ML20148T159
| ML20148T159 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/03/1997 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Graesser K COMMONWEALTH EDISON CO. |
| References | |
| 50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9707080405 | |
| Download: ML20148T159 (2) | |
See also: IR 05000454/1997003
Text
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July 3, 1997
Mr. K. Graesser
Site Vice President
Byron Station
Commonwealth Edison Company
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4450 N. German Church Road
Byron, IL 61010
Dear Mr. Graesser:
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(DRS);
50-455/97003(DRS))
This will acknowledge receipt of your letter dated May 5,1997, in response to our letter
dated April 4,1997, transmitting a Notice of Violation associated with activities at the
Byron Generating Station, Units 1 and 2. The first violation contained in the Notice of
Violation was associated with the failure to adequately implement chemistry and radiation
protection procedures and to establish procedures which cover chemistry procedure usage.
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We have reviewed your corrective actions for this violation and have no further questions
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at this time. These corrective actions will be examined during future inspections.
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However, we have questions regarding your response to the second violation contained in
the Notice of Violation associated with the failure to c rain chemistry personnel on the post
accident sampling system at a six-month frequency required by chemistry procedures. In
your response, you stated that your staff revised the applicable procedure to clarify the
training requirements. Through discussions with Mr. Robin Colglaizer of your staff, we
understand that the procedure was revised to reduce the frequency of training from 6-
months to 12-months. We are concerned that this change to your training requirements
may not be consistent with previous commitments to the NRC.
In a January 5,1984, letter from T. R. Tramm of the Commonwealth Edison Company to
H. R. Denton of the Office of Nuclear Reactor Regulation, commitments for periodic
training and re-training of technicians on the post accident sampling system were
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transmitted to the NRC. The letter indicated that training on procedures used to obtain
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post accident samples, which were not used in obtaining routine samples, would occur at
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least every 6 months. Subsequently, the NRC relied upon that information to evaluate the
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adequacy of your post accident sampling capabilities. By our records, you have not
notified the NRC of any intended change to the above commitment.
Based on the inconsistency between your proposed corrective actions and previous
commitments to the NRC, we request that you evaluate your corrective actions and the
above commitment to the NRC and submit an additional response within 30 days of the
date of this letter addressing this inconsistency and providing additional information.
99 Ch
llI.lli .lil.lil.lll.lll!.Ill.El.li
9707080405 970703
ADOCK 05000454
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K. Graesser
2
July 3, 1997
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If you have any questions concerning this request, please contact Mr. Steven Orth of my
staff at (630) 829-9827.
1
Sincerely.
Original Signed by Melvyn Leach (for)
John A. Grobe, Acting Director
Division of Reactor Safety
Docket Nos. 50-454; 50-455
Enclosures:
1. Ltr 05/05/97, K. L. Graesser,
Comed, to US NRC
2. Ltr 01/05/84, T. R. Tramm,
Comed, to US NRC
cc w/o encis:
T. J. Maiman, Senior Vice President,
Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
K. Kofron, Station Manager
D. Brindle, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
cc w/encls:
Document Control Desk - Licensing
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
State Liaison Officer, Wisconsin
State Liaison Officer
Chairman, Illinois Commerce Commission
Distribution:
Docket File w/encls
Rlli PRR w/encls
J. L. Caldwell, Rlll w/encls
PUBLIC IE-01 w/encls
SRis, Byron, Braidwood,
Rlll Enf. Coordinator w/encls
OC/LFDCB w/encls
Zion w/encls
R. A. Capra, NRR w/encls
DRP w/encls
LPM, NRR w/encis
TSS w/encls
DRS w/encls
A. B. Beach, Rlli w/encls
DOCDESK wencls
DOCUMENT NAME:G:\\DRS\\BRYO70}7.DRS
To receive a copy of this docurnent, indicate in the box:
'C' = Copy without attachrnent/enciczure
"E" = Copy with attachrnent/ enclosure
- N* = No copy
0FFICE
RIII
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RIII
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Rill
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NAME
S0rth:jp #
GShear 646
RLanskbury @ $
JGrobe #- 6 4--
DATE
07/l /97
07/ / /97
07/.3 /97
07/ 3 /97
Ott1C1AL RLCOMU CDPY
Commonw ealth 1.dmn Compan)
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lh run Generating station
4 450 North (scrnun (.hurch Road
.
