IR 05000445/1993028

Insp Repts 50-445/93-28 & 50-446/93-28 on 930712-16.No Violations Noted.Major Areas Inspected:Insp of Unit 2 Startup Radiation Survey Results Including Audits,Program Changes,Appraisals,Training & Surveying & Monitoring

ML20056D777
Person / Time
Site:	Comanche Peak
Issue date:	08/12/1993
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20056D773	List: IR 05000445/1993028 ML20056D772
References
50-445-93-28, 50-446-93-28, NUDOCS 9308180014
Download: ML20056D777 (9)

Text

.

.

P APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

'

Inspection Report: 50-445/93-28 50-446/93-28 Operating Licenses: NPF-87 NPF-89 Licensee: TU Electric ,

Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station Inspection At: Glen Rose, Texas Inspection Conducted: July 12-16, 1993 Inspector: L. T. Ricketson, P.E., Senior Radiation Specialist Facilities Inspection Programs Section Accompanied by: Heather Astwood, Intern Office of Nuclear Material Safety and Safeguards Approved: ( Jh VI.44/

B. Murray, Chief, Facil t'es Inspection Date

[

Programs Section Inspection Summary Areas Inspected (Units 1 and 2): Special, announced inspection of the Unit 2 startup radiation survey results. The inspection also involved routine inspection activities for both Units 1 and 2 related to the radiation protection program including audits and appraisals, program changes, training and qualifications, external exposure controls, internal exposure controls, controls of radioactive materials and contamination, and surveying and monitorin Results Units 1 and 2): '

. The Unit 2 initial radiation shield survey did not identify any problems or anomalies up to the 50 percent power level. Additional surveys will be performed (Section 2).

• Nuclear Overview conducted a good audit to confirm that the new 10 CFR Part 20 had been properly implemented (Section 3.1).

9308180014 930813 ~

PDR G

ADOCK 05000445 PDR a

'

t l .

l t

.

l l-2-l * Within the radiation protection department, the surveillance and control

! group placed heavy reliance on contract radiation protection personnel I (Section 3.3).

• Permanent and contract radiation protection technicians were qualified

to perform their assigned tasks (Section 3.3).

• Excellent programs were implemented during routine operations for exposure control, calibration of instruments, and control of radioactive contamination and surveying (Sections 3.4-3.6).

1 Summary of Inspection Findings:

,

• Inspection Followup Item was opened (Section 2).

l l

Violation 445/9256-01 was closed (Section 4).

l

, Attachment l

• Attachment - Persons Contacted and Exit Meeting

!

!

!

P i

?

,

l l-3-DETAILS  :

!

'

1 PLANT STATUS At the beginning of this inspection period, Unit I was operating at ,

100 percent power. Unit 2 operated at 78 to 92 percent powe !

!

2 STARTUP TEST RESULTS EVALUATION (72301, 83521) -

l The inspector reviewed the licensee's initial startup radiation shield test !

results for Unit 2. Radiation surveys were performed at approximately 5 and-50 percent power. Additional _ surveys will be performed at 100 percent powe ;

The inspector reviewed Initial Startup Test Procedure 1S0-2088, " Radiation Survey Test," Revision 1, and noted that the procedure was reviewed'and approved before use and that the test-results were reviewed and_. accepted by ,

the Test Review Group. ISU-208B incorporated Radiation Protectio Instruction RPI-604B, Biological Shield Survey." The. licensee 'specifically l

'

compared the test results with established acceptance criteria and-determined that radiation levels were within the maximum acceptable values established, i and most were below the expected levels. Thus far, the licensee had not t identified radiation levels which exceeded the radiation zone _ designations in l Figures 12.3-4 through 12.3-23.8 of the Final Safety Analysis Repor J t

Radiation Protection Instruction RPI-604B " references" American National

^

Standards Institute's (ANSI) ANS-6.3.1-1980, " Program for Testing Radiation :

Shields in Light Water Reactors," but does not commit to follow all provisions l of the industry standard. Licensee representatives explained that this meant :

the procedure writer referred to the document for guidance but did not' !

incorporate.the instructions in their entirety. Consequently, there were :

differences between the licensee's' approved procedure and the guidance i provided in the ANSI document.: For example, ANSI ANS-6.3.1.provided several '

diagrams of techniques for taking radiation measurements at the radiation base ;

points. Section 6.1.3 of RP1-604B instructs, " Survey the areas in the general ;

vicinity of the radiation. base. points." Licensee representatives stated that,. j although it was not proceduralized, the accepted way of taking measurements ~

was to include the area within a 1 meter radius of the radiation base poin In reviewing the survey results, the inspector noted that not all penetrations I or groups of penetrations through the containment building were surveyed. The licensee's procedure included surveys of many mechanical and electrical penetrations in the containment building wall,=but no surveys were made around -1 the main steam line penetrations, for example, at approximately the 880-foot i level. There was only one radiation base point near the feedwater;,  !

penetrations on the 852-foot leve ;

i Licensee representatives replied _to the inspector's questions concerning this i matter and stated that since surveys were obtained inside containment on the 860-foot elevation, outside the bioshield, which. indicated insignificant dose rates (less than 1 millirem / hour), additional survey points outside containment were not warrante .

f i

!  !

.

-;

'

.

!

I-4-The inspector discussed with licensee's representatives the event described in NRC Information Notice 93-39, " Radiation Beams from Power Reactor Biological Shields."

Licensee representatives stated. that penetrations' in the reactor. shield wall and bioshield were not surveyed; however, during a telephone conference on August 11, 1993, the radiation protection manager committed to surveying the i accessible penetrations outside the bioshield. :This is an inspection followup iten (446/9328-01). This and the results of the. licensee's radiation surveys performed at 100 percent power will be reviewed during a future inspectio OCCUPATIONAL RADIATION EXPOSURE (83750)  :

r The licensee's programs were inspected to determine compliance with Technical l Specification 6.11 and the requirements of 10 CFR Part 20, and agreement with !

the commitments of Chapter 12.5 of the Final Safety Analysis Repor l7

!

3.1 Audits and Appraisals The licensee implemented new Part 20 for both units on January 1, 1993. . The

.

Nuclear Overview Department performed'an audit during March 22-29,:1993, to .

!

evaluate the implementation of the new 10 CFR Part 20 changes, i Audit QAA-93-ll3 was performed by a .two-man team from the Nuclear Overview Department. The audit, not designed to be a. comprehensive review of the -

entire radiation protection program, concluded that the regulatory changes had i been properly implemented. No items were identified which- required a response by the radiation protection departmen The inspector reviewed surveillance reports conducted by the Independent l Safety Engineering Group during January 5 through February 22, 1993. The l

.

surveillance report numbers were:. 93-3, 93-4, 93-6, 93-10,:93-17, and 93-8 l l

The reports provided an objective narrative of the events observed. No deficiencies were identified. The inspector noted in Field Note 93-10 that an apparent problem was identified and corrected Ec the time of occurrence. The Containment- Access- Visual -Inspection Verification- Form was. not completed, and . :

the surveillance specialist notified the appropriate management. The l situation was then corrected by the completion of the for f i

The surveillance manager. stated that the pract_ ice followed was to identify j actions which would result in violations or problems, seek immediate j corrective actions, and document them in the surveillance reports. If a  :

violation had already occurred and was identified after the fact,.-the - i surveillance group askpd the responsible group to initiate a Operatioris j Notification Evalu:tien form to document and track the item. If the H responsible group did not, the surveillance group initiated she, form. The

~

1 surveillance group followed up' on the item, regardless of which group

'

I documented i The inspector reviewed.0perations Notification and Evaluation Forms (used for the more significant events) and radiological awareness reports originated since January 1,1993, to evaluate the licensee's radiological occurrence reporting' system. Station Procedure STA-421 provided guidelines for

! z u _ . _ _ _ _ -

-

_ _ .. -. ,_ _ _ _ . _ . . . _ . . .

,

P

.

.

.

- ,

-5- l determining the applicability of the Operations Notification and Evaluation Form. The radiological: awareness- report was used to document events not- i reaching the threshold of the Operations Notification and Evaluation For ;

The investigations of the events documented by both' methods were thorough, and i the corrective actions were timely and appropriat _j 3.2 Changes On June 1, 1993, the radiation protection supervisors in charge of.the .j surveillance and control group and the ALARA group exchanged responsibilitie l A member of the technical support group assumed the position of dosimetry supervisor, after the former supervisor accepted a position with the corporate offic l

!

3.3 Training and Qualifications'

,

.Within the radiation protection department, the surveillance and control group  !

was composed of 19 permanent radiation protection technicians and 18 contract i technicians. The inspector noted that heavy _ reliance was placed on contractor .  !

radiation protection technicians to implement the-routine radiation protection a program in that about 50 percent of the positions were filled with ,

'

contractors. The licensee stated that permanent staffing of the radiation _

protection department was under review to determine which positions would be .,

filled by contractors. The inspector reviewed the licensee's-  !

qualification / task matrix and determined that.all technicians were qualified l to performed basic functions such as radiation surveys, air sampling, an j sample analysi l 3.4 External Exposure Control The inspector reviewed the licensee's dosimetry processing operation and noted that there had been no major changes in'the program since it was reviewed during NRC Inspection 50-445/92-29; 50-446/92-29 and that it continued to be a state-of-the-art program. The accreditation by the National Voluntary l Laboratory Accreditation Program was-extended to July 1,1994._ The license l was accredited in all eight American National Standards Institute N13.11- test  ;

categories and participated in a. quarterly, interlaboratory cross-comparison .!

program with other utilitie .l

. .

l Routine personnel dosimetry was processed quarterly with visitors and i terminated employees' processed monthly. The exposure results were maintained j in the licensee's computer data base until a hard copy was required. The  ;

i inspector reviewed selected examples of reports provided to terminated- 1 employees and determined that the reports satisfied regulatory requirement The inspector discussed problems identified with the Merlin Gerin electronic  !

dosimeter calibrator. The dosimetry supervisor stated that they used .i some Merlin Gerin dosimetry equipment and that they were aware of the - l identified problem, but they did not have a calibrator. Calibration factors l were entered into the' electronic dosimeters manuall !

t

>

1:

I a, w . , . _ . . - , _ . _ _ . _ . - . . _ - . . . _ ,_

d

__

'

-6-The licensee implemented administrative dose limits to maiatain exposures below regulatory limits, and there have been no planned special exposures as i defined in new 10 CFR 20.120 ;

The inspector toured the radiological controlled area and the interim low :

level waste storage area and noted that area postings were in place and clearly visible. The licensee used posting inserts of various colors to distinguish different instructions or area descriptions. The inspector ,

performed independent radiation measurements and did not identify areas improperly poste The inspector observed locked high radiation areas and determined that they were properly controlled in accordance with technical specification requirement .5 Internal Exposure Control .

The inspector reviewed the licensee's program of air sampling and examined its ,

ability to retrieve sampling information for various areas. The inspector determined that the licensee's information retrieval- capability in this area was very goo .

During tours of the licensca's facility, the inspector noted that respirators that were ready for issue had Seen inspected within the previous 30 days, as require ,

!

The inspector reviewed whole-body counting equipment checks and background *

counts and determined that the licensee performed the checks every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, if the equipment was in use. Ambient air respirator fit testing equipment was j operable and available for us .

3.6 Control of Radioactive Materials and Contamination. Surveys, and

!

Monitorinq i

The inspector reviewed selected radiation survey recordscand to verify that, ,

proper surveys were conducted and that the records of surveys were complet ,

From survey records, the inspector compiled a list of survey instruments and reviewed calibration records to verify that the instruments were properly calibrate l Portable survey instruments were calibrated by members of the instruments and controls group working' in the instrument calibration laboratory. The ;

'

inspector interviewed the instruments and controls personnel and determined that a sufficient number of operable, calibrated radiation survey instruments were available for use during routine operations. The instruments and

~

'

controls personnel also performed calibrations on air samplers, tool monitors, personnel contamination sonitors, and portal monitors. Representatives from the radiation protection group performed daily response checks on instruments and ensured that friskers, tool monitors, and personnel contamination monitors :

'

could detect contamination levels of 5000 disintegrations per minute per 100 centimeters square l

!

i I

.

.

'

-7-The inspector visited the control room to inspect radiation monitoring '

readouts and interviewed operations personnel to determine that radiation monitoring was functioning properl .7 Conclusions The inspector determined that a proper Unit 2 startup radiation survey program had been implemented. Although the licensee's procedure for radiation shield testing did not follow exactly industry guidance in all respects, it provided sufficient information to ensure there were no major problems with the containment shield walls. Penetrations of the reactor support wall and bioshield wall were not checked and the licensee committed to review this matter and to perform additional surveys for accessible penetrations as appropriat Because nearly 50 percent of the surveillance and control groups were contract ,

personnel, it was concluded that a strong reliance was placed on

" nonpermanent" employees. All of the technicians were qualified to perform basic health physics tasks, independentl Excellent programs were noted during routine operations in the areas of dosimetry, external and internal exposure, and control of radioactive contamination and surveyin '

4 FOLLOWUP ON CORRECTIVE ACTIONS FOR A VIOLATION (92702) -

(Closed) Violation 445/9256-01: Failure to Survey This event involved workers performing in service inspection preparation work l in the Unit I reactor containment building on November 7, 1992. The workers removed insulation from piping and used a wirebrush to remove corrosion from a e valve without first evaluating the associated radiation hazards, through the analysis of contamination survey The inspector reviewed the corrective actions proposed by the licensee in the letter of January 18, 1993, and determined that the licensee had complied with its commitments. Specifically, the following actions were taken to prevent recurrence of the violation:

! A review was conducted by licensee personnel of selected work groups to determine if contract outage workers had received the proper type and j amount of site orientation / radiation worker trainin Licensee *

'

representatives were concerned that many of the workers had been given s the shorter, site specific radiation protection training inappropriately, rather then the more in-depth initial radiation worker trainin Based on reviews of worker resumes, the licensee determined that this was not a contributing problem, and it concluded that there was no need for a major restructuring of the inprocessing and training syste However, a lesson plan for " Enhanced Radiation Worker Training" was made ready for use. The course, more detailed than the site specific

_ __

. .

!

-

.

!

P-8-training, but more concise than the initial radiation worker training, will be given to selected radiation worker l l

On April 23, 1993, radiation protection personnel presented a seminar to selected permanent employees in the mechanical maintenance department on ,

lessons learned pertaining to radiological _ work practice Presentations to other work groups have been scheduled and will be l completed prior to the next scheduled outag l i

The inspector reviewed a plan developed by radiation protection personnel which provided clear guidance to radiation protection technicians with regard to job coverage responsibilities. The plan was i designed to ensure the against coverage lapses which occurred during Refueling Outage IRF02. The plan also made changes to control point '

locations to improve communication :

,

[

,

I

!

l i

l

)

l l

-!

l i

.

.

ATTACHMENT 1 PERSONS CONTACTED Licensee Personnel

.

• A. M. Barnette, Staff Health Physicist

• S. E. Bradley, Radiation Protection Supervisor, Surveillance and Control

• J. Cahill, Jr., Group Vice President R. S. Carr, Dosimetry Supervisor

• R. E. Fishencord, Radioactive Materials Control Supervisor

• H. S. Harris, Licensing Engineer D. C. Kay, Technical Support Supervisor

• R. J. Prince, Radiation Protection Manager

• C. L. Terry, Vice President, Nuclear Engineering and Support L. A. Wojcik, Nuclear and Mechanical Analysis Supervisor 1.2 NRC Personnel

• D. N. Graves, Senior Resident Inspector, Unit 2

• E. Werner, Resident Inspector, Unit 1

• Denotes personnel that attended the exit meetin In addition to the personnel listed, the inspector contacted other personnel during this inspection perio EXIT MEETING An exit meeting was conducted on July 16, 1993. During this meeting, the inspector reviewed the scope and findings of the report. The licensee did not identify as proprietary, any information provided to, or reviewed by the inspecto ,

l I

!

!

!

!

!

!

9