IR 05000454/1998021

Insp Repts 50-454/98-21 & 50-455/98-21 on 981013-16.No Violations Noted.Major Areas Inspected:Alara Planning & Radiation Work Permit Programs & Whole Body Counting & Screening Programs

ML20155K274
Person / Time
Site:	Byron
Issue date:	11/05/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155K272	List: IR 05000454/1998021 ML20155K267
References
50-454-98-21, 50-455-98-21, NUDOCS 9811130159
Download: ML20155K274 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

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i Docket Nos: 50-454;50-455 License Nos: NPF-37; NPF-66  !

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Report Nos: 50-454/98021(DRS); 50-455/08021(DRS)

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Licensee: Commonwealth Edison Company (Comed)

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' Facility: Byron Generating Station, Units 1 & 2 i Location: 4450 North German Church Road Byron,IL 61010  ;

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Dates: October 13-16,1998 i

inspector: K. Lambert, Radiation Specialist  !

L D. Nissen, Radiation Specialist  !

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Approved by: Gary Shear, Chief, Plant Support Branch 2 i .. Division of Reactor Safety

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9811130159 981105 PDR ADOCK 05000454 G PDR .

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EXECUTIVE SUMMARY Byron Generating Station, Units 1 & 2 NRC Inspection Reports 50-454/98021; 50-455/98021 This routine inspection of the radiation protection program included the ALARA planning and radiation work permit programs, and whole body counting and screening programs. The following conclusions were mad The as-low-as-is-reasonably-achievable (ALARA) planning and radiation work permit programs were effectively implemented. The radiation protection staff was actively involved in the work planning process to ensure that radiation protection goals and concerns were addressed (Section R1.1).

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The whole body counter and pre-screening monitoring programs were effectively implemented. Cognizant individuals were knowledgeable regarding use and calibration of the whole body counters and pre-screening monitors, and calibrations were performed in accordance with station procedures (Section R1.2).

. Lack of communication between radiation protection and radwaste staffs and the lack of management oversight of radioactive waste processing, resulted in poor housekeeping in the radioactive waste building (Section R2.1).

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Report Details IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 As-Low-As-Is-Reasonablv-Achievable Plannino and Radiation Work Permit Proarams Insoection Scope (IP 83750)

The inspectors reviewed the station's program for performing as-low-as-is-reasonably-achievable (ALARA) reviews and the development of radiation work permits (RWPs).

This included a review of applicable procedures, ALARA plans and RWPs, and discussions with cognizant individual Observations and Findinos The inspectors' review of station procedures indicated that procedures were sufficiently detailed and were consistent with industry guidance. A member of the ALARA group, responsible for RWP preparations, attended the station's work planning meetings to ensure that the radiation protection staff was aware of upcoming wor The station's procedures required that work groups initiate an RWP request 8 - 12 weeks before the scheduled work dates. The RWP coordinator is responsible for reviewing requests and ensures that radiological surveys are performed of the work area. Once surveys are completed, the overall dose for the job is estimated. The procedures required that an ALARA review be completed forjobs with a total dose greater than one person-rem. Jobs that required a formal ALARA review also required a pre-job briefing. In addition, the ALARA group began an initiative to perform micro ALARA planning of alljobs with a dose estimate greater than 100 millirem (mrem). The

' micro ALARA planning included a detailed review of the task for the job, the use of mockups and shielding, worker involvement in the ALARA planning and actions to reduce the dos The inspector's reviewed several RWPs and ALARA reviews prepared during the B2R07 refueling outage. ALARA plans were detailed and incorporated lessons teamed from previous job evolutions. ALARA plans were attached to the RWPs and special instructions were included in the RWPs. RWPs were appropriately completed and provided applicable radiation protection information. Specialinstructions in RWPs were used to communicate hold points, radiation protection continuous coverage, or specific cautions regarding the work to be performed. RWPs, ALARA reviews, and surveys were all filed together as a work package, this aided in retrieving data for job history and lessons learne . _ _ . ._ _ _ _ _ _ _ _ _ _ _ _ _ .

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. . . .. Conclusions The ALARA planning and RWP programs were effectively implemented. The radiation protection (RP) staff was actively involved in the work planning process to ensure that radiation protection goals and concerns were addresse R1.2 Whole Body Countina and Screenino Proaram Inspection Scope (IP 83750}

