IR 05000397/1989012
| ML17285A510 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 05/18/1989 |
| From: | Cicotte G, Garcia E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A509 | List: |
| References | |
| 50-397-89-12, NUDOCS 8906070175 | |
| Download: ML17285A510 (16) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
'eport No.
Docket No.
License No.
Licensee:
50-397/89-12 50-397 NPF-21 Washington Public Power Supply System P.
0.
Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No.
Inspection at:
WNP-2 Site, Benton County, Washington Inspection Conducted:
April 17-21, 1989 Inspected by Approved by:
~Sam ar:
Q G.
R. Cicotte, Radiati on Specialist j~eu Cri -~r/ ~Pe~
M. Garcia, Acting Chief Facilities Radiological Protection Section Date Signed r8; rNP Date Signed Ins ection durin eriod A ril 17-21 1989 Re ort No. 50-397/89-12 Areas Ins ected:
Routine, unannounced inspection by a regionally based inspector of liquid and gaseous waste systems, follow"up, occupational exposure, and tours of the facility.
Inspection procedures 30703, 84723, 84724, 92702, and 83750 were addressed.
Results:
Of the four areas addressed, no violations were identified.
Some concerns regarding whole body counting (paragraph 5.F) and radiological work practices (paragraph 6), weve identified.
8906070175 8905i8 PDR ADOCK 05000397 Q
pNU
DETAILS 1.
Persons Contacted
~C.
M. Powers, Plant Manager J.
W. Baker, Assistant Plant Manager J.
D. Arbuckle, Compliance Engineer
"L. L. Bradford, Health Physics Supervisor T.
M. Brun, Plant guality Assurance (gA) Engineer A. I. Davis, Senior Radiochemist
"R.
G. Graybeal, Health Physics/Chemistry (HP/C) Manager
"J.
T. Irish, Program Analyst (Bonneville Power Authority)
D.
A. Kerlee, Principal gA Engineer D.
E.
Larson, Radiological Programs and Instrument Calibrations (RP8 IC)
Manager L.
L. Mayne, Chemistry Craft Supervisor
"D.
B. Ottley, Acting Manager, RP8IC Manager
"D. J. Pisarci k, Health Physics Support Supervisor E.
R.
Ray, Instrumentation and Controls (I8C) Supervisor R.
L. Wardlow, Radiological Services Supervisor
"Denotes those present at the exit interview held on April 21, 1989.
In addition to the individuals identified above, the inspector met and held discussions with other members of the licensee's and contractors'taff and personnel.
2.'i uids and Li uid Wastes 84723 A.
Audits Licensee gA audit ¹87-420-A, conducted by the licensee on December 2, 1988, was reviewed for completion of corrective actions.
The audit had identified one significant finding, and three concerns.
The findings appeared to have been addressed in a timely manner.
The findings did not directly relate to liquid wastes.
B.
Chanches No major changes to the licensee's program had occurred.
Changes to the Offsite Dose Calculation Manual (ODCM) were made in response to NRC recommendations and licensee identified omissions and minor errors which did not significantly affect calculated results.'.
Effluents According to licensee records, no releases of.radioactive..liquids to the environment had occurred since the last inspection of this program area.
Typically, the licensee releases large volumes of liquid in support of fuel handling activities (e. g., draining the reactor cavity).
This area will be examined in a subsequent inspectio Instrumentation Surveillance tests, procedures, and tracking systems were examined.
No concerns were identified.
This area will be further examined in a subsequent inspection.
Although no examination of recent release records was possible, the licensee's program appeared fully capable of meeting its safety objectives.
No violations or deviations were identified.
3.
Gaseous Waste S stem 84724 A.
Audits and A
raisals Licensee gA audit ¹87-420-A, as noted in paragraph 2A, above, was reviewed.
No major findings had been made in the area of gaseous effluents.
The audit did not appear to involve an in-depth assessment of impaired gaseous waste systems, as had been previously observed by the inspector (see Inspection Report No. 50-397/89-02).
~Chan ea The licensee had made no significant changes to their overall program or procedures.
Those procedural changes which were reviewed were administrative in nature, except as discussed in paragraph 3.D, below.
