IR 05000454/1986016

Insp Repts 50-454/86-16 & 50-455/86-13 on 860414-24.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Program,Including Organization & Mgt Controls,Training & Qualification & IE Info Notices

ML20197K217
Person / Time
Site:	Byron
Issue date:	05/14/1986
From:	Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197K188	List: IR 05000454/1986016 ML20197K185
References
50-454-86-16, 50-455-86-13, IEIN-85-081, IEIN-85-81, NUDOCS 8605200295
Download: ML20197K217 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-454/86016(DRSS); 50-455/86013(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Byron Nuclear Power Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conduc d: April 14-24, 1986 Y s Inspector: W. B. Grant O lY Dhte '

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Approved By: L... ege ef @

Facilities Radiation Date Protection Section Inspection Summary Inspection on April 14-24, 1986 (Report No. 50-454/86016(DRSS);

50-455/86013(DRSS))

Areas Inspected: Routine unannounced inspection of the radiation protection program including: organization and management controls; training and qualifica-tions; exposure controls; control of radioactive materials and contamination; surveys and monitoring; I&E Information Notices; and Unit 2 preoperational testin Results: No violations or deviations were identified.

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i DETAILS

'1 . Persons Contacted

• Burkamper, Quality Assurance Supervisor L.-Bushman, ALARA Coordinator l_ *R. Flahive, Radiation / Chemistry Supervisor J. Hirsh, Health Physicist Consultant  :

• T. Joyce, Assistant Superintendent Technical Services i *J.-Langan, Compliance Staff .

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l W. McNeill, Lead Radiation / Chemistry Foreman l . *R. Plenlewicz, Production Superintendent

• R. Querto, Station Manager t

• M. Snow, Assistant Compliance Supervisor

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-*R.-Ward, Services Superintendent

• K. Weaver, Station Health Physicist J. Weitzel, Health Physics Staff l *K. Yates, Nuclear Safet *E. Zittle, Compliance Staff

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! J. Hinds, NRC Senior Resident Inspector -

• P.-Brockman, NRC Resident Inspector

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• Denotes those attending the exit meetin l

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The. inspector also contacted the members of the training, services, radiation / chemistry, and engineering staffs during this inspection.

i General l This inspection, which began at 10:00 a.m. on April 14, 1986, was conducted L to examine the routine radiation protection program, the results of the increased management involvement in the radiological control program and the preoperation status of Unit . Licensee Action on Previous Inspection Findings l- (Closed) Violation (454/85022-01): Procedures did not restrict containment entry when.incore detectors were withdrawn. Procedures 80P-1C-01, l

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B0P-1C-03, and BOP-1C-04 regarding "Incore Moveable Detector Flux Mapping" were revised to limit containment access when the detectors are unshielded.

'(Closed) Violation (454/85022-02): Instructions on radiological conditions and precautions given'to two workers as required by 10 CFR 19.12 were

, inadequate for entry into a high radiation area. Formal annual training

! for radiation workers was revised to include additional training on RWP j . adherence and digidose use. Meetings were held with all station departments

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to discuss the incident, to stress that workers read and understand the RWP before signing, and to emphasize the need for pre-job planning and work

,. group communication.

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(Closed) Violation (454/85022-03): Radiation / Chemistry technician not in continual attendance with workers in a greater than 1000 mR/hr radiation area as required by Technical Specification 6.12.2. Disciplinary meetings were held with workers involved, pre-job planning and communications were discussed. Disciplinary actions were taken. Radiation / Chemistry supervi-sion held meetings with all station departments to discuss this 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 communication (Closed) Violation (454/85022-04): Emergency entry into containment made without an RCT in continual attendance as required by RWP, resulting in exceeding RWP specified dose limits. Disciplinary action was taken, and meetings were held with all station work groups to stress RWP adherence, pre-job planning, and work group communicatio (Closed) Violation (454/85022-05): Workers remained in the controlled area after exceeding their authorized dose limits. Disciplinary action was taken, and superintendent meetings were held with involved workers stressing the significance of the event and potential problems that may have occurre (Closed) Violation (454/85022-06): Maintenance workers did not contact the Radiation / Chemistry Department for an evaluation of jobsite conditions prior to entering a contaminated work are Disciplinary action was taken, the station Manager met with the Radiation / Chemistry and Maintenance Departments to emphasize worker responsibility to comply with Radiation Control Standards and Procedures, and radiation protection awareness meetings were held with all station work group (Closed) Violation (454/85022-07): Maintenance workers initiated personal decontamination without Radiation / Chemistry personnel in attendance as required by procedure. Disciplinary action was taken. Radiation Protection Awareness meetings were held with maintenance personnel. Personal awareness and individual accountability to the radiation protection program were highlighte (Closed) Violation (454/85022-08): Two workers entered containment without continual RCT surveillance being provided as required by the RWP. Station superintendents met with the involved individuals to discuss the signifi-cance of the event and the potential problems that may have occurre Radiation Protection Awareness meetings were held with all station work groups in an attempt to prevent future violation (Closed) Violation (454/85022-10; 455/85020-02): Security personnel did not stop an individual who alarmed the portal monitor from leaving the plant, nor was Radiation / Chemistry notified. Training sessions were conducted with the security force to reemphasize their responsibilities with respect to the portal monitors. New signs were posted at the portal monitors providing specific instructions as to proper exit procedure __

