IR 05000483/1987013
| ML20235T760 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/08/1987 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235T731 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-483-87-13, NUDOCS 8707220262 | |
| Download: ML20235T760 (21) | |
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i U.S. NUCLEAR REGULATORY COMMISSION j
REGION III
Report No. 50-483/87013(DRSS)
Docket No. 50-483 License No. NPF-30 Licensee:
Union Electric Company
Post Office Box 149
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St. Louis, MO 63166 Facility Name:
Callaway County Nuclear Station Inspection At:
Callaway Site, Callaway County, Missouri Inspection Conducted:
April 20 through June 15, 1987 Inspector:
C. F. Gill
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Ed/87 Da(e '
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Approved By:
L. R. Greger, Chief f-8-87 Facilities Radiation Date Protection Section Inspection Summary Inspection on April 20 through June 15, 1987 (Report No. 50-483/87013(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radiation protection program during a maintenance outage, including:
changes in organization, personnel, facilities, equipment, programs, and procedures; audits and appraisals; planning and preparation; training and qualifications of new personnel; internal and external exposure control; control of radioactive materials, contamination, surveys, and monitoring; the ALARA program; and open items.
Results:
No violations or deviations were identified.
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l DETAILS l
1.
Persons Contacted
L. Auman, Foreman, Health Physics
- L. Beaty, I&C Engineer
- G. Blair, Staff Engineer, GA
- J. Blosser, Plant Manager j
- D. Capone, Manager, Nuclear Engineering i
- J. Cruickshank, Radwaste Shipping Foreman
- J. Gearhart, Superintendent, QA05
- C. Graham, Supervisor, Health Physics Technical Support
- G. Hamilton, Radwaste Engineer B. Holderness, Health Physicist l
- J. Little, Assistant QA Engineer l
- C. Naslund, Manager, Operations Support
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J. Neudecker, Foreman, Health Physics A. Passwater, Licensing Superintendent J
- J. Peevy, Assistant Manager, Technical Services j
- J. Polchow, Supervisor, Health Physics
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- G. Randolph, General Manager, Nuclear Operations
- J. Ridgel, Superintendent, Radwaste
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- R. Roselius, Superintendent, Health Physics D. Shafer, Supervising Engineer, Licensing
- V. Shanks, Superintendent, Chemistry N. Slaten, Supervising Engineer, Nuclear G. Spires, Foreman, Health Physics
- P. Tuton, Field Services Supervisor, GA
- E. Thornton, QA Engineering Evaluator M. Williams, Principal Health Physicist
- C. Brown, NRC Resident Inspector
- B. Little, NRC Senior Resident Inspector
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The inspector also contacted other licensee employees including radiation protection technicians and members of the engineering staff.
- Denotes those present at the exit meeting on April 24, 1987.
- Denotes those contacted by telephone during the period April 27 j
through June 15, 1987.
2.
General This inspection, which began at approximately 1:00 p.m. on April 20, 1987, was conducted to review the radiation protection program during an extended maintenance outage, including organization and management controls, qualifications and training, audits and appraisals, planning and preparation, internal and external exposure controls, ALARA program, control of radioactive material and contamination, and open items.
During plant tours, the inspector noted that area postings, access controls, and housekeeping were adequate; no apparent procedure adherence problems were identified.
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3.
Licensee Action on Previous Inspection Findings (0 pen) Open Item (483/84035-01):
Determine post-accident effluent sampling system iodine line loss correction factors.
NRR has not responded to the licensee's May 14, 1985 request for deviation from this portion of NUREG-0737, Item II.F.1, Attachment 2.
Pending the receipt of a response from NRR, this matter remains open.
(0 pen) Open Item (483/85006-04):
Prepare documents which identify the required compliance activities for NUREG-0737, Items II.B.3 and II.F.1 (Attachments 1, 2, and 3).
In a letter dated March 27, 1987, the licensee transmitted to NRC/ Region III a listing of additional items to be addressed in the licensee's NUREG-0737 Compliance Review Report and a schedule for completion of these items.
During this inspection, the inspector reviewed the eight action items completed by the licensee; no significant problems were noted.
The licensee has seven remaining action items, which are scheduled for completion by July 1, 1987.
This matter will be reviewed furthet during a future inspection.
(0 pen) Unresolved Item (483/86004-01):
Determine if the post-accident noble gas effluent monitors for the main safety relief valves /
power-operated relief valves are physically located in accordance with NUREG-0737, Item II.F.1, Attachment 1, requirements.
NRC Region III, by memorandum dated April 28, 1986, has requested that the acceptability of the installed post-accident noble gas effluent monitoring systems at Callaway be determined by NRR.
Pending the receipt of a response from NRR, this matter remains open.
(0 pen) Unresolved Item (483/86004-02):
Determine the acceptability of Technical Specifications 3.3.3.6 and 4.3.3.6 concerning identification of post-accident noble gas effluent radiation monitors.
NRC Region III, by memorandum dated April 28, 1986, has requested that the acceptability of Callaway Technical Specifications 3.3.3.6 and 4.3.3.6 be determined by NRR.
Pending the receipt of a response from NRR, this matter remains open.
(Closed) Unresolved Item (483/87007-01):
Complete the review of an incident during which off gases were inadvertently vented into the Radwaste Building.
The licensee has completed the review of this incident and completed or scheduled corrective actions.
Corrective actions which have
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been completed include placement in the Control Room of copies of a drawing which includes the details of the waste gas hydrogen recombiner skid, p'ans to utilize the drawing when preparing work packages for the waste gas system, and discussion of the matter with the individuals involved.