Amendment 6 to the ODCM was submitted with the June-December 1988 Semiannual Effluent Release Report (SAERR).
The changes consisted primarily of 1) additions recommended by an NRC review of amendment 4 to the ODCM (see Inspection Report No. 50-397/88-26),
and 2) correction of tables to bring them into agreement with NUREG/CR-4013, LADTAP-II Technical Reference and User Guide.
The changes resulted in significant clarification of calculations and equation definitions.
Effluents The SAERR for July-December 1988 was reviewed.
'No obvious errors, omissions, anomalies, or trends upward in readings were observed.
Dose calculations for 1) direct radiation from recreational river use by an adult, and 2) thyroid dose from milk ingestion by a teenager, were verified as correct.
The magnitude of recorded effluent releases were observed to be a small fraction of 10 CFR 50 Appendix I and
CFR 20 Appendix B release and release rate:l-imits.
Numerous material deficiencies, as recorded on equipment deficiency tags, remain on various portions of the gaseous radioactive waste system (see Inspection Report No. 50-397/89-02).
The licensee had experienced elevated levels of radioactivity in the off"gas system, due primarily to one or more small fuel leaks into the reactor
coolant.
No examples of unmonitored release paths or bypassing of processing systems were observed.
The off-gas pre-treatment monitors were examined.
A deficiency tag attached to the sample rack stated that the sample pump trips after several seconds of operation.
Some control lights were not on, even though the monitor was operational.
Of the three off-gas refrigerant pumps, OG-20B was running, OG-20A was tagged,
"Leaks When Running,"
and OG-2C was tagged "Will Not Run."
When the matter was discussed with the licensee, the inspector's observations were acknowledged.
A licensee evaluation had concluded that even without any refrigerant pumps the plant could continue to operate for some time under current conditions without exceeding Technical Specification limits.
D.
Instrumentation The following surveillance tests (ST) were reviewed to assure the licensee maintains radioactive effluent monitoring equipment in accordance with Technical Specifications (TS) 3/4. 3. 1. 1, 3/4. 3. 2. 1, 3/4.3.7.5, and 3/4.3.7.12:,
(MSL = Main Steam Line, CFT = Channel Functional Test, CC = Channel Calibration)
Procedure PPM Title 7. 4. 3. l. 1. 11 7. 4. 3. l. 1. 5G 7. 4. 3. 1. 1. 12A 7. 4. 3. 1. 1. 12B 7. 4. 3. 1. 1. 12C 7. 4. 3. 1. 1. 12D 7. 4. 3. 7. 12. 1 7. 4. 3. 7. 12. 2A 7. 4. 3. 7. 12. 2B 7. 4. 3. 7. 12. 5 7. 4. 3. 7. 12. 6 MSL Hi h Radiation Channels A and C - CFT Revision G, dated 5-18-87 MSL Hi h Radiation Channels B and D - CFT Revision 6, dated 1-26-89 MSL Hi h Radiation Channel A-CC Revision 4, dated 3-2-88, deviated 5-13-88 MSL Hi h Radiation Channel B-CC Revision 4, dated 3-2-88, deviated 5-14-88 MSL Hi h Radiation Channel C-CC Revision 4, dated 3-2-88, deviated 5-13-88 MSL Hi h Radiation Channel D-CC Revision 4, dated 3"2"88, deviated 5-13-88 Main Condenser Off-Gas Post Treatment Gross Gamma Monitor-CFT Revision 3, dated 2-2-87 Main Condenser Off-Gas Post. Treatment Gross Gamma Monitor-Channel A-CC Revision 1, dated 3-6-87 (The procedure was last performed prior to the most recent revision)
Main Condenser Off-Gas Post Treatment Gross Gamma Monitor-Channel A-CC Revision 1, dated 3-6-87
~ Reactor Bui 1 din Elevated Release Noble Gas Monitor-CFT Revision 5, dated 5-19-88, deviated 8-25-88 Reactor Buildin Elevated Release Noble Gas Monitor-CC Revision 2, dated 11-4-87
7. 4. 3. 7. 12. 11 7. 4. 3. 7. 12. 12 7.4.3.7.12.7 7. 4. 3. 7. 12. 18 Turbine Bui ldin Ventilation Exhaust-Noble Gas Activit Monitor-CFT Revision 4, dated 5-16-88, deviated 8-25-88 Turbine Buildin Exhaust Noble Gas Monitor-CC Revision;3, dated 5-16-88 Radwaste Buildin Elevated Release-Noble Gas Monitor-CFT Revision 4, dated 5-16-88, deviated 8-25-88 Radwaste Buildin Elevated Release"Noble Gas Monitor-CC Revision 2, dated 11-4-87
'A prodecure deviation is defined in Administrative Procedure 1.2.3 as
"A short on the spot non complex change to a procedure which does not alter the intent and for which the normal revision process is not applicable.
Deviations receive a post implementation review."
Additionally, daily and shift source checks and channel checks, in conjunction with representative sampling and analysis results, were reviewed.
Some procedural inconsistencies between I&C STs on the various channels were observed.
The licensee initiated the appropriate procedure changes upon being informed.
The 7.4.3. l. 1. 12A/B/C/D series of surveillances were found to have had a deviation initiated on May 13, 1988.
Two of the STs were verified several days later, without having the proper approvals from the Plant Operations Committee (POC)
on the deviation form, although the POC had approved the deviation as-is on May 14, 1988.
This appeared to be an isolated example.
The deviation was otherwise in accordance with PPM 1.2.3, Use of Plant Procedures.
On the reactor building effluent monitor CFT, PPM 7.4.3.7.12.5, an annotation had been deleted by deviation No.88-792, dated August 25, 1988.
The annotation referred to a TS requirement to check the annunciation capability for a downscale meter failure.
Discussion with the I&C Supervisor, and review of setpoint change requests and rationale, revealed that the downscale meter annunciation was removed to prevent annunciation due to low background count rates.
The function of the affected relay is checked manually for annunciation, and the inputs of high voltage and power are checked to assure application of a control signal to the relay.
The inspector concluded that for low radiation. rate conditions, these signals would be more representative of circuit "
conditions than the physical position of the meter.
The ability"of"the ST to perform a check of instrument failure was determined to.have been retained.
pc Overall, despite some material deficiency problems as described above, the licensee's program appeared capable of meeting its safety objectives.
No violations or deviations were identified.
Followu on Corrective Actions for Violations 92702 50-397/89-09-01 o en This item refers to a failure to maintain a
caution - radiation area sign at the entrance to a radiation area (see
Inspection Report No. 50-397/89-09).
The licensee's timely response
'dated April 14, 1989, to the Notice of Violation (NOV), contained the information required by the NOV.
The licensee, in their response, had
,committed to reconfigure certain radiological postings by April 30, 1989.
This was observed to have been initiated but not completed at the time of this inspection.'he licensee had also committed to frequent tours of the plant by Health Physics (HP) supervision, and this was verified to have been occurring.
Other commitments, to redefine supervisory responsibilities and to revise procedures as administrative procedures, had commitment dates in May and July 1989.
The licensee stated that procedure PPM 11. 2.7. 2, Entr Into Conduct In and Exit from Radiolo ical Controlled Areas, will be redesignated PPM 1.11.11, by May 31, 1989.
This matter will be examined in a subsequent inspection.
5.
Occu ational Ex osure Control Shi in and Trans ortation 83750 A.
Audits and A
raisals No audits in this program area had been conducted since the last inspection.
Two plant gA surveillances had been conducted, one of air sampling and analysis in March 1989, and the other of source checks in February 1989.
No new concerns were identified as a
result of those survei llances.
B.
~Chan ea II No major changes in the licensee's program had been made since the last inspection of this program area.
C.
Plannin and Pre aration Licensee preparations for the outage, including scheduling, HP staffing, acquisition of materials, and work package review, were examined.
The licensee had hired what appeared to be an adequate number of HP technicians (HPTs) for coverage of scheduled work.
No concerns were identified in HP supplies.
Work package review changes, as described in Inspection Report No. 50-397/89-09, appeared to have been effective in ensuring early review and input from the HP staff.
Records of outage planning meeting attendance revealed that HP staff regularly participated in those meetings.
With respect to priot experience, many of the repetitive tasks had been planned based on data and exposures from the previous outage.
The licensee's methodology appeared to have improved regarding advance planning.
0.
Trainin and ualifications of New Personnel The contractor HPTs work experience, as stated in resumes, and their licensee provided HP training was reviewed.
Based on that review and discussion of relevant experience with both contractor and licensee HPTs, no concerns were identified.
Representative HP training records for non-HP outage contractor personnel were
examined.
The training addressed the applicable portions of 10 CFR 19. 12, Instruction to workers.
and licensee procedures.
External Ex osure Control The licensee processes dosimetry in accordance with certification by the National Voluntary Laboratory Accreditation Program (NVLAP).
Accreditation is for all categories except I, III, and VI (low energy photons).
The lower energies are not expected to contribute significantly to dose in comparison with those gamma radiations normally encountered at the facility.
No examples of improperly worn dosimetry were observed.
An examination of licensee stocks and procedures for special dosimetry applications revealed that the licensee's program is adequate for the outage.
A review of representative work packages and surveys revealed that the licensee used the most recent surveys for each work package when performing dose estimations.
The licensee was observed to be maintaining plant status boards and individual radiation work permit (RWP) packages with recent survey data.,
Contractor HPTs hired for the outage, if fully qualified, are permitted by the licensee to perform all of the duties of fully qualified licensee HPTs, except supervision and survey/work package reviews.
The licensee had modified their computer-based dose summary system, such that additional search functions were available.
At the time of the inspection, only one individual'as approaching 25K of the limits of 10 CFR 20.101(a).
All individual dose records which were reviewed had dose histories (NRC-4 forms) included in their records.
Representative licensee forms NRC-5 equivalent were reviewed.
No concerns were identified.
No overexposures had been recorded or reported by the licensee.
Internal Ex osure Conti pl Representative records of bioassay and whole-body counting (WBC)
equipment maintenance were reviewed.
The licensee stated that no individuals had been exposed to airborne activity greater than 40 MPC-hours.
Air sample data supported body burden calculations for those records which were reviewed.
Although the licensee, uses a
high threshold for facial contamination (10,000 or more disintegrations per minute, or dpm),
no examples of personnel with significant uptakes were found.
On July 18, 1988, the licensee had last performed the calibration portion of Radiological Programs Instruction (RPI) 5.3, ~Efficienc Calibration for Routine Whole Bod Count/Th roid Count, Revision 4, dated 11-25-86.
RPI 5s3 states that the calibration "should" be performed every six months or when equipment is changed.
The licensee had made some minor equipment configuration changes in March 1989.
When the matter of six month calibration frequency was
discussed, the licensee staff personnel stated that their policy is that the calibration is unnecessary if no anomalous measurements are observed in the daily source checks.
In accordance with TS 6.8, Procedures and Pro rams, the periodicity of programmatic review and revision for licensee plant procedures (PPMs) is every two years.
Environmental Programs Instructions (EPI) are reviewed/approved as described in Inspection Report No. 50-397/88-28 and TS 6.8.2.
The licensee stated that RPIs are handled similarly, in that procedures not needing revision at the time of periodic review would not be documented on the procedure itself as revised or reviewed.
The above two matter s will be examined in a subsequent inspection (Open Item 50-397/89-12-01).
A review of representative air sample data identified no concerns.
The licensee stated that their review of air sample data indicated that more representative sampling would be necessary.
More frequent breathing zone samples were being obtained at the time of the inspection.
Control of Radioactive Material and Contamination Surve s
and
~Monitori n No significant exposures to highly radioactive "Hot" particles were observed to have occurred since the last inspection of this program area.
Surveys of material being removed from the radiologically controlled area (RCA) were observed.
Waste minimization by sorting of waste materials in the plant appeared to be effective.
Other matters are discussed in paragraph 6.-, below.
Maintainin Occu ational Ex osures ALARA The licensee had divided ALARA review functions among several HP staff members.
