ML20249B419
| ML20249B419 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/18/1998 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-98-07, 50-483-98-7, ULNRC-3839, NUDOCS 9806230073 | |
| Download: ML20249B419 (11) | |
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a Union Electric l'O Ilox 620 Callaway Plant Fulton, MO 65251 June 18,1998 l
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl-137 Washington, DC 20555-0001 ULNRC-3839 I,
Gentlemen:
4 REPLY TO NOTICE OF VIOLATION UE issPeCTiOs nePOnT sO. so-483/98oov CALLAWAY PLANT UNION ELECTRIC CO.
This responts to Mr. Blaine Murray's letter dated May 19,1998, which transmitted four Notices of Violation for events discussed in Inspection Report 50-483/98007. Our response to these violations is presented in the attachment.
None of the material in 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,
,M f
J. V. Laux Manager, Quality Assurance JVUtmw Aitachment: 1) Response to Violations
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9806230073 980618 PDR ADOCK 05000483-G PDR a subsdary of Amoma Cseperstron
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ULNRC-3839 June 18,1998 Page2 cc: Mr. Ellis W. Merschoir Regional Administrator
- U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plazt. Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident laspector Callaway Resident Omce U.S. Nuclear Regulatory Commission
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8201 NRC Road Steedman, MO 65077 Ms. Kristine M. Thomas (2 copies)
Licensing Project Manager, Callaway Plant Omce of Nuclear Reactor Regulation U.' S. Nuclear Regulatory Commission
.l Mail Stop 13E16 Washington, DC 20555-2738 l
Manager, Electric Department l
Missouri Public Service 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 Suppon Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839
Attachment to ULNRC-3839 June 18,1998 Page1 STATEMENT OF VIOLATION During an NRC inspection conducted on April 27 through May 1,1998, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the first violation is documented below:
A.
Technical Specification 6.11 states, in part, that procedores for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20. 10 CFR Part 20.1902(b) states, in part, that the licensee shall post each High Radiation Area with J
a conspicuous sign or signs bearing the radiation symbol and the words " Caution High Radiation Area."
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."
Contrary to the above, 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.
This is a Severity Level IV violation (Supplement IV ) (50-483/9807-01).
Reason for the Violation The controlled area had recently been expanded due to higher dose rates created by a filter placed in the shielded host drum. In the process of enlargmg the area, a posting was not placed on the east side of the rope barricade. Personnel believed that the area was sufficiently posted to prevent inadvertent entry and met the requirement of HDP-ZZ-01500, Section 3.2.8.1 and 10CFR20.1902(b) to be " conspicuously posted." The area did no' have a sign on the 8-foot section of rope on the east side of the posted area. The root cause of this deficiency is that a clear meaning of the term " conspicuously posted" per 10CFR20 has not been defined nor communicated by HP management.
The meaning of" conspicuously posted" is not defined in either 10CFR20 or NRC guidance documents. Additionally, HDP-ZZ-01500, Radiological Posting, does not define nor provide guidance as to the meaning of" conspicuously posted." Consequently, the term is subject to interpretation.
Corrective Steps Taken and Results Achieved:
To augment the existing postings, HP Personnel immediately added a Caution-High Radiation Area (CHRA) posting to the east side of the radiological rope surrounding the area.
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I Attachment to ULNRC-3839 June 18,1998 Page 2 Corrective Steps to Avoid Further Violations:
Procedure HDP-ZZ-01500, Radiological Postings, was revised to incorporate a definition of" conspicuously posted" This change clarified expectations as to the meaning of this term. HP Department personnel will be trained on this procedure change. Consistent with NUREG/CR 5569, Health Physics Position Data Base, HPPOS-234, the yellow and magenta barricades are not only an access control mechanism but play an integral part in warning and communicating radiological hazards to plant personnel.
It has been communicated to plant personnel, when approaching a radiological barricade, they are to follow the barricade to locate the radiological posting for the area if the posting is not readily apparent from their location. This will also be incorporated into General Employee Training.
Date when Full Compliance will be Achieved:
HDP-ZZ-01500 was revised on June 9,1998. Estimated completion date for incorporation into General Employee Training is June 30,1998. HP personnel will be trained on procedure changes by June 30,1998.
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Attachment to ULNRC-3839 June 18,1998 Page 3 STATEM ENT OF VIOLATION During an NRC inspection conducted on April 27 through May 1,1998, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the second violation is documented below:
B.
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.
Regulatory Guide 1.33, Appendix A, Section 7.e(l), includes procedures for the access control to radiation areas including a radiation work perrait system.
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.
Contrary to the above, on April 27,1998, the inspector identified that six radiation workers failed to understand the restrictions / limitations of the radiation work permit and maintain an awareness of the work area radiological conditions.
T.is is a Severity Level IV violation (Supplement IV ) (50-483/9807-02).
I Henson for the Viointion
- 1. Radiologicalinformation presented on radiological survey sheets may be too complicated and not formatted in an optimum way for typical radiation workers to assimilate and understand. The information is not provided in a user-friendly format that is easily retained by non-HP Personnel.
- 2. Some personnel have come to rely on HP Personnel to provide RWP restrictions, requirements and Radiation Survey information at thejob site.
A formal root cause evaluation is being performed to evaluate other contributing factors and to identify other potential contributing causes for the violation.
Corrective Steps Tnken nnd Results Achieved:
To emphasize management concern and expectations on this issue, management sent written correspondence to all Callaway employees reiterating the importance of understanding the requirements of the RWP and maintaining an awareness of the radiological conditions in their work area.
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l Attachment to ULNRC-3839
- June 18,1998 1:
Page 4 -
Corrective Steps to Avoid Further Violations:
l Better ways to communicate radiological conditions and requirements will be evaluated to p
formulate a' comprehensive approach to address this issue. These actions willinclude:
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- 1. Perform a form' root cause analysis to determine the causal factors contributing to this problem.
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- 2. - Survey other plants with effective approaches in this area to benchmark their good practices and lessons learned. The objective will be to determine the most effective way to present RWP and radiological condition information to plant personnel so the information is understood and retained.
3 Solicit input from various plant work groups to review this issue and provide recommendations on improvements and solutions.
' Date when Full Compliance will be Achieved:
Benchmarking, data collection, and evaluations will be complete by September 1,1998. A
-comprehensive action plan will be developed by October 1,1998, with full l'
implementation by April 2,1999.
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Attachment to ULNRC-3839 June 18,1998 Page 5 STATEM ENT OF VIOLATION l
During an NRC inspection conducted on April 27 through May 1,1998, four violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure l
for NRC Enforcement Actions," NUREG-1600, the third violation is documented below:
C.
Technical Specification 6.1 I states, in part, that procedures for personnel radiation protection shall be prepared consistem with the requirements of 10 CFR Part 20. 10 CFR Part 20.1904(a) states, in part, that the licensee shall ensure that each container of ficenJ 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 estimated and radiation levels to permit individuals handling or using the containers to take precautions to avoid or minimize exposure.
Section 4.0 of Procedure HTP-ZZ-02005, " Handling and Control of Radioactive Material," 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 of the survey on a label on the package.
Contrary to the above, on April 29,1998, the inspector identified approximately 36 sealed bags (containers / packages) of radioactive material located in the radwaste building Elevation 2000 foot halhvay 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 / packages to take precautions to avoid and minimize their exposure.
This is a Severity Level IV violation (Supplement IV ) (50-483/9807-03).
Renson for the Viointion The direct cause of this violation was that the responsible personnel did not rigorously ensure the bags were dose-rated. These bags contained low-level radioactive waste generated during the refuel outage. All bags are dose rated prior to transport to the sorting area. The bags were placed in the Radwaste 2000' elevation hallway in preparation for removal to a transport container. Contract laborers had soned the contents of the bags and then staged the re-bagged material in the hallway for loading into the transport container. After sorting, the bags needed to be resurveyed and labeled since some of the contents may have been shufIled.
I Attachment to ULNRC-3839 June 18,1998 Page 6 Several Factors contributed to this event:
- 1. The individual designated to perform the survey of the bags left the power block te attend required training as assigned.
- 2. At the time of the occurrence, plant heat-up activities were in progress. Personnet l
with responsibility for dose rating sorted trash were involved in several RCS filter change outs that were being performed. Technician manpower was limited and additional resources were not requested.
Corrective Steps Taken and Results Achieved:
The bags were dose-rated. Three RAM areas were set up for the staging of bags that had not been dose-rated. The posting on these areas was " Contact HP for Survey Prior to Entry, Radioactive Materials." Contract Laborers and Rad / Chem Helpers were instructed to place all bags to be dose-rated in these areas. Personnel were instructed to periodically inspect these areas and dose-rate the bags accumulated in the area.
Corrective Steps to Avoid Further Violations:
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Procedure HTP-ZZ-02005 has been revised providing guidance to establish temporary j
staging areas, consisting of boundary ropes and appropriate postings, to place bags in until j
a technician can dose-rate and label the bags. The action of placing unlabeled bags in a posted radiological area until they can be surveyed individually will permit personnelin the area of the staged bags to take precautions to minimize their exposure. HP Personnel and Rad / Chem Helpers were notified of this practice.
j Date when Full Compliance was Achieved:
i The action to prevent further violations was completed June 12,1998.
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Attachment to ULNRC-3839 June 18,1998 Page 7 STATEMENT OF VIOLATION During an NRC inspection conducted on April 27 through May 1,1998, four violations of NRC l
requirements were identified. In accordance with the " General Statement of Po!. icy and Procedure
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for NRC Enforcement Actions," NUREG-1600, the fourth violation is documented below:
D.
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 1973.
i Regulatory Guide 1.33, Appendix A, Section 7.c(3), includes procedures for airborne radioactivity monitoring.
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 DAC value is in excess of I DAC. Section 2.2(b) of the same procedure defmes 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 i
Area shall be conspicuously posted with a standard radiological warning sign (s) and the i
words " Caution Airborne Radioactivity Area."
Contrary to the above, on April 29,1998, the inspector identified that on April 19,1998, the hallway outside "A" RHR Heat Exchanger Room, on elevation 2000 foot of the auxiliary building was not posted as an airborne radioactivity area from approximately 2 I
a.m. until 5 a.m. Additionally, the inspector identified that on April 25,1998, the Letdown Heat Exchanger Valve Room located on elevation 1974 foot of the Auxiliary Building was not posted as an airborne radioactivity area from approximately 2 a.m. until 4 a.m.
This is a Severity Level IV violation (Supplement IV ) (50-483/9807-04).
Renson for the Viointion The cause of the condition dating back to April 19,1998, was an oversight on % part of the HP Technician and Supervisor reviewing the Air Acti ity Concentration korksheet.
These individuals did not recognize the elevated air sample result and, consequently, missed the requirement to post the area as an airborne area.
A contributing factor is that the continuous air monitor in the hallway outside the "A" Residual Heat Removal Heat Exchanger Roam did not alarm. This led the HP Personnel to conclude that a noble gas condition did not exist. The continuous air monitors are very l
sensitive to noble gas and operating history has shown these monitors to alarm at very low concentrations of noble gas.
Att.achment to ULNRC-3839 June 18,1998 Page 8 I
The cause of the occurrence on April 25,1998, was that responsible HP Personnel decided to wait on a back-up sample prior to posting the area. Contributing factors include:
- 1. The area was posted " Contact HP For Survey Prior to Entry" (CHP). This prohibited entry into the area by personnel until HP assessed the radiological conditions. The assumption was made personnel would be adequately warned of the airborne hazard by the CHP and Caution-High Radiation Area (CHRA) posting already present on the I
area. Personnel involved incorrectly assumed that the CHP posting could suffice for the Airborne Radioactivity Area (ARA) posting until the back-up air sample results were obtained.
- 2. Personnel involved believed that since the air sample was for a specificjob which had been completed, the airborne radiological condition most likely no longer existed. A i
back-up sample was in progress that would confirm no airborne condition existed or would validate the need to post the area.
1 Corrective Steps Taken ami Results Achieved:
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l No remedial actions were taken because these events were transient in nature and occurred during Refuel 9. The radiological conditions no longer exist; consequently j
remedial or compensatory actions were not required.
Corrective Steps to Avoid Further Violations:
Concerning the April 19 occurrence, the personnel involved in the inadequate review of the airborne survey data have been coached to ensure accuracy and attention to detail when reviewing air sample logs. As an isolated case, no other corrective actions are deemed necessary.
Concerning the April 25 occurrence, it is the policy and practice of the HP Department to take the proper compensatory action (posting, access control, protective equipment) based on available radiological survey results. If follow-up survey results do not confirm the conditions, then the radiological controls are revised accordingly. This has been emphasized to HP Department personnel and will be re-emphasized in the next HP Retraining session. Estimated time of completion of this action is September 30,1998.
In addition, procedure HTP-ZZ-03300, Airborne Radioactivity Surveys, was revised to provide guidance to ensure prompt and consistent posting of airborne radioactivity areas based on gamma spectroscopy analysis of air samples. Posting requirements will be clarified to eliminate misconceptions concerning CHP posting in lieu of the proper radiological posting during the next HP retraining session.
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Page 9 Date when Full Compliance will be Achieved:
Procedure changes are complete and HP personnel will be trained on these changes by June 30,1998. The procedure changes will also be included in HP retraining scheduled for completion by September 30,1998.
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