IR 05000483/1986011

Insp Rept 50-483/86-11 on 860825-0905.Violations Noted: Failure to Maintain Containment Purge Valves in Required Closed Position & Failure to Perform Needed Evaluations of Radiation Hazards Present

ML20206T577
Person / Time
Site:	Callaway
Issue date:	09/24/1986
From:	Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206T568	List: IR 05000483/1986011 ML20206T565 ML20206T571
References
50-483-86-11, IEIN-86-022, IEIN-86-22, NUDOCS 8610070060
Download: ML20206T577 (13)

Text

-

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/86011(DRSS)

Docket No.-50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 St. Louis, M0 63166 Facility Name: Callaway County Nuclear Station Inspection At: Callaway Site, Callaway County, M0 Inspection Conducted: August 25 through September 5, 1986 Inspector: . . Gil fd/-80 Date Accompanying Inspector: W. J. Slawinski Approved By: L hief f"2Y A Facilities Radiation Protection Date Section Inspection Summary Inspection on August 25 through September 5, 1986 (Report No. 50-483/86011(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection and radwaste programs, including: solid radwaste, liquid radwaste, gaseous radwaste, transportation activities, organization and management controls, effluent reports, audits and appraisals, and control of radioactive materials and contamination. Also certain Licensee Events Reports, radiological work practice violations, an internal exposure incident, open items, and licensee response to IE Information Notice No. 86-22 were reviewe Results: Two violations were identified (failure to maintain the containment purge valves in the required closed position - Section 15, and failure to perform needed evaluations of radiation hazards present - Section 16).

8610070060 86092S 3 PDR ADOCK 0500

-

-

.

DETAILS 1. Persons Contacted

• J. Cassmeyer, Assistant QA Engineer J. Cruickshank, Radwaste Foreman

• R. Farnam, Rad / Chem Foreman

• J. Gearhart, QA Operations Support Superintendent

1. • C. Graham, HP Technical Support Supervisor S. Growcock, QA Scientist G. Hamilton, Radwaste Engineer B. Holderness, Health Physicist

• J. Laux, QA Technical Support Superintendent

• J. Little, Assistant QA Engineer

1. J. Polchow, Health Physics Operations Supervisor

• G. Randolph, Plant Manager

• J. Ridgel, Radwaste Superintendent

• R. Roselius, Health Physics Superintendent D. Schafer, Supervising Engineer, Licensing

• V. Shanks, Chemistry Superintendent N. Slaten, Supervising Engineer, Nuclear

• C. Brown, NRC Resident Inspector 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 meeting on August 28, 1986.

1. Denotes subsequent telephone conversations between September 2-5, 1986, 2. General This inspection, which began at 2:00 p.m. on August 25, 1986, was conducted to review the operational radiation protection and radwaste programs, including solid radwaste, liquid radwaste, gaseous radwaste, transportation activities, organization and management controls, effluent reports, audits and appraisals, and control of radioactive materials and contaminatio Also, certain Licensee Event Reports, radiological work practice violations, an internal exposure incident, open items, and licensee response to IE Information Notice No. 86-22 were reviewed. The inspectors conducted radiation and contamination surveys of selected plant areas using NRC and licensee survey instruments (Xetex 305-B and Ludlum 177); readings were in general agreement with posted licensee data. Area postings, access controls, and housekeeping were excellent. The inspectors' concerns regarding the increasing contamination of the floor areas in the auxiliary, fuel, and radwaste buildings are discussed in Section 12.

l

,

- , . _ ,- - - - , - - - - - --e - . . - - . , , - , , - - ,

-

.

