IR 05000498/1990012
| ML20043G273 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/08/1990 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20043G270 | List: |
| References | |
| 50-498-90-12, 50-499-90-12, NUDOCS 9006200115 | |
| Download: ML20043G273 (12) | |
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APPENDIX
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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NRC Inspection Report:
50-498/90-12 Operating Licenses: NPF-76
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50-499/90-12 NPF-80
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Dockets:
50-498
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i 50-499
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Licensee:
Houston Lighting' & Power Company (HL&P)
P.O. Box 1700 i
Houston, Texas 77251 Facility Name:
South Texas Project Electric Generating Station (STP)
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Units 1 and 2
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Inspection At:
Energy Development Complex (EDC)
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12301 Kurland Drive Houston, Texas
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STP Site, Bay City, Matagorda County, Texas Inspection Conducted: May 7-10, 1990 d!7 Inspector:
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J.J.Nichoas,SeniorRadiationSpecialist Facilities Radiological Protection Section Approveo:
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i B. Murray, Chief, Facilyties Radiological Date '
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Protection Section Inspection Summary Inspection Conducted May 7-10, 1990 (Report 50-498/90-12; 50-499/90-12)
I Areas Inspected:
Routine, unannounced inspection of the licensee's radiological environmental monitoring program (REMP) including organization and management controls, training and qualifications, and implementation of the REMP.
Results:
The inspector determined that the licensee had implemented a REMP in accordance with NRC requirements. The REMP was being conducted in accordance with Technical Specification (TS) requirements. Quality assurance (QA) audits and surveillances had been performed as required and were technically
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2-comprehensive and performance based.
The meteorological monitoring instrumentation had been calibrated and maintained in accordance with TS requirements. The meteorological annual joint frequency distribution data recovery for 1988 and 1989 was greater than 90 percent. The licensee's staff involved in implementing the REMP had experienced a low turnover of personnel
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during the last 18 months.
The licensee had not submitted any chang.s to the Offsite Dose Calculation Manual (ODCM) concerning the REMP as a result of the annual land use censuses conducted in 1988 and 1989 per TS requirements. No licensee event reports (LERs) had been written in 1988 and 1989 involving REMP activities. The licensee had submitted their Annual Radiological Environmental Operating Reports for 1988 and 1989 as per TS requirements.
Within the areas inspected, no violations or deviations were identified.
The licensee had adequately addressed all previously identified inspector followup items in the area of radiological environmental monitoring.
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DETAILS l
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Persons Contacted HL&P
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- J. R. Lovell, Manager, Technical Services F
J. E. Behm, Senior QA Specialist R. L. Erickson, Supervisor, Nuclear Assurance Audits s
- E. M. Hardcastle, Senior Radiological Laboratory Technician, Radiological Services Laboratory (RSL)
- R. E. Lockwood, Senior Staff Engineer, RSL
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- D. L. Munzenmaier, Senior Radiological Laboratory Technician, RSL A. R. Passafuma, Senior Radiological Laboratory Technician, RSL i
F. F. Reed, Instrumen and Controls (I&C) Surveillance Coordinator
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- Denotes those present during the exit meeting on May 10, 1990.
2.
Organization and Management Controls (84750)
The inspector reviewed the licensee's organization, management controls, staffing, and assignment of REMP responsibilities for STP to determine agreement with commitments in Chapter 13.1 of the Final Safety Analysis Report (FSAR) and compliance with the requirements in Section 6.2 of the TS.
g The inspector verified that the organizational structure of the Technical
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Services Department and the RSL were as defined in the FSAR and TS.
Managehant control procedures and RSL position descriptions were reviewed
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for the assignment of responsibilities for the managment and implementation of the REMP.
The inspector determined that the duties and.
responsibilities of the RSL staff were adequately described in approved l
procedures. The administrative controls and REMP implementing
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responsibilities specified in the RSL procedures were being implemented.
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The procedures reviewed are listed in the Attachment to this report.
Personnel position descriptions for the RSL staff had been recently revised and submitted for management approval.
The inspector reviewed the submitted RSL staff position. descriptions and noted that they were specifically written for the duties and responsibilities assigned to the RSL staff.
The inspector reviewed the staffing of the RSL and determined that two HSL technicians had left the laboratory since the previous NRC inspection of
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L the REMP in December 1988.
One of these vacancies is to be filled in l
June 1990 by a chemistry shift supervisor recruited from the STP chemistry, L
staff.
The licensee was actively recruiting to fill the second vacancy.
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-4-These two vacancies represented a turnover rate of approximately 20 percent in the last 18 months.
No violations or deviations were identified.
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3.
Training and Qualification (84750)
The inspector reviewed the licensee's training and qualification program for RSL personnel responsible for implementing the REMP including:
education and experience, adequacy and quality of training, employee knowledge, qualification requirements, and industry accreditation to determine agreement with commitments in Chapters 13.1 and 13.2 of the FSAR and co cliance with the requirements in Section 6,4 of the TS.
The inspector reviewed the education and experience backgrounds of the present RSL staff assigned to REMP responsibilities and determined that all of the technical staff met the qualifications specified in the FSAP, TS, and American National Standards Institute /American Nuclear Society (ANSI /ANS) Standard 3.1 - 1981.
It was determined that the licensee had a qualified staff to conduct the REMP.
The RSL staff is responsible for collection, documentation, and analysis of all radiological environmental samples.
The inspector reviewed selected RSL personnel training and qualification records and verified that the RSL technicians responsible for performing REMP activities had completed the required training and were qualified to perform their assigned responsibilities. The licensee's training program for RSL staff was included in the accredited training program for STP staff.
The RSL training program was being implemented in accordance with approved STP procedures and documented in official training records.
No violations or deviations were identified.
4.
Radiological Environmental Monitoring Program (84750, 80521, 80721)
The inspector reviewed the licensee's REMP to determine agreement with commitments in Appendix 11.A.3 of the FSAR and compliance with the requirements in Sections 3/4.12.1, 3/4.12.2, 6.8.1, and 6.9.1.3 of the TS.
The inspector reviewed the licensee's procedures for implementation of the REMP.
Procedures for the administration of the REMP; sample collection, accountability, preparation, and analysis; and RSL instrumentation calibration, quality control, and operation were written with sufficient detail to ensure TS compliance.
Selected REMP sample logs, sample receipt logs, and sample data reports for 1988 and 1989 were reviewed.
The procedures reviewed are listed in the Attachment to this report.
The inspector reviewed the Annual Radiological Environmental Operating Reports for 1988 and 1989 and determined that the sampling and analysis requirements specified in the TS and ODCM had been met.
The inspector
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-5-noted that data presentation in the annual reports was in a format that directly correlated to ODCM requirements.
The licensee had added the 1988 and 1989 annual reports Table I-2, Sample Collection Schedule, data which provided sample collection dates of the va. lous environmental sample media in a format which provided direct correlation to ODCM samp' ling
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requirements. The licensee had conducted the annual land use censuses for 1988 and 1989 in accordance with TS requirements and the results of the censuses were documented in the respective Annual Radiological
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Environmental Operating Reports.
The inspector reviewed the licensee's ODCM, Revision 3, dated January 1989, and determined that it contained the required REMP information in accordance with the TS.
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s The inspector inspected selected environmental media sampling stations associated with the REMP. The following types of sampling stations were inspected: airborne, surface water, direct radiation (thermoluminescent dosimeters [TLD]), soil,andbroadleafvegetation. The required
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equipment at the selected sampling stations was in place, calibrated, and operational.
During the inspection of the various environmental sampling stations, the inspector verified that the sampling locations were as described in the ODCM and the Annual Radiological Environmental Operating Reports.
The inspector reviewed the licensee's environmental TLD program. The licensee had approved procedures for the placement, collection, preparation, and analysis of the environmental TLDs. The environmental TLDs were being exchanged quarterly.
The licensee's environmental TLD results were compared to the NRC TLD results for collocated TLD sites for 1988 and 1989 and the results were in satisfactory agreement.
No violations or deviations were identified.
5.
Facilities. Equi,pment, and Supplies (84750, 80521, 80721)
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The inspector inspected the RSL located at the EDC including the environmental sample receipt and storage area, sample preparation and laboratory areas, radiochemistry counting room, and TLD processing area.
The RSL areas were equipped with the necessary chemicals, labware, sample processing equipment, and analytical instrumentation to perform the
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l required TS analyses. The radiochemistry counting room had added a new computer system to process sample analytical data since the pre /ious NRC i
inspection conducted in December 1988. The laboratory facilities, equipment, and instrumentation were adequate to perform the rtquired REMP sampling and radiological laboratory analyses to meet TS and 00CM i
requirements.
No violations or deviations were identified.
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Quality Control of Radiological Analytical Measurements (84750, 80521, i
80721)
The inspector reviewed the RSL program for maintenance, calibration, and quality control of the environmental air samplers and radiological analytical instrumentation to determine agreement with the recommendations
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in Regulatory Guide 4.15 and compliance with the requirements in.
Sections 3/4.12.3 and 6.8.1 of the TS.
The inspector reviewed the maintenance and calibration records for the REMP air samplers. Maintenance, calibration, and quality centrol of the environmental air samplers were being performed by the RSL staff in
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accordance with an approved procedure.
The licensee's environmental air
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sampler maintenance, calibration, and quality control programs were found to be satisfactory.
The RSL radiological analytical instrument calibration and quality control procedures, radiochemistry counting room instruments' calibration data and quality control data, and other documentation of instrument performance were reviewed. The RSL radiological instrument calibration and quality control procedures were satisfactory and met TS requirements and-regulatory guidance.
The records of the calibrations and quality control measurements for the radiological counting instruments were reviewed and found to be satisfactory and documented in accordance with RSL procedures.
The RSL participates in the U.S. Environmental Protection Agency's.(EPA)
Environmental Radioactivity Laboratory Intercomparison Program as required by the TS.
The inspector reviewed the licensee's RSL performance in the
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EPA crosscheck program during 1988 and 1989 as published in the respective
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licensee's Annual Radiological Environmental Operating Reports and verified that the licensee's analytical results were normally within the EPA's acceptance criteria of three standard deviations of the known EPA values.
- No violations or deviations were identified.
7.
Meteorological Monitoring Program (84750, 80521, 80721)
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The inspector reviewed the licensee's meteorological monitoring program to determine agreement with commitments in Chapter 2.3 of the FSAR and compliance with the requirements in Section 3/4.3.3.4 of the TS, and adherence to the recommendations of Regulatory Guides 1,23 and 1.97 and
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ANSI /ANS Standard 2.5 - 1984.
The meteorological data monitoring and recording instrumentation calibration and surveillance procedures and records were reviewed for the primary 60-meter tower and the backup 10-meter tower.
It was verified that. the primary and backup meteorological towers' instrumentation was calibrated semiannually according to procedures during 1989 and met TS
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requirements.
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The inspector reviewed the licensee's monitoring system data recovery for 1989 and determined that the data recovery for the individual meteorological p remeters required by the TS exceeded the 90 percer.t recovery level.
It was noted that the licensee used a contractor meteorologist to review and edit the meteorological data. Data which was not directly available from the primary meteorological tower
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instrumentation had been restored and edited using data interpolation or l
restoring the missing data using backup meteorological tower data.
No violations or deviations were identified.
8.
Quality Assurance program (84750)
The inspector reviewed the licensee's QA surveillance and audit programs regarding REMP activities to determine agreement with commitments in
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Chapter 17 of the FSAR and compliance with the requirements in Sections 6.5.2.8 and 6.8.1 of the TS.
The inspector reviewed the surveillance and audit reports of QA activities performed during 1989 and 1990 in the areas related to the REMP. The QA surveillances and audits reviewed are listed in the Attachment to this report. The inspector reviewed the licensee's surveillance and audit plans, checklists, and findings and confirmed that the identified findings were reviewed by licensee's management and that responses and corrective actions to findings had been completed and documented in accordance with QA procedures.
The QA surveillances and audits were performed by qualified auditors who were knowledgeable in radiological environmental monitoring activities at nuclear power facilities.
The licensee's QA surveillances and audits had been performed in accordance with STp QA procedures and schedules.
The inspector verified that the REMP audits and surveillances were comprehensive and contained suf ficient depth to satisfy TS requirements.
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The RSL staff performed quarterly internal audits of the RSL activities during 1989 and 1990. The inspector reviewed the quarterly audit
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checklists and work sheets and the observation reports issued as a result l
of these internal audits for the time period January 1989 through April 1990.
It was noted that 43 observation reports had been issued l
during 1989 and 13 observation reports had been issued during the first calendar quarter of 1990. All observation reports reviewed had been closed. As a result of these observation reports and internal audits,
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many program improvements have been made, i'
No violations or deviations were identified.
9.
Exit Meeting (30703)
l The inspector met with the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on May 10, 1990. The inspector summarized the scope and findings of the inspection.
The licensee did not
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, 1 identify as proprietary any of the material provided to, or reviewed by,
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the inspector during the inspection.
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ATTACHMENT i
SOUTH TEXAS PROJECT UNITS 1 and 2
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NRC INSPECTION REPORT 50-498/90-12 and 50-499/90-12 l
l DOCUMENTS REVIEWED j
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1; Plant General Procedure (PGP)
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Number Title Revision Date
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OPGP03-ZR-0039 Radiological Environmental
01/31/90
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Monitoring Program 2.-
Plant Technical Procedure (PTP)
Number Title Revision Date
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OPTP01-ZE-0001 Management of Tt :hnical
08/04/89
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Services Labora,ory Quality Assurance Program
- OPTP01-ZE-0002.
USCEA/NIST Measurement
10/21/89
Assurance Program l
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Plant Radiation Protection Procedures (PRP)
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OPRP10-ZL-0001-Radiological Laboratory
03/26/90 i
Administrative Procedure
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'JPRP10-ZL-0002 Quality Assurance for the
03/26/90-Radiological Laboratory
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OPRP10-ZL-0003~
Hoescht Celanese Plant Access
03/29/89 i
OPRP10-ZL-0006 Sample Receipt, Accountability,
08/08/89 and Storage -
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OPRP10-ZL-0009 Radiological Laboratory Safety
04/21/89 OPRP10-ZL-0010 Preparation of Aqueous Samples
01/05/90 for Liquid Scintillation Counting l-0PRP10-ZL-0011 Gamma Analysis in Environmental
08/25/89
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OPRP10-ZL-0012 Iodine-131 Analysis in
09/02/88
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Environmental Media OPRP10-ZL-0013 Strontium 89/90 Analysis in
08/01/88 Environmental Media
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OPRP10-ZL-0015 Radiological Laboratory
11/01/C9 Preparation of Radioactive Standard Solutions and Calibration Sources
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OPRP10-ZL-0016 Alpha / Beta Analysis in
11/16/89 Environmental Media
OPRP10-ZL-0020 Preparation of-Raw Milk Samples
01/25/88 L
for Long-Term Storage
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OPRP10-ZL-0022 Quality Control of Radiologica:
06/02/88 Laboratory Equipment OPRP10-ZL-0023 Radiological Laboratory EPA
08/26/88 Cross-Check Program OPRP10-ZL-0024 Standardization of Carriers and
09/29/88 Standard Chemical Solutions OPRP10-ZL-0025 Radiological Laboratory Chemical
06/28/88 and Reagent Control
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OPRP10-ZO-0002 Operation and Standardization of
10/20/88-the Tennelec Counter System.
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OPRP10-ZO-0003 Operation and Standardization of
09/30/89 the ND66 MCA Counting System
OPRP10-20-0004-Operation and Standardization of
01/05/90 the Liquid Scintillation Systems
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i OPRP10-Z0-0005 Operation and StanderJization of
09/25/89
!L the Radiological Laboratory Beta-Gamma Coincidence System L
OPRP10-ZO-0006 Operation of the Radiological
12/15/89 Laboratory Data Analysis System L
l0PRP10-ZQ-0001 Documentation and Testing of
12/26/89 l
Radiological Laboratory Computer Programs l'
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I OPRP10-ZU-0005 Environmental Sample Collection
01/10/90 of Airborne Particulate and Radioiodine OPRP10-ZU-0007 Environmental TLD Monitoring
03/17/89 OPRP10-ZU-0009 Surface and Ground Water Sample
11/13/89 Collection-9PRP10-ZU-0010 Sample Collection of Soil /
12/15/89
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Sediment and Vegetation OPRP10-ZU-0015 Donation / Purchase of Meat.
02/15/88 Poultry, Eggs, Milk, and Fish 4.
Plant Maintenance Procedure (PMP)
N_ umber Title Revision Date OPMP08-EM-0001 Primary Meteorological Calibration 5 04/10/90 (60-MeterTower)
OPMP08-EM-0002 Backup Meteorological Calibration 3 04/10/90 (10-MeterTower)
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Plant Surveillance Procedures (PSP)
Number Title Revision Date OPSP05-EM-0001 Primary Meteorological System
11/22/89 Calibration (60-MeterTower)
0 PSP 05-EM-0002 Backup Meteorolopical System
11/22/89 Calibration (10 Meter Tower)
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Quality Assurance (QA) Audits and Surveillances
> QA Audit 88-57(G), " Radiological Environmental Monitoring Program," conducted November 14-22, 1988 QA-Audit 89-62(G), " Radiological Environmental Monitoring Program," conducted
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November 14-22, 1989 l
t QA Audit 88-02(M), " Chemistry / Radiochemistry Offsite Dose Calculation Manual,
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Radiological Effluent and Environmental Monitoring," conduc ed l
l January 18-29, 1988
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QA Audit 89-07(M2), "Offsite Calculation Manual / Radiological Effluents /
Environmental Monitoring," conducted February 27 through March 10, 1989 QA Surveillance Report (QASR)89-066, "REMP Biological Sampling," performed March 7 and Ap."11 5, 1989
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l QSAR 89-168, "Environmeltal Air Sampling," performed June 13, 1989
' QSAR 89-188,." Technical Specification Surveillance' Test Conduct T.S. 4.3.3.4 - OPSP05," performed July 7-12, 1989 i.
QASR 89-256, "REMP Biolcgical Sampling: Soil Core Sample," performed
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October 11, 1989 QASR 89-257, " Environmental Sampling of Surface and Ground Water:
Composite Sampling,From 1500 Continuous Water Sampler," performed October 11, 1989.
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OASR 90-003, " Environmental' Air Sampling," performed January 17, 1990 I
QASR-90-004, " Environmental Sampling of Surf ace Water," performed January 17,
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QASR 90-023, "REMP - Biological Sample Analysis," performed February 22 and 26,
1990 QASR 90-025, " Radiological Environmental Monitoring Land Use Survey - T.S. 3/4.12.2," performed February 22, 1990 g
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