The inspectors reviewed the calibrations for the whole body counter (WBC) and the pre-screening monitoring programs. This included a review of applicable procedures, calibration records and discussions with cognizant individual Observations and Findinas The licensee used Eberline PM-7 personnel monitors with a count time of less than 30 seconds as a pre-screening tool for determining if internal contamination existe Entrance and exit pre-screening was performed on employees and contractora. Pre-screening was also performed on workers for cause (i.e. had facial contamination 2 were involved in a work evolution where inhalation or ingestion of radioactive materials was possible). If a worker alarmed the PM-7 then a whole body count would be performed to determine what isotopes were present and to quantify the dose. The PM-7 monitors were calibrated every six months as required using a cobalt-60 source and were source checked before use with a plant smear of approximately 30 nanocuries (nCi) activity. The WBC calibration was performed every 18 months by personnel from the Commonwealth Edison corporate offices. Calibrations were technically sound, performed as required, and the sources used were appropriate. A previous review of the WBC quality control program was documented in NRC inspection report 50-454/455-9701 Conclusions The whole body counter and pre-screening monitoring programs were effectively implemented. Cognizant Individuals were knowledgeable regarding the use of the whole body counters and pre-screening monitors, and calibrations were performed in accordance with station procedure R2 Status of RP&C Facilities and Equipment R Radioloaical Postinas. Labelina. and Housekeepina Insoection Scope (IP 83750)

The inspectors performed walkdowns of the radiologically posted areas (RPAs) in order to review radiological postings, labeling of containers, housekeeping and material condition of radiation protection equipmen _ _ _ _ _ _ _ _ _ __

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. Observations and Findinas The inspectors observed that radiological postings and boundaries in the RPAs were generally well maintained. The inspectors verified, through independent measurements, that radiological postings reflected the actual area radiological conditions. Containers in the auxiliary building were labeled in accordance with station procedures and regulatory (

requirements. Material condition of radiation protection equipment was goo l Housekeeping in the auxiliary building was also good,

' During walkdowns of the radioactUe waste (radwaste) building, the inspectors noted a large amount of processed radwaste stored in a non contaminated area of the buildin The inspectors noted that some of these bags were not labeled, while others had holes in them. Dates on some bags were from ' June 1998, indicating that radwaste had been accumulating for several months. The inspectors also noted a large amount of processed radwaste stored in a contaminated area of the building and a third large area of radioactive waste waiting to be processe Discussion with RP supervisors revealed that radwaste workers were to notify the RP staff when radwaste was brought to the building in order for RP to survey and label the waste. RP supervisors indicated that they knew waste was being brought to the radwaste building, but were not notified by the workers. Because they were not notified, surveys were not performed. The inspectors noted that this demonstrated both a lack of initiative on the part of RP and a lack of communication between the RP and radwaste staffs. In addition, the workers who processed waste had been assigned to perform work at the settling pond. Without additional workers assigned to process waste, the amount of unprocessed waste had built up, adding to the overall poor appearance of the are Station management indicated that responsibility for radwaste had recently been transferred to the chemistry department. The inspectors discussions with both RP management and Chemistry management revealed that there had been a lack of managemen: oversight in this area. Specifically, no management or supervisors had toured or been h this area for several week The inspectors informed station management that a lack of attention to processing and storage of radwaste led to the poor housekeeping condition of the radwaste buildin Station management acknowledged and agreed with the inspectors' conclusion Station management's immediate actions were to ensure bags were labeled and re-bagged those bags with holes, in addition, corrective actions included obtaining a sea-land container for storing the radwaste bags until they could be shipped to a radwaste processor, Station management was evaluating additional long term actions to prevent recurr- ' * ice corrective actions were not completed, the processing of radwaste and ran sto building housekeeping will be reviewed during a future inspection (Inspection Follow-up item (IFI) 50/454/98021-01(DRS); 50-455/98021-01(DRS)).

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l Conclusions Lack of communication between radiation protection and radwaste staffs and the lack of management oversight regarding the processing of radwaste and condition of the area, resulted in poor housekeeping in the radwaste buildin R8 Miscellaneous RP&C lasues R (Closed) Insoection Follow-up Item (IFI) 50-455/98010-04: While performing a turbine lube oil flush, the hose that was transporting oil disconnected and sprayed oil onto all levels of the turbine building. About 500 gallons of oil went into the condenser. The inspectors reviewed the results of the cleanup of the oil. Chemistry personnel performed a thorough assessment to determine how to remove the oil and to establish oil and grease levels that would be acceptable for startup. It was determined that if oil and grease levels were below one part per million, there would be no impact to the water quality of the unit and no Electric Power Research Institute (EPRI) action levels exceeded. The predetermined cleanup level for residual oil and grease was achieved during the cleanup, and no problems were identified with the water quality because of this event. This item is close .

R8.2 (Closed) Licensee Event Report (LER) 50-455/98-003: During the Unit 2 shutdown, when the reactor cavity was being flooded, the area radiation monitors alarmed on a high radiation signal. Dose rates peaked at about 650 milliroentgens per hour (mR/hr)

at the surface of the cavity due to high levels of cobalt-58 (Co-58). The licensee had implemented the routine shutdown template devised by Byron and Braidwood station The template included direction for the addition of hydrogen peroxide to initiate a crud burst and a cleanup regime that removed the crud from the system. The licensee's )

investigation identified that low letdown flow during the cleanup (after the crud burst)

was a contributor to the high radiation dose rates. The letdown flow was only at a rate of about 50 gallons per minute (gpm). However, letdown flow rates had historically been i about 80 gpm or higher. The inspectors discussed this event with chemistry personnel

