IR 05000445/1990018

Insp Repts 50-445/90-18 & 50-446/90-18 on 900430-0504.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Program,Including Organization & Mgt Controls,Training & Qualifications & External Exposure

ML20043E172
Person / Time
Site:	Comanche Peak
Issue date:	06/01/1990
From:	Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20043E171	List: IR 05000445/1990018
References
50-445-90-18, 50-446-90-18, NUDOCS 9006120142
Download: ML20043E172 (11)

Text

{{#Wiki_filter:.. o , -. . . . APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-445/90-18 Operating License: NPF-28 50-446/90-18 Construction Permit: CPPR-127 , - Dockets: 50-445 - 50-446 Licensee: TV 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 i Inspection Conducted: April 30 through May 4, 1990 Inspector: dekwse ? 4- /- 96 , L. T. Ric$ son,\\AA., Lenior Radiation Date Sp ialist ! s (,, W , Approved: c 4 - /- SO m 4 B. Aurra~y, Chief Facilities Radiological Fate Protection Section x Inspection Summary Inspection Conducted April 30 through May 4, 1990 (Report 50-445/90-18; 50-446/90-18) Areas Inspected: Routine, unannounced inspection of the licensee radiation protection (RP) program including organization and management controls, training and qualifications, external exposure controls, internal exposure controls, control of radioactive materials and contamination, and ALARA program, o

osults

Within the areas inspected, no violations or deviations were identified. The licensee's RP program was fully staffed and staff members met the required qualifications. Training programs for radiation workers and RP workers were fully implemented and appeared adequate. A comprehensive mock-up

' training program had been implemented to support the ALARA program.

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radiological: controlled area (RCA)'had been established and controls appeared '

.i > adequate to maintain personnel exposures low and prevent the spread of I

radioactive contamination.

Preliminery shield surveys results indicated'that ! plant radiation levels are-in agreement with'the levels predicted in the Final-i

> _ .' -# - Safety Analysis Report.(FSAR). The ALARA' program was aggressively, pursuing:

- means to maintain, low personnel exposures. Only a<1imited number of Quality

- Assurance-(QA) surveillances had been performed.

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^ DETAILS l 1.

Persons Contacted TV Electric (TUEJ

• E. J. Schmitt, Radiation Protection Manager R._J. Prince, Assistant RP Manager
• D. C. Kay, Senior Engineer, Corporate Health Physics J. R. Curtis, Surveillance and Control Supervisor R. E. Fishencord, Radioactive Material Control Supervisor G. D. Jones, Dosimetry Supervisor S. E. Bradley, ALARA Supervisor

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• J. F. McMahon, Nuclear Training Manager
• L. Barnes, Technical Staff Training Manager
• A. T. Reiff, RP Training Program Coordinator
• W. G. Westhoff, Quality Operations Manager
• D. R. Leech, Quality Specialist S. M. Lehman, Quality Specialist
• G. J. Laughlin, Instruments and Controls Manager
• S. Palmer, Stipulation Manager
• T. A. Hope, Site Licensing CASE
• H. S. Phillips, CASE Consultant /Philtec Services

' NRC

• W. D. Johnson, Senior Resident Inspector
• Denotes those present at the exit meeting on May 4, 1990,

t 2.

Followup on Previous Inspection Findings (Closed) Open Item (445/8929-05; 446/8929-05): Air Cleaning Systems - This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the completion of the preoperational tests of the plant air cleaning systems.

It was further discussed in NRC Inspection Report 50-445/89-82; 50-446/89-82 when the inspector reviewed the results of the containment preaccess filtration system filter test and the hydrogen purge exhaust system filter test. During this inspection, the inspector reviewed the results of the control room filtration system test and the primary plant filtration system. NRC has no further questions concerning this matter.

(Closed) Open Item (445/8929-06; 446/8929-06): Radiation Monitoring - This item was identified in NRC Inspection Report 50-445/89-29; 50-446/89-29 and involved the steps necessary to ready the digital e

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l i radiation monitoring system (DRMS) for use.

It was further discussed in NRC Inspection Report 50-445/89-80; 50-446/89-80 when the inspector determined that the licensee had completed all necessary calibrations, performed functional testing, and established administrative controis but i had not established the set points for the instruments. The inspector ' verified that set points were established on December 20, 1989, and that ) the system was operable.

' (Closed) Open Item (445/8942-03; 446/8942-03): Instrumentation - This item was identified in NRC Inspection Report 50-445/89-42; 50-446/89-42 , and involved the placement and operation of high sensitivity personnel contamination monitors and portal contamination monitors.

The inspector verified that high sensitivity monitors were in place and operational at > the exit areas of containnient and the RCA.

Portal monitors were at the , primary and alternate exits of the protected area and at the entrance to i the RCA.

, , 3.

Open Items Identified During This Inspection An open item is a matter that requires further review and evaluation by the inspector, such as an item pending specific action by the licensee or a previously identified violation, deviation, unresolved item, or programmatic weakness.

Open items are used to document, track, and ensure adequate followup on matters of concern to the inspector. The following open items were identified: , Open Item Title Paragraph-445/9018-01; Beta Aerosol Beacon Survey Documentation

446/9018-01 . 4.

Observations The following are observations the inspector discussed with licensee i representatives.

The observations are not violations, deviations, unresolved items, or open items. Observations are identified for licensee consideration as program improvement items, but have no specific regulatory requirement.

position Description The licensee did not have a job description for instrument and control (I&C) technicians who performed calibration of radiation protection instrumentation which would ensure continued radiation ' protection expertise.

See paragraph 5.

Contract RP Technician Qualification Criteria i The licensee had no written criteria for evaluating the experience of contract RP technicians.

See paragraph 6.

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n . .- . .. 5-Respiratory Protection Training Individuals receiving respiratory protection training were not instructed to verify that respirators issued to them were of the proper size, as determined by fit testing.

See paragraph 6.

Laundry Monitoring - The licensee had not finalized a method for ensuring the laundry was free of hot particles or high level contamination.

See paragraph 9.

5.

Organization and Management Controls The inspector reviewed the organization and management controls to determine compliance with Technical Specification (TS) 6.2 and commitments in Chapter _12.5.1 of the FSAR.

The RP structure continues as last reported in NRC Inspection Report 50-445/89-42; 50-446/89-42 to consist of the manager, assistant manager, and four RP supervisors. There has been minor personnel reassignment between supervisors to balance workloads. The inspector noted that the most significant changes were the transferal of oversight of 22 contract decontamination personnel to the maintenance department and the transferal of 2 RP specialists to the instrument and controls (I&C) department. The inspector discussed with the licensee the latter reassignment of individuals who would be responsible for the calibration of radiation instrumentation and expressed the concern that continuity of RP expertise and perspective might not be maintained for these two positions should the specific individuals have to be replaced.

The inspector also expressed a concern that timely response to calibration needs might be affected by the transfer of calibration duties to another department. The licensee's representatives responded that they would consider the use of specific job descriptions for the positions to assure that individuals had RP expertise and an appreciation of the characteristics of radiation instrumentation and that they believed the response time would not suffer.

The RP program is fully staffed with approximately 40 technicians and specialists in addition to the management structure described in the previous paragraph. A small number of contract employees were utilized in access control and dosimetry / personnel processing.

The licensee employed seven contract RP technicians for startup. The licensee's representatives stated that they may hire as many as six more, depending on need.

They further stated that they will be " sizing" the staff (primarily the surveillance and control group) during the initial operating period as the workload becomes known and do not plan on long-term dependence on a large number of contract RP technicians. The dosimetry / personnel processing staff is currently adequate, but will probably need supplementing during outage condition. . . .. (. . i-6-The inspector interviewed representatives of Quality Assurance (QA) who stated that the group had undergone reorganization and that the responsibility for both audits and surveillances of RP was now under Quality Operations.

(The other programs under the supervision of the QA manager were Quality Programs, Quality Construction, and Quality Technical Support.) The inspector noted that only six surveillances were performed invniving RP in 1989 and none had apparently been conducted during the period of October 25, 1989, through February 5, 1990.

The inspector reviewed QA Audit Report QAA-89-24A which documented the results of the audit conducted of the RP program. The audit was conducted during the period of September 28 through October 6, 1989, and the audit team included members of the corporate health physics organization.

The audit resulted in the identification of one deficiency and two observations. The inspector determined that the scope and depth of the audit were adequate and noted that the response to the deficiency was timely.

No violations or deviations were identified.

6.

Training and Qualifications ~ The inspector reviewed the training program for radiation workers and RP f technicians and reviewed qualifications of RP technicians to determine l compliance with TS 6.3 and 6.4 and 10 CFR 19.12.

l ! The inspector reviewed training schedules and matrices and determined that i adequate training programs existed for radiation workers, radiation protection technicians, and users of respiratory protection equipment.

Licensee representatives also pointed out that they conduct an advanced i radiation worker course and an intermediate level course called, " Radiation Practices," which is primarily practical, using the mock-up facilities. The inspector determined that instructors in nuclear training have had adequate time for preparation for classes thus far, but representatives expressed a concern that adequate staffing may not t,e available for outage situations.

j The inspector reviewed lesson plans and training handouts and noted that ! individuals receiving respiratory protection training were taught to inspect the respirators they receive for damage, but were not instructed to verify that the size of the respirator was the same as assigned during fit testing.

The inspector reviewed resumes of licensee and contract technicians and determined that all were qualified in accordance with TS requirements.

l The inspector noted, however, that there was no written criteria for i evaluating the experien:e of contract RP technicians to determine that I they have the necessary experience to meet TS requirements.

No violations or deviations were identified.

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External Exposure Control The inspector reviewed the licensee's external control program to determine compliance with TS 6.8 and the requirements of 10 CFR Parts 19.13, 20.101, 20.102, 20.105, 20.202, 20.401, and 20.408; and the commitments of Chapter 12.5.2 of the FSAR.

The inspector determined that the licensee had a state of the art dosimetry system with a supply of approximately 10,000 thermoluminescent dosimetry (TLD) badges. About 1750 people were monitored. Self-reading dosimeters (SRDs) were required for entry into the RCA. The inspector noted that all personnel observed in the RCA were wearing both TLDs and ' SRDs.

- The inspector reviewed the radiation work permit (RWP) program and determined that the licensee utilized both general access permits (GAPS) , for routine activities where radiological conditions are not expected to change rapidly; and RWPs, for specific tasks where radiological hazards are significant or may change rapidly. The ALARA staff typically generates both documents, but members of the surveillance and control group are trained and are allowed to write RWPs such as for emergency work on the night shift..Such RWPs require RP supervisory approval before being put into effect.

The inspector reviewed the licensee's Procedure RPI-606, " Radiation Work and General Access Permits," and noted that GAPS may be used for areas with contamination levels as high as 50,000 dpm/200 cm' while instructions for writing GAPS only address protective clothing requirements when discussing RWPs. The licensee representative stated that special protective clothing instructions would be used in such cases and individuals would be guided by the examples in the computer system.

Copies of GAPS and RWPs were posted for review, as were maps to show the locations of high radiation areas and very high radiation areas.

The inspector reviewed radiation surveys and determined that they were adequate.

The inspector determined that the dosimetry staff is supplied with a daily list of security badges which have been deactivated. They review this list, along with a monthly report of TUE terminations in an effort to determine if all terminated personnel have followed the proper exit procedures so that radiation exposure reports may be sent as required by 10 CFR Parts 19.13(d) and 20.408, 8.

Internal Exposure Control The inspector reviewed the lice m e's program for control of internal radiation exposure to determine compliance with TS 6.8 and the requirements of 10 CFR Parts 20.103, 20.201, and 20.401; and agreement with the commitments in Chapter 12.5 of the FSAR and the recommendations of Regulatory Guide (RG) 8.15, NUREG-0041 Industry Standards ANSI Z88.2-1980 and ANSI /CGA G-7.1-198. e C o . -8-The inspector reviewed the licensee's respiratory protection program and determined that facilities for respirator deconning/ cleaning, maintenance, disinfecting, inspection, storage, and issue appeared adequate for nonoutage conditions. The inspector noted that the monthly inspection of respirators was documented; however, the masks themselves carried no , indication that they had been inspected.

The licensee's representatives stated that they would consider adding a dated inspection slip in each respirator bag as an extra measure to ensure that wearers receive respirators recently inspected and added that respirators, thus far, have only been worn during drills.

The inspector determined tlat the licensee used two models of respirators, each in three sizes.

Respirator fit tests were performed in the personnel processing center, using po table units.

The inspector interviewed technicians at access contr(1 concerning the requirements for issuing respirators and determined taat the individuals were knowledgeable.

Self-contained breathing apparatus (SCBA) were inspected monthly and air from the bottle filling station was checked on a quarterly basis by an outside contractor to assure that it met the standard for Grade D air, as, defined by Industry Standard ANSI /CGA G-7.1-1989. The licensee performed its own check every time bottles were filled.

The licensee's representatives stated that they plan to have the instrument air system available for use as breathing air and will incorporate the necessary filter system and carbon monoxide monitor before use. Once again, an outside contractor will verify that the proper quality of air is being provided.

The inspector also verified that portable ventilation units were available and a procedure has been implemented for their testing and use.

The licensee procured 12 beta aerosol beacons (BABs) to use for monitoring airborne radioactive contaminants. The units may be used as continuous air monitors or used to monitor instantaneous concentrations of airborne radioactive contaminants, such as during system breaches. When coupled with the correct hardware, the devices can produce a hard opy of the survey results, to comply with 10 CFR 20.401(b).

The impector noted that procedures were implemented for the use of the BABs-tiowever, the licensee stated that a procedure was being developed to instruct RP technicians in how to use the devices to document survey results.

This matter is considered an open item, pending review of the survey documentation procedure (445/9018-01; 446/9018-01).

The licensee utilizes a quick count type whole body counter for processing individuals wishing to obtain dcsimetry and enter the RCA. A chair-style counter is available for use as a backup or for individuals who can not be - .

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counted in the primary counter.

The licensee's Station Procedure STA-655, ! " Exposure Monitoring Program," requires personnel undergoing medical ' procedures involving radioisotopes to notify RP.

No violations or deviations were identified.

9.

Control of Radioactive Material and Contamination, Surveys, and Monitoring The inspector reviewed the licensee's programs for surveying / monitoring

and controlling radioactive materials to determine compliance with TS 6.8.

i and the requirements of 10 CFR Parts 19.12, 20.201, 20.203, 20.205, 20.207, 20.301, and 20.401; and with the commitments in Chapter 12.5 of the FSAR.

The inspector reviewed access control procedures and determined that they were adequate. The inspector noted that the licensee required individuals i to initially sign in on the appropriate GAP or RWP. Access control

technicians then checked the individuals' qualifications for entry via l computer terminal.

The inspector also noted that should the radiological i conditions in the area controlled by either permit change, the computer l would not authorize entry by individuals until they had reread the permit i and the updated requirements. The licensee placed portal monitors at the entrance to the RCA and high sensitivity personnel contamination monitors (PCMs) at the exit. Additional PCMs were located at the , containment entry / exit area.

Tool monitors and friskers were used to l survey items before release from the RCA.

RP technicians were stationed at the. exit to assist personnel and ensure that all individuals and items were properly monitored prior to leaving.

Personnel exposures, as

recorded by the self-reading dosimeters, were recorded via computer j terminal as individuals exited.

! The licensee's representatives stated that they were reviewing possible alternatives to the present access control layout. The current layout I appears inadequate to handle the amount of personnel traffic brought about by the operation of two units or by outage conditions.

y i The inspector determined that the licensee had an adequate supply of ) protective clothing (PC) and modesty garments available.

The licensee ' will not laundry protective clothing onsite, but will use a vendor for the service. The licensee had made no shipments of PC at the time of the inspection. The inspector determined that the licensee had not established written procedures that address what percentage of the laundry would be surveyed to verify that laundry returned by the vendor was free from hot particles or high levels of contamination.

The inspector reviewed the licensee's program for documenting and tracking leaks in the RCA.

RP documents the date which catchbags were installed and periodically reviews the status with the maintenance department until the leaks are replaced. At the time of the inspection, the licensee was tracking approximately 70 leaks.

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11.. Exit Meeting ^ - The inspector met with the resident inspector and the licensee's-representatives denoted in paragraph 1 at the conclusion of the inspection - on May 4, 1990, and summarized-the scope,and findings of the inspection as presented in this report.- The licensee did not identify as proprietary.

any of the materials provided to, or reviewed by, t S inspector during-the inspection.

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O 4' v, , . -10-The inspector reviewed the licensee's biological shield surveys made at 2 percent power.

No unexpected radiation levels or breaches in shielding were identified and the levels appeared to be consistent with FSAR projections. The licensee completed surveys made at 48 percent power subsequent to this inspection and a licensee representative stated in a telephone conversation on May 11, 1990, that there still were no radiation levels above those predicted.

l No violations or deviations were identified.

10. ALARA The inspector. reviewed the licensee's ALARA pro.1 ram to determine compliance with requirements of i'l CFR 20.1(c) s.nd agreement with the commitments in Chapter 12.1 of the FSAR and recommendations of RG 8.8 and 8.10.

The licensee's ALARA group consisted of a supervisor and three technicians.

One of the technicians worked closely with work planning and ! scheduling and another with work control to ensure that RP is involved in the early stages of work evolution.

Tht third individual was responsible for ALARA implemented radiation shielding. As stated previously, the ALARA group was responsible for producing most of the RWPs, with the i exception being those written occasionally on the night shift.

It was the technical support staff, however, which reviewed new procedures (or amendments) of other departments, such as maintenance, for ALARA concerns.

The licensee's representative stated that, because of ALARA considerations, the plant used a " modified" elevated pH to reduce the amount of plateout in the primary system.

Other programs under consideration by the licensee were " ultrafiltration" to remove contaminants and identification and removal of stellite components in

valves in the primary system.

l The licensee's representative also stated that outage planning would soon I begin and that job exposure data had been collected from other facilities to aid the ALARA staff in the planning.

The inspector determined that the licensee had a successful program for soliciting and reviewing ALARA suggestions from workers.

Twenty-eight suggestions were received in 1989 and ten thus far this year.

The licensee had established several system mock-ups in the training center, including a mock steam generator, motor operated valves, and piping. The mock-ups will be used prior to outages and in advanced radiation worker training.

No violations or deviations were identified.

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