Areas of known low dose rate were to be inspected first.
If the leakage could not be found, then areas of a higher radiation field would be inspected. This pre-planning helped to minimize radiation exposure.
I The RCT reviewed previous surveys of the radiation fields in the containment. Because of this, the RCT knew of areas in the containment where local high dose rates existed. This also helped to minimize rcdiation l exposures.
J. M. Taylor November 21, 1985 The personnel entered the containment with proper dosimetry that was functional and conservatively set to alarm below the administrative limit. The workers checked the indication from their dosimetry during the job and therefore were cognizant of their dose accumulating.
The most important element of the radiation protection program that was properly used during this event was the exposure control system. Each individual entered the containment under an approved radiation work permit with a conservatively selected administrative exposure limit. The basis for the selection of the administrative limit was to assure that exposures would be minimized, both individually and collectively, and that the potential for approaching regulatory exposure limits did not exist.
The workers' awareness of their exposure accumulating in combination with the approved administrative exposure limit that was set intentionally very low in comparison to 10 CFR Part 20 limits positively assured that regulatory limits would not be exceeded and that a suostantial potential for exceeding the regulatory limits did not exist.
May 1,1985 Event In regard to the May 1,1985 event, the following elements of the radiation protection program were present and effective in preventing a serious safety event.
This event involved a containment entry during plant operation by two electricians whose job was to reset a thermal overload device on an incore detector drive motor. Pre-planning for this job took place to the extent that the Radiation Chemistry Department was involved with the containment entry. Their involvement assured the exposure control system was used in that a radiation work permit was issued to cover this job, exposure limits were assigned, and that proper dosimetry was issued to the personnel involved in the job. In addition, RCT's were assigned to cover this job, had performed a survey of the work area, and were in the process of retrieving the workers when the job was completed.
The personnel entered the containment with proper dosimetry that was functional and conservatively set to alarm below the administrative limit. Although the alarming state of the dosimetry was heard by the workers and temporarily ignored, this was an indication to them that an abnormal condition existed.
As in the April 17, 1985 event, the exposure control system of the radiation protection program was properly used. Each worker entered the containment under an approved radiation work permit with a conservatively selected aoninistrative exposure limit that was well below regulatory limits.
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J. M. Taylor November 21, 1985 In this event, regulatory limits were not exceeded and a l substantial potential for exceeding these limits was not evident. This was l a result of the conservatively set administrative exposure limit for the l job, the functioning dosimetry which the workers heard alarming, the short l duration of the job itself, and the worker retrieval actions of the RCTs.
July 1, 1985 Event Concerning the July 1, 1985 personnel contamination event, the
! following elements of the radiation protection program functioned to prevent a serious safety event and mitigate the effects of a personnel contamination.
This event involved a maintenance crew which was removing contami-nated insulation from a leaking valve. The area in the plant where the
, personnel contamination occurred was properly posted as being contaminated.
l Therefore, the source of the contamination was identified and not unknown.
This minimized the potential for other personnel to become contaminated.
Once contaminated, the affected personnel did follow policy for exiting a radiation area by frisking themselves. This activity triggered a oecontamination effort and prevented personnel from leaving the station in a contaminated condition.
When a RCT became involved in the decontamination effort, proper documentation was generated to ensure follow-up actions would take place to confirm that the decontamination was effective and complete. A Radiation Occurrence Report was generated immediately and this prompted management involvement in the resolution of the incident.
SUMMARY
It has been shown above that these three events did not result in a
, system designed to prevent or mitigate a serious safety event not being able to perform its intended function under certain conditions. None of the exposures which led to the proposed civil penalty, whether taken individually or cumulatively, constituted " serious safety events" as that term is used for the purposes of a Severity Level III violation. None of the exposures were significant, none of them exceeded regulatory limits and none of them presented a substantial potential for exposure in excess of regulatory limits.
The managerial and administrative systems of the radiation protection program provide multiple layers of control and are essentially sound. The incidents primarily resulted from individual failures to follow certain elements of established procedures. However, during the period when f these incidents occurred, the radiation protection program performed its function of protecting many other workers from overexposures and contaminations. Therefore, these incidents do not support a finding that the system was unable to perform its intended function.
