IR 05000130/2002003
| ML17291A675 | |
| Person / Time | |
|---|---|
| Site: | 05000130, Columbia  |
| Issue date: | 03/01/1995 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A674 | List: |
| References | |
| 50-397-95-04, 50-397-95-4, NUDOCS 9503080076 | |
| Download: ML17291A675 (11) | |
Text
ENCLOSURE U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-397/95-04 License:
NPF-21 Licensee:
Washington Public Power Supply System 3000 George Washington Way P.O.
Box 968, MD 1023 Richland, Washington Facility Name:
Washington Nuclear Project-2 Inspection At:
Washington Nuclear Project-2 Inspection Conducted:
January 30 through February 3, 1995 Inspector:
L. T. Ricketson, P.E.,
Senior Radiation Specialist Facilities Inspection Programs Branch Approved:
urra
,
C
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,
ac>>t>e nspection Programs Branch Date Ins ection Summar Areas Ins ected:
Routine, announced inspection of portions of the radiation protection program, including the program to maintain occupational exposures as low as reasonably achievable (ALARA), solid radioactive waste management, and the transportation of radioactive materials; Results:
guality assurance audit and surveillances of activities provided management with good insight into the success of the implementation of the ALARA concept (Section 1. 1).
Acceptable progress was made with most elements of the source term reduction plan (Section 1.2).
The quality assurance organization performed sufficient reviews of the process control program but did not devote attention to transportation activities (Section 2. 1).
'P503080076 950303 PDR ADOCK OS000397 PDR
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The experience of supervisory personnel in the radwaste group was a
strength.
The balance of the staff was appropriately trained and qualified (Sections 2.2 and 2.3).
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A good solid radioactive waste management had been implemented.
Housekeeping within the radioactive waste building needed improvement (Section 2.4),
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Implementation of the transportation program was good.
No problems had occurred with waste shipments (Section 2.5).
Summar of Ins ection Findin s:
Violation 397/9241-03 was closed (Section 3. 1).
Inspection Followup Item 397/9314-03 was closed (Section 3.2).
Inspection Followup Item 397/9330-01 was closed (Section 3.3).
Violation 397/9417-01 was closed (Section 3.4).
Attachment:
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Attachment Persons Contacted and Exit Heeting
-3-DETAILS
MAINTAININGOCCUPATIONAL EXPOSURE ALARA The licensee's program was inspected to determine compliance with Technical Specifications 6.5, 6.8, 6. 11, and 6. 12 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapter, 12 'of the Final Safety Analysis Report.
1.1 Audits and A
raisals The inspector reviewed the following quality assurance surveillances that addressed ALARA considerations:
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294-005,
"On-Line Condenser Tube Plugging Tests,"
performed January 14-15, 1994
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,
294-026,
"ALARA Considerations During Diaphragm Replacement on CRD SPVS," performed April 6, 1994
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294-034,
"Mechanical Stress Improvement Process,"
performed April 28 through June 3,
1994
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294-039,
"Outage ALARA Awareness,"
performed May 11, 1994
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295-006,
"Management Support of ALARA Activities," performed January 9-16, 1995
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295-007,
"ALARA Program Observation,"
performed January 10-21, 1995 The surveillances occasionally identified deficiencies and consistently provided recommendations for improvements.
The inspector determined that surveillances by quality assurance personnel were conducted with sufficient frequency and in enough detail to provide management with'a good assessment of daily program performance.
guality Assurance Audit 294-010,
"Radiation Protection,"
was performed February 28 through March 14, 1994, and included a review of the ALARA program.
The audit team included a technical specialist for the, area of ALARA design reviews.
The quality of the audit was good.
Four recommendations for improvement were made by the audit team in this area.
1.2 Plannin and Pre aration The licensee's collective radiation dose in 1994 was 867 person-rem.
On November 8, 1994, licensee representatives met with Region IV staff and presented a plan to reduce source term within the plant and lower total radiation exposure.
During this inspection, the inspector reviewed actions taken by the licensee to implement the elements of the plan.
The inspector determined that the
licensee was proceeding with the implementation of most items; however, no progress had been made in two areas:
(1) the installation of sensing probes on floor and equipment drain sumps had not been addressed and (2) no progress had been made on implementing a mechanism to ensure that operations personnel were aware of the consequences of draining systems and the possible effects on radiation levels and personnel doses.
During the discussion, the radiation control personnel recognized that they would either need to use one tracking system or devise a means of coordinating the use of the several site tracking systems being used in order to ensure that all items were addressed.
1.3 Conclusions The quality assurance audit and surveillances of activities in this area provided management with good insight into the success of the implementation of the ALARA concept.
The licensee made acceptable progress with most elements of its source term reduction plan.
SOLID RADIOACTIVE WASTE MANAGEMENT AND TRANSPORTATION OF RADIOACTIVE MATERIALS (86750)
The licensee's program was inspected to determine compliance with Technical Specification 6. 11, the requirements of 10 CFR Part 71, Department of Transportation Regulations
CFR Parts 171 through 178, and agreement with the commitments of Chapter 11 of the Final Safety Analysis Report.
2. 1 Audits and A
raisals The inspector reviewed the results of guality Assurance Audit 93-648,
"Radioactive Waste Process Control Program,"
performed December 6,
1993, through January 10, 1994, and determined that the requirements of Technical Specification 6.5.2.8.
1 were met.
The audit addressed:
radioactive waste processing and storage practices, implementation of process control licensing elements, radioactive waste control room operations, and radioactive waste/material related corrective actions and commitments.
The audit did not address transportation activities.
The inspector noted that NRC Bulletins 79-19 and 79-20 listed actions to be taken by licensees.
Item 7 in both bulletins was an instruction to:
"Establish and implement a
management-controlled audit function of all transfer, packaging, and transport activities to provide assurance that personnel, instructions and procedures, and process and transport equipment are functioning to ensure safety and compliance with regulatory requirements."
The bulletins predate the licensee receipt of an operating license; however, the licensee addressed this item in a letter dated August 28, 1979.
The response is tracked by Commitment Data Entry V0941 and states,
"We have reviewed the Bulletin and will assure that recommendations contained in Items 1-7 will be met for our plants when they reach the operating stage."
In answer to the inspector's question on how Item 7, specifically, was being met, licensee representatives responded this is fulfilled by the aggregate of all of the Quality Assurance (QA) activities specified in the SNP-2 Operational Quality Assurance Program Document (OQAPD).
This includes:
the review and self checking of each shipment performed by the radwaste program manager, supervisors, and workers; the quality checks performed for shipments; and QA surveillances and audits performed by the QA organization.
The quality assurance group had performed only one surveillance of transportation activities since the previous inspection of this area.
Quality Assurance Surveillance 295-015,
"Radioactive Haterials Shipping Assessment,"
was performed January 26 through January 31, 1995, at the request of the radwaste supervisor, after this NRC inspection was announced.
The surveillance included four recommendations for improvement.
2.2 Chanches A new radwaste supervisor was designated September 1993.
A new radwaste crafts supervisor had been with the program for approximately 1 year.
Through interview and resume review, the inspector determined that both individuals had extensive experience in radwaste and transportation activities.
The group also included a health physicist who had primary responsibility for operating the computer code, used to classify and characterize radioactive waste.
In a recent change of operation, a senior and junior radiation protection technician were assigned to the radwaste group.
The technicians'esponsibilities included the conducting of radiation surveys on radioactive shipments and ensuring that proper health physics practices were followed during the preparation of radioactive shipments.
2.3 Trainin and ualifications of Personnel During the review of shipping documents, the inspector noted the names of individuals taking part in the shipping operations.
The inspector requested a
list of people who had been provided training in U.S.
Department of Transportation and NRC regulatory requirements, in accordance with the licensee's commitment to follow the instructions in NRC Bulletin 79-19.
The inspector compared the training list with the names noted during the-transportation records review, but could not confirm that all people taking part in the transportation activities had been trained.
Licensee's representatives acknowledged that there were apparent problems with the training records management system but maintained that all individuals had been trained.
The licensee was able to verify through alternate means, such as by the presentation of training certificates or other records, that all individuals had been trained and were qualified to take part in transportation activitie.4 Im lementation of the Solid Radioactive Waste Pro ram The licensee had identified the following waste streams:
Reactor Water Clean-Up Filter Demineralizer Powdered Resin Equipment Drain and Floor Drain Filter Demineralizer Powdered Resin Condensate Filter Demineralizer Powdered Resin Equipment Drain and Floor Drain Polishing Bead Resin Dry Active Waste and Reactor Coolant Based Waste The inspector reviewed sampling results and confirmed that these waste streams were sampled annually, as required.
Scaling nuclides used by the licensee were Co-60, Cs-137, and Ce-144 for activation products, fission products, and transuranics, respectively.
The inspector reviewed the following procedures and determined that they offered appropriate guidance:
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11.2.23.2,
"Radioactive Waste Classification," Revision
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11.2.23. 14,
"Sampling of Radioactive Waste Streams, Revision
The inspector toured the radioactive waste building and noted several areas where housekeeping needed improvement.
On the 507-foot elevation of,the radioactive waste building, the inspector noted examples of plastic bags and packaging in contaminated areas, contrary to the licensee waste reduction philosophy.
The same items were observed sitting on step-off pads on consecutive days.
Licensee representatives accompanying the inspector also identified a roll of plastic sheeting stored for future use in a contaminated area.
The licensee's representatives stated that they were trying to discourage the use of this type of material because it, also, was contrary to their waste reduction philosophy.
On the 467-foot elevation of the radioactive waste building, the inspector observed three vacuum cleaners sitting against the wall behind a piece of sheet metal in a room used to store unused resin.
The inspector performed radiation measurements and identified radiation levels of approximately
millirems per hour on contact and 25 millirems per hour at 30 centimeters.
Licensee's representatives acknowledged that this area was not the final staging area for the vacuum cleaners.
The inspector determined that the vacuum cleaners had been in the area for at least 2 weeks.
The inspector also confirmed that a radiation survey of the area was conducted on January 16, 1995.
The inspector noted that the area around the reactor water cleanup resin precoat area was posted as a high high radiation area (the licensee's term for an area with radiation levels greater than 1000 millirems per hour)
and was being controlled by the use of.rope barricades and flashing lights.
Licensee's representatives stated that this area had been controlled in this manner for 3 to 4 weeks, but that they did not intend that this be the long-term method of contro.5 Shi in of Low Level Radioactive Waste for Dis osal and Trans ortation of Other Radioactive Material The licensee maintained current copies of applicable regulations and burial site licenses and permits.
A subscription service provided copies of regulation updates, Copies of applicable certificates of compliance for shipping containers and radioactive material licenses for shipment consignees were on file.
The inspector verified that the individuals responsible for transfer, packaging, and transport of low-level radioactive material were designated in writing.
The inspector also reviewed the following procedures and identified no problems:
11.2.23.3,
"Radioactive Material Shipping Names," Revision
11.2.23.4,
"LSA Radioactive Materials Shipments,"
Revision
11.2.23.6,
"Shipping Other than LSA Radioactive Materials," Revision
11.2.23.29,
"LSA Contaminated Laundry Shipments,"
Revision
The inspector attended a prejob briefing presented before the loading of a shipment of condensate resin destined for burial.
The briefing was not required by the radiation work permit but was held to ensure workers understood their responsibilities.
Instructions in the applicable radiation work permit and radiation survey results were also discussed, The inspector determined that this was a good practice.
The inspector observed the ensuing preparation of shipment No. 95-07 and observed no problems.
Afterward, the inspector reviewed the shipping documents and, likewise, identified no problems.
The inspector reviewed random shipping documents and interviewed cognizant personnel and determined that the licensee made 140 radioactive shipments in 1994.
Approximately 74 of the shipments contained radioactive waste.
No problems were identified at the waste burial site.
No problems were identified by the inspector during the review of shipping records.
2.6.
Conclusions The quality assurance organization performed sufficient reviews of the process control program but did not devote attention to transportation activities.
The experience of supervisory personnel in the radwaste group was a strength.
The balance of the staff was appropriately trained and qualified as required.
Implementation of the solid radioactive waste management was good; however, housekeeping within the radioactive waste building needed improvement.
Implementation of the transportation program was good.
No problems had occurred with waste shipment FOLLOWUP (92904)
3. 1 Closed Violation 397 9241-03:
Dis osal of Radioactive Coolin Tower Studqe From August 1985 to December 1992, the licensee disposed of cooling tower sludge containing radioactivity at an average concentration of 5 E-7 microcuries per milliliter by burial in an on-site landfill.
This method was not authorized by
CFR 20.301.
In an amended response to the violation dated September 6,
1994, the licensee committed to submitting an application to the state of Washington for disposal of the cooling tower sludge in accordance with 10 CFR 20.2002.
Until the disposal conditions are established by the state, the licensee committed to storing the sludge in shallow basins lined with plastic.
The basins were located inside the fence of the solid waste landfill complex.
3.2 Closed Ins ection Followu Item 397 9314-03:
Control of the Installation and Removal of Shieldin NRC inspectors noted examples in which temporary shielding had been installed on one shift, removed on the next shift before the completion of work in the area, and then reinstalled in the same location.
The inspectors determined that the licensee did not have a means of identifying who was authorized to install and remove shielding or how the shielding was to be installed or removed.
This item was further reviewed during NRC Inspection 50-397/93-39.
The licensee initiated Problem Evaluation Request 293-976 to track the resolution of the concern.
The issue was considered by the Senior Site ALARA Committee in January 1994 and the committee decided that the responsibility should be given to the Radiation Protection Hanager.
Administrative Procedure 1.3.44,
"Control of Temporary Shielding," Revision 5, stated that the Radiation Protection Manager is responsible for implementation of the temporary shielding program, for having an ALARA review performed to determine shielding requirements, ensuring a log is maintained of all installed temporary shielding, and that craft manpower is assigned to install/remove the temporary shielding.
3.3 Closed Ins ection Followu Item 397 9330-01:
Tritium in storm drain ponds Small quantities of tritium and other licensed material were found in the storm drain pond.
It was determined that some of the material came from contamination of the turbine building sumps.
However, the tritium contamination resulted after liquid recondensed from gaseous effluents on external horizontal building surfaces and was carried by water runoff into the storm drain ponds.
The gaseous effluents 'contained tritium vapor originating from steam leaks in the plant primary coolant system.
As corrective action, the licensee ceased pumping liquid from the sumps to the pond.
To address the presence of tritium, the licensee requested from the
-9-state of Washington a revision of the site HPDES permit to include tritium below the concentration of 20,000 picocuries per liter.
3.4 Closed Violation 397 9417-01:
Failure of Radiation Workers to Read the Latest Revision of A licable Radiation Work Permits
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NRC inspectors identified individuals entering the radiological controlled area without reading the latest revisions of the radiation work permits.
Problem Evaluation Request 294-0460 was initiated to track the resolution of the problem.
As corrective action, the licensee stopped work to ensure that radiation protection management's expectations were understood.
Workers were questioned by radiation protection personnel, and copies of the latest revisions of the radiation work permits were maintained at radiation protection control points.
Workers are required to review the radiation work permits before gaining access to the radiologically controlled are ATTACHMENT
PERSONS CONTACTED 1. 1 Licensee Personnel
- J.
P. Albers, Radiation Protection Manager
- J, R. Allen, Radwaste Health Physicist
- W. H. Barley, Corporate Radiological Health Officer
- T. I. King, Radwaste Crafts Supervisor
- C. R. Madden, Technical Specialist, guality Assurance
- J. A, McDonald, guality Assessment Manager
- M. M. Monopoli, Maintenance Manager
- J. J.
Muth, Plant Assessment Manager
- L. M. Nolan, Radwaste Supervisor
- R. F. Patch, Health Physics Operations Supervisor
- J.
M. Pedro, Licensing Engineer
- V. E. Shockley, Assistant to Radiation Protection Manager
- J.
C. Wiles, guality Assurance Engineer 1.2 NRC Personnel
- Denotes personnel that attended the exit meeting.
In addition to the personnel listed, the inspector contacted other personnel during this inspection period.
EXIT MEETING An exit meeting was conducted on February 3, 1995.
During this meeting, the inspector reviewed the scope and findings of the report.
The licensee did not express a position on the inspection findings documented in this report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector.