IR 05000397/1991021
| ML17286A982 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/24/1991 |
| From: | Chaney H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286A981 | List: |
| References | |
| 50-397-91-21, NUDOCS 9108130258 | |
| Download: ML17286A982 (14) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-397/91-21 License No.
NPF-21 Licensee:
Mashington Public Power Supply System (Supply System)
P.
0.
Box 968 3000 George Washington Way Richland, WA 99352 Inspection Conducted:
June 24-2
, 1991 a ey, en> r a
1a ion p cia 1st u as,
>e Reactor Radiological Protection Branch Inspected by:
Approved by:
Summary:
Facility Name:
Mashington Nuclear Project No.
2 (WNP-2)
Inspection at:
MNP-2 site, Benton County, Washington e
1gne a
e lgne Areas Ins ected:
Routine, unannounced inspection of the licensee's radiation pro ec son program including:
occupational radiation protection; radiological environmental monitoring; transportation of radioactive materials; control of radioactive materials and contamination; post refueling outage R-6 radiation exposure expenditure (ALARA) performanc'e; and follow-up on previous inspection findings.
Inspection procedures 92701, 92702, 84750, 90713, 86750, 83729, and 83750 were used.
Results:
- The iicensee's implementation of their radiation protection program ss reproving due to filling of vacancies in the RP technician staff, the procedure improvement program, and realignments of supervisory resources at both onsite RP and offsite RP support organizations.
The licensee's effective use of technical consultants has improved the licensee's performance in the processing and transportation of radioactive waste (radwaste).
The environmental monitorinq programs (radiological and non-radiological)
are being effectively implemented, and they are being conducted with a high degree of professionalism.
The applied quality control and audit activities for the radiological and non-radiological environmental monitoring actives are being conducted with a high degree of sophistif>cation, using very technically competent personnel.
No violations or deviations were identified during the inspection of the areas noted above.
9108130258 9i0724 PDR ADQCH, 05000>+7
'
DETAILS 2.
Persons Contacted
. Licensee
- J. Baker, Plant Manager
"L. Harrold Assistant Plant Manager
"J., Allen, supervisor, Radwaste
"J. Arbuckle, Compliance Engineer
"J. Bell, Manager, Plant Services C. Card, Supervisor, Radiological Environmental Monitoring Program
- R. Graybeal, Manager, Health Physics/Chemistry (HP/Chem)
"D. Pisarcik, Assistant Manager, HP/Chem
- R. Webring, Man'ger, Plant Technical (") Denote personnel that were present at the exit meeting held on June 28, 1991.
Additional licensee personnel attended the exit meeting or were contacted during the inspection, who are not reflected in the above listing.
Follow-u on Previous Ins ection Findin s (92701 and 92702)
(Closed)
Ins ector Follow-u Item 397/91-07-01:
"Failure to Implement u
y nspec son an n orcemen u
e sn (IEB) 79-19" - This item was previously discussed in NRC Inspection Report 50-397/91-07, and involved the licensee's failure to implement initial and retraining of personnel performing activities associated with the processing and transportation of radioactiv'e waste.
This findinq was identified during an audit by a contracted technical expert performing an appraisal of the radwaste program at WNP-2.
The NRC inspector reviewed corrective actions made to training program instructions and lesson plans for radwaste personnel.
The-inspector also verified that all current radwaste workers had received the training as required by IEB 79-19.
With the licensee's annual requirement for retraining and management oversight of radwaste activities, future deviations from IEB 79-19 should be minimized.
The inspector had no further questions regarding this matter.
(Closed)
Ins ector Follow-u Item 397/91-07-03:
"Failure to Classify roper y a
a was e
topmen
,
-
-
-
is item was previously discussed in NRC Inspection Report No. 50-397/91-07, and involved the State of Washington suspendinq the licensee's authorization to use the commercial low-level radioact>ve waste disposal site.
The licensee had misclassified a radioactive waste shipment as "Class A" requiring no stabilization, when in actuality the shipment should have been classified as "Class B" requiring stabilization prior to disposal/burial per 10 CFR Part 61.
The inspector reviewed the licensee's corrective actions as described in detai 1 in Supply System Ltr. G002-91-0588, from G. Sorensen to G.
Robertson (WSDH), dated March 22, 1991.
The inspector examined a
total of 4-shipments (3 radwaste and 1 involving radioactive materials to another licensee).
See paragraph 4 of this report for details of the
inspection.
The licensee appears to have implemented adequate corrective actions to prevent a recurrence of the misclassification problem.
(Closed) Notice of Violation 397/91-07-04:
"Failure to Register as a
ser o
as
-
-
>s s
em was previously discussed in NRC Insqection Report No. 50-397/91-07, and involved the licensee's utilization of an NRC certified cask without informing the NRC prior to such use, The inspector reviewed the licensee's corrective actions contained in Supply System Ltr. G02-91-092, from G.
Bouchey to U.S.
NRC, dated Hay 9, 1991.
The inspector verified that the licensee had communicated to the NRC their intent to use NUPAC Cask 10-142, NRC Certificate of Certification No. USA/9208/B.
The NRC inspector examined several plant procedures that provided instructions for the use of NRC certified casks in the shipment of radioactive materials and verified the licensee had included a check-off to indicate that the licensee was a
registered user of the cask.
The licensee's actions appear to be-adequate to prevent a future recurrence of this problem.
(Closed)
Ins ector Follow-u Item 397/91-10-01:
"Review of Root-Cause-na ysss or e
a was e
us 1ng eva ion Radioactive Resin Spill"
- This item was previously discussed in NRC Inspection Report No.