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(Closed) Violation (454/85022-11; 455/85020-03): No authorized procedure or temporary procedural change described a valve lineup through which diluted reactor coolant water was transferred from the recycle holdup tanks to the Unit 2 condensate pit sump. An authorized temporary change to BOP AB-9 was initiated to address the transferring of the recycle holdup tank to the radwaste release tank via the chemical drain tank. The importance of using an approved procedure was stressed to all operating and radwaste personne I (Closed) Open Item (454/85037-01; 455/85041-01): Provide additional j reactor systems training for RCTs. The pilot course on reactor systems training was given February 24 through March 7, 1986. This course has been added to the current RCT training program for both new and experienced RCT i i

(Closed) Open Item (454/85037-02): Resolution of ROR 85-38 involving an injured worker leaving the controlled area without anyone notifying Radiation / Chemistry. The injured worker and her supervisor, who assisted her, were both counseled on the importance of notifying Radiation / Chemistr ,

Disciplinary action was take ! Organization and Management Controls The inspector reviewed the licensee's organization and management controls for the radiation protection program including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement these programs, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these program l

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Since the last radiation protection inspection the following personnel changes were made:

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• The Radiation / Chemistry Supervisor was reassigned to license trainin * The Assistant Technical Staff Supervisor, Operating, was promoted to Radiation / Chemistry Superviso * The Lead Health Physics Foreman was promoted to ALARA Coordinato * A Health Physics Foreman was promoted to Lead Health Physics Forema * A Staff Health Physicist terminated employmen * A Staff Health Physicist took maternity leav * The four contract Health Physicists (HP) who formerly were providing feedback and advice on the HP program to HP Management were assigned functional HP dutie In addition to the contract HPs, the licensee has 16 contract radiation protection personnel including: nine junior technicians, four senior technicians, two supervisors, and one clerk.

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The Station Health Physicist (SHP) was appointed Radiation Protection Manager (RPM). The SHP's qualifications for RPM were reviewed and he appears to meet or exceed the ANSI NI8.1-1971 qualification, required by Technical Specification 6.3.1. The appointment of the SHP to RPM adds a level of management between the RPM and the Station Manage However, the licensee has recently established regularly scheduled meetings between the two. There appears to be no problem with the RPM direct access to the Station Manager on matters concerning radiation protectio Two audits of the radiation / chemistry program have been conducted in 1986 by the onsite QA department. Corrective action was taken on one finding and three observations. No problems were note A comprehensive assessment of the radiation protection program was conducted by Nuclear Services Health Physics (Corporate) during February 1986. The assessment team's findings were very positive, recognizing 13 good practices and eight items needing some improvement. No problems were note An audit by INP0 conducted in August 1985 had six findings and one concer As of April 15, 1986, corrective action was completed on four findings and the one concern. The findings remaining open require further corporate evaluation or the completion of radwaste system No violations or deviations were identifie .

5. Training and Qualifications The inspector reviewed the training and qualifications aspects of the licensee's radiation protection, radwaste, and transportation programs, including: changes in responsibilities, policies, goals, and methods:

qualifications of newly hired or promoted radiation protection personnel; and provision of appropriate radiation protection, radwaste, and transpor-tation training for station personne Also reviewed was management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The inspector reviewed reactor systems training conducted by the station training department. This training was developed in response to weaknesses identified during previous inspections, specifically the RCT's inexperience with reactor systems. The pilot course was presented February 24 through March 7, 1986. Lesson plans were reviewed; no problems were noted. All currently qualified RCTs will complete the two week course as part of their continuing training. Reactor systems' training will also be included'in the '

RCT certification training progra Contractor personnel training records were selectively reviewed. It appears that contractors have received a basic eight-hour Nuclear General Employee Training (NGET) course. When required, contractors receive additional training commensurate with their job requirements. The inspector attended portions of contractor NGET class. The classroom was of adequate size and well equipped. The class size allowed for 'ndividual attention. In general, the presentation was of good quality and students participated. No problems were note No violations cr deviations were identifie *

