ML20140J425

Responds to NRC Re Violations Noted in Insp Repts 50-454/97-03 & 50-455/97-03.Corrective Actions:Radiation Protection Mgt Reviewed Dept Expectations During Continuing Training Sessions

ML20140J425
Person / Time
Site:	Byron
Issue date:	05/05/1997
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-97-0106, BYRON-97-106, NUDOCS 9705140077
Download: ML20140J425 (7)

Text

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e Commonwealth Edmm Oimpan)

Ilyron Generating Station 4450 Wrth Ucrman Church Road 9 pyron, lL 610in9794 Tel H15-2M54 il 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. Graesser dated 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 ano 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 contain, 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 acditional training on identifying contamination hazards.

2) In addition to establishing priorities for decontamination activities, the RP Department will also assist Operating in ,l initiating been tagged.action requests for leaking equipment which has not yet -l- ~

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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. l }

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Byron Ltr. 97-0106 May 5, 1997 Page 2 l

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l If your staff has any questions or comments concerning this letter, please refer them to 9on Brindle, Regulatory Assurance Supervisor, at (815)234-5441 i ext.2280.

Respectfully, l

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)K. L. Gr as r l

. Site Vice P sident Byron Nuclear Power Station .

l KLG/DB/rp Attachment (s) cc: 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 Revie Dept, c/o Document Control Desk, 3rd Floor, Downers Grove DCD-Licensing, Suite 400, Downers Grove.

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',+ a ATTACHMENT I s

J VIOLATION (454/455-97003-02)

Technical Specification 6.8.l _ requires, in part, that written procedures shall be established,Jimplemented and maintained covering activitiosareferenced in I Appendix A of Regulatory C"ide 1.33, Revision 2, February 1978.

a. Regulatory Guide 1.33, Appendix A recommends that radiation 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 centimeters (an ) be posted with a sign that states." CAUTION, 2

CONTAMINATEC AREA."

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 which contained removable. contamination of 1,000 to 6,000 dpm per 100 cm2 were not posted with a sign.that stated, " CAUTION, CONTAMINATED AREA." (50-454/97003-02a and 50-455/97003-02a)

b. Regulatory Guide 1.33, Appendix A recommends that procedures be

. implemented which specify chemistry instructions and the 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 cubic centimeter gas vial be evacuated prior to containing a 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

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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 chendstry 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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REASON FOR THE VIOI.ATION

a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)

Per BRP 5010-1, " Radiological Posting and Labeling Requirements", areas 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 4 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 surveys of these areas due to a lack of attention to detail. BRP 6020-3, " Routine Plant Surveys", requires contamination surveys of work surfaces, equipment, and floors to support general access. However, the contamination surveys were not performed in sufficient detail to identify the contamination on the pump seals. It was apparent that the pump seals had leaked primary system water which after evaporation, resulted in a collection of dried boron which is a known contamination hazard.

The Radiation Protection Department is connCtted to maintaining high material conditio: standards in radiologically posted areas to ensure i 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 housekeeping practices, radiological hazards are reduced and personnel contamination events are mini.ed/ed.

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

The set-up of instrumentation and analysis for a gas sample was being ,

performed by two (2) Chemistry technicians. The gas vial was not evacuated due to a miscommunication between the technicians. The status of the analysis activities was not properly maintained.

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

Chemistry Department Policy 200-3 covers procedure acherence, 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.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Individual corrective actions with regard to the llotice of Violation is as follows:

a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)

1. To emphasize procedure compliance and material condition priorities, Radiation Protection management reviewed department expectations during continuing training sessions which concluded in March 1997. Fainted discussions on survey expectations focused on the importance of properly identifying and posting contamination hazards. All Radiation Protection Laboratory 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 l completed since management expectations were presented and no additional contaminated areas were found that were not posted,

b. Preparation of'5+;> Samples for Isotopic Analysis (50-454/455 97003-2b)

1. The chemistry technicians were copnseled 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 samplir: procedures in i HRSS ha a been placed in plastic. covers and marking pens will be ,

used to : ark steps.

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

1. None i

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' CORRECTIVii. MEPS 'THAT WILL BE TAKEN TO AVOID FURTHER VIOLATION '

a. Radiological Posting and Labeling Requirements (50-454/455 97003-02a)

'l. To assist Radiation Protection (RP) in identifying contamination control concerns as conditions in the plant change between routine surveys, operating personnel will receive adattional. training on identifying contamination nazerds. 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 40norols 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 eqaipment which has not yet been .

tagged. This will also assist RP in reducing repeat-decontamination by ensuring the cause of the leak is. addressed.'

TRR 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) l.l To meet'Rev alatory Guide 1.33, Appendix A requirements,. Chemistry 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. .NTSN 454-100-97-00302c-01 tracks this action.

-DATE WHEN FULL CcMPLIANCE WILL BE ACHIEVED

a. Radi" logical Posting and Labeling Requirements (50-454/.455 97003-02a)

Full compliance.was achieved on 3/4/97 when the proper boundaries and postings were placed around the affected areas.

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

i Full compliance was achieved on 3/5/97 when the gas sample and analysis {

was performed.in'accordance with the proredure.

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'c. Procedure Adherence Procedure (50-454/455 97003-2c) 1 Full compliance will be. achieved by 8/29/97 when the procedure is I completed, approved for use, and site personnel have been trained. This issue was initially identified in the Chemistry area, training for .

' Chemistry personnel will be. completed by 7/15/97.  ;

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• ATTACHMENT II

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VIOLATION (454/455-97003-04) ,  !

Technical Specification 6.8.4.d. requires that a program be implemented which will ensure the capability exists to obttin and analyze reactor coolant samples, radioactive iodine and particulate samples in plant gaseous effluents and conta'inment atmosphere samples under accident conditions.

Procedure BAP.560-10, " Byron Chemistry Post-Accident Program Description," Revision 2, dated December 2, 1996, requires, in part, that chemistry technicians receive semiannual training on the post accident sampling-system (PASS) and receive training on PASS procedures at least every six months.

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))

REASON FOR THE VIOLATION i

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 '

-changed to annually. BAP 560-10, " Byron Chemistry Post-Accident Program Description", was not revised to reflect the new requirements stated in BTP 300-29. '

b CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

-1. BAP 560-10 was revised to clarify the requirements of PASS training for  !

technicians.

2. Chemistry and Training personnel performed a review to assure that other >

training requirements are consistent between the, administrative and

. raining procedures.  ;

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

1. None DATE WHEN FULL CcNPLIANCE WILL BE ACHIEVED Full compliance was achieved on 4/29/97 with the completion of the revision to BAP 560-10.

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