IR 05000454/1990007
| ML20012E796 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/20/1990 |
| From: | Grant W, Markley A, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20012E790 | List: |
| References | |
| 50-454-90-07, 50-454-90-7, 50-455-90-06, 50-455-90-6, NUDOCS 9004060309 | |
| Download: ML20012E796 (10) | |
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a V. $. NUCLEAR REGULATORY COMMIS$10N l
REGION !!!
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Report No. 50-454/90007(DR$$); 50-455/90006(DR$$)
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Docket Nos. 50 454; 50 455 Licenses No. NPF-37; NPF-66
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Licensee: Commonwealth Edison Company l
P. O. Box 767 Chicago, IL 60690
Facility Name: Byron Station, Units 1 and 2
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Inspection At: ' Byron $tation, Byron, Illinois
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Inspection Conducted:
Februars 20-28, 1990 Inspector:
WN.
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Date Accompanying W.,CJ/
p Inspector:
A. Markley/ *
3/80//*
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W.L.dl
, Approved By:
W. Snell, Chief 3/eeho Radiological Controls and Date
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Emergency Preparedness Section
L Inspection Summary L
Inspection _on February 20-28. 1990 (Reports No. 50-454/90007(DR$$):
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No. 30-4557966 5 Tif5))
Areas Inspecte :. F.outire unannounced inspectirn uf the radiological protection and tee radwaste prograrns including: changes in the organization; audits and
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surycillances external e;;pusure control; internal exposure control of radioactive I
materials and contamination; meiataining exposures ALARA; transportation of radioactive materials (IF 83750); solid, liquid, and gaseous radwaste programs L
(IP 84750). Also, reviewed were two allegations (IP 99024) and actions taken
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in response to previous inspection findings (IP 93702).
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_ Result s : The licensee's radiation protection and radwaste programs appear to L
function well. One violation for failure to follow a DOT requirement was not I'
issued in accordance with Section VA of Appendix C to 10 CFR Part 2.
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9004060309 900323
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Persons _ Contacted
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'S. Barrett, Radiation Protection Supervisor
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'D. Berg, Safety Assessment Engineer
'W. Bielasco, Technical HP Group Leader l
- L. Bushman, ALARA/ Operations HP Group Leader
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- E. Carroll, Regulating Assurance, Braidwood
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'A. Chernick, Training Supervisor
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D. Drawbaugh, Radiation Protection Foreman
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- R. Fernandez, Radwaste Coordinator t'
S. Fletcher, RP Instrumentation
'D. Herrmann, Radwaste Operations
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A. Mills, Fuel Handling Foreman
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B. McNeill, RCA Coordinator i
R. Munson, ALARA Analyst J. Parteete, IM Foreman
'G. Schwartz, Production Superintendent
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- M. Snow, Regulatory Assurance Supervisor J. Stout, Radiation Protection Foreman
'R. Ward, Technical Superintendent
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'D. Winchester, NQR Superintendent
'D. Wozaiak, Project Manager PWR Projects, G.O.
'W. Kropp, NRC Senior Resident Inspector f
The inspector also contacted other licensee and contractor representatives.
' Denotes those present at the exit meeting.
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General This inspection was conducted to review aspects of the licensee's radiation protection and radsaste programs, the licensee's response to
previous inspection findings, and investigation of two allegations.
t During plant tours, the inspectors noted that area posting, access
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controls, and housekeeping were good.
3.
Licensee Action on Previous Inspertio_n findinos (IP 92701]
i (Closed) Open Item (454/88013-07: 455/88013-07):
Use of proper
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calibration sources on the pause / walk through portal monitors and t
verification of the alarm setpoints. The licensee has purchased and is t
i using one uti Cs-137 and Co-60 sources in the calibration of the IRT
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Alarm setpoints for these monitors have also been i
verified, i
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Changes (IP 83750)
The inspectors reviewed changes in personnel, facilities, equipment,
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program and procedures that could affect the occupational radiation
protection program.
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t One Radiation Protection (RP) foreman has transferred to the training
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department;however,twotechnicianswerepromotedtoforeman,bringAing the number of foreman to the allotted six. There are currently 21 RP technicians, four "B" RP technicians in training and three "B" technicians l
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committed to an upcoming training class. The current RP technician staff
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appears to be strained in performing the radiation protection functions i
required by the outage.
