IR 05000483/1993011
| ML20057A567 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/07/1993 |
| From: | David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057A562 | List: |
| References | |
| 50-483-93-11, NUDOCS 9309140409 | |
| Download: ML20057A567 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-483/93011(DRSS)
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Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149
St. Louis, MO 63166 Facility Name:
Callaway Nuclear Power Station Inspection At:
Callaway Site, Callaway County, Missouri Inspection Conducted: August 2 through September 2, 1993 Inspector:
I 7!f 3 DavidW.Nelsfp/
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Radiation Specialist Approved By:
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E C-1 /7 /93 William S'nell,' Acting Chief Da'td "
Reactor Support Programs Branch
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Inspection Summary Inspection on Auaust 2 throuah September 2. 1993 (Report No. 50-483/93011(DRSS))
Areas Inspected:
Routine, announced inspection of the radioactive protection and outage planning programs (Inspection Procedure (IP) 83750). The inspection also included tours of the auxiliary and radwaste buildings and the spent fuel pool area (IP 83750).
Results:
The radiation protection program appeared to be effective in implementing the requirements of the regulations.
Excellent housekeeping practices were observed during the tours of the auxiliary and radioactive waste buildings. The licensee's quality assurance (QA) surveillances continued to be excellent and improvements in outage planning were noted.
Weaknesses in the ALARA program and in the ALARA self-assessment were noted and identified.
In addition, a total of five inspection followup items (IFIs)
and one violation followup were closed.
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DETAILS
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1.
Persons Contacted
- J. Blosser, Manager, Operations Support
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- W. Campbell, Manager,_ Callaway Plant
- C. Graham, Supervisor, Health Physics Technical Services
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- M. Evans, Superintendent, Health Physics
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- G. Hamilton, Supervisor, Quality Assurance
- R. Miller, Supervisor, Radioactive Waste and Transportation
- J. Neudecker, Supervisor, Health Physics Operations j
- S. Petzel, Engineer
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- J. Polchow, Superintendent, Radioactive Waste and Transportation i
- G. Randolph, Vice President, Nuclear Operations
- D. Calhoun, Resident inspector
- B. Bartlett, Senior Resident Inspector The inspectors also interviewed other licensee personnel during the
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course of the inspection.
- Denotes those present at the onsite exit meeting on August 6, 1993.
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2.
General This inspection was conducted to review aspects of the licensee's
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radiation protection and outage planning programs. The inspection included tours of radiation controlled areas, observations of licensee i
activities, review of representative records, and discussions with l
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licensee personnel.
3.
Licensee Action on Previous Inspection Findinos (IP 83750)
(Closed) Violation No. 483/92025-2: The licensee failed to survey
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packages containing radioactive materials within the time limits specified in the procedures. To close the violation, the licensee i
conducted training classes for personnel responsible for receiving
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packages and revised their procedures to more closely conform to the
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requirements of 10 CFR 20.
The licensee had written procedures the j
requirements of which exceeded those specified in 10 CFR 20 for j
receiving packages containing less than D0T Type A quantities 'of
radioactive material and the licensee had revised the procedures to more l
closely reflect that of the regulation. This violation is closed.
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(Closed) IFI No. 483/92006-1: The training and experience' records for
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chemistry and radioactive waste technicians were inadequate and could
not have been used to determine if the technicians were qualified to
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i perform functions normally carried out by health physics operations -
technicians.
Since the inspection, the system for recording the qualifications and experience records of the technicians has been improved. The licensee routinely uses qualification cards to record a
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technician's experience and training and those cards are readily available for inspection.
This item is closed.
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(Closed) IFI No. 483/92006-2:
The licensee lacked a formal process for reviewing contract technicians qualifications and experience.
In addition, the exam administered to the vendor technicians to test knowledge levels was too basic and not very comprehensive.
The licensee changed the process to insure that the resumes of all contract technicians would be reviewed by the Supervisor of Health Physics Operations as well as one of his first line supervisors prior to empl oyment. The licensee also decided to participate in a standard program developed by the Health Physics Training group at Northeast Utilities for the training and qualification of vendor radiation protection technicians (RPTs).
The group developed a series of exams to test the fundamental knowledge of RPTs. The licensee administers the test to the vendor RPTs, sets its own pass / fail criteria, returns the results to NfU, and determines how often the technician will be tested.
NEU maintains the test results in the database and member participates have access to that data. A review of the exam indicated that it had addressed a wide variety of h pics and was comprehensive in scope. This
l IFI is closed.
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(Closed) IFl No. 483/92011-1: A concern was raised about the qualifications of the new Superintendent of Health Physics to serve as Radiation Protection Manager (RPM).
Immediately following that inspection, the Supervisor of Health Physics Operations, who meets the qualification guidelines of Regulatory Guide 1.8, was assigned the duties and title of Radiation Protection Manager (RPM). The Superintendent of Health Physics will assume the responsibilities of RPM when qualified per the guidelines of Regulatory Guide 1.8.
This item is closed.
(Closed) IFI No. 483/92025-1:
Concerns were raised during a previous inspection regarding the licensee's responsibilities with regard to the quality assurance provisions of 10 CFR 71 Subpart H.
Since that inspection, Quality Assurance performed a surveillance (April 5,1993)
to determine the licensee's commitments under the subpart.
The auditors concluded, in part, that " application and oversight of vendor QA programs to satisfy the remaining Subpart H requirements for design, fabrication, assembly, and modification does not appear to be adequately addressed by plant procedures, processes, or oversight activities." 'As a result, the licensee will conduct planned and periodic audits of their Part 71 package vendors and review and revise those procedures that are found to be deficient. This item is closed.
LClosed) IFI No. 483/92025-2:
lhe item identified deficiencies in the licensee's process for receiving packages containing radioactive material. The licensee took the actions described in the first paragraph of this section (see violation 483/92025-2). This item is closed.
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4.
Oroanization and Manaaement Controls (IP 83750)
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The inspector reviewed the licensee's organization and management controls for the health physics operations group including:
organizational structure, staffing, and delineation of authority.
Staffing levels and the management structure of the health physics ' group remained essentially as described in the last inspection report.
No violations or deviations were identified.
5.
1993 Health Physics Action Plan (IP 83750)
The 1993 Action Plan for the Health Physics department was reviewed.
The following are examples of the action items taken from the plan:
P 10 CFR 20 - The licensee fully implemented the requirements of the
new Part 20 on January 1, 1993. The licensee was one of only a few nuclear power plants to implement early; all other plants are required to be in compliance by January 1,1994.
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Vendor RPT training and qualification - Initiatives taken and
completed included rewriting the vendor RPT lessen plans, developing a procedure for the vendor RPT approval process, and improving the vendor RPT exam databank.
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l In-house RPT training and qualification - Completed initiatives
included improving the availability of records documenting RPT
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qualifications with regard to ANSI 3.1 and the completion of all
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qualification cards for journeyman technicians.
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Procedures and Programs - Completed initiatives included
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l proceduralizing survey standards and developing bases documents l
for correlating surface contamination levels to derived air j
concentrations (DAC) for respiratory protection assessments.
l Included in this group was the development of a qualification card for first line HP operations supervisors. The licensee was considering enrolling supervisors from other departments in an
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ALARA subset of the program. This was an excellent idea and the j
licensee was encouraged to pursue this option at the exit meeting.
Facilities and Equipment - The licensee purchased additional
health physics related equipment, including a PCM-1, additional i
temporary shielding, new survey instruments, portable high efficiency particulate air (HEPA) filter units, several Beta Aerosol Beacons, and 2 automatic floor cleaning machines.
Taken as a whole, these initiatives indicate a willingness on management's part to continue to allocate resources to improve the program.
Several initiatives, however, have been delayed:
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Full implementation of the electronic dosimetry program has been
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i delayed until after the next refueling outage scheduled for
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September 1993. The licensee purchased approximately 130 electronic dosimeters, but has used them sparingly.
Full implementation of the program will continue to be delayed until a final decision is reached on the vendor who will supply the f
dosimeters.
Progress toward fully automating access control has been slow.
- The plan calls for full implementation by January 1,1994.
How that the licensee has completed the work required (training and procedural revisions) to implement the new 10 CFR Part 20 and planning for the outage is almost complete, the licensee should be able to
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complete the remaining initiatives before the end of the year.
No violations or deviations were identified.
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Quality Assurance (0A) Surveillances (IP 83750 and IP 84750)
The inspector reviewed the extent, thoroughness, and results of several surveillances performed since the last inspection.
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Quality assurance continues to conduct excellent surveillances.
The following are examples of surveillances conducted during the first half
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of 1993 and not reviewed during previous inspections:
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SP93-047 " Assess the land Use Census conducted annually at
Callaway." The surveillance was comprehensive and performance based. A number of findings and weaknesses were identified and corrective actions for past deficiencies were evaluated.
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auditor concluded that improvements in the Land Use Census program were needed and went on to identify those areas. This was an excellent surveillance.
SP93-026 " Control and Storaae of Radioactive Material". The
surveillance assessed the accountability and control of radioactive material stored at the Stores II warehouse. The surveillance found:
The instrument used to perform surveys was not the
instrument specified in the procedure (HTP-ZZ-03100). The licensee should have used a Ludlum Model 14C and not a R02.
The system for identifying the containers was confusing.
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some cases there were more than one identification number stenciled on a given container and more than one log entry for that same container.
The accuracy of the log entries with respect to container
content was poor. Approximately 25% of the time the contents of the container did not match that of the manifest.
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The contents of one container included hazardous, flammable,
and chemical liquid substances.
The auditor found that the
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relevant procedure (HTP-ZZ-02005) had not specified what l
types of materials that could not be stored in containers l
with radioactive material (RAM) and concluded that the procedure needed revision to bring it into conformance with
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current plant policy. That policy disallows the storage of
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RAM with other hazardous materials. Although this was a excellent finding, concerns raised in another inspection report (50-483/92011(DRSS)) with regard to the lack of radiation monitoring equipment and a fire suppression system
in the warehouse were not addressed.
If flammable liquids
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or chemicals were found in one container, questions should
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have been raised about the likelihood of finding the same material in other containers and/or whether the presence of the material in other containers constituted a hazard that l
had not been analyzed. This issue was discussed at the exit
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meeting.
SP92-030 " Definitions of Restricted Area and Members of the
Public." A good regulatory compliance surveillance.
- SP93-051 " Implementation of the Radiolooical Monitorino Procram."
An excellent surveillance, broad in scope, comprehensive in content, and based on performance. The auditor determined that the radiological monitoring program needed to be re-evaluated even though it had operated adequately. The auditor issued two Suggestion, Occurrence, and Solution (SOS) documents to address
the deficiencies and concerns raised during the surveillance, i
Again, an excellent surveillance.
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Reviews of the surveillances conducted during the first half of 1993
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l indicated that QA has been successful in finding the proper mix between i
conducting regulatory compliance and performance based surveillances.
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1993 were in response to issues raised during previous inspections the mix tended toward regulatory compliance during that quarter while the r
surveillances performed auring the second quarter were more performance
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based.
No violations or deviations were identified.
7.
Outaae Plannino (IP 83750)
The licensee made significant improvements in the planning, scheduling, and work coordination effort for the October 1993 outage. The licensee expanded the grid coordinate system described in Inspection Report No. 50-483/92006(DRSS) to include not only containment, but the auxiliary and radioactive waste buildings as well.
In addition, the planning for the outage began earlier than for previous outages and
coordination between the plant planning group and the ALARA planner improved.
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The grid coordinate system had not only been expanded to include other buildings, the scope of the system had expanded as well.
Equipment and
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component location information hd been added to the system's database
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and, as a result, work requests (jobs) could be pinpointed (given a grid
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location) to a specific location within an area or room regardless of i
elevation.
Once all of the jobs were site specified, the information
could be displayed on a site grided floor plan and the jobs sequenced on j
the schedule to prevent the radiological conditions brought on by one l
job from effecting another job in the same area or room.
The licensee
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anticipates that before the 1995 outage, the computerized grid system
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will be able to produce grid maps that include not only work request
information, but survey data and digital photographs of the areas as j
well.
The grid system is an excellent addition to the outage planning
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program.
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the preliminary preparation for the outage had been completed. Most, if
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l the master schedule, a majority of the radiation work requests (RWP) had
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l been partially completed, and most of the Frag Net flow charts had been l
developed.
Interviews with the ALARA planner and health physics l
management indicated that the planning for the October outage was much l
improved over that for previous outages and the health physics group would be fully prepared to support the outage by the October 1993 start date.
No violations or deviations were identified.
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The ALARA staff continued to be stable and remained as described in
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previous inspections. The staff is small, one ALARA planner and one ALARA coordinator. The ALARA planner reviews all work requests and i
works with the planners and schedulers to insure that radiological j
concerns are addressed and the health physics group is aware of all upcoming radiologically significant jobs. The ALARA coordinator, on the
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other hand, generates the RWPs and coordinates HP job coverage efforts
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with other departments. The staff has remained small, even though the scope of the ALARA program has continued.to expand and the
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responsibilities of the planner have increased. While staff size has not been an issue during previous inspections, the lack of an adequate
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staff may have begun to-have a negative impact on the program (see next several paragraphs).
In addition to the planner getting help from the plant planning group to prepare for the outage, the staff will be augmented with personnel from the corporate office during the upcoming-outage.
In July 1993, the licensee performed a self-assessment of the plant's ALARA program.
Personnel from the ALARA group as well as QA participated in the self-assessment.
Significant findings from the self-assessment included:
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There was inadequate procedural guidance for minimizing stellite
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introduction into che coolant.
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The licensee failed to complete actions in response to some ALARA
suggestions. As a result, plant personnel were reluctant to submit ALARA suggestions.
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Knowledge of the ALARA program by plant personnel was found to be
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very limited. The team concluded that management had been ineffective in getting the ALARA message out to the employees.
There were no real incentives for meeting ALARA goals.
- There was a large discrepancy between the estimated and actual
man-hour projections for jobs performed during the last refueling outage. The assessment went on to imply that the planners had not done an adequate job reviewing past job histories.
Radiological hold points were not integrated into plant procedures
or work documents.
Planning and Scheduling Planners had only a limited knowledge of
ALARA principles and had limited input into ALARA reviews.
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The assessment concluded that the ALARA program was not being implemented as effectively as it could be and, until improvements were
made, the program could not be considered effective. The inspector concurred with those findings and discussed these issues raised by the assessment at the exit meeting. A number of SOSs were submitted addressing these concerns (three Occurrence 50S's and eight Suggestion 50S's).
This was a very good self-assessment. However, issues involving the performance of the ALARA planner and coordinator were not addressed.
The plant took the position that because the ALARA group participated in the self-assessments, issues directly related to their specific duties
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would not be included in the assessment.
Because of that stance, issues l
with regard to the performance of the ALARA group such as workload, staff size, expanding responsibilities, and group effectiveness were
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the exit meeting.
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The licensee recorded 8.2 man-rem for the first six months of 1993, l
well within the 20 man-rem non-outage goal for the year.
The goal for the 1993 outage had been set at 230 man-rem.
In both cases, the goals set appear reachable and within the licensee's long-term dose goals of 20 man-rem for non-outage years and three year running averages for 1993,1994, and 1995 of 196,196 and 185 man-rem respectively.
