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Insp Repts 50-454/96-08 & 50-455/96-08 on 960903-06. Violations Noted.Major Areas Inspected:Review of Control of Radioactive Matls & Posting of Radiological Hazards within Auxiliary Bldg & Unit 2 Containment Bldg
	ML20129E870
Person / Time
Site:	Byron
Issue date:	09/27/1996
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20129E844	List: ML20129E838; ML20129E863; ML20129E870;
References
	50-454-96-08, 50-454-96-8, 50-455-96-08, 50-455-96-8, NUDOCS 9610030314
	Download: ML20129E870 (7)
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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket Nos: 50-454, 50-455

' Licenses No: NPF-37, NPF-66

Reports No: 50-454/96-08, 50-455/96-08

Licensee: Commonwealth Edison Company (Comed)

Facility: Byron Generating Station, Units 1 & 2

Location: Opus West III

1400 Opus Place

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Down'ers Grove, IL 60515

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Dates: September 3 - 6, 1996

Inspectors: S. K. Orth, Radiation Specialist

D. B. Hart, Radiation Specialist

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Approved by: Thomas J. Kozak, Acting Chief

Plant Support Branch 2

9610030314 960927

PDR ADOCK 05000454

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Report Details

IV. Plant Support

R1 Radiological Protection and Chemistry (RP&C) Controls

RI.1 Control of Radioactive Materials and Radioloaical Surveys

a. Inspection Scope (83750)

The inspectors reviewed the control of radioactive materials and the

posting of radiological hazards within the Auxiliary Building (AB) and

the Unit 2 Containment Building. The inspectors made frequent tours of

the radiologically posted areas and reviewed radioactive material

labelling and radiological postings.

b. Observations and Findinas

During tours of the Unit 2 Containment Building, the inspectors noted

good control and labelling of radioactive materials. The inspectors

found high and very high radiation areas to be posted and controlled in

accordance with NRC requirements.

During a tour of the AB, the inspectors identified a weakness in the

control of radioactive material (RAM) and the posting of a radiation

area. During a verification of radiation levels in the vicinity of a

posted radiation area on the 346' level of the AB, the inspectors

measured 15 mrem /hr on contact with the boundary and 8 mrem /hr at 30 cm

from the boundary. Following the inspectors' observations, a radiation

protection technician performed confirmatory surveys and measured about

12 - 13 mrem /hr at the boundary. The source of the radiation was

primarily from the contents of a 55-gallon barrel and a vacuum cleaner

which were both positioned near the boundary. The technician

immediately repositioned the equipment within the area and the dose

rates at 30 cm from the boundary were reduced to about 2 - 3 mrem /hr.

The RP staff indicated that station personnel may have moved the barrel

to obtain equipment from the storage area but failed to recognize the

effect of the barrel's position on area dose rates. A problem

identification form (PIF) was initiated to address the situation and

develop corrective actions to prevent recurrence.

The failure to post each radiation area (an accessible area in which an

individual could obtain a dose equivalent in excess of five mrem in one

hour at a distance of 30 cm from the source of radiation or any surface I

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which the radiation penetrates) with a conspicuous sign or signs bearing

the radiation symbol and the words " CAUTION, RADIATION AREA" is a

Violation of 10 CFR 20.1902(a). (50-454/455-96008-01(DRS)) l

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c. Conclusions l

A tour of the Auxiliary Building identified that material within a

posted radiation area had been moved which caused radiation levels to

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increase outside the area boundary. This NRC identified violation

brought into question the effectiveness of the licensee's radioactive

material control program.

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RI.2 Unit 2 Outaae Dose Control and ALARA Implementation I

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a. Inspection Scope (83750)

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The inspectors reviewed the radiological controls implemented for the i

Unit 21996 refueling outage (B2R06), including ALARA goals and results.

The following high dose jobs were observed in progress (either remotely

or on location):

. resistance temperature detection (RTD) modification,

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. steam generator inspections and reassembly,

. reactor coolant pump seal inspections, and

. reactor head funnel grinding and welding.

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b. Observations and Findinal

The Unit 2 Containment Building general area dose rates were about 50

percent higher than historically found which presented the licensee with

a challenge to meet established dose goals for the outage. The dose

goals were based on a ten percent reduction from historical dose

a performance. The inspectors observed that the RP department maintained

close oversight of outage tasks and dose was effectively controlled as a

result. ALARA tools implemented for the outage included the use of

additional shielding and the incorporation of lessons learned from

previous outages which effectively mitigated the effects of the

increased dose rates.

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As of September 6, 1996, over 80 percent of the steam generator and 90

percent of the RTD work scope was complete and the dose expended was

about 21 and 70 rem, respectively. The licensee effectively applied

1 lessons learned from the 1996 unit 1 RTD modification to the 82R06

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modification, including improvements in communications, radiation

protection technician (RPT) shift interfaces, and handling of removed

piping and equipment. As a result of higher area dose rates, the

licensee's current B2R06 dose exceeded the unit 1 modification dose of

69 rem. However, the implementation of lessons learned appeared to

improve work efficiency by about 10 percent, mitigating the effect of

higher area dose rates.

The inspectors attended pre-job briefings, which provided a good level

of information. The RP taif clearly communicated RWP requirements,

dose and dose rate alarms, and radiological hold points. However, the

inspector identified some weaknesses concerning workers' preparation.

During the ALARA meeting to discuss the repair of the fuel transfer

cart, the maintenance staff did not appear prepared for the evolution

and were unaware of job scope and the tools needed. As a result, the

ALARA pre-job meeting was used to determine the job scope and the role

of participants. The inspectors also noted that persons frequently left

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during meetings to pursue action items being discussed. In addition,

the meeting participants had little discussion regarding work scope

contingencies. The health physics support supervisor (HPSS)

acknowledged the weaknesses in worker preparation and indicated that

management's expectations were subsequently explained to the work

groups.

The inspectors observed good radiation worker (radworker) practices.

Personnel properly donned and removed protective clothing and

demonstrated a good knowledge of electronic dosimetry alarm setpoints.

The licensee provided additional support at the Containment Building

step-off-pads which were effective in improving worker performance and

correcting errors. Workers demonstrated good awareness of radiological

conditions and appropriate use of low dose waiting areas.

, c. Conclusions

The licensee's control of Unit 2 outage dose was a strength. The

licensee effectively used past outage work critiques to apply lessons

learned to existing work. Although pre-job ALARA meetings ensured

workers were aware of radiological requirements, weaknesses in worker

preparation and a lack of identifying work contingencies was evident.

During outage work evolutions, workers demonstrated good radiological

practices.

RI.3 Source Term Reduction

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a. Insoection Scone (83750)

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The inspectors reviewed the licensee's efforts to reduce the

radiological source term. The inspectors reviewed the licensee's cobalt

reduction and hot spot reduction programs. In addition, the inspectors

_ reviewed the licensee's efforts in reducing dose for the 1996 Unit 2 re-

4 fueling outage through pH control and shutdown chemistry.

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. b. Observations and Findinas

Communications between RP and operations staff was effective in

maintaining radiological impediments to a minimum and reducing general

area dose rates. Based on the identification of these impediments, the

licensee developed effective initiatives to reduce source term. During

plant shutdowns, the licensee routinely flushed specific system piping

in containment to reduce general area dose rates. In addition, the RTD

modification (Section RI.2) removed a significant amount of corrosion

product traps, which reduced general area dose rates in the Containment

Building.

Good teamwork between chemistry and radiation protection was also

successful in mitigating the effects of the May 1996 Unit 2 shutdown.

Following the May 1996 Unit 2 reactor shutdown, the licensee observed

significantly higher dose rates in the chemical and volume control

system (CVCS) letdown piping. The licensee's chemistry and RP

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department reviewed industry data and identified a relationship between

end of cycle boron concentration, pH, and dose rates on the CVCS letdown

system. Prior to the August 1996 Unit 2 shutdown, the licensee

maintained the reactor coolant system (RCS) pH at about 6.95 and

monitored the dose rates on the CVCS piping with electronic personal

dosimeters (EPDs). The dose rates on the CVCS remained constant,

indicating a decrease in the transport of corrosion products from the

core and in the deposition of the deposits on out-of-core systems.

The RP, chemistry, and operations departments also demonstrated good

teamwork in controlling shutdown chemistry. Boric acid was added early

in the shutdown and this was followed with hydrogen peroxide addition.

A significant amount of cobalt was removed from the reactor incore

surfaces as result. During the last three Unit 2 refueling outages, the

licensee removed an average of about 1200 curies (Ci) of Co-58 and 16 Ci

of Co-60 during this process.

c. Conclusions

Teamwork between radiation protection, chemistry, and operations staff

has been effective in reducing source term. Shutdown chemistry control

and system flushing have had positive effects.

V. Manaaement Meetinas

X1 Exit Meeting Summary

On September 6, 1996, the inspectors presented the inspection results to

licensee management. The licensee acknowledged the findings presented.

The inspectors asked the licensee whether any materials examined during I

the inspection should be considered proprietary. No proprietary !

information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

K. Kofron, Station Manager

T. Gierich, Operations Manager

P. Johnson, Technical Service Superintendent

E. Campbell, Maintenance Superintendent

D. Brindle, Regulatory Assurance Supervisor

W. McNeil, Radiation Protection

D. Goldsmith, Health Physics Supervisor

W. Grundmann, Chemistry Supervisor

INSPECTION PROCEDURES USED

IP 83750: Occupational Radiation Exposure

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

50-454-96008-01 VIO inadequate posting of a radiation area

Closed

None.

Discussed

None.

LIST OF ACRONYMS USED )

AB Auxiliary Building

ALARA As-Low- As-i s-Re a sonabl y- Ach i evabl e

CFR Code of Federal Regulations I

Ci Curies

CVCS Chemical and Volume Control System

EPD Electronic Personal Dosimeter

HPSS Health Physics Support Supervisor

ODCM Off-site Dose Calculation Model

PIF Problem Identification Form

RA Radiation Area

RCS Reactor Coolant System

RP Radiation Protection

RPT Radiation Protection Technician

RP&C Radiation Protection and Chemistry

RTD Resistance Temperature Detector

RWP Radiation Work Permit

SG Steam Generator

TS Technical Specification

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Documents Reviewed

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Licensee listing of " Hot Spots" (August 1996).

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Licensee trends of Cobalt-60 and Cobalt-58 concentrations during B2R04,

B2R05, and 82R06. ,

"CVCS/ Letdown System End of Cycle Dose Rate Excursions," David Kozin,

Jur.e 11, 1996 (Presentation to NEI Health Physics Forum, Dallas, Texas).

RWP Estimated and Actual Totals: Year to date Totals.

RTD Bypass Elimination Project: ALARA Post Job Report BIR07.

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ML20129E870

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