IR 05000498/1999003

Insp Repts 50-498/99-03 & 50-499/99-03 on 990222-25.No Violations Noted.Major Areas Inspected:Plant Support

ML20207D418
Person / Time
Site:	South Texas
Issue date:	03/04/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207D414	List: IR 05000498/1999003 ML20207D409
References
50-498-99-03, 50-498-99-3, 50-499-99-03, 50-499-99-3, NUDOCS 9903090331
Download: ML20207D418 (11)

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ENCLOSURE.

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U.S. NUCLEAR REGULATORY COMMISSION

. REGION IV 4 Docket Nos.: 50-498

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50-499 1 License Nos.: NPF 76 NPF-80 i Report No.: 50-498/99-03

50-499/99 03 Licensee: STP Nuclear Operating Company

Facility

South Texas Project Electric Generating Station, Units 1 and 2

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Location: FM S21 - 8 miles west of Wadsworth Wadsworth, Texas

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Dates: February 22 to 25,1999 l

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l Inspector: Michael P. Shannon, Senior Radiation Specialist i

Accompanied by

James S. Dodson, Radia' n Specialist

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Approved By: Gail M. Good, Chief, Plant Support Branch Attachment : Supplemental Information

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9903D90331 990304

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-2-EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report No. 50-498/99-03; 50-499/99-03 Plant Sucoort

• Overall, the radiological environmental monitoring program was effectively implemented in accordance with the Technical Specification and the Offsite Dose Calculation Manual requirements. Tritium levels in the main cooling reservoir continued to trend down. The operation of South Texas Project Nuclear Station resulted in no detectable buildup of radioactivity off site (Section R1.1).

• A good meteorological monitoring program was in place. The performance of the meteorological monitoring equipment exceeded the guidance contained in Regulatory Guide 1.23 (Section R1.2).

• Descriptive radiological environmental monitoring program implementing procedures were maintained (Section R3.1).

= The senior radiation protection technicians assigned to implement the radiological environmental monitoring program were fully qualified to perform their assigned task Continuing training topics did not cover radiological environmental monitoring program related activities (Section R5).

= An experienced staff implemer.ted the radiological environmental monitoring program (Section R6).

• Good, effective audit and quality monitoring reports of the radiological environmental j monitoring program were performed by qualified auditors. Condition reports identified issues at the proper threshold to provide management with an overview of the I radiological environmental and meteorological monitoring programs. Overall, corrective l actions were closed in a timely manner; however, some actions were closed before all items were completed (Sections R7.1, and R7.2).

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-3-Report Details

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IV. Plant Support l l

R1 Radiological Protection and Chemistry Controls ,

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R Radioloaical Environmental Monitorina Procram Inspection Scope (84750)

The radiological environmental monitoring program was reviewed to determine compliance with Technical Specifications and Offsite Dose Calculation Manual requirements. Selected environmental sampling stations were inspecte Observations and Findinas i The inspectors verified that selected air, water, and vegetation sample stations were maintained as described in the Offsite Dose Calculation Manual, Revision 9. The inspectors accompanied and observed a senior radiation protection technician who collected and prepared selected air, surface water, and vegetation samples for analyses. These activities were conducted in accordance with approved procedure l The inspectors noted that air sample media was collected by replacing the sampler 1 heads in the field, minimizing the potential for cross contamination and preserving sample integrity. Air sampler equipment was calibrated in accordance with procedural

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requirements using instrumentation traceable to known standards. A review of the sample collection logs and sample analyses records revealed that these documents l

were properly maintained. The environmental storage area was stocked with the necessary equipment and consumable supplies to perform the required sampling activitie The inspectors determined that collection frequency, processing, and analyses of the

radiological environmental samples were performed in accordance with Table B5-1 of the Offsite Dose Calculation Manual. The 1997 annualland use census was performed in accordance with Section 3.12.2 of the Offsite Dose Calculation Manual, and the land use census results were documented in the annual radiological environmental operating

, report. A comprehensive radiological environmental monitoring report for 1997 was i submitted within the time requirements of Section 6.9.1.3 of the Offsite Dose Calculation Manual. From a review of 1997 environmental off-site sample data, the inspectors concluded that the operation of South Texas Project Nuclear Station resulted in no J

detectable buildup of radioactivity off site, and thermoluminescent dosimeter results indicated that plant operations did not affect the ambient radiation levels in the environmen Tritium levels in the main cooling reservoir continued to trend down, in early 1996,

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tritium levels in the main cooling reservoir peaked at approximately 17,000 picoCuries per kilogram, which represented 56 percent of the NRC's 30,000 picocurie per kilogram

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reporting level. The licensee determined that increased tritium levels were attributed to processing resin in the water cleanup systems with natural lithium, rather than lithium

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-4-depleted in lithium-6. At the end of 1997, tritium levels in the main cooling reservoir were approximately 8,000 picoCuries per kilogram. Water from the main cooling reservoir was not used for drinking or recreation; therefore, doses to the public were not applicabl Environmental samples were analyzed on site by the licensee. The licensee participated in an interlaboratory comparison program as required by Section 3.12.3 of the Offsite Dose Calculation Manual. The inspectors verified that analytical results from the interlaboratory comparison program were reported in the annual radiological environmental operating report in accordance with the requirements of Section 4.11.3 of the Offsite Dose Calculation Manual, Conclusions Overall, the radiological environmental monitoring program was effectively implemented in accordance with the Technical Specification and the Offsite Dose Calculation Manual requirements. Tritium levels in the main cooling reservoir continued to trend down. The operation of South Texas Project Nuclear Station resulted in no detectable buildup of radioactivity off sit R1.2 Meteoroloaical Monitorina Proaram Lnspection s Scope (84750)

The meteorological monitoring program was reviewed to determine agreement with

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commitments in Section 2.3.3 of the Updated Final Safety Analysis Report and the recommendations in NRC Regulatory Guide 1.23. The inspectors reviewed data collection and data displays at station facilitie Observations and Findinas The inspectors verified that the meteorological tower's primary and secondary instrumentation and configuration agreed with the guidance in Regulatory Guide 1.23 and commitments in Section 2.3.3 of the Updated Final Safety Analysis Report. The primary tower provided for meteorological instrument redundancy at the 10- and 60-meter levels. The inspectors were informed that the primary and secondary instrumentation were each provided with backup power supplies that utilized propane generators to ensure power was availabl The inspectors verified that appropriate meteorological data was transmitted and displayed in the Unit 1 technical support center and control room. Daily system channel checks were recorded by control room operations personnel during each 12-hour shif t, in accordance with procedure requirement From a review of selected calibration records, the inspectors determined that the meteorological instrumentation was properly maintained and calibrated in accordance with station procedures. Calibration tolerances for the meteorologicalinstrumentation were within the recommendations of Regulatory Guide 1.23. The 1997 meteorological

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l-5-data recovery rate of 97 percent exceeded the recommended rate of 90 percent indicating that overall, an effective meteorological program was in plac .Qonclusions A good meteorological monitoring program was in place. The performance of the  !

meteorological monitoring equipment exceeded the guidance contained in Regulatory '

Guide 1.2 R3 Procedures and Documentation R Radioloaical Environmental Monitorina Procram implementina Procedures Insoection Scope (84750)

t The inspectors reviewed the radiological environmental monitoring program implementing procedure Observations and Findinas .,

The radiological environmental monitoring program implementing procedures contained sufficient detail for personnel to effectively implement the licensee's environmental '

monitoring program. The inspectors determined that the requirements contained in the Technical Specifications and the Offsite Dose Calculation Manual, Revision 9, were appropriately described in station implementing procedure Conclusions Descriptive radiological environmental monitoring program implementing procedures were maintaine R4 Staff Knowledge and Performance Inspection Scope (84750)

Selected environmental monitoring program personnel were observed and interviewed to determine their knowledge of the radiological environmental monitoring program sampling and analyses requirements and implementing procedure Observations and Findinas

The inspectors observed appropriate sampling and handling practices used by a senior radiation protection technician assigned to collect and analyze air, surface water, and vegetation samples. Air samples were appropriately handled to prevent cross

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j contamination of the particulate filter, and water containers were properly rinsed prior to -

sample collection. Through discussions and observations, the inspectors noted that the two senior radiation protection technicians responsible for implementing the radiological

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-6-environmental monitoring program demonstrated good knowledge of the Offsite Dose Calculation Manual requirement c. Conclusions Appropriate sampling and handling practices were used for collecting and analyzing environmental medi R5 Staff Training and Qualification a. Insoection Scope (84750)

The training and qualification programs for the personnel implementing the radiological environmental monitoring program were reviewe b. Observations and Findinas From a review of training documentation, the inspectors determined that both senior radiation protection technicians assigned to implement the radiological environmental rnonitoring program were fully qualified to perform their assigned tasks. However, the inspectors noted that although these technicians attended a continuing training program, the training topics were designed for operational health physics group activities and not radiological environmental monitoring program related activities. For example, the senior radiation protection technicians assigned to implement the radiological environmental monitoring program did not receive continuing training on sample preparation and analyzes, and laboratory instrumentation calibration. The radiation protection manager stated that the continuing training program for personnelinvolved in the radiological environmental monitoring program would be re-evaluate c. Conclusions The senior radiation protection technicians assigned to implement the radiological environmental monitoring program were fully qualified to perform their assigned task Continuing training topics did not cover radiological environmental monitoring program related activitie I R6 Organization and Administration a. Inspection Scope (84750)  ;

The organization, staffing, and assignment of the radiological environmental monitoring l program respcasibilities were reviewe I b. Observations and Findinas )

i The organizational structure of the radiological environmental monitoring program l remained unchanged since the last program inspection in May 1997. From interviews j with personnel involved with the radiological environmental monitoring program, the !

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inspectors determined that radiation protection management provided appropriate

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support to implement an effective program.

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j Conclusions

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An experienced staff implemented the radiological environmental monitoring program, i

R7 Quality Assurance Program i R7.1 Badioloaical Environmental Monitorina Quality Assurance Proaram Insoection Scoce (84750)

i Quality assurance audits and monitoring reports of the radiological environmental

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! Observations and Findinas

i The inspectors reviewed the qualifications of the lead auditor assigned to evaluate l radiological environmental monitoring program activities and determined that this j individual had appropriate technical and audit experience.

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The quality audit schedule and plans covered the appropriate program areas to provide

management with a good overview of the radiological environmental monitoring program. Radiation protection management and quality management were appropriately involved in developing the audit plan j i

Quality Audit 98-16," Radiological Environmental Monitoring Program," conducted from

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November 16 through December 10,1998, identified eight department level l deficiencies, two recommendations, and two procedure feedback items. All items were '

i properly documented in the station's condition reporting program. In addition to

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members of the licensee's quality organization, a technical specialist from another -

power station was used to supplement the audit staff. The audit was comprehensive

and provided management with an excellent assessment of the radiological

environmental monitoring program and areas needing attentio The inspectors noted that quality originated condition reports were tracked by the quality )

area lead to ensure corrective actions identified adequately addressed the issu L Nine quality monitoring radiological environmental monitoring program reports ,

(observations) were written since the last inspection in May 1997. The inspectors l determined that these reports provided good insight concerning the area reviewe However, during discussions with members of the quality organization, the inspectors .

determined that the quality monitoring reports were used by the quality organization to l 4 assess a program's performance and not normally forwarded to the management of the ,

department being reviewed. Quality department management informed the inspectors that they would review the distribution process of quality monitoring reports.

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No problems were identified during the review of the one department self assessment i

which was performed during this inspection period. The assessment covered radiological environmental monitoring program records generated and transmitted to the records management system. One finding and eight recommendations were identified and properly captured in the station's condition reporting syste Conclusions Good, effective audit and quality monitoring reports of the radiological environmental monitoring program were performed by qualified auditors. Deficiencies, recommendations, and procedure feedback items were documented in the station's condition reporting progra R7.2 Condition Reports and Corrective Actions I Inspection Scope (84750) 1 Selected condition reports were reviewed to evaluate the effectiveness of the licensee's ;

controls in identifying, resolving, and preventing problem Observations and Findinas i l

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The inspectors reviewed condition reports related to the radiological environmental and meteorological monitoring programs and determined that the station identified issues at l the proper threshold to identify equipment and program problems. Overall, corrective l actions were closed in a timely manner and were sufficient to resolve repeat problem ]

However, during the review of the corrective actions, the inspectors identified that some

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condition report actions were closed before allitems were completed. For example, l action No.1 of Condition Report 98-19634 stated that,"all OPRP10 procedures would j be made quality related procedures." However, action No.1 was closed with the

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statement that "all procedures currently beir.g revised are reclassified as quality related."

Radiation protection management informed the inspectors that they were reopening the identified condition reports to ensure all actions are completed prior to closur ;

I Conclusions Condition reports identified issues at the proper threshold to provide management with

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an overview of the radiological environmental and meteorological monitoring program Overall, corrective actions were closed in a timely manner; however, some actions were closed before all items were complete I i

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$ V. Manaaement Meetinas X1 Exit Meeting Summary i

The inspectors presented the inspection results to members of licensee management at

an exit meeting conducted on February 25,1999. The licensee acknowledged the findings presented. No proprietary information was identified.

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ATTACHMENT i

SUPPLEMENTAL INFORMATION ,

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I PARTIAL LIST OF PERSONS CONTACTED j

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Licensee

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P Arrington, Licensing Engineer L. Cochiane, Quality Specialist ,

W. Cottle, Executive Vice President and General Manager Nuclear i J. Groth, Vice President Nuclear Operation E. Hardcastle, Senior Radiation Protection Technician S. Head, Licensing Supervisor S. Horak, Quality Specialist R. Lovell, Generation Support Manager B. Mookhoek, Licensing Engineer A. Passafuma, Senior Radiation Protectior Technician i T. Powell, Health Physics Manager J. Sherwood, Health Physics Supervisor NRC N. O'Keefe, Senior Resident inspector i

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INSPECTION PROCEDURE USED IP 84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring

LIST OF DOCUMENTS REVIEWED iI PROCEDURES OPGP03-ZR-0039 Radiological Environmental Monitoring Program, Revision 8 ,

OPRP10-ZU-0001 REMP Sample Collection, Revision 2 l OPRP10-ZU-0007 Environmental TLD Monitoring, Revision 7 )

OPRP10-ZL-0006 Sample Receipt, Accountability and Storage, Revision 9 l OPRP10-ZL-0011 Gamma Analysis in Environmental Media, Revision 6  !

l OPRP10-ZL-0012 lodine 131 Analysis in Environmental Media, Revision 5

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OPRP10-ZL-0013 Sample Preparation for Strontium 89/90 Analysis, Revision 4 OPRP10-ZL-0016 Alpha / Beta Analysis in Environmental Media, Revision 4 I

OPRP10-ZL-0022 Quality Control of Radiological Laboratory Equipment, Revision 5 l

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2-OUALITY ASSURANCE

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Ouality Audit 9816 Radiological Environmental Monitoring Program Department Assessment of the Radiological Environmental Program, February 18,1999 Quality Monitoring Report MN-97-0-0765 Quality Monitoring Report MN-97-0-1064 -

Quality Monitoring Report MN-97-0-1065 Quality Monitoring Report MN-97-0-1066 Quality Monitoring Report MN-98-0-0550 Quality Monitoring Report MN 98-0-0551 Quality Monitoring Report MN-98-0-0552-Quality Monitoring Report MN-98-0-0570 Quality Monitoring Report MN 98-0-0671 REPORTS 1997 Annual Radiological Environmental Operating Repod QTHER Offsite Dose Calculation Manual, Revision 9 Training Records Organizational Charts Meteorological Tower Instrumentation Calibration Records

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