IR 05000454/1997003

Ack Receipt of 970505 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03 on 970404

ML20148T159
Person / Time
Site:	Byron
Issue date:	07/03/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Graesser K COMMONWEALTH EDISON CO.
References
50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, NUDOCS 9707080405
Download: ML20148T159 (2)

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July 3, 1997 l

Mr. Site Vice President Byron Station Commonwealth Edison Company '

4450 N. German Church Road Byron, IL 61010

Dear Mr. Graesser:

l SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-454/97003(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. ,

We have reviewed your corrective actions for this violation and have no further questions '

at this time. These corrective actions will be examined during future inspections.

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 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 ,

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. Subsequently, the NRC relied upon that information to evaluate the

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,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.

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.

99 Ch llI.lli .lil.lil.lll.lll!.Ill.El.li 9707080405 970703 PDR ADOCK 05000454 G PDR

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• July 3, 1997 .

If you have any questions concerning this request, please contact Mr. Steven Orth of my staff at (630) 829-9827.

Sincerely

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Original Signed by Melvyn Leach (for)

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:

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

• N* = No copy 0FFICE RIII le RIII c RIII l x) Rill [c NAME S0rth:jp # GShear 646 RLanskbury @ $ JGrobe #- 6 4--

DATE 07/l /97 07/ / /97 07/.3 /97 07/ 3 /97 Ott1C1AL RLCOMU CDPY

Commonw ealth 1.dmn Compan)

y lh run Generating station

. 4 450 North (scrnun (.hurch Road

lh run.1161010-9 91

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 ,

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.

This letter contains the following commitments:

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.

2) In addition to establishing priorities for decontamination activities, the RP Department will also assist Operating in

, initiating action requests for leaking equipment whi;h has not yet l been tagged.

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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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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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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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KLG/DB/rp -

R Attachment (s )

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 '

F.'Niziolek, Division of Engineering - IDNS. ,

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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ATTACHNENT I VIOLATION (454/455-97003-02)

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

Regulatory Guide 1.33, Appendix A recommends that radiation

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protection procedures be implemented which cover contamination control. -

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 ;

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."

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, ,

CONTAMINATED AREA." .(50-454/97003-02a and 50-455/97003-02a) l

b. Regulatory Guide 1.33, Appendix A recommends that procedures.be implemented which specify chemistry instructions and the j calibration of laboratory instruments.

Procedure BCP 300-62, " Preparation of Gas Samples for Isotopic ,

Analysis," Revision 4, dated November 14, 1996, requires that a 15 I cubic centimeter gas vial be evacuated prior to containing a i sample.

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)

c. Regulatory Guide 1.33, Appendix A recommends that procedures be established which cover procedure adherence.

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).

(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)  ;

Per BRP 5010-1, " Radiological Posting and Labeling Requirements", areas l with removable contamination greater than 1000 dpm/100 cm are required

to be posted with a sign that states, " Caution Contaminated Area".

Contrary to this requirement, Radiation Protection did not post the 1/2A ;

Chemical and Volume Control (CV) Pumps, the 2A Safety Injection (SI)

Pump, and the 2A Residual Heat ~ Removal (RHR) Pump as contaminated areas.

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  !

contamination surveys were not performed in sufficient detail'to J

identify the contamination on the pump seals. It was apparent that the f pump seals had leaked primary system water which after evaporation,' l

! resulted in a collection of dried boron which is a known contamination l hazard.

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  !

achieve this goal, aggressive goals have been established for minimizing contaminated area square footage in the plant. By maintaining good ,

l housekeeping practices, radiological hazards are reduced and personnel. 1 l contamination events are minimized.

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 '

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.

!J c. Procedure Adherence Procedure (50-454/455 97003-2c)

l Chemistry Department Policy.200-3~ covers procedure adherence,

. additionally Site Policy Memo 200-14 governs the use'of procedures.

Personnel had improperly relied on policies and memos in lieu of an approved procedure for providing guidance on-adherence'to procedures.

l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED LIndividual corrective actions with regard to the Notice of Violation is as follows:

a. -Radiological Posting and Labeling Requirements (50-454/455 97003-02a) i 1. To emphasize procedure compliance and material condition

. priorities, ' Radiation Protection ' management . reviewed department expectations during continuing training sessions which concluded

. in March 1997. Pointed discussions on survey expectations focused

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on the importance of properly identifying and posting .

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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.

b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)

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.

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.

c. Procedure Adherence Procedure (50-454/455 97003-2c)

1. None CORRECTIVE STEPS THAT WILL BE TAIGN TO AVOID FURTHER VIOLATION a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)

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.

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.

TRP 97-809 will track training RP on submitting action requests.

b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)

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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,

" Procedure Use and Adherence", will be applicable to all Site

, 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.  ;

J b. Preparation of Gas Samples for Isotopic Analysis (50-454/455 97003-2b)

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Full compliance was achieved on 3/5/97 when the gas sample and analysis was performed in accordance with the procedure. .

, c. Procedure Adherence Procedure (50-454/455 97003-2c)

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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, e ATTACHMENT II '

VIOLATION (454/455-97003-04)

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 ,

samples, radioactive iodine and particulate samples in plant gaseous effluents i and containment atmosphere samples under accident conr'itions.

, Procedure BAP 560-10, " Byron Chemistry Post-Accident Program Description," Revision 2, dated December 2, 1996, requires, in part, j

, 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)

This is a Severity Level IV violation (Supplement I). ,

(50-454/455-97003-04(DRP))  !

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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

l CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1. BAP 560-10 was revised to clarify the requirements of PASS training for technicians. .

l 2. Chemistry and Training personnel performed a review to assure that other training requirements are consistent between the administrative and training procedures.

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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! ; .Y ;-n C:mm:nwealth Edison Ons hast Nahonal Plasa Checapo. In.no s

Address Reply solost Oif20 DDM 2 ! Chicago. Ithnois 60690 l January 5, 1984

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Mr. Harold R. Denton, Director

Office of Nuclear Reactor Reculation U.S. Nuclear Regulatory Commission

{ Washington, DC 20555 i

l Subject Byron Generatlng Statlon Units 1 and 2

! Braidwood Generating Station Units 1 and 2

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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).

t The Byron /Braldwood post-accident sampling system is the same

! sampling system used for routine sampling operations. Only a few special

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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:

1. Review the following procedures BZP 380-10 " Post accident samplin of reactor coolant, redweste and containment air-genera .

BZP 380-11 " Post accident sampling of undiluted reactor coolant."

BZP 380-12 " Post accident sampling of diluted reactor coolant."

BZP 380-13 " Post accident sampling of undiluted liquid radwaste."

DZP 380-14 " Post accident sampling of diluted radweste."

BZP 380-15 " Stripped-gas sampling of post accident reactor coolant."

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i BZP 380-16 " Post accident diluted reactor coolant /radweste sample l disposal."

BZP 380-17 " Post accident sample transfer from primary sample room."

BZP 380-18 " Post accident sampling of containment atmosphere. room."

BZP 380-A7 " Post accident sample transport routes."

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.

Please direct further questions regarding this matter to this office.

Very truly yours, fik&

T. R. Tramm Nuclear Licensing Administrator 1m l

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