ML20207T877
| ML20207T877 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/16/1987 |
| From: | Gill C, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207T825 | List: |
| References | |
| 50-483-87-07, 50-483-87-7, IEIN-86-023, IEIN-86-024, IEIN-86-042, IEIN-86-043, IEIN-86-044, IEIN-86-046, IEIN-86-103, IEIN-86-107, IEIN-86-23, IEIN-86-24, IEIN-86-42, IEIN-86-43, IEIN-86-44, IEIN-86-46, NUDOCS 8703240397 | |
| Download: ML20207T877 (17) | |
See also: IR 05000483/1987007
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-483/87007(DRSS)
Docket No. 50-483
License No. NPF-30
Licensee:
Union Electric Company
P. O. Box 149
St. Louis, M0 63166
Facility Name:
Callaway County Nuclear Station
Inspection At:
Callaway Site, Callaway County, Missouri
Inspection Conducted:
February 9-27, 1987
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Inspector:
C. F. Gill
Dat'e /
Accompanying Inspector:
W. J. Slawinski
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Approved By:
L. R.
reger, Chief
3//6/87
Facilities Radiation Protection
Date
Section
Inspection Summary
Inspection on February 9-27, 1987 (Report No. 50-483/87007(DRSS))
Areas Inspected:
Routine, unannounced inspection of the radiation
protection and radwaste programs, including:
solid radwaste, liguid
radwaste, gaseous radwaste, transportation activities, organization
andmanagementcontrols,auditsandappraisals,andcontrolof
radioactive materials and contamination.
Also certain Licensee Event
Reports, open and unresolved items, and licensee response to selected
IE Information Notices were reviewed.
Results:
No violations or deviations were identified.
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8703240397 870317
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DETAILS
1.
Persons Contacted
R. Baker, Supervisor, I&C Engineering
L. Beaty, I&C Engineer
- J. Blosser, Assistant Manager, Operations and Maintenance
J. Cermak, President, CFA Inc. (Consultant)
- J. Cruickshank, Radwaste Shipping Foreman
- J. Gearhart, Superintendent QA
- C. Graham, Supervisor, Health Physics Technical Support
S. Growcock, QA Engineer
- G. Hamilton, Radwaste Engineer
D. Heinlein, Assistant Supervisor, Operations
- B. Holderness, Heap h Physicist
- J. Little,hift Supervisor, Operations
R. Lamb S
Assistant QA Engineer
- S. Miltenberger, General Manager, Nuclear Operations
- A. Neyhalfen, Manager, QA
- A. Passwater, Licensing Superintendent
J. Patterson, Shift Supervisor, Operations
- J. Polchow, Supervisor, Health Physics
- G. Randolph, Plant Manager
- J. Ridge 1, Superintendent, Radwaste
- R. Roselius, Superintendent, Health Physics
S. Sampson, Shift Supervisor, Operations
- D. Schafer, Supervising Engineer, Licensing
- R. Simpson, Assistant QA Engineer
N. Slaten, Supervising Engineer, Nuclear
G. Spires, Foreman, Health Physics
T. Stotlar, Engineering Supervisor, QA
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 staff.
- Denotes those present at the exit meeting on February 13, 1987.
- Denotes those contacted by telephone during the period
February 17-27, 1987.
2.
General
This inspection, which began at 1:00 p.m. on February 9,1987, was
conducted to review the operational radiation protection and radwaste
programs, including solid radwaste, liquid radwaste, gaseous radwaste,
transportationactivities,oranizationandmanagementcontrols} nation.
audits
and appraisals, and control o radioactive materials and contam
Also, reviewed were certain Licensee Event Reports, open and unresolved
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items, corrective actions taken as a result of previously identified
violations, and licensee response to selected IE Information Notices.
The inspectors conducted radiation and contamination surveys of selected
plant areas using a licensee survey instrument; measurements were in
general agreement with posted licensee data.
Area postings, access
controls, and housekeeping were good; an exception to this is discussed
in Section 10 regarding posting and internal exposure controls in a
liquid radwaste system sump area of the auxiliary building.
3.
Licensee Actica on Previous Inspection Findings
(0 pen)OpenItem(483/84035-01):
Determine post-accident effluent
sampling, system iodine line loss correction factors.
NRR has not responded
to the licensee's May 14, 1985 request for deviation from this portion of
NUREG-0737, Item II.F.1, Attachment 2.
Pending the receipt of a response
from NRR, this matter remains open.
(0 pen)OpenItem(483/85006-04):
Pre)are documents which identify the
required compliance activities for NUlEG-0737, Items II.B.3 and II.F.1
(Attachments 1 2 and 3).
The licensee issued Revision 2 of the
ComplianceAction,ReportandRevision1oftheComplianceReviewReport
in January 1987.
The inspectors reviewed these documents and discussed
with licensee re)resentatives the action items which appear to require
closure before tie licensee demonstrates a) parent compliance with the
above delineated TMI Action Plan Itams.
T1ose items apparently requiring
closure include calculations, system modifications, monitor calibrations,
procedural revisions, and personnel training.
As of February 27, 1987,
the licensee has not established an action item completion schedule.
This matter will be reviewed further during a future inspection.
(Closed)UnresolvedItem(483/85016-01):
Correction of a wide range gas
monitoring system design deficiency.
Completion of Callaway Modification
Request No. 85-312A has apparently corrected the deficiency; this matter
is considered closed.
(0)en)UnresolvedItem(483/86004-01):
Determine if the post-accident
no)1e gas effluent monitors for the main safety relief valves /
Sower-operated relief values are physically located in accordance with
1UREG-0737, Item II.F.1, Attachment 1, requirements.
NRC Region III, by
memorandum dated April 28, 1986 has requested that the acceptability of
the installed post-accident noble gas effluent monitoring systems at
Callaway be determined by NRR.
Pending the receipt of a response from
NRR, this matter is remains open.
(0 pen) Unresolved Item (483/86004-02):
Dettrmine the acceptability of
Technical Specifications 3.3.3.6 and 4.3.3.6 concerning identification
of post-accident noble gas effluent radiation monitors in the accident
monitoring Technical Specifications.
NRC Region III, by memorandum dated
April 28, 1986, has requested that the acceptability of Callaway Technical Specifications 3.3.3.6 and 4.3.3.6 be determined by NRR.
Pending the
receipt of a response from NRR, this matter remains open.
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(Clo;ed) Violation (483/86011-01):
Failure to maintain containment purge
valves closed with less than two channels of the containment atmosphere
gaseous radioactivity monitors operable.
Corrective actions outlined in
the licensee's response dated October 24, 1986 were reviewed; no problems
This violation was formall
were noted.
Inspection Report No. 50-483/86020(DRP)y closed in Section 6.b of
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(Closed) Violation 483/86011-02):
Failure to adequately evaluate the
airborneradioactiv(ityconcentrationwithinthereactorbuildingprior
to entry.
Corrective actions outlined in the licensee's response dated
October 24, 1986 were reviewed no problems were noted.
The inspectors
discussedwithlIcenseerepresen;tativesandtheNRCSeniorResident
Inspector the licensee's aerformance during a recent similar containment
entry; no significant pro)lems were noted.
(Closed) Violation (483/86014-02):
Failure to continuously collect
samples with auxiliary sampling equipment while releasing the contents
of a gas deciy tank to the environs with the Radwaste Building Vent
iodine and particulate samplers inoperable.
The correct actions outlined
in Section 6 of Inspection Report No. 50-483/86014(DRSS)appearadequate
to prevent recurrence.
4.
Organization and Management Controls
The inspectors reviewed the licensee's organization and management controls
for the radwaste program, including changes in the organizational structure
and staffing, effectiveness of procedures and other management technigues
used to implement the program, experience concerning self-identification
and correction of program implementation weaknesses, and effectiveness of
audits of the program.
The licensee's Radwaste Department has responsibility for all radwaste
processing systems and shipping operations.
Department management is
arovided by a Radwaste Superintendent; one level of management exists
aetween the Plant Manager and Radwaste Superintendent.
The Radwaste
Department consists of 15 radwaste technicians, two radwaste aparentice
technicians, 20 helpers, seven radwaste foreman, one radwaste slipping
foreman, and one radwaste engineer.
With the exception of replacement
personnel required because of promotions and internal transfers, the
radwaste staff remains stable.
Radwaste shift personnel normally consist
of a radwaste foreman, two radwaste technicians, and four helpers.
Technicians typically perform all system evolutions involved with
radwaste system operation, packaging and shipping; helpers perform all
laundry, decontamination, DAW segregation and compaction operations.
No violations or deviations were identified.
5.
Gaseous Radioactive Waste
The inspectors reviewed the licensee's gaseous radwaste management program,
including changes in equipment and procedures gaseous radioactive waste
effluentsforcompliancewithregulatoryrequirements;adequacyofrequired
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records, reports, and notifications; process and effluent monitors for
compliance with maintenance and operational requirements; and experience
concerning identification and correction of programmatic weaknesses.
Two modifications to the gaseous radwaste treatment system have recently
been completed.
A continuous oxygen analyzer was added to the waste gas
holdup system to facilitate explosive gas monitoring capabilities.
Prior
to installation of the analyzer, grab samples were taken and analyzed as
allowed by technical specifications.
The licensee also installed redundant
isolation valves in the lines leading to the hydrogen recombiners to reduce
problems associated with line leakage.
On January 29, 1987, during preparation for maintenance on a catalytic
hydrogen recombiner, off gases were inadvertently vented into the
Radwaste Building. As a result of increased radiation levels from the
off gases, a Steam Generator Blowdown Isolation occurred when a radiation
monitor trip setpoint was reached.
The licensee evaluation of activity
released to the Radwaste Building during this incident indicates that no
significant radiological release occurred.
A review of Incident Report
No.87-008 indicated that the cause of this incident was an im)ro)er
valve lineup during pre)arations for maintenance.
Apparently act1 the
radwaste operator and t1e radwaste technician participating in' system
tagout activities failed to identify the potential vent )athway.
Pending
completion of licensee's review and corrective actions t11s matter is
considered an unresolved item.
(483/87007-01)
Sampling and release methods and procedures, records, and reports appear
adequate.
The inspectors selectively reviewed records of continuous and
batch gaseous releases made from July 1986 through January 1987.
There
were 41 and 18 gaseous radioactive waste batch releases for the last six
months of 1986 and for 1987 through February 23, respectively.
The
licensee reported preliminary 1986 gamma and beta air dose totals at the
site boundary of 0.62% and 0.75% of the Technical Specification dose
limits, respectively.
The 1986 maximum organ dose to the nearest resident
was preliminarily reported as 0.59% of the Technical Specification dose
limit.
Preliminary data for total gaseocs release of fission and
activation products, radiciodine,ively.
and tritium for 1986 are 5.19 E+3,
1.16 E-3, and 20.5 curies respect
No violations or deviations were identified.
6.
Liquid Radioactive Waste
The inspectors reviewed the licensee's liquid radwaste management
program, including changes in equi) ment and procedures; radioactive
waste effluents for compliance wit1 regulatory requirer,wnts; adequacy
of required records, reports, and notifications; process and effluent
monitors for compliance with maintenance calibration, and operational
requirements;andexperienceconcerningIdentificationandcorrectionof
programmatic weaknesses.
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Sampling and release methods and procedures, records, and reports appear
adequate.
The inspectors selectively reviewed records of liquid batch
releases made from July 1986 to present.
Effluent release permits were
generated and appeared appropriate for each discharge of liquid radwaste;
there were no unplanned liquid releases in 1986 or to date in 1987.
There were 148 and 157 liquid radioactive waste batch releases for the
first and last six months of 1986, respectively and a reported 41 batch
releases for 1987 through February 23.
The licensee reported preliminary
whole body and maximum organ dose totals for 1986 of 8.7% and 3.5% of the
Technical Specification dose limits, respectively.
Preliminary data for
total licuid release of fission and activation products, dissolved and
entrainec noble gases, and tritium for 1986 are 6.5 E-2, 2.14, and
435 curies, respectively.
Two significant modifications to the liquid radwaste treatment cystem
were completed and made operational in 1986.
To more effectively
accommodate increases in the volume of secondary liquid waste (SLW) from
the drain collection system, all but one of the stations SLW CUNO filter
trains were replaced by a hollow fiber filter (HFF) system.
The remaining
CUNO filters will be used primarily as a back-up and to filter special
process streams.
The HFF system allows for increased processing of
licuid waste and is backflushable to facilitate cleaning of the filter
mecia which allows the reuse of the HFF filters, thus reducing the
generation of solid radwaste compared to the non-backflushable CUNO
filters.
This modification is expected to reduce the amount of generated
solid radwaste by about 100 drums per year.
The HFF system contains 32
filter module elements with nominal 0.1 micron pore openings which are
used for filtration of three incoming waste streams from the condensate
polishing system.
The HFF system also incorporates a water / oil separator
to reduce oil content in the feed stream and a phase separator to collect
suspended solids resulting from the backflush cycle.
In 1987, the licensee began remote sampling of highly contaminated
resins from the decant tank by use of a local sampling station added to
the liquid radwaste process system.
The sampling station allows eight
to 72 milliliter samples to be collected remotely and significantly
reduces personnel exposures associated with manual sample collection.
The licensee reported that initial sampling operations using this new
system were performed without problems.
Two 100,000 gallon outdoor batch waste discharge tanks were added to
the system in 1985.
These tanks were added primarily to accommodate an
increase in the volume of secondary liquid waste and are contained within
a dike which re)ortedly can retain the contents of each tank.
Report
No. 483/86011(DRSS) inaicated that the Technical Specifications were to
be revised to allow addition of these tanks; however, it was subsequently
determined that these tanks are not specifically addressed in the Technical
Specifications because they are considered protected outdoor tanks.
No violations or deviations were identified.
