IR 05000458/1989034

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Insp Rept 50-458/89-34 on 890911-15.No Violations Noted. Major Areas Inspected:Liquid & Gaseous Radwaste Mgt Programs
ML19325E957
Person / Time
Site: River Bend Entergy icon.png
Issue date: 10/30/1989
From: Murray B, Nicholas J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML19325E956 List:
References
50-458-89-34, NUDOCS 8911130109
Download: ML19325E957 (14)
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F APDENDIX

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION IV

NRC Inspection Report:

50-458/89-34 Operating License:

NPF-47 Docket:

50-458 Licensee: Gulf States Utilities (GSU)

P.O. Box 220 St. Francisv111e, Louisiana 70775 Facility Name:

River Bend Station (RBS)

Inspection At:

RBS, St. Franesiv111e, Louisiana

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Inspection Conducted:

September 11-15, 1989 Inspector:

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JfB. Nicholas, Senior (Radiation Specialist Date facilities Radiological Protection Section

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Approved:

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B. Murray, Chief. Faci 11tief Radiological Date

Protection Section I

Inspection Summary i

Inspection Concocted September 11-15, 1989 (Report 50-458/89-34)

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Areas Inspected:

Routine, unannounced inspection of the licensee's liquid end i

L gaseous radioactive waste management programs.

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Results: The inspector determined that the licensee was implementing the

radioactive wasce effluent program (RWEP) in accordance with the Radiological l

Effluent Technical Specifications (RETS) and Offsite Dose Calculation Manual (ODCM). The licensee had performed 1,096 radioactive liquid batch releases and 95 gaseous batch releases during the period January 1, 1987,

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through June 30, 1989.

The cuantities of radionculides released in the radioactive waste effluents were within the limits specified is the RETS.

Offsite doses had been calculated using methods specified in the ODCM and were

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I within Technical Specification (TS) limits. The licensee reported three unplanned radiological liquid releases during the second calendar quarter of 1989. The licensee had not made any niajor equipmer.t or design changes in the i

radioattive waste management systems since October 1987.

The licensee had submitted changes to their Process Control Program (PCP) and ODCM and had

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received NRC approval for these changes. No Licensee Event Reports (LEP.s) had 8911130109 891030

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been written in 1987, 1988, and through August 1989 involving radioactive effluent release activities. The licensee had submitted their Semiannual

- Effluent Release Reports'and respective addendum reports for 1987, 1988, and 1989 as' per TS requirements.: Quality Assurance (QA) surveillances and audits had been performed as required by the TS,

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j Within the areas inspected, no violations or deviations were identified.

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DETAILS l

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Persons Contacted I

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'J. C. Deddens, Senior Vice President, River Bend Nuclear Group

'T. F. Plunkett, Plant Manager R. J. Backen, Supervisor, Quality Systems

  • J. E. Booker, Manager, Oversight T. D. Burnett, Chemistry Foreman
  • E. M. Cargill, Director, Radiological Programs F

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  • J. W. Cook, Lead Environmental Analyst, Licensing
  • T. C. Crouse, Manager, QA J. D. Davis, QA Sarve111ance Coordinator
  • R. G. Eas11ck, Supervisor, Radwaste
  • L. A. England. Director, Nuclear Licensing C. L. Fantacci, Supervisor, Radiological Engineering
  • W. J. Fountain, Senior QA Engineer
  • P. D, Graham, Executive Assistant
  • J. R. Hamilton, Director Design Engineering R. P. Hebert, Senior QA Engineer
  • G. K. Henry, Director, Quality Operations
  • K. C. Hodges, Supervisor, Chemistry
  • R. E. Horn, Nuclear Training Coordinator - Technical D. L, Jarrell, Plant Chemist J. A. Johnson, Chemistry Training Instructor
  • G. R. Kimmel, Director, Quality Services
  • R. J. King, Supervisor, Nuclear Licensing T. P. Laiche, Radiation Protection Specialist G. D. Lipham, Senior Chemistry Specialist I. M. Malik, Supervisor, Operations QA
  • J. H. McQuirter Licensing Engineer S. D. Rima, Radiation Protection Training Instructor
  • M. F. Sankovich, Manager, Engineering Department J. E. Spivey, Internal QA Audits Coordinator

"K. E. Suhrke, Manager, Project Management

  • R. G. West, Assistant Plant Manager, Technical Services

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  • D. Williamson, QA Engineer Others
  • E. J. Ford, NRC Senior Resident Inspector - RBS W. B. Jones, NRC Resident Inspector - RBS

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  • L. G. Johnson, Manager, Technical Operations - Cajun

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  • J. M. Miller, Director, Joint Operations - Cajun
  • Denotes those present during the exit interview on September 15, 1989.

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Inspector Observations

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The following are observations that the inspector discussed with the

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licensee during the exit interview on Sep. ember 15, 1589. Observations are not violations, deviations, unresolve d items, or open items. These observations were identified for licenser censideration for program i

improvement, but the observations have no specific regulatory requirement.

The licensee stated that the observations,ould be reviewed, i

a.

Nuclear Trainino Department Records - The licensee had not included

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in an individual plant staff's computerized permanent training record i

any training received prior to Institute of Nuclear Power l

Operations (INPO) accreditation, (See paragraph 4)

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0A Surveillance Reports - The licensee had not performed a QA surveillance directly related to the performance of the RETS

activities during 1988 and 1983.

(See paragraph 7)

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Organization and Management Controls (84750)

f The inspector reviewed the licensee's organization, staffing, and staff functional assignments related to the liquid and gaseous radioactive waste programs to determine agreement with commitments in Chapters 13.1.2 and

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13.5 of the Updated Safety Analysis Report (USAR) and compliance with the

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requirements in Section 6.2 of the TS.

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The inspector verified that the organizational structures of the RBS radwaste operations section, radiological engineering section, and chemistry / radiochemistry section (C/RS) responsible for the perfermance of

the 3'EP were as defined in the FSAR and TS. The RBS staff assignments,

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management control procedures, and position descriptions were reviewed for

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the assignment of responsibilities for the management and implementation

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of the RWEP.

The organizational structure and staffing of the radwaste e

operations section, radiological engineering section, and C/RS for managing and implementing the RWEP arpeared to be sufficient to meet tho

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requirements for the routine perfor'ance of the liquid and gaseous

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radwaste activities.

The inspecto verified that the administrative

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control responsibilities specified in the RBS procedures were being

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implemented.

Selected procedures listed in Attachment I to this report

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were reviewed.

The inspector reviewed the staffing of the radwaste operations section,

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radiological engineet Ing section, and the C/RS and determined that all three sections were fully staffed except for two nuclear chemistry technician position vacancies.

No violations or deviations were identified.

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Training and Qualifications (84750)

The inspector reviewed the licensee's training and qualification program for nonlicensed nuclear equipment operators, radiological engineering i

staff, and C/RS personnel responsible for conducting the RWEP to determine

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agreement with commitments in Chapter 13.2 of the USAR and compliance with the requirements in Sections 6.3 and 6.4 of the TS.

i The inspector reviewed the qualifications of the present. radiological

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engineering section staff and selected personnel from the radwaste

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operttions section and C/RS responsible for the implementation of the RWEP i

and verified that they met the required qualifications specified in the

USAR and TS.

It was determined that the licensee had an adequately l

qualified staff.

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The inspector reviewed the licensee's training program for radwaste

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nuclear equipment operators, radiation protection specialists, and C/RS

nuclear chemistry technicians, including a review of the various training

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instructors' qualifications, training facilities, training procedures, i

course descriptions, job performance measures, and individual staf f

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training records. The inspector found that the licensee's training I

programs for the three areas; radwaste operation, radiation protection,

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and chemistry were being implemented and documented in accordance with

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RBS procedures.

It was determined that the RBS nuclear training department had received INPO accreditation.

The inspector reviewed individual staff training records for selected

nuclear equipment operators, radiological engineering personnel, and C/RS personnel who perform RWED activities.

The inspector verified that all of

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the selected RBS staff responsible for various aspects of the RWEP had

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completed the required training on the RETS, ODCM, and radwaste systems to

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perform liquid and gaseous effluent releases in accordance with RBS

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procedures and TS. However, it was noted that any training received by i

RBS personnel prior to the INPO accreditation of the nuclear training

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department was not included as part of an individual's computerized i

permanent training record.

This made the tracking of an individual's

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training in. specific task areas difficult if that individual had been l

trained using procedures, course materials, and lesson plans which were

'i utilized prior to INPO accreditation.

This observation was discussed with the licensee during the inspection and at the exit interview on

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September 15, 1989. The licensee agreed to evaluate the inspector's concern for an individual's complete training documentation not being

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included in the nuclear training department's computerized permanent

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training records, j

No siolations or deviations were identified.

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6.

Liouid Radioactive Waste Systems (84750)

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program including:

liquid waste system operation, liquid waste sampling.

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and procedures for liquid waste effluent systems to determine agreement

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with commitments in Chapter 11 of the USAR and compliance with the

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l requirements in Sections 3/4.11.1.1, 3/4.11.1.2, 3/4.11.2.3, 3/4.11.1.4,

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l 6.8, 6.14, and 6.15 of the TS and the ODCM.

The inspector reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits,

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analytical results, sampling requirements, surveillance tests, RWEP

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operating procedures, and off site dose projections and results from liquid radioactive waste effluents.

Selected documents and records listed in

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' Attachment 1 to this report were reviewed.

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'The inspector reviewed current approved revisions of RBS procedures governing the release of liquid radioactive waste.

These liquid effluent t

release procedures provide for the following:

representative sampling of

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liquid radioactive waste; chemical and radionuclide analyses prior to

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release; calculation of effluent release rate, effluent radiation monitor

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setpoints, projected offsite racionuclide concentrations, and offsite l

doses prior to release; recording effi v nt dilution parameters during releases; and verifying effluent discharge flow rates and effluent volume

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discharged.

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The inspector reviewed a representative number of liquid release permits l

for the period January 1988 through August 1989.

It was determined that I

the processing, sampling, and analysis of liquid radioactive waste

effluent and approval and performance of liquid radioactive waste

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discharges were conducted in accordance with RBS procedures. Quantities i

of radioactive nuclides released in the liquid effluents were within the l

limits specified in the RETS.

Offsite doses had been calculated according

to the CDCM and were within the TS limits.

Eff1 vent radiation monitor

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setpoints were calculated in accordance with the ODCM.

The inspector determined that no design changes had been made to the I

liquia radwaste systems since the previous NRC inspection of this area

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conducted in June 1988.

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No violations or deviations were identified.

6.

Gaseous Radioactive Waste Systems (84750)

The inspector reviewed the licensee's gaseous radioactive waste effluent program including:

gaseous waste system operation, gaseous waste

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sampling, procedures for gaseous waste effluent systems, and air cleaning l

systems to determine agreement with commitments in Chapter 11 of the USAR i

and compliance with the requirements in Sections 3/4.6.5.4, 3/4.6.5.6, l

3/4.7.2, 3/4.11.2.1, 3/4.11.2.2, 3/4.11.2.3, 3/4.11.2.5, 3/4.11.2.6, 3/4.11.2.7, 6.8, 6.14, and 6.15 of the TS and the ODCM.

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The inspector reviewed the licensee's implementation of the RETS and ODCM to ensure agreement with analysis sensitivities, reporting limits, analyt! cal results, sampling requirements, surveillance tests, RWEP operatitig procedurcs, and offsite dose projections and results from ganous effluents.

Selected documents and records listed in Attachment I to this report were reviewed.

The inspector reviewed current approved revisions of RBS procedures and surveillance tests which govern the release of ga',eous radioactive waste.

These gaseous effluent procedures and surveillant.e tests provide for the following:

representative sampling of gaseous radioactive waste, calculation of offsite doses, and verification ref effluent discharge flow rates and effluent volume discharged.

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The inspector reviewed selected analyses of sampics taken from the main plant exhaust duct, fuel building ventilation, and radwaste building ventilation continuous release paths for the period January 3988 through July 1989.

It was determined that the continuous gaseous waste releases were being performed according to procedure and the quantities of gaseous radioactive nuclides released were within the limits specified in the RETS. Offsite doses had been calculated according to the ODCM and were within the TS limits.

The inspector reviewed weekly noble gas activity data measured prior to the offgas holdup pipe and determined that the TS requirement was being met. The inspector reviewed selected operation's daily surveillance ico sheets for the period January 1988 through August 1989 and verified continuous monitoring of the hydrogen concentration in the offgas treatment v s em.

The inspector determined that no design changes had been made to w e gaseous radwaste management systems since the previous NRC inspection in June 1988.

The inspector reviewed the licensee's prxedures, surveillance tests, and selected records and test results for maintenance and testing of air cleaning systems which contain high efficiency particulate air (HEPA)

y filters and activated charcoal adsorbers.

The inspector verified that the licensee's procedures and surveillance tests provided fer the required

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l periodic functional checking of ventilation system components, evaluation

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of HEPA and activated charcoal adsorbers, and replacement and in place L

filter testing uf the filter systems. The inspector reviewed records and l

test results for the period January 1987 through August 1989 for the main control room air conditioning system, fuel building ventilation system, and the standby gas treatment system. The in place filter testing and j

activated charcoal laboratcry tests had been performed in accordance sith

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I approved procedures by a contract laboratory and the test results were

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l verified to be within TS lin.its except on two surveillance tests of the

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charcoal adsorber material found in the Fuel Building Ventilation Filter, HVF-FLT-28, tested on August 22, 1989, and in the Standby Gas Treatment System Filter, ISTS FLT-1B, tested on November 3,1988.

It was

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noted that the licensee took immediate corrective action following the

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unacceptable test results ar.d replaced the unsatisfactory activated charcoal adsorber material iti each of the filter systems.

The new activated charcoal adsorber material was tested and the test results met

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-0-i TS requirements. The inspector reviewed and verified the test results of the replacement activated charcoal adsorber material, The licensee had performed QA audits on the contractors performing the testing on the i

station ventilation systems and had placed the contractors on the RBS

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qualified suppliers list.

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No violations or deviations were identified.

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QA Audit Program (84750)

The inspector reviewed the licensee's QA surveillance and audit programs for the RWEP to determine agreement with commitments in Chapter 17 of the l

USAR and the requirements in Section 6.5.3.8 of the TS.

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ine inspector revie ed the QA surveillance and audit plans and checklists, selected QA department proccdures, audit schedules for 1988 and 1989, and

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the qualifications and training of the QA surveillance inspectors, QA

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auditors, and technical specialists who performed the surveillances and audits of the RWEP activities. Surve111ances and audit reports of QA

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activities performed during 1988 through August 1989 in areas related to

radwaste processing were reviewed for scope, thoroughness of program evaluation, and timely followup of identified deficiencies. The inspector determined that the QA audits were performed by qualified personnel

knowledgeable in radioactive waste activities at nuclear power facilities and an effective use of technical specialists was b61ng implemented. The

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licensee's QA audits had been performed in accordance with RBS QA proceoures and schedules and had not identified any significant problems.

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The documents which were reviewed are listed in Attachment I to this l

report.

It was noted by the inspectur that the QA operations surveillance section was unable to produce a QA surveillance report for the period of

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January 1988 through August 1989 which was directly related to the l

performance of RETS activities and the associated N surveillance

requirements.

However, QA surveillances have no specific regulatory requirement.

It was apparent that the licensee did not have a means for I

readily retrieving or determining if a QA surveillance had been performed i

on a specific RBS surveillance test procedure in a specific area of plant

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activities.

This observation was discussed with the licensee during the inspection and at the exit interview on September 15, 1989.

The licensee t

indicated they would evaluate the inspector's concerns for the lack of QA

surveillance activities involving the RWEP and especially the t

implementation of the RETS and ODCM and the lack of ability to readily

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retrieve or determine if a QA surveillance report covering specific RETS i

surveillance activities had been performed.

i The inspector determined that the licensee was using a contractcr

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laboratory to perform TS required radiochemistry analyses on several

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radioactive effluent composite samples.

The licensee oss also using j

several contractors to perform in place filter testing and laboratory charcoal adsorber analyses on the station ventilation systems as required by TS. The licensee had performed QA audits on all of tnese :ontractors i

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and had placed them on the R.

qualified suppliers list.

The inspector r4 viewed the audits performee the licensee on tne contractors and found

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the audits to be adequate.

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No violations or deviations were identified.

8.

Licensee Event Reports (LERs) (84750)

The inspector determined that the license had not written any LERs since l

the previous NRC inspection of the radioactive waste effluents program in June 1988 that irivolved radioactive effluent release activities.

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No violations or deviations were identified.

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Reports of Radioactive Waste Effluents (S4750)

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The inspector reviewed the licensee's reports concerning radioactive waste systems and effluent releases to determine compliance with the i

requirements of 10 CFR Part 50.36(a)(2) and Section 6.9.1.8 of the T5.

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The inspector reviewed the licensee's semiannual effluent release reports for the periods January 1 through June 30,1987; July 1 through

December 31, 1957; January 1 through June 30, 1988; July 1 through t

December 31, 1988; and January 1 through June 30, 1989. These reports

were written in the format described in NRC Regulatory Guide 1.01 and

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contained the information required by TS.

During the period January 1,

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1987, through June 30, 1989, the licensee had performed 1,096 liquid batch relev.es and 95 gaseous batch releases.

The licensee reported three r

unplanned radiological liquid releases to the environment duH ng the

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second calendar quarter of 1989.

The inspector reviewed the licensee's

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changes to the ODCM and PCP as detailed in the appropriate semiannual effluent release reports as per TS requirements.

Wo violations or deviations were identified.

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Exit Interview (30703)

The-inspector met with the senior resident inspector and the licensee I

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representatives denoted in paragraph 1 at the conclusion of the inspection on September 15, 1989.

The inspector summarized tne scope and findings of

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the inspection and discussed the inspector's observations. The licensee l

representatives stated at the exdt interview that they would evaluate the

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inspector's observations and concerns and take appropriate actions to

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implement program improvements.

The licensee did not identify as l

c proprietary any of the materials provided to or reviewed by the inspector

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during the inspection.

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ATTACHMENT 1

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.-("'o RIVER BEND NUCLEAR STATION

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50-458/89-34'

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NRC Inspection Report i

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DOCU!iENTS REVIEWED u

Title Revision Date j

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Aoministrative Procedures j

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ADH-0001, Plant Staff Organization, I

Responsibilities and Authorities

10/17/88-ADM-0007, Selection Training, Qualification

s and Evaluatiori of Plant' Staff Personnel

08/18/88 l

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ADM-0015, Station Surveillance Test Program

02/09/89

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ADM-0036, Containment Purge Information

10/17/88

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ADM-0038, Radioactive Waste Management Program

06/05/89'

,j ADM-0042, Conduct of Chemistry 4.

10/21/87

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ADM-0054, Radioactive Liquid Effluent 8atch i

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Discharge

05/19/88 i

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Radwaste Procedures, i

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RWS-0203, Personnel. Qualification for Radwaste

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11/14/88

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'RWS-0204, Radwaste Processing Control Program 2.

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i RWS-0206', Radwaste Scaling Factors Program

06/05/89 t

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RWS-0009, Conduct of Radwaste Vendor Services

11/17/87 l

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RWS-0211, General Performance Control for Radwaste

04/13/89 l

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'RWS-0212, Radwaste Process Logs and Records

03/28/89 l

RWS-0304, Radioactive Waste Handling and Control

03/08/89 o-u L

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Chemistry Section Procedures j

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a LSP-0003, Chemistry Personnel Qualifications

04/07/89 i

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$P CSP-0100, Chemical / Radiochemical Technical

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Specifications ~Surveillances'

08/16/88-

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CSP-0103, Chemistry Section 10 CFR 61 Compliance

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Progran.

02/12/88

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CSP-0110, Radioactive Liquid Effluent Batch Discharges

07/27/88

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Chemistry Operatina Procedures

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COP-0001, Sampling via Various Balance-of-Plant I

Sample Panels

05/03/89-

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COP-0007, Sampling the Off-Gas Treatment Sample Panels

07/16/87

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t COP-0046, Sampling Gaseous Effluents via the Wide Range Gas Monitors.

02/02/89-

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COP-0050, Grab Sampling Gsseous Streams

09/08/87

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COP-0057. Gra's Sampling of Liquid Monitors

08/11/89 l

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COP-0301, Operation of the Beckman Liquid

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Scintillation Counter, Series LS-3800

04/18/88

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. COP-0303, Operation of the Canberra Multi-Channel i

Analyzer, Series 90.

03/10/87

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. COP-0304, Operation of Eberline Solid State Scintillation Counting System-Model

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MS-2/RD-13.

02/12/87

100P-0601, Analysis of Air for Tritium, Silica Gel

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Method'

12/16/87

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COP-0602, Analysis of Aqueous Samples for Tritium

01/06/88

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. COP-0613, Determination of Alpha Activity

09/05/87

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COP-0804, Determination of Gamma Spectroscopy

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"a Priori" Lower Limits of Detection (LLD)

04/22/87

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COP-0809, DRMS System Operation

01/18/89

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' Chemistry Operatina Procedures (Cont)

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COP-1003, Post-Accident Sampling of Gaseous Effluents

09/06/89

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COP-1004, Post-Accident $ampling of Liquid Effluents

12/19/87'

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Radiation Section Procedures

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b RSP-0008, Of' site Dose Calculation Manual

(ODCM) Procedure

02/14/89

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Radiation Protection Procedures

,3 RPP-0097, Manual Method of Determining Cumulative Dose Contributions from Liquid Effluents

08/11/88 l

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RPP-0102, Dose Calculation from Gaseous Effluents

08/11/88

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Radiation Health Physics Procedure

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.RHP-0032, Dose Rate Calculation from Gaseous Effluents 0-08/05/88

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8.. Surveillance Test Proc dure

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j STP-000-001, Gaily Operating Legs

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Y 9. 10uality Assurance Prncedures

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QAP-l'2, Quality Assurance / Quality Control

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Organizations Responsibilities, and Duties

10/26/87

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10. Quality Assurance Instructions

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QAI-2,0', Plannin0 and Scheduling GSU Quality

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Assurance-Audits

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02/07/89

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QAI-2.1, Audit Perf a r sce, Reporting and Followup

09/14/88

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QAl-2.3, Planning,' Scheduling, and Reporting QA

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v Surveillance of Plant. Activities

09/20/88

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' QAI-2.4, Quality Assurance Evaluation of Supplier /

Contractor QA Programs

05/03/88 QAl-2.11, Qualified Supplier List

01/06/88 l

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11. Quality Assurance Surveillar.ces and Audits

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1988-1989 QA Audit Schedule

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QA Surveillance Report:

05-88-10-12 " Chemistry Tech.

Spec, Surveillances for S/U," performed October 13, 1988 l

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-QA Surveillance Report:

05 88-06-42, " Conduct of Chemistry

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and F/U 05-87-11-14," performed July 22, 1988

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-QA Surveillance Report:

05-89-05-46, " Surveillance Test

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Performance Program." performed May 27, 1989

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05-87-03-03, "Radwaste Management IE. Notice 87-07,"

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performed March 14, 1987

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83-01-I-0DCM, "Offsite Dose Calculation Manual Program,"

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QA Audit Report:

88-05-I-CHEi4, " Chemistry Program." herformed May 10-19,1988

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.QA Audit Report:

88-09- -PCON/RWMP,," Rad.oactive Waste Management and Process Programs," performed Septe:rber 6-15, 1988

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89-06-I-PCON/RwMP, " Process Contro': 'and Radioactive Waste Management Programs," performed June 13-22, 1989 y

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QA Vendor Audit Report:

86-12-A-0163, Chem-Nuclear Systems, Inc., performed

, December 16-18, 1906 (

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QA Vendor Audit Report: 88-11-P-0261, Nuclear Consultirg Services, Inc.,

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QA Vendor Audit Report:, 88-09-P-0256, Controls for Environmental sollution, i

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88-07-P-0253. Environmental Enpineering and

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. Testing', performed July 19-21, 1968 I

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87-02-P-0228, Nuclear Air Filtration Testing l

Associater, performed February 18 19, 1987 i

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July 1 throtgh De:; ember 31, 1988

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January 1 through June 30, 1989

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