ML20199F233

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)

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

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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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