IR 05000483/2005011
| ML051780129 | |
| Person / Time | |
|---|---|
| Site: | Callaway  (NPF-030) |
| Issue date: | 06/24/2005 |
| From: | Shannon M Division of Nuclear Materials Safety IV |
| To: | Naslund C Union Electric Co |
| References | |
| IR-05-011 | |
| Download: ML051780129 (20) | |
Text
June 24, 2005
SUBJECT:
CALLAWAY PLANT - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000483/2005011
Dear Mr. Naslund:
On June 5, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. C. Younie, General Manager, Operations and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:
Radiation Monitoring Instrumentation
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
Radioactive Material Processing and Transportation
Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one NRC-identified violation of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy. If you contest the noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; and the NRC Resident Inspector at the Callaway facility.
Union Electric Company-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
//RA//
Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Docket: 50-483 License: NPF-30
Enclosure:
NRC Inspection Report 05000483/2005011 w/attachment: Supplemental Information
REGION IV==
Dockets:
50-483 Licenses:
NPF-30 Report:
05000483/2005011 Licensee:
Union Electric Company Facility:
Callaway Plant Location:
Junction Highway CC and Highway O Fulton, Missouri Dates:
May 14, through June 2, 2005 Inspectors:
Louis C. Carson II, Senior Health Physicist, Plant Support Branch Bernadette D. Baca, Health Physicist, Plant Support Branch Daniel R. Carter, Health Physicist, Plant Support Branch Donald L. Stearns, Health Physicist, Plant Support Branch Approved By:
Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety
Enclosure SUMMARY OF FINDINGS Callaway Plant NRC Inspection Report 05000483/2005-011 IR 05000483/2005-011; Union Electric Co; 05/16 - 06/02/2005; Callaway Plant; Occupational Radiation Safety involving access control to radiologically significant areas.
The report covered a one week period of inspection on site by a team of four region-based health physics inspectors. One finding of very low safety significance (Green) was identified.
The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, Significance Determination Process, (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings Cornerstone: Occupational Radiation Safety
Green. The team identified a non-cited violation of 10 CFR 20.1201(f) because the licensee failed to reduce the dose that individuals may be allowed to receive in the current year by the amount of occupational dose received at other facilities. Specifically, on May 16, 2005, the licensee failed to enter inspectors year-to-date exposure into the PRORAD computer system and subsequently reduce their allowable exposure margin.
The finding is greater than minor because it was associated with an Occupational Radiation Safety cornerstone attribute (Human Performance) and it affected the associated cornerstone objective. The failure to reduce exposure margins to control personnel exposure decreases the licensees ability to ensure adequate protection of the worker health and safety from exposure to radiation. The significance of the finding was evaluated using the Occupational Radiation Safety Significance Determination Process because the finding involved an individual workers potential for unplanned, unintended dose resulting from actions contrary to NRC regulations. The finding was determined to be of very low safety significance because the finding did not involve; (1) ALARA planning and controls, (2)
an overexposure, (3) a substantial potential for an overexposure, or (4) an impaired ability to assess dose. Additionally, this finding had cross-cutting aspects associated with human performance. Licensee personnel directly contributed to the finding when they failed to enter workers exposure into the licensees dose tracking computer system. The finding was placed into the licensees corrective action program as CAR 2005-03354 (Section 2OS1).
Enclosure Report Details 2. RADIATION SAFETY Cornerstone: Occupational Radiation Safety [OS]
2OS1 Access Control To Radiologically Significant Areas (71121.01)
a.
Inspection Scope This area was inspected to assess the licensees performance in implementing physical and administrative controls for access to radiologically controlled areas. The team used the requirements in 10 CFR Part 20, the technical specifications, and the licensees procedures required by technical specifications as criteria for determining compliance.
b.
Findings Introduction. The NRC team identified a non-cited violation of 10 CFR 20.1201(f) for failure to reduce the dose that an individual may be allowed to receive in the current year by the amount of occupational dose received at other facilities. The finding was of very low safety significance.
Description. On May 17, 2005, while processing into the radiologically controlled area the inspectors on the team noticed that their available exposure margin recorded in the licensees PRORAD computer system had not been reduced to reflect year-to-date exposure data. On May 16, 2005, the inspectors processed into the licensees dosimetry process which completed NRC Form 4's, and estimates of annual exposures.