The licensee also plans to discuss this incident with all Radwaste Operators during the next requalification session.
The corrective actions taken
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appear adequate to prevent recurrence.
This matter is considered closed.
(Closed) Open Item (483/87007-02):
Revise seal table area access control.
The licensee has fabricated a temporary cover for the seal table access ladder that can be carried into the Reactor Building and locked in place by the Health Physics Department during Modes 3, 4, and
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This device will be used as an interim access control provision until a permanent design change can be evaluated and implemented; the licensee plans to install the permanent' device during the refueling outage which is scheduled to begin in September 1987.. Health Physics Technical
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Procedure No. HTP-ZZ-06001, "High Radiation /Very High Radiation' Area Access," was revised on March 24, 1987 to include the following seal table area entry requirements:
The real table area shall be. locked or barricaded to preclude
perronnel entry.
T.he access gate shall be posted " CONTACT HP FOR SURVEY PRIOR TO
ENTRY."
Personnel requiring access to the seal table area shall initiate
and obtain an RWP in accordance with Administrative Procedure No. APA-ZZ-01002, " Radiation Work Permits and Access Control,"
if an applicable RWP is not already in effect.
The licensee's response to this NRC inspector concern appears to be
timely, thorough, and technically sound; this matter is considered
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closed.
4.
Organization and Management Controls The inspector reviewed the licensee's radiation protection organization and management controls for the radiation protection program, including
changes in the organization structure and staffing, effectiveness of j
procedures and other management techniques used to implement the program,
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experience concerning self-identification and correction of program
implementation weaknesses, and effectiveness'of audits of these
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programs.
The inspector reviewed the organizational reporting chain of the Radiation Protection Manager (RPM).
There is only one level of management between the RPM and the Plant Manager; there appears to be no problems with the RPM's access to'the Plant Manager.
Recently the Manager, Callaway Plant, was promoted to General Manager, Nuclear Operations.
The Assistant Manager, Operations and Maintenance, was promoted to Manager, Callaway Plant.
The new Callaway Plant Manager obtained some expertise in radiation protection while serving in the nuclear navy program; he expressed to the inspector his personal commitment to fully support the Callaway radiation protection program.
There are currently 65 radiation, chemistry, and radwaste technicians positions authorized; all but one,are currently filled.
Thirty-two are radiation protection technicians, fifteen are radwaste technicians and seventeen are chemistry technicians.
There are eight radiation protection foremen, seven radwaste foremen, and four chemistry foremen.
The radiation i
protection professional staff includes the Health Physics Superintendent, the Health Physics Operations Supervisor, the Health Physics Technical
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Support Supervisor,'and two staff health physicists.
The chemistry-professional staff-includes the Chemistry Superintendent, two Chemistry i
i Supervisors,.one chemical' engineer, and two chemists.
The radwaste professional staff includes the Radwaste Superintendent, one radwaste I
shipping foreman, and one engineer. There are.also six Rad / Chem-apprentices and 20 Rad / Chem helpers.
The apprenticeship program is discussed in Inspection Report.No.'50-483/86004;- the helper program is discussed in Inspection Report No. 50-483/87007.
The licensee's radiation-protection staff has remained unchanged during the last year.
The average employment' history at Callaway for radiation protection technicians (RPTs) and foremen is 3.5 and 5.5 years,
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respectively, which is good for a relatively new plant (June 1984. fuel load).
It is the licensee's policy that newly hired technicians have at least three years relevant experience before employment at Callaway; the majority of this experience was.in the nuclear navy ELT program.
Due to j
the licensee's heavy reliance on the nuclear navy program to provide an
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experience base for their hirees, the radiation protection staff has very little commercial nuclear power plant experience' other than at Callaway.
It may be desirable to broaden their experience through short term assignments at other commercial nuclear power plants for i
some personnel.
The high level of staff stability and the increasing experience of i
the technicians is highly desirable and could lead to a very effective radiation protection program.
Several utility policies, however,-have j
the potential of partially negating the positive effect of staff stability, including transfer to open positions within the four groups of technicians
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(HP Operations, HP Technical Support, Chemistry, and Radwaste) based almost solely on seniority, limited progressive remuneration based'on experience /
superior performance, and a recent budgetary decision to reduce the staff by two RPTs and one health physicist.
Since many RPTs consider the tasks associated with the HP Operations group to be the least desirable, the utility seniority transfer policy has resulted in job coverage being conducted by the least experienced RPTs. With the rewards for superior performance being rather limited, the utility must rely on indirect methods to encourage good performance and on their ability to hire RPTs with good self-motivation.
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The proposed elimination of three HP positions has the potential for a negative effect on the radiation protection program, particularly the reduction of the number of health physicists from two to one.
Overall, it appears that more effective management support may be necessary to obtain the maximum benefit from the high staff stability and experience level of the radiation protection staff.
No' violations or deviations were identified.
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5.
Changes The' inspector reviewed changes in the organization, personnel, facilities, equipment, and programs.that-could effect the outage.
radiation protection program.
During the current maintenance outage, the station RPTs and foremen are providing continuous' coverage by working twelve-hour days, six days per week.
Health physics coverage is being provided by the Health Physics Operations Supervisor and the Health Physics Superintendent.
These health physicists are also working twelve-hour days to provide continuous.
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coverage during the weekdays, except between 10 p.m. and 5 a.m., and
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twelve-hour coverage each day on the weekends; however a health physicist remains on call during the off-hours. 'Although the health ~ physicist coverage for-the current maintenance outage seems appropriate,.the inspector discussed with the licensee the desirability of more extensive-coverage during the refueling' outage which-is scheduled.to begin in September 1987.
It also appears that the use of the Health Physics Superintendent for shiftly job coverage may detract from his managerial-duties.
The. inspector discussed with the. licensee the apparent'
desirability of using the two Health Physics Technical Support group health physicists for job coverage duties during outages.
It appears that the licensee's professional health physics staff may be undersized, especially dur*ng outages, if one of these two health physics positions
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is! eliminated (see Section 4).
The five HP Operations foremen are augmented during the outage by the-foreman from other groups (HP Technical Support, Chemistry, and Radwaste)-
and the temporary upgrade of five house RPTs to foremen.
The contracted and house RPTs work under the direction of these foremen who, in turn, report to a designated lead shift foremen.
Job coverage and contracted RPT oversight is facilitated by the use of these foremen.
The HP Operation RPTs are augmented by 18 RPTs from other groups (HP Technical I
Support, Chemistry, and Radwaste).
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These changes appear to benefit the station outage radiation protection program by providing the needed shiftly radiation protection coverage and better oversight of outage activities.
No violations or deviations were identified.
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l 6.
Planning and Preparation
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The inspector reviewed the outage planning and preparation performed by the licensee, including:
additional staffing, special training,.
increased equipment and supplies, and job related health physics considerations.
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The station ra:liation protection group has been augmented for the outage with'18 contracted radiation protection personnel, including eleven senior technicians and seven junior technicians.
The inspector selectively verified that those technicians.not meeting ANSI 3.1-1978 selection i
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criteria were not providing radiation protection duties without proper supervision.
Contract technicians are required to pass all Union Electric j
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l The supply of portable survey instruments, portable ventilation equipment, protective clothing, and respiratory protection equipment appears adequate for the outage.
Radiation protection influence / participation in job planning I
and preparation' includes mock-up training for high exposure work, decontamination and installation of shielding prior to initiation of work, and radiation protection and ALARA participation,in plannir.g and outage meetings. -Problems identified concerning the ALARA program
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j are discussed in Section 11.
l No violations or deviations were identified.
7.
Training and Qualifications of New Personnel The inspector reviewed the education and training qualifications of new plant and contractor radiation protection personnel, and training provided
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to them.
Also reviewed was radiation protection training provided to other contractor personnel.
Selection of contracted radiation protection technicians includes a review of the technicians' resumes, discussion with previous employees, an entrance examination, and a personal interview if the examination grade is marginal.
After selection, the contract technicians are given
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three days of training including 18-20 hours of classroom instruction on general rad worker training, Union Electric radiation protection
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procedures, radiation work permit usage, detector theory, shielding calculations, and about 1/2 day of practical health physics evaluations.
A 125 and a 200 question examination is given to each junior and senior technician, respectively; a passing grade of 70 percent is required.
The inspector reviewed the test questions; the tests appear to be thorough, comprehensive, and of moderate difficulty.
The examination is followed by individual interviews with foremen concerning the questions missed.
In addition, the Health Physicist Operations Supervisor and the Health Physics Superintendent interview each technician to assess the technician's qualifications, training, experience, radiation protection knowledge, and resume.
Examination records were selectively reviewed;
no problems were noted.
In January 1987, the licensee revised the HP Operations RPT six-month requalification program by altering the examination cycle.
The new exam cycle is scheduled such that two exams are given during cach six-month requalification training cycle.
The examinations cover procedures, shift directives, systems, HP theory, and the retest of concepts frequently missed on previous examinations.
The cycle is designed such that all HP procedures and shift directives will be covered in 18 months, identified systems will be reviewed over two years, and theory review will be identified in the study guide.
Questions missed by 25% or greater
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of the RPTs are to be reviewed at RPT meetings.
RPTs performing significantly below the group. average are to be interviewed by a foreman.
RPTs with grades below 70% are to retake the same test in an open-book manner and have a followup interview with a. foreman.
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The inspector reviewed the results for the first examination in this cycle; it was noted that most of the RPTs scored between 80% and 90%,
with the exception of two RPTs who scored slightly above 70%.
The inspector discussed with the HP Operations Supervisor the counseling these two RPTs received; no problems were noted.
The revision of the HP Operations RPTs requalification requirements appears to strengthen the requalification training program; however, the technicians in the other groups (HP Technical Support, Chemistry, and Radwaste), which may augment the job coverage activities of the HP Operations RPTs during outages, have not revised their requalification programs in a similar manner.
Partially in response to INPO concerns, the licensee has established a field observation program.
This program increases the on-the-job i
l supervision of the HP Operation RPTs for routine (performed at least once a week), planned (known greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance), and jump-up (known less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance) tasks.
Task observation will be performed by the three office foreman and the HP Operations Supervisor.
Each office foreman is to observe each of the 14 tasks, twice during a 15-week cycle.
The HP Operations Supervisor is to observe each task once during a 15-week cycle.
Observations of jump-up tasks may be performed by the Respiratory Protection or Instrumentation Foremen on PM or Saturday AM shift, if shift workload allows.
The present field observation program tasks are for RCA job coverage, surveys, and miscellaneous activities.
Respiratory protection and calibration tasks are being l
developed.
Field Observation Reports (FORs) are completed for each
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observation in which RPT performance is assessed.
The inspector reviewed l
several completed FORs and the associated task performance criteria checklists; no problems were noted.
No violations or deviations were identified by the inspector.
