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| {{Adams | | {{Adams |
| | number = ML20148T159 | | | number = ML20216B093 |
| | issue date = 07/03/1997 | | | issue date = 08/28/1997 |
| | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03 on 970404 | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03 Issued on 970703 |
| | author name = Grobe J | | | author name = Grobe J |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
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| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9707080405 | | | document report number = 50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9709050227 |
| | title reference date = 05-05-1997 | | | title reference date = 08-04-1997 |
| | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE |
| | page count = 2 | | | page count = 2 |
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| {{#Wiki_filter:4, Od | | {{#Wiki_filter:.__ ._ |
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| July 3, 1997 l
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| Mr. Site Vice President Byron Station Commonwealth Edison Company ' | | Oc0 |
| 4450 N. German Church Road Byron, IL 61010 | | . |
| | August 28, 1997 Mr. Site Vice President Byron Station l Commonwealth Edison Company 1 4450 N. German Church Road Byron, IL 61010 l |
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| ==Dear Mr. Graesser:== | | ==Dear Mr. Graessor:== |
| l SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(DRS);
| | SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(DRS); |
| 50-455/97003(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. , | | This will acknowledge receipt of your letter dated August 4,1997, in response to our letter dated July 3,1997, requesting clarification of corrective actions for a Notice of i Violation associated with activities at the Byron Generating Station, Unhc 1 and 2. ' |
| We have reviewed your corrective actions for this violation and have no further questions ' | | Specifically, the second violation contained in the Notice of Violation concerned the f ailure to train chemistry personnel on the post accident sampling systern at a sb month freqJency required by chemistry procedures. In your previous response d; ed Mry 5, 1997, you stated that your staff revised the applicable procedure to clarify the training requirements and to reduce the frequency of training from six months to twelve-months, which appeared to be inconsistent with previous commitments to the NRC. We have reviewed your rnsponse dated August 4,1997, and have no further questions at this time. |
| at this time. These corrective actions will be examined during future inspections. | |
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| i 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 this response, you indicated that your staff had performed an evaluation to change the commitment to the NRC in 1993 but did not notify the NRC of the intended change Consequently, this response provided the notification of that change, The corrective actions for this violation and your evaluation for the change in the commitment to the NRC will be examined during future inspections, |
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| 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 ,
| | Sincerely, Original Signed b.v John M. Jacobson (for) |
| transmitted to the NRC. The letter indicated that training on procedures used to obtain }
| | John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-454; 50 455 License Nos. NPF 37; NPF 66 I g |
| post accident samples, which were not used in obtaining routine samples, would occur at least every 6 months. Subsequently, the NRC relied upon that information to evaluate the
| | Enclosure: Ltr dtd 08/04/97, K. L. Graesser, Comed, to USNRC M {\ |
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| | DOCUMENT NAME:G:/DRS/BYR08287.DRS |
| ,I adequacy of your post accident sampling capabilities. By our records, you have not notified the NRC of any intended change to the above commitment.
| | *C' = Copy without ettechment/ enclosure *E' = Copy with ettechment/ enclosure 4,.ce[.. |
| | , e copy of thle document,lndicate in the ben: |
| | 0FFICE. Rlli e Rlll c Rlll Rill A n,l NAME S0rth:jp D C' GShear 6 d. RLanskbury Qh t. JGrobe R F DATE 08/as/97 08/2t /97 08/2(, /97 08/4.X NU U OFF1CIAL RECORD GOPY 9709050227 970828 PDR |
| | {{kk!\\II.\kII,k 1 . |
| | G ADOCK 05000454 .6 *' |
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| 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.
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| 99 Ch llI.lli .lil.lil.lll.lll!.Ill.El.li 9707080405 970703 PDR ADOCK 05000454 G PDR
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| | K. Graesser 2 August 28,1997 cc w/o encl: T. J. Malman, Senior Vice President, Nuclear Operations Dlvision |
| * 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.
| | 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/ encl: Document Control Desk Licensing Richard Hubbard Nathan Schloss, Economist Office of the Attorney General Stato Liaison Officer, Wisconsin State Liaison Officer Chairman, Illinois Commerce Commission Distribution: |
| | | Docket File w/ encl SRis, Byron, Braidwood, R. A. Capra, NRR w/ encl PUBLIC IE-01 w/enci Zion w/enci TSS w/enci OC/LFDCB w/enci LPM, NRR w/encI DOCDESK w/onci DRP w/onct A. B. Beach, Rlll w/enci CAA1 w/enci DRS w/ encl J. L. Caldwell, Rlll w/enci Rill PRR w/onct Rlli Enf. Coordinator w/enct |
| Sincerely
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| Original Signed by Melvyn Leach (for)
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| John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-454; 50-455 Licenses Nos. NPF-37; NPF-66 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:
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| 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
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| *N* = No copy 0FFICE RIII le RIII c RIII l x) Rill [c NAME S0rth:jp # GShear 646 RLanskbury @ $ JGrobe #- 6 4--
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| DATE 07/l /97 07/ / /97 07/.3 /97 07/ 3 /97 Ott1C1AL RLCOMU CDPY
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| | _ - - -_________ __________________ - _ _ _ _ _ _ _ _ . |
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| Commonw ealth 1.dmn Compan)
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| y lh run Generating station
| | ( AlfilllHH1WL'allh lall%nft (WHHpAH) |
| . 4 450 North (scrnun (.hurch Road
| | *. Ih run Utnrra:6ng htathast j 4 450 Nonh German Churt h kitd |
| * | | , lh run, IL 610109794 101814 244%44l August'4, 1997 LTR BYRON 97 0105 FILE: 1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention Document Control Desk |
| lh run.1161010-9 91 | | . |
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| | Subject: Byron Nuclear Power Station Units 1 and 2 Response to Request for corrective Action Clarification Inspection Report No. 50-454/97003; 50-455/97003 NRC Docket Numbers 50-454, 50-455 References 1) Geoffrey E. Grant letter to Mr. Graesser dated April 4, 1997, transmitting NRC Inspection Report 50 454/97003; 50 455/97003 2) Mr. Graesser letter to NRC Document Control Desk dated May 5, 1997, transmitting Response to Notice of Violation Inspection Report No. 50-454/97003; 50 455/97003 3) John A. Grobe letter to Mr. Graesser dated July 3, 1997, transmitting request for clarifying information regarding corrective actions to findings in NRC Inspection Report 50-454/97003; 50 455/97003 - |
| TclH142 M 5441 May 5, 1997 LTR: BYRON 97-0106 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 ,
| | Enclosed is Commonwealth Edison Company's response to the request for corrective action clarification which was transmitted in Reference 3. Thio letter cited inconsistencies between our proposed corrective actions noted in our response to the Notice of Violation (Reference 2) and previous commitments to the NRC, and asked for clarification. Comed's response is provided in the Attachment 1. Fomal notification of changes to commitmente made in the T.R. |
| I 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.
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| This letter contains the following commitments:
| | Tramm letter, dated January 5, 1984, is included in Attachment II. |
| 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.
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| 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 l been tagged.
| | A l'niconn Compan) |
| | SN Y$ $ tf #, _ _ _ _ |
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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.
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| 'If your staff has any questions or comments concerning this letter, please l refer them to Don Brindle, Regulatory Assurance Supervisor, at (815)234-5441 :
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| ext.2280. t
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| Respectfully, d<)
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| l l- 3K. L. Gr ss l' Site Vice P sident l Byron' Nuclear Power Station !
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| R Attachment (s )
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| 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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| l Safety Review Dept, c/o Document Control Desk, 3rd Floor,LDowners Grove-DCD-Licensing, Suite 400, Downers Grove. +
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| | Byron Ltr. 97 01t5 August 4, 1997 Page 2' |
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| | If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Reguletory Assurance Supervisor, at (815)234 5441 ext.2200. |
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| ' | | Respectt'ully, i |
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| | K. L. Gr a r , |
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| | Site Vice resident Byron Nuclear Power Station K14/DB/rp |
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| | .Sttachment(s) |
| | cci A. L. 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 F. Nisio"ak, |
| | . Division of Engineering - IDNS D, L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept,-c/o Document Control Desk, 3rd Floor, Downers Grove DCD Licensing, Suite 400, Downers Grove.- |
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| | L ATTACIDENT I In regards to your concern that the changa in post accident sampling system (PASS) training f requency, f rom 6-months to 12-nonths, may not be consistent with previous commitments to the NRC, we agree. |
| ATTACHNENT I VIOLATION (454/455-97003-02)
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| 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. j i
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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. -
| | In an October 26, 1982 letter from T.R. Tramm of the Commonwealth Edison Ccmpany to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operacion ot' the post accident sampling system. Retraining will be given as necessary to maintain competence (ninimum yearly). |
| 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 ;
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| equal to 1000 disintegrations per minute (dpm) per 100 square. l centimeters ( cm ) be posted with a sign that states " CAUTION, a
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| CONTAMINATED AREA."
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| I 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 j which contained removable contamination of 1,000 to 6,000 dpm per J 100 cm2 were not posted with a sign that stated, " CAUTION, ,
| | During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it difficult to a,ssure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R. |
| CONTAMINATED AREA." .(50-454/97003-02a and 50-455/97003-02a) l
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| b. Regulatory Guide 1.33, Appendix A recommends that procedures.be implemented which specify chemistry instructions and the j calibration of laboratory instruments.
| | Tramm of the commonwealth Edison Company to H. R. Denton of the Office of Puclear Regulatory Regulation, commitments for periodic training and re-training of technicians on the post accident sampling system were transmitted to the NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtaining routine samples, would occur at least every 6 months. |
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| Procedure BCP 300-62, " Preparation of Gas Samples for Isotopic ,
| | The Radiation Chemistry Department was reorganized in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the PASS, so only annual review of non-routine activities should be required. In 1993, Byron Station believed that a change from the semi-annual review of procedures did not require a formal submittal to the NRC and could be accomplished through the 10CFR50.59 safety evaluation process. A 50.59 safety evaluation was performed for the PASS in 1993, and procedures containing training requirements changed. |
| Analysis," Revision 4, dated November 14, 1996, requires that a 15 I cubic centimeter gas vial be evacuated prior to containing a i sample.
