IR 05000498/1993018

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Insp Repts 50-498/93-18 & 50-499/93-18 on 930517-21.No Violations Noted.Major Areas Inspected:Radiation Protection Program Activities Re Unit 1 Maint Outage & Unit 2 Refueling Outage
ML20045A658
Person / Time
Site: South Texas  
Issue date: 06/08/1993
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20045A655 List:
References
50-498-93-18, 50-499-93-18, NUDOCS 9306110168
Download: ML20045A658 (9)


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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Inspection Report:

50-498/93-18 50-499/93-18 Operating Licenses: NPF-76 NPF-80 Licensee: Houston Lighting and Power Company P.O. Box 1770 Houston, Texas 77251 Facility Name:

South Texas Project Electric Generating Station Inspection At:

Matagorda County, Texas Inspection Conducted: May 17-21, 1993 Inspectors:

L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section W. Holley, C.H.P., Senior Radiation Specialist Facilities Inspection Programs Section Approved:

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B. Kurray, Chief, Facil,ttdes inspection Dater

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Programs Section

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Inspection Summary Areas Inspected (Units 1 and H : Routine, announced inspection of radiation protection program activities related to the Unit 1 maintenance outage and the Unit 2 Refueling Outage (2RE03), including program changes, planning and preparation, external exposure controls, internal exposure controls, controlr, of radioactive materials and contamination, and the program for maintaining occupational exposures as low as reasonably achievable (ALARA).

Results (Units 1 and 2):

Minor changes were made in the radiation protection organization in an

effort to increase the effectiveness of the ALARA group.

State-of-the-art equipment was added to reduce radiation exposures,

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increase the efficiency of the radiation work permit program, and increase the amount of information depicted by radiation surveys.

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{DR ADOCK 05000498 PDR

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-2-Contract radiation protection technicians were hired to sufficiently

supplement the permanent radiation protection staff. Adequate supplies and equipment were available to handle outage activities.

Contract radiation protection technicians were rigorously screened and

met qualification requirements.

Specialized training was given to selected radiation workers to reduce exposures and contamination events.

Excellent external radiation exposure controls were maintained.

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Radiation work permits provided appropriate guidance.

The content of pre-job briefings and jo'o coverage provided by radiation protection personnel were excellent.

Considerable effort was expended to familiarize radiation workers with good health physics practices.

All the elements of a superior internal exposure control program were

implemented, and the program has been very effective.

New procedures had been established that addressed the maintenance program for self-contained breathing apparatuses.

Excellent performance was achieved concerning the controls of

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radioactive materials and contamination.

A low number of personnel contaminations had occurred.

Radiological housekeeping within the

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radiological controlled area was good.

Total radiation exposures for the last refueling outage and for 1992.

  • exceeded the licensee's goals; however, this was the result of the outage duration being extended.

It appeared that the same may be true for Refueling Outage 2RE03, but the licensee's total exposures will likely be below the national average for pressurized water reactors.

i Management's commitment to maintaining radiation exposures ALARA was

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strong.

Attachment:

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Attachment - Persons Contacted and Exit Meeting

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.1 DETAILS i

i 1 PLANT STATUS Unit I was in a forced outage which began in January. Unit 2 was in Refueling Outage 2RE03, 2 OCCUPATIONAL EXPOSURE DURING EXTENDED OUTAGES (83729, 83750)

The licensee's program was inspected to determine compliance with Technical Specifications 6.4, 6.8, 6.11, and 6.12 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapters 12 and 13 of the Final

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Updated Safety Analysis Report.

2.1 Changes New equipment obtained by the licensee included a digitized survey system.

The system was used for producing computerized, color photographs used with survey maps.

Radiation and contamination levels were added as information directly on the photographs. The result was an improved method of familiarizing the workers with the areas and hazards in which they would be

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working.

Video cameras inside the bioshields were added to the units to enable the licensee to perform visual inspections at power.

The radiological occurrence reporting program was changed to include cause codes for trending and analysis.

j ALARA personnel had access to the newly installed computer local area network.

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This made the review of documents such as radiation work permits by supervisory personnel easier and more efficient.

The ALARA group was restructured so that one radiation protection supervisor was responsible for the production of radiation work permits and another for coordination with the work control organization.

Formerly, the supervisors had both responsibilities, except that they were divided between the two units.

The licensee felt that the division based along the lines of function rather than unit would be more efficient and allow each supervisor's group to be more focused. The inspectors identified no problems associated with the redistribution of assignments.

2.2 Planning and Preparation

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The licensee supplemented the permanent radiation protection staff with approximately 45 contract radiation protection and 40 decontamination technicians.

The inspectors determined, through observation and interview with technicians, that the licensee had prepared properly with ample supplies of temporary shielding, radiation detection instrumentation, air monitoring equipment, portable ventilation, and protective clothing.

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-4-A preoutage shielding plan was developed which identified locations where temporary shielding was needed and subsequently placed, j

2.3 Training and Qualifications The licensee's procedure for evaluating, screening, and training contract radiation protection technicians remains unchanged from that described in NRC

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Inspection 50-498/92-31; 50-499/92-31. Once again, a large portion of the

contract radiation protection technicians had worked previously at the I

licensee's facility.

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The inspectors reviewed resumes of selected contract radiation protection

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technicians and determined that they met qualification requirements.

The licensee conducted advanced radiation worker training for-personnel who routinely work within the radiological controlled area. The training was a

combination of classroom lectures and practical exercises.

Lessons learned

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were discussed and simulated repair work was performed with the aid of mock-ups with the goal being the reduction of personnel radiation exposures and contaminations.

2.4 External Exposure Control

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The licensee had received accreditation as an approved processor from the National Voluntary Laboratory Accreditation Program for seven test categories (as defined in ANSI N13.11).

The licensee was accredited in all categories except Category I (accident, low energy photons).

J The inspectors vecified that individuals entering the radiological' controlled area wore appropricte personnel monitoring.

Additionally, all workers wore

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electronic, alarming dosimeters.

Radiation protection stationed a technician q

at the entrance of the radiological controlled area to ensure that radiation workers had the proper dosimetry and did not enter with consumable items.

The inspectors attended pre-job briefings and noted that radiation protection supervisors provided excellent instructions regarding radiation safety. The inspectors noted also that the licensee had implemented the practice of using a briefing checklist to ensure that the briefings were consistent (if multiple briefings were necessary) and comprehensive.

The inspectors reviewed selected examples of radiation work permits for the

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higher dose jobs and determined that they provided appropriate guidance. The inspectors determined that the licensee incorporated radiation safety-

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instructions into work packages.

Licensee representatives stated that_the

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inclusion of the instructions into the work packages provided workers with i

advanced information and resulted in the workers becoming accustomed to good

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health physics practices as they reviewed the procedures and prepared for the l

work.

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The licensee had devoted considerable effort to the streamlining of the ALARA packages for outage work with the intent being to make them more user j

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The result was a package which was concise but included the pertinent information for planning the work so as to accrue minimum exposure.

The inspectors observed work in progress, such as repairs to the burnable poison rod assembly tool (Radiation Work Permit 93-2-687), replacement of the waste holdup tank filter (Radiation Work Permit 93-1-692), and transfer of a high integrity container of spent resins in preparation for disposal (Radiation Work Permit 93-1-151).

On all jobs, the radiation protection personnel maintained control of the areas, posted areas correctly, conducted surveys properly, and ensured that the work proceeded in a. manner which maintained low exposure.

The inspectors made several tours of the radiological controlled areas in both units and reviewed area postings and determined that they were appropriate.

Locked high radiation areas were properly controlled.

The licensee used video cameras extensively during the outage.

Representatives stated that 15 cameras were used in Unit 2 to maintain surveillance of work areas while avoiding additional exposure.

2.5 Internal Exposure Control During observation of work activities, the inspectors confirmed that areas were appropriately sampled to detect airborne radioactive contamination.

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inspectors noted that both lapel and portable air samplers were used to determine breathing zone radioactivity concentrations.

Engineering controls such as portable ventilation units with high efficiency particulate. filters were used. extensively to limit concentrations of airborne radioactive

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materials.

The inspectors reviewed respirator issue records and randomly verified the qualifications of users.

The inspectors also confirmed that workers were issued equipment of the correct type and size.

Respirator use was light.

Sufficient supplies of respirators were available. Maximum permissible concentration-hours were tracked.

All values were less than regulatory limits.

Through records review, the inspectors confirmed that air supplied by the-licensee's tank filling station and breathing air compressor had been tested

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at the proper intervals and met Grade D breathing air specifications (as defined in ANSI /CGA G-7.1).

Regulators for all self-contained breathing apparatuses were overhauled in July 1992, and a program had been established

to flow test them annually.

The program was implemented by Station Procedure OPGP03-ZR-0021, " Respiratory Protection Program," Revisien 6, and Department Procedure OPRP06-ZR-0005, ' Maintenance, Inspection, and Y,orage of

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Respiratory Protection Equipment," Revision 0.

The lack of a proceduralized program was discussed in NRC Inspection Report 50-598/92-12; 50-499/92-12.

The licensee developed a program for the testing of ventilation units and vacuum cleaners using high ef ficiency particulate filters.

The implementation of the program will be reviewed during a future inspectio *

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e-6-The licensee maintained two whole-body counting units available for use.

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examples had been identified of individuals exceeding investigational limits of internal radioactive contamination; however, the inspectors discussed with licensee personnel one instance in which detectable amounts of radioactive contamination were identified as the result of ingestion.

Subsequent whole-body counts showed that the material had cleared from the individual's body. The licensee's dose calculations confirmed that the resulting radiation.

dose was insignificant.

2.6 Controls of Radioactive Materials and Contamination. Surveys, and Monitorina The licensee had identified 12 personnel skin contaminations directly related to Refueling Outage 2RE03 as of May 20, 1993.

Personnel contaminations per 1000 radiological controlled area entries have declined steadily since the first refueling outage.

Radiological housekeeping within the radiological controlled area, including containment, was good. Much of containment in both units could be entered without protective clothing.

Shoe covers were used as a supplemental measure to control the low levels of contamination.

The licensee laundered protective clothing on site.

A laundry monitor was used to check all laundry prior to its being restocked.

Personnel operating the laundry monitor were observed to wear proper protective clothing.

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Workers leaving the radiological controlled area frisked hard hats, hand-carried items, and certain areas of the body such as the ankles and tops of the feet, then passed through beta sensitive personnel contamination monitors.

Radiation protection technicians were available to assist in the

frisking of hand-carried items. Tool monitors in both units were functioning

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at the time of the inspection.

Items moved from the radiological controlled area were surveyed properly before release.

The inspectors observed personnel leaving the radiological controlled area and noted that they followed proper procedures. The inspectors also observed radiation protection personnel's handling of potentially contaminated individuals and noted that this, too, was conducted properly.

The inspectors observed radiation instrumentation in use and verified that the instrumentation was appropriate for the task, was within the specified calibration interval, and had been properly response tested before use.

While observing jobs conducted in the radiological controlled area, the inspectors determined that radiation protection technicians conducted radiation level and contamination surveys properly.

The inspectors reviewed selected survey records and determined that the records contained the required information. The inspectors also performed confirmatory measurements and did not identify discrepancies.

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2.7 Maintainina Occupational Exposures ALARA Refueling Outage IRE 04, discussed in NRC Inspection Report 50-498/92-31; 30-499/92-31 resulted in a total exposure of 135.1 person-rem.

The. original goal was 95 person-rem; however, the outage extended 41 days beyond the planned duration for a total of 103 days, and the scope of the work was

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increased. Total exposure for the site in 1992 was 146.784 person-rem. The site goal for 1992 was 135 person-rem.

Unit 2 did not have a refueling outage.

The highest single radiation exposure received was 1.073 rems.

As of May 17, 1993, the licensee had accrued a total dose of 116 person-rem.

The goal for the outage was 142 person-rem.

The site goal was 162 person-rem.

As during Refueling Outage IRE 04, some stages of the present outage extended longer than projected, and licensee representatives predicted that the goal would be exceeded.

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The licensee supplemented the ALARA staff with four additional staff members during the preparation for Refueling Outage 2RE03. The staff members were replaced with contract ALARA technicians when the outage began.

ALARA personnel checked the status of cumulative exposures resulting from each job on a daily basis to ensure that work proceeded as planned from radiation protection perspective. An administrative dose limit of I rem was implemented for radiation workers. The radiation protection manager received a listing daily of individuals with radiation exposure greater than 500 millirems.

The radiation protection manager, in turn, contacted the supervisor of any person added to the list to draw attention to the individual's radiation dose status.

ALARA staff members demonstrated that they had begun to establish subdirectories and files on various jobs with the aid of the computer system.

Retrieval ease of information was greatly enhanced.

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The licensee continued its refinement of a mechanism to provide radiological information on plant systems.

Radiation protection technicians supplied information on various systems, acquired during surveys or job coverage. The information was collected and used by the ALARA staff to update the system's radiological information files for future use.

The licensee initiated a program for tracking hot spots in the plant.

The program was similar to its program for tracking leaks and drip bags.

Additionally, identification /information tags were affixed to the hot spots.

Work continued on the source term reduction program.

Identification of valves containing cobalt was complete. A mechanism was in place' which would ensure that the valves or valve components would be considered for replacement with noncobalt material when maintenance work was performed. The master parts list used for procurement was amended to include notes requesting material with low cobalt content.

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i-8-2.8 Conclusions The licensee made minor changes to its organization in an effort to increase the effectiveness of the ALARA group.

State-of-the-art equipment was added to reduce radiation exposures, increase the efficiency of the radiation work permit generating process, and increase the amount of information depicted by radiation surveys.

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The licensee sufficiently supplemented the permanent radiation protection staff and stocked supplies and equipment to prepare properly for the refueling outage.

Contract radiation protection technicians were rigorously screened and met qualificatio..equirements. Additional, specialized training was given to selected radiation workers to reduce exposures and contamination events.

Excellent external radiation exposure controls were maintained.

Radiation work permits provided appropriate guidance.

The content of pre-job briefings-and the job coverage by radiation protection personnel were excellent.

Considerable effort was taken to familiarize radiation workers with good health physics practices.

All the elements of a superior internal exposure control program were implemented, and the program has been very effective. The licensee

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proceduralized a maintenance program it had lacked for self-contained breathing apparatuses.

Excellent performance was achieved by controls of radioactive materials and contamination. A low number of personnel contaminations had occurred.

Radiological hs :sekeeping within the radiological controlled area was good.

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Total radiation exposures for the last refueling outage and for 1992 exceeded-the licensee's goals; however, this was the result of the outage duration being extended.

It appeared that the same may be true for Refueling Outage 2RE03, but the licensee's total exposures will likely be below the national average for pressurized water reactors.

Management's commitment to maintaining radiation exposures ALARA was strong.

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ATTACHMENT 1 PERSONS CONTACTED 1.1 Licensee Personnel R. A. Aguilera, Supervisor, Health Physics

  • H. W. Bergendahl, Manager, Technical Services
  • J. Groth, Vice President Nuclear Generation
  • S. M. Head, Deputy General Manager, Licensing J. M. Inman, Supervisor, Health Physics
  • T. J. Jordan, General Manager, Nuclear Engineering
  • W. H. Kinsey, Vice President, Plant Support R. V. Logan, General Supervisor, ALARA/ Work Control
  • G. L. Parkey, Plant Manager
  • P. E. Parrish, Senior Specialist, Nuclear Licensing
  • R. W. Pell, Manager, Health Physics G. T. Powell, General Supervisor, Health Physics Operations Support T. R. Tessmer, Radiation Protection Specialist B. L. Whitmer, General Supervisor, Health Physics Operations 1.2 NRC Personnel
  • R. J. Evans, Resident Inspector
  • Denotes personnel that attended the exit meeting.

In addition to the personnel listed, the inspectors contacted other personnel during this inspection period.

2 EXIT MEETING An exit meeting was conducted on May 21, 1993. During this meeting, the inspectors reviewed the scope and findings of the report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspectors.