IR 05000445/1989050
| ML20246N552 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/25/1989 |
| From: | Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20246N544 | List: |
| References | |
| RTR-NUREG-0041, RTR-NUREG-0737, RTR-NUREG-41, RTR-NUREG-737, RTR-NUREG-CR-1063, RTR-REGGD-01.008, RTR-REGGD-08.002, RTR-REGGD-1.008, RTR-REGGD-8.002 50-445-89-50, 50-446-89-50, 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 8909080150 | |
| Download: ML20246N552 (10) | |
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l APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Reporti 50-445/89-50 Construction Permit:
CPPR-126 50-446/99-50 CPPR-127 Dockets:
50-445 50-446 Licensee: TU Electric
Skyway Tower 400 North Olive,_L.B. 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES)
Inspection At:
CPSES, Glen Rose, Somerville County, Texas Inspection Conducted: July 17-21,1989 Fbs M Inspector:
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y. T_ Ricketson, P.E., Radiation Specialist
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/Facilitier Radiologicci Protection Section
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Approved:
U T 27!#9 mE. Baer, Chief, Facilities Radiological Date
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Protection Section Inspection Summary Inspection Conducted July 17-21, 1989 (Report 50-445/89-50: 50-446/89-50)
Areas Inspected:
Routine, unannounced inspection of the applice.nt's radiation protection (RP) program including organization and management controls, training and qualifications, external exposure controls, internal expcsure controls, control of radioactive materials and contamination, and facilities and equipment.
Results: Within the areas inspected, no violations or deviations were ideatified. Two open items were identified involving:
radiation levels around the fuel transfer +.ube and procedures for calculating radiation dose to the skin.
The applicant is making good progress toward implementing a RP program to suppert plant operation.
In order to bcister operational RP experience, the applicant has committed to supplementing the existing staff with cor< tract
I technicians prior to startup. Procedures were in place to ensure proper 8909080100 E:90825 PDR ADOCK 05000445
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oversite by corporate personnel'and onsite management. RP technicians are
L qualified in accordance with industry standards.
General Employee Training (GET)' was found to be adequate. The dosimetry program has been reaccredited and most operating procedures were in place.
The applicant has established a program for performing in-vivo testing for internal contamination and has retained a contractor for in vitro testing. An adequate inventory of respiratory protection equipment was available and procedures were -in place for distribution, maintenance, and quality control. Most necessary procedures were in place to ensure the prevention of the spread of radioactive contamination; however, a hot particle control program had still not been formalized. Area monitors were in place and calibrated.
RP facilities were as described in the Final Safety Analysis Report (FSAR).
Portal monitors and personnel contamination monitors (PCM) had not been put into operation.
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DETAILS
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Persons Contacted TU Electric
- M. R. Blevins, Nuclear Operations Support Manager
- J. R. Waters, Site Licensing Engineer J. R. Curtis, RP Supervisor S. W. Swan, Technical Training Supervisor A. H. Redlow, RP Supervisor G. D. Jones, RP Supervisor S. E. Bradley, Senior Engineer
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W. G. Hartshorn, Quality Assurance (QA) Operations Surveillance Supervisor C. L. Mansfield, Engineer F. P. Miller, QA Auditor
- D. W.. Fuller,' Training Specialist, Nuclear
- J. Smith, Plant Operations Staff NRC
- R. E. Baer, Chief, Facilities Radiological Protection Section
- J. S. Wiebe, Lead Project Inspector
- Denotes those present at the exit interview on July 21, 1989.
2.
Action on Previous Inspection Findings (0 pen) Open Item (445/8942-01; 446/8942-01):
Hot Particle Identification and Control Program - The applicant is developing Procedure RPI-612 which will be the basis for the hot particle program. This item remains open until the procedure has been approved and implemented.
(Closed) Open Item (445/8942-02; 446/8942-02):
Startup Shield Survey Procedure - The inspector reviewed Procedure HPI-604, " Biological Shield Survey," which follows the guidance of ANSI /ANS 6.3.1 - 1980. The procedure is currently being revised to simplify the survey maps included and to more clearly list the penetrations which are to be surveyed. The proposed procedure appears adequate to close this item.
(0 pen) Open Item (445/8942-03; 446/8942 'J3):
Instrumentation and Operability - It was noted by the inspector that the installation of PCMs at the exits to the radiological.ontrolleo area and the reactor building had not been completed. This iten is being expanded to include the portal monitors at the primary and alternate access point exits.
Placement of both types of instrumentation has not been completed.
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-The applicant's representatives stated that this was intentional to
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Six PCMs and seven portal monitors were available. This remains an open item pending insta'lation and calibration of instrumentation prior to
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initial criticality.
3.
Open Items Identified During This Inspection 1 An open item is a matter that requires further review and evaluation by the' inspector.or applicant. Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector.
.The-following open items were discussed with the applicant during the exit meeting:
Open' Item Description Paragraph
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.445/8950-01; Skin Dose Calculation Procedure
446/8950-01 for Individuals Immersed in Noble Gas Atmospheres 445/8950-02; Fuel Transfer Tube Radiation
446/8950-02-Levels 4.
Inspector's Observations The following are observations the inspector discussed with the applicant during the exit interview on July 21, 1989. These observations are not violations, deviations, unresolved items, or open items. These
' observations were identified for applicant consideration for program
~ improvement, but the observations have no specific regulatory
. requirements, a.
Training for NRC Personnel - Although specific training had been developed for NRC personnel, members of th? applicant's training staff responsible for scheduling such training were unfamiliar with its existence; consequently, some inspectors were enrolled in the wrong training class. Training management stated that a memorandum would be circulated to the staff to ensure their familiarity with training necessary for NRC personnel.
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Verification of Posting and Controls of High Radiation Areas and Extremely High Radiation Areas - Procedure RPI-602, " Radiological Surveillance and Posting," only requires verification of posting and controls in these areas be performed weekly. The inspector discussed the need to verify these areas on a more frequent schedule.
c.
The term " background radiation level" is not defined ir Procedures STA-652, " Radioactive Materials Control," or RPI-602, " Radiological Surveillance and Posting," which contain survey procedures and contamination and release limits.
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5.
Organization and Management Controls -(83522).
.The inspector examined the applicant's onsite organization regarding RP activities to. determine compliance with the FSAR commitments and the.
recommendations of URC Regulatory. Guides (RGs) 1.8, 8.2, and 8.8.
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The management structure'was described in NRC Inspection A
Report 50-445/89-42; 50-446/89-42.
Regarding staffing, RP management
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stated that approximately ten' contract RP technicians with operating plant
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- experience will be' employed before startup to supplement the existing staff members, many of'whom have only 6perating experience acquired while
. working.during outages at othet facilities. Contract technicians will'
also be used after startup on a permanent basis.
E There had been no' additional audits of RP since NRC Inspectior.
Report 50-445/89-42; 50-446/89-42. The 1989 audit is scheduled for August.- The inspector reviewed the audit, TEL-88-2, performed on the supplier of bioassay. services (see paragraph 8).
The audit was of adequate depth and identified two deficiencies. The vendor's responses were acceptable and the company remained on the applicant's approved vendors list.
NRC Inspection Report 50-445/89-42; 50-446/89-42 identified that the individual who had been performing QA surveillance had taken a position in the training department and a replacement had already been selected.
The QA operations surveillance supervisor contacted the inspector to inform him of a. change in plans. The current plan is to use qualified personnel from the corporate office to perform surveillance.
' Procedure STA-510, " Plant Management Monitoring Drograms," requires that managers visit work areas on at least a quarterly basis for the purpose of evaluating the performance of the staff.
- The ir,spector reviewed Procedures TID-201, " Radiation Protection Program Review," and TID-202, " Trending of Radiological Performance Indicators,"
which provide corporate oversite for the RP audit program. The inspector also reviewed a report of the " Pre-operational Readiness Review" performed February 29 through June 30, 1988.
No violations or deviations were identified.
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Training and Qualifications (83523)
The inspector reviewed the applicant's training program and RP parsonnel's qualifications to determine compliance with FSAR commitments; 10 CFR Part 19.12 requirements; and the recommendations of ANSI N18.1-1971, NRC
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RGs 8.13, 8.27, 8.29, and 8.8; NUREG 0041; NRC Radiological Assessment Branch Position statement of August 5, 1982 (qualifications for RP
.tnanagers); and NRC staff position' statement of October 1, 1981 (health physics technician qualification criteria).
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The manag; ment-structure of RP.was discussed in NRC Inspection L-Report 50-445/89-42; 50-446/89-42. The inspector reviewed resumes of the
RP technicians and verified that they were qualified in accordance with
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ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel." As noted-in paragraph 1, many of the applicant's RP
. technicians have limited experience at operating nuclear power plants; therefore, the applicant plans to supplement the existing RP' staff with contract personnel.
The inspector evaluated the refresher GET and verified that topics discussed included:
safety, security, emergency planning, fire protection,. quality control, and RP. Two sets of exams were used
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following the lecture and a passing grade of 70 percent was required. The inspector noted that the GET included a discussion of " current events,"
which was a review of. incidents occurring at other facilities. The GET instructor appeared knowledgeable and adequately prepared. The GET handout given to the inspector at the start of the class was outdated (February 6,1989, instead of May 19,1989) and apparently was not purged
._ hen the latest' revision was made.
The instructor and the inspector w
failed to find other outdated copies in the stack of handout material; therefore, it was presumed that this was an isolated case.
Training courses for radiation workers and respiratory protection, as well as practical exercises, were evaluated during NRC Inspection Report.50-445/89-42; 50-446/89-42 and found to be adequate.
No. violations or deviations were identified.
7.
. External Exposure Control (83524)
The inspector reviewed the applicant's external exposure control program to determine compliance with FSAR commitments; 10 CFR Parts 19.13, 20.1, 20.101, 20.102, 20.104, 20.105, 20,202, 20.401, and 20.408 requirements; and the recommendations of NRC RGs 8.2, 8.4, 8.7, 8.8, 8.14, and 8.28; ANSI N13.2'1969, ANSI N13.27-1981, and ANSI N319-1976; snd NUREGs/CR-1063,
-1064, and 1304. The applicant uses four element thermoluminescent dosimeters (TLD) for monitoring whole body exposure and will also use the devices, along with ring badges, for determining extremity exposure. The dosimetry program has been reaccredited in all categories by the National Voluntary Laboratory Accreditation Program in accordance with 10 CFR 20.202(c). The applicant has a contract with a vendor to provide emergency backup service.
shere appears to be adequate staffing in the dosimetry section for startup I
and operation. There is a full time records clerk. Other support personnel are employed by the same department in the personnel processing L
center.
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The applicant has begun issuing dosimetry in anticipation of plant start-up.
Information resulting from the use of TLDs will be compared with that from pocket dosimeters to ensure that the two methods are in agreement (within plus or minus 20 percent).
Required actions and action levels are established in Procedure STA-655, " Exposure Monitoring Program."
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The applicant's representative stated the VARSKIN code would be used for calculating skin doses due to hot particles and that other methods were being explored to refine calculations.
Current!y, there is no established procedure for computing skin doses for individuals who have been immersed in noble gas atmospheres. The supervisor of dosimetry stated that a formal skin dose procedure will be developed and added to the dosimetry procedures. This is considered an open item pending approval and implementation of the procedure.
(445/8950-01; 446/8950-01)
The inspector reviewed procedures for routine and nonrcutine notification
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of exposure data and found them to be adequate. The inspector reviewed the following procedures which are germane to this area:
I.D. Number Title RPI-509
" Personnel Dosimetry Processing Program" RPI-510
" Numbering / Coding of TLD Badges" RPI-511
" Operation of the Panasonic Manual TLD Reader" RPI-512
" Calibration of the Panasonic Manual TLD Reader" RPI-513
"TLD Selection and ECF Determination" RPI-514
" Maintenance of the Panasonic Manual TLD Reader" RPI-515
" Neutron Dose Measurement" RPI-516
" Dose Determination" RPI-517
" Operation of the Panasonic Automatic TLD Reader" l
RPI-518
" Calibration of the Panasonic Automatic TLD Reader" RPI-519
" Maintenance of the Panasonic Automatic TLD Reader" RPI-521
" General Area Monitoring Badges" RPI-523
" Operation of Pocket Alarming Dosimeters" RPI-524
" Calibration of Pocket Alarming Dosimeters" RPI-525
" Verification and Testing of Pocket Dosimeters"
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RPI-527
" Testing and QC of Personnel Dosimetry Processing"
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RPI-528
" Multiple Dosimetry Badging"
RPI-529
"TLD Irradiation" STA-ESS
" Exposure Monitoring Program" No violations or deviations were identified.
8.
Internal Exposure Controls (83525)
The inspector reviewed the applicant's program for control and measurement of internal radiation exposure to determine compiiance with FSAR l~
commitments; 10 CFR Parts 20.103, 20.201, 20.203, and 20.401 requirements; the recommendations of NRC RGs 8.2, 8.7, 8.8, 8.9, 8.15, 8.20, 8.26, and
8.27; ANSI N343-1978; and NUREG+0041.
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g-Currently.cthe applicant has the capability for performing w Lle body and thyroid counting.
Investigative levels are set at 10 percent ~
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of: the recommended body burdens._ Operating procedures, calibration sourcer,.and pnantoms wert avsilable. A contractor har been retained to-perform bioassays for tritium and.'is on the^ applicant's approved vendor listJ The services:of the contractor would also be used for fec41 analysis, blood work,' etc..should the need arise.
Only respiratory equipment' approved by.the National Institute of Occupational Safety and Health (NIOSH)~ is used. Air cylinders are inspected monthly.. Fit testing procedures were observed during the previous NRC inspection of this area and found to be adequate. The inspector noted that while the procedures prohibit facial hair,.which.
could prevent a proper seal, the applicant.has no provisions to provide.
razors for use in' emergency situations.
.A medical screening examination:is required before an individual.is issued-a respirator.. The inspector tested the system by requesting a fit test and was denied because records showed that he had no record of a medical examination.
The inspector again challenged the respirator issue system at access control.and was rightfully denied a respirator because he did not meet the-applicant's qualification requirements.
Currently., the applicant uses only self-contained breathing apparatuses
.with compressed air, which are routinely tested.for proper air quality.
Instrument air may be used in the future for supplied breathing air, in which case, it also will be tested for proper quality.
The inspector rev.iewed the following procedures which are germane to this'
area:
I.D. Number Title RPI-500
" Bioassay Program" RPI-501
" Indirect Bioassay Sampling" RPI-502
" Operation of the ND WBC/9845 System" RPI-503
" Calibration of the Stand-up WBC" RPI-504
" Calibration of the ND WBC/9845 System" RPI-SO5
" Estimation of Airborne Radioactivity" RPI-506
"MPC-HR Tracking" RPI-507
" Internal Dose Calculations" No violations or deviations were identified.
9.
Control of. Radioactive Material and Contamination; Surveying and Monitccing (83526)
The applicant's programs for the control of radioactive materials and contamination, radiological surveys, and monitoring were examined for agreement with commitments in the FSAR; ccmpliance with the requirements Lw
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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.
All area radiation monitors are in place and calibrated. The inspector confirmed that the placement of the monitors agreed with the locations
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'specified in the FSAR. The calibration of selected monitors was also-verified.
A-sufficient inventory of protective clothing,. respiratory protection
' equipment, survey instrumentation, air monitoring equipment, and portable sampling equipment;were available.
A survey schedule has been established and implemented where' appropriate (in fuel storage area, for example).
Survey records were reviewed during the previous NRC ~ inspection of this ' area. Calibrated portable survey instruments were evailable in sufficient quantities.
The inspector' reviewed'the following procedures which are germane to this area:
I.D. Number Title STA-620.
" Containment Entry" STA-652
" Radioactive Material Control" STA-660
" Control of High Radiation Areas" RPI-600
" Radiological Surveillance and Posting" STA-653
" Radioactive Waste and Contamination Minimization Program" STA-654
" Personnel Contamination Control" RPI-400
" Decontamination Program" RPI-402
" Personnel Decontamination" RPI-601
" Radiation Survey" RPI-602
" Contamination Survey" RPI-603
" Airborne Radioactivity Survey" RPI-604
"Biologira1 Shield Survey" RPI-605
" Fire Response" RPI-610
" Radiography Controls" RPI-611
" Radiological Diving Controls" RPI-108
" Investigation and Evaluation of Radiological Incidents" STA-501
"Nonroutine Reporting" STA-502
" Routine Raporting" STA-503
" Plant Incident Report" No violations or deviations were identified.
10.
Facilities and Ecuipment (83527)
l The inspector reviewed the following areas for commitments with the description given in Amendment 76 to the FSAR:
RP and access control facilities, the turbine building north / south corridor (gathering area for individuals preparing to enter the radiation controlled area [RCA]),
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-locker rooms, access control office, the east / west corridor (entry into
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RCA), personnel decontamination room, hot' lab, chemistry counting room,
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i chemistry cold lab, and laundry room. All ereas appeared to be in agreement with FSAR commitments..
The inspector reviewed the spent. fuel. transfer area to determine agreement with.the information discussed in NRC Bu11etin.78-08. A small section of, the fuel element transfer tube is unshielded in a' manner described'in Bu11etin.78-08, making it possible for dose rates to exist in the area.in the order of 108 to 10 rems per hour (according to'the applicant's calculations). Access to this area is relatively easy. A fence and locked gate currently control the area;'however, the applicant's own calculations show that this would not prevent the' possibility of a person in,the area receiving radiation exposure in excess of allowable limits.
The licensee has prepared a proposed design modification to' correct the
. situation. This is considered an open item unti1~such action is taken to prevent likelihood of an individual in the area receiving such an exposure Action on this item must be completed before transfer of spent fuel through the transfer tube.
(445/8950-02; 446/8950-02)
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No violations or' deviations were identifieo.
11.
Exit Interview The inspector n'et with the NRC resident inspector and licensee representatives denoted in paragraph'I on July. 21, 1989, and summarized
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-the scope and findings of the inspection as presented in this report.
Licensee representatives acknowledged their understanding of the inspection findings.
The licensee did not identify as proprietary, any of the materials provided to or reviewed by the inspector during the inspection.
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