IR 05000498/1998002

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/98-02 & 50-499/98-02 on 980212
ML20217F676
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/22/1998
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Cottle W
AFFILIATION NOT ASSIGNED
References
50-498-98-02, 50-498-98-2, 50-499-98-02, 50-499-98-2, NUDOCS 9804280234
Download: ML20217F676 (5)


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- UNITED STATES

NUCLEAR REGULATORY COMMISSION 3-g RECf 0N dV

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611 RYAN PLAZA DRIVE. SUITE 400 AR LINGTON, TEXAS 760114064

April 22,1998 I

William T. Cottle, President and Chief Executive Officer STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483-l SUBJECT:

NRC INSPECTION REPORT 98-02 Thank you for your letter of March 16,1998, in response to our letter and Notice of l

l Violation dated February 12,1998. We have reviewed your reply and find it responsive to the l

L concems raised in our Notice of Violation. We will review the implementation of your corrective l

actions during a future inspection to determine that full compliance has been achieved and will be maintained.

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Sincerely,

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Blaine Murray, Chief L

Plant Support Branch Division of Reactor Safety i

Docket Nos.: 50-498 50-499

License Nos.: NPF-76 NPF-80 cc:

Lawrence E. Martin, Vice President Nuclear Assurance & Licensing

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STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 A. Ramirez/C. M. Canady

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City of Austin

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i Electric Utility Department 721 Barton Springs Road Austin, Texas 78704 9804280234 980422 PDR ADOCK 05000498 G

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STP Nuclear Operating Company-2-

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Mr. M. T. Hardt/Mr. W. C. Gunst l

l City Public Service Board

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l P.O. Box 1771 l

San Antonio, Texas 78296 l1 i

D. G. Teea/R. L. Balcom Houston Lighting & Power Company P.O. Box 1700

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Houston, Texas 77251 l

l Jon C. Wood L

Matthews & Branscomb l

One Alamo Center 1106 S. St. Mary's Street, Suite 700 l

San Antonio, Texas 78205-3692 Jack R. Newman, Esq.

Morgan, Lewis & Bockius 1800 M. Street, N.W.

j Washington, D.C. 20036-5869 Mr. G. E. Vaughn/Mr. C.. A. Johnson Central Power & Light Company P.O. Box 289 MailCode: N5012

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Wadsworth, Texas 77483 lNPO Records Center j

700 Galleria Parkway i

Atlanta, Georgia 30339-5957

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Bureau of Radiation Control State of Texas 1100 West 49th Street Austin, Texas 78756 Mr. Jim Calloway Texas Public Utility Commission William B. Travis Building 1701 North Congress Avenue L

P.O. Box 13326 Austin, Texas 78701-3326

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l STP Nuclear Operating Company-3-John Howard, Director Environmental and Natural Resources Policy

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l Office of the Govemor P.O. Box 12428 Austin, Texas 78711

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Judge, Matagorda County Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 l

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STP Nuclear Operating Company-4

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L DISTRIBUTION w/coov of licensee's letter dated March 16.1998:

i DCD (IE06)

l Regional Administrator STP Resident inspector l

DRS Director l

DRS Deputy Director DRP Director DRS-PSB

Branch Chief (DRP/A)

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MIS System

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Project Engineer (DRP/A)

Branch Chief (DRP/TSS)

R. Bachmann, OGC (MS: 15-B-18)

RIV File DRS Action item File (98-G-0017) (Goines)

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I DOCUMENT NAME: R:\\_STP\\STP802AK.MPS To receive copy of desument, Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PSB Anf> 'E C:DRS)Pj$ljy MPShannon':nh BMurr@ L 04M/98 04/z/98 OFFICIAL RECORD COPY l

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STP Nuclear Operating Company-4-DISTRIBUTION w/coov of licensee's letter dated March 16.1998:

DCD (IE06)

Regional Administrator STP Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/A)

MIS System Project Engineer (DRP/A)

Branch Chief (DRP/TSS)

R. Bachmann, OGC (MS: 15-B-18)

RIV File DRS Action item File (98-G-0017) (Goines)

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DOCUMENT NAME: R:\\_STP\\STP802AK.MPS To receive copy of 6wnt, Indicate in box:"C" = Copy without endosures "E" = Copy with enclosures "N" = No copy RIV:PSB M E

C:DRS)P$lk MPShannori:nh BMurrFj-

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04M/98 044/98 OFFICIAL RECORD COPY g800

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  • APR-20-1998 09:18 NUCLEAR LICENSIto 512 972 8253 P.02/39

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.- - r mmamum.non naaxzu me.an wnw vw, March 16,1998 NOC-AE-000106 File No.: G02.04.02 10CFR2.201 STI: 20563225

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73@@0W37 U. S. Nuclear Regulatory Conunission

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Aue=wina: Document Contml Desk t

APR 2 o S33 Washington,DC 20555 South Texas Pmject

REGION IV

Units 1 and 2 Docket Nos. STN 50-498; STN 50-499 Recly to Notices of Violation 9802-01. 9802-02. and 9802-04 South Texas Project has reviewed the Notices of Violation contained in inspection report 50-496; 49W98-02 dated Febmary 12,1998, and submits the attached reply. Tbc only commitments contained in this correspondence are located in the Corrective Actions sections of the attachments.

If there are any questions regarding these replies, please contact Mr. S. M. Head at (512)

972-7136 or me at (512) 972-7799.

. R. Lovell Manager Generation Support WEM/wem Attachments: A. Reply to Notice of Violation 9802-01 B. Reply to Notice of Violation 9802-02 C. Reply to Notice of Violation 9802-04

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APR-20-1998 09:19 I4JCLEAR LICEFGitG 522 972 8233 P.03/09

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ST-NOC-ABM106 File No.: G02.04.02 Page 2 Ellis W.Marschoff Jon C. Wood Regional Adminierator,RegionIV Matthews &Bransmmb U. S. Nuclear Regulatory Commiaion One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700 Arlington,TX 76011-8064 San Antonio,TX 78205-3692

'Ihnas W. Alexion Institute ofNuclear Power Pmject Manager, Mail Code 13H3 Operations-Records Center U.S. Nuclear Regulatory Commission 700GalleriaParkway Washington,DC 20555 0001 Atlanta, GA 30339-5957 David P. Loveless Richard A.Ratliff Sr. ResidentInspector Bureau of Radiation Control clo U. S. Nuclear Regulatory Commission Texas Department ofHealth P. O. Box 910 1100 West 49th Street Bay City,TX 77404 4 910 Austin,TX 78756-3189 J. R. Newman, Esquire D. G. Tees /R. L. Balcom

_W IAwis & Bockius Houston Lighting & Power Co.

1800 M. Street, N.W.

P. O. Box 1700 Washington, DC 20036-5869 Houston,TX 77251 M. T. Hardt/W. C. Gunst Central Power and Light Comaaay City Public Service ATrN: G.E.Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 782%

Wsisworth,TX 77483 A. Ranizer/C. M. r'anady U.S. Nuclear Regulatory Commission

' City of Annin Attention: DarnetControlDesk Electnc Utility Department Washington, DC 20555-0001 721 Barton Springs Road Austin,TX 78704

APR-20-1998 G9:19 NUCLEAR LICENSING 512 972 8253 P.04/09

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Attachmeet A NOC-AE-000106 Page 1 of 2 Reply to Nodce of Violation 9802-01 1,

e*=**mmt of Vialatian:

Daring an NRC inspection conducted on January 12-15,1998, three violations of NRC requirements were insaamed. In acconlance with the " General Statement of Policy and Procedure for NRC Enforcement Acdons," NUREG-1600, the violatlocs are listed below:

10 CMt 19.12(a) states, in par 4 that all individuals who in the course of employment are likely to moelve in a year an c-:-:, :%al dose in excess of 100 millirems shall be kept informed of the storage, transfer, or use of radiation and/or radioactive matedal.

Contrary to the above, radiate workers who were likely to receive an wtianal dose in excess of 100 millirems per year were not informed of the presence of airbome radioactivity. Sgremily, on September 23 and haremhar 28,1997, workers in the Unit 1 Reactor C=' W=at Building and Unit i reactor cavity area, respectively, were not m' formed that they were working in an airborne radioactivity area.

This is a Sevedty level IV violation (Supplement IV) (50498/9802-01).

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h6 Tam PmW Position:

South Texas Project concurs that the violation occurred.

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BeagLa for the Viointion:

The cause of this event was a lack of established guidelines as to when workers should be ' formed m

of changing conditions.

IV.

Corrective Actions:

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Revise procedure OPRP07-ZR-0010, Radiation Work Permits, to stipulate that persons logged in on an RWP at the time it is revised to change protective measures shall be notified

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of the change as soon as practicable. This action will be completed by 4/15S8.

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Revise procedure OPRPO4-ZR.0015, Radiological Postings and Warning Devices, to state that personnel located within an area where posting changes occur shall be notified of the y

change aa soon as practicable. This action will be completed by 4/1568.

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I APR-20-1998 09:20 NUCLEAR LICEtGING 522 972 8230 P.05/09

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Attarhrnenf A NOC-A5000106 Page 2 of 2 V.

Date of Full Comoliance; l

Mant produres require revisions be made, as necessary, to the Radiation Work Permit during l

l changing conditions which will keep workers informed of these changes. South Texas Project is in full mr=13-m.

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APR-20-1998 09:20 tOCLEAR LICENSItG 512 972 8298 P.06/09

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Attachment B NOC-AE-000106 Page 1 of 2 Reply to Notice of Violation 9802-02 L

StadamentofYiolation:

During an NRC iaWion conducted on January 12-15,1998, three violations of NRC requimments were identified. In accordance with the " Genera 1 Statement of Policy and Procedure l

for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

i Tarhainal Speification 6.11.1 states, in part, that procedures for personnel radiation i-Aection shall be prepared consistent with the requimnents of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving perivusel radiation l

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10 CFR 20.1501 (a) states, in part, that each IMeaa shall make or cause to be made, surveys that may be necessary for the licensee to comply with the regulations in this part and j

are reasonable undar the circumstanem to evaluate concentrations or quantities of i

radioactive matarial and the potential radiological hazards that could be present.

Radiation Prate *ian Procedure OPGP03-ZR-0050, " Radiation Protection Program,"

l Revision 1, Section 4.6.4, states, in part, " Job coverage, or specific surveys, shall be of the

type and frequency... to assess the extent of... concentrations of radioactive materials and the potential radiological hazards to which workers may be exposed."

Cbotrary to the above, between 3:40 p.m. on Sept a% 22, and 12:15 a.m. on Ser/wruber 23,1997, airborne radioiodine activity surveys were not jwfo nd in Unit i Reactor Containmant Building to assess the extent of concentrations of radioactive material, and the l

potential radiological hazards to which workers may have been exposed.

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This is a Severity Level IV violation (Supplement IV) (50-498N802-02).

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ha=*h Tar =c Pro'ect Panitian-n

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Soudi Texas Project concurs that the violation occuned.

31, n-aa for the Vial = tion:

The cause of the failure to perform air sampling sufficient to identify airborne radioiodine in the reactor naarminment was the decision to stop sampling based on historical and recent sample results without consideration of the remaining source term and plant configuration changes that could result in incseased Merec radioactivity. Additionally, the sh=~a of specific plans to use continuous air

=r" 4 equipment contributed to the stafT's inability to become aware of changing radiological naa m nes e L ; L A eor

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Attachment B NOC-AFA00106 Page 2 of 2 IV.

Corrective Actions:

1.

Health Physics resumed routine sampling for radioiodine on the morning of 9/23/97 and continued for the duration of the refueling outage.

2.

This event will be e. 'ered in Health Physics continuing training prior to the next refueling.

This action will be ampleted by 10/168.

3.

Procedure OPRPO4-ZR-0013 " Radiological Survey Program," will be revised to include guidance on the use of plant radiation monitoring ' system to monitor changes in radiological conditions and also to pavvide for use oflocal continuous monitoring equipment. This action will be completed by 4/1568.

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Date of Full Compline:

Required sampling is being performed in all areas of the station. South Texas Project is in full compliance.

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  • APR-20-1998 09:21 NUCLEAR LICENSING 512 972 8298 P.08/09

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Attachment C

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NOC-AF 000106 Page 1 of 2 Reply to Notice of Violation 9802-04 L

m**maat of Vial =tiaa:

During an NRC inspection caade d on Jaauary 12-15,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

Technical Speikh 6.8.1.a states, in part, that written procedures shall be established, i=atamaa'ad and maintained covering the applicable pr-Anres recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, AppaMir A, Section 7.e.3, rs-,ds procedures for airborne radioactivity monitoring.

Radiation Protection Procedure OPRPO4-ZR-0015, " Radiological Posting and Waming Devices," Revision 3, Section 2.2, states, in part, "STP (South Texas Project) will post airbome radioactivity areas at 0.25 DAC or greater."

Contrary to the above, from 11:07 p.m. until 11:45 p.m. on September 28,1997, the Unit I reactor cavity was not posted as an airbome radioactivity area when airbome radioactivity saraple results revealed that the aid,oice radioactivity was greater than 0.25 DAC.

'niis is a Severity level IV violation (Supplement IV) (50-498/9802-04).

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South Texas Project Position:

South Texas Project concurs that the violation occurred.

EL P 7 for the Vioimian:

Contrary to procedure OPRPO4-ZR-0015, which requires posting airborne radioactivity areas at 0.25 DAC or greater, the reactor cavity was not posted when there was data indicating that the airborne radionedvity concentration exceeded 0.25 DAC. The procedure does not provide for delay in posting until confirmatory measurements are taken.

IV.

Carrective Actions-1.

Communicate in Health Physics continuing training that actions will first be taken to post airborne radioactivity areas based on available sample results and that confumatory measurements will follow posting in priority. This action will be completed by 6/15/98.

CC,21 Av-9802

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Attachment C NOC-AE-000106 l

Page 2 of 2 V.

Dess of FullCornpliance:

Airborne radioactivity areas are properly posted. South Texas Project is in full compliance.

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