IR 05000397/1985029
| ML17278A437 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/23/1985 |
| From: | Cook R, Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17278A435 | List: |
| References | |
| 50-397-85-29, NUDOCS 8510090530 | |
| Download: ML17278A437 (18) | |
Text
1 U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
Docket No.
License No.
50-397/85-29 I
50-397 NPF-21
I Licensee:
Facility Name:
Inspection at:
Inspection conducted:
Washington Public Power Supply System P. 0. Box 968 Richland, Washington 99352
'1 Washington Nuclear Pro)ect No. '2 (WNP-2)
WNP-2 Site, Benton County, Washington August 12-21, 1985 and in office inspection effort between August 22 and September 12, 1985 Inspectors:
C. I. Sherman, Radiation Specialist R. Cook, Radiation Specialist Date Signed
't ~s RS Da e Signed Z'0 (115 Approved By:
G. P.
Yu as, Chief Facili i s Radiological Protection Section Da e S gned Summary:
Ins ection on Au ust 12-21, 1985 and in office ins ection effort between Au ust 22 and Se tember 12, 1985 (Re ort 50-397/85-29)
Areas Ins ected:
Routine unannounced inspection of health physics program including followup on violation (92702), transportation (86721), solid radioactive waste processing and disposal (84722, 84850), organization (83722),
and training (83723).
This inspection involved 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> onsite by two regionally based inspectors and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of in office inspection effort.
Results:
Of the areas inspected, one violation was identified in one area for failure to post a radioactive material storage area as required.
85i0090530 850924 PDR ADOCK 05000397
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DETAILS Persons Contacted J.
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- V, A.
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- M, Martin, Assistant Managing Director for Operations Powers, Plant Manager Baker, Assistant Plant Manager Graybeal, Health Physics/Chemistry Manager Peters, Plant Administration Manager Feldman, Plant equality Assurance Manager Berry, Health Physics Supervisor Bradford, Health Physicist Shockley, Health Physics/Radiochemistry Support Supervisor Davis, Senior Radiochemist Allen, Health Physicist Larson, Manager, Radiological Programs Denison, Principal Engineer, NSAG Smith, Lead HP Technician Ehlert, Lead HP Technician Frisch, Engineer Bouchey, Director, Support Services Sorensen, Manager, Regulatory Programs Mills, State of Washington, Energy Facilities Site Evaluation Council
- Denotes those individuals participating in the exit interview on August 21, 1985.
Followu on Enforcement Items A letter dated July 11, 1985, G.
C. Sorensen (SS) to J.
B. Martin (NRC)
contained the response to the Notice of Violation dated June 13, 1985.
The response was examined by the inspector and found consistent with
CFR 2.201.
Violation A involved Technical Specification (TS) 6.2.2.f.2 (overtime).
The inspector verified that corrective steps identified were taken.
These steps included revision to plant procedure manual (PPM) 1.3.2.7 and a memo dated June 26, 1985 from Assistant Plant Manager to Department Managers reemphasizing the TS requirements.
Licensee actions were considered to be satisfactory by the inspector (Closed, 85-20-01).
Violation B involved TS 6.11.1 (radiation protection).
The inspector verified portions of the corrective action taken during the initial inspection (50-397/85-20)
and subsequent actions were examined during this inspection period.
The aforementioned letter stated in part that the six week training cycle scheduled for completion by August 16, 1985, would reemphasize labeling and posting requirements.
A communication problem between the trainin'g department and the plant appeared responsible for this commitment not being met.
The licensee sent a
letter dated, September 1'8',
1985, Sorenson(SS)
to Martin(NRC) confirming that the training w'as completed'.as 'of August 27, 1985 (Closed 85-20-02).
The inspector'xamined the progress of the licensee in completing a review committed tq in response to a Notice of Violation in NRC I
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Inspection Report 50-397/84-07.
This violation related to misclassification of QC 1 equipment within the scope of QC 2 system boundaries.
The licensee initiated non-conformance report documents (NCRs) to resolve problems with those documents with the wrong quality class specified.
The inspector examined several of the NCRs, based on this review, this matter is considered closed (84-07-02, 84-CS-05).
Followu on NRC Circulars and Notices Licensee action regarding the following Circulars and Notices were reviewed by the inspector.
IC-79-21 IC-80-14 IC-80-18 IC-81-09 IN-83-10 IN-84-50 IN"84-15 IN-84-55 IN-83-14 IN-84-61 IN-84-88 XN-84-59 IN-84-91 IN-84-82 GL-85"08 Prevention of Unplanned Releases of Radioactivity Radioactive Contamination of Plant Deminerlized Water
CFR 50.59 Evaluations...Radioactive Waste System Containment Effluent Water Bypass Radioactivity Monitors NRC Certified Transport Packages QA Programs for 10 CFR 50/10 CFR 71 Reporting of Radiological Releases Seal Table Leaks Spent Resin...exothermic Chemical Reaction Overexposure of Divers SBGTS Problems Circumventing Health Physics Procedure QC Meteorological Measurements Guidance for Posting Ra'diation Areas Termination Reports The above items are closed.
No violations or 'deviations were identified.
The inspector examined "Corporate Licensing,and Assurance Audit No.85-327.
This audit covered activities required to be, audited pursuant to TS 6.5.2.8.J,K)L 6 M.
t No violations or deviations were identified.
ualit Assurance - Effluent and Environmental Monitorin Activities (80721)
Inspection Report 85-11 identified deficiencies in the area of quality assurance for effluent calculations when computer codes are utilized.
Specifically, regulatory guide 4.15 addresses this matter.
In response to those inspection findings, the licensee committed to examine this area and has implemented PPM 12.11.2,
"Chemistry Verification of Calculation Routines".
The inspector noted in review that this procedure calls for a comparison of computer to hand calculation and a review by a second knowledgeable person.
The procedure also defines documentation requirements and establishes a code reverification frequency based on estimated usag II I
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The inspector discussed with the Health Physics/Chemistry Support Supervisor and the Plant Radiochemist, status of verification of codes used to compute TS required offsite dose projections.
The licensee is making satisfactory progress in completing code verification.
No violations or deviations were identified.
ualit Assurance Schedule and Surveillance Review The inspector examined the annual QA surveillance plan for the period July 1985 to June 1986.
Eighteen surveillances are scheduled in the, area of radiological controls and five surveillances in the area of radwaste and environmental control,.
The inspector discussed with cognizant licensee representatives the need to expand audits in the area of radioactive waste solidification and classification in order to meet the regulatory requirement of 10 CFR 20.311(d)(3).
The following surveillance reports performed by the plant QA staff during the preceding 12 months were examined by the inspector.
SR-2-84-078 SR"2-84-107 SR-2-84-140 SR-2-84-141 SR-2-84-142 SR-2-84-197 SR-2-84"198 SR-2-84"230 SR-2-85-021 SR-2-85"036 SR-2-85-070 SR-2-85-071 SR-2-85-073 SR-2-84-253 SR-2"84-199 Radiological Surveys Radiation Exposure Records Personnel Exposure Protective Clothing Control Contamination Control ALARA Program Control Radiation Work Permit Control Respiratory Protection Device Control Personnel Exposure Monitoring Radiation Exposure Records and Reports Respiratory Protective Device Control Protective Clothing Control and Usage Contamination Control Receipt, Storage and Transfer of Radioactive Material Radwaste Control and Management
,le QASR 2-84-199, Radwaste Control and Management identified several deficiencies in radwaste processing activities.
The QASR set forth examples of failure to implement four procedures consistent with their stated requirements.
The procedures are as follows:
Radioactive Waste Management Program, Rev.
Radioactive Waste"Process Control Program, Rev.
Chem-Nuclear Mobile Solidification Interface, Rev.
Solid Waste Processing System, Rev.
I These deficiencies are further discussed in paragraph 8, of this, report.
No violations or deviations were j.denti<ied.-
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Trans ortation Activities
CFR 71.3 states that a licensee subject to the regulations in this part may not deliver any'icensed material for transport except as authorized or as exempted.
CFR 71.10 provides on exemption for Type A quantities of radioactive material.
A review of the licensee's solid waste shipment activities to date indicates the licensee has reached the threshold where Type B quantities will be necessary in order to transport low 1evel radioactive waste for land burial economically.
The licensee can still produce Type A quantity shipments by blending low activity resin from the condensate system with high activity resin from the RWCU system.
The licensee currently ships resins in dewatered form in non-HIC liners and in USA/A NRC certified containers.
Shipments are typically classified as low specific activity (ISA) waste.
In consideration of the potential for multiple shipments requiring the use of NRC certified packagings, the inspector examined the licensee's program for meeting the requirements of 10 CFR 71.
A review of several shipment records indicated that the determinations of 71.87 are made and that the records of 71.91 are maintained.
The licensee is dependent in large part on the documentary materials and certifications provided by the vendor who maintains an NRC approved QA program.
