IR 05000498/1986030

Insp Repts 50-498/86-30 & 50-499/86-27 on 860915-19.No Violations or Deviations Noted.Major Areas Inspected: Radwaste Mgt & Transportation Activities,Including Organization & Training

ML20215M733
Person / Time
Site:	South Texas
Issue date:	10/23/1986
From:	Baer R, Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20215M728	List: IR 05000498/1986030 ML20215M727
References
50-498-86-30, 50-499-86-27, NUDOCS 8611030210
Download: ML20215M733 (13)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-30 Construction Permits: CPPR-128 50-499/86-27 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Light and Power Company (HL&P)

P.O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project Electric Generating Station, Units 1 and 2 (STP)

Inspection At: STP Site, Matagorda County, Texas Inspection Conducted: September 15-19, 1986 Inspector: -  !

/6b.3/ff R'. E. Baer, Radiation Specialist, Facilities Dhte '

Radiological Protection Section Approved: C /C/8 /(.

Taine Murray, Chief, Facilities Radiological Date Protection Section Inspection Summary Inspection Conducted September 15-19, 1986 (Report 50-498/86-30; 50-449/86-27)

Areas Inspected: Routine, announced inspection of the licensee's radioactive waste management and transportation activities, including: organization, training, liquid radwaste systems, gaseous radwaste systems, solid radwaste systems, audits, air cleaning systems, radiation monitoring instrumentation, and transportation progra Results: Within the areas inspected, no violations or deviations were identifie Twelve open items are discussed in paragraph PDR ADOCK 05000498 G PDR

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DETAILS Persons Contacted Houston Lighting and Power Company W. H. Kinsey, Plant Manager

• C R. Beavers, Lead Engineer, Computer Support

• D. Bednarczyk, Supervisor, Operations Quality Assurance (QA)

• J. O. Bottle, Engineer, Operations QA H. S. Blinka, Supervisor, Performance Support D. J. Cody, Manager, Training

• R. C. Craft, Supervisor, Radiation Protection

• J. C. Dierickx, Supervisor, Chemical Support

• B. A. Franta, Manager, Staff Training R. A. Gangluff, Supervisor, Chemical Analysis

• J. D. Green, Manager, QA

• S. M. Head, Licensing W. G. Isereau, Supervisor, Audit / Surveillance

• G. L. Jarvela, Manager, Health and Safety Services S. D. Korenek, Technician, Chemical D. A. Leazar, Supervisor, Reactor Performance J. W. Loesch, Plant Superintendent M. A. Ludwig, Manager, Maintenance

• M. A. McBurnett, Supervising Engineer, Site Licensing W. B. Mooney, Chemical Plant Operator

• K. E. Nemec, System Engineer J. C. Oliver, Chemical Plant Operator G. Ondriska, Lead Engineer, Startup

• W. C. Parrish, Supervisor, Radiological Support

• M. F. Rejcek, Supervisor, Chemical Operations W. F. Scott, Foreman, Radwaste M. E. Smith, Manager, Outage

• T. E. Underwood, Manager, Chemical Operations and Analysis

• B. R. Wahlheim, System Engineer, Technical Support

• B. N. Woolweber, System Engineer, Technical Support Others F. R. Donley, Startup Engineer, Volt Technical Services W. G. Leska, Startup Engineer, Westinghouse Instrument Service C *S. Phillips, Licensing Engineer, Westinghouse D. L. Garrison, Resident Inspector, NRC

• Denotes those individuals present at the exit interview on September 19, 198 .

The NRC inspector also interviewed other licensee and contractor employees, including radiation protection, chemistry, and construction personne .. .__

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3 Scope of Inspection This inspection covered the initial oreoperational review of the licensee's liquid, solid, and gaseous radioactive waste programs and transportation activitie . Open Items Identified During This Inspection Open items are matters that require further review and evaluation by the NRC inspector or the licensee. Open items are used to document, track, and ensure adequate follow-up on matters of. concern to the NRC inspecto Open Item Description Paragraph 498/8630-01; 499/8627-01 Organization and Management Controls 4 498/8630-02; 499/8627-02 Radwaste Training Program 5 498/8630-03 Radwaste Program Audit 6 498/8630-04 Quality Assurance Program 6 498/8630-05 Liquid Radwaste System 7a 498/8630-06 Gaseous Radwaste System 7b 498/8630-07 Solid Radwaste System 7c 498/8630-08 Air Cleaning System 8 498/8630-09 Area Radiation Monitors 9a 498/8630-10 Calibration of Process and Effluent Monitors 9b 498/8630-11 Process and Effluent Monitors 9b 498/8630-12 Procedures 10 Radioactive Waste Management Organization The NRC inspector examined the licensee's onsite organization regarding radioactive waste management to determine agreement with the Final Safety Analysis Report (FSAR) commitments and recommendations of Regulatory Guide (RG) 4.1 The NRC inspector verified that the organization and mar,a0ement controls of the onsite radwaste organization were as depicted in the FSAR, Figures 13.1.-2A and 13.1.-2C, Amendment 53. The licensee stated that the

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position of the radwaste foreman had been changed to environmental /radwaste foreman and additional duties and responsibilities had been assigned to this position in the area of hazardous wast The NRC inspector reviewed the job descriptions which defined the responsibilities for the chemical operations and analysis manager, chemical operations supervisor, chemical operations foreman, chemical piant operator, ensfronmental/radwaste foreman, and environmental /radwaste specialist. The NRC inspcetor noted that the job descriptions did not define the interface with other organizations, specifically between the chemical operations foremen and the reactor operations department shift supervisor The NRC inspector reviewed Procedure OPGP03-Z0-0021, "Radwaste Minimization Program," Revision 1, October 10, 1984, which defines the licensee's program and responsibilities for implementation of the radwaste program. The NRC inspector noted that the licensee had not developed a corporate policy statement addressing radioactive waste management and the minimization of radioactive waste generation for this statio This item is considered an open item (498/8630-01; 498/8627-01) pending:

Define responsibilities and interfaces with other station department "

Develop a corporate radioactive waste management and minimization program policy statemen No violations or deviations were identifie . Radioactive Waste Management Training Program The NRC inspector reviewed the licensee's radioactive waste training program to determine agreement with commitments in Sections 13.2.1.2 and 13.2.1.3.2 of the FSAR; compliance with 10 CFR Part 19.12 requirements; the recommendations of ANSI /ANS 55.1-1979, 55.4-1979, 55.6-1979; NUREG-0761; and Regulatory Guides 4.15, 8.8, 8.10, and 8.2 Each plant department had been assigned the responsibility for its own training. The chemical operations departirent training program patterned around Procedure OTCP01-ZA-0001, " Certification of Chemical Operations and Analysis Division Personnel for Examination and Testing," applies to the initial training provided personnel. The licensee had supplemented training by sending chemical operators to operating nuclear power plants with similar plant equipment, where they were afforded the opportunity to actually operate the equipmen The NRC inspector noted that a training program or procedure had not been developed for the transportation activities area of the radioactive waste program. A licensee representative stated that training on transportation activities scheduled before June 1987 would meet the requirements set

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forth in inspection and enforcement (IE) Bulletin Number 79-19, " Packaging of Low-Level Radioactive Waste for Transport and Burial."

The NRC inspector discussed with licensee representatives the status of the retraining program. The licensee stated that the frequency for retraining had not been defined but would probably be a 3 year cycle. The training department will provide for the retraining of chemical operator Procedure OEEE08-IP-008.12, " Chemical Operator Training Program," was in the review cycle at the time of this inspectio The licensee plans to use contract personnel for collecting and processing

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dry active waste. There was no training program or procedure for these activities at the time of this inspectio This item is considered an open item (498/8630-02; 499/8627-02) pending:

Implementation of a training / retraining program for chemical operator Develop and implement a training program for all personnel involved with the handling and packaging of low-level radioactive waste as required in IE Bulletin 79-1 No violations or deviations were identifie . Audits and Reviews The NRC inspector reviewed the licensee's internal audit / review program regarding radioactive waste and transportation activities to determine agreement with Section 13.4 of the FSAR; the requirements of 10 CFR Part 71, Appendix H; and the recommendations of ANSI N18.7-1976, Regulatory Guides 1.33, 1.144, 1.146, and 4.15.

[ The NRC inspector reviewed Procedures IP-4.4Q, " Performance of Quality L Assurance Audits and Surveillance Activities," Revision 1, June 10,1986, and IP-4.5Q, " Quality Assurance Program for Radioactive Waste Management,"

Revision 0, November 1, 1984. The NRC inspector discussed with licensee representatives the status of audits of radwaste activities. The licensee stated that no audits had been performed on the radwaste program.

i The NRC inspector noted the licensee had a corrective action program and procedures which outlined the radwaste program. At the time of this inspection, the licensee had not developed an audit program or completed checklist that included the following elements:

Staff effectiveness, work practices, adequacy of training, and procedural compliance.

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Low-level waste transfer, packaging, and storage activities.

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Operation of liquid, gaseous, and solid waste systems, including the control measures used for liquid and gaseous effluent release Instrumentation operation and calibration for all effluent, process, and area radiation monitor Air cleaning system testing, operation, and maintenanc This is considered open item (498/8630-03) pending:

Completion of an approved audit plan, including a checklist, for the radwaste progra Completion of an approved audit plan, including a checklist, for the transfer, packaging, and transport of low-level radioactive wast The NRC inspector discussed with licensee representatives the status of the quality assurance program to meet the requirements of 10 CFR Part 71.101. The licensee stated that they had not submitted their quality assurance program for the transport of licensed material to the NRC for approval. The NRC inspector stated that the quality assurance program would have to be submitted in accordance with 10 CFR 71.101(c)

prior to the transport of greater than type A quantities of radioactive materia This is considered oLen item (498/8630-04) pending the submittal and approval of the quality assurance program for transport of licensed materia No violations or deviations were identifie . Radioactive Waste Management The NRC inspector reviewed selected portions of the licensee's radioactive waste management program with respect to FSAR, Chapter 11, " Radioactive Waste Management"; Chapter 12, " Radiation Protection"; Chapter 13,

" Conduct of Operations"; and Chapter 14, " Initial Tests and Operations." Liquid Radioactive Waste System The NRC inspector reviewed the licensee's liquid waste management system to determine agreement with FSAR commitments and the recommendations of ANSI /ANS 55.6-1979, N323-1978, and IE Bulletin 80-1 The licensee had divided the liquid radioactive waste system into four subsystems for testing purposes: WLO-1, Reactor Coolant; WLO-2, Waste Evaporators; WLO-3, Liquid Waste Process; and WLO-5, Boron Recycle. These systems were still in the construction stage at the time of this inspectio Scheduled preoperational testing of the

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above subsystems is set for March 1987 with completion approximately mid-April 198 The NRC inspector spent a limited amount of time reviewing the liquid radioactive waste system, since it was still under construction. The NRC inspector noted that the licensee had not performed an ALARA l

I review of the "as-built" liquid waste system against the recommendations of the industry standard ANSI /ANS 55.6-1979, " Liquid Radioactive Waste Processing System for Light Water Reactor Plants."

The NRC inspector discussed with licensee representatives the need to pay particular attention to the waste evaporator packages, waste collection tank room, and waste monitor tank 1A, B, and C room. The NRC inspector discussed the need to interface with the chemical i

operators to determine what valves and the frequency at which these I valves will need to be operated during routine plant evolutions and with the maintenance department regarding pumps and motor The licensee had not verified that tank volumes for all tanks listed in the FSAR and proposed Technical Specifications were correct;

, verified that samples collected would be representative for determining quantities and concentrations of radioactive materials in liquids released to unrestricted areas; verified discharge flow rates used to determine the volume released; and verified that recorders were properly calibrated for the liquid radioactive waste system. A licensee's representative stated this verification would be completed during the prerequisite test of individual components before preoperational testin The NRC inspector was unable to determine if the licensee had reviewed plant systems as recommended in IE Bulletin 80-10,

" Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment."

This bulletin required operating facilities to review systems and interfaces and identified where contamination of nonradioactive systems could result, to review operating procedures and identify valving errors or operating conditions which could result in the contamination of a nonradioactive system, and to establish a routine sampling / analysis or monitoring program for these systems. A licensee's representative stated that the chemical operations and analysis division would perform the IE Bulletin 80-10 revie The NRC inspector noted the licensee had not developed an approved preoperational test procedure for all subsystems of the liquid radioactive waste syste This is conside ed an open item (498/8630-05) pending:

Completion of an approved preoperational test procedure for all liquid radioactive waste system , ..

Completion of the preoperational tests on all liquid radioactive waste system Development of a sampling / analysis program as recommended in IE Bulletin 80-1 Review of operating pro:edures for valving errors and operating conditions which could contaminate nonradioactive system Verification of tank volumes, representative sampling, discharge flow rates, and recorder reading *

Performance of an ALARA review of the liquid radioactive waste system, including the recommendations of ANSI /ANS 55.6-197 No violations or deviations were identifie Gaseous Radioactive Waste System The NRC inspector reviewed the licensee's gaseous radioactive waste system to determine agreement with FSAR commitments and the recommendations of ANSI /ANS 55.4-1979 and N323-197 The NRC inspector's review of the gaseous radioactive waste system

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indicated that the licensee had installed the major components. The licensee had developed and approved the preoperational test 1-WG-P-01, " Waste Gas Processing System," Revision 0, September 9, 1986, for the gaseous radioactive waste syste The licensee stated that the system would be turned over from construction in late November 1986, with testing to start shortly thereafter and with preoperational testing scheduled for late March 1987 and lasting approximately 2 weeks. The licensee will verify flow paths, tank vent systems, and the capability to obtain a system sample as part of the preoperational tes The NRC inspector noted that the licensee had not performed an ALARA review of the "as-built" gaseous waste system against the recommendations of ae industry standard ANSI /ANS 55.4-1979,

"American National Standard for Gaseous Radioactive Waste Processing Systems for Light Water Reactor Plants." The licensee had not reviewed the gaseous waste system and other gaseous systems as recommended in IE Bulletin 80-1 The licensee had not determined that tank volumes were as specified in the FSAR and proposed Technical Specifications, that flow rates used to determine volume releases were correct, that recorders were properly calibrated, and that samples to be taken would be representative of the effluent being release _ _ _ _ . _

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This is considered an open item (498/8630-06) pending:

Completion of the system preoperational tes Performance of an ALARA review of the gaseous radwaste system, including the recommendations of ANSI /ANS 55.4-197 *

Review of operating procedures for valving errors and operating conditions which could contaminate nonradioactive system Develop a sampling / analysis program as recommended in IE Bulletin 80-1 Verification of tank volumes, representative sampling, discharge flow rates, and recorder reading No violations or deviations were identifie c. Solid Radioactive Waste System The NRC inspector reviewed the solid radioactive waste system to determine agreement with FSAR commitments and the recommendations of industry standard ANSI /ANS 55.1-197 The NRC inspector noted from document reviews and discussions with licensee's representatives that during preoperational testing the licensee plans, in addition to verifying the flow paths for resins, to demonstrate the transfer capability. The NRC inspector was not able to verify that the resins from the chemical volume control system (CVCS) would be included in this demonstratio The CVCS would include the longest resin transfer pathway with pipe bends of minimum radius. The NRC inspector determined.the licensee had not provided for spent resin sampling before transfer to the solidification container. The licensee stated a representative sample would be taken from the solidification container to determine 10 CFR 61.55 classification requirement The NRC inspector noted that the licensee had not performed an ALARA review of the "as-built" solid radioactive waste system against the recommendations of industry standard ANSI /ANS 55.1-197 The NRC inspector also noted that the preoperational test.did not address the ability to transfer spent resins and concentrates to the vendor-supplied portable solidification syste This is considered an open item (458/8630-07) pending:

Completion of approved preoperational test procedure Completion of preoperational test Verification of representative sampling of spent resin _, _

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Performance of an ALARA review of the solid radwaste system, including the recommendations of ANSI /ANS 55.1-197 No violations or deviations were identifie . Air Cleaning Systems The NRC inspector reviewed the licensee's air filtration system to determine agreement with FSAR commitments, the recommendations of ANSI N509-1980, N510-1980, and Regulatory Guides 1.140 and 1.5 The licensee had committed to testing all air cleaning systems, in FSAR Table 9.4-4, " Filters Performance Data and Tests Acceptance Criteria,"

which utilize HEPA filters and iodine removal carbon filters (activated charcoal adsorber beds) to the recommendations of ANSI N510-1975 and RDT M16-IT which is included in ANSI N509-1976, Table 5.1. The NRC inspector noted the licensee had received new activated charcoal in 1986, analytical report 9151/3, April 16,1986, and analytical report 7492/1, August 8, 1986, which had been tested and was acceptable to ANSI N509-1980. The acceptance criteria of ANSI N509-1980 is to ASTM D3803-1979, not RDT M16-IT. The NRC inspector also noted that the activated charcoal had not been loaded into the filter housings at the time of this inspectio The NRC inspector discussed with licensee representatives the advantages of changing the FSAR and proposed Technical Specifications to the ANSI N509-1980 and N510-1980. The licensee stated they were considering changing to the newer standar The NRC inspector discussed with licensee representatives the desirability of including portable air cleaning systems which use HEPA filters on a test schedule, such as initially and after each filter change, since these units will be used as an engineering control to reduce airborne particulates in the plan The licensee stated they would consider testing these system This is considered an open item (498/8630-08) pending:

Completion of preoperational testin Resolve issue of which ANSI document testing will be performed to 1975-1976 or 198 No violations or deviations were identifie . Radiation Monitoring Instrumentation The NRC inspector reviewed the licensee's inplant radiation monitoring system to determine agreement with FSAR commitments, NUREG-0737 requirements, and the recommendations of industry standards

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ANSI /ANS 6.8.1-1981, 55.4-1979, 55.6-1979, N13.1-1969, N13.10-1974, and N323-197 Area Radiation Monitoring System The NRC inspector reviewed the area radiation monitor range and locations described in Table 12.3.4-1 of the FSAR against the recommendations of industry standard ANSI /ANS 6.8.1-1981, Table The NRC inspector noted that the licensee had not designated an area radiation monitor for the portable solidification system control panel area in the truck bay adjacent to the mechanical and electrical auxiliary building The licensee had not installed the area radiation monitoring detecto'rs nor completed prerequisite testing or preoperational testing of this system at the time of this inspectio This is considered an open item (498/8630-09) pending:

Completion of preoperational testing of all area radiation monitor Completion of calibration, surveillance, and operation procedure Evaluation of monitoring requirements at the portable solidification syste No violations or deviations were identifie Process and Effluent Radioactivity Monitoring System The NRC inspector reviewed the process and effluent radioactivity monitors described in Table 11.5-1, 11.5-2 and 12.3.4-2 of the FSA The NRC inspector was not able to identify the necessary procedures for surveillance, calibration, and operation of all the process and effluent monitors from the station procedure status and inde The NRC inspector discussed with licensee representatives the need to verify that the installed liquid, particulate, and iodine monitors are viewing a representative portion of the effluent stream and that the calibration of gaseous and liquid radioactivity monitors is performed with appropriate gaseous and liquid standards, traceable to the National Bureau of Standards (NBS), over the full range of the instrumentatio This is considered an open item (458/8630-10) pending calibration of

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gaseous and liquid radioactivity monitors with NBS traceable gaseous

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The NRC inspector did not verify that the process and effluent radioactivity monitoring systems conformed to the recommendations of ANSI /ANS-N13.1-1969, " Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities"; N13.10-1974, " Specifications and Performance of Onsite Instrumentation for Continuously Monitoring Radioactivity in Effluents"; and N323-1978, " Radiation Protection Instrumentation Test and Calibration." This will be reviewed during a future inspectio The NRC inspector noted that the licensee had not provided a particulate, iodine, and gaseous radioactivity monitor for the portable solidification system control panel are This is considered an open item (498/8630-11) pending:

Completion of preoperational testing of process and effluent monitor Determination of effluent monitor calibration source Completion of process and effluent monitor surveillance, calibration, and operational procedure Determination of representative sampling for offline monitor No violations or deviations were identifie . Procedures The NRC inspector reviewed the licensee's procedures to determine compliance with 10 CFR Part 20, 10 CFR Part 61, 10 CFR Part 71, and 49 CFR Parts 100-199 requirements; recommendations contained in RGs 1.33, 4.15, 8.8, and 8.10; and NUREG 076 The licensee had not developed all procedures in the following areas:

Radioactive Waste Activities - Shipping, storage, handling, and compactio Area, Process, and Effluent Instrumentation - Operation, surveillance, and calibratio Filter Replacement and Surveillance - Liquids, HEPA, and charcoa Air Cleaning Systems - Maintenance and testin Filter and Shield Cask Handlin Sampling and Effluent Release Control Solid Waste Processing Contro i l

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This is considered an o)en item (498/8630-12) pending completion of procedures referenced a)ov . Exit Interview The NRC inspector met with licensee representatives identified in paragraph 1 at the conclusion of the inspection on September 19, 198 The NRC inspector discussed the scope and findings of the inspection, including the open items identified in paragraph 3. The NRC inspector stated that open. items identified in this report, except 498/8630-04 and 498/8630-10, must be resolved before issuance of an operating license.

Open item 498/8630-04 must be resolved prior to any radioactive material

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greater than type A quantities being offered for transport and 498/8630-10 i

must be resolved within 6 months of power operation.

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