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| 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)
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| c. Regulatory Guide 1.33, Appendix A recommends that procedures be established which cover procedure adherence.
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| Contrary to the above,.as of March 3, 1997, the licensee had not established procedures which cover adherence to chemistry g procedures. (50-454/97003-02c and 50-455/97003-02c). i This is'a Severity Level IV Violation (Supplement I).
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| (50-454/455-97003-02a, b, c(DRS))
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| . i REASON FOR THE VIOLATION ,
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| a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a) ;
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| Per BRP 5010-1, " Radiological Posting and Labeling Requirements", areas l 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".
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| Contrary to this requirement, Radiation Protection did not post the 1/2A ;
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| Chemical and Volume Control (CV) Pumps, the 2A Safety Injection (SI)
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| Pump, and the 2A Residual Heat ~ Removal (RHR) Pump as contaminated areas.
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| 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-L 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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| ; identify the contamination on the pump seals. It was apparent that the f pump seals had leaked primary system water which after evaporation,' l
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| ! resulted in a collection of dried boron which is a known contamination l hazard.
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| The Radiation Protection Department is committed to maintaining high material condition standards in radiologically posted areas to ensure j
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| minimal radiological impediments to safety related equipment. To !
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| achieve this goal, aggressive goals have been established for minimizing contaminated area square footage in the plant. By maintaining good ,
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| l housekeeping practices, radiological hazards are reduced and personnel. 1 l contamination events are minimized.
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| b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b) j I
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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 L evacuated due to a ndscommunication between the technicians. The status | |
| ! of the analysis activities was not properly maintained.
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| !J c. Procedure Adherence Procedure (50-454/455 97003-2c)
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| l Chemistry Department Policy.200-3~ covers procedure adherence,
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| . additionally Site Policy Memo 200-14 governs the use'of procedures.
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| 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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| l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED LIndividual corrective actions with regard to the Notice of Violation is as follows:
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| a. -Radiological Posting and Labeling Requirements (50-454/455 97003-02a) i 1. To emphasize procedure compliance and material condition
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| . 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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| contamination hazards. All Radiati'on Protection Laboratory
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| . Supervisors and Technicians attended this training.
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| 2. 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.
| | Attachment !! |
| | | Dyron station wou)d like to revise NRC commitments regarding post accident sampling system (PASS) procedure review and performance requirements. Station procedures and processes have changed since the commitments were made, warranting an update to the commitments. |
| b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
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| 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.
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| 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.
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| c. Procedure Adherence Procedure (50-454/455 97003-2c)
| | We are reducing the required training because technicians maintain proficiency with the sample panels by using the PASS for routine sampling. Some of the PASS procedures are nearly identical to other sampling procedures with minor valve lineup changes. We will require technicians to perform or witness the performance of those procedures that include use of non routine equipment and procedures over the course of a year. These procedures have been moved from the Byron Emergency Response (BZP series) procedures into the Byron Chemistry (BCP series) procedures and include: |
| 1. None CORRECTIVE STEPS THAT WILL BE TAIGN TO AVOID FURTHER VIOLATION a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
| | BCP 300 11 Post Accident Sampling of Undiluted Reactor Coolant BCP 380-12, Post Accident sampling of Diluted Reactor Coolant BCP 380 15, Stripped Gas Sampling Of Post Accident Reactor Coolant BCP 380 16, Post Accident Diluted Reactor Coolant /Radwaste Sample Disposal BCP 380-18, Post Accident sampling of containment Atmosphere We will also review required procedures annually, rather than every 6 months. |
| 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.
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| 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.
| | These procedures include those listed above and also: |
| | | BCP 380-10, Post Accident Sampling of Reactor Coolant, Radwaste, and Containment Air General BCP 300 17, Post Accident Sample Transfer from Primary Samplu Room The following procedures were referenced in the T.R. Tramm lettor to H.R. 2 Denton dated January 5, 1984 as requiring semi-annual training. These procedures cover sampling liquid radwaste which are not requi"Sd to meet post |
| TRP 97-809 will track training RP on submitting action requests.
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| b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
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| 1. None
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| c. Procedure Adherence Procedure (50-454/455 97003-2c)
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| 1. To meet Regulatory Guide 1.33, Appendix A requirements,. Chemistry I personnel, along with office Support personnel, are developing a procedure usage procedure. The new procedure BAP 1310-10,
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| " 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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| a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)
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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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| J b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)
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| | accident sampling as described in the UFSAR. These procedures do not require annual training. |
| 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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| J 4 Full compliance will be achieved by 8/29/97 when the procedure is completed, approved for use', and site personnel have been trained. This issue was initially identified in the Chemistry area, training for
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| Chemistry personnel will be completed by 7/15/97.
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| | BCF 380-13, Post Accident Sampling of Undiluted Liquid Radwaste DCP '.80-14, Post Accident Sampling of Dilute Radwaste Procedure BZP 300 A7 was also referenced .in the aforementioned letter and has been incorporated in?o BCP 300-17, Post Accident sampling Transfer from Trimary Sample Room. |
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| | In an October 26, 1982 letter from 4.R. Tramm of the Commonwealth Edison company to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operation of the post accident samplirg system. Retrai.ing will be given as necessary to maintain competence (minimum yearly). |
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| , e ATTACHMENT II '
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| VIOLATION (454/455-97003-04)
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| Technical Specification 6.8.4.d requires that a program be implemented which 4 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 i and containment atmosphere samples under accident conr'itions.
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|
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| , Procedure BAP 560-10, " Byron Chemistry Post-Accident Program Description," Revision 2, dated December 2, 1996, requires, in part, j
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| , that chemistry technicians receive semiannual training on the. post 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)
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| This is a Severity Level IV violation (Supplement I). ,
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| (50-454/455-97003-04(DRP)) !
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| l l
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| 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 I changed to annually. BAP 560-10, " Byron Chemistry Post-Accident Program l Description", was not revised to reflect the new requirements stated in BTP l-300-29. 1 l
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| l 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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| l 2. Chemistry and Training personnel performed a review to assure that other training requirements are consistent between the administrative and training procedures.
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| CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION
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| 1. None 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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| (p: \ 97byltrs\ 970106.wp f \7)
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| ! ; .Y ;-n C:mm:nwealth Edison Ons hast Nahonal Plasa Checapo. In.no s
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| Address Reply solost Oif20 DDM 2 ! Chicago. Ithnois 60690 l 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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| { Washington, DC 20555 i
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| l Subject Byron Generatlng Statlon Units 1 and 2
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| ! Braidwood Generating Station Units 1 and 2
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| !
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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 to H. R. Denton.
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| ' (b): October 26, 1982 letter from T. R. Tramm to | |
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| H. R. Denton.
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| !; Osar Mr. Denton
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| i This letter provides supplemental information regarding the i periodic training to be provided to Byron /Braldwood rad / chem technicians for post-accident sampling procedures. This revises information provided in reference (b).
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| t 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
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| -
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| procedures are not used in obtaining and routine samples. The following special retralning will be completed by all radiation-chemistry j technicians at least every six months:
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| 1. Review the following procedures BZP 380-10 " Post accident samplin of reactor coolant, redweste and containment air-genera .
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| BZP 380-11 " Post accident sampling of undiluted reactor coolant."
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| BZP 380-12 " Post accident sampling of diluted reactor coolant."
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| BZP 380-13 " Post accident sampling of undiluted liquid radwaste."
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| DZP 380-14 " Post accident sampling of diluted radweste."
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| BZP 380-15 " Stripped-gas sampling of post accident reactor coolant."
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| 0 4 A PDR h
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| . _ _ _ _ _ . - _ . . _ . _ _ . _ _ _ . .. .
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| yor*
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| IT g
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| ;. 1 H. R. Denton -2- January 5, 1984
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| | During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it diffleult to assure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R. |
| i BZP 380-16 " Post accident diluted reactor coolant /radweste sample l disposal."
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| BZP 380-17 " Post accident sample transfer from primary sample room."
| | Tramm of the Commonwealth Edison company to H. R. Denton of the CfCice of Nuclear Regulatory Regulation, commitments for periodic training and re-train $ng of technicians on the post accident sampling system were transmitted to thu NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtair.ing routine samples, would occur at least every 6 months. |
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| BZP 380-18 " Post accident sampling of containment atmosphere. room."
| | The Radiation-Chemisstry Department was reorganised in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the Pass, so only annual review of non-routine activities should be required. |
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| BZP 380-A7 " Post accident sample transport routes."
| | Byron 9tation feels that revising these commitments will reduce the burden on Training and Chemistry with no reduction in capability of performing the required tasks. |
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| 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.
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| | | (pt\97byltts\970185.wif) |
| Please direct further questions regarding this matter to this office.
