IR 05000498/1997022

Insp Repts 50-498/97-22 & 50-499/97-22 on 970825-28.No Violations Noted.Major Areas Inspected:Plant Support Program to Maintain Occupational Exposures as Low as Reasonably & Quality Oversight of Radiation Protection Program

ML20216J266
Person / Time
Site:	South Texas
Issue date:	09/10/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20216J260	List: IR 05000498/1997022 ML20216J257
References
50-498-97-22, 50-499-97-22, NUDOCS 9709170213
Download: ML20216J266 (9)

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U.S. NUCLEAR RECULATORY COMMISSION: .

REGION IV  :

Docket Nos.: -50 498- -

50 499 License Nos.:. NPF 76

- NPF 80 Report No.: 50-498/97-22 50-499/97 22 Licensee: Houston Lighting & Power Company Facility: : South Texas Project Electric Generating Station, Units 1 and Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas '

Dstes: August 25 28,1997-

. Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety -

ATTACHMENT: . Supplemental Information

9709170213 970910

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G -- ADOCK 05000498 PDR- g

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2-EXECUTIVE SUMMARY South Texas Project E:ectric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/97 22;50-499/97-22 This announced, routine inspection reviewed the program to maintain occupational exposures as low as is reasonably achievable (ALARA), training and qualifications of members of the radiation protection organization, and quality oversight of the radiation protection progra Plant Sprnari

• The ALARA program produced excellent results. The licensee's 3-year collective radiation exposure for 19941996 was well below the national average (Section R1.1).

• The method of perpetuating ALARA lessons learned needed improvement (Section R1.1).

• Appropriate continuing training was provided to the radiation protection technicians (Section RS).

• A highly qualified radiation protection staff was maintained (Section RS).

• Management oversight of radiation protection activities was good. Appropriate corrective actions were implemented to address assessment findings (Section R7).

• Generally, radiation protection personnel used the condition reporting system properly. However, in some examples, the problems identified in condition reports were not stated clearly, or the corrective actions did not address the apparent causes of the problems (Section R7).

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- Reoort Details

. IV. Plant SMDD9olt R1 Radiological Protection and Chemistry Controls-R ALARA . insoection Scoce (83750) The inspector interviewed ALARA staff members and reviewed the following:

• - Person rem totals o' - Annual ALARA reports

• ALARA committee activities

-* ALARA initiatives - '

= ' Source term reouction programs-

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• - Hot spot tracking and removal results

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• ALARA post-job reviews-

• ALARA suggestions and lessons learned Observations and Findinos

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The licenseo maintained a low source term. Previous ALARA initiatives, such as sub-micron filtration of the reactor coolant system and stellite removal, continued.

New ALARA initiatives, such as upgraded robotics, expanded self monitoring, and

._ vacuum filling of the reactor coolant system were implemented. Hot spots were

> tracked and flushed. Cleanliness requirements were incorporated into selected maintenance procedures. - Housekeeping within the radiological controlled area was excellent.

T _ ALARA work packages were completed for the upcoming refueling outage. Outage scope was frozen sufficiently in advance of outage activities to provide ALARA technicians time to review upcoming radiological work requests and include dose saving measure ' Post-job reviews for previous outage work were performed, in accordance with procedural requirements. ' Th'e licensee attempted to interview contractor employees before they lef t site: however, when this was not feasible, the contractor wc,rk

- group leaders were interviewed or comments and suggestions from in-progress observations were included in the packages. The inspector concluded that these-

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were acceptable contingency action 'The AL' ARA Review Committee met as required. According to the meeting minutes,

' there _was good support from all department .

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~4-The 1996 ALARA report contained a section that discussed the ALARA

suggestions. According to the report 5- ALARA suggestions were submitted by-individuals in the conventional manner and 81 ALARA suggestions collected through the lessons learned program, a system used site wid Such a large number of ALARA suggestions / lessons learned is usually indicative of excellent performance in identifying dose saving measures.- However, when the inspector attempted to verify that radiation protection personnel had'dispositioned the ALARA suggestions / lessons learned in a manner that resolved the original problem and perpetuated the dose saving knowledge, the radiation protection personnel were unable to reconstruct a list of ALARA suggestions for which they took credi Unable to start from a specific bank of ALARA suggestions,-the inspector attempted to select ALARA suggestions from the lessons learned recorded in post job review This proved difficult because of the large number of lessons learned. Most lessons learned were not focused on dose reduction, but rather on other means of making the work activities more efficient. ALARA suggestions were a subset of the whole and the licensee had not sorted the ALARA suggestions into an easily reviewable file. Even with the assistance of licensee personnel, the inspector was not able to verify that lessons learned were dispositioned in such a manner as to address the original problem and perpetuated the knowledge. Because of this, it appeared that radiation protection personnel preparing radiation work permits and ALARA work packages did not have access to alllessons learned about dose saving measure ;

The inspector interviewed. ALARA technicians who stated that accessing dose saving lessons learned for specific work activities was cumbersome, if not-impossible. The licensee acknowledged that ensuring lessons learned were i retrievable was an area that needed improvemen !

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-The licensee's person-rem totals for 1994-1996 are listed below. The licensee's-three-year average per unit for this period was 80 person-rems. This was below the most recent, available industry averages. The _ licensee's goal for 1997 is to accrue less than 300 person rem TOTAL RADIATION EXPOSURE (in Person rems)

1994 1995 1996 Licensee (per unit 24 14 .5 average) -

Nationai PWR-- .133 170 Not yet available Average i

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5-c .' Conclusions lThe ALARA program produced excellent results. The licensee's three-year collective radiation exposure for 1994 1996 was well below the national averag The method of perpetuating ALARA lessons learned needed improvemen R5 Staff Training and Qualification Insoection Scone (83750)

The inspector interviewed radiation protection personnel and reviewed the -

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Radiation protection technician continuing training topics

Training procedures listed in the attachment to this report

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- Instructor _ qualification * Condition reports

Personnel qualifications b.- Observations and Findirigg Continuing training topics presented to radiation protection technicians included current industry events, lessons learned, specialized radiation protection training, and information on selected plant systems. Training met procedural guideline Radiation protection training deficiencies were not identified as the root cause of l problems identified in condition reports. Three instructors were assigned to radiation protection technician training. All had practical radiation protection experienc There were three people in the licensee's site and corporate radiation protection

. organization that were certified as hoalth physicists by the American Board of Health Physics. There were two people with advanced degrees and nine with bachelors degree Within the. radiation protection organization, forty individuals were registered by the National Registry of Radiation Protection Technologists. in the radiation protection 1 operations group, 21 of 34 technicians were registere Conclusions -

' Appropriate continuing training was provided to the radiation protection technician A higtpy qualified radiation protection staff was maintaine ,

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-_ RG - Radiological Protection and Chemistry Organization and Administration

- There was a reduction in staffing in the radiation _ protection organization during the assessment period. Staffing declined from 77 authorized positions in 199_5 to 63 in

~ 1997. Two contractor health physicists were employed. . Additional reductions were -

planned to the year 2000. The inspector identified no objective evidence that the staff reduction compromised safet .

R7: Quality Assurance in Radiological Protection and Chemistry Activities

> Insocction Scone 1837501

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The inspector interviewed quality assurance and radiation protection personnel and reviewed the following:

• Audits Audit checklists

• Surv6illances

• Condition reports

• Event trending and analysis Observations and FindiD21 The most recent _ quality assurance audit of the radiation protection organization was .

conducted during a refueling outage. The audit team included two technical _

specialists from other nuclear sites. The audit checklist indicated a comprehensive !

sampling of radiation protection activities was reviewed. Two deficiencies were -!

identified. The radiation protection organization addressed the findings promptly and appropriatel During a review of selected condition reports assigned.to the radiation protection organization for action, the inspector noted that it was occasionally difficult to understand the problem being documented. -Members of the radiation protection professional staff also had difficulty understanding some of the examples and acknowledged the inspector's findin Although it was not true generally, the inspector noted that the corrective actions listed in some condition reports did not seem to match the identified cause of the occurrence, Radiation protection representatives acknowledged that this finding

'was also identified in a recent self assessment of the use of the condition reporting i syste = Cpnclusions Management oversight of radiation protection activities was good. Appropriate corrective actions were implemented to address assessment finding i

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Generally, radiation protection personnel used the condition reporting system properly. However, in some examples, the problems identified in condition reports were not stated clearly, or the corrective actions did not address the apparent causes of the problem R8 Miscellaneous Radiation Protection issues R8.1 (Closed) 50-498:499/9710 01: Faile.; to perform air samolina The is spector verified the corrective actions described in the licensee's response letter, oated April 17,1997, were implemented. No similar problems were identifie V. Manaaement Meetinas X1 Exit Meet:ng Summary The inspector presented the inspection results to members of licensee management at an exit meeting on August 28,1997. The licensee acknowledged the findings presented. No proprietary information was identifie ____

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A TTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED

- L!pensee J. Inman, Radiation Protection Supervisor R. Logan, Manager, Radiation Protection R. Lovell, Manager, Unit 1 Operations R. Masse, Plant Manager Unit 2 M. McBurnett, Manager, Licensing-G. Parkey, Plant Manager, Unit 1 R. Rohkugler, Director, Quality-J. Savage, Staff Specialist, Quality Assurance S. Smith, Technician, Quality Assurance S. Torey, Radiation Protection Supervisor NEG-D. Loveless, Senior Resident inspector J. Keeton, Resident inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure ITEM CLOSED Ginsfd 50-498;499/9710-01 VIO Failure to perform contamination surveys; failure to perform air sampling LIST OF DOCUMENTS REVIEWED Health Physics Condition Report Summarios First Quarter 1996 through Second Quarter 1997 List of Condition' Reports (August 2E, _1995 August 21,1997)

Condition Report 96-6772 Condition Report 96 6928 Condition Report 96 7285 Condition Report 97 3769 Condition Report 97 9458

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-2-Quakty Audit Report 97 03 - Radiological Contro's/Radwaste (February 10 through March 27,1997)

Quahty Surveillance Report 96-016 (February 5 8,12 15,20,26,1996)

Quality Surveillance Report 96-028 (March 25 28,1996, and April 2,1996)

Quality Surveillance Report 96 050 (April 1618,22 24,30, and May 7,1996)

Quality Surveillance Report 96-067 (July 8-11, 23, 24, 29, and 31,1996)

19941996 ALARA Annual Reports Radiation Protection Continuing Training Courses / Topic 1996 and 1997 Lessons Learned From Events Topics 1996 and 1997 Procedures OPGP03ZXOOO2 Condition Reporting Process OPGP03ZR0052 ALARA Program, January 30,1997 OPRP012A0037 Radiation Protection OJT/Oualification Program, March 16,1992 OPRP07ZR0009 Performance of High Exposure Work, May 14,1997 OPRP072R0011 Radiological Work ALARA Reviews, January 30,1997

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