IR 05000483/1986014

Insp Rept 50-483/86-14 on 860512-29.Violation Noted: Failure to Perform Required Continuous Sampling of Effluent Releases

ML20199F233
Person / Time
Site:	Callaway
Issue date:	06/16/1986
From:	Gill C, Januska A, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20199F208	List: ML20199F202 ML20199F216 ML20199F233
References
50-483-86-14, NUDOCS 8606240234
Download: ML20199F233 (7)

Text

_-

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/86014(DRSS)

Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 St. Louis, M0 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Reform, M0 Inspection Conducted: May 12-29, 1986 h.Y. Muult<v Inspectors: A.G.danuska / 66 Date C b~lb*C%

Date Approved By:

Qf/kkMJmI" M. C. Schumacher, Chief ~D Radiological Effluents and Date Chemistry Section Inspection Summary Inspection durina the period May 12-29, 1986 (Report No. 50-483/86014(DRSS))

Areas Inspected: Routine, unannounced inspection of the confirmatory measurement program, including sampling, comparison of licensee analytical results with those obtained from the Region III Mobile Laboratory, and counting room quality control; a review of the 1985 Annual Environmental Operating Report; and review of two License Event Report Results: One violation (failure to perform required continuous sampling of effluent releases - Section 6) and no deviations were identifie PDR ADOCK 05000483 G PDR m

r-

.

DETAILS 1. Persons Contacted 1G. Randolph, Manager, Callaway Plant 1J. Peevy, Assistant Manager, Technical Services 1V. Shanks, Superintendent Chemistry 12R. Roselius, Superintendent Health Physics 12C. Riggs, Supervisor, Primary Chemistry 12C. Graham, Supervisor, Health Physics Technical Services IT. Stotlar, Supervising Engineer 15. Growcock, QA Scientist 1D. Widmer, Engineer 10. Brownawell, QA Engineer 1M. Trusty, Acting Counting Room Foreman G. Lewis, Rad Chem Technician, Counting Room T. Lohmann, Rad Chem Technician, Counting Room 1B. Little, NRC Senior Resident Inspector 1 Denotes those present at exit interview on May 16, 198 enotes subsequent telephone conversations between May 20-29, 198 . Management Controls and Organization No changes in management controls or the staffing structure of the Chemistry and the Health Physics Departments have occurred since a previous inspection (Inspection Report No. 50-483/86001) although promotions within the Health Physics Department, including the Supervisor Health Physics Technical Services and the Superintendent, Health Physics, have taken place. These promotions should increase the efficiency of the Departmen No violations or deviations were identifie . Confirmatory Measurements Containment air particulate, containment charcoal, degassed reactor coolant, gas stripped from reactor coolant, discharge monitor tank and a spent fuel pool sample were analyzed for gamma emitting isotopes by the licensee and by the inspector using the Region III mobile laboratory. Results of the sample comparisons are listed in Table 1; comparison criteria are given in Attachment The containment samples, counted in lieu of unit vent samples which contained no particulate activity, yielded all agreement i l

l

w--_ __- -_ _ _ _ _-_-________- _ _ _ __________- __ _

.

.

Filtered reactor coolant and gas stripped from the reactor coolant also yielded all agreements. Dose equivalent iodine results from the primary coolant sample compared very well. Procedure CTP-ZZ-02570 " Determination of E-BAR in the RCS" was reviewed to determine the accuracy of E-BAR

_ determinations. The procedure appears to be technically sound and the average beta and gamma energies used agreed with accepted value The licensee agreed to count a portion of the fuel pool sample for gross beta, H-3, Sr-89 and Sr-90 and report the results to Region II (0 pen Item No. 483/86014-01) Quality Control of Analytical Measurements An inspector reviewed the implementation of the counting room QC program.

l The program is described in Health Physics Departmental Procedure,

,

HDP-ZZ-04700, " Count Room Quality Control Program," February 20, 1986, 1 l Revision 0. Control charts for efficiency, background, blank, and I resolution or peak position, depending on the instrument, were examined for all counting room equipment and found to be complete and curren The inspector noted that when an instrument was declared "Out of Control" (00C) on the control chart, the specific data for that date was entered on an attached " Control Chart Worksheet" designated for either outlying data or control chart setup data. An instrument is declared 00C and so marked when the average of shiftly QC results exceed three standard deviations of the mean or when a single result exceeds five standard deviations of the mean. The licensee has a method for using 00C instruments <

if necessary while still assuring a valid result. This method requires !

additional QC measurements, the discretion of the count room foreman and evaluation of analyses performe An inspector observed two RCTs (primary chemistry) preparing liquid and gas samples for the confirmatory measurements split and reviewing spectral l data, and two RCTs (counting room) reviewing spectral data for the prepa- l ration of a release report and installing required electronic modules to set up a replacement germanium detector. It appeared from discussions with these individuals and observations that appropriate training had been presented and that the RCTs were knowledgeable in their area.

l Environmental Protection An inspector reviewed the radiological portion of the licensee's " Annual Environmental Operating Report" for 1985. Interpretations and conclusions

<

regarding the samples analyzed during this report period indicate that the ,

, radioactivity detected around the plant is consistent with previous dat l Licensee Event Report Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine l that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplishe . - _ _ _ _ _ _ _ _ _ _ _

r

~

.

(Closed) LER 86-011-00: Sampling Not Performed With Rad Monitor Inoperabl On April 16 and 17, 1986, two incidents occurred which involved failures to perform continuous sampling of effluent releases from the Radwaste (RW)

Building Vent System. The plant was in Mode 3 (Hot Standby) and Mode 2 (Startup), respectively, during the event On April 16, 1986, a gaseous radwaste release from a gas decay tank was authorized. In accordance with Procedure HTP-ZZ-02007, the automatic isolation of the release pathway was tested prior to the release. While testing the alert alarm of the RW noble gas radiation monitor, GH-RE-108, sample flow to the continuous sampling system, GH-RE-10A, was isolated by a signal from GH-RE-108. Since HTP-ZZ-02007 does not require the restor-ation of sample flow to GH-RE-10A, this system remained inoperable until after termination of the release (0541 to 1545) when this condition was discovered by an HP technician while obtaining the sampler's charcoal cartridge and filte Upon discovery of the GH-RE-10A isolation on April 16, 1986, the immediate corrective action taken was to restore sample flow to the monitor. Also, a change to HTP-ZZ-02007 was issued on April 16, 1986, to delete testing of the alert alarm for GH-RE-10B, and a temporary modification was installed on April 17, 1986, on GH-RE-10A to provide an alarm to the Main Control Room when GH-RE-10A is isolated. To prevent recurrence, a Request for Resolution has been written to evaluate a permanent design change which provides an alarm to the Main Control Room when GH-RE-10A is isolated. Also, the incident has been discussed with the HP iechnical Support technicians and will be covered in the periodic requalification trainin The inspectors' review of licensee documentation and interviews with licensee representatives revealed that Procedure HTP-ZZ-02007 had apparently been used on eight previous occasions in conjunction with releases from gas decay tanks. Presumably, the use of this procedure has always isolated GH-RE-10A and no procedural step required the restoration of this system; yet data indicates that required weekly samples have been properly obtained since initial criticalit It appears that someone has restored the system on the eight previous eight occasions, even though the procedure does not specify such action. Although it is unknown whether system restoration occurred before or after gas decay tank releases, it appears that the licensee had eight opportunities to identify the problem with Procedure HTP-ZZ-02007 and take adequate corrective actions to prevent recurrence before the April 16, 1986 inciden Failure to continuously collect samples with auxiliary sampling equipment, as required by Technical Specification Table 4.11-2, while releasing the contents of a gas decay tank to the environs with the Radwaste Building Vent System iodine and particulate samplers inoperable, is a violation of Technical Specification 3.3.3.10. The corrective actions noted above appear adequate to prevent recurrenc (Violation No. 483/86014-02)

The second event on April 17, 1986, was a result of miscommunication between Instrumentation and Controls and Health Physics personnel when taking the radiation sampler out of service for calibration testin The corrective actions specified in the LER appear adequate to prevent recurrenc w_

.

(Closed) LER 86-012-00: Containment Atmosphere Rad Monitors Inoperable During Containment Purge. On April 16, 1986, while the plant was in- ,

Mode 2 (Startup), Containment Atmosphere Radiation Monitors were placed in bypass while a containment mini purge was in progress. The monitors were placed in bypass prior to replacing filters to prevent spurious Engineered Safety Features Actuations which had previously been experience Since the mini purge had been in progress for an extended period of time and since the filters are routinely replaced, Operations personnel failed to recognize the need to secure the mini purge prior to placing the monitors in bypass. The corrective actions specified in the LER appear adequate to prevent recurrenc One violation and no deviations were identifie . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Section . Exit Interview The inspectors reviewed the scope and findings of the inspection with i licensee representatives (denoted in Section 1) at the conclusion of the inspection on May 16, 1986, and by telephone through May 29, 198 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. Licensee representatives did not identify any such documents or processes as proprietar I Attachments:

! Table 1, Confirmatory Measurements l Program Results, 2nd Quarter 1985 j Attachment 1, Criteria for Comparing Analytical Measurements

,

1

i i

-

n- 1

. .

,

.

TABLE 1 U S NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT CONFIRMATORY MEASUREMENTS PROGRAM FACILITY: CALLAWAY FOR THE 2 QUARTER OF 1986

---

NRC------- ----LICENSEE---- ---LICENSEE:NRC----

SAMPLE ISOTOPE RESULT ERROR RESULT ERROR RATIO RES T P FILTER NA-24 7.3E-11 1.5E-12 7.7E-11 9.7E-13 1.1E 00 4.7E 01 A MN-54' 1.7E-12 3.9E-13 2.5E-12 2.4E-13 1.5E 00 4.2E 00 A CO-58 2.4E-12 3.4E-13 2.OE-12 2.OE-13 8.3E-01 7.OE 00 A CS-134 1.3E-11 4.7E-13 1.1E-11 3.1E-13 8.5E-01 2.8E 01 A CS-137 1.6E-11 5.3E-13 1.6E-11 3.OE-13 9.8E-01 3.OE 01 A CE-144 2.6E-12 7.9E-13 2.7E-12 5.1E-13 1.OE 00 3.3E 00 A C FILTER BR-82 5.6E-11 1.5E-12 4.6E-11 7.5E-13 8.2E-01 3.9E 01 A I-131 5.8E-10 2.7E-12 5.6E-10 1.5E-12 9.8E-01 2.1E O2 A I-133 1.3E-10 2.OE-12 1.3E-10 1.1E-12 9.SE-01 6.5E 01 A PRIMARY NA-24 2.1E-02 3.6E-04 2.2E-02 1.9E-04 1.OE 00 5.8E 01 A I-131 2.5E-03 1.SE-04 2.4E-03 7.3E-05 9.8E-01 1.4E 01 A I-132 6.6E-03 3.OE-04 6.SE-03 1.1E-04 9.9E-01 2.2E 01 A I-133 6.OE-03 1.7E-04 6.2E-03 7.2E-05 1,OE 00 3.5E 01 A I-134 1.1E-02 7.8E-04 9.5E-03 4.3E-04 8.8E-01 1.4E 01 A I-135 8.7E-03 7.OE-04 9.OE-03 3.SE-04 1.OE 00 1.2E 01 A CS-137 2.1E-04 1.3E-04 2.2E-04 4.5E-05 1.OE 00 1.7E 00 N CS-138 2.SE-02 2.6E-03 2.6E-02 8.SE-04 1.OE 00 9.8E 00 A OFF GAS KR-85M 4.9E-02 4.6E-04 4.9E-02 1.8E-04 1.OE 00 1.1E O2 A XE-133 8.7E-01 2.1E-03 8.9E-01 8.7E-04 1.OE 00 4.2E O2 A XE-133M 2.6E-02 1.9E-03 2.9E-02 8.5E-04 1.1E 00 1.4E 01 A XE-135 2.2E-01 7.6E-04 2.1E-01 3.OE-04 9.8E-01 2.OE O2 A KR-88 9.4E-02 1.5E-03 8.4E-02 4.7E-04 8.9E-01 6.3E 01 A XE-138 3.6E-02 3.3E-03 3.1E-02 1.1E-03 8.7E-01 1.1E 01 A F POOL CR-51 3.5E-05 6.2E-06 2.9E-05 3.OE-06 8.1E-01 5.7E 00 A MN-54 4.4E-06 7.8E-07 3.7E-06 4.3E-07 8.3E-01 5.7E 00 A CO-57 3.6E-06 4.6E-07 2.9E-06 2.6E-07 7.9E-01 7.SE 00 A CO-58 9.2E-04 3.2E-06 9.1E- 04 1.7E-06 9.9E-01 2.9E O2 A CO-60 2.7E-04 1.9E-06 2.7E-04 1.1E-06 1.OE 00 1.4E O2 A T TEST RESULTS: )

A= AGREEMENT D= DISAGREEMENT o= CRITERIA RELAXED N=NO COMPARISON t -

_ - _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _

. .

-

..

ATTACHMENT 1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS

.This attachment provides criteria for comparing results of capability tests and verification measurements. The criteria are based on an empirical relationship which combines prior experience and the accuracy needs of this progra In these criteria, the judgment limits are variable in relation to the com-parison of the NRC's value to its associated one sigma uncertainty. As that ratio, referred to in this program as " Resolution", in::reases, the acceptability of a licensee's measurement should be more selective. Conversely, poorer agreement should be considered acceptable as the resolution decreases. The values in the ratio criteria may be rounded to fewer significant figures to maintain statistical consistency with the number of significant figures reported by the NRC Reference Laboratory, unless such rounding will result in a narrowed category of acceptanc RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE Agreement

<3 No Comparison 23 and <4 .5

,2.4 and <8 .0

.2E and <16 .67 2,16 and <51 0.75 - 1.33 251 and <200 0.80 - 1.25 2200 0.85 - 1.18 Some discrepancies may result from the use of different equipment, techniques, and for some specific nuclides. These may be factored into the acceptance criteria and identified on the data shee l l

l

{