IR 05000483/1998016
| ML20236Y197 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/06/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236Y195 | List: |
| References | |
| 50-483-98-16, NUDOCS 9808110243 | |
| Download: ML20236Y197 (15) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.: 50-483 License No.: NPF-30 Report No.: 50-483/98-16 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Hwy. CC and Hwy. O Fulton, Missouri Dates: July 1317,1998 Inspector (s): Michael C. Hay, Radiation Specialist Plant Support Branch Approvec By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information i
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2-EXECUTIVE SUMMARY Callaway Plant NRC Inspection Report 50-483/98-16 This routine, announced inspection reviewed the implementation of the radiological environmental and meteorological monitoring program Plant Support
Overall, good radiological and meteorological monitoring programs were implemente Meteorological data recovery was greater than 90 percent from 1995 through 199 Environmental air sampling stations were maintained at a high state of operational readiness. Excellent sampling and handling practices were used for collecting enviroismental air sample .
Effective quality assurance audits and survcillances of the radiological environmental ,
monitoring program were performed by qualified personne l ,
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3-Report Details IV. Plant Support R1 Radiological Protection and Chemistry Controls R 1.1 Radiological Environmental Monitorina Proaram Inspection Scope (84750)
The radiological environmental monitoring program was reviewed to determine compliance with the requirements in the Technica! Specifications and Offsite Dose Calculation Manual. Selected environmental media sampling stations were inspected, Observations and Findinas The inspector accompanied and observed a health physics technician collect air and water samples. These activities were conducted in accordance with approved procedures. A review of the sample collection logs, sample shipment and receipt forms, and analysis reports were performed. These documents were adequately maintained; 1 however, the inspector noted that records were not organized in a manner that allowed f for easy retrieval. This observation was discussed with the health physics technical support supervisor who agreed that improvements were warranted and stated that the record disorganization was partly due to the records recently being moved from the corporate office in St. Louis to the station during the departmental reorganization performed in June of 199 I The inspector determined that collection frequency, processing, and analyses of the radiological environmental samples were performed in accordance with the Offsite Dose Calculation Manual. The 1995,1996, and 1997 annual land use censuses were properly performed, and the land use census results were documented as required in the appropriate annual radiological environmental operating reports. The inspector noted that, with the exception of low levels of tritium detected in the river water, there was no evidence of station operations affecting environmental radiation levels (See Section R7.2). Conclusions Overall, a good environmental monitoring program was implemented in accordance with the Technical Specifications and the Offsite Dose Calculation Manual. Collection frequency, processing, and analyses of the radiological environmental samples were performed in accordance with the Offsite Dose Calculation Manual. The annualland
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j use censuses were properly conducted with the results appropriately documented in the l appropriate radio!ogical environmental operating report I l
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-4-R1.2 Meteorological Monitorina Proaram ]nspection Scope (84750)
The meteorological monitoring program was reviewed to determine agreement with commitments in the Final Safety Analysis Report and the recommendations in NRC Regulatory Guide 1.23. The inspector reviewed data collection and data displays at station facilitie Observations and Findinas The inspector noted that the meteorological tower's primary and secondary instrumentation and configuration agreed with the guidance in Regulatory Guide 1.23 and commitments in the Final Safety Analysis Report description. The primary tower provided for meteorological instrument redundancy at the 10 , 60 , and 90-meter level The backup tower contained meteorologicalinstrumentation at the 10-meter level. Both the primary and backup tower utilized two separate power sources to ensure an uninterruptible power supply. The meteorological data recovery rates during the 1995, 1996, and 1997 were greater than 90 percen The inspector verified that appropriate meteorological data was transmitted and displayed in the appropriate facilities including the control room and emergency operations facilit Conclusions Overall, a good meteorologic&l monitoring program was implemented. The performance of the meteorological monitoring program agreed with the guidance contained in Regulatory Guide 1.23. Meteorological data recovery was greater than 90 percent from 1995 through 199 R2 Status of Radiological Protection and Chemistry Facilities and Equipment R Environmental Monitorina Eauipment Inspection Scope (84750)
