IR 05000498/1987013
| ML20235E353 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/02/1987 |
| From: | Chaney H, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20235E350 | List: |
| References | |
| 50-498-87-13, 50-499-87-13, NUDOCS 8707110012 | |
| Download: ML20235E353 (13) | |
Text
{{#Wiki_filter:_ l . , l APPENDIX U.S. NUCLEAR REGULATORY COMMISSION I
REGION IV
l NRC Inspection Report: 50-498/87-13 Construction Permits: CPPR-128
50-499/87-13 CPPR-129 l Dockets: 50-498 Expiration Date: December 31, 1987 50-499 Licensee: Houston Lighting & Power Company (HL&P) P. O. Box 1700 i Houston, Texas 77001 ! Facility Name: SouthTexasProjectElectricGeneratingStation(STP), Units 1 and 2 ,
Inspection At: STP Site, Bay City, Matagorda County, Texas Inspection Conducted: April 13-17, 1987 Inspector: Ik ))O&%Q 7/[/[7 H.%hdfley, Radiat~ ion Spepialist, Facilities Date' p Radiological Protection Section , Approved: 'ds MM(d/1, 7[[/h ' l B. Murray, Chfef, Fadlities Radiological Date~ ' Protection Sectiof'(FRPS) Inspection Summary Inspection Conducted April 13-17, 1987 (Report 50-498/87-13; 50-499/87-13) Areas Inspected: Routine, announced licensee's radiation protection (RP) preoperational inspection of the progrdm, including: management controls and organization, training and qualification, external radiation exposure , l control (including spent fuel transfer tube access control), internal radiation exposure control, respiratory protection, radiological posting program, radiological survey program, ALARA and radiation work control program, radiation protection instrumentation and calibration, radiation protection facilities, radiation protection equipment and expendable supplies, radiation protection program audits and reviews, and the post-accident sampling system.
An allegation concerning radiation protection activities was also reviewed.
Results: Within the areas inspected, no violations or deviations were identified.
No open items were closed during this inspection.
8707110012 870706 PDR ADOCK 05000498 G PDR _ _ _ _ _ _ _ _ _ _
l . . -2-DETAILS [ l i 1.
Persons Contacted ) l HL&P !
- W. H. Kinsey, Plant Manager
- M. A. McBurnett, Supervising Engineer Site Licensing l
- G. L. Jarvela, Health & Safety Services (H&SS) Division Manager
- R. C. Craft, Radiological Protection Supervisor (RPS)
- W. C. Parish, Radiological Support Supervisor i
' I S. Head, Engineer, Project Compliance Group
- E. L. Brown, Project Compliance Engineer
. l
- C. A. Ayala, Project Compliance Engineer l
W. G. Isereau, Operations Quality Assurance (QA) Audit / Surveillance Supervisor
- J. H. Busby, Operations QA Auditor
- D. A. Leazar, Reactor Performance Supervisor
,
- R. J. Daly, Start-up Manager j
- G. Ondriska, Start-up Supervisor
- G. L. Parkey, Technical Support Manager l
NRC, Region IV '
- T. Reis, NRC Resident Inspector
- B.- Murray, Chief, FRPS
- G. L. Madsen, Reactor Inspector
- E. Hildebrand, Reactor Inspector
- G. L. Branson, Consultant
- Denotes those present during the exit interview.
2.
Follow-up on Previous Inspection Findings (0 pen)OpenItem 498/8629-01: Organization and Management Controls - This i l item involved the licensee's need to resolve the following NRC concerns: Development of a program for issuance of reports and notifications to a.
the NRC.
l b.
Issuance of a policy statement from senior HL&P management concerning the RP program.
' This item will remain lo en pending the licensee's development and NRC review of Procedures IP 1.4Q and 1.15Q for concern (a), and issuance of a management policy by the. licensee concerning the Radiation Protection (RP) Program at STP for resolution of concern (b).
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. . i-3- ! (0 pen) Open Item 498/8629-03: General Employee Training - This item . concerned the NRC's review of General Employee Training - 1 (GET-1) to j determine compliance with the requirements of 10 CFR Part 19.12.
This ' item was not completely reviewed during this inspection and will remain open pending further rsview by the NRC.
(0 pen)OpenItem 498/8629-04: Radiological Worker Training - This item concerned the licensee's training program for radiological workers, l including respiratory protection equipment (RPE) training for General Employee Training (GET) 2 & 3.
The licensee needed to resolve the-following NRC concerns: a.
Provide RPE (GET-3) instructors with appropriate technical training.
b.
Provide HL&P policies associated with the STP RP program to all personnel who attend GET.
The licensee stated that concern (a) will be completed by May 1, 1987, when selected Nuclear Training Department instructors will have completed vendor provided RPE technical training.
(0 pen)OpenItem 498/8629-05: Radiation Protection Staff Training - This Safety Analysis Report (FSAR) presentation and documentation of Final item concerned the licensee's training commitments.
The licensee needed to resolve the following NRC concerns: a.
Properly document waivers of training for H&SS personnel, b.
Verify that all training addressed in the FSAR has been completed for H&SS personnel.
The licensee was still working on this item at the time of the NRC inspection.
I (0 pen) Open Item 498/8629-06: External Radiation Exposure Control - This ) item concerned the licensee's dosimetry program for external exposure and j involved the licensee's need to resolve the following NRC concerns:
a.
Evaluate the temperature limitations of personnel thermoluminescent dosimeters.
b.
Complete development and implementation of corrective actions for controlling access to areas adjacent to the Unit 1 spent fuel transfer tube.
The licensee hed adequately resolved the NRC's concern regarding item (a).
Concerning item (b), the NRC inspector determined that the licensee's proposed amendment to the FSAR and the additional controls to be installed on access ladders to the fuel transfer tube locations in Units 1 and 2, were sufficient to resolve portions of this concern. This concern will remain open pending licensee actions to implement the additional personnel
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i . . i-4- . i access controls and posting for the Unit 1 fuel transfer tube. The I , l licensee stated that corrective actions for this item would be completed prior to the first use of the fuel transfer tube with irradiated fuel.
l ' ! (0 pen)OpenItem 498/8629-07: Internal Exposure Control - This item concerned the licensee's program for assessing internal exposures to j l airborne radioactive material and the need for the licensee to resolve the j following NRC concern: - Develop methodologies for the determination of maximum permissible concentration-hours exposure based on bioassay results.
l This item will remain open pending completion of licensee actions.
(0 pen)OpenItem 498/8629-08: Respiratory Protection - This item concerned the licensee's respiratory protectior. program and the licensee's , need to resolve the following NRC concerns: ! a.
Issuance of a respiratory protection policy that agrees with the guidance in NRC Regulatory Guide 8.15.
, b.
Designating, in writing, the site contact for respiratory protection program inquiries.
i The licensee had addressed both items (a) and (b) in drafts of a Radiation Protection Manual and a policy handout.
However, the NRC inspector determined that the respiratory protection policy did not satisfy the l recommendations of NRC Regulatory Guide 8.15 and that the Radiation !. i Protection Manual had ambiguous statements concerning administrative radiation exposure limits. These items will remain open pending further l licenseeactionstoresolveitems(a)and(b).
] (0 pen)OpenItem 498/8629-09: Radiological Posting - This item concerned the licensee's radiological posting program and the need to develop
specific procedures for the periodic review of posting and verification of i high radiation area access controls.
This item remains open pending I licensee action.
(0 pen)OpenItem 498/8629-10: Radiological Surveys - This item involved the licensee's radiological monitoring and survey program and the need for the licensee to resolve the following NRC concerns: a.
Development of a reactor shield survey program that satisfies the recommendations of ANSI /ANS 6.3.1-1980.
b.
Establish a proper survey program for release limits concerriing potentially contaminated materials.
The licensee had revised the reactor shield survey program and submitted it to the Plant Operations Review Committee for approval. The licensee is revising the procedure concerning surface contamination limits.
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.. -5-(0 pen)OpenItem 498/8629-12: RP Instrument and Equi ment Use/ Calibration - This item involved the licensee's need to resolve t1e following NRC concern: Completion of use and calibration procedures for RP instrumentation.
The licensee had not established calibration and use procedures for portal and portable area radiation monitors. This item will remain open pending licensee issuance of remaining RP instrument procedures.
(0 pen) Open Item 498/8629-13: Radiological Control Facilities - This item involved the licensee's facilities for in-plant offices, decontamination areas, training facilities, etc., and the need for the licensee to complete construction and acceptance of the facilities. The NRC inspector determined that the licensee had accepted all facilities except for: Protective clothing laundry facility Radioactive material / equipment decontamination shop This item will remain open pending licensee completion of the above noted facilities.
(0 pen)OpenItem 498/8629-14: RP Equipment and Expendable Supplies - This item involved the licensee's inventories of expendable RP supplies, RP support equipment (portable ventilation system, temporary shielding, etc.), emergency response kits, and the need to complete the following: Stocking and placement of emergency kits to support the STP emergency plan.
This item will remain open pending licensee action.
(0 pen) Open Item 498/8629-15: Audits and Reviews - This item involved the licensee's audit and review of the RP program by the QA Department and the need for the licensee to resolve the following NRC concerns: a.
Defining the specific audit and review functions of the Nuclear Safety Review Board and the Independent Safety Engineering Group in regard to the review / audit of RP program activities, b.
Conduct a comprehensive audit of the STP RP program.
The NRC inspector did not complete the review of concern (a) during this inspection and will review it during a future inspection. The licensee ' had started an audit of RP program activities and expects to complete the ' audit by April 22, 1987. These items will be reviewed further during future inspections.
(0 pen)OpenItem 498/8629-16: Dost-Accident Sampling System (PASS) - This item involved the licensee's reactor coolant and containment atmosphere PASS and the need to resolve the following NRC concerns: I I
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Developing corrective action for the elimination or containment of mechanical joints on the sample lines.
b.
Evaluate relocation of the one area radiation monitor (ARM) monitoring the PASS cubicles, including the locations of remote readouts.
The licensee had developed a proposal for enclosing the mechanical joints within a metal cabinet equipped with a drain system to resolve item (a).
The licensee stated that the enclosure system will be installed before exceeding the 5 percent reactor power limit.
The licensee had procured two portable, remote area monitors and had placed them in the PASS facility which adequately resolved item (b).
Item (a) will remain open pending completion of licensee actions regarding i containment of PASS sample lines, c 3.
Program Areas Inspected The following program areas were inspected.
Unless otherwise noted, the inspection was completed and revealed no violations, deviations, unresolved items, or open items.
Notations after a specific inspection item are used to identify the following: I = item not inspected or only partially inspected; V = violation; O = deviation; O = unresolved item; and 0 = open item.
Inspection P rocedure.
Inspection Requirements 83522 Radiation Protection, Plant Chemistry, Radwaste, and Environmental: Organization and Management Controls 02.01 Organization, Responsibilities, and Authorities 02.02 Staffing 02.03 Identification and Correction of Weaknesses Audits and Appraisals - 0 (see p(aragraph 2) 02.04 Communication to Employees - 0 see paragraph 2) 02.05 02.06 Documentation and Implementation < 83523 Radiation Protection, Plant Chemistry, Radwaste, , Transportation, and Environmental: Training and
Qualifications 02.01 Training and Qualifications Program - 0 (see paragraph 2) 02.02 Education and Experience 02.03 Adequacy l ! ! _ _ _ - _ - _ _ _ - _ - _ -
-_ _ _ _ . . ' -7-83524 External Occupational Exposure Control and Personal Dosimetry 02.01 Physical Controls - 0 (see paragraph 2) 02.02 Administrative Controls 02.03 Personal 00simetry 83525 Internal Exposure Control and Assessment 02.01 Administrative Controls - 0 (see paragraph 2) 02.02 Engineering Controls 02.03 Respiratory Protection Equipment 02.04 Air Scmpling for Assessing Individual Exposure 02.05 Bioassays 8357.6 Control of Radioactive Paterials and Contamination, Surveys, and Monitoring 02.01 Area Radiation and Airborne Radioactivity Monitors 02.02 Portable Survey, Sampling, and Contamination Monitoring Instruments. 0 (see paragraph 2) 02.03 Protective Clothing and Equipment 02.04 Radioactive Material and Contamination Control 02.05 In-Plant Surveys and Monitoring - 0 (see paragraph 2) 83527 Facilities ard Equipment 02.01 Facilities - 0 (see paragraph 2) 02.02 Equipment Tl 2514/01 Task II.B.3 Post-Accident Sampling - 0 (see paragraph 2) 92703 IE Bulletin, Confirmatory Letter, and Generic Letter Followup 02.01 Bulletin Review 02.02 Confirmatory Action Letter Review 4.
Allegation 4-87-A-025 The NRC inspector reviewed an allegation concerning the adequacy of the RP p(rogram at STP. The allegation was comprised of 16 separate allegations several were common to one problem area such as personnel qualifications). The allegation involved personnel qualification, staff size, loss of staff persornel, RP technician (RPT) training, RPT shift manning, excessive collateral duties for senior RPTs, RPT work practices, RP equipment use, and inadequacies in RP program implementing procedures.
The NRC inspector investigated each allegation and also reviewed each allegation with the alleger. The NRC inspector noted that many of the allegers concerns had bean previously discussed as NRC concerns during previous routine NRC inspections. The alleger admitted to the NRC inspector that he was not aware of the results of the NRC's inspection a
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. . . i-8-l program as conducted at STP for the RP program and he was.not familiar with all of the procedures used to implement the STP RP program.
NRC Inspection Reports 50-498/86-29, 50-499/86-29, 50-498/87-02, and l 50-499/87-02 address indirectly, to some degree, all of the alleger's concerns.
The following is a listing of the alleger's allegations and the findings of the investigation into each allegation: I a.
The Radiation Protection Supervisor (RPS) does not have any recent operating experience.
Finding: Substantiated. The RPS does not have current commercial operating reactor experience because he has been employed at STP since 1980. The RPS possesses extensive professional and supervisory experience (approximately 20 years) in RP programs involving weapons isotope production reactors plants and isotope separation and processing plants that adequately qualifies him, per industry standard ANSI 18.1-1971, for his current supervisory position.
b.
The Lead RPTs have little or no experience at an operating commercial power plant.
Finding: Substantiated. This concern was previously identified by the NRC in NRC Inspection Report 50-498/86-29 and brought to resolution in NRC Inspection Report 50-498/87-02.
c.
Only three senior RPTs have operating commercial power plant experience.
Finding: Not Substantiated. The licensee has currently employed in the H&SS Department RP Group six RPTs that have commercial reactor plant operating experience and four of the six are senior RPTs.
d.
There are not enough lead RPTs available to satisfy FSAR commitments to staff each operating shift with one lead RPT.
Finding: Substantiated. Section 12.5.1.1 of the FSAR commits the licensee to having one lead RPT on each shift during plant operation.
Currently the licensee has only 3 lead RPTs and is working either a 5 or 6 shift rotation during this phase of plant construction.
' e.
Two parts: (1) Currently there are insufficient RPTs on shift to support plant activities, especially industrial safety, which takes up to 50 percent of the RPTs on shift.
(2) Once the plant is operating there will be a shortage of qualified RPTs to staff the shifts.
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a ,- . , -9-Finding: '(1) Substantiated. The on-shift technicians are providing up to 50 percent of their on-shift time to support the industrial safety program for. Units 1 and 2.
The technicians are apparently l providing marginal but adequate support:to the preparations for implementing the RP program at Unit 1.
(2) Not Substantiated. The licensee's available inhouse technical staff RPTs and the aggressive recruitment program appears to be adequate to meet the RP program needs of Unit 1 by the scheduled start of fuel loading.
f.
The on-shift RPTL are responsible for initial first aide response.
Finding: Substantiated. Since the RPTs need to respond to all emergencies at a nuclear power plant,'due to the possible involvement of radiation or radioactive materials, this is a practice found at many power plants. This allegation has no regulatory bearing.
g.
Most of the response organization for the RP group are from the RPT Aide (first step in a 3 to 4-year apprentice program that culminates in attachment of ANSI 3.1-1983 RPT qualification) training class which is just beginning.to cover health physics related material.
Finding: Substantiated.
During the recent STP emergency response drill, the licensee used as many of the aides as possible for training purposes.
The licensee used qualified RPTs for situations requiring such experience. This is not considered a regulatory
matter.
h.
The alleger stated that his statistical analysis showed that the licensee could not meet the loose surface contamination limits (100 disintegrations per minute beta-gamma radioactivity) on laboratory counting equipment used for new fuel receipt.
I Finding: Not Substantiated. The alleger's statistics were found to be not in agreement with acceptable statistical analyses performed by the licensee or the NRC inspector. The NRC inspector's and the licensee's analysis did not agree, but the results showed that the counting system, as operated, could detect the aforementioned loose surface contamination limits for beta-gamma radioactivity. There is no specific regulatory requirement on surface contamination limits for routine facility operations, only for the external contamination on packages offered for transportation.
i.
Two parts: (1) Variable flow rate portable air samplers are calibrated at one flow rate point only, as referenced on the unit.
(2) RPTs, when obtaining air samples, routinely use a sample flow rate above that referenced on portable air samplers.
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_ _ _ _ - _- -..__ _ .:. . I-10 : j j Finding:- (1)~NotSubstantiated. The licensee routinely calibrates i portable variable flow air samplers at three to four different flow rates as evidenced in STP. calibration procedures OPRP05-ZI-0013, " Calibration of Vane Pump Air Samplers," dated January 31, 1986, and
OPRP05-ZI-0014, " Calibration of the Radeco H-809V, H-809V1, H-809C, ' and the F8J HV-1 Air Samplers," dated November 14, 1983. The alleger ' stated that he was not familiar with the procedures and that his arent misreading of the calibration allegation was based.on the app (2) sticker on the air samplers.
Not Substantiated. This part of' the allegation is a result of the alleger's failure to properly interpret the air sampler calibration sticker which indicated the span of the flow rate calibration and not a fixed point calibration.
-The flow rate calibration notation of 1-3 CFM was misinterpreted as 1.3 CFM.
j.
RPTs are required to perform additional duties, such as: General Employee Training, radiation worker portion Procedure writing
Whole Body. counting Respiratory fit testing SCBA/ respirator inspection Instrument calibration Finding: Substantiated. These duties, in addition to routine job coverage, are consistent with RP program management practices found at.Other preoperational and operational nuclear power stations.
k.
The current shift rotation includes a week of training, which is normally used for supporticg whole body counting and instrument calibration.
Finding: Substantiated. Due to the increased number of personnel requiring processing into the exposure control system many personnel are being used for training and whole body counting activities. All RPTs are being trained in only those areas that qualifications are-nearing expiration. There is no regulatory requirement for this area.: Currently the NRC is tracking RPT training commitments via J Open Item 498/8629-005 which was previously addressed in NRC ' Inspection Reports 50-498/86-29 and 50-498/87-02.
1.
There is currently no system in place to train RPTs in plant procedures. Senior RPTs are not required to go through any site specific training. Qualification cards only address counting room equipment calibration, whole body counting, respirator fit testing, ' and' microwave oven surveys.
Finding: Not Substantiated. This area was discussed in NRC Inspection Report 50-498/86-29. The licensee currently has inplace a suitable RPT training program that is proceduralized in I _ - - _-__ _ __ _ _ _ _ _ -
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-11-OPRP01-ZA-0008, " Radiation Protection Personnel Training," dated December 4,1985.
m.
This is a two part allegation: (1) There is no formal method in place to track RPT qualification or provide continuing education.
The tracking of RPT qualifications has been suspended since the leaving of the lead RPT responsible for this area.
(2) NRC Inspection and Enforcement Information Notices (IEINs) are occasionally distributed to RPTs, but the RPTs do not receive any amplifying information.
They (RPTs) are not held accountable for IEINs contents.
Finding: (1) Partially Substantiated.
The Nuclear Training Department has a computerized tracking system for personnel training and qualification.
The H&SS tracking of RPT qualifications and training had been suspended following the leaving of the lead RPT that was responsible for this area.
The licensee is attempting to find a suitable person to coordinate the H&SS tracking of RPT qualifications.
There is no regulatory requirement for this aspect of the licensee's program.
The NRC is already tracking this area of concern via Open Item 498/8629-05.
(2) Not Substantiated.
The licensee evaluates and distributes IEINs to the appropriate STP department for a written response (no written response is required to be forwarded to the NRC for these IEINs) to the contents of the IEINs.
The licensee was found to distribute IEINs to RPTs in the required reading material (procedure changes and other industry informational notices).
There is no regulatory requirement for holding RPTs responsible for the IEINs information.
The NRC inspector verified that the licensee routinely provides a proper review for NRC distributed documents, including IEINs.
This item concerned supervisory RPT practices involving poor n.
judgement and the issuance of a Radiation Work Permit (RWP) for control of the radioactive material without requiring the use of personnel docimetry.
Finding: Not substantiated.
The alleger's concern involves discussions with supervisory RPT where the technicians indicated their preferred methods for handling certain RP situations which did not totally agree with the alleger's position on how these situations should be handled.
The NRC inspector had interviewed several RPTs during this inspection and other inspections and found that the lead RPTs and the RPT supervisors are knowledgeable in RP practices and exert an aggressive attitude towards job performance of subordinates.
The NRC inspector reviewed the issuance of the subject RWP and found that it provided the necessary radiological controls for the radiological hazards involved.
No licensee or regulatory requirements were violated.
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. o ,
-12-o.
Procedures OPRP03-ZM-0015, "H&SS Use of Radioactive Sources," and l OPGP03-ZR-0018, " Disposal and/or Transfer of Radioactive Sources," { references the use of procedure OPGP03-ZR-0019, "Use of Sealed l Sources and Standards." Procedure OPGP03-ZR-0018 does not exist and document control has no record of it ever existing.
Finding: Partially Substantiated.
The referenced procedure . (OPGP03-ZR-0018) has not been issued.
Document control records show l that the procedure has been identified for issuance by May 1,1987.
j l The two procedures that reference the nonexistent procedure appear to
have suitable radiological controls within them to stand alone.
No ' regulatory requirements have been violated.
p.
The Whole Body Counter (WBC) continually fails its quality control (QC) diagnostic / response check; yet, it is approved by the Radiological Support Group for use.
Finding: Partially Substantiated.
The NRC inspector reviewed QC logs for the WBC and determined that there were various periods over the last year that the WBC experienced abnormally high QC failures.
The licensee found that these QC failures were normally a result of poor positioning of the QC check source on the WBC detectors.
All failures appeared to have been reviewed by the H&SS staff specialist /RPT in charge of the WBC prior to allowing use of the counter.
The NRC inspector discussed with the licensee the need to take action to resolve the below noted concerns that were brought out in allegation items 4(d), 4(e), and 4(o).
Item 4(d) The need to fill vacant lead RPT positions (3) with qualified personnel in order to satisfy FSAR Section 12.5.1.1 commitments regarding shift staffing.
1 Item 4(e) Resolve the excessive use of RP technician resources to
implement the STP industrial safety program, especially those activities involving Unit 2.
These ancillary support activities by the H&SS Department, if allowed to continue, will have an adverse impact on implementing the radiation protection program for Unit 1 at STP.
Item 4(o) Evaluate and eliminate from operational procedures references to nonexistent procedures.
The licensee stated during the exit interview that actions would be taken i to resolve the above noted items.
This allegation will remain open ' (498/8713-01) pending additional review of the above noted concerns during future inspections.
j No violations or deviations were identified.
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C . 6-13-
5.
Exit Interview l The NRC inspector met with NRC personnel and licensee representatives identified in paragraph I at the conclusion of the inspection on April 17, 1987. The licensee was advised that the open items addressed in this report would be used to track areas requiring either further NRC inspection or completion of licensee action and that these items will need to be resolved before recommending that STP be issued an operating license.
The NRC inspector expressed concern regarding the lack of progress the licensee had made toward resolving open items. The NRC inspector noted that during the exit interview for NRC Inspection Report 50-498/87-02; 50-499/87-02, the licensee stated that most open items would be completed by April 1, 1987.
However, this inspection revealed the April 1, 1987, completion date was not achieved. The NRC inspector stated that licensee management attention is needed to assure open items are resolved in a timely manner.
The licensee stated that actions will be taken immediately to procure at least five contractor senior RPTs with commercial power reactor experience to supplement the RP staff at STP for Unit 1 operations.
Recruitment activities will also continue for the hiring of at least 12 permanent senior RPTs.
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