IR 05000498/1987033

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Insp Repts 50-498/87-33 & 50-499/87-33 on 870608-12.Major Areas Inspected:Radiation Protection Program,Including Mgt Controls & Organization,Training & Qualification,External & Internal Radiation Exposure Control
ML20235G660
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 06/26/1987
From: Chaney H, Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20235G630 List:
References
50-498-87-33, 50-499-87-33, NUDOCS 8707140339
Download: ML20235G660 (8)
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/87-33 Construction Permits: CPPR-128 50-499/87-33 CPPR-129 Expiration Date: December 31, 1987 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 (STP), Units 1 and 2 Inspection At: STP Site, Bay City, Matagorda County, Texas Inspection Conducted: June 8-12, 1987 Inspector- 4/24h7 MvH. JP. Chaney, Radiati6n Specialist, Facilities Date

/ Radiological Protection Section Approved:

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h g/2c/pr A B. 36rray, Chief, Facflities Radiological Date '

'7/ rrotection Section Inspection Summary Inspection Conducted June 8-12, 1987 (Report 50-498/87-33; 50-499/87-33)

Areas Inspected: Routine, announced preoperational inspection of the licensee's. radiation protection (RP) program including: management controls and organization, training and qualification, external radiation exposure control, internal radiation exposure control, respiratory protection, l-'

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 j supplies, radiaticn protection program audits and reviews, and the  !

post-accident sampling syste Results: Within the areas inspected, no violations or deviations were identified. Thirteen open items were closed during this inspectio . PDR ADOCK 0500 O.

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l -2-DETAILS Persons Contacted HL&P

  • H. Kinsey, Plant Manager
  • A. McBurnett, Supervising Engineer, Site Licensing
  • G. L. Jarvela, Health Physics Division Manager (HPM)

R. C. Craft, Radiological Protection Supervisor

  • W. C. Parish, Radiological Support Supervisor
  • S. Head, Engineer, Project Compliance Group
  • E. L. Brown, Project Compliance Engineer
  • C. A. Ayala, Project Compliance Engineer
  • G. Isereau, Operations Quality Assurance (QA) Audit / Surveillance Supervisor
  • D. A. Leazar, Reactor Performance Supervisor
  • J. Daly, Start-up Manager
  • Ondriska, Start-up Supervisor
  • L. Parkey, Technical Support Manager Others
  • T. Reis, NRC Resident Inspector
  • R. Baer, NRC Region IV Inspector
  • K. Oh, Korea Advanced Energy Institute
  • H. Scott, NRC Region IV Inspector
  • Denotes those present during the exit interview on June 12, 198'/. Follow-up on Previous Inspection Findings (Closed) Open Item 498/8629-01: Organization and Management Controls -

This item involved the licensee's need to resolve the following NRC concerns: Development of a program for issuance of reports and notifications to the NR Issuance of a policy statement from senior HL&P management concerning the RP progra The NRC inspector determined that the licensee had reorganized the Nuclear Operations Department effective June 1, 1987. Three new divisions were formed for plant operation and operations support. A new department had been created to be responsible for the areas of chemical operations, chemical analysis, and health physic , . ..

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-3-l This new department is called the " Technical Services Department." The department manager position for this new department is currently vacan The formally Health and Safety Services Division had been renamed the Health Physics (HP) Division. The NRC inspector discussed with the plant manager the need for providing adequate management access for the HPM when RP problems cannot be resolved at the Technical Services Manager leve The licensee had also removed the industrial safety responsibilities from  ;

the HP Division in this reorganizatio '

The licensee had adequately resolved the NRC's concerns regarding items (a) and (b), by issuance of HL&P management policies involving the RP Program and development of STP Operating Procedure OPGP03-ZX-0005,

" Event Reporting," respectively. This item is considered close (Closed) Open Item 498/8629-03: General Employee Training - This item concerned the NRC's review of General Employee Training - 1 (GET-1) to determine compliance with the. requirements of 10 CFR Part 19.12. The NRC inspector reviewed the licensee's presentation of GET-1 training and determined that it satisfied the requirements of 10 CFR Part 19.1 This item is considered close (Closed) Open Item 498/8629-04: Radiological Worker Training - This item concerned the licensee's training program for radiological workers, including respiratory protection equipment (RPE) training (GET-2 & 3).

The licensee needed to resolve the fol". wing NRC conc.trns-l Provide RPE (GET-3) instructors with appropri.ste technical training, f Provide HL&P policies associated with the STP RP program to all personnel that attend GE The licensee had provided two GET instructors with advanced respiratory protection technical training and had scheduled two other GET instructors for the same training to satisfy item (a). The licensee had implemented issuance of RP program management policies to all STP personnel which adequately resolved item (b). This item is considered close (Closed) Open Item 498/8629-05: Radiation Protection Staff Training -  !

This item concerned the licensee's presentation and documentation of Final l Safety Analysis Report (FSAR) training commitments. The licensee needed  !

to resolve the following NRC concerns: Properly document waivers of training for HP Division personne Verify that all training addressed in the FSAR has been completed for '

HP Division personnel.

t The licensee had documented all training waivers and verified that the  !

minimum FSAR required training had been provided to HP Division personne This item is considered close !

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l-4-(0 pen) Open Item 498/8629-06: External Radiation Exposure Control - This

, item was discussed in NRC Inspection Reports 50-498/86-29, 50-498/87-02, l and 50-498/87-13 and concerned the licensee's need to resolve control of access to the areas adjacent to the Unit I spent fuel transfer tube as required by NRC Bulletin 78-0 The NRC inspector determined that the licensee's proposed amendment to the FSAR and the additional physical access restraints to be installed on access ladders to the fuel transfer tube locations in Units 1 and 2 are )

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sufficient to satisfy the requirements in NRC Bulletin 78-0 Verification of the licensee's actions will be reviewed in a future inspection (prior to first use of the transfer tube for movement of ,

irradiated fuel) via this open ite This item remains open pending '

future revie (Closed) Open Item 498/8629-07: Internal Exposure Control - This item concerned the licensee's program for assessing internal exposures to radioactive material (RAM) and the need for the licensee to resolve the following NRC concerns:

. Develop methodologies for determination of maximum permissible concentration-hours (MPC-hrs) of uptake using bioassay result The licensee had developed instructions for the back-calculating and determination of MPC-hrs of exposure based on bioassay results which resolved the NRC's concerns in this area. This item is considered close (Closed) Open Item 498/8629-08: Respiratory Protection - This item concerned the licensee's respiratory protection program and the licensee's need to resolve the following NRC concerns: Issuance of a respiratory protection policy that agrees with NRC Regulatory Guide 8.15 guidance, Designating in writing the site contact for respiratory protection program inquire The licensee had addressed both items (a) and (b) in drafts of a Radiation Protection Manual and a policy handout that adequately resolved the NRC's concerns in this area. This item is considered close (Closed) Open Item 498/8629-09: Radiological Posting - This item concerned the licensee's radiological posting program and the need to i develop specific procedures for the periodic review of posting and verification of high radiation area access control measures. The licensee had incorporated instructions into operations procedure OPRP01-ZA-0033 for the periodic review of high radiation access controls, including isolation / locking device intergrity, which adequately resolved the NRC's concerns in this area. This item is considered close _ _ _ _ _ _ _ - _ _ _ _ _ _

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-5-(Closed) Open Item 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: Development of a reactor shield survey program that satisfies the l recommendations of ANSI /ANS 6.3.1-198 Establish a proper survey program for release limits concerning  !

potentially contaminated material The licensee had issued two operating procedures (OPGP03-ZR-0037 and OPGP03-ZR-0038) for the performance of radiation shielding surveys during initial reactor power operations that adequately resolved concern (a). i The licensee had revised the procedure (OPGP03-ZR-0012) for control of RAM that implemented radiation and surface contamination limits that adequately resolved concern (b). This item is considered close (Closed) Open Item 498/8629-12: RP Instrument and Equipment Use/ Calibration - This item involved the licensee's need to procure the instruments identified in the FSAR and develop use and calibration procedure The licensee had procured the specified instruments and had issued operation and calibration procedures which adequately resolved the NRC's concern in this area. This item is considered close (Closed) Open Item 498/8629-13: Radiological Control Facilities - This item involved the licensee's facilities for inplant offices, decontamination areas, training facilities, etc., and the need for the licensee to complete construction and acceptance of the facilitie The licensee had taken control of all remaining radiological facilities which j adequately resolved the NRC's concerns in this area. This item is considered close (Closed) Open Item 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 follow!ng:

. Stocking and placement of emergency kits to support the STP Emergency Pla The licensee had stocked and prestaged emergency kits in many areas of the plant and in emergency response facilities for use during a radiological emergency, which provided adequate radiological response equipment to resolve the NRC's concerns in this area. This item is considered close (Closed) 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:

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I I Defining the specific audit and review functions.of the Nuclear Safety Review Board (NSRB) in regard to the review / audit of RP program activities at ST ]

' Conduct a comprehensive audit of the STP RP progra The licensee's QA Department had completed a comprehensive audit of the

-.STP RP program during April 1987 ( Audit No. 87-02) which adequately resolved NRC concern (a). The NSRB issued a memorandum concerning the .!

future auditing of the STP RP program and the use of technical experts  !

during such audits that adequately resolved concern (b). This item is  :

considered close i

(0 pen) Open Item 498/8629-16: Post-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:

. Developing corrective action for the elimination or containment of mechanicr' joints on the sample lines feeding the liquid grab sample ,

pane The licensee had developed a proposal for enclosing the mechanical joints within a metal cabinet equipped with a drain system in order to resolve this ite The NRC inspector reviewed ongoing construction of the cabinet. The NkC inspector discussed with licensee personnel the need to ensure that all mechanical fittings containing undiluted reactor coolant within the PASS cubicle are properly contained or eliminated. The licensee stated that a suitable system would be installed prior to

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exceeding the 5 percent reactor power limit. This item will remain open pending completion of licensee actions regarding containment of mechanical .

joints on PASS sample line l I

(Closed) Open 1: 498T "13-01: Allegation 4-87-A-025 - This allegation was discussed in NRC Inspection Report 50-498/87-13 and concerned the adequacy of the RP program and the licensee's need to resolve the following concerns: , The need to fill vacant lead RP technician positions (3) with  !

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qualified personnel in order to satisfy FSAR Section 12.5. commitments regarding shift staffin Eliminate erroneous reference to nonexistent procedures in issued procedure Reduce the use of RP technicians for the conduct of the industrial safety progra The NRC inspector determined that the licensee had promoted three senior l RP technicians to the position of lead RP technician which provided six  !

lead RP technicians for shift assignment. The licensee had also hired nine contractor RP technicians to supplement the permanent STP staff until

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HL&P RP personnel gain more experienc Eight of the contractor .

i technicians possess commercial. operating reactor plant experience and satisfy ANSI 18.1-1971 qualification criteria for senior RP technician The NRC inspector also noted that the licensee was actively recruiting experienced.RP. technicians to supplement their permanent staff and to prepare for the staffing of Uni.t The NRC: inspector noted that the licensee had initiated a. program to consolidate procedures within the HP Division in order to. reduce the -large number of procedures and eliminate unnecessary procedure .The licensee's' recent reorganization of the Nuclear Operations Department, effective June 1, 1987, transfered the responsibility for industria safety from.the HP Division to the Human Resources Department (HRD).

Conduct of the industrial safety testing / inspections is being gradually phased out in the HP Division as the HRD acquires and trains personne The NRC inspector ' determined that the licensee had taken or initiated sufficient corre'ctive actions to resolve this allegation. This open item is considered close No violations or deviations were identifie . 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; D = deviation; V = unresolved item; and 0 m open ite Procedure Inspections Requirements 83522 Organization and Management Controls (Radiation Protection) -

02.01 - Organization, Responsibilities, and Authorities 02.02 - Staffing 02.03 - Identification and Correction o# M aknesses 02.04 - Audits and Appraisals 02.05 - Communication to Employees 02.06 - Documentation and Implementatio Training and Qualifications (Radiation Protection)

02.01 - Training and Qualifications Program 02.02 - Education and Experience 02.03 - Adequacy L ____ _______________ .i

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-8-83524 External Occupational Exposure Control and Personal Dosimetry 02.01 - Physical Controls 02.02 - Administrative Controls 02.03 - Personal Dosimetry 83525 Internal Exposure Control and Assessment 02.01 - Administrative Controls 02.02 - Engineering Controls 02.03 - Respiratory Protection Equipment 02.04 - Air Sampling for Assessing Individual Exposure 02.05 - Bioassays 83526 Control of Radioactive Materials and Contamination Surveys and Monitoring  ;

02.01 - Area Radiation and Airborne Radioactivity Monitors 02.02 - Portable Survey, Sampling, and Contamination Monitoring Instruments 02.03 - Protective Clothing and Equipment 02.04 - Radioactive Material and Contamination Control 02.05 - In-Plant Surveys and Monitoring 83527 Facilities and Equipment 02.01 - Facilities 02.02 - Equipment TI 2514/01 Task II.B.3 Post-Accident Sampling - 0 (see paragraph 2)

92703 IE Bulletin, Confirmatory Letter, and Generic Letter Follow-up 02.01 - Bulletin Review 02.02 - Confirmatory Acti;n Letter Review 4. Exit Interview The.NRC inspector met with NRC personnel and licensee representatives identified in paragraph 1 at the conclusion of the inspection on June 12, 198 The NRC inspector stated that the RP program was adequately implemented to support fuel load and reactor plant power operation ,

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