IR 05000458/1988016
| ML20151Q074 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 07/27/1988 |
| From: | Baer R, Chaney H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20151Q072 | List: |
| References | |
| 50-458-88-16, NUDOCS 8808100317 | |
| Download: ML20151Q074 (12) | |
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~ APPENDIX-i U.S.. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-458/88-16 Operating License: NPF-47 Docket:
50-458 Licensee:
GulfStatesUtilities(GSU)
P.O. Box 220 St. Francisville, Louisiana 70775-Facility Name:
River Bend Station (RBS)
Inspection At:
RBS, St. Francisville, Louisi na
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Inspection Conducted: June 20-24, 1988 Inspector:
//27 <SS Hf D. Chaney, Radiation Specialist, Facilities Date Radiological Prntection Section
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Approved:
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R. d aer, Chief, Facilities Radiological Date Protection Section Inspection Summary
_ Inspection Conducted June 20-24, 1988 (Report 50 458/88-16)
Areas Inspected:
Routine unannounced inspection of the liquid and gaseous effluer.t release program.
Two allegations concerning the training and
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qualifications of supervisory personnel were reviewed.
Results: Within the areas inspected, no violations or deviations were
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identified.
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8808100317 880805 PDR ADOCK 05000458 O
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DETAILS 1.
Persons Contacted l
GSU
- J. Deddens,'Vice President, River Bend Nuclear Group (RBNG)
T. Plunkett, Plant Manager
- J. E. Booker, Manager of RBS Oversight D. Burnett, Chemistry Foreman
- E. M. Cargill, Supervisor, Radiological Programs
- J. W. Cook, I'ad Environmental' Analyst
- T. C. Crouse, riinager, Quality Assurance (QA)
- L. A. England, fi. actor, Nuclear Licensing
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R. G. Easlick, Radwaste Supervisor-C. L. Fantacci, Radiation Protection Supervisor j
R. Gould, QA Engineer i
- P. D. Graham, Assistant Plant M?. nager, Operations
- G. K. Henry, Director, Quality,0perations
- K. C. Hodges, Chemistry Supervisor
- I. M. Malik, Quality Systems Supervisor
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- W. H. Odell, Manager, Administration W. Parker, Training Department, Operations Instructor i
A. A. Rouchon, Radwaste Equipment Operator D. Robinson, Computer Systems Engineer
- M. F. Sankovich, Manager, Engineering J. Spivey, QA Engineer
- K. E. Suhrke, Project Management Others
- W. Jones, NRC Resident Inspector
- W. L. Curran, Cajun Electric-Site Representative
- Denotes those-present at the exit interview on June 24, 1988.
The NRC insp/ quality control (QC), instrumentation and control (I&C), and ector also interviewed several other licensee employees including QA
radiation protection (RP) personnel.
2.
Inspector Observation The following is an observation that the NRC inspector utscussed with the licensee during the exit interview an June 24, 1988.
Observations are not-violations. deviations, unresolved items, or open items.
This observation
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was identified for licensee c nsideration for program improvement, but the
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observation has no specific regulatory requirement.
The licensee stated j
that the observation would be reviewed.
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Audit Technical Specialist Selection - The' individual used as a technical specialist for RBS Audit 87-06-I-PCON/RWMP (Process Control and Radioactive Waste Management Programs) did not have sufficient operational experience and technical training in radwaste activities to be considered a technical specialist.
3.
Open'ItessIdentiQed ring This Inspection
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An o3en item is a matter that requires further review and tvaluation by the iRC inspector.
Open items are used to documer,t, trach, and ensure
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adequate followup on matter of concern to the NRC inspecter.
The following open item was identified:
Open Item Title goParagraph 458/8816-01 Quality Assurance Audits
4.
Followup on Previously Identified Inspection Findings (Closed) Deviation 458/8622-02:
Installation of Radwaste Studge Tank and Compactor - This item was previously discursed in NRC Inspection
Reports 50-458/8G-22 and 50-458/87-18 and cancerned the licensee s failure to have installed and/or operational the re.o active-liquid waste sludge n
tank, semple valves, and a dry waste comprctor.
The NRC inspector reviewed the licensee's response end impiamentatien of' corrective actions (deferring operation of the sludge tank iia a revision to the Updated Safety Analysis Report [USAR), installat.on of sample valves,imd installation and testing of a waste comractor), and determined that the licensea had implemented adequate correcive actions to resolve the NRC concerns in this area.
(Closed) Open Item 458/8414-07:
Calibration of Liquid and Gaseous'
Effluent Monitors - This item was previously discussed in NRC Inspection Reports 50-458/84-14, 50-458/84-33, 50-458/85-46' 50-458/85-E3, and
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50-458/86-34 and involved the licensee's calibration program for effluent vonitors using National Bureau of Standards traceable liquid and gaseous radioactive sources.
The NRC inspector reviewed the,licw 's calibration progam, its implementation, and determined that the NRC;* c b ens in this area had been adequate'y resolved.
5.
Radwaste Program Organization and Management Controls _(83522/83722)
The licensee's organization and staffing of the radioactive waste group was inspected to determine:
agreement with USAR Sections 13.1.2, 13.1.3, 13.4, and 13.5 commitments; compliance with the requirements of the facility operating license Technical Specifications (TS) 6.2, 6.5.3.8.k, 1, and m, 6.6, 6.8, 6.9.1.8, 6.10.2.d.-6.10.3.a, d, and g, 6 I? 6 14, and 6.15; and recommendations'of NRC Regulatory Guide (RG) 1.33, and 1-NUREG-0761.
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The NRC inspector reviewt:' the I.icensee's liquid.and gasens radioactive waste management program including performance of a batch. liquid effluent.
release, management policies and plans, radwaste group (part of Operations Department) staffing and organization, prncedures for implementing the radwaste program, quality assurance audits of imp %menting orocedures, and routine and special reports submitted to the NRC by the licensee.
The-licensee's Semiannual Efficent Release Reports for 1987 were reviewed and found to satisfy-TS 6.9.1.8 requirements.
During the inspection of licensee audits, the NRC inspector determined that wM le Audit 87-06-I-PCON/RWMP (Process Control and Radioactive Waste Management Programs) was performed in accordance with the QA Program Audit Plan and implementing procedures, it did not clearly show that licensee activities, involving the radwaste program, satisfied-USAR or TS committaents and requirements. The subject audit?das a comprehensive performance based audit of the;11censee's implementation of the plant's
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radwaste managerhent plan implementing procedures.
The'NRC inspector noted that the audit checklists did not contain any reference concerning the verification of TS requirements.
Previous licensee' audits have focused on the verification that the bplementing procedures adequately addressed USAR and TS commitments and requirements.
This is considered an open item'
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pending licensee evaluation as to the degree.of TS validation required in a given audit (458/8816-01).
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Procedure and documents reviewed during this audit'are' described in the i
Attachment to this report,
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No violations or deviations were identified.
6.
Radwaste Organization Staff Qualifications and Training (53523/83723)
The training and qualifications of personnel assigned to radwaste-
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operations duties were inspected to determine agreemert with the
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commitments in USAR, Section 13.2.3; the requirements of-10 CFR Part 19.12, TS 6.3.1 and 5.4.1; the recommendations of RG 1.8,
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NUREG-0761, and industry standard ANSI /ANS 3.1-1978.
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The NRC inspector reviewed radwaste organizational responsibilities, staffing, personnel qualifications, including a performance based review
of personnel performing a liquid effluent release and waste stream
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sampling.
Licensee training plans, implementing procedures, lesson-r outlines, on-the-job-training program, INPO ac.creditation, and training
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records for six radwaste personnel were reviewed.
No violations or deviations were identified.
7.
Liquids and Liquid Wastes (84523/84723_}
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The licensee's program for control, processing, and discharge of I
radioactive liquid wastes (RLW) was inspected to determine agreement with
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the commitments contained in Section 11 of the USAR, and compliance with
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the requirements of.TS 3.11.1.1, 3.11.1.3, 3.11.1.4, 4.3.7.10, 4.11.1.1.1, 4.11.1.1.2, 4.11.1.2, 4.11.1.3, and 4.11.1 4; and agreement with the
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guidance in NRC RG 1.109 and NUREG-0473.
The NRC inspector reviewed the licensee's program for controlling
'dischargos of RLW including discharge permits, valve lineups, tank recirculation, sampling and analysis of liquids, and the quarterly verification of discharge isolation. valve operation upon receipt of a high
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activity signal.
Condensate storage tank radioactive material inventory.
was reviewed.
Reactor control room readouts of process monitors were observed.
Discharge permits (Chemistry Department Form CSP 0110.PER) for releases conducted in 1988 were reviewed.
The lice'nsee's-calibration and periodic channel test of effluent ~ discharge monitors (RE-107 and RE-108)
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were reviewed (Surveillance Procedures STP-511-4226/4280/4281/4580 and
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4581).
The NRC inspector also observed the performance of a planned RW release (No. 88-0184) involving procedures.(COP-001, CSP-110 and SOP-1C3).
No violations or deviations were identified.
8.
Gaseous Waste System (84724)
The licensee's program for control, procassing, and release of radioactive-gaseous effluent was inspected to determine agreement with Section 11.3
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of the 1)SAR; compliance with the requirements of TS 3.3.7.11, 3.6.5.4, 3.6.5.6, 3.11.2.1, 3.11.2.2, 3.11.2.3, 3.11.2.4, 3.11.2.5, 4.3.7.11, j
4. 6. 4. 4, 4. 6. 5. 6, 4.11. 2.1.1, 4.11. 2.1. 2, 4.11. 2. 2, 4.11. 2. 3, 4. 22. 2. 4, and 4.11.2.5; and the guidance in NRC RG 1.109, 1.340, 1.52, NUREG-0737, RUREG-0473, and industry standards ANSI N509-1980 and ANSI N510-1980.
The NRC inspector reviewed the licensee's documented program for control of waste gas releases to verify that proper sampling and analysis were
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performed and that dose rates in unrestricted areas did not exceed 10 CFR Part 50 and TS limits.
The NRC inspector also reviewed the licensee's special and routine calibration program for gaseous ~ effluent monitors that monitor the main stack and fuel building effluent release pathways.
The licensee's records of in place and laboratory testing of the high-efficiency particulate air (HEP."i) filters and adsorber units for the standby gas treatnient and fuel building ventilation systems was inspected.
No violations or deviations were identified.
9.
Allegation (4-88-A-0015)
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An allegation was received in the NRC Region IV office stating that a
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newly appointed (October 1,1987) radiation protection technician (RPT)
foreman:
(a) was not qualified for the position, (b) used verbally abusive language when directing RPTs, and (c) gave improper written instructions to RPTs to review old Radiation Work Permits (RWP).
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Discussion The NRC,nspector reviewed the subject foreman's qualifications,ition experience, and licensee's procedural restrictions governing,pos appointments.
The foreman was promoted from the classification of RPT and had more than 5 years of RPT experience involving RBS plant operations and military duties.
The foreman had been employed at RBS as an RPT for more than 3 years.
In Section 13.1.2.1.3 of the USAR, the licensee commits to the training and qualification guidance of industry standard ANSI /ANS 3.1-1978 for the position of radiation protection supervisor (RPS) but not the lower position of RPT foreman, which reports to the RPS. - The licensee's primary procedure governing-qualification and selection of personnel for plant staff positions is Administrative Procedure (ADM) 007.
This arocedure is supplemented by Radiation Section Procedure (RSP) 003.
ADA-007 does not address qualifications for the position of RPT foreman.
RSP-003 also does not reference.the qualification requirements of the RPT foreman position.
Another internal GSU document governing personnel selection and I
qualifications is the GSU Company Position Description for "Radiation
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Protection Foreman." This five page document establishes the organizational location of the position, nature and scope of the position, and the prerequisite qualifications governing the position.
This document is not ieferenced in higher tiered documents such as AGM-007 and RPP-003 and is considered a guidance document only.
This document states, in part, "The incumbent must have 5 years of ap) lied Radiation Protection / Dosimetry experience of which 3 years must )e at a nuclear power plant.
These 3 years of experience shall include at least one routine refueling outage."
The subject foreman was hired as an RPT at RBS on December 17, 1984, the licensee's first refueling outage commenced on September 14, 1987.
The RPT was promoted to the position of RPT foreman on October 1, 1987.
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Conclusion This portion of the allegation was not substantiated since the foreman satisfied all aspects of the licensee's commitments, b.
Discussion The licensee was already aware of the subject foreman's problem involving tactfulness and an aggressive verbal communication style j
with plant personnel when carrying out radiological 3rotection duties
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and interaction with subordinates.
Interviews with iRC resident inspectors and plant staff indicated that the foreman had been observed on occasion to use abusive language in enforcing radiological
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protection practices.
The licensee had sent the foreman to two
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Conclusion This portion of the allegation was substantiated, but is not considered a regulatory matter in that.the foreman's actions did not appear to be of_a harassing or intimidating nature.
c.
Discussion
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The NRC. inspector reviewed the purported foreman's written instructions (unsigned and undated) concerning the updating of closed RWPs that were used during the September through December 1987 refueling outage.
Selected RWPs from the same period were reviewed.
for the type of corrections being.made to them.
Most'of the changes were made to correct minor errors and update the listing of radiological surveys associated with a specific job.
The failure to.
update and periodically ~ review the RWPs during the normal course of-the outage is the subject of an apparent violation.which is discussed in NRC Inspection Re3 ort 50-458/88-10. Most of the RWPs reviewed had been annotated,'on tie routing sheet, as to the' fact that updating had
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been accomplished.
The historical data cn an RWP is sometimes used for development of radiological controls for similar tasks.
The foreman's instructions-were aimed at making the PWPs a more presentable record package.
Conclusion The allegation was substantiated as to the fact that the RWPs were updated / modified.
It could not be substantiated that the mcdifications were for the express purpose'of concealing errors in the RWPs.
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10.
Allegation (4-88-A-0048)
An allegation was received by the NRC concerning the inadequate training of GSU and RBS personnel for the purpose of replacing RPTs during a labor strike due to commence on June 18, 1988.
The alleger stated that training and qualification cards for the replacement RPTs were being completed in less than one day.
Discussion The subject strike did not take place.
The NRC inspector reviewed the licensee's proposed replacement RPT selectees and the training program for them.
The licensee selected approximately 24 personnel from the GSU corporate office and RSS work' site.
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that have had previous experience as a RPT (state programs, naval nuclear cower, or commercial).
Except for current RP supervisors and managers with current RPT qualifications, and the manager of radiological programs eight
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selectees were processed through a qualification program that included radiological surveys (radiation, air, and contamination), portable and laboratory instrumentation operation, survey,results' documentation, issue of respiratory protection equipment, radioactive material control, radiological posting, tion areas).and access control over radiologically control ar (including high radia The licensee's. records of training indicated that training involved 2 days-(approximately 16' hours) of'
qualification.
This qualification did not allow for personnel without current RBS RP experience / qualifications. to establish radiological controls for work operations.
Conclusion This allegation was not substantiated.
11.
Exit Meeting The NRC inspector reviewed the scope and findings of the inspection with licensee representatives and the NRC resident inspector noted in paragraph 1 of this report at the conclusion of the inspection on June 24, 1988.
In response to the inspector's comments regarding the licensee's audit prograia, the licensee agreed to review their present audit plan to determine whether it properly address the programmatic and performance based aspects to be included in a given audit.
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ATIACHMENT TO NRC INSPECTION REPORT 50-458/88-16 DOCUMENTS REVIEWED IIILE BEVISION DBTE Piver Bend Nuclear Procedures Manual (RBNP)
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RBNP Directive No.
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Radioactive Waste Management Policv Statement
08/13/87 S t a t i on_Op erat i ng Manual Administrative Progedures (ADM)
ADM-OOO1 Station Staff Organization.
Responsibilities and Authorities
05/03/85 ADM-OOO3. Development, Control and Use of Procedures
03/31/88 ADM-OOO7 Selection, Training. Qualification and Evaluation of Plant Staff Personnel
01/10/86 ADM-0012, Corrective Action Program
07/07/87 ADM-OO25, Conduct of Radiation Protection Services
03/31/87 ADM-OO38, Radioactive Waste Management Program
08/26/87 ADM-OO42, Conduct of Chemistry
10/21/87.
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ADM-OO45. System Management and Utilization of the DRMS
4/15/88 ADM-OO54, Radioactive Li quid Ef fluent Batch Discharge
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05/19/88 Chemistry Operatino Procedures (COP)
CDP-OOO1, Sampling Via the Radwaste Sample
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Pcnel - PNL 130
6/17/85 COP-OOO7, Sampling the Off-Gas Treatment Sample Panels
7/16/87 COP-OO15. Sampling the Circulating Water
01/27/87 COP-OO15. Sampling the Normal Service Water
01/27/87 COP-OO19, Sampling of Liquid Radwaste Sludge and Rosin Holding Tanks
07/29/87 COP-OO26. Sampling the Auxiliary Boiler Water
08/08/85 COP-OO46, Sampling Gaseous Effluents Via the Wide Range Gas Monitors
'01/27/87 l
COP-OO50. Sampling Gaseous Streams
01/27/87'
COP-OO57, Grab Sampling of Liquid Monitors
08/11/87
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COP-0809. DRMS System Operation O
01/22/86-COP-1003 Post Accident Sampling of Gaseous
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Effluents
07/14/85 COP-1004, Post Accident Sampling of Liquid
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Effluents
12/20/85 I
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IIILE BEVIS10N DOTE Chemi stry Section Procedures (CSP)
CSP-OOO2, Chemistry Section Forms Control
01/30/87 CSP-OOO3, Chemistry Per sonnel Dualifications
03/13/87 CSP-0100. Chemical / Radiochemical Technical Specifications Surveillances
08/28/86 CSP-0107 Control of Plant Non-Radioactive Discharges
09/17/85 CSP-0110. Radioactive Liquid Effluent Batch Di scharges
5/12/86 Radiation Section Procedures (RSP)
RSP-OOO3, Personnel Qualification for the Radiation Protection Section
06/16/88 RSP-OOOS. Offsite Dose Calculation Manual (ODCM) Procedure
08/13/87 RSP-02OO. Radiation Work Permits
07/13/87 Radi at i on Protection Procedures (RPP)
RPP-OO27 Gaseous Effluents Monitor Setpoint Determinations
05/12/88 RPP-OO95, Primary Calibration of Main Condenser Off-Gas Post Treatment System Noble Gas Activity Monitors O
08/11/86 RPP-OO97 Manual Methods of Determining Cumulative Dose Contributions From Liquid Effluents O
04/29/87
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RPP-OOO1. Determination of Background Values for DRMS Process Radiation Monitors
12/22/87 Radwa_ste Procpglures ( R W S_),
RWS-0203. Personnel Qualifications for Radwaste Section
02/19/87 RWS-0204, Radwante Processing Control Program
11/10/87 RWS-0208, Waste Management and Leak Detection
06/12/87 RWS-0209, Conduct of Radwaste Vendor Services
11/17/87 RWS-0211. General Performance Control for Radwaste
05/18/87 RWS-0212, Radwaste Process Logs and Records
07/02/87 RWS-0213. Radwaste (Process) Shift Relief and Turnover
03/07/87 RWS-0304, Radioactive Waste Handling and Control
07/06/87 S_y_s t em Operatina Procedures (SOP)
SOP-0108, Li qui d Radwaste Processing
11/02/87 Su r vei ll.3_n_g e Te s t Procedures (STP)
l STP-311-4214. RMS-Main Plant Exhaust Duct Noble Gas Activity 18 Month Chcal (IRMS-RE125)
08/26/86 STP-511-4226. RMS-Coolino Tower Blowdown Line Flow Rate 18 month Chcal
02/05/88
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TITLE RE.MISI Otj DOTE
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STP-511-4231. RMS-Main Plant Exhaust Duct Monitoring System Effluent Flow Rate Monitor. Quarterly Chfunct and 18 month Chcal (1RMS-FE126)
01/21/88 STP-511-4232. RMS-Main Plant Exhaust Duct Monitorino System Sampler Flow Rate Monitor, Quarterlv CHFunct. 18 month CHCAL (1RMS-FEX126)
11/20/87 STP-511-4215. RMS-Main Plant Exhaust Duct Noble
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Gas Activity Monitor 18 month CHCAL (1RMS-RE126)
06/29/87 STP-511-4515. RMS-Mai n Pl ant Exhaust Duct Noble Gas Activity Monitor Quarterly CHFunct (1RMS-RE126)
03/18/88 STP-511-4280. RMS-Liquid Radwaste Effluent Line Radiation Monitor 18 Month Chcal (1RMS-RE107)
01/20/88 STP-511-4281. RMS-Radiation Monitor Cooling Tower Blowdown Line 18 Month Chcal (1RMS-RE108)
01/28/88 STP-G11-4580. RMS-Li quid Radwaste Ef f luent Line Radiation Monitor Quarterly Chfunct ( 1 RMo,-RE 107 )
07/22/87 STP-511-4581. RMS-Radiation Monitor Cooling Tower Blowdown Line Quarterly Chfunct (1RMS-RE108)
03/18/88 STP-511-8207, Cumulative Done Contributions From Liquid Effluents 4'
10/11/85 STP-606-8213. Manual Noble Gas Dose Rate
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Determination O-06/02/86 STP-406-3601. In Service Testing of the Fuel Building Filtration System
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STP-257-3601, In Service Testing of Standby Gas Treatment Filtration System
06/30/85 STP-257-8601, Standby Gas Treatment System Carbon Analysis
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(05/05/87)
STP-406-8602. Fuel Building Ventilation Chercoal 05/05/87)
Filtration System Carbon Analysis-
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Station Support _ Procedures Section 5 _Ir.ainino Administration Proceduros (TAP)
TAP-5-OO7, Training Records and Documentation J
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Section 7.
Trainino Program Procedures (TPP)
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TPP-12, Non-Licensed Operator Training j
Trainino Plans i
NEO-019-2. Liquid Radwaste Collection
07/23/87 i
NEO-020-2. Liould Radwaste Processing
07/23/87-3-I
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TIILE REVISION DGIE l
I Qua l i t y_Ruygr an c o Doc u men tat _i_on j
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Manter Audit P1an for Radwaste Program (RWMP)
O Master Audit Plan for Process Control Program (PCON)
O Audit: 87-06-I-PCON/RWMP 06/87
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i River Bend Station Updated Safety Analysis Report 08/87 Miscel1aneous Documents RBS Condition Report No. 88-0472, Meteorological Monitoring System 06/19/88 Digital Radiation Monitoring System Data Quality Report for RE-107, RE-108, RE-125. and RE-126 Report on Liquid Effluen? Monitor (RE-107 and RE-108)
Primarv Calibrations 04/88 Qualification Mr.nual for Replacement Radiation Protection Technicians During the Stri ke ( J >.t n e 1998)
Position Description for Radiation Protection Foreman Radiation Protection Section Organizational Chart 03/88 Radwaste Section Organizational Chart Tr ining Records for B.
W.
Patin, A.
A.
Rouchon, P.
A.
Crescenzi, W.
M.
Spencer, R.
A.
Wilson of the Radwaste Section
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1-4-