IR 05000483/1993016

Insp Rept 50-483/93-16 on 930920-24.No Violations Noted. Major Areas Inspected:Radioactive Protection & Outage Planning Programs & Tours of Auxiliary & Radwaste Bldgs & SFP Area

ML20059B285
Person / Time
Site:	Callaway
Issue date:	10/21/1993
From:	David Nelson, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059B273	List: IR 05000483/1993016 ML20059B270
References
50-483-93-16, NUDOCS 9310280118
Download: ML20059B285 (8)

Text

.

-

.

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/93016(DRSS)

Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name: Callaway Nuclear Power Station Inspection At: Callaway Site, Callaway County,. Missouri Inspection Conducted: September 20-24, 1993 Inspector: ( M14+ ha u lo f Zi f 4 6 I

David W. Nelson Date '

Radiation Specialist Approved By: Id

'

mb8 toA//11 William Snell, Chief Dats Radiological Prcgrams Section 2 inspection Summary Insoection on September 20-24. 1993 (Report No. 50-483/93016(DRSS))

Areas Insoected: Routine, announced inspection of the radioactive protection and outage planning programs (Inspection Procedure (IP) 83750). The inspection also included tours of the auxiliary and radwaste-buildings and the spent fuel pool area (IP 83750).

Results: The radiation protection program appeared to be effective in implementing the requirements of the regulations. Excellent housekeeping practices were observed during the tours of the auxiliary and radioactive waste buildings. Excellent planning and scheduling activities, in support. of the October 1993 refueling outage, were noted. A weakness was noted in the licensee's process for ensuring that airborne radioactivity monitor setpoints were set in accordance with the Final Safety Analysis Report and the Technical Specification

9310280118 931021 PDR O ' ADOCK 05000483 E!

PDR [L

_

_

-

. )

.

DETAl . Persons Contacted

• J. Blosser, Plant Manager

• C. Graham, Supervisor, Health Physics Technical Services -,

• Evans, Superintendent, Health Physics

• Hamilton, Supervisor, Quality Assurance ~

• Miller, Supervisor, Radioactive Waste and Transportation

• Neudecker, Supervisor, Health Physics Operations

• Petzel, Engineer

• Randolph, Vice President, Nuclear Operations

• D. Calhoun, Resident Inspector The inspectors also interviewed other licensee personnel during the ,

course of the inspectio * Denotes those present at the exit meeting on September- 24, 199 ;

2. General This inspection was conducted to review aspects of the licensee's radiation protection and outage planning programs. The inspection included tours of radiation controlled areas, observations of licensee activities, review of representative records, and discussions with licensee personne . Oraanization and Manaaement Controls (IP 83750) ,

The inspector reviewed the licensee's organization and management controls for the health physics operations group including:

organizational structure, staffing, and delineation of authorit Staffing levels with the health physics group and the management structure remained essentially as described in the last inspection repor The licensee has assigned four teams with the responsibility for -

managing the October 1993 outage. The members of each team will remain the same during the course of the outage and each team will be led by an .

Outage Shift Manager (OSM) and include at least one member from Health ,

Physics management. During past outages there have been problems with communications between the OSM and the Health Physics department especially between shifts. The licensee anticipates that by assigning personnel to teams many of those problems will be alleviate No violations or deviations were identifie :

- - - . _

. - - -. . .- --.

.

. Health Physics Action Plan (IP 84750)

'

One concern raised by the presence of elevated levels of fission products in the primary coolant (IR 50-483/930ll(DRSS)) was the effect'

the presence of the products would have on the plants gaseous and liquid effluents. A review of the semi-annual effluent reports for the second half of 1992 and the' first half of 1993 alleviated many of those concerns. The report's data, shown below, indicated that the effects on effluents had been minima July-December 1992 January-June 1993 (Activity in curies)

Gaseous 3rd Qrt 4th Qrt 1st Qrt 2nd Qrt Total 8.8E+02 1.8E+02 5.4E+00 3.9E+01 Total I-131 7.5E-06 1.lE-04 5.lE-06 3.4E-06 Particulate 1.9E-04 8.6E-04 2.4E-06 1.3E-04 Tritium 2.0E+00 1.7E+01 1.3E+01 1.5E+01 Liauid Total (Excluding Tritium, Gases and Alpha) 5.3E-03 1.4E-02 3.0E-04 3.5E-04 Tritium 3.5E+02 5.3E+02 9.9E+02 1.9E+02 Gases 7.1E-03 1.6E-01 0.0E+00 0.0E+00 In preparation for the October 1993 refueling outage the Health Physics Department (HPD) examined the effect that failed fuel would have on the radiation protection program during the refueling outage. Specifically the department examined:

Personnel contamination incidents (PCI) - for the first nine months of 1993 the plants primary systems had remained " tight" and there had been no indication that the hot particles that had been collected and analyzed contained fission products. However, because the dose consequences of an isotopic change from corrosion to fission products would be significant, the licensee decided that fecal samples would be collected and analyzed if a nasal smear indicated the presence of Ce-144 or if a whole body count indicated the presence of transuranics. This approach would appear to be appropriat ,

. . ... _ __- _ _

.  :

.

.

During the outage the licensee has decided to formally report only those contamination events (area contamination or hot partir les)-

as "PCI"s when the level of contamination of the event exceeds .

1000 counts per minute (cpm). The old criteria for reporting J events as PCIs was 100 cpm. The licensee will continue to record and trend all events whether they are reported or not. The licensee partially based their decision to' change their criteria because the revised 10 CFR Part 20 skin dose limit was raised to '

50 rem per year from the old skin dose limit of 7.5 rem per-quarter. In addition, the licensee would no longer record hot particles found on modesty garments as a PC The licensee made this decision based on the determination that while many of the PCIs recorded during the last outage had been found on modesty garments the dose consequences of those PCIs had been negligibl The licensee would continue to assess the dose consequence of any PCI the activity of which exceeds 10,000 cp *

Whole body counting - the licensee will use the presence of Ce-144 and the isotopes of neptunium to indicate the presence of transuranics. If uptakes of fission products are indicated fecal samples will be collected and analyze *

Personnel contamination monitors (PCM) and Portal Monitors - the licensee determined that the monitors would be able to detect the presence of fission products without changing their calibration regimen. In addition, the sources used to check the instrument's setpoints were determined to be adequat *

Thermoluminescent dosimeters (TLD) - the licensee determined that its TLD program was adequate for monitoring individuals exposed to fission products. The licensee's dosimetry program had been recently recertified by the National Voluntary Laboratory Accreditation Program (NVLAP) in all eight categorie *

Survey instrument calibration procedures were adequat *

10 CFR Part 61 analyses - the licensee collected and sent for l analysis several waste samples from a number of waste stream Early results indicated that the transuranic content of the wet  !

waste (resins and filters) had increased significantly and caution was needed to ensure that future waste shipments would not exceed l

'

a regulatory limi *

Area smears and air filters - during the outage the licensee will periodically analyze smears and air filters for the presence of transuranic In additien, the licensee will use Cascade Air l Impactors to determine the particle size of its airborne  ;

contamination to assist in determining whether respiratory  !

protection is needed during a projec i

!

_ _ _ _ . _ __ _ !

. .. _

-

...

.

In conclusion, The HP department's preparation for responding to the

' presence of failed fuel during the October 1993 outage appeared to be well thought out and comprehensiv No violations or deviations were identifie . Outaae Plannina (IP 83750)

By the end of the inspection the licensee appeared to have completed the ALARA planning for the 1993 refueling outage. More than 93% of the radiation work permits had been written, most if not all of the work flow charts had been drawn and planning for all but a few of the jobs scheduled had been completed. The remaining jobs that needed " planning" involved low radiological risk and the ALARA planner was confident those jobs would be " planned" before~the start of the outage. In Inspection Report No. 50-483/930ll(DRSS) the inspector concluded that the licensee's preparation for the outage had been excellent, further review during the inspection reconfirmed that conclusio No violations or deviations were identifie . ALARA (IP 83750)

In response to the findings of the ALARA self assessment performed prior to the last inspection, the licensee took a number of steps to improve the staffs awareness of upper management ALARA expectations. Those steps included:

Discussing ALARA goals and objectives.at the Outage Review Board meeting *

Supervisors attending ALARA awareness trainin *

Supervisors discussing ALARA goals and principles with their employee *

Making department supervisors personally responsible for meeting their ALARA goal t In addition, the licensee took steps to improve the process for reviewing job histories and assigning more realistic dose estimates. In the past the planners had used man-hour estimates frcm old jobs without first reviewing the most current job historie In many cases the estimates were inaccurate and as a result unrealistic dose goals were issigned. To alleviate the problem the ALARA planner reviewed the most recent job histories of most of the projects scheduled for the outage and met with the work groups responsible for those jobs. Conversations with HP personnel and reviews of the dose estimates for a number of projects indicated that the planner had been successful in assigning more realistic dose goal y

• .

-

4 l

The licensee also improved the methodology for trending dose and .j

' enforcing dose goals during the outage. Each day during the outage the l plant will generate a Daily ALARA Report. The report.will provide l exposure data on specific projects, departments, RWPs and in some cases individual workers. If a RWP is projected to exceed its budgeted man- 1 rem or man-hours goal a Job In-Progress ALARA R9 view (JIAR) will usually be held. Those individuals who exceed or are close to exceeding 300 mrem in seven consecutive days will be identified in the Daily report and may be interviewed by one of the shift ALARA coordinators. Finally, one individual will be assigned to each of the 13 major outage projects and be responsible for meeting the dose goals of that project. The licensee anticipates that these enhancements will ensure that the 230 man-rem (2.3 man-Sievert) goal for the outage will be me No violations or deviations were identifie . Radiation Monitors (IP 83750)

