ML20236F580
| ML20236F580 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/29/1998 |
| From: | Graesser K COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-454-98-10, 50-455-98-10, BYRON-98-0196, BYRON-98-196, NUDOCS 9807020232 | |
| Download: ML20236F580 (8) | |
Text
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Commonw e.ttth lihwn Company a
Byron Generating Station 4450 North German Church Roatl liyrtni. ll. 610l O-9'9 6 TelHI5 14+5441 June 29, 1998 LTR:
BYRON 98-0196 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. 50-454/98010; 50-455/98010 i
i FRC Docket Numbers 50-454, 50-455
REFERENCE:
John A. Grobe letter to Mr. Kingsley dated May 28, 1998, transmitting NRC Inspection Report 50-454/98010; 50-455/98010
/
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 three (3) Severity Level IV violations requiring a written response.
Comed's response is provided in the attachment.
This letter contains the following commitment:
1)
Through various Audio and Visual tools, Radiation Protection
)
Department personnel are bringing che plant to the employee to advise the employee on good rad worker practices and why those practices will benefit everyone.
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.a 9007020232 900629 i
PDR ADOCK 05000454 G
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o Byron Ltr. 98-0196 June 29, 1998 Page 2 If your staff has any questions or comments concerning this letter, please refer them to D6n Brindle, Regulatory Assurance Supervisor, at (815)234-5441 ext.2280.
Respectfully.,'
)'
K.
L. Graesser Site Vice President Byron Nuclear Power Station KLG/DB/rp Attachment (s) l cc:
C. J.
Paperiello, Acting NRC Regional Administrator - RIII J. B. Hickman, Byron Project Manager - NRR E.
W.
Cobey, Senior Resident Inspector, Byron l
M.
J.
Jordan, Reactor Projects Chief - RIII F. Niziolek, Division of Engineering - IDNS I
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ATTACHMENT I i
VIOLATION (454/455-90010-01) 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."
Contrary to the above, on April 3, 1998, the radiologically posted area established for the sodium-24 used in the moisture carryover test, a radiation l
area with a radiation dose rate of approximately 10 millirem in one hour at 30 centimeters from the shipping / storage cask, was not posted with a sign bearing
- the radiation symbol and the words " CAUTION, RADIATION AREA."
(50-454/455-98010-01)
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION We agree with the violation. During the preparation for the Moisture carryover' Test on the new Unit 1 Steam Generators, the sodium-24 test source was received on-site.
An area was established to maintain positive controls over the source, which was measured at 10 millirem per hour at 30 centimeters.
The area was initially pre-staged with a yellow and magenta rope barrier and
" DANGER-HIGH RADIATION" postings (covered over) based on anticipated radiation levels when the source would be exposed. The source was received in its shielded storage container and moved into the pre-staged area.
Based on the Radiation Protection Technicians (RPT) survey, the area should have been posted " CAUTION-RADIATION AREA" however., the RPT left the area unposted. The area was left unposted due to the RPT's confusion over the existing posting and misapplication of the rules for posting as a radiation area.
Radiation Protection (RP) supervision questioned the RPT and learned that the area needed to be posted " CAUTION-RADIATION AREA" based on information provided.
Immediately, one RPT was sent to control the area while the
" CAUTION-RADIATION AREA" postings were gathered by another RPT to post the area properly.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The area was posted properly within 30 minutes of discovery of the posting omission.
2.
The Radiation Protection Technician involved was counseled on the expectations of roping and posting radiological areas as defined in BRP 5010-1, " Radiological Posting and Labeling Requirements," by RP supervision. Disciplinary actions were evaluated and executed by RP supervision, as necessary.
3.
The incident was discussed with all Radiation Protection personnel.
In j
addition, verbatim compliance with procedures has been emphasized.
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CORRECTIVE ~ STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
.1.
None.
DATE WHEN FULL COMPLIANCE'nTLL BE ACHIEVED-Full-compliance was achieved. on '4/03/98 when the posting. deficiency was corrected.
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ATTACHMENT II VIOLATION (454/455-98010-02a, b)
Technical Specification 6.11 requires that procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Byron Administrative Procedure BAP 720-3, Revision 18, dated October 27, 1997,
" Control of Materials for Conditional or Unconditional Release from Radiologically Posted Areas," Step C.4 states, that all items having the potential to be contaminated shall be unconditionally released or meet the conditional release requirements. The referenced procedure defines unconditional release as an article / material that has no detectable licensed radioactive material above background and defines conditional release as an article / material that is contaminated, or suspected to be contaminated, and is logged and controlled to prevent unauthorized use or removal and is returned to a permanent RPA (radiologically posted area) within 1 shift unless appropriate controls are established.
Contrary to the above, I
a.
On February 19, 1998, the licensee unconditionally released a radioactive material bag containing protective clothing having radioactive contamination at a level of 128,000 disintegrations per minute (50-4 54 /4 5 5-98 010- 02a) ; and b.
On February 25, 1998, the licensee unconditionally released a 480 volt panel that had 4,500 disintegrations per minute of removable contamination. (50-454/455-98010-02b)
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION a.
Protective clothing We agree with the violation. A Biohazard bag containing protective clothing was left in the Bechtel first aid office during disassembly of the. Containment Access Facility (CAF) at Byron Station.
The origin of the bag can be traced to an injury that occurred to a Bechtel craft person on 1/31/98 in which the individual's left leg was cut.
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The Biohazard bag was not properly disposed of at the time of the injury i
and was placed in the Bechtel Nurses Office sometime just prior to the CAF being dismantled (2/23/98) for shipment to Braidwood. Attempts to i
contact the' contract Radiation Protection Technician whose name appeared to match the initials on the bag were unsuccessful.
Byron personnel who were in the CAF just prior to its removal did not observe any Biohazard bags in the CAF.
b.
480 volt panel We agree with the violation. The electrical panel shipped to Braidwood L
was improperly surveyed by a contract Radiation Protection Technician.
l BRP 6020-3 and BAP 720-3 delineate both the frisker speed and distance, from an object, required for unconditional release of materials. The i
technician may have surveyed the item in question too quickly which caused him to miss the radioactivity and inappropriately release the
- panel, i
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED
[.
1.
All of the events were immediately corrected following discovery, i.e.,
the items were properly' controlled.
2.
All of the events were discussed with all Radiation Protection i
Department personnel.
l CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
Programmatic controls addressing unconditional release of materials were reviewed and found to be acceptable.
DATE WHEN FULL CCHPLIANCE WILL BE ACHIEVED l
a.
Protective clothing Full compliance was achieved on 4/1/98 when Braidwood Radiation Protection personnel took control of the material.
b.
480 volt panel Full compliance was achieved on 2/25/98 when Braidwood Radiation Protection personnel took control of the panel, i
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ATTACHMENT III VIOLATION (454/455-98010-05a, b, c)
Technical Specification 6.11 requires that written procedures for personnel radiation protection be prepared consistent with the requirements of 10 CFR 20 and be approved, maintained and adhered to for all operations involving personnel radiation exposure.
Radiation Protection Procedure BRP 5000-7, Revision 7, dated June 28, 1996,
" Unescorted Access To and Conduct In Radiologically Posted Areas," requires that each person entering a RPA (radiologically posted area) is responsible to adhere to the rules.
Step 3.z requires, in part, that workers avoid bad rad practices; they do not adjust glasses with outer rubber gloves, they do not touch thd r faces while in protective clothing, and they do not wear protective clothing partially unzipped.
Contrary to the above, (a)
On April 27, 1998, a worker inside of containment unzipped his protective clothing and reached inside to read his pager without removing his outer rubber gloves (50-454/455-98010-05a) ;
(b)
On April 27, 1998, two workers removing insulation inside of containment reached up and adjusted their glasses without removing their outer rubber gloves (50-454/455-98010-05b);
(c)
On April 30, 1998, a worker inside of containment rubbed his nose without removing his outer rubber glove.
(50-454/455-98010-05c)
This is a Severity Level IV violation (Supplement IV).
REASON FOR THE VIOLATION We agree with the violation.
In each of the instances cited in the violation, the workers exhibited misjudgment (habit intrusion), in that, they performed tasks mainly based on past experience without fully understanding the current situation (possible contamination).
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
The individuals' involved were counseled about their infractions at the I
time, advised to invoke the " attention to detail" philosophy and to utilize the Rad Worker practice training that they had received.
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2.
On May 2, 1998, RP Management issued Byron Letter 98-0143 which implemented a policy to address rad worker deficiencies in the field.
Individuals exercising poor rad worker practices are electronically
" locked out" of the RPA, and a Problem Identification Form (PIF) is written to document the issue. The worker and their supervisor are required to meet with the Radiation Protection Supervisor to discuss the inappropriate behavior prior to being allowed back into the RPA.
3.
Radiation Protection (RP) personnel continuously advise rad workers during pre-job briefs, on-the-job coverage, and greeter interfaces.
ALARA analysts were instructed to emphasize good rad worker practices during ALARA briefings.
4.
A new awareness campaign was put in place to increase radiation workers' sensitivity to proper radiation worker practices. Radiation Projections' " Easel Program" and " Focus Rad Tid Bits" (articles in the daily plant paper) are constant reminders that Radiation Protection is everyone's job and the articles incorporate both new topics and revisit problem areas that are trended by ongoing assessments.
5.
The Radiation Protection Laboratory Supervisor (RPLS) Plant Walkdown and Quality Assessment Policy 0006D has been amended to question and document whether radiological areas have been evaluated. The expectation on the frequency of this walkdown has been increased from three per month to four per month. This program gets RPLS's into the field to look over their pre-assigned areas and requires documenting findings on a routine basis. This program in the past has been a valuable tool in providing a current status of the plants material condition. The increase in frequency and expectation enhancements have been discussed with all RPLS's.
6.
Heightened awareness regarding rad worker practices in the field has been brought to the attention of Radiation Protection Technician's during second quarter re-qualification training.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.
Radiation Protection is taking an aggressive approach to " putting out the word" on rad worker practices. The plan is to attend tailgate meetings throughout the plant to promote " Rad Worker Good Practices," as RP would like to see used in the plant. Through various Audio and Visual tools, RP is bringing the plant to the employee to advise the employee on good rad worker practices and why those practices will benefit everyone. Maintenance and Construction Department personnel were immediately informed regarding poor rad worker practices on May 3, 1998.
Conduct of these presentations to station personnel will be a
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continuous process.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1.
Full compliance was achieved on 5/03/98 upon completion of " Rad Worker Good Practices" training given to Maintenance and Construction Department personnei.
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