ML20202D778
| ML20202D778 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/12/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20202D766 | List: |
| References | |
| 50-498-98-02, 50-498-98-2, 50-499-98-02, 50-499-98-2, NUDOCS 9802170174 | |
| Download: ML20202D778 (21) | |
See also: IR 05000498/1998002
Text
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-498; 50-499
Report No.: 50-498/98-02;50-499/98-02
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
Oates: January 12-15,1998
Inspectors: Michael P. Shannon, Senior Radiation Specialist
Michael C. Hay, Radiation Specialist
Approved By: Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
Attachment: Supplemental Information
9802170174 980212
PDR ADOCK 05000498
G PDR
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EXECUTIVE SUMMARY
South Texas Project Electric Generating Station, Units 1 and 2
NRC Inspection neport 50-498/98-02; 50-499/98-02
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This announced, routine inspection reviewed extemal exposure controls, internal exposure
controls, dose assessment and dose records, controls of radioactive materials and
contamination, staff training and qua'ification in radiological protection programs, and radiation
protection quality assurance activities.
Ooerations
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Following an airborne radiation alarm in the Unit 1 reactor containment building, control
room personnel failed to inform the health physics staff of the alarm in accordance with
management expectations (Section R1.3).
Plant Suocort
Overall, a good external exposure cor, trol program was in place; however, problems
were identified with a prejob as low as is reasonably achievable (ALARA) briefing. High
radiation area controls were effective (Section R1.1).
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Hot * wkeepbg wRhin the radiological controlled areas of Unit 1 and 2 was very good
(Sec on R1.1).
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Overall, a good internal exposure control program was implemented (Section R1.2).
Overall, a good program was in place for calibration and response checking of station
radiation survey meters. Effective cont;ols were implemented to prevent the spread of
contamination. All radioactive material was properly labeled and posted (Section R1.3).
A violation was identified for the failure to survey for radiciodine airborne activity in the
Unit i reactor containment building (Section R1.3).
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A non-cited violation was identified for the failure of workers to follow radiation work
permit requirements (Section R1.3).
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A violation was identified for the failure to post the reactor cavity as an airborne
radioactivity area (Section R1.3).
A violation, with two examples, was identified for the ft lure to inform workers of changing
radiological conditions (Section R1.3).
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Effective training programs were maintained for radiation protection technicians and
radiation workers (Section RS.1).
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Report Det4[13
Summarv of Plant Status
Both Units 1 and 2 operated at full power during the inspection period. !
IV. Plant Sunoort
R1 Radiological Protection and Chemistry Controls
R1.1 External Exoosure Controls
a. insoection Sqoce (83750)
Selected radiation workers and radiation prc'ection personnelinvolved in the extemal
exposure control program were interviewed. Tours of the radiological controlled area
were performed. The following items were reviewed:
- Radiological controlled area access controls
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Job coverage by radiation protection personnel
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Housekeeping within the radiological controlled area
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Dosimetry program
b. Observations ard Findinas
The inspectors conducted several tours of the radiological controlled area and performed
independent radiation measurements to confirm the appropriateness of radiological
postings. All Technical Specification high radiation areas were properly locked and
posted. All workers observed in the radiological controlled area wore their dosimetry
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properly and knew to contact radiation protection personnel if their electronic dosimeters
alarmed. Housekeeping throughout the radiological controlled area was very good.
The inspectors determined that job coverage provided by radiation protection technicians
was appropriate for the radiological work observed. The inspectors attended a Unit 1
orejob ALARA briefing addressing entry into the reactor containment building during
power to remove insulation from a valve. The inspectors observed a good e. change of
information among the participants including: expected dose rates obtained from
historical surveys; unexpected radiation levels that would warrant turning back; and
proper handling, storage, and tagging of the insulation material following its removal. The
health physics technician assigned to provide job coverage discussed the expected
radiological conditions with the worker. The discussior also included a change in
radiological conditions that would be present in approximately 2 days, when the valve
was to be removed and the letdown heat exchanger was secured.
The inspectors commented that discussing future radiological conditions could lead to
workers' confusion. This observation was similar to observations made in NRC
Inspection Report 50-498/97-10; 50-499/97-10. Health physics management agreed that
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further attention was needed to ensure that workers understood applicable radiological
information.
A review of Radiation Work Permit 1998-1-0155, Revision 0, used for the above task
identified that the radiological work area dose rates were listed as 50-60 millirems per
hour. However, a review of the radiological survey information revealed work area dose
rates were documented as70-100 millirems per hour. The inspectors commented that
providing radiological information on a radiation work permit that was not accurate could
lead to workers' misunderstanding of the radiological conditions. Health physics
management acknowledged the inspectors' comment.
l Neutron Doses
The licensee stated that approximately 8 to 10 entries into the reactor containment
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building at power have been made weekly since 1994. The inspectors reviewed neutron
l doses for workers that entered containment at power between January 1991 - June
1990. The inspectors noted that the highest individual neutron dose was 100 millirem in
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a year. Extensive surveys of neutron exposure rates were conducted by the licensee in
both Units reactor containment buildings at 100 percent eactor power to document
neutron dose rates. The licensee informed the insp0,, tors that the average neutron
energy cpectra encountered in the reactor containment at power were between
20 - 60 kilo-electron volts (kev).
The licensee currently process its dosimeters on site and was certified by the National
Voluntary Laboratory Accreditation Program for all categories with the exception of
category 1 which pertains to accident low energy photons. Neutron doses are based on
use of correction factors that were developed using bonner sphere measurements to
characterize the neutron fluence and energy spectra encountered in the reactor
containment building during power. A two-chip lithium-6 dosimeter was used by the
licensee for evaluating neutron doses to personnel. The inspectors concluded that the
neutron personnel dosimeters would provide an accursie response to the neutron
energies workers would encounter during containment entries.
c. Conclusions
Overall, a good external exposure controi sod dosimetry program was implemented. All
Technical Specification required high radiation area doors were properly locked and
posted. Housekeeping within the radiological controlled area was very good. All
personnel observed wore their dosimetry properly. Prejob ALARA briefings were
adequate.
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R1.2 Internal Exoosure Controls
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a. [nsoection Scooe (83750)
Selected radiation protection personnel involved with the internal exposure control
program were interviewed. The following items were reviewei
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Respiratory protection program
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Whole-body counting program, including the calibration of the counter
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The intsmal dose assessment program
b. Observations and Findinas
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The inspectors were informed that no respirators had been issued for radiological
protection since the previous inspection.
Whole body counters were verified to be calibrated using standards traceable to the
NationalInstitute of Standards and Technology (NIST). The inspectors noted that an
l- acceptable phantom was used along with radiation sources that covered energy ranges
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between approximately 88 - 1836 kev. The inspectors concluded that a proper whole
body calibration program was in place.
Internal dose assessments were reviewed. Both whole-body counting of individuals and
estimates derived from cverage airbome concentrations of I-131 taken from air sampling
data resulted in proper estimates of committed dose equivalent. Both techniques were
compared by the inspectors and found in good agreement.
Upon review of air sample data for Unit 1 reactor containment building, the inspectors
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identified that an airbome radioactivity area greater than 0.25 derived air concentration
(DAC) occurred on September 28,1997, in the reactcc cavity. However, the inspectors
determined that no DAC-hour assessments were performed. The licensee initiated
Condition Report 98-659 to evaluate the intemal radiation exposure for personnel known
to have been in the affected area during the event. See Section R1.3, ' Unit 1 Reactor
Cavity Event," for disposition of this matter.
c. Conclusions
Overall, a good intemal exposure control program was implemented. Whole-body
counters were prope:ly calibrated. Intemal dose estimates conducted by the licensee
were properly performed.
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R1.3 Control of Radioactive Materials and Contamination: Su9eving and Monitoring
a. Insoection Scooe (83750)
Areas reviewed included:
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Portable instrumentation calibration and performance checking programs
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Posting and labeling
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Radiological surveys necessary to assess personnel exposure
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Radiation Work Permits
b. Observations and Findinas
l The inspectors reviewed neutron survey meter instrumentation for proper calibration and
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_ energy response testing. A neutron spectrum analysis was performed using bonner
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wphere neutron spectroscopy in the reactor containment building at power. From these
measurements correction factors were calculated. A review of calibration certification
documents noted that the neutron survey meters were calibrated using a PuBe
(plutonium-beryllium) source which was traceable to NIST. These meters were
calibrated to exposure rates rangirig from 2 millirems per hour through 200 millirems per
hour that adequately covered the licensee's normal exposure rates of 20-60 millirems per
Sour errountered in the reactor containment building at power. The inspectors
concluded that the licensee had implemented a proper neutron survey instrument
calibration program.
During tours in the radiological controlled area, the inspectors noted that all portable
radiation protection survey instrumentation observed was properly calibrated and source
response checked.
Radioactive material observed was labeled and posted properly. Contamination
boundaries were all marked and posted clearly.
Unit 1 Reactor Containment Building Airbome Event
The inspectors reviewed Condition Report 97-16562. This report documented a
September 22 23,1997, event in which the airborne concentration of radioiodine in
Unit 1 reactor containment building increased above 0.25 DAC. Areas greater than
0.25 DAC are required by station procedures to be posted as an airbome radioactivity
area. A time line describing the event follows:
September 22,1997
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12:30 p.m. Stopped surveying Unit 1 reactor containment building for airborne
radiciodine activity
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3:41 p.m. Unit 1 reactor containment building purge piaced out-of service for
scheduled calibration
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. 7:52 p.m. Unit 1 reactor containment building atmosphere monitor removed
from service
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8:08 p.m. Unit 1 reactor containment building chill water secured for open
loop cooling water system outage
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10:31 p.m. Contaminated Unit i reactor containment building worker alarmed
personnel contamination monitor
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11:00 p.m. Contaminated worker given whole body count, results indicated
lodine radioactivity was present
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11:40 p.m. Unit 1 health physics personnel received a reactor containment
building atmosphere monitor alarm at the radiological access area
September 23,1997
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12:43 a.m. Unit 1 reactoi containment building air sample revealed greater
l than 0.25 DAC (0.32 DAC), which required that the building be
l posted as an airbome radioactivity area
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1:33 a.m. Unit i reactor containment building posted as an airbome
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radioactivity area
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2:26 a.r Unit 1 reactor containment building air sample less than 0.25 DAC
(posting of airbome radioactivity area removed)
The licensee evaluation determined that the following factors contributed to the
unexpected increase in radioiodine airbome concentration in Unit i reactor containment
t,uilding:- (1) it was known that minor fuel damage existed prior to outage 1RE07 as
evidenced by noble gas, iodine, and cesium concentrations in the reactor coolant;
(2) core alterations were in progress with the reactor cavity full of water; and (3) raactor
containment building purge and chill watei systems were out-of-service resulting in an
increase in temperature and humidity. This increase in temperature and humidity within
the Unit 1 reactor containment building caused an unexpected increase in radioiodine
being carried out of solution from the reactor cavity and going airbome.
Failure to inform Workers of a Chanae in Radioloaical Conditions
During review of Condition Report 97-16562, the inspectors noted that approximately
87 workers were in the reactor containment building on September 22-23, when airborne
radiological conditions changed, thus reouiring the building to be posted as an airbome
radioactivity area. All workers were sigred in on radiation work permits thet stated,"No
entry into posted airborne radioactivity areas (exclading noble gas)." The inspectors
noted no actions were taken to inform the workers of the change in radiological
conditions or posung. The licensee investigation revealed that the night shift health
physics division manager provided instructions [to his staff) "not to stop work," even
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though radiation work permits in use did not permit entry into posted airborne
radioactivity areas. The licensee's investigation noted that the night shift health physics
manager stated that his decision was based on his " assessment that the dose potential
for workcro due to the low concentration was minimal and that his experienca led him to
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believe that subsecuent confirmatory sampling in progress would show air
concentrations below the criteria requiring posting."
10 CFR 19,12(a) states, in part, that all individuals, who in the course of employment, are
likely to receive in a year an occupational dose in excess of 100 millirems shall be kept
informed of the storage, transfer, or use of radiation and/or radioactive material. The
inspectors concluded that workers in the Unit 1 reactor containment building on
September 22-23,1997, were likely to receive an occupational due in excess of
100 millirems per year. The inspectors noted that a similar event occurred again on
September 28,1997, in the Unit 1 reactor cavity which is described on pages 11 and 12.
Corrective acticnc to prevent a recurrence were identified in Condition Report 97-16562,
action item No. 2. The inspectors noted that action item No. 2 required an evaluation of
the "hea!th physics response to posting Unit 1 reactor containment building as an
airbome radioactivity area." The inspectors reviewed this investigation report, which was
dated November 10,1997, and noted that recommended corrective action No. 2, stated,
" Evaluate current procedures to ensure appropriate methods are in place to both allow
health physics to amend radiological controls in the field with appropriate
evaluations / approvals and to communicate field changes to workers." However, the
inspectors concluded that there were no immediate corrective actions that addressed the
failure to inform the workers in the reactor containment building of a change in
radiological conditions.
The inspectors concluded that corrective actions were not implemented within a
reasonable time to prevent the second event which occurred on September 28,1997.
Therefore, this licensee identified event involving the failure to inform the workers of the
presence of airborne radioactive materialin excess of the station posting airbome
threshold requirements, is being cited as the first exemple of a violation of 10
CFR 19.12 (a), because the critcria for exercise of discretion as descritsed in
Section Vll.B.1 of the NRC's Enforcement Policy were not satisfied (50-498L 02-01).
The licensce's position, as stated in the additional material provided to the inspectors on
January 21,1998, is that they do not believe the events involved a violation
10 CFR 19.12(b) because no new radiological health problems were introduced by the
insignificant change in the Total Effective Dose Equivalent (TEDE) stemming from the
airborne radiciodine. Specifically, the licensee stated that the airborne level change was
minimal (adding only approximately 0.24 millirems per hour TEDE to a worker), and that
workers in the area were informed, via radio'ogical postings (radiation area), that
conditions u, to 100 millirems per hour TEDE could exist in the work area.
However, the inspectors noted that at the time the reactor containment building monitor
alarmed at 11:40 p.m. on September 22,1997, the potential radiological health
protection problems were unknown. The fact that the change in radiological conditions
was minimal was not known during the event. The inspectors concluded that conditions
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were unknown for the following reasons: (1) sampling for radioiodine in containment had
stopped at 12:30 p.m. on September 22,1997, thus indicating that the health physics
staff was not expecting a radioiodine airbome condition; (2) a review of the reactor
containment building atmosphere monitor data for September 22,1997, revealed that
airborne radiological conditions were recorded as 2 DAC, and the health physir.s staff
was not aware of this condition; (3) the health physics staff was not aware of an
increasing trend in reactor containment building airbome condition that began when the
reactor containment building purge system was placed out-of service at approximately
4 p.m. on September 22,1997; and (4) at 11 p.m. on September 22,1997, the cause of
a reactor containment building workers contamination alarm was determined to be
radiciodine actWity; however, the licensee took no actions to verify airbome conditions in
the reactor containment building. Additionally, the health physics staff was not aware of
the Unit 1 reactor containment building atmosphere monitor set point until the licensee's
investigation of this event. The inspectors noted that the monitor was set to alarm at
approximately 4 DAC.
Failure to Survey
On September 22,1997, at 3:41 p.m., the licensee placed the reactor containment
building purge system out of service for calibration. The inspectors reviewed the Unit 1
- reactor containment building atmosphere monitor data and noted an increasing trend in
l radiological airborne conditions of 3.25E-10uCi/cc at 4 p.m. to 3.88E-8uCi/cc
l (approximately 2DAC) at 7 p.m. From interviews with health physics personnel, the
) inspectors determined that the licensee was not aware of thia iricreasing trend during this
f time. At 7:52 p.m., the monitor was removed from service for a scheduled surveillance
l test. The health physics staff was not aware that the monitor was removed from service
f until the inspectors' review of this event on January 13,1998. Additionally, once the
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airbome monitor was placed out-of-service, no radiciodine airbome surveys were
performed until 12:15 a.m. on September 23,1997, in response to the reactor
containment building atmosphere monitor alarm. Subsequently, the first time that
radiciodine air sampling was performed following the decision to stop air sampling at
12:30 p.m. on September 22,1997, was at 12:15 a.m. on September 23,1997, some 11
and 3/4 hours later.
Durir,g review of additional material provided to the inspectors on January 21,1998, by
the licensee, the inspectors noted that the licensee stated that they had identified the
issue of failure to survev and were sampling the Unit 1 reactor containment building
airborne radioactivity by using the reactor containment building atmosphere monitor.
The inspectors agree that the atmosphere monitor was in service from the time the
licensee stopped sampling for radiciodine airbome activity on September 22,1997, at
12:30 p.m. until the time it was removed from service at 7:52 p.m. that same evening.
However, there was no information provided to the inspectors to conclude that this
airborne information was being evaluated in an effort to maintain an awareness of the
airbome radiological conditions in the Unit 1 reactor containment building on September
22, at 12:30 p.m. until the monitor was removed from service. Additionally, a review of
the reactor containment building atmosphere monitor data from 7 p.m. on September 22,
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1997, revealed that airborne radiological conditions were recorded at 2 DAC, and no
actions were taken by the licensee to verify this condition.
The licensee also stated that in the analysis section of Condition Report 9716562:
(1) item No.1, ident$ed that airbome radioiodine concentrations above the current
thresholds for posting was projected by health physics prior to the outage. However, the -
information was not synthesized into outage radiation work permits; (2) item No. 2, stated
that, the alert alarm set point for RE80111B at approximately 4 DAC was too insensitive
to provide meaningful warning of increasing reactor containment building radioiodine
concentrations; and (3) item No. 5, stated that, the decision to cease air iodine grab
sampling removed air sampling as a method for early waming of increasing air iodine
concentrations.
The inspectors noted that although the licensee projected the airbome radioicdine
concentrations prior to the outage, it did not relieve the licensee of the requirement to
evaluate the potential radiological hazards that could be present during the time that
work was being performed in a radiological controlled area. Additionally, the inspectors
l noted that corrective action No. 8 of Condition Report 97-16562 stated " develop
l guidance for adjusting radiation monitoring system alarm set points to account for
chan0ing plant conditions, outage periods should be especially reviewed to ensure that
adequate waming of changing conditions is provided when compared to normal plant
conditions." However, there were no actions identified to perform or evs.luate surveys
after the atmosphere monitor was removed from service to ensure compliance with
station procedures or 10 CFR 20.1501(a) requirements.
Technical Specification 6.11.1 states, in part, that procedures for personnel radiation
protection shall be prepared consistent with the requirements of 10 CFR Part 20 and
shall be approved, maintained, and adhered to for all operations involving personnel
radiation exposure.
10 CFR 20.1501(a) states, in part, ". . . that each licensee shall make or cause to ba
made, surveys that: (1) May be necessary for the licensee to comply with the regulations
- in this part; and (2) Are reasonable under the circumstances to evaluate -(ii)
concentrations or quantities of radioactive material; and (iii) The potential radiological
hazards that could be present."
Section 4.6.4 of Radiation Protection Procedure OPGP03-ZR-0050, " Radiation
Protection Program," Revision 1, states, in part, that, " Job coverage, or specific surveys,
shall be of the type and frequency . . to assess the extent of . . concentrations of
radioactive materials and the potential radiological hazards to which workers may be -
exposed.*
The inspectors concluded that specific corrective actions were not completely identified
to address the entire event. Therefore, this licensee identified event involving the failure
to survey for rdiciodine from 3:41 p.m. on September 22,1997, until 12:15 a.m. on
September 23,1997, to determine the concentrations of radioactive material and the
potential radiological hazards present in the Unit 1 reactor containment building is being
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cited as a violation of Technical Specification 6.11.1, because the criteria for exerciss of
discretion as described in Section Vll.B.1 of the NRC'c Enforcement Policy was not
satisfied (50-498/9802-02).
Failure to Follow Radiation Work Per nit Instructions
During the review of Condition Report 97-16562, the inspectors noted that on
September 23,1997, the Unit i Reactor Containment Building was posted as an
"Airbome Radioactivity Area" fiom 1:33 a.m. until 2:26 a.m. During discussions with
health physics staff, the inspectors were informed that between 1:33 a.m. and 2:26 a.m.,
approximately 24 workers entored the reactor containment building, a posted airbome
radioactivity area, using radiation work permits that did not allow entry into this s,rea. A )
review of the corrective actions identified that prior to the next refueling outage, this event
would be highlighted during the training cycle, and mes.ns to physically deter workers
from entering an area where radiological conditions have changed would be evaluated.
The inspectors concluded that these corrective actions would likely prevent a similar
occurrence.
Technical Specification 6.8.1.a states, in part, that written procedures shall be
established, implemented, and maintained covering the app!! cable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.1, recommends procedures for the
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radiation work permit system.
l Radiation Protection Procedure OPGP03-ZR-0051, "Radiologica'. Access and Work
l Controls, " Revision 7, Section 5.3.3, states, in part, "RWP (Radiation Work Permit)
j instructions, radiological postings and baniers, . . . shall be adhered to at all times."
.
The failure to follow the airbome restrictions on the radiation work permits is identified as
t a violation of Technical Specification 6.8.1. However, this nonrepetitive
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licensee identified and corrected v;olation is being treated as a Non-Cited Violation,
consistent with Section Vll. B.1 of the NRC Enforcement Policy (50-498/9802-03).
As discussed previously, during review of the airbome event on September 22,1997, the
inspectors noted that a radiation monitor alarm for Unit i reactor containment was
received in the Unit 1 control room; however, no response actions were docun ented by
the control room staff. In discussions with the Unit 1 operations manager, the inspectors
were informed that if an alarm is expected, documentation was not rec;uired. However,
the inspectors were informed by operations management that it was management's
expectation that this alarm should have been communicated to the health physics staff.
Operations management stated that they would review the circumstances of this event to
improve future communications between operations and health physics staff.
i Unit 1 Reactor Cavity Event
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The inspectors reviewed Unit 1 reactor cavity air samole data and identified that on
September 28,1997, at 11:07 p.m. air sample results indicated thet airbome radiological
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activity was 1.5 DAC. During discussion with the health physics staff, the inspectors
noted that the health physics division manager was not aware of this event untilit was
identified by the inspectors, on January 13,1998. On January 14,1998, the licensee
documented the event in Condition Report 98-659. The inspectors interview-i the
acting health physics supervisor who was involved in this event to gain an u. w tanding
of the circumstances surrounding it. The supervisor informed the inspectors that he was
confused by the fact that the 1.5 DAC air sample was just radioiodine activity and not a
mixture of isotopes. The inspectors were informed that no actions were taken to inform
the workers of the change in radiological conditions because it was the acting health
physics supervisor's opinion that a backup air sample would result in an airbome
radioact" .y concentration below the procedural posting limit (<0.25DAC). The
inspectors questioned the fact that if radioiodine was not expected by the acting health
physics supervisor did he have a compkte understanding of the event. The inspectors
noted that the backup air sample results taken at 11:45 p.m. on September 28,1997,
were less than 0.25 DAC. The inspectors review of the radiological survey data
concluded that v/orkers in the Unit 1 reactor cavity on September 28,1997, were likely to
receive an occupational dose in excess of 100 millirems per year.
A review of Radiation Work Permit 1997-1-0261, Revision 0, which was used for reactor
cavity decontamination revealed that it stated, "No entry into posted airbome radioactivity
areas (excluding noble gas)." The failure to inform the workers of the presence of ,
airborne radioactive materialin excess of the station posting airborne threshold on
September 28,1997, is a second example of a violation of 10 CFR 19.12(a)
(50-498/9802-01).
The inspectors reviewed radiological postings conceming the September 28,199i, event
and identified thht from 11:07 p.m. to 11:45 p.m. on September 28,1997, air sample data
revealed that airbome concentration in the Unit 1 reactor cavity area was 1.5 DAC.
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Technical Specification 6.8.1.a states, in part, that written procedures shall be
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established, implemented, and maintained covering the applicable procedures
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.3, recommends procedures for airborne
( radioactivity monitoring.
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Racation Protection Procedure OPRPO4-ZR-0015, " Radiological Posting and Waming
Devices," Revision 3, Section 2.2 states, in part, "STP (South Texas Projects) will post
airbome raf aactivity areas at 0.25 DAC or greater."
The failure to post the reactor cavity as an airborne radioactivity area on September 28,
1997, from 11:07 p.m. until 11:45 p.m., in accordance with Procedure OPRPO4-ZR-0015,
Revision 3, is a violation of Technical Specification 6.8.1 (50-498/9802-04).
c. Conclusions
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A good program was in place for proper calibration and response checking radiation
survey meters. Radioactive material was properly labeled and posted. Violations were
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identified for the failure to: (1) perform a radiological survey; (2) post the reactor cavity
as an airborne radioactivity area; and (3) inform workers of changing radiological
conditions. A non-cited violation was identified for the failure to follow radiation work
permit airborne restrictions.
R5 Staff Training and Qualification la Radiological Protection
R5,1 Staff Training and Quakfications
a, inspection Scoos (83750)
Personnel involved with radiation protec'Jon technician and radiation worker training were
interviewed. The following items were revieweJ:
- R'adiation protection technician continuing training lesson plans
Radiation worker required training
b. Observations and Findinos
The inspectors interviewed an instructor responsible for the development of radiation -
protection technician continuing training lesson plans. The inspectors were informed that
performance issues identified by the condition reporting system, along with health
physics management input, were useful in determining objectives for upcoming
- continuing training. The in.pectors reviewed the latest radiation protection technician
lesson plan and noted that it contained appropriate subject information.
The inspectors reviewed the training requirements for radiation workers requiring -
unescorted access to the radiological controlled area. Procedure OPRP01-ZR-0005,
" Access Control Point Management," Revision 2, Section 4.1.2, requires that all persons
requiring unescorted access to the radiological controlled area shall have current GET ll
training. The training records for five radiation workers who performed cavity
decontamination during' the Unit 1 Outage 1RE07 were reviewed. The licensee's
documentation verified that each worker was properly trained.
c. Conclusions
The licensee had implemented effective training programs for radiation protection
technicians and radiation workers.
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R7 Quality Assurance in Radiological Protection and Chemistry Activities
R7.1 Quality Assurance Audits and Surveillances. and Health Physics DivisiOD
Self-Assessments-
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a. Inspection Scow (83750)
Selected personnel involved with the performance of quality assurance audits and
surveillances, and radiation department self-assessments were interviewed. The
following items were reviewed:
- Quality assurance audits performed since August 1997
Quality assurance surveillances performed since August 1997
Health Physics division self assessments performed since August 1997
b. Qhservations and Findinas
No quality assurance audits or surve3 lances had been performed since the last radiation
protection inspection in Augusi 1997, Additionally, the inspectors noted that the last
operational based health physics self-assessment was performed in April 1997.
The inspectors reviewed 17 quality assurance monitoring reports (observations) and
noted no negative trends.
V. Manaaement Meetinas
u X1 Exit Meeting Summary
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The inspectors presented the inspection results to members of licensee management at
an exit meeting on January 15,1998. The licensee acknowledged the findings
preselited. The ticensee stated that they did not agree with the potential violation
pertaining to failure to inform the workers when radiological conditions changed because
the actual change in radiological conditions did not constitute a substantial increase to
the workers TEDE. No proprietary in'ormation was identified.
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ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licensee
J. Groth, Vice President, Nuclear Engineering
R. Aguilera, Radiction Protection Supervisor
J. Allessi, Sr. Health Physicist Technician
P. Anington, Licensing Engineer
P. Carter, Sr. Health Physicist Technician
J. Diehl, Health Physicist
L. Earls, Health Physicist
S.C. Horak, Sr. Health Physicist Technician
D. Huberak, Health Physics Technician
J. Inman, Health Physicist
R. Logan, Health Physics Division Manager
J. Lovell, Manager, Unit 1 Operations
R.E. Messe, Unit 2 Plant Manager
J. Sepulveda, Radiation Protection Supervisor
S. Smith, QA Specialist
NBC
W. Sifre, Resident inspector
INSPECTION PROCEDURE USED
83750 Occupational Radic.t.'on Exposure
LIST OF ITEMS OPENED AND CLOSED
Ooened
50-498/9802-01 VIO Failure 13 inform workers of a change in radiological conditions
50-498/9802-02 VIO Failure to survey
50-498/98G2-04 VIO Failure to post and airborne radioactivity area
Ooened and Closed
50-498/9802-03 NCV Failure to follow RWP requirements
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LIST OF DOCUMENTS REVIEWED
Procedure OPGP03ZR0048, " Personnel Dosimetry Program," Revisicn 2
Procedure OPGP03ZR0050, " Radiation Protection Program," Revision 1
Piocedure OPRP02ZR0007, " Evaluation of Intakes," Revision 2
Procedure OPRP02ZR0010, " Personnel Exposure investigation," Revision 3
Procedure OPRP02ZR0011, " Calibration of WBC System," Revision 0
Procedure OPRP02ZX0022, "Non-Routine Dosimetry issue and Control, Revision 5
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Procedure OPRP04ZR0004," Release of Materials From Radiologically Controlled Areas,"
Revision 1
Procedure OPRPO4ZR0013, " Radiological Survey Program," Revision 4
Procedure OPRP07ZR0010, " Radiation Work Permits," Revision 4
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JAH-21-1998 09853
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MILEm L1&NSING 512 972 8290 P.02/05
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ENCLOStlRE 3
January 21,1998
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To: M. A.McBurnett
Freas: R. V. Logan
Subket: SIP Notes on Potential Violations identHind in NRC Inspection
93 2 Radiation Protadlan Programa
'Ibe following is our analysis of the poennrial violations identified in the NRC Exit Meeting
on Januay 15th. We believe that tha potential violation related to nohfination of
individuals requhed by Part 19.12 is not valid. We believe that we have previously
with conective action in progress, the potential violations relative to the entry
into a posted airbome area without the proper RWP and relative to the failure to perfonn
a survey. Additionally, we wuld like to ensure the circumstances relative to the failure to
post an airborne are clearly understood. Accordingly, the following describes our position
on eoch of the Potential violations,
hmm v af one.nei.i vinininn
10CFR19.12(aV1) states: "All individuals who in the course of employment ce likely to-
receive in a year an pecupational done in excess of 100 inrem (1 mSv) shall be kept
infonned of the storage, transfer, or use of radiatina and/or radioactive material."
Contrary to the requirements of 10CFR19.12(a)(1) STP failed to keep workers informed
of a change as required on two occasions. 'Ihe first occasion occuned on 09/22/9'i when
_
workers were not notified when maavned airborne radio-lodine levels were verified to be
0.32 DAC in the rannar containmant building. The second occasion occuned on 09/27/97
when workers in the reactor cavity were not informed of measured radio-iodine levels at
1.5 DAC. In neither case was entry into posted airbome radioactivity areas allowed unde-
the radiation work permits in use. The failure to notify the affected individuals that the
'
instructions previously given, by radiation work permit, were no longer applicable
constitutes a failure to properly inform workers.
Position
South Texas Project does not believe that the events described represent a violation of
NRC Requirements.
10CFR19.12(b) states "In determining those individuals subject to the requirements of
paragraph (a) of this section, the licensee must take into consideration assigned activities
dunng normal and abnormal situa*lons involving exposure to radiation and/or radioactive
material which can reasonably be expected to occur during the life of a licensed facility.
The extent of these instructions must be commensurate with the potential radiologic 1d
heahh protection problems prescrit in the work place."
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, .pp.gcf30= 03:54 tOCLFJR LICENSlHCi- 512 972 8298 P.03/Of2
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It is clear (by direct reference) that section 19.12(b) quali6cs the precedmg section (a) by
dw.dimgt
(i) Who must receive the infonnation in section (a)
'
(ii) To what extent these instructions must be made available, hased on the
potential radiologi^ cal health protection problems present.
While not- explicitly stated, the pote$dal radiological health protection problems -
referenced in section 19.12(b) for a power reactor facility can be assumed to stem from
the total effective dose equivalent (TEDE), found by summing the committed effective
dose equivalent (CEDE) and deep dose equivalent (DDE) for the exposure involved.
In the first occasion cited above, an aidsse level of 0.32 DAC equates to an
approximately equivalent change of 0.24 mrem /hr TEDE. Workers in the area were -
laformed, via radiological p=Haga, that conditions up to 100 mrom/br TEDE could exist
in the work area. During interviews conducted for this investigation the night shift Health
Physics Manager indicated that : hic decision was based on his maanamant that the dose
- petial for workers due to this low concentration was minimal and that his experience
k d him tW5 that subsequent confirmatory sampling in progress would show air
concentration below the criteria requiring posting.- He stated that he had considered a
plant page anncunermant informing woriers of the ahborne radioactivity but rejected this -
l. as he believed that the message would not be clearly understood and potentially cause
undue concern. Additionally, he indicated that he rejected the idea of using the
containmant evacuation alarm as he felt this would result in undue panic on the part of -
workers resulting in potential personnelinjury. In direct questioning regarding the extent
' to which he felt schedule pressure may have influenced his decisions , tbs night shift
Health Physics Manager indicated that his understanding of the minimal exposure potential
that the airborne condition represented and his concem for not creating undue worker
concem and confusion lead to these decisions.
We believe that no new potential radiological health protection problems were introduced
by this insignificant change in the TEDE as a result of the presence of an additional 0.24
mrem /hr in the area. Consequently, we have met our duty to keep workers informed as
required by 19.12(a)(1) through the ire.ial instructions provided to the workers.
In the second occasion cited above, an airbome level of 1.5 DAC equates to an
approximate change of 1.13 mrem /hr TEDE. Workers in the area were informed, via
radiological postings, that conditions up to 1000 mrem /hr TEDE could exist in the work
area. Discussions with the Health Physics personnel in the area has revealed that they
considered the need to pull the individuals out of the area due to the measurement
obtained. However, they believed that this would have resulted in higher total exposures
to the workers due to the need to traverse the area to exit and subsequemly re-enter the
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N21-1998 09 54 MILEM t.lCOGI G 512 972 8290 P.04/06
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area upon compledon of the verification sample. While our full investigation of this
- occunence is not yet complete, the Health Physics personnel have stated that they had the
best interest and safety of the workers at the forefmnt during the event.
We believe that that no new pM*1 radiological health protection problems were
intradwed by this lanignificant change in the TEDE a : a result of the presence of an
additional 1.13 nuem/br in the area. Consequently, we have met our duty to keep workers
informed as required by 19.12(aX1) through the initial instructions provided to the
worken.
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Summary of violation
Wodoers failed to heed radiological airborne posdngs thus violating their radiation work
permits and procedures OPGP03-ZR-0050 and OPOP03-ZR 0051.On 09/23/97
apprmimanaly 24 workers failed to adhere to station procedures governing radiation work
pennha in that they entered a posted airborne radioactivity area when prohibited to do so
by instructions on their radiation work pernut.
Ensiden
S17 concurs that these vinistim occurred;however, these occurrences were self-
identinnd through condation report 97-16562 under the analysis section, item #8,
"Womcas aradne the cantainment on RWPs after 0133 and before 0226 failed to observe
the change in postings and thus failed to comply with their RWPs and with several
procedure steps requiring RWP comphance." While our initial conective actions should be
effective in miminizing the recurrence of similrr events in the future, additional mammuts
were r-maadad to help institudonalize the change. These suggestions have been
inchuled for consideration to help prevent recurrence .
Corrective actions from the condition report.
C5- Include this event in general employee traming industry events. ' Ibis should
be timed to ensure that the majority of STPNOC employees review this
topic during requal pdor to the next outage and contractors coming la for .
the next ourage are also presented this m**arial.
C6- Include a summary of this event in the outage focus day for 2RE06.
C1' - Consider a means to physically deter workers from entering and area where
radiological conditions have changed which may require new radiological
work permitinstructions.
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JfH-21-1998 :09:55 RJCLEAR LICD 61HG 512 972 8290 -P.05/06
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Si=wn=rv of vialation -
10CPR20.1501(a) states: "Each liraneaa shall make or cause to be made, surv vs that (1)
- may be =**sary for the AI -m to comply with the regulations in this part; aM (2) are
ramenanhia under the circumstances to evaluate (i) the xtent of the radiation levis; and
(ii) oone at ations or quantidos of radioactive materials; and (iii) the potential hazards that
could be present."
- On 09/22/97 the E=w failed to pesform the required airborne radioactivity surveys to
_ identify the presence of airborne radio-lodine ira concentations up to 2.0 DAC.
Position
STP concurs that we did not adequately comply with 10CFR20.1501; however, this issue
was selfddantified and is appropriately covered in our actions completed under Condition
Report condition reprt 97-16562.
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A survey, as defined in 10CFR20.1003 means "an evaluation of the radiological candirlans
and pan =!*1. hazards incident to the production, use, transfer, release, disposal, or
presence of radioactive material or other sources of radiation. When appropriate, such an
evaluation includes a physical survey of the location of te radioactive material and
measurements or eawlations of levels of radiation, or eaarantrations or quantities of
radioactive materialpresent."
While a survey was performed prior to the outage, and continuous measurements were
being obtained by plant monitoring instmments (RE8011B - During the lavestigation this -
instrumant was used to calculate the maximum concentration premt in the work place
during the event), the staff failed to utilize these surveys appropriatety. This was ideatified
in the analysis section of condition report 9716562, item #1, " Airborne radio-lodine -
concentrations above the current thresholds for posting was projected by health physics
prior to the outage. This information was tct syd+-M into outage RWPs.", item #3,
"Tbc alert alarm set point for RE8011B at apptoximarr.ly 4 DAC was too irwmitive to
- provide i== hyal waming of mereasing RCB radio-iodine concentrations." and , item
- 6, "Ihe decision to cease air iodine grab umallag removed air sa.mpling as a method for
early waming ofincreaJng air iodine concentrations."
Corrective actions from the condition report -
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C7- Include a discussion cf this eye.at and subsequent programmatic changes
which have occurred in Health Itysics continuing training prior to 2RE06.
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- JFN-21-1We it>*do tOCLEfH L1u.tb1tu g2 m e p, %
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C8- Develop guid:nce for adjusting radiation monitoring system alarm set
points to account for changing plant conditions. Outage periods should be
especially reviewed to ensure that adequate warning of changing conditions
is provided when compared to normal plant operations.
Summary of pneantini viniatian
Health Physics fai'.ed to properly post an airborne area as required by station procedures.
During Unit l's seventh refueling outag*, Health Physics failed to post the reactol cavity
as an airbome radioactivity area as required by station procedures. Air umpling during
cavity A~na**mlantion activities identified radio-iodine concentrations of up to 1.5 DAC
in the work area. No action was taken by Health Physics personnel present in the area to
post the area as airborne radioactivity area.
Positinn s
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STP concurs that the violation occurred. The individual involved was aware that the
previous air samples taken in the area indicated less than 0.25 DAC and fully believed that
the sample in&= ting 1.' DAC was cross contaminated and invalid. He elected to obtain
another air sample in th 'ork area prior to posting the area. 'Ihe back up air sample
identified concentrations buow 0.25 DAC which the individual believed justified taking no
action prior to obtaining the confirmatory air sample. A full investigation is being
performed under condition reoort 98-0659. A full root cause investigation into the event is
expected to be completed by J26/98 with appropriate corrective actions identified.
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