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who indicated that during the cleanup they had requested maximum flow from operations who had responded that approximately 50 gpm was maximum flow. The investigation identified two causes of the event. The first was inadequate cleanup analysis, due to poor communications between chemistry and operations. The second failure involved poor controls for reactor cavity flood up. The EPRI recommended limit for soluble Co-58 was 0.05 microcuries per milliliter (uCi/ml). The chemistry procedure did not adequately evaluate the consequences of not following the EPRI recommendations. The corrective actions included developing a formalinterface between chemistry and operations personnel, revision of the procedures and a method to correlate Co-58 levels to approximate doses at the cavily surface after flood up. The inspectors reviewed the completed corrective actions which appeared appropriate. This item is close R8.3. (Closed)IFl 50-455/98010-03: During the Unit 2 shutdown, when the reactor cavity was  !

being flooded, the area radiation monitors alarmed on a high radiation signal. The licensee issued an event report regarding this issue, and all subsequent actions are documented in section R8.2. This item is close l

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R8.4 (Closed) Violation NIO) 50-454/98009-05 and 50-455/98009-05: The inspectors reviewed the implementation of corrective actions for a violation concerning the failure to j post a contaminated area properly The inspectors performed walkdowns in the 1 auxiliary building to observe the posting of contaminated areas as well as other radiological postings. The inspectors noted that radiological rope boundaries established around contaminated areas were appropriate and in accordance with NRC regulations and station procedures. No problems with posting of contaminated areas were identified. This item is close i

R8.5 (Closed) VIO 50-454/98008-02 and 50-455/98008-02: The inspectors reviewed the  !

effectiveness of the licensee's corrective actions for a violation concerning the failure to adhere to chemistry procedures. The inspectors observed a chemistry technician obtain ;

a reactor coolant system sample and noted that there had been much improvement in i chemistry technician performance and procedure adherence. No new examples were .

identified. This item is close l X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the i conclusion of the inspection on October 16,1998. The licensee acknowledged the findings presented.

The licensee did not identify any information discussed as being proprietar I

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. 1 PARTIAL LIST OF PERSONS CONTACTED Licensee B. Adams, Regulatory Assurance Manager J. Bauer, Radiation Protection Manager R. Colglazier, NRC Coordinator D. Herrmann, Radwaste/ Chemistry i J. Kuczynski, Technical Lead, Health Physics l W. Levis, Station Manager

! W. McNeill, Operational Lead, Health Physics E. Roche, Nuclear Oversight - Downers Grove i NRC E. Cobey, Senior Resident inspector INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 92904 Followup- Plant Support 1 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-454/455-98021-01 IFl Lack of attention to processing radwaste and poor housekeeping in the radwaste buildin Closed 50-455/98010-04 IFl Oilin the condense /98-003 LER During the Unit 2 shutdown, when the reactor cavity was being flooded, the area radiation monitors alarmed on a high radiation signa /98010-03 IFl Shutdown chemistry alarmed radiation monitor /455-98009-05 VIO Failure to post the contamination area in accordance with procedure /455-98008-02 VIO Failure to follow chemistry procedure Discussed None

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LIST OF ACRONYMS USED ALARA As Low As is Reasonably Achievable Co-58 Cobalt-58 EPRI Electric Power Research Institute gpm' Gallons per Minute IF Inspection Follow-up item LER Licensee Event Report uCi/mi Microcurie per Milliliter mrem fAillirem .

mR/hr Milliroentgens per Hour nCi Nanocurie NRC Nuclear Regulatory Commission PlF Problem identification Form ,

RP Radiation Protection -

- RPA Radiologically Posted Area RWP Radiation Work Permit radwaste Radiological Waste VIO Violation

- WBC- Whole Body Counter  ;

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LIST OF DOCUMENTS REVIEWED  ;

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Radiation Protection Department Policy Statement, Micro ALARA Planning BAP 700-1, Rev. 8, ALARA Program BAP 700-2, Rev.14, ALARA Action Review  !

BAP 575-9, Rev. 7, Radiation Work Permit Program 4 l

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BAP 720-3, Rev. 20, Control of Materials for Conditional or Unconditional Release from 1 Radiologically Posted Areas l

i BAP 700-T1, Rev.11, ALARA Action Review, ALARA Brief Checklist BRP 5010-1, Rev. 4, Radiological Posting and Labeling Requirements )

BRP 6200-5, Rev.7, Writing Radiation Work Permits 1 BRP 6200-5TB, Rev. 7, Radiation Work Permit ALARA Recommendation Checklist LER 50/455-98003 i

PIF B1998-03971 I PlF B1998-03731 PIF B1998-03643 PlF B1998-03835 ,

l PlF B1998-04254 RWP Request 98003141 l

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RWP 980201, Rev 2, Robotics Activities Calibration records for the Eberline PM-7 and WBC i 10 r