The licensee failed to enter the inspectors dose information into the PRORAD computer system due to confusion as to where NRC exposure data was to be entered. In addition the team determined that the licensee assigned NRC inspectors a dose margin 5000 millirem per year. The licensee assigned all other personnel entering the radiologically controlled area a dose margin of 2000 millirem per year. With a dose margin of 5000 millrem and not inputting prior dose into the PRORAD system an NRC inspector could receive exposure while on site that could exceed a federal exposure limit (5000 millirem).
Analysis. The failure to reduce a persons exposure margin in accordance with federal regulations is a performance deficiency. The finding is greater than minor because it was associated with the Occupational Radiation Safety cornerstone attribute (Human Performance) and it affected the cornerstone objective. The failure to reduce exposure margins to control personnel exposure decreases the licensees ability to ensure adequate protection of the worker health and safety from exposure to radiation. The significance of the finding was evaluated using the Occupational Radiation Safety Significance Determination Process because the finding involved an individual workers potential for unplanned, unintended dose resulting from actions contrary to NRC regulations. The finding was determined to be of very low safety significance because the finding did not involve; (1) ALARA planning and controls, (2) an overexposure, (3) a substantial potential for an overexposure, or (4) an impaired ability to assess dose.
-2-Enclosure Enforcement. 10 CFR 20.1201(f) requires that licensees reduce the dose that an individual may be allowed to receive in the current year by the amount of occupational dose received while employed by any other person. Because this violation was of very low safety significance and was entered into the licensees corrective action program as CAR 2005-03354, it is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000483/0511-01, Violation of 10 CFR 20.1201(f)
for failure to reduce individuals exposure margin.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a.
Inspection Scope This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment
Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage
Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area
Self-assessments and audits
Corrective action program reports since the last inspection
Licensee action in cases of repetitive deficiencies or significant individual deficiencies
Calibration expiration and source response check currency on radiation detection instruments staged for use
The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training
-3-Enclosure
Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units The inspector completed 9 of the required 9 samples.
Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
Licensee Event Reports b.
Findings No findings of significance were identified.
Cornerstone: Public Radiation Safety [PS]
2PS1 Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems (71122.01)
a.
Inspection Scope This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
The most current radiological effluent release reports, changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, self-assessments, audits, and licensee event reports
Gaseous and liquid release system component configurations
Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluent; including effluent release permit generation and dose projections to members of the public
Abnormal releases or special reports
Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection
Monthly, quarterly, and annual dose calculations
-4-Enclosure
Surveillance test results involving air cleaning systems and stack or vent flow rates
Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control
Interlaboratory comparison program results
Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
Licensee Event Reports The inspector completed 10 of the required 10 samples.
b.
Findings No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a.
Inspection Scope This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:
The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program
Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges
Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting
-5-Enclosure
Shipping records for non-excepted package shipments
Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
C Licensee event reports and special reports The inspector completed 6 of the required 6 samples.
b.
Findings No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program And Radioactive Material Control Program (71122.03)
a.
Inspection Scope This area was inspected to ensure that the Radiological Environmental Monitoring Program verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
Annual environmental monitoring reports
A sampling of air sampling stations and thermoluminescence dosimeter monitoring stations
Collection and preparation of environmental samples
Operability, calibration, and maintenance of meteorological instruments
Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement
-6-Enclosure
Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection
Calibration and maintenance records for air samplers and composite water samplers; and environmental sample radiation measurement instrumentation quality control program, interlaboratory comparison program results, and vendor audits
Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access area] and the methods used for control, survey, and release from these areas
Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records
Audits, self-assessments, special reports, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
Licensee event reports The inspector completed 10 of the required 10 samples.
b.
Findings No findings of significance were identified.
4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution b.
Inspection Scope The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
Radiation Monitoring Instrumentation (Section 2OS3)
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)
Radioactive Material Processing and Transportation (Section 2PS2)
-7-Enclosure
Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)
b.
Findings and Observations No findings of significance were identified.
4OA5 Other TI 2515/161 - Transportation of Reactor Control Rod Drives in Type A Packages a.
Inspection Scope This area was inspected to verify that the licensees radioactive material transportation program complies with specific requirements of 10 CFR Parts 20, 71, and Department of Transportation regulations contained in 49 CFR Part 173. The inspector interviewed licensee personnel and determined the licensee had undergone refueling/defueling activities between January 1, 2002, and present, but it had not shipped irradiated control rod drives in Department of Transportation Specification 7A Type A packages.
b.
Findings and Observations No findings of significance were identified.
4OA6 Meetings Exit Meeting Summary The team conducted a telephonic exit of the inspection results to Mr. C. Younie, Manager, Operations and other members of licensee management during an exit meeting conducted on June 2, 2005. The licensee acknowledged the findings presented.
