ML20137Q533

Insp Repts 50-454/97-03 & 50-455/97-03 on 970303-07. Violations Noted.Major Areas Inspected:Chemistry & Radiation Protection Program

ML20137Q533
Person / Time
Site:	Byron
Issue date:	04/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137Q508	List: ML20137Q502 ML20137Q525 ML20137Q533
References
50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9704110017
Download: ML20137Q533 (16)

See also: IR 05000454/1997003

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION lli

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, Docket Nos: 50-454; 50-455 l

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Licenses No: NPF-37; PF-66

Reports No: 50-454/97003(DRS); 50-455/97003(DRS)

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Licensee: Commonwealth Edison Company (Comed)

Facility: Byron Generating Station, Units 1 & 2

Location: 4450 North German Church Road

i Byron, IL 61010  ;

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Dates: March 3-7,1997

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Inspectors: S. Orth, Radiation Specialist

D. Hart, Radiation Specialist  ;

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Approved by: T. Kozak, Chief, Plant Support Branch 2

Division of Reactor Safety

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9704110017 970404

PDR ADOCK 05000454

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EXECUTIVE SUMMARY

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j Byron Generating Station, Units 1 & 2

NRC Inspection Reports 50-454/97003; 50-455/97003

!- This inspection included an announced review of the chemistry and radiation protection

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programs. One violation with three examples was identified concerning the failure to

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establish and implement procedures. One additional violatian was identified concerning

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the failure to provide training on the post accident sampling system (PASS) at the required

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Plant Suncort

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The water chemistry of primary and secondary systems was well maintained and

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monitored. The licensee took appropriate actions to mitigate the effects of

! circulating water inleakage. (Section R1.1)

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The laboratory and in-line instrument quality control program was well implemented

i and ensured the accuracy of chemistry analyses. Interlsboratory program results -

were generally very good; however, discrepancies in 1995 results were not

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effectively resolved. (Section R1.2)

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The PASS maintenance program was effective in ensuring system operability. A

Non-Cited Violation was identified concerning the lack of instructions for performing

PASS surveillances. (Section R1.3)

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Access to safety related equipment remained relatively unencumbered by

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radiological impediments. An example of a violation was identified concerning the

i failure to post contaminated areas in accordance with procedures. A Non-Cited

. Violation was identified concerning the fai ure to post a high radiation area.

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Examples of violations were identified concerning the failure to adequately

implement chemistry procedures and the failure to establish a procedure covering

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chemistry procedure adherence. Although contamination control practices were

generally good, chemistry technicians did not always adhere to routine sampling

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and analyses procedures, potentially effecting analytical accuracy. (Section R4.1)

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One violation was identified concerning the failure to provide PASS training at the

frequency specified by procedures. (Section R5.1)

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Improvements were observed in the chemistry department self assessment i

{ program. (Section R7) i

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j Renort Details

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IV. Mant Suncort

R1 Rodological Protection and Chhi (RP&C) Controls

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R1,1 Plant Water Chemistry Control-

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a. Inanection Scone (84750)  !

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j The inspectors reviewed the licensee's management of primary and secondary  ;

, water chemistry including the program to mitigate impurities in the systems.  !

- Included was a review of the licensee's trending and analysis of chemistry 4

j parameters for the period of January 1996 through January 1997 and a review of i

the following procedures: I

, BAP 560-1, " Primary Chemistry Program Descririt!r,il." rwvisica 9, dated

i November 13,1996;and

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BAP 560-2, " Secondary Chemistry Monitoring Program," Revision 8, dated

September 26,1996.

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b. Observations and Findinas

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, The licensee's procedures, BAP 560-1 and BAP 560-2, were consistent with the .

industry guidelines for minimizing the concentration of corrosive agents and I

( radiation source term buildup. The licensee continued to use all-volatile treatments

! (AVT) chemistry in the secondary system to reduce oxygen concentrations and iron

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transport and to control pH, via addition of hydrazine and methoxypropyl amine.

