IR 05000483/2009008

IR 05000483-09-008 on 06/22/09 & 06/26/09 for Callaway Plant, Radiation Safety Team Inspection

ML092290709
Person / Time
Site:	Callaway
Issue date:	08/17/2009
From:	Greg Werner NRC/RGN-IV/DRS/PSB-2
To:	Heflin A AmerenUE
References
FOIA/PA-2010-0209 IR-09-008
Download: ML092290709 (24)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N ust 17, 2009

SUBJECT:

CALLAWAY PLANT- NRC RADIATION SAFETY TEAM INSPECTION REPORT 000483/2009008

Dear Mr. Heflin:

On June 26, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Callaway Plant. The enclosed Radiation Safety Team inspection report documents the inspection findings which were discussed with you and other members of your staff. A subsequent telephone exit was conducted on July 13, 2009, with Mr. D. Trokey, Licensing Representative, and other members of your staff to recharacterize several issues based upon additional information we received after the onsite inspection period.

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 two 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 Based on the results of this inspection, no findings of significance were identified.

AmerenUE -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/

Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Docket No. 50-483 License No. NPF-30

Enclosure:

NRC Inspection Report No. 05000483/2009008 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000483 License: NPF-30 Report: 05000483/2009008 Licensee: AmerenUE Facility: Callaway Plant Location: Junction of Highway CC and Highway O Fulton, MO Dates: June 22 - 26, 2009 Inspectors: D. Stearns, Health Physicist, Team Leader L. Carson II, Senior Health Physicist D. Graves, Health Physicist L. Ricketson, P.E., Senior Health Physicist Accompanied By: N. Greene, Health Physicist Approved By: Gregory E. Werner, Chief Plant Support Branch Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

IR 05000483/2009008; 06/22/2009 - 06/26/2009; AmerenUE; Callaway Plant; Radiation Safety

Team Inspection The report covered a five-day period of inspection on site by a team of five region-based health physics inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

Licensee-Identified Violations

None

REPORT DETAILS

RADIATION SAFETY

Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety

[PS] 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

• Audits and self-assessments; licensee event reports or special reports if any were required since the previous inspection

• 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 Specific documents reviewed during this inspection are listed in the attachment.

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports or special reports These activities constitute completion of nine of the required nine samples as defined in Inspection Procedure 71121.03-05.

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

(1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure;

(2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out of service, are controlled in accordance with the applicable regulatory requirements and licensee procedures;

(3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and

(4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual (ODCM), and licensee procedures required by the technical specifications as criteria for determining compliance.

The team conducted in-office inspection and reviewed:

• Appropriate program documents, procedures, and evaluations related to the radiological effluent controls program listed in the attachment to this report

• The implementation of the Radiological Effluent Controls Program requirements as described in Radiological Effluent Technical Specifications

• Changes, if any, to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Updated Final Safety Analysis Report

• Changes, if any, to the Offsite Dose Calculation Manual made by the licensee since the last inspection

• The annual effluent release reports since the previous inspection

• The correlation between the effluent doses and the environmental monitoring results The team conducted an onsite inspection which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review:

• The gaseous and liquid discharge system configuration

• Selected point of discharge effluent radiation monitoring systems and flow measurement devices

• The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits

• Effluent discharges made with inoperable (declared out of service) effluent radiation monitors including the projected doses to members of the public

• Surveillance test results on non-safety related ventilation and gaseous discharge systems (HEPA and charcoal filtration) including the methodology to determine the stack and vent flow rates

• The identification of nonradioactive systems that have become contaminated, if applicable

• Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration

• The methods used to determine the isotopes in the plant source term

• A selection of monthly, quarterly, and annual dose calculations

• Records of abnormal gaseous or liquid discharges, if any, including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report

• Effluent sampling records

The team reviewed the licensees program of problem identification and resolution including:

• Placement of problems identified through audits, self-assessments, and monitoring results into the corrective action program and adequacy of immediate and long term corrective actions

• Problem identification and resolution follow-up activities

• Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three of the required three samples as defined in Inspection Procedure 71122.01-05.

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 licensee=s 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 licensee=s 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

• 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, if any Specific documents reviewed during this inspection are listed in the attachment.

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting These activities constitute completion of six of the required six samples as defined in Inspection Procedure 71122.02-04.

b. Findings

No findings of significance were identified.

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

a. Inspection Scope

This area was inspected to ensure that the radiological environmental monitoring program 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 [or controlled access 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

• Audits, self-assessments, corrective action documents and licensee event reports or special reports, if any were required, since the previous inspection Specific documents reviewed during this inspection are listed in the attachment.

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports or special reports These activities constitute completion of ten of the required ten samples as defined in Inspection Procedure 71122.03-04.

b. Findings

No findings of significance were identified.

4OA2 Problem Identification and Resolution

Annual Sample Review

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. However, during the inspection of the Radiological Environmental Monitoring Program, the team noted that the licensee had not resolved a continuing problem with the S-02 Portland River composite sampler. The S-02 Portland River composite sampler serves to assure representative sampling downstream of the plant discharge. The licensees corrective action and trending program from 2005 through 2008 identified longstanding operability and reliability concerns with the sampler. This issue was also documented in a 1996 NRC Inspection report which stated that reliability of the sampler had been a concern since 1989. The team determined the licensees Radiological Environmental Monitoring Program staff, maintenance department, and system engineers had made considerable efforts to maintain Sampler S-02 operable in accordance with the Offsite Dose Calculation Manual. The team noted that licensee management had not corrected this longstanding condition. Design Change Package 2003021 was developed to increase the reliability of the sampler. The licensees Unit Reliability Team evaluated this design change to have a low priority and therefore, implementation of the design change has been delayed to 2014.

4OA5 Other Activities

.1 (Closed) Temporary Instruction 2515/173, Review of the Implementation of the Industry

Groundwater Protection Voluntary Initiative

a. Inspection Scope

An NRC assessment was performed of the licensees groundwater protection program to determine whether the licensee implemented the voluntary Industry Groundwater Protection Initiative dated August 2007 (Nuclear Energy Institute 07-07, ADAMS Accession Number ML072610036). Inspectors interviewed personnel, performed walkdowns of selected areas, and reviewed the following items:

• Records of the site characterization of geology and hydrology

• Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involve licensed material for which there is a credible mechanism for the licensed material to reach the groundwater

• Implementation of an onsite groundwater monitoring program to monitor for potential licensed radioactive leakage into groundwater

• Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts

• Records of leaks and spills recorded, if any, in the licensees decommissioning files in accordance with 10 CFR 50.75(g)

• Licensee briefings of local and state officials on the licensees groundwater protection initiative

• Protocols for notification to the local and state officials and to the NRC regarding detection of leaks and spills

• Protocols and/or procedures for 30-day reports if an onsite groundwater sample exceeds the criteria in the radiological environmental monitoring program

• Groundwater monitoring results as reported in the annual effluent and/or environmental monitoring report

• Licensee and industry assessments of implementation of the groundwater protection initiative

b. Findings

No findings of significance were identified. Implementation of the Groundwater Protection Initiative is voluntary. Under the final initiative, each site was to have developed and implemented an effective, technically sound Groundwater Protection Program by August 2008. The licensee completed its Groundwater Protection Initiative self-assessment in November 2008 and issued the report on December 22, 2008. The self-assessment identified the licensee had weaknesses in the following areas:

(1) its hydrological study,

(2) identification of potential enhancements to leak or spill detection mechanisms,

(3) groundwater well maintenance and sampling program, an

(4) procedures for the decision making process for potential remediation of leaks and spills. The NRC team confirmed the findings of the self-assessment were entered into the corrective action program. At the time of the inspection, the licensee had corrected all actions identified in the self-assessment. The Nuclear Energy Institute assessment is currently on-going.

4OA6 Management Meetings

Exit Meeting Summary

On June 26, 2009, the team presented the inspection results to Mr. A. Heflin, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff who acknowledged the findings. On July 13, 2009, a re-exit was performed by telephone

with Mr. D. Trokey, Licensing Representative, and other members of the plant staff due to additional information received after the onsite inspection period. The team confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

S. Abraham, Systems Engineer, Groundwater Protection

J. Barbour, Systems Engineer

P. Bott, Systems Engineer/Meteorological Monitoring

C. Emerson, Countroom/Dosimetry Engineer

L. Franks, Associate Engineer, Engineering

J. Geyer, Manager, Radiation Protection

C. Graham II, Consulting Health Physicist, Radiation Protection

J. Houston, Senior Health Physicist, Shipping

J. Nurrenbern, Consulting Engineer/Shipper

D. Thompson, Senior Health Physicist, Instruments

D. Trokey, Regional Regulatory Affairs Specialist

R. Wishau, Senior Health Physicist

NRC

D. Dumbacher, Senior Resident Inspector

J. Groom, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

None

Closed

None

Discussed

None Attachment