IR 05000454/1996008

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-454/96-08 & 50-455/96-08

ML20134J769
Person / Time
Site:	Byron
Issue date:	11/12/1996
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Graesser K COMMONWEALTH EDISON CO.
References
NUDOCS 9611180051
Download: ML20134J769 (2)

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November 12, 1996

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Mr. :

Site Vice President  !

Byron Nuclear Power Station i Commonwealth Edison Company ,

4450 North German Church Road

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Byron, IL 61010 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO. 50-454/96008(DRS);  !

50-455/96008(DRS))

Dear Mr. Graesser:

This will acknowledge receipt of your letter dated October 22, 1996,  ;

in response to our letter dated September 27, 1996, transmitting a Notice

, of Violation associated with the inadequate posting of a radiation area at the ,

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Byron Generating Station, Unitr. ! and 2. We have reviewed your corrective t

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actions and have no further questions at this time. These corrective actions i will be examined during future inspections. i l

Sincerely, Original Signed by Brent Clayton (for)  !

l Geoffrey E. Grant, Director Division of Reactor Safety

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l Docket Nos. 50-454, 50-455 l Licenses No. NPF-37, NPF-66

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Enclosure: Comed 1tr dtd 10/22/96 l l 1 l See Attached Distribution

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DOCUMENT NAME:G:DRS\BYR11Q 6.DRS To ,ecolwe e copy of this document inocete i~n Ee box: "C" = Copy without ettechment/ enclosure "E" = Copy with ettechment/ enclosure ,

"N" = No copy

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0FFICE RIII _ l6 RIII l Al RIII lu RIII fe. lC NAME S0rth:jp64) TKozak W RLarfsjkbury M 4 BCl ayt'on/GGrant DATE 11/ p; /96 11/ g /96 11/ 9 /96 11/r2./96 l OFFICIAL RECORD COPY  :

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' 9611190051 961112 I PDR ADOCK 05000454 G PDR

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. raesser -2-November 12, 1996 cc: D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer K. Kofron, Station Manager D. Brindle, Regulatory Assurance Supervisor I. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing cc w/ltr dtd 11/22/96: Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer, Wisconsin State Liaison Officer Chairman, Illinois Commerce Commission Distribution:

Docket File w/ encl RIII PRR w/ encl W. L. Axelson, RIII w/ encl PUBLIC IE-01 w/ encl SRIs, Byron, Braidwood, Enf. Coordinator, RIII w/ encl OC/LFDCB w/ enc 1 Zion w/ encl RAC1 w/ encl (E-mail)

DRP w/ encl LPM, NRR w/ encl CAA1 w/ encl (E-mail)

DRS w/ encl A. B. Beach, RIII w/ encl i

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. Lonunonucahh Ed: ion Compam

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H3 run Generatmg station 4450 North German Church Riud

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'i cl u t 4-2h44 et October 22, 1996 LTR: BYRON 96-0269 FILE: 1.10.0101

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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. 50-454/96008; 50-455/96008 NRC Docket Numbers 50-454, 50-455 REFERENCE: Geoffrey E. Grant letter to M dated September 27, 1996, transmitting NRC Inspection Report 50-454/96008; 50-455/96008 Enclosed is Commonwealtli Edison Company's response to the Notice of 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 response is provided in the attachment.

This letter contains t he following commitments:

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The entire Byron RPT group will be evaluatedi by Job Performance Measures, to determine whether or not this may be a Training or Attention to Detail issue, according to RP Policy 28, " Byron RP

- Dept. Self Assessments."

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Byron RP will determine if additional positive controls are needed in Low and High level tool storage areas, to prevent future occurrences.

3. RP and Training will track the Job Performance Measures being conducted to determine future Training requirements, if needed.

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The Byron Contracted RPT program Posting and Labeling Lesson Plans will be updated to include this event.

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Byron. Training Dept. will determine if this event should be included in the Generic Contracted RPT Program taught at PTC and in Contracted Decon Laborer Training..

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i Byron Ltr: 96-0269 October 22, 1996 $

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The following procedures will be added to RP required reading during 4th quarter Continuing Training: ,

BRP 5010-1, " Radiation Posting and Labeling Requirements" I i

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i BAP 720-3, " Control and Release of Materials in the RPA" .)

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Byron RP will determine the feasibility of posting all tool and equipment storage cages as Radiation Areas. f

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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. 2280. ,

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Respectfully, I i

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K. 'L. 'Grae er *

Site vice resident '

Byron Nuclear Power Station '

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l i-Attachment (s) ,

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A. B. Beach, NRC Regional Administrator - RlII G. F. Dick Jr., Byron Project Manager - NRR  !

S. D. Burgess, Senior. Resident Inspector, Byron

R. D. Lanksbury, Reactor Projects Chief - RIII )

F. Niziolek, Division of Rngineering - IDNS

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D. L. Farrar, Nuclear Regulatory Services Manager, Downers Grove Safety Review Dept, c/o Document Control Desk, 3rd Floor, Downers Grove l DCD-Licensing, Suite 400, Dowers Grove. )

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s VIOLATION (454/455-96008-01) . .

i 10 CFR 20.1902 (a) requires that the licensee post each radiat' ion area with a

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conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." {

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contrary to the above, on September 5,1996, the area outside the high level tool storage area.on the 346'

i elevation of the Auxiliary Building, a radiation area l

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with a radiation dose rate of approximately 'eight millirem in one hour at 30 cm }

from the surface that the radiation penetrated was not posted with a sign bearing j the radiation symbol and the words " CAUTION, RADIATION AREA."

[t This is a severity Level IV violation (Supplement I),

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REASON FOR TER VIOLATICM  :

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l A contracted Decontamination Laborer moved a barrel and vacuum cleaner out of the E high level tool storage area on the 346 elevation in the Auxiliary Building in order to move additional barrels into the area. When he moved them back into the cage location.

he placed them next to the cage boundary, not back to their original ~!

He was unaware of the Federal Regulations concerning storage of radioactive material. ,

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Comme m vs BTEPS TA N AMD RESULTS W MVED

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Radiation Protection, upon notification of the discrepancy, immediately  ;

surveyed the cage, and moved the equipment to a proper position in the l cage. '

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A re-creation of the scene was performed to determine exact dose rates and posting requirements. i 3.

The contracted RPT group was tailgated on posting and labeling * I l

requirements.

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Byron HPS notified the NRC Inspector of this investigation and the 1 procedural requirements of the High Level tool storage cages.

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The Byron RP department completed a survey sweep of all tool and equipment storage cages to insure proper postings and labelings.

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CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION 1.

The entire Byron RPT group will be evaluated, by Job Performance Measures, to determine whether or not this may be a Training or Attention to Detail issue, according to RP Policy 28, " Byron RP Dept.

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Self Assessments." NTS item 455-200-96-0009-01 will track this action.

2.

Byron RP will deternine if additional positive controls are needed in Low and High level tool storage areas, to prevent future occurrences.

NTS item 455-200-96-0009-02 will track this action.

3.

RP and Training will track the Job Performance Measures being conducted to determine future Training requirements, if needed. NTS item 455-200-96-0009-03 will track this action.

4.

The Byron Contracted RPT program Posting and Labeling Lesson Plans will be updated to include this event. NTS item 455-200-96-0009-04 will track this action. I 5. Byron Training Dept. will determine if this event should be included in the Generic Contracted RPT Program taught at PTC and in Contracted Decon Laborer Training. N",S item 455-200-96-0009-05 will track this action.

6.

The following procedures will be added to RP required reading during 4th quarter Continuing Training:

BRP 5010-1, " Radiation Posting and Labeling Requirements" BAP 720-3, " Control and Release of Materials in the RPA" NTS item 455-200-96-0009-06 will track this action.

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Byron RP will determine the feasibility of posting all tool and equipment storage cages as Radiation Areas. NTS item 455-200-96-0009-08 will track this action.

DATE WHEN FULL COMPLIANCE WI'LL BE ACHIEVED Pull compliance was achieved on 9/05/96 when material within the cage had been re-positioned and a re-survey of the area conducted to ensure radiation leiels were within the posting limits, e -

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