The inspector noted that the licensee's program as described in PPM 1.12.1 and 1.12.2 lacks the details and formality to ensure that the specific requirements of 10 CFR 71 will be met for all shipments.
The inspector also examined the licensee's QA program authorized pursuant to
CFR 71 '01(f) as it applied to subpart H of 10 CFR 71.
Section 10 of the licensee's Operational Quality Assurance Program Description (OQAPD)
sets forth requirements for inspection of activities that, affect safety-related functions of plant items, Section 10.2.2 states,
"Inspection Procedures, instructions or checklists will, as appropr'iate, provide for:...d.
Acceptance or rejection criteria...f. specifying necessary measuring and test equipment including accuracy requirements.
The inspector examined Inspection Planning Report (IPR) Nos.85-472 and 85-475 for shipments 85-29-02 and 85-30-02 respectively.
The inspector noted that these IPRs did not contain the specific acceptance criteria or MME accuracy requirements.
The inspector also noted the IPR referenced the wrong (vendor) procedure for the shipping container.
These shipments were not made under
CFR 71 as they contained Type A quantities of RAM.
The licensee's functional manual for nuclear operation(corporate level),
Nuclear Operation Standard NOS-41, "Quality Assurance Program for Radioactive Materials Shipping Packages,"
states in part that procedures for preparation of packages, inspection for damage and deterioration shall be reviewed and approved by the Plant QA Manager and Plant Manager.
The normal vehicle for this approval is the'~Plant Operation Committee (POC).
The vendor procedures provided detai3ed instructions not incorporated in the PPM, these procedures
.referenced by. the IPRwere not POC approved at the time of inspection; When presented with the findings regardihg lack of formality in',the
CFR 71 area and weakness in the QA pr'ogram'.(or certified package's that
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would be considered violations when Type B quantity shipments were made, the Plant Manager agreed to provide a letter commitment to Region V that no Type B quantity shipments would be made until the licensee conducted a
thorough examination of their program, including the QA/QC aspects and corrected all deficiencies.
A written commitment was received by letter dated September 18, 1985.
This matter was discussed at the exit interview.
This matter will be reexamined after the licensee performs Type B
shipments (Open, 85-29-01).
The inspector also examined records associated with the following Type A shipments of Class A, I,SA material made in 1985:
85-39-02 85-30-02 85-33-02 85-36-02 85-10-02 85-38-02 85-31-02 85-34-02 85-37-02 85-29"02 85-32-02 85-35-02 85-01-02 No violations or deviations were identified.
Radioactive Waste Processin (RWP) (84722)
j The licensee operates the RWP facilities under cognizance of the operations department.
The licensee,has
.recognized the need to provide a
distinct organizational status to the GAWP programs'and,has initiated this by selecting an individual for the position oj opera'tions radioactive waste supervisor.
It is expected that.,transfer of r'esponsibility from several operations Shift Supervisors,"to one individual'devoted to RWP will improve continuity of operations and provide other benefits.,'
Plant Procedure Manual (PPM) Section l.'12.1, Ra'dioactive Waste Management Program (RWMP), Revision 0 dated August"31, 1983, defines the scop'e and major objectives of the RWMP.
This pxogram, assigns
a program management role to the plant technical manager 'through the radwast'e
.pr'ogra'm leader.
Responsibilities are assigned to other indivi'duals within the licensee organization.
I'uality Assurance Surveillance Report (QASR) No. 2-84-199 of Radwaste Control and Management dated May 22, 1985, identified four deficiencies in the area of radioactive waste management and process control.
A general statement based on inspector review of the'rea, review of the QASR and discussion with several individuals is that the RWMP as described in PPM 1.12.1 was not being effectively implemented.
The inspector examined the potential enforcement aspects of the QASR and other findings and concluded that the potential violations were licensee identified and were not severity level 1, 2, or 3, therefore, a Notice of Violation need not be issued pursuant to 10 CFR Appendix C
provided the violations were or will be corrected within a reasonable time.
One of the deficiencys identified by the QASR was promptly corrected.
The remaining three were deferred pending a management decision on reorganization 'of the chemistry and radwaste programs.
Decisions on both
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of these reorganizations were made by licensee management shortly prior to or during the inspection period.
The reorganization of radwaste programs and rewrite of PPM 1.12.1 will likely place management of the solid radioactive waste processing directly under the radiation protection and chemistry manager.
Xn view of the need for a comprehensive review of the program and the major organizational changes, the inspector accepted a commitment from the licensee"to have the revised program fully implemented prior to November 1, 1985.
This matter will be reinspected at that time (Open, 85-29-02).
I'acilit Tour The inspector toured the reactor building, turbine generator building and radioactive waste processing building several times during %he inspection period.
Housekeeping was noted to be-generall'y acceptable, posting and labeling were acceptable with, one exception.
The inspector observed a
radioactive materials storage area posted as a high radiation're'a.
The area in question is used to store large (100 cf) liners for'hipping dewatered or solidified resin.
At the time of inspection, several liners were in the process of being filled.
The radwaste health physicist stated that typical resin being processed contained about 400 millicuries of cobalt-60 per liner or ll microcuries per gram.
CFR 20.203,
"Caution Signs...(e)(1)"
states that each area containing more than 10 times the
CFR 20 Appendix C quantity of RAM'shall 'be
'onspicuously posted,
"Caution Radioactive Material(s)".
At the time of inspection and for an undetermined period of time prior to the inspection this area was not posted as required.
The Appendix C
quantity for Cobalt-60 is 1 microcurie.
The exceptions of 10 CFR 20.204 did not apply.
The individual containers were not labeled, however, the provision of 20.203(f)(3)(vi) was met for these items.
Failure to post an area represents an apparent violation of 10 CFR 20.203(e)(1).
The licensee promptly corrected the posting violation, therfore, a
written response is not required.
Trainin (83723)
The following aspects of training were examined:
Organization of training as specified in TS 6.2.1.
Completion of replacement and retraining program for health physics personnel.
The inspector identified an inconsistency between the training organization or shown in TS Figure 6.6.2-1a.
The licensee was aware of this and has committed to submit a TS change to reflect the current organization.
The licensee has initiated appropriate steps to include all HP staff in the replacement and retraining program of TS 6.4.1.
The licensee letter of September 18, 1985, Sorensen (SS) to Martin (NRC) set forth an acceptable plan for completing this progra ftt ll f, It)
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No violations or deviations were identified.
11.
Semi-annual Effluent Re ort The inspector examined the report required by 50.36a(a)(2)
and TS 6.9.1.11.
Examination of the semi-annual effluent report showed that some of the information designated as supplemental by regulatory guide (RG) 1.21 was not included in the report.
Examples of desirable information recommended in RG 1.21 but not adequately addressed in the report covering the period January to June 1985 are described below:
RG 1.21 Appendix B, A.2 - The MPC calculated from TS or derived from Appendix B of 10 CFR 20 and brief description of methodology.
RG 1.21 Appendix B, A.4 - Summary description of methods used to determine activity.
RG 1.21 page 13 item 4.
RG 1.21 Appendix B, page 13 item 5, number, of batch liquid releases, time period...,
average stream flow.
The following items extracted
.from the report are provided for the six month report period.
II 1'iquid effluent - fission and activation product 3.8 millicuries + 22%
- tritium
. 1070 millicuries + 22/
Gaseous Effluent fission and activation gases'74000 millicuries + 36/
- tritium 930 millicuries +'6%
- iodines 19 'millicuries + 36/
- particulate
, '2 'tnillicuries + 36%
- alpha
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Solid Waste for burial 195 curies
+ 20%
Solid Waste Shipments to U.S. Ecology,,Richland
Maximum Dose Xiquid Effluent (Annualized)
(whole body)
7 micr'orem/year Maximum Dose Gaseous Effluent (annualized)
(whole body)
.15 millirem/year These rates are extremely low and well within all regulatory limits and ALARA guidance (Appendix X to 10 CFR Part 50).
No violations or deviations were identified.
The inspector reviewed the final startup report test Nos.
1 and 2, Chemical and Radiochemical Test. and Radiation Measurements.
Test results were satisfactory.
The inspector also reviewed a memo dated June 6, 1985, M. Wuestefeld to R. Graybeal, Chemical and Radiochemical Testing conducted during PATP.
Review of this memo and discussion with cognizant licensee representatives provides adequate assurance that the gaseous radiation monitors are adequately calibrated.
This closes open items (50-397/85-03-02, 84-20-07, 84-20-08 and 84-CS-07).
No violations or deviations were identifie b P
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13.
Exit Interview Failure to complete corrective actions in response to a Notice of Violation was identified.
The licensee indicated that the matter would be promptly corrected.
An apparent violation involving posting of a radioactive material storage area was discussed.
The licensee stated that shipments of Type 3 quantities of RAM would not be made until their program was modified as necessary and approved internally.
The licensee also "'stated that their radioactive waste programs would be reorganized and procedures and program description rewritten and reapproved by November 1,
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