IR 05000498/1997012

Insp Repts 50-498/97-12 & 50-499/97-12 on 970428-0501.No Violations Noted.Major Areas Inspected:Plant Support

ML20141K112
Person / Time
Site:	South Texas
Issue date:	05/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141K102	List: IR 05000498/1997012 ML20141K099
References
50-498-97-12, 50-499-97-12, NUDOCS 9705280324
Download: ML20141K112 (12)

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I ENCLOSURE

4 i i U.S. NUCLEAR REGULATORY COMMISSION l REGION IV i

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Docket Nos.: 50-498 )

50-499  !

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License Nos.: NPF-76  ;

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NPF-80 i

i Report No.: 50-498/97-12 l

50-499/97-12 r J l Licensee

Houston Lighting & Power Company

{ l Facility: South Texas Project Electric Generating Station, Units 1 and 2 1 j Location: FM 521 - 8 miles west of Wadsworth Wadswonh, Texas

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1 l j Dates: April 28 through May 1,1997 {

j inspector: Gilbert L. Guerra, Jr., Radiation Specialist, Plant Support Branch 1 1 ,

i Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety

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ATTACHMENT

Supplemental Information

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9705200324 970521 PDR ADOCK 05000498 G PDR

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l EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/97-12;50-499/97 12 Plant Suooort I i

• An excellent radiological environmental monitoring program was implemented l (Section R1,1). l

• An effective meteorological monitoring program was implemented (Section R1.2).

• Environmental monitoring stations were properly maintained with operable and calibrated equipment. The offsite dose calculation manual criteria for establishing

. control sample locations differed from NRC guidance (Section R2.1).

• The meteorological towers were properly maintained with allinstrumentation  ;

calibrated at the proper frequencies, Data recovery was greater than 90 percent I (Section R2.2).

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• Radiological environmental monitoring implementing procedures contained sufficient detail (Section R3.1).

• Licensee staff had an excellent understanding of the radiciogical environmental monitoring program, the offsite dose calculation inanual, and regulatory requirements (Section R4).

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• Personnel responsible for implementing the radiological environmental monitoring program were well trained and qualified (Section RS).

• Adequate staffing was maintained. Management provided good support for the radiological environmental monitoring program (Section R6.1).

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• Comprehensive audits were performed. The audits identified items for improvement and evaluated the performance and implementation of the radiological environmental i

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l l * Excellent annual radiological environmental operating reports were submitted in a i timely manner (Section R8.1). ,

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l -3- l Report Details .

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l l Summary of Plant Status Units 1 and 2 were operating at power during the inspection. There were no operational occurrences that impacted the results of the inspection, IV. Plant SuDDort R1 Ratiiological Protection and Chemistry Controls I i

R _ adioloalcal Environmental Monitorina Proaram (84750)

R Inspection Scoce

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The inspector reviewed the radiological envir:nmental monitoring program to i determine compliance with the requirementr en the offsite dose calculation manua l Observations and Findinos l

The licensee ur,ed the cffsite dose calculation rnanual and appropriate procedures to )

implement the program. These documents contained sufficient detail for conducting l the radiological environmental monitoring program. The licensee had made minor ]

changes to the offsite dose calculation manual. The inspector noted that the J changes did not decrease the effectiveness of the offsite dose calculation manua ,

Environmental technicians were knowledgeable of the sampling procedures and the !

offsite dose calculation manual requirement l

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l Licensee staffing was adequate and management controls were appropriate. All environmental sampling was conducted as required. The licensee maintained a Nuclear Energy Institute /Nat5nal Institute of Standards and Technology traceable laboratory which performed ensironmente; sample analyses. The annual land use census wac pcrformed as required. Excellent annual reports were written and submitted to tho' NFC as require Environmental control and indicator sample station data trending was performe Except for high tritium levels in the main cooling reservoir, environmental sample data for indicator stations agreed with control sample dat Tritium levc: .i the main cocling reservoir were trending down since 1995 when plant processes produced greater amounts of tritium. The cause of the higher tritium production was attributed to resin in the water processing system which had been treated with natural lithium instead of lithium depleted in lithium-6. Lithium-6 interacts with neutrons in the reactor to produce tritium. Approximately 3,500 Curies of tritium were released in 1995 to the main cooling reservoir, and

approximately 1,500 Curies were released during 1996. Prior to 1995, the licensee had averaged approximately 800 Curies per year. Tritium levels in the main ecoling reservoir peaked to approximately 17,000 picocurie per kilogram in early 1996, which represents 56% of the NRC's 30,000 picocurie per kilogram reporting leve At the end of 1996, tritium levels in the main cooling reservoir were down to approximately 9,000 picocurie per Kilogram. Water from the main cooling reservoir is not used for drinking or recreation; therefore, doses to the public are not of concer The inspector noted that the radiological environmental monitorir.g program was fully implemented in accordance with the requirements in the offsite dose calculation manual. Based on observations during this inspection and review of previous NRC findings in this program area, the inspector determined that performance continued to be excellen Conclusions ,

i An excellent radiological environmental monitoring program was implemented in accordance with offsite dose calculation manual requirement R1.2 Meteorofoaical Monitorina Proaram (84'750) Inspection Scone l The inspector reviewed the meteorological monitoring program to determine agreement with the recommendations in NRC Regulatory Guide 1.23 and compliance with the commitments in the Updated Final Safety Analysis Report, Section Observations and Findinas l

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The licensee utilized a 60 meter primary meteorological tower and a 10 meter backup meteorological tower, both equipped with the required instrumentatio l Tower instrumentation conformed te commitments documented in the Updated Final Safety Analysis Report, Section 2.3 and Regulatory Guide 1.23. Meteorological l data was available to the control room operations staff and at the emergency response facilities. Calibrations and daily channel checks were performed as required. The meteorological towers and data recording equipment had been upgraded in December of 1995. The upgrades provided for data to be available by several methods including direct link, modem, and chart recorders. Backup power supplies and propane generators were provided. A lightning suppression system was also in use.

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5- Conclusions An effective meteorological monitoring program was implemented. The performance of the meteorological monitoring program satisfied the commitments of the Update Final Safety Analysis Report, Section 2.3, and agreed with the guidance contained in Regulatory Guide 1.2 R2 Status of Radiological Protection and Chemistry Facilities and Equipment I R2.1 Environmental Monitorina Eauipment and Facilities (84750) Insoection Scone The inspector visited selected environmental sampling stations to verify that stations were properly maintained and equipment was operable and properly calibrated. Sample prer,aration and storage f acilities were inspected to verify that sufficient supplies and spare equipment were availabl Observations and Findinas The inspector observed the facilities used for environmental media sample preparation and storage. The sample prep:. ration / storage area was equipped with the necessary spare equipment and supplies to perform the required radiological environmental monitoring program sampling activitie The inspector toured the environmental sampling locations, which included sampling ,

stations for the collection of air, broadleaf vegetation, and water samples with an environmental specialist. The location of thermoluminescent dosimeters was also noted. The inspector noted that air sampler equipment in use was properly calibrated and operational. A timing device was used on each air sampler to track operation history. Environmental samples were properly handled and prepared for q laboratory analyse ]:

The inspector noted that the licensee's offsite dose calculation manual criteria for establishing control sample stations specified that they should be located in a minimal wind direction. However, NRC guidance documents, specifically, the Branch Technical Position on an Acceptable Radiological Environmental Monitoring Program, Revision 1, November 1979, specifies that control stations are to be located in the least prevalent wind direction. The inspector noted that the licensee's offsite dose calculation manual did not require that control sample stations be located in the least prevalent wind direction. If the definition for a control station as described in the Branch Technical Position is used, it would place the licensee's control air sample station in a different location than it is currently located. According to the Branch Technical Position, the purpose of the control sample is to obtain background information, and if it is not practical to establish control locations in accordance with the distance and wind direction criteria, other

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sites which provide valid background data may be substituted. Flexibility exists in ,

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the NRC guidance documents for the establishment of the most practical background location. A technical evaluation showing Sny differences in background j data,if any, between the licensee's control air sample station and one located per j (N criteria in the Branch Technical Position had not been performed by the license Using wind rose data for the South Texas Project compiled between July 21,1973, i

and September 30,1977, the licensee's control air sample station is located in about the seventh least prevalent wind direction. The inspector was not able to j determine why the wording in the licensee's offsite dose calculation manual did not ;

reflect the language in the NRC guidance. The inspector determined that the control .

I air sampie station was located as documented in the NRC approved offsite dose calculation manual; therefore, this matter did not involve a violation of regulatory requirements. This issue was discussed during the exit meeting on May 1,199 l The licensee acknowledged the inspector's comment and provided no response  !

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regarding the location of the control station.

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The licensee maintained sufficient supplies and spare t vironmental sampling equipment to perform the activities described in the offsite dose calculation manua Environmental monitoring stations were properly maintained with operable and calibrated equipment. The offsite dose calculation manual criteria for establishing t control sample locations differed from NRC guidanc !

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R2.2 Meteoroloaical Monitorina Eauioment (84750) , Inspection Scope e

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The inspector observed the meteorological instrumentation at the meteorological l towers and reviewed the associated calibration records to ensure that the ,

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meteorological instrumentation on the towers was operable, calibrated, and maintained in accordance with written procedures, the guidance in Regulatory .

i Guide 1.23, and Updated Final Safety Analysis Report, Section Observations and Findinas

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The inspector toured the meteorological towers with licensee technicians responsible for performing periodic calibrations of the monitoring equipment on the ,

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towers. The licensee maintained a primary tower with monitoring instrumentation at the 10 and 60 meter levels, and a backup tower with instrumentation located at '

the 10 meter level. The instrumentation at these levels included wind speed, wind direction, and temperature sensing instrumentation. Instrumentation, including recording and transmitting equipment, was noted to be in good operating conditio ;

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-7-The inspector noted that the instrumentation agreed with Regulatory Guide 1.23 recommendations and the licensee's Updated Final Safety Analysis Report, Section 2.3. The inspector noted that a!Iinstrumentation was operable and properly calibrated. Calibration records indicated that the instrumentation was maintair;ed properly and calibrations were performed at the proper frequencies. Daily channel checks were performed on each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> operations shift in accordance with operations procedure requirements. Operation of the meteorological towers resulted in data recovery rates of 96.2 percent for 1994, 97.1 percent for 1995, and 97.6 percent for 199 Conclusions The mef uological towers were properly maintained with allinstrumentation calibrateu at the proper frequencies. Data recovery was greater than 90 percen R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Chances in the Offsite Dose Calculation Manual and Radioloaical Environmental Monitorina Imolementina Procedures (84750) Inspection Scope The inspector reviewed changes made to the offsite dose calculation manual and implementation procedures regarding the radiological environmental monitoring program, Observations and Findinas

i Revisions 7 and 8 to the offsite dose calculation manual had been issued since the

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last inspection. The changes affecting the radiological environmental monitoring j program were minor and mostly reflected changes in sample locations and  !

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descriptions. The inspector noted that the changes did not result in a decrease in j the effectiveness of the offsite dose calculation manual. The implementing l procedures described the responsibilities for collection, documentation, and analysis j of environmental media samples. The licensee's procedures were written wito !

sufficient detail for conducting the required radiological environmental monitoring j program activitie '

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The licensee had made minor changes to the offsite dose calculation manual. The I changes did not decrease the effectiveness of the radiological environmental monitoring program. The radiological environmental monitoring program implementing procedures contained sufficient detai '

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R4 Staff Knowledge and Performance

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The inspector observed and held discussions with personnel involved with the implementation of the radiological environmental monitoring program to determine their knowledge of environmental sampling and implementing procedures. The ,

l inspector noted that good collection practices were used by the environmental

. specialist in maintaining sample integrity. All activities observed were conducted in

an orderly fashion. The inspector noted that the licensee's staff knowledge of

] sampling procedures, the offsite dose calculation manual, and NRC requirements ,

was excellen j R5 Staff Training and Qualification i The training and qualification programs for the technical staff responsible for

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implementing the radiological environmental monitoring program were reviewe Training records revealed that the current staff implementing the radiological environmental monitoring program were properly trained and qualified. These

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individuals had several years of experience with offsite dose calculation manual requirements, which included environmental sampling and analysi !

R6 Radiological Protection and Chemistry Organization and Administration R6.1 Environmental Monitorina (84750)

l Inspection Scope j The organization, staffing, and assignment of the radiological environmental monitoring program responsibilities were reviewe Observations and Findinas

. Management of the radiological environmental monitoring program was performed by *he health physics division. Changes were noted in the organization since the last inspection. Specifically, the environmental laboratory which performs sample i analyses had been relocated in January 1996, from the Houston, Texas, location to the South Texas Project site. The licensee experienced a loss of personnel as a result of the move. However, the licensee effectively maintained the radiological environmental monitoring program during this period. Currently, two individuals were responsible for the majority of the collection and preparation of the j environmental samples, including the review of the sample analysis results and i preparation of the annual report I Conclusions  !

The present organization maintained adequate staffing and provided management i support for implementing the radiological environmental monitoring progra i

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. R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Audits (84750) Insoection Scope Quality assurance audit reports concerning the radiological environmental monitoring program were reviewed for scope, thoroughne'ss, and timely followup of identified deficiencies. Laboratory quality control was also reviewe Obsen n v.s and Findinas The lict.: maintained an effective quality assurance program for the radiological environm', monitoring program. This consisted of the performance of audits, surveillance had self assessment The inspector reviewed the results of the audits, surveillances, and self assessment performed by the licensee between 1994 and 1996. The inspector noted that the reviews were comprehensive, thorough, and provided management with the appropriate oversight of the radiological environmental monitoring progra Findings were corrected in a timely manne The licensee established and implemented a measurement assurance program which consisted of three parts. The laboratory participated in a Nuclear Energy Institute / National Institute of Standards and Technology Measurements Assurance Program (intercomparison program), an inter-utility intercomparison program, and a -

licensee prepared and controlled environmental sample intracomparison progra Acceptable results were noted with the intercomparison data, Conclusions Thorough, comprehensive audits were performed at the required frequency. The audits identified items for improvement and evaluated the performance and implementation of the radiological environmental monitoring program. Laboratory quality control was goo ~

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R8 Miscellaneous Radiological Protection and Chemistry Issues R8.1 Annual Radioloaical Environmental Ooeratina Reports (84750) Inspection Scope The inspector reviewed the annual reports concerning radiological environmental monitoring program activities to determine compliance with the requirements of Technical Specifications and the offsite dose calculation manual. These documents were reviewed for omissions, obvious mistakes, anomalous measurements, observed biases, and trends in the dat Observations and Findinas The licensee issued excellent annual reports which included photographs, graphs and charts, and provided additional explanatory information. The reports were well organized and contained the appropriate informatio Sampling results included in the 1994,1995, and 1996 Annual Radiological Environmental Operating Reports indicated that sampling was performed as required. Discrepancies or missed samples were reported as required. The inspector noted that sampling, analyses, and reporting requirements were met. The annual land use censuses were conducted as required, and the results were included in the repor Conclusions Excellent annual radiological environmental operating reports were submitted in a timely manner. The reports contained the required informatio V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the results of the inspection to members of licensee management at the conclusion of the inspection on May 1,1997. The licensee acknowledged the findings presented. The licensee made no commitments regarding the issue discussed in Section R2.1 involving the offsite dose calculation manual criteria for locating control sample stations. No proprietary information was identified.

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ATTACHMENT l

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SUPPLEMENTAL INFORMATION l PARTIAL LIST OF PERSONS CONTACTED l Licensee W. Cottle, Executive Vice President and General Manager Nuclear i J. Groth, Vice President Nuclear Operation j E. Hardcastle, Radiation Protection Technician i S. Head, Licensing Supervisor T. Koser, Licensing Engineer i M. Markovich, Senior Quality Specialist R. Masse, Unit 2 Plant Manager M. McBurnett, Licensing Director G. Parkey, Unit 1 Plant Manager A. Passafuma, Radiation Protection Technician J. Sherwood, Health Physics Supervisor NRC

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W. Sifre, Resident inspector INSPECTION PROCEDURE USED IP 84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF DOCUMENTS REVIEWED PROCEDURES OPOP01-ZA-0015 Oversight Planning and Scheduling Process, Revision 3 OPSP05-EM-0001 Primary Meteorological System Calibration, Revision 9 OPSP05-EM-0002 Backup Meteorological System Calibration, Revision 7 OPGP03-ZR-0039 Radiological Environmental Monitoring Program, Revision 6 OPRP10-ZL-0001 Radiological Laboratory Administrative procedure, Revision 7 OPRP10-ZL-0002 Quality assurance for the Radiological Laboratory, Revision 7 OPRP10-ZU-0001 REMP Sample Collection, Revision 2 OPRP10-ZL-0006 Sample Receipt, Accountability and Storage, Revision 8 OPRP10-ZL-0011 Gamma Analysis in Environmental Media, Revision 6 OPRP10-ZL-0022 Quality Control of Radiological Laboratory Equipment, Revision 5

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t QUALITY ASSURANCE ,

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Quality Audit 96-08 Radiological Environmental Monitoring Program

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Surveillance 96-007 Classification of Metrology Laboratory, Heaith Physics, and Chemical ;

Analysis Condition Reports -!

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Surveillance 95-103 Radiological Laboratory Activities l Surveillance 95-037 Radiological Laboratory Activities i

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Internal Assessment of the Radiological Environmental Program, July 1996

Quality Monitoring Report MN-97-0-0046 I Quality Monitoring Report MN-97-0-0329 ,

i Quality Monitoring Report MN-96-0-0642  ;

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REPORTS }

I Annual Radiological Environmental Operating Reports - 1994,1995,1996  !

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Offsite Dose Calculation Manual, Revision 8 I Training Records Organizational Charts Meteorological Tower Instrumentation Calibration Records l

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