J. M. Taylor Noventer 21, 1985 The above analyses showing that a Severity Level III penalty was unwarranted here is further supported by experience with incidents at plants in other Regions. Like the incidents here, radiation exposures at Peach Bottom (EA-85-42), Turkey Point (EA-83-138) and H.B. Robinson (EA-84-13) involved failures to survey or to survey adequately, failure to obey warnings and failure to follow procedures such as obtaining a radiation work permit.
However, unlike the incidents here, the violations at those other plants were found by the NRC to have created situations which could have resulted in exposures exceeding regulatory limits. In accordance with those findings, each of those other plants was penalized at Severity Level III under Supplement IV.
Here the NRC has made no such finding. Indeed, for the reasons ciscussed above, Commonwealth Edison does not believe such a finding can be made. The lack of a " serious safety" finding here clearly distinguishes the Byron incidents from exposure events at other plants which were penalized at Severity Level III. Therefore, if the Commission intends to apply its Enforcement Policy uniformly across the Regions, the events at Byron should not be maintained at Severity Level III.
MITIGATION Notwithstanding our position that these violations were wrongfully categorized as a Severity Level III problem, even if they are categorized Severity Level III, we believe an adequate basis exists for mitigation of the proposed civil penalty. The five factors contained in Section V(B) of 10 CFR Part 2, Appendix C are addressed below.
Prompt Identification and Reporting When a licensee promptly identifies and reports a violation to the NRC, the base civil penalty may be reduced by 50%. Personnel from the Byron Station Radiation Chemistry Department were involved with each of the three l events either as they occurred or within minutes thereafter. Moreover, l
immediately after the events Radiation Occurrence Reports were generated.
l Since Byron Station personnel identified the events at the first available opportunity for discovery, Commonwealth Edison should be given full credit for promptly identifying the events. None of these events were required to be reported to the NRC. Although the April 17, 1985 event was not reported, the May 1,1985 anc July 1,1985 events were voluntarily and completely reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the occurrences. As described in Attachment A, the corrective actions in response to the May 1, 1985 anc July 1, 1985 events were immediate with respect to when the events occurred.
These corrective actions also addressed the April 17, 1985 event. For all these reasons, the penalties for the events of May 1,1985 and July 1,1985 i
should be reduced by the full 50%.
J. M. Taylor November 21, 1985 Corrective Actions Unusually prompt and extensive corrective actions support the reduction of a civil penalty by as much as 50%. As described in Attachment A, our corrective actions in response to these incidents were very comprehensive. These actions were initiated and pursued to conclusion under our own initiative and went far beyond the narrow confines of the specific violations. The programmatic corrective actions taken by the station and corporate office support this. The corrective actions for the events of May 1, and July 1, 1985 were taken as promptly as possible consistent with the nature of those actions and full credit should be given for this timeli-ness. These same corrective actions addressed the April 17, 1985 event.
For all these reasons, the pe.nalties for the events of May 1, and July 1, 1985 should be reduced by the full 50%.
Past Performance A civil penalty may be reduced by up to 100% of the base amount for good prior performance in the general area of concern. In the seven months since Byron's operating license was issued, these are the first violations involving the general area of radiation protection. Therefore, Byron's prior performance in this area has been good. Accordingly, the literal terms of the Enforcement Policy support a full 100% reduction of the penalty. N3 thing in the Enforcement Policy indicates a minimum period of operatlon for determining prior good performance. However, we recognize that the period of good performance has been relatively short and, therefore, that an argument can be made for a reduction by less than the full amount.
Prior Notice We do not consider IE Information Notice Nos. 84-19 and 82-51 to be prior notice of similar events. The events described in those Notices involve entry into the reactor cavity while the incore detector thimbles were withdrawn. Byron Station had taken additional action to prevent unauthorized entry into the reactor cavity. Physical access controls to the reactor cavity were upgraded as well as specific procedural controls. With ,
respect to the April 17 and May 1 events at Byron, these administrative overexposures did not result from an entry into the reactor cavity. To the extent that these Notices inform licensees of the hazards generally existing from potential high radiation sources inside containments, we believe the Byron radiation protection control syster,had already taken proper actions.