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7.
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
notifications; implementation of procedures to properly classify and
characterize waste, prepare manifests, and mark packages; and experience
concerning identification and correction of programmatic weaknesses.
The following revised procedures were reviewed for adequacy and
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compliance with applicable regulations; no significant problems
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were identified:
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RDP-ZZ-00004
" Waste Classification," Revision 2, April 1,1986.
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RDP-ZZ-00006
" Shipment of Radioactive Material," Revision 5
April'22, 1986.
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RDP-ZZ-00007
" Determination of Curie Content in Waste Containers,"
Revision 2, April l', 1986.
RDP-ZZ-0011
" Packaging Spent Filter Cartridges For Disposal,"
Revision 3, October 14, 1986.
RDP-ZZ-0013
"10 CFR 61 Sampling Program," Revision 0,
November 6, 1986.
NUS Process Service Corporation recently comaleted processing a backlog
of spent resins and evaporator bottoms for t1e licensee.
The waste was
placed in ten NUS process liners and subsequently shipped to the Richland,
Washington burial site.
Two liners were transported on each of five
separate ship e to the burial site; the final two liners were ship)ed
from the stction on S nuary 22, 1987.
The licensee has recently purciased
four liners and associated discharge pumps from NUS and plans to implement
a low-level resin process (dewatering) program in 1987.
The licensee
anticipates revising their Process Control Program to incorporate the
planned program modifications.
Hot resin processing will continue to be
performed by contractor (s). The licensee indicateo their primary spent
re-in tank (1000 gallon) is currently at 40-50% capacity, the secondary
ta.ik (2500 gallon) is at about 25% capacity.
Current inventory in the
evaporator bottoms tank is minimal.
The station also plans to dispose
of hot resins and filters in a High Integrity Container (Radlock-500)
in lieu of their " stove pipe" type drums (1.e. 55 gallon drums with
internal shielding sized to accommodate specific filters).
The licensee
reported that the contents of 25 " stove pipe" drums can be placed in one
High Integrity Container.
As discussed in Section 6, replacement of SLW CUNO filters by the HFF
system is expected to reduce solid radwaste generation by 100 55 gallon
drums per year.
The licensee has no immediate )lans to implement a
super-compaction program for DAW waste, althougl vendors offering such
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service are being considered.
Alternatively, the station is considering,
increasing the compaction ability of their three conventional compactors.
The station expects to reduce DAW volume using compaction techniques
together with an increased effort to reduce DAW generation.
The inspectors reviewed selected portions of the licensee's solid
radwaste storage and shipping records for the last six months of 1986.
The licensee presently has 132 drum equivalents (55 gallon) of solid
radwaste in storage.
These drums are located in the low-level solid
radwaste storage area in the radwaste building.
The licensee generated
approximately 6600 cubic feet of solid radwaste in 1986, including DAW,
spent filter cartridges, and solidified liners.
This met the licensees
7500 cubic feet " excellent" goal for the year.
The 1987 goals for
packaged solid radioactive waste are 6700, 9000 and 11,000 cubic feet
for excellent, commendable, and acce) table, respectively.
Considering the
maintenance and refueling outages scleduled for 1987, such goals are an
indication of the licensee's conscientious efforts to minimize radwaste
volume by use of process equipment, waste segregation, and DAW compaction.
No violations or deviations were identified.
8.
Transportation Activities
The inspectors reviewed the licensee's trans)ortation of radioactive
materials program, including determination w1 ether written implementing
procedures are adequate, maintained current, properly approved, and
acceptably implemented; determination whether shipments are in compliance
with NRC and D0T 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 weaknesses.
The inspectors selectively reviewed portions of solid radwaste shipment
records for 1986 and to date in 1987.
The information on shi) ping papers
appears to satisfy NRC, 00T, and burial site requirements.
T1e licensee
had twelve radwaste shipruents in 1986 containing a cumulative 19.37 curies
and comprising a volume of 5928 cubic feet.
This volume is a 21% increase
over that for 1985; however, approximately 4000 cubic feet of 1986's waste was
generated during an outage earlier in the year and also due to backlog
processing of spent resins.
Two shipments of spent resins, two liners
each were made to date in 1987 and consisted of 3.18 curies in 728 cubic
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feet; these two shipments were the remains of the processed spent resin
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backlog.
No violations or deviations were identified.
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9.
Audits and Appraisals
The inspectors reviewed reports of audits and appraisals conducted by
the licensee including audits required by Technical Specifications. Also
reviewed were management techniques used to implement the audit program
and experience concerning identification and correction of programmatic
weaknesses.
The inspectors reviewed corrective actions taken or planned in response
to problems identified during the last annual QA Radwaste Audit performed
by the licensee from July 28 to August 6, 1986.
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 isolation and restoration of
Group D Augmented systems.
To correct the latter problem, the Operations
Supervisor was reported to have issued a Night Order specifying all systems
that require independent verification.
Additional plans call for revising
appropriate procedures to reflect all Group D Augmented systems which
require independent verification for isolation and restoration.
Corrective
actions for the other problems included additional training and planned
procedural modifications to develop and clarify requirements.
Also, the
licensee confirmed that stored solid radwaste accountability log sheets
were appropriately completed and the inventory was inspected, properly
documented and located in accordance with requirements.
The inspectors
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identified no problems with the corrective actions.
The inspectors reviewed the report of a QA audit pertaining to
implementationofon-the-jobtrainingforhealthphysicsandradwaste
personnel conducted by the licensee from September 25 to October 3,
radwaste on-the j, team determined that overall, health physics andob training
1986.
The audit
The audit identified one procedural adherence problem concerning failure
of two Radwaste Foremen to attend " Administration of On-The-Job Training"
prior to approving personnel qualifications for various tasks.
The inspectors also reviewed UEQA radwaste surveillance reports for the
later part of 1986 and to date in 1987 and discussed the corrective
actions taken or proposed with the Radwaste Superintendent.
In general,
responses to surveillance findings appear thorough, timely, and technically
sound.
The inspectors also reviewed the tentative radwaste QA audit and
surveillance schedule for 1987; no problems were noted.
The licensee's
QA audit and surveillance program appears adequate to assess technical
performance, regulatory and procedural compliance, and personnel
qualification and training of the radwaste and transportation
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programs.
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No violations or deviations were identified.
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10.
Control of Radioactive Materials and Contamination
The inspectors reviewed the licensee's program for control of radioactive
materials and contamination; effectiveness of survey methods, practices,
equipment, and procedures; adequacy of review and dissemination of survey
data; and effectiveness of methods of control of radioactive and
contaminated materials.
The inspectors performed direct radiation and smearable contamination
surveys of equipment and selected areas in the auxiliary building;liary
survey
results were consistent with licensee posted data.
During an auxi
building tour on February 9, 1987 the inspectors noted that a February 2,d
1987 non-dose-tracking (NDT) RWP and survey sheet for an accessible liqui
radwaste system sump area indicated smearable contamination levels up to
450 000 dpm/100cm .
The area required a single set of protective clothing
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(PCs) for entry; there appeared to be no requirements for additional
protective clothing or indication that it was a potential airborne
radioactivity area.
Subsequent investigation by the licensee revealed
that the highly contaminated areas were limited to isolated wet spots,
resulting from pump leakage, that would presumably remain wet and
therefore, did not represent a potential airborne hazard when the survey
was performed.
Infrequent entries into the area and the apparent relative
inaccessibility of the contaminated spot factored into the licensee's
decision not to upgrade RWP requirements beyond full PCs.
The licensee informed the inspectors that their policy has been to
evaluate any access controls and postings for area with smearable levels
> 100,000 dpm/100cm2 with regard to " Contact HP Prior to Entry,',' postings
and consideration of additional protective requirements, including a
second set of PCs or respiratory protection, and to decontaminate
accessible areas to less than 25,000 dpm/100cm whenever possible.
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Licensee representatives stated that normal station practice was to
include more information in the remarks section than were present in the
subjectNDTRWPandsurveysheet. The Health Physics Supervisor discussed
the specific concerns with the personnel directly involved, issued a memo
on the matter to the Health Physics Superintendent, and plans to include
this item in the next schedule retraining session for Health Physics
Technicians and Foremen.
The radwaste sump area was resurveyed soon
after discovery of the inadequate NDT RWP and survey sheet on February 9,
1987, the area was posted " Keep Out" on February 10, 1987, and the sump
leakage repaired after the area was decontaminated on February 11, 1987.
Although corrective action was prompt, thorough, and adequate, the
situation existed for a wed., apparently without being noticed during
numerous licensee health physics plant tours.
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Floor area contamination in the auxiliary, fuel, and radwaste buildings
is determined monthly and comprised 10,000 square feet in January 1986
and increased to a peak value of 14,000 square feet in July 1986.
In
January 1987, the floor area contamination was reported as 12,009 square
feet. The station's 1987 goals for floor area contamination in the
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auxiliary, fuel, and radwaste buildings are 12,000, (acceptable), 10,000
(commendable), 8,000 (excellent) square feet.
It appears highly desirable
for the station to maintain these contaminated areas as low as practical
because recent increases in reactor coolant specific activity due to fuel
leakage will tend to increase contamination levels produced.
No violations or deviations were identified.
