IR 05000458/1985065
| ML20136B817 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 10/21/1985 |
| From: | Murray B, Nicholas J, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20136B808 | List: |
| References | |
| 50-458-85-65, NUDOCS 8511200292 | |
| Download: ML20136B817 (9) | |
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APPENDIX U. S. NUCLEAR REGULATORY COMIS.5I0N
REGION IV
NRC Inspection Report:
50-458/85-65 License:
NPF-40 Docket:
50-458 Licensee: Gulf State Utilities (GSU)
P. O. Box 2951 Beaumort, Texas 77704 Facility Name:
T,,er Bend Station (RBS)
Inspection At:
kiver Bend Station, St. Francisville, Louisiana Inspection Conducted:
September 16-20, 1985 Inspectors:
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Blair Nicholas,lSenior Radiation Specialist, Date
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acilities Radiation Protection Section O
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lair Spitzberg( Radiation Specialist, Date Facilities Radiological Protection Section Approved:
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//fifth e6!8/
h B.Murray, Chief,'Facilit[esRaciological
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~ Protection Section Inspection Summary
~ Inspection Conducted September 16-20, 1985 (Report 50-458/85-65)
Areas Inspected:
Routine unannounced inspection of the licensee's radiological environmental monitoring program (REMP) including:
organization and management controls; qualifications and training; radiological environmental monitoring program; meteorological monitoring program; facilities, equipment and supplies; quality control of radiological analytical measurements; quality assurance (QA)
program; contractor activities; and reportable occurrences. The inspection involved 54 inspector-hours onsite and 8 inspector-hours offsite by two NRC inspectors.
Results: Within the areas inspected, no violations or deviations were identified.
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Persons Contacted GSU
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~*J..C. Deddens, Vice President' River Bend Nuclear Group
- T. F. Plunkett, Plant Manager
- B. E. Boyer, Environmental Analyst G. Collett, Radiation Protection; Instrument Foreman
- J.1V. Conner, Supervisor - Environmental Services
- T..C. Crouse,-QA Manager..
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' *P. E. Freehill, Superintendent, Start-up and Testing. (SU&T)
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- D. R. Gipson, Assistant Plant Manager - Operations.
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- M. A. Harrington, Senior Radiological Environmental Analyst
- B. E. Hey, Licensing Engineer
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G. R.'Kimmell, Supervisor,' Operations QA
.C. L. Nash, Chemistry Supervisor
- E. R. Oswood, QA. Engineer
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- S.-R.~Radebaugh, Assistant' Superintendent SU&T M. Reed, Environmental Radiation Protection Technician
- C. A._Rohrmann, Nuclear Training Coordinator - Technical D. M.'Ross, Radiological Health Supervisor B. L. St. Cyr, Senior Environmental Analyst-
- J. E. Spivey, Jr., QA Engineer
Others
- D. D. Chamberlain, NRC Senior Resident Inspector
- Denotes those present during the exit briefing on September 20, 1985.
The NRC inspectors also interviewed several other RBS employees during the inspection.
2.
. Environmental Services Organization and Management Controls The NRC inspectors' reviewed the-licensee's onsite environmental services organization, management controls,' and assignment of REMP responsibilities to verify compliance with commitments.in Chapter 13.1 of the Final Safety Analysis Report (FSAR), requirements in Section 6.2 of the Technical Specifications (TS), and Environmental' Services Group (ESG) procedur~es, a.
Organization The NRC inspectors verified that the organizatio'nal structure within the ESG at the onsite environmental laboratory was as defino'r in the-TS,_FSAR, and ESG procedures.
The. responsibility for manag' ment'
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I of the REMP is assigned to the Vice President - Safety and Environment at'the corporate level and the REMP is managed and coordinated at the
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RBS by the Supervisor - Environmental-Services.
Since'the previous
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NRC inspection of.the REMP conducted in June 1984, there have been several personnel changes.
The consultant acting in the position of
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senior radiological environmental analyst has left RBS and has been replaced by the staff member who was formerly the senior environmental
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. an.alyst.
The senior environmental analyst position was just recently
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filled with an experienced and qualified environmentalist.
The ESG staff has also increased its size to six GSU employees with the
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addition of a second technician.
The current ESG organization
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structure and staffing appeared to be consistent withzthe REMP
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requirements.
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Manacement Controls
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'The NRC inspectors reviewed the ESG management control procedures
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- and position descriptions for the assignment of-responsibilities for-the management and. implementation of the REMP.
The NRC inspectors verified that the administrative control responsibilities specified
.by the FSAR and TS were being implementeu.
