IR 05000483/1996012
| ML20135D745 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/06/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20135D704 | List: |
| References | |
| 50-483-96-12, NUDOCS 9612100118 | |
| Download: ML20135D745 (13) | |
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! l ENCLOSURE l
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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I Docket No.: 50-483
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License No.- NPF-30 ,
I l Report No.: 50-483/96-12
- Licensee
- Union Electric Company ;
Facility: Callaway Plant l l Location: Junction Hwy. CC and Hwy. O Fulton, Missouri f Dates: November 4-8,1996 i
! Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist l
1 Plant Support Branch
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i Approved By: Blaine Murray, Chief, Plant Support Branch i Division of Reactor Safety
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i ATTACHMENT:
j Attachment: Supplemental Information i
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9612100118 961206 PDR ADOCK 05000483 G PDR
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EXECUTIVE SUMMARY r
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l Callaway Plant NRC Inspection Report 50-483/96-12 This inspection reviewed radiation protection activities in support of the 1996 refueling outage. Included were reviews of the licensee's planning ar'd preparation for the refueling outage, exposure controls, controls of radioactive material and contamination, and program to maintain radiation exposures as low as is reasonably achievable (ALARA).
Plant Support
- The licensee planned and prepared appropriately for the refueling outage. Job scheduling was a strength. ALARA packages were complete. An adequate number of qualified contractor radiation protection technicians supplemented the radiation protection staff. Sufficient supplies of protection clothing, radiation protection instruments, and consumable items were maintained (Section R1.1).
- External exposure controls were generally good; however, a violation resulting from a failure to control a high radiation r oa was identified. An additional posting inconsistency was identified in a radioactive waste storage area. Radiation work permits generally provided good guidance; however a non-cited violation was identified after an individual was allowed to revise radiation work permit requirements without second-person review. Radiation protection personnel responded well to an event that resulted in rapidly increasing dose rates. Dosimetry use, whole body counting, skin dose calculations, and internal dose calculations were performed appropriately (Section R1.2).
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- A violation was identified because the licensee failed to maintain radioactive contamination within the radiological controlled area. No other major concerns ,
related to contamination controls were identified. Radiation worker performance was average to good (Section R1.3).
- The ALARA group was sufficiently staffed with supplemental personnel during the refueling outage. in-progress ALARA reviews were performed properly, but post ALARA job reviews could have been improved if performed sooner. ALARA goals were not achieved because of unexpectedly high dose rates (Section R1.4). j
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-3-Reoort Details Summarv of Plant Status 111. Enaineerina E2 Engineering Support of Facilities and Equipment i E Review of Updated Final Safety Analysis Report Commitments A recent discovery of a licensee operating their f acility in a manner contrary to the Updated
! Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused
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review that compares plant practices, procedures, and/or parameters to the UFSAR-
- description. While performing the inspection discussed in this report, the inspector
reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant
, practices, procedures, and/or parameters, IV. Plant Support
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R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Planning and Preparation
' Insoection Scope (83750)
Selected radiation protection supervisors and technicians were interviewed and the l following items were reviewed
- Job scheduling and sequencing
- ALARA packages i
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- Resumes of contractor radiation protection technicians
- Supplies of radiation protection instrumentation, protective clothing, and consumable items 4 Observations and Findinas ;
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! The inspector reviewed the licensee's planning and scheduling of work activities within l containment. To prevent unnecessary duplication of such tasks as scaffold erection and i removal or removal and reinstallation of shielding, the licensee divided the elevations of the 1
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reactor building into grids and assigned heation numbers to all work activities. By doing i
- this, the licensee was able to identify work activities to be performed in the same area and
! schedule the activities in a manner that eliminated unnecessary duplication. The inspector j concluded that job scheduling was a strength because it reduced the total amount of time !
j consumed performing work activities, thereby reducing the total radiation exposure j
accrue !
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-4-ALARA job packages and job histories were comprehensive. The files included all information necessary to formulate reasonable dose projections and plan radiation safety instructions. When work activities had not been performed previously and no job history file existed, the licensee contacted other sites to learn of potential problems and solution The inspector reviewed resumes of selected contractor radiation protection technicians and ;
determined the individuals met the qualifications requirements of Technical
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Specification 6.3. Selected licensee radiation protection technicians were given supervisory responsibility, temporarily, to oversee the work of the contractor radiation l protection technicians. These individuals became " temporary, modified foremen" for the duration of the ref"' ling outage. Although licensee personnel stated that supplemental staffing of the radiation protection organization may have been marginal, the inspector did not identify objective evidence that safety was compromised. Therefore, the inspector concluded that supplemental staffing of the radiation protection organization was adequat Sufficient supplies of protective clothing were available. According to interviews with licensee and contractor personnel, there were sufficient supplies of radiation protection instrumentation and consumable item Conclusions !
The licensee planned and prepared appropriately for the refueling outage. Job scheduling was a strength. ALARA packages were complete. An adequate number of qualified contractor radiation protection technicians supplemented the radiation protection staf i Sufficient supplies of protection clothing, radiation protection instruments, and consumable items were maintaine R1.2 Exposure Controls Inspection Scope (83750)
Selected maintenance supervisors, maintenance workers, and radiation protection supervisors were interviewed. The following items were reviewed:
- Radiological controlled area access control
- Corrective action documentation
- Control of high radiation areas
- Posting within the radiological controlled area
- Radiation work permits
- Job coverage by radiation protection personnel
- Dosimetry issue and use
- Dosimetry records
- Whole body counting results
- Internal dose calculation results
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l i Observations and Findinas Access controls to the radiological controlled area, observed by the inspector, were well ,
implemented. According to the licensee's corrective action program documentation, ,
access control problems occurred infrequently. For the refueling outage, the normal access l
control process was enhanced by an additional practice. Radiation workers preparing to work in the containment building were required to list their names and the radiological information of the areas in which they were to work on a note card and carry the cards i with them into the containment building. Once in the containment building, the mrkers reported to the area radiation protection control desk and surrendered the car s. When the workers were finished with their tasks, they retrieved the note cards and exited the are l This practice helped to ensure that workers were aware of radiological working conditions I and that radiation protection personnel were aware of work activities in progress. The inspector concluded that this was a good practic A high radiation area is defined in 10 CFR 20.1003 as an area, accessible to individuals, in which radiation levels could result in an ind.vidual receiving a dose equivalent in excess of I O.1 rem in one hour at 30 centimeters from the radiation source or from any surf ace that the radiation penetrates. 10 CFR 20.1902 requires the posting of each high radiation area with a conspicuous sign bearing the radiation symbol and the words " Caution, High Radiation Area." Also, Technical Specification 6.12.1 requires that entrarices to areas in which radiation levels are greater than 100 millirems per hour but less than 1000 millirems per hour be barricaded and posted. During the inspection, high radiation areas in the licensee's f acility were typically controlled well; however, during a tour of the containment building on November 5,1996, the inspector identified that the doorway through the i bioshield to the steam generator "D" area was not barricaded or posted as a high radiation area. Survey records of the area confirmed that radiation levels at poi.its within this area were greater than 100 millirems per hour (but less than 1000 millirems per hour). This was a violation of Technical Specification 6.12.1 and 10 CFR 1902 (483/9612-01).
A high radiation area sign was on the door to the area; however, the door was tied in the l open position and the posting was not visible to people entering the area. Neither the licensee nor the inspector identified individuals that entered into the high radiation area without wearing electronic alarming dosimeters or without using the proper radiation work permit. Thus, the potential for an exposure in excess of regulatory limits was smal Licensee personnel reviewed the matter and determined through personnelinterviews the l
following sequence of eve.nts:
- A radiation protection supervisor saw a rope with a high raNtion area sign across l the entrance to the area approximately 30 to 45 minute' pnor to the inspector's tou !
- The rope barricade and posting were removed. The door, which was used during l normal operations to control access to the area, was returned to service, and a i locksmith repaired the door's loc l l
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Contractor electricians secured the door in an open position because they wanted frequent access to the are *
The NRC inspector identified the violation during a tour of the containment buildin The licensee initiated a corrective action document (SOS 96-1700)to record the problem and ensure the implementation of corrective actions. The preliminary root cause of the event was identified by the licensee as inattention to detail. The inspector concluded that contributing factors could include training weaknesses and lack of oversight of contractor i personnel. The licensee will perfnrm further review of the matter to close the corrective !
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action documen During a tour of radioactive waste storage areas, the inspector observed another item related to radiological area posting and exposure control. Sea / land containers were stored in the fenced area designated as the " south yard." Some of the containers were posted as high radiation areas; some were posted as radiation areas, indicating the radiological conditions within the containers. The inspector and the health physics operations supervisor performed radiation measurements on the outside of the containers and confirmed that no high radiation areas existed outside the containers. However, they found radiation levels outside one of the containers labeled with a radiation area sign (container number 2518) equal to radiation levels around containers labeled with high radiation areas signs (container numbers 2409 and 2517). Radiation measurements of ;
approximately 60 millirems per hour were noted, on contact with the exterior of the l container The inspector entered container number 2518 and found bags of dry active wast j Because of the large number of bags, the inspector was unable to perform radiation measurements at the rear of the container, in the area indicated by the external radiation measurements as potentially having the highest radiation levels. Such measurements would have been necessary to confirm the presence of a high radiation area and an l improperly posted container. The inspector reviewed inventories of the containers and noted that container number 2518 contained more items with higher contact dose readings than container number 2409. The inventory of container number 2517 was not reviewe The inspectJr identified this seemingly inconsistent posting practice to the licensc Licensee representatives acknowledged the inspector's findings, initiated a corrective action document (SOS 96-1735), and stated that the contents of the sea / land container would be reviewed, as time permitted, and appropriate actions would be taken to ensure l that the containers were nmperly poste i With regard to other items associated with exposure control, radiation work permits were based on current survey information, and they generally provided appropriate guidanc ,
However, some examples were identified by the inspector in which the same individual l prepared, reviewed, and approved revisions of the radiation work permit. Procedure HTP-ZZ-01201," Preparation and Maintenance of General and Specific Radiation Work Permits,"
Revision 27, Section 5.4.5 requires that the individual updating the radiation work permit forwara it to radiation protection supervision for review and approval. When the inspector
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identified this item as a potential violation of the licensee's procedural guidance, licensee [
j personnel stated that the individual initiating the revisions of the radiation work permit was j one of the temporary, modified foreman who were promoted during the outage to better control contractor radiation protection technicians. Licensee representatives stated it was their position that these individuals were members of radiation protection supervisio Therefore, the procedure was not violate After considering the licensee's position, the NRC concluded that the purpose of the procedure was to ensure the revisions to radiation work permits were reviewed by a second person Because the temporary, modified foremen did not obtain a second-person
. review, the foreman did not comply with the intent of the procedure. This a violation of Procedure HTP-ZZ-01201 and Technicel Specification 6.8, which requires that procedures listed in Appendix A of Regulatory Guide 1.33, Revision 2 be established, implemented, and maintained. Neither the inspector nor the licensee identified examples in which the revisions resulted in a decrease in radiation safety. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy (483/9612-02).
The opportunities for observation of radiation protection job coverage were limited becauss most outage work was completed; however, the inspector observed radiation protection coverage of work, such as during filter changeouts, in the auxiliary building and noted radiation protection coverage was goo The inspector interviewed selected maintenance supervisors and maintenance personnel to determine the quality of radiation protection support. The maintenance personnelindicated that radiation protection support was good and radiation protection personnel were knowledgeable and helpful. However, one traintenance supervisor indicated that the pre-job briefings given by contractor radiation protection personnel were not the same quality as those provided by licensee personnel because of the contractor's lack of familiarity with areas within the plan Radiation protection personnel responded well to results of a crud burst on November Workers were in a residual heat removal heat exchanger room when their electronic dosimeters alarmed. The workers left the area and notified radiation protection personne Radiation protection personnel performed surveys and identified increasing radiation dose rates in the "B" residual heat removal pump room, "B" residual heat iemovat heat exchanger room, and the south piping penetration room. The inspector confirmed that areas with dose rates greater than 100 millirems per hour were posted and controlled as high radiation area The inspector identified no problems with the assignment ano use of dosimetry, completion of dosimetry records, or performance of whole body counting. The licensee had not quantified the number of events resulting in skin exposures or internal dose, but the inspector reviewed examples of dose calculations at random. No problems were identifie The maximum internal dose assigned as of the time of the inspection was 14 millirem l l
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The maximum internal dose assigned as of the time of the inspection was 14 milkrem l Because of the low maximum internal exposure, the inspector concluded that internal exposure controls were effectiv l Conclusions !
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External exposure controls were generally good; however, a violatica resulting from a I f ailure to control a high radiation area was identified. An additional posting inconsistency j was identified in a radioactive waste storage area. Radiatior, work permits generally ;
provided good guidance; however a non-cited violation was identified after an individual '
was allowed to revise radiation work permit requirements without second-person revie Radiation protection personnel responded well to an event that resulted in rapidly l increasing dose rates. Dosimotry use, whole body counting, skin dose calculations, anJ i internal dose calculations were performed appropriatel l R1.3 Contamination Control
! Inspection Scope (83750)
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The health physics superintendent and the radwaste supervisor were interviewed and the following items were reviewed ,
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- Shipping documents for shipment of reactor coolant pump internals j
- Corrective action documentation
- Personnel contamination events
- Personnel contamination incidents l
- Release of material from the radiological controlled area l
- Instrument calibration for portable radiation detection equipment, tool monitors, and !
personnel contamination monitors
- Survey records Observations and Findinas
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The inspector reviewed the events surrounding the licensee's discovery that contaminated J objects were released from the radiological controlled area during the shipment of a reactor coolant pump internal On October 24,1996, the licensee shipped a container carrying reactor coolant pump internals to a vendor in California for repair. Prior to shipment, large area smear surveys were performed by radiation protection technicians on the container to determine the level of radioactive contamination. Parts of the container, the trunnions, were removed from the container and placed, unpackaged, in the back of an escort vehicle in the manner in which they were received.
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On October 25, according to licensee representatives, an individual leaving the radiological controlled area was found to have radioactive contamination on a shoe. The individual was interviewed and licensee representatives identified that the contamination came from a contaminated lif ting sling. The lifting sling was determined by the licensee to have been 1 used to lift the shipping container carrying the reactor coolant pump internals. The ;
licensee's draft rencit of the event stated that the lifting sling was new and had not been I used inside the reactor building prior to its use on the shipping container. Because the ]
lifting sling was in contact with the shipping container trunnions, the radioactive waste j supervisor called the contract transportation company and informed the dispatcher that it I l
was possible that the trunnions were contaminated. The licensee advised the trucking company personnel to cover the trunnions with plastic as a precautionary measure to prevent the spread of contaminatio On October 29, the vendor receiving the reactor coolant pump internals performed radiological surveys to determine radiation and contamination levels. Average removable contamination levels were determined to be 800 to 6500 disintegrations per minute per 100 centimeters squared. One smear indicated a contamination level of 211,000 disintegrations per minute per 100 centimeters squared. The highest radiation levels were 4-9 millirems per hour on contact with the trunnion On October 30, licensee personnel notified Region IV of the event. An event review team was assigned to review the facts of the event and propose corrective action Procedure HTP-ZZ-02005," Handling and Control of Radioactive Material," Revision 20, states in Section 4.2.1, " Unconditional Release," that health physics personnel shall survey items removed from the radiological controlled area to ensure they meet the criteria for ;
unconditional release. The criteria states that there shall be less than 1000 disintegrations ;
per minute per 100 centimeters squared removable contamination and less than 5000 )
disintegrations per minute per 100 centimeters squared total contaminatio l 49 CFR 171.2(a) states, in part, that no person may offer or accept a hazardous material for transportation in commerce unless the hazardous material is properly classed, described, packaged, marked, labeled, and in condition for shipment as required or authorized by 49 CFR Parts 171-17 The inspector concluded that the smear surveys, performed by licensee personnel before releasing the shipping container, were insufficient to identify the contamination on the trunnions and identified a violation of Procedure HTP-ZZ-02005. Beause the licensee did not know that the trunnions were contaminated, no attempt was made to package, mark, or label them for shipment or to classify and describe the radioactive contamination. Thus, the general Department of Transportation shipping requirement was also violated. Even though the violation was licensee-identified, specific and comprehensive corrective actions to prevent recurrence were not identified (482/9612-03).
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To further evaluate the licensee's control of radioactive materials, the inspector and a radiation protection representative surveyed items in Warehouse 2. This warehouse was used to store items and equipment used during the refueling outage. No problems involving improper storage of contaminated items were identifie Radiation worker practices were observed by the inspector. Only minor concerns were i identified. Performance by radiation workers was average to good during the inspection I perio Conclusions l
A violation was identified because the licensee failed maintain radioactive contamination within the radiological controlled area. No other major concerns related to contamination controls were identified. Radiation worker performance was average to goo R1.4 Maintaining Occupational Exposures ALARA Scope of Insoection The ALARA coordinator was interviewed and the following items were reviewed:
- ALARA group outage staffing
- In-progress ALARA reviews
- Post-job ALARA reviews j
- ALARA pre-job briefing notes l
- ALARA pre-job briefing attendance lists l
- Exposure projections for work activities !
- Actual exposure accrued for work activities Observations and Findinas Six additionalindividuals were assigned to aid the ALARA coordinator. The inspector l reviewed work responsibilities assigned to these individuals and concluded that the ALARA i group was sufficiently supplemented for the refueling outage, j l
The inspector reviewed the exposure totals accrued by work activities and selected ALARA
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packages for work activities accruing exposure in excess of the dose originally projected. l The inspector confirmed in-progress reviews were conducted for the work activities, in '
accordance with Attachment 5 of Procedure HTP-ZZ-01102," Pre-job ALARA Planning and Briefing," Revision 13.
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l According to the ALARA coordinator, post-job critiques and review meetings were not routinely held before contractor personnel left the site. Such meetings are important because they allow the timely solicitation of input from workers. When the inspector l identified this item as a potential weakness in the program, licensee personnel stated that input was solicited on a more informal basis as the workers left the radiological controlled i area. Additionally, the health physics superintendent stated that two people would be sent i to the major contractor to discuss work activities and solicit ideas for improvement.
l The licensee was faced with higher than expected dose rates inside the bioshield. Despite removing approximately 1100 curies of cobalt 58 (approximately twice that removed )
during the previous refueling outage) and 13 curies of cobalt 60, does rates were generally '
l twice as high as expected. As a result, the actual dose accrual for most work activities within the bioshield exceeded the ALARA goals. An ALARA goal of 170 person-rems was set for the refueling outage. As of the last day of the inspection, the exposure total was
- 214 person-rems. The inspector determined that the methodology used to set goals was l basically sound and would have resulted in challenging goals had the licensee been able to l estimate the dose rates more closely. The licensee was reviewing the matter to determine l why dose rates exceeded the projections by such a large margin.
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The ALARA group was sufficiently staffed with supplemental personnel during the refueling outage. in-progress ALARA reviews were performed properly, but post ALARA job reviews could have been improved if performed sooner. ALARA goals were not achieved because of unexpectedly high dose rate R7 Quality Assurance in RP&C Activities The inspector requested copies of quality assurance surveillances related to radiation protection activities performed during the outage. Quality assurance representatives stated that several surveillances had been performed, but the surveillance reports had not been completed. The inspector chose not to review notes or draft informatio I l
V. Manaaement Meetinas X1 Exit Meeting Summary j
The inspectors presented the inspection results to members of licensee management at an exit meeting on November 8,1996. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Licensee representatives identified two documents that I
they considered proprietary. The inspector determined that none of the inspection findings presented during the exit were based on proprietary information and did not capture the proprietary documentatio l l
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ATTACHMENT
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PARTIAL LIST OF PERSONS CONTACTED i
Licensee -
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J.' Cruickshank, Radiation / Chemistry Supervisor - Radwaste & Environmental I M. Evans, Superintendent, Health Physics
- R. Farnam, Supervisor, Health Physics Operations K. Gilliam, ALARA Coordinator G. Hamilton, Supervising Engineer, Quality Assurance G. Hughes, Acting Plant Manager J. Little, Engineer, Quality Assurance G. Randolph, Vice President, Nuclear Operations NRC l
F. Bush, Resident inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEMS OPENED, CLOSED, AND DISCUSSED Opened 483/9612-01 VIO Failure to barricade and post a high radiation area 483/9612-02 NCV Lack of second-person review of radiation work permit revisions '
483/9612-03 VIO Failure to control radioactive material / Failure to meet transportation requirements Closed 483/9612-02 NCV Lack of second-Person review of radiation work permit revision l
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I-2-LIST OF ACRONYMS USED
, UFSAR Updated final safety analysis report ALARA As low as is reasonably achievable
List of Documents Reviewed l I
Corrective Action Documents List of Suggestion Occurrence Solutions related to radiation protection activities, October 12 through November 4,1996 Procedures
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HTP - ZZ - 01102, "ALARA Planning and Briefing," Revision 13 HTP - ZZ - 01201," Preparation and Maintenance of General and Specific RWP," Revision
HTP - ZZ - 01500, " Radiological Posting," Revision 14 HTP - ZZ - 02002, " Receipt and Shipment of Radioactive Material," Revision 14 HTP - ZZ - 02005, " Handling and Control of Radioactive Materials," Revision 20 HTP ZZ - 03100," Performing Radiation Surveys," Revision 3 HTP - ZZ - 03300, " Airborne Radioactivity Survey," Revision HTP - ZZ - 06001,"High Radiation Area /Very High Radiation Area Access," Revision 17 HTP - ZZ - 06009, " Personnel Contamination incidents," Revision 24 RTN - HC - 01100, " Shipment of Radioactive Materials," Revision 9 Miscellaneous Do_guments Refueling Outage 7 Report / Lessons Learned List of work activities for Refueling Outage 8 and dose projections Selected resumes of contractor radiation protection technicians Selected personnel contamination event / incident reports Shipping documentation for reactor coolant pump internals, shipped October 24,1996 Event Review Team Minutes for November 4,1996 - Contaminated Material Shipped Off-Site Without Adequate Health Physics Survey Event Review Team Minutes for November 6,1996 (Draf t) - Unexpected Reactor coolant System Crud Burst re: SOS 96-1713