No violations or deviations were identified.
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Cycle 6 Fuel Reliability Action Plan (IP 83750)
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The licensee developed an action plan to address radiological concerns raised by the fuel problems experienced during operating cycle 6.
The plan addressed a wide range of concerns which included evaluating the impact on offsite dose to the public for analyzed accidents, the
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frequency of radiation surveys and primary coolant sampling, the scope
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of the training program and the impact of the increased source term on the upcoming refueling outage. A review of the plan indicated that it
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was well thought out, comprehensive and provided a firm foundation for
the health physics group's activities before, during and after the j
upcoming outage.
t The fuel problems have resulted in the specific activity of the reactor coolant approaching 0.35 microcuries per gram Dose Equivalent I-131.
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Technical Specification (TS) 3.4.8 limits specific activity in the reactor coolant to 1.0 microcurie per gram Dose Equivalent I-131 and i
allows 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to reduce levels below this limit prior to initiating a
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reactor shutdown. The licensee's action plan included an administrative action level of 0.5 microcuries per gram Dose Equivalent I-131 to reevaluate the situation. The activity increase has resulted in higher
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radiation doses to radioactive waste and chemistry technicians during
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reactor coolant sampling and processing but has not yet resulted in
increased doses to the rest of the station. The effect on effluents has
been minimal as there has not been a noticeable increase in the amount i
l of fission products in the gaseous and liquid releases.
There was no indication of steam generator tube leakage and reactor coolant system leakage was less than 0.1 gallon per minute at the time of the l
inspection. The Part 61 radioactive waste sample isotopic profiles had shown an increased presence of fission products in the waste and the licensee had taken steps to insure that the waste met the burial site's
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acceptance criteria.
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On September 2,1993, a telephone conference was held with the licensee
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to discuss the action plan.
Prior to this conference, NRC had raised
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questions to the licensee about the implementation of the plan and specifically asked if a formal ALARA review was conducted to determine of it was prudent to shut the plant down early to limit the amount of activity released to the coolant and likely reduce the total dose that will be expended during the upcoming outage, scheduled to begin October 1, 1993, and the balance of plant life. During the conference, the
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licensee indicated that the conclusion from a preliminary cost-benefit
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analysis was that the cost for replacement power during the time the reactor would be shut down was prohibitive compared to the benefit that would be realized from the possible reduction in dose projections for the future. The bases for this conclusion were that replacement power-is much more expensive in September than in October and scheduling
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l conflicts would result in a significantly longer outage than is
presently scheduled. Other items addressed during the conference
included details about the health physics group's preparation for supporting the upcoming outage and the scope of the training program for both contractor and site personnel with regards to the radiological
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conditions expected during the outage. NRC indicated that specific issues with regard to the implementation of the action plan would be f
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examined during a planned pre-outage inspection.
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No violations or deviations were identified.
10.
Plant Tours (IP 83750)
The inspector toured the auxiliary and radwaste buildings and found i
niinor incidences of poor housekeeping practices in both buildings.
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general, however, housekeeping practices in both buildings were excellent. Radiological controls (postings, barriers, etc.) in both buildings were appropriate and within the regulatory requirements.
t No violations or deviations were identified.
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11.
Exit Interview (IP 83750)
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The inspector met with licensee representatives (denoted in Section 1)
at the conclusion of the inspection on August 6, 1993, to discuss the i
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scope and findings of the inspection.
During the exit interview, the inspector discussed the likely
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informational content of the inspection report with regard to documents or processes reviewed by the inspectors during 1... inspection.
Licensee representatives did not identify any such documents or processes as proprietary. The following matters were specifically discussed.
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Excellent housekeeping practices in the auxiliary and radioactive waste buildings (Section 10).
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Excellent QA surveillances (Section 5).
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Good preparation for the October 1993, refueling outage (Section 6).
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The cloceout of five IFIs and one violation (Section 2).
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Concerns about the ALARA self-assessment (Section 7).
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