IR 05000445/1989021

Insp Repts 50-445/89-21 & 50-446/89-21 on 890417-21.No Violations or Deviations Noted.Major Areas Inspected:Unit 1 Water Chemistry & Radiochemistry Programs

ML20247F606
Person / Time
Site:	Comanche Peak
Issue date:	05/17/1989
From:	Baer R, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20247F548	List: IR 05000445/1989021 ML20247F544
References
50-445-89-21, 50-446-89-21, NUDOCS 8905300114
Download: ML20247F606 (17)

Text

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1: APPENDIX U.S. NUCLEAR' REGULATORY COMMISSION REGION.I 'NRCLInspection Report: 50-445/89-21 Construction Permits: CPPR-126 50-446/89-21- CPPR-127 Docketsi -50-445'

- 50-446-Licensee: TU Electric 400 North Olive L.B. 81 Dal'las, Texas 75201 Facility Name': Comanche Peak Steam Electric Station (CPSES)

Inspection At: CPSES Site, Glen Rose, Texas Inspection Conducted: April 17-21, 1989 Insp'ector: , SY/7/M9 Date

/d acilities Nicholas, Radioleyical Se'nior Radiation Specialist Protection Section

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iApproved: ///M[ .A 7 8 R'. E. Baer, Chief, Facilities Radiological Date Protection Section Inspection Summary Inspection Conducted April 17-21, 1989 (Report 50-445/89-21; 50-446/89-21)

Areas' Inspected: Routine, unannounced preoperational inspection of the

= licensee's Unit I water chemistry and radiochemistry program Results: The NRC inspector determined that the licensee had developed a water chemistry program and radiochemistry program based on regulatory and industry

. guidelines which should provide plant operational support in compliance with ( regulatory and Technical Specification (TS) requirements. The nuclear training l -department is presently developing a chemistry technician training program i .accordance'with Institute'of Nuclear Power Operations (INPO) accreditation .

guidelines. Quality Assurance (QA) surveillance and audits had been performed '

as required and were technically comprehensive. The licensee's postaccident sampling system testing was in progres Within the areas inspected, no violations or deviations were identifie Six j previously identified open items were closed and one open item updated in 'i paragraph 2. Five new open items are listed in caragraph 3 and respectively discussed in paragraphs 5, 9, 11, 12, and 1 s'905300114 890510 l PDR ADOCK 05000445 j G PNV  ;

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DETAILS'

1 ~. Persons Contacted l TU Electric

• A. B. Scott, Jr. , Vice President, Nuclear Operations R. J. Adams, Supervisor, Instruments and Controls (I&C) Engineering

• R. A. Beleckis, Staff Emergency Planner

• R. Blevins, Manager, Technic 61 Support

• D. M. Bozeman, Chemistry / Environmental Manager R. E. Fishencord, Radiation Protection Supervisor L. N. Carbarino, Chemist, Technical Support Chemistry A. J. Glass, Staff Engineer, Unit 1 Test Group

• W. G. Hartshorn, Supervisor, Operations QA Surveillance

• D. L. Hubbard, Supervisor, Maintenance and Engineering Training J. D. Kidd, Preventive Maintenance Coordinator

• R. B. McCamey, Staff Chemist J. F. McMahon, Director, Nuclear Training

• F. P. Miller, QA Audit Engineer G. B. Moore, Chemistry Supervisor R. W. Nichols, Radiation Protection Instrument Technician J. C. Pickett, I&C Staff Engineer

• R. J. Prince, Assistant Radiation Protection Manager A. H. Redlow, Jr. , Radiation Protection Supervisor

• E. J. Schmitt, Radiation Protection Manager

• J. C. Smith, Plant Operations T. G. Spalding, Staff Chemist R. L. Theimer, Chemistry Supervisor  !

• M. O. Wadlington, Manager, Technical Support Chemistry S. M. Ward, Senior Engineer, Results L,igineering Communications

• J. R. Waters, Licensing Engineer

• J. E. White, Chemistry Training Program Coordinator Others

• E. Ottney, CASE Program Manager

• R. F. Warnick, Assistant Director for Inspection Programs, NRC

• Denotes those present during the exit interview on April 21, 198 . Followup on Previous Inspection Findings (92701)

(Closed) Open Item (445/8333-23; 446/8317-23): Operability of Portable Radios for Control Room and Roving Operators - This item was identified in NRC Inspection Report 50-445/83-33; 50-446/83-17 and involved the lack of a fully operational radio communications system between the control room and roving operators for use during normal and emergency operations. The NRC inspector reviewed the licensee's radio system installation and the

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results of their operability test The results of the operability tests were found satisfactory. The NRC inspector verified that radio communications could be established between various locations in Unit 1 and the Unit I control room, technical support center.(TSC), and emergenc operations support center (OSC).