Selected environmental sampling stations were inspected to verify that the stations were properly maintained and that all sampling equipment was operable and properly calibrated. The environmental monitoring program storage areas were inspected to verify sufficient supplies and equipment were available to perform the licensee's environmental sampling program. The licensee's maintenance and calibration program for the air sampling equipment was reviewe Observations and Findinas The inspector toured and inspected selected environmental media sampling locations for airborne, river water and ground water. With the exception of the upstream river
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r-5-water control station discussed in Section R7.2, the inspector verified that the locations of the environmental media sampling stations met the requirements specified in the Offsite Dose Calculation Manua All air samplers in the field were verified operational and properly calibrated. The inspector observed that housekeeping within the air sample stations was very goo Proper maintenance and calibration records were maintained for each environmental air sampler. The inspector noted that on the average only two air sample deviations were reported in the annual radiological environmental operating reports indicating that a very reliable air sampling program was being implemente The necessary equipment and sufficient supplies to perform required sampling activities were verified. All sampling equipment was properly stored in designated storage areas for easy retrieva Conclusions Sufficient equipment and supplies were available and properly maintained to implement the radiological environmental monitoring program. Environmental air sampling stations were maintained at a high standard of cleanliness and reliability, as indicated by the few occurrences of air sample deviations from 1995 through 199 R2.2 Meteorological Monitorino Eauioment Insoection Scoce (84750)
The meteorological tower instrumentation was inspected. Instrument calibration procedures and records were reviewed to ensure that the meteorological instrumentation was operable and properly calibrated and maintained in accordance with the Final Safety Analysis Report and the guidance contained in Regulatory Guide 1.2 Observations and Findinas Through review of selected calibration records for the meteorological instrumentation, the inspector noted that calibrations were performed at the required frequencie Record review also indicated that calibration tolerances for the maeorological instrumentation were within the recommendations of Regulatory Guide 1.2 The inspector toured both the primary and backup meteorological towers and
, instrumentation areas. All areas observed were in good operational condition, and I
housekeeping within these areas was very good. Through review of logs, the inspector noted that both the primary and secondary meteorological towers and associated instrumentation were checked daily by operations personnel and periodically by instrumentation and control personnel when abnormal indications were observe Conclusions -
Overall, the meteorological monitoring equipment was maintained in excellent operating condition. Calibrations were performed at the required frequencies, and daily checks
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-6-were performed to ensure proper operation of the equipment. Housekeeping of all observed areas was very goo R3 Procedures and Documentation R3.1 Radioloalcal Environmental Monitorina Procram Imolementina Procedures Inspection Scoce (84750)
The inspector reviewed the radiological environmental monitoring program implementing procedure Observations and Findinas The radiological environmental monitoring program implementing procedures described the responsibilities and requirements for the collection and shipment of environmental samples, tracking the shipment of samples, receipt of analyses results, reporting of analyses results, evaluation of analyses results, and performance and recording requirements of the land use census. The procedures contained sufficient detail for personnel to effectively implement the licensee's environmental monitoring program and report the analyses results of the enviror, mental samples collected at the facility. The inspector determined that the requirements contained in the station Technical Specifications and Offsite Dose Calculation Manual were appropriately described in the station procedure Conclusions Good environmental monitoring program implementing procedures were maintaine R4 Staff Knowledge and Performance inspection Scoce (84759)
Selected environmental monitoring program personnel were observed and interviewed .
to determine their knowledge of the radiological environmental monitoring program sampling and analyses requirements and implementing procedures, Observations and Findinas The inspector observed that personnel collecting air samples used excellent sampling and handling practices to ensure sample integrity. Air sampler heads with sample filters were preassembled inside the environmental laboratory allowing complete replacement of the heads in the field minimizing the possibility of sample cross contaminatio Samples collected in the field were properly placed in labeled bags to ensure sample type and location were properly tracke The inspector was informed that river water composite samples were collected in plastic containers that would be reused result ng in the possibility of cross contamination of
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-7-samples. The Supervisor of Health Phyrts, Technical Support, stated that to prevent the possibility of cross contamination the . vill be evaluating changes such as only using new containers or ensuring that a container is not reused until the sample results obtained from the contract laboratory indicate that there was no detectable activity present in that containe Through interviews with personnel involved with the collection of environmental media samples, the inspector determined that personnel were very familiar with the requirements of the radiological environmental monitoring progra c. Conclusions Excelleni sampling and handling practices were used for collecting environmental air samples. The knowledge and performance of the radiological environmental monitoring program personnel were very goo R5 Staff Training and Qualification a. Ln_socction n Scope (84750)
The training and qualification programs for the personnel implementing the radiological environmental monitoring program were reviewed. A review of qualification cards and qualification standards were performe b. Observations and Findinas The inspector verified that the health physics personnel implementing the radiological environmental monitoring program were properly trained, experienced, and met the qualification requirements for the work they performed. A comprehensive qualification program was established entailing formal course work, level of knowledge check-outs, and practical factor The inspector noted that one qualification card indicated that an individual had completed all required training and practical factors which allowed the individual to l perform environmental monitoring duties independently for approximately 13 months prior to fully completing the last section entitled " Evaluation." This section required a signature by the supervisor of heath physics, Technical Support, which indicated that satisfactory completion of all practical factors along with demonstrated expertise in all
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areas had been shown. This section also required a signature by the superintendent of j health physics which indicated that the person was interviewed with respect to (
departmental philosophies, policies, and practices for the performance of the activities within the scope of the individuals' qualification card and indicated that the j superintendent determined the individual to be fully qualified. The training supervisor for the radiological environmental monitoring program also stated that one other individual l had also performed environmental duties for an extended period of time and had not completed the final evaluation section of the qualification card. The training supervisor stated that one contributing reason for this deficiency was attributed to the fact that there was no incentive for the person in qualification to make an effort to see the i
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I 8-required individuals for the final evaluation section signatures since they could perform all required duties without those final interview ;
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Section 4.2.6 of Health Physics Department Procedure HDP-ZZ-06017, Revision 20,
" RAD / CHEM Technician Health Physics Technical Support Qualification Program," l states, in part, "Upon completion of all prerequisite courses, knowledge items, and practical factors on a qualification card, the candidate will receive an evaluation by the ,
supervisory personnel on the card . . . . Successful completion of the final evaluation l determines the candidate to be fully qualified for activities within the scope of the appropriate qualification card." Although this procedure did not address a time limit for ,
when the evaluation section of a qualification card should be completed, the inspector was informed that the extended period of time as described in the previous examples did not meet management expectations. To correct this deficiency, the training coordinator implemented a training index to keep track of the progress for allindividuals in qualification status. The inspector was also informed that regularly scheduled ;
meetings held by the radiological environmental monitoring program supervisors will discuss the progress of individuals in qualificatio !
c. Conclusions i A comprehensive qualification program was established entailing formal course work, level of knowledge check-outs, and practical factors; however, management expectations were not met for individuals fully completing their qualification cards in a timely manne l R6 Organization and Administration a. Insoection Scoce (84750)
The organization, staffing, and assignment of the radiological environmental monitoring program responsibilities were reviewe b. Observations and Findinas The organization; structure and staffing qualifications for the radiological environmental monitoring program met Technical Specification requirements. Personnel from the health physics, technical support section, were responsible for De collection, shipment, and documentation of radiological environmental samples. Analyses of environmental samples were conducted by an offsite contract laborator Since the last inspection, performed in November of 1995, several changes had been implemented. In June of 1998 the Manager, Licensing and Fuels, who was delegated l with the overall responsibility for tne radiological environmental monitoring program, was i reassigned as the Supervisor of Health Physics, Technicai Support. The Supervising
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Engineer, Safety Analysis and Radiological Engineering, who was responsible for implementation and monitoring of the radiological environmental monitoring program, was reassigned as the Health Physicist, Technical Support. The collection and
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shipment of environmental media were conducted by 10 health physics technicians supervised by a health physics supewiso The organizational changes that were made relocated the supervision and management duties from personnel located at the corporate office in St. Louis to the station. In discussion with the Supervisor of Health Physics, Technical Support, these changes should improve the performance of the radiological environmental monitoring program since all activities associated with the program would be conducted by personnelin one centralized location, thus allowing for better communications between personnel and also allowing for the Supervisor of Health Physics, Technical Support, to more effectively oversee the program, Conclusions The organizational structure and staffing qualifications for the radiological environmental monitoring program met Technical Specification requirements. Supervisory and management duties were relocated from corporate personnel located in St. Louis to the station. This change centralizes all activities implementing the radiological environmental monitoring program and should enhance communications and allow more effective oversight of the progra R7 Quality Assurance Program R7.1 Radiological Environmental Monitorino Ouality Assurance Procram Inspection Scope (84750)
Quality assurance audits and surveillance of the radiological environmental monitoring program were reviewe Observations and Findinos The inspector reviewed Quality Assurance Audit Report AP96-009 satisfying the biennial audit requirement for the radiological environmental monitoring program. A review of four quality assurance surveillance reports which covered portions of the radiological environmental monitoring program were reviewed. The audits and surveillance were pedormed by qualified personnel and were very comprehensive and effectively evaluated the radiological environmental monitoring program. Audit and surveillance findings were properly captured through use of the facility corrective action program The licensee used a contract laboratory to perform radiological analyses of environmental media samples. The inspector reviewed Audit SQL-127 issued on October 31,1995. The audit was conducted to verify the contract laboratory's ability to provide the radiological analyses of environmental media samples in accordance with
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the laboratory's quality assurance manual and the f acility technical and quality j requirements. The audit team determined that overall the contract laboratory effectively
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implemented the controls of its quality assurance program which complies with the guidance in NRC Regulatory Guide 4.15.
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-10-Quality assurance for environmental media analytical results was demonstrated by the contract laboratory participating in the Environmental Protection Agency Interlaboratory Comparison Program. A review of the interlaboratory comparison program results indicated that acceptabb results were obtaine Conclusions Quality assurance audits and surveillance were performed by qualified personnel and were found to be very comprehensive and effectively evaluated the radiological environmental monitoring program. Participation in the Environmental Protection Agency Interlaboratory Comparison Program verified the contract laboratory's ability to perform accurate analyses of environmental samp!s R7.2 Suaaestion Occurrence Solution (SOS) and Corrective Actions inspection Scope (84750)
Selected Suggestion Occurrence Solution reports were reviewed to evaluate the effectiveness of the licensee's controls in identifying, resolving, and preventing problems in the radiological environmental monitoring and meteorological monitoring programs, Observat;ons and Findinac Suggestion Occurrence Solution reports issued in 1996,1997, and 1998 in the areas of radiological environmental monitoring and meteorological monitoring programs indicated that licensee personnel used this reporting system as needed and had a proper threshold for identifying problems. Suggestion Occurrence Solution reports were initiated for problems identified during quality assurance audits and the routine implementation of the radiological environmental and meteorological monitoring programs. The Suggestion Occurrence Solution reporting system was effectively used to track and trend identified problem The inspector reviewed Suggestion Occurrence Solution 98-2878 dated July 2,1998, written during a quality assurance audit of the radiological environmental monitoring program, which identified that elevated tritium activity was detected in the upstream control sample location in December 1997 and February 1998. This Suggestion Occurrence Solution also stated that the Offsite Dose Calculation Manual, Table 16.11-7, Notation 6 states,"The upstream sample shall be taken at a distance beyond significant influence of the discharge." The Suggestion Occurrence Solution also stated that a further review should be performed to determine if the upstream sampler location is beyond significant influence of the plant discharge since similar issues were identified prior to the movement of the upstream sampler to its new location which took place in November of 199 During review of this issue, the inspector noted that the licensee had a similar occurrence of the upstream river water control station being significantly influenced by plant discharge prior to 1994. The licensee identified that on several occasions with different river conditions a back flow eddy was observed flowing upstream from the i station discharge and around the front of the intake structure past the intake bays which u- . _ _ _ _ . . _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -
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-11-are located approximately 100 feet upstream of the plant discharge location. The licensee moved the control station approximately 25 feet further upstream from the intake structure where it could be attached and protected by a barge barrier used to prevent vessels from damaging the facility intake structure. Prior to the licensee moving the control station, they performed one tracer study using a plant discharge and determined that the proposed location for the control station was not affected by plant dischar0e for that particular river condition. However, other river condition effects were not evaluate The inspector made two tours to the upstream river water control station during the inspection, During these tours, the inspector noted that visible eddy currents could be seen traveling upstream from the plant discharge location to the plant intake. Debris on the surface of the water was seen floating upriver toward the intake structure. During discussion with the inspector, a health physics technician stated that while collecting an upstream river water control sample, when water conditions were clear, a cloud of water could be seen emanating from the point of the plant discharge, which traveled upriver completely surrounding the intake structur During discussions with the radiological environmental monitoring supervision, they stated that the tritium detected in the upstream river water control station in December 1997 was the result of plant discharge influencing the sample. The inspector reviewed both the December upstream river water control station and downstream river water indicator station tritium results. The upstream river water control station result was approximately 713 picocuries per liter, while the downstream river water indicator station tritium result was approximately 219 picocuries per liter. The inspector noted that in December of 1997 the control station, whien is intended to provide background !
radiological data not influenced by the plant, had detected tritium concentrations greater l than 300 percent larger than the indicator station which is intended to determine the j
- influence of plant activities on the environment. The inspector also noted that in l February 1998, the upstream river water control station and downstream river water indicator station tritium results were er.mimately 287 and 350 picocuries per liter respectively. The licensee stated that the February results could be attributed to background levels of tritium and not the result of plant discharge. The inspector noted that since the December 1997 results indicated that the control station had the potential to be significantly influenced by plant discharge then the determination of when natural background levels of tritium were detected by the indicator station were less certai l The inspector inquired if the Suggestion Occurrence Solution issued on July 2,1998, ,
was the first documented report indicating that a problem existed which would require a cause for its determination and corrective actions to prevent its recurrence. The inspector was provided with a radiological environmental problem report written on February 10,1998, which identified that the control station had been affected by plant discharge during December 1997; however, this problem report corrective actions !
recommended the continued monitoring of the environmental results with no planned i action to determine the cause or to prevent its recurrenc Technical Specification 6.8.1 states, in part, " Written procedures shall be established, i
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implemented, and maintained covering the Offsite Dose Calcula~ tion Manual implementation." Offsite Dose Calculation Manual Table 16.11-7, Notation 6, states, in l
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-12-part, "The upstream sample shall be taken at a distance beyond significant influence of the discharge."
-The licensee agreed that the control station was influenced by plant discharge, however, at both the exit on July 17,1998, and during a conversation on July 23,1998, they stated that the influence of plant discharge was not significant on the upstream ris er water control station. They determined the control station sample results to not be significant because: (1) it is considerably below the lower limit of detection of 3000 picocuries per liter as listed in their Offsite Dose Calculation Manual, (2) it is well below the reporting level of 30,000 picocuries per liter as listed in the Offsite Dose Calculation Manual, and (3) it was only one data point out of 48 indicating an influence from the plant discharg The inspector agreed that the tritium activity concentration results from the river water control station were significantly below the required lower limit of detection or reporting level concentration requirements indicating that the plant was not adversely affecting the environment; however, this does not address the fact that the control station could of been significantly influenced by plant discharge. The comment that only the December 1997 control station sample indicated a significant influence from plant discharge indicates that this occurrence is not predictable as the licensee determined in past observations because of variabilities such as river conditions which continually change and affect the amount of plant discharge that can travel upstream to were the control station is locate The issue of whether the licensee was in compliance with the Offsite Dose Calculation Manual for placement of an upstream river water control station in a location not significantly influenced by plant discharge is an unresolved item pending review of this !
issue by the Office of Nuclear Reactor Regulation (URI 50-483/9816-01). Conclusions Overall, the Suggestion Occurrence Solution reporting system was effectively used to track and trend identified problems. In general good evaluations, assessments, and timely corrective actions were performe An unresolved item was identified involving the location of the upstream river water l control station.
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R8 Miscellaneous Radiological Protection and Chemistry issues (Closed) Insoection Followuo item 50-483/9516-01: Operability of Comoosite Samolers i
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NRC Inspection Report 50-483/9516 identified an inspection followup item (95-016-02)
regarding operability problems associated with the composite water samplers. These problems were mainly as a result of planning delays, obtaining parts, harsh environment, design changes, silt buildup, and river flooding resulting in the composite samplers being inoperable nearly half the time from 1989 through 1995. The inspector reviewed the operability of the composite samplers from 1996 through 1997 and noted )
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-13-that the licensee stillis encountering frequent problems with the downstream sampler,
' however, significant improvement for maintaining the samplers online was note Through review of the radiological environmental operating reports, the inspector noted that the composite samplers were operable approximately 90 percent of the time from 1996 through 1997. Daily grab samples were performed when the composite samplers were offlin X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting conducted on July 17,1998. The licensee acknowledged the findings presented. No proprietary information was identified.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED licensee R. Affolter, Plant Manager C. Emerson, Rad / Chem Supervisor K. Gillam, Rad / Chem Supervisor C. Graham, Health Physics Supervisor, Technical Support J. Kerrigan, Senior Health Physicist, Technical Support J. Laux , Quality Assurance Manager R. Miller, Radwaste Supervisor E. Olson, Chemistry Supervisor M. Reidmeyer, Quality Assurance Engineer NRC l
M. Shannon, Senior Radiation Specialist INSPECTION PROCEDURE USED IP84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring ITEMS OPENED. CLOSED. AND DISCUSSED Opened 50-483/9816-01 URI Location of upstream control station Clor,ed 60-483/9516-02 IFl Operability of Composite Samplers UST OF DOCUMENTS REVIEWED ORGANIZATION CHARTS Radiation Protection / Chemistry Organization - July 1998 L
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2-OUALITY ASSURANCE AUDITS AND SURVEILLANCE Audit AP96-009 " Quality Assurance Audit of Radiological Environmental Monitoring Plan," August 9,1996 Audit SQL-127 " Union Electric Company Audit of Teledyne isotope Midwest Lab,"
October 31,1995 Surveillance SP96-046 " Environmental Radionuclides Data Evaluation," June 5,1996 Surveillance SP96-107 " Dose Consequences of Niobium-95 in Liquid Effluents," April 8, 1997 Surveillance SP97-042 " Emergency Offsite Dose Assessment and Protective Action Recommendations," July 15,1998 Surveillance SP98-036 " Outage Related Effluent and Environmental Monitoring," June 11, 1998 REPORTS Report RE 94-027 " River Water Tracer Study to Determine if the Plant Discharge is Effecting the Upstream Composite River Water Sampler," May 24, 1994 PROCEDURES APA-ZZ-01022 " Radiological Environmental Monitoring," Revision 002 HDP-ZZ-06017 " RAD / CHEM Technician Health Physics Technical Support Qualification Program," Revision 20 HTP-ZZ-04143 " Operation of the Collins Model 42 River Water Composite Sampler,"
Revision 009 HTP-ZZ-042221 " Calibration of Miscellaneous Air Samplers," Revision 012 HTP-ZZ-07001 " Collection and Shipping of Environmental Samples," Revision 026 HTP-ZZ-07100 " Land Use Census Program," Revision 000 HTP-ZZ-07101 " Radiological Environmental Monitoring Program," Revision 000 HTP ZZ-07102 " Sample Collection and Shipment for REMP," Revision 0 HTP-ZZ-07103 " Evaluation and Reporting of REMP Data," Revision 000
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