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IE Information Notices
The inspectors reviewed the licensee's internal responses to selected
IE Information Notices.
The licensee's evaluations, conclusions and
corrective actions are presented below:
Notice No. 86-23:
" Excessive Skin Exposures Due to Contamination with Hot
Particles."
lhe licensee has developed procedures for followup of skin
contamination events and calculation of dose to skin.
The critical skin
and depth dose methodologies described in the Information Notice are
utilized by the licensee.
Callaway Station experienced approximately
ten incidents of hot particle skin contaminations in 1986, primarily
during the refueling outage earlier in the year.
As a result of these
incidents, no individual received radiation exposure exceeding 10 CFR 20
limits.
The licensee identified several potential contributors to this
problem including inefficient laundry frisking and potentially degraded
laundry cleaning fluid quality causing cross contamination of PCs during
dry cleaning.
Frisking of laundered PCs is performed with hand-held
pancake GM detectors; PC reissue release criteria is less than 0.2 mR/hr.
of fixed contamination.
The Corporate Radiation Protection Committee has
made a recommendation for the )rocurement of a laundry monitor system to
replace the current manual metlod of monitoring.
If approved, the
monitoring system is expected to be on-sit: and operational for the
upcoming 1987 maintenance outage.
An increased changeout frequency has
been implemented to resolve the problem of degraded cleaning fluid quality.
Notice No. 86-24:
" Respirator Users Notice:
Increased Inspection
Frequency for certain Self-contained Breathing Apparatus Air Cylinders."
Callaway Station does not use the subject air cylinders for
self-contained breathing apparatus.
Notice No. 86-42:
" Improper Maintenance of Radiation Monitoring Systems."
Thisnoticeaddressesuseofelectricaljumpersandverificationofjumper
of jumper installation or removal to ensure a system / pendent verification
removal.
Callaway Station procedures require an inde
component is restored
to operational status.
Thelicenseeindicatedthesubjectnoticewas
discussed in an I&C meeting.
Notice No. 86-43:
" Problems with Silver Zeolite Sampling of Airborne
Radiciodine."
In late 1986, the licensee discontinued all use of silver
zeolite cartridges for radiciodine sampling and does not plan to resume
use of such cartridges.
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Notice No. 86-44 and 86-107:
" Failure to Follow Procedures When Working
in High Radiation Areas" and " Entry Into PWR Cavity with Retractable
Incore Detector Thimbles Withdrawn," respectively.
Inspector concerns
regarding these notices are discussed in Section 12.
Notice No. 86-46:
"Im
Protection EquiFiiient." proper Cleaning and Decontamination of Respiratory
Callaway Station cleans respiratory protection
manufacturers recommendations. phate-free solution in accordance with
equipment in a non-organic phos
Notice No. 86-103:
" Respirator Coupling Nut Assembly Failures." Callaway
StationdoesnotusethesubjectMSAULTRA-VUErespiratorsandhasnot
experienced mechanical failure of the sealing flange with those used.
12.
PWR Cavity Access Controls
IE Information Notices No. 86-44 and 86-107 concerned potential
radiological hazards associated with entry into TIP rooms and cavities
beneath reactor vessels.
Callaway Station has two areas similar to
those described in the Information Notices, the incore instrument tunnel
and the seal table area.
Both areas are potential very high radiation
areas (>1R/hr), depending on cperational mode and location of incore
detectors.
Procedures address access control and confirmation of detector location
and movement restrictions for incore instrument tunnel entry.
Incore
instrument tunnel access requires key authorization by the Emergency Duty
Officer after verification by the Shift Supervisor that the incore
thimbles are fully inserted into the core, the moveable incore detectors
are in their stored positions, and the supply breaker to the incore
detector drive units are tagged-out.
Additionally, if health physics
surveys required prior to entry indicate that the tunnel is a very high
radiation area (>1R/hr), a special RWP is written which includes
procedural requirements for very high radiation area access.
Access
controls and restrictions on thimble location and detector movement appear
adequate for the incore instrument tunnel.
No problems were identified.
The licensee reported that training / retraining of Health Physics
and Reactor Operation staffs cover the transient radiological hazards
from incore detectors and thimbles and the importance of work group
communication.
The subject matter also is tentatively scheduled for
Health Physics and Operations retraining prior to the station's next
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refueling outage later in 1987.
The inspectors discussed IE Information
Notice No.86-107 with the Assistant Supervisor of Operations and three
Shift Supervisors.
The individuals are aware of the problems described
in the notice including the potential radiological hazards.
No problems
were identified.
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The TIP room described in IE Information Notice No. 86-44 is eguivalent
to the licensee's seal table area.
The entrance to this area is not
routinely posted with precautionary signs but can potentially be a very
high radiation area and/or a contamination area under certain conditions.