Records of ALARA committee and other meetings revealed that the licensee was providing adequate time for major task preparation.
At the time of the inspection, all major tasks had been addressed.
The licensee planned to remove a highly radioactive crud trap consisting of an elbow in a reactor water cleanup (RWCU) line.
Significant engineering difficulties had been surmounted by the licensee (the removal of the line presents a potentially unisolable reactor pressure vessel leak).
However, the'actual shielding of the crud trap in preparation for removal presented a concern with respect to apparent confusion among licensee staff as to time sequence and duration.
Licensee calculations of shielding effectiveness were reviewed, with no concerns identified.
Mockup of the temporary shielding was observed to include the actual equipment to be used, but physical interferences were not mocked up.
The ALARA coordinator and the ALARA reviewer had not seen the mock-up at the time of the inspection.
This particular task, and control rod drive (CRD) removal/installation work, in which a concern regarding
communications during CRD removal was identified, were discussed with the licensee.
After discussion of the above concerns with the licensee, the inspector concluded that the licensee had sufficient time and was devoting adequate attention to those concerns.
ALARA program efforts appeared to have been effective in reducing collective dose by about 12K in 1988 from 1987.
The licensee's collective dose is about average for single unit boiling water reactor (BWR) stations.
The licensee stated that collective dose reduction effort were being focused on those tasks with the highest dose potential.
Shi in of Low-Level Wastes For Dis osal and Trans ortation No transportation incidents involving the licensee's'adioactive material shipments were observed to have occurred.
The licensee typically ships the material a short distance to the burial facility.
The licensee stated that no audit of this area.had been conducted in this program area since the last inspection.
The Process Control Program was last inspected in Audit 87-420, dated November 27, 1987.
The licensee uses a two year cycle in their guality Assurance Program, and the audit would thus be due in November, 1989.
Waste classification and packaging were previously inspected (See Inspection Report 50-397/88-41).
The licensee's program appeared fully capable of meeting its safety objectives.
No violations or deviations were identified.
Faci lit Tours Tours of.the Radwaste Building (RWB), Reactor Building (RB), and Turbine Building (TB) were conducted.
Independent radiation surveys were performed with an NRC ion chamber survey instrument, Model ¹R0-2A, Ser.ial
¹008962 due for calibration July 14, 1989.
Housekeeping in most areas was being maintained above average, with the exceptions of the 522'levation of the RB and the 452'ejevation of,the RWB, which were somewhat cluttered with tape,. gloves, protective clothing, and other similar materials.
On the 501'levation of the TB, continuous air m'onitor"~(CAM)'¹TB-3A :was found to have riot had its weekly source check done on April 17.,~:1989.,
The licensee, conducted a satisfactory source check when the matter.iwa's,',"-
brought to their attention.
Several friskers placed by"'the"'licensee throughout the plant for personnel contamination monitoring,,were, found
.
to have their alarms set to "off", while others were.set at differing*
values above their respective background count rates.~.L'icensee procedures governing frisker use state that the alarms will'be set at the
"desired" level above background.
The licensee stated that frisker alarm setpoints were being evaluated for greater procedure specificit Some personnel practices were observed:
Location Action 606'B Two individuals reached into an uncontaminated area without removing protective clothing (PCs) or being monitored.
606'B One individual reached into the contaminated area without PCs.
606'B One individual was dressed in PCs less conservatively than called for by the RWP (although adequate for the tasks/area).
437'WB Individual working on top of spent resin liner in contaminated area without head covering, eye protection, or tape op PCs, as called for by the RWP.
When brought to the attention of the licensee, the licensee acknowledged the observations and stated that these would be discussed with the appropriate licensee staff to determines the extent of the problem.
The inspector expressed concern regarding the depth of RWP review by those using the RWPs.
This matter will be examined in a subsequent inspection (Open Item ¹50-397/89-12-02).
I The licensee's program appeared capable of meeting its safety objectives.
No violations or deviations were identified.
7.
Exit Interview At the conclusion of the inspection on April 21, 1989 the inspector met with those individuals, denoted in paragraph 1.
The scope and findings of the inspection were summarize s(