IR 05000483/2007006

IR 05000483-07-006, on 6/4-8/2007, Callaway Plant; Radiation Safety Team Inspection

ML071760397
Person / Time
Site:	Callaway
Issue date:	06/22/2007
From:	Shannon M Plant Support Branch Region IV
To:	Naslund C Union Electric Co
References
IR-07-006
Download: ML071760397 (21)

Text

June 22, 2007

SUBJECT:

CALLAWAY PLANT - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000483/2007006

Dear Mr. Naslund:

On June 8, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every 2 years. These areas are:

Radiation Monitoring Instrumentation

Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

Radioactive Material Processing and Transportation

Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one licensee-identified violation, which was determined to be of very low safety significance. If you contest any non-cited violation in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Callaway facility.

Union Electric Company-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Docket: 50-483 License: NPF-30

Enclosure:

NRC Inspection Report 05000483/2007006 w/attachment: Supplemental Information

REGION IV==

Dockets:

50-483 Licenses:

NPF-30 Report:

05000483/2007006 Licensee:

Union Electric Company Facility:

Callaway Plant Location:

Junction Highway CC and Highway O Fulton, Missouri Dates:

June 4-8, 2007 Inspectors:

Don Stearns, Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Louis Carson, Senior Health Physicist, Plant Support Branch Gilbert Guerra, CHP, Health Physicist, Plant Support Branch Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Approved By:

Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety

-2-Enclosure

SUMMARY OF FINDINGS

IR 05000483/2007006; 6/4-8/2007; Callaway Plant; Radiation Safety Team Inspection

The report covers a 1-week period of onsite inspection by five regional health physicists. One licensee-identified violation, which was determined to be of very low safety significance, was reviewed. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

Cornerstone: Public Radiation Safety

None

Licensee Identified Violations

One violation of very low safety significance, which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance.

The team interviewed licensee personnel and reviewed:

• Calibration of area radiation monitors associated with transient high and very high radiation areas and post-accident monitors used for remote emergency assessment

• Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage

• Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area

• Self-assessments, audits, and licensee event reports

• Corrective action program reports since the last inspection

• Licensee action in cases of repetitive deficiencies or significant individual deficiencies

• Calibration expiration and source response check currency on radiation detection instruments staged for use

• The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units The inspector completed nine of the required nine samples.

b. Findings

No findings of significance were identified.

2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)

a. Inspection Scope

This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; the Offsite Dose Calculation Manual; and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:

• Radiological effluent release reports since the last inspection, changes to the Offsite Dose Calculation Manual, radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, program for identifying contaminated spills and leakage and the licensee's process for control and assessment, self-assessments, audits, and licensee event reports

• Gaseous and liquid release system component configurations

• Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluent, and radioactive liquid and gaseous effluent release permits and dose projections to members of the public

• Abnormal releases

• The licensee's understanding of the location and construction of underground pipes and tanks and storage pools that contain radioactive contaminated liquids, the technical bases for onsite monitoring, the licensee's capabilities of detecting spills or leaks and identifying groundwater radiological contamination both on site and beyond the owner-controlled area

• Changes made by the licensee to the Offsite Dose Calculation Manual, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection

• Monthly, quarterly, and annual dose calculations

• Surveillance test results involving air cleaning systems and stack or vent flow rates

• Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control

• Interlaboratory comparison program results

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection The inspector completed 11 of the required 11 samples.

b. Findings

No findings of significance were identified.

2PS2 Radioactive Material Processing and Transportation (71122.02)

a. Inspection Scope

This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:

• The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program

• Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges

• Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting

• Shipping records for non-excepted package shipments

• Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection The inspector completed six of the required six samples.

b. Findings

No findings of significance were identified.

2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program (71122.03)

a. Inspection Scope

This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed

• Annual environmental monitoring reports and licensee event reports

• Selected air sampling and thermoluminescence dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

• Each event documented in the Annual Environmental Monitoring Report, which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement

• Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection

• Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, interlaboratory comparison program results, and vendor audits

• Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area and the methods used for control, survey, and release from these areas

• Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records

• Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection

The inspector completed 10 of the required 10 samples.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

a. Inspection Scope

The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:

• Radiation Monitoring Instrumentation (Section 2OS3)

• Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)

• Radioactive Material Processing and Transportation (Section 2PS2)

• Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)

b. Findings and Observations

No findings of significance were identified.

4OA6 Management Meetings

Exit Meeting Summary

On June 08, 2007, the team presented the inspection results to Mr. Charles D. Naslund, Senior Vice President and Chief Nuclear Officer, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.

4OA7 Licensee Identified Violations

The following finding of very low significance was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600 for being dispositioned as Non-Cited Violations.

• Two examples of a Technical Specification 5.4.1.a violation were reviewed by the team. Technical Specification 5.4.1.a states, in part, that written procedures shall be established, implemented, and maintained, which cover applicable

procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Section 7(e) of the regulatory guide requires procedures for radiation surveys which would limit personnel exposure and materials released into the environment. Procedure HTP-ZZ-02023, Unconditional Release of Material from Radiological Controls, Revision 2, Section 5.1.1, states, in part, that radiation protection personnel shall survey items removed from the radiological controlled area to ensure no byproduct material is released within the limits of detection for the instrument used. Contrary to procedure, pieces of contaminated scaffolding were identified outside the radiological controlled area.

The first example, on May 22, 2006, involved a worker reporting to radiation protection with a piece of scaffolding labeled as radioactive material from the south side of the replacement steam generator storage facility. A radiation protection technician surveyed the item and detected radioactive material when placed in the Gamma tool monitor and when frisked with a Ludlum Model 177 frisker. This event was documented in the licensees corrective action program as Condition Action Request 200604011. The second example, on May 31, 2006, involved a maintenance worker who identified two pieces of scaffolding labeled as radioactive material from the south end of the 2033 turbine building.

A radiation protection supervisor investigated the discovery, determined the items to be radioactive material and dispositioned them as radioactive material.

This event was documented in the licensees corrective action program as Condition Action Request 200604287. This finding was determined to be of very low safety significance because:

(1) it was a radioactive material control finding,

(2) it was not a transportation finding,

(3) it did not result in public dose greater than 0.005 rem, and

(4) the number of occurrences was not greater than five.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Farnam, Manager, Radiation Protection

D. Thompsom, Health Physicist, Radiation Protection

H. Osborne, Health Physicist, Radiation Protection

F. Stuckey, Respiratory Protection Program

B. Turner, Supervisor, Operations Rad Waste

C. Smith, Auditor, Quality Assurance

J. Apland, Technician, Radiation Protection

C. Graham, Health Physicist, Radiation Protection

C. Jutting, Design Engineer, Nuclear Engineering

R. Rice, Supervising Engineer, Nuclear Engineering

E. Mayhorn, Consulting Engineer, Supplier Quality

R. Baker, Engineer, Systems Engineering

NRC

D. Dumbacher, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

NONE Opened and Closed During this Inspection NONE