lh run.1161010-9 91
TclH142 M 5441
May 5,
1997
LTR:
FILE:
1.10.0101
U.S. Nuclear Regulatory Commission
Washington, DC 20555
Attention:
Document Control Desk
Subject:
Byron Nuclear Power Station Units 1 and 2
Response to Notice of Violation
Inspection Report No. 50-454/97003; 50-455/97003
NRC Docket Numbers 50-454, 50-455
Reference:
Geoffrey E. Grant letter to Mr. Graescer dated
,
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April 4,
1997, transmitting NRC Inspection
Report 50-454/97003; 50-455/97003
Enclosed is Commonwealth Edison Company's response to the Notice of
Violation (NOV) which was transmitted with the referenced letter and
Inspection Report. The NOV cited two (2) Severity Level IV violations
requiring a written response.
Comed's response is provided in the attachment.
This letter contains the following commitments:
1)
To assist Radiation Protection (RP) in identifying contamination
control concerns as conditions in the plant change between routine
surveys, operating personnel will receive additional training on
identifying contamination hazards.
2)
In addition to establishing priorities for decontamination
activities, the RP Department will also assist Operating in
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initiating action requests for leaking equipment whi;h has not yet
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been tagged.
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3)
Chemistry personnel, along with Office Support, are developing a
new procedure BAP 1310-10, " Procedure Use and Adherence" to
address Regulatory Guide 1.33, Appendix A requirements.
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Byron Ltr. 97-0106
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May'5, 1997.
Page 2
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'If your staff has any questions or comments concerning this letter, please
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refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441
ext.2280.
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Respectfully,
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3K. L. Gr ss
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Site Vice P sident
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Byron' Nuclear Power Station
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KLG/DB/rp
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Attachment (s )
cc:
A. Bs Beach / NRC Regional Administrator - RIII
G. F.. Dick Jr.,. Byron Project Manager - NRR
S. D.. Burgess, Senior.. Resident Inspector, Byron
R. D. Lanksbury, Reactor Projects Chief - RIII
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F.'Niziolek, Division of Engineering - IDNS.
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D. L. Farrar, Nuclear Regulatory . Services Mat ager, Downers Grove
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Safety Review Dept, c/o Document Control Desk, 3rd Floor,LDowners Grove-
DCD-Licensing, Suite 400, Downers Grove.
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ATTACHNENT I
VIOLATION (454/455-97003-02)
Technical Specification 6.8.1 requires, in part, that written procedures shall
be established, implemented, and maintained covering activities referenced in
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
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Regulatory Guide 1.33, Appendix A recommends that radiation
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protection procedures be implemented which cover contamination
control.
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Procedure BRP 5010-1 " Radiological Postings and Labeling
Requirements," Revision 12, dated January 31, 1997, requires, in
part, that areas with removable contamination greater than or
equal to 1000 disintegrations per minute (dpm) per 100 square.
centimeters ( cm ) be posted with a sign that states " CAUTION,
{
a
CONTAMINATED AREA."
contrary to the above, as of March 3 and 4, 1997, areas within the
1A and 2A Chemical and volume Control System pump rooms, the 2A
Safety Injection pump room, and the 2A Residual Heat Removal room
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which contained removable contamination of 1,000 to 6,000 dpm per
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100 cm2 were not posted with a sign that stated, " CAUTION,
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CONTAMINATED AREA." .(50-454/97003-02a and 50-455/97003-02a)
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b.
Regulatory Guide 1.33, Appendix A recommends that procedures.be
implemented which specify chemistry instructions and the
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calibration of laboratory instruments.
Procedure BCP 300-62, " Preparation of Gas Samples for Isotopic
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Analysis," Revision 4, dated November 14, 1996, requires that a 15
cubic centimeter gas vial be evacuated prior to containing a
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sample.
Contrary to the above, as of March 5, 1997, a chemistry technician
failed to evacuate the gas vial prior to placing a sample in the
vial.
(50-454/97003-02b and 50-455/97003-02b)
c.
Regulatory Guide 1.33, Appendix A recommends that procedures be
established which cover procedure adherence.
Contrary to the above,.as of March 3,
1997, the licensee had not
established procedures which cover adherence to chemistry
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procedures.
(50-454/97003-02c and 50-455/97003-02c).
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This is'a Severity Level IV Violation (Supplement I).
