IR 05000445/1988007

Insp Repts 50-445/88-07 & 50-446/88-06 on 880201-05.No Violations or Deviations Noted.Major Areas Inspected: Licensee Radiological Environ Monitoring Program Including Organization & Mgt Controls & Training & Qualifications

ML20147F591
Person / Time
Site:	Comanche Peak
Issue date:	02/29/1988
From:	Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20147F576	List: IR 05000445/1988007 ML20147F569
References
50-445-88-07, 50-445-88-7, 50-446-88-06, 50-446-88-6, NUDOCS 8803070386
Download: ML20147F591 (13)

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APPENDIX U.S. NUCLEAR REGULATORY COMISSION REGION-IV NRC Inspection. Report: .50-445/88-07 Construction Persits: CPPR-126 50-446/88-06 ~CPPR-127

. Dockets: 50-445'-50-446

' Licensee: TU Electric 400 North Olive, L.B. 81 Dallas, Texas 75201 Facility Name:- Comanche Peak Steam Electric Station (CPSES)

Inspection At: CPSES Site, Glen Rose, Texas Inspection Conducted: February 1-5, 1988 Inspector: . .:t8 r

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B.. Nicholas, Senior Radiation Specialist Date '

ilities Radiological Protection Section Approved: W 2/ Egg D6te I B. Murray, Chief Facilp ies Radiological

. Protection Section Inspection Summary Inspection Conducted February 1-5, 1988 (Report 50-445/88-07; 50-446/88-06)

Areas Inspected: Routine, unannounced preoperational inspection of the licensee's radiological environmental monitoring program (REMP) including organization and management controls, training and qualifications, and implementation of the REM Re=ults: Within the areas inspected, no violations or deviations were identified. One previously identified open item is closed in paragraph Two new open items are discussed in paragraphs 6 and BBg]DR 45 PDR ADOCK O P O

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, DETAILS o Persons Contacted TU Electric i

• A. B. Scott, Vice President, Nuclear Operations

• D. Bever, Supervisor, Quality Assurance (QA) Audits M. R. Blevins, Manager, Technical: Support

'R. W. Borden, Chemistry / Environmental Technician D. M. Bozeman, Chemistry / Environmental Manager G.~,J. Brown, Chemistry / Environmental Technician

• J. D. Bull,. Environmental Supervisor C. -D. Curry, Senior Chemistry / Environmental Technician

• R. D. Delano, Licensing Engineer

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• E. T. Floyd, Radiation Protection Technician

• W. G. Hartshorn, Supervisor, QA Operations Start Up Surveillance

• N. S. Harris, Senior QA Surveillance Technician

• D. L. Hubbard, Supervisor, Nuclear Operations Training

• G. J. Laughlin, Supervisor, Instruments and Controls (I&C) Support

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n *P. A. Leyendecker, Supervisor, Site Surveillance

• W. I. Helton, Executive Assistant to Vice President of Nuclear Operations

• D. M. McAfee, Manager, QA R. Rasmussen, Supervisor, I&C Computer Group

• E. J. Schmitt, Radiation Protection Manager

• J. C. Smith, Plant Operations

• B. W. Wieland, I&C Manager NRC ,

• H. Livermore, NRC Senior Lead Inspector

• S. D. Bitter, NRC Resident Inspector, CPSES

• Denotes those present during the exit interview on February 5, 198 . Followup on Previous Inspection Findings (92701)

(Closed) Open Item (445/8504-01; 446/8503-01): Meteorological Equipment l Space Parts Inventory - This' item was identified in NRC Inspection l Report 50-445/85-04; 50-446/85-03 and involved the lack of adequate spare parts '

l to maintain meteorological tower operability. The NRC inspector reviewed

the licensee's inventury of meteorological equipment and procedures for l maintaining on hand an adequate supply of spare components for preventive I maintenance or replacement to keep at a minimum a single channel operation of all meteorological equipment. The licensee's corrective actions resolved the NRC's concerns. This item is considered close .

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3. Open Items An open item is a matter that requires further review and evaluation by the NRC inspector or licensee. Open items are used to document, track, and ensure adequate followup on matters of concern to the NRC inspecto The following open items were discussed with the licensee during the exit interview on February 5,1988, and are identified in paragraphs 6 and 7 of this repor Open Item Description 445/8807-01; 446/8806-01 Environmental Air Sampler Calibration 445/8807-02; 446/8806-02 Meteorological Instrumentation Reliability 4. Organization and Management Controls (83522)

The NRC inspector reviewed the licensee's organization, staffing, identification and correction of program weaknesses, audits and appraisals, communication to employees, and documentation and implementation of the chemistry / environmental section (C/ES) to determine adherence to commitments in Chapter 13 in the Final Safety Analysis Report (FSAR) and the requirements in Section 6.2 in the draft Technical Specifications (TS).

The NRC inspector verified that the organizational structure of the C/ES was as defined in the FSAR and draft TS. Management control procedures and position descriptions were reviewed for the assignment of responsibilities for the management and implementation of the REMP. The NRC inspector verified that the admini5trative control and program implementing responsibilities specified in procedures were being implemented. Selected documents listed in Attachment 1 to this report were reviewe The NRC inspector reviewed the staffing of the C/ES and determined the section was fully staffed including a supervisor, a senior chemistry / environmental technician, and two chemistry / environmental technicians. All of the C/ES staff except for the senior chemistry / environmental technician are new to their positions and responsibilities since the previous NRC inspection of this area in February 198 The NRC inspector r.oted that the C/ES personnel turnover had been approximately 75 percent in the past 36 month The C/ES staffing was detennined to be in accordance with licensee co mitment No violations or deviations were identifie . ._ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

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4 Training and Qualifications (83523)

The NRC inspector reviewed the licensee's training and qualification program for C/ES personnel responsible for implem n ting the REMP including: education and experience, adequacy ano quality of training, employee knowledge, qualification requirements, new employees, Institute of Nuclear Power Operations (INP0) accreditation, and audits and appraisals to determine adherence to commitments in Chapter 13 in the FSAR and the requirements in Sections 6.3 and 6.4 in the draft T The NRC inspector reviewed the education and experience of the present C/ES staff and verified that they met the required qualifications specified in the FSAR and draft TS. It was determined that the licensee had an adequately qualified staff to conduct the REM The NRC inspector reviewed the licensee's training program for C/ES personnel including a review of training procedures, personnel training  !

records, and qualification cards. The NRC inspector found that the licensee's training program was being implemented and documented in accordance with CPSES procedure Selected documents listed in Attachment 1 to this report were reviewe No violations or deviations were identifie . Radiological Environmental Monitoring Program (80521)

The NRC inspector reviewed the licensee's REMP to determine adherence to the requirements in Sections 3/4.12, 6.8, and 6.9.1.6 in the draft T The NRC inspector reviewed the licensee's procedures for implementation of the preoperational REMP. The procedures for the administration of the REMP and collection and shipment of radiological environmantal samples to meet draft TS requirements were written with sufficient detail to ensure TS complianc Selected procedures and documents listed in Attachment 1 to this report were reviewe The NRC inspector reviewed the annual preoperational radiological environmental monitoring reports for 1984, 1985, and 1986 and determined that the sampling and analysis requirements specified in the draft TS had been me A review of current REMP activities verified that the radiological effluent technical specifications (RETS) as proposed in NUREG-0472, "Radiological Effluent Technical Specifications for Pressurized Water Reactors," were being implemented. The NRC inspector reviewed the annual land use censuses which were conducted in 1984, 1985, and 1986 and performed out to a radius of 5 miles from the plan The NRC inspector reviewed the licensee's draft Offsite Dose Calculation Manual (0DCM) dated December 1987 and the draft Radioactive Elfluent and Environmental Monitoring Manual (REEM) dated October 1987 and determined ,

that both documents appeared to contain the required information in accordance with the draft TS and were being submitted to the NRC Office of '

Nuclear Reactor Regulation for approva I

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The NRC inspector reviewed selected REMP sample logs, laboratory receipt forms, and data reports for 1986 and 198 The NRC inspector inspected the following types of sampling stations:

airborne, surface / drinking water, ground water, direct radiation (thermoluminescent dosimeters, TLD), milk, and broad leaf vegetation. The required equipment at the selected sampling stations was in place and operational at the time of the inspection. During the inspection of the various environmental sampling stations, the NRC inspector verified that the locations were as described in the licensee's environmental manual procedures and Table 6.1 of the draft REEM and Table 3.1 of the draft 00C The NRC inspector reviewed the calibration program for the REMP air samplers. The air sampler flow indicators have normally been calibrated annually by the I&C department per I&C Manual Procedure, INC-405, Air Sampler Flow Indicator Calibration," Revision 1, dated September 22, 198 Environmental Manual Procedure, ENV-201, "Collection, Preparation, Storage, and Shipment of Air Samples," Revision 3, dated May 13, 1987, requires that during the weekly collection of the air particulate filter and charcoal absorber samples that the air sampler calibration sticker be checked to assure that the air sampler is in current calibration. The procedure does not define current calibration or the frequency of calibration, nor does the calibration sticker on the air samplers indicate the calibration due date. However, it has been the practice of the licensee, since 1982, to annually calibrate the air sampler flow indicators in conjunction with preventive maintenance on the air sampler During the inspection of the air sampling stations, the NRC inspector noted that 5 of the 10 air samplers which were in service had not been -

recalibrated within the last 12 months. Further investigation concluded also that 2 of the 3 air samplers which were out-of-service as replacements had not been recalibrated within the last 12 months. The licensee had not established a required calibration frequency for the environmental air sampler flow irdicators and had not placed the 13 air samplers on the measuring and test equipment (KLTE) listing for maintenance and calibration. This observation was discussed with the licensee during the inspection and at the exit interview on February 5, ,

1988. The licensee agreed to revise the necessary procedures to establish a required calibration frequency, add the 13 air samplers and calibration requirements to the M&TE list, and replace the 5 air samplers in the field which had not been recalibrated within the last 12 months with more recently calibrated air samplers as soon as possible. This is considered an open item (445/8807-01; 446/8806-01) pending licensee resolutio The NRC inspector reviewed the licensee's environmental TLD progra The licensee had an approved procedure for the placement, collection, preparation, and shipment of environmental TL0s to the offsite contractor l

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laboratoryL for processing. The NRC inspector compared the licensee's TLD 1 results to the NRC:TLD results for collocated TLD sites for 1985 and 1986 t and noted satisfactory agreement between the result l

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No violations or deviations were identifie . . Meteorological ~ Monitoring Program (80521)

i The NRC inspector reviewed the licensee's meteorological monitoring program (MP) to determine adherence to commitments in Chapter 2.3.3 in the FSAR, the requirements in Section 3/4.3.3.3 in the draft TS, and the recommendations of Regulatory Guides (RG) 1.23 and 1.97 and American National Standards Institute (ANSI /ANS) Stan<iard 2.5-198 The NRC inspector reviewed the primary and backup meteorological towers'

data monitoring and recording equipment, instrument calibration procedures, and calibration records. It was verified that the two l meteorological towers instrumentation was being calibrated semiannually !

by I&C technicians and daily channel checks of instrumentation operation !

and validity of data were being performed by a health physics technician assigned to determine meteorological instrumentation data recovery reliabilit The NRC inspector discussed with the licensee the recommendation of ANSI /ANS 2.5-1984 and RG 1.23 to perform a reliability test to document a-joint meteorological instrumentation data recovery for atmospheric-stability, wind speed, and wind direction to be at least 90 percent for an annual period prior to plant operation. The NRC inspector reviewed the licensee's unedited joint recovery meteorological *

data for the period July through December 1987 and noted that the joint recovery of data had been determined to be approximately 88 percen >

Edited joint frequency meteorological data for January 1988 indicated a *

recovery of 97.5 percent. . A similar concern had been identified as an open item in NRC Inspection Report 50-445/84-06; 50-446/84-03 and was closed in NRC Inspection Report 50-445/84-43; 50-446/84-17. However, since the

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i licensee has not demonstrated, since 1984, at least a 12-consecutive-month .

joint data recovery of greater than 90 percent and documented this test during the station preoperational phase, this is again considered an open item (445/8807-02; 446/8806-02) pending completion of a documented study showing at least a 12-consecutive-month joint recovery of meteorological data of greater than 90 percen ;

No violations or deviations were identifie ; Quality Assurance Program (80521) ,

c The NRC inspector reviewed the licensee's QA surveillance and audit programs to determine adherence with commitments in Chapters 13.4 and 1 in the FSAR and requirements in Section 6.5.2.8 in the oraft T The NRC inspector reviewed selected QA surveillance and audit procedures, surveillance and audit schedules for 1986 and 1987, and the qualifications -

of surveillance technicians and auditors. Surveillances and audit reports ,

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of QA activities performed during 1984, 1985, 1986, and 1987 in the areas related to the REMP were reviewed for scope to ensure thoroughness of program evaluation. The NRC inspector noted that the QA surveillances and QA audits were designed to determine compliance with the draft TS and REMP procedures. The NRC inspector reviewed surveillance and audit plans, checklists, and findings and confirmed that the identified findings were reviewed by licensee's management and that responses and corrective actions to findings had been completed and documented in accordance with QA procedures. The NRC inspector determined that the surveillances and audits were performed by qualified personnel knowledgeable in REMP activities. Selected documents and procedures listed in Attachment 1 to this report were reviewe No violations or deviations were identifie . Facilities, Equipment, and Supplies (80521)

The licensee collects and ships REMP samples to an offsite contractor laboratory for analysis. The NRC inspector inspected the facilities, equipment, and supplies that are used by the licensee for preparation of REMP samples for shipment. The facilities, equipment, and supplies appeared to be adequate to perform the REMP requirement No violations or deviations were identifie . Contractor Activities (80521)

The licensee uses a contractor laboratory to perform analyses of REMP samples. The licensee's program for oversight of contractor activities and the quality control of analytical measurements by the contractor were reviewed to verify adherence to the requirements in Sections 3/4.12 and 6.9.1.6 in the draft TS and agreement with the recommendations of RG 4.1 The licensee performs vendor audits triannually with annual evaluations to retain current status on the approved vendors list. The NRC inspector reviewed the audit performed on the licensee's contractor laboratory in March 1985 and verified that the contractor had been approved for the required analyses and placed on the current approved vendors lis The licensee's contractor laboratory participates in the U.S.

l Environmental Protection Agency's (EPA) Environmental Radioactivity i

Laboratory Intercomparison Program. The NRC inspector reviewed the i licensee's contractor laboratory's results of the cross-check sample l analysis comparisons for 1984, 1985, and 1986 as published in the annual l REMP reports and found most of the laboratory's results were within the

! EPA's acceptance criteria of three standard deviations of the known EPA value ,

No violations or deviations were identified.

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i 11. Reportable Occurrences (80521)

The NRC inspector reviewed the licensee's licensee event reports and the 1984, 1985, and 1986 annual environmental monitoring reports for reportable occurrences dealing witn the REMP to determine adherence to the reporting requirements in Section 6.9.1.6 in the draft TS. No reportable occurrences or events relating to the REMP were identified during the inspectio No violations or deviations were identifie . Exit Interview The NRC inspector met with the NRC operations resident inspector and the licensee representatives denoted in paragraph 1 at the conclusion of the inspection on February 5, 1988. The NRC inspector summarized the scope of the inspection and discussed the inspection findings and two open items as presented in this repor l l

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! . ATTACHMENT

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. COMANCHE PEAK STEAM ELECTRIC STATIO '

-NRC-Inspection Report: 50-445/88-07; 50-446/88-06

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Documents Reviewed

.TitlA' ~ Revision .Da'te Station Administration Manual STA-101, Nuclear Operations Organization 5 07/14/87 STA-402, Station . Quality Surveillance Program- 6' 07/01/85

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STA-608, Control of Measuring and Test Equipment- 10 09/03/86 STA-624, Administrative Control of the Offsite Dose Calculation Manual and Process Control' Manual 0 12/10/85

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STA-714, Meteorological Monitoring Program 0 03/11/86

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, Chemistry / Radiochemistry Manual

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CHM-101, Chemistry / Radiochemistry: Administrative' 6 65/13/87

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CHM-103, Cher2istry and Environmental Shipping of 1 12/16/86-Samples c: ..

-- CHM-106, Chemistry :and Environmental Sdction - l' 06/19/86 Organization:and Responsibilities

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L Environmental Manual ENV-200, Radiological Environmdntal 0 Not Issued I

Sampling / Analysis Program ENV-201, Collection, Preparation, Storage, and 3 05/13/87 Shipment of Air Samples ENV-202, Collection, Preparation, Storage, and 2 04/16/86 Shipment of Fish Samples ENV-203, Collection, Preparation, Storage, and 2 04/16/86 Shipment of Vegetation Samples ENV-204, Placement, Collection, Preparation, and 3 04/16/86 Shipment of Thermoluminescent Dosimeters ENV-205, Collection, Preparation, and Shipment of 2 04/16/06

- Surface, Ground ~ and Drinking Water Samples

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Y0 - INC-7683X,sChannel Calibr'a tion Primary 10m' Tower ~3 '09/08/87 WindJSpeed Channel 4118

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.-INC-7685X, Channel Calibration Primary.60m' Tower 3 12/28/87 Wind Direction Channel 4115 INC-7686X, Channel'. Calibration Primary 10m Tower 3 12/28/87

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'INC-7687X, Channel Calibration Backup Tower 10m 3 12/28/87

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NQA 2 3.'07, Quality Assurance Audit Program; 0 10/05/87

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NQA-3.23, Surveillance. Program 0- 10/05/87

[ Quality Surveillanc'e Report 84-013,' Env'ironmental

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. Radiological Monitoring Program, dated May 6, s.: 1985

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. Surveillance Activity-Summary - 87009,

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Environmental Radiological Surveillance of

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Surveillance Activity Summar'y - 87054,? Verification .

of: Land Use Census. Plotting.on Radial ~ Maps, date '

Mays 7, 1987

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: Surveillance ActivityJSummary --87062, I&C -

.Meteorologica1LSystem, dated June 8, 1987 Surveillance Report.No. 05-87-0009,. Collection, Preparation, Storage and Shipment of Fish

. Samples, dated October 23, 1987-Surveillance Report No. OS-87-0010, Instrumentation a'nd Control Channel Calibration Air Delta Temperature "A", Primary ~ 60. Meter Tower, dated October 26; 19871

. Surveillance Report No. OS-87-0028, Site Meteorologica1' Monitoring Program, dated

December 12, 1987

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. Surveillance Repers No. 05-88-0002, Primary 110 Meter Tower Wind Direction Calibri, tion, dated

. January 13, 39C8

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Surveillance Report No. 05-88'0009, Pr! mary 10 Meter Tower Dew Point Calibration, dated

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January 28, 1988 Quality Assurance Audit TUG-86-15, Environmental Monitoring Program, conoucted June 23-27, 1986 Quality' Assurance Audit.idG-87-15, Environmental Monitoring Program, conducted June 24 through

- July 2, 1987-Quality Assurance Audit TEL-1, Teledyne Isotopes-Westwood, New Jersey, conducted March 28-29, 1985 Approved Vendors List Comanche Peak Steam Electric Station Annual Environmental Radiation Monitoring Reports 1984 Annual Report 1985 Annual Report 1986 Annual Report s

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