On August 8,1993, the Quality Assurance (QA) department documented in a surveillance a discrepancy between the Final Safety Analysis Report (FSAR) and the Callaway Equipment List's controlling isotope for establishing the setpoints and calibrating the Containment Atmosphere radiation monitors (GTRE0031 and GTRE0032) and the Containment Purge Exhaust radiation monitors (GTRE0033/23 and GTRE0022). The instruments had been calibrated using Kr-85 as the controlling isotope whereas the FSAR stipulated that the controlling isotope whould be Xe-133. QA reported the discrepancy to Health Physics (HP) who in turn expanded the evaluation of the concern to include other safety related airborne radioactivity monitors. By September 15, 1993, HP's evaluation revealed that the Contol Room Heating, Ventilation, and Air Conditioning (HVAC)

_

monitors (GKRE0004 and GKRE0005) had also been calibrated using the wrong isotope (Kr-85). In addition, HP determined the use of Kr-85 had resulted in non-conservative alarm setpoints for the GKRE0004/5 and GTRE0022/33 monitors per the requirements of Technical Specifications (TS) 3.3.3.1. and 4.9.4.2.. On September 16, 1993 the licensee reported the discrepancy to the NRC and on September 22, 1993, the licensee declared monitors GKRE0004/5 (Control Room HVAC manitors) inoperable, L isolated the Control Room Ventilation System and initiated operation of the Control Room Emergency Ventilation System.

Ouring the week of the inspection the licensee's Event Review Team met to discuss the discrepancies reported in QA's surveillance. The team determined the following

• The controlling isotope for monitors GTRE0031/32, GTRE0022/33 and GKRE0004/5 should have been Xe-13 * Use of the incorrect isotope Kr-85 had resulted in non-conservative setpoints for GKRE0004/5 and GTRE0022/33. As a result, the setpoints for monitors GTRE0022/33 could have allowed i the Technical Specification 4.9.4.2 limits (SE-3 microcuries/ cubic centimeter) to be exceeded during CORE ALTERATION The setpoints l j

I I l

L - _ - _ - - _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ -

__ _ _ _ . _ _ - . _

-

,

.

,

s for monitors GTRE0004/5 had been non-conservative from 1984 until .

January 1, 199 ,

F

• On January 1,1993, the licensee adopted the new 10 CFR 20 rules and the resultant change in the conversion factors for Kr-85 and Xe-133 in the new part 20 had modified the setpoints of monitors GTRE0004/5 to within 5% of that required by the TS. Therefore the monitor's setpoints had been acceptable since January 1,199 *

Further evaluations would be needed to confirm the determinations made by Health Physics and the Event Review Team. Additional work that neeoed to be done included:

• Evaluating the need to change the setpoints of monitors GTRE0022/3 * Determining past operability of monitors GTRE0022/33 and -

GTRE0031/3 ,

• Checking the controlling isotopes on all radiation process monitor * Determining why there was a discrepancy between the requirements of the TSs and the FSAR and why the discrepancies had not been identified earlie The conclusions drawn by the Event Review Team included the following:

'

The condition (loss of a safety function) was reportable to the NRC per 10 CFR 50.73(a)(v)(C) and (D).

The condition (deviation from a TS requirement) was reportable per 10 CFR 50.73(a)(2)(i)(B).

• From 1984 to January 1, 1993, monitors GKRE0004/5 did not meet the requirements of TS 3.3.3.1 (non-conservative setpoints).

• From January 1,1993, to the time of the inspection monitors GKRE0004/5 were in compliance with the requirements of TS 3.3. * From 1984 to the time of the inspection monitors GTRE0022/33 did not meet the requirements of TS 4.9.4.2 (non-conservative setpoints).

Following completion of evaluations by the licensee a determination will be made about whether or not the licensee had been in full compliance with the provisions of their TSs and/or had violated NRC requirement Until that time this issue will be considered an Unresolved Item (50-483/93016-01).

One Unresolved item was identifie . .. . . -- . - . .- . .

,

,- u

<

..

a Plant Tours (IP 83750)

,

The inspector toured the auxiliary and radwaste buildings and found d that housekeeping practices in both buildings were excellen Radiological controls (postings, barriers,' etc.) in both buildings were appropriate and within the regulatory requirement No violations or deviations were identifie . Unresolved Item An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable item, a deviation,.or a ,

violatio !

1 Exit Interview (IP 83750)

The inspector met with licensee reprecentatives (denoted in Section 1)

at the conclusion of the inspection on September 24, 1993, to discuss the scope and findings of the inspectio i During the exit interview, the inspector discussed the likely .l informational content of the inspection report with regard to document ;

or processes reviewed by the inspectors during the inspection. Licensee i representatives did not identify any such documents or processes as i proprietary. The following matters were specifically discusse Excellent housekeeping practices in the auxiliary and radioactive waste buildings (Section 8).  :

Excellent preparation for the October 1993, refueling outage (Section 5). The licensee's response to the ALARA self-assessment (Section 6). Possible violations of NRC requirements with regard to airborne -

radiation monitors (Section 7).

,

8