ML20217G610

Forwards Response to Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03.Corrective Actions:Retraining Will Be Given as Necessary to Maintain Competence

ML20217G610
Person / Time
Site:	Byron
Issue date:	08/04/1997
From:	Graesser K COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-454-97-03, 50-454-97-3, 50-455-97-03, 50-455-97-3, BYRON-97-0185, BYRON-97-185, NUDOCS 9708070323
Download: ML20217G610 (5)

Text

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, Commonwealth 1:di+n Compan)

Ilyron Generating Station e

4450 Nonh German Church Road Ily ron, 11.61019 979i '

Tel M142H 5441 August 4, 1997 LTR: BYRON 97-0185 FILE: 1.10.0101 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk t

Subject:

Byron Nuclear Power Station Units 1 and 2 Respense to Request for Corrective Action Clarification Inspection Report No. 50-454/97003; 50-455/97003 NRC Docket Numbers 50-454, 50-455

Reference:

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. 60-454/97003; 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  !

l Enclosed is Commonwealth Edison Company's responso to the request for corrective action clarification which was transmitted in Reference 3. This letter cited inconsistencies between our proposed corrective actions noted in # .O 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 I. Formal notification.of changes to commitments made in the T.R.

Tramm letter, nated January 5, 1984, is included in Attachment II.

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Byron Ltr. 97-0185 August 4, 1997 Page 2 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.

Respectfully, i

K. L. Or e r Site Vice President j Byron Nuclear Power Station KLG/DB/rp Attachment (s) ccr A. B. 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 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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ATTACHMENT I In regards to your concern that the change in post accident sampling system (PASS) training frequency, from 6-months to 12-months, may not be consistent with previous commitments to the NRC, we agree.

In an October 26, 1982 letter from T.R, Traum of the Commonwealth Edison Company to H.R. Denton of the Office of Nuclear Regulatory Regulation, l

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 sampling system. Retraining will be given as necessary to maintain competence (minimum 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 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 Office of Nuclear 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 i 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 requira 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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Attachment II Byron station would 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 F.yron Emergency Response (BZP series) procedures into the Byron Chemistry (BCP series) procedures and include:

BCP 380-11, 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 Peactor Coolant /Radwaste Sample Disposal BCP 300-18, Post Accident Sampling Of Containment Atmosphere i

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 380-17, Post Accident Sample Transfer from Primary Sampla Room The following procedures were referenced in the T.R. Tramm letter to H.R.

Denton dated January 5, 1984 as requiring semi-annual training. These procedures cover sampling liquid radwaste which are not required to meet post accident sampling as described in the UFSAR. These procedures do not require annual training.

BCP 380-13, Post Accident Sampling of Undiluted Liquid Radwaste BCP 380-14, Post Accident Sampling of Dilute Radwaste Procedure BZP 380-A7 was also referenced in the aforementioned letter and has been incorporated into BCP 380-17, Post Accident Sampling Transfer from Primary Sample Room.

In an October 26, 1982 letter from T.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 se.mpling system were transmitted to the NRC. The letter indicated formal initial training will be given to all personnel responsible fot operation of the post accident sampling system. Retraining 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 difficult 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 office of Nuclear 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.

Byron Station 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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