Multiple Occurrences A base civil penalty may be increased where multiple examples of a particular violation are identified during an inspection period. In this case, only one particular violation occured more than once. In two of the three events (April 17 and May 1, 1985) workers in controlled areas did not leave as quickly as possible when their accumulated dose equivalent equaled the administrative exposures authorized for the jobs. While we do not
J. M. Taylor November 21, 1985 minimize the seriousness of these two incidents, it should be noted that during the May 1, 1985 event the workers' delay was limited to no more than three minutes in a field of about 5 rads per hour. Moreover, because these two administrative overexposure incidents occurred quite close in time there was an inadequate opportunity to ensure that the lessons learned from the first incident were disseminated before the second incident occurred. The July 1, 1985 event involved a personnel contamination and the particular violations associated with this incident were not a repetition of the particular violations related to the administrative overexposures. Since the root cause of the July 1,1985 event was an individual's negligence in following radiation protection procedures, we do not believe the corrective actions taken in response to the May 1, 1985 administrative overexposure event could have been reasonably expected to prevent the July 1,1985 event. Under these circumstances, we believe that no increase for multiple occurrences is warranted.
Based on the foregoing discussion of the five factors in Section V(B) of 10 CFR Part 2, Appendix C, Comraonwealth Edison believes there is adequate basis to fully mitigate the proposed civil penalty.
After carefully considering the circumstances of these events, Commonwealth Edison believes these incidents were wrongfully classified as a Severity Level III problem. At a minimum, the proposed civil penalty should be fully mitigated.
Very truly yours, foi. Cordell Reed Vice President 1m cc: J. G. Keppler - Region III SUBSCRIBE 0 AND SWORN to befog me thJs12 day of 7/ d1ynUua , 1985 U /100 Notary' pud';ic ()
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ATTACHMENT A Although we believe the Byron radiation protection program func-tioned properly to prevent a serious safety event from occurring as a result of these incidents, corporate and station management have recognized areas within the program which needed strengthening. Corrective action has been aggressive and multi-faceted, addressing aspects of the radiation protection program in general as well as the specific incidents which resulted in the violations. The major thrust of the actions taken was to improve employee personal awareness of their responsibilities in the program and the ramifications, botn to the station and to their personal health and safety, if they fail to adhere to radiation protection procedures and practices.
Particular emphasis has been placed on the key role the maintenance and operating supervisors play in the overall effectiveness of the radiation protection program and the involvement and coordination of these departments with the Radiation Chemistry Department.
This response will first enumerate the steps taken by both the Station and Corporate Office to enhance the radiation protection program at Byron and then address corrective actions for each specific violation.
Finally, the results achieved will be addressed collectively.
Programmatic Corrective Actions Byron Station Actions
- 1) The Assistant Superintendent for Administrative and Support Services conducted radiation protection awareness sessions with station personnel including the security force and selected contractor personnel. The main objectives of these sessions were:
a) To re-empnasize the ind:.vidual responsibilities each employee has in the radiation protection program. Throughout the discussions, procedural adherence, detailed prior planning, and common sense were highlighted and continually re-inforced.
b) To re-stress specific radiation protection practices, including use of radiation work permits (RWP's), use of personal dosimetry, proper whole body frisking methods, and proper completion of radiation time cards, c) To demonstrate proper donning and removal of protective clothing and use of step off pads, d) To review dose-time relationships and basic formulas to use for computing stay times.
e) To review Radiation Occurrence Reports (ROR's) and Personnel Contamination Reports with emphasis on lessons learned.
f) To respond to questions regarding the radiation protection program.
- 2) The Radiation Chemistry Management conducted two sets of meetings with station departments to discuss the details of the May 1,1985 and the July 1, 1985 radiation incidents. In these meetings a station health physicist explained the root causes of both events and stressed the necessity of each worker to be thoroughly familiar with their radiation work permit and to always seek assistance of the Radiation Chemistry Department whenever in doubt of proper radiation protection practices.