3. Licensee Actions on Previously Inspection Findings (Closed) Open Item (483/84035-02): Procedurally control filter housing deluge systems to preclude flooding of adjacent ducting and overloading of the liquid radwaste system. The licensee has revised the fire pre plans to warn against overfilling the filter housing with water and to contain sufficient directions concerning the timely draining of the water to nearby floor drains. During a plant tour, the inspectors verified that appropriate hoses and fittings are stored near filter housings which contain fire protection deluge systems. Administrative Procedure APA-ZZ-00170, " Radioactive Waste Management Program," has been revised to add the requirement that the Radwaste Group be notified prior to draining 200 gallons or more into the liquid radwaste system; licensee representatives stated'that this provision would preclude radsaste system overload due to deluge system operation. This matter is considered close (0 pen) Open Item (483/85006-04): Prepare documents which identify the required compliance activities for NUREG-0737, Items II.B.3 and II. (Attachments 1, 2, and 3). As of August 25, 1986, the licensee reported completion 20 of 30 action items needed to demonstrate compliance with their commitments to the previously listed NUREG-0737 items. By September 15, 1986, the licensee expects to have six more action items completed. The remaining four action items have not been assigned definite completion dates. The licensee issued Revision 1 of the Compliance Action Report on August 27, 1986; Revision 1 of the Compliance Review Report is scheduled to be issued by October 30, 1986. This matter will be reviewed further during a future inspectio . Organization and Management Controls The inspectors reviewed the licensee's radiation protection organization and management controls for the radiation protection program, including changes in the organizational structure and staffing, effectiveness of procedures and other management techniques used to implement the program, experience concerning self-identification and correction of program implementation weaknesses, and effectiveness of audits of the progra All health physics staff positions are fille The average employment history at Callaway for health physics technicians and foremen is three and five years, respectively. It is the licensee's policy that newly l

hired technicians have at least three years relevant experience before employment at Callaway. In general, except for career path promotions, the staff remains very stable.

No violations or deviations were identifie . Gaseous Radioactive Waste The inspectors reviewed the licensee's gaseous radwaste management program, including changes in equipment and procedures; gaseous radioactive waste effluents for compliance with regulatory requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; and experience concerning identification and correction of programmatic weaknesse __ . _ _ _ .

-

..

.

Sampling and release methods and procedures, records, and reports appear

. adequate. The inspectors selectively reviewed records of gaseous releases made from January 1, 1985 through June 30, 1986. There were 74 and 78. gaseous radioactive waste batch releases during 1985 and the first six months of 1986, respectively. The 1985 gamma and beta air dose totals were .1% and .2% of the technical specification dose limits, respectively. The total gaseous releases of noble gases, radiciodine, and tritium for 1985 were 1.7 E+3, 3.1 E-4, and 5.1 Curies, respectivel No violations or deviations were identifie . Liquid Radioactive Waste The inspectors reviewed the licensee's liquid radwaste management program, including changes in equipment and procedures; liquid radioactive waste effluents for compliance with regulatory' requirements; adequacy of required records, reports, and notifications; process and effluent monitors for compliance with maintenance, calibration, and operational requirements; reactor coolant chemistry; and experience concerning identification and correction of programmatic weaknesse Sampling and release methods and procedures, records, and reports appear adequat The inspectors selectively reviewed records of liquid releases made from January 1, 1985 through June 30, 198 There were 597 and 148 liquid radioactive waste batch releases during 1985 and the first six months of 1986, respectively. The 1985 whole body and maximum organ dose totals were 1.8% and 0.66% of the technical specifications dose limits, respectively. The total liquid tritium release for 1985 was 5.9 E+2 Curie On February 8, 1985, an unplanned release occurred from Secondary Liquid Waste Monitor Tank B (THF04B) which resulted in the discharge of 170 gallons of waste water without an efflLent release permi Effluent release permit CAL-85-L109 had been generated for the dise:harge of Liquid Waste Monitor Tank B (THB078); however, due to personnel trror, release of Secondary Liquid Waste Monitor Tank B was initiated instead of Liquid Waste Monitor Tank B. This condition was recognized by personnel in the Control Room and the release was immediately terminated. No technical specificationsz or 10 CFR 20 limits were exceeded as a result of this release. Corrective action was taken to prevent recurrenc Several modifications to the liquid radwaste treatment system have been completed. Two 100,000 gallon batch waste release tanks were added to the system in June 1985. These tanks were needed due to an increase in the volume of secondary liquid waste (SLW), especially waste from condensate demineralizer (polisher) regenerations. The technical specifications were revised to allow the addition of these tanks. Partially because of the increase in the volume of SLW, the SLW CUNO filters will be replaced by recently ordered backflushable filters; this modification is expected to reduce the amount of generated solid radwaste by 100 drums per year. The licensee has also added a local liquid sampling station to the liquid radwaste process system specifically for analysis of highly contaminated resins. This modification not only increases the effectiveness of the radwaste treatment system, it is also an example of the licensee's conscientious ALARA progra No violations or deviations were identifie . .. ._ -- - - . _ -

-

.

,

, , Solid Radwaste

. The inspectors reviewed the licensee's solid radwaste management program,

. including changes to equipment and procedures; processing, control, and storage of' solid wastes; adequacy of required records, reports, and t notifications; implementation of procedures to properly classify and characterize waste, prepare manifests, and mark packages;.and experience concerning identification and correction of programmatic weaknesses.

i 1- Partially due to operational difficulties with the installed radwaste processing system, the licensee contracted with NUS Process Services Corporation (NUSPSC) to process a backlog of spent resins and evaporator-bottoms. The vendor has completed the assigned tasks; the resultant ten liners are awaiting shipment to a burial site. The licensee expects to ship two liners on each of five flat-bed trucks; shipments.are expected

, to be completed by the end of 1986. In April and May 1986, the licensee performed a special QA audit of the Union Electric Nuclear Operations (UENO) radwaste program and NUSPSC to verify control of vendor and contractor activities, the NUSPSC Process Control Program (PCP), and process equipment operation. This audit concluded that the UENO Radwaste and NUSPSC program and procedural requirements are effectively implemented; however, the QA auditors identified four problems with equipment operatio The inspectors reviewed the audit report and interviewed QA auditors and the Radwaste Superintendent concerning the audit findings and the resultant

corrective actions; no significant problems were note g -The annual QA Radwaste Audit was performed by the licensee from July 28

to August 6, 1986, to assess operation of radwaste systems, storage of radioactive waste, shipment of radioactive materials, Curie content

' determination, and technical specifications. Problems identified by the audit included: six failures to follow procedures; three problems

associated with numbering, inspecting, and maintaining storage logs; and the lack of independent verification of the isolation and restoration of Group D Augmented systems. The inspectors reviewed the audit report and interviewed QA auditors and the Radwaste Superintendent concerning

~

I the audit findings and the proposed corrective actions; no significant i

problems were noted.

l l The inspectors reviewed selected portions of the licensee's solid radwaste

processing, storage, and shipping records for the period January 1, 1985 through July 31, 1986. It was noted that a significant portion of the j generated radwaste was due to Secondary Liquid Waste (SLW) CUNO filter j change out, light Dry Active Waste (DAW) drums, spent resins, and

'

evaporator bottoms. The licensee plans to reduce the volume of radwaste from all four of the sources. As discussed in Section 6, the replacement of the SLW CUNO filters by recently purchased backflushable filters is expected to reduce the generated solid radwaste by 100 drums per yea The licensee has recently ordered a number of 52 gallon drums for DAW storage and plans to contact vendors offering special super-compaction

!

i i

I

i

. - - . . - - . - - - . - - _ - - . - _ _ . - - .

-

.

services. By the use of a proper vendor super-compactor, two 52-gallon drums of DAW may be compressed into a single 55-gallon drum. This technique, coupled with a conscientious program to reduce DAW generation, is expected to reduce DAW volume by a factor of tw The licensee recently was granted an amended permit by the Missouri Department of Natural Resources which increased the allowable boron concentration in waste streams by a factor of ten. According to licensee representatives, this permit would allow less frequent resin regenerations and an approximate reduction factor for spent resin radwaste of four. The licensee has begun a conscientious program to keep non-contaminated water from being routed inadvertently to the radwaste processing system. Licensee representatives informed the inspectors of several examples including the valving arrangement and procedural modification which precludes the routine draining of the fuel transfer canal water (30,000 gallons) to the radwaste processing system. As mentioned in Section 3, Administrative Procedure APA-ZZ-0017 has been revised to add the requirement that the Radwaste Group be notified prior to draining 200 gallons or more into the liquid radwaste syste The licensee presently has approximately 450 drum equivalents (55-gallons)

of solid radwaste in storage. Approximately 250 drum equivalents are the ten liners of spent resins and evaporator bottoms discussed abov t3ecause of the presence of these liners, storage volume is at a record level; the liners are presently stored in the truck loading bay which has been designated as a high radiation area. The approximately 200 55-gallon drums of radwaste are in the solid radwaste storage area which is reportedly designed to hold 1950 55-gallon drums. The 1986 goals for packaged solid radioactive waste are 7500, 10,000 and 12,000 cubic feet for excellent, commendable, and acceptable, respectivel Approximately 6000 cubic feet of solid radwaste has been generated to date in 1986; approximately 4000 cubic feet of that was generated during the outage and due to backlog packaging by NUSPSC. The licensee expects to meet the 7500 cubic foot goal for 1986 and to generate even less solid radwaste next yea No violations or deviations were identifie . Process Control Program Revision 3 to the Callaway Process Control Program (PCP) was issued March 1, 1985. This revision incorporated revised formulations for the solidification of concentrated wastes (borated), revision to the boric acid binding agent (sodium metasilicate) addition chart, and incorporation of a new solidification formulation chart for non-borated concentrated wastes. Revision 4 (August 2, 1985) to the PCP incorporated a revised formulation for the solidification of spent resin having a resulting waste classification of Class "A" to be shipped as " UNSTABLE" waste. Licensee representatives stated that the formulation was developed by in-plant testing, both lab scale and full scale, to achieve a high waste loading while still meeting all applicable requirements for disposa __

-

.

Revision 5 (March 1986) to the PCP provided for incorporation of vendor supplied updated solidification formulation nomograms, and incorporated text changes and cove'rsheet changes denoting that formulations contained within the document are considered proprietary. Additionally, a section within the document dealing with specifications for solidifications agents was removed as this information is addressed in purchase specifications for this material. Revision 6 (April 29, 1986) to the PCP was made to incorporate programmatic control for use of vendor services for the packaging of solid radioactive wast The purpose of these controls is to provide assurance that vendor activities related to the packaging and documentation of solid radioactive waste processing are performed in a manner consistent with plant technical specification Vendor PCP's were reviewed and approved by the Onsite Review Committee prior to implementatio The inspectors reviewed Revision 6 to the PCP. The above delineated revisions to the Process Control Program do not appear to change the overall conformance of the program to the requirements governing its intended us No violations or deviations were identifie . Transportation Activities The inspectors reviewed the licensee's transportation of radioactive materials program, including determination whether written implementing procedures are adequate, maintained current, properly approved, and acceptably implemented; determination whether shipments are in compliance '

with NRC and DOT regulations and the licensee's quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notifications; and experience concerning identification and correction of programmatic weaknesse The inspectors selectively reviewed portions of the solid radwaste shipment records for 1985 and to date in 1986. The information on the shipping papers appears to satisfy NRC, DOT, and burial site requirement The licensee had ten shipments in 1985 and seven shipments to date in 1986 consisting of 4896 and 3684 cubic feet, respectively. As discussed in Section 7, the low volume of radwaste shipments appears, in part, to be due to the licensee's conscientious efforts to minimize solid radwaste volume by judicious use of radwaste process equipment, waste segregation, and dry active waste (DAW) compaction.

! No violations or deviations were identifie . Effluent Reports l The inspectors selectively reviewed radiological effluent analysis results to determine accuracy of data reported in the Semiannual

.

Radiological Effluent Release Report for 1985 and the first half I

of 1986. Technical Specification 6.9.1.7 states that the format l

and content of this report shall be in accordance with Regulatory

'

Guide 1.21 (Revision 1) dated June 1974. No significant discrepancies from this regulatory guide were identifie _ - , . .-

.-

__

-

.

In April 1984, a consultant. verified the validity of the computer program which uses plant monitoring data and the dose calculation methods in the Offsite Dose Calculation Manual (0DCM) to compute offsite doses. The licensee also reverified the computer program validity by completing hand checks of the offsite dose results reported in their first Semiannual Radioactive Effluent Release Report (October through December, 1984).

Revision 3 to the ODCM was approved for use on July 3, 198 Changes incorporated into revision 3 include:

