IR 05000483/1981018
| ML20010G027 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/25/1981 |
| From: | Greger L, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20010G023 | List: |
| References | |
| 50-483-81-18, 50-486-81-01, 50-486-81-1, NUDOCS 8109150246 | |
| Download: ML20010G027 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-483/81-18; 50-4ti6/81-01 Docket Nos. 50-483; 50-486 Licenses No. CPPR-139; CPPR-140 Licensee: Union Electric Company P. O. Box 149 St. Louis, MO 63166 Facility Name: Callaway, Units 1 and 2 Inspection At: Callaway Site, Callaway County, M0 Inspection Conducted-Aq ast 4-6, 1981 W$h Inspector:
P. C. Lovendale g[W/g/
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,Qw Approved By:
L. R. Greger, Chief 8[
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Facilities Radiation Protection Section Inspection Summary:
Inspection on August 4-6, 1981 (Reports No. 50-483/81-18; 50-486/81--0 0 Areas Inspected: A meeting was held to discuss the preoperational and routine operational inspection program in the radiation protection and radwaste manage-
ment areas. Also, the inspector performed an initial review of the licensee's radiation protection organization and addressed licensee concerns regarding implementation of their quality assurance program. The meeting involved 18 inspector-hours onsite by one NRC inspector.
Results: No violations of NRC requirements were identified.
8109150246 810826 PDR ADOCK 05000483 G
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i DETAILS i
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Persons Contacted
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- M. A. Stiller, Plant Superintendent
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J. R. Peevy, Assistant Superintendent, Engineering - Radiation / Chemical
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R. R. Roselius, Health Physicist l
P. A. Walsh, Health. Physicist i
i J. R. Polchow, Rad / Chem Foreman
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J. A. Ridgel, Rad / Chem Foreman j
D. F. Schnell, General Manager of Operations, Union Electric
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- Denotes those present at the management meeting.
2.
Initial Management Meeting This management meeting, which began at 9:30 a.m. on August 5, 1981, was j
conducted to discuss with the licensee the following matters:
a.
The NRC function and inspection program in the radiation protection
and radwaste management areas, including the performance of unannounced
inspections, methods of taking enforcement action, and'the conduct of management interviews.
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The need for an effective audit and management controls program.
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The preoperational testing program for radwaste systems and monitors, and the inspector's function in reviewing the program.
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The radiation protection program,' and areas which will be reviewed by the inspector-before issuance of an operating license.
t A description of radiation protection and radwaste management problems e.
j noted at similar facilities.
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The licensee's radiation protection organization.
3.
Radiation Protection Organization and Qualifications At the request of NRR, the inspector reviewed the licensee's radiation.
- protection organization and personnel qualifications.
I Currently, the Radiation / Chemical Group is headed by the Assistant
Superintendent, Engineering - Radiation / Chemical. He directly supervises i
two health phys'cist (HP), one chemist, one chemical' engineer, and two
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radiation / chemical foremen. The radiatien/ chemical foremen supervise l
22 radiation / chemical ~ technicians'(RCT).
j l-Positions yet to be filled include three RCTs and one experienced HP.
i It is'also possible that additional foremen will be appointed.
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The licensee appears to have expended considerable effort and resources to hire highly qualified technicians. The RCTs have from three to eight
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years experience as engineering laboratory technicians (ELT) in the Naval Nuclear Power Program. Also, six of the RCTs have additional nuclear power plant experience and two are degreed. All 22 RCTs appear to meet or exceed the selection requirements for technicians in Section 4.5.2 of ANS 3.1-1978.
The two health physicists (HP) hold B.S. degrees in health physics. One has two and one-half years experience developing the radiation protection program at another nuclear power plant under construction. The other has about one year experience developing the licensee's radiation protection program, one year of operational health physics experience at various operating power reactors, ap'l a total of about four years of operator experience at a power reactor and in the Navy. This person will head the
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Radiation / Chemical Group in the absence of the Assistant Superintendent,
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Engineering - Radiation / Chemical.
It appears that the two HPs do not meet the experience requirements of Regulatory Guide 1.8 for Radiation Protection j
Manager.
i The radiation / chemical-foremen each have about six years experience as Navy ELTs.