| | _ _ _ - - - - |
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| Very truly yours, fik&
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| T. R. Tramm Nuclear Licensing Administrator 1m l
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| 7921N l '
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| }} | | }} |
Similar Documents at Byron |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P6171999-10-21021 October 1999 Forwards non-proprietary & Proprietary Versions of HI-982083, Licensing Rept for Byron & Braidwood Nuclear Stations. Proprietary Rept Withheld,Per 10CFR2.790(b)(4) ML20217M2871999-10-21021 October 1999 Refers to Rev 5 Submitted in May 1999 for Portions of Byron Nuclear Power Station Generating Stations Emergency Plan Site Annex.Informs That NRC Approval Not Required Based on Determination That Plan Effectiveness Not Decreased ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217F7891999-10-0808 October 1999 Forwards Insp Repts 50-454/99-12 & 50-455/99-12 on 990803- 0916.One Violation Occurred Being Treated as NCV ML20217B6351999-10-0505 October 1999 Forwards for Info,Final Accident Sequence Precursor Analysis of Operational Event at Byron Station,Unit 1,reported in LER 454/98-018 & NRC Responses to Util Specific Comments Provided in ML20212L1791999-10-0505 October 1999 Informs That as Result of Staff Review of Util Responses to GL 92-01,rev 1,suppl 1 & Suppl 1 Rai,Staff Revised Info in Rvid & Is Releasing Rvid Version 2 ML20217B2991999-10-0101 October 1999 Forwards Insp Repts 50-454/99-16 & 50-455/99-16 on 990907-10.No Violations Noted.Water Chemisty Program Was Well Implemented,Resulted in Effective Control of Plant Water Chemistry ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr ML20212J6751999-09-30030 September 1999 Forwards Replacement Pages Eight Through Eleven of Insp Repts 50-454/99-15 & 50-455/99-15.Several Inaccuracies with Docket Numbers & Tracking Numbers Occurred in Repts ML20217A5821999-09-29029 September 1999 Advises of NRC Plans for Future Insp Activities at Facility for Licensee to Have Opportunity to Prepare for Insps & to Provide NRC with Feedback on Any Planned Insps Which May Conflict with Plant Activities ML20216F8051999-09-17017 September 1999 Forwards Insp Rept 50-454/99-14 & 50-455/99-14 on 990823-27. 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[Table view] Category:OUTGOING CORRESPONDENCE
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Security Program Was Effectively Implemented in Areas Inspected.No Violations Were Identified ML20211P1841999-09-0808 September 1999 Forwards Insp Repts 50-454/99-15 & 50-455/99-15 on 990824- 26.No Violations Noted.Objective of Insp to Determine Whether Byron Nuclear Generating Station Emergency Plan Adequate & If Emergency Plan Properly Implemented ML20211Q6821999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Byron Operator Licesne Applicants During Wks of 000619 & 26.Validation of Exam Will Occur at Station During Wk of 000529 ML20211N5151999-09-0303 September 1999 Ack Receipt of Re Safety Culture & Overtime Practices at Byron Nuclear Power Station.Copy of Recent Ltr from NRC to Commonwealth Edison Re Overtime Practices & Safety Culture Being Provided ML20211K1081999-09-0202 September 1999 Responds to Request for Addl Info to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity, for Braidwood,Units 1 & 2 & Byron,Unit 2 ML20211M1371999-09-0202 September 1999 Discusses 990527 Meeting with Ceco & Byron Station Mgt Re Overtime Practices & Conduciveness of Work Environ to Raising Safety Concerns at Byron Station.Insp Rept Assigned for NRC Tracking Purposes.No Insp Rept Encl ML20211G4021999-08-25025 August 1999 Forwards Insp Repts 50-454/99-10 & 50-455/99-10 on 990622-0802.No Violations Noted ML20211B8691999-08-20020 August 1999 Forwards Insp Repts 50-254/99-10,50-265/99-10,50-454/99-09, 50-455/99-09,50-456/99-10 & 50-457/99-10 on 990628-0721. Action Plans Developed to Address Configuration Control Weaknesses Not Totally Effective as Listed ML20210A3151999-07-16016 July 1999 Forwards Insp Repts 50-454/99-08 & 50-455/99-08 on 990511-0621.Three Violations Being Treated as Noncited Violations ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20196K0161999-06-30030 June 1999 Discusses 990622 Meeting at Byron Nuclear Power Station in Byron,Il.Purpose of Visit Was to Meet with PRA Staff to Discuss Ceco Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA Staff ML20212H8241999-06-24024 June 1999 Informs That Effective 990531 NRC Project Mgt Responsibility for Byron & Braidwood Stations Was Transferred to Gf Dick ML20207G0601999-06-0707 June 1999 Provides Updated Info Re Number of Failures Associated with Initial Operator License Exam Administered from 980914-0918. NRC Will Review Progress Wrt Corrective Actions During Future Insps ML20207G0421999-06-0404 June 1999 Forwards Insp Repts 50-454/99-04 & 50-455/99-04 on 990330-0510.Violations Identified & Being Treated as non-cited Violations ML20207E5451999-05-28028 May 1999 Forwards Insp Repts 50-454/99-07 & 50-455/99-07 on 990517-20.No Violations Noted.Fire Protection Program Was Effective ML20207B6361999-05-25025 May 1999 Forwards SE Accepting Revised SG Tube Rupture (SGTR) Analysis for Bryon & Braidwood Stations.Revised Analysis Was Submitted to Support SG Replacement at Unit 1 of Each Station ML20206U3471999-05-20020 May 1999 Forwards Insp Rept 50-454/99-05 on 990401-22.No Violations Noted.Insp Reviewed Activities Associated with ISI Efforts Including Selective Exam of SG Maint & Exam Records, Calculations,Observation of Exam Performance & Interviews ML20207A2151999-05-19019 May 1999 Forwards Insp Repts 50-454/99-06 & 50-455/99-06 on 990419-23.No Violations Noted.Insp Consisted of Review of Liquid & Gaseous Effluent Program,Radiological Environmental Monitoring Program,Auditing Program & Outage Activities ML20207B8751999-05-18018 May 1999 Responds to Ltr Dtd 990225,expressing Concerns That Low Staffing Levels & Excessive Staff Overtime May Present Serious Safety Hazards at Some Commercial Nuclear Power Plants in Us ML20206N4791999-05-13013 May 1999 Forwards RAI Re 980529 Amend Request for Byron & Braidwood to Credit Automatic PORV Operation for Mitigation of Inadvertent SI at Power Accident.Response Requested 60 Days After Receipt Date ML20206J1981999-05-0505 May 1999 Forwards Exam Answer Key for Forms a & B,Grading Results for Facility & Copies of Individual Answer Sheets for Each Individual Taking Gfes of Written Operator Licensing Exam Administered by NRC on 990407.Without Encls ML20206E7021999-05-0303 May 1999 Advises That Info Contained in Document Entitled, Licensing Rept for Sf Rack Installation at Byron & Braidwood Stations, HI-982083,will Be Withheld from Public Disclosure Per 10CFR2.790 ML20206D0361999-04-28028 April 1999 Confirms Plans to Have Meeting on 990527 in Lisle,Illinois to Discuss Results of Ceco Evaluation on Potential Chilling Effect Concern within Working Environ & Use of Overtime within Operations Dept Organization at Byron Station ML20205Q2621999-04-14014 April 1999 Forwards Insp Repts 50-454/99-03 & 50-455/99-03 on 990217-0329.Five Violations Identified & Treated as Ncvs. Expresses Continued Concern with Configuration Control & Human Performance Errors at Byron Station ML20206U3261999-03-29029 March 1999 Forwards RAI Re 981208 Response & Suppls to NRC Re Use of Overtime in Byron Station Operations Dept.Response Requested within 30 Days of Date of Ltr ML20196K8821999-03-26026 March 1999 Advises of Completion of Plant Performance Review on 990201 to Develop Integrated Understanding of Safety Performance. Overall Performance Acceptable.Plant Issues Matrix & Insp Plan Encl ML20205B4901999-03-26026 March 1999 Forwards SER Authorizing Util 981022 Relief Requests 12R-24, Rev 0,which Requests Deferral of Rv shell-to-flange Vessel Weld Exam to End of Second 10-year Insp Interval,Pursuant to 10CFR50.55a(a)(3)(ii) & 12R-34,rev 0 ML20204G3641999-03-19019 March 1999 Forwards Safety Evaluation & Technical Ltr Rept Re Second 10-yr Interval ISI Request for Relief 12R-11,rev 2.Licensee Proposed Alternative to code-required Pressure Test Authorized for Current Interval ML20204E2631999-03-18018 March 1999 Discusses Review of Ceco Evaluation of Chilling Effect on Byron Station Personnel.Identified Number of Questions Re Ceco Findings & C/As.Requests Further Evaluation of Chilling Effect at Byron Be Conducted & Response to Encl Questions ML20204D1971999-03-16016 March 1999 Discusses Review of Revision 4Q to Portions of Licensee Emergency Plan Site Annex ML20204B6721999-03-12012 March 1999 Forwards Copy of Preliminary Accident Sequence Precursor Analysis of Operational Condition Discovered at Plant on 980912 ML20207K1861999-03-11011 March 1999 Discusses Review of Rev 4P to Portions of Byron Power Station EP Site Annex.Based on Determinations That Changes Do Not Decrease Effectiveness of EP & Plan Continues to Meet Standards of 10CFR50.47(b),NRC Approval Not Required ML20207J5201999-03-10010 March 1999 Forwards Insp Repts 50-454/99-02 & 50-455/99-02 on 990105-0216.No Violations Noted.Expresses Concern Re Trend of Configuration Control & Human Performance Errors at Byron Station ML20203G7981999-02-11011 February 1999 Forwards Insp Repts 50-454/99-01 & 50-455/99-01 on 990119-22.No Violations Noted.Insp Involved Exam of Maint & Engineering Related Activities for Electrical Circuit Breakers ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20203C9861999-02-0808 February 1999 Ack Receipt of ,Which Transmitted Changes Identified as Rev 52 to Security Plan.No NRC Approval Required ML20202H9401999-02-0303 February 1999 Informs That Update of Set Number 58 of UFSAR Has Been Completed.Confirmation Sheet Providing Update Encl ML20199H8561999-01-19019 January 1999 Discusses Insp Repts 50-454/98-25 & 50-455/98-25 on 981124-990104 & Forwards Nov.Violation Identified Involving Unacceptable Preconditioning of Stroke Time Testing of AFW Pump Discharge Valves ML20199E8861999-01-15015 January 1999 Discusses Two Unresolved Security Items Identified in Sections S3.b1 & S3.b2 of Insp Repts 50-454/98-03 & 50-455/98-03,dtd 980211.One Item Re Adequacy of Alarm Sys Testing When Two Alarm Zones Were Returned to Svc ML20198N8261998-12-30030 December 1998 Forwards Insp Repts 50-454/98-24 & 50-455/98-24 on 981130- 1204.No Violations Noted.Purpose of Insp Was to Determine If Licensed Operator Requalification Training Activities Conducted IAW with NRC Requirements ML20198J0211998-12-18018 December 1998 Forwards Insp Repts 50-454/98-20 & 50-455/98-20 on 981006- 1123.No Violations Noted ML20198F4451998-12-17017 December 1998 Forwards Insp Repts 50-454/98-23 & 50-455/98-23 on 981116-14.No Violations Noted.Purpose of Insp Was to Verify Accuracy of Licensee Response to Region III Questions Re Grid Stability ML20206N4431998-12-10010 December 1998 Forwards Security Insp Repts 50-454/98-22 & 50-455/98-22 on 981116-20.No Violations noted.Challenge-testing of Some Detection Equipment Showed Some Vulnerabilities That Util Indicated Would Be Corrected 1999-09-08
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August 28, 1997 Mr. Site Vice President Byron Station l Commonwealth Edison Company 1 4450 N. German Church Road Byron, IL 61010 l
Dear Mr. Graessor:
SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(DRS);
50-455/97003(DRS))
This will acknowledge receipt of your letter dated August 4,1997, in response to our letter dated July 3,1997, requesting clarification of corrective actions for a Notice of i Violation associated with activities at the Byron Generating Station, Unhc 1 and 2. '
Specifically, the second violation contained in the Notice of Violation concerned the f ailure to train chemistry personnel on the post accident sampling systern at a sb month freqJency required by chemistry procedures. In your previous response d; ed Mry 5, 1997, you stated that your staff revised the applicable procedure to clarify the training requirements and to reduce the frequency of training from six months to twelve-months, which appeared to be inconsistent with previous commitments to the NRC. We have reviewed your rnsponse dated August 4,1997, and have no further questions at this time.
In this response, you indicated that your staff had performed an evaluation to change the commitment to the NRC in 1993 but did not notify the NRC of the intended change Consequently, this response provided the notification of that change, The corrective actions for this violation and your evaluation for the change in the commitment to the NRC will be examined during future inspections,
Sincerely, Original Signed b.v John M. Jacobson (for)
John A. Grobe, Acting Director Division of Reactor Safety Docket Nos. 50-454; 50 455 License Nos. NPF 37; NPF 66 I g
Enclosure: Ltr dtd 08/04/97, K. L. Graesser, Comed, to USNRC M {\
DOCUMENT NAME:G:/DRS/BYR08287.DRS
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0FFICE. Rlli e Rlll c Rlll Rill A n,l NAME S0rth:jp D C' GShear 6 d. RLanskbury Qh t. JGrobe R F DATE 08/as/97 08/2t /97 08/2(, /97 08/4.X NU U OFF1CIAL RECORD GOPY 9709050227 970828 PDR
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K. Graesser 2 August 28,1997 cc w/o encl: T. J. Malman, Senior Vice President, Nuclear Operations Dlvision
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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/ encl: Document Control Desk Licensing Richard Hubbard Nathan Schloss, Economist Office of the Attorney General Stato Liaison Officer, Wisconsin State Liaison Officer Chairman, Illinois Commerce Commission Distribution:
Docket File w/ encl SRis, Byron, Braidwood, R. A. Capra, NRR w/ encl PUBLIC IE-01 w/enci Zion w/enci TSS w/enci OC/LFDCB w/enci LPM, NRR w/encI DOCDESK w/onci DRP w/onct A. B. Beach, Rlll w/enci CAA1 w/enci DRS w/ encl J. L. Caldwell, Rlll w/enci Rill PRR w/onct Rlli Enf. Coordinator w/enct
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, lh run, IL 610109794 101814 244%44l August'4, 1997 LTR BYRON 97 0105 FILE: 1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention Document Control Desk
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Subject: Byron Nuclear Power Station Units 1 and 2 Response to Request for corrective Action Clarification Inspection Report No. 50-454/97003; 50-455/97003 NRC Docket Numbers 50-454, 50-455 References 1) Geoffrey E. Grant letter to Mr. Graesser dated April 4, 1997, transmitting NRC Inspection Report 50 454/97003; 50 455/97003 2) Mr. Graesser letter to NRC Document Control Desk dated May 5, 1997, transmitting Response to Notice of Violation Inspection Report No. 50-454/97003; 50 455/97003 3) John A. Grobe letter to Mr. Graesser dated July 3, 1997, transmitting request for clarifying information regarding corrective actions to findings in NRC Inspection Report 50-454/97003; 50 455/97003 -
Enclosed is Commonwealth Edison Company's response to the request for corrective action clarification which was transmitted in Reference 3. Thio letter cited inconsistencies between our proposed corrective actions noted in our response to the Notice of Violation (Reference 2) and previous commitments to the NRC, and asked for clarification. Comed's response is provided in the Attachment 1. Fomal notification of changes to commitmente made in the T.R.
