IR 05000483/1998007
| ML20247L367 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/19/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247L347 | List: |
| References | |
| 50-483-98-07, 50-483-98-7, NUDOCS 9805220385 | |
| Download: ML20247L367 (18) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-483 License No.:
NPF-30 Report No.:
50-483/98-07 Licensee:
Union Electric Company Facility:
Callaway Plant Location:
Junction Hwy. CC and Hwy. O Fulton, Missouri Dates:
April 27 through May 1,1998 Inspector:
Michael P. Shannon, Senior Radiation Specialist, Plant Support Branch Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:
Supplemental Information l
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9805220385 980519 i
PDR ADOCK 05000483 I
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-2-i EXECUTIVE SUMMARY Callaway Plant NRC inspection Report 50-483/98-07 l
This announced routine inspection reviewed the radiation protection program focussing on refueling outage activities. Areas reviewed included: exposure controls, controls of radioactive material and contamination, surveying and monitoring, the program to maintain occupational exposure as low as is reasonably achievable (ALARA), contractor training and qualifications, l
and quality assurance in radiation protection activities.
Plant Sunoort
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in general, the external exposure controls program was effectively implemented. Danger
(locked) High Radiation Areas were properly controlled and posted. Overall, Caution High Radiation A.reas were properly controlled. Station workers knew the proper response to electronic dosimeter alarms (Section R1.1).
A violation of Technical Specification 6.11 was identified for the failure to conspicuously
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post a High Radiation Area (Section R1.1).
A violation of Technical Specification 6.8.1 was identified because workers failed to
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understand the restrictions / limitations of the radiation work permit and did not maintain an awareness of the work area radiological conditions (Section R1.1).
- Housekeeping was very good throughout the radiological controlled area (Section R1.1).
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An effective internal exposure controls program was in place. Continuous air monitors and HEPA filter ventilation were appropriately used to monitor and limit airbome exposures. Respiratory equipment was properly controlled and issued. The internal dose assessment program was effectively implemented (Section R1.2).
ALARA work planning was effectively implemented. Radiological work package tasks
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were well planned, and ALARA personnel were appropriately involved during the outage planning stage. Lessons-leamed from past similar work were incorporated into the radiological work packages. The outage review board and activity coordinators were appropriately involved in outage exposure goal sating and monitoring (Section R1.3).
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Personnel contamination incidents and events were properly handled, and radiation
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protection personnel stationed at the radiological controlled area exit provided appropriate guidance to station workers who alarmed the personnel contamination monitors. Good controls were in place to prevent the spread of radioactive contamination (Section R1.4),
A violation of Technical Specification 6.11 was identified for the failure to properly label
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i 36 bags (containers / packages) of radioactive material with the appropriate radiological
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-3-information to permit individuals handling or using the containers to take precautions to avoid or minimize their exposure (Section R1.4).
A violation of Technical Specification 6.8.1 was identified for the failure to properly post
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two areas as an Airborne Radioactivity Area (Section R1.4).
A very good ALARA program was implemented. Effective chemistry shutdown plans and
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controls were in place which reduced steam generator channel head dose rates about 27 percent. Station management demonstrated their support for the ALARA program by delaying the start of the refueling outage by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in an effort to decontaminate the reactor coolant system and reduce the general area dose rates. The outage exposure goal of 185 person-rem was established using past best performance and industry experience in conjunction with appropriate involvement by activity coordinators and the outage review board (Section R1.5).
In general, a good contractor health physics technician training program was in-place.
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Lesson plans used for training contractor health physics technicians were well organized and developed. Radiation protection management was appropriately involved in developing the training topics (Section R5.1).
Overall, an adequate quality assurance program was implemented. A quality assurance
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audit schedule and plans covered the appropriate program areas to provide management with an overview of the radiation protection program. Quality assurance audit teams were not comprised of personnel with strong radiation protection backgrounds in the areas being audited. The audits covered the appropriate program areas; however, they did not provide an in-depth review of the areas audited. One radiation protection department self-assessment was performed since January 1997.
The assessment provided a very good evaluation of the areas reviewed, and appropriate recommendations were identified for program improvements (Section R7.1).
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Report Details i
Summary of Plant Status During the inspection the plant was in the start-up phase of their ninth refueling outage.
IV. Plant Suonort R1 Radiological Protection and Chemistry Controls R1.1 External Exoosure Controls a.
Insoection Scoce (83729/83750)
Selected radiation workers and radiation protection personnel involved in the external exposure coritrol program were interviewed. A number of tours of the radiological controlled area, including the reactor containmentbuilding, were performed. The following items were reviewed:
Control of High Radiation Areas and High Radiation Area keys
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Radiation work permits
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Job coverage by radiation protection personnel
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Housekeeping within the radiological controlled area
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Personnel dosimetry use
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b.
Observations and Findinos During tours of the radiological controlled area, the inspector determined that Danger High Radiation Areas (areas where the dose rate was greater than 1000 millirems per hour at 30 centimeters) were properly posted and controlled. The inspector reviewed the control of the licensee's Danger High Radiation Area key program and performed an inventory of the Danger High Radiation Area keys.
In general, Caution High Radiation Areas (areas where the dose rate was greater than 100 but less than 1000 millirems per hour at 30 centimeters) were properly posted and controlled. However, on April 29,1998, the inspector identified that a Caution High Radiation Area located in the radwaste building, elevation 2041-foot, surrounding the fuel pool clean-up filter *B" change area, was not conspicuously posted on the east side of the enclosure which was approximately 8 feet long. The inspector determined that dose rates in the area were as high as 200 millirems per hour, on contact, and 120 millirems per hour at 30 centimeters.
Section 3.2.8.1 of Procedure HDP-ZZ-01500, " Radiological Posting," Revision 15, requires each Caution High Radiation Area to be conspicuously posted with a standard radiological warning sign (s) and the words " Caution High Radiation Area." Technical
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l f-5-Specification S.11 states, in part, that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20.10 CFR 20.1902(b)
states, in part, that the licensee shall post each High Radiation Area with a conspicuous sign or signs bearing the radiation symbol and the words " Caution High Radiation Area."
The failure to conspicuously post the east side of the fuel pool clean-up filter "B" change area enclosure as " Caution High Radiation Area"is a violation of Technical Specification 6.11 (50-483/9807-01).
Radiation work permits and area radiological survey maps were written in a clear consistent manner and provided station workers with the appropriate controls and radiological information to safely accomplish their tasks. However, on April 27,1998, the inspector interviewed approximately six workers working in the reactor building on various elevations outside the bioshield wall. These workers were questioned about the general radiological conditions in their work area. None of these workers knew the answer. Additionally, the inspector questioned some of these workers about the restrictions / limitations of their radiation work perrnits. Again, none of these workers knew the answer. A review of the radiological survey data for the above elevations revealed that dose rates ranged from 2-50 millirems per hour, and contamination levels ranged from 2000-22,000 disintegration per minute per 100 centimeters squared.
Section 3.0 of Procedure HTP-ZZ-01203, "RWP Access Control," Revision 24, states, in part, that individual workers perform the following when entering the radiological controlled area: (1) read and understand the RWP and (2) review work area radiological survey data to ensure awareness of radiological conditions. Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(1) of Appendix A of this Regulatory Guide includes procedures for the access control to radiation areas including a radiation work permit system.
The failure to understand the restrictions / limitations of the radiation work permit and maintain an awareness of the work area radiological conditions is a violation of Technical Specification 6.8.1(50-483/9807-02).
Housekeeping throughout the radiological controlled area was very good.
All radiation workers observed wore their dosimetry properly. When questioned, workers knew to leave their work area and contact radiation protection personnel if their electronic dosimeter alarmed.
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Conclusions l
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In general, the exterreal exposure controls program was effectively implemented. Danger High Radiation Areas were properly controlled and posted. Overall, Caution High f
Radiation Areas were properly controlled. Station workers knew the proper response to
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-6-I electronic dosimeter alarm. Housekeeping was very good throughout the radiological
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controlled area. A violation was identified for the failure to conspicuously post a Caution l
High Radiation Area. A second violation was idenufied because workers did not l
understand the restrictions / limitations of the radiation work permit and did not maintain l
an awareness of the work area radiological conditions.
R1.2 Internal Exoosure Controls a.
Insoection Scooe (83729/83750)
Selected radiation protection personnel involved with the intemal exposure control program were interviewed. The following items were reviewed:
Air sampling program, including the use of continuous air monitors and filtration
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units Respiratory protection program
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Whole-body counting program, including the calibration of the counter
The internal dose assessment program
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b.
Observations and Findinas Continuous air monitors and HEPA filter ventilation were appropriately used throughout the radiological controlled area to monitor and limit worker's airbome exposures.
- r There wee 6 fu!!-faced negative pressure respirators and 12 air supplied bubble hoods issued for rasological work during the refueling outage. The inspector reviewed the control and issue programs for this equipment and identified no problems. The licensee identified two tasks which required respiratory protection equipment for radiological work during the outage. The inspector reviewed the total effective dose equivalent /as low as is reasonably achievable (TEDE/ALARA) evaluations for these taskswhich were performed to ensure compliance with the requirements of 10 CFR Part 20, Subpart H, and concurred with the licensee's conclusions that respiratory protection equipment satisfied TEDE/ALARA principles.
There had been 32 positive whole-body counts which occurred during the refueling outage for which the licensee assigned an internal dese. The inspector reviewed the internal dose assessment program and noted that the licensee recorded internal dose at a conservative level (1 millirem). The highest internal dose assigned to anyone individual during the refueling outage was 51 millirems.
The whole-body counter was verified to be calibrated using standards traceable to the National Institute of Standards and Technology. The inspector noted that an acceptable l
phantom was used along with radiation sources which covered energy ranges between l
approximately 88 - 1836 kev. The whole-body counting system was appropriately I
calibrated and ' prior to use" quality control (source) checks were properly performed.
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Conclusions An effective internal exposure controls program was in place. Continuous air monitors and HEPA filter ventilation were appropriately used to monitor and limit airbome exposures. Respiratory equipment was properly controlled and issued. A review of the TEDE/ALARA evaluations determined that respiratory protection equipment usage satisfied TEDE/ALARA principles. The internal dose assessment program was effectively implemented. The whole-body counter calibration program was properly maintained.
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R1.3 Plannino and Preparation a.
Insoection Scoce (83729/83750)
Radiation protection personnel involved in radiation protection planning and preparation were interviewed. The following items were reviewed.
ALARA job planning
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Job scheduling and sequencing
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ALARA packages
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Incorporation of lessons learned from similar work
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Supplies of radiation protection instrumentation, protective clothing, and
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consumable items b.
Observations and Findinas
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Radiological work package tasks were well planned, and ALARA personnel were appropriately involved during the outage planning stage. Lessons-learned from past similar work were incorporated into the radiological work packages. Post-job briefings captured lessons-leamed and suggestions from craft workers, activity coordinators, and radiation protection personnel. At the completion of the task, job hir, tory comments were provided to the ALARA personnel and activity coordinators for evaluation and incorporation into future similar radiological work packages. A review of selected radiation work permit packages revealed that lessons learned from past similar work and the industry were appropriately incorporated to improve job task performance.
The outage review board and activity coordinators were appropriately involved in outage exposure goal setting and monitoring.
The inspector attended radiation protection staff shift turnover meetings. Good communication between shifts was noted, and tumovers were performed in a professional manner. Discussio as on work status and problems encountered during the shift were effectively communicated.
From interviews conducted with radiation protection personnel and field observations, the inspector determined that no problems were identified with the adequacy of radiation l
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i protection instrumentation, protective clothing, and consumable supplies to support radiological work.
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Conclusions Radiological work package tasks were well planned, and ALARA personnel were appropriately involved during the outage planning stage. Lessons-learned from past similar work were incorporated into the radiological work packages. The outage review board and activity coordinators were appropriately involved in outage exposure goal setting and monitoring. Staff shift turnover meetings were effective.
R1.4 Control of Radioactive Materials and Contamination: Survevina and Monitoring a.
Insoection ScoceJ83729/83750)
Areas reviewed included:
Radiological controlled area access controls
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Control of radioactive material
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Portable instrumentation calibration and performance checking programs
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Adequacy of the surveys necessary to assess personnel exposure
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Observations and Findings Observations performed by the inspector at the radiological controlled area egress point revealed that workers used the personnel contamination monitors properly. Radiation protection personnel stationed at the radiological controlled area exit provided appropriate and timely guidance to workers who alarmed the monitors. Personnel contamination incidents and events were properly handled.
The licensee provided good controls to prevent the spread of radioactive contamination.
Contaminated areas were properly posted and marked with tape and rope. Trash and laundry barrels were properly maintained. Step-off pads were placed at the entrances and exits to contaminated areas. The inspector observed radiation worker activities while exiting contaminated areas and noted use of good health physics practices during the removal of potentially contaminated protective clothing.
