IR 05000445/2004009
| ML043410173 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/06/2004 |
| From: | Shannon M Plant Support Branch Region IV |
| To: | Blevins M TXU Energy |
| References | |
| IR-04-009 | |
| Download: ML043410173 (20) | |
Text
December 6, 2004 M. R. Blevins, Senior Vice President and Principal Nuclear Officer TXU Energy ATTN: Regulatory Affairs Comanche Peak Steam Electric Station P.O. Box 1002 Glen Rose, TX 76043 SUBJJECT: COMANCHE PEAK STEAM ELECTRIC STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000445/2004009 AND 05000446/2004009
Dear Mr. Blevins:
On October 22, 2004, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Steam Electric Station, Units 1 and 2, facility. The enclosed report documents the inspection findings, which were discussed at the conclusion of the inspection with Mr. M. Lucas, Vice President, Nuclear Engineering, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions 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 Protection Strategic 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 Control Program This inspection report documents one self-revealing, non-cited violation of very low safety significance (Green). However, because the finding was of very low safety significance and it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation consistent with Section VI.A of the NRC Enforcement Policy. Additionally, two licensee-identified violations which were determined to be of very low safety significance are listed in this report. If you contest any non-cited violation in this report, 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 the Comanche Peak Steam Electric Station facility.
TXU Energy -2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs 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).
Sincerely,
//RA//
Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-445 50-446 Licenses: NPF-87 NPF-89
Enclosure:
NRC Inspection Report 05000445/2004009 and 05000446/2004009 w/attachment: Supplemental Information
REGION IV==
Dockets: 50-445, 50-446 Licenses: NPF-87, NPF-89 Report: 05000445/2004009 and 05000446/2004009 Licensee: TXU Generation Company LP Facility: Comanche Peak Steam Electric Station, Units 1 and 2 Location: FM-56, Glen Rose, Texas Dates: October 18 - 22, 2004 Inspectors: Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Binesh Tharakan, Health Physicist, Plant Support Branch Donald Stearns, Project Engineer, Branch E, Division of Reactor Projects Approved By: Michael P. Shannon, Chief, Plant Support Branch Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000445/2004009; 10/18/2004 - 10/22/2004; Comanche Peak Steam Electric Station, Units and 2 ; Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems The report covered a one week period of inspection on site by a team of four region-based inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
The team reviewed a self-revealing non-cited violation of Technical Specification 5.5.1, which occurred when the licensee failed on two occasions to sample in accordance with Offsite Dose Calculation Manual requirements. Specifically, non-citedduring the third quarter of 2002 and the fourth quarter of 2003, the licensee failed to maintain portions of composite samples from the plant effluent tanks. The samples are required to be collected monthly and analyzed quarterly. The finding was placed into the licensees corrective action program.
The finding is greater than minor because it is associated with one of the cornerstone attributes (effluent measurement) and affects the cornerstone objective because the failure to implement offsite dose calculation requirements decreases the licensees assurance that the public will not receive unnecessary dose. The team determined that the finding had very low safety significance because: (1) the finding was not a radioactive material control finding, (2) it was an effluent release program finding, (3) the finding impaired the licensees ability to assess dose, (4) the licensee did not fail to assess dose because it was able to assess dose to the public using the remaining composite samples, and (5) it did not result in doses that exceeded 10 CFR Part 50,
Appendix I or 10 CFR 20.1301(d). This finding had crosscutting aspects associated with human performance. When licensee personnel failed to store the samples properly, they directly contributed to the finding (Section 2PS1).
Licensee Identified Violations
Violations of very low safety significance, which were identified by the licensee have been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. These violations and corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a. Inspection Scope
This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees 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 very high radiation areas and post-accident monitors used for remote emergency assessment
- Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage
- Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area
- Self-assessments and audits
- Corrective action program reports since the last inspection
- Licensee action in cases of repetitive deficiencies or significant individual deficiencies
- Calibration expiration and source response check currency on radiation detection instruments staged for use
- The licensees capability for refilling and transporting SCBA air bottles to and from 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 perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee Event Reports The inspector completed 9 of the required 9 samples.
b. Findings
No findings of significance were identified.
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)
a. Inspection Scope
This area was inspected to ensure that the gaseous and liquid effluent processing systems 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 (ODCM), and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- The most current radiological effluent release reports
- Gaseous and liquid release system component configurations
- Radioactive liquid and gaseous effluent release permits and dose projections to members of the public
- Changes made by the licensee to the ODCM, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection
- Monthly, quarterly, and annual dose calculations
- Surveillance test results involving air cleaning systems and stack or vent flow rates
- Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control
- Interlaboratory comparison program results
- Audits, self-assessments, and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Changes to radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, and licensee event reports
- Abnormal releases The inspector completed 10 of the required 10 samples.
b. Findings
Introduction.
The team reviewed a self-revealing, non-cited violation of Technical Specification 5.5.1, which occurred when the licensee failed on two occasions to sample in accordance with ODCM requirements. The violation had very low safety significance.
Description.
The licensee collects monthly liquid samples from the plant effluent tanks.
These monthly samples form a composite sample which is shipped offsite for vendor analysis, quarterly. The vendor conducts analyses for Fe-55, Sr-89, and Sr-90. According to the 2002 and 2003 Annual Effluent Reports, the licensee lost or misplaced a monthly sample during the third quarter of 2002 and during the fourth quarter of 2003. This finding is considered self-revealing because the licensee was alerted to the problem by the absence of the samples.
Analysis.
The failure to maintain required samples for analysis is a performance deficiency. The finding is greater than minor because it is associated with one of the cornerstone attributes (effluent measurement) and affects the cornerstone objective because the failure to implement offsite dose calculation requirements decreases the licensees assurance that the public will not receive unnecessary dose. Because the finding involved an occurrence in the licensee's radiological effluent monitoring program that is contrary to ODCM requirements, the team processed the finding using the Public Radiation Safety Significance Determination Process. Using the process, the team determined that the finding had very low safety significance because:
- (1) the finding was not a radioactive material control finding,
- (2) it was an effluent release program finding, (3)the finding impaired the licensees ability to assess dose,
- (4) the licensee did not fail to assess dose because it was able to assess dose to the public using the remaining composite samples, and
- (5) it did not result in doses that exceeded 10 CFR Part 50, Appendix I or 10 CFR 20.1301(d). This finding had crosscutting aspects associated with human performance. When licensee personnel failed to store the samples properly, they directly contributed to the finding.
Enforcement.
Technical Specification 5.5.1 requires that the ODCM be established, implemented, and maintained. ODCM Surveillance Requirement 4.11.1.1.1 states that radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis program of Table 4.11-1. Table 4.11-1 requires liquids released from plant effluent tanks be sampled during each batch release and a composite analysis conducted quarterly. The licensee violated this requirement when it failed to maintain samples for analysis on two occasions. The finding was documented in the licensees corrective action program by SmartForms 2002-003448 and 2004-000060. Because this violation was of very low safety significance and was entered into the licensees corrective action program, it is being treated as an non-cited violation (NCV), consistent with Section VI.A of the NRC Enforcement Policy: NCV 05000445;05000446/2004009-01, Failure to maintain and analyze composite samples on two occasions.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a. Inspection Scope
This area was inspected to verify that the licensees radioactive material processing and transportation 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 release reports, and the scope of the licensees audit program
- Liquid and solid radioactive waste processing systems configurations, the status and 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 transferring radioactive waste resin and sludge discharges
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting
- Shipping records for non-excepted package shipments
- Audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Licensee event reports and special reports The inspector completed 6 of the required 6 samples.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program (71122.03)
This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees 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, 10 CFR Part 50, Appendix I, the ODCM, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Annual environmental monitoring reports
- Eight air sampling stations and eleven thermoluminescence dosimeter (TLD) monitoring stations
- Collection and preparation of particulate, iodine, and surface water environmental samples
- Operability, calibration, and maintenance of meteorological instruments
- Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement
- Calibration and maintenance records for the licensee air samplers, vendor quality control program, vendor interlaboratory comparison program results, and vendor audits
- Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area and the methods used for 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
- Audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Significant changes made by the licensee to the ODCM as the result of changes to the land census or sampler station modifications since the last inspection
- Licensee event reports and special reports The inspector completed 10 of the required 10 samples.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
- Radiation Monitoring Instrumentation (Section 2OS3)
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)
- Radioactive Material Processing and Transportation (Section 2PS2)
- Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)
a. Findings and Observations
No findings of significance were identified.
4OA4 Cross-Cutting Aspects of Findings
Section 2PS1 describes an issue with a human performance cross-cutting aspect which involved the failure to sample in accordance with ODCM requirements.
4OA6 Management Meetings
Exit Meeting Summary
On October 22, 2004, the team presented the inspection results to Mr. M. Lucas, Vice President, Nuclear Engineering, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.
4OA7 Licensee Identified Violations
The following findings of very low significance were identified by the licensee and are violations of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600 for being dispositioned as Non-Cited Violations.
1. 10 CFR 71.12(c)(2) requires a licensee to comply with the terms and conditions of the Certificate of Compliance. Certificate of Compliance 9168 requires successful passage of a leak test of the secondary lid on a CNS 8-120B cask. However, the licensee identified one example in which it shipped a cask that had not successfully met the secondary lid leak test acceptance criteria.
The licensee performed the leak test using a modified test rig (as allowed by vendor procedures.) The modification involved the use of a longer than normal length of hose.
During a review of shipment records, the licensee determined through an engineering analysis that Shipment Number 2002-0043, shipped on June 3, 2002, would not have met the leak testing acceptance criteria. The finding was placed in the licensees corrective action program as SmartForm 2003-003675. The finding was of very low safety significance because
- (1) it was associated with radioactive material control and transportation,
- (2) there was no radiation limit exceeded,
- (3) there was no breach of the package during transit,
- (4) it was a Certificate of Compliance finding,
- (5) there was no design documentation deficiency, and
- (6) it was a maintenance/use performance deficiency.
2. Technical Specification 5.4.1.a. requires that procedures be established, implemented,
and maintained covering the applicable procedures in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Appendix A, Section 7 specify procedures for the Control of Radioactivity. Procedure RPI-213, Section 4.2.1 stated that the criteria for unconditional release from the radiological controlled area (RCA) is "no detectable activity." On October 18, 2003, a nylon sling marked RCA ONLY was found at the Service Water Intake Structure Building. The sling was counted in a small article monitor and found to have a radioactivity level of 5,900 disintegration per minute. This finding was documented in the licensees corrective action program as Smart Form 2004-3304.
This finding was of very low safety significance because
- (1) it involved an occurrence in the licensees radioactive material control program,
- (2) public exposure was not greater than five millirem, and
- (3) there were no more than five occurrences during the previous eight quarters.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- R. Barrios, Digital Radiation Monitoring System Technician, Instruments and Controls
- S. Bradley, Health Physics Supervisor, Radiation and Industrial Safety
- A. Caves, Radiation Protection Technician, Radiation and Industrial Safety
- J. Curtis, Radiation Protection Manager, Radiation and Industrial Safety
- T. Edwards, Supervisor, Radioactive Waste Operations
- D. Farnsworth, Senior Chemist, Chemistry
- R. Garcia, Radiation Protection Supervisor, Radiation and Industrial Safety
- R. Knapp, Health Physicist, Radiation and Industrial Safety
- W. Knowles, Radiation Protection Supervisor, Radiation and Industrial Safety
- M. Macho, Health Physicist, Radiation and Industrial Safety
- M. Lucas, Vice President, Nuclear Engineering
- D. OConnor, Radiation Protection Supervisor, Radiation and Industrial Safety
- T. Parker, Engineered Safety Features System Engineer, Nuclear Engineering
- M. Syed, Digital Radiation Monitoring System Engineer, Nuclear Engineering
- B. Vaughan, Radiation Protection Technician, Health Physics
- M. Watts, Radiation Protection Technician, Radiation and Industrial Safety
- D. Wilder, Manager, Radiation and Industrial Safety Manager
NRC
- D. Allen, Senior Resident Inspector
- A. Sanchez, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
NONE Opened and Closed During this Inspection
- 05000445;
- 05000446/2004009-01 NCV Failure to maintain and analyze composite samples on two occasions (Section 2PS1)