(50-454/455-97003-02a, b, c(DRS))
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REASON FOR THE VIOLATION
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Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
a.
Per BRP 5010-1, " Radiological Posting and Labeling Requirements", areas
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with removable contamination greater than 1000 dpm/100 cm are required
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to be posted with a sign that states, " Caution Contaminated Area".
Contrary to this requirement, Radiation Protection did not post the 1/2A
Chemical and Volume Control (CV) Pumps, the 2A Safety Injection (SI)
Pump, and the 2A Residual Heat ~ Removal (RHR) Pump as contaminated areas.
Radiation Protection did not identify contamination on routine plant
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surveys of these areas due to a lack of attention to detail.
BRP 6020-
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3, " Routine Plant Surveys", requires contamination surveys of. work
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surfaces, equipment, and floors to support general access. However, the
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contamination surveys were not performed in sufficient detail'to
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identify the contamination on the pump seals.
It was apparent that the
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pump seals had leaked primary system water which after evaporation,'
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resulted in a collection of dried boron which is a known contamination
hazard.
The Radiation Protection Department is committed to maintaining high
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material condition standards in radiologically posted areas to ensure
minimal radiological impediments to safety related equipment.
To
achieve this goal, aggressive goals have been established for minimizing
contaminated area square footage in the plant.
By maintaining good
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housekeeping practices, radiological hazards are reduced and personnel.
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contamination events are minimized.
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b.
Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
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The' set-up of instrumentation and analysis for.a gas sample was being
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performed by two (2) Chemistry technicians. The gas vial was not
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evacuated due to a ndscommunication between the technicians.
The status
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of the analysis activities was not properly maintained.
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c.
Procedure Adherence Procedure (50-454/455 97003-2c)
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Chemistry Department Policy.200-3~ covers procedure adherence,
. additionally Site Policy Memo 200-14 governs the use'of procedures.
Personnel had improperly relied on policies and memos in lieu of an
approved procedure for providing guidance on-adherence'to procedures.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
LIndividual corrective actions with regard to the Notice of Violation is as
follows:
a.
-Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
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1.
To emphasize procedure compliance and material condition
. priorities, ' Radiation Protection ' management . reviewed department
expectations during continuing training sessions which concluded
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in March 1997.
Pointed discussions on survey expectations focused
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on the importance of properly identifying and posting
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contamination hazards. All Radiati'on Protection Laboratory
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All routine plant general area surveys as documented on
BOP 6020-TB, "RP Lab Supervisor Routine Checklist", have been
completed since management expectations were presented and no
additional contaminated areas were found that were not posted.
b.
Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
1.
The chemistry technicians were counseled on the need for proper
communication since they were involved in preparing the sample
vial and did not communicate its actual status.
2.
Preparation procedures in the Hot Lab and sampling procedures in
HRSS have been placed in plastic covers and marking pens will be
used to mark steps.
c.
Procedure Adherence Procedure (50-454/455 97003-2c)
1.
None
CORRECTIVE STEPS THAT WILL BE TAIGN TO AVOID FURTHER VIOLATION
a.
Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
1.
To assist Radiation Protection (RP) in identifying contamination
control concerns as conditions in the plant change between routine
surveys, operating personnel will receive additional training on
identifying contamination hazards. Operating has successfully
identified equipment issues through the action request process in
the past.
Operating will now also notify RP when they identify
adverse conditions, such as leaking equipment, to ensure proper
radiological-controls are established. Training Revision Request
(TRR)97-810 will track this training.
2.
In addition to establishing priorities for decontamination
activities, the RP Dept. will also assist Operating in initiating
action requests for leaking equipment which has not yet been
tagged. This will also assist RP in reducing' repeat
decontamination by ensuring the cause of the leak is addressed.
TRP 97-809 will track training RP on submitting action requests.
b.
Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
1.
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Procedure Adherence Procedure (50-454/455 97003-2c)
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1.
To meet Regulatory Guide 1.33, Appendix A requirements,. Chemistry
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personnel, along with office Support personnel, are developing a
procedure usage procedure. The new procedure BAP 1310-10,
" Procedure Use and Adherence", will be applicable to all Site
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personnel. NTS# 454-100-97-00302c-01 tracks this action.
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
a.
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Full compliance was achieved on 3/4/97 when the proper boundaries and
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postings were placed around the affected areas.
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b.
Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
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Full compliance was achieved on 3/5/97 when the gas sample and analysis
was performed in accordance with the procedure.
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c.
Procedure Adherence Procedure (50-454/455 97003-2c)
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Full compliance will be achieved by 8/29/97 when the procedure is
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completed, approved for use', and site personnel have been trained. This
issue was initially identified in the Chemistry area, training for
Chemistry personnel will be completed by 7/15/97.
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ATTACHMENT II
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VIOLATION (454/455-97003-04)
Technical Specification 6.8.4.d requires that a program be implemented which
will ensure the capability exists to obtain and analyze reactor coolant
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samples, radioactive iodine and particulate samples in plant gaseous effluents
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and containment atmosphere samples under accident conr'itions.
Procedure BAP 560-10, " Byron Chemistry Post-Accident Program
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Description," Revision 2, dated December 2,
1996, requires, in part,
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that chemistry technicians receive semiannual training on the. post
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accident sampling system (PASS) and receive training on PASS procedures
at least every six months.
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Contrary to the above, PASS training of chemistry technicians was not
conducted from October 1995 to June 1996, a period in excess of six
months.
(50-454/97003-04 and 50-455/97003-04)
This is a Severity Level IV violation (Supplement I).
,
(50-454/455-97003-04(DRP))
REASON FOR THE VIOLATION
In 1993, the Chemistry and Training Departments reviewed technician training
for post-accident and revised the frequency as documented in Byron Letter 93-
0312.
Byron Training Procedure (BTP) 300-29, " Chemistry Department Training
Program", was revised at the that time and the frequency of PASS training was
changed to annually.
BAP 560-10, " Byron Chemistry Post-Accident Program
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Description", was not revised to reflect the new requirements stated in BTP
-300-29.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
1.
BAP 560-10 was revised to clarify the requirements of PASS training for
technicians.
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2.
Chemistry and Training personnel performed a review to assure that other
training requirements are consistent between the administrative and
training procedures.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
1.
None
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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full d:ompliance was achieved on 4/29/97 with the completion of tihe revision to
BAF 560-10.
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C:mm:nwealth Edison
Ons hast Nahonal Plasa Checapo. In.no s
Address Reply solost Oif20 DDM
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Chicago. Ithnois 60690
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January 5, 1984
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Mr. Harold R. Denton, Director
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Office of Nuclear Reactor Reculation
U.S. Nuclear Regulatory Commission
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Subject
Byron Generatlng Statlon Units 1 and 2
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Braidwood Generating Station Units 1 and 2
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Post Accident Sampling System
NRC Docket Nos. 50-454, 50-455, 50-456 & 50-457
References (s):
August 26, 1982 letter from T. R. Tramm
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to H. R. Denton.
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(b):
October 26, 1982 letter from T. R.
Tramm to
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Osar Mr. Denton
This letter provides supplemental information regarding the
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periodic training to be provided to Byron /Braldwood rad / chem technicians
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for post-accident sampling procedures.
This revises information provided
in reference (b).
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The Byron /Braldwood post-accident sampling system is the same
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sampling system used for routine sampling operations.
Only a few special
procedures are not used in obtaining and routine samples.
The following
special retralning will be completed by all radiation-chemistry
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technicians at least every six months:
1.
Review the following procedures
BZP 380-10
" Post accident samplin
of reactor coolant, redweste and
containment air-genera .
BZP 380-11
" Post accident sampling of undiluted reactor coolant."
BZP 380-12
" Post accident sampling of diluted reactor coolant."
BZP 380-13
" Post accident sampling of undiluted liquid radwaste."
DZP 380-14
" Post accident sampling of diluted radweste."
BZP 380-15
" Stripped-gas sampling of post accident reactor coolant."
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H. R. Denton
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January 5, 1984
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BZP 380-16
" Post accident diluted reactor coolant /radweste sample
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disposal."
BZP 380-17
" Post accident sample transfer from primary sample room."
BZP 380-18
" Post accident sampling of containment atmosphere. room."
BZP 380-A7
" Post accident sample transport routes."
2.
Perform or witness the performance of five of the ten procedures
listed at the high radiation sampling system.
Over the course of a
year, all ten procedures must be performed or witnessed.
Please direct further questions regarding this matter to this
office.
Very truly yours,
fik&
T. R. Tramm
Nuclear Licensing Administrator
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