Text

IR 05000498-06-008, IR 05000499-06-008; January 23-26 2006; South Texas Project Electric; Radiation Monitoring Instrumentation & Protective Equipment; Radioactive Gaseous & Liquid Effluent Treatment & Monitoring Systems; & Radiological Envi
	ML060600168
Person / Time
Site:	South Texas
Issue date:	02/27/2006
From:	Shannon M P; Plant Support Branch Region IV
To:	Sheppard J J; South Texas
References
	-RFPFR IR-06-008
	Download: ML060600168 (20)
	v • d • e

February 27, 2006James J. Sheppard, President and Chief Executive Officer

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, Texas 77483SUBJECT:SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION - NRCRADIATION SAFETY TEAM INSPECTION REPORT 05000498/2006008;

05000499/2006008 Dear Mr. Sheppard:

On January 26, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspectionat your South Texas Project Electric Generating Station, Units 1 and 2, facility The enclosedRadiation Safety Team inspection report documents the inspection findings which were

discussed with Mr. Gary Parkey, Executive Vice President of Generation and General Plant

Manager, and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.

The team reviewed selected procedures and records, observed activities, and interviewed

personnel. Specifically, the team evaluated the inspection areas within the Radiation ProtectionStrategic Performance Area that are scheduled for review every two years. These areas are:*Radiation Monitoring Instrumentation*Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems

Radioactive Material Processing and Transportation

Radiological Environmental Monitoring Program and Radioactive Material ControlProgram This inspection report documents one self-revealing, non-cited violation of very low safetysignificance (Green). Additionally, one licensee-identified violation, which was also determined

to be of very low safety significance, is listed in Section 4OA7 of this report. If you contest

these non-cited violations or their significance, you should provide a response within 30 days of

the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the

Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive,

Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear

Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at theSouth Texas, Units 1 and 2, facility.

STP Nuclear Operating Company-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be made available electronically for public inspectionin the NRC Public Document Room or from the Publicly Available Records (PARS) com

ponentof NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this inspection, we will be pleased to discuss themwith you. Sincerely, //RA//

Michael P. Shannon, ChiefPlant Support Branch

Division of Reactor SafetyDockets: 50-498 50-499

Licenses: NPF-76

NPF-80Enclosure:NRC Inspection Report 05000498/2006008; 05000499/2006008w/Attachment: Supplemental Informationcc w/enclosure:E. D. Halpin

Vice President, Oversight

STP Nuclear Operating Company

P.O. Box 289

Wadsworth, TX 77483S. M. Head, Manager, LicensingSTP Nuclear Operating Company

P.O. Box 289, Mail Code: N5014

Wadsworth, TX 77483C. Kirksey/C. M. CanadyCity of Austin

Electric Utility Department721 Barton Springs Road

Austin, TX 78704J. J. Nesrsta/R. K. TempleCity Public Service Board

P.O. Box 1771

San Antonio, TX 78296

STP Nuclear Operating Company-3-Jack A. Fusco/Michael A. ReedTexas Genco, LP

12301 Kurland Drive

Houston, TX 77034Jon C. WoodCox Smith Matthews

112 E. Pecan, Suite 1800

San Antonio, TX 78205A. H. Gutterman, Esq.Morgan, Lewis & Bockius

1111 Pennsylvania Avenue NW

Washington, DC 20004INPORecords Center

700 Galleria Parkway

Atlanta, GA 30339-3064Director, Division of Compliance & InspectionBureau of Radiation Control

Texas Department of State Health Services

1100 West 49th Street

Austin, TX 78756Brian AlmonPublic Utility Commission

William B. Travis Building

P.O. Box 13326

1701 North Congress Avenue

Austin, TX 78701-3326Environmental and Natural Resources Policy Director

P.O. Box 12428

Austin, TX 78711-3189Judge, Matagorda CountyMatagorda County Courthouse

1700 Seventh Street

Bay City, TX 77414Terry Parks, Chief InspectorTexas Department of Licensing

and Regulation

Boiler Program

P.O. Box 12157

Austin, TX 78711

STP Nuclear Operating Company-4-Susan M. JablonskiOffice of Permitting, Remediation and Registration

Texas Commission on Environmental Quality

MC-122, P.O. Box 13087

Austin, TX 78711-3087Ted Enos4200 South Hulen

Suite 630

Fort Worth, TX 76109

STP Nuclear Operating Company-5-Electronic distribution by RIV:Regional Administrator (BSM1)DRP Director (ATH)DRS Director (DDC)DRS Deputy Director (RJC1)Senior Resident Inspector (JXC2)Branch Chief, DRP/A (CEJ1)Senior Project Engineer, DRP/A (TRF)Team Leader, DRP/TSS (RLN1)RITS Coordinator (KEG)Only inspection reports to the following:DRS STA (DAP)T. Bloomer, OEDO RIV Coordinator (TEB)ROPreports

