IR 05000483/1987031
| ML20236S937 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/19/1987 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236S905 | List: |
| References | |
| 50-483-87-31, IEIN-87-039, IEIN-87-39, NUDOCS 8711300194 | |
| Download: ML20236S937 (23) | |
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U.S.. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-483/87031(DRSS) ,
Docket No. 50-483 License No. NPF-30 l
Licensee: Union Electric Company Post Office-Box 149 St. Louis, MO 63166 Facility Name: Callaway County Nuclear Station Inspection At: Callaway Site, Callaway County, Missouri Inspection Conducted: October 6-9, 1987 (Qi 0 , 9/2Al($m ',
Inspector: C. F. Gill // //#M'7
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Accompanying Inspector: W. W. Ogg Approved By:
& e ww&/p L. R. Greger, Chief //////k'7
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Facilities Radiation Date'
Protection Section Inspection Summary Insper. tion on October 6-9, 1987 (Report No. 50-483/87031(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; licensee response to NRC Information Notice No. 87-39; certain LERs; and open item Results: Two violations were identified (failure to sample and analyze the unit vent gaseous tritium effluent monthly, Section 16; and failure to follow RWP requirements, Section 20).
8711300194 871119 PDR ADOCK 05000483 G PDR l
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i DETAILS Persons Contacted
'*R. Affolter, Superintendent,' Systems Engineering L. Auman, Foreman, Health Physics L. Beaty, I&C Engineer
- J. Blosser, Plant Manager
- W. Campbell,' Manager, Nuclear Engineering
- J. Gearhart, Superintendent, QA0S
- C. Graham, Supervisor, Health Physics Technical Support
- D. Hollabaugh, Supervising Engineer, System Engineering
- J. Little, Assistant QA Engineer
- J. Neudecker, Foreman, Health Physics
- J. Polchow, Supervisor, Health Physics Operations
- G. Randolph, General Manager, Nuclear Operations
- W. Robinson, Assistant Manager, Operations and Maintenance
- R. Roselius, Superintendent, Health Physics
- K. Schweiss, System Engineer
- V. Shanks, Superintendent, Radwaste
- T. Sharkey, Supervisor, Compliance G. Spires, ALARA Coordinator
- B. Stanfield, QA Engineer
- T. Stotlar, Supervising Engineer, QA0S D. Stretch, Health Physicist i C. Brown, NRC Resident Inspector
- B. Little, NRC Senior Resident Inspector The inspectors also contacted other licensee employees including radiation protection technicians and members of the engineering staf * Denotes those present at the exit meeting on October 9, 1987. General This inspection, which began at approximately 1:00 p.m. on October 6, 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, licensee response to NRC Information Notice No. 87-39, certain LERs, and open items. During !
plant tours, the inspectors noted that area posting, access controls, and housekeeping were adequate; apparent procedure adherence problems ;
are discussed in Section 2 !
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.= . Licensee Action on Previous Inspection Findings (Closed) Open Item (483/87013-01): Improve:the hot tool crib decontamination facility. The licensee h'as moved the decontamination station out'of the' general access area and established positive administrative controls to adequately stage the collection, decontamination,- and reissuance of tools and equipment.in the area of the hot tool cri This matter is-considered close '(0 pen) Open Item (483/87013-02): . Improve the ALARA program. Although the. licensee has made some improvements in the ALARA program, further 3 improvements appear desirable; see Section 1 (0 pen) Open' Item (483/87013-03): Improve the utilization of.the Radiological Work Practice Deficiency Reporting.(RWPDR) syste Although the licensee made some initial improvements in the utilization of the RWPOR system, further improvements appea desirable; see Section.1 (Closed).0 pen Item (483/87013-04): Correct the calibration criteria in the containment high range radiation monitor surveillance procedure ~
The licensee issued Revision 6 of the subject procedures (16. ISL-GT-00R59 and 60) which included corrections of the source calibration tolerance from - 50%, + 200% to i 15% and the electronic calibration tolerance from
- 17%, + 20% to i 10%. The. licensee stated.that the earlier calibration ,
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tolerances were due to an incorrect interpretation of vendor information and that the vendor concurred with the procedural revision The matter is considered close . Organization and Management Controls The inspectors 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 precedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of these program The. radiation protection, chemistry, and radwaste organizational structures remain the same as described in Section 4 of Inspection Report No. 50-483/87013,, except two technician positions are vacan Because the licensee is considering reducing the number of technician 1 positions, there are no current plans to fill vacant position In'spector concerns regarding the proposed reduction of technicians is discussed in Section 4 of Inspection Report No. 50-483/8701 The licensee stated that a decision concerning whether or not to retain the apprenticeship program would be made in approximately one year, when the current six apprentice technicians are qualified pursuant to ANSI 3.1-1978 criteria. The licensee also stated that current staffing j
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i plans include retaining two health physicist positions. The.Radwaste Superintendent has resigned to accept a position with another licensee; the' Chemistry Superintendent has been appointed as the Radwaste ,
Superintendent; and the Secondary Chemistry Supervisor has been appointed l as the Chemistry Superintenden No violations or deviations were identifie { Changes The inspectors reviewed changes in the organization, personnel, facilities, equipment, and programs that could affect the outage radiation protection progra During the current refueling outage, the station RPTs and foremen are providing continuous coverage by working 12-hour days, six days per wee Health physics coverage is being provided by the Health Physics Operations '
Supervisor and the Health Physics Superintendent. These health physicists are also working 12-hour days to provide continuous coverage during the weekdays, except between 12:30 a.m. and 5:30 a.m., and 12-hour coverage ;
each day on the weekends; however, a health physicist remains on-call during the off-hour The five HP Operations foremen are augmented during the outage by the foreman froia other groups (HP Technical Support, Chemistry, and Radwaste)
and the temporary upgrade of five house senior RPTs to foreman. The contracted and house RPTs work under the direction of these foremen who, in turn, report to a designated lead shift foreman. Job coverage and contracted RPT oversight is facilitated by the use of these forema The HP Operations 14 senior and two junior RPTs are augmented by 14 senior and ten junior RPTs from other groups (HP Technical Support, Chemistry, and Radwaste).
These changes appear to benefit the station outage radiation protection program by providing needed radiation protection coverage and better oversight of outage activitie No violations or deviations were identifie . Planning and Preparation i
The inspectors reviewed the outage planning and preparation performed by the licensee, including: additional staffing, special training, increased equipment and supplies, and job related health physics consideration The station radiation protection group has been augmented for the outage L with 36 contracted radiation protection personnel, including 26 senior
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technicians and ten junior technicians. The inspectors selectively
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verified that those technicians not meeting ANSI 3.1-1978 selection ;
criteria were not providing radiation protection duties without proper l supervision. Contract technicians are required to pass all Union Electric qualification card requirements. The licensee obtained a much lower than desired percentage of contract'RPTs who had previous Callaway work experience. The licensee discussed with the inspectors future plans to ensure optimum numbers of contract and return RPTs for future outage Although licensee representatives indicated that RP job coverage was occasionally strained during this outage, the licensee stated that the augmentation by technicians from other station groups (HP Technical Support, Chemistry, and Radwaste) increased the overall staff sufficiently to provide overall adequate health physics coverage; possible exceptions to this claim are discussed.in Sections 11, 14, 15, and 2 The supply of portable survey instruments, portable ventilation equipment, protective clothing, and respiratory protection equipment appears adequate for the outage with the exception of occasional protective clothing shortages due to the temporary failure of the laundry facility to meet demand Radiation protection influence / participation in job planning 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 planning and outage meetings. Preplanning regarding worker protection from hot particles is discussed in Section 19. Addition ALARA preplanning is discussed in Section 1 No violations or deviations were identifie . Training and Qualification of New Personnel The inspectors reviewed the education and training qualifications of contractor radiation protection personnel, and training provided to them. Also reviewed was radiation protection training provided to other contractor personne Selection of contracted radiation protection technicians includes a review of candidate technicians' resumes, discussion with previous employees, an entrance examination, and a personal interview if the examination grade'is marginal. After selection, the contraction technicians are given three days of training including 18-20 hours of {
classroom instruction on general rad worker training, Union Electric j radiation protection procedures, radiation work permit usage, detector ;
theory shielding calculations, and about one and a half day of practical )
health physics evaluations. A 120 and 190 question examination is given j to each junior and senior technician, respectively, a passing grade of j 70% is required. The inspectors reviewed the test questions; the tests j appear to be thorough, comprehensive, and of moderate difficulty. The j
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examination is followed by individual interviews with foremen concerning the questions missed. In addition, the Health Physicist, Operations Supervisor and the Health Physics Superintendent interviewed approximately 80% of the technicians to assess their qualifications, l training, experience, radiation protection knowledge, and resume Examination records were selectively reviewed; no problems were note The inspectors reviewed the training manual for the HP outage course which was taken by all utility and contract radiation protection personnel; the course was also discussed with several members of the radiation protection staff. The major objectives of the course were to present an overview of outage activities and schedule, good ALARA and RP practices, procedural requirements, hot particle precautions, special outage health physics topics, and job coverage checklist Although the inspectors were unable to attend the course, a review of the manual and interviews with personnel who had taken the course indicates that the instruction to radiation protection personnel was comprehensive, thorough, and technically sound. In particular, the module on hot particle precautions was extensive and emphasized recent i incidents at Callaway and other plants, techniques for locating and
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removal of hot particles, contamination control guidelines, u::a of the hot particle survey kits, and recent revisions to Procedure Nos. HTP-ZZ-06009, Personnel Decontamination, and HTP-ZZ-01490, Assessment of Skin Contamination and Determination of Skin Dose, regarding skin contamination by hot particles. The licensee's hot particle contamination action plan is discussed in Section 1 The HP Operations RPT six-month requalification program remains essentially the same as described in Inspection Report No. 50-483/87013; however, the field observation program has been somewhat modified. The HP Operation Supervisor and his foremen are each responsible for the performance of field observations for five hours per week. The present field observation program tasks are for RCA job coverage, surveys, respiratory protection, instrumentation, calibrations, and miscellaneous activitie The Tasks l Performance Criteria Checklist (TPCCs) have been prepared for 32 tasks;
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TPCCs are being developed for five additional task No violations or deviations were identifie . External Exposure Control The inspectors 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 notification i '
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I Exposure records of plant and contractor personnel for 1987 to date were selectively reviewed. No exposure greater.than 10 CFR 20.101 was note Total uposure for 1986 was about 224 person-rem. The total exposure for 1987 through October 6, 1987, is about 240 person-rem based on TLD and
" corrected" self-reading dosimeter reading The inspectors selectively reviewed current RWPs on file at Access Control for completeness, approval, ALARA review, and survey dat 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 forema No problems were note Posting and labeling in the radiation controlled area (RCA) were observed during plant tours; no problems were noted. Housekeeping appeared to be adequat No violations or deviations were identifie . Internal Exposure Control The inspectors 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 notification Whole body counting data and air sample data for 1987 to date were selectively reviewed; no problems were noted. There have been two internal uptake incidents in 1987; these incidents are discussed belo j
- On September 23, 1987, a worker was discovered by a contamination exit portal monitor to have facial contamination. A hand-held frisker measured 1300 and 1100 cpm in the area of the right and j left nostrils, respectively; nasal smears read 13,200 dpm (right '
nostril) and 2630 dpm (left nostril). The worker's whole body count (WBC) data indicated an intake of 46.45 nanoccries of Co-58 and 13.86 nanocuries of Co-60. The worker's subsequent WBC data over the next five days indicated that the internal contamination was insoluble material which quickly cleared the body. The organ dose (lower large intestine) was calculated to be less than 1 mre The co-workers of the individual who became contaminated were surveyed; no contamination was detected. The inspectors reviewed the dose evaluation; no significant problems were noted. However, the inspectors noted the Personnel Contamination Report (PCR) ,
regarding the incident listed the apparent cause of the contamination as " unknown", stated that the individual was wearing a face shield,
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and..indicatedit'he worker did not touch his-face. .It seems apparent
'that.a more thorough review of the incident should have been conducted
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to' determine the actual root cause of the contamination. Section 14 discusses the generally poor quality of-the~PCR write-ups and.the apparent need to more effectively identify, track, and trend- ,
contamination root causes to prevent recurrences, j The' inspectors discussed with the licensee the apparent-- .
~l-inappropriateness of- classifying facial contamination event .
(PCEs) as an_" unknown" and that the event evaluation should conside including the determination of local airborne activity. Also, the inspectors pointed out that stating that facial alpha _ contamination-was not greater-than 400-dpm appeared not to' properly address the y' 1 potential alpha hazard in-the subject'PCR. In response to the inspectors' concerns, the licensee' committed to: initiate a-Radiological Work Deficiency Report for the' facial contamination
- event; to amend-the PCE if it is' concluded that the individual:
touched his face; to wr.i.te PCE's in the future so that root'causes
.are adequately identified reflected; and to clarify tne alpha contamination results of,the subject facial. contamination even The Health ~ Physics' Superintendent, stated that the, method he would use for~poorly written PCE's in the-future would be to have a health physics foreman rewrite:the PCE after the event is .more -
thoroughly reviewed with-the worker and the worker's supervisor,
'if appropriat * On October 1, 1987, positive termination WBCs were identified fo eight. contract eddy current testing (ECT) workers. The licensee's preliminary evaluation indicated that the workers'had approximatel two toLfive'nanocuries.of I-131 in their thyroids (less than 5% MP08).
The preliminary root cause analysis indicated that these workers had been subjected to chronic exposure monitored by the licensee.over a period of five'to six days to concentrations of airborne I-131 at or below approximately 0.1 maximum permissible concentration (MPC)
while' conducting steam generator ECT in'the reactor building without respiratory protection. After the ECT worker uptakes were discovered, the licensee also collected WBC data on the RPT's who'had provided job coverage; 18 RPTs were tested,.13 of these showed I-131 uptakes of similar to those of the ECT workers. The licensee estimated that none of these workers were exposed to greater than 10 MPC-hour )
Pending completion of the licensee's evaluations, this matter is )
considered to be an Unresolved Item. This. matter was discussed at I
' the exit meeting and will be reviewed further during a future inspection-(483/87031-01).
'No' violations or deviations were identified.
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10. Control of Radioactive Materials and Contamination ,
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; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness *
of methods of control of radioactive and contaminated material In May 1987, the licensee began a contaminated area mnd leak k reduction program. A radwaste foreman was assigned to coordinate the effort which included interfacing with other departments (Operations, Engineering, I&C, Planning and Scheduling, Health Physics, and Maintenance). A weekly report is prepared which tracks radioactive liquid leaks and contaminated areas. These reports indicate that the floor area contamination in the auxiliary, fuel, and radwaste buildings has been reduced from 12,500 square feet in {_
May 1987, to 10,000 square feet by the end of August 1987; the decontamination task force was disbanded at the end of August "
because of outage manpower considerations. Although the 20%
reduction in floor area contamination over a five-month period does not necessarily represent significant progress, a selective review of the weekly reports showed that considerable effort was expended by the licensee. The ratio of floor areas requiring full PCs to floor areas requiring partial PCs has been reduced from about 3 to 0.5, and the number of contaminated leaks has been reduced from a high of 104 in February 1987 to 28 (including 12 in the reactor building) as of October 1, 1987. The licensee has also virtually eliminated, auring non-outage conditions, highly contaminated areas (2500 square feet in May 1987) that require consideration of respiratory protection. (The license requires that respirators be worn in areas i where surface smears are greater than or equal to 100,000 dpm/100 cm2 and the work has the potential to causes high airborne concentrations).
l l In reviewing PCR No. 87023 described in Section 9 and the RWP, which required no respirator, the in.epectors noted that the facial contamination countrate (13,000 dpm) was higher than the countrate of smearable surface contamination (10,000 dpm) reported under Radiological Conditions on the RWP. The licensee stated that a conservative nominal average value is recorded in the contamination block of the RWP However, in Guideline 1 of the licensee's RWP procedure HTP-ZZ-01201 it states that:
- The location and level of the highest contamination is to be listed under the Radiological Conditions of the RW Guideline 5 of the same procedure states that:
- A full face respirator is required for entries intc areas where surfaces smear greater than 100,000 dpn per 100 cm2 , and the work has the potential to cause high airborne concentration . _ _ _ _ _ _
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The. licensee and the inspector reviewed survey data reports of the work area in question for the two days before and immediately after the personnel contamination incident. Smearable contamination varied between !
10,000 dpm per 100 cm2 and 200,000 dpm per 100 cm2, and the post incident survey showed a maximum of 120,000 dpm per 100 cm2 During these reviews the licensee found that smearable contamination values from a Hot Particle Survey report inadvertently had been used to report smearable contamination on the RWP. The regular smear report which should have been used had a maximum smear of 80,000 dpm per 100 cm2 The licensee's representative stated that notwithstanding the few smears which showed greater than 100,000 dpm per 100 cm2, he would have reported an average value less than 100,000 on the RW The matter is left as an Unresolved Item (483/87031-02).
The licensee routinely performs hot particle smear surveys in which measured lengths of duct tape (11 inches long) are singly pressed against a surface, without any rubbing motion, and later frisked for contaminatio Hot particle smears of this type generally produce lower countrates than regular smears. . Licensee personnel stated that special training sessions would be conducted to prevent results from hot particle surveys inadvertently being used in the future for tabulating smearable contamination conditions on RWP' Inspector observations at access control points indicate that workers are properly using step-off pads and following frisking and portal monitor procedure No problems were note No violations or deviations were identifie . Maintaining Occupational Exposures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposure ALARA, including: changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; 4 worker awareness and involvement in the ALARA program; establishment of I goals and objectives and effectiveness in meeting them. Also reviewed i were management techniques used to implement the program and experience !
concerning self-identification and correction of implementation weaknesse The 1987 ALARA exposure goals are 300, 250, and 225 person-rem for acceptable, commendable, and excellent, respectively. As discussed in Section 8, through October 6, the 1987 total exposure is about 240 person-rem based on TLD and " corrected" self-reading dosimeter records. The licensee may have difficulty meeting the 1987 exposure goals because of many unanticipated maintenance tasks; there were two l extended outages in 1987, the refueling outage involved removal of all l fuel and control rod assemblies from the reactor vessel, and many unforeseen technical difficulties have occurred during the refueling
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outage. No major outages are planned for 1988; therefore, the licensee
! has established the 1988 ALARA exposure goals as 100, 75, and 50 l person-rem for acceptable, commendable, and excellent, respectivel L L-____-___________-_____________-_____-_
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' During an earlier inspection (Inspection Report No. 50-482/87013),
based on plant tours, documentation reviews, and interviews with plant personnel, the inspector identified apparent weaknesses in six areas.of theLALARA program. The status of those' perceived weaknessesLis discussed belo *- ' Housekeeping, although adequate, appears; generally not to have-significantly improved compared to observations made by the'-
inspector during previous onsite-inspections. However, as discussed'in Section-10,'significant progress has been made in the reduction of contaminated ficar areas and contaminated process system leakage. The Rad / Chem helper staff still has a high turnover rate.and generally remains relatively inexperience 'On April 14 through May 15, 1987, a QA surveillance (Report No..SP87-058) was conducted regarding tool and small equipment
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decontamination. .The auditors identified apparent procedural inadequacies and several failures to. follow procedures, including two failures of Rad / Chem helpers to comply with RWP protective clothing requirement * The ALARA suggestion program is being actively promoted and better utilized by the workers. The licensee conducted an ALARA slogan contest and is pursuing the implementation of the winning slogan and
, associated logo. After the current outage, the' licensee plans to conduct an ALARA poster contest. Additional attention to the timely implementation.of the appropriate ALARA suggestions appear desirabl '
- 'The-licensee still has only approximately 20 job history files; i .it appears desirable that the. files be better organized and more extensive, thorough and comprehensive. As discussed in Inspection 1 Report No.- 50-483/87013, the licensee may be missing the opportunity I for significant dose-savings by not creating more effective job ]
history file The newly appointed ALARA Coordinator indicated he i
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plans'to upgrade these files after the current outag * The ALARA pre-job briefings appear to have improved significantly !
compared to the spring maintenance outage briefings. On May 4-5, 1987, a QA surveillance (Report No. SP87-054) was. conducted of the removal and transfer of a CVCS SWI filter; concerns were identified by the auditors in the following areas: use of specialized tools, use of extremity dosimetry, and the storage drum dose rate estimate. During this outage an inspector attended a pre-job briefing for a similar filter transfe The pre-job worker briefing appeared to be thorough, comprehensive, and technically soun The problems identified in the May 1987 filter transfer <
have apparently been adequately corrected by the licensee; the workers appeared highly involved in the detailed planning of
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- The complex arrangement of developing composite ALARA/RWP data
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by entering the output of three separate computer programs into
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a personal computer has been replaced by a single computational format (ADABASE). Although the capabilities of the current system were not reviewed in detail by the inspectors, the preparation of =
ALARA data appears to be more timel .
- An ALARA Coordinator has been appointed by the licensee; he is assisted by two RPTs during the current outage. The outage ALARA ---
group appears to provide adequate job coverage. In addition to his ALARA duties, the ALARA Coordinator is also responsible for ( ' --
tracking decontamination records and tracking / trending personnel contamination incidents (PCIs) and radiological work practice deficiencies (RWPDs) to identify root causes in order to prevent
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recurrences. Because the duties of the ALARA Coordinator appear l to be more extensive than one person can effectively accomplished , _ _ .
and the licensee has apparently no plans for an ALARA support staff after the outage, the inspectors discussed with var',ous j l members of the licensee's supervisory and managerial staff the L_
apparent desirability of reducing the work load on the ALARA Coordinator or the assignment of ALARA RPTs to assist the ALARA Coordinator during non-outage periods, as appropriate. The inspectors' concerns regarding the adequacy of the tracking and trending of PCIs and RWPDs are discussed in Sections 14 and 15, respectivel No violations or deviations were identifie . Audits and Appraisals The inspectors reviewed reports of audits and appraisals conducted for or by the licensee including audits required by the technical specification Also reviewed were management techniques used to implement the audit program,'and experience concerning identification and correction of programmatic weaknesse Approximately ten QA surveillance performed of the radiation protection /
radwaste/ radioactive shipment programs since May 1987 were reviewed by the inspectors. Responses to findings appear timely and technically sound. Two of the surveillance reports (Nos. SP87-054 and 58) are discussed in Section 1 ,
No violations or deviations were identified by the inspector . Facilities and Equipment
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The inspectors toured radiation protection facilities, observed radiation protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staf Newly acquired facilities and procured equipment which should enhance the radiation protection program are discussed belo .
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- i : The' licensee has completed .the extensive modification of the health physics RCA access control-(HPAC) facility which is described in-Section 13 of Inspection Report No. 50-483/87013. 'The inspectors noted~that the HPAC modification significantly improved the abilit of- the HP staff to reduce the potential for traffic. flow bottlenecks and facilitate the increased activities associated with.the outag *: The licensee'has installed an eighth' personnel contamination monitor (three PCM-1 % , four;PCM-1A's, and one~PCM-18). The inspectors verified that the licensee has located the monitors properly to-provide. optimum contamination monitor.ing coverage.for the outag . The licensee has eliminated whole body frisking by handheld friskers and' requires hand and foot monitoring in only a few selected locations. .Because of the licensee's confidence that the personnel contamination monitors will' detect'any significant facial l
contamination, used respirators are'not smear-surveyed to ascertain potential past respirator failur * The ALARA/ outage RP preplanning'resulted.in a reactor head shield being installed to reduce the dose rate by a factor of 15,.four very high radiation ' area (VHRA) gates being installed at the entrances into the bioshield area, and significant sHelding of the. regenerative heat exchanger (RHE) located between the B&C steam generators. The VHRA gates and the shield structures for the reactor head and RHE may be left in place during normal plant operation; the lead shielding associated with the reactor head and RHE may be stored in special metal containers which may also be left in place during normal plant operations. Due to good ALARA/RP preplanning, the licensee may realize significant future dose-savings by being able to quickly reinstall the aforementioned shielding each outage without expending person-rem in carrying the shielding, shielding structures, and gates to and from containmen ,
e' The licensee has installed a breathing air system which consists of 12 manifolds with six regulator stations; thus 72 persons may '
simultaneously receive breathing air from this system. The system supplies the air to bubble hood suits and in-line respirator The inspectors verified an adequate supply of bubble hoods and selectively reviewed the use of the breathing air system; no problems were noted. The supply of breathing air for this outage appeared adequat * The licensee has installed a new automatic laundry frisker (ALF) for the monitoring of laundered protective clothing (PC). The ALF consists sof a conveyor system which moves the PCs at a rate of two and a half inches /per second between gas flow counters located two inches above and below the conveyor belt. The PCs are relaundered if they read
.05 mR/hr or greater of fixed contamination; if the relaundered PCr
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, fail the second monitoring test, they are discarded as radioactive
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wast Licensee representatives stated that the'ALF setpoints correspond'to aboutL1000 cpm as measured by a hand-held frisker in contact with the PCs and that approximately ten percent of.the laundered PCs' alarm the ALF. The inspectors toured the laundry
. facility, including the operation of the ALF; no problems were note * The licensee has recently purchased various. other instrumentation-including remote. readout underwater radiation monitors for diving operations, 100 cm2 area pancake frisker' probe attachments to supplement the standard 17 cm2 area probe to obtain radiation readings.for the standard smear-survey area of 100 cm2, additional
- air samplers to: provide. adequate airborne-survey data under outage conditions, and psychrometer-for the evaluation of allowable iodine protection factors for the GMR-I respiratory canisters (see Section 17 of Inspection Report No. 50-483/87013).
- . The licensee had a contractor fabricate three hot particle survey kits which consist of special adapters for the hand-held pancake friskers and the-R0-2' ion chambers. The' pancake friskers have a three-inch diameter, 5-cm high geometric adapter.with circular washer-like shields having concentric holes of various sizes to-locate the hot particl The pancake frisker adapter is used when personnel contamination between 10,000 and 35,000 cpm is fou nd.- For contamination above 35,000 cpm,-the contamination is removed immediately without taking time to ascertain whether it is aldiscrete particle. The R0-2 adapters consist of two distance geometry spacers and four different thicknesses of absorber shields; the R0-2 adapter may be used to initially l qualify and quantify the hot particle. The use of the hot particle survey kits is described in the Health Physics outage training course for RPTs, Procedure No. HTP-ZZ-06009, Personnel
' Decontamination, and Procedure No. HTP-ZZ-01490, Determination of-Beta Skin Dos No violations or deviations were identifie .- Personal Contamination Reports
. Callaway Plant Health Physics Technical Procedure No. HTP-ZZ-06009, Personne~1 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 occurre The licensee has begun a program to monitor PCEs for root causes and to take corrective action to prevent recurrenc The 1987 goal is not to exceed 100 PCEs; the
. total, as of October 6, 1987, is 184 (114 personnel and 70 clothing contaminations). The 1988 PCE goals are 100, 75, and 50 for acceptable, commendable, and excellent, respectivel .
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The inspectors selectively reviewed personnel contamination event reports and interviewed members of the health physics staff regarding I the adequacy of managerial oversight and corrective action to prevent recurrence; it appears that the licensee does not have a very effective system to identify the root causes of PCEs or an effective system to track and trend root cause (once properly identified) to promptly initiate corrective actions to prevent recurrenc Although, the PCE reports often state that the root cause is unknown; a selected review of PCE reports which report that the contamination root cause is unknown indicate that often either the event has not been investigated thoroughly or the report write-up was of less than desirable quality (see Section 9 for an example of an apparently poorly investigated PCE and/or poorly written report). Based on discussions with members of the RP staff, it appeared that workers involved in PCEs are interviewed in a cursory manner and any followup review usually takes place after the worker has left the site or is based on discussions with the worker several days after the even Also, the PCE form contains a limited number of j apparent cause categories and, as discussed in Section 11, the already apparently overburdened ALARA Coordinator is additionally responsible for tracking and trending PCEs to identify root causes in order to prevent recurrences. Based on discussions with licensee representatives, it appeared that apparent generally less than desirable quality of the PCE reporting system may be partially due to a lack of or ineffective use of
- RPT manpower; thus the consideration of significantly reducing the RP/ Chemistry /Radwaste technician staff may be inadvisable unless the
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licensee improves RPT effectiveness (see Section 4). The upgrading of the PCE reporting system was discussed at the exit meeting, committed to by the licensee (see Section 9), and will be reviewed further during a future inspection (483/87031-03). w 15. Radiological Work Practice Deficiency Reports During an earlier inspection (Inspection Report No. 50-483/87013),
the inspector noted the apparent underutilization of the RWPD reporting system and the apparent desirability of establishing a more formal system to monitor and trend RWPD report The licensee appeared to be making progress regarding the utilization of the RWPD reporting system in that 34 RWPDs were reported for 1986 versus 134 RWPDs reported during the first three quarters of 1987; however, since mid-September very few RWPD reports have been written reportedly because of an incident involving a union grievance concerning implementation of the system. The plant manager met with union and RPT personnel on two different occasions during the week of October 26 through 30, 1987. He indicated that the union has relented in their objection to the system and no further problems are anticipated. This matter will be reviewed further during a future inspection to ensure that the RWPD system is being implemented in accordance with administrative Procedure No. APA-ZZ-01000, Section 4.12 (0 pen Item No. 483/87013-03).
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The' inspectors selectively reviewed RWPD reports and interviewed members of the health physics staff regarding.the adequacy of managerial oversight.and corrective action to prevent recurrence; it appears that the licensee does not have a very effective system to identify the root
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'cause of RWPDs or an effective system to track and trend root causes (once properly identified) to promptly initiate corrective actions to
. prevent recurrence The most frequently reported root cause is personnel error'and the usual recorded corrective action is counseling of the individual involved; it appears that the licensee does not systematically review the RWPDs to identify any potential programmatic weaknesses. Also,.it appears desirable to upgrade the RWPD' form, the depth of the root cause investigation, and the quality of report write-ups; specifics were discussed with the HP supervisory staff. As discussed in Section 11, the already apparently overburdened ALARA Coordinator is -
additionally responsible for tracking and trending RWPDs to. identify' root i
causes in order to prevent recurrences. Based on discussions with licensee representatives, it appears that the apparent generally less than desirable. quality of the RWPD reporting system may be. associated with RPT manpower usage weaknesse Because further. improvements appear desirable, this matter remains an open item (0 pen Item No. 483/87013-03).
No violations or deviations were identified by the inspector . Licensee Event Report (LER) Followug p The inspectors reviewed selected .Rs to determine that deportability requirements were. fulfilled and adequate and timely corrective action was accomplished, including actions to prevent recurrence. In addition, each event was'evalut ed for previous similar events, root causes, and potential generic applicability. The review consisted of in-office review, direct observations, discussions with licensee personnel, and review of record The following LERs are considered close LER 483/87-023-00: Failure to Establish Technical Specification Alternate Continuous Sampling During a Surveillance Due to Procedural Inadequacies. On August 31, 1987, during performance of Surveillance Procedure No. ISL-GT-0R21B on the unit vent noble gas activity monitor (GT-RE-218), the unit vent particulate and iodine sampler (GT-RE-21A)
became inoperable due to a loss of sample flow at 1707 CDT. Sample i flow was returned at 1711 CDT and subsequently flow was lost at 1714 CDT; the sample flow was returned again at 1749 CDT. During the times when GT-RE-21A was inoperable, the licensee was in violation of Technical Specification (T/S) 3.3.3.10, LC0 Action Statement 43 which states that the effluent releases-via the affected pathway may continue for up to ;
i- 30 days provided samples are continuously collected with auxiliary '
sampling equipment; although the effluent released continued, the t licensee did not continuously sample the effluent.
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The Shift Supervisor's daily log indicates that HP was notified to take continuous samples at 0528 CDT when the surveillance procedure on GT-RE-21B was approved to start, due to periodic loss of sample flow to GT-RE-21A during the surveillance. At approximately 2057 CDT, the on-shift Operations Supervisor, upon review of the RM-11 printout, noted the T/S requirements and contacted HP to verify that continuous sampling was being performed. He was reportedly informed that continuous sampling was not being performed; however, the 12-hour grab samples required to be ,
collected by Action Statement 40 were being taken (T/S 3.3.3.10, LC0 applicable action statement when GT-RE-21A is out-of-service). The Counting Room RPT on-duty was apparently unaware that GT-RE-21A was considered out of-service by control room personnel. Also, the procedure did not specifically state when GT-RE-218 and GT-RE-21A would be out cf service during the surveillance or when to apply T/S Action Statements 40 and 43. The Counting Room personnel commenced alternate sampling at 2119 CDT and continued sampling until GT-RE-21A and GT-RE-21B were '
removed from the Equipment Out-0f-Service Log at 1500 CDT on September 1, 198 The primary cause of this event was attributed by the licensee to the failure of the procedure (ISL-GT-0R21B) to adequately communicate to the HP Count Room, Operations, and I&C personnel the specific requirements to meet the T/S by performing alternate continuous sampling. The licensee corrective actions, including planned procedural revisions and engineering evaluations, appear adequate to prevent recurrence. The violation of T/S 3.3.3.10 LC0 Action Statement 43 appears to meet the criteria of 10 CFR Part 2, Appendix C for self-identification and correction of problems; therefore, a Notice of V!olation is not being issue LER 483/87-016-00: T/S Violation Tritium Sample Missed Due to Personnel Error. On June 25, 1987, the monthly sampling and analysis of unit vent gaseous tritium effluents were not performed as required by Technical Specification (T/5) Surveillance Requirement 4.11.2.1.2. On July 20, 1987, during a routine review of release permit data by Health Physics '
management personnel, it was discovered that the required tritium sample had not been collected as required by the T/S. The sample was taken immediately and analyzed; this sample showed a tritium concentration which was not significantly different from the previous sample taken on May 28, 1987. The root cause of the failure to sample tritium was attributed by the licensee to personnel error in failing to follow the T/S surveillance procedure. A contributing factor was the Health Physics Technical Support technician's reliance on an incomplete Task Description Summary (TDS) on the surveillance task sheet to perform this surveillanc Corrective actions taken by the licensee to prevent recurrences include disciplinary counselling of the appropriate Health Physics personnel and instructions to all Health Physics Technical Support technicians to follow the appropriate surveillance procedure and not to rely on the surveillance task sheet TOS to determine the surveillance requirement l
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A~similar event previously occurred in February 1985 and'was the subject-of.Callaway Plant LER 483/85-015-00. dated March 28,-1985. As stated in that document, on February 28, 1985; it was discovered that the monthly tritium sampling.to be performed by February 25, 1985, had been misse The licensee attributed ~this/ event to the lack of specific information on the: surveillance task sheet rather than to personnel error in failing to follow the T/S surveillance procedure; The licensee's failure to
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properly identify the root cause and take appropriate correctives action
, in February 1985 is a contributing factor for T/S violation described in f LER'483/87-016-00 in that the technician relied on an incomplete TDS to A perform a surveillance rather than the T/S surveillance procedure.
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l- Although this problem was. identified by the licensee, the violation cq which occurred on June 25, 1987, could reasonably be. expected to have ei been prevented if the licensee's corrective action had been-adequate
- folhing the violation on February 25, 198 Failure to monthly sample o'
ant"malyze the' ur)it vent gaseous tritium effluent is a violation of Techn! cal Specification 4.11.2.1.2.,(Violation: 483/87031-04).
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Onevfolatio$wasidentifiedbytheinspector :1 E. In{ormation Nolice No. 87Q9 The inspectors reviewed licensee action taken in response to NRC Information Notice.Np. 87-39, Control of Hot Particle Contamination-at Nuclear Power Flants., , Partially because the licensee'has. experienced 4 hot particles prior to the current outage.(see Section 11 of Inspection
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Report N d has a history of defective fuel (see
$tction 18 50-483/87007)/ag'
of Inspection Re port No. '50~483/87013),
it was decided by the lIM j lGW g
license n ,p 6' a zero'e'to' fuelreconstitute defect core (see certain Section fuel 18)
assemblies in an attempt and to implement to achieve a comprehensive
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j p A hot particles ,a contamination control action plan (see Section 19).
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1 Hot ' Particles, Defective' Fuel, and Iodine Spiking q.y g Technical. Specification 3.4.8 requires the licensee to' prepare and submit L '
a Spegial Repset.nto the Commission pursuant to Specification 6.9.2 within J 30 days whenever the specific activity of the reactor coolant is greater a i
than 1 microcurie per gram DOSE EQUIVALENT I-131 (DEI-131). The licensee -l has submitted four of these reports to the NRC; the root cause in each-
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casehasbeenattiibutedtofuelcladdingdefect DEI-131 exceeded l 1 uCi/gm on August 25, 1986, January 30, 1987, April 2, 1987, and September 11, 1987, as feported in Special Reports 86-07, ULNRC-1374, hn dated September 23, 1986; 87-01, ULNRC-1452, dated February 27, 1987; 87-02, ULNRC-1495. dated April 22, 1987, and 87-09, ULNRC-1636, dated 3 Q September 28, 1981, p spectivel '
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' Partially because the licensee has experienced. hot particles prior to the t
current outage (see Section 11'of Inspection Report No. 50-483/87007) and
.-the above indications.of defective fuel, it was decided by.the licensee
.to remove defective fuel assemblies from.the core during the current-
- outage' and replace the: leaking fuel pins (reconstitution) in a few assemblies for return to the core in an attempt to achieve a.zero fuel defect core. Ultrasonic testing identified some fuel defects in 11 fuel-
' assemblies; three of these assemblies (with~one defective fuel pin each)-
were reconstituted for later return to the core, the other eight
- defective.'assemM ies will not be returned to the cor . _ Hot' Particle Contamination Control Action Pla ,
The licensee appears to have developed and adequately. implemented a comprehensive hot l particle contamination control action pla Completed actions include the following. item * Development of special requirements for hot particle control such as identifying plant systems where'the potential for hot particle contamination exit * Hot particle awareness trainin * Contamination controls for hot particles which include hot particle buffer areas around five major plant areas which have significant-
- potential to produce hot particle contaminatio * Development of methodologies.for decontamination of personnel contaminated with hot ~ particles, including establishment of a-dedicated personnel decontamination station for hot particle contaminatio * Development of dose assessment methodologies and procedures for hot particle contamination incidents including fabrication of dose-measurement adapters for R0-2 ion chambers and hand-held pancake probe frisker * Development of special decontamination techniques and procedures for hot particle contaminated tools and equipment including those being removed from water (reactor cavity and spent fuel pools).
- Laundering of protective clothing with hot particle contamination, including segregation of PCs and the purchase of a high efficiency laundry monito * Reduction of the hot particle contamination in the spent fuel pool and refueling cavity, including the use of special filters / skimmer I
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e ssessment' of' hot particle content in the RCS prior to breaching
. primary plant system ,
e Increased.use of whole body frisking monitors including the purchase of more'. monitor e Identification and purchase of various special materials and supplies for hot particle contamination contro ~
Based on plant' tours, observation of worker activities, interviews with plant' personnel,'and procedure. reviews, it appears that the'. licensee has-developed a through, comprehensive, and effective. program to control and assess hot' particle contamination. Hot particle awareness training is discussed;in Section 7; the new automatic . laundry frisker and the s . fabrication of hot particle survey kits are discussed in -Section 13; and
. reconstitution work in hot particle area of the fuel building and the hot'
particle Llaundry facility are discussed in Section' 2 . Surveillance / Plant Tours
- The inspectors conducted numerous and frequent plant tours in the auxiliary, fuel,'and radwaste. buildings and in containment for the purpose of examining the. licensee's performance'of radiation protection
.and contamination control practices, observing work activities performed under the requirements of more than a dozen RWPs, and; interviewing-workers who performed tasks authorized by other RWPs= The inspectors ,
conducted radiation and contamination surveys of selected plant areas
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using NRC and licensee survey instruments; readings were in general-
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agreement with posted-licensee data. Housekeeping generally appeared adequate; however, during the tours the inspectors noted isolated incidents of poor housekeeping. ~ Relevant observations are discussed belo * Health Physics Access Control (HPAC)
Worker ingress and egress of the controlled area is an apparently smooth operation at the licensee's large and well-staffed HPA Good practices observed include: each worker must sign-in'on his RWP.after reading it; and each containment worker must fill out a green 3 x 5 card which records his RWP number and exposure margi Recent modifications to the HPAC are discussed in Section 13 of Inspection Report No. 50-483/87013 and Section 13 of this repor * Reactor Cavity / Upper Internals Lifting Rig in Tent The lifting rig was highly contaminated and rusty. Workers were in airline respirators removing the rust in preparation for paintin The tent was the innermost of the three-SOP protocol. An extra buffer zone is between the tent and the second protective clothing
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l removal station. An inspector witnessed an appropriate response by health physics technicians on duty when they stopped an exiting worker l' 'after two steps out of the innermost zone because he had not removed his outer rubber overshoes. They helped him back into the zone, masslin-smeared and checked where he had walked, and then helped him remove the outer shoecover * Overheads Licensee representatives stated that the overheads as well as formerly externally contaminated prominent tanks have been decontaminated to less than 1000_dpm per 100 cm2 ,
- South Pipe Penetration Room Here some poor housekeeping was seen in that a drum containing used overalls was filled to overflowing and a part of a posted barrier was dow A RPT smear-surveyed in and around the area, found no contamination outside the barrier demarcation, and replaced the barrier.
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- The 2000' Level Freon Tool-Cleaning Station Here the non-dose-tracking (NDT) type of RWP was in us The inspector noted that the technicians operating the apparatus had the proper protective clothing and equipment as listed on the RW * The RHR Suction Pump Contamination Zone A small contamination area with an apparently proper boundary surrounds the RHR herculite-covered pump caps protruding through the floor from the next lower level. A rigger's tool belt lay just outside the zone, An inspector smeared the tools and belt. There was no contamination detectable on the smears when counted by a Ludlum-177 hand-held frisker located in a low background are i
- Accompanying an Equipment Operator (EO) on His Shiftly Rounds The accompanied E0 visually checked pumps and valves for leaks and electric motors for overheating. He also checked automatic fire equipment, such as on elevation 2026 where the fire box indicator lights were not functioning properly. The E0 is instructed to call the control room whenever problems are identified so that repairs are expeditiously performed, as appropriate. The E0 was required to donn PCs four times in the five hours it took to complete his rounds; considering his duties, the number of PC changes did not seem excessive. Although there was a temporary lack of certain PC supplies, no significant radiological concerns were noted by the inspecto ]
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- ' Reconstitution Work-in the Fuel Building i
' An -inspector noted that the three-SOP / buffer zone control for hot
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- particles was in effect for.the fuel reconstitution effor On the floor _ in the buffer zone there was an example of good practice used
, x by the-licensee in that barrels of extra clean protective clothing, especially rubber overshoes were~ available. Also, the inspector-noted that sleeving was being used to keep cables clean that'had )
to cross boundaries. However, on October 8, 1987, the inspector i noted that workers were removing items from the refueling pool
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water without wearing respirators as required by RWP No. 87-386-2, Reconstitution of Fuel Assemblies. This failure to adhere to the RWP precautions occurred even through a contract' radiation protection technician was present monitoring the work and even though all involved ~ personnel' had been specifically cautioned regarding respirator requirements in pre-job' briefing Administrative Procedure No. APA-ZZ-01000, Callaway Plant Health Physics Program, requires individuals to obey RWP respiratory protection requirements. Failure to follow APA-ZZ-01000 RWP requirements is.a violation of Technical-Specification 6.8. which requires adherence to RWP procedure (Violation: 4 483/87031-05).
- Laundry Facility-Vertical baffle - strips of vinyl plastic at the face of the licensee's.two large sorting hoods enhance air flow into the hoods while sorting. . Air in the work room is continuously monitored.using-AM5 monitors. An inspector discussed with the licensee's laundry contractor the daily survey program of masslin cleaning, masslin smearing, and adhesive-strip smearing for hot particles. Sorted '
clothing is pushed from inside the hoods into respective drums (coveralls /shoecovers/ gloves). Personnel are whole body counted not less than annually. No problems were noted regarding laundry facility operatio One violation was identified during plant tour . Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)
at the conclusion of the onsite inspection on October 9, 1987. Further discussions were conducted by the telephone through October 30, 198 The inspectors summarized the scope and results of the inspection and discussed the likely informational content of tha inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary. .In response to certain matters discussed by the
. inspectors, the licensee:
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.- O a. Acknowledged the inspectors' ALARA concerns regarding an October 1987 airborne incident which resulted in positive whole body counts for several workers (Section 9).
l b. Stated.the intent to improve the personnel contamination event reporting system (Section 14).
c. Acknowledged the inspectors' concerns and stated that a satisfactory resolution has been reached _with the union regarding the recent apparent reluctance of RPTs to file radiological work practice deficiency reports which involve misconduct by fellow union members (Section 15).
d. Acknowledged the failure to monthly sample and analyze the unit vent gaseous tritium effluent as required by Technical Specification 4.11.2.1.2 (Section 16).
e. Acknowledged the apparent failures to follow RWP requirements (Section 20).
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