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The licensee effectively maintained control of primary and secondary water

! chemistry in both units. The concentration of chloride in the primary systems was

, maintained between 3-5 parts per billion (ppb). During routine operations, steam

generator (SG) sodium and chloride concentrations were 0.3 - 1.0 ppb. The

concentration of foodwater iron was often above the licensee's goal of 1.5 ppb, but

I was maintained below the action level 1 concentration of 5 ppb. The licensee

experienced circulating water inleakage in both units which resulted in significant

, increases of secondary water impurities. During March of 1996, the Unit 2 SG

chloride concentration increased above the 20 ppb action level specified in

procedure BAP 560-2. It appeared that the licensee took appropriate actions and

reduced the levels in a timely manner, ensuring minimal corrosion effects.

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i The licensee's radiochemistry data did not indicate any fuel integrity problems.

There were no increases in the reactor coolant noble gas or radioiodine activity nor

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was there a change in the radioiodine ratios. Additionally, the licensee had not

observed any gross indications of a freilure in fuel integrity.

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k c. Conclusions

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The primary and secondary systems water chemistry was well maintained and

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4 monitored. The licensee took appropriate actions to mitigate the effects of i

circulating water inleakage.  !

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l R1.2 rwuty Control of Laboratory and in-line Chemistry instruments

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s. Inanection Scone (84750)

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The inspectors reviewed the licensee's quality control (OC) program for both '

laboratory and in-line instruments. The inspectors reviewed the licensee's

implementation of procedure BAP 560-12, " Byron Station Chemistry Quality j

Control Program," Revision 2, dated January 1,1994. The inspectors also <

reviewed the licensee's maintenance of instrument control charts and performance I

of instrument calibrations. ,

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b. Obmarvations and Findinas

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The inspectors reviewed the preparation, labeling, and storage of reagents and

calibration standards. The inspectors did not identify any chemicals which were '

improperly labeled or which had been used beyond their expiration date. Laboratory

chemicals were appropriately stored (i.e. incompatible chemicals were not stored in

common locations).

The inspectors observed that performance tests for the licensee's laboratory and in-

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line instruments were appropriately performed. The licensee's laboratory control

charts were well maintained and indicated proper instrument response, with ,

statistical distribution of performance test data. The chemistry staff reviewed i

instrument control charts as required. The in-line instruments were tested as  :

required with corrective actions taken for instruments not meeting the stated

acceptance criteria contained in procedure BCP 520-6, " Byron Station in-line l

Quality Control Program."

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While the liconsee achieved excellent results for the 1996 interlaboratory i

comparison program, the inspectors identified some problems in the licensee's

corrective r,ctions for discrepancies in the 1995 comparison results. For example,

the licensee's third quarter 1995 lithium results were not within the stated I

acceptance criteria, in response, the licensee analyzed additional samples to I

investigate the disagreements but no documentation to assess the results of the

additional analyses existed. During the inspection, the licensee obtained the results

which indicated further disagreements. Although the cause of the disagreements

could not be determined, the inspectors verified that the 1996 results were within

the licensee's required tolerance and that there was no current problem with the

licensee's analytical accuracy. The lack of timely resolution reduced the ability to

correct potential analytical or instrument problems indicated by the data. The

licensee attributed this problem to a change in the administration of the program,

which had improved in 1996.

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c. Conclusions

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The laboratory and in-line instrument quality control program was well implemented

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and ensured the accuracy of chemistry analyses. Interlaboratory program results

were generally very good; however, discrepancies in 1995 results were not

effectively resolved.

R1.3 Post Accident Samolina System W!ntanance and Surr*mco Proaram

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j a. Insnaction Scone (84750)

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The inspectors reviewed the licensee's program to ensure the operability of the post

accident sampling system (PASS). The inspectors reviewed the licensee's OC

3 program required by procedure BAP 560-10 " Byron Chemistry Post-Accident I

i Program Description," Revision 2, dated December 2,1996. In addition, the '

i inspectors reviewed maintenance records and discussed system operability with the

l cognizant member of the chemistry staff.

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b. Observations and Findinos

The licensee's OC program required that a PASS surveillance program, consisting of

routine performance tests and calibrations of PASS equipment to ensure its

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readiness, be implemented. With the exception of gas chromatograph and ion

chromatograph surveillances, the inspectors noted that the licensee did not have

i procedures which defined the surveillance frequency and the method of performing

surveillances for the remaining system capabilities. Previously, the licensee had

followed a corporate sponsored Nuclear Operations Directive (NOD) NOD CY.5,

i which provided instructions to accomplish this program but was deleted in 1995.

l Although the licensee did not establish new guidance to replace the NOD, the

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chemistry staff continued to perform surveillances at the frequencies provided in

the NOD. As a result of self assessment activities (Section R7), the licensee

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identified this deficiency and was in the process of developing a procedure to define

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the surveillance program. Concurrently, the licensee performed quarterl/ sampling

of diluted and undiluted reactor coolant samples to ensure the capabilities of the

, system. The licensee's results indicated that diluted and undiluted samples could

be obtained at the PASS and that the dilution factor had remained constant.

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Technical Specification 6.8.4.d requires the licensee to implement a program to

ensure the capability of to obtain end analyze reactor coolant under accident

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conditions. The failure to have procedures, as required by BAP 560-10, to ensure

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the readiness of the PASS is a violation of TS 6.8.4.d. However, this licensee

identified and corrected violation is being treated as a Non-Cited Violation,

consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV Nos. 50-

454/97003-01 and 50-455/97003-01).

The inspectors reviewed outstanding licensee work requests for the PASS and

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observed that deficiencies in the system were corrected in a timely manner. With

the exception of the containment sump sample, the inspectors observed that

outstanding maintenance requests did not effect the licensee's ability to obtain

PASS samples. In January 1997, the licensee identified a problem with a check

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valve which affected the licensee's ability to obtain containment sump samples.

i The licensee had initiated a work request to correct the problem, which was

acheduled for late March 1997.

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The PASS maintenance programs was effective in ensuring system operability. A

j Non-Cited Violation was issued concerning the lack of instructions for performing

PASS surveillances.

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{ R2 Status of RP&C Facilities and Equipment

l R2.1 Radialaaical Survevs and identification of Radialanical Harmids

a. Inanection Scone (83750)

j On March 3 and 4,1997, the inspectors reviewed the radiological conditions in the

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Auxshary Buildmg (AB) and the adequacy of radiological postings and surveys, as

required by procedure BRP 5010-1 " Radiological Postings and Labeling

Requirements," Revision 12, dated January 31,1997. The inspectors also

reviewed the licensee's investigation concerning the inadequate posting of the

volume control tank (VCT) room in October of 1996.

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b. Observations and Findings

The inspectors observed that the licensee maintained good access to safety related

equipment with minimal radiological impediments. The inspectors verified that

radiation areas and high radiation areas (HRAs) were properly posted and controlled.

However, the inspectors identified several indications of pump seal leakage (i.e.

boric acid residue) in the 1 A and 2A chemical and volume control pump rooms, the

2A safety injection pump room, and the 2A residual heat removal (RHR) pump room

which were not within posted contaminated areas (CAs). As a result of the

inspectors' observations, the licensee conducted surveys of the identified areas and

measured removable radioactive contamination between 1,000 and 6,000

disintegrations per minute (dpm) over 100 square centimeter (cm 2) areas.

Procedure BRP 5010-1 requires that areas with removable contamination greater

than or equal to 1000 dpm per 100 cm2 be posted with a sign that states

" CAUTION, CONTAMINATED AREA". Subsequently, the licensee placed

boundaries and postings around the affected areas. The licensee indicated that the

site quality verification (SOV) organization had recently found problems in the

contamination control program but comprehensive corrective actions had not yet

been implemented.

TS 6.8.1 requires, in part, that written procedures be established, implemented,

and maintained covering the applicable procedures recommended in Regulatory

Guide (RG) 1.33, Appendix A, Revision 2, February 1978. RG 1.33, Appendix A

recommends that radiation protection procedures be implemented which cover

contamination control. BRP 5010-1 contains instructions for the labeling and

posting of contaminated areas and, thus, implements tho recommendation of RG

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1.33. The failure to post contaminated areas in accordance with BRP 5010-1 is a

violation of TS 6.8.1 (Violation Nos. 50-454/97003-02a and 50-455/97003-02a).

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During October of 1996, the licensee identified four occasions when radiological

. postings for the volume control tank (VCT) room and the valve aisle room were

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found to be incorrect. On two occasions, the high radiation area (HRA) posting for

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the VCT roorn was found on the door to the valve aisle room. Although the VCT

room was not correctly posted, the room remained controlled and locked,

preventing unauthorized access into the area. On two other occasions, the CA

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- posting for the valve aisle room was found on the entrance to the VCT room.

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Following the initial events, the licensee implemented the following corrective

actions: (1) the postings were corrected; (2) RP surveellences of the AB were

increased; (3) additional adhesives to the HRA signs were provided; and (4) a

formal investigation was initiated by the licensee.

During the licensee's investigation, a contract fire watch individual indicated that on

two occasions he replaced fallen radiological postings and on two occasions he had

moved radiological postings which he thought were incorrect. The individual

indicated that he thought he was taking the proper action in placing the fallen signs

on the door he felt they belonged and subsequently moving the signs when he

found they were on what he believed was the wrong door. As a long term

corrective action, the licensee and its contractor discussed the event with plant

staff and emphasized the correct actions to take when abnormal situations are

observed. The individual's access to the site was revoked.

The failure to properly post the VCT, a HRA, is a violation of 10 CFR 20.1902(b).

However, this licensee identified and corrected violation is being treated as a Non-

Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy

(NCV Nos. 50-454/97003-03 and 50-455/97003-03).

c. Conclusions

Access to safety related equipment remained relatively unencumbered by

radiological impediments. An example of a violation was identified concerning the

failure to post CAs in accordance with procedures. A Non-Cited Violation was

identified concerning the failure to post a HRA.

R4 Staff Knowledge and Performance in GPaiC

R4.1 Samolina and Analysis of Primary Coahnt

a. Insoection Scone (84750)

The inspectors observed chemistry technicians (cts) obtain and analyze routine

reactor coolant liquid and gas samples. The following procedures were used during

the sampling and analysis evolutions:

BCP 140-12, " Gas Analysis using the Hewlett Packard 6890 Gas Chromatograph,

Revision 0, dated December 7,1995;

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BCP 300-23, " Reactor Coolant or Pressurizer Liquid Grab Sample," Revision 13,

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dated September 16,1996;

BCP 300-62, " Preparation of Gas Samples for Isotopic Analysis," Revision 4, dated

i November 14,1996; and

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BCP 300-77, " Preparing a Pressurized Liquid Sampia for Analysis Using the i

l De9assing Panel," Revision 7, dated August 2,1994.

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On March 4 and 5,1997, the inspectors identified numerous procedure adherence

problems while observing cts obtaining and analyzing routine chemistry samples.

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As the cts were obtaining a reactor coolant sample on March 4,1997, the

inspectors questioned the cts actions which prevented imminent violations of

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procedure BCP 300-23. For example, prior to performing step F.30, the cts had l

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not performed a radiological survey of the liquid sample panel (LSP) as directed by i

step F.29. Once questioned by the inspectors, a dose rate of less than 3 millirem

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per hour was obtained. Prior to additional questions by the inspectors, the cts

subsequently failed to recognize that obtaining a dose rate of less than 3 millirem

per hour (mrom/hr) on the LSP in step F.29 required them to proceed to step F.43

instead of continuing to step F.30.

During the operation of the gas chromatograph (GC), the inspectors also identified

problems with procedure adherence. Procedure BCP 140-12 required the cts to

discard the results of the first performance test of the shift to ensure the sample

lines were adequately purged and then perform a second test. During the operation

of the GC on March 5,1997, the results of the first performance test of the shift

were not acceptable, and the CT properly repeated the analysis. However, the CT

indicated that it was acceptable to use the initial results if they were within the

licensee's acceptance range. The chemistry supervisor indicated to the inspectors

that this was not acceptable and communicated this to all cts in the department.

On March 5,1997, the inspectors identified that the licensee failed to adequately

follow procedure BCP 300-62. Prior to transferring a gas sample, procedure BCP

300-62 requires that the 15 cubic centimeter (cc) gas vial be evacuated. Two cts

had participated in the preparation and analysis but had not adequately ensured that

all of the procedural steps had been completed. CT A had prepared the vial for the

analysis by placing a septum on the viel, but he did not evacuate the vial.

Subsequently, CT B transferred the sample to the viel but did not recognize that the j

viel was not adequately prepared in accordance with BCP 300-62. The failure to j

evacuate the sample vial potentially introduced a nonconservative error in the I

analysis from a potential loss of sample. As a result of problems in the analyses,

the licensee repeated the entire evolution.

TS 6.8.1 requires, in part, that written procedures be established, implemented,

and maintained covering the applicable procedures recommended in RG 1.33,

Appendix A, Revision 2, February 1978. RG 1.33, Appendix A recommends that

procedures be implemented which specify chemistry instructions and the calibration

of laboratory instruments. Procedure BCP 300-62 provides chemistry instructions

for the preparation of gas samples, thus implements the recommendation of RG

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1.33. The failure to evacuate gas vials in accordance with BCP 300-62 is a ,

violation of TS 6.8.1 (Violation Nos. 50-454/97003-02b and 50-455/97003-02b). l

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During routine chemistry sampling, it was common practice for one CT to read the '

procedure steps and another perform the required actions. The inspectors observed

that the two cts frequently exchanged roles during the evolutions. The inspectors

noted that the lack of consistency appeared to contribute to the problems described

above. The chemistry supervisor indicated that this was a newly implemented

practice and that he planned to review its effectiveness and to ensure that the cts

understood his expectations. ,

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Effective contamination controls were used by cts while they obtained and

analyzed radioactive samples. The cts demonstrated good use of gloves while

handling potentially contaminated samples and performed contamination surveys

prior to removing samples from contaminated sample sinks. Prior to removing

samples from the sample room, the cts performed radiological surveys.

As a result of the procedure adherence problems discussed above, the inspectors

also reviewed the licensee's guidance and requirements concerning procedure ,

adherence. On November 1,1996, the station manager approved Site Policy Memo  !

No. 200.14 which provided management's expectations to site personnel. The

memorandum provided guidance concerning procedure adherence, independent l

verification, and conduct of general day-to-day activities. However, the inspectors l

identified that the lice. see did not have a procedure which covered adherence to

chemistry procedures.

TS 6.8.1 requires, in part, that written procedures be established, implemented, i

and maintained covering the applicable procedures recommended in RG 1.33, l

Appendix A, Revision 2, February 1978. RG 1.33, Appendix A recommends that

procedures be established which cover procedure adherence. The failure to

establish procedurep which cover procedural adherence is a violation of TS 6.8.1

(Violation Nos. 50-454/97003-02c and 50-455/97003-02c).

c. Conclusions

Three examples of a violation were identified concerning the failure to adequately

implement chemistry procedures. Although contamination control practices were

effective, cts did not always adhere to routine sampling and analyses procedures,

potentially effecting analytical accuracy.

R5 Staff Training and Qualification in RPaiC

R5.1 Post Accident Samolina Svstam Trainina (84750) ,

The inspectors reviewed licensee training records and discussed the continuing

training program for cts with a member of the training program. The inspectors

identified that the licensee's training program was not in accordance with BAP 560- j

10, " Byron Chemistry Post-Accident Program Description," Revision 2, dated '

December 2,1996. Procedure BAP 560-10 requires that cts receive training on

PASS procedures and perform or witness the performance of the stated procedures

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at least every six months. During the discussion, the chemistry trainer indicated

that the CT post qualification training program was conducted on an annual

frequency covering the topics in proceduas BTP 300-29, " Chemistry Training

Program," Revision 7. Procedure BTP 300-29 contains the topics covered in annual

CT training program, including post accident sampling system (PASS) procedure

review. The instructor's 1995 and 1996 records indicated that training was

conducted in September through October of 199F and in June through August of

1996. ' The inspectors discussed this with the chemistry supervisor who initially

indicated that he believed training had been ccnducted on a six month period.

TS 6.8.4.d requires that a program be implemented which will ensure the capability

exists to obtain and analyze reactor coolant samples, radioactive iodine and

particulate samples in plant gaseous effluents and containment atmosphere samples

under accident conditions. Procedure BAP 560-10 describes the PASS program

and requires that cts receive training semiannual training on the system and

receive training on PASS procedures at least every six months. The failure to

provide semiannual PASS training in accordance with BAP 560-10 is a violation of

TS 6.8.4.d (Violation Nos. 50-454/97003-04 and 50-455/97003-04).

R5.2 nu=lifications of Radiation Protection Staff (83750)

The inspectors reviewed the qualifications of the Health Physics Supervisor (HPS),

who was appointed to the position in February 1997. The HPS held a bachelors

degree in physics and mathematics and had several years of experience in nuclear

operations and licensing, but he had limited experience in professional health

physics. The inspectors noted that the individual met the minimum qualifications of

a technical manager contained in ANSI N18.1-1971, but did not meet the

qualifications of Regulatory Guide 1.8, September 1975, for a Radiation Protection

Manager (RPM). In accordance with TS 6.3, the licensee's lead health physicist

(LHP) met the requirements of Regulatory Guide 1.8 and held the functional

responsibilities of the RPM. The inspectors concluded that the HPS and LHP were

qualified with respect to the licensee's TS requirements.

R7 Quality Assurance in RP&C Activities

The inspectors reviewed the licensee's chemistry self assessment program including

audits and surveillances performed by corporate personnel, contractors, and the

licensee's chemistry and SOV staffs. The inspectors observed a notable

improvement in the chemistry staff's performance in this area from performance ,

documented in NRC inspection Report Nos. 50-454/455-95011(DRP). In 1996, the {

chemistry organization performed a comprehensive surveillance which reviewed the

adequacy of previous corrective actions. In addition, the licensee had reviews

performed by vendors and the corporate staff which covered a wide range of ,

chemistry activities and identified performance issues and improvement items, in

aggregate, the assessments of the chemistry program covered quality control,

procedure adequacy, post accident sampling system maintenance and surveillances,

and CT procedure adherence. Although CT procedure adherence problems were

still evident (Section R4.1), the licensee audits appeared effective in identifying

program problems. The inspectors verified that the licensee had developed and

documented corrective actions to address assessment findings. The chemistry

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supervisor indicated that he had planned to perform additional department

surveillances for 1997 and that he was confident that the chemistry staff

understood his expectations.

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R8 MisceBaneous RP&C issues (84750)

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R8.1 (Closed) Licensee Event Report (LER) 50-454/96013 Revision 0: On August 15, ,

1996, the licensee identified that the alarm setpoint for the containment I

atmosphere particulate and gaseous radiation monitors (1/2 PRO 11J) would not

i detect the design basis leak rate of one gallon per minute (gpm) in less than one

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hour. The licensee indicated that the alarm setpoints had been determined with

respect to radioactive release requirements. However, to meet the requirements of

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TS 3.4.6.1, the TS basis states that leak detections systems are consistent with

the recommendations of Regulatory Guide 1.45 " Reactor Coolant Pressure

Boundary Leakage Detection System," dated May 1973. Regulatory Guide 1.45

states that monitor sensitivities be such that a leak of one gpm in one hour be

detected. As immediate corrective actions, the licensee declared the monitors

inoperable and entered the limiting condition action requirements. On August 16,

1996, the licensee determined the correct actpoints for the monitors, which were

consistent with Regulatory Guide 1.45. The inspectors reviewed the licensee's

determination and verified that the current control room alarm setpoints were

consistent with the determination. As additional corrective actions, the licensee

reviewed other radiation monitor setpoints to ensure that all were consistent with

design criteria. As documented in the LER, other means of leak detection were

operable for the above period of time. The failure to have operable reactor coolant

leak detection systems required by TS 3.4.6.1 is a violation. However, this

licensee-identified and corrected violation is being treated as a Non-Cited Violation,

consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-454/

97003-05 and 50-455/97003-05).

R8.2 (Closed) LER 50-454/96022 Revision 0: On December 5,1996, the licensee

identified that the alarm setpoints for containment fuel handling incident radiation

monitors (1/2ARO11J and 1/2ARO12J) were not in accordance with TS Table 3.3-

6. The licensee determined this inconsistency as a result of corrective actions for

LER 96-013. Table 3.3-6 requires the trip setpoint to be set at a level such that the

actual submersion dose in the containment building would not exceed 10 millirem

per hour (mrom/hr). The as found setpoints were 75 mrom/hr (alert) and 100

mrom/hr (high alarm). After identifying the problem, the licensee removed the

monitors from operation and redetermined the alert and high alarm setpoints (i.e. 35

and 40 mrom/hr, respectively) as required by TS Table 3.3-6. The inspectors

reviewed the licensee's setnint justification document and ensured that the alarm

setpoints in the control room were as documented. During the period of time that

the setpoints were outside of the TS requirements, the licensee indicated that the

containment purge radiation monitors had setpoints which would have alarmed if

radiation levels exceeded 10 mrom/hr above background. As additional corrective

actions, the licensee completed a change request to correct the Updated Final

Safety Analysis Report (UFSAR) description of radiation monitors 1/2ARO11J and

1/2ARO12J to be consistent with the TS requirements. The failure to adhere to TS

Table 3.3-6 is a TS violation. However, this licensee-identified and corrected

10

._. - --. - - _ - + . . - - - . - . - - - . - - - . - - . - .

, -

l

3

j -

i

i violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 l

j ' of the NRC Enforcement Policy (NCV 50-454/97003-06 and 50-455/97003-06).

R8.3 (Onan) VIO Nos. 50-454/95011-01(c) and 50-455/95011-01(c): While obtaining I

-

reactor coolant samples, cts failed to adequately follow chemistry procedures.

l The inspectors verified that the licensee had completed the following corrective

actions

I

1

! -

The chemistry manager communicated his expectations that procedures be I

!

'

opened and used in the field and that errors in procedures be forwarded to l

chemistry management for correction;  !

! -

The chemistry manager communicated his expectations that lab supervisors

j will accompany cts in the field to observe and evaluate the cts and

j evaluate the adequacy of the chemistry procedures; and

,

'

i

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The cts were formally trained on the procedure revision process in April

1996 continuing training.

!

However, as described in Section R4.1, the inspectors identified additional

l- examplas of inadequate procedural adherence by cts. Based on these

,

i

observations, this violation will remain open.

'

I R8.4 (Closed) VIO Nos. 50-454/96005-02 and 50-455/96005-02: During chemistry <

training on May 27-31,1996, the licensee identified a procedure dsficiency i

! concerning sample line purge times but failed to take effective corrective actions. i

i The inspectors verified that the licensee's planned corrective actions were

! subsequently implemented. Following the event, the licensee corrected the

j affected procedures to ensure representative samples were obtained. Chemistry i

j personnel were counseled on the event with emphasis placed on evaluating the full  ;

i

impact of a problem. During December 1996, CT continuing training included a '

discussion of the issue. As documented in Section R7, the licensee conducted

additional self assessments which identified problems. The inspectors reviewed the

.! results of these assessments which were adequately evaluated to ensure that

! corrective actions were properly determined. This item is closed.

I .

V. Management Meetings

,

X1 Exit Meeting Summary s

On March 7,1997, the inspectors presented the inspection resu!ts to licensee  ;

management. The licensee acknowledged the findings presented. l

The inspectors asked the licensco whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

11 i

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. _. _ _ _ _ - - _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ - _ _ _ . _ _ _ _ . . _ _ _ _ _ _ . _ _ _ . .

.

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j PARTIAL LIST OF PERSONS CONTACTED

Licensee

J. Bauer, Health Physics Support Supervisor

! D. Brindle, Regulatory Assurance Supervisor

j R. Colglazier, NRC Coordinator

j W. Grundmann, Chemistry Supervisor

W. Israel, Audit Supervisor

K. Kofron, Station Manager

'

i W. McNeil, Radiation Protection

l D. Mead, Leed Chemist

j D. Starke, Quality Chemist

! INSPECTION PROCEDURES USED

!

l IP 837f,0 Occupational Radiation Exposure

]- IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring

. IP 92904 Followup - Plant Support

,

'

ITEMS OPEN, CLOSED, AND DISCUSSED

! Onened

l

3

50-454/455-97003-02(a-c) VIO Failure to establish, maintain, and implement

procedures recommended by Appendix A of

'

Regulatory Guide 1.33.

50-454/455-97003-04 VIO Failure to provide PASS training in accordance

with procedure BAP 560-10

Closed

50-454/455-96005-02 VIO Failure to take adequate corrective actions

50-454/455-97003-01 NCV Failure to establish PASS surveillance procedures

50-454/455-97003-03 NCV Failure to post a high radiation area in

accordance with 10 CFR Part 20

50-454/455-97003-05 NCV Failure to have proper radiation monitor

setpoints

50-454/455-97003-06 NCV Failure to have proper radiation monitor

setpoints

50-454/96013 LER Radiation monitor alarm setpoints greater than

technical specification requirements

12

._. .- . . . . -- .- - _ . . . . -. . -. .- - . _ .- . . -..

.

J

.

. 50-454/96022 LER Radiation monitor alarm setpoints greater than

technical specification requirements

!

Discussed l

j 50-454/455-95011-01(c) VIO Failure to follow chemistry procedures  !

t

f

,

"

<

)

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J

h

I

i

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l

!

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__ . _ . . . _ _ _ _ _ . ___ _.___. . _ - . _ _ . . . _ _ . _ _ _ . ._._ ._ _ . _ _ . _ . . _ .

, .

i

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l

ilST OF ACRONYMS USED

i

i A8 Auxiliary Building

{

AW

All-Volatile Treatment i

CA Contaminated Area

CFR Code of Federal Regulations

CT Chemistry Technician .

1 OPM Disintegrations Per Minute

GC Gas Chromatograph

"

GPM Gallons Por Minute

{

HPS Health Physics Supervisor

'

HRA High Radiation Area

LER Licensee Event Report

LHP Lead Health Physicist

LSP Liquid Sample Panel

.

'

MREM /HR Millirem per hour  ;

NCV Non-Cited Violation '

PlF Problem identification Form

i PPB Parts Per Billion

OC Ouality Control

Radweste Radioactive Waste

'

RG Regulatory Guide

RHR Residual Heat Removal

RP Radiation Protection

i

RPT Radiation Protection Technician l

. RP&C Radiation Protection and Chemistry

i SG Steam Generator

I

SOV Site Quality Verification

TS Technical Specification

UFCAR Updated Final Safety Analysis Report

'

VCT Volume Control Tank

-

VIO Violation

!

i

!

,

!

!

.

1

4

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_ _ - - __

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PARTIAL LIST OF DOCUMENTS REVIEWED

Byron Station On-Site Review Report, " Technical Specification 3.3.3.1 Regarding

ARO11/12 Alarm / Trip Setpoints," Dated February 14,1997.

Chemistry Performance Assessment, Surveillance OAS 06-96-025, Dated December 17,

1996.

Problem Ident!'ication Form No. 454-200-97-0015, " Regen Waste Drs'n Tank Overfilled /

Overpressurized."

Problem Investigation Report No. 454-200-96-0052S1, "High Radiation Area Not Posted

Due to improper Sign Movement." ,

Process Radiation Monitor Setpoint Justification Document (with Updates), dated

August 12,1993.

Site Quality Verification Audit of Chemistry, OAA 06 95-14, dated December 5,1995.

UFSAR Appendix E.21, " Post Accident Sampling (ll.B.3)."

UFSAR Section 9.3.2, " Sampling Systems."

UFSAR Section 10.3.5, " Water Chemistry."

UFSAR Section 11.5.2.4, " Sampling."

l

UFSAR Section 11.5.2.5, " Instrument inspection, Calibration, and Maintenance."

UFSAR Chapter 13, " Conduct of Operations."

15

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