In addition, one foreman has about three years experience developing the licensee's radiation protection program and has spent four
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weeks at another power reactor during a refueling outage. The other foreman has one year experience developing the licensee'
radiation pro-tection program and about three months experience -at another power reactor providing radiological support for maintenance operations. Both foremen appear to meet the selection requirements for supervisors not requiring NRC licenses in Section 4.3.2 of ANS 3.1-1978.
According to the licensee, the Assistant Superintendent, Engineering -
Radiation / Chemical will serve as the plant's Radiation Protection Manager (RPM). He holds a B.S. degree in health physics and has about six and one half years of professional experience in applied radiation protection.
About three and one half Jears of this experience was gained as an ELT supervisor in the Naval Nuclear Power Program. The remaining three years experience was developing the radiation protection and radiochemistry
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programs at Callaway,
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Section 13.1.3.1 of the licensee's FSAP requires plant personnel to meet or exceed the intent of the requirements set forth in ANS 3.1-1978,
" Selection and Training of Nuclear Power Plant Personnel" and Regulatory-Guide 1.8, " Personnel Selection and Training." Regulatory Guide 1.8 requires that the RPM have at least five years of professional experience in applied radiation protection. Three of this five years shall be in applied radiation protection in a nuclear facility dealing with radio-logical problems similar to those encountered in nuclear power plants.
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ANS 3.1-1978 defines " nuclear power plant experience" as experience acquired in the preoperational and startup testing activities, or operation of nuclear power _ plants and includes experience acquired at military pro-pulsion nuclear plants.
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The current Assistant Superintendent Engineering - Radiation / Chemical meets the Radiation Protection Manager academic and experience require-ments of Regulatory Guide 1.8.
The Plant Chemist and the Chemical Engineer each hold B.S. degrees. The Plant Chemist has about five years of general chemistry experience including some experience in health physics. The Chemical Engineer has about ten years work experience as a chemical engineer including about one and one half years at another nuclear power plant under construction.
It appears that neither the Chemist or the Chemical Engineer meet the radiochemistry experience requirements of Section 4.4.3 of ANS 3.1-1978. Also, it appears that no person in the current radiation protection organization meets the radiochemistry requirements.
4.
Radiation / Chemical Tecnician (RCI) Training At the request of NRR, the inspector reviewed the licensee's RCT training program. The RCTs will serve as both radiation protection technicians and chemistry technicians on a rotating basis. Experience at other facilities with this type arrangement has shown that the technicians may have difficulty maintaining competency in both radi tion protection and chemistry. A high quality training / retraining program, designed to main-tain competency in both radiation protection and chemistry is essential with this type of organizaton.
It appears that the licensee's initial training program raeets these needs. However, the licensee has not developed an RCT retraining program for use during the operations phase.
The licensee's RCT training program consists of four phases. Phases one and two last about 18 weeks and cover nuclear theory and plant systems.
Phase three is a four-week course covering general health physics theory and problem solving. Phase four is a four-week course covering radiation detection.
It is presented by Health Physics Services at the University of Missouri.
Phase four also includes training on DOT and NRC regulations.
In addition, the RCTs receive a four-week chemistry course which includes sessions on theory, calculations, and sampling systems. Each phase of training includes working laboratories, or problem solving sessions; the health physics course includes homework assignments. Examinations are given periodically throughout the training program.
The inspector visited a radiation detection laboratory class in session at the University of Missouri. The class appeared to be professionally administered and of high quality.
5.
Quality Assurance for the Radiation Protection Program The licensee asked the inspector to comment on the applicability of Regulatory Guide 1.33, Revision 2, "Qeality Assurance Program Criteria for Nuclear Power Plants," to the radiation protection program.
Also, the licensee wanted to know if the Quality Assurancee program required by 10 CFR 50, Appendix B, should be applied to the purchase of radiation pro-tection equipment.
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There matters were discussed with the licensee and with other Region III NRC personnel.
Conclusions are as follows:
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Regulatory Guide 1.33, Revision 2, does apply to the radiation protection program in that it requires that certain activities by covered by written procedures, including procedures for control of radioactivity. These procedures should be developed by radiation protection personnel and approved by the onsite review group, b.
The Q'zality Assurance Program required by 10 CFR 50, Appendix B, applies to structures, systems, and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. Quality assurance practices such as receipt inspection, NBS tracability, and periodic calibration should be applied to radiation protection equipment, but this equipment generally does not fall into the category of " safety-related" equipment.
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