The first set of meetings was complete by June 26, 1985 and the second set was complete by July 19, 1985.
- 3) Following the July 1, 1985 personnel contamination event, the Station Superintendent conducted an immediate expectation session with the Radiation Chemistry and Maintenance Departments on July 3,1985. The importance of following radiation protection program requirements was stressed in this session.
- 4) Radiation Occurrence Reports and Personnel Contamination Reports are now being discussed daily in the Plan of the Day meeting. This will ensure early and widespread dissemination of the event and immediate f ollow E through to identify and implement corrective and preventive actions.
- 5) An Event Review Board has been implemented to review station significant events to include ROR's and Personnel Contamination Reports. This board consists of senior station management and is convened periodically.
This board ensures that prompt corrective action has been taken or is in progress and considers the ramifications on other plant activities.
- 6) To improve communications and cooperation between the Maintenance, Operating, and Radiation Chemistry Departments, health physics personnel are routinely attending maintenance planning meetings to provide radiation protection input in the pre-planning of work activities.
- 7) The scope of training received by Radiation Chemistry Technicians has been enhanced to include familiarization with plant systems of radiological significance.
- 8) A full time Radiation Work Permit Coordinator has been assigned in the Radiation Chemistry Department. His responsibilities include reviewing RAP's and ensuring proper procedural adherence.
Corporate Actions
- 1) A letter was issued on July 16, 1985 from D.P. Galle, Assistant Vice President and General Manager, Nuclear Stations Division, to the Station Managers addressing Company policy with respect to adherence to radiation protection requirements. This letter requires each station to conduct meetings with on-site Company and contractor personnel to address the Company's radiation protection policy and stress the Company's commitment to this policy. Formal training of approximately 1250 personnel at Byron Station is essentially complete (refer to Byron Station Programmatic Corrective Action 1 above).
- 2) Nuclear Services Health Physics conducted an intensive review of Byron Station's radiation protection program during the period July 15 through 19, 1985. The assessment team included health physicists from tne Nuclear Services Staff as well as individuals from other operating nuclear stations. Representative categories where observations and recommendations were identified included the following:
a) Departmental interface.
b) Radiation Protection Management Staffing and Equipment.
c) Worker performance.
d) Radiation Occurrence Reports / Personnel Contamination Reports. 5 e) ALARA.
f) Radiation Work Permit.
The report issued by the team included 40 recommendations for improving the radiation protection program. A Radiation Protection Task Force was implemented in early September to expedite corrective actions to respond to the Corporate Overview and INPO evaluations. The Task Force meets weekly and has completed 39 of the 40 Corporate Overview concerns and 2 of the 7 INPO findings.
- 3) At the Station Managers meeting on July 17, 1985, the personnel contamination and administrative overexposure events at Byron Station were reviewed for possible application at all stations.
- 4) At the Radiation Chenistry Supervisors meeting on June 6,1985, the administrative overexposure event at Byron Station was reviewed. The discussion includeo event description, corrective actions taken at the time of the occurrence, and applicability to other stations. Each Supervisor was instructed to review this event with their respective s ta ffs.
- 5) Nuclear Services Health Physics (NSHP) has issued verbal guidance to the Radiation Chemistry Supervisors regarding the criterion for immediate NSHP notification in the event of a radiological occurrence.
- 6) Nuclear Services Health Physics has issued procedure, SRP 1100-1, Rev.
1; cated September 1985, which requires stations to submit Radiation Occurrence Reports to them for their evaluation and determination of the appropriate level of corporate response.
SPECIFIC CORRECTIVE ACTIONS: ;
Alleged Violation Al A. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
- 1. Contrary to the above, operating procedure BOP-IC-03, Incore Moveable Detectors - Partial Core Flux Mapping, was found to be inadequate in that the procedure did not restrict containment entry while the incore detectors were withdrawn. This inadequacy resulted in two individuals entering containment on May 1,1985 to work on incore detectors that were in a withdrawn or unshielded position.
Admission of the Alleged Violation The Station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and admit that procedure BOP-IC-03 was not prepared consistent with the requirements of 10 CFR 19.12, as incorporated by reference in 10 CFR 20.206, in that the procedure was not adequately written to minimize exposures.
Reason for the Violation In this particular case the operating procedure review failed to ensure the appropriate consistency of radiation protection precautions that were integrated into the BOP-IC procedures.
Corrective Actions Taken t
- 1) Operating procedures listed below were revised, as necessary to provide for consistent terminology and definition of terms and consistent precautionary measures for safe location of incore detectors during personnel entry into the containment. The procedure revisions were effective May 14, 1985.
BOP IC-01 "Incore Movable Detector Flux Mapping" BOP IC-03 "Incore Movable Detectors Partial Core Flux Mapping" BOP IC-04 "Incore Movable Detectors Quarter Core Flux Mapping"
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- 2) " Containment Entry Checklist", BAP 1450-T2, was reviewed and revised to include the following:
- The Shift Engineer or Shift Foreman to verify the incore detector locations.
- The Shift Engineer or Shift Foreman to verify the out of service on the incore detector system.
- Listing of the specific position of each incore detector.
- Personnel protection cards on the incore detector system for individuals entering containment.
- The Nuclear Station Operator to verify the location of the incore detectors.
- The Nuclear Station Operator to attach placards to the turbine / rod control panels to assure the reactor power level is not changed.
- Rad-Chem personnel to review the position of the incore detectors for radiation protection concerns when preparing radiation work permits.
This procedure revision was in effect May 16, 1985. ,
Corrective Action to Prevent Further Violations The actions taken 'above are sufficient to pretent future violations.
Date When Full Complishce Was Achieved >
Full compliance was hchieved on May 16, 1985.
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Alleged Violation A2 A. lechnical Specification 6.11 requires that procedures for personnel raolation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and aohered to for all operations involving personnel radiation exposure.
- 2. BRP 1140-1, Radiation Work Permit (RWP), Section E.1 requires that emergency entries be made under a Type II RWP with a Rad / Chem Technician (RCT) in continual attendance at the job-site.
Contrary to the above, on May 1, 1985, two electrical maintenance workers who signed the RWP made an emergency entry into containment under a Type II RAP (50147) and worked at a job-site in a high radiation area without continual RCT attendance.
Admission of the Alleged Violation The Station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and admit that the electricians involved with the May 1,1985 containment entry did not adhere to Section E.1 of procedure BRP 1140-1.
Reason for the Violation The individuals involved failed to communicate and preplan the job adequately in accordance with proper radiation protection practices.
Corrective Actions Taken The Station Superintendent conducted a discipline meeting on June 25, 1985, with all workers involved in the incident. Topics addressed in this meeting included: personnel performance errors, seriousness of the violation, corrective actions taken, and lessons learned. Appropriate disciplinary action was taken and letters were placed in personnel files on June 26, 1985.
Corrective Actions to Prevent Further Violations Radiation Protection Supervision held meetings with all Station f . Departments to discuss the details of the May 1,1985 incident, to I
stress the requirement that all workers read and understand the RWP before signing and to emphasize the need for pre-job planning and work group communications. These meetings were completed by June 26, 1985.
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The Station Superintendent immediately issued a letter on.May 13,1985I stating that an emergency RWP will only be used in cases of personnel i injury, life saving actions, fire fighting actions, preventing equipment damage, preventing a unit trip, or. preventing a significant spread of contamination. The situation must have an RCT in continual attendance and a pre-job survey if-the dose rate exceeds l rem / hour.- The Raciation Work PeIait (RWP) procedure, BRP 1140-1, was revised May 29, 1985, to reflect this directive.
Date >When Full Compliance Was' Achieved June 26, 1985 0890K
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Alleged Violation A3 A. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
- 3. BRP 1140-1, Section C.3 requires that each person assigned to do work which requires an RWP read and understand the RWP and comply with the requirements of the RWP in all respects.
RWP 50106, written for the April 17, 1985 containment entry, required continual Rad / Chem Technician (RCT) surveillance. RWP 50106 implemented Technical Specification 6.12.2 which requires that an approved RWP for personnel entry into radiation fields greater than 1000 mR/hr specify general area dose rates and maximum stay times for individuals. In lieu of the stay time specification on the RWP, continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.
Contrary to the above, on April 17, 1985 two individuals entered containmentunderRWP50106withoutcontlnualRCTstrveillance being provided during the entry as required by the RWP.
Admission of Ule Alleged-Violation The station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and admit that the workers involved with the April 7,1985 containment entry did not adhere to Section C.3 of procedure BRP 1140-1.
Reason-for the Violation The violation was caused by individuals' lack of adequate respect of radiological controls and not strictly complying with the Radiation Work Permit.
Corrective Actions Taken The Assistant Superintendent of Administrative and Support Services and the Assistant Superintendent of Operations conducted meetings with the Shift Foreman, Rad /Cnem Tech, and Equipment Attendant to discuss the significance of the event and the potential problems that may have ensued. This item was completed by July 18, 1985.
4-Corrective-Action to Prevent Further Violations
-The Radiation Protection Awareness meetings and the Radiation Protection Supervision meetings, both described in the Byron Station programmatic
' corrective actions, are sufficient to prevent future violations.
Date When Full Compliance Was Achieved October 15, 1985 0890K
m Alleged Violation A4 A. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
- 4. BRP 1000-A1, Work in Controlled Areas - Personnel Conduct when Leaving a Controlled Area, Section 1.d., requires that workers leave the controlled area as quickly as possible when the current accumulated dose equivalent is equal to the exposure authorized for the job.
Contrary to the above, on May 1, 1985, two workers remained in a high radiation area for an estimated 2 to 3 minutes over the approximately 1 minute needed to reach their RWP authorized exposure of 100 mrem. Individual doses of 280 mrem and 340 mrem were received by the workers. Also, on April 17, 1985, three workers remained in containment after reaching their RWP authorized dose limit of 200 mrem. Individual doses of 254 mrem, 260 mrem, and 295 mrem were received by the workers.
Admission of the Alleged Violation The station has carefully reviewed the Inspector's account of the events discussed in reference (a). We find it to be act. urate and admit that the workers involved with the May 1,1985 and April 17, 1985 incidents did not adhere to procedure BRP 1000-A1.
Reason for the Violation The individuals involved in both incidents were negligent in following proper radiation protection practices.
Corrective Actions Taken Tne Station Superintendent conducted a discipline meeting on June 25, 1985, with all workers involved in the May 1, 1985 incident. Topics addressed in this meeting included: personnel performance errors, seriousness of the violation, corrective actions taken, and lessons learned. Appropriate disciplinary action was taken and letters were placed in personnel files on June 26, 1985.
r The Assistant Superintendent of Administrative and Support Services and the Assistant Superintendent of Operations conducted meetings with the Shift Foreman, Rad / Chem. Tech, and Equipment Attendant involved in the April:17, 1985 incident to discuss the significance of the event and the potential problems that may have ensuud. This item was completed by July 18, 1985.
Corrective Action to Prevent Further Violations The actions taken to prevent future violations are addressed in violation A3.
Date When Full Compliance Was Achieved
' October 15, 1985
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Alleged Violation A5 A. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and aohered to for all operations involving personnel radiation exposure.
- 5. BRP 1000-A1, Work In Controlled Areas - Personnel Conduct in a Controlled Area, requires that the following rules be observed to minimize exposure and the spread of contamination: (a) Assume all surfaces and objects are contaminated unless otherwise indicated; (b) Perform all work in such a manner that the possibility of spreading contamination is minimized; (c) Consult the Rad / Chem Department before uncovering contaminated equipment or disassembling potentially contaminated material; and (d) Observe precautions noted on all radiological signs and labels. In addition, this procedure states the job supervisor and/or individual shall contact the Rad / Chem Group for protective clothing requirements, dose rates, monitoring requirements for the job, and special precautions due to unusual radiological conditions noted or suspected prior to entering a controlled area.
BRP 1470-1, Personnel Decontamination, requires that decontamination methods be performed only under the direction of CECO trained individuals; only Rad / Chem Department personnel are so trained.
Contrary to the above, mechanical maintenance representatives did not: (a) contact the Rad / Chem Department prior to removing contaminated insulation from a CVCS valve on July 1, 1985 to determine the protective clothing requirements, dose rates, and special radiological conditions before entering the controlled area or during work activities when it became apparent that the valve insulation was contaminated, (b) observe precautions on labels identifying contaminated components connected to the valve, (c) contact Rad / Chem personnel as indicated by a posted sign when they entered the work area and when they alarmed the personnel frisker, and (d) contact Rad / Chem personnel to initiate personnel decontamination measures.
Admission of the Alleged Violation The station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and aamit that a mechanical maintenance crew did not adhere to procedures BRP 1000-Al and BRP .1470-1 on July 1, 1985.
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Reason for the Violation L .The Mechanical Maintenance Foreman involved was negligent in following radiation protection procedures and proper radiation protection practices.
Corrective Actions Taken A disciplinary meeting was held with the maintenance foreman on July 15, 1985. The foreman was reassigned to other duties which involved no supervisory responsibilities. In addition, on July 4,1985, a posting was placed on the door to the decontamination room instructing personnel to contact Rad / Chem prior to performing personnel decontamination.
The Station Superintendent met with the Rad / Chem and Maintenance departa,ents on July 3, 1985 to emphasize workers' responsibilities to comply with Station Radiation Control Standards and procedures.
Corrective Action to Prevent Further-Violations The corrective actions discussed above are sufficient to prevent future violations. Radiation protection practices including personnel decontamination, postings, frisking, and Radiation Work Permit usage were re-emphasized'in the Radiation Protection Awareness meetings.
Personal awareness and individual accountability to the radiation protection program were highlighted to address personnel error nonconformances.
Date when Full Compliance Was Achieved By July 15, 1985, the decontamination room posting was placed on the door and the meeting between Rad / Chem Supervision and Maintenance Department was completed.
Radiation Protection Awareness meetings for maintenance personnel were completed October 15, 1985.
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Alleged Violation A6 A. Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements
- of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure. .
- 6. BRP 1460-3, Operation of the IRT Portal Monitors, Section E.3.
requires that security personnel stop any personnel from leaving the plant when said person (s) triggers the alarm of either portal monitor in the guarchouse. Security shall then notify the Radiation / Chemistry Department for further action.
Contrary to the above, on June 6,1985, security personnel did not.
stop an individual who alarmed the portal monitor from leaving the plant, nor was the Rad / Chem Department notified.
Admission of the Alleged Violation The station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and admit that security personnel did not adhere to procedure BRP 1460-3 on June 6, 1985.
' Reason for the Violation Confusion existed among station workers as to proper portal exit procedures and security guards were not agressively executing their responsibilities.
Corrective Actions Taken Training sessions were conducted with all members of the security force to reemphasize their responsibilities with respect to the radiation portal monitors. In addition, new signs were posted at the portal monitor locations providing instructions as to proper exit procedures.
The training was completed by July 10, 1985 and the new signs were installed by July 20, 1985. i Corrective Action to Prevent Further Violations i
,' The actions taken above are sufficient to prevent future violations.
. .This topic was discussed with personnel at the Radiation Protection l Awareness sessions.
l Date when Full Compliance Was Achieved l October 15, 1985
Alleged Violation B B. 10 CFR 19.12 requires instructions in radiological conditions and
-precautions be given to all individuals working in or frequenting a restricted area. These instructions must be commensurate with potential radiological health conditions in the restricted area.
Contrary to the above, on May 1,1985, two workers were not specifically instructed regarding the use of integrating dosimetry devices they wore while working in a high radiation area. Also, the workers were not informed of current radiation levels in the work area before entry, nor -
were they informed that continuous RCT attendance at the job-site was required for this entry.
Admission of the Alleged Violation The station has carefully reviewed the Inspector's account of the event discussed in reference (a). We find it to be accurate and admit that the workers involved with the May 1,1985 event were not given adequate instructions regarding radiological health protection in preparation for their containment entry.
Reason for the Violation The Health Physics Foreman was negligent in not properly informing the Electrical Maintenance workers of radiological conditions, precautions, and use of dosimetry for the job. In addition, formal annual training for radiation workers did not include instructions on use of the digidose instrument.
Corrective Actions Taken Corrective actions on " radiation levels" and " continual RCT attendance" were immediately addressed by issuance of a letter by the Station Superintendent on May 13, 1985, clarifying that an emergency RWP will only be used in cases of personnel injury, life saving actions, fire fighting actions, preventing equipment damage, preventing a unit trip, or preventing a significant spread of contamination. These situations must have an RCT in continual attendance and a pre-job survey if the dose rate exceeds 1 rem / hour. The Radiation Work Permit (RAP) procedure, BRP 1140-1, was revised May 29, 1985, to reflect this directive.
- Radiation Protection Supervision held meetings with all Station Departments to discuss the details of the May 1,1985 incident, to stress the requirement that all workers read and understand the RWP before signing and to emphasize the need for pre-job planning and work-group communications. These meetings were completed by June 26, 1985.
Corrective actions on digidoses were as follows:
- 1) Digidose use was discussed in Radiation Protection Supervision meetings discussed above.
'2) Upon issuance of digital dosimeters, instructions are provided to personnel on its use and alarm setpoint.
Corrective Action to Prevent Further Violations Tne instruction of the use of digidoses was added to the Nuclear General Employee Training Program. Training was amended June 13, 1985. This change to the NGET program in addition to the actions taken above are sufficient to prevent future violations.
] Date Ahen Full Compliance Was Achieved June 26, 1985 OB90K
0 Alleged Violation C C. 10 CFR 20.201(b) requires that the licensee make such surveys as may be necessary to comply with Part 20. As defined in 10 CFR 20.201(a),
" survey" means an evaluation of the radiation hazard incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, the licensee failed to make such surveys as were necessary to show compliance with 10 CFR 20.101(a) and 10 CFR 20.103(a)(1) in that no evaluation was conducted of the radiological hazards associated with the July 1, 1985 CVCS valve inspecticn work either before the maintenance crew's entry into the controlled area or during work activities when it became apparent that the valve insulation was contaminated.
Admission of the A11eoed Violation The station has carefully reviewed the Inspector's account of the event discussed in reference (a) and finds it to be accurate. Although the affected area was posted contaminated, we admit that there were no specific measurements made of the level of radiation or of the concentration of radiactive material present at the valve.
Reason for the Violation The Mechanical Maintenance Foreman involved was negligent in following radiation protection procedures.
Corrective Actions Taken A disciplinary meeting was held with the maintenance foreman on July 15, 1985. The foreman was reassigned to other duties which involved no supervisory responsibilities.
In addition, the Station Superintendent met with the Rad / Chem and Maintenance departments on July 1, 1985 to emphasize workers' responsibilities to comply with Station Radiation Control Standards and procedures.
Corrective Action to Prevent Further Violations The Radiation Protection Awareness meetings and the additional meetings conducted by Radiation Protection Supervision are sufficient to prevent future violations. Station procedures in effect prior to this incident provided for proper surveys in accordance with 10 CFR Part 20. Surveys were not taken, in this instance, because of personal negligence.
Date When Full Compliance Was Achieved October 15, 1985 l
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Results Achieved As a result of the comprehensive corrective action taken, the Station affirms that the Radiation Protection Program at Byron has been improved.
This improvement has resulted from a combination of programmatic changes, procedural changes, enhanced communications between workers and departments, and most important, communicating to all workers their personal responsibilities in the Radiation Protection program. Since the time frame of the cited incidents the following has been achieved.
There have been no overexposure incidents.
Radiation Occurrence Reports have significantly declined.
Personnel Contamination Reports have significantly declined.
An increased awareness on the part of all station personnel of their responsibilities in the Radiation Protection Program now exists. This was demonstrated by the numerous questions that were raised in the Radiation Protection Awareness sessions.
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