(0 pen) Open Item (445/8333-57; 446/8317-57): Continuous Iodine Monitors in the Unit -1 TSC and Emergency OSC - This item was identified'in NRC Inspection Report 50-445/83-33;.50-446/83-17 and involved the installation of continuous iodine monitors in the Unit 1 TSC and emergency OSC.for use during emergency response operations. This item was further discusse'd in e NRC Inspection Report 50-445/84-43; 50-446/84-17 and noted several instrument-deficiencies including their failure to operate at the time of the inspection in November 1984. During this inspection, the NRC

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inspector reviewed the licensee's emergency equipment inventories in the Unit 1 TSC and emergency OSC, and determined that a portable continuou iodine monitor was available for use in both locations. These instruments were new and of a different manufacturer and design than the instrumer.ts described in NRC Inspection Report 50-445/84-43; 50-446/84-17 as having several design deficiencies. An inspection of the new instruments indicated that the NRC inspector's concerns involving air flow had been resolved. .The NRC inspector reviewed the licensee's Emergency Preparedness Procedure EPP-204, " Activation and Operation of the Technical Support Center," Revision 7, dated February 28, 1989, and verified  ;

habitability of- the TSC, whea activated .is to be continuously monitored

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using an area radiation monitor and a portable continuous radioiodine monitor capable of detecting radiciodine concentrations as low as 1.0.E-07 uCi/cc. The NRC inspector reviewed the Radiation Protection Instructions RPI-919, " Calibration of the Portable Continuous Iodine Monitor," Revision 0, dated July 21, 1988, and RPI-920, " Operation of'the Portable Continuous Iodine Monitor," Revision 0, dated July 21, 198 These procedures provide instructions on how to perform the semiannual instrument calibration and startup and operation of the portable

! continuous iodine monitors. The licensee's procedures require verification of detector operability by performing an instrument response check to a known radioactive source and an alarm function check based on an_ alarm setpoint determined during the instrument's last calibratio The NRC inspector verified instrument operability of each continuous portable iodine monitor in the Unit 1 TSC and emergency OSC. The NRC inspector noted the following items to improve the operation of these portable iodine monitors:

I Install a continuous strip chart recorder to the output of the LABTECH scaler / analyzer to provide a continuous record of air activity for trending and monitoring of dat Add the recording of the current alarm setpoint value on the monitor data sheets RPI-920-1 and RPI-920-2 for easy and ready referenc Install a red flashing light in conjunction with the audible alarm on the LABTECH scaler / analyze This item remains open pending licensee's evaluation and actions to resolve the noted instrument operational improvements.

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(Closed) Open Item (445/8333-70; 446/8317-70): Comparison of. Primary and Secondary Meteorological Tower Data This item was identified in NRC Inspection Report 50-445/83-33; 50-446/83-17 and involved the lack of a real-time. comparison of-10-meter instrument _ data between the primary meteorological tower and the backup meteorological tower. 'The NRC-inspector reviewed the results of a study performed during the. period -

October.1-through December 31, 1988, which compared the wind speed data, wind direction data, and the sigma theta data from the primary and backup meteorological towers at the 10-meter level'. The results of this stud indicated that both wind speed and wind direction parameters from the backup tower provided good-representativeness when. compared to.the primary tower data. The wind speed data and wind direction data from both towers