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No violations or deviations.were identified.
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Qualifications and Trainina.
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The NRC inspectors reviewed the training and qualifications of the ESG
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staff to determine compliance with commitments in Chapters 13.1.3 and
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i 13.2.of the FSAR, and the requirements in Sections 6.3 and 6.4 of the TS, and-ESG procedures.
The NRC inspectors reviewed the resumes for each ESG staff member and determined that the members of the ESG staff met the experience and i
educational qualifications as committed to in the FSAR, TS, and ESG
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Procedure ESP-8-002,' " Qualifications and Training of River Bend Nuclear
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Group Environmental Services Group Personnel," Rev. O, March 4, 1985.
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p The NRC inspectors discussed the training program for ESG personnel with
the nuclear training coordinator - technical and the environmental ' services
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supervisor. The nuclear training department does not plan to establish a
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classroom training program with formal lectures for the ESG,since the
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Ltraining requirements are diverse and specialized and best served by on-the-job training..The on-the-job training program is being supple-r mented by off-site vendor training in specialized areas.
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The NRC inspectors reviewed the training records and certificates of i
- qualification for the six individuals assigned to the ESG.
ESG personnel had received training in meteorology,' hazardous wastes, RBS plant systems,
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I and occupational and environmental ra'iation. protection. The NRC 1 d I
inspectors noted that many tasks indicated-on the individual staff
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. certificates of qualification had-not been completed; thereby not
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' certifying the individual to perform those tasks.
The NRC inspectors'
-observations as discussed in;the following. paragraph are not considered u
violations of established regulatory requirements. The NRC inspectors discussed these observations with'the licensee as matters.to be
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considered for program improvement.
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The NRC inspectors' review disclosed the following observations:
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The senior radiological environmental analyst was not certified to
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-perform gamma isotopic analyses of REMP samples in accordance.with his position description.
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'The same individual was not certified to perform National Pollutant
Discharge Elimination System-(NPDES) sampling and analyses while holding the position of senior environmental analyst who is respon-i sible for managing the ESG water quality laboratory and direction of
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the NPDES permit compliance including analytical and technical support for operation of the RBS sanitary waste treatment systems.
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The environmental analyst.who is responsible for ensuring the c.
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accuracy and retrievability of meteorological measurements from the meteorological tower instruments is'not certified to perform daily
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meteorological tower surveillance checks which he currently performs
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routinely.
j The NRC inspectors, at the exit briefing, suggested that all ESG staff
members' certificates of qualification should be completed in accordance L
with ESG Procedure ESP-8-002 and should certify for each individual'all j-tasks which that individual may have occasion to perform.
The licensee j
indicated that.these certifications should be completed by December 1985 j
for all ESG staff.
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The NRC inspectors-considered the above observations were not significant.
j enough to' impact on the implementation of the present EMP and were not-i considered a major problem since the'NRC~ inspectors determined that the
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present staff members had'been trained and were qualified to perform their
. assigned responsibilities.
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iNo violations or deviations were identified.
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4.
. Radiological Environmental Mon'itorina Program.
l The NRC inspectors reviewed the licensee's REMP'to determine compliance j
. with requirements'in Sections:3/4.12 and 6.9 1.7 of'the TS and ESG j
procedures.
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'The NRC inspectors reviewed the annual radiological environmental
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monitoring report for 1984 and determined that the requirements specified
in the Environmental. Report - Operating License Stage, Table 6.2-1,
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- J Supplement 5, were met.. A review of current REMP activities indicated i[
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implemented.
that the recently issued TS requirements'in Section 3/4.12 were being 2 -
The NRC inspectors reviewed selected environmental sampling stations
E associated with the REMP._ The following types of sampling stations were
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airborne, precipitation, milk, direct radiation, vegetation, t
and surface water. The required equipment at the. selected sampling i
stations was in place, calibrated, and operational at~the time of the inspection. During the inspection of the various environmental stations, the NRC inspectors verified that the locations lwere as described in the
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Offsite Dose Calculation Manual (00CM), Table 4.1.
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The licensee had purchased an automatic sampler to be installed in the
plant discharge line for TS required sampling.
The sampler had been received and will-be installed as soon as the required utilities.and security equipment.are installed.
In the interim, ESG' personnel are
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collecting grab samples to satisfy the TS requirement.
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The~NRC inspectors reviewed the licensee's procedures for implementation
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of the REMP. The licensee had identified 47 procedures-for the ESG, 36 were REMP related of which 34 had been written and approved. The proce-
dures for administration of:the REMP,. collection of environmental samples,
- and analytical procedures to meet TS analysis requirements were written
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with sufficient detail to ensure compliance with the TS.
It was noted i
that procedures for the. operation and performance checks of the meteoro-
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logical monitoring equipment were written and approved.
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i The NRC inspectors reviewed the annual land use census which was conducted
.during the period July 15 through August 30, 1985, and performed out to
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a radius of 8 kilometers from the plant as per ESG Procedure ESP-8-051.
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=The results.of the land use census will be reported in the 1985' annual ll REMP, report in accordance with:TS.
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The NRC inspectors reviewed the licensee's 00CM and verified that it had l
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been ' approved by the NRC Office of Nuclear Reactor Regulation 'and had
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l-been implemented upon the issuance of the operating license to R8S.
The NRC inspectors also reviewed the changes incorporated into Revision 3 of
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- the ODCM.
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p TheNRCinspectorsreviewedthecalibrationprogramfortheREMPaN,1
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l The_NRCLinspectors reviewed the RBS environmental,TLD program.
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L mental TLD's (Procedure ESP-8-028) and for the selection processing, and
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The-licensee is currently deploying environmental TLD badges and processing
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them in performing studies which will provide data to meet the requirements of ANSI N545-1975.
These studies are expected to be completed by April 1986.
At that time it is expected that the licensee will be implementing their n
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own environmental TLD program without the required support of a contractor laboratory.
At the time of the inspection, the licensee was not performing radiological analyses an the environmental samples collected.
The samples were being sent offsite to a contractor for analysis.
The licensee has plans to perform radiological analyses on environmental samples onsite and has equipped a laboratory and radioanalytical counting facility.
The NRC inspector discussed with the environmental services supervisor the antici-pated plans for the ESG to perform the entire REMP onsite including sampling and analyses without the support of an offsite contractor laboratory.
The NRC inspectors were informed that the ESG planned to be performing all of the REMP sampling and analyses in accordance with TS requirements by January 1986.
A period of time would be established for performing duplicate analyses and making result comparisons with the contractor laboratory prior to terminating the offsite laboratory support.
No violations or deviations were identified.
5.
Meteorological Monitoring Program The NRC inspectors reviewed the licensee's meteorological monitoring program to determine compliance with the requirements in Sections 3/4.11 and 3/4.12 of the TS, requirements of Supplement 1 to NUREG-0737, recommen-dations of Regulatory Guides 1.23 and 1.97 and American National Standards Institute (ANSI /ANS) Standard 2.5-1984, and ESG procedures.
The NRC inspectors reviewed the meteorological tower data monitoring and recording equipment, instrument calibration procedures and records, maintenance proc dures, and surveillance procedures and records.
It was verified that the meteorological tower instrumentation was being calibrated semiannually by I&C technicians and daily surveillance checks of instrumen-tation operation were being performed according to ESG Procedure ESP-8-012 by the ESG environmental analyst.
It was noted that the dew point sensors were inoperable and have been repeatedly worked on by I&C personnel in attempts to make them operational with no success.
This observation is also documented in Quality Assurance Finding Report (QAFR) P-85-08-41-D.
Resolution to this dew point sensor problem is being studied by the licensee.
The NRC inspectors reviewed the results of a 60 day reliability study performed on the R8S meteorological monitoring system and found that the results indicated an overall 95 percent data recovery for the period March 12 through May 11, 1985.
No violations or deviations were identified.
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Facilities, Equipment, and Supplies The NRC inspectors inspected the ESG laboratory facilities including the environmental sample preparation laboratory, radiochemistry counting room, and environmental sample receiving and storage area. The laboratory areas inspected were equipped with the necessary chemicals, labware, and analytical instrumentation to perform the required analytical procedures to support RBS operation.
No violations or deviations were identified.
7.
Quality Control of Radiological Analytical Measurements The NRC inspectors reviewed the ESG program for calibration and quality control of radiological analytical measurements to determine compliance with Section 3/4.12.3 and 6.8 of the TS, ESG procedures, and the recommen-dations in Regulatory Guide 4.15.
The NRC inspectors reviewed the ESG quality control procedures, counting instruments' calibration data and performance check data, and other documentation of instrument performance.
Data for the period July 1984 through August 1985 were reviewed.
The procedures had been recently approved and were not fully implemented at the time of the inspection.
It was noted that the alpha / beta counting system had been initially calibrated in June 1984, the liquid scintillation spectrometer in August 1984, and the gamma spectroscopy system in March 1985.
Records associated with the quality control of the counting instruments since their initial calibration were not on approved forms and the performance checks had not been per-formed and the data presented according to procedure.
The NRC inspectors observed a lack of familiarity with the counting instruments and the need for additional training and experience for the ESG personnel responsible for maintaining the counting instruments and performing the analytical measurements.
The NRC inspectors were concerned with the lack of experience and qualification of the ESG personnel in using the counting instrumentation.
The NRC inspectors determined that the primary reason for the lack of familiarity and quality control with the radioanalytical counting instruments was due to the loss of the ESG consultant who was acting in the position of senior radiological environmental analyst and who had not trained additional ESG personnel in the operation of the counting instruments prior to his leaving.
The NRC inspectors' concerns with the radioanalytical counting instruments' quality control program and analytical performance of the ESG personnel on the counting instruments were discussed during the exit briefing.
The NRC inspectors stated that the ESG was not prepared at this time to assume the entire, implementation of the REMP analytical program. The licensee acknowledged the NRC inspectors'
concerns and agreed to evaluate them and take corrective action to establish and implement a quality radiological analytical program to support the REMP prior to releasing the offsite contractor laboratory.
The NRC inspectors stated that the ESG radiological laboratory analytical program should be fully implemented in accordance with procedures by January 198 r
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-8-The NRC inspectors reviewed the licensee's laboratory performance in the Environmental Protection Agency-(EPA) crosscheck program during 1984 and verified that the licensee's analytical results were within the three sigma acceptance criteria established by the EPA.
The licensee had not routinely performed analyses on EPA samples during 1985 due to the loss of the ESG consultant and lack of experienced and qualif.iej personnel to perform radioanalytical measurements.
No violations'or deviations were identified.
8.
QA Program The NRC inspectors reviewed the licensee's QA audit program to determine compliance with commitments in Chapter 13.4 of the FSAR and requirements in Section 6.5.3.8 of the TS.
The NRC inspectors reviewed the REMP audits conducted by the GSU QA staff on the ESG since the previous NRC inspection conducted in June 1984.
The following audits were reviewed:
a.
Environmental and Radiological Monitoring Program, Audit No. IGSU-84/12, December 3-7, 1984 b.
Environmental and Radiological Monitoring Program,
' Audit No. GSUS/EMON-85/07, July 22-26, 1985 The NRC inspectors reviewed the audit procedures and checklists.
The NRC inspectors noted that the QA audits were designed to determine compliance with the TS and REMP procedures.
The 1984 audit generated 16 QAFR's to be addressed and resolved by the ESG.
In addition to the REMP deficiencies identified in the QAFRs, the audit team reviewed GSU's corrective actions to six open items identified in NRC Inspection Report 50-458/84-12 and recommended that the open items be submitted for closure.
The 1985 audit generated 11 QAFR's to be addressed and resolved by the ESG.
The NRC inspectors reviewed the audit findings and the ESG responses from both audits and confirmed that the audit findings were reviewed by management and that responses and corrective actions to the audit findings had been completed and documented in accordance with QA procedures.
The NRC inspectors noted that the audit teams performing the two REMP audits'of the ESG included a lead auditor qualified to the requirements of ANSI /ASME N45.2.23-1978 and a qualified technical specialist knowl-edgeable in radiological environmental analytical activities.
No violations or deviations were identified.
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Contractor Activities
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The NRC inspectors reviewed the licensee's procedures and audits used for
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" monitoring,their contractor's activities.
The licensee had conducted an
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W fi-environmental samples are performed.
The NRC inspectors reviewed the
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audit. checklist, and results of the audit conducted June 27-28, 1984.
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No violations or deviations were identified.
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10. ' Reportable Occurrences
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The NRC inspectors reviewed licensee event reports and the 1984 Annual
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Environmental Monitoring Report for reportable occurrences dealing with
'the REMP to determine compliance with reporting requirements of Section 6.9
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.of the TS..The NRC inspectors found no reportable events.
No violations or deviations were identified.
11.
Exit Briefina
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.The NRC inspectors met with the NRC senior resident inspector and
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licensee representatives denoted in paragraph 1 of this report at the
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conclusion of the inspection on September 20, 1985.
The lead NRC
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inspector summarized the scope of the inspection and discussed the il inspection findings as presented in this report.
The licensee committed I
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to evaluate and take appropriate action on the following items:
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ESG staff certificates of qualification (see paragraph 3).
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Resolution of the meteorological monitoring tower dew point
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sensor problem (see paragraph 5).
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c.
Implementation of the radiological counting instruments'
calibration and quality control program according to approved procedures (see paragraph 7).
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