IR 05000483/1986004

Insp Rept 50-483/86-04 on 860317-21.No Violation or Deviation Noted.Major Areas Inspected:Radiation Protection Program During Maint Outage,Including Changes in Organization,Personnel,Facilities,Equipment & Procedures

ML20155D854
Person / Time
Site:	Callaway
Issue date:	04/10/1986
From:	Gill C, Grant W, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155D847	List: IR 05000483/1986004 ML20155D843
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-2.F.1, TASK-TM 50-483-86-04, 50-483-86-4, IEIN-85-081, IEIN-85-81, NUDOCS 8604170451
Download: ML20155D854 (12)

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U. S. NUCLEAR REGULATORY CO MISSION l

REGION III

Report No. 50-483/86004(DRSS)

Docket No. 50-483 License No. NPF-30 ;

Licensee: -Union Electric Company i Post Office Box 149 i St. Louis, MO 63166 l Facility Name: Callaway County Nuclear Station  !

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Inspection At: Callaway Site, Callaway County, M0 l

Inspection Conducted: March 17-21, 1986 kl. 0 Yufby Inspectors: C. F. Gill V'/# ' 4 gg Date W. B. Grant o

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[. 8. bb[p Approved By: L. R. Greger, Chief 9'-/0-f6 Facilities Radiation Protection Date Section Inspection Summary Inspection on March 17-21, 1986 (Report No. 50-483/86004(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection program during a maintenance outage, including: changes in organization, personnel, facilities, equipment, programs, and procedures; audits and I appraisals; planning and preparation; training and qualifications of new personnel; internal and external exposure control; control of radioactive materials, contamination, surveys, and monitoring; and the ALARA progra Also reviewed were open items and licensee's response to IE Information Notice 1-No. 85-8 Results: No violations or deviations were identifie I I

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DETAILS 1. Persons Contacted

• Bledsoe, Jr. , Compliance Engineer

• Gearhart, QA Superintendent

• C. Graham, Health Physics Technical Supervisor

• S. Growcock, QA Scientist J. Kerrigan, Chemistry Foreman S. Merciel, Assistant Compliance Engineer

• J. Peevy, Assistant Manager, Technical Services

• J. Polchow, Health Physics Operations Supervisor

• G. Randolph, Plant Manager

• J. Ridgel, Radwaste Superintendent C. Riggs, Supervisor, Primary Chemistry

• R. Roselius, Health Physics Superintendent R. Seylar, Engineer, Nuclear Projects D. Shafer, Supervising Engineer, Licensing

• N. Slaten, Supervising Engineer, Nuclear G. Spires, Health Physics Foreman

• B. Stanfield, QA Assistant Engineer

• T. Stotlar, QA Supervising Engineer

• B. Little, NRC Senior Resident Inspector The inspectors also contacted other licensee employees including radiation protection technicians and members of the engineering staf * Denotes those present at the exit meetin . General This inspection, which began at 1:00 p.m. on March 17, 1986, was conducted to review the radiation protection program during a refueling-and maintenance outage,-including organization and management controls, qualifications and training, audits and appraisals, planning and prepara-tion, internal and external exposure controls, ALARA program, control of radioactive material and contamination, open items, and IE Information Notice No. 85-81. During plant tours, the inspectors noted that area postings, access controls, and housekeeping were good; no apparent procedure adherence problems were identifie . Licensee Actions oni P revious Inspection Findings (Closed) Open Item (483/84016-04): Install area monitor on manipulator crane and correct FShR inconsistency regarding monitor locations. The physical installatiois of the monitor was verified by the NRC Senior Resident Inspector; the licensee's analysis indicates that the new monitoring configuration satisfies the recommendation of ANSI /ANS 6.8.1-1981; and the licensee plans to correct FSAR inconsistencies concerning monitor location in the next scheduled amendment submitta . 2

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(0 pen) Open Item (483/84035-01): Determine post-accident effluent sampling system iodine line loss correction factor The licensee stated that NRR has.not responded to the licensee's May 14, 1985, request for deviation from this portion of NUREG-0737, Item II.F.1, Attachment 2. This matter will be reviewed further during a future inspectio (0 pen) Open Item (483/84035-02): Procedurally control filter housing deluge systems to preclude flooding of adjacent ducting. The use of fire hoses to supply the filter housing water deluge systems has been found acceptable by Region III Fire Protection Specialists and the NRR Fire Protection Reviewer (0 pen Item 483/84035-03 was closed in Inspection Report No. 50-483/85024); the fire pre plans have been revised to warn against overfilling the filter housings with water; and work requests have been issued to install swivel adapters to the 1-1/2 inch hose connection on the water deluge fire protection systems for the charcoal filter unit However, deluge water filter housing drainage has not been addressed by the fire pre plan This matter will be reviewed further during a future inspectio (0 pen) Open Item (483/85006-01): Calibrate liquid and gaseous effluent monitors. All monitors except the radwaste exhaust wide range gas monitor (WRGM) have been calibrated. The low range noble gas detector has been calibrated for this WRGM; however, detector inoperability precluded the calibration of the mid and high range noble gas channel The licensee plans to complete the calibration as soon as replacement detectors arrive onsite. This matter will be reviewed during a future inspectio (Closed) Open Item (483/85006-03): Seal concrete surfaces that could become contaminate As of March 21, 1986, nearly all of the needed painting-had been completed; the licensee expects to complete this task during the current outag (0 pen) Open Item (483/85006-04): Prepare documents which identify the required compliance activities for NUREG-0737, Items II.B.3 and II.F.1, Attachment 1, 2, and The licensee completed an internal document titled, "NUREG-0737 Compliance Review Report," dated February 25, 198 This document supercedes an earlier report dated June 25, 1985, which Region III inspectors found too superficial to justify the licensee's claim of full compliance with the commitments to these four NUREG-0737 items (Inspection Report No. 50-483/85017, Section 3). In general, the current document seems adequate to provide a detailed (line-by-line)

identification of each commitment associated with the previously listed NUREG-0737 items, ascertain compliance, identify any corrective measures needed or variance requests required, and identify activities needed to document complianc In addition to a previously generated variance request (0 pen Item 483/84035-01), the licensee identified the following commitments from which they intend to request variances from NRR: (1)

capability to take a grab sample for hydrogen in the containment atmosphere and (2) capability to measure noble gas concentrations as equivalent Xe-133 or microcuries/cc of actual noble gas. The licensee has also identified the need for modification of two systems, corrections to the FSAR, ;

procedural changes, and recalibration. The licensee has begun an action l plan tracking system for actions needed to comply with NUREG-0737 and to

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I document compliance; however, this system is in the preliminary stage Because the licensee apparently misinterpreted several of the NUREG-0737 commitments, the licensee plans to revise portions of the compliance review report and add numerous action plan items to the compliance tracking system. This matter will be reviewed further during a future inspectio ,

(0 pen) Unresolved Item (483/85016-01): Correction of a wide range gas monitoring system design deficiency. This item remains open pending completion of Callaway Modification Request No.83-312 (Closed) Violation (483/85017-01): . Violation of Technical Specification 4.7.9.2. Licensee corrective actions outlined in the licensee's response dated September 20, 1985, were reviewe No problems were note (Closed) Violation (483/85017-02): Violation of Technical Specification 3.3.3.6 and 3.3.3.10. Licensee corrective actions outlined in the licensee's response dated September 20, 1985, were reviewed. No problems were note . Changes The inspectors reviewed changes in organization, personnel, facilities, equipment, programs, and procedures that could affect the outage radiation protection progra Effective January 15, 1986, the following personnel changes were made:

• The Manager, Callaway Plant, was promoted to the new position of General Manager - Nuclear Operation * The Assistant Manager, Technical Services, was promoted to Manager -

Callaway Plan * The Superintendent, Health Physics, was promoted to Assistant Manager -

Technical Service * The Supervisor, Health Physics, Technical Support, was promoted to Superintendent - Health Physic * A Staff Health Physicist, was promoted to Supervisor - Health Physics, Technical Suppor The licensee plans to fill the vacant staff health physicist position in April 1986. Also, the number of radiation protection foremen have been increased from seven to eigh No violations or deviations were identifie . Organization and Management Controls The inspectors reviewed the licensee's radiation protection organization and management controls for the radiation protection program, including effectiveness of procedures and other management techniques used to implement the program and experience concerning self-identification and correction of program implementation weaknesse .. .

The new' Superintendent - Health Physics (SHP) was appointed Radiation Protection Manager (RPM). The SHP's qualifications for RPM were reviewe The designated RPM appears to meet or exceed the ANSI /ANS 3.1-1978 quali-fications required by Technical Specification 6.3.1. There remains one level of management between the RPM and the Plant Manager; no problems with the RPM's access to the Plant Manager were noted. Except for career path promotions, the staff remains stabl No violations or deviations were identifie . Planning and Preparation The inspectors reviewed the outage planning and preparation performed by the licensee, including: additional staffing, special training, increased equipment and supplies, and job related health physics consideration The licensee's radiation protection group was augmented with 50 contracted radiation protection technicians (RPTs). The inspectors selectively verified the contract technicians' qualifications through a review of their resumes. All 50 RPTs are ANSI 3.1-1978 qualified as senior techni-cians. Contract technicians are required to pass all Union Electric qualification card requirement Special pre-outage training provided to station and contract workers include pre-job ALARA briefings for each work group, and RWP program trainin No problems were noted in this are The supply of portable survey instruments, portable ventilation equipment, protective clothing, and respiratory protection equipment appears adequate for the outag Radiation protection is represented at, and participates in, all planning and outage meeting No problems were note The licensee has designed and installed lead shielding under the reactor head, while it was in its stored position, to reduce radiation from the inside of the reactor head while reactor head gaskets were replaced. The shielding reduced radiation levels from the reactor head by about a factor of 10 (3-4 R/hr down to 300-400 mR/hr).

An inspector observed part of the installation of the reactor head gasket Workers appeared to follow procedures and used good health physics practice No problems were note In an effort to reduce radioactive waste, the licensee is limiting the amount of disposable materials that are brought into the radiation controlled area (RCA).

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7. Training and Qualifications of New Personnel The inspectors reviewed the education and training qualifications of new plant and contractor radiation protection and chemistry personnel, and training provided to them. Also reviewed was radiation protection training provided to other contractor personne Selection of contracted radiation protection technicians includes a review of the technicians' resumes, an entrance examination, and a personal interview if the examination grade is marginal. After selection, the contract technicians are given three days of training including 18-20 hours of classroom instruction on general rad worker training, Union Electric radiation protection procedures, radiation work permit usage, detector theory, shielding calculations, and about 1/2 day of practical health physics evaluations. A 50 question examination is given; a passing grade of 70 percent is require The examination is followed by individual interviews with foremen on qualification card questions. In addition, radiation protection staff members interview groups of 3 or 4 technicians to assess their qualifications, training records, resumes, and course outlines. Examination results were selectively reviewe No problems were note The inspectors selectively reviewed contractor personnel training record It appears that contractors have received training commensurate with their

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job requirements. An inspector attended portions of contractor general employee rad worker training. The classroom was of adequate size and well equipped. The class size was small which allowed for individual attentio In general, the presentation was of good quality and students participate No problems were note The licensee has started an apprenticeship program which will enable

, licensee personnel to becone qualified as Assistant Radiation-Chemical Technicians. Completion of the 36 month, 6000 training-hour apprenticeship program will result in promotion of the employee to an Assistant Radiation-Chemical Technician classification in health physics, radwaste, or chemistry. Currently, two Plant Helpers are enrolled in each of the three apprenticeship classification programs. This training should prove very useful to those receiving it and also augment the licensee's radiation protection staf No violations or deviations were identifie . Audits and Appraisals The inspectors reviewed reports of audits and appraisals conducted for or by the licensee including audits required by the technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse . .

A station Quality Assurance (QA) audit of Radiation Protection was conducted October 21-29, 198 Areas audited included respiratory protection, use of RWPs, and compliance with Technical Specificatio .2.2c and 6.12. The audit identified two concerns, both in the area of computer software. The licensee appears to be responsive to these Concern The first station QA audit of Radwaste was conducted July 15-19, 198 Areas audited included radwaste solidification, determination of curie content of waste containers, storage of radwaste, radwaste personnel training, gaseous radwaste, drumming operations, radwaste night orders and standing orders, radwaste trending, and technical specification requirement No problems were note No violations or deviations were identifie . External Exposure Control The inspectors reviewed the licensee's external exposure control and personal. dosimetry programs, including: changes in program to meet outage needs; use of dosimetry; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification Exposure records of plant and contractor personnel for 1985 and 1986 to date were selectively reviewed. No exposures greater than 10 CFR 20.101 or administrative limits were noted. Total exposure for 1985 was about 36 person-rems. The total exposure for 1986 through March 19, 1986, which includes 19 days of the outage, is about 116 person-rem An inspector selectively reviewed current RWPs on file at Access Control for compl 'aness, approval, ALARA review, and survey data. Current radiation and contamination survey maps are displayed in a catalog type display file on the desk in Access Control and are available for referenc Survey records are reviewed by a foreman. No problems were note Posting and labeling in the radiation controlled area (RCA) were observed during plant tour No problem areas were note Housekeeping appeared to be goo No violations or deviations were identifie . Internal Exposure Control The inspectors reviewed the licensee's internal exposure control and assessment programs, including: changes to procedures affecting internal exposure control and personal exposure assessment; determination whether engineering controls, respiratory equipment, and assessment of individual intakes meet regulatory requirements; planning and preparation for maintenance and refueling tasks including ALARA considerations; and required records, reports, and notification _ _ _ _ . _ _ _ _ - _ _ _ _ . _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - _ _ - - _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _

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Whole body counting data, respiratory protection records, and air sample data for 1985 and 1986 to date were selectively reviewed. No problems were note An inspector toured the respirator issue facility located at Access Control. The facility appeared to be adequately equipped and supplied to accommodate respirator users. A "Respro" book in the facility lists employees and contractors by name and date of their medical evalua-

' tion, mask fit test, and training. A worker's data must be current before a respirator will be issue The licensee is using a vendor supplied respirator cleaning facilit Equipment for a permanent facility has been purchased; however, a location for this facility has not been designate During a plant tour, an inspector noted auxiliary filtering ventilation systems in use in the pressurizer enclosure during valve repair, and in the steam generators during eddy current testin No problems were note No violations or deviations were identifie . Control of Radioactive Materials and Contamination The inspectors reviewed the licensee's program for control of radioactive materials and contamination, including: adequacy of supply, maintenance, and calibration of contamination survey and monitoring equipment; effec-tiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methods of control of radioactive and contaminated material Inspector observations at access control points indicate that workers are properly using step-off pads and following frisking and portal monitor procedure No problems were note The licensee has essentially completed the program for sealing of concrete surfaces in the plant. The inspectors observed several newly painted areas; no problems were note The licensee records and trends personal and clothing contamination event There were 70 such events recorded in 1985, and 66 recorded to date in 1986. The inspectors selectively reviewed records of personal contamina-tion events for 1985 and 1986. Records reviewed did not indicate the presence of significant contamination levels or poor work practice No violations or deviations were identified.

t 12. Maintaining Occupational Exposures ALARA The inspectors reviewed the licensee's program for maintaining occupational exposure ALARA, including: changes in ALARA policy and procedures; ALARA considerations for maintenance and refueling outage; worker awareness and involvement in the ALARA program; establishment of goals and objectives, and effectiveness in meeting them. Also reviewed was management techniques used to implement the program and experience concerning self-identification ,

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The licensee established ALARA goals for 1985, including overall station goals for total dose and contaminated areas, and individual working group goals for total dose. The licensee's station goal for total dose in 1985 was originally 160 person-rems; as the licensee gained operating experi-ence, the goal _was gredually reduced to 50 person-rems. The estimated total dose for'1985 was 36 person-rems, due in part to an apparently effective ALARA program and to relatively low dose rates during the first full year of operation. The 1986 total dose goals of 450, 350, and 250 person rems have been designated by the licensee as " acceptable,"

" commendable," and " excellent," respectivel In addition to the exposure goals outlined above, it is a station goal that no individual receive more than 5 rems during 198 This goal was met in 1985 and to date in 198 The station's ALARA program includes provisions for dose reduction by minimizing contaminated areas. The licensee's goal for 1985 was to keep the total contaminated areas of the auxiliary, radwaste, and fuel buildings below 10,000 square feet. This 1985 goal was met; however, the trend has been upwards since June of 1985. Partly because of this upward trend, the 1985 goal was increased to 12,500 square feet. Because both the contami-nated area trend and goal increase appear contrary to good radiation protection practices, the inspectors reviewed station documentation and interviewed licensee personnel in an attempt to ascertain the root cause of the increase in contaminated areas. The increase appears partly due to a chronic lack of adequate maintenance and repair of minor contaminated system leaks, and a somewhat understaffed and inexperienced decontamination staf The minor leaks from pipe fittir.gs and valves in potentially radioactive systems, and their negative effect on the health physics staff's ability to maintain the amount of plant contaminated areas ALARA, were discussed with the licensee during a previous inspection (50-483/

85006). Upon review, the inspectors noted that the backlog of leak repair work requests has continued to increase during the past year. The licensee plans to implement a Decontamination Request Form program in the near future which should facilitate obtaining proper priority for future leak i repair work orders. The decontamination staff is discussed in the next paragraph. The reduction of contamination areas is highly desirable and should be vigorously supported by managemen The Radwaste Superintendent is responsible for general housekeeping and decontamination in Radiologically Controlled Areas (RCAs). During plant operation, one foreman is assigned full time (day shift) to these activities; he may draw from a work force of 20 helpers. The training and qualifications of the helpers is described in Inspection Report No. 50-483/8501 The number of helpers has been reduced to 20 from 26; more than half of the current helpers were recently hired. The increase in contaminated areas appears to be due, in part, to a relatively inexperienced and understaffed decontamination staff. During the outage, the regular decontamination staff was augmented by 40 additional contracted workers who, together with the house staff, provided around the clock coverage with 20 helpers and decontamination technicians on each shift to operate the respirator cleaning and laundry facilities, collect and sort radioactive waste, frisk and decontaminate tools, maintain general house-

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keeping, and decontaminate equipment and floors. Each shift crew is divided into four work groups that are supervised by foremen. These fore-men are supervised by a Ra maste Outage Foreman 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> per da The licensee is consicering increasing the number of contracted workers in the above areas to 60 for the next refueling outage due, in part, to the noted increase in contaminated areas which has occurred during this outag The station's ALARA program also established 1985 goals for solid waste generation, gaseous effluents released, liquid effluents released, airborne contamination area, and personnel contamination incidents. Upon review, the inspectors found that the goals appeared reasonable and were met. The 1986 goals were modified to reflect the licensee's 1985 experience; all of the revised goals appear reasonable with the possible exception of personnel contamination incidents, which increased from 80 in 1985 to 150 in 198 The inspectors reviewed the ALARA organization, the qualification and experience of its members, and the effectiveness of the organization in instituting dose savings programs during outages. The outage ALARA staff consists of five health physics foremer each shift, of which one is an RWP coordinator and ALARA reviewer. The ALARA reviewer's duties include attending all pre-job planning meetings, conducting pre-job ALARA brief-ings, reviewing daily RWP dose and man-hour reports, preparing job history files, reviewing completed ALARA suggestion forms, attending post-job ALARA review meetings, and maintaining ALARA record The AL. ARA oversight of work-in progress is mainly the concern of the other health physics shif t foremen. The outage ALARA staff provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage under the direction of the chairman of the Plant ALARA Committee (PAC), who is also the Health Physics Operations Supervisor. In addition to the chairman, the PAC consists of 11 members, one from each plant major disciplinary are The PAC meets at least quarterly to set ALARA goals, evaluate the effectiveness of the ALARA program, resolve ALARA concerns, respond to completed ALARA suggestion forms, review job history files, and implement the lessons learned from each task performed to develop dose saving techniques for future jobs. The ALARA staff members appear to have the proper qualifications, experience, expertise, and dedication to establish and maintain an effective ALARA progra The location of the ALARA group in the station organization, consideration of ALARA principles by other station groups and departments and their working relationship with the ALARA group, management involvement, and the types and number of workers assigned to meet ALARA goals also seem conducive to the establishment of an effective ALARA program. The ALARA staff is compiling what appears to be extensive, thorough, and comprehensive job history files. These files contain all relevant pre-job planning and preparation work records and post-job review records (which discuss dose savings lessons learned). The proper use of these files in pre-job planning and preparation should result in an overall reduction in personnel exposure for future similar task No violations or deviations were identifie . .

k 1 Facilities and Equipment The inspectors toured radiation protection facilities, observed radiation protection equipment in use, and discussed plans for improving access control facilities and equipment with the health physics staf Newly acquired facilities and procured equipment which should enhance the radiation protection program include: (1) three new PCM-1A portal moni-tors, which increases the total to seven; (2) two drycleaning units are expected to be purchased in the near future; (3) a Freon tool cleaning unit; (4) a second whole body counter for use in the central processing facility; (5) the health physics, chemistry, and radwaste some staff offices have been relucated from temporary onsite trailers to the renovated startup building; (6) new, more effective microphones and headsets, which may be used in boom, throat, or respirator mike modes, have replaced less effective throat microphones and headsets (these may significantly reduce dose by cutting stay times and number of personnel in high radiation tasks areas).

1 Radiological Work Routine Violations (RWRV)

There were 23 RWRVs in 1985 and 11 in 1986 to date. The inspectors selectively reviewed RWRV reports for 1985 and 1986. No significant problem areas were noted and no disciplinary action was taken by the license No violations or deviations were identifie . IE Information Notice No. 85-81 The inspectors reviewed licensee action taken in response to IE Information Notice No. 85-81, " Problems Resulting in Erroneously High Readings with Panasonic 800 Series Thermoluminescent Dosimeters (TLDs)." The licensee has purchased and is using this type of TLD. Approximately 1000 suspect lead filters were replaced by Panasonic in 198 The abnormal response of TLDs to such agents as chemical contaminants, ultraviolet light, and humidity is well known by the license Procedures require investigation of abnormal or unusual responses, as appropriat . Main Steam PORV Plume Radiation Monitors During the review of the post-accident noble gas effluent monitoring system for the main steam safety relief valves / power operated relief valve (PORV) pathway, the inspectors noted that the technical adequacy of the licensee's installed radiation monitors was questionabl The radiation monitors are located on the auxiliary building roof and oriented, shielded, and collimated to detect the plume from the PORV If the PORVs are blocked, the radiation monitors appear incapable of responding to post-accident main steam release via the safety relief valves. The PORV are not code safety valves and are presently not governed by the technical specifications; thus, the licensee may operate the plant with blocked PORVs without restriction. Also, in accident circumstances the licensee may elect to block leaky PORVs to prevent the release of radioactive effluents and/or the loss of secondary system

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coolant. The licensee is reviewing the technical adequacy of these radiation monitors as part of their internal commitment and compliance analysis report regarding NUREG-0737, Item II.F.1, Attachment 1, (0 pen Item No. 483/85006-04). The inspector informed the licensee that the acceptable location for externally mounted monitors specified by NUREG-0737 is on the main steam line upsteam of the safety valves and PORV and that NRR is presently evaluating a similar technical issue at the D. C. Cook Nuclear Power Plant (Inspection Reports No. 50-315/85011; 50-316/85011, Unresolved Item No. 315/85011-05; 316/85011-04). Inspector concerns with the present locations were discussed during the exit meeting and the licensee was informed that concurrence on the acceptability of the monitor locations must be obtained by the licensee from NRR. Pending resolution of this issue by NRR, this matter is considered an unresolved item (483/86004-01).

17. Technical Specifications 3.3.3.6 and 4.3. During the review of the licensee's commitments to NUREG-0737, Item II.F.1, Attachment 1, the inspectors noted that the installed post-accident noble gas effluent radiation monitors were apparently those described in Appendix 7A and Subsection 18.2.12.2 of the FSA The post-accident noble gas effluent radiation monitors identified in the FSAR are used to monitor effluents from the plant unit vent, the radwaste building, the main steam PORVs, and steam discharge from the turbine-driven auxiliary feedwater pump. Generic Letter 83-37, "PWR NUREG-0737 Technical Specification," dated November 1, 1983, specifies that all of the licensee identified post-accident noble gas effluent radiation monitors should be included in the accident monitoring technical specifications; however, Callaway Technical Specifications 3.3.3.6,

'% cident Monitoring Instrumentation Limiting Condition for Operation,"

and 4.2 3.6, " Accident Monitoring Instrumentation Surveillance Requirements," include only the plant unit vent high range noble gas monitor. Inspector concerns with the present technical specifications were discussed during the exit meeting and the licensee was informed that concurrence on the acceptability of Technical Specifications 3.3. and 4.3.3.6 must be obtained from NRR. Pending resolution of this issue by NRR, this matter is considered an unresolved item (483/86004-02).

18. Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on March 21, 198 The inspectors summarized the scope and results of the inspection and discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents / processes as proprietar