IR 05000445/1990023

Insp Repts 50-445/90-23 & 50-446/90-23 on 900618-22.No Violations or Deviations Noted.Major Areas Inspected: Radiological Environ Monitoring Program,Including Organization & Mgt Controls,Training & Qualifications

ML20055G874
Person / Time
Site:	Comanche Peak
Issue date:	07/13/1990
From:	Murray B, Wilborn L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20055G871	List: IR 05000445/1990023 ML20055G870
References
50-445-90-23, 50-446-90-23, NUDOCS 9007240263
Download: ML20055G874 (8)

Text

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APPENDIX . U.S. NUCLEAR REGULATORY COMMISSION [

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REGION IV

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  -NRC-Inspection. Report: 50-445/90-23 Operating License: NPF-87:
     '50-446/90-23 Construction Permit: CPPR-12 I   1 Dockets: 50-445'
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Licensee: TV Electric Skyway Tower

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  ,  -400 North Olive,.L.B. 81 ij
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Dallas,. Texas 75201 l

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  , Facility _Name: Comanche _ Peak-Steam Electric Station (CPSES)
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  ' Inspection At: CPSES site, Glen Rose, Texas   ;
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InspectionLConducted: . June 18-22, 1990

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n y Inspector:

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_Lofenzo pf born, Radia_ an Specialist Date Facilities Radiological Protection Section -! m Approved: uf : N)llji[./,/// - '7//M.

  .The inspector'also interviewed several other licensee personnel during the inspectio i 2 .^ Inspector Observation
  ~The;following observation was discussed with the licensee during the exit meeting on June 22,'199 This observation is.not a-violation, deviation, ,

unresolved item, or open item. This observation was . identified for-licensee consideration for program improvement, but the observation has no: i

  : specific regulatory requiremen ;

Review of Annual REMP Reports - The annual REMP reports for 1988 and 1989 i contained discrepancies that the licensee's reviews had not identifie ;

  (see paragraph'4)     ' Organization and Management Controls    *

The inspector reviewed the licensee's organization, management controls,

  .and assignment of REMP responsibilities to determine adherence to s

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a d'y commitments in Chapter 13 of the Final Safety Analysis Report (FSAR) and the' requirements in Section 6.2 in the Unit 1 T ; ~ Organization 'jq The CPSES chemistry and environmental staff was' responsible for- 1

 ,  collection, documentation, and shipment of the radiological-  1
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environmental samples collected around the CPSES sit Environmental ) samples-are shipped to an offsite contractor for radiological d V -analyse .s] e The-CPSES. radiation-protection staff was responsible for' reviewing i and evaluating the-sample results provided by the contractor } The inspector verified that the organizational structure of the CPSES

   ' chemistry and environmental and: radiation protection staffs with respcasibilities associated with the REMP were as defined in the FSAR $j anr1 satisfied TS requirements. The organizational structure and  'f staffing appeared sufficient to conduct routine REMP activities.,  i n    Only one. environmental staff member had terminated during the past  1
   :28 month j Management Controls     /

O The inspector' verified that the assignment of administrative control , j responsibilit'ies'for the implementation and management of the_REMP 3 were as specified in the management control procedures and position y descriptions and as identified in the FSAR and-T d,

  : NoJviolations or deviations were identified, s

3; Qualifications and Training

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  -The-inspector reviewed the licensee's training and qualification program  j" for CPSES personnel involved in REMP activities to determine agreement
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with commitments in Chapter 13 in the FSAR and-the requirements in

  . Sections 6.3 and 6.4 in'the Unit 1 T l
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The inspector re' viewed the-individual training records of selected ,i

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personnel who' had been assigned responsibilities for implementing REMP LI

  . activities and verified that the licensee's-training program was being  j implemented and documented in accordance with applicable-procedures,
  -instructions,-policies, and regulation :

The inspector reviewed the education and experience of the current staff ,

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involved in'REMP activities and determined that they met the required qualifications specified in the FSAR and unit T It was determined that the licensee had an adequately qualified staff to conduct the REM No violations or' deviations were identifie :

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4.' R'adiological Environmental Monitoring Program

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 ;The~i_nspector_ reviewed-the licensee's REMP to determine compliance with'

Lthe requirements in-Section 6.8.3 of the Unit 1 TS and the Offsite Dose Calculation Manual (0DCM). The inspector reviewed the licensee's-procedures for. implementation of the REMP. The proceduresLfor_the M administration of the REMP and collection and shipment of radiologicali environmental samples to meet TS and ODCM requirements were written with-9 sufficient detail to ensure TS and_0DCM complianc I The inspector' reviewed .the annual, radiological environmental monitoring -

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reports for 1987, 1988, and 1989 and determined that the sampling and 1 analysis requirements of.the.TS and ODCM had been met. The inspector noted.that:the annual land use census, performed out to a' radius of iSl miles from the plant,-had been conducted in a timely manner each of the

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years.and was included in the respective annual radiological environmental-monitoring = reports. The inspector observed the following during .the '

 . review of the, annual radiological environmental monitoring reports:
 . .The.1988 and 1989 reports were not dated to indicate that the reports

, , -were submitted before May Section 6.9.1.3 of the Unit l'TS, which became? effective in April 1990, requires that reports, be submitted ' before May 1,'of each yea > In Appendix B, " Synopsis of Analytical Procedures" and specifically: The Analysis of Water Samples for Tritium, page 68 in'the 1988 report and page 66 in the 1989 report.showed the:two sigma ~ error as i ,

  "2((S/2 . . . ." instead of "2((S/T2 . . .., " where T was the number of -i l   minutes the sample was counte _l The " List of Tables," page iv in the'~1988 and 1989 reports referenced 1987 in the " Summary of Data for the CPSES REMP for 1988 and 1989." t .The inspector observed that a milk sample was~ collected from a-location identified.as SW-12.5; however, this sample location was not-included in either Table 3.1 or Figure'3.1 of the ODCM.

h l, These items were discussed with the licensee during the inspection and at ' the exit meeting on June 22, 1990. [ The inspector inspected selected environmental sampling stations associated with the REMP. The following types of sampling stations were-inspectedi airborne, direct radiation by thermoluminescent E dosimeters (TLDs) .: ground water, surface water, drinking water, vegetation,

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• and milk. The required equipment at the selected sampling stations was in l> place,' calibrated, and operational at the time of the inspection. During L the inspection of the various environmental sampling stations, the

 . inspector verified that the locations were as described in Table 3.1 of Lc~

the ODCM, except for the milk sampling at location SW-12.5. The inspector noted that the sampling stations described in Table 3.1 are the minimum ' locations required for compliance. Additional locations may be monitored h

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as special studies to evaluate potentiel pathways of exposure without ,

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   . adding such locations to the monitoring prog.am described in-Table 3.1 of

' y the'ODC ' ' g The inspector reviewed the licensee's maintenance and calibration projram for the REMP. air samplers and found it to be satisfactor c .

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   'The inspector reviewed the licensee's environmental TLD for direct -l
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radiation measurements program and noted that the licensee had an approved

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procedure for.the placement, collection, preparation, and shipmen', of f ' environmental TLDs to the offsite contractor laboratory for processing.- The-inspector-determined that the licensee's performance had beer satisfactory for 1987, 1988, and 198 No violations or deviations were identifie . Meteorological Monitoring Program l l The inspector reviewed the licensee's meteorological monitoring program to -

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determine adherence to commitments in Section 2.3.3 in the FSAR, the l

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   ' requirements in -Sections 2.3 and 3/4.3.3.6 in the ODCM, and the -  i
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recommendations of Regulatory Guides 1.23 and 1.97, and American National i L Standards Institute (ANSI /ANS) Standard 2.5-198 ;

The inspector reviewed the meteorological tower data monitoring and  ;

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recording. equipment, the preventive and corrective maintenance activities, ! instrumentation calibration procedures and records, and surveillance . !

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procedures and records..The. inspector verified that the meteorological- l tower instrumentation.had been operable, except during a 13-day period in ! y June.1989 when the backup tower was intentionally taken out of service to .; support the rebuilding effort on the primary tower which had been knocke i-down during a storm in May 1989.' A special meteorological data recovery e;" report, dated March 1, 1990, Reference: CPSES-9005550, was submitted to the NRC in accordance with CPSES Procedure STA-714 and Section 3.3.3.6-in the'0DC It was verified that the meteorological tower instrumentation-had been-calibrated semiannually by instruments and controls technicians , and daily surveillance checks of instrumentation operation had been  ! perfo'rmed according to CPSES Procedure STA-714 by radiation protection: personnel. The inspector determined that the-licensee had conducted a proper' meteorological monitoring progra , No violations or deviations were identifie 'l Qualitylsyuna3ce Program The inspector reviewed the licensee's QA audit and surveillance programs ' to determine adherence with commitments in Sections 13.4 and 17.2 i's the FSAR and requirements in Section 6.5.2.8 in the Unit 1 T The inspector reviewed selected audit and surveillances performed in 1988 and 1989. The inspector also reviewed the qualifications of the

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+ individuals perforning the audits and surveillances. -The inspector noted . r that the-QAtaudits and surveillances were designed to determine compliance-with REMP procedures and the TS. The inspector reviewed audit and l

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surveillance plans, checklists, and findings and confirmed that the- .

 -identified findings were reviewed by- the licensee's management and that the' responses and corrective actions to findings had been completed in a timely manner and documented in accordance with QA procedures. The y  . inspector' determined that the audits and-surveillances were performed by qualified personnel knowledgeable in REMP activitie ~
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No violations or deviations were identifie'. d r .7.- Facilities, Equipment, and Supplies  ! The. licensee's. environmental personnel are responsible for collecting and shipping REMP samples to an offsite contractor laboratory for analyse The inspector inspected the facilities, equipment, and supplies that were '; used=by the licensee for preparation of REMP samples for shipment. .The inspector determined-that the facilities, equipment, and supplies were adequate to support REMP activitie No violations or deviations were identifie q Contractor Activities The licensee used an offsite contractor laboratory to perform analyses of REMP environmental media samples. The licensee pttformed vendor audits: triennially with annual evaluations to retain current status on the ' approved vendors list. The' inspector reviewed the aadit' performed on the licensee's contractor laboratory in-March 1988 (Document .

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 -Identification TEL-88-2) and verified that the contractr had been-approved for the required analyses and placed on the curre,t approved' l vendors lis i The contractor laboratory participated in the:U.S. Environmental i
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Protection Agency's (EPA) interlaboratory comparison progra The inspector found the contractor's results-of.the cross-check sample analysis comparisons to be within the EPA acceptance criteria of three , standard deviations of the'known values supplied by.the EP ; The inspector determined that the licensee's audit program for contractor ' activities associated with the REMP was adequat No violations or deviations were identifie . Reportable Occurrences The inspector reviewed the 1987,1988, and 1989 annual radiological environmental monitoring reports for reportable occur"ences dealing with the REMP and found that none of the analytical measurements exceeded any notification level and the licensee had not written any licensee event

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i k 1 reports involving the REMP: activities-since the previous NRC inspection of , the REMP in February 1988,  ;

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No' violations or deviations were identifie , l Exit Meeting

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The-' inspector mot with the resident-inspector,.the licensee

  : representatives, and others denoted-in paragraph 1 at the conclusion of-the inspection ~on June 22, 1990. The inspector summarized the scope and
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findings Lof the irispection and discussed the inspector's' observation = as l presented in thir, report. The licensee stated that the' inspector's <

  . observation would be reviewed. The licensee did not identify a proprietary any of the materials provided to, or reviewed by, the  t-inspector during thelinspectio : ,
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