Tramm letter, dated January 5, 1984, is included in Attachment II.
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Byron Ltr. 97 01t5 August 4, 1997 Page 2'
If your staff has any questions or comments concerning this letter, please refer them to Don Brindle, Reguletory Assurance Supervisor, at (815)234 5441 ext.2200.
Respectt'ully, i
K. L. Gr a r ,
Site Vice resident Byron Nuclear Power Station K14/DB/rp
.Sttachment(s)
cci A. L. 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 F. Nisio"ak,
. Division of Engineering - IDNS D, L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept,-c/o Document Control Desk, 3rd Floor, Downers Grove DCD Licensing, Suite 400, Downers Grove.-
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L ATTACIDENT I In regards to your concern that the changa in post accident sampling system (PASS) training f requency, f rom 6-months to 12-nonths, may not be consistent with previous commitments to the NRC, we agree.
In an October 26, 1982 letter from T.R. Tramm of the Commonwealth Edison Ccmpany to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operacion ot' the post accident sampling system. Retraining will be given as necessary to maintain competence (ninimum yearly).
During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it difficult to a,ssure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R.
Tramm of the commonwealth Edison Company to H. R. Denton of the Office of Puclear Regulatory Regulation, commitments for periodic training and re-training of technicians on the post accident sampling system were transmitted to the NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtaining routine samples, would occur at least every 6 months.
The Radiation Chemistry Department was reorganized in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the PASS, so only annual review of non-routine activities should be required. In 1993, Byron Station believed that a change from the semi-annual review of procedures did not require a formal submittal to the NRC and could be accomplished through the 10CFR50.59 safety evaluation process. A 50.59 safety evaluation was performed for the PASS in 1993, and procedures containing training requirements changed.
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Dyron station wou)d like to revise NRC commitments regarding post accident sampling system (PASS) procedure review and performance requirements. Station procedures and processes have changed since the commitments were made, warranting an update to the commitments.
We are reducing the required training because technicians maintain proficiency with the sample panels by using the PASS for routine sampling. Some of the PASS procedures are nearly identical to other sampling procedures with minor valve lineup changes. We will require technicians to perform or witness the performance of those procedures that include use of non routine equipment and procedures over the course of a year. These procedures have been moved from the Byron Emergency Response (BZP series) procedures into the Byron Chemistry (BCP series) procedures and include:
BCP 300 11 Post Accident Sampling of Undiluted Reactor Coolant BCP 380-12, Post Accident sampling of Diluted Reactor Coolant BCP 380 15, Stripped Gas Sampling Of Post Accident Reactor Coolant BCP 380 16, Post Accident Diluted Reactor Coolant /Radwaste Sample Disposal BCP 380-18, Post Accident sampling of containment Atmosphere We will also review required procedures annually, rather than every 6 months.
These procedures include those listed above and also:
BCP 380-10, Post Accident Sampling of Reactor Coolant, Radwaste, and Containment Air General BCP 300 17, Post Accident Sample Transfer from Primary Samplu Room The following procedures were referenced in the T.R. Tramm lettor to H.R. 2 Denton dated January 5, 1984 as requiring semi-annual training. These procedures cover sampling liquid radwaste which are not requi"Sd to meet post
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accident sampling as described in the UFSAR. These procedures do not require annual training.
BCF 380-13, Post Accident Sampling of Undiluted Liquid Radwaste DCP '.80-14, Post Accident Sampling of Dilute Radwaste Procedure BZP 300 A7 was also referenced .in the aforementioned letter and has been incorporated in?o BCP 300-17, Post Accident sampling Transfer from Trimary Sample Room.
In an October 26, 1982 letter from 4.R. Tramm of the Commonwealth Edison company to H.R. Denton of the Office of Nuclear Regulatory Regulation, commitments for periodic training and testing of the post accident sampling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible for operation of the post accident samplirg system. Retrai.ing will be given as necessary to maintain competence (minimum yearly).
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During initial plant operation, the Radiation Protection and Chemistry Departments were combined. The Radiation Chemistry Technicians had a larger scope of job responsibilities, making it diffleult to assure all technicians routinely used the sample panels. In a January 5, 1984, letter from T. R.
Tramm of the Commonwealth Edison company to H. R. Denton of the CfCice of Nuclear Regulatory Regulation, commitments for periodic training and re-train $ng of technicians on the post accident sampling system were transmitted to thu NRC. The letter indicated that training on procedures used to obtain post accident samples, which were not used in obtair.ing routine samples, would occur at least every 6 months.
The Radiation-Chemisstry Department was reorganised in 1988, and the job responsibilities for technicians were redefined providing a more narrow scope for Chemistry Technician duties. Chemistry Technicians receive extensive practice in collecting routine samples from the Pass, so only annual review of non-routine activities should be required.
Byron 9tation feels that revising these commitments will reduce the burden on Training and Chemistry with no reduction in capability of performing the required tasks.
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