IR 05000483/1998013
| ML20236V329 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/29/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236V309 | List: |
| References | |
| 50-483-98-13, NUDOCS 9808030087 | |
| Download: ML20236V329 (14) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-483 License No.:
NPF-30 Report No.:
50-483/98-13 Licensee:
Union Electric Company j
Facility:
Callaway Plant Location:
Junction Hwy. CC and Hwy. O j
Fulton, Missouri j
Dates:
July 14-17,1998 Inspector:
Michael P. Shannon, Senior Radiation Specialist, Plant Support Branch Approved By:
Blaine Murray, Chief, Plant Support Branch Attachment :
Supplemental Information i
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9808030087 980729
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PDR ADOCK 05000403
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-2-EXECUTIVE SUMMARY Callaway Plant NRC Inspection Report 50-483/98-13 This announced, routine inspection reviewed engineering safety feature filter ventilation systems maintenance and in-place filter testing; implementation of the liquid, gaseous, and particulate radioactive effluent monitoring program; status of the effluent monitors and chemistry counting equipment; training and qualifications of personnel; sad quality assurance oversight.
Enaineerina The engineering safety feature air filtration and adsorption units were properly
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maintained. Good in-place filter and laboratory testing programs were implemented.
System engineers responsible for the engineering safety feature filter ventilation systems
. were knowledgeable of their systems and appropriately involved in the filter testing j
program Housekeeping in the areas of the air cleaning systems was very good
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- (Sections E2.1 and E3.1).
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Overall, a good radioactive effluent monitoring program was maintained. A decreasing
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trend was noted in the radioactivity released through liquid effluents during 1996 and i
1997 (Section R1.1).
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A good effluent monitor calibration and channel check program was in-place. Effluent
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monitors were properly calibrated, and channel checks were performed in accordance with Final Safety Analysis Report requirements. Instrumentation used for analyzing effluent samples was properly maintained and calibrated. Housekeeping in the areas where effluent monitors were located was very good (Section R2).
An effective training program was in-place for personnel responsible for the effluent
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monitor program. Initial and continuing training program course materials were well organized, covering the subject areas needed to accomplish the required tasks and help ensure that the organization's technical competence was maintained (Section RS).
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Quality assurance oversight was effective. Audits were intrusive and thorough, providing management with a good assessment of the radiological effluent controls program. Audit findings were properly documented, tracked in the station's Suggestion Occurrence Solution Reporting System, and closed in a timely rrianner. Quality assurance department surveillance reports were well written and properly assessed the program
areas reviewed. Suggestion Occurrence Solution Reports identified issues at the proper l:
threshold to provide management with the tools needed to assess the program l
(Section R7).
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-3-A violation of 10 CFR 20.1501(a) was identified involving the failure to perform
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radiological surveys prior to, or at the start of, grinding / needle gun work within the containment building (Section R8).
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-4-Rap 2rt Details Ill. Enoineerina E2 Engineering Support of Facilities and Equipment E2.1 Enoineered Safetv Feature Filter Ventilation Svstems a.
Insoection Scoce (84750)
The inspector per'ormed visual inspections of the control room emergency ventilation and the emergency exhaust air cleaning systems and interviewed the engineers assigned to the systems.
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Observations and Findinos During walkdowns of the control room emergency ventilation and the emergency exhaust filtration systems, the inspector noted that the equipment was maintained. Additionally, the inspector determined that there was no obviouc physical damage to the air cleaning systems which would have prevented them from performing their required functions.
Redundant systems were available, as required. Test ports for in-place filter testing were
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installed and easy to access. From interviews with the two systems engineers
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responsible for the air cleaning systems, the inspector concluded that they were both
knowledgeable of their systems and appropriately involved in the filter testing program.
Housekeeping in the areas of the air cleaning systems was very good.
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Conclusions Engineering safety feature filter ventilation systems were properly maintained. System engineers responsible for the engineering safety feature filter ventilation systems were knowledgeable of their systems and appropriately involved in the filter testing program.
Housekeeping in the areas of the air cleaning systems was very good.
E3 Engineering Procedures and Documentation E3.1 Enoineered Safetv Feature Filter Ventilation System Eauioment Testino Results a.
Insoection Scoce (84750)
The inspector reviewed the following to determine compliance with Technical Specification requirements:
Records of in-place filter testing of high afficiency particulate air filters and
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I charcoal adsorbers f
Records of laboratory tests of charcoal adsorbers i
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Ohnervations and Findinas
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In general, filter testing was properly tracked by the system engineers. Through a review
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of the in-place test results, the inspector confirmed that the licensee complied with the
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Technical Specification requirements of Sections 4.7.6 C and 4.7.7 (b). The inspector
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also confirmed that laboratory testing of charcoal adsorber samples was performed in accordance with Technical Specification requirements of Sections 4.7.6 (d) and 4.7.7(c).
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Conclusions Overall, good in-place filter and laboratory testing programs were maintained.
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E7 Quality Assurance in Engineering Activities
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The inspector confirmed that an audit was performed of the vendor performing laboratory testing of samples of the charcoal adsorber material. The inspector concluded from a review of the audit summary that there were no adverse findings which would render the vendor laboratory test results invalid.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1,1 Implementation of the Liauid. and Gaseous Radioactive Waste Proaram
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Insoection Scone (84750)
Selected personnel involved in the radioactive waste effluent program were interviewed.
The following items'were reviewed:
Offsite Dose Calculation Manual
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1996 and 1997 annual effluent release reports
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Release permits
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Quarterly r.nd monthly sampling results
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Sampling procedures
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Technical Specification requirements
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Observations and Findinas L
Annual Radioactive Effluent Release Reports
A review of the Annual Effluent Release Reports for 1996 and 1997 revealed that the reports were written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the information required by the Offsite Dose Calculation Manual. The annual effluent release reports identified a decreasing trend in the radioactivity released through liquid effluents. The inspector determined from a review of l
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-6-i the 1996 and 1997 annual reports that all liquid and gaseous effluents discharged by the licensee during the above period were in compliance with regulatory requirements.
From a review of information, supplied by the licensee, related to radioactive effluent
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releases by other pressurizer water reactors, the inspector determined that gaseous
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releases by the licensee were in the worst quartile, with an improving trend and liquid
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l releases were in the best quartile, as compared to similar facilities.
Batch and Continuous Release Permits and Samolina Analyses Results j
The inspector randomly selected seven liquid radioactive effluent and four airbome radioactive effluent batch release permits, five airbome radioactive effluent continuous
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L release permits, and their periodic sample analyses results for review. The selection i
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confirmed that sampling and analysis were performed in accordance with the
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l requirements of Tables 16.11-1 and 16.11-4 of the Final Safety Anaiysis Report.
Cumulation dose contributions from liquid and gaseous effluents were determined at
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least once per 31 days in accordance with the methodologies and parameters described
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in the Offsite Dose Calculation Manual.
i Samolina Procedures
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L On July 15,1998, the inspector observed the sampling, analyses and preparation of the
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liquid batch release permit for Discharge Monitor Tank "B." The sample of the tank was l
collected from radweste building sample station No. SJ-144. No problems were
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identified during the sample analyses and batch release permit preparation. However,
during the sample collection, the inspector identified that the technician assigned to j
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collect the sample did not follow Sections 2.3,4.1.4.2, and 4.2.3 of Procedure CTP-SJ-01120, " Operation of Radwaste Sample Station (SJ-144)," Revision 9, which was used to collect the sample.
i Technical Specification 6.8.4.e. requires procedures for the implementation of the L
radioactive effluent controls program.
L Section 2.3 of the above procedure states, in part, " Verify the sample station ventilation L
system is operating properly by; (a) Verify the loss of hood suction indicator light is not l
lit." However, the inspector noted, and the technician confirmed, that this was not l.
performed prior to or during the sampling evolution. Section 4.1.4.2 states, in part, l
" Verify purge rate is at a minimum of 500 cc/ min by flow indicator." When questioned by l
the inspector, the technician was not able to explain what the purge rate was or if it was at least 500 cubic centimeters per minute (cc/ min) by flow indicator. The technician
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stated that the flow indicator bubble (which indicates the amount of flow) was near the
' top of the flow indicator; however, he was not aware of the amount of flow it indicated.
