IR 05000498/1998020

Insp Repts 50-498/98-20 & 50-499/98-20 on 981102-05. Violation Noted.Major Areas Inspected:Radiological Controlled Area Access Controls,Radiation Work Permits, Radiological Surveys & pre-job Health Physics Briefings

ML20196G926
Person / Time
Site:	South Texas
Issue date:	12/02/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20196G898	List: IR 05000498/1998020 ML20196G893 ML20196G917
References
50-498-98-20, 50-499-98-20, NUDOCS 9812080153
Download: ML20196G926 (11)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-498

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50-499 License Nos.: NPF-76 NPF-80 Report No.: 50-498/98-20 50-499/98-20 Licensee: STP Nuclear Operating Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas Dates: November 2-5,1998 Inspector (s): Michael C. Hay, Radiation Specialist Approved By: Blaine Murray, Chiet, Plant Support Branch Attachment: Supplemental Information i

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9812080153 981202 PDR ADOCK 05000498 G PDR ,

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EXECUTIVE SUMMARY South Texas Project Electric Generating Station, Units 1 and 2 NRC Inspection Report 50-498/98-20; 50-499/98-20 Plant Suocort

Overall, the internal and external exposure control programs were effectively implemented. Workers were knowledgeable of work area radiological conditions and controls. Calibration and response checks for portable radiation detection instruments and whole body counters were properly conducted. Housekeeping throughout the radiological controlled area was good (Section R1.1 and R1.2).

A violation of 10 CFR 20.1501 was identified involving the failure to survey, resulting in a radiation area not being properly posted. No response to this violation is required (Section R1.1).

Survey documentation not accurately reflecting an area surveyed was identified by the l NRC. The licensee had also identified examples where surveys were not meeting management expectations (Section R1.1).

Overall, an effective quality assurance program was implemented. Quality assurance surveillances and a radiation protection department self assessment provided management with a good assessment of program performance. No negative trends were identified during the review of radiological condition reports written since January 15,1998 (Section R7.1).

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! Report Details l

IV. Plant Support l

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R1 Radiological Protection and Chemistry Controls l

R Exposure Controls j l Inspection Scope (83750) l The inspector interviewed radiation protection personnel and reviewed the following:

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• Radiological controlled area access controls

• Radiation work permits

• Radiological Surveys

-* Pre-job health physics briefings

• Control of high and locked high radiation areas

• Radiological posting

• Personnel dosimetry use Observations and Findinas The inspector observed activities at the radiological controlled area access / egress l control point and noted that station workers used the personnel contamination u

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monitoring and computerized log-in/out equipment properly. Radiation protection personnel were available to provide timely response and direction to station workers who alarmed the personnel contamination monitors or who needed assistance gaining l - access to the radiological controlled area. The inspector determined that the access I

and egress process functioned properly and was easy for the radiation workers to us The inspector determined that the radiation work permits provided accurate radiological data and proper radiological controls to protect and inform the worker. All radiation workers questioned by the inspector were knowledgeable of their radiation work permit requirements and knew to contact health physics personnel if their electronic dosimeter alarme The inspector attended a health physics pre-job briefing performed prior to the transfer of spent resin to a high integrity container. Good communications were noted between

the participants. The expected radiological conditions and controls to maintain doses l ALARA, along with the actions to take for unexpected conditions, were discusse Overall, the inspector determined that the pre-job briefing was effectiv During tours of the radiological controlled area, the inspector observed that high radiation areas were properly posted and controlled. All high and locked high radiation doors observed were locked or properly controlled.

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During a tour of the Unit 2 fuel handling building on November 2,1998, the inspector i measured radiation exposure rates between two storage containers on the 68-foot elevation of approximately 26 millirem per hour. The area was not conspicuously posted as a radiation area. The inspector notified health physics personnel who verified radiation exposure rates. The licensee documented the survey results and properly posted the area as a radiation are i The inspector was informed by the licensee that between October 29 and November 2, 1998, steam generator nozzle dams were placed in the storage containers. The nozzle dams created the radiation levels which required posting the area as a radiation are The inspector determined that the licensee failed to survey the area to evaluate the extent of radiation levels and the potential radiological hazards that could be present following placement of the steam generator nozzle dams into the storage container The failure to survey resulted in the area not being identified as a radiation are CFR 20.1501 requires that each licensee make or cause to be made surveys that j may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and t

that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production,

use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.

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The licensee did not make surveys to ensure compliance with 10 CFR 20.1902 which !

requires the posting of each radiation area with a conspicuous sign or signs bearing the radiation symbol and the words " CAUTION, RADIATION AREA." 10 CFR Part 20 defines a radiation area as,"an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0.005 rem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates." The failure to survey an area to ensure compliance with 10 CFR 20.1902 is identified as a violation of 10 CFR 20.1501 (50-499/98020-01).

t The inspector noted that immediate corrective actions consisted of properly posting the identified unposted radiation area, informing all plant health physics personnel of the

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problem, and performing a radiological survey of the entire radiological controlled area l to ensure that all areas were properly posted and controlled. The licensee initiated l Condition Report 98-17892 to evaluate the apparent cause of the event and determine j the associated corrective actions needed to prevent a recurrenc The inspector performed additional independent radiation surveys of selected areas and confirmed that survey data was accurate. During review of survey documentation, the inspector noted that Survey 2-98-10-1152 performed on October 18,1998, failed to indicate that the reactor head stand area was posted as a high radiation area although i radiation levels in this area required such postings. T he licensee stated that, although survey No. 2-98-10-1152 did not indicate that the reactor head stand was posted as a 1 high radiation area, the health physics log recorded that the area was posted as a high

{ radiation area on October 18,1998. The inspector verified that the log entry was made

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5-and determined that the proper radiological controls were established. Through review of condition reports and audits, the inspector noted that the licensee had also identified several examples where surveys were not completed in accordance with management

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expectations. The inspector discussed with the licensee that hprovement was needed

! to ensure that surveys were properly performed and survey maps accurately reflected the radiological conditions and postings. The licensee acknowledged the inspector's commen The inspector noted that all radiation workers observed in the radiological controlled  ;

area wore dosimetry devices appropriately. Thermoluminescent dosimeters were verified to be processed by a National Voluntary Laboratory Accredited Progra Conclusions in general, the external exposure control program was effectively implemented.

l' Workers were knowledgeable of the work area radiological conditions and controls.

l Radiation work permits provided accurate radiological data and proper radiological l controls to protect and inform the worker. A violation of 10 CFR 20.1501 was identified involving the failure to survey, resulting in a radiation area not being properly poste Survey documentation did not accurately reflect the areas surveye R1.2 Control of Radioactive Material and Contamination: Insoection Scope (83750)

The inspector interviewed radiation protection personnel and reviewed the following:

• Radioactive contamination controls t

• Personnel contamination events I * Air sampling

• Portable survey instrument calibration

• Whole body counter calibration

• Housekeeping within the radiological controlled area Observations and Findinas The inspector noted that radiological contamination survey instruments and personnel contamination monitors were properly used by workers exiting contamination area Release of materials from the radiological controlled area was conducted appropriatel Personnel contamination events were properly recorded. The inspector reviewed selected skin dose evaluations and determined that they were appropriately conducted using a proper computer code. The inspector reviewed an internal uptake dose estimate and verified the estimate was performed appropriatel Air sample records for the period of October 1 through October 31,1998, were reviewed. The records were maintained in an orderly manner and no deficiencies were noted.

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4 6-The inspector reviewed calibration and response test records for portable radiation detection instruments, small article monitors, personnel contamination monitors, and whole-body counters. All radiation detection instrumentation reviewed had been calibrated within the specified interval and properly response checked. Whole-body counters were properly calibrated using National Institute of Standards and Technology traceable source The inspector noted during a tour of the radiological controlled area on November 2

, 1998, several housekeeping deficiencies on the 68-foot elevation of the fuel handling l building. These deficiencies included miscellaneous pieces of personnel l anti-contamination clothing not properly stored in designated storage locations. The l inspector informed the licensee of these observations. On subsequent tours, the j inspector noted that all housekeeping discrepancies were properly addressed by the

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licensee, and overall housekeeping throughout the radiological controlled area was l

good.

Conclusions Overall, control of contamination was being effectively implemented. Personnel contamination events were properly recorded, and skin dose calculations were appropriately conducted. Air samples were properly performed and recorde Calibration and response checks for portable radiation detection instruments and whole-body counters were properly conducted. In general, housekeeping within the radiological controlled area was goo ;

R1.3 Maintainina Occuoational Exposure As Low As is Reasonab!v Achievable (ALARA) Inspection Scope (83750)

Radiation protection personnelinvolved with the ALARA program were interviewed. The

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following areas were reviewed:

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• Outage exposure goal establishment and status

- Site exposure goal establishment and status Observations and Findinas l Station, department, and individual exposures were appropriately tracked and trended ( by the ALARA group. The inspector noted that the 79 person-rem goal for 1998 was l exceeded. As of November 4,1998, the unit average person-rem was 93. The major l reason for the actual person-rem dose being higher was due to significantly higher personnel dose received during Unit 2 Outage 2RE06 than what was projected.

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Projected person-rem for Outage 2RE06 was 127; however, the actual person-rem for

. the outage was 174. The licensee believes the difference was the significant increase in i general plant radiation levels from unexpected high levels of cobalt-58. In review of I radiological surveys performed in the steam generators, the inspector noted that

radiation levels had increased by approximately 40 percent from the previous outage,

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-7-l which accounted for the significant increase in personnel dose. The inspector was informed that the licensee was in the process of evaluating better techniques to identify and quantify the amount of corrosion product buildup so that more accurate projections of radiation exposure rates are available for future outage planning. The licensee was also evaluating a modification to the primary system chemistry control in order to reduce the production and deposition of cobalt-5 In discussions with ALARA personnel, the inspector was informed that no major  ;

preoutage planning problems occurred. No major outage tasks required an extended {

scope, and no emergent work was required which resulted in significant personnel dose, j The inspector attended a health physics post outage ALARA meeting where lessons learned and performance strengths were discussed. The inspector noted that good observations and recommendations were discusse Conclusions The person-rem goal for Unit 2 Outage 2RE06 was significantly underestimated due to l radiation exposure levels being approximately 40 percent higher than expected. The i'

licensee was evaluating techniques to improve outage radiation exposure projections along with modifications to the primary system chemistry control to reduce the production and deposition of cobalt-5 l R5 Staff Training and Qualifications i Inspection Scope (83750)

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The inspector reviewed the qualifications of the new health physics division manage ) Observations and Findinas Due to a recent staff change, a new individual was designatcd to fill the health physics ,

division manager (radiation protection manager) position. Updated Final Safety Analysis !

Report (FSAR), Section 13.1.3.1, states, in part, that supervisory personnel will meet or l exceed the guidance given on personnel qualifications contained in USNRC Regulatory i Guide 1.8. From a review of the new health physics division manager's resume, the ,

inspector determined that this individual satisfied FSAR commitment ! Conclusions i The new health physics division manager satisfied FSAR commitment ;

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R7 Quality Assurance in Radiation Protection Activities l

l R7.1 Ouality Assurance Surveillances. Radiation Protection Self Assessments. and l Radioloaical Condition Reports Inspection Scope (83750)

Quality assurance surveillances, radiation protection self assessments, and radiological condition reports from January 16 to November 2,1998, were reviewe Observations and Findinas Quality Assurance Surveillance 08.2.7 was reviewed. This surveillance assessed the i

effectiveness and implementation of the health physics program in compliance with the requ'rament of 10 CFR 20.1101(c). A radiation protection audit performed during Unit 2 outage and a radiation protection self assessment were also reviewed. Overall, the inspector determined that all we e probing and comprehensive and provided management with'a good assessment of the radiation protection program. The inspector noted that findings were captured in the licensee's corrective action program for evaluatio The inspector reviewed selected radiological condition reports written since January 15, 1998, and noted that the station identified items at a proper threshold to provide management with a good overview of radiological program areas. Corrective actions to -

prevent a recurrence appeared to be effective and, in general, condition reports were closed in a timely manner. The inspector identified no negative trends during this revie Conclusions Overall, an effective quality assurance program was being implemented. Two quality assurance surveillances and a radiation protection program self assessment were completed since January 15,1998, providing management with a good assessment of the areas reviewed. No negative trends were identified during the review of radiological condition reports written since January 15,199 R8 Miscellaneous Radiological Protection and Chemistry issues R8.1 (Closed) Insgection Follow-up item 50-498:-499/97006-09: Review the imolications of Contaminated Tools Beina Released This item involved miscellaneous tools which were transported from South Texas l Project to a vendor and discovered by the vendor to have low levels of fixed contamination. The inspector reviewed the actions taken by the licensee's assessment team and determined the problem was properly evaluated and corrective actions were (.

appropriate to prevent a recurrence. The inspector identified no similar issue !

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-9-R8.2 (Closed) Violation 50-498:-499/98002-01: Failure to inform Workers of a Chanae in Radioloaical Conditions The inspector verified the corrective actions described in the licensee's response letter dated March 16,1998, were implemente R8.3 (Closed) Violation 50-498:-499/98002-02: Failure to Survev The inspector verified the corrective actions described in the licensee's response letter dated March 16,1998, were implemente ,

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R8.4 (Closed) Violation 50-498:-499/98002-04: Failure to Post an Airborne Radioactivity Area The inspector vernied the corrective actions described in the licensee's response letter dated March 16,1998, were implemente ,

V. Manaaement Meetinas .

X1 Exit Meeting Summary e The inspector presented the inspection results to members of licensee management at an exit meeting on November 5,1998. The licensee acknowledged the findings presented. No proprietary information was identifie i I

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ATTACHMENT I

Sucolemental Information j PARTIAL LIST OF PERSONS CONTACTED Licensee I

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P. Arrington, Licensing D. Bryant, Chemistry Supervisor i W. Bullard, Health Physics Supervisor l L. Earls, Consulting Engineer J J. Groth, Vice President, Nuclear Engineering S. Head, Licensing S. Horak, Quality Assurance Auditor / Specialist ]

B. Mackenzie, Manager, Engineering and Technical Support )

G. Powell, Health Physics Division Manager P. Serra, Manager, Emergency Response J. Sherwood, Radiation Protection Supervisor j J. Simmons, Health Physics Supervisor NRC )

C. O'Keefe, Senior Resident inspector INSPECTION PROCEDURE USED 83750 Occupational Radiation Exposure LIST OF ITEMS OPENED AND CLOSED i Closed '

50-498;-499/97006-09 IFl Revie'N the implications of Contaminated Tools Being Released 50-498;-499/98002-01 VIO Failure to Inform Workers of a Change in Radiological ,

Conditions l 50-498;-499/98002-02 VIO Failure to Survey  ;

50-498;-499/98002-04 V!O Failure to Post an Airborne Radioactivity Area Opened 50-499/98020-0 VIO Failure to Survey i

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l -2-l LIST OF DOCUMENTS REVIEWED l Procedure OPGP03ZR0050, " Radiation Protection Program," Revision 2 Procedure OPRP02ZR0007, " Evaluation of Intakes," Revision 3  !

l Procedure OPRP04ZR0013, " Radiological Survey Program," Revision 5 l Procedure OPRP07ZR0010, " Radiation Work Permits," Revision 6 l Procedure OPGP03ZR0051," Radiological Access and Work Controls," Revision 9

Procedure OPRP04ZR0011," Radiation Protection Key Control," Revision 3 Procedure OPRP04ZR0016," Radiological Air Sample Analysis," Revision 5 l

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