IR 05000498/1989044
| ML20005F229 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/03/1990 |
| From: | Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20005F222 | List: |
| References | |
| 50-498-89-44, 50-499-89-44, NUDOCS 9001160072 | |
| Download: ML20005F229 (13) | |
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APPENDIX g
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U.S, NUCLEAR REGULATORY COMMISSION-
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REGION ~IV.
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NRC~ Inspection Report:
50-498/89-44 Operating Licenses:
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50-499/89-44 NPF-80
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. Dockets:- 50-498:
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50-499
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Licensee:. Houston Lighting & Power Company h
P.O. Box 289'
N Wadsworth,. Texas 77483
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Facility Name': South Texas Project Electric Generating Station (STPEGS)'
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-Inspection At:
STPEGS Site, Bay City, Matagorda County, Texas F
Inspection; Conducted: November 27 through December 1, 1989 t
Inspectors:
L. T. Ricketson, P.E., f(a.11ation Specialist Dater Facilities Radiological Protection Section
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' Accompanied B. Murray, Chief, Facilities Radiological
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Protection Section (November 30 and December 1, 1989)
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. Approved:
M e i B. Murray, Chief, Faciyffies Radiological Date '
Protection Section V o
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I Inspection Summary Inspection Conducted November 27 - December 1,1989 (Report 50-498/89-44;
-50-499/89-44)
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Areas Inspected:
Routine, unannounced inspection of the licensee's radiation I
protection program including organization and mancgement controls, training and I
qualifications, external exposure controls, internal exposure controls, control
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of radioactive material and contamination, maintaining personnel exposures as l
low as is reasor. ably achievable (ALARA), and transportation of radioactive
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materials.
Results: Within the areas inspected, there was one licensee identified s
violation.
No deviations were identified.
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The radiation protection program appears to be well organized and managed.
Additional revisions to health physics (HP) position descriptions are planned r
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iin ' order. to make: the ' descriptions job-specific. The HP staff is adequately.
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M trained;and-qualified. Detailed training requirements are specified-for HP
personnel at the n chnical--level;,however,' specific training criteria for HP.
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Ps-supervisors and professionals-have'not been_ established. The-staffing leve.1
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- appears adequate;for a~two-unit! facility, but it appears that rescheduling may:
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'be.needed to-provide additional support for: day shift activities. -Procedures--
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and controls'a~re generally good and assessments of problem areas-or-technical g
~ issues.are dealt:with'in.a-timely and thorough manner.
Instrumentation,.
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equipment; and supplies appear adequate. Additional changes and. modifications W
- .are planned for the ALARA program to 1'mprove this: area; h
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DETAILS 1.
Persons Contacted HL&P
- M. ;R. Wisenburg, Chairman, Nuclear Safety Review Board
- S. L. Rosen, Vice President, Nuclear Engineering and Construction
- R. W.-Chewning, Vice President, Nuclear Operations
- W. A. Kinsey, Plant Manager
- J. R. Lovell, Manager Technical Services
- H. W. Bergendahl, Manager HP.
- R. A. Gangluff, Manager Chemical Operations & Analysis R. W. Pell, General Supervisor, HP Operations Support T. W. Tessmer, HP Supervisor,-Outage Planning R. V. Logan, HP Supervisor, ALARA R. E. Bilbrey, Supervisor, Dosimetry S. Torey, Training Coordinator, HP J. E. Simms, HP Supervisor, Transportation
- C. A. Ayala, Supervising License Engineer
- A. K. Khasia, Senior Licensing Engineer S. Childers, Maintenance Foreman R. Amos, Mainte n nte Foreman K. Christian, Unit 1 Operations Supervisor C. Brown, Outage Manager N_R_C
- J. _I Tapia, Senior Resident, STP, Unit 2
- Denotes those present at the exit meeting on December 1, 1989.
The ir.spectors also interviewed other plant personnel during the course of the inspection.
2.
Action on Previous Inspection Findings (0 pen) Open Item-(498/8931-01; 499/8931/01):
ALARA Program - This item wss discussed in NRC_ Inspection Report 50-498/89-31; 50-499/89-31 and involved several matters concerning the licensee's ALARA program. The licensee conducted a review of its ALARA program and, as a result, has initiated changes.
However, until the changes have been implemented, this item will remain open. This matter is discussed further in paragraph 10.
(Closed) Open Item (498/8931-02; 499/8931-02): Establishment of Areas for Control of Containment - This item was discussed in NRC Inspe'ction Report 50-498/89-31; 50-499/89-31 and involved the placement of step-off pads in areas without adequate room for removal of protective clothing.
The inspectors reviewed the results of the licensee's evaluation and noted that the actions taken by the licensee included:
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The revision ~of Standing Order 31, " Assigned (Management)LRRA Tours,"
to specifically list contaminated area set-up and step-off pad
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. locations;as a required-review item.
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The change-'of Procedure OPRP02-ZX-0007,=" Radiological Posting and
' Warning Devices,". to clarify the-requirements separating the step-off
' pad from the. posted area.
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Instructions to the warehouse personnel to order only. step-off pads
_i with one specific phrase ~to ensure consistent wording.
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The licensee's actions appear adequate in regard to.this matter.
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(Closed) Open Item-(498/8931-03; 488/8931-03):
Evaluation of Protective-
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- Clothing Use This item was-discussed in NRC Inspection
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Report 50-498/89-31; 50-499/89-31 and involved the various types of clothing'-
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. workers were wearing in containment, making it difficult to determine
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which: workers had been in contaminated areas and which had cleared
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-personnel' contamination monitors. The inspector reviewed the licensee's
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memo giving instructions'to workers and clarifying the licensee's policy on-the use of modesty and protective clothing. The insoector also noted
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that-the subject was' covered in the outage newsletter. The licensee's acti_ons appear adequate in regard to this matter.
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(Closed) OpeniItem (498/8931-04;'499/8931-04):
Evaluation of
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-Transportation and QA Program - This item was discussed in NRC Inspection
. Report'50-498/89-31; 50-499/89-31 and involved further review of the licensee's transportati.on program.
The program was reviewed during this inspection and the_ licensee's actions were found to be' adequate to close this item. 'See-paragraph 11.
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'3.
.0 pen Items Identified Durino This Inspection
Open items are matters that _ requires further review and evaluation by the l
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inspector,1 including _an_ item pending specific action by the licensee or a
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_previously-identified violation, deviation, unresolved item, or programmatic weakness.
Open items are used to document, track, and ensure
= adequate followup by the inspector.
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Doen Item Title Paracraoh
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-498/8944-01 Shielding and Procedural Modifications
i 499/8944-01 498/8944-02 Sanitary Sewage Sludge Disposal
499/8944-02
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4.
Observations
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The following are observations the inspector discussed with licensee's representatives.
The observations are not violations, deviations,
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E unresolved items, or open items. Observations are identified for licensee
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consideration:as program improvement items, but have'no specific regulatory requirement.
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E ab Position' Descriptions e
Position descriptions had not been established for radiation
protection personnel that identify specific technical work (1 responsibilities.
(See: paragraph 5)-
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Training e
'The training. program does not address the type and frequency of-U training that radiation protection supervisors and professional personnel should receive.
(See paragraph 6)
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5.
Oroanization and Management Controls -(33722)
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The: inspectors reviewed the' organization'and management controls ~
concerning the -radiation protection program to determine compliance with'
TS requirements and FSAR commitments.
The radiation protection staff
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consists of.4 bout 80 personnel. This staffing level appears adequate to C
support a two' unit; site;-ho9ever, several HP technicians interviewed by-
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the inspectors expressed-the opinion that the HP technicians were
' stretched rather thin on day ' shifts and during outage conditions.
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Maintenance personnel stated.that there were-probably some maintenance jobs'that'had short delays because of the lack of available HP coverage;
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= however,. they did not believe that delays were a significant problem and that the HPs provided good, comprehensive coverage.
The licensee does not
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place a. heavy reliance on. contractors for routine radiation protection
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functions. ' Contract personnel are hired to supplement-the permanent plant
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staff during outage situations, but the licensee reverts.back to the
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permanent plant staff once the outage is completed. The licensee has expe_rienced a low turnover rate within the RP staff; three persons terminated in 1989.
.The-inspectors reviewed the amount of overtime HP technicians were working. Overtime did not. appear to be excessive with technicians working j
about 200-350 hours.per year.
Interviews with HP technicians did not
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reveal any instances where the technicians believed that they were being-
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-required to work excessive amounts of overtime.
Position descriptions existed for various positions in the radiation i
_ protection department.
However, the descriptions were rather generic l
without specific reference to radiation protection duties at a power i
reactor. The licensee stated that they were in the process of revising their position descriptions in order to make them job specific.
Interviews with various memoers of the plant staff indicated that a good j
working relationship exists between the HP department and other
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departments such as operations and maintenance.
The inspectors reviewed t
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L management support provided to the HP department.in the areas of~ staffing;
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. budget for: equipment, instrumentation,.and. supplies; and training.
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appears;that management provides good s'upport for radiation protection
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activities.
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-Theiradiation protection' department appears to be a well managed
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- organization _ :The licensee conducted a detailed analysis of the'various
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_ jobs-assignedLto radiation protection department along.with needed m
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- manpower to accomplish these tasks. The licensee's;orga'nization does not c
Lincludetan independent corporate support group to provide oversight of the-onsite radiation department activities; all radiation protection-
' activities are under the Manager, Technical Services. The: inspectors did
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'nottidentify any problems with the current organization, but the need for
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-the-licensee to' conduct aggressive-performance based audits ~to provide proper management oversight was discussed-The licensee has performed
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several comprehensive audits.
The inspector _noted that the audits appear'
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- to-be oriented to ensure compliance with~ existing procedures, but did nnt
- include comments-on the technical adequacy or program-improvement items
'for the radiation' protection' program.
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h No violations or deviations were identified.
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Training and Qualifications (83723)-
n The^ inspectors reviewed the licensee's training and qualification program
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to determine compliance with the requirements of 10 CFR 19.12 and the
- Technical Specifications;. commitments in the FSAR; and the recommendations
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in ANSF 18.1 -11971.
The inspectors interviewed seven individuals from the radiation protection ~ department, including both technicians and
supervisors, to discuss training activities, f
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- The: licensee ~had developed specific written training programs for
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technician level workers; however, training requirements had not been is established for HP-supervisors and professional personnel. The-inspectors
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examined work resumes and training records for about 15-members of the
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F radiation protection staff.
The' training records provided a list of all
training provided. The records indicated that HP technicians attend about
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2 weeks of-plant systems-training.
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The: licensee's HP staff appeared to be well trained and -included several i
persons with strong academic backgrounds in HP.
The staff had
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a good mix of senior HP technicians; degreed personnel at the bachelor,
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' Master and Ph.D' levels; and three health physicists certified by the
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American Board of Health Physics.
The inspectors reviewed the following training and qualification procedures:
IP-8.18, "0JT/ Qualification Program," Rev. 3, 11/29/88
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.IP-8.29,:" Radiation Protection Technical Training Program,"
Rev. O, 10/13/89 OPRP01-QA-0037, " Radiation Protection OJT/ Qualification Program" Rev. 1, 9/18/89 No violations or deviations were identified.
7.
External Exposure Control (83724)
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The inspectors reviewed _the licensee's external control program to determine agreement with FSAR commitments; compliance with the requirements of 10 CFR Parts 19.13, 20.1, 20.101, 20.102,_20.104, 20.105, 20.202, 20.401, and 20.408; and agreement with the recommendations of RGs 8.2. 8.4, 8.7, 8.8, 8.14, 8.28, and ANSI N13.11-1983 and N13.15-1985.
The inspectors reviewed the results of the licensee's investigation of radiation streaming from sludge lancing penetrations in the fuel handling building.
IE Bulletin 78-08 discussed " Radiation Levels from Fuel Element-Transfer Tubes." Open Item.498/8629-06 was used to track the licensee's actions to control access to areas adjacent to the fuel transfer tube and was last discussed in NRC Inspection Report 50-498/89-31; 50-499/89-32.
While performing radiation surveys on August 25, 1999, in these areas durin"; the-first spent fuel transfer, the licensee 1ientified an area outside the fuel handling building in which the instantaneous radiation dose rate was as high as 15 R/h.
This was on contact with a small area next to one' of _the sludge lancing pipes exiting the fuel handling building._ Sludge lanci.ng penetrations had been added as a design modification begun June 4, 1934, and provided a pathway through the shielding which_coincidently aligned with the fuel transfer tube. When the situation was identified, the licensee stopped fuel transfers entil further evaluation could be made.
On review, the licensee identified that it was possible for design changes such as this, performed by the support engineering group, to go unreviewed by the ALARA program. To ensure against the possibility of not -identifying small but highly intense beams of radiation, the licensee used X-ray film, in a reproducible geometry, to map the entire-area around the penetrations and used the results to
. position thermoluminescent dosimeters to record the radiation dose.
Using these measurements and the fact that the maximum number of fuel assemblies transferred in any hour was four, the licensee calculated that the maximum exposure an individual standing 18 inches from the sludge lanse piping could have received was 110 mrem to a small area of the body in an hour.
Further, the licensee's investigation determined that no work was scheduled or observed _near the sludge lancing piping during spent fuel transfers.
Therefore, it is unlikely that anyone received a significant exposure.
The results of the licensee's evaluation were reviewed by the inspectors.
The design engineering department reviewed penetration drawings in an effort to identify other possible problem areas.
HP conducted a walkdown of surrounding areas and performed surveys as fuel assemblies were
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. transferred.- : A: barricade was erected around the area and a security guard -
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was posted to keep l individuals from entering-the area. ~ Lead blankets.were-
- used as temporary shielding.
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The licensee committed 'to two long-term' corrective actions:.
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-(1): installation of shielding.(in both Units 11 and 2)=to prevent!
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thigh radiationzlevels_-outside the fuel = handling ~ building and (2) amend the i
design engineering modification program to ensure that an ALARA. assessment
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.isl performed on> all future ' modifications-in the radiological restricted
- area. This matter is considered an open item pending a review of: the licensee's actions.
(498/8944-01;499/8944-01)_
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The inspectors also reviewed. dosimetry issue practices and selected
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dosimetry records and notifications.
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.The. inspectors reviewed the following,related procedures:
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. OPRP02-ZX-0015, " Quality Control Checks for Panasonic TLDs,
' Revision 6, May 20, 1989
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OPRP06-ZQ-0012, " Quality Assurance ~ Program for TLD Processing,"
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Revision 2, September.14, 1987
No violations,orahviations were identified.
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- Interr.a1 Exposure Control '(83725)
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x The inspecto'rs reviewed the licensee's program for-control of internal-
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> radiation exposure to determine agreement with commitments in the FSAR; g
compliance with the requirements of 10 CFR Parts 20.103, 20.201, 20.203, and 20.401;-and agreement with the recommendations of RGs.8.2, 8.7, 8.8, t
Bil5,:8.20, Bi26,-and 8.27; ANSI N343-1978; and NUREG-0041.
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LLicensee representatives stated that they will soon institute a program of~
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performing random whole body counts in addition to those performed
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initially, upon termination, and for special inve'stigations.
Individuals
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will be selected from the respirator issue list.
The licensee is continuing the changeout of regulators on the breathing air' system to allow more widespread use.
The old regulators restricted
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the number of individuals which could work off of one manifold. The
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licensee representative stated that there were approximately 70 regulator:
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each in both Units 1 and 2 and the replacement order would give priority F
to the more frequently used locations. Those in Unit 2 containment are scheduled for replacement before the April 1990 outage. The service air system was used for breathing air at times during the Unit 1 outage. The air was checked both in-house and by a vendor and found to meet air quality requirements.
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The licensee is preparing a procedure by which MPC-h'ours are calculated by using the.results of whole body counting. The procedure is scheduled for implementation before the end of the year.
The inspectors reviewed the following related procedures:
OPRP02-ZR-0001, "Use of-Varskin to Determine Skin Dose," Revision 0, January 11, 1988
'0PRP02-ZR-0002, "MPC Evaluation," Revision 1, August 1, 1989 OPRP02-ZB-0002, " Biological Sample Collecting," Revision 2, August 26, 1988 OPR02-ZB-0005, " Internal Dosimetry," Revision 1, July 6, 1987 No violations or deviations were identified.
9.
. Control of Radioactive Material and Contamination, Surveys, and Monitoring (83726)
The inspectors reviewed the licensee's programs for surveying / monitoring and controlling radioactive materials to determine agreement with commitments in the FSAR, and compliance with tne requirements nf 10 CFR Parts.19.12, 20.201, 20.203, 20.205, 20.207, 20.301, and 20.401.
The inspectors reviewed the circumstances surrounding the licensee's report of radioactive contamination-found in sludge f rom the or site sewage treatment plants.
NRC Information Notice No. 88-22 alerted licensees to the potential.for contamination of sewer sludge and the relevant regulatory requirements. The notice, in turn, referenced IE Bulletin 80-10, " Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment." The licensee has several sanitary waste troatment stations on site and as a result of Information Notice No. 88-22 began a quarterly sampling program. On September 14,'1989, the licensee identified levels of Cobalt-58 at 1.3 E-6 microcuries per gram and Cobalt-60 at 2.5 E-7 microcuries per gram.
The measurements were made or. dry samples.
A sample-taken from the separate system of the Nuclear Training Facility (NTF) indicated that any activity was below the licensee's,ower limit of
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detection, which was approximately 1.0 E-7 microcuries pe gram (for dry sample s). Previous samples from all stations in April 1989 showed no detectable contamination.
The licensee's practice was to dispose of sludge at an ofisite landfill.
Fif teen shipments were disposed between April 7 and Atgust 15, 1989, the last shipment before the September 14 sample.
At the licensee's request, representatives from the Bureau of Radiation Control from the state of Texas performeu measurements of the disposed sludge at the landfill using e microR meter and took samples for laboratory counting.
The inspectors contacted representatives from the state of Texu and verified trat
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.sirveys;' indicated nothing above background levels and sample results were N
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- As a > result of this, situation,.the' licensee committed to 'the; follo' ing
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="4 All _ shipments of sludge f rem' onsite sewage treatment stations,Jother
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{R ttnanLfrom the NTF,:will beisuspended,
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1All shipments of' sludge'from the'NTF will'be m pled and analyzed,-
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prior to shipping, to deterrnine if radioactive contamiration.is
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Jpresent.:
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To 1 Thel 11cens'ee will obtain: an exemption from the state of Tdxas beforeL
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resuming _ disposal of sludge, s
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= Licensee representatives stated that tnere'was sufficient sto. rage space
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ifor the sluage:atione of= treatment plants on site until an exemption from,
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the: state of Texasicould be obtaine6.-
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M Normally,i the-NRC would, consider a -violation of the req'uirements of 3
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- 10'CTR_20,201,:forz failure to-a'dequately survey in situations-such as--
ithisj however, becauseithe licensee identified the condition, promptly
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notified the-NRC and-took--impediate corrective action, and because the'
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levels of radioactive contamination discovered were low,' the NRC hab s"
'm celected tonuse itidiscretionary option (per 10 CFR Part 2, Appendix C,
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Section;V.G.1) and:not: cite a violation.' This matter is considered.an:-
open item pending.a further rsHER of,the licensee's corrective actions.
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.(498/8944-02;-499/8944-02)
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- TheLinspectors also reviewed radiological restricted area access control i
practices and *adiological.. posting, and performed confirmatory radiation
surveys.
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The inspectors reviewed the following related procedures:
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OPRP08-ZA-0001, " Radiation Work Permits,"' Revision 5, November 22,
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1989
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OPRP08-ZR 0002, " Respiratory Protection Equipment Control,"
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Revision 5, November 20, 1989
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No violations or deviations were identified.
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10. ALARA (83728;
g The inspectors reviewed ALARA activities with special emphasis on the
'i recent Unit I refueling outage.
For the period January 1 through
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Novencer 30,'1989, the licensee had expended about 165 person-rem for both i
units. The 1989 totals included abot.t 142 person-rem received during the
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tunitL1 outage. ;The licensee had set an outage goal of 100 person-rem.
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reviewing outage activ_ities,:it was noted that most of the ALARA goal,.
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.c overrun appeared to be due to low original-person-hour work estimates and
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the performance of unplanned outage work identified after the start of the -
M outage rather'than-an ineffective ALARA program. The licensee had issued
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a well' documented ALARA outage re' port. The inspector also reviewed.
several_ completed'ALARA packages = accomplished during the outage. :,The-packages were comprehensive,:well written documents, j
Several comments regarding the-licensee's ALARA program were last
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' discussed in NRC Inspection. Report 50-498/89-31; 50-499/89-31.' -Since the
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previous inspection, the licensee nas cenducted a review of their'ALARA
program. including manpower assignments. The-licensee stated that an-evaluation of their review is continuing and all planned changes have not-
.been finalized.
The inspectors discussed.the following items.concerning
n-the.present'ALARA program:
'The-licensee's ALARA program mainly addresses radiation protection activities assoc.ated with outage / maintenance jobs.
The program does=
.not include; source term evaluation and controls such as reactor.
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coolant system chemistry considerations to control-the buildup of
> radiation levels in plant systems or the use of chemical W
decontamination techniques.
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The.ALARA program:does not include the routine review and corrective-actions for. chronic, low person-rem conditions that exist in plantL g
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areas such as " hot spots" from contaminated piping in passageways,-
contaminated drain. sumps, etc.
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Some design. changes initiated by engineering support groups have not received an ALARA review.
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lA comprehensive ALARA manual has not been established. The ALARA
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program is referenced _ir -several separate procedure:,.
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'The inspectors reviewed the following ALARA documents and procedures:
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South Texas Project Electric Generat1ng Station ALARA Policy, Revision 0, March 1,1985
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OPRF01-ZA-0002, "RWP ALARA Reviews," Revision 1, August 3, 1989 IP-2.3Q, "ALARA Program," Revision 0, July 29, 1986
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Procedure OPGP03-ZR-0033, "ALARA Engineering and Procedure Review,"
Revision 3, August 3, 1989
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Procedure OPGP03-ZR-0028, "ALARA Review Committee," Revision 3, August 3, 1989 f
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--12-OPGP03-ZR-0035, "ALARA Suggestion-Program," Revision 1, September 1,
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1989 OPGP03-ZA-0003, " License Compliance Review,". Revision 8, March 18,
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OPGP03-ZR-0008, " Operational ALARA Program," Revision 3, August 3, 1989'
Unit 1 Refueling Outage ALARA Report, November 28, 1989 Since the licensee is still in the process of revising their ALARA program, Open Item 498/8931-01; 499/8931-01 remains open pending further
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review by the NRC, No violations or deviations were identified.
11.
Transportation (86721)
The inspectors reviewed the licensee's program for transportation of radioactive materials and radioactive waste to determine compliance with-the requirements of 10 CFR Part 71 and 49 CFR Parts 170 through 189.
It was noted in NRC Inspection Report 50-498/89-31; 50-499/89-31 that the responsibility for the transportation of radioactive material and radioactive waste had been transferred from the Chemical Operations group to HP, -The program is staffed with a supervisor and a technician.
The supervisor stated that.other HP technicians are available to him if neces>ary..HP management stated that another individual, to act as a
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backup, is. scheduled for training in transportation requirements, and emergency support is available from the Chemical Operations group.
. The inspectors verified that the individual supervising the program had current copies of state permits, transportation contracts, burial site contracts, Certificates of Compliance for shipping containers, 10 CFR Part 71 and 49 CFR Parts 170 through 189. The inspector also verified that the licensee has received approval for its transportation quality assurance program (Docket No. 71-0645)
The inspectors reviewed documentation of selected radioactive material and radioactive waste shipments and found them to be adequate.
The inspectors reviewed OPRP03-ZR-0002, Revision 1, " Radioactive Waste Shipment," issued November 22, 1989. The licensee consolidated various procedures concerning transportation into one, making instruction easier to find, No violations or deviations were identifie.jfrM'g,
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