ML20237D088
| ML20237D088 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/17/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| ULNRC-1697, NUDOCS 8712230038 | |
| Download: ML20237D088 (3) | |
Text
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m 1901 Gratiot Street. St. Louis December 17, 1987 Donald F. Schnell Vce President U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 ULNRC-169 7 j
Gentlemen
- i INSPECTION REPORT NO. 50-483/87031
]
This responds to W. D.
Shafer's letter dated November 19, 1987 which transmitted the report of the inspection conduct-ed at Callaway Plant during the period of October 6 through October 9, 1987.
Our responses to the violations are presented below.
None of the material in these responses is considered proprietary by Union Electric Company.
(50-483/87031-04) SEVERITY LEVEL IV: VIOLATION 1 Technical Specification 4.11.2.1.2 requires, in part, monthly sampling and analysis of the unit vent gaseous tritium effluent.
Contrary to the above, the monthly sampling and analysis of the unit vent gaseous tritium effluent required by June 25, 1987, was not accomplished until July 20, 1987.
Response
Corrective Actions Taken and Results Achieved Immediately upon discovery of this event, a tritium sample was taken from the unit vent.
This sample showed that the tritium concentration of 2.29E-8 Ci/cc was not a significant change from the May 28, 1987 sample concentration of 2.27E-8 Ci/cc.
Management has instructed all Hee.lth Physics (HP) Technical Support technicians to follow the applicable surveillance procedure and not to rely on the surveillance task sheet Task Description Summary (TDS) to determine the surveillance requirements.
Management invoked disciplinary counselling 8712230038 871217 DR ADDCK 05000403 D I (h kO PDR Mailing Address: P.O. Box 149 St. Louis. MO C3166
ULNRC-1697 Page 2 of 3 for the Health Physics personnel involved with this inci-dent.
Although personnel have been instructed to not rely on the surveillance task sheet TDS to determine the surveillance requirements, the TDS for this task sheet was revised to accurately describe the surveillance activity.
Corrective Action to be Taken to Avoid Further Violations No further corrective action is considered necessary.
The instructions provided to the HP technicians are considered sufficient to avoid further violations of this nature.
The Date When Full Compliance Will Be Achieved
' Union Electric is in compliance with our License conditions and Technical Specifications.
(50-483/87031-05) SEVERITV LEVEL IV: VIOLATION 2 Technical Specification 6.8.1 requires adherence to the applicable procedures recommended in Appendix A to Regulato-ry Guide 1.33, Revision 2, February 1978.
Section 7.e. (1) of the aforementioned Appendix A requires radiation work permit (RWP) procedures.
Administrative Procedure No.
APA-ZZ-01000, Callaway Plant Health Physics Program, Revi-sion 1, Section 4.13.4.1 requires individuals to obey RWP respiratory protection requirements.
Contrary to the above, on October 8, 1987, during an inspec-tion tour of the fuel building, an inspector observed that workers performing activities governed by the restrictions of RWP No. 87-386-2, Reconstitution of Fuel Assemblies, were removing items from the water without wearing respirators as required by the RWP.
Response
Corrective Actions Taken and Results Achieved Union Electric management counselled the contract HP techni-cian involved and instructed the Westinghouse reconstitution crew supervisor to follow all of the requirements of the RWP.
Health Physics management proposed a Radiological Work Practice Deficiency (RWPD) report to document the incident internally, and Quality Assurance, who identified the incident, wrote a Request for Corrective Action (RCA) to Health Physics management.
RWP 87-386-2 was revised to more explicitly state the RWP requirements for the reconstitution work.
- 4-ULNRC-169 7 Page 3 of 3 Management discussed the significance of the incident with Union: Electric HP Rad / Chem foremen.and the Numanco Site Coordinator at the time of its occurrence and also discussed
.the incident with the Westinghouse Site Coordinator, who documented the incident in his-Quality Report to the
-Westinghouse Division Office.
Radiological Category II training has been modified to.
emphasize to plant workers the importance of following the requirements of RWP's.
Corrective Action to be Taken to Avoid Further Violations The cause of this violation is a failure by_the contract HP technician to enforce the RWP requirements at the job site.
Contract HP' technician training will be revised to emphasize the responsibility of knowing and enforcing RWP requirements'and will specifically include direction that RWP requirements are not to be downgraded without an actual' revision to the'RWP.
This incident and the importance of clearly delineating RWP requirements will be incorporated into the next Union Electric HP Requalification training class.
The Date When Full Compliance Will Be Achieved Union Electric is in compliance with our License conditions and Technical Specifications.
Training for Union Electric personnel-will be completed by January 29, 1988.
Revision and_ implementation of contract HP technician training will be. completed prior to further utilization of contract HP personnel.
If you have any questions regarding this response or if additional information is required, please let'me know.
Very truly yours, m
Donald F.
Schnell cc:
A.
B. Davis - Regional Administrator, Region III J.M. Hinds - Chief, Reactor Projects, Section lA, Region III Tom Alexion - Licensing Project Manager (2 copies) y B. H. Little - NRC Resident Inspector B. J. Washburn - Manager, Utility Operations, Missouri Public Service Commission
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