This was discussed with RP and station management L
and will be reviewed during future inspections.
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5.
' Audits and Surveillances (IP 83750)
The inspector reviewed station quality assurance (QA) audits of the L
radiation protection and radwaste programs conducted since the last inspection.
Extent of audits, qualifications of auditors, and adequacy of corrtetive actions were reviewed.
One audit of radiation protection and two audits of radwaste were conducted during this period. The areas reviewed included:
solidification of waste; radioactive shipments; transportation; nuclear fuel handling and storage; radiation occurrence reports; whole body counting and training of operators.
No discrepancies were noted. The extent of the audits and qualifications of the auditors appeared adequate.
Surveillances of radiation protection and radwaste activities conducted during the period were selectively reviewed.
Corrective action on findings appeared to be timely and technically sound.
The quality assurance surveillance program is undergoing a significant change at this time to enable the auditors to observe more work in the field.
The inspectors had a concern with documentation of a surveillance done under this interim program.
This will be reviewed during a future inspection.
No violations or deviations were identified.
6.
External Exposure control _s (Ip 83750. 83724)
The licensee's external exposure control pr-ogram was reviewed, including changes in facilities, equipment, personnel, and procedures, adequacy of dosimetry program to meet routine ana emergency needs; dose tracking capabilities; required records, reports and notifications; effectiveness of management techniques used to implement these programs;
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and experience concerning self-identification and correction of program
implementation weaknesses.
Exposure records of plant and contractor personnel were selectively reviewed for 1989 and 1990 to date.
No exposures greater than 10 CFR 20.101 or licensee administrative limits were noted.
No violations or deviations were identified.
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Internal Exposure Control and Assessment (IP 83725)
The licensee's internal exposure control and assessment program was reviewed including: changes in facilities, equipment, personnel and
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respiratory protection training; procedures af fecting internal exposure control and personnel assessment of individual intales relative to regulatory requirements; required records, reports and notification; effectiveness of management techniques used to implement these programs; and experience concerning self-identification and correction of program implementation weaknesses.
A review of the licensee's whole body count records indicated that no
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exposures in excess of the 40 MPC-hour control measure occurred during
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1989 or 1990 to date.
No violations or deviations were identified.
8.
Control of Radioactive Materials and Contamination. Surveys and Monitoring (IPTiMD. 877R)
The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; procedures; adequacy of review and dissemination of survey data, and effectiveness of methods of control of radioactive and contaminated materials.
The inspectors selectively reviewed personnel External Contamination
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Records (PECRs), event trending and summary data for 1990 to date.
Two hundred and forty-two personnel contamination events had been reported during 1990 through March 2.
Two hundred and twenty of the PECRs have been attributed to the Unit I refueling outage and twenty to balance of plant activities. The RP staff has catngorized 60 of the events af, Category 1 greater than 20K dpm, arid 220 of the events as Category II, less than 30K dpm. No specific cause has been determined for the apparent increase in PECRs in 1990.
The inspectors noted that causal factors, when identified, were included in the report.
As discussed in a Previous inspection Report (50-454/89015: 50-455/89017):
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Teveral tool and equipment cages, tool labinets, and about 40 gang boxes located throughout the Auxiliary Building are used for storage of fixed
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contaminated and potentially contaminated tools and equipment.
Tools and
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equipment which are usec for work on contaminated systems or in
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contaminated areas are surveyed, decontaminated if necessary, and
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returned to these storage locations.
Tools and equipment are not allowed to be taken out of the RCA on a routine basis.
Radiation protection personnel survey the tools and equipment in gang boxes on a monthly frequency; so far, there is no evidence that tools / equipment are being returned to these storage areas without being surveyed and decontaminated. However, the practice of having locked storage containers for possibly contaminated tools and tquipment that are not controlled by radiation protection is not a good practice.
The feasibility of a large caged central storage area for RCA tools and equipment was discussed at the exit meeting.
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The licensee has developed a het particle floor monitor which uses a large area gas proportional probe w,th appropriate instrumentation.
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i monitor provides a large surface area and a quick response to detect high activity particles while wheeling the monitor across the floor. The t
licensee has detected about 7 hot particles since they started using the floor monitor in 1990.
No violations or deviations were identified.
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Maintaining Occupational Exposures ALARA (IP B3750. 83728)
The inspectors reviewed the licensee's program for maintaining
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occupational exposure ALARA, including: ALARA group staffing and
qualifications; changes in ALARA policy and procedures, and their
implementation; ALARA consideration for maintenance and refueling
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outages; worker awareness and involvement in the ALARA program;
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establishment of goals and objectives, and effectiveness in meeting i
them.
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The total station dose for 1989 was approximately 172 person-rem of which
about 130 person-rem was 6ttributed to the Unit 2 refueling outage.
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total dose for 1990 through March 2 is approximately 268 person-rem,
almost all of which can be attributed to the Unit I refueling outage.
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station goal for 1990 is 305 person-rem.
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Solid Radioactive Waste (IP 84750)
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The licensee's solid radioactive waste management program was reviewed, l
including: determination whether changes to equipment and procedures
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were in accordance with 10 CFR 50.59; adequacy of implementing procedures j
to properly classify and characterize waste, prepare manifests, and mark packages; overaM performance af the process control arid gyality assurance
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progrsms; adequacy of required ncords, reports, t.nd notif tettions; and l
experience concerning identifiestion and correction of prcgrammatic l
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veAkne$ses.
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Licensee representatives and records indicate that in 1989 the licensee made 39 shipments of dry active waste (DAW) filters and dewatered resins.
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In 1989 ta date, two shipments of dewatered resins have been made.
i Compacted and uncompacted DAW is usually packaged in S5 gallon drums;
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occasionally uncompacted DAW is packaged in metal bins (96 cubic feet). A
waste sorting table is used to separate clean trash from DAW to minimize i
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the DAW to be compacted. The licensee is also investigating the reduction j
of radwaste through the utilization of launderable bags, rags, and mops.
l There is an aggressive Radwaste Volume Reduction Program in effect with a j
committee which meets monthly to discuss and suggest methods to effectively l
reduce radwaste volume. An onsite vendor representative performs dewatering of filtering demineralization waste in vendor supplied metal liners and
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high integrity containers (HICs).
Licensee QA/QC personnel verify that i
the dewatering / solidification meets NRC And burial site rJquirements.
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l The inspectors reviewed the sta'ts of the radwaste Volume Reduction
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System (VR$). This system is described in Inspection Report
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No. 50-454/80034; 50-455/86029. Mechanical problems continue to prohibit i
operation of the VR$. Operation of the VR$ is not anticipated in the i
near future,
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Classification and shipping of solid radwaste appear to have been
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performed in accordance with regulatory requirements and licensee l
procedures.
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No violations or deviations were identified.
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11.
Liovids a_nd Licuid Radioactive Wastes (!p 84750)
l The_ licensee's reactor liquids and liquid radwaste management programs
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were reviewed, including: determination whether changes to equipment and l
procedures were in accordance with 10 CFR 50,59; determination whether reactor liquids meet chemical and radiochemical requirements; determination whether liquid radioactive waste effluents were in
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accordance with regulatory requirements; adequacy of required records,
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reports, and notificetions; determination whether process and effluent
monitors are maintained, calibrated, and operated as required; and
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experience concerning identification and correction of programmatic
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weaknesses, t
The inspectors reviewed selected records of radioactive liquid effluent
sampling and analysis for 1990 and the semiannual effluent reports for
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1989.
The pathways sampled and the analyses performed appear to comply
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with Technical Specification Table 4.11-1.
Total liquid radioactive effluent (excluding tritium) in 1989 was (48 uCi, No problems were i
id9ntified during the review of selected records. The records indicate i
that releases were maintalvd within applicable limits,
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No violations or deviations were identified, t
12. Gaseous Rad _tf active Waste _ (IP 84750)
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The licensee's gaseous radwaste management program was reviewed,
including determination whether changes to equipment and procedures were
in accordance with 10 CFR 50.59; determination whether gaseous l
radioactive waste effluents were in accerdance with resulttory l
requirements; adequacy of required records, reports, and notifications;
determination whether process and effluent monitors are maintained,
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calibrated, and operated as required; and experience concerning i
identification and correction of programmatic weaknesses,
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The inspectors reviewed selected records of radioactive' gaseous effluent l
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pathways sampled and analyses performed appear to comply with the i
requirements of Technical Specification Table 4.11-2.
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i The lic6nsee also made a concerted effort by repair / modification to minimize gaseous leaks into containment, which necessitate containment
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venting.
This has contributed to a marked decrease in noble gas releases. The 1989 cuarterly breakdown is as follows:
74 curies during l
the first quarter; 47 curies during the second quarter; 342 curies during the third quarter and 352 curies during the fourth quarter. The c s.,
calculated offsite doit associated with these releases remains less than one percent of applicault technical specification limits.
Noble 945 releases are quantified by radiation protection personnel based on analyses of samples collected prior to batch releases from waste gas decay tanks and containment venting.
Non-betch or continuous releases are quantified by radiation protection
personnel based on analyses of grab samples collected from the vent stacks
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and the time period of the release or using the wide range gas monitor
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data and the proper time f rame, instructions on non-batch release quantification are contained in Procedure No. RP 1750-5. No problems were noted.
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No violations or deviations were identified.
13.
Ef fluent Control Instrumentation (IP 84750)
Calibration records for two liquid monitors and three noble gas particulate and iodine monitors were reviewed.
The liquid monitors were the liquid radwaste effluent monitor and the turbing building fire and oil sump monitor.
The noble gas monitors were one plant vent monitor (high and low range), one containment purge monitor and one wide range gas r;onitor (WRGM).
Calibrations were adequate and timely. The calibestion procedures
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for noble gas monitors were select,isely reviewed.
It was noted that the calibration procevares have been etvised to address background considerations.
The setpoints for the above monitors ware reviewed. No problems wars identified, o
The inspectors observed the performance rf a cclibration of the waste gas decay tank effluent monitor.
Mair ter.ance was performed in accordance with procedure. However, liquids drcined through the, step cocks were collected on a paper towel withnat the use of positive contamination
control.
This issue was discussed with the radiatior, protect'on group.
The radiatioit protection group indicated that this would be fo1* owed en
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and they would cocu9tht the results. A review of contamination cor.trols
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for process and effluent s.ov.itor maintonerte will be performed during a e
future inspection.
No violations or 6eviations were identified.
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Transportation of Radioactive Materials (IP 83750)
The licensee's transportation of radioactive materials program was reviewed, Jr. eluding determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesses.
Records of radioactive material shipments made during 1989 and 1990 to
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date were reviewed.
In 1989, the licensee maoe 39 shipments of radioactive waste as Low Specific Activity (LSA) materials in exclusive use vehicles.
In 1990 to date, two such shipments have been made.
The inspector reviewed a recent licensee radwaste shipment problem that was identified by a State of Washington inspector at the Richland, Washington waste burial site.
The problem is discussed below:
On December 18, 1989, the licensee made an LSA radwaste shipment from Byron Station to the Richland Washington waste burial site. The exclusive use shipment (89-37) was comprised of S5 gallon drums of DAW.
The packapes were considered to be Type A strong, tight, and shipped pursuant to 49 CFR 173.425(b). The shipment was loaded by the licensee according to station procedure. Upon arrival at the burial site on December 21, 1989, a Washington State Inspector discovered that Drum #96 was included on the shipment but was not manifested. This is contrary to 49 CFR 172.200. Drum #96 was not marked " Radioactive LSA" contrary to 49 CFR 173.425(b)(B); it was, however, part of a shipment of over one hundred drums which were correctly marked and were in an enclosed trailer. The manifest had two drums listed as Package #100, but the shipment contained only one Drum #100 contrary to 49 CFR 172.200.
Failure to follow DOT regulations is a violation of 10 CFR 71.5(a).
The State of Washington cited the licensee for these DOT violations; no other enforcement action was taken by the State. Upon notification by the State of Washington the licensee immediately initiated appropriate corrective action. This was the first violation of DOT regulations by the licensee. Consequently, pursuant to Section V.A. of Appendix C to 10 CFR Part 2, a Notice of Violation will not be issued for this isolated Severity Level V violation (Violation 454/90007-01; 455/90006-01).
One violation was identified; however, a Hotice of Violation will not be issued.
15. Allegation Followup (IP 99024) (AMS No. RIII-90-A-0008)
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On January 18, 1990, an individual contacted an NRC employee in the Byron Station Guard House and expressed concerns about the radiation protection program at Byron Station.
During this inspection, the inspector contacted the individual by telephone and discussed the allegations further to obtain more specific information.
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The inspector reviewed licensee procedures, RWPs and survey data and
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interviewed licensee and contractor personnel to determine the validity
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of the concerns expressed by the alleger.
The allegations are discussed
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below.
