ML20151R966
| ML20151R966 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/27/1998 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-98-13, ULNRC-3882, NUDOCS 9809010278 | |
| Download: ML20151R966 (4) | |
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Union Electric Po Box 620 Callsway Plant Fulton, MO 65251 August 27,1998
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U. S. Nuclear Regulatory Commission Wggg Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 ULNRC-3882 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/98013 CALLAWAY PLANT UNION ELECTRIC CO.
This responds to Mr. Blaine Murray's letter dated July 29,1998, which transmitted a Notice of Violation for events discussed in Inspection Repon 50-483/98013. Our reuonse to the violation is presented in the attachment.
None of the materialin the response is considered proprietary by Union Electric.
If you have any questions regarding this response, or if additional information is required, please let me know.
Very truly yours, V.,Y,/
J. V. Laux Manager, Quality Assurance
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Attachment:
- 1) Response to Violation 9809010278 980827 PDR ADOCK 05000483 G
PDR a subsudnery of Amoren Corporation
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- ULNRC-3882 August 27,1998 Page 2 i
cc: Mr. Ellis W. Merschoff Regional Administrator
. i U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector j
Callaway Resident Office U.S. Nuclear Regulatory Commission l
8201 NRC Road Steedman, MO 65077 Ms. Kristine M. Thomas (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738 i
Manager, Electric Department Missouri Public Senice Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington,DC 20037 Manager, Plant Support Wolf Creek Nuclear Operating Corporation
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PO Box 411 Burlington, KS 66839 4
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d Attachment to ULNRC-3882 August 27,1998 PageI l
Statement of Violation During an NRC inspection conducted on July 14-17,1998, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR 20.1501(a) states, in part, "Each licensee shall make surveys or cause to be made, surveys that -(2) Are reasonable under the circuinstances to evaluate the (ii) concentrations or quantities of radioactive material; and (iii) The potential radiological hazards that could be present."
Contrary to the above, between April 13-15,1998, grinding / needle gun work was performed on the 2000-foot elevation of the containment building liner floor plate without performing surveys to evaluate the concentration or quantities of radioactive material and the potential airborne radiological hazards that could be present.
This is a Severity Level IV violation (Supplement 50-483/9813-01).
Reason for the Violation The reason for this violation was inadequate guidance for performing evaluations for this type of work and incomplete documentation of evaluations for the work performed April 13 through April 15,1998.
Callaway Plant believes the controls implemented were reasonable for the circumstances and adequately protected the worker as evidenced by the absence of Personnel Contamination Events / Incidents or positive Whole Body Counts. However, the following corrective action is being implemented to strengthen our current program.
Corrective Steps Taken and Results Achieved:
1.
It has been re-emphasized to the Rad / Chem Planner to identify any work documents for further evaluation which involve abrasive processes that could create a potential airborne radiological hazard.
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The ALARA Supervisor and the ALARA Technicians have been instructed to, in conjunction with item #1, review the weekly schedule for identified items and any
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Attachment to ULNRC-3882 August 27,1998 Page 2 other work documents which may involve abrasive processes which have the potential to cause an airborne radiological hazard..
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HP Operations personnel have been reminded to evaluate all abrasive processes for potential fixed contamination prior to start of work. If appropriate documentation does not establish the absence offixed contamination, then appropriate engineering controls, containment devices or respiratory protection in conjunction with air sampling will be employed to assure the worker is adequately protected against airborne radiological hazards.
Corrective Steps to Avoid Further Violations:
Procedural controls will be enhanced to ensure that the absence of fixed contamination is j
evaluated and documented when activities utilizing abrasive processes have the potential to create an airborne radiological hazard. This guidance will be contained in procedure HTP-ZZ-01201, " Preparation and Maintenance of General and Specific Radiation Work Permits". The procedure will require a documented basis be included with the Radiation Work Permit (RWP) for those cases where there is insufficient fixed contamination to create a radiological airborne hazard.
Ifit cannot be determined by review that an acceptable low level of fixed contamination exists, HP Personnel have been instructed to implement appropriate engineering controls and/or containment devices to protect the worker from airborne contaminants. Air sampling will be used to verify the adequacy of these controls. When warranted by TEDE j
ALARA Evaluations, respirators will be employed to protect the worker until such time as air samples can be analyzed and evaluated to determine whether continued use of respirators is required.
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Date when Full Compliance will be Achieved:
The procedure revision and training of HP Personnel on the procedure changes will be completed by October 30,1998.
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