ML20199F233
| 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: |
| References | |
| 50-483-86-14, NUDOCS 8606240234 | |
| Download: ML20199F233 (7) | |
See also: IR 05000483/1986014
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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
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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 Reports.
Results: One violation (failure to perform required continuous sampling of
effluent releases - Section 6) and no deviations were identified.
8606240234 860617
PDR ADOCK 05000483
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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, 1986.
20enotes subsequent telephone conversations between May 20-29, 1986.
2. 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
Department.
No violations or deviations were identified.
3. 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 1.
The containment samples, counted in lieu of unit vent samples which
contained no particulate activity, yielded all agreements.
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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 values.
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 III.
(0 pen Item No. 483/86014-01)
4. 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,
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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 current.
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 performed.
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.
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5. Environmental Protection
An inspector reviewed the radiological portion of the licensee's " Annual
Environmental Operating Report" for 1985. Interpretations and conclusions
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regarding the samples analyzed during this report period indicate that the ,
, radioactivity detected around the plant is consistent with previous data. l
6. 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 accomplished.
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(Closed) LER 86-011-00: Sampling Not Performed With Rad Monitor Inoperable.
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 events.
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 filter.
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 training.
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 criticality. 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 incident.
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 recurrence. (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 testing.
The corrective actions specified in the LER appear adequate to prevent
recurrence.
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(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
experienced. 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 recurrence.
One violation and no deviations were identified.
7. 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 3.
8. 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, 1986.
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 proprietary.
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Attachments:
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1. Table 1, Confirmatory Measurements l
Program Results, 2nd Quarter 1985 j
2. Attachment 1, Criteria for Comparing
Analytical Measurements
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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
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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
program.
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 acceptance.
RESOLUTION RATIO = LICENSEE VALUE/NRC REFERENCE VALUE
Agreement
<3 No Comparison
23 and <4 0.4 -
2.5
,2.4 and <8 0.5 -
2.0
.2E and <16 0.6 -
1.67
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 sheet.
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