Allegation:
The alleger stated that he purposely failed the NGET course f
because he did not want to work around radiation / contamination. Therefore, he worked on a visitor's pass the entire time he was at the Byron i
site.
He didn't feel trained enough to work around radiation.
He was never issued dosimetry and when he and other workers went to get a whole t
body count there was no one there and they never received one.
Discussion: When asked by the inspector for more specific information
concerning the allegation, the alleger stated he had been hired by
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Westinghouse and had intentionally failea NGET training because he didn't want to work around radiation / contamination. On January 7,1990, he came to work at the plant and tried to be laid off because he did not want to lose his unemployment by walking off the job.
The alleger was assigned r
to work on the turbine floor dismantling the Unit I turbine which is normally a clean area.
On January 16, 1990, the turbine workers were told not to return to their work location because of a contamination problem.
Radiation protection had detected low level contamination in the turbine interior during a routine survey. At his request the alleger did not return to the turbine work location. On January 18, the alleger contacted
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Radiation Protection concerning whole body counting (WDC) as a visitor.
He was told that normally workers are not required to get entrance and exit WBC unless they are issued dosimetry, and since he was not working in the radiologically controlled area he was not required to have dosimetry and therefore not required to have a WBC.
The alleger was told he could i
get a WBC if he wanted one. He stated he was not concerned about the WBC F
but he did not want to work at Byron Station.
FindRg: The inspector was able to confirm that the alleger had failed fiGET, had not been issued dosimetry and had never had a whole body count.
However, he worked on a visitor's badge in an area which was normally not controlled for radiation / contamination. When the area was found to be contaminated with low-level beta gamma activity, dosimetry was still not required and furthermore he did not return to that work location. He worked in the tool issue cage on the turbine floor.
Radiation protection records show the alleger did not work on the RWP issued for the contaminated turbine work and that no personnel contamination incidents resulted from the turbine work.
The alleger was offered a whole body count and he declined. The allegation was partially substantiated.
However, his concerns about lack of dosimnry and whole body counts, while substantiated, were not required for the work he was doing.
16. Allegation Followup (IP 99024) AMS No. RIII 90_-A-0011)
On January 29, 1990, an individual telephoned RIII and expressed concerns about the actions of a fuel handling foreman (FHF) at Byron Station during the Unit I refueling outage in March 1987.
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The inspector reviewed the licensee Radiation Occurrence Report (ROR) 87-07 I
and interviewed licensee personnel to determine the validity of the
concerns experienced by the alleger. The allegation is discussed below.
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A11coation: The alleger stated a fuel handling foreman raised an
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In-core detector out of the water in the spent fuel pool against i
radiation protection directions and,*' armed the electronic dosimetry.
- This was done as a joke.
Discussion: A licensee Radiation Occurrence Report (ROR 87-07) was l
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written on this event on March 27, 1987.
The ROR describes the movement
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of the in-core thimble from one side of the reactor cavity to the other i
with the FHF holding the thimble under water using a pneumatic vise tool.
l A radiation protection technician (RPT) was monitoring the radiation level
on the refueling bridge crane during movement.
Radiation levels were
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20-50 mR/hr.
When the crane reached the opposite side of the reactor I
cavity, the FHF attempted to move the thimble to the underwater waste
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barrel using the pneumatic tool by " tossing" the thimble toward the side
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of the reactor cavity. This sudden movement lifted the end of the thimble
out of the water and dose rates increased to greater than 5 R/hr for 5-6 seconds. The RPT shouted at the FHF "what the hell do you think you're i
doing," stopped the operation, and called his foreman. The ROR
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investigation did not find the FHF's actions to be a willful disregard for the RPTs instructions but apparently an attempt to hasten completion
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of the job.
i Finding:
The allegation was partially substantiated. However, no evidence-was found to indicate the FHF's actions were done as a joke and
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no record was found that indicated that electronic dosimetry alarmed.
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Exit Meeting (IP 30703)
l The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on February 28, 1990, to discuss the scope and findings of the inspection.
The inspectors t'so discussed the i
likely informatioral content of the inspection report wP,h regard to
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documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as
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proprietary.
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y This following matters were specifically discussed by the inspectors:
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The need to complete the review of the hot tool control program, b.
The violation concerning the DOT regulations and the fact that the NRC will not issue a violation.
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The apparent increase in personnel contamination events and the need to determine causes.
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