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were-essentially the'same under all meteorological-conditions examine The results of the sigma theta data from.the two meteorological towers indicated- that for 94 percent of the time the Pasquill stability classes-typed by the backup meteorological tower sigma theta value were identical or within one' stability class difference typed by the primar meteorological tower sigma theta value. ' Based on the results of the 3-month study, it was concluded that use.of the 10-meter backup meteorological tower. wind speed, wind direction, and/or sigma theta data during occurrences of missing counterpart data from the 10-meter level of ;j the primary meteorological tower will not result in any adverse impact on I either. radiation protection actions or emergency radiological dose calculations (Closed).Open Item (445/8443-01): Postaccident Sampling of Radioactive Liquids Introduced to the Liquid Radioactive Waste System - This item was identified in NRC Inspection Report 50-445/84-43 and involved the fact that the-the licensee had not evaluated and taken action as necessary to ensure that sampling and analysis of lfquids introduced into the liquid radwaste system, following a reactor incident, could be performed without creating a concurrent accident situation and without any personnel exceeding the 10 CFR Part 50 GDC-19 limits on personnel radiation exposure. The NRC inspector reviewed the licensee's evaluation of postaccident sampling and analysis of radioactive liquids following a reactor incident. It was determined-that procedures had been developed for processing, sampling, and analysis of highly contaminated liquid radioactive waste. A dose rate evaluation had been performed for sampling and analysis of a liquid radioactive waste sample based on source term information from the TMI-2 incident. The results of the evaluation indicated.that station personnel could safely perform all the activities associated with sampling and analysis of highly radioactive liquids from !

-the liquid radioactive. waste system without exceeding 10 CFR

.Part 50 GDC-19 radiation exposure limit (Closed) Open Item (445/8442-01; 446/8416-01): Gaseous Waste Representative Sampling - This item was identified in NRC Inspection Report 50-445/84-42; 50-446/84-16 and involved the fact that the licensee had not verified that the sample taken from a gas decay tank was representative of the entire waste gas tank volume. The NRC inspector reviewed the licensee's calculations for mixing the contents of a gas decay tank using the waste gas compressor and the volume necessary to purge'the sample lines. The licensee's Chemistry Procedure CHM-516,

" Sampling and Analysis of Gaseous Waste Systems," Revision 2, dated

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October 20, 1987, requires that all gas decay tanks must be isolated and recirculated for a minimum of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to ensure thorough mixing of the tank prior to sampling. Also during. sampling of a gas decay tank, a minimum

purge volume of 5 cubic feet is required. These tank recirculation and-L sample line purge volume requirements appear to resolve the NRC's concerns involving representative sampling of the gaseous waste processing system, (Closed) Open Item (445/8807-01; 446/8806-01)

' Environmental Air Sampler Calibration - This item was identified in NRC Inspection Report 50-445/88-07; 50-446/88-06 and involved.the licensee not establishing a required ~ calibration-frequency for the radiological environmental air samplers and had not placed the air samplers on the station equipment-preventive maintenance tracking system for periodic maintenance.and calibration. The NRC inspector verified that the licensee had placed the radiological environmental air samplers on the station's equipment j tracking system and that a maintenance and calibration frequency of l 12 months had been established for the air samplers. The NRC inspector  ;

reviewed the licensee's procedure for calibration of the air . sampler's '

flow indicator and verified that all of the 13 radiological environmental

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air samplers had'been calibrated in 1988 and were scheduled for preventive .)

maintenance and calibration in 198 (Closed) Open. Item (445/8807-02; 446/8806-02): Meteorological Instrumentation Reliability - This item was identified in NRC Inspection Report 50-445/88-07; 50-446/88-06 and involved the licensee not demonstrating a 12-consecutive-month joint data recovery of. greater.than 90 percent from the meteorological tower instrumentation and documenting the test results prior to station operation. The NRC inspector reviewed the licensee's results of a reliability test of joint meteorological instrumentation data recovery for the period January 1988 through March 1989 and verified that the meteorological-data recovery for each primary meteorological tower parameter, as well as jointly, was greater than 90 percent for the documented 15-month perio , Open Items LAn open item is a matter that requires further review and evaluation by the NRC inspector or licensee. Open items are used to document, track,

'and ensure adequate followup on matters of concern to the NRC inspecto The following open items were discussed with the licensee during the exit interview on April 21, 1989:

Open Item Description Paragraph 445/8921-01; 446/8921-01 Corporate Technical Support 5a Chemistry Organization 445/8921-02; 446/8921-02 Primary Chemistry Sampling 9 System 445/8921-03; 446/8921-03 Secondary Chemistry Sampling 11 System l

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445/8921-04; 446/8921-04 Facilities and Equipment 12 445/8921-05; 446/8921-05 Postaccident Sampling System 13 4. NRC Inspector Observation The following is an observation the NRC inspector discussed with the licensee during the exit interview on April 21, 1989. This observation is not a violation, deviation, unresolved item, or open ite This observation was identified for licensee consideration for program improvement, and the observation has no specific regulatory requirement The licensee stated that the observation would be evaluate Chemistry / Environmental Section Staffing The licensee's present chemistry staff of 16 technicians may not be adequate to support Unit 1 startup and complete all routine required operation . Organization and Management Controls (83522]

The NRC inspector reviewed the licensee's corporate technical support chemistry (CTSC) group and onsite chemistry / environmental section (C/ES)

organization and staffing to determine agreement with commitments in Chapter 13 in the Final Safety Analysis Report (FSAR) and compliance with the requirements in Section 6.2 of the Unit 1 draft TS, Corporate Technical Support Chemistry Organization The NRC inspector reviewed the CTSC group organizational structure and staffing to support CPSES chemistry activitie The CTSC organization includes area chemical coordinators who are assigned to various plants within the corporate system and report chemistry activities directly to the CTSC manager. It was determined that an area chemical coordinator supported by one staff chemist had been assigned full time to support CPSES chemistry activitie The NRC inspector reviewed the Nuclear Engineering and Operations Procedure, NE0 2.17,

" Plant Water Chemistry Program," Revision 2, dated December 2, 1987, and determined that the procedure outlined the general responsibilities of the CTSC manager in relationship to CPSES water chemistry activities. The NRC inspector was concerned that the CTSC group had not developed a program description or implementing procedures to support the general responsibilities outlined in NEO 2.1 The NRC inspector was also concerned that the CTSC group had not established specific job / position descriptions for the CTSC staff assigned to CPSES which would describe the minimum qualification requirements, training requirements, and assignment of ,

job responsibilities to interface with the CPSES chemistry staf This item is considered open (445/8921)/(446/8921)-(01) pending:

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l Development of a corporate chemistry / radiochemistry _ program description to support.CPSE ~

Development of-specific job / position descriptions uefining CPSES assigned staff minimum qualification and training requirement '

- Development of: procedures which define the responsibilities and-interface'with the onsite chemistry / radiochemistry staf *

Development of implementing procedures governing.CTSC activities within the assigned areas of responsibilit Onsite Chemistry / Environmental Section Organization

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~.The NRC inspector' verified that.the organizational structure of the C/ES was as defined _in-the FSAR and draft TS. The NRC inspector reviewed the C/ES. staff assignments and management: controls for the implementation of the CPSES water chemistry and radiochemistry programs. The NRC inspector verified that the duties and responsibilities of the C/ES staff were adequately described in approved procedures and position descriptions. Selected procedures,-

listed in the attachment to this report,. were reviewe The NRC inspector reviewed the staffing of the C/ES'and determined

.that,all but-one chemistry supervisor. position and one chemistry technician position of the 26 technical staff positions approved for CPSES Unit 1 operation were filled. The number of C/ES personnel were in accordance with licensee commitments. However, the NRC inspector noted that the 16 chemistry technicians presently on staff to support Unit I startup and operation appeared not to be enough to meet staffing requirements for routine shift rotation and also complete all additional required startup testing tasks. This observation was discussed with the licensee during_the inspection and at the exit interview on April.21, 1989. The licensee agreed to evaluate the present workload and overtime requirements of the present chemistry technician staff and take necessary action to resolve the NRC inspector's concer The NRC inspector determined that the chemistry staff had experienced a personnel turnover of approximately 75 percent since the previous NRC inspection of this area in September 198 No violations or-deviations were identifie . Chemistry / Environmental Section Personnel Qualifications (83523)

The NRC inspector reviewed the qualifications of the chemistry staff _to ;

determine agreement with the commitments in Chapter 13.1.3 of the FSAR and compliance with the requirements in Section 6.3 of the Unit 1 draft T .t)

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The NRC inspector reviewed the education and experience backgrounds of the present chemistry staff and determined that all chemistry technical staff met the education and experience qualification requirements for chemistry and radiochemistry personnel required in the FSAR and draft T No violations or deviations were identifie . Chemistry / Environmental Section Personnel Training (83523)

The NRC inspector reviewed the licensee's chemistry / radiochemistry training program to determine agreement with the commitments in Chapter 13.2 of the FSAR and compliance with the requirements in Section 6.4 of the Unit I draft T The NRC inspector discussed the training program for chemistry and radiochemistry personnel with the chemistry training program coordinator and the maintenance and engineering training supervisor. The NRC inspector reviewed the nuclear training department chemistry staff qualifications, chemistry training facilities, chemistry training program procedure, chemistry technician task analyses, chemistry technician qualifications manual, proposed initial and continuing chemistry training programs, chemistry course development progress, and INPO accreditation schedule and progress. The NRC inspector found that the licensee's chemistry training program was being developed in accordance with INPO accreditation guidelines and was meeting the licensee's proposed development schedul It was determined that the chemistry training program was in the task analysis and objectives development stage of INPO accreditation. The licensee has proposed a schedule to submit to INPO the chemistry training program self evaluation report in December 1989 with a total chemistry training program completion and accreditation date of April 199 No violations or deviations were identifie . Primary Chemistry Program (84525]

The NRC inspector reviewed the licensee's Unit 1 primary chemistry program  ;

including establishment and implementation of a chemistry control program for the reactor coolant system and bo'ated r water sources and a quality l control (QC) program for chemical measurements to determine agreement with the commitments in Chapters 5 and 9 of the FSAR and compliance with the requirements in Sections 3/4.1.2.5, 3/4.4.6, 3/4.4.7, 3/4.5.1, 3/4.5.4, 3/4.6.2.2, and 6.8 of the Unit I draft T The NRC inspector reviewed the lictesee's Unit 1 primary chemistry program and found that it met the requirements of the FSAR and the Uait 1 draft  ! '

T It was verified that the licensee's administrative procedures, surveillance procedures, chemical control procedures, instrument calibration and QC procedures, and analytical procedures had been completed and approve I The licensee had completed and approved procedures to provide surveillance of TS requirements in the primary chemistry area, i

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I The NRC inspector determined that the type and quantity of analytical instrumentation in the radiochemistry laboratory and counting room to be adequate to perform the analysis requirements as specified in the FSAR and the Unit I draft TS. The licensee had calibrated and put into operation all of the radiochemistry laboratory and counting room analytical instrumentation according to procedure. The QC program was being implemented on all operating laboratory equipmen The licensee had developed approved procedures for the preparation, accountability, and QC of nuclear instrument radioactive calibration standards traceable to the National Institute of Standards and Technology ps recommended by ANSI N323-197 The NRC inspector inspected the radiochemistry counting room and reviewed the status of the counting instrument calibration and QC programs to determine agreement with the recommendations of ANSI N323-1978 and Regulatory Guide 4.15. The liquid scintillation spectrometer was calibrated for tritium analysis and a quench curve calibration had been established. The alpha / beta gas proportional counting systems were calibrated for gross alpha and beta measurements of planchet samples. The gamma spectrometer system and associated high purity germanium detectors were calibrated for the principal counting geometries at various shelf distances from the detectors. The QC program for the nuclear counting instruments had been implemented and instrument QC control charts were being kept updated. The instrument's calibration records were found in order and according to procedur No violations or deviations were identifie . Primary Chemistry Sampling Systems (84525)

The NRC insoector reviewed the licensee's primary chemistry sampling j system to determine agreement with the commitments in Chapters 9 and 11 of the FSA (

The NRC inspector inspected the Unit 1 primary chemistry sampling are The Grab Sample Hood Assembly (Primary Sample Panel) brings samples from the reactor coolant system and reactor auxiliary systems to a common sampling panel located in the auxiliary building on the same elevation as I the radiochemistry laboratory and counting room. Grab sample capability is provided for pressurized and nonpressurized samples of the various reactor systems and their components. At the time of the inspection, the Unit 1 Grab Sample Hood Assembly was installed and startup testing of the panel instrumentation, valve lineups, and sample line verifications was in progres {

l The licensee had developed sampling procedures to operate the primary i sample panel and obtain grab samples of the primary reactor coolant i systems and auxiliary systems. The NRC inspector reviewed the sampling !

procedures and determined that they provided sufficient guidance in the proper techniques for collection of specific grab sample The licensee's !

procedures appeared to be adequate for sampling of the primary reactor coolant system and associated auxiliary systems.

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'This item is'c'onsidered open (445/8921)/(446/8921)-(02) pending completion

, 'of the startup testing of the Grab Sample Hooa Assembly and subsequent NRC l inspector review and approval of'the' completed startup test procedure

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L prior.'to Unit 1 initial criticalit No violations or deviations were identifie . Secondary Chemistry Program (79501,'79502)

The NRC _ inspector reviewed the licensee's Unit I secondary cheo stry program including establishment and implementation of a water chemistr control program and a QC program for chemical meartrements to determine agreement with commitments in Chapter 10 of the FSAR and compliance.with the requirements in Sections 3/4.7.1.4 and 6.8 of the Unit I draft T The NRC inspector' reviewed the licensee's Unit 1 secondary chemistry-program and found that it met the requirements of the FSAR and the Unit 1 draft TS. It was verified that all secondary chemistry analytical procedures, chemical control procedures, surveillance procedures, secondary chemical process systems operations procedures, and instrument calibration and QC procedures had been completed, approved, and teste The licensee'* procedures appeared to be adequate to monitor'and control

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the secondarv chemistry program. The secondary chemistry limits for operation were found to be very restrictive and based on Electric Power Research. Institute guideline The licensee's secondary chemistry laboratory. was . fully equipped and operational'to support startup activities. The NRC inspector determine that the type and quantity of analyt kal instrumentation in the secondary laboratory to be adequate to suppor* startup activities and perform the analysis requirements as specified in the FSAR and the Unit-1 draft T The NRC inspector verified that the analytical instrumentation in the secondary chemistry. laboratory had been calibrated and a QC program had been. implemented in accordance with CPSES procedure No' violations or deviations were identifi? . Secondary Chemistry Sampling System (79501, 79502)

The NRC inspector reviewed the licensee's unit 1 secondary chemistry sampling system to determine agreement w .h the w mitments in Chapter 10 of the FSAR.

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The NRC inspector inspected the Unit I secondary chemistry sampling area The secondary chemistry sample panel, steam generator blowdown sample panel, and condensate storage tank sample panel, were nearly installe Some construction activities still needed to be completed. The licensee had not installed a sample sink at the condensate storage tank sample panel.. The sample panels were in various stages of startup testing for the panel process instrumentation, valve lineups, and sample line verification l L--____--_______-______________

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. The licensee had developed sampling procedures to operate and obtain grab samples from the various secondary chemistry systems. The NRC inspector reviewed the sampling procedures and determined that they provided adequate guidance to collect specific grab samples. The licensee's

procedures appeared to be adequate for sampling of the secondary water 4 chemistry systems.

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The licensee had approved procedures for the operation, calibration, and QC of the secondary in-line process instrumentation. The NRC inspector inspected the secondary chemistry in-line process instrumentation for Unit 1 and verified that it had been installed and calibrated. A QC program for the in-line process instruments had been developed but was not

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fully implemented since startup testing of the s.condary sample panels and l process instrumentation was still in progres '

This item is considered open (445/8921)/'446/8921)-(03) pending completion i of the following items prior to Unit I initial criticality:

Installation of a sample sink at the condensate storage tank sample pane '

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Construction in the areas of the secondary chemistry sample panel Startun testing of the various secondary sample panels and subsequent NRC 1';pector review and approval of the completed startup test proceture .

No violations or deviations were identifie , 12. Facilities and Equipment (84525, 79501)

The NRC inspector inspected the facilities and equipment to be used by the chemistry staff in performing their various chemistry support responsibilities. The following facilities were inspected: corrosion laboratory, water production laboratory, secondary chemistry laboratory,

, primary chemistry laboratory, and radiochemistry counting laboratory. The NRC inspector determined that all the laboratories were fully equipped and operational to support Unit 1 startup activitie However, it was noted that in the primary chemistry laboratory the construction modifications to the fume hood ventilation system and the removal of the hot cell were not complete This item is considered open (445/8921)/(446/8921)-(04) pending completion of the fume hood modifications and hot cell removal in the primary

. chemistry laboratory prior to Unit 1 initial criticalit .

No violations or deviations were identifie . Postaccident Sampling System (84525)

,9 The NRC inspector reviewed the licensee's Unit 1 postaccident sampling system (PASS) to determine compliance with requirements in NUREG-0737,

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._ Item II.B.3 and Section 6.8.3.d of the Unit I draft T _ _ _ _ _ _

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The NRC inspector. inspected the areas in Unit 1 where the PASS sampling modules and operating modules were installed. The licensee had completed procedures for operation of the PASS. The PASS equipment was installed and preoperational. testing had been completed. The in-line pH and conductivity instrumentation had been calibrated and tested. Operator training on the PASS had been conducte The NRC inspector noted that during a recent emergency drill an internal QA audit identified several deficiencies in the bperation of the PAS The licensee had not collected and analyzed reactor coolant and containment atmosphere samples under sin ulated accident conditions. The licensee had not developed a surveillance and preventive maintenance program to ensure spontaneous aperation of PASS sampling and analysis equipment upon deman This item is considered open (445/8921)/(4 6/2921)-(05) pending the following to be completed prior to Unit 1 exceeding 5 percent power:

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Resolution of internal QA audit deficiencie Testing and calibration of the in-line analytical instrumentation and the development and implementation of a preventive maintenance and QC program on the PAS Verification of system performance by collecting samples of reactor coolant and containment atmosphere under simulated accident conditions and performing required comparative analyses with routine analyses of the reactor coolant and containment atmosphere to verify representative samplin No violations or deviations were identifie . QA Program (83522)

.The NRC inspector reviewed the licensee's internal audit and surveillance programs to determine agreement with the commitments in Chapters 1 .

and 17.2 of the FSAR and compliance with the requirements in  !

Section 6.5.2.8 of the Unit I draft T The NRC inspector reviewed selected QA surveillance and audit procedures, surveillance and audit schedules for 1988 and 1989, and the qualifications of surveillance technicians and auditors. Surveillance and audit reports of QA activities performed during 1986, 1987, and 1988 in the areas related to the chemistry / radiochemistry program were reviewed for scope to ensure thoroughness of program evaluation. The NRC inspector noted that the QA surveillance and QA audits were designed to determine compliance with CPSES procedures and draft IS. The NRC inspector reviewed surveillance and audit plans, checklists, and findings and confirmed that the identified findings were reviewed by licensee's management and that corrective actions to findings had been completed and documented

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1 in accordance wi_th DA procedure The NRC inspector determined'that the surveillance and avaits were performed by qualified personne1~

knowledgeable in chemistry and radiochemistry activities at nuclear power facilitie Selected documents listed in Attachment I to this report were

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reviewe ~No violations or deviations were. identifie . Procedures The NRC inspector reviewed the licensee's procedures to determin compliance with the requirements in Section 6.8 of the Unit I draft T The NRC. inspector reviewed selected nuclear engineering and operations procedures,-station administration manual procedures,

' chemistry / radiochemistry manual procedures, and chemistry and radiochemistry instruction manual procedures which direct'the administration and operations of the C/ES. The licensee's procedures appeared to meet the regulatory requirements and recommendations of the regulatory guides and industry standards which are regarded as being necessary:to effectively implement a water chemistry / radiochemistry progra No violations'or deviations were identifie . Exit Interview The'NRC inspector met with the NRC Assistant Director for Inspection Programs at CPSES and the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on April 21, 1989. The NRC inspector summarized the scope of the inspection and discussed the closure of six previously identified open items and details of the current inspection findings which resulted in the generation of five new open item The NRC

inspector stated that the open items' dealing with plant systems and construction must be resolved prior to Unit 1 initial criticality except for the PASS open item which must be resolved prior to Unit 1 exceeding 5 percent power. The licensee stated that they would review and evaluate the NRC inspector's findings and take action as necessary to resolve the identified open item . .. .. _ - _ _ _ _ _

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f- I ATTACHMENT Comanche Peak Steam Electric Station NRC Inspection Report: .50-445/89-21 and E9-446/89-21 Documents Reviewed Title Revision Date 1. Nuclear Engineering and Operations (NEO) Procedures NEO 2.17, Plant Water Chemistry Program 2 11/02/87 NE0 2.20, Senior Management QA Overview Program 3 11/13/87 NE0 3.06, Reporting and Control of Deficiency 3 11/14/88 Reports NE0 3.07, Quality Assurance Audit Program 2 03/23/89 2. Nuclear Engineering and Operations Policy Statements Policy No. 21, Plant Water Chemistry Program 1 07/01/88 3. Station Administrative (STA) Procedures STA-101, Nuclear Operations Organization 6 02/02/88 STA-609, Reactor Coolant Water Chemistry Control 0 Draft Program STA-610, Secondary Water Chemistry Control Program 3 12/01/87 STA-702, Surveillance Test Program 6 04/15/88 4. Chemistry / Radiochemistry Manual (CHM) Procedures CHM-101, Chemistry / Radiochemistry Administrative 7 07/15/88 Control CHM-102, Control and Storage of Chemicals and Reagents 4 07/13/88 CHM-104, Chemistry / Radiochemistry Quality Control 6 08/11/88 Program CHM-106, Chemistry Organization and Responsibilities 2 07/08/88 CHM-107, Laboratory Safety Program 3 03/15/88 i

CHM-109, Chemistry Action Guidelines for Out-of- 0 02/09/88 l i

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CHM-111, Post Accident. Sampling: Program 0 03/18/88

. CHM-501, Chemistry Control of the Steam Generators ~ 3- 03/29/88 n CHM-502,' Chemistry Control of-the Water Treatment 3 09/16/88 System CHM-503, Chemistry Control of the Condensate-System ;4 09/16/88 CHM-504, Chemistry Control of the' Feedwater. System 3 '09/16/88 CHM-505, Chemistry Control of the Secondary Support 3 09/16/88 Systems:

CHM-506, Chemistry Control of the Primary System 3 08/18/88 CHM-508,l Chemistry Control of the Primary Cooling 4 .01/20/88.-

. Systems

CHM-509, Chemistry Control of the Primary Makeup System 3 03/14/8 CHM-510,. Chemistry. Control . of the Boron Recovery System 2 04/30/86 CHM-511,. Chemistry Control of the Safeguards System

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3 01/27/88 CHM-513, Operation of the Process Sampling System 1- 10/10/84 CHM-514~,.0peration of the Secondary Sampling System' 1 08/10/88 CHM-519, Chemistry Control of the Refueling Water 3 02/13/89-CHM-703, Technical Specification Surveillance of the 1 10/16/84 Refueling Water Storage' Tank CHM-706, Technical Specification Surveillance of the 2 08/18/88-Secondary Coolant System CHM-707, Technical Specification Surveillance of the 2 09/28/87 Diesel Fuel-011 Tanks Quality Assurance (0A) Surve111ances and Audits NQA 3.06, Reporting and Control of Deficiency Reports 3 11/14/88

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NQA 3.23, Surveillance Program 2 02/13/89 Surveillance Activities Summary (SAS) - 87002, " Hot Lab Chemistry Control of CCW Corrosion Chemicals and Analytical Techniques," dated January 1, 1987 SAS-87022, " Chemistry Support of the CCW Hx and DGSWC

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Chemical Cleaning," dated February 18-25, 1987 SAS-87040, " Counting Room Radiochemistry," dated April 15, 1987 SAS-87080, " Chemistry M&TE and Reagent Quality Control,"

dated August 3-10, 1987 Surveillance Report (SR) No. 05-87-0006, " Diesel Fuel Receipt, alysis, and Storage for Unit 3 EDG's,"

dated October 14-21, 1987 l

SR No. 0S-87-0017, " Steam Generator Chemistry Control -

Unit 1," dated November 12-18, 1987 SR No. OS-88-0003, " Chemistry Training Records Control,"

dated December- 28, 1987, through - January 7, 1988 SR No. OS-88-0018, " Chemistry Laboratory Reagent Control and Hot'sekeeping Requirements," dated February 25, 1988 SR No. 05-88-0025, " Radiochemistry M&TE Control," dated March 11, 1988 SR No. 05-88-0029, " Secondary Chemistry Laboratory and Water Production Laboratory M&TE Control," dated March 17-18, 1988 SR No. 05-88-0051, " Chemistry Laboratory Analysis Statistics," dated April 25-28, 1988 SR No. 05-88-0096, " Chemistry Support of Unit 2 Layup,"

dated July 19-25, 1988 SR No. 05-88-0104, " Chemistry Laboratory Activities,"

dated September 15-16, 1988 SR No. 05-88-0138, " Quality Control (VAP Program),"

dated October 26-31, 1988 SR No. 05-88-0163, " Diesel Fuel Oil Procurement, Testing, and Records," dated December 15-16, 1988 QA Audit Report: TUG-86-19, " Secondary Chemistry,"

performed August 18-22, 1986 QA Audit Report: TUG-87-12, " Measuring and Test Equipment," performed May 26 through June 5, 1987 QA Audit Report: TUG-87-21, " Secondary Chemistry,"

performed August 17-21, 1987 l

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QA Audit Report: TUG-87-25, " Primary Chemi stry,"

performed September 21-25, 1987 i

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QA Audit Report: TUG-88-02, "Offsite Dose Calculation Manual," performed January 11-14, 1988 QA Audit Report: TUG-88-16, " Chemistry," performed 1 July 25 through August 2, 1988 QA Audit Report: TUG-88-27, " Chemical / Combustible and Lubricant Control Program," performed October 7 through November 2, 1988 l

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