IR 05000483/1983010
| ML20024C309 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/22/1983 |
| From: | Greger L, Greger L, Lovenale P, Lovendale J, Lovendale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20024C304 | List: |
| References | |
| RTR-NUREG-0830, RTR-NUREG-830, TASK-2.B.2, TASK-2.B.3, TASK-2.F.1, TASK-3.D.3.3, TASK-TM 50-483-83-10, NUDOCS 8307120506 | |
| Download: ML20024C309 (7) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-483/83-10(DRMSP)
Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company P. O. Box 149 St. Louis,' MO 63166 Facility Name: Callaway County Nuclear Station Inspection At: Callaway Site, Callaway County, M0 Inspection Conducted: May 24-27, 1983 d @"+ f3-Inspector: {.C.Loendale Date '
Approved By
. Gre r, Chief
/J # # 3 1 Facilities Radiation D4te '
Protection Section Inspection Summary Inspection on May 24-27, 1983 (Report No. 50-483/83-10(DRMSP))
Areas Inspected: Routine, unannounced preoperational inspection of the radiation protection program including: organization, training, radiation protection procedures, facilities and equipment, and previous inspection findings. Also, the status of certain TMI Action Plan Items were reviewed.
The inspection involved 32 inspector-hours onsite by one NRC inspector.
Results: No items of noncompliance or deviations were identified.
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DETAILS 1.
Per-ans Contacted
- M. S. Evans, Senior Training Supervisor
- J. C. Gearhart, Supervisor, QA - Operations
- S. E. Miltenberger, Manager, Callaway Plant
- J. R. Peevy, Superintendent, Health Physics
- R. L. Powers, Superintendent, Site QA
- G. L. Randolph, Assistant. Manager, Technical Services
- W. R. Robinson, Compliance Supervisor R. R. Roselius, Supervisor, Health Physics Operations
- J. H. Neisler, NRC Senior Resident Inspector The inspector also contacted other licensee employees including Rad / Chem foremen and technicians.
- Denotes those present at the exit meeting.
2.
General This inspection,- which began at 8:00 a.m. on May 24, 1983, was conducted to examine the licensee's provisions for health physics staff, initial training, radiation protection procedures, facilities, and instruments and equipment necessary to comply with regulatory requirements and commit-ments in the Final Safety Analysis Report (FSAR).
3.
Licensee Action on Previous Inspection Findings (Closed) Open Item (483/8-08-01): Health physics organization different from that described in the FSAR. The inspector verified that the needed revisions to the FSAR were made. The licensee stated that further revi-sions would be made as needed. No further prcblems were noted.
4.
Organization The licensee's health physics, radwaste, and chemistry organizations were reviewed. Except-for rotation of radiation / chemical technicians (RCTs) and addition of a radiation / chemical foreman - ALARA position, the organization remains as previously stated.1 Previously, about forty percent of the RCTs were to rotate between the three, groups (health physics, radwaste, and hemistry). Sixty percent were to be permanently assigned to a specific c
group. The current organization has all RCTs permanently assigned to either radwaste, health physics', or chemistry. The radiation / chemical foreman - ALARA position was created to fulfill the.need for an ALARA
. program administrator. The individual in this position as well as all other foremen appear to meet the selection criteria for supervisors not requiring an NRC license. No problems were noted.
-Inspection Report No.. 50-483/82-08-
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The current staffing plan allows for 63 RCTs to staff the chemistry, health physics, and radwaste groups. Thirty-two of the RCTs will be assigned to health physics, sixteen RCTs will be assigned to chemistry, and fifteen RCTs will be assigned to radwaste. Currently, there are eleven RCT openings in health physics, five RCT openings in chemistry, and ten RCT openings in radwaste. Three recently hired RCTs are scheduled to start work July 11, 1983. Current plans call for filling all remaining vacancies by November 1983.
A review of the RCTs' qualifications revealed that they meet or exceed the selection criteria for technicians in Section 4.5.2 of ANS 3.1-1978.
Eight of the technicians are certified by the National Registry of Radia-tion Protection Technologist (NRRPT). Also, ten radiation / chemical foremen, the Supervisor of Radwaste, and two training supervisors are certified by the NRRPT.
In a letter to NRR dated September 4, 1981, the licensee stated that the Health Physics Supervisor (current title is Superintendent, Health Physics)
would participate in two refueling outages at other nuclear power plants by fuel load. In addition, the Supervisor, HP Technical Support was to attend one refueling outage. To date, this commitment has not been met.
An attempt to send the Superintendent, Health Physics to one refueling had to be cancelled. The inspector discussed with the licensee the need to meet this commitment or inform NRR of intended changes in the commitment.
The licensee stated that NRR would be informed of any changes.
This matter was discussed during the exit meeting and will be reviewed during a future inspection.
(483/82-08-02)
The licensee's health physics organization, responsibilities, and adminis-trative controls are delineated in Administrative Procedure APA-ZZ-00031,
" Conduct of Operations - Health Physics." This procedure includes topics such as Health Physics Department organization and qualifications, per-sonnel responsibilities, procedure requirements, Health Physics Department operations, training, and stop work authority. The inspector reviewed this procedure. Except for licensee identified deficiencies, no problems were noted.
The inspector noted that morale within the organization appears good. This is evidenced by the very low turnover rate of employees. Except for promo-tions or transfers to other departments, only three employees have terminated in the last two years. Two of these individuals were encouraged to leave and the other left because he did not like the area.
This low turnover has apparently contributed to the licensee's successful program development.
No items of noncompliance or deviations were identified.
5.
RCT and General Employee Training The radiation / chemical technician training remains as previously described.2 The inspector attended a portion of a training session concerning field
Inspection Reports No. 50-483/81-18 and No. 50-483/82-08.
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usage of instrumentation following an accident. This training was con-ducted in the training building. The classroom was of adequate size and was well equipped. Also, the class size was small which allowed for individual attention.
In general, the presentation was of good quality with substantial student participation. No problems were noted.
The licensee's RCT qualification program requires the completion and sign off of certain practical factors before an RCT is allowed to perform operations related to those practical factors. The qualification cards needed to implement this program have not yet been developed. The delay in implementing this part of the program is apparently due to the need for completion of remaining health physics procedures.
Implementation of this program will be reviewed during a future inspection.
(483/83-10-01)
The licensee's general employee training which is designed to meet the requirements of 10 CFR 19.12 remains as previously described.3 A represen-tative from the training department indicated that refresher training in this area would be presented to station employees beginning in the near future.
6.
Facilities The inspector toured selected areas of the plant related to radiation protection, including the access control area, laboratories, laundry facilities, change areas, decontamination facilities, counting room, and office areas to determine if space deficiencies noted during a previous
inspection still exist.
Some space deficiencies remain unresolved as follows:
Although the problem is under review, no space has been allotted for a.
storage, cleaning, maintenance, and issuing of respiratory protection equipment.
b.
The wet wash laundry is small and occupies space in the access control area which could be better utilized for respiratory equipment issuance /
storage, protective clothing storage, or increased locker space.
Better use of this space would likely lessen congestion during outages and ultimately improve productivity by improving movement of workers through the area.
The small steam generator platforms are to be modified to increase avail-able working space for steam generator entries. Also, permanent office space for the chemiscry, radwaste, and health physics groups will be in j
the building currently occupied by start-up personnel. The question of
where these groups will locate between the time the Emergency Oper.- tions I
Facility (present location of these groups) needs to be sacated and the time start-up personnel vill be vacating the space they occupy has not yet been answered. The remaining space deficiencies were discussed during the exit meeting and will be reviewed during a future inspection.
(483/82-08-04)
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Inspection Report No. 50-483/82-08.
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7.
Instruments and Equipment The licensee appears to have procured _an adequate supply of portable survey instruments including low and high range beta gamma, alpha, neutron, and extendable probe instruments. Also, an adequate supply of air samplers is available. Although a calibrator has been purchased, the calibration facility construction is not complete. No other problems were noted.
A cursory review of the fuel building exhaust monitor installation revealed-that the sample piping may contain unnecessary bends and other line restric-tions which may affect the representativeness of the samples. FSAR Section 11.5.2.3, " Airborne Monitoring Systems," states that these systems will be designed and installed in accordance with ANSI N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities." This matter was discussed during the exit meeting and will be reviewed further during a future inspection.
(483/83-10-02)
8.
Radiation Protection Procedures The' inspectors reviewed the following health physics procedures to deter-mine if they are consistent with 10 CFR 19 and 20, FSAR commitments, and good health physics practices.
APA-ZZ-00031, Revision 0, Conduct of Operations - Health Physics APA-ZZ-00150, Revision 0, Callaway Plant ALARA Program HDP-ZZ-01200, Revision GR1, Radiation Work Permit Program HDP-ZZ-04000, Revision 0, Health Physics Instrumentation Program HDP-ZZ-06010, Revision 0, Personnel Monitoring for Contamination HTP-ZZ-01440, Revision 0, Pocket Dosimeter Calibration Checks HTP-ZZ-02201, Revision 0, Handling of Radioactive Material HTP-ZZ-02002, Revision 1, Receipt of Radioactive Material HTP-ZZ-03002, Revision 0, Contamination Survey Methods HTP-ZZ-03004, Revision GR2, Airborne Radioactivity Survey Methods HTP-ZZ-03008, Revision GR2, Leak Test of Sealed Sources HTP-ZZ-04521, Revision 0, Operation of the Whole Body Counting System HTP-ZZ-05002, Revision 0, High Radiation Levels HIP-ZZ-05005, Revision 0, High Airborne Radioactivity Levels HTP-ZZ-05007, Revision 0, Personnel Contamination b
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HTP-ZZ-05008, Revision 0, Evaluation of Exposure for Lost, Suspect Damaged, or Offscale Dosimetry HTP-ZZ-05012, Revision 0, Radiation Exposure Discrepancy Evaluation HTP-ZZ-06009, Revision GR1, Personnel Decontamination HTP-ZZ-06014, Revision GR1, Selection and Use of Protective Clothing HTP-ZZ-08002, Revision 0, Issuance and Return of Respiratory Protection Devices HTP-ZZ-08201, Revision 0, Conducting Qualitative Respirator Fit Testing HTP-ZZ-08300, Revision 0, MSA Respiratory Cleaning Inspection and Storage Procedure HTP-ZZ-03002 contains unconditional release limits that are not supportable by regulation. The Superintendent, Health Physics stated that he would review the contents of this procedure and make the needed changes.
Several minor needed changes were also discussed with the licensee. No other significant problems were identified.
In a letter to NRR dated December 10, 1981, the licensee committed to development of a radiation protection plan which generally follows the guidance of NUREG-0761, " Radiation Protection Plans for Nuclear Power Reactor Licensees" Draft Report, March 1981. The Callaway radiation protection plan includes the Health Physics Manual and the health physics procedures. Currently, about 75 percent of the health physics procedures are complete. The Health Physics Manual is scheduled for completion by July 1, 1983.
9.
Status of Certain TMI Action Plan Items The inspector reviewed the status of TMI Action Plan Items II.B.2, " Design Review of Plant Shielding"; II.B.3, " Post-Accident Sampling Capability";
II.F.1.1, " Noble Gas Effluent Monitor";
II.F.1.2, " Sampling and Analysis of Plant Effluents"; II.F.1.3, " Containment High Range Radiation Monitor";
and III.D.3.3, " Improved Inplant Iodine Instrumentation Under Accident Conditions."
The licensee stated that the shielding design review required to satisfy Item II.B.2 has been completed. The results of that review indicate that installation of the post accident sampling system was the only needed modification. The design review and needed modification will be reviewed during a future inspection.
The Safety Evaluation Report for Callaway (NUREG-0830) dated October 1981 states that the licensee must demonstrate the capability to promptly obtain reactor coolant samples as required by Item II.B.3 before five percent power operation; this will be a license condition.
Currently, the licensee
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estimates the post-accident sampling system will be fully operational by mid-November 1983. A review of this installation will be conducted during a future inspection.
Items II.F.1.1, II.F.1.2, and II.F.1.3 are all included as part of the ststion's radiation monitoring system (RMS). Monitors needed to meet these requirements will be operational about January 1984. However, a letter to NRR dated April 15, 1983, indicates that the steam generator safety valve and atmospheric dump valve monitors may not be operational until sometime after fuel load. These monitors are needed to satisfy the requirements of Item II.F.1.1, " Noble Gas Effluent Monitor." Installation of the station's radiation monitoring system will be reviewed during a future inspection.
The Safety Evaluation Report (NUREG-0830) states that based on licensee commitments, the requirements of Item III.D.3.3, " Improved Inplant Instru-mentation Under Accident Conditions," have been satisfied. The licensee's equipment and capabilities needed to satisfy these requirements will be reviewed during a future inspection.
10.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on May 27, 1983. The inspector summarized the scope and findings of the inspection.
In response to certain items discussed, the licensee:
a.
Stated that NRR would be informed regarding present intentions for health physics supervision's participation in refueling outages at other plants.
(Section 4)
b.
Acknowledged the inspector's comments concerning certain space deficiencies.
(Section 6)
Acknowledged the inspector's comments concerning installation of c.
effluent air sampling systems. The inspector stated that all effluent monitor installations would be reviewed to ensure that representative samples can be collected and that the systems have been installed as committed in the FSAR.
(Section 7)
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