On April 29,1998, during tours of the radiological controlled area, the inspector identified approximately 36 sealed bags (containers / packages) of radioactive material located in the radwaste building Elevation 2000-foot hallway, outside the recycle evaporator valve gallery, which were not labeled with radiological information to permit individuals handling or working in the vicinity of the containers to take precautions to avoid and minimize their exposure. At the inspector's request, the bags were surveyed. Survey results revealed that some of the bags had dose rates as high as 30 millirems per hour on contact.
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l-9-l Section 4.0 of Procedure HTP-ZZ-02005, " Handling and Control of Radioactive Material,"
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Revision 22, states, in part, that the package shall be conspicuously labeled with the radiation caution symbol and the words " Caution Radioactive Material." Mark the results l
of the survey on a label on the package. Technical Specification 6.11 states, in part, l
that procedures for personnel radiation protection shall be prepared consistent with the
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requirements of 10 CFR Part 20.10 CFR 20.1904(a) states, in part, that the licensee shall ensure that each container of licensed material bears a durable, clearly visible label bearing the words " Caution Radioactive Material." The label must provide sufficient information, such as the date for which the activity is estima'ed, and radiation levels to permit individuals handling or using the containers to take precautions to avoid or minimize exposure.
The failure to label the bags (containers / packages) with the appropriate radiological information to permit individuals handling or using the containers to take precautions to avoid or minimize exposure is a violation of Technical Specification 6.11 (50-483/9807-
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During the same tour of the radwaste building on April 29,1998, the inspector identified an extension ladder going into the overhead of the waste evaporator coridensate tank and pump room leading to valve No. HBV-375, which was not posted " Contact Health Physics" or identified on the posted area survey map. Health physics management expectation was to survey or post allladders during routine radiological surveys. The inspector determined that this area is surveyed on a monthly frequency. A review of the survey files identified that the overhead was last surveyed 3 months earlier during the January 1998 survey cycle.10 CFR 201501(a) requires surveys to be performed to identify potential radiological hazards present. From a review of the radwaste operator'u logs, the radiation protection staff informed the inspector that the overhead area in question was last entered approximately 3 years ago. Thus, the inspector determined that this issue did not meet the threshold as a violation of 10 CFR Part 20. However, the inspector commented that management attention regarding this issue was needed because a noncited violation was identified for a similar issue about 2 years ago, Licensee management acknowledged the inspector's comment.
All portable radiation detection survey instrumentations observed by the inspector were properly response tested and calibrated.
The inspector reviewed the air sample log covering the refueling outage period. During this review, the inspector identified two areas which had not been posted as an airborne radioactivity area, in accordance with station procedures. Section 2.2(a) of Procedure HDP-ZZ-01500, " Radiological Posting," Revision 15, defines an airborne radioactivity area due to noble gas as an area in which the derived air concentration j
(DAC) value is in excess of 1 DAC. Section 2.2(b) cf the same procedure defines an airborne radioactivity area due to particulate as an area in which the DAC value is in excess of 0.3 DAC. Section 3.2.7.1 of Procedure HDP-ZZ-01500, states, that each airborne radioactivity area shail be conspicuously posted with a standard radiological warning sign (s) and the words " Caution Airborne Radioactivity Area."
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-10-l The first area which had not been posted was the hallway outside "A" residual heat i
removal heat exchanger room, on elevation 2000 foot of the Auxiliary Building. A noble gas air sample taken at approximately 2 a.m. on April 19,1998, indicated 1.25 DAC. A back-up air sample taken approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> later at about 5 a.m. revealed that the area no longer met the requirements for posting an airborne radioactivity area. The inspector was informed by radiation protection supervision that the particulate, lodine, and noble gas (PING) monitor located in the hallway outside the area was working, but did not alarm during the time in question. The licensee was not able to explain the discrepancy between the PING monitor and the air sample, other than to say that the air sample could have been closer to the source of the noble gas. During discussions with radiation protection supervision the inspector was informed that the noble gas alarm was set at twice the background level, however, the set point was not correlated to a DAC l
value. The inspector determined that the operation of the PING monitor did not relieve the licensee's staff of the requirement to properly post the area.
The second area was the letdown heat exchanger valve room located on the 1974-foot elevation of the auxiliary building. An air sample taken at approximately 2 a.m. on
- April 25,1998, indicated 3.66 DAC particulate. A back-up air sample taken about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later revealed the area no longer met the posting requirements of an airborne radioactivity area.
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.The licensee stated that neither the hallway outside the "A" residual heat exchanger room nor the letdown heat exchanger room were posted as airborne radioactivity areas during the times in question.
Technical Specification 6.8.1 requires, in part, that written procedures be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(3) of Appendix A of this Regulatory Guide includes procedures for airborne radioactivity monitoring. The failure to post the above areas as an Airborne Radioactivity Area is a violation of Technical
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Specification 6.8.1(50-483/9807-04).
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Conclusions Personnel contamination incidents and events were properly handled, and radiation protection personnel stationed at the radiological controlled area exit provided appropriate guidance to station workers who alarmed the personnel contamination monitors. Good controls were in place to prevent the spread of radioactive
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contamination. A violation was identified for the failure to properly label approximately 36 bags (containers / packages) of radioactive material with the appropriate radiological information to permit individuals handling or using the containers to take precautions to
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l avoid or minimize their exposure. Portable radiation detection survey instrumentation was properly response tested and calibrated. A violation was identified for the failure to properly post two areas as an airborne radioactivity are l R1.5 Maintaining Occupational Exoosure As Low As is Reasonably Achievable (ALARA)
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Insoection Scooe (83729/83750)
Radiation protection personnel involved with the ALARA program were interviewed. The following areas were reviewed:
Chemistry controls
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Outage Review Board support
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Exposure goal establishment and status
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Temporary shielding program
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ALARA suggestion program
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b.
Observations and Findinos During discussions with chemistry personnel, the inspector determined that management support for shutdown chemistry controls was excellent. There was a good use of industry and Callaway station resources for developing a plan to reduce reactor coolant activity during shutdown. Effective chemistry shutdown plans and controls were in place, in addition to the excellent training and coordination between operation, chemistry, and health physics personnel to accomplish the successful reduction in steam generator channel head dose rates about 27 percent.
The inspector noted that station management demonstrated their support for the ALARA program by delaying the start of the refueling outage by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in an effort to decontaminate the reactor coolant system and reduce the general area dose rates. The inspector noted that shutdown chemistry controls were effective in removing approximately 1100 curies of activity from the reactor coolant system.
The inspector determined that the outage exposure goal of 185 person-rem was established using past best performance and industry experience. The inspector noted that there was appropriate involvement by all activity coordinators and the outage review board in the development of the goal. The inspector concluded that the exposure goals were aggressive. Station and task activity exposures were appropriately tracked and trended by the ALARA staff. A review of the daily ALARA report for May 1,1998, revealed that the licensee would be under their outage exposure goal by approximately 10 person-rem.
A review of the daily outage report showed that emergent work accounted for approximately 8.5 person-rem of the total person-rem during the refueling outage.
During discussions with radiation protection ALARA personnel, the inspector was i
informed that ALARA staff was given ample time to review the majority of the emergent work packages in an effort to incorporate ALARA principles into the job planning.
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A review of selected work packages revealed that the packages documented lessons leamed and suggestions from past job performance which were evaluated and incorporated into the work plan to improve job efficiency and reduce task exposure.
A very good temporary shielding program was in-place. There were 41 temporary shielding packages installed during the refueling outage. The goal was tr uduce each area's general radiation levels by at least 50 percent. A review of selected pre-and post shielding general area survey data revealed that for the majority of the temporary shielding installations, general area dose rates were reduced approximately 70-80 percent. Temporary shielding packages were maintained in a neat orderly manner with proper engineering evaluations.
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Conclusions A very good ALARA program was effectively implemented. Effective chemistry shutdown plans and controls were in place to accomplish the successful reduction in steam generator channel head dose rates about 27 percent. Station management demonstrated their support for the ALARA program by delaying the start of the refueling outage by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in an effort to decontaminate the reactor coolant system and reduce the general area dose rates. The outage exposure goal of 185 person-rem was established using past best performance and industry experience in conjunction with appropriate involvement by activity coordinators and the outage review board.
R5 Staff Training and Qualification in Radiological Protection and Chemistry RS.1 Radiation Protection Staff Trair:ina a.
Insoection Scone (83729/83750)
Personnel involved with contractor radiation protection technician training and resume evaluation were interviewed. The following items were reviewed:
Radiation protection technician training lesson plans
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Resumes of contractor radiation protection technicians
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I Radiation protection management over sight of the training program
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Observations and Findinas (
Twenty-nine contractor senior radiation protection technicians and 7 contractor junior l
I radiation protection technicians were hired to support outage radiological activities. All contractor senior radiation protection technicians met or exceeded the guidance of l
American Nuclear Standards Institute (ANSI) 3.1-1978 (3 years of radiation protection l
experience) level technicians.
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The lesson plans used for training contract radiation protection technicians were well organized and developed, and site and industry lessons learned were incorporated.
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-13-Radiation protection management was appropriately involved in developing the training topics. All contrac'or radiation protection technicians were tested on site-specific l
information, radiation protection procedures, and on-the-job training and evaluations
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were given prior to workers being assigned independent tasks.
l The on-the-job evaluation qualification program was reviewed. Tasks listed were appropriate, and evaluation guidelines were clearly stated. However, during the review of the contractor senior radiation protection technician qualification cards, the inspector identified that 17 of the 29 contractor senior radiation protection technicians were assigned independent work assignments prior to their qualification cards being approved.
Section 7.3 of Procedure APA-ZZ-00014, " Conduct of Operations," Revision 7, is titled
" Evaluation and Qualification of Contractor Health Physics Technicians.' Section 7.3.1 of this procedure states, in part, that prior to performing work activities at Callaway Plant, the experience and qualification of contractor technicians must be reviewed and approved. During discussions with radiation protection management, the inspector was informed that it was the licensee's position that Section 7.3.1 of the above procedure was meant to refer to the contractor health physics technician's resume. However, a review of the procedure by the inspector did not identify this interpretation.
Technical Specification 6.8.1 requires, in part, that written procedures be established, l
I implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Section 7.e(6) of Appendix A of this Regulatory Guide includes procedures for the training in radiation protection. The failure to approve the 17 contractor senior health physics technician's qualification cards prior to assigning them work activities is a violation of Technical Specification 6.8.1. However, during the review of the contractor senior health physics technician's qualification cards, the inspector noted that although the qualification cards were not approved, all practical factors, on-the-job, and task-performance evaluations were completed prior to the individual being assigned independent tasks. Thus this failure constitutes a violation of minor significance and is being treated as a noncited violation consistent with Section IV of the NRC Enforcement Policy (50-483/9807-05).
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Conclusions in general, a good contractor health physics technician training program was in-place.
Lesson plans used for training contract health physics technicians were well organized and developed, and radiation protection management was appropriately involved in developing the training topics. Qualification tasks were appropriate for assigned activities, and evaluation guidelines were clearly stated. A noncited violation was identified for the failure to approve contractor senior health physics technician's qualification cards prior to assigning them work activities.
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-14-R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Quality Assurance Audits and Surveillance. and Radiation Deoartment Self-Assessments and Radiological Sucaestion Occurrence Solution Reoorts a.
Insoection Scoce (83729/83750)
Selected personnelinvolved with the performance of quality assurance audits and surveillance and radiation department self-assessments were interviewed. The following items were reviewed:
Qualifications of personnel who performed quality assurance audits and
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surveillance Quality assurance audits performed since January 1,1997
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Quality assurance surveillance performed since January 1,1997
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Radiation protection department self-assessments performed since January 1,
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1997 Radiological suggestion occurrence solution reports written since January 1,
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1997 b.
Observations and Findinos Quality Assurance Audits and Surveillance The quality assurance audit schedule and plans covered the appropriate program areas to provide management with a good overview of the radiation protection program.
Radiation protection and quality assurance management were appropriately involved in developing the audit plans.
Two radiological audits (AP97-007 and AP98-003) had been performed since January 1997. The inspector determined that the audits covered appropriate areas of the radiation protection program. However, the audit teams did not include a team member with applied experience in the radiation protection areas being audited. The inspector commented that although the audit covered the appropriate program areas, it did not provide an in-depth review of the areas audited. The licensee acknowledged the inspector's comment.
Two radiological suggestion occurrence solution (SOS) reports were written in each of the audits. The inspector noted that these items were appropriately tracked in the station's SOS reporting system.
One quality assurance operational radiation protection surveillance (SP98-009) had been performed since January 1997. Technical specialists working with the licensee's quality assurance engineer were used for this surveillance. The surveillance covered the i
station's ALARA Program. The inspector determined the surveillance provided management with a good overview of the ALARA progra _ _ _ __ _ - ____ _
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Radiation Protection Deoartment Self-Assessments One radiation protection department self-assessment was performed since January 1997. This assessment was performed April 13-17,1998, and covered the operational aspects of the health physics program. Technical specialists from other utilities were used for this assessment. The inspector determined that the assessment provided a very good evaluation of the areas reviewed, and appropriate recommendations were identified for program improvements; however, because of the timing of the assessment in relation to the refueling outage schedule, these recommendations had not been evaluated as of May 1,1997. On Friday May 8,1998, the licensee faxed copies of the Suggestion Occurrence Solution Reports to the inspector which documented the assessment recommendations.
Radiological Suggestion Occurrence Solution (SOS) Reoorts Overall, the licensee identified and documented radiological issues at the proper threshold to provide management with the tools needed to assess the radiation protection program. Generally, radiological SOS reports were closed in a timely manner to resolve repetitive problems. However, during a review of a summary of radiological SOS reports written since January 1997, the inspector noted that the licensee identified a number of repetitive problems with workers failing to sign in on the proper radiation work permit and using the computerized access control system. On April 30,1998, the inspector reviewed the licensee's preliminary evaluation of these events and noted that in all cases, radiological controls were proper although, the wrong radiation work permit were used. The licensee assembled a task team to address the electronic radiation work permit / access control issue. The inspector reviewed the task team charter and schedule of activities pertaining to this issue and determined it was reasonable to correct the problem. This item will be subject to further NRC review and is being identified as an inspection follow-up item (50-483/9807-06).
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Conclusions Overall, an adequate quality assurance auditiself-assessment program was implemented. The quality assurance audit schedule and plans covered the appropriate program areas to provide management with an overview of the radiation protection program. Radiation protection and quality assurance management were appropriately involved in developing the audit plans. Audit teams were not comprised of personnel with strong radiation protection backgrounds in the areas being audited. The audits covered the appropriate program areas; however, they did not provide an in-depth review of the areas audited. One radiation protection department self-assessment was performed since January 1997. Technical specialists from other utilities were used for this assessment. The assessment provided a very good evaluation of the areas reviewed, and appropriate recommendations were identified for program improvements.
An inspection follow up item was opened regarding the licensee evaluation and corrective actions associated with the electronic radiation work permit / access control system problem _ _ _ _ _ _ _ _ _
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-16-V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on May 1,1998. The licensee acknow: edged the findings presented. No proprietary information was identified.~
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ATTACHMENT SUPPLEMENTAL INSPECTION INFORMA1!ON PARTIAL LIST OF PERSONS CONTACTED Licensee G. Randolph, Vice President and Chief Nuclear Officer R. Affolter, Plant Manager D. Brownawell, Engineer, Quality Assurance M. Evans, Superintendent, Health Physics R. Farnam, Supervisor, Health Physics Operations K. Gilliam, ALARA Coordinator J. Kerrigan, Counting Room Supervisor, Health Physics J. Laux, Manager, Quality Assurance M. Reidmeyer, Engineer /NRC Interface, Quality Assurance NBC D. Passehl, Senior Resident inspector INSPECTION PROCEDURE USED 83729 Occupational Exposure During Extended Outages 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED AND CLOSED Opened I
483/9807-01 VIO Failure to conspicuously post a High Radiation Area.
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483/9807-02 VIO Failure to understand radiation work permit requirements and work area radiological conditions.
483/9807-03 VIO Failure to label containers of licensed material.
483/9807-04 VIO Failure to post two airborne radioactivity areas.
483/9807-06 IFl Electronic radiation work permit / access control problems evaluation.
Ooened and Closed 483/9807-05 NCV Failure to approve contractor health physics technicians qualification cards prior to assigning independent tasks.
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-2-LIST OF DOCUMENTS REVIEWED List of radiological Suggestion Occurrence Solution reports (01/01/97 - 04/24/98)
Quality Assurance Department Audit Reports AP97-007 and AP98-003 Quality Assurance Department Surveillance Report SP98-009 Radiation Protection Self-Assessment performed April 13 - 17,1998 Procedures APA-ZZ-00014, * Conduct of Operations," Revision 7 APA-ZZ-01000, "Callaway Plant Health Physics Program," Revision 13 APA-ZZ-01001, "Callaway Plant ALARA Program," Revision 6 HDP-ZZ-03000, " Radiological Survey Program," Revision 20 HTP-ZZ-01102, " Pre-job ALARA Planning and Briefing," Revision 14 HTP-ZZ-01203, "RWP Access Contrcl," Revision 24 HTP-ZZ-06009, " Personnel Contamination Incidents," Revision 25
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