ML20198N373
| ML20198N373 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 10/24/1997 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-97-17, 50-455-97-17, BYRON-97-0240, BYRON-97-240, NUDOCS 9711040084 | |
| Download: ML20198N373 (6) | |
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October 24, 1997 LTRI BYRON 97-0240 FILET 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. 50-454/97017; 50-455/97017 NRC Docket Numbers 50-454, 50-455
Reference:
John A. Grobe letter to Mr. M. Graesser dated October 1, 1997, transmitting NRC Inspection Report 50.454/97017; 50-455/97017 Enclosed is commonwealth Edison Company's response to the Notice ot Violation (NOV) which was transmitted with the referenced letter and Inspection Report. The NOV cited one (1) Severity Level IV violation requiring a written response.
Comed's respones is provided in the attachment.
This letter contains the following commitments:
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The outage kick-off meetings for the upcoming steam generator replacement will include a discussion of radiological postings and barriers and t*= expectation f
4 that RP must be contacted prior to move.aent of such items.
- FM 2)
A training video is currently under production to M,b /
heighten worker awareness regarding the purpose of high
/
radiation area controls and the types of barriers that are used in the field. The video will be presented at ang T
department tailgates.
3)
Revision 1 of the Comed Radiation Worker Handbook will be ho distributed in November 1997.
Topics from the handbook are periodically emphasized through station
,g communications such.as the daily rewsletter and f@u tailgates.
~ ww 4)
To ensure that Radiation Protection is responding D M C hg
( 4 consistently when contacted by workers who are requesting to move a radiological posting or barrier, all Radiation Protection personnel will be trained on the proper-response to these requests.
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MilllElOlllipliWillli A Unicom O>mpany
-___-___2______-_-___-___--___--_____--_.
Byron Ltr. 97-0240 October 24, 1997 Page 2 If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext. 2880.
Respectfully, b
a K. L. Grae er Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment cc:
A. B. Beach, NRC Regional Administrator - RIII G.
F. Dick Jr.,
Byron Project Manager - NRR Senior xesident Inspector, Byron R. D. Lanksbury, Reactor Proiects Chief - RIII F. Niziolek, Division of Engineering - IDNS (p:\\97byhrs\\970250. doc)
ATTACHMENT VIOLATION (454/455-97017-02) 10 CFR 20.1902 (a) requires that the licensee post each radiation area with a conspicuous sign or signs bearing the radiation symbol and the
/
words
- CAUTION, RADIATION AREA."
10 CFR 20.1902 (b) requires that the licensee post each high radiation area with a conspicuous sign or signs bearing the radiation symbol and the words,
- CAUTION, HIGH RADIATION AREA" OR
- DANGER, HIGH RADIATION ARFA."
Contrary to the above, on January 24, 1997, an area inside the 2A containment spray pump room, a high radiation area with a radiation dose rate in excess of 100 millirem in one hour at a distance of 30 centimeters from the radiation source was not posted with a sign bearing the radiation symbol and the words *CAUTICN, HIGH RADIATION AREA" or ' DANGER, HIGH RADIATION AREA."
Also, on August 4,
- 1997, the 2B letdown heat exchanger room, ' a radiatior area with radiation dose rate in excess of 5 ndllirem in one hour tt a distance of 30 centimeters from the radiation source was not posted with a sign bearing the radiation symbol and the words, " CAUTION, RADIATION AREA."
(50-454/97017-02 and 50-455/97017-02)
This is a Severity Level IV Violation (Supplement IV).
REASON FOR THE VIOLATION The violation is due to workers moving radiological postings attached to movable barriers.
Event 1 occurred on January 24, 1997. A Radiation Protection Technician (RPT) was covering a job in the 2A containment spray pump room.
He recogni7ed that a rope which established a high radiation area boundary had been moved.
Questioning the movement of the rope, the RPT surveyed the area and found the boundary did not encompass the entire high radiation area.
After extensive investigation, the root caese of the rope being moved remained indeterminate.
As corrective action, the entire room was posted high radiation area because it contained numerous localized high radiation areas that were individually roped which increased the risk of a repeat event.
Event 2 occurred on August 4, 1997. A Radiation Protection Technician (RPT) identified the swing gate and posting to the 2B letdown heat exchanger room had been moved to an adjacent area.
Mechanical Maintenante was working in the room.
Their RWP was immediately suspended.
Although the worker that moved that swing gate was not identified after extensive investigation, the entire group was counseled on RP expectations for moving radiological postings and barriers.
In both instances, Radiation Protection promptly identified and corrected the deficiencies.
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1 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The boundary in the 2A containment spray pump room was immediately corrected to encompass the high radiation area. As long term corrective action, the individual high radiation areas in the containment s}.rsy and residual heat removal pump rooms have been consolidated so the entrance to the area has a single high radiaticn area posting and barrier.
Low dose waiting areas were designated witbin the rooms.
This improvement enhanceo human f actors and minimizei the opportunity for barriers and postings to be moved or obstructed.
2.
To addrers the swing gate being moved in the 2B letdown heat exchanger room, the swing gate was immediately repositioned and the RWP for the job was immediately suspended.
The Radiation Protection Supervisor and Maintenance Supervisor conducted a walkdown of the job site and discussed departmental expectations.
The Mechanical Maintenance group was counseled to contact RP to move radiological postings and barriers.
3.
Radiation Protection tailgated the contracted meintenance work group to discuss the purpose of swing gates and other radiological barriers.
That communication proved effective.
Shortly after the presentation, a contractor notified RP of a malfunctioning swing gate.
The worker was appropriately recognized.
4.
On September 17, 1997, the Station Manager issued a memo to all site personnel discussing expectations for radiation workers.
The memo discussed the radiation worker error that resulted in violation 50-454/455/97017-01 identified in this report (which did not require written response) and the pesting event that occurred on August 4, 1997. The memo heightened worker awareness regarding good RP practices.
5.
The RP Supervisor has given two presentations at the Plan of the Day Meeting regarding radiation worker expectations.
The Plan of the Day Meeting is attended by senior station management and representatives from all departments.
6.
Station departments were tailgated on the expectation for line management to monitor the performance of radiation workers in the field to ensure compliance with station procedures and policies. Additionally, all RP Technicians have been presented an RP Management expectation to challenge radiation workers in the field to ensure proper radiological work practices and compliance with site procedures.
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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
Byron Station conducts outage kick-off meetings, available to station personnel, to emphasize site focus areas including Radiation Protection, Security, and Safety.
The RP presentation will include a discussion on the purpose of radiological postings and barriers and the expectation that these items not be moved without RP approval.
The kick-off meetings will be held Novembei 3, 1997.
NTS item 454-201 01702-01 will ensure the presentation addresses expectations for moving radiological postings and barriers.
2.
Comed has established a High Rad WIN Team to address the root cause of high radiation area compliance issues that have occurred in the company. These events included the movement of postings and barriers. The WIN team reviewed the cause and corrective actions of all high radiation area events occurring in the last two years.
The WIN team then proposed a standardized strategy to address compliance with high radiation area controls. The WIN team recognized a weakness in training workers on the purpose of high radiation area controls. As a result, a training video is in production and will be used as a tool to height <n worker awareness.
The video will be available in November.
NTS item 454-201-97-01702-02 tracks the presentation of the training video at department tailgates.
3.
The Comed Radiation Worker Handbook addresses the movement of radiological postings and barriers. The han6 book states that workers are not to remove or relocate items such as radiological postings, signs, ropes, or step off pads.
The handbook is dirtributed in NGET to all new employees and serves as an easy and readily accessible reference to answer worker's questions. Periodically, topics from the handbook are highlighted through station communications such as the daily newsletter, tailgates, and bulletin board postings.
The handbook is currently under revision and will be redistributed in October and November.
NTS item 454-201-97-01702-03 tracks the distribution of the handbook.
4.
To ensure that Radiation Protection is responding censistently when contacted by workers who are requesting to move a radiological posting or barrier, all Radiation Protection personnel will be trained on the proper response to these requests.
The proper response is for a member of Radiation Protection to assess the work site and determine the most ef fective way of meeting the worker's needs while maintaining regulatory compliance.
Any alterations to radiological controls will be made by Radiation Protection or under the direct supervision of Radiation Trotection.
NTS item 454-201-97-01701-04 will ensure this expectation is clearly stated in BRP 5010-1, " Radiological Posting and Labeling Requirementr."
and all Radiation Protection personnel, including all contracted RP personnel, are trained.
(pA97byhrs\\970250 doc)
4 5.
Radiation Protection also has programs it. place to ensure new employees are given expectations on radiological posting and barrier movement.
The expectations are given in initial NGET and contractor orientation training.
The Initial NGET lesson plan emphasizes the expectation to contact RP if a radiological posting or rope may need to be moved or adjusted.
Radiation Protection can then evaluate the best way to meet the needs of the worker and still maintain regulatory compliante.
In addition, during mockup training for initial NGET, radiation workers experience several practical field issues including donning and doffing of protective clothing, use of radiological barriers such as swing gates and rope, use of low dose waiting areas, and posting idertification. Mock up training has historically proven effective emphasizing expectations discussed during the classroo.n presentation.
All new contractor employees are given a presentation by RP management to address department expectations during orientation training. This presentation also informs workers to contact RP if a radiological postings and barriers needs to be moved because only RP is allowed to e.ove thess items.
The I
presentation also reinforces several topics given in NGET and the radiation worker handbook.
DATE WHEN TULL COMPLIANCE WILL BE ACHIEVED Full compliance for Event 1 was achieved on -Tanuary 24, 1997, when the proper high radiation area boundary was established.
Tull compliance for Event 2 was achievad on August 4, 1997, when the swing gate was returned t ; its proper location.
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