50-397/91-10, and involved the NRC inspector's desire to review the Root-Cause-Analysis (R-C-A) on a radioactive resin spill that covered nearly the entire 437 foot elevation of the Radwaste Building on April 13, 1991.
The spill occurred during the backwashing of "C" Condensate Filter Demineralizers.
The inspector examined the licensee's R-C-A report, dated June 24, 1991, and initiated by NDR 291-0245.
The licensee attributed the spill to equipment failure, particularly the failure of level indication (stuck at 53K full indication) for tank CPR-TK-14 (Condensate Backwash Receiving Tank),
and the failure of a 12 inch butterfly type valve (COND-V-231C) that allowed uncontrolled leakage of condensate (via a deteriorated valve seat) into CPR-TK-14.
The inspector noted that the R-C-A additionally identified two other pieces of equipment which contributed to the magnitude of the event.
They were the high-high level alarms for two sumps servicing the 437 level of the Radwaste Building.
The level indicators for these sumps did not initiate sump pumpdown and allowed the resin to backup into the 437 level floor drains.
There were outstanding maintenance work requests on these two sumps.
The R-C-A found that operators performed their procedural tasks exactly as written and intended, and that their actions or inactions did not cause this event to occur.
The inspector found the R-C-A to be technical sound and of adequate scope.
The failure of the tank level indicator was unanticipated as was the fai lure of the valve seat.
The radiological significance of this spill was sufficient to require the licensee to spend approximate'ly 14 days decontaminating and repainting the area.
A large portion of some affected areas, such as the shield cubicles for spent resin tanks, were considered highly contaminated prior to the April= 13th spill and were included in the decontamination effort.
Approximately 6. 1 person-rem were expended in the decontamination and repainting of the area to retur n it to the radiological status existing prior to the spill.
The decontamination effort was completed with only one incident.
The incident, involvinq decontamination personnel exceeding their administrative dose i>mits, is discussed in the above
3.
noted NRC report and is considered an Inspector Follow-up Item (397/91-10-02).
At the time of this inspection, the licensee had initiated, but not completed, the R-C-A for this incident.
The licensee expected to complete the R-C-A for this incident by August 30, 1991.
The licensee s proposed corrective actions"(repair level-indicator for tank CPR-TK-14 and valve COND-V-231C, perform failure analysis on level indicator CPR-LIS-96 and evaluate replacement of valve(s)
COND-V-231(s),
complete repairs to W-2 and W-3 sumps'igh-high level instrumentation and alarm and institute a routine inspection of COND-V-231 valves)
appear sufficient.
The inspector had no further questions regarding this issue.
'Closed)
Notice of Violation 397/990-29-01:
"Failure to Maintain ocumen a ion o a ioac ive a eria
) Transport Package Design and Testing Results" - This violation was previously discussed in NRC Inspection Report No. 50-397/90-29, and involved the licensee's failure to maintain a copy of the design and testing results for a Department of Transportation (DOT) Specification 7A package that was used by the licensee to ship radioactive material to another authorized licensee.
The NRC inspector examined the licensee's corrective actions (revision of Plant Procedure 11.2.23.6,
"Shipping Other Than LSA Radioactive Materials," to include a signoff on the RAM shipping checklist that test and results are on file for the DOT specification package),
and verified that the corrective action had been implemented.
The inspector had not further concerns regarding this matter.
Radioactive Waste Treatment and Effluent and Environmental Monitorin The licensee's radiological and non-radiological environmental monitoring programs were examined to determine compliance with 10 CFR Part 20.106(g); Facility Operating Licensee Condition 2.C(29),
Appendix A; Technical Specifications (TSs) 3.12.1, 4.12.1, 3.12.2, 4.12.2, 6.3, 6.4, 6. 5. 1, 6. 5. 2. 1, 6. 5. 2.8. j, 6. 5. 2.8.m, 6. 5. 2. 9. c, 6. 8. 1. i-k, 6. 9.1. 10, and 6. 10.3.m, and Appendix B, "Environmental Protection Plan (EPP)";
and agreement with the guidance contained in NRC Regulatory Guides (RGs) 4. 1, 4.6, 4'3, and 4.15.
Currently the EPP does not require any ecological studies or samplinq to be performed, but does require annual reporting on the status of National Pollution Discharge Elimination System (NPDES) activities and any environmental impact evaluations performed.
WPPSS currently implements a
comprehensive ecological monitoring program (EMP) per the Washington State Energy Facility Siting Evaluation Council (EFSEC)
agreements/resolutions.-
J,
'I
Audits The licensee's audit and e'valuation of the Radiological Environmental Monitoring Program (REMP) and non-radiological Environmental Protection Plan (EPP) were examined.
The following audits were evaluated to determine compliance with the requirements of TSs 6.5.2.8.j and m, and Section 5. 1 of the EPP.
Audit 91-555
"Radiological (TLD)/Non-radiological Environmenta)
and Effluent Monitoring, June 10-14, 1991.
Audit 90-545, "Radiological Environmental and Effluent Monitoring, December 17-19, 1990.
Audit 90-506, "Radiological/Non-radiological Environmental and Effluent Monitoring, January 12-February 23, 1990.
Audit 89-490, "Radiological/Non-radiological Environmental and Effluent Mon)toring, April 24-May 3, 1989.
The inspector found the licensee's audits of the REMP and EPP to be of high quality and comprehensiveness.
The inspector attended a
post audit exit meeting, reviewed audit findings, and held discussions with lead auditors involved in most of the audits.
Audits routinely incorporