IR 05000498/1989031

Insp Repts 50-498/89-31 & 50-499/89-31 on 890814-25.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Activities Associated W/Current Refueling Outage

ML20248H224
Person / Time
Site:	South Texas
Issue date:	09/28/1989
From:	Baer R, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20248H218	List: IR 05000498/1989031 ML20248H215
References
50-498-89-31, 50-499-89-31, NUDOCS 8910110221
Download: ML20248H224 (22)

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APPENDIX

U.S. NUCLEAR REGULATORYICOMMISSION

. REGION IV-

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NRC Inspect 1on Report: L50-498/89-31 -Operating Licenses: NPF-76 50-499/89-31 NPF-80

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, . Dockets: 50-498 50-499

. Licensee: Houston. Lighting & Power Company P.O. Box 289 Wadsworth, Texas -77483

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Facility 1Name: South Texas Project Electric Generating Station (STP)

Units.1 and 2

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Inspection Ati STP Site, Bay City, Matogorda County, Texas

. Inspection' Conducted: August 14-25, 1989 Inspector: MM /s M f7 w- 9-29 - 9f L.'T. /RickWson, tE. , Radiation Specialist Date FacilistiefRadiological Protection Section Approved- A b ~ ,

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28 c95 R.' E. Baer, Ch',ef, Fac111 tics RadinTCgical__ .cate Protection Section qV .\

h ,Inspectton Sme_.ey -i lgspection Londucted Augt'st 14-25, W9?,ppp_rt 50_498/89-_3M0;49_9/s9-31}

H Armas Insoectr(di Roui.ine, knenne uced fr.spectior, of the licensee's redistbn p;

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protectien activities associated with the current refuelir.g outag ]g Results: Audit and-surveillance activities were of adec,uate depth. Health b

Physics (HP) technicians were found to be adequately quellfied. Sufficient supplies of dosimetry devices were available. No overexposure or internal

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contamination incidents have occurred. Control of areas and contamination appeared good. Supplies of certain items were marginal. The ALARA program needed development and appeared understaffed. No violations or deviations were identified. Four open items were identified. .gjjoi 221 ep2oo3 Q OCK 05000498 FDC

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2 DETAILS l Persons Contacted HL&P

• E. Vaughn, Vice President, Nuclear Operations W. H. Kinsey, Plant Manager J. R. Lovell, Manager, Technical Services

• J. E. Geiger, General Manager, Nuclear Assurance

• J. W. Loesch, Manager, Plant Operations

• H. W. Bergendahl, Manager, HP

• C. Parish, General Supervisor, HP Technical Support R.'W. Pell, General Supervisor, HP Operations Support

• J. P. Bleau, General Supervisor, HP Operations, Unit I W. D. Wood, General Supervisor, HP Operations, Unit 2 T. W. Tessmer, Supervisor, Outage Planning R. V Logan Supervisor, ALARA R. E. Bilbrey, Supervisor, Dosimetry S. Torey, Supervisor, Training R. L. Erickson, Supervisor, Nuclear Assurance, Audits W. G. I.sereau, Supervisor, Nuclear Assurance, Surveillance R. A. Cook, Auditor

• P. L. Walker, Senior Licensing Engineer

• A. K. Khosia, Senior Licensing Engineer

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• J. E. Bess, Senior Resident, STP, Unit 1

• J. I. Tapia, Senior Resident, STP, Unit 2

• R. J. Evans Resident, STP, Unit 1

• D. L. Garrison, Resident, STP Unit 2 ,

'B. Murray, Chief, Reacter Programs Branch  !

• Denotes those present during the exit meeting on August 25, 1989.

The inspector also interviewed other plarit personnel during the course of the inrpectio l Action on Previras it;specticn Findinos  !

(Closed) Open Item (a98/8629-05): External Radiation Exposure Coritrol -

This item was discussed in NRC Inspection Reports 50-498/86-29, 50-498/87-02, and 50-498/87-33; 50-499/87-33 and involved the control of

. access to the areas adjacent to the fuel transfer tube as described by NRC j Bulletin 78-10. At that time, the inspector determined that the licensee's proposed action, when implemented, would be sufficient to address the potential problem of individuals being exposed to very high radiation levels during the transfer of spent fue The licensee surveyed i

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I the area around the fuel transfer tube during its use, as required by Standing Order.36 and measured levels as high as 3,600 R/h. The licensee installed ladder locks on the stairway above and below the fuel transfer tube. The doors to the stairway were equipped with locks requiring special keys which are controlled and the area was physically searched i before fuel transfer to ensure that no one was presen (Closed) Violation (498/8882-01; 499/8882-01): Failure to Issue Personnel Radiation Exposure Reports - This item was discussed in NRC Inspection i Report 50-499/88-82; 50-499/88-82 and involved the failure of the licensee I to send reports of exposure history to both the NRC and the exposed individual after the termination of employment of that individual. As i corrective action, individuals responsible for maintaining dosimetry records were given training involving the review of federal regulations and licensee procedures. Dosimetry now receives monthly reports from the personnel department listing the terminated employees. Additionally, Security provides input to Dosimetry when personnel security access badges are terminated. Finally, according to the supervisor of HP operations support, an exit whole body count also triggers the process for sending termination reports. The inspector did not identify further examples of this violation and considers the licensee's actions sufficient to prevent recurrenc (Closed) Open Item (498/8882-02; 499/8882-02): Poor HP Response to Quality Assurance (QA) Audit Findings - This item was discussed in NRC Inspection Report 50-498/88-82; 50-499/88-82 and involved the tardy and incomplete responses from HP to QA. Although there has been only one audit of HP since this item was opened, there have been substantial changes in the staffing, and the responses given to the deficiencies identified were complete and timel (Closed) Open Iten (498/8882-03; 499/8882-03). Updates te the HP 0:sanization in lechnicci 5pe:if'. cation (TS) and Finti Safety Analysis Reper t (FSAR) - Thi.; iten was discussed in NRC Inmettion 3 lbpor t 50- 08/8S-62; 50-499/88-82 and involved changes in the HP )

organizatier wnich vere not reflected f n the appropriate docuwer,ts. The j organization had changed with the establishment of the HP cpration j suppcrt group, cc nposed of internal and sternal desimetry, ?adwaste r,hippir,g, instrument ation, and decontamination. FF AR amendu.er.t requests have been suteitte (Close.d) Dren I w (493/8882-04; 493/888h04): Lad of Techr.ical Experience cf Superviscr in Charge of Respiratory Protection - Tm s item was discussed in NRC Inspection Report 50-498/88-82; 50-499/?8-82. The current supervisor of HP operations support, the group in charge of respiratory protection, was hired since the previous inspection and has l had training and experience in both industrial hygiene and HP. This experience includes the use of respiratory protection equipment. The ;

inspector, by interviewing the individual and reviewing the individual's resume, determined that the person possesses the necessary qualifications to oversee a respiratory protection progra _ _ _ _ _ _ _ _ - - - . , _ _ - _ _ _ _ _ . _-- _ _ _ _ _ - --.

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.-(Closed) Open Item '(498/8882-05; 499/8882-05): Training for C1erical.

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Staff - This item was discussed in.NRC Inspection Report 50-498/88-82; 50-499/88-82 and involved individuals in charge of maintaining personnel monitoring records being unfamiliar with licensee procedures concerning the records. A-.special training' course was arranged for the individuals

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with information concerning federal requirements and plant procedures being presented by members of the Hp organization. The inspector' veri _fied

'that individuals had received training and.had in their possession.a cop of the licensee's procedure applicable to their responsibilitie .(Closed) Open-Item (498/8882-06; 499/8882-06): Unit 1 Shielding Modifications and Unit 2 Shield Survey - This item was discussed in NRC Inspection Report- 50-498/88-82; 50-499/88-82 and involved radiation.

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shielding and surveys. Licensee representatives stated that modifications had been completed to correct shielding deficiencies in Unit.1 and that the information was used to ensure the same situation did not exist in Unit 2. Surveys of Unit.2.at 100 percent power were completed. Shield survey procedures followed the guidelines of. ANSI /ANS 6.3.1-198 . Open Items Identified During This Inspection An open _ item is a . natter that requires further review and evaluation by

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the inspector. :Open items are used to document, track, and ensure adequate followup'on matters of concern to the inspector. The following open items were' identified:

Open Item Title Paragraph 498/8931-01- ALARA Program Evaluation 7 499/8931-01

'498/8931-02 Establishment of Areas for 10 499/8931-02 Control of Contamination 49B/8931-03 Ev31uation of protective 10 499/89?1-03 Clothing Use 498/8931-94 Evalui. tion of Transportation 31 499/8931-04 and QA Program Observations TE The following arc < observations the inspector. discussed with licensee

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representatives. The observations are not violations, deviatfons, unresolved 1tems, er open items. They wen identified for licensee consideration, for program improvement, but have no specific regulatcry requirement s

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p . -s 5 Equipment and Supplies - Some items such as posting inserts,. frisking probes, respiratorccartridges, and decontamination articles were in short supply and threatened to delay the schedule of work. Temporar ~

shielding longer that 3 feet long was not available. Use of blankets 5 feet long would have been helpful-in reducing total radiation dose in at least one-area, according to the licensee's personne . Waste Handling Area - The waste segregation and storage area was crampe Radiation' Survey Records - Retrieving survey information seemed cumbersome. Although HP personnel were;able to provide the inspector with the requested survey information on areas selected at random, it was a' slow process, with the technician needing to check lists of i

surveys in the computer data base. One individual stated that the system was better suited to filing the information than retrieving-

.i Survey information was more readily available if the area happened to'be covered by a radiation work permi ' 5 .- ~ Audits and Appraisals The inspector reviewed the '.icensee's audits and surveillance of the HP division sto determine co.npliance with commitments in the FSAR; the requirements of 10 CFR Part 50, Appendix B; and the recommendations of

- Regulatory Guide (RG) 1.14 Only one audit had been performed of the HP division since the previous inspection. Audit 89-25 was conducted during the period May 16-26, 1989, and identified six deficiencies, two of which were corrected during the audi HP was required to respond concerning the other four. The responses included identification of the roct causes of the deficiencies, statements of remedial' actions, and planned actions to prevent recurrenc The re:ponses were provided within the allotted tim '

The following surveillance were reviewed:

i 89-001 Perscenel-External Dosimetry Issuance and Use 1 89-003 Counting Room Activities 69-0D3 Radiological Surveys ,89-035 Radir> active Source Inventory and Leak Test j 89-040 Access Cortrol/ Radiological Posting ,

69+677 Radiation Exoosure Lim'ts89-036 Internal Desimetry j

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89-092' Radiation Work Permit i S9-128 Access Control / Radiological Posting  !89-144 Radiological Surveys89-166 Survey Instrument Calibrations i 89-179 Respirator Test and Maintenance l

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.89-185 Radiation Work Permits09-186 Radiological Shielding 89-190 Counting Room Activities89-198 Personnel External Dosimetry Issuance and Use No violations or deviations were identifie . Training and Qualification of New Personnel The inspector reviewed the licensee's staffing in the HP division to determine compliance with FSAR commitments; 10 CFR Part 19.12 requirements; and the recommendations of ANSI N18.1-1971, RGs 1.8, 8.8, 8.13, 8.27, 8.29, and NUREG-004 Personnel employed since the previous inspection included the HP division manager and the HP operation support supervisor as well as contract HP technicians for outage coverage. The inspector determined that the manager was qualified in accordance with existing guidance. The HP operations support supervisor has responsibility for respiratory protection and meets the recommendations of NUREG 004 The licensee employed approximately 40 HP contractor technicians for the outage. The technicians' resumes were screened before hiring by the site coordinator. The licensee was especially interested in individuals with experience in the types of jobs that were scheduled to be completed during the Unit I outage. All senior technicians were further screened by written tests. The inspector reviewed selected resumes of the technicians and determined that the technicians were qualified in accordance with ANSI 18.1-1971. Observations and interviews by the inspector did not identify unqualified personne No violations or deviations were identifie . Planning, Preparation, and___ALARA

'ihe inspector re; viewed the licensee's preparation for the outage and ALARA program to determine sgreement with the commitments in the FSAR Section 12; the ret,uirements of 10 CFR Part 20.1(c); ar.d the  !

recommendation of RGs 8.8, 8.10, and 8.2 HP has one person designated as the outage planner. The individual was involved ir. the scheduling and planning of the work being performed during l: the outage and contitues to be involved by attending the work control i l meetings. Licensee representatives ststed that HP concerns were built I into the crVtical path fer outage work activities. All ndiation work l permits for scheduled wark were completed prict to the start of the outage. Additionally, the HP outage planner has access to the 'stest outage activity schedule via computer termina _ _ _ , . , ----, - , , - " ' " ' ' ' ' ' ' ~" ' ._

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g The licensee s ALARA program has only one staff' person to' cover the

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, ' activities of both units and it appears to be understaffed. 'During.the outage,:the individual has the help of one contract employee. Apart from

' the outage activities, the ALARA staff person had reviewed 86 proposed-modifications to. procedures during 198 The licensee provided for the inspector's review.a list of jobs requiring radiation' work permits to be accomplished during.the outage. Five~ jobs were predicted to result in an exposure of 1.0 to 4.99 man rems, six from

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5.00 to 10.00 man rems, and one in excess of 10.00 man rem The ALARA packages did'not always contain enough information to clearly identify detailed ALARA steps to.be accomplished before work began ~on a specific job. Additionally, in cases in which a job was started and-unplanned problems; arose causing the original man-rem estimate to be increased. it was unclear as to what steps were taken, if any, to-ensure that-~ the proper ALARA evaluation was' performed to account for the changes

.in work conditions. Licensee representatives stated that they. recognize

- that some weaknesses exist with their present'ALARA' program and that a complete-evaluation is planned after the refueling-outage is complet They further stated that they plan to evaluate such areas as staffing, documentation, and implementing procedures. This matter is considered an open item pending a review of the licensee's evaluation of the ALARA progra (498/8931-01; 499/8931-01)

The licensee set a goal of 100 man-rem for the outage and had used approximately 80 percent of the goal by the last day of the inspectio Licensee representatives stated that the goal was intentionally

" aggressive." Licensee representatives further stated that total exposures were higher than planned for various reasons. Estimates by the different departments or contractors of man-hours necessary to accomplish tasks were low in some cases and radiation dose rate levels were higher than anticipated. Erection of scaffolding had not been accomplished in en optimum manner'and stuck bolts increased. doses associated with the removal of manways frem the steam generators. Because this is the licensee's first refueling outage, the data base is relatively small. The licensse

, .had obtained radiation dose rate and task man-haur information from Palo Verde 3 aad used this~informc. tion as guidance in the preparation of ALARA package The licensee uses a mor.kup for training individuals invoived with all wnk having to do with the steam generater. Television cameras were used I y extensively and varicus jobs such ar mar.wty remeval and nozzle dam  ;

5 installation were videu taped for later viewing and ALARA oriefings. . The i licensee also made use of what is called a " surrogate tour." This is a series of as rany as fifty-thousand still pictu-es taken within the plant

'and stored on a laser disk. When used with one of the several comp >ter 3 hookups, this system al?ows individuals to review areas (and information  !

in the form of supplemental graphics) in which work is to be perferme l

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,4 , a l 8 The inspector attended work planning meetings, plan of the day (POD)

meetings, and prejob briefings. The ALARA concept was stressed in eac In the POD meetings, the cumulative man rem total was presente Individual departments were kept apprised of their totals. Prejob briefings included expected dose rates and instruction on how to lower exposur No violations or deviations were identifie . External Exposure Control The inspector reviewed the licensee's external exposure control program to determine compliance with FSAR commitments; 10 CFR Parts 19.13, 20.1, 20.101,10.102, 20.104, 20.105, 20.202, 20.401, and 20.408 requirements; and the recommendations of RGs 8.2, 8.4, 8.7, 8.8, 8.14, 8.28, and ANSI N13.11-1983, N13.27-1981, N319-197 The licensee has had an adequate supply of thermoluminescent dosimeters (TLDs) thusfar, although at times the excess was as little as 100 devices. Normally, about approximately 1700 people are monitored by TLDs in both units. At the time of inspection, there were about 2200 being monitored. During steam generator work, about 1000 TLDs were committed to use in jump packs (multibadging).

All TLDs are processed at the licensee's laboratory in Housto Site personnel can assign different priorities to the processing of different badge It typically takes one week to receive exposure information; however, doses for the individuals working in the steam generators were available for review before the following shift began work, according to a licensee's representativ Thusfar during the outage, the highest exposure recorded for an individual has been approximately 1250 mrem. This individual, and two others who have received in excess of 1 rem, were involved in steam generator wor The inspector observed that calibrated radiation survey meters were available to HP personnel. An adcquate supoly of 0 to 200 mrem dosimeters were available, but the number of 0 to 1500 mrem dosinters was 1-imited to about 300. Alarming dosimeters wert irsued to indi /iduals entering higF radiation area The inspector aleo reviewed area posting and made indeper; dent radiation measuremen No violations or devictions were identifie Interna 1 1 Exposure Control The inspector reviewed the licensee's program for control of internal radiation exposure to determine compliance with commitments in the FSAR;

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the requirements'of 10 CFR Parts 20.103, 20.201, 20.203, 20.401; and the

' recommendation of RGs 8.2, 8.7,.8.8, 8.9, 8.15, 8.20, 8.26, and 8.27; and ANSI'N343-1978 and NUREG-004 Whole body counting had not identified any case of internal contaminatio Procedures require the tracking of a worker that exceeds 1 percent.of a body burden and requires work restrictions if the 10 percent level is exceede .The licensee had approximately 300 'u11 faced respirators available for i, use. On at least one occasion, a shortage of cartridges for the l: respirators threatened to delay the work schedule. Thusfar, the .

respirator decontamination process has been able to. keep up'with the deman Respirator control appeared to be stringent. At.the-respirator

.. issuance point, qualifications were verified by HP personnel using computer' terminal ~to'~ access a central data base. In order to maintain better control of equipment, individuals were issued no more- than one-respirator at a time. The inspector also observed fit testing at th Central Processing Facility.

L Instrument air was used at one point'for breathing air. The supply was l checked for quality' prior to its use and found to n,eet or exceed the I

requirements for Grade "D" air as specified in ANSI 286.1-197 No violations or deviations were identifie . Control of Radioactive Materials and Contamination, Surveys, and Monitoring The licensee's programs for the control and survey / monitoring of radioactive materials were reviewed to determine agreements with commitments in the FSAR and compliance with requirements of 10 CFR Parts 19.12, 20.201, 20.203, 20.205, 20.207, 20.301, and 20.40 The inspector reviewed access control procedures and facilities and determined that thoy were adequate. Modesty clothing was stored in an area outside the radiological restricted area (RRA). Protective

. clothing (PC) was stored within the RRA Supplies of each location

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appzared tc be adequate. Laundry facilities (wet wash only) were separate

! for modest) cle:Mng aad PC, as were the monitors for each. The setpoint for tne ht.ndry monitor was 30,000 disintegrations per minute (dpm) for PC and 5,000 c'g for the modest 3 clothing. When modesty clothing was found to bis contamir,ated, it was disposed, h The itceasee established as zdM tior.a! r.ontroi point outside of f contai nmer,t. An 49 veHfied the correctness iof the RWP of eyone going i nt.) the area ud was able to obserte work beirg performed in several l

different Preas v?a closed circoit television monitor __

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Much of the area within containment was maintained free of contamination, allowing individuals to enter without wearing PC. Contaminated areas were barricaded and posted as appropriate. Air sampling units were positioned appropriatel The inspector discussed with licensee representatives the location of some step-off pads. Some step-off pads appeared to be located in areas without adequate room for the removal of PC. One example was the area on top of the pressurize Even though HP representatives stated that the primary access to this area was on another level, nonetheless, the step-off pad on top was used occasionally to exit and its position was such that adjacent piping made undressing difficult. The inspector noted that the step-off pad was later repositioned to allow more room. In another case, the step-off pad was totally within the contaminated area. This area was later released as clean. There was no evidence that supervisory HP personnel had reviewed the setup of the areas. This is considered an open item pending the licensee's review of its procedure for establishing and overseeing areas controlled for the purpose of preventing the spread of contaminatio (498/8931-02; 499/8931-02)

Housekeeping was generally acceptable to this point in the outage, but there were signs that it might be beginning to falter somewha HP technicians commented that an increasing number of tools were being left in contaminated areas rather than being bagged and taken to the decontamination area. Space in the waste segregation and storage area was becoming cramped. Barrels containing waste were being moved and rearranged in an effort to ease this conditio The inspector performed independent radiation measurements in the tool room and verified that controls over contaminated tools had been maintaine High sensitivity personnel contamination monitors (PCM) were placed outside of containment and at the exit from the RRA. The inspector i verified their use by individuals leaving both areas. The personnel contamination incidents which has occurred thusfar has been low level, general contamination, attributed to poor undressing technique. HD has 1 addressed this problem with the individuals and the appropriate supervisors when there is a trend reflecting on the performance of any particul v group. No het _carticles have been identifie I The iicensee did not have tool monitors ir, s m ice & ring the ti % of the j inspection and all itarr; leaving the RRA had to be hand fritked by HP i technicians before removal. The inspector noted that a cabinet monitor i had arrived on site, but had not been installed,. 1 l \

l Within containment, the inspector ob5med that, at tiraes, individuals in ;

PC, in street clothes, and in modesty cloth <ng (gyn snorts aM a t-shirt) !

worked side by sido. Modesty c'otMng is inter.ded to be used under the PC j at:d remain en the workers during transit beneen the RRA exit point and the PCM/ change roam area. The practice was ccnfusing and appeared as

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though it made it difficult for HP to determine: (1) if individuals had worked in contaminated areas or (2) if individuals had used the PCM after removing PC. The licensee stated that controls of clothing practices had become lax and that due to the high temperature in containment, some workers had developed the habit of wearing modesty clothing as a routine practice. The licensee also stated that the use of PC in designated clean areas needs to be reviewe The matter is considered an open item pending the licensee's evaluatio (498/8931-03; 499/8931-03)

No violations or deviations were identifie . Transportation The inspector reviewed the licensee's program for transportation of radioactive materials to determine compliance with the requirements of 10 CFR Part 71.5 and 49 CFR Parts 170 through 18 According to an interdepartmental agreement dated July 25, 1989, the HP division has assumed responsibility for shipping of radioactive material and radioactive waste. HP maintains the state permits, transport contracts, burial site contracts, and performs inspections of shipping containers. Copies of the Certificates of Compliance had not been transferred from Chemical Operations Division. This area is considered an open item pending the NRC's further review of the licensee's transportation records and quality control program for transportatio (498/8931-04; 499/8931-04)

There have been eight shipments of contaminated items since June 198 The inspector reviewed records of four shipment No violations or deviations were identifie . Exit Meeting The inspector met with the resident inspectors and the licensee's representatives denoted in paragraph I at the conclusion of the inspection on August 25, 1989, and summarized the scope and findings of the j inspection as presented in this report. The licensee did not identify as j proprietary any of the materials pt ovided to or reviewed by the inspector I during the inspectio ,

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