IR 05000498/1986024

Insp Repts 50-498/86-24 & 50-499/86-22 on 860811-15.No Violations or Deviations Noted.Major Areas Inspected: Chemistry/Radiochemistry Program & post-accident Sampling Sys

ML20214M614
Person / Time
Site:	South Texas
Issue date:	09/04/1986
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214M612	List: IR 05000498/1986024 ML20214M608
References
50-498-86-24, 50-499-86-22, NUDOCS 8609110199
Download: ML20214M614 (14)

Text

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APPENDIX U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report: 50-498/86-24 Construction Permits: CPPR-128 50-499/86-22 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project Electric Generating Station, Units 1 and 2 (STP)

Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: August 11-15, 1986 Inspector: _

f/Mrd, J Blair Nicholas, 5enior Radiation Specialist, Date '

acilities Radiological Protection Section Appraved:

nl /b]JAl(Alf Gl$A B'.' Murray, ChieT, Facili ies Radiological D'4te'

Protection Section

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Inspection Summary Inspection Conducted August 11-15, 1986 (Report 50-498/86-24; 50-499/86-22)

Areas Inspected: Routine, announced preoperational inspection of the licensee's chemistry / radiochemistry program, including organization and management controls, staffing and staff qualifications, training, primary chemistry program, secondary chemistry program, primary chemistry sampling, secondary chemistry sampling, facilities and equipment, analytical instrumentation, audits and review of chemistry / radiochemistry activities, procedures, and postaccident sampling syste PDR ADOCK 05000498 G pga

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Results: Within the areas inspected, no violations or deviations were identifie Eleven open items are identified in paragraph ;

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-3-DETAILS

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• Persons Contacted HL&P $

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• H. Kinsey, Plant Manager S. E. Citzler, Lead Chemistry Technician J. C. Dierickx, Chemical Support Supervisor .

• B. A. Franta, Manager, Staff Training

• R..A. Gangluff, Chemical Analysis Supervisor R. B. Garcia, Chemistry Training Instructor K. E. Haviland, Chemical Technician

• S. M. Head, Lead Licensing Engineer, Project Compliance

• W. G. Isereau, Operations Quality Assurance (QA) Audits / Surveillance Supervisor D. R. Keating, Operations QA General Supervisor C. L. Kern, QA Specialist R. A. Latsch, Nuclear Chemist

• J. W. Loesch, Plant Superintendent

• M. A. McBurnett, Supervising Engineer Site Licensing R. L. Meier, Senior Chemistry Training Instructor R. E. Schirmer, Lead Chemistry Technician D. A. Tomas, Nuclear Training Program / Administrative Support Services

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Supervisor

• T. E. Underwood, Manager, Chemical Operations & Analysis (C0&A)

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Others

• D. R. Carpenter, Senior NRC Operations Resident Inspector

• G. L. Constable, Chief, Reactor Projects Section C

• Denotes those present during the exit briefing on August 15, 198 The NRC inspector also interviewed several other STP station personnel during the inspectio . Open Items Identified During This Inspection Open items are matters that require further review and evaluation by the NRC inspector or the licensee. Open items are used to document, track, and ensure adequate followup on matters of concern to the NRC inspecto Open Item Description Reference Paragraph

(498/8624-01) Chemical Analysis Section 4 Personnel Qualifications

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(498/8624-02) Chemical Analysis Section 5-Training Program (498/8624-03) Primary Chemistry Program 6 (498/8624-04) Secondary Chemistry Program 7 (498/8624-05) Primary Chemistry Sampling System (498/8624-06) Secondary Chemistry Sampling System 9 (498/8624-07) Postaccident Sampling System 10 (498/8624-08) Facilities and Equipment 11 (498/8624-09) Chemistry / Radiochemistry Analytical 12 Instrumentation (498/8624-10) Quality Assurance Program 13 (498/8624-11) Procedures 14 Chemical Operation and Analysis Organization and Management Controls The NRC inspector reviewed the licensee's organization and staffing regarding chemistry and radiochemistry activities to determine agreement with commitments in Section 13.1.2 of the Final Safety Analysis Report (FSAR).

The NRC inspector verified that the organizational structure of the C0&A division was as defined in the FSAR and STP procedures. -The NRC inspector reviewed STP management control procedures and position descriptions for the assignment of responsibilities for the management and implementation of the STP secondary chemistry and primary chemistry program The duties and responsibilities of the C0&A staff were adequately described in approval procedures and position description The NRC inspector reviewed the staffing of the chemical analysis section (CAS) and chemical support section (CSS) of the C0&A division and noted tnat all of the 27 staff positions approved for Unit 1 had been fille The number of chemical analysis and support personnel appeared to be sufficient to meet staffing requirements for a routine five shift rotatio No violations or deviations were identifie . Chemical Analysis Section Personnel Qualifications The NRC inspector reviewed the qualifications of the C0&A division staff in regard to the CAS and CSS to determine agreement with commitments in

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-5-Section 13.1.3 in the FSAR and the recommendations of Regulatory Guides (RG) 1.8 and 4.15, and ANSI /ANS 3.1-198 The NRC inspector reviewed the resumes of the present CAS and CSS staff to determine if the members of the staff met the education and experience qualification recommendations for chemistry / radiochemistry personnel as outlined in ANSI /ANS 3.1-1981. Based on the review of the CAS and CSS staff resumes it was noted that all supervisors, lead chemistry techni-cians, senior chemistry technicians, and the nuclear chemist met the ANSI /ANS 3.1-1981 qualifications. The six chemistry technicians and seven associate chemistry technicians had not met the experience requirements of 3 years in their specialty at the time of the inspection. The NRC inspec-tor reviewed the CAS personnel shift assignments and determined that each of the five shifts had at least one person on shift who met the ANSI recommended qualification The NRC inspector reviewed the on-the-job (0JT) qualification cards for the CAS personnel. It was noted that not all of the lead chemistry technicians, senior chemistry technicians, chemistry technicians, and associate chemistry technicians presently on staff had completed all three phases of.0JT qualification requirements. This item is considered open (498/8624-01), pending all CAS non-supervisory personnel onsite prior to August 1, 1986, completing through phase III OJT qualificatio ,

No violations or deviations were identifie . Chemical Analysis Section Training Program The NRC inspector reviewed the licensee's CAS training program to determine agreement with commitments in Section 13.2.2.2 in the FSA The licensee's training facility was inspected and found to include offices, classrooms, and a chemistry / radiochemistry laboratory and counting room which are to duplicate in many aspects the plant's chemistry laboratories and counting facilit The laboratory and counting room were not fully equipped with analytical equipment at the time of the inspectio The NRC inspector discussed the training program for CAS personnel with the nuclear training department manager for staff training and the two chemistry training instructors who had developed the CAS training progra The NRC inspector reviewed selected interdepartmental training procedures and selected nuclear training department procedures which administer and implement the nuclear training program. A training program for CAS personnel had been developed and the NRC inspector reviewed the course outline, objectives, and associated lesson plans for the three phase i chemistry analysis technician training program (CATTP) designed for j inexperienced entry level personnel and the specialized chemical analysis i technician training program (SCATTP) developed for personnel with prior j nuclear chemistry experience. The NRC inspector found the CAS training i

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-6-courses and associated 0JT qualification training adequate to prepare the CAS staff for their technical dutie The NRC inspector reviewed selected CAS staff individual training and OJT records. The records indicated that four out of the five senior chemistry technicians had completed the SCATTP training and 6 out of the 13 chemistry technicians had completed the three phase CATTP. The seven associate chemistry technicians were scheduled to start CATTP phase III instruction on September 8, 1986. This item is considered open (498/8624-02) pending all CAS non- w pervisory personnel onsite prior to August 1, 1986, completing CATTP or SCATTP qualification trainin No violations or deviations were identifie . Primary Chemistry Program The NRC inspector reviewed the licensee's primary chemistry program to determine agreement with commitments in Section 5 in the FSAR and Section 3 in the proposed Technical Specifications (TS).

The NRC inspector reviewed the licensee's primary chemistry program.and found that it appeared to agree with the FSAR and the proposed TS. It was noted that most of the administrative procedures, surveillance procedures, chemical control procedures, instrument calibration and quality control procedures, and analytical procedures had been completed and approve ~

Several procedures in the areas of administration, primary system chemical control, and analytical analysis had been identified by the licensee and were in various stages of developmen The NRC inspector reviewed selected primary chemistry procedure The licensee had approved procedures for the operation, calibration, and quality control check of the currently acquired analytical instrumentation except for the gas chromatograph which was in developmen The licensee had not developed detailed procedures for the preparation and quality control of nuclear instrument radioactive calibration standards traceable to the National Bureau of Standards (NBS). The licensee had not completed calibration of any in-line process instrumentation or hot laboratory analytical instrumentation which is to be used to support the primary chemistry progra This item is considered open (498/8624-03) pending:

Completion of all identified administrative procedures, primary chemistry system procedures, TS surveillance procedures, primary chemistry analytical procedures, instrument calibration procedures, and instrument quality control procedure * Development of detailed preparation procedures for all nuclear instrument radioactive calibration standards which are traceable to the NB . -.

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Calibration of all primary chemistry in-line process instrumentation and hot laboratory analytical instrumentation and implementation of an approved instrument quality control progra Verification of all primary chemistry analytical procedures using known standard No violations or deviations were identifie . Secondary Chemistry Program The NRC inspector reviewed the licensee's secondary chemistry program to determine agreement with commitments in Sections 9 and 10 in the FSAR and Section 3 in the proposed T The NRC inspector reviewed the licensee's secondary chemistry program and found that it appeared to agree with the FSAR and proposed TS. The program development appeared to be on schedule and near completion. The NRC inspector noted that many of the implementing and analytical procedures had been completed and approved. Several procedures in the areas of chemical addition and secondary plant chemical process systems operations had been identified by the licensee and were in various stages of developmen The NRC inspector reviewed selected secondary chemistry procedure The licensee had developed approved analytical procedures for the determination of most of the chemistry parameters to be measured to support station startup and operating requirements. The procedures appeared to be adequate to monitor and control the secondary chemistry progra The licensee had approved procedures for the operation, calibration, and quality control check of most analytical and in-line process instrumentation to be used in the support of the secondary chemistry program. The remaining identified procedures were in various stages of developmen The licensee had not completed calibration of all in-line process instrumentation or cold laboratory analytical instrumentation which is to be used to support the secondary chemistry progra This item is considered open (498/8624-04) pending:

Completion of all identified administrative procedures, secondary chemistry system procedures, secondary chemical control and analytical procedures, instrument calibration procedures, and instrument quality control procedure Calibration of all secondary chemistry in-line process instrumentation and cold laboratory and MUD analytical

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-8-instrumentation and implementation of an approved instrument quality control progra *

Verification of all secondary chemistry analytical procedures using known standard ,

No violations or deviations were identifie , Primary Chemistry Sampling System The NRC inspector reviewed the licensee's primary chemistry sampling ,

system to determine agreement with commitments in Sections 9 and 11 in the

, FSAR and in Sections 3 and 6 in the proposed T The NRC inspector inspected the Unit 1 primary chemistry sampling are At the time of the inspection, the Unit l' primary chemistry sample panel

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was not completely installed and checkout of the panel instrumentation and valves had not been scheduled. The sample lines had not been traced and measured as a basis for determining sample line flush times. The licensee had not verified tank volumes for all potentially contaminated tanks and had not determined recirculation times and sample flush times to produce representative samples. The licensee had not written an approved sampling procedure to operate the primary sample panel and obtain grab sample Specific sampling procedures had not been written to provide step-by-step guidance for collection of all primary chemistry samples which would include such information as sampling frequency, sample point valve identification, sample point location, sampling valve lineups, specific tank recirculation times, sample line flush times to provide a representative sample, sample quantity, and sample container labelin This item is considered open (498/8624-05) pending:

Installation and complete testing of the primary sampling panel and verification of all sample point *

Verification of primary chemistry and radwaste tank volumes and tank recirculation times (where applicable) to produce representative samples.

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Determination of sample line flush times for each primary chemistry sample point to produce a representative sampl *

Completion of approved sampling procedures and valve lineups for use of the primary sampling panel and development end implementation of detailed procedures for each primary chemistry system to be sample No violations or deviations were identifie . ._ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

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-9- Secondary Chemistry Sampling System s

The NRC inspector reviewed the licensee's secondary chemistry sampling system to determine agreement with commitments in Section 10.in the FSAR and in Sections 3 and 6 in the proposed T ,

The NRC inspector inspected the Unit 1 various secondary chemistry sampling areas. The sampling areas inspected included those for water treatment systems, makeup demineralized water system, secondary support systems, and the plant secondary system including condenser, condensate polishing, and steam generator The NRC inspector determined that the condensate polishing sampling panel had not been installed. The sampling panels for secondary support systems, condenser, steam generators, and process analyzer panels were conveniently installed in the cold chemistry laboratory. The sampling panels were installed but not turned over to the licensee from construction. The sample points and sample lines had not been verifie The process analyzers were installed, but were not checked and calibrate Sample points had been identified for all secondary chemistry systems and tanks. The licensee had not verified secondary chemistry tank volumes and had not determined sample line flush times to produce representative sample This item is considered open (498/8624-06) pending:

Installation and complete testing of all the various secondary chemistry sampling panels and verification of all sample point Installation and complete testing and calibration of all the secondary chemistry process analyzer Verification of all secondary chemistry tank volumes and tank recirculation times (where applicable) to produce representative sample *

Determination of sample line flush times for each secondary chemistry sample point to produce a representative sampl Completion of approved sampling procedures and valve lineups for use of all the various secondary chemistry sampling panels and development and implementation of detailed sampling procedures for each secondary chemistry system to be sample No violations or deviations were identifie ._ - . . _- -.

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-10-1 Postaccident Sampling System The NRC inspector reviewed the licensee's PASS to determine agreement with commitments in Section 9.3.2 in the FSAR and the requirements in NUREG-0737, Item II. The NRC inspector inspected the area in Unit 1 where the PASS was being installed. The liquid and gas sample panel, PASS laboratory fume hood, and PASS control panels were installed, but sample lines and ventilation ducts were not connected. The PASS in-line instrumentation was installed in the various PASS panels, but had not been tested or calibrated. The PASS laboratory construction had not been completed. Postaccident sample radionuclide analysis procedures and backup analytical procedures to in-line analyzers had not been writte ~

This item is considered open (498/8624-07) pending: .

Installation of proposed system, completion of operating and analysis procedures, and calibration of in-line instrumentatio Implementation of a maintenance and quality control' program on the PAS *

Completion of theoretical and operational training of CAS technicians on the PAS ~

Checkout of system operation by performing trial runs using the- -

sample transport devices and sample preparation laboratory facilitie Verification of system performance by collecting samples of reactor coolant and containment atmosphere under simulated accident conditions and performing required comparative analyse The NRC inspector stated that a detailed review of the completed PASS and associated procedures will be conducted during subsequent inspections prior to plant operation No violations or deviations were identifie . Facilities and Equipment The NRC inspector inspected the facilities and equipment to be used by the CAS staff in performing their various chemistry support responsibilitie The following facilities were inspected: cold laboratory, MUD laboratory, hot laboratory, radiochemistry counting room, chemistry sampling panels, PASS control room and laboratory, training chemistry laboratory, training l counting room, and CAS personnel work areas. It was noted that the l licensee had not completed construction of all the chemistry and radiochemistry facilitie . - . - --. .-. .

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N-11-At the time of the inspection, the cold laboratory was not equipped with instrumentation and not operational. The hot laboratory, radiochemistry counting room, and PASS control room and laboratory were in various stages of construction. The training chemistry laboratory and counting room were completed, partially equipped with instrumentat. ion, and semi-operationa The laboratory areas appeared to provide adequate spac The chemistry sampling panel areas were still under construction and some sample panels were not yet installed except for the secondary systems and steam generator sample panel which was nearly complete This item is considered open (498/8624-08) pending completion of construction and routine occupancy of all the CAS work area No violations or deviations were identifie . Chemistry / Radiochemistry Analytical Instrumentation and Quality Control The NRC inspector reviewed the licensee's inventory of analytical equipment and supplies to be used in the laboratories and counting roo The type and quantity of analytical instrumentation on hand and proposed appeared to be adequate to perform the analyses specified in the FSAR and proposed TS. Most of the instruments were located in temporary work areas'

or storage and were not all operationa The NRC inspector verified that the licensee had demonstrated operability of nearly all the laboratories' analytical instrumentation and had calibrated and implemented a quality control check program on~ selebted - -

chemistry analytical instrumentation to support startup activities. Many of the instruments were still in the process of being setup and calibrated. The quality control program was not totally implemente The NRC inspector reviewed the status of the counting room instrumentation calibration and quality control to determine agreement with the recommendations of ANSI N323-1978 and RG 4.15. None of the counting instruments had been calibrate This item is considered open (498/8624-09) pending:

Procurement of remaining proposed instrumentation, supplies, and spare parts for Unit 1 instrumentatio Final location and placement of the analytical equipment in the respective work area Completion of operating, calibration, and quality control check procedures for all analytical instrument *

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Implementation of an instrument quality control check program.for all analytical instrument No violations or deviations were identifie . Quality Assurance Program The NRC inspector reviewed the licensee's internal audit / surveillance .

program regarding CAS activities to determine agreement with commitments in Section 17 in the FSAR, the requirements of 10 CFR,Part 50, Appendix B, and the recommendations of ANSI N18.7-1976, and RGs 1.33, 1.144,.1.146, and 4.1 .

The NRC inspector reviewed the QA department organization, selected QA audit and surveillance procedures, audit and surveillance schedules for

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1986, QA auditor qualifications, and audit and surveillance reports. A review of the existing audit program was conducted to determine if'the audit program as it relates to the CAS included in its scope the following areas: s Reviews performed by supervision within the CAS of such activities as staff effectiveness, work practices, adequacy of staff training, and procedural complianc *

Audits performed to ensure compliance with TS and Code of Federal Regulation Audit format, including the existence of audit procedures and checklists, to provide an insight regarding the adequacy and scope of the proposed audit activitie *

Audits in the areas of plant water quality and secondary chemistry control of feedwater and steam generator water qualit *

Audits in the areas of laboratory instrument operation, calibration, and calibration check *

Audits in the area of instrument radioactive calibration sources validity and their contro Audits in the area of chemistry and radiochemistry procedural accurac Composition of audit teams to ensure that team members possess the necessary technical expertise to evaluate the assigned are Corrective action program to provide timely resolution of identified deficiencie The NRC inspector reviewed reports generated from audits and surveillances performed during 1985 and 1986 in the areas of secondary chemistry and

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-13-radiochemistry for scope to ensure thoroughness of program evaluation and timely followup of identified deficiencie The NRC inspector found that the STP QA audit program was in a stage of development and had not developed the CAS audit / surveillance program to cover'all the above area .The scope of the audit reviewed dealt primarily with procedural review and compliance and was very limite The NRC inspector determined that the licensee was making an effort to have a well qualified audit / surveillance staf However, the QA department did not have an auditor on staff who had chemistry and radiochemistry experience and was technically knowledgeable in chemistry / radiochemistry procedures and activities at nuclear power facilitie This item is considered open (498/8624-10) pending:

Development and implementation of a comprehensive audit and surveillance program for CAS activities covering at least the areas listed abov *

Completion of detailed checklist *

Selection of qualified audit team members and technical specialists to perform chemistry / radiochemistry audits and surveillance *

Completion of scheduled audits and surveillances of the CAS program and activities prior to fuel load and plant operatio No violations or deviations were identifie . Procedures The NRC inspector reviewed the licensee's C0&A division procedures to determine compliance with 10 CFR Part 20 requirements and agreement with recommendations contained in RGs 1.21, 1.33, 4.15; and ANSI N13.1-1969, N18.7-1976, and N323-197 The NRC inspector reviewed the plant general procedures, plant chemical procedures, and plant surveillance procedures which direct the administration and operations of the C0&A division and CAS. The NRC inspector determined that the licensee had approved and issued 219 procedures (71 percent) out of a proposed 310. It was noted that 11 procedures were currently in the review process and 80 procedures were yet to be writte The licensee's approved and planned procedures when implemented appear to meet the regulatory requirements and recommendations of those RGs and ANSI standards which are regarded as being necessary to effectively implement a chemistry / radiochemistry program. All C0&A approved procedures will be reviewed during future inspections.

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-14-This item is considered open (498/8624-11) pending comp'etion l and approval of all C0&A procedures directing CAS activitie No violations or deviations were identifie . Routine and Emergency Facilities for the NRC Mobile Laboratory-The NRC inspector discussed with the licensee the installation of support electrical and telephone facilities for the NRC mobile laboratory, both onsite for routine inspections, and at the emergency operations facility (EOF) at the STP nuclear training center during radiological incident response activities. The NRC inspector outlined the mobile laboratory's support requirements as follows: The parking location should be on a level concrete slab approximately 15' X 30' in an area away from overhead electrical transmission lines and with easy access for receiving radioactive samples from each uni Electrical power should be provided to the vehicle through three independent (nonground faulted) 115 volt, 30 ampere circuits equipped with twist-lock receptacles located within 50 feet of the parked vehicl Telephone line and a rr.odular connection should be provided at the vehicle parking sit The NRC inspector discussed several onsite locations with the licensee and the licensee said they would evaluate suitable parking locations and investigate how the support requirements could be met at both units onsite and at the EO . Contractor Activities The NRC inspector determined that the licensee was not using contractor personnel or laboratories to perform chemical or radiochemical analyse No violations or deviations were identifie . Exit Briefing The NRC inspector met with the NRC senior operations resident inspector, chief of the NRC Region IV reactor projects section C, and the licensee's representatives identified in paragraph 1 of this report at the conclusion of the inspection on August 15, 1986. The NRC inspector discussed the scope and findings of the inspection and summarized the 11 NRC concerns identified in this report as open item The NRC inspector stated that all open items identified should be resolved prior to initial criticality of Unit 1 except for the PASS open item which must be resolved prior to Unit 1 exceeding 5 percent power. The licensee stated that they would review and evaluate the NRC's concerns and take action as necessary to resolve the identified open item '

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