• Cleanup of typographical errors previously identified by an errata transmitted by letter, ULNRC-803, dated April 17, 1984 from Mr. Donald F. Schnell, Vice President Nuclear, Union Electric Company to Mr. Harold R. Denton, Director, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commissio * Incorporation of changes resulting from the 1984 Land Use Censu * Incorporation of changes to environmental monitoring station locations previously described in the above referenced lette During a Union Electric QA audit of the Radiological Protection Program, conducted in June 1986, independent calculations by UEQA verified that off-site dose and dose rate contributions from liquid and gaseous effluents are determined in accordance with the methodology and parameters in the ODC 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 technical specification Also reviewed were management techniques used to implement the audit program, and experience concerning identification and correction of programmatic weaknesse The inspectors selectively reviewed portions of UEQA audit and surveillance reports for 1985 and to date in 1986 and the audit and surveillance schedule for the remainder of 1986. The licensee's Quality Assurance (QA) audit program appears adequate to assess technical performance, compliance, and personnel qualification and training in the areas of radiation protection, plant chemistry, radwaste, and transportation. The QA auditors in these technical areas seem to be well qualified and to have developed adequate surveillance plans to ensure personnel are well qualified and trained and that procedures are adequate and correctly implemente The inspectors also reviewed the radiation protection findings of the 1985 and 1986 INP0 audits and discussed the corrective action responses to INPO and UEQA audits and UEQA surveillance reports with the Health Physics Superintendent. In general, the responses to audit findings appear thorough, timely, and technically soun No violations or deviations were identifie . . . , _ _ - _ _ , _ _ -

. - - .- - - - .. -

.

A 12. 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; effectiveness of survey methods, practices, equipment, and procedures; adequacy of review and dissemination of survey data; and effectiveness of methodt, 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 procedures. No problems were noted.

l The _ inspectors made independent surveys to confinn postings and to verify that the licensee has an effective program for the control of' radioactive

and contaminated material Posting of contaminated, radiation, high radiation, and very high radiation areas appear appropriate. Surveys for

'

'

contaminated material outside designated contaminated areas were conducted inside and around the outside periphery of the auxiliary, radwaste, and fuel buildings; no problems were note Floor area contamination in the auxiliary, fuel, and radwaste buildings has increased from 10,000 square feet in January 1986 to 14,000 cubic feet in July 198 It appears highly desirable for the licensee to

'

. maintain contaminated areas within. the goal of 12,500 cubic feet because

,

the recent increase in reactor coolant specific activity, due to leaky fuel . elements, will tend to increase the contamination levels resulting i

from future process system component leakages.

,

There were approximately 100 personnel contamination events at Callaway

'

in the first half of 1986. The licensee defines these events when a worker's skin or clothing has detectable contamination as indicated by'a hand-held frisker, excluding radon contamination. When compared to data 4 from other commercial nuclear power plants,-the frequency of personnel

contamination at Callaway is not atypical. The licensee still has

! moderately frequent portal monitor alarms due to radon daughter product l

. contamination of workers' polyester clothing. There have been approximately 200 of these events to date in 1986. The licensee has I

significantly reduced the number of these incidents by correcting .

ventilation system problems and selectively coating initially unpainted

, concrete walls; however, the use of a spray static eliminator has been l abandoned as ineffective.

l

'

No violations or deviations were identified, i

,

13. Radiological Work Practice Violations (RWPV)

l i There were 23 RWPVs in 1985 and 30 to date in 1986. The inspectors

!

selectively reviewed RWPV reports for 1986. No significant problem l

areas were noted.

l No violations or deviations were identified.

l l

I 9 l

. -- - - . -. _ -.- - - _ - - _ . - - .

-

.

'1 IE Information Notice No. 86-22 The inspectors reviewed licensee action taken in response to IE Information Notice No. 86-22, "Underresponse of Radiation Survey Instrument to High Radiation Fields." The licensee does not presently use,~ nor are there plans to purchase in the near future, the Eberline Model ESP-1 survey meter referenced in the notic . Licensee Event Report Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, and immediate corrective-action and corrective action to prevent recurrence had been accomplishe (0 pen) LER 86-016-00: Containment Atmosphere Rad Monitor Inoperable During Containment Purge. During a containment purge on May 21, 1986, containment atmosphere gaseous radioactivity monitors GT-RE-31 and GT-RE-32 were sequentially placed in bypass at 0905 CDT and 0938 CDT, respectively. This resulted in a condition prohibited by the Technical Specification 3.3.3.1 which requires the containment purge valves to be maintained closed with either of the monitors inoperable. Each monitor

.was rendered inoperable for approximately ten minute The monitors were placed in bypass prior to replacing filters to prevent spurious Engineered Safety Features Actuations which had previously been experience Operations personnel apparently failed to recognize the need to secure the purge prior to placing the monitors in bypas Actions to prevent recurrence include progressive discipline for the '

involved personnel, encumbering devices and procedural controls for the bypass switches,- deletion of the requirement to bypass the monitors during filter change-outs, and consideration of a change to the appropriate technical specification A similar event had previously occurred on April 16, 1986, and was the subject of Callaway Plant LER 86-012-00 dated May 16, 1986. As stated in LER 86-012-00, health physics and operations personnel had been instructed to bypass the Engineered Safety Features Actuation System (ESFAS) trip bistables for various radiation monitors during filter replacements due to spurious ESFAS actuations previously experience Similar to the April 16, 1986 event, the event on May 21, 1986, apparently occurred because the operators failed to recognize the need to secure the purge prior to placing the monitors in bypas The corrective action taken as a result of the April 16, 1986 event was the issuance of an Operations Department Night Order to emphasize the necessity to verify compliance with T/S Action Statements prior to placing the radiation monitors in bypass. Also, progressive discipline was initiated with the involved operations personnel. This corrective action was apparently not adequate to prevent recurrence on May 21, 198 It was also noted by the inspectors that a similar event occurred on February 26, 1985 and was the subject of Callaway Plant LER 85-013-00 dated March 28, 1985. As stated in LER 85-013-00, due to personnel error

-

.

from inadequate procedural guidance, a mini purge was comenced w'th the containment atmosphere radiation monitors in bypass. Although t' a corrective action taken by the licensee has been adequate to prevent an identical recurrence, they were not adequate to preclude the occurrence and recurrence of bypassing the monitors during purging, as reported in Callaway Plant LERs 86-012-00 and 86-016-00. This matter was discussed at the exit meetin Although this problem was identified by the licensee, the violation which occurred on May 21, 1986, could reasonably be expected to have been prevented if the licensee's corrective action had been adequate following the violations on February 26, 1985 and April 16, 198 Failure to maintain the containment purge valves closed with either of the containment atmosphere gaseous radioactivity monitors inoperable is a violation of Technical Specification 3.3. (483/86011-01)

(Closed)LER 86-020-00: Engineered Safety Features Actuations on Containment Noble Gas Activity. On June 14, 1986, Containment Purge Isolations and Control Room Ventilation Isolations occurred at 0147 CDT

and'1851 CDT. The actuations occurred as a result of noble gas activity in containment due to leakage from a pressurizer level transmitter root valve. The plant was in Mode 1, Power Operation, at 69% power during the actuation at 0147 CDT and at 74% power during the actuation at 1851 CDT. The licensee's corrective actions, including repair of the valve, appear adequat (Closed) LER 86-021-00: Personnel Errors Causes Technical Specification 3.3.3.1 Violation After Rad Monitor Failed. At 1028 CDT on June 17, 1986, Technical Specification on 3.3.3.1, Table 3.3-6, Action 27 was violated when Operations personnel failed to restore operability of Control Room (CR) HVAC radiation monitor, GK-RE-05, or to initiate a CR Ventilation Isolation within one hour after GK-RE-05 alarmed (0928 CDT) on loss of flo The operator acknowledged the alarm at 0934 CDT but did not identify the violation until 1110 CDT, at which time he initiated corrective action GK-RE-05 was restored to operable status at 1121 CDT. The plant was in Pode 1 Power Operation, at 99% power. The licensee corrective actions, including planned design changes and special training, appear adequate to prevent recurrenc One violation was identified by the inspectors.

j 16. Internal Exposure Incident On August 25, 1986, between 0830 CDT and 1010 CDT, several entries

'

were made into the reactor building (containment) at power to look for unidentified leaks. Since an air sample had been collected within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the decision was made by Health Physics (HP) that another air sample would not be collected prior, to entry. Although the licensee did not conduct a formal ALARA review or prepare a special RWP for these entries, a briefing was given to the personnel entering the reactor building by the rad / chem foreman at HP access control. The respiratory protection requirements imposed were full face respirator for entry l

inside the bioshield, self contained breathing apparatus (SCBA) for ,

[ entry into the steam cloud, and no respirators required for entry

!

,

, 11

. . __ _. _

_ . _ _ _

~

s outside the bioshield. These requirements were based on anticipated stay times and the results of air samples collected from the area ,

'

outside the bioshield on August 24, 1986 at 0800 CDT.(2.62 MPC iodine,

.076 MPC particulate, and 46.2 MPC noble. gas) and 1220 CDT (3.36 MPC iodine, .212 MPC particulate, and 49.6 MPC noble gas).

Upon exiting the reactor building, between 0940 CDT and 1010 CDT on August 25, 1986, personnel alarmed the portal monitor. Inspector

review of the personnel / personal clothing decontamination records for these persons indicate that eight had facial contamination which measured from 250 to 200 cpm and two had nasal smear count rates from 300 to 600 cpm measured with a ludlum 177 frisker. The licensee requires individuals to obtain a whole body count (WBC) if the nasal swabs or facial contamination is above 100 and 400 cpm, respectively. All ten

,

of the individuals who entered the reactor building without'SCBAs received the mandatory WBC; four had not worn respirators at least part of the time; six had worn full face respirates. The licensee's WBC data sumary for the individuals ran J, organ burden _(MPOB)ged , 1.2 to 17from MPC-hours, 3.4 to 50 and total percent

.013 to .175maximum rem thyroidperm bsible

dose commitment. The licensee plans to continue the WBC for each individual until the total MP0B for that individual is less than five percent.

'

At 0915 CDT on August 25, 1986, air samples were collected in the reactor building outside the bioshield and sent for analysis. The analysis indicated air concentration of 10.2 MPC iodine,1.74 MPC particulates, and 106 MPC noble gas. At approximately 1100 CDT on August 25, 1986, air samples were collected in the reactor building inside the bioshield and sent for analysis. The analysis indicated air concentrations of 79.2 MPC iodine, 6.77 MPC particulate, and 3110 MPC noble gas. As soon as the concentration levels were known, health physics restricted entry and deferred further work activities in the reactor building until

efforts to mitigate the leak and reduce airborne levels were accomplished.

'

Based on stay times and air sample results, the licensee calculated

possible iodine (I-131 and I-133) uptake for individuals ranging from i

7.4 to 81 MP.C-hours. The calculational methodology was apparently

!- conservative in that WBC measured uptake was lower in all case The increase in airborne concentrations in the reactor building between the last air sample at 1220 CDT on August 24, 1986 and the first entries at 0830 CDT on August 25, 1986 could have been readily predicted by j- health physics personnel based on available data on changing reactor power level and past plant experience with the spiking of reactor coolant

-

specific activity which accompany changing reactor power levels. At 0615 CDT on August 25, 1986, operations commenced a plant shutdown from

,

100% power due to excessive unidentified RCS leakage. At 0705 CDT on August 25, 1986, at approximately 60% power, the reactor was manually scrammed because of difficulty with manual rod control. The inspectors reviewed past plant operational data relating iodine spiking in the RCS

which accompany rapie reactor power changes. From this data, it appears

'

that one would expect the RCS iodine concentration to quickly increase i by an order of magnitude after a rapid decrease in power; a corresponding

increase in the RCS leakage steam cloud would rapidly spread to increase reactor building airborne concentrations.

'

,

- ym,. , . - , , . ,,r,y , ,,.y,m,..., ..._,m ..,y....m..,,.,,,.y,. . -,.w._,,- -

_ , - . . _ _ _ . , -. _ % ,. _. , , . y *

.

Health physics personnel should have anticipated the increase in reactor building airborne concentrations and ordered special air samples to be taken and analyzed prior to first entries, which were made at 0830 CDT on August 25, 1986, or taken other actions commensurate with entries made during periods of significantly high, yet unknown, airborne concentration levels. The inspector and the Senior Resident Inspector discussed numerous concerns with plant managers regarding several administrative / procedural controls and practices demonstrated during this event. This matter was discussed at the exit meetin Failure to make such surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present is a violation of 10 CFR 20,201(b). (483/86011-02)

One violation and no deviations were identifie . Exit Meeting An inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the onsite inspection on August 28, 1986. Further discussions were conducted by the telephone through September 5, 198 The inspector also discussed the likely infonnational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietary. In response to certain matters discussed by the inspector, the licensee: Acknowledged the violation of Technical Specification 3.3.3.1 and the inspectors' concerns regarding the recurrence of the violatio (Section 15) Acknowledged the apparent violation of 10 CFR 20.201(b) and the inspectors' concerns regarding the administrative / procedural controls and practices demonstrated during the event. (Section 16)

-- _ ._ .

_ - . . _ . . -- _ _ . _ - .