IR 05000498/1990035

Insp Repts 50-498/90-35 & 50-499/90-35 on 901029-1102.No Violations or Deviations Noted.Major Areas Inspected: Radiation Protection Activities Associated W/Recent Refueling Outage of Unit 2

ML20058K414
Person / Time
Site:	South Texas
Issue date:	12/09/1990
From:	Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058K407	List: IR 05000498/1990035 ML20058K404
References
50-498-90-35, 50-499-90-35, NUDOCS 9012170221
Download: ML20058K414 (7)

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s APPENDIX  ;

U.S. NUCLEAR REGULATORY COMMISSION REGION I j

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l NRC Inspection Report: 50-498/90-35 Operating Licenses: NPF-76 ,

50-499/90-35 NPF-80-Dockets: 50-498 50-499 -!

Licensee: Houston Lighting & Power Company (HL&P) ,

P.O. Box 1700 l Houston, Texas 77251-

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Facility Name: South Texas Project Electric Generating Station (STPEGS)

Inspection At: STPEGS Site, Bay City, Matagorda County, Texas'

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Inspection Conducted: -October 29 through' November 2, 1990 Inspector: '

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L. Ric ~ on, .E., Senior Radiation 'Dat '

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Spec (i_a. is , Rad (iological Protection and .

I Emergency Preparedness Section'- - ,

l Approved: ) 8L 0 laine Murray,' Chief, R OdilD/ M /d l ological Protection Date/~

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l and Emergency Prepar es's Section- j Inspection Summary 1 Inspection Conducted October 26 through November 2,- 1990 (Report '50-498/90-35; 50-499/90-35)

l Areas Inspected:- Routine, unannounced inspection of the licensee's radiation protection activities associated with the recent refueling outage of Unit Results: Within'the areas inspected, no violations or deviations wer identified. The licensee adequately supplemented its health physics (HP) staff with qualified contract personnel. Planning and coordinating.of activities

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E associated with the Unit-2 refueling outage and HP support appeared to be accomplished in an efficient manner. Exposure controls were well' implemented-  !

and controls over radioactive materials and-contamination;had been improve !

The licensee continued to devote resources to strengthening the program of .

maintaining radiation exposures as low as reasonably achievable (ALARA). l Preparation and shipment of radioactive waste appeared to be conducted according to requirement pOk D o _ ,

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! Persons Contacted HL&P

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• H. Kinsey, Vice President, Nuclear Generation

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• C A. Ayala, Senior Supervising Engineer, Licensing ,

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• H. W. Bergendahl, HP Manager ,

J. P. Bleau, HP General Supervisor, Unit 1 . ,

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• M. K. Chakravorty, Nuclear Safety Review Board (NSRB) Executive Directo *D. J. Denver, Manager, Plant Engineering .

• A. K. Khosla', Senior Engineer, Licensing- ':

R. V. Logan, Supervisor, ALARA

• J. R. Lovell, Manager, Technical Services-R. W. Pell, General-Supervisor,'HP Technical' Support J. E. Simms, HP Supervisor, Transportation T. W. Tesmer, Supervisor, Outage Planning ,

S. Torrey, HP Training Coordinator i

• R. Wisenburg, Plant Manager

• D. Wood, HP General Supervisor, Unit 2

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• J. Evans, Resident Inspector -

• Denotes those present at the-exit meeting on November'2, 199 The inspector also interviewed other plant personnel during the course of the inspectio . Action on Previous Inspection-Findings (92701)

-(Closed) Open Item (498/8931-01; 499/8931-01).- This item was'last y discussed in NRC' Inspection Report 50-498/89-31;40-499/89-31 and involved-  !

the lack of staffing in the ALARA group, lack of documentation in ALARA/ radiation work' permit'(RWP) review packages',-and' revision and-consolidation of ALARA policy statements and implementing procedure ,

Staffing for the ALARA group was. increased to faur with an additional: ,

contract technician providing support during the refueling outag i L

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Licensee representatives, stated that management had recently given }

approval for an additional engineering position .for-the grou The inspector reviewed'ALARA/RWP files and noted increased information-added during the ALARA review process. ' For jobs performed in the radiological restricted. area (RRA), projected to result 'in a collective  ;

dose greater than 1 person-rem, the packages included: the RWP requests -

and person-hour estimates; radiation survey information; detailed guidelines for the work to be' performed, with suggestions on temporary ,

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contamination controls, posting requirements,' dosimetry requirements, HP coverage requirements, and training requirements; ALARA review and; job l history; and examples of industry events involving similar wor )j The licensee has revised and consolidated policy statements and procedures .

having to do with ALARA. The following documents were effected:-

j NGP-705, "ALARA Program,": Revision' 1. (July' 27,- 1990). j

IP 2.03Q, " Radiation Protection and.ALARA Programs,": Revision-1; (September 21,1990) ,

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L OPGP03-ZR-35, "ALARA Suggestion Program," Revision 1.(September 1,-~

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OPGP03-ZR-0008, " Operational ALARA' Program,"' Revision 3 ( August 3, ,

1989)  ;

OPGP03-ZR-0028, "STPEGS ALARA Review Committee," Revision-3 (August 3, 1989): i

OPGP03-ZR-0033, "ALARA Engineering and Procedure Review," Revision;3 ;

(August 3, 1989)

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ll OPRP07-ZA-0001, " Performance of High Exposure Work,". Revision'1

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i (June 1, 1990) i OPRP07-ZD-0002, "RWP Program ALARA Reviews," Revision 0.(March 30',;

1990) i OPRP07-ZD-0001, " Health Physics Temporary Shielding Program,"'

Revision 0 (March 30, 1990)_ l

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OPRP07-ZT-0001, " Health Physics - Performance Trending," ~ Revision 3 (Proposed approval date November 9, 1990)

The inspector noted additional efforts by the. licensee to: increase the- ,

effectiveness of the ALARA program. 'Among these:were programs'to trend low radiation dose areas and ultrafiltration of the reactor coolant system (with chemistry as the lead group). Through computerized dose tracking, the licensee was able to review exposures. associated with each RWP; daily, and to compare the results with the prejob estimates per. formed by.the i ALARA group to determine whether additional precautions or changes in ,

instructions to workers needed to be mad The licensee's actions were sufficient to' address the NRC's concerns in-  !

this area. Additional elements of the ALARA program are discussed in-paragraph t

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-4- Organization and Management Controls (83750)

The inspector reviewed the. licensee's organization and management. controls to determine compliance with' Technical Specification (TS) 6.2, commitments ;

in Chapter 13.of the Updated Final- Safety Analysis Report-(UFSAR),: and -

agreement with Regulatory Guide-(RG)-1,3

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Functionally, the licensee's organization remained the same'as:during-the {

previous inspection, although there had been-personnel reassignments,- 'An !

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additional engineering position had just been approved:forithe ALARA - ;

group, as discussed in paragraph For added support for the Unit-2 outage, the 1_icensee' employed , 4 approximately 53 contract senior HP technicians, 22 contract junior'HP!

technicians, and increased the. number of contract decontamination _ workers to approximately 6 The inspector reviewed copies of radiological occurrence reports;and-radiological controls ' deficiency reports and noted 'an example of 'an ,

. individual apparently deliberately disregarding the: instructions o_f both j the RWP under which entry into the RRA was made and an HP providing .1 coverage. The individual entered a high contamination area. which was not _ 4 permitted by the RWP, and in direct conflict with the instruction of the- ;

H The individual was: sighted by HP personnel, via television camera, climbing up a steam ' generator platform and was notified by' radioi speaker -

to leave the area. The individual was then escorted from the:RRA~and '

access-pr_ivileges were-revoked. The-inspector: determined;that this was an

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isolated case and it appeared that HP's control worked adequately to cope with the situatio No violations or deviations were identified.- Training and Qualifications (83750)

The inspector reviewed selected' resumes of contract HP technicians and-determined that they met the commitments in Chapter 12 of, the UFSA No violations or deviations were identifie . Outage Activities (83750) 'k The inspector reviewed the licensee's~ activities duringithe Unit- refueling outage to determine' compliance with TSs 6;11'and 6.12; the requirements of 10 CFR Parts 19.12, 20.101,:20.102,;20.103,:20.105, 20,201, 20.202, 20.207, 20.301,.20.401, 71, and 49hCFR: Parts;171-through 178; the commitments of Chapter 12 of the UFSAR and the recommendations of RG 1.8,.8.8, 8.10, 8.15, NUREG-0041,' Industry Standards-ANSI Z88.2-1980, ANSI /GCA G-7.1-1989'and ANSI'N323-197 The inspector attended meetings of the work control organization and noted that there was a free exchange of.information among departments'regarding

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l the schedules for various work'1tems'and any_ associated problems.; The _ _ _ 'l meetings were conducted in an orderly fashion'and'a11Ldepartments appeared: i to be represented. HP was. represented by a member of the ALARA group an_d'

the Unit 2 HP general superviso "

The inspector attended prejob meetings conducted by HP,.

Participants i particular work evolutions were briefed'on the_ radiological. conditions'_in j

the areas in which they were to work. .. Instructions also= included al1~

requirements listed on their respectiveLRWPs and industry events involving !

similar work. Briefings were thorough;'however, repeated entrances 11ntol ' !

the briefing room (which also served as La break room) by. uninvolved 1 personnel were distractin h Certain RWPs required that(individuals attend'the prejob meeting 4n receive special instruction; however,-the inspector noted that(there were' ,

no means of ensuring that individuals actually received.-the required > '

briefing The inspector compared the. lists of meeting attendees with, lists of personnel assigned to the respective-RWPs, but did notJidentify:

specific problems. Licensee representatives acknowledged'the lack;ofc .;

positive control and initiated a change in: procedure, which required _the '

confirmation of attendance. of a prejob: meeting, prior to'the addition o an individual onto the computerized access-list for'that specific.RW j Licensee representatives also discussed, as a long-term. solution,. changes 1 i to the computer program at access control which.would prevent entry o personnel not meeting the RWP criteri ~ .

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The inspector attended a meeting concerning the use of a strippable; coating on the reactor cavity walls. The coating-is' intended asia 4'

person-rem reduction item by reducing both' decontamination = time.a'nd'sourcez term. The first leyer of coating was applied before the cavity was; flooded and a second coating will be applied to seal:in; contaminants. The entire coating will be removed prior _to resumption of operations and dispesed as waste. The inspector-reviewed portions of an1 engineering safety evaluation of the process' performed' prior to its use.. The

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inspector noted that charcoal filter' systems in the. heating.cVentilation, and air conditioning r>ystems were' tagged out of. service, by procedure, during the application of the coating, thus preventing _ vapors from being l drawn through the filters and damaging the The inspector deteimined that, in an effort to keep radiation ex'posure low the licensee had conducted mockup training for several jobs including steam generator nozzle dam installati0n, steam generator shotlpeening, _and reactor coolant pump work. HP restric'.ed access to certain areas during a crud burst proceeding the outage and used lead-blankets extensively as temporary shielding of hot spots. The inspector also noted the extensive use of television cameras for contro11' ng various ' areas and job g Monitors were located at the RRA access control and HP control point '

The inspector reviewed the access con' rol point of the RRA and noted that it was more open, with fewer solid wa 1s, than the. control point in:

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Unit 1, which made it easier for HP technicians-to observe workers as they i exited the RRA and performed contamination- check '

The inspector verified that portable radiction survey instruments and i portable air samplers were'available.- The inspector.noted that.a tool '

monitor had been installed in the exit area of the RRA :Such monitors

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were not available during the last outage for: Unit l'. The-inspector also

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t noted that the unit frequently was not functioning properly. Hand-hel frisking units were also at the exit of. theLRRA and: personnel were required to frisk their ankles and tops of'the their, shoes, in the event

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contamination might'have been present in an areaLsbielded from the:

beta-sensitive detectors of the_ personnel contamination' monitor The inspector reviewed the respiratory. protection equipment issue process and storage' area and confirmed that individuals working:there were familiar with the licensee's procedures. -Additionally, the~ inspector-reviewed the qualifications of selected = individuals:and confirmed that they were qualified to. receive the respira_ tory protection equipment issued:

to them. By use of a computer terminal, controlitechnicians could check

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to ensure that, within the preceding year, worker.C had received respiratory protection training, fit tests, and medical, evaluations.1 The inspector noted some inconsistency in. the form in which the'information -

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was presented, in that the-dates of completion of two of the items were listed along with the due da;.e for the thir The inspector observed HP's'cov9 rage of jobs-in the reactor. containment l building, including.the liftir.g of the upper internals and 0-ring removal,_ ,

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and work on the incore dete:. tor drive mechanism The tasks required prejob instructions by Hr as:well as continuous coverage. 'HP technicians appeared to perform their duties wel l The licensee took additional precautions to-lower the number of personnel contaminations during the outage. Precautions included theluse of shoe covers by all individuals within containment evenLin areas with contamination levels below 1000 disintegrations per minute, increased use of plastic sheets covering.potentially contaminated areas'and~ components,.

increased distances between. walkways and controlled areas. 'The licensee's goal was to limit the number of personnel contamination occurrences to 100. As of November 1, 1990, the' licensee had recorded 25. personnel contaminations, with only 5 resulting in skinLexposures calculated as being greater than 10 millire The collective exposure goal for the outage was 125 person-rem. As o November 1,1990, the -licensee had accrued 82 person-re The inspector reviewed posting and performed confirmatory measurements, but did not identify problem areas._ Licensee representatives related to  ;

the inspector the details of a recent occurrence involving an area which was anticipated would be a~ locked.high radiation area during the course of the outage. TS 6.12.2 requires that enclosed areas in which radiation 3

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levels exceed 1000 mR/h at 18 inches from the source or accessible. surface 4

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ll be controlled by a locked door. Radiation levels-in Room 307, housing?the, -!

regenerative heat exchanger, were expected to rise above the threshold l value and the room'was being controlled as a locked high radiation areac s l On the morning of October 24, 1990, an HP technician discovered thatLthe l door to Room 307 was not completely closed and, therefore, not=. locke The licensee's-investigation: revealed that a . key to the room.had be.en' {

checked out by a HP technician who supported work in the area on the; '

evening of October 23 and the morning of October 24, 1990. When questioned'about the occurrence, the HP technician acknowledged that he

- could not remember challenging the lock af ter leav.ing the areacthe.'second time. The licensee'si subsequent = investigation of the matternincluded the performance of radiation. surveys of the room, which: revealed that'

radiation levels within the room had not-yet exceeded the limit of!

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1000 mR/h at 18' inches. Therefore, the TS' had not been violate ~

l However, the licensee initiated a procedure change to require l1.ndependent; *

verification of all locked high radiation doors.. The item was'alsofto be-

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included in the next session of HP technician continuing-training.i i%

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In. preparation for transfer' of spent fuel,: the licensee had-placed-la larg~e

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concrete shielding block in line with-the sludge lancing-por.ts, outside; l the reactor and fuel handling buildings to negate any' radiation streaming, j Increased shielding was piaced in the seismic gap;between the'two" i buildings and-a wire cage-was erected.to preventLaccess toothe area'near= l the sludge. lancing ports. . Licensee representatives: stated'that they would !

physically check and secure the' areas along the" spent fuel! transfer _ path R as they did during-the Unit 1 outage, to prevent' personnel exposur The inspector observed the preparation _of a shipment of dry: activated  !

waste, including labeling, surveying, and securing of.the container. 'Th l

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inspector reviewed documents associated with the' shipment',Eincluding<the' i licensee checklist for preparing-. shipments, manifest for~ the' shipment,  !

computer generated waste classification and analysis,l shipping; papers,.

driver instructions, and license of the consigne * ~

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No violations or deviations were identifie . Exit Meeting '

l The inspector met with the resident inspector and the'11censee's . =l representatives denoted in paragraph I at.the conclusionfof,th Rinspection i on November 2, 1990, and summarized the' scope-and findings 4f the inspection as presented in this report. The licensee did notoidentify as  !

proprietary any of the materials provided to, or reviewed by, the  !

inspector during the inspection, a

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