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8.
External Exposure Control The inspector reviewed the licensee's external exposure control and personal dosimetry programs, including:
changes in program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
Exposure records of plant and contractor personnel for 1986 and 1987 to date were selectively reviewed.
No exposure greater than 10 CFR 20.101 I
or administrative limits were noted.
Total exposure for 1986 was about 224 person-rem.
The total exposure for 1987 through April 22, 1987, which includes 21 days of the outage, is about 112 person-rem based on reported self-reading dosimeter readings.
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The inspector selectively reviewed current RWPs on file at Access Control for completeness, approval, ALARA review, and survey data.
Current radiation and contamination survey maps are displayed in a catalog type display file on the desk in Access Control and are available for reference.
Survey records are reviewed by a foreman.
No problems were noted.
Posting and labeling in the radiation controlled area (RCA) were observed during plant tours; no problem areas were noted.
Housekeeping appeared to be adequate.
No violations or deviations were-identified.
9.
Internal Exposure Control The inspector reviewed the licensee's internal exposure control and assessment programs, including:
changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notifications.
Whole body counting data and air sample data for 1986 and 1987 to date were selectively reviewed; no problems were noted.
No airborne uptake har, been reported in 1987, as of April 22.
In 1986, reportedly only two airborne uptake incidents took place; an August incident which involved thyroid uptake of I-131 and I-133 by ten individuals who were initially estimated to have received between 3.4 and 50% of maximum permissible organ burden (MP08) (see Section 16 of Inspection Report No. 50-483/86011)
and an April incident which involved the GI uptake of Co-60 by two individuals who received.17 and.8% MPOB.
The inspector reviewed the licensee internal reports of these incidents, including the descriptions of the events, lessons learned, action to prevent recurrence, the
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evaluation of whole body counts (WBC) data, and assessment of internal I
exposure; no problems were noted.
Because the computer generated WBC data assessment for the individuals involved in the August 1986 incident differed significantly from the procedural hand-calculations, the licensee obtained independent assessments from two independent consultants; the consultants verified the validity of the licensee's hand-calculations.
The licensee has also hired a consultant to review and revise, as approm iate, plant procedures, the data base, and software associated wi.h the computer generated WBC data assessment program; all necessar; corrections and j
revisions are expected to be completed by August 1987.
Until this project is successfully completed, the licensee intends to rely on procedural hand-calculations for future incidents which may require WBC data assessment with consultant verificv ion, if deemed appropriate.
No violations or deviations were identifisd.
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Control of Radicar,tive Materials and Contamination The inspector 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;
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effectiveness of survey methods, practices, equipment, and procedures;-
-1 adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated materials.
Inspector observations at access control points indicate that workers are properly using step-off pads and following frisking and portal monitor procedures.
No problems were noted.
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Floor area contamination in the auxiliary, fuel,'and radwaste buildings are' reported in the licensee's Monthly Health Physics Radiological Data
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Summary.
These reports indicate an increase in: floor area contamination from about 12,000 square feet in January 1987 to about 14,000 square feet in March 1987.
The reports also reveal that the floor area contamination monthly average has remained above 12,000 square feet for over a year.
The station's 1987 goals for floor area contamination in the auxiliary, fuel, and radwaste buildings is 12,000 (acceptable), 10,000 (commendable),
8,000 (excellent) square feet.
Recent increases in reactor coolant specific activity due to increased fuel leakage should tend to increase contamination levels in the plant.
An audit of the radiation protection program was performed at the:
Callaway Plant October 16-29, 1986, by the Union Electric Quality Assurance Operation Support Group.
One of the audit conclusions was that the radiological material control program has not been adequately implemented; therefore, control of radiological material has not been effective.
The audit also noted minor problems'with the survey equipment control program.
Twelve procedural and two technical specification violations were identified in these two functional areas, The auditors entered their findings into deficiency-reporting and correction systems
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by issuing two Incident Reports and the following eight Requests for
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Corrective Action (RCA):
RCA No. 8611-146, " Calibration Program Implementation"
RCA No. 8611-147, " Incomplete Master Source Index Entries"
RCA No. 8611-148, " Licensed Sources Moved Without Documentation"
RCA No. 8611-149, " Exempt Sources Moved Without Documentation"
RCA No. 8611-150, "QA Record Not Filed"
- RCA No. 8611-151, " Conditioned Release Log Not Current"
RCA No. 8611-152, "IR Not Generated to Identify Sealed
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Source Leaks"'
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l RCA No. 8611-153, " Leak Test Not Performed on Sealed Source
Prior to Use"
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The inspector reviewed the responses to the above RCAs and interviewed the auditors and appropriate radiation protection staff members; no problems were noted.
The inspector also selectively reviewed QA surveillance reports which verified that the correction actions specified in the response to the RCAs have been implemented; no problems were noted.
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root cause of many of the violations was listed as insufficient management
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oversight by HP Operations foremen and corrective actions included additi.onal RPT requalification training.
The Job Observation Program and the expanded RPT requalification are discussed in Section 7.
RCA No. 8611-153 resulted in the issuance of LER No. 483/86-036-00 which is discussed in Section 14 of Inspection Report No. 50-483/87007.
During an auxiliary building plant tour, it was noticed that a table which was located in the general access area just uutside the hot tool crib, had bagged contaminated material piled on top and lying in the near vicinity.
The inspector was informed by licensee representatives that the table was a decontamination station and a staging area for highly contaminated material.
Bagged tools and equipment are decontaminated on the table if a hand-held frisker reads less than 500 cpm on the outside of the bag.
If the reading is greater than
500 cpm, the bag and its contents are carried to an area outside the hot machine shop for decontamination.
The table decontamination station contains materials for decontamination by hand; the area outside the hot machine shop contains more sophisticated decontamination equipment, including a Freon cleaning unit; tools and equipment which prove difficult to decontaminate by hand methods are also transferred to the area outside the hot machine shop.
The inspector discussed with HP supervision the poor HP practice of decontamination activities in a general access area and the apparent desirability of an integral positive-control facility for properly staging the collection, decontamination, and reissuance of tools and equipment in the area of the hot tool crib.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection (483/87013-01).
No violations or deviations were identified by the inspector.
11. Maintaining Occupational Exposures ALARA The inspector reviewed the licensee's program for maintaining occupational
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exposure ALARA, including:
changes in ALARA policy and procedures; ALARA
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considerations for maintenance and refueling outage; worker awareness and involvement in the ALARA program; establishment of goals and objectives,
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and effectiveness in meeting them.
Also reviewed were management techniques used to implement the program and experience concerning self-identification and correction of implementation weaknesses.
The licensee established ALARA goals for 1986 and 1987, including overall j
station goals for total dose and contaminated areas, and individual j
working group goals for total dose.
The 1986 total dose goals of 450,
350, and 250 person-rem were designated by the licensee as " acceptable,"
" commendable," and " excellent," respectively.
The total dose for 1986 was 224 person-rem.
The 1987 exposure goals are 300, 250, and l
225 person-rem for acceptable, commendable, and excellent, respectively.
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l In addition to the exposure goals outlined above, it is a station goal that no individual receive more than 5 rems during 1987.
This goal was met in 1986 and to date in 1987.
During plant tours, documentation reviews, and interviews with plant personnel, the inspector identified apparent weaknesses in the licensee's ALARA program, including:
Housekeeping, although adequate, appears to have declined compared
to observations made by the inspector during previous onsite inspections.
It was also noted that the licensee has not met their contaminated floor area ALARA goals (see Section 10).
The problems
with housekeeping and decontamination were also noted during a
previous inspection (Inspection Report No. 50-483/86004); as stated
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in that report, these problems appear to be due, in part, to a relatively inexperienced and understaffed Rad / Chem helper staff.
The inspector's concern regarding the'high turnover rate for the helper staff was discussed with members of the licensee's supervisory and managerial staff.
The ALARA suggestion program is not actively promoted and is
utilized mostly by the radiation protection staff.
The Plant ALARA Committee (PAC), however, has developed plans to encourage participation by all plant departments in the ALARA suggestion program by the use of posters and an awards program.
Although the HP budget has funds approved for awards, no policy has been established for the promotion of the ALARA suggestion program nor has criteria been established regarding the award criteria.
The licensee continues to move slowly in this important area of the radiation protection program.
The licensee has prepared approximately 20 job history files; these
were selectively reviewed by the inspector.
It appears desirable that the files be better organized and more extensive, thorough, and comprehensive.
The existing job history files encompass the
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significant jobs with the potential for high exposure; however, l
the job history files do not appear to be adequately segmented into individual tasks in a manner which would facilitate the ALARA reviews necessary to further enhance the overall goal of exposure reduction.
It also appears the licensee may be missing the opportunity for significant integral dose-savings by not creating job history files for smaller, more routine tasks which require an initial ALARA review.
Based on discussions with plant personnel, it appears that
often ALARA pre-job briefings are done rather informally without individuals necessarily being fully aware of their duties and responsibilities.
After steam generator sludge lancing, the licensee attempted to feed a suction device into a steam generator with a thick metal tape (fish tape) in order to remove residual material.
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l Apparently because an individual did not properly understand his duties, several tens of feet of fish tape were left in the steam generator, tangled around the support structure.
Numerous attempts to remove the fish tape were made by utility and contract personnel, all met with failure until a specialist consultant removed the tape with the use of sophisticated remote tools.
Due to the high dose rate in the vicinity and the additional man-hour expenditure, the estimated exposure for sludge lancing was grectly exceeded.
It appears desirable for the licensee to have ALARA pre-job planning sessions and worker briefings which are extensive, thorough, and I
comprehensive enough to greatly decrease the probability of errors i
of this significance occurring and to significantly limit the l
exposure during recovery after such an incident has occurred.
The output of three separate computer programs must be entered
into a personal computer before data directly relevant to the ALARA program can be generated.
Because the information in the three separate tracking systems (RWP, status of work scheduling, and work request progress) are not designed to be compatible, the resulting composite data used by the ALARA group is not in the most useful form and the accuracy may be suspect.
Also, the ALARA data generated is often not timely and the time spent in manipulating data reduces the overall effectiveness of the ALARA program.
It appears that the licensee may need to significantly improve the ALARA computer program capabilities.
- The ALARA staff is under the direction of the chairman of the Plant ALARA Committee (PAC), who is also the Health Physics Operations Supervisor.
In addition to the chairman, the PAC consists of 11 members, one from each plant major disciplinary area.
The PAC meets quarterly to set ALARA goals, evaluate the effectiveness of the ALARA program, resolve ALARA concerns, respond to completed ALARA suggestion forms, review job history files, and implement the lessons learned from each task performed to develop dose-saving techniques for future jobs.
Most of the daily ALARA duties are the responsibility of the RWP Coordinator (foreman) who is responsible for both RWP and ALARA duties.
During the outage, the RWP Coordinator has been assisted by two RPTs.
The Planning and Scheduling Department has assigned a planner as a full time liaison with the HP Operations staff.
The foreman in charge of dosimetry also lends support to the ALARA organization by aiding in the compilation of dose expenditure data.
It appears, partially because of the fragmentation of the ALARA
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organization among individuals who have other responsibilities and
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duties, the ALARA program is not making the most effective use of available manpower.
It appears that the ALARA group may function more effectively if it were a more cohesive organization without the impediment of other duties; the desirability of the appointment of a full time ALARA Coordinator was discussed with licensee supervisory and managerial personnel.
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The above inspector concerns and the apparent need to significantly improve the ALARA program n s discussed at the exit meeting and will be reviewed further during a future inspection (483/87013-02).
No violations or deviations were identified.
12. Audits and Appraisals I
l The inspector reviewed reports of audits and appraisals conducted for or
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by the licensee including audits required by the technical specifications.
A1so reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesses.
I A station Quality Assurance (QA) audit of the radiation protection l
program was conducted October 16-29, 1986.
Areas audited included radiological surveys, survey equipment control, and radioactive material control.
No cor.dition's adverse to quality were identified with the radiological survey program; however, the audit identified minor problems with the survey equipment control.progren and concluded that the radiological material control progran has not been adequately implemented.
The inspector reviewed the audit report, the associated requests for corrective action (RCAs), and the response to the RCAs, and interviewed the auditors and appropriate radiatlon protection staff.
The licensee appears to be adequately responsive to the auditors' concerns; the audit findings and corrective actions are discussed in Section 10.
In addition to the QA audit report, the inspector also reviewed the 1986 INP0 radiation protection program inspection report and recent QA surveillance reports, including the adequacy of the licensee's responses to the concerns identified by these reports.
The surveillance reports reviewed included RCA personnel access controls, respiratory protection qualification records, radiation reduction efforts during contaminated filter transfer, radiological posting, RWP compliance, and the GMR-I canister program.
No quality concerns were identified for RCA access
control and contaminated filter transfer; minor problems were identified i
regarding respiratory protection qualification records,and postings; significant RWP compliance problems were identified; and the GMR-I canister
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program is discussed in Section 17. <The inspector reviewed the licensee's-l response to the INPO inspection report and the QA surveillance reports;
minor problems with the corrective actions were discussed and resolved with the appropriate radiation protection staff.
The surveillance of RWP compliance was conducted by QA personnel on
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April 6-9, 1987.
Six examples were identifiod by the auditors of failure i
to follow RWP instructions regarding protective clothing and respiratory i
protection requirements.
The QA auditors also noted that 22 of 48 j
individuals observed did not follow procedure and read the RWP under which they were entering the RCA.
It appears that the licensee may have
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a significant RWP compliance problem; however, efforts to correct the
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problem are somewhat hampered by the failure of the QA auditors to record i
the names of the procedural violators and to follow Administrative i
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I Procedure No. APA-ZZ-01000, "Callaway Plant Health Physics Program,"
which requires that a Radiological Work Practice Deficiencies (RWPD)
report be completed when a violation of a health physics procedure or policy occurs.
The RWPD reporting program is discussed in Section 15.
No violations or deviations were identified.
13.
Facilities and Equipment The inspector toured radiation protection facilities, observed radiation
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protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staff.
The licensee recently modified the health physics RCA access control (HPAC) facility and traffic patterns to facilitate the increased activities during the current maintenance outage.
Before the next refueling outage, which is scheduled for September 1987, the licensee intends to more extensively modify the facility to accomplish the following goals:
Reduction in the time to process workers in and out of the
RCA during outages, j
l Reduction in delays associated with the processing and writing
i of RWPs for special jobs.
Improvement of the plant contamination control program.
- Improvement of the plant ALARA program.
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Increase in effectiveness of health physics personnel
and improvement in shift turnover during outages.
Provide a more effective utilization of available space.
- Improvement of the respiratory protection program.
- The inspector discussed the details of the HPAC facility modifications with the licensee; no problems were noted.
The licensee expects to accomplish the above goals by making the following provisions for personnel at the HPAC facility:
Additional workspace for technicians and foremen.
- Better location for personnel and item decontamination areas.
- A location for ALARA/RWP briefing of workers.
- Additional space for storage and issuance of respirators.
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In response to INPO concerns, the licensee has improved the environmental conditions in the counting room, locked appropriate potential high radiation area doors, and increased supervisory oversight of the radiation instrumer t calibration program.
A review of the licensee's contamination monitoring instrumentation inventory indicates that the station has 75 hand-held friskers (Ludlum/Model 177's) and 13 contamination monitors (three PCM-l's, four PCM-1A's, and six Gamma 10's).
The inspector reviewed the assigned i
locations for each instrument, and selectively verified that instruments
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were in their assigned locaticns; no problems were noted.
No violations or deviations were identified.
14.
Personal Contamination Reports Callaway Plant Health Physics Technical Procedure No. HTP-ZZ-06009,
" Personnel Decontamination," requires a Personnel / Personal Clothing Decontamination Record Form be prepared for each detectable skin and/or clothing contamination event (PCE).
The 1986 goal was not to exceed 250 PCEs; 240 occurred.
The licensee has begun a program to carefully monitor PCEs for root causes and to take prompt corrective action to prevent recurrence.
The 1987 goal is not to exceed 100 PCEs; the total, as of April 24, 1987, is 58.
The inspector selectively reviewed personnel contamination event reports and interviewed the health physics supervisory staff regarding the adequacy of managerial oversight and corrective action to prevent recurrence; no significant problems were noted.
A significant number of the PCEs which occurred during the current outage were hand conta: inations due to inadequate laundering of rubber gloves; althougn ;e management oversight allowed several recurrences, once the root cause was determined prompt and effective corrective action was forthcoming.
Corrective actions for the glove contamination included the following instructions:
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Turn gloves right side out before washing.
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All outer gloves from within the bioshield are to be thrown away.
- Everyone in the Reactor Building will wear surgical gloves under
outer glove liners.
After washing, all outer giovas should be frisked with a pancake
probe.
If greater than 100 cpm, gloves will be rewashed; frisk both sides.
Complete distillation on all laundry machines, check filters, etc.
- Maintain a record of reject rate, time, etc., by shift so that HP
can evaluate the magnitude of the problem, the impact for the next outage, and the effect of any corrective action.
No violations or deviations were identified.
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15.
Radiological Work Practice Deficiency Reports I
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Through 1986, Callaway Plant Administrative Procedure No. APA-ZZ-00160,
"Callaway Plant Health Physics Program," required that a Notice of Radiological Work Practice Violation (RWPV) Form be prepared for radiological incidents or situations which do not conform with health
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physics procedures or good health physics practices.
Because the RWPV
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Form was used only for significant violations of HP procedures and practices, the licensee revised the procedure in an attempt to create l
a useful tool to monitor, trend, and improve radiological work practices of plant personnel.
Beginning in 1987, Callaway Plant Administrative Procedure No. APA-ZZ-01000, "Callaway Plant Health Physics Program," established the Radiological Work Practice Deficiency (RWPD) Reporting System.
The procedure states that the RWPD reports shall be used to monitor, trend,
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and improve radiological work practices of plant personnel.
The objective
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of these reports is to identify and correct violations / deficiencies in
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radiological work practices, to minimize their occurrence, and to prevent the continuation of problems that could compromise worker safety or become a regulatory concern.
The RWPD reports consist of a description of the facts concerning the incident or deficiency, an evaluation to determine root cause or generic problems, and documentation of corrective actions taken.
When applicable,
the RWPD report is forwarded to the worker's supervisor for review and l
corrective action.
A RWPD report is to be completed when a violation of health physics procedures, practices, or polices occurs or when deficiencies related to radiological controls are observed.
As of April 24, 1987, 18 RWPD reports have been initiated; because the number of RWPD reports was similar to the number of RWPV reports issued over the same time period during previous years, the inspector selectively reviewed RWPD and RWPV reports and interviewed HP supervisory personnel to determine if the more extensive RWPD reporting system was being adequately utilized.
Ic appears that the new RWPD reporting system is being significantly underutilized and a formal tracking and trending program for the RWPD reporting system has not been effectively established.
l An example of a failure to properly utilize the RWPD reporting system occurred during the QA surveillance of RWP compliance on April 6-9, 1987.
Twenty-eight procedural violations were noted by the auditors; yet the auditors failed to use the RWPD reporting system thereby somewhat hampering corrective actions by not recording necessary information, such as the names of the procedural violators (see Section 12).
After discussions with inspector and HP supervisory personnel, QA auditors agreed to use the RWPD reporting system during future audits including a followup audit of RWP compliance on April 13-20, 1987, which identified the following procedural violations:
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A worker was observed in the RCA conducting grinding activities
without wearing a respirator, although the RWP required that a respirator be worn.
A worker was observed decontaminating tools and equipment in
the hot machine shop area without wearing a RWP required hood.
A worker left a contaminated area to use the restrocin end re-entered
the area without following the plant's frisking policy.
The underutilization of the RWPD reporting system and the apparent desirability of establishing a more formal system to monitor and trend RWPD reports was discussed at the exit meeting and will be reviewed further during a future inspection (483/87013-03).
No violations or deviations were identified by the inspector.
16.
Containment High Range Radiation Monitor Surveillance Calibration As part of the inspection of the licensee's compliance with commitments j
made to the NRC regarding NUREG-0737, Item II.F.1.3, the inspector
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reviewed the following Callaway Plant I&C Loop Calibration Surveillance Procedures:
No. ISL-GT-00R59, " Loop-NUC; CTMT High Range Area Rad Mon"
No. ISL-GT-00R60, " Loop-NUC; CTMT High Range Area Rad Mon"
I These procedures list the source calibration tolerance as -50%, +200%.
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The inspector contacted vendor personnel who stated that the tolerance usually suggested was 115%.
The licensee agreed to correct the procedures before use.
The inspector reviewed the data sheets for the four source l
calibrations which the licensee has completed; three actual calibration
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tolerances were somewhat beyond 15%.
This matter was discussed at the exit meeting and will be reviewed further during a future inspection (483/87013-04).
No violations or deviations were identified by the inspector.
17.
GMR-I Canister Respiratory Protection Program On December 29, 1986, the NRC issued an exemption to 10 CFR 20, Appendix A, Footnote d-2(c) to the licensee which allows the use of a radioactive protection factor of 50 for GMR-I canisters at Callaway.
The licensee requested the exemption and made specific commitments in letters to the NRC dated October 22, 1985 (ULNRC 1193) and August 29, 1986 (ULNRC 1368).
The licensee altered some commitments in a letter (ULNRC 1409) to the NRC dated November 18, 1986.
In response, Union Electric received a correction to the exemption from the NRC on January 15, 1987.
A QA surveillance was conducted on March 9-13, 1987 (SP87-017) to verify that the Union Electric program implementing the 10 CFR 20 exemption for i
GMR-I canisters satisfies all applicable NRC commitments and restrictions.
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Twenty individual commitments were identified and reviewed for compliance by the QA auditors.
The following internal licensee documentation which implements this program was also reviewed by the QA auditors:
UOTH 87-035
UDPMS 87-0002 Health Physics Operations Shift Directive (HPOSD) 403
Proposed Revision 5 of HDP-ZZ-01300, " Internal Dosimetry Program"
Proposed Revision 8 of HTP-ZZ-08300, "MSA Respirator, Supplied Air
Hood, and SCBA Inspection and Storage" Proposed Revision 7 of HDP-ZZ-08000, " Respiratory Protection
Program" Proposed Revision 6 of HTP-ZZ-08002, " Issuance, Use and Return of
Respiratory Protection Devices" HDP-ZZ-06017, Revision 8, " Rad-Chem Technician Health Physics
Qualification /0JT Program" Although the QA auditors found that the applicable commitments associated with the GMR-I program are adequately addressed, the auditors felt that the followirig recommendations would enhance the use of GMI canisters:
Proceduralize temperature and dewpoint measurement methodology.
- Develop calibration procedures for temperature and dewpoint
measurement devices.
Develop a method to document temperature and dewpoint measurements.
- Expand Section 2.2.3 of Qualification Standard of Attachment 11 to
HDP-ZZ-06017.
Specifically, the revised standard should address followup bioassays related with the use of GMR-I canisters.
Address temperature and dewpoint measurements as a qual card task.
- The Health Physics Superintendent agreed to implement all auditor recommendations and to develop a procedure to address the performance and documentation of temperature and dewpoint measurements as well as the calibration of the instruments, based on manufacturer's recommendations.
In addition, HDP-ZZ-06017 will be revised to incorporate the followup
bioassay surveys as a knowledge item and the measurement of temperature I
and dewpoint as a qual card task.
The licensee expects to have these changes implemented by July 1, 1987.
No violations or deviations were identified.
18.
Reactor Coolant High Specific Activity Special Reports Technical Specification 3.4.8 requires the licensee to prepare and submit a Special Report to the Commission pursuant to Specification S.9.2 within 30 days whenever the specific activity of the reactor coolant is greater than 1 microcurie per gram DOSE EQUIVALENT I-131 (DEI-131).
The licensee has submitted three of these reports to the NRC; the root cause in each case has been attributed to fuel cladding defects.
DEI-131 exceeded i
1 uCi/gm on August 25, 1986, January 30, 1987, and April 2, 1987, as
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reported in Special Reports 86-07, ULNRC-1374, dated September 23, 1986; 87-01, ULNRC-1452, dated February 27, 1987; and 87-02 ULNRC-1495, dated April 22, 1987, respectively.
l The inspector reviewed the reports for compliance with Technical Specification requirements; no problems were noted.
The inspector also discussed with licensee supervisory and managerial personnel, the significance the defective fuel and high specific activity may have on the radiation protection program implementation.
The licensee informed the inspector of the plans to detect and remove defective fuel from the core during the next refueling outage, scheduled for September 1987.
No violations or deviations were identified.
j 19.
Radiation Monitor Technical Specification Amendment The NRC #ssued Amendment No. 20 to Facility Operating License No. NPF-30 for Callaway Plant, Unit 1 on April 10, 1987.
The amendment consists of a change to the Technical Specifications in response to the licensee's application dated December 30, 1986, supplemented by a March 13, 1987 submittal.
The amendment changes the Technical Specifications to delete the trip functions of the containment atmosphere radiation monitor associated with containment purge isolation and control room ventilation.
Union Electric Company requested the Technical Specification changes because these monitors were causing spurious trips and also to provide flexibility for monitor maintenance.
The changes to the echnical Specifications are as follows:
The containment atmosphere gaseous radioactivity moniter3
(GT-RE-31 and 32) are removed from Table 3.3-6. " Radiation Monitoring Instrumentation for Plant Operations."
The minimum operability requirements for containment purge system
noble gas activity monitors (GT-RE-22 and 33), which provide an alarm and automatic termination of release, was changed from one to two in Table 3.3-13, " Radioactive Gaseous Effluent Monitoring Instrumentation."
Action 41 associated with the above monitors has been changed to
state that with one channel operable, purging of effluents may continue for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; with both channels inoperable, immediately suspend purging.
The bases for Technical Specification 3/4.9.4, " Containment Building
Penetrations," has been modified to include the GT-RE-22 and 33 setpoint concentration of SE-3uCi/cc which is equivalent to approximately 150 mR/hr submersion dose rate.
(Note:
the setpoint for GT-RE-31 and 32 was 9mR/hr.)
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Exit Meeting The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on April 24, 1987.
Further discussior.s were conducted by the telephone through June 15, 1987.
The inspector summarized the scope and results of the inspection and discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the i
inspection.
The licensee did not identify any such documents / processes i
I as proprietary.
In response to certain matters discussed by the inspectors, the licensee:
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Acknowledged the inspector's concerns regarding the decontamination activities in the area of the hot tool crib.
(Section 10)
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Acknowledged the inspector's concerns regarding the ALARA program l
and agreed to appoint a full-time ALARA Coordinator.
(Section 11)
c.
Agreed to improve the utilization of the Radiological Work Practice Deficiency reporting system.
(Section 15)
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d.
Agreed to correct the calibration criteria in the containment high j
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range radiation monitor surveillance procedures.
(Section 16)
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