When at power, very high radiation area procedural access controls are
exercised for entry into the Reactor Building and include the following:
An appropriate RWP.
A radiation survey instrument for exposure rate measurements.
A radiation monitoring device which integrates the area
exposure rate and alarms when a present exposure is received.
Continuous health physics coverage or pre-job ALARA briefing by
Health Physics Supervision.
Written authorization by Health Physics Supervision and
Operations Shift Supervisor; the latter authorizing appropriate
key issuance.
Once in the Reactor Building, access to the seal table area is possible
without any additional controls.
Licensee representatives stated that
the entrance (access ladder) to the seal table area is posted " Contact
HP Prior To Entry" during shutdown; however, the sign is removed when
the plant is in other than a shutdown mode of operation.
Prior to flux
mapping in operational modes, 3rocedures require Operations personnel to
contact Shift Suaervision and iealth Physics prior to withdrawing incore
detectors into tie seal table area.
However, it appears similar controls
are not required when shutdown, or if maintenance activities require
detector movement.
Tagging-out the supply breakers to the detector drive
motors are required only when incore instrument tunnel access is needed
and does not apply to the seal table area.
Therefore, It appears the
licensee should consider additional posting and access controls for the
seal table area and restrictions on remote incore detector movement,
especially when shutdown.
The licensee is considering the following
recommendations:
Continuously posting or labeling seal table area entrance
with " Contact HP for Survey Prior to Entry."
Posting each of the four detector drive unit boxes " Contact
for HP Survey Prior to Entry" to prevent possible uptake from
working on boxes without respiratory protection.
Administrative Controls (i.e. tagging-out) to prohibit
remote movement of detectors while individuals are in the
seal table area.
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This matter was discussed at the exit meeting and will be reviewed
further during a future inspection.
(483/86007-02)
No violations or deviations were identified.
13.
External Exposure Determination - Maximum Absorber Thickness
The inspectors reviewed the licensee's dosimetry program to verify
compliance with NRC requirements (Form NRC-5) which specify that
whole body doses be determined using a maximum absorber thickness of
1000 mg/cm when eve protection (> 700 mg/cm ) is provided and a
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maximum of 300 mg/cm withouteyeTprotection. The licensee's dosimetry
2
program employs the use of a 4-chip TLD system; one chip with a tissue
equivalent absorber thickness of 30 mg/cm , two 300 mg/cm chips and one
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at 1000 mg/cm . The station evaluates whole body gamma exposures through
2
a tissue equivalent absorber of 300 mg/cm ; eye protection is not routinely
2
required.
For mixed beta / gamma fields, a computer algorithm calculates
7 mg/cm2 and 300 mg/cm2 dose equivalents.
No problems were noted.
No violations or deviations were identified.
14.
Licensee Event Report (LER) Followup
The inspectors reviewed selected LERs to determine that reportability
requirements were fulfilled and adequate and timely corrective action
was accomplished, including actions to prevent recurrence.
In addition,
each event was evaluated for previous similar events, root cause, and
potential generic applicability.
The review consisted of in-office
review, direct observations, discussions with licensee personnel,
and review of records.
a.
The events described in the following LERs do not appear to
constitute violations of Technical Specifications, regulatory
recuirements, or demonstrate significant programmatic weaknesses
anc are considered closed:
LER N0.
TITLE
483/86-014-00
ESF Actuations on Containment Purge Rad Monitor
Spikes
483/86-035-00
ESF Actuations After Containment Rad Monitor
Taken Out of Bypass.
483/86-038-00
Valve Leakage Results in Hi containment Rad
Levels and ESF Actuations.
483/86-041-00
ESF Actuations When Containment Rad Monitor
Taken Out of Bypass.
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b.
The-following two LERs document the licensee's failure to meet
Technical Specifications or other regulatory requirements.
The violations appear to meet the criteria of 10 CFR Part 2,
Appendix C for self-identification and correction of problems.
Therefore, a Notice of Violation is not being issued and these
LERs are considered closed:
LER 483/86-036-00:
Sealed Source Leak Tests Not Performed Due
to Personnel Error.
On March 21, 1986, the licensee received
nominal 131 microcurie Pm-147 and 147 microcurie T1-204 sealed
sources.
The licensee performed receipt surveys of the shipping
packages as required and the material was logged into the licensee's
source accountability system.
Health Physics personnel recognized
the sources required leak testing on a six-month frequency and noted
this in the accountability system.
Sealed source leak test
certificates did not accompany the sources. Thus, upon receipt
of the sources, the licensee did not know when the sources were
last leak tested nor apparently realized that in the absence of
a certificate from the transferrer, leak testing was required by
Technical Specifications prior to use.
