IR 05000483/1989016

Insp Rept 50-483/89-16 on 890821-25.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection & Radwaste Mgt Programs Including Changes Since Last Insp, Audits & Appraisals,External Exposure Control & ALARA

ML20247E929
Person / Time
Site:	Callaway
Issue date:	09/07/1989
From:	Grant W, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247E907	List: IR 05000483/1989016 ML20247E902
References
50-483-89-16, NUDOCS 8909180047
Download: ML20247E929 (9)

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p L .U. S. NUCLEAR REGULATORY COMMISSION t

REGION III

~ Report No. 50-483/89016(0RSS)

. Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office. Box 149 St Louis, MO 63166 Facility Name: Callaway County Nuclear Station Inspection At: 'Callaway Site, Callaway County, Missouri Inspection Conducted: August -25, 1989 W0 k ^4 Inspector: W. B. Grant 47 D

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A, b W(ilTiamSnell, Chief Approved By: f/7/8 Radiological Controls and Date Emergency Preparedness Section Inspection Summary Inspection on August 21-25, 1989 (Report No. 50-483/89016(0RSS))

Areas Inspected: Routine, unannounced inspection of radiation protectiovi and radwaste management programs including: changes since the last inspection, audits and appraisals, external exposure control, ALARA (IP 83750),

I implementation of solid, liquid and gaseous radioactive waste programs (IP 84750), and shipping of low-level waste for disposal (IP 83750). Also-reviewed were open and unresolved items (IP 92701).

Results: The licensee's radiation protection and radwaste management programs are good and continue to be effective-in protecting the health and safety of workers and the public. No violations or deviations were identified.

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j i DETAILS s

l 1 Persons' Contacted t

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. L. Beaty, Instrument and Controls l

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• F. Eggers, Supervisory Engineer, QA C. Graham,. Supervisor, Health Physics Technical Support'  ;

• G. Hamilton, Supervisor,-Radwaste l

• J. Laux, Manager, QA

• J. Little, Engineer, QA S. Meyer, Systems Engineer

• J. Peevy, Assistant Manager, Technical Services ,

• J. Polchow, Superintendent, Chemistry /Radwaste I

• G. Randolph, General Manager, Nuclear Operations

• C. Riggs, Supervisor, Chemistry

• W. Robinson, Assistant Manager, Operations and Maintenance j

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• R. Roselius, Superintendent, Health Physics G. Spires, ALARA Coordinator

• D. Voeller, Rad / Chem Foreman: i l *S. Little, NRC Senior Resident Inspector  ;

• C. Brown, NRC Resident Inspector l

The inspector also contacted other. licensee representative !

• Present at the exit meeting on August 25, 1989. j

' General This ir. pection was conducted to review the radiation protection program and the cadwaste management program including radwaste shipping and transportatio During plant tours,,the inspector noted that area l

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posting, access control, and housekeeping were goo . Licensee Action on Previous Inspection Findings (IP 92701)

l (Closed) Unresolved Item 483/88018-02): Evaluate liquid radwaste '

monitor apparent inoperability. The licensee's evaluation of liquid ,

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releases made during the time the liquid effluent monitor and associated is,lation valve may not have been functioning properly determined that 10 CFR 20 limits had not been exceede !

(Closed) Unresolved Item (483/89010-01): Inadequate survey resulting in  ;

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an unposted very high radiation area VHRA; this item is discussed in Section 1 )

i Changes (IP 83750, 84750)  !

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The inspector reviewed changes in organization, personnel, facilities, l equipment, program and procedures that could affect the occupational j radiation protection program or the radwaste operations, j

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I The Health Physics Group (HP) staffing has been stable. The HP Foreman, Dosimetry position which was vacated in July 1989 has been filled by a Chemistry Foreman. .The: individual appears to be qualified in accordance

!with ANSI /ANS 3.1-197 No. violations or deviations were-identifie .' Audits and Surveillance'(IP 83750, 84750)

The ' inspector selectively reviewed the results of Quality Assurance (QA).

audits and surveillance conducted by the licensee since the last

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inspection of radiation protection and radwaste activities. Also reviewed were the extent of the audits and surveillance, their thoroughness, and the qualifications of the auditor .'Two onsite QA audits, one.of the radiation protection program and one of the radwaste program were conducted during this period. The radwaste audit was completed July' 14, 1989; no major findings resulted._. The audit reviewed the Process Control Program (PCP), Technical Specification-compliance, training, tool and small equipment decontamination procedures, and radwaste work contro The radiation protection audit was in progress during the inspection. The anticipated results of the audit were discussed with one of the auditors during the inspection; none of the issues appeared to be of major _ concer Approximately 20 QA surveillance reports of radiation protection and radwaste were reviewed. Corrective action on findings appeared to be timely and technically sound. The extent of the audits and the surveillance and the qualifications of the auditors appeared adequat No violations or deviations were identifie . External Exposure Control (IP 83750)

The. inspector reviewed the licensee's external exposure control and-personnel dosimetry programs, including: changes in the program;.use of dosimetry to determine whether requirements are met; planning and ;

preparation for maintenance and refueling tasks including ALARA '

considerations; and required records, reports and notification The licensee's personnel dosimetry program remains essentially as described in Inspection Report No. 483/89010. Exposure records of plant and contractor personnel were selectively reviewed for 1989 to date. No exposures greater than 10 CFR 20.101 limits were note Posting and labeling in the RCA were observed during plant tours; no '

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problems were note Housekeeping appeared to be goo No violations or deviations were identifie i

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I 7. Internal Exposure Control and Assessment (IP'83750L The inspector reviewed the licensee's internal. exposure control and assessment programs including: changes'in facilities and equipment;

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determination whether engineering controls ~and assessment of individual intakes et regulatory requirements; planning and preparation..for

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maintenance:and refueling tasks' including ALARA consideration; required records, reports, and notifications; effectiveness of management techniques used to implement their program; and experience concerning self-identification and correction of program implementation weaknesse The licensee used the Whole-Body Counter (WBC) during the-recent outage for baseline counting of incoming contractor personnel, routine annual counting of station personnel, and random counting of workers on active RWPs involving possible airborne contamination. Contractor and nonstation Union Electric personnel are counted when their work at the station is completed. A total of 1600 WBC's were performed during the outage with three positive counts and six counts due to external contamination. The three positive counts involved are intake of Co-60 and two intakes of I-131. All were less than 1% of the Annual Limit of Intake (ALI).

No violations or deviations were identifie . Maintaining Occupational Exposures ALARA (IP 83750)

The inspector reviewed the licensee's program for maintaining occupational exposure ALARA, including: changes in ALARA policy and procedures; ALARA considerations for the maintenance and refueling outage; worker awareness and involvement in the ALARA program; establishment of and effectiveness in meeting goals and objectives. Also, reviewed were management techniques used to implement the program and experience concerning self-identification and corrections of implementation weaknesse The 1989 radiation dose through July is approximate 270 person-rem of which about 250 person-rem was attributed to the 55-day maintenance /

refueling outag ALARA pre-job briefings appear to have continually improved during 198 Inspector discussion with licensee personnel indicate that effective pre-job planning and briefings on outage tasks resulted in considerable dose saving Management support for the ALARA program has been extensive and the effectiveness of that support is apparen No violations or deviations were identifie . Liquid Radioactive Waste (IP 84750)

The inspector reviewed the lir.ensee's liquid radwaste management program, including determination whether liquid radioactive waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse ________-_____________ _ -_ _ -

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There was one major change to the liquid radwaste system during the period since the last radwaste inspection. The change involved the relocation of the liquid effluent monitor sample inlet lin The liquid effluent monitor HP-RE-18 monitors liquid discharges and provides alarm and isolation functions. The modification relocated the monitors sample

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inlet from the Radwaste Building discharge pipeline to the common header L of the Discharge Monitor Tank (OMT), thereby. reducing the length of piping to'the monitor and increasing the length of. piping between the sample inlet and the discharge isolation valv The purpose of the modification was to improve monitor response time and decrease valve isolation time. This modification adequately responds to a inspector concern discussed in Inspection Report No. 483/88018 Section 1 The inspector reviewed selected records and procedures associated with

. controlled liquid releases.and the semiannual effluent reports for the last half of 1988 and the first half of 1989. All releases for 1988 and 1989, to date, have been batch releases. The approximate activity (excluding tritium) released per quarter is listed below:

1988 (120 releases)

Third Quarter 38 millicuries Fourth Quarter '41 millicuries 1989 (120 releases)

First Quarter 5 millicuries Second Quarter 2' millicuries The licensee has reduced the mesh size of the filter on the Reactor Ceolant System (RCS) from 30 microns to the current 0.45 microns. This has reduced radioactivity levels in the RCS and consequently in the liquid effluen i No violations or deviations were identifie . Gaseous Radioactive Waste (IP 84750)

The licensee's gaseous radwaste management program was reviewed, including: determination whether changes to equipment and procedures were in accordance with requirements; determination whether gaseous radiation waste effluents were in accordance with regulatory requirements; adequacy of required records, reports, and notifications; determination whether selected monitors were maintained, calibrated and operated as required; and experience concerning identification and correction of programmatic weaknesse Gaseous effluents are released from two points, the unit vent and the '

radwaste building vent. The inspector reviewed selected records of effluent sampling and analysis, and the semiannual effluent reports for the last half of 1988 and the first half of 198 The pathway sampled

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L .and analyses performed appeared to comply with the requirements o Technical Specification Table 4.11-2. For 1988 and-1989 to date, dose rates and'offsite doses from gaseous effluents were less than 1% of limits specified in Technical Specifications 3.1 The gaseous effluents for 1988 and'1989 totaled:

1988 Third Quarter 55 curies Fou"th Quarter 218 curies 1989 First Quarter 65 curies'

Second Quarter- 230 curies For batch releases (from.one of the-eight waste gas decay tanks and from containment purges and vents),' activity released is quantified by isotopic analyses of samples collected prior to the releases.

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Quantification of continuous (non-batch) releases from the unit vent and the radwaste building vent are made from weekly grab sample The inspector also reviewed the licensee surveillance to satisfy Technical Specification 3.11.'2.6, which limits the activity of the contents of each waste gas decay tank. Of the eight storage tanks (with a capacity of 600 cubic feet each), usually only one or two are in service at any one time. Results of the most recent surveillance indicated about-300 curies of radioactive gas ~(Xe-133 equivalent) in the currently in-service tank, which was weli under the Technical Specification limit of 250,000 curie No violations or deviations were identified.

!- 1 Solid R$dioactive Waste (IP 84750)

The inspector reviewed the licensee's solid radioactive waste management program, including: determination whether change to equipment and procedures were in accordance with requirements; adequacy of implementing procedures to properly. classify and characterize waste, prepare manifests, and mark packages; overall performance of process control and quality assurance programs; adequacy of required records, reports, and notifications; and experience concerning identification and correction of programmatic weaknesse The licensee has a functioning program including implementing procedures to meet the requirements of 10 CFR 20.311 ar,d 10 CFR 61.55 and 61.5 In 1988, there were six shipments of solid radwaste containing about 935 curies of Class A waste to Richland, Washington and 2 shipments of Class C waste to Barnwell, South Carolina. In 1989 to date, there has-been eight shipments of Class A waste containing approximately 38.5 curie No violations or deviations were identifie _ _ - _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -

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1 Transportation'of Radioactive Materials (IP 83750)-

The licensee's, transportation of radioactive materials program was-reviewed, including: determination whether written implementing procedures were adequate, maintained current, properly approved and acceptably. implemented; determination whether shipments were'in compliance-with NRC and 007 regulations and the. licensee quality assurance program; determination if there were any transportation incidents involving licensee shipments; adequacy of required records, reports, shipment documentation, and notification; and experience concerning identification and correction of programmatic weaknesse Selected records of radioactive material shipments made in 1989 to'date were reviewed. The shipments appeared to have been made in accordance with the requirements of 10 CFR 61 and 71, 49 CFR 170-179, and the licensee's procedures. Generally, the licensee QA and.QC groups provide good oversight of shipping activitie No violations or deviations were identifie . Instrumentation (IP 84750)

The inspector reviewed calibration and channel function test procedures and results for process radiation monitors (PRM) on gaseous system (containment purge and the plant unit vent monitors). Calibration methods appear appropriate and meet technical specification' frequency requirement No problems were note No violations or deviations were identifie . Air Cleaning Systems (IP 84750)

Technical specifications require filter testing of the control room emergency ventilation system and the emergency exhaust syste The inspector reviewed' records of tests of these air cleaning system and discussed testing procedures with the System Engineer responsible for the performance of the tests. The review included both.in place. tests of HEPA filters and iodine adsorber units as well as laboratory tests of activated carbon samples. Surveillance testing of the system has been timely and test results have met acceptance criteria. No problems were note No violations or deviations were identifie . Improperly Posted Very High Radiation Area On April 29, 1989, an unposted Very High Radiation Area (VHRA)

was identified under a fuel elevator which has been used in fuel reconstitution activities. The licensee's investigation (Incident Report 89-141) determined that an inadequate survey had been performed following removal of the elevator from the Spent Fuel Pool (SFP) on April 23, 1989. The object, when discovered, read 1000 R/hr at contact

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I but was shielded by the elevato'r structure, therefore, only a localized

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area exceeded 100 mR/hr. The contract technicians who perfore.d the survey of the elevator when it was' removed from the SFP s! & d that a thorough survey was made and no elevated radiation levels were foun However, the survey results were not documented. .The combination of high general dose rate (50-60 mR/hr at contact) and the. fact that the elevator was highly contaminated were possjble mitigating factors as to why the-elevated dose rates were.not found initiall The highest whole body exposure for personnel who were involved in removing the elevator from the SFP or who located and surveyed the piece was 35 mrem. The licensee determined that the piece of-metal was part of a torn grid strap from a fuel assembly which had been repaired in the fuel elevator on April 21, 1989. Attempts had been made to flush the piece of out of the bottom of fuel elevator basket but because the piece was never visually observed in 1 the. fuel basket and no abnormal radiation reading were reported it wa assumed it had been removed and was in the bottom of the fuel poo The licensee investigation determined that the root cause of this event was an inadequate radiological survey performed on the fuel elevato ~

As part of the corrective action, the licensee stated that the lessons learned from this event and an emphasis on attention to detail when performing surveys will be incorporated into. technician requal training and the contract HP training course. Specifically, the importance of adequate surveys and how inadequate surveys can be precursors to significant radiological incidents will be emphasize A Training Field Report (CA #937) will be generated to accomplish thi Special precautions have been incorporated into Health Physics Procedure HDP-ZZ-3000, Radiological Survey Program, to instruct personnel to be especially. thorough in performing surveys on mater'ials removed from the SFP or Refuel canal due to the potential for highly activated irradiated components or fuel fragments being presen The licensee's investigation was timely and thorough, and corrective actions were sound. This matter is considered licensee identified and corrected. Unresolved Item 483/89010-01 is considered close . Radiological Controls During Inspection of Spent Fuel Pins (IP 83726)

While performing visual inspections of spent fuel in the spent fuel pool (SFP) the licensee identified two broken fuel pins. The fuel inspection was being performed by the licensee and Westinghouse personnel on fuel which was found to have defects through ultrasonic testing following Cycle 2 refueling in October 1987. Because the SFP area where the work was being performed was designated as Caution Hot Particle Area / Contaminated Area, specific radiological controls were in effect:

• The inspection activities were confined to the cask loading area of the SFP.

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! * A local vacuum system was used to remove any fuel particles or crud I from the surface of the water and from the water under the fuel elemen '

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• The SFP cleanup system was in constant operatio * The SFP work area and adjoining buffer area were radiologically controlled to prevent the spread of hot particle * The work was performed under a specific RWP by experienced Westinghouse personnel with dedicated Callaway HP coverag * Tools and equipment removal from the SFP were sprayed and wiped down while being removed from the SF The licensee intends to do some reconstitution of fuel and will require similar radiological controls during those activitie No problems were note . Exit Meeting (IP 30703)

The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the inspection on August 25, 1989. The inspector summarized the scope and findings of this inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents and processes reviewed by the inspector. The licensee did not identify any such documents or processes as proprietar _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _