IR 05000397/1985003
| ML17277B624 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/29/1985 |
| From: | Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17277B623 | List: |
| References | |
| TASK-2.B.3, TASK-2.F.1, TASK-TM 50-397-85-03, 50-397-85-3, NUDOCS 8502210080 | |
| Download: ML17277B624 (18) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-397/85-03 Docket No.
50-397 License No.
NPF-21 Licensee:
Facility Name:
Washington Public Power Supply System P.
O. Box 968 Richland, Washington 99352 I
Washington Nuclear Project No.
(WNP-2)
Inspection at:
WNP-2 Site, Benton County, Washington Inspection conducted:,
January 7-11, 1985 Inspectors:
'
G. I.
ie man, Ra ation Specialist D te Signed Approved By:
G. P.
u as, Chief Facilit s Radiological Protection Section Date Signed Summary:
Ins ection on Januar 7-11 1985 (Re ort No. 50-397/85-03)
Areas Ins ected:
Routine unannounced startup inspection to examine implementation of TMI action items II.B.3 (PASS)
and II.F.l (Effluents)
and followup on previous inspection findings.
The inspection involved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> onsite by one regionally based inspector.
Results:
Of the areas inspected, no violations or deviations were identified.
!
8502210080 850131 PDR ADOCK 05000397!
Pt
DETAILS 1.
Persons Contacted
='D. Walker, Plant Quality Assurance Manager-C. Powers, Assistant Plant Manager
>J. Martin, Plant Manager-W. Fitch, State of Washington, EFSEC
- "C. VanHoff, Supply System
>J.
Shannon, Director, Power Generation-
-G. Bouchey, Director, Support Services
- "J. Peters, Plant Administrative Manager
"-L. Berry, Health Physics Supervisor
"-R. Graybeal, Health Physics/Chemistry Manager V. Schockley, Health Physics/Chemistry Support I. Bradford, Health Physicist R. Wardlow, Health Physicist D. Larson, Manager, Radiological Programs J. Mills, Plant ALARA Coordinator D. Gano, Shift Technical Advisor B. Talbert, Shift Technical Advisor M. Wuestefeld, Reactor Engineering Supervisor D. Feldman, Plant QA Supervisor R. Mertens, Plant Quality Assurance L. Morrison, Chemistry Supervisor A. Davis, Radiochemist Supervisor
"-Denotes those individuals attending the exit interview on January 11, 1985.
2.
Licensee Action on Previous Ins ection Findin s a
Violations (0 en)
50-397/84-07-02):
Violation involving failure to properly classify radiation monitors as quality Class 1 equipment.
The licensee's response letters dated May 10, 1984 and June 15, 1984, identified the root cause for misidentification of quality class as lack of clear direction to assure correct classification.
The licensee's review determined that misidentification occurred in quality class (QC)
1 equipment items scoped within quality Class
system boundaries.
The licensee reviews further identified 10 systems with misidentified work documents, these systems which had QC 1 component documents misidentified were:
~Sstem No.
S stem Title 4.0 11.0 31.1 31.2 35.0 36.0 Reactor Water Cleanup Closed Cooling Water Floor Drain Processing Equipment Drain Processing Radioactive Drains Process Radiation Monitor
'f
.I J
1'
62.0 72.0 80.0 106.0 Fire Protection Reactor Feedwater System Reactor Building HVAC Process Sampling The licensee's corrective actions for the misidentified documents were described in their June 15, 1984 letter.
The corrective actions are being tracked by the licensee under their Plant banality Assurance Surveillance Program.
The licensee corrective actions consist of gC classification review of components, classification of document review, document action review and retest or reinspection as required.
At the time of inspection, the licensee had closed their review for seven of the ten systems identified.
The licensee will advise NRC RV of final actions taken upon completion of their reviews.
This matter remains open pending completion of the licensee effort and NRC examination of corrective actions.
b.
Ins ector Identified Items (Closed)
(84-20-07):
Item regarding completion of the Chemistry and Radiochemistry Test Procedure 8.2.1.
Inspection Report 50-397/84-20 described NRC review of this procedure.
Review of test conduct and test results are described in paragraph 5 of this report.
(Closed)
(84-20-08):
.Item regarding completion of the Radiation Protection Test Procedure 8.2.2.
Inspection Report 50-397/84-20 described NRC review of this procedure.
Review of test conduct and test results are described in paragraph
of this report.
3.
External Ex osure Control a
~
The inspector examined the area of dosimetry use including proper wearing of dosimeters, comparison of pocket dosimeters with thermoluminescent dosimeter results and extremity dosimetry.
This area was found acceptable.
b.
Radiolo ical Occurrences The inspector examined the licensee's log of radiological occurrences.
Of the 23 occurrences logged, 15 were completed in review and considered closed regarding corrective actions.
The occurrences examined appeared to be minor incidents of the type and number expected for a new facility, namely procedural violations and minor skin contamination.
The licensee's action in the areas of followup, corrective actions and decontamination surveys were adequat l'
c ~
Control of Radioactive Material The inspector examined the 'log maintained of release surveys and observed technicians performing these surveys at the access control point.
The inspector observed an instance where the, technician failed to document a release survey.
The inspector also observed a
survey technique that could fail to identify contamination.
These matters were promptly corrected when identified to the heal,th physics-supervisor.
The inspector noted that while records of surveys are required by 10 CFR 20.401, and these records are kept by a log maintained at the radiological access point, no procedural requirement
.has been developed to maintain this log or provide guidance in 'its use.
The inspector noted that plant procedures manual, (PPM) procedure 11.2.15.7,
"Release of Material from Radiolo icall Controlled Areas " provides survey guidance but not documentation guidance.
This deficiency was identified to licensee personnel.
No violations or deviations were identified 4.
Facilities and E ui ment a
~
New Facilities The licensee is constructing a 2000 square foot building to be used as an alternate health physics access/control point for outage workers.
The inspector reviewed construction status and plans for this facility.
The licensee intends to complete this facility in time for the spring 1985 outage.
The licensee is also constructing a decontamination facility which will consist of chemical cleaning and degreasing tanks and work
, space.
Ventilation systems for these tanks will be equipped with high efficiency particulate filters.
Work on this facility is also expected to be complete for the upcoming outage.
b.
Portal Monitors The inspector examined the licensee's technique for source testing the portal monitors at the health physics control point.
The licensee uses a 200 nanocurie Cesium-137 source to verify operability of this monitor.
The inspector noted that under some conditions and when the source is placed in a persons pocket the portal monitor will,not detect the source.
The licensee's evaluation of this matter, will be examined in a subsequent inspection (Open, 85-03-01).
No violations or deviations were, identifie k IJ
5.
Radioactive Waste S stems - Startu Testin Startup testing and test results for radioactive waste systems including chemistry control, radiochemistry control, effluent monitoring, off gas system and the reactor water cleanup system were examined.
The review was to verify that required tests were conducted in accordance with the test program and that results were reviewed and approved as required.
a
~
Chemistr and Radiochemist
" Effluent Honitors The FSAR Chapter 14, Section 14.2.1.2.3.1,
"Test Number 1 - Chemical and Radiochemical
" describes the licensee's commitment. to perform certain tests.
This description includes the statement,
"Calibrations will be made of monitors in the stack, liquid waste systems and liquid process lines".
The FSAR test description includes test acceptance criteria.
These descriptions do not specifically address acceptance criteria for any calibrations.
The acceptance criteria related to monitors are that the activity of gaseous and liquid effluents must. conform to license limitations.
Calibrations performed during the chemical and radiochemical test were to calculate off gas flow, perform reactor coolant activity balances and to study the response of process and effluent radiation monitors to effluent radioactivity, concentrations.
The inspector reviewed completed t'est procedure 8.2.1 and the Startup Test Report prepared by General Electric.
Based on this review the inspector noted the following items in the area of calibration of monitors.
Acceptance criteria for certain aspects of the test were not included in the procedure, however, the FSAR described acceptance criteria were met.
Tests conducted to verify the off gas post treatment monitor response and tests conducted to verify reactor building elevated release monitor response and calibration were not conclusive in that sufficient activity. was not available -at those monitors to produce readings significantly above background.
J The inconclusive result for verification of calibration of radiation monitors was not documented with a procedure deviation or nonconformance report.
Licensee representatives were aware of the need to perform additional measurement and stated that the calibration verifications would be performed at a future date.
The inspector noted informality in the review, documentation, and approval of this test in that; portions of the startup test report data were illegible; notations were made in other than space provided and not explained, and blocks were left
incomplete.
These missing or unclear items were not formally identified in the test review process.
These observations represent a lack of attention to detail.
This matter was discussed with licensee representatives at the exit interview.
The inspector will examine the licensee's future calibration verifications in a subsequent inspection (50-397/85-03-02).
b.
Chemistr Control Data gathered in startup test 8.2.1 were compared against GE documents GE22A7303, Fuel Warrant S ecification
, GE22A2707, Rev.
(Feed)
Mater ualit S ecification and the Technical Specifications.
The data sheets were examined from tests 8.2.1:
11.0, 11.1, 11.13, 11.14, 11.9.
Acceptance criteria were maintained within limits as stated in the Startup Test Report and Apparent Test Results Form.
Data from test 8.2.1 indicate that reactor system water quality was maintained within the limits of technical specification 3.4.4.
Current chemistry results with the reactor operating were also reviewed and found to be within Technical Specification limits.
c.
Chemistr and Radiochemistr Effluent Release Concentrations The inspector reviewed gaseous activity release data and liquid activity release data to verify that effluent levels remain within Technical Specification limits.
Based on a selective examination of startup test data through test condition six and the semi annual effluent release report for the period January to June 1984, the inspector concluded that effluent concentrations remain well below regulatory limits.
No violations or deviations were identified in the area of startup testing.
6.
Health Ph sics Trends The inspector examined the monthly Health Physics/Chemistry Trending Report for November 1984.
The report provides trend analysis of radiological performance factors including worker exposure, effluent releases, radioactive waste, coolant chemistry and radiochemistry and plant health physics indicators.
The following items were noted by the inspector; Whole body exposure through November was 20.8 man rem distributed as follows: station 10.5, utility 2.5, contract 7.8.
The maximally exposed individual received less than 0.75 rem to date.
Offsite air doses from all effluents and pathways are less than 20% of the TS limit A total of 16000 cubic feet of radwaste have been generated containing approximately 30 curies of activity.
Radiological occurrences and skin contamination together total 28 for the year to date.
Trending of plant contaminated areas, radiation areas and airborne activity areas showed increases expected with plant power ascension.
Reactor coolant gross activity has remained below 0,1 microcuries/gram.
-4 Haximum dose equivalent iodine trended was 1.8 x 10 microcuries per gram.
The health physics trending report appears to provide useful information for reviewing the status of plant radiological indicators.
7.
Licensee Audits The inspector examined selected surveillances conducted by the licensee's plant gA organization in the areas of chemistry and radiation protection.
The following surveillances were examined.
Surveillance number Area 2-84-055 2-84-077 2-84-078 2-84-107 2-84-142 2-84-197 2-84-142 2-84-198 2-84-215 2-84-140 Offsite Shipment of RAM Radiation Area Access Control Radiological Surveys Radiation Exposure Records Contamination Control ALARA Program Contamination Control Radiation Vork Peimit (RWP) Control Inter facility Transfer of RAM Internal Exposure Only two of the audits identified deficiencies.
The deficiencies did not warrant further regulatory attention.
8.
Radiation Protection Startu Tests FSAR Section 14,2.12.3.2 describes the licensee commitment to perform radiation measurements to assure the protection of personnel in the plant.
These measurements'are implemented as test procedure 8.2.2.
The inspector verified by review of the completed test procedure and the startup test report STR-2, that the test was conducted in accordance with the test procedure and that the'acceptance criteria were met.
Two radiation base points were noted by the licensee where dose rates exceeded FSAR'design radiation levels, these were the entrance to the TIP room and the condenser bay entrance.
The licensee has determined that no remedial actions are necessary as the two locations are within identified high radiation areas.
No violations or deviations were ident'ified.
e
l
ALARA Pro ram The ALARA program at WNP-2 is implemented by section 11.2.2 of the PPM.
The inspector examined licensee records to verify that the program is being implemented.
Procedure 11.2.1.2,
"ALARA Program" describes programmatic objectives in the following areas:
ALARA Goals and Objectives Training Plant Modification Plant Procedure Review Outage Planning Work Request Review Post Activity Evaluation The inspector reviewed the last three plant ALARA committee meeting minutes.
The following items were noted.
The plant ALARA committee is functioning as required ALARA goals are utilized ALARA suggestions are examined and assigned for action I
The inspector examined the licensee's program in the areas of work request review and procedure review.
The ALARA checklist required by PPM 11.2.1.2 and other prejob activities were examined for a reactor water cleanup pump seal replacement job and found to meet the general criteria of Regulatory Guide 8.8 gC.3.a,
"Preperation and Planning."
Based on discussion with the ALARA coordinator, interaction with other work groups for ALARA planning is acceptable.
Based on review of several current RWP's and discussion with the ALARA coordinator, ALARA review of RWP issuance as stated in PPM 11.2.8.1'step 5.A.2.f 'appears adequate
.
The inspector reviewed conduct of PPM 11.2.2.7
,
"ALARA Procedure Analysis" by examining a selection of approximately 50 of the ALARA procedure reviews that have been performed to date.
Based on this review, the inspector noted that step 11.2.2.7.5.2.a, the determination that an ALARA review is necessary, or marking the form "N/A" if not necessary>
is not being'performed.
Step 11.2.2.7.5.3 requires calculation of exposures associated with the procedure and that this information be documented on the ALARA review form.
Step 11.2.2.7.5.4 states that changes agreed to by the author be n'oted in the comment section of the ALARA review form.
The inspector noted that the three steps noted above were not documented on the procedure review form for any of the reviews examined.
The ALARA coordinator stated he was not aware of these requirements and had not performed them.
Step 11.2.2.7.5.10 8 ll states that the Health Physics and Chemistry Manager (HPM) or his designee will review the ALARA review form and sign and date the procedure review for t
Steps
Sr ll were accomplished, however, the HPM designated the AIARA Coordinator to review his own work.
This designation appeared to be a
contributing cause.to the condition that steps 11.2.2.7.5.3 and 4 were not performed.
Examples of failure to follow a written procedure represent an unacceptable degree of formality.
This area will be examined in a subsequent inspection (open, 50-397/85-03-03)
10.
Exit Interview The inspector conducted an exit interview on January ll, 1985, at the conclusion of the inspection with the individuals denoted in paragraph 1.
The inspector summarized the scope and findings of the inspection.
The inspector discussed the findings presented in paragraphs 3.c, 5.a and 9.
These findings indicate a lack of attention to detail which can lead to violations of regulatory requirement t.
II i t