IR 05000445/1989042
| ML20247L225 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/17/1989 |
| From: | Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247L215 | List: |
| References | |
| TASK-3.D.3.3, TASK-TM 50-445-89-42, 50-446-89-42, IEIN-86-023, IEIN-86-043, IEIN-86-23, IEIN-86-43, IEIN-87-039, IEIN-87-39, IEIN-88-063, IEIN-88-63, NUDOCS 8908010188 | |
| Download: ML20247L225 (9) | |
Text
_ _ _ _ _ _ _ _.
-
cy,
>.
J.
..
.
,
.
'
,
<-
APPENDIX-U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC_ Inspection Report: 50-445/89-42 Construction _ Permits: CPPR-126 50-446/89-42 CPPR-127-Docketsi.50-445-50-446
' Licensee: TU Electric.
400 North Olive, L.B. 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Elect ic Station (CPSES)
' Inspection.At: CPSES, Glen Rose, Somerville County, Texas
. Inspection Conducted: June 5-9, 1989 Inspector:
[f h
[)bdI[
7//7/
'
L. T.' Ri'cketson,' P'.E., Radiation Specialist Oate /-
Facilities Radiological Protection Section Accompanied By:
R. E. Baer, Chief, Facilities Radiological Protection Section Approved-
Mk O
R.E~.Baer, Chief,FacifitiesRadiological Cate /
'
g)[O Protection Section
>
Inspection Summary Inspection Conducted June 5-9,1989 (Report 50-445/89-42; 50-446/89-42)
Areas Inspected:
Routine, unannounced inipection of the licensee's radiation protection (RP) programs organization and management controls (83522), training and qualifications (83523), external exposure controls (83524), internal exposure controls (83525), controls of radioactive materials and contamination
-(83526), facilities and equipment (83527), and the ALARA program (83528).
Results:. Within the areas inspected, nc violations or deviations were identified.
Four open items were identified involving: a hot particle program, startup shield procedures, instrumentation'and operability, and the representation of ALARA personnel in the work control organization-.
89080101se spo73g gDR ADOCK 05000445 PDC
.--
. _ _ _ _
')
.
- *
,
,
..
Management controls were in place and found to be adequate. Staffing appeared to lack depth in1some areas of the RP program. The training program for respiratory protection, radiation worker, and health physics (HP) technicians were found to be adequate. Equipment was state-of-the-art in both ir,ternal and external exposure control. Adequate measures' appear to be in place for control of radioactive materials and contamination.
,
i l
l'
l-
{L--_ _...
- -. _ _ _ _ _ _ _
-
.
.
.
DETAILS 1.
Persons Contacted TU Electric
- W. J. Cahill, Executive Vice President, Nuclear Engineering and Operations J. J. Kelley, Plant Manager
- E. J. Schmitt, RP Manager
- R. J. Prince, Assistant RP Manager R. E. Fishencord. RP Supervisor J. R. Curtis, RP Supervisor A. H. Redlow, RP Supervisor G. D. Jones, RP Supervisor J. F. McMahon, Manager, Nuclear Training
- D. L. Hubbard, Technical Staff Training Manager
- S. W. Swan, Technical Training Supervisor
- A. Reiff, Program Coordinator, RP Training S. E. Bradley, Engineering Senior D. M. McAfee, Quality Assurance (QA) Manager B. W. Walls, QA Audit Group Leader W. G. Hartshorn, QA Operations Surveillance Supervisor
- F.
P. Miller, QA Auditor A. Pereira, QA Issue Interface NRC
- R. F. Warnick, Assistant Director for Inspection Programs, CPPD, NRR
- M. Malloy, Project Manager
- J. S. Wiebe, Lead Project Inspector
~S. D. Bitter, Resident Inspector, Operations Other
- E. Ottney, Program Manager, Citizens Association for Sound Energy
- Denotes those present at the exit meeting on June 9, 1989.
2.
Open Item Identified During This Inspection An open item is a matter that requires further review and evaluation by the NRC inspectors or licensee. Open-items are used to document, track, and ensure adequate followup on matters of concern to the NRC inspectors.
The following open item was discussed with the licensee during the exit l
meeting.
Open Item Description Paragraph 445/8942-01; Hot Particle Identification 446/8942-01 and Control Program
_ - _ _ _ _ _ - _. _
ru -
,c
,.
..
q
.
.
, :.
(
,
L 445/8942-02; Startup Shield Test Procedure
,446/8942-02
445/8942-03; Instrumentation and Operability 446/8942-03
445/8942-04; ALARA Personnel Involvement in 446/8942-04 the Work Control Organization
3.
Inspectors' Observations The following are observations the NRC inspectors discussed with the licensee during the exit interview on June 9, 1989. These observations are n'ot' violations, deviations, unresolved items, or open. items.
These observations were identified for licensee consideration, for program improvement, but the observations have no specific regulatory requirements. The licensee stated that these observations would be evaluated.
a.
' Training program Practical Factors - The licensee did not devote enough time to critique individuals after practical factors training exercises (see paragraph 5).
b.
Training and Emergency Plan Clothing - The licensee had not uniquely identified protective clothing used for training and emergency plan so that it would be kept separate from other clothing used in the plant (see' paragraph 5).
c.
- Plant Systems Training for ALARA Personnel - The licensee had not developed and. implemented a comprehensive training program of plant systems for individuals assigned to the ALARA program (see paragraph 10).
4.
Organization and Management Controls (83522)
The NRC inspectors examined the licensee's organization regarding FP activities for CPSES to determine compliance with the Final Safety Analysis Report (FSAR) commitments; recommendations of NRC Regulatory
' Guides _(RGs) 1.8, 8.2, 8.8, NUREG-0731, and ANSI.N18.1-1971; NRC Radiological Assessment Branch Position statement of August 5, 1982 (qualifications for RP managers); NRC staff position statement of October 1, 1981 (HP technician qualification criteria years of experience); the licensee's internal audit / review program regarding RP activities to determine compliance with FSAR commitments; the requirements of 10 CFR Part 50, Appendix B; and the recommendations of ANSI N18.7-1976,
'
N45.2.12-1977, and NRC RG 1.144.
The NRC inspectors reviewed the organizational structure, management directives, and policy statements and found them adequate. The NRC l
inspectors verified that RP personnel had been given the authority to stop i
work then they consider conditions to be unsafe.
_ _ _ _ _ _ _. _. _ _ _ _ _. - _. _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _... _ _ _ _ _.. _ _ _. _ _ _ _ _ _ _
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.. _ _ _ _.. _ _ _ _ _ _ _ _. _ _. _ -. _ _ _ _ _. _, _ _ _ _ _. _ _ _. _ _. _ _.. _
_ _ _ _.
___ ______-
)}, "
.
.
~
The management structure of the RP program consisted of the manager, assistant manager, and four RP supervisors.
Reporting to the RP supervisors were.11 RP senior technicians (lead techni:1ans or specialists) and approximately 22 technicians. All personnel' satisfied the qualification of ANSI Standard N18.1.
In reviewing the staffing, the NRC' inspectors noted a lack of depth in some positions due to the extent-of specialization in the RP program.
For example, only two people were qualified (or in training to be qualified) to inspect and maintain respirators.
The NRC inspectors reviewed the results of licensee Audits TUG 87-11,
"
TUG 87-22, and TUG 88-12 performed May 11-15, 1987; August 31 through September 4,.1987; and July 11-15, 1988, respectively. The audits covered various aspects lof the RP program and appeared to have adequate depth.
In addition to site personnel, both consultant and corporate auditors were-used.
The NRC inspectors reviewed the qualifications of the auditors and determined that they were adequate.
The NRC inspectors noted.that QA group was persistent in its pursuf t of responses to deficiencies and assurance of corrective actions were verified.
The NRC_ inspectors also reviewed selected surveillance and determined that they were of adequate' depth. According to the quality surveillance manager, one individual had responsibility to perform surveillance involving RP, but has taken a position in training. A replacement has been selected. The possibility of crosstraining of auditors was discussed as a means of adding depth in this area.
Checklists'for surveillance of many procedures have been developed by the previous auditors and are available as guidance.to the new auditor.
No violations or deviations were identified.
5.
Training'and Qualifications (83523)
The NRC inspectors rev$ewed the licensee's RP training program for CPSES personnel to determine compliance with FSAR commitments; 10 CFR Part 19.12 requirements; and the recommendations of ANSI N18.1-1971, NRC RGs 8.13, 8.27, 8.29, and 8.8, and NUREG-0041.
The NRC inspectors attended selected classes and observed practical exercises. Selected outlines and lesson plans were reviewed and
,
l determined to be acceptable. The NRC inspectors observed some individuals l
involved in the simulated controlled access practical exercises who did I
not follow the suggested undressing order, even though guidance was posted in the area.
In some cases, the individuals were corrected by the instructor; however, there appeared to be no thorough, individual critique given to the participants af ter completion of the exercise.
The NRC inspectors noted the use of mockups in training for steam generator work and discussed the use of training aids for jobs involving the steam generators.
!
l
-
_ _ _ _
_ - _.._
_ _ - _ -
_-
_
-
.-.
.
. J,:.:.,
'
+
6.
%
The' licensee uses video taping equipment in some radiation worker training exercises to allow individuals to review their own performance.
The NRC inspectors noted also that protective clothing used in the practical exercises was not marked in a mannerLwhich would identify it as belonging exclusively to the training department..The NRC. inspectors
.
observed:that such. identification should keep the protective clothing from being laundered with that from the rest ~of the plant, thereby' eliminating the possibility of contamination or spread of hot particles.
Qualifications of select staff members were reviewed and found to be adequate.
No violations or deviations were identified.
6.
External Exposure Controls (83524)
The NRC inspectors reviewed.the licensee's external exposure control program to determine compliance with FSAR commitments; 10 CFR Parts 19.13, 20.1, 20.101, 10.102, 20.104, 20.105, 20.202, 20.401, and 20.408; and the recommendations of NRC RGs 8.2, 8.4, 8.7, 8.8, 8.14, 8.28, and N13.2-1969, ANSI N13.27-1981, N319-1976, a-t NUREG/CR-1063, 1064, and 1304.
The NRC inspectors reviewed the dosimetry program and noted that the licensee has-state-of-the-art equipment and an-adequate _ supply of thermoluminercent dosimeters. The dosimetry program complies with 10 CFR 20.202(c)(1), having been accredited in all eight categories by the National Voluntary Laboratory Accreditation. P-ogram (NVLAP) in 1987 and anticipating renewal of the accreditation shorcly.
The NRC inspectors'noted that the M censee had not developed a hot particle control program. The individual responsible for developing the program was on leave and, thus, was unavailable +o discuss the status of
'the program.
This is considered an open item psnding licesee action to implement a hot particle identification and control program prior to full power testing.
(445/8942-01; 446/8942-01)
!.
No violations or deviations were identified.
7.
Internal Exposure Controls (83525)
The NRC inspectors reviewed the licensee's program for cont-ol and measurement of internal radiation exposure to determine compliance with:
FSAR commitments; the requirements of 10 CFR Parts 20.103, 20,201, 10.203, and 20.401; the recommendations of NRC RGs 8.2, 8.7, 8.8, 8.9, 8.15, 8.20, 8.26, and B.27; and the recommendations of ANSI N343-1978 and NUREG-004 _ _ _ _ _ _ _ _ _ _ _ _
..
i
.
.,
,
i o
i
l
The NRC inspectors observed that the licensee had state-of-the-art equipment for performing fast scan whole body counts and for performing respirator fit testing.
The NRC inspectors reviewed implementing
!
procedures and found them to be adequate.
I No violations or deviations were ioentified.
8.
Control of Radioactive Materials and Contamination, Surveying, and
)
Monitoring
'
The licensee's programs for the control of radioactive materials and i
contamination, radiological surveys, and monitoring were examined for
'
agreement with: commitments in the FSAR; compliance with the requiremerits of 10 CFR Parts 19.12, 20.5, 20.201, 20.203, 20.205, 20.207, 20.301,
'
20.401, 20.402, and NUREG-0737, Item III.D.3.3; and the recommendations of IEINs 86-23, 86-43, 87-39, and 88-63.
The NRC inspectors reviewed procedures for access control and found them to be acceptable. The NRC inspectors interviewed technicians about their duties and responsibilities and found them to be knowledgeable.
Records of radiation surveys were examined and found to be adequate; however, it was noted that the due date for calibration for the instrument used was not included as part of the record. While this is not a requirement, it would, prevent an instrument not in current calibration from being used to perform surveys. An adequate supply of survey instruments was available.
Startup survey procedures will be reviewed during a future inspection to verify their adequacy as defined by guidance in ANSI Standard 6.3.1.
This is considered an open item pending review of startup shield survey procedures.
(445/8942-02; 446/8942-02)
No violations or deviations were identified.
9.
Facilities and Equipment (83527)
Facilities were reviewed and appeared to be adequate, but were not compared in depth with the commitmer;ts in the FSAR at this time.
_
_ _ _ _ _ - - - _ _ _ _ _
-
_
__
.__
._
__
._
._
_
.-
-
- _ - _
.. _
..,
.
m 8'
o l
Facilities examined included:
access control, radiation staff inplant j
officesi-protective clothing storage area, instrumentation. storage area, I
' locker areas, and personnel decontamination. area.
Facilities will be examined further during a future inspection.
The NRC inspectors noted that the licensee had not completed installation of the personnel contamination monitors (PCMs)'at the exit to the
.
radiologically controlled area and the reactor. building.
The licensee had not completed the design for the exit control.from the reactor building.
.This is considered an open' item pending. licensee completion of~ exit designs and installation of the PCMs prior to initial criticality.
(445/8942-03;.446/8942-03)
No violations or deviations were identified..
10. ALARA~ '(83528)-
The NRC inspectors reviewed the licensee's ALARA program.to determine agreement with FSAR commitments and the recommendations of NRC RGs 8.8 and'
8.10.
The NRC inspectors initially had a concern that ALARA persor.nel were not-involved in.the early stages of scheduling of work, thereby not allowing adequate time for a proper review. This concern was discussed with the managers of work control and RP.
The managers presented the NRC inspectors with a proposed organizational chart of the Work Control Center dated May 26,.1989, which showed the inclusion of HP personnel. The RP manager confirmed that HP. personnel were to be the ALARA representatives.
The proposed organizational structure will adequately address'the NRC's concern, but will be. considered an open item (445/8942-04; 446/8942-04)
until the organization has been implemented as represented prior to full power testing.
The NRC inspectors noted that the individuals performing ALARA reviews of-work packages did not have a good knowledge of plant systems.
The.NRC inspectors noted that the ALARA program included dryrun training prior to the implementation of certain procedures. This was in keeping with good practice and should aid in reducing overall radiation dose.
Another progressive practice initiated by the ALARA group was the planned purchase and use of a " surrogate tour", which is a series of perhaps as many as 50,000 photographs taken inside the plant, stored on a laser disk, and accessed by computer.
It will be used by different departments and when used for planning work should be helpful in reducing radiation
,
exposures.
L No violations or deviations were identifie _ _ _ _ _ _ _ _ _ _ _ _ -
.s.
.....
,
.
11.
Exit Meeting The NRC inspectors met with the licensee and other NRC representatives as denoted in paragrepi 1 on June 9, 1989, and summarized the scope and findings.of the 1',ispection as presented in this report.
Licensee representatives acknowledged their understanding of the inspection findings.
!
!
l i
l
1
l
!
l
!
_ _ _ _ _.. _ _ _ _ _..
- _