IR 05000445/1989029

Insp Repts 50-445/89-29 & 50-446/89-29 on 890502-04.No Violations or Deviations Noted.Major Areas Inspected:Unit 1 Solid,Liquid & Gaseous Radwaste Sys,Radioactive Matl Transportation Program & Radwaste Mgt Program

ML20244C824
Person / Time
Site:	Comanche Peak
Issue date:	05/30/1989
From:	Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20244C823	List: IR 05000445/1989029 ML20244C820
References
50-445-89-29, 50-446-89-29, NUDOCS 8906150152
Download: ML20244C824 (11)

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-APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/89-29 Construction Permits: CPPR-126 50-446/89-29 CPPR-127 Dockets: 50-445 50-446 Licensee: TV Electric 400 North Olive, L.B. 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES)

Inspection At: CPSES, Glen Rose, Somervell County, Texas Inspection Conducted: May 2-4, 1989 Inspector: .

d f H.'D. Chaney, Senior Radiation Specialist 675oh Date

/ Facilities Radiological Protection Section

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Approved:

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R.'E. Baer, Chief, Facilities Radiological Date D[d9 .

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Protection Section Inspection Summary l Inspection Conducted May 2-4, 1989 (Report 50-445/89-29; 50-446/89-29)

Areas Inspected: Routine, announced preoperational inspection of the J licensee's Unit-1 solid, liquid, and gaseous radioactive waste (radwaste)

systems; radioactive material (RAM) transportation program; and radwaste management progra Results: The NRC inspector determined that the licensee had developed radwaste management, radwaste processing and effluent control, and RAM transportation programs based on regulatory and industry guidelines which should assure plant operations in this area are carried out in accordance with regulatory and Technical Specification (TS) requirements. The nuclear

, training department (NTD) is currently finishing a new nonlicensed operator I (Auxiliary Operator [A0]) training and qualification program designed for radwaste processing and effluent control operations. This training program will support the new organizational changes that involved l

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making radwaste operations a separate group within the operations departmen Quality assurance (QA) department is well staffed and organized to provide surveillance and audit functions when radwaste systems and programs are fully developed. All radwaste systems (solid, liquid, gaseous, process and effluent monitors, and air filtration systems) are under going calibration, preoperational testing, or development of preoperational test Within the areas inspected, no violations or deviations were identifie Two previously identified open items were closed and one open item was updated in paragraph 2. Seven new open items are listed in paragraph 3 and respectively discussed in paragraphs 6, 8, 9, 10, 11, 12, and 13.

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DETAILS , '.

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11 Persons Contacted TU Electric? w

• ML Blevins, Manager, Technical Support R. Beleckis,-- Staff. Emergency Planner

. *M. Bozeman, Manager," Chemistry / Environmental . . . ..

J.'Burnett, Radiation. Protection'(RP) Staff; Health Physicist, '

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.S.~Cassingham,- Training Coordinator, NTD '

J. , Curtis, Supervisor, RP

• G,: Davis, Open Items-Coordinator

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• R. Fishencord, Superv_isor,- RP-Radwaste , . .

.W.~ Hartshorn, Supervisor, Operations QA. Surveillance

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• D. Koss',' Administrative Assistant,: Operations Department

• S. Leuders, Supervisor, 0perations-Radwaste *

P. Leyendecker, Manager, Operations QA.. Surveillance Group

D. McAfee, Manager . Operations QA ,

W. Moore, Nonlicensed Operator Training. Specialist,.NTD M. Niemeyer, Supervisor Operations Training,'NTD

• R. Prince, Assistant Manager,'RP g

• G. Ruszaia, Operations Specialist l *E. Schmitt, Manager, RP

• J. Smith, Plant Operations Staff l W. Wells, Supervisor, Operations QA Audit. Group Others R. Warnick, Assistant Director for Inspection Programs, NRC'

S. Bitter, Resident NRC Inspector - Operations-S. Burris, Senior Resident NRC. Inspector - Operation *J..Wiebe, Lead NRC Project Inspector - Operations-F. Cobb, Lead Engineer HVAC Startup, Consultant S. Ginn, Shift Test Engineer (STE) Radwaste Processing Systems, Consultant '

R. Furushima, STE, Liquid Radwaste, Consultant F. Maddy, STE, Digital Radiation Monitoring. System (DRMS), Consultant F. Miller, Operations OA Specialist (RP), . Consultant

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'l G. Ondriska, Startup Supervisor, Consultant

• E. Ottney, Program Manager, CASE A. Pereira, QA Issue Interface, Consultant J. Sanders, Lead Engineer Instrument and Controls Startup, Consultant

• J. Waters, Site Licensing' Engineer-

• Denotes those present during .the exit interview on May 5,198 I J

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4 Followup on Previous Inspection Findines (92701]

(Closed) Open Item (445/8402-04): Sampling and Analysis of Plant Gaseous Effluents (NUREG-0737 Item II.F.1-2) - This item was previously discussed in NRC Inspection Reports 50-445/84-04, 50-445/84-25, and 50-445/84-43, and involved: potential problems with the licensee's ability to obtain representative effluent samples from the vent stack monitoring systems (X-RE-5570 A and B sample skids), lack of~an evaluation as to the dose rates to be encountered by personnel approaching the sample skids, and lack of emergency procedures to address potential radiological problems when obtaining samples under reactor accident conditions. ;The NRC inspector reviewed the consultant's study of sample line losses for Units 1 and 2 vent stack and Unit I reactor containment airborne radioactivity sampler / monitors, the licensee's evaluation.and calculations on expected personnel exposures during the manual sampling of vent stack releases under reactor accident conditions, and incorporation of the aforementioned data into plant Emergency Procedure EPP-11 The licensee's actions have adequately resolved the NRC's concerns in this are (Closed) Open Item (445/8833-45): Confirm Methods for Sampling of Liquid Wastes During A Drill - This item was previously discussed in NRC Inspection Reports 50-445/83-33 and 50-445/84-43, and involved the need for the licensee to evaluate the sampling of liquid radwaste tanks following a reactor accident. The licensee had performed an evaluation of the doses that would be incurred by plant staff personnel and addressed postaccident sampling precautions in applicable procedures (CHM-517 and EPP-117). The licensee's actions adequately resolve the NRC's concerns in this area and confirmation during a drill scenario will not be necessary since these systems would be inaccessible following a major reactor acciden (Closed) Open Item (445/8314-06): Solid Radwaste Management - This item was previously discussed in NRC Inspection Reports 50-445/83-14, 50-445/84-23, 50-445/84-42, and 50-445/85-05, and involved the licensee's completion of solid radwaste processing system preoperational testing of auxiliary connections for vendor provided processing equipment. All ,

aspects of this open item have been resolved by the licensee except for: '

(1) NRC approval of the Process Control Program; and (2) the development, f abrication, installation, and testing of the spent resin sampling device that will be part of the system used for transfer of resin to vendor supplied processing equipment. These remaining concerns will be l identified and tracked via a new open item number. These concerns are '

discussed in paragraph 10 of this repor . Open Items An open item is a matter that requires further review and evaluation by the NRC inspector or licensee. Open items are used to document, track, and ensure adequate followup on matters of concern to the NRC inspecto The following open items were discussed with the licensee during the exit l

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interview on May 5, 1989. These open items are applicable to both CPSES units, Unit 2 items will be used for. future Unit 2 inspection preparation purpose ;

Open Item Description Paragrap /8929-01; Radwaste Organizations 6-446/8929-01 445/8929-02; Liquid Radwaste System 8 446/8929-02 445/8929-03; Gaseous Radwaste System 9 446/8929-03 445/8929-04; Solid Radwaste System 10 446/8929-04 445/8929-05; Air' Cleaning' Systems 11 446/8929-05

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445/8929-06; Radiation Monitoring System ?

446/8929-06  !

l 445/8929-07; Audits and Surveillance 13 !

446/8929-07  !

4. NRC Inspector Observations The following is an observation the NRC inspector discussed with the licensee during the inspection and at the exit interview on May 5,198 This observation is not a violation, deviatinn, unresolved item, or open ]

item. This observation was identified for licensee consideration for program improvement, and the observation has no specific regulatory- I l requirements. The licensee stated that the observation is currently under I evaluatio Onsite Space for Solid Radwaste Storage - There does not appear to be adequate space for long term storage of large processed waste i

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container, such as dewatered and solidified resin liners and their  !

l shieldin . Backcround f The licensee's solid, liquid, and gaseous radwaste systems were l- extensively examined and evaluated by the NRC inspector using Final Safety.

( Analysis Report (FSAR) commitments and industry standards during the l period March 1983 through March 1985. The following NRC inspection reports and memorandum were used in preparation for this inspection:

50-445/83-14 (all), 50-445/83-16 (paragraph 15), 50-445/83-31 (all),

50-445/83-35 (paragraphs 15 and 17), 50-445/84-02 (paragraph 11),

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50-445/84-04 (all), 50-445/84-23 (a11)L 50-445/84-25-(paragraphs 2 and 3)L

.50-445/84-42. (all),: 50-445/84 .43;(a11), 50-445/85-01:(all), and

.50-445/85-05 (all)fand Memorandum For Docket' File'50-445 and 50 446,-from--

H. Chaney' to Docket File, . Subject;. Meeting Between CPSES" Representatives-and NRC,RegiontIV Personnel Concerning NUREG-0737 Action Items,-dated July'20, 1984. In.1985, the licensee.had for the most part', i satisfied all of thelNRC Region.IV' concerns regarding the construction and preoperational testing ofisolid, liquid,'and gaseous radwaste systems,.asi

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! -well.as most NUREG-0737 Action Item . . Radioactive' Waste' Management Organizatio The'NRC 1nspector reviewed the licenseets onsite organization involved'in

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radwaste management'to determine agreement with(commitments:in; ,

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Sections'11 and 13'of the FSA '

The licensee has inplace twoLgroups -of personnel that implement. the CPSE radwaste program. One group within the' operations department is relatively' new and not fully staffed-at. the-time' of this inspection. This group will be responsible for operation of plant solid,iliquid, and gaseous processing equipment,:and will be. comprised of a Radwaste .

Supervisor and a staff of approximately six'to ten specially trained nonlicensed A0s. Only the supervisor.of this group:has'been assigned and

, selection of the A0s is ongoing. 'The other group is'within the RP

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department and is fully staffe This group will be responsible'forL implementation of 30'CFR Parts 20.311 and 61 relatedtactivities, all; packaging / vendor processing of radwaste, effluent releases, and RAM transportation activities. The NRC inspector examined.po'sition'.

descriptions for key functions. CPSES site personnel are supported by a professional staff of' health'

physicists and engineers at the offsite corporate offices:in Dallas,

. Texas. Currently,'a corporate' staff member visits the site weekly or more ofte The NRC inspector examined senior management policies, program documentation, and implementing procedures and found them to be of sufficient detail and possessing adequate quality and radiological controls to ensure. compliance with TS and NRC and Department of Transportation requirements', '

This area will be considered.an open item (445/8929-01; 446/8929-01)-

pending licensee-completion of:

• The organizing and staffing of the operations-radwaste grou , ' Implementation of group specific instructions on . responsibilities and dutie No violations or deviations were identifie ; e-

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l 7.- Training an'd Qualifications The NRC ' inspector examined the licensee's program for qualification and h training.of personnel responsible for implementation'of the CPSES radwast . program to. determine agreement with commitments in Section 13 of the FSARg'

and-the requirements of NRC Inspection and Enforcement Bulletin No. 79-1 The>licenseehadimplementedahealth-physicsIqualificationcours (TRA-301) and an .A0 qualification course (Section 11 of TRA-202). .I'

l Position descriptions'for supervisors and managersLhave been developed and.'

appear'to. accurately reflect-functional dutie' HP technicians assigned to radwaste operations will or'have received ~

special training and qualifications in solid.radwaste-management, processing,'and transportation requirements. This training and qualification satisf.ies the requirements.of NRC Inspection and' Enforcement Bulletin No. 79-1 s Currently, a sufficient number of A0s (49) have been qualified 'under the standard A0 nonlicensed operator qualification program and are available to support initial operations of. Unit 1. -The licensee has prepared a special training and qualification program for A0s'that'will be permanently assigned to radwaste operations. This. training program and-others (HP, licensed operator, etc ) are scheduled to be submitted in December 1989 for peer review and national accreditatio No violations or deviations were identifie . Liquid Radioactive Waste System The NRC inspector examined the licensee's liquid radwaste system .

(Channels A, B, and C; reactor coolant drain. tanks; effluentLrelease; and the boron recycle system) to determine agreement with descriptions and--

commitments contained in Section 11 of the FSAR. .This ' system will be common to both Units 1 and The NRC inspector discussed with' licensee representatives liquid system flow paths,. process and effluent monitor locations, and current modifications to the liquid radwaste system. These modifications are to improve spent resin transfer and collection, provide attachment points for -!

a 50 gallon'per minute vendor supplied (leased) filter and 1 demineralization system, and improve the reliability of the boron' recycle  !

evaporator packag Currently, construction is still ongoing for certain J modifications, and schedules indicate that all preoperational testing- W verification via the System Functional Test Program (SFT) (licensee '

Procedures:STA-808A and.809A).should be completed by August 31, 198 l The NRC inspector examined the licensee's proposed procedures for the . l control and monitoring of liquid effluent releases. Liquid waste tank recirculation times and sampling instructions (CHM-517) were reviewed, i The licensee had purchased special simulated liquid calibration sources for performance of a full range calibration of the liquid effluent i

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monitor. This resolves the NRC's concerns raised in NRC Inspection-Report 50-445/84-23 about confirming the vendors primary calibration of

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the ir.strumen This area will be considered an open item (445/8928-02; 446/8929-02)

pending licensee completion of the following system tests and approval of the test results by the Joint Test Group-(JTG):

ICP-PT-41-01 SFT, Liquid Waste Processing System Channel "B"

ICP-PT-41-02 SFT, Waste Evaporator / Liquid Waste Processing System Channel "A" ICP-PT-41-04 SFT, Reactor Coolant Drain Tank Subsystem ICP-PT-56-01 SFT, Boron Recycle System Spent Resin Transfer and Collection System No violations or deviations were identified in this are . Gaseous Radioactive Waste System The NRC inspector examined the licensee's gaseous radwaste system (processing, storage, and effluent release systems) to determine agreement with descriptions and commitments contained in Section 11 of the'FSA This system will be common to both Units 1 and The NRC inspector discussed with the licensee the current state of the radwaste gas collection, processing, and storage system flow paths, f process equipment, and effluent release monitoring components. . Currently, ,

the licensee is developing a test matrix for completing Preoperational J Test Verification ICP-PT-61-01 SFT, which is scheduled for completion on i or about July 28, 198 The licensee is developing calibration procedures 1 for the full range calibration of gaseous effluent monitors' during the '

first refueling outage or calibration cycle of the monitor ,

This area will be considered an open item (445/8929-03; 446/8929-03) 'l pending licensee completion of: j Preoperational testing (1CP-PT-61-01 SFT) of gaseous radwaste syste Development of full range calibration procedures for gaseous effluent monitor No violations or deviations were identifie ;

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1 Solid Radioactive Waste System The NRC/ inspector' reviewed the-lic'ensee's solid.radwaste. system to

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' determine. agreement'with the. commitments in Section 11 of the FSA g f- .This system will be' common to. both Units 1 and 2.

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L The MRC inspector:reverifi$d that the licensee would 'not; be using th'eir1 .

installed ' solid radwaste' compaction and solidification systems, and.would

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be relying on offsitel vendor suppl.ied volume reduction programs.and o'nsite l provided solidification / dewatering processes. . The. licensee's Process-l Control Program for radwaste< processing is currently 'under review by;the

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The licensee is currently, modifying thE resin transfer system piping'to-ensure. sufficient flow is present to prevent solidification o'r'

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stratification ~ of. resins during transfers._ The' licensee. has not installed .

a sampling system for sampling resins being transferred to a~vendon'sl>

processing system. The NRC inspector' discussed with licensee

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representatives the need to test any spent resin' sampling' device,to ensure that' resin sampling can be performed in a. radiologically. safe manner; Flushing ~of resin transfer hoses has 'bsen addressed by the 1icensee in the design of the syste <

This-area will be co:sidered an open item (445/3929-04; 446/8929-04)

pending licensee completion of:

a Spent resin transfer system modification and' testin 'l Installation and testing of a spent resin: sampling devic I l

Receiving approval for use of the CPSES radwaste Process Control J Progra l l No violations or deviations were identifie . Air Cleaning Systems The NRC inspector discussed with licensee representatives the current'

status of preoperational testing of air' cleaning. systems for the Control Room, Primary Plant Ventilation System, Containment Pre-Access Filtration System, and the Containment Hydrogen Purge Filtration System. The l licensee's representatives stated that.the adsorber medium would be '

replaced in all systems. and fresh adsor:cer (charcoal) would be subjected j to inplace testing, as would'the high: efficiency filters; >Preoperationa .

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-testing and inspections.are being scheduled to' minimize' filter /adsorber '

-l contamination due to' construction and painting. activitie ;

q The licensee is currently balancing Unit I spaces in preparation' for l system testing and qualificatio .

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This will be considered an open item (445/8929-05; 446/8929-05)

pending licensee:

Implementation of preoperational testing and NRC review of the result Completien of Unit I ventilation and filtration system balancin No violations or deviations were identifie . Radiation Monitoring Instrumentation The NRC inspector reviewed the licensee's inplant radiation monitoring system (DRMS) for agreement with commitments in Sections 11 and 12 of the FSAR, and the requirements of NUREG-073 The licensee has completed calibration of all area radiation monitors, main steam line monitors, containment high range radiation monitors, and 12 out of 18 liquid process and effluent monitor Ventilation system monitors (5) still require calibration. The preoperational test procedures (CP-PT-7001 and 7002) for the DRMS are in final stage of JTG revie Preoperational testing is scheduled to begin on or about June 4, 198 This area will be considered an open item (445/8929-06; 446/8929-06)

pending licensee:

Completion of instrument calibration Completion of functional testing of the DRM Finalizing of DRMS setpoints and establishing administrative control over the DRM No violations or deviations were identifie '

13. Audits and Reviews ,

The NRC inspector reviewed the staffing, auditor qualifications, audit and surveillance implementing procedures, results of HP/RP audits, audit / surveillance checklists, procedure compliance data base (cross reference of surveillance by procedure) for developing audits, and licensee's program for tracking and closure of audit / surveillance i finding The licensee's audit and surveillance program is well documented, staffed with qualified personnel, and has developed and implemented performance based surveillance and audits of licensee activities. The QA audit of the RP program (TUG-88-12) was effective in identifying two deficient conditions of a minor nature. This audit was comprehensive

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and verified the licensee's' compliance with implementing procedures'and NRC regulation The licensee had not' initiated an audit of the radwaste program. An audit of the HP and operations department's' activities concerning redwaste and RAM transportation is scheduled to be completed. '

prior to fuel loa This area will be' considered an open item (445/8929-07; 446/8929-07)

pending licensee:

Completion of a comprehensive compliance audit of the radwaste progra No violations or deviations were identifie . Exit Interview The NRC inspector met with licensee re' preventatives identified in paragraph 1.at the conclusion of the inspection on May 5, 1989. The NRC inspector stated that actions had been completed'to resolve some old open items in the radwaste area and that the remaining item and new items should be completed prior to issuance of an operating licensee unless otherwise indicated in the report.

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