STP Site Secretary (LAR)Sunsi Review Completed: Yes ADAMS: Yes G No Initials: mps

Publicly Available

G Non-Publicly Available

G Sensitive Non-SensitiveR:\_STP\2006\STP2006-08RP-Team-LC2.wpdRIV:DRS/PSBPSBPSBPSBC:PSBLCCarsonIIGLGuerraLTRicketsonBDBacaDLStearns

/RA//RA//RA//RA/ /RA/02/ 23 /0602/ 27 /0602/ 23 /0602/ 22 /0602/ 27 /06C:PSBC:DRP/AC:PSBMPShannonCEJohnsonMPShannon/RA//RA//RA/02/ 27 /0602/ 27 /0602/ 27 /06OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

Enclosure-1-ENCLOSUREU.S. NUCLEAR REGULATORY COMMISSION REGION IV Dockets:50-498, 50-499 Licenses:NPF-76NPF-80Report No:05000498/2006008

05000499/2006008Licensee:STP Nuclear Operating Company

Facility:South Texas Project Electric Generating Station, Units 1 and 2Location:FM 521 - 8 miles west of Wadsworth Wadsworth, Texas 77483Dates:January 23 - 26, 2006

Inspectors:L. C. Carson II, Senior Health Physicist - Team LeaderB. D. Baca, Health Physicist

G. L. Guerra, Health Physicist

L. T. Ricketson, P.E., Senior Health Physicist

D. L. Stearns, Health PhysicistApproved By:Michael P. Shannon, Chief, Plant Support BranchDivision of Reactor Safety

Enclosure-2-SUMMARY OF FINDINGSIR 05000498/2006008, 05000499/2006008; January 23-26 2006; South Texas Project ElectricGenerating Station; Radiation Monitoring Instrumentation and Protective Equipment;Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems; and Radiological

Environmental Monitoring Program and Radioactive Material Control ProgramThe report covered a one week period of inspection on site by a team of five region-basedhealth physics inspectors. Based upon the results of the inspection, the team reviewed one

self-revealing violation of very low safety significance (Green). The significance of most

findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609, "Significance

Determination Process," (SDP). Findings for which the SDP does not apply may be "Green" or

be assigned a severity level after

NRC management review. The NRC's program foroverseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.NRC-Identified and Self-Revealing FindingsCornerstone: Public Radiation Safety (PS)*Green. The team reviewed two examples of a self-revealing non-cited violation ofTechnical Specification 6.8.1, resulting from the licensee's failure to prevent radioactivematerial from being unconditionally released from a radiologically controlled area. The

first example involved a radiation detection instrument with fixed radioactive

contamination. The second example involved a contaminated lifting sling that was usedto remove equipment and containers from the containment building. In both examples,the radioactive material was identified after it was removed from a radiologically

controlled area but before it left the protected area. Corrective actions for the firstexample involved counseling the responsible individual. Corrective actions for the

second example are still being evaluated. Both examples were entered into thelicensee's corrective action program as Condition Reports 04-4266 and 05-14345.This finding is greater than minor because it was associated with a Public RadiationSafety cornerstone attribute (material release) and it affected the associated

cornerstone objective in that the failure to control radioactive material decreases the

licensee's assurance that the public will not receive unnecessary dose. Using the PublicRadiation Safety Significance Determination Process, the team determined that thefinding had very low safety significance because: (1) the finding was a radioactive

material control finding, (2) it was not a transportation finding, (3) it did not result in

public dose greater than 0.005 rem, and (4) radioactive material was not released from

the protected area more than five times. Additionally, this finding had cross-cutting

aspects associated with human performance. In the first example, a radiation protection

technician failed to maintain direct supervision of the contaminated instrument. In the

second example, the procedural guidance allowed the licensee to use only portable GM

instruments on large items despite the loss of detection sensitivity.

Enclosure-3-Licensee Identified ViolationsOne violation of very low safety significance, which was identified by the licensee, hasbeen reviewed by the team. Corrective actions taken or planned by the licensee have

been entered into the licensee's corrective action program. This violation and corrective

action is listed in Section 4OA7 of this report.

Enclosure-4-Report Details2.RADIATION SAFETYCornerstone: Occupational Radiation Safety [OS]

2OS3Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a.Inspection ScopeThis area was inspected to determine the accuracy and operability of radiationmonitoring instruments that are used for the protection of occupational workers and theadequacy of the program to provide self-contained breathing apparatus (SCBA) to

workers. The team used the requirements in 10 CFR Part 20 and the licensee's

procedures required by technical specifications as criteria for determining compliance.

The team interviewed licensee personnel and reviewed:*Calibration of area radiation monitors associated with transient high and veryhigh radiation areas and post-accident monitors used for remote emergency

assessment*Calibration of portable radiation detection instrumentation, electronic alarmingdosimetry, and continuous air monitors used for job coverage*Calibration of whole body counting equipment and radiation detectioninstruments utilized for personnel and material release from the radiologicallycontrolled area*Licensee Event Reports, audits and self-assessments

Corrective action program reports since the last inspection

Licensee action in cases of repetitive deficiencies or significant individualdeficiencies*Calibration expiration and source response check currency on radiation detectioninstruments staged for use*The licensee's capability for refilling and transporting SCBA air bottles to andfrom the control room and operations support center during emergency

conditions, status of SCBA staged and ready for use in the plant and associated

surveillance records, and personnel qualification and training*Qualification documentation for onsite personnel designated to performmaintenance on the vendor-designated vital components, and the vital

component maintenance records for SCBA units. The inspector completed 9 of the required 9 samples.

Enclosure-5- b.FindingsNo findings of significance were identified.2PS1Radioactive Gaseous And Liquid Effluent Treatment And Monitoring Systems(71122.01) a.Inspection ScopeThis area was inspected to ensure that the gaseous and liquid effluent processingsystems are maintained so that radiological releases are properly mitigated, monitored,and evaluated with respect to public exposure. The team used the requirements in

10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation

Manual, and the licensee's procedures required by technical specifications as criteria for

determining compliance. The team interviewed licensee personnel and reviewed: *The most current radiological effluent release reports, changes to radiationmonitor setpoint calculation methodology, anomalous sampling results, effluent

radiological occurrence performance indicator incidents, self-assessments,

audits, and licensee event reports*Gaseous and liquid release system component configurations*Routine processing, sample collection, sample analysis, and release ofradioactive liquid and gaseous effluent; and Radioactive liquid and gaseous

effluent release permits and dose projections to members of the public *Abnormal releases

Changes made by the licensee to the Offsite Dose Calculation Manual, the liquidor gaseous radioactive wast

e system design, procedures, or operation since thelast inspection*Monthly, quarterly, and annual dose calculations

Surveillance test results involving air cleaning systems and stack or vent flowrates*Instrument calibrations of discharge effluent radiation monitors and flowmeasurement devices, effluent monitoring system modifications, effluentradiation monitor alarm setpoint values, and counting room instrumentation

calibration and quality control *Interlaboratory comparison program results

Licensee event reports, special reports, audits, self-assessments and correctiveaction reports performed since the last inspectionThe inspector completed 10 of the required 10 samples.

Enclosure-6- b.FindingsNo findings of significance were identified.2PS2Radioactive Material Processing and Transportation (71122.02) a.Inspection ScopeThis area was inspected to verify that the licensee's radioactive material processing andtransportation program complies with the requirements of 10 CFR Parts 20, 61, and 71

and Department of Transportation regulations contained in 49 CFR Parts 171-180. The

team interviewed licensee personnel and reviewed:*The radioactive waste system description, recent radiological effluent releasereports, and the scope of the licensee's audit program*Liquid and solid radioactive waste processing systems configurations, the statusand control of any radioactive waste process equipment that is not operational or

is abandoned in place, changes made to the radioactive waste processing

systems since the last inspection, and current processes for transferringradioactive waste resin and sludge discharges*Radio-chemical sample analysis results for radioactive waste streams and use ofscaling factors and calculations to account for difficult-to-measure radionuclides *Shipping records for non-excepted package shipments

Licensee event reports, special reports, audits, state agency reports,self-assessments and corrective action reports performed since the last

inspectionEither because the conditions did not exist or an event had not occurred, noopportunities were available to review the following items:*Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,driver instructing, and disposal manifestingThe inspector completed 6 of the required 6 samples. 2PS3Radiological Environmental Monitoring Program (REMP) And Radioactive MaterialControl Program (71122.03) a.Inspection ScopeThis area was inspected to ensure that the REMP verifies the impact of radioactiveeffluent releases to the environment and sufficiently validates the integrity of theradioactive gaseous and liquid effluent release program; and that the licensee's surveys

and controls are adequate to prevent the inadvertent release of licensed materials into

the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensee's procedures

Enclosure-7-required by technical specifications as criteria for determining compliance. The teaminterviewed licensee personnel and reviewed *Annual environmental monitoring reports and licensee event reports

Selected air sampling and thermoluminescence dosimeter monitoring stations

Collection and preparation of environmental samples

Operability, calibration, and maintenance of meteorological instruments *Each event documented in the Annual Environmental Monitoring Report whichinvolved a missed sample, inoperable sampler, lost thermoluminescence

dosimeter, or anomalous measurement*Significant changes made by the licensee to the Offsite Dose Calculation Manualas the result of changes to the land census or sampler station modifications

since the last inspection*Calibration and maintenance records for air samplers, composite watersamplers, and environmental sample radiation measurement instrumentation,

quality control program, interlaboratory comparison program results, and vendor

audits*Locations where the licensee monitors potentially contaminated material leavingthe radiological controlled area [or controlled access area] and the methods usedfor control, survey, and release from these areas *Type of radiation monitoring instrumentation used to monitor items released,survey and release criteria of potentially contaminated material, radiation

detection sensitivities, procedural guidance, and material release records *Licensee event reports, special reports, audits, self-assessments and correctiveaction reports performed since the last inspectionThe inspector completed 10 of the required 10 samples. b.FindingsIntroduction. The team reviewed two examples of a Green, self-revealing non-citedviolation of Technical Specification 6.8.1, resulting from the licensee's failure to preventradioactive material from being unconditionally released from the radiologically

controlled area.Description. On March 31, 2004, a radiation protection technician observed a radiationdetection instrument outside a radiologically controlled area behind the Unit 2 equipment

hatch lay down area. Upon further examination, the radiation protection techniciannoted a "Radioactive Material" label on the instrument. This alerted the radiation

protection technician to the fact that radioactive material had been unconditionally

released from a radiologically controlled area. Surveys of the instrument indicated no

loose radioactive contamination, but did identify 3.7 to 3.9 nanocuries of fixed

Enclosure-8-radioactive contamination. The licensee concluded that another radiation protectiontechnician assigned to frisk items in the area left the instrument unattended and failed to

return it to the radiologically controlled area at the end of the work shift.On October 29, 2005, an individual carrying a lifting sling from the maintenanceoperations facility caused a contamination monitor in the east gatehouse to alarm. Radiation protection personnel responded to the alarm and determined the sling was

contaminated with radioactive material (approximately 149 nanocuries). The licensee

concluded that the radioactive material originated from equipment and containers riggedout of the reactor containment building during outages. Prior to being released from the

containment building, the all items were surveyed using portable Geiger-Muller (GM)

friskers. However, the portable GM friskers were not capable of detecting the all

quantities of radioactive material present on the items. Even though it was not in the

containment building, the lifting sling captured and concentrated small amounts ofradioactive material in the webbing. The lifting sling was also surveyed with portable

GM friskers and again the radioactive material was not detected. A more sensitive

measurement device, such as a tool monitor with scintillation detectors was not requiredby the licensee's procedure to supplement the portable GM friskers and therefore was

not used. In both of these examples, although the radioactive material was allowed outsideradiologically controlled areas, it was not removed from the licensee's protected area.Analysis. NRC regulations provide no minimum level of licensed radioactive materialthat can be disposed of in a manner other than as radioactive waste or transferred to a

licensed recipient, with one exception in 10 CFR 20.2005. In the first example, the licensee intended the instrument with fixed radioactivecontamination be "conditionally released" from the radiologically controlled area under

the control of a radiation protection technician. However, when the radiation protectiontechnician using the instrument failed to maintain oversight of it, it was then

unconditionally released. The failure of the radiation protection technician to control

radioactive material outside the radiologically controlled area was a performance

deficiency.In the second example, the licensee failed to detect the radioactive material present inthe lifting sling before it was released from the radiological controlled area. Information Notice No. 85-92, "Surveys of Waste Before Disposal from Nuclear Reactor Facilities,"

and Health Physics Position 073 provide guidance applicable to situations in which small

amounts of radioactive material are accumulated. The guidance states that, "In order to

preclude the unintentional release of radioactive material, a good monitoring program

likely would include careful surveys using equipment and techniques for detecting very

low levels of radioactivity. Surveys conducted with portable survey instruments using

pancake GM probes are generally more appropriate for small items and small areas

because of the loss of detection sensitivity created by moving the probe and the

difficulties in completely scanning large areas. This does not preclude the use of such

instruments for larger items and areas, if supplemented by other survey equipment or

techniques." The accumulation of small amounts of contamination that escaped

pancake probe detection may be detected using detectors sensitive to gamma radiation,

such as by using a sensitive scintillation detector in a low-background area. Thelicensee did not supplement its surveys made with portable pancake GM probes with

Enclosure-9-surveys made with a sensitive scintillation detector. Therefore, the accumulatedradioactive material was not discovered until an individual attempted to take the lifting

sling from the protected area and entered a more sensitive radiation detection devicelocated outside the radiologically controlled area. The failure to confine radioactive

material to the radiologically controlled area is a performance deficiency. This finding is greater than minor because it was associated with a Public RadiationSafety cornerstone attribute (material release) and it affected the associated