The team asked the licensee whether or not any materials examined during the inspection should be considered proprietary. No proprietary information was identified.
Attachment A-1 SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. Barbour, System Engineer, Meteorological Tower R. Farnam, Superintendent, Health Physics J. Hiller, Engineer, Regional Regulatory Affairs E. Olson, Superintendent, Chemistry & Radwaste H. Osborn, Senior Health Physicist, Health Physics Operations M. Reidmeyer, Supervisor, Regional Regulatory Affairs F. Stuckey, Rad/Chem Supervisor, Health Physics Operations D. Thompson, Staff HP Instrumentation C. Younie, Manager, Operations ITEMS OPENED, CLOSED, AND DISCUSSED Opened None.
Opened and Closed During this Inspection 05000483/2005-011 NCV Violation of 10 CFR 20.1201(f) for failure to reduce individuals exposure margin (Section 2OS1)
Previous Items Closed None LIST OF DOCUMENTS REVIEWED Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment Procedures ITL-SD-00R39 I&C Technical Procedure, Area Radiation SD-00R39, Revision 005 HTP-ZZ-04177, Eberline PCM-2 Operation, Revision 000 HTP-ZZ-04176, Eberline Model GTM Small Articles Monitor Operation, Revision 001 HTP-ZZ-04175, Eberline Model PM-7 Portal Monitor Operation, Revision 001 HTP-ZZ-04102, Operation of the Eberline RO-2(X) Series Ion Chamber, Revision 007
Attachment A-2 HTP-ZZ-04106, Operation of the Ludlum Model 14C, Revision 005 HTP-ZZ-04108, Operation of the Ludlum Model 3 Portable Rate Meter, Revision 005, HTP-ZZ-04101, Operation of the Ludlum Model 177 Series Alarm RateMeter, Revision 007 HDP-ZZ-04000, Health Physics Instrumentation Program, Revision 018 Surveillance Tests ISL-GT-00R59, Revision 012, I&C Loop Calibration Surveillance Procedure, CTMT High Range Area Rad Monitor ISL-GT-0R21B, I&C Loop Calibration Surveillance Procedure, Plant Unit Vent Effluent Radiation Detector, Performed 04/06/2005 ISL-HB-00R18, I&C Loop Calibration Surveillance Procedure, Liquid Radwaste Discharge Radiation Detector, Performed 03/14/2005 Surveillance Task Sheet S699109, ISL-GT-00R60 - Channel Source Cal Surveillance Task Sheet S699107, ISL-GT-00R59 - Channel Source Cal PM Task Sheet P699287, Loop Calibration, Seal Table Area Rad Hi Condition Reports CARs; 200400195, 200402320, 200404826, 200408432, 200405582, 200405948 Self-Assessments, Quality Audit Reports Focused Self-Assessment on INPO AFI RP.4.1, Contamination Detection, dated February 9,2004, Self Assessment Report; Callaway Plant Health Physics Instrumentation Program, dated March 29, 2004.
Quality Assurance Audit of Radiation Protection AP05-001, dated March 11, 2005 Calculation HPCI-05-03, Release of radioactive material, Revision 0 Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems Procedures APA-ZZ-00345 Fuel Reliability Program, Revision 8 CDP-ZZ-00900 NPDES Monitoring, Revision 20 CTP-ZZ-01114 Primary and Radwaste Bomb Sampling, Revision 31 HDP-ZZ-04700 Count Room Quality Control Program, Revision 13 HSP-ZZ-00005 Radioactive Gaseous Effluents Dose Rate, Revision 14 HTP-ZZ-02012 Gaseous Radwaste Release Permit (Containment) Revision 39
Attachment A-3 HTP-ZZ-02006 Liquid Radwaste Release Permit (Batch) Revision 58 HTP-ZZ-02021 Gaseous Radwaste Release Permit [Miscellaneous] Revision 10 HTP-ZZ-02012 Gaseous Radwaste Release Permit (Containment) Revision 39 ESP-GG-03005 FGG02B In-Place Bypass Leakage Test, Revision 10 ETP-ZZ-03005 In Place Bypass Leakage Testing of HEPA Filters, Revision 5 ETP-ZZ-03004 In-Place Bypass Leakage Testing of Adsorber Stage, Revision 4 MSE-GG-QG003 Emergency Exhaust System Flow Rates - B Train, Revision 2 RTN-HB-01000 Operation of the Liquid Radwaste Discharge Monitor Tanks, Revision 20 Radiological Effluent Monitoring Program Callaway Action Requests:
2005-0214, 2005-0609,2005-1730,2005-2962 2004-0079, 2004-0757, 2004-0764,2004-0795, 2004-1042, 2004-1858, 2004-2149, 2004-2526, 2004-2897, 2004-3212, 2004-3911, 2004-5033, 2004-5604, 2004-7623, 2004-9065, 2004-6023, 2004-6122, 2004-6139, 2004-6391, 2004-7427, 2004-8875, 2004-9000, 2004-9546 2003-6808, 2003-7430, 2003-4400, 2003-4519, 2003-4613, 2003-4802, 2003-8661, 2003-9297, Release Permits RP09-2004-L0137, RP12-2004-G0001, RP13-2004-G0002, RP14-2003-L0141 RP14-2004-L0063, RP14-2004-G0047, UR04-2004-G0009, UR03-2004-G0036 RP10-2005-L0018, RP11A-2005-G0021, RP13-2005-G0002 Surveillance Tests S705621: FGK01B Filter Unit Testing (Control Room Filter)
S703816: FGK02B Filter Unit Testing (Control Room Pressurization)
S690976: FGH01 Filter Unit Testing (Radwaste Building)
S691097: FGG02B Filter Unit Testing (Auxiliary/Fuel Building Emergency Filter)
Surveillance Packages S709701, S711088, S711777, S713344, S713659, S716981, S716761 S718686, S719735, S720113, S721135, S721137, S723153 Annual Self-Assessments, Quality Audit Reports, and Special Reports 2003 and 2004 Callaway Plant Radioactive Effluent Release Reports Callaway Plant Off-Site Dose Calculation Manual dated December 9, 2004 Special Report ULNRC05089 dated November 10, 2004 Effluents Interlaboratory Comparisons:
2003 and 2004 Analytics Radiochemistry Cross Check Program Results 2003 and 2004 Radiological Environmental Monitoring Program for Callaway Plant
Attachment A-4 Section 2PS3: Radiological Environmental Monitoring Program and Radioactive Material Control Program Audits and Self-Assessments NUPIC Audit/Survey Number 18558; Environmental, Inc., Revision 0 NUPIC Audit/Survey Number 18558; Environmental, Inc., Revision 1 NUPIC Audit/Survey Number 18822; Framatome ANP, Inc.
NUPIC Audit/Survey Number 18822; Framatome ANP, Inc., Revision 1 NUPIC Audit/Survey Number 18822; Framatome ANP, Inc., Findings Close Out SA03-HP-S05; NVLAP On-site Assessment of Dosimetry Processing Laboratory 100502-0 Condition Reports 2003-4877, 2003-5410, 2003-8265, 2003-8622, 2003-8728, 2004-0343, 2004-0500, 2004-1138, 2004-1468, 2004-1470, 2004-2348, 2004-2633, 2004-3284, 2004-3826, 2004-3839, 2004-4102, 2004-5305, 2004-5482, 2004-5938, 2004-6027, 2004-6662, 2004-7427, 2004-7907, 2004-8140, 2004-8756, 2004-9513, 2005-0653, 2005-0687, 2005-1616, 2005-2314, 2005-3541, 2005-3542 Procedures APA-ZZ-01003 Callaway Plant Offsite Dose Calculation Manual, Revision 15 APA-ZZ-01022 Radiological Environmental Monitoring, Revision 6 HTP-ZZ-02023 Unconditional Release of Radioactive Material, Revision 1 HTP-ZZ-02024 Conditional Release of Radioactive Material, Revision 0 HTP-ZZ-07001 Collection and Shipping of Environmental Samples, Revision 42 HTP-ZZ-07100 Land Use Census Program, Revision 3 HTP-ZZ-07101 Radiological Environmental Monitoring Program (REMP), Revision 7 HTP-ZZ-07101 Appendix A, REMP Sampling Locations, Revision 3 HTP-ZZ-07103 Evaluation and Reporting of REMP Data, Revision 5 Cross Checks and Instrument Calibrations 2003 and 2004 Analytics Radiochemistry Cross Check Program Results Calibration Record for Instrument Numbers: LAS-4094, LAS-4095, LAS-4097, and LAS-4100 Surveillances P683146, P711182, P715024, P715026, P715587, P715883, P721978, P721979, P721980, P722474, P731396, P731414, P731416, P731417, S714833, S714856, S714857, S714858, S714968, S721311, S721312, S721475, S721476, S721477, S731006, S731007, S731042, S731044, S731097
Attachment A-5 Miscellaneous 2003 and 2004 Callaway Meteorological Data Validation Final Report and Data Summaries 2003 and 2004 Callaway Plant Annual Radiological Environmental Operating Report 2003 and 2004 Callaway Plant Land Use Census Report 2003 and 2004 Radiological Environmental Monitoring Program for Callaway Plant, Environmental, Inc. Midwest Laboratory Quality Assurance Program, QAP-1, Revision 1 Special Report ULNRC04982 dated April 13, 2004 Special Report ULNRC04992 dated May 3, 2004 Special Report ULNRC05033 dated July 28, 2004 Special Report ULNRC05051 dated September 3, 2004 Section 2PS2: Radioactive Material Processing and Transportation Procedures APA-ZZ-00833 Hazardous Material Transportation Security Plan, Revision 0 APA-ZZ-01011 Process Control Program Manual, Revision 6 HDP-ZZ-08000 Respiratory Protection Program, Revision 14 HTP-ZZ-01433 Personnel Exposure Records, Revision 37 HTP-ZZ-08002 Respiratory Protection Issue and Use, Revision 23 HTP-ZZ-08203 Testing Mine Safety Appliances Regulators and Respirators Using the Biosystems Posichek-3 Tester, Revision 12 HTP-ZZ-08300 Respirator, Supplied Air Hood, and SCBA Inspection and Storage, Revision 23 HTP-ZZ-08510 Testing of Breathing Air, Revision 8 RTN-HB-00130 Operation of the ALPS System, Revision 8 RTN-HC-01100 Shipment of Radioactive Materials, Revision 18 RTS-HC-01130 10 CFR 61 Sampling Program, Revision 7 RTS-HC-01160 Shipment of Radioactive Wastes, Revision 16 TR-OP-035 Handling Procedure for Duratek Transport Cask Model CNS 8-120B, Revision 18 Audits and Self Assessments AP04-012 Quality Assurance Audit of Radwaste
Attachment A-6 Training Records T64.0340 8 Shipping & Packaging Radioactive Material, 20041222 T64.0650 8 Highway Transport and Disposal Criteria for RAM, 20040811 T64.0650 8 Shipping RAM, 20040811 Corrective Action Documents 200404243, 200407486, 200404729, 200404074, 200401865, 200306975, 200404172, 200409088, 200408875, 200405729, 200404871, 200403566 Shipping Packages 03-0032, 03-0049, 03-0062, 04-0020, 04-0060 Certificates of Compliance 9168 8-120B Package 9208 10-142 Package Radioactive Material Licenses R-86011-K06 Studsvik Processing Facility R-73006-F13 Duratek Services Inc.
SUMMARY OF FINDINGS Callaway Nuclear Generating Station NRC Inspection Report 05000483/2005011 INSPECTION PERIOD 05/16-06/02/05 Cornerstone: Occupational Radiation Safety D. Carter(4640)
PIM NRC NCV ORS June 02, 2005 71121.01 Human Performance Flag Violation of 10 CFR 20.1201(f) for failure to reduce individuals exposure margin
Green. The team identified a non-cited violation of 10 CFR 20.1201(f) because, the licensee failed to reduce the dose that individuals may be allowed to receive in the current year by the amount of occupational dose received at other facilities. Specifically, on May 16, 2005, the licensee failed to enter inspectors year-to-date exposure into the PRORAD computer system and subsequently reduce their allowable exposure margin.
The finding is greater than minor because it was associated with a Occupational Radiation Safety cornerstone attribute (Human Performance) and it affected the associated cornerstone objective. The failure to reduce exposure margins to control personnel exposure decreases the licensees ability to ensure adequate protection of the worker health and safety from exposure to radiation. The significance of the finding was evaluated using the Occupational Radiation Safety Significance Determination Process because the finding involved an individual workers potential for unplanned, unintended dose resulting from actions contrary to NRC regulations. The finding was determined to be of very low safety significance because the finding did not involve; (1) ALARA planning and controls, (2)
an overexposure, (3) a substantial potential for an overexposure, or (4) an impaired ability to assess dose. Additionally, this finding had cross-cutting aspects associated with human performance. Licensee personnel directly contributed to the finding when they failed to enter workers exposure into the licensees dose tracking computer system. The finding was placed into the licensees corrective action program as CAR 2005-03354 (Section 2OS1).