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6. External Exposure Control and Personal Dosimetry The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including: changes in facilities, equipment, personnel, and procedures; adequacy of the dosimetry program to meet routine and emergency needs; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications; effectiveness of management techniques used to implement these programs and experience concerning self-identification and correction of program implementation weaknesse The inspector reviewed exposure results for 1986 to date; no exposures exceeding NRC limits were identified. Approximately 3000 individuals are currently whole body film badged with some additional individuals also having extremity and multiple badging. The licensee has reduced the number of people requiring film badges from a December 1985 high of 370 This reduction effort is continuin The total dose for 1985 was about 97 person-rems. This period included a short maintenance outage in July and a maintenance outage which began October 28 and ended December 18, 1985. The total 1986 done through March 31 was 19 person-rem The HP staff reviews daily exposure updates to identify individuals approaching their limit, and to contact the appropriate work supervisor and access control personnel when limits are approache Updates are maintained at access control. No problems were note No violations or deviations were note . Internal Exposure Control and Assessment The inspector reviewed the licensee's internal exposure control and assessment program, including: changes in facilities, equipment, personnel, respiratory protection training, and procedures affecting internal exposure control and personal assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; required records, reports, and notifications, effectiveness of management techniques used to implement these programs and experience concerning self-identifica-tion and correction of program implementation weaknesse Whole Body Count (WBC) results from November 1985 through March 1986 were reviewed. No results approaching the 40 MPC-hour evaluation level were noted. Biweekly reports generated by the WBC contractor are reviewed by the HPs to assure abnormalities, and results exceeding the licensee's investigation level are identified. Calibration of the standup NaI scintillation counter indicated no problems, nor have daily check source readings (C0-60 and Cs-137) identified instrument drift or abnormalitie The WBC computer program converts Maximum Permissible Body Burdens (MPBB)

to MPC-hours when the prescribed investigation level (3% MPBB for a single isotope; 5% MPBB total) is reached. The conversion has not been procedura-lized, however, a draft procedure has been written and is being revised for inclusion in the station HP procedure (0 pen Items No. 50-454/85022-09; No. 50-455/85022-01).

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Air sample data for 1985 and 1986 to date was selectively reviewed. During plant tours, auxiliary filtering ventilation systems were observed in use in various cubicles where repair / maintenance work was going o No problems were note . Control of Radioactive Materials and Contamination, Surveys and Monitoring The inspector reviewed the licensee's program for control of radioactive materials and contamination, including: changes in instrumentation, equipment, and procedures; effectiveness of survey methods, practices, equipment and procedures; adequacy of review and dissemination of survey data; effectiveness of methods of control of radioactive and contaminated materials; and management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse '

The inspector reviewed records of routine and special radiation and contamination surveys conducted in 1986 to date. All surveys, routine and special, are reviewed by an HP foreman for completeness and any unusual conditions. No problems were note The inspector selectively reviewed survey instrument and portal monitor calibration records. Instruments and monitors appeared to be calibrated

in accordance with procedures. The licensee is changing the calibration procedure to include calibration points at 20%, 50%, and 80% of each scale. The procedure formerly required calibration points at only 20%

and 80% of all scales. Calibration ranges reflected applicable ranges encountered in the field. Responses were within tolerance levels. A computer tracking system is used to identify upcoming calibration date No problems were note On March 3, 1986, in response to an inspector concern the licensee started smear surveying at the Unit 2 trackway exit from the turbine building three times a week. Some workers exit the turbine building to the uncontrolled area at the Unit 2 trackway and return without passing through a portal monitor or frisking. The concern was that workers may have been contami-nated in the turbine building and could track contamination to the uncontrolled area. This additional control should ensure workers are not inadvertently spreading contamination to the uncontrolled are The active RWPs were selectively reviewed. RWPs contained current survey information which is updated every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Approvals and ALARA reviews were included where required. Administrative exposure limits are used in dose predictions.

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, Unit 2 Preoperational Tests PR 2.60.61 The_ inspector witnessed portions of preoperational test PR 2.60.61 for the Unit 2 containment purge process radiation monitor Loop 1. The inspector verified that the testing was conducted in accordance with approved procedures, the test equipment was properly installed, the data was collected and recorded properly, and that test deficiencies were documented and test changes were processed in an approved manne Tests witnessed included proper operation of: the monitor high pressure alarm; the monitor loss of sample flow alarm; automatic pump control; power failure and battery test; low voltage cutout; and high radiation alarm No problems were note No violations or deviations were identifie . I&E Information Notices IE Notice 85-81: Problems Resulting in Erroneously High Reading with Panasonic 800 series Thermoluminescent Dosimeters (TLD). Byron does not use TLDs for personnel monitoring at this time. When a TLD program is used at Byron it will be part of a corporate functio This Information Notice was referred to Ceco corporat No violations or deviations were identifie . Monthly NRC Briefing At the April 22, 1986. monthly NRC briefing, the licensee summarized the status of their program for improving the plants' radiation protection performance. All 40 recommendations from the July 1985 corporate assess-ment were reported to have been completed, and five of the seven INP0 findings were reported to have been comp,leted, with the remaining requiring further corporate evaluation or completion of the radwaste volume reduction system. Radiation Protection Awareness meetings have been held with approximately 2400 people. The licensee's efforts to identify and correct radiation protection program weaknesses is continuing; these efforts are commendable and indicate significant improvement in management support for the radiation progra Additional items discussed in the April 22, 1986 monthly NRC briefing, including meeting attendees, are documented in NRC Inspection Report No. 50-454/86014(DRP).

12. Exit Meeting The inspector met with licensee representatives (denoted in Secticn 1) at the conclusion of the inspection. The scope and findings of the inspection were summarized. The inspector also discussed the likely information content of the inspection report with regard to the documents and processes reviewed during the inspection. The licensee identified no such documents /

processes as proprietary. The licensee acknowledged the inspector's comments concerning the positive effects of strong management support of the radiation protection program and the need to continue that support.

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