The sources were used on
1986, for calibration of wide range gas monitors.
The
March 21,s initial leak test on these sources was performed in
licensee
August 1986; no leakage was detected.
On October 28, 1986, a licensee QA audit discovered that these
two sealed sources received on March 21, 1986, were used without
satisfying Technical Specification surveillance requirements.
Technical Specification 4.7.9.2.b recuires that sealed sources,
transferred without a certificate incicating the source was leak
tested within the previous six months, shall be leak tested prior
to use.
In November 1986, the licensee received the vendor's leak
test certificates which verified both sources were leak tested in
March 1986, prior to their shipment to the licensee.
The violation
was identified by the licensee, reported to the NRC, and appears to
have been appropriately corrected including measures to prevent
recurrence.
Corrective actions include procedural revisions to
require leak testing all Technical Specification required sealed
sources received from transferrers, even those with accompanying leak
test certificates.
Although similar to a previous problem for which a Notice of Violation
wasissued(InspectionReportNo. 50-483/85017), the inspectors
determined the root cause for the events differed significantly,
corrective actions for the initial event appeared adequate and the
latter occurrence would not reasonably be expected to have been
prevented by the corrective actions for the former.
LER 483/86-039-00:
Action Statement Not Entered When Less
Conservative Radiation Monitor Setpoint Calculated Due to Computer
Software Error.
On December 15, 1986, the licensee discovered that
a liquid radioactive release on October 19-20, 1986, for a Discharge
Monitor tank was performed with the Liquid Radwaste Discharge
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Monitor's trip setpoint at a less conservative value than required
by. Technical Specification.
This is a violation of Technical
~ Specification 3.3.3.9, action statement (a).
The licensee's ensuing
-investigation discovered that sever
Silar events had occurred
since initial criticality in 0ctober 1984.
For all eight occurrences,
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the licensee reported that actual post release data, including actual
. grab,d that' applicable Technical Specification liquid effluent. sample a
showe
concentrations and dose limitations were.not exceeded.
Sampling
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'and analysis, release calculations, discharge permit approvals, and
discharge line valving were reported by the licensee to be performed
in accordance with procedures.
The'latter occurrence was discovered by a utility Health Physicist
.while obtaining data from the discharge permit for reasons unrelated
to the release.
The licensee's investigation determined that the
computer software, which calculates discharge monitor setpoints,
summed the non gamma emitter tritium)concentrationswithgamma
emitters, resulting in a non c(onservative setpoint for the discharge
monitor.
Further investigation by the licensee determined that a
total of eight out of 1225 discharge permits exhibited a.similar
error.
The licensee attributed all eight events to problems
associated with the' vendor's software.
Reportedly, the software
used to generate discharge permits allows the licensee to use a
" Waste Editor Program'! (WEP) and correct any erroneously inputted
data.
However, when WEP is used to edit non gamma emitters, the
softwares' non gamma designator (i.e. flag) is internally removed
from the calculation and the program sums the non gamma and gamma
contributions.
The' licensee indicated the )roblem was not described in the software
operators' manual nor were t1ey notified by the software vendor.
Although the software was tested to verify calculational accuracies,
the testing would not normally have revealed the WEP edit problem.
In accordance with approved procedures, the~ licensee also reviews
all release permits for accuracy; however, the software's non gamma
emitter designators are not normally checked during these reviews.
The inspectors determined that the licensee's corrective actions,-
including actions to prevent recurrence, appear adequate.
The
software vendor was also notified of this problem by the licensee.
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The licensee is assessing this matter with regard to the reporting
!.
requirements'of 10 CFR 21 and have agreed to contact the NRC office
of Inspection and Enforcement concerning the possible generic
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implications of the software error including the vendor's failure-
to notify the licensee of the problem.
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No violations or deviations were identified by the inspectors.
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15.
Exit Meeting
Theinspectorsmetwithlicenseerepresentatives(denotedinSection1)
at the conclusion of the onsite inspection on February 13, 1987.
Further
discussions were conducted by the telephone through February 27, 1987.
The inspectors also discussed the likely informational 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
documentshrocesses as proprietary.
In response to certain matters
discussed )y the inspectors, the licensee:
a.
Acknowledged the inspectors' concerns regarding an incident involving
the inadvertent venting of waste gas into the Radwaste Building.
(Section 5)
b.
Acknowledged the inspectors' concerns regarding the posting
of a radwaste sump area.
(Section10)
c.
Acknowledged the inspectors' concerns regarding seal table area
access control.
(Section12)
d.
Agreed to contact the NRC Office of Inspection and Enforcement
regarding the possible generic implications of a recently discovered
computer software error concerning Technical Specification
setpoints.
(Section 14)
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