Section 4.2.3 states, in part, "After flushing at least 100 mis (from the sample line) rinse the sample container with sample water." However, the technician was not aware of the
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requirement to flush at least 100 milliliters (mis) from the sample line prior to rinsing the
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f-7-amount of time the sample line was purged prior to rinsing the sample container) that the
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technician had flushed the sample of at least 100 mis prior to rinsing the sample container with sample water. Additionally, the technician failed to monitor the sample's contact radiation levels in accordance with management's expectation as described in Section 3.3 of the above procedure.
The inspector concluded that the sample taken was a good representation of the tank's contents because the purge flow was verified by the inspector to be approximately 900 cc/ min, and the sample line was purged of at least 100 mis prior to the technician rinsing the sample container with sample water. Additionally, the proper radiological controls were used during the sample preparation to reduce the possibility of cross contamination.
The failure to follow the requirements of the above procedure is identified as a Violation of Technical Specifications 6.8.4.e. However, this failure constitutes a violation of minor significance and is not subject to formal enforcement action.
On July 16,1998, the licensee wrote Suggestion Occurrence Solution Report 98-3009 documenting the event and the immediate corrective actions taken to correct the problem.
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Conclusions Overall, a good radioactive effluent monitoring program was maintained. The licensee's radioactive effluent sampling and analyses met the requirements of the Final Safety Analysis Report requirements. The licensee demonstrated a decreasing trend in the
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radioactivity released through liquid effluents during 1996 and 1997. A minor violation was identified for the failure to follow sampling procedure requirements.
R2 Status of Radiation Protection and Chemistry Facilities and Equipment a.
Insoection Scooe (84750)
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Areas reviewed included:
Effluent monitor physical condition
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Effluent monitor calibrations
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Analytical instrumentation calibrations
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Observations and Findinas
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During walkdowns of the liquid and gaseous effluent radiation monitors and effluent i
storage tanks, the inspector found all monitors to be operable, and all monitors and tanks I
to be in good material condition. Additionally, housekeeping in the above areas was very I
good. The inspector determined that gaseous and liquid radioactive waste was proper l
stored and inventories were properly maintained.
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-8-A review of the calibration records and channel check documentation for the effluent monitors revealed that the monitors were properly calibrated, and channel checks were performed in accordance with laboratory procedures and the Final Safety Analysis Report requirements.
The inspector determined from observations and interviews with counting room personnel that all analytical instrumentation used for analyzing effluent samples was properly maintained and calibrated.
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Conclusions A good effluent monitor calibration and channel check program was in-place. Effluent monitors were properly calibrated, and channel checks were performed in accordance with the Final Safety Analysis Report requirements. Housekeeping in the areas where effluent monitors were located was very good. Analytical instrumentation used to analyze efflusnt samples was properly maintained and calibrated.
R5-Staff Training and Qualif! cation a.
Insoection Scone (84750)
Personnel involved with the radioactive waste effluent training program were interviewed.
The following items were reviewed:
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instructor qualifications
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Continuing training lesson plans
Management oversight of the training program
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Observations and Findinas The inspector reviewed the qualifications of the instructor assigned to provide initial and continuing training to tde health physics technician support staff involved in the radioactive effluent program. The instructor had a strong technical and operational effluents program background and was registered by the National Registry of Radiation Protection Technologists (NRRPT).
A review of the initial and continuing training program course materials revealed that the initial training material was well organized, covering the subject areas needed to accomplish the required tasks. Additionally, continuing training course material provided technicians with the appropriate topics to help ensure that their technical competence was maintained. The inspector noted a good use of course feedback forms for program improvements.
Lesson plans were well organized, developed, and site and industry lessons leamed were incorporated in the training material. The inspector determined that management was appropriately involved in developing the training topics,
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-9 The inspector reviewed the health physics technical support section staffing, and
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determined that the licensee was adequately staffed to support licensee commitments.
l Additionally the inspector noted that there had been little change and no reduction in the technical staff during the past 2 years.
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Conclusions An effective effluent training program was in-place. Initial and continuing training program course materials were well organized, covering the subject areas needed to accomplish the required tasks and help ensure that the organization's technical competence was maintained.
R7 Quality Assurance in Radiation Protection and Chemistry Activities a.
Insoection Scooe (84750)
Selected quality assurance department personnelinvolved with the oversight of the radioactive waste effluent program were interviewed. The following items were reviewed:
Qualifications of personnel who perform quality assurance department audits and
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surveillance
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1996 and 1997 quality assurance audits l
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Quality assurance surveillance
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Radioactive waste effluent program Suggestion Occurrence Solution Reports
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Observations and Findinas 6Mdits and Surveillance l
A review of the qualifications of the lead auditor lavolved in the oversight of the radiological effluent control program identified that the auditor had adequate experience and training to perform effective audits and surveillance. However, during discussions i
with the lead auditor, the inspector noted that the majority of this individual's training was l
self-taught from reviews of Regulatory Guides and industry information during preparations for audits and surveillance. The inspector commented that typically quality assurance auditors attended on-site training programs in an effort to improve their program knowledge. The licensee acknowledged the inspector's comment.
Two Quality Assurance Department Audit Reports AP%-009 (1996) and AP97-003
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(1997) which covered the radiological effluent control program were performed since the
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_ last inspection of this area in August 1996. The inspector noted that check lists used for these audits provided guidance that appropriate program areas were reviewed. The inspector determined that both audits were intrusive and thorough, providing i
management with a good assessment of the radiological effluent controls program. A l
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. number of findings were identified in botn audits which were properly documented, tracked in the stationt Suggestion Occurrence Solution Reporting System, and closed in a timely manner.
Seven quality assurance department surveillance reports pertaining to the radiological effluent monitoring program were written since August 1996. The inspector determined that, in general, the surveillance were well written and properly assessed the program areas reviewed.
Suaoestion Occurrence Solution Reoorts A review of the radiological effluent control program Suggestion Occurrence Solution Reports written since August 1,1996, revealed that the licensee identified issues at the proper threshold to provide management with the tools needed to assess the program.
The review also identified that, in general, response timeliness was appropriate and, overall, corrective actions appeared to be effective to correct the issue identifuxf.
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Conclusions Quality assurance oversight was effective. Audits were intrusive and thorough, providing management with a good assessment of the radiological effluent controls program. Audit
' findings were properly documented, tracked in the station's Suggestion Occurrence Solution Reporting System, and closed in a timely manner. Quality assurance
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department surveillance reports were well written and properly assessed the program
' areas reviewed. Suggestion Occurrence Solution Reports identified issues at the proper threshold to provide management with the tools needed to assess the program.
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Miscellaneous Radiation Protection and Chemistry issues a.
Insoection Scone (83750)
Selected radiation work permits.were reviewed for radiological survey evaluations.
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Observations and Findinas During the review of Radiation Work Permit 98 - 51701, Revision 1, which was used to remove paint on the 2000-foot elevation of the containment building liner floor plate between April 13-15,1998, the inspector noted that radiological conditions in the work area were not completely evaluated prior to allowing grinding / needle gun work on the painted surface. The inspector determined that loose surface contamination surveys were performed prior to the start of grinding / needle gun activities. However, neither fixed contamination surveys were performed prior to the start of work, nor airbome surveys were performed during the initial phase of work to determine the potential airbome radiological hazard that could be present.
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-11-10 CFR 20.1501(a) requires the licensee to make surveys that are reasonable under the circumstances to evaluate the concentrations of radioactive material and the potential radiological hazards that could be present.
A review of the loose surface contamination surveys of the work area indicated that the area was less thar,1000 disintegrations per 100 centimeters squared (dpm/100cm2).
However, during discussions with radiation protection supervision, the inspector was informed that areas inside the contairiment building were typically contaminated to levels of approximately 1000 - 10,000 dpm/100cm2. When asked if fixed contamination or airborne surveys were performed to determine the radiological hazards that could be present prior to/or at the start of, grinding / needle gun work, radiation protection supervision stated, that there was no need to perform the above surveys because to the best of their knowledge, the area in question had never been flooded with radioactive water, and thus, it likely did not contain fixed radioactive material.
The inspector noted, during discussions with the radiation protection supervisor who authorized Radiation Work Permit 98 - 51701, Revision 1, that he first thought the containment liner was painted during the plant's construction phase, although, he was not certain of the time frame. The inspector was later informed, by radiation protection supervision, that the liner was painted during Refueling Outage 3, in 1989.
i The inspector's primary concem was that radioactive material imbedded in the paint could become an airborne concern during grinding / needle gun work activities.
It was the licensee's position that: (1) the ALARA group evaluated Radiation Work
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Permit 98-51701 prior to it being issued; however, the inspector noted that the radiation l
work permit work package did not include documentation supporting this evaluation, (2) prior to the liner plate being painted, during Refueling Outage 3, the surface was i
wiped down with a solvent to prepare it for painting; however, radiation protection i
supervision stated that the wipe down should not be construed to mean that the area l
was decontaminated; (3) each individual work task was reviewed and protective requirements were tailored to the specific evolution; and (4) once the work package goes into the field, the health physics technician reviews the radiation work permit and performs the survey necessary to ensure the radiological conditions are as expected during the pre-job planning. However, a revlew of the radiation work permit package, by the inspector, revealed that it did not discuss the fact that the fixed contamination levels were evaluated during the radiation work permit preplanning review process.
Additionally, the health physics technician providing job coverage for the evolution was a temporary contractor radiation protection technician, who did not know the contamination history of the area.
From information provided by the licensee, the inspector determined that no positive j
whole-bedy results were identified regarding the above work activities.
The failure to evaluate the potential radiological hazards present in the work area is identified as a Violation of 10 CFR 20.1501(a) (50-483/9813-01).
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. Conclusions A violation was identified involving the failure to perform radiological surveys prior to, or at the start of, grinding / needle gun work activities within the containment building.
V. Management Meetings X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on July 17,1998.' The licensee acknowledged the findings presented and stated the following two positions: (1) although the technician who obtained the sample did not follow the procedure it was of minor safety significance and did not meet
the threshold of a cited violation; (2) a proper radiological evaluation was performed prior
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to the start of work, and it is the licensee's (unwritten) policy not to paint over contamination. No proprietary information was identified.
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I ATTACHMENT l
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Suoolemental INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. Affolter, Plant Manager C. Emerson, Radiation / Chemistry Supervisor C. Graham, Health Physics Technical Support Supervisor K. Gilliam, Radiation / Chemistry Supervisor
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J. Kerrigan, Radiation / Chemistry Supervisor j
J. Kovar, Engineer, Quality Assurance J. Laux, Manager, Quality Assurance R. Mi!!er, Radwaste/ Environmental Supervisor
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E. Olson, Chemistry Supervisor M. Reidmeyer, Engineer /NRC Interface, Quality Assurance NBC M. Hay, Radiation Specialist, Region IV D. Passehl, Senior Resident inspector LIST OF INSPECTION PROCEDURES USED IP 83750 Occupational Radiation Exposure IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ITEMS OPENED AND CLOSED Ooened 483/9813-01 VIO Failure to perform a radiological survey.
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2-LIST OF DOCUMENTS REVIEWED Annual Radioactive Effluent Release Reports for 1996 and 1997 List of radiological Suggestion Occurrence Solution Reports (08/01/96 - 07/12/98)
Quality Assurance Department Audit Reports AP96-009 and AP97-003 Quality Assurance Department Surveillance Report SP96-016 Quality Assurance Department Surveillance Report SP96-068 Quality Assurance Department Surveillance Report SP96-107 Quality Assurance Department Surveillance Report SP97-017 Quality Assurance Department Surveillance Report SP98-018 Quality Assurance Department Surveillance Report SP98-036 Quality Assurance Planning Guide - Environmental Monitoring Revision 13 APA-ZZ-00100, " Procedure Adherence," Revision 11 APA-ZZ-01000, "Callaway Plant Health Physics Program." Revision 13 APA-ZZ-01003, "Off-site Dose Calculation Manual," Revision 9 CTP-SJ-01120, " Operation of Radwaste Sample Station (SJ-144)," Revision 9 HTP-ZZ-02006, " Liquid Radwaste Release Permit (Batch)," Revision 49 HTP-ZZ-03100, " Performing Radiation Surveys," Revision 3 HTP-ZZ-03300, " Airborne Radioactivity Surveys," Revision 4 TDP-ZZ-00056, "RadChem Technician-HP Training Program," Revision 7
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initial and Continuing Effluent Training Material l
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