IR 05000483/1997016

Insp Rept 50-483/97-16 on 970915-19.No Violations Noted. Major Areas Inspected:External & Internal Exposure Controls, Dose Assessment & Records,Controls of Radioactive Matl & Contamination & Surveying & Monitoring

ML20211K879
Person / Time
Site:	Callaway
Issue date:	10/07/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20211K868	List: IR 05000483/1997016 ML20211K865
References
50-483-97-16, NUDOCS 9710100061
Download: ML20211K879 (11)

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- ENCLQ1U_flE U.S. NUCLEAR REGULATORY COMMISSION '

REGION IV >

Docket No.':- 50-483; ,

License No.:. - NPF 30

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Report No.:- 50-483/97-16 Licensee: Union Electric Company i Facility: Callaway Plont Location: Junction Hwy. CC and Hwy. O Fulton, Missouri ,

- Dates:

- September 1519,199 '

Inspector: Larry Ricketson, P.E., Senior Radiation Specialist

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Plant Support Branch-Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safet *

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ATTACHMENT: Supplemental Information

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9710100061 971007 PDR G ADOCK 05000483 PDR ..,

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EXECUTIVE SUMMARY s

Callaway Plant NRC Inspection Report 50-483/97 16 This announced, routine inspection reviewed external exposure controls, internal exposure controls, dose assessment and dose records, controis of radioactive materials and contamination, and surveying and monitorin Plant Suocort

• Generally, external exposure controls and dose assessment techniques were good; however, a noncited violation involving the control of a locked high radiation area was identified and corrected by the licensee (Section R1.1).

• Sound programs were implemented to control internal exposure, but respirator storage needed improvement. Respirators wers packed into small bins in a manner that had the potential to distort the rubber or other elastomeric parts (Section R1.2).

• Radioactive material and contamination controls were generally wellimplemented, but a problem was identified with the control of items conditionally released from the radiological controlled area. Records did not always reflect the actual storage location of items conditionally released (Section R1.3.).

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BennILDatails LV.J3anLSupport R1 Radiolog' cal Protection and Chemistry Controls 81.1 ExtetriExonsure Canttols intpr.clion Scone f 8375Q)

The radiation protection program was inspected during normal operations. No major

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Work activities were conducted during the inspection; therefore, no performance-based inspection was conducted. The inspector interviewed radiation protection personnel *.nd acviewed the followinJ:

• Control of high radiation areas

• Hir,h radiation area key control

• Radiological posting

• Radiation work permits

• Access controls

• Dosimetry use

• Dosimetry processing

• Dosimetry records

• Skin dose measurements

• Notifications Ohsstyntions and Find uns The inspe,: tor's review s indicated thet most elements involved in the external exposure control progt im were implemented properl The licenst e implementi d the use of electronic, alarming dosimeters for routine use during radiological controlled area entries. Workers were knowledgeablu of requirements for logging in and out of the radiological controlled area using the new electronic dosimeter system. Access controls functioned appropriatel Since no major work activities were being conducted, only general radiation work permits wero in effect. The work permits provided guidance commensurate with the radiation harards at the tim Radiation workers wore the electronic dosimeters and thermoluminescent dosimeters in accordance with procedural guidance. The licensee's dosimetry program was reviewed and accredited by the National Voluntary Laboratory Accreditation Program, as required by 10 CFR 20,1501(c). The inspector reviewed the findings of

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-4 the latest dosimetry program review and noted that one deficiency was identifie The licensee addressed the finding appropriately. The licensee's dosimetry accreditation extends through March 31,199 Skin dose calculations were performed appropriately af ter personnel contamination incidents. The inspector verified that the results of dose calculationa were included in the individuals' dosimetry records, in accordance with 10 CFR 20.2103 and 10 CFR 20.2106. The insoector noted that the highest single whole body dose resulting from contamination events was approximately 64 millirems. The inspector concluded that contamination incidents did not contribute significantly to the workers' individual dose High radiation areas were properly controlled, during the inspection. However, the licensee identified, through the problem reporting program, events during which personnel entered into a locked high radiation area without complying with the requirements of Technical Specification 6.12. Technical Specification 6.1 requires that indiv' tuals entering high radiation areas have idiation dose rate measuring devices, ,adiation dose integrating and alarming devices, or health physics coverage. Technical Specification 6.12.2 requires that individuals entering into an areas with radiation levels greater than 1000 millirems per hour do so in accordance with the requirements of Technical Specification 6.12.1 and a radiation work permit that specifies the dose rate levels in the immediate work areas and the maximum allowable stay time for the individuals in that are The licensee documented (in SOS 97 0742) that two entries were made into the emergency personnel hatch vestibule on June 17,1997, by individuals who did not comply with the requirements of Technical Specification 6.12. The licensee deterrnined through a root cause analysin that the events resulted from a series of miscommunications, a weakness in the key control program, and poor worker knowledge of posting requirements. Corrective actions, implemented or proposed by the licensee, included: revising instructions to security personnel to require the isruance of locked, high radiation area keys only to radiation protection personnel; providing additional t aining to security personnelinforming them of the radiological significance: of the en. ,rgency personnel batch door; providing additional training to plant personnel with regard to posting requirements; and using area posting of unique color for locked high radiation areas. This nonrepetitive, licensee identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (483/9716-01).

The inspector noted that locked high radiation area keys were issued and controlled propert/ Licensee personnel accounted for all keys. Radiological areas were posted

- appropriately,

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5- , Conclusions Generally, external exposure cont'ols and dose assessment techniques were good; howevu, a noncited violation involving the control of a locked high radiation area was identified and corrected by the license RI.2 Internal Exposure Controls Insocction StormEJ1101 The insnector interviewed radiatien protection personnel and reviewed the following:

• Air sampling results

• Respiratory protection

• Whole body counting Observations and Findinas internal exposure contributed very little to the total site exposure, in 1990 the site dose was 248 person rems. Internal sources accounted for approximately 200 millirems of the exposur Whole body counts were generally performed as required; however, the inspector noted an example that occurteo on October 10,1990, in which an individual was identified as having contamination on his mustache. The contamination level was approximately 350 counts per minute. Typicalindustry practice, in such a case, would be to perform a whole body count to determine if radioactive material was ingested. Licensee representatives acknowledged that such a practice is the expectatic.i at the licensee's f acility, as well. They could not explain why a whole body count was not performed. Licensee representatives stated that this item will be discussed with radiation protection technicians to ensure they understand management's expectation During the review of the personnel contamination event / incident log, the inspector noted that there had been no review of the information in the log by a radiation protection supervisor since May 1997. Ucensee personnel acknowledged the inspector's comment and revised the instructions in the shif t task assignment to require the radiation protection shif t supervisor to review, initial, and date the log weekly. SOS 971093 was initiate No program existed for testing the effectiveness of ventilation systems or vacuum cleaners equipped wi'h high efficiency particulate air filters. Licensee representatives stated that they would review this item and determine if it would be a beneficial program enhancement. SOS 97 1091 was initiate . _ - .

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6-In other arcar related to the control of internal exposure, the inspector verified that individuals listed in respirator issue records had current qualifications and that respirators issued to individuals matched the sizes with which the individuals were f stt oc The inspector noted that housekeeping in the respirator issue room needed improvement. Additionally, respirator storage needed attention because it was inconsistent and haphazard. Some respirators in the storage bins were sealed in bags; some were not. Common practice is to store respirator in bags, following inspecting, cleaning, and disinfecting Respirators were packe into small bins in a manner that had the potential of distorting the rubber or other elastomeric part The supervisor with responsibility for the respiratory protection program acknowledged that he had not been in this area recently and stated that he would take action to improve the housekeeping and stora0e conditions. SOS 971096 was initiate Regulators and air cylinders for self contained breathing apparatuses were tested according to procedural requiremerto. Breathing air was tested quarterly to ensure that it met the standards of Grade D air as describe in ANSI /CGA G- Conclusions Sound programs were implemented to controlinternal exposure, but respirator storage needed improvement. Respirators were packed into small bins in a manner that had the potential to distort the rubber or other elastomeric part R1.3 Control of RadioactlytMaterial and Contamination: Surveying and Monitoring Insoection Scooe (8375Q1 The inspector interviewed radiation protection personnel and reviewed the following:

• Control / release of materials

• Source accountability

• Source leak testing

• Personnel contamination events

• Portable sur icy instrument calibration

• Personnel contamination monitors and tool monitor calibration

• Alarming dosimeters / pocket ion chambers calibration

• Whole body counter calibration

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b. Qhutut[ons and Findinas The licensee performed most activities in th!s area appropriately. Selected sources from the licensee's inventory records were reviewed by the inspector and the licensee accounted for all examples. Likewise, leak test records, documenting that sources were tested at the proper intervals, were available for randomly chosen examples. With the aid of a radiation protection technician and a highly sensitive, portable radiation detection instrument (sodium iodido scintillation detector), the inspector performed checks of a warehouse and several trash dumpsterr, outside the radiological controlled area. No uncontrolled licensed material was identifie The licensee established a process for the conditional release from the radiological controlled area of items having fixed or internal radioactive contamination. A log was maintained of these items, listing the locations in which the ltrams were supposed to be stored. The inspector reviewed the log and attempted to verify the locations of selected items. One item, a leak rate monitor (Serial No. 2002), was not in the area identified on the log as the instrument's intended storage area, the m*asuring and testing equipment room. Radiation protection personnel conducted interviews and searches and found the leak test monitor was checked out of the storage room, used during a test, and lef t in the radiological controlled area in the equipment operators' mudroom. Because the item was contained within the radiological controlled area, no regulatory deficiency related to the control of radioactive materials occurred. However, the example demonstrated a weakness in the licensee's ability to account for conditionally released items. SOS 971078 was initiate During tours of the radiological controlled area, the inspector reviewed posted area survey records and compared the results with conditions inside the areas. The inspector noted that areas tagged as hot spots were not consistently indicated on radiation survey records. Licensee representatives stated that, in some cases, the areas tagged as hot spots no longer met the defiriition of hot spots, but the tags had not been removed. They further stated they would review the matter with radiation protection technicians to ensure they understood manogement expectations and were consistent in the tagging of hot spots and the recording of survey informatio The previous comment, notwiths.tanding, the inspector found that survey records were complete and easy to read. The inspector noted examples of radiation measurement instrumentation used to perform the surveys and compared the examples with instrument calibration records. The inspector determined that instruments used fur the performance of surveys were within the calibration interval The inspector reviewed the licensee's portable instrument calibration program and found it to be acceptable, but noted that no procedural guidance existed to ensure that tnstruments that f ailed response tests were evaluated in a timely manner to i

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-8-determine when and how the instruments were used prior to f ailing the tes Licensee representatives acknowledged the inspector's comment and initiated a temporary change notice to Procedure HDP ZZ-04000, " Health Physics Instrumentation Program," Revision 14, to require instruments to be evaluated within one working day after discovery of the non conformance. SOS 971092 was initiate c. Conclusions Radioactive material and contamination controls were generally wellimplemented, but a problem was identified with the control of items conditionally released from the radiological controlled area. Records did not always reflect the actual storage lacation of items conditionally release R8 Miscellaneous Radiological Protection and Chemistry issues 8.1 [Clolcdl._ Violation 483/96012-01: Failure to Barricade and Post a High Radiation ALCD The inspector verified the corrective actions described in the licensee's response letter, dated January 6,1997, were implemented. No similar problems were identifie .2 1Cloied) Violation 483/96012-03: Failure to Control Radioactive Materials nod Meet Transnortation Reauirements The inspector verified the corrective actions described in the licensee's response letter, dated January 6,1997, were implemented. No similar problems were identifie .3 {Closedlyoteiglyed item 483/92004-03: Changes to the Offsite Dose Calculation Manual During a review of corrective actions for an NRC identified violation (483/9516 01),

NRC personnel noted that the licensee revised the offsite dose calculation manual wordmg pertaining to the requirements for gathering of milk and vegetation samples in a manner that may have reduced the requirements of the offsite dose calculation manual. The revisions were discussed with licensee personnel and the offsite dose calculation manual was revised, egain, to reflect the original wording. During this inspection, the inspector determined that the revisions resulted in no actual changes in the locations from which milk and vegett.ble samples were gathered nor in the method by which they were gathered. The inspt.ctor determined that no reaulatory issues existed as a result of the licensee's revisions to the offsite dose calculation manua __

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X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management ,

at an exit rnecting on September 19,1997. The licensee acknowledged the findings presented. No proprietary information was identifie .. . . . . _ .. .

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' ATTACHMENT- l

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SUPPLEMENTAL INFORMATION I

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l PARTIAL LIST OF PERSONS CONTACTED-I LkADEsa R. Affolter, Plant Manager *

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M. Evans, Superintendent. Health Physics R. Fernam, Supervisor, Health Physics Operations i K. Gilliam, ALARA Coordinator l C. Graham, Health Physics Technical Support

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J. Laux, Manager, Quality Assurance

-~J. Little, Engineer, Quality Assurance B.-Miller, Dosimetry Supervisor, Health Physi i

- G. Randolph, Vice President, Nuclear Operations M. Reidmeyer, Engineer /NRC Interf ace, Quality Assurance D. Thompson, Instruments Supervisor, Health Physics blRC'

O. Passehl, Senior Resident inspector i F. Brush, Resident inspector INSPECTION PROCEDURES USED i

83750- Occupational Radiation Exposure [

ITEMS OPENED, CLOSED, t.ND DISCUSSED Onened

.483/9716-01 NCV Personnel Entry into Locked High Radiation Area

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! 2 Closed 483/9716 01 _NCV Personnel Entry into Locked High Radiation Area 483/9612 01 VIO Failure to Barricade and Post a High Radiation Area 483/9612 03 VIO = Failure to Control Radioactive Materials / Failure to Meet

- T*=nsportation Requirements 483/9704 03 URI Offsite Dose Calculation Manual Changes LIST OF DOCUMENTS REVIEWED List of Suggestion Occurrence Solution Systern reports (9/01/96 9/05/97)

Procedures

• HDP ZZ-01400, " Dosimetry Quality Control Program," Revision 14 HDP ZZ-01500, " Radiological Posting," Revision 15 HDP ZZ 03000, " Radiological Survey Program," Revision 20 HDP ZZ 04000, " Health Physics Instrumentation Program," Revision 14 HDP ZZ-08000, " Respiratory Protection Program," Revision 12 HTP-ZZ 01320, " Internal Dose Assessment," Revision 11

. HTP Z -Z 01417 " Dosimetry Processing," Revision 18 HTP ZZ 02004,." Control of_ Radioactive Sources," Revision 16 HTP ZZ 06009, " Personnel Contamination incidents," Revision 24 -

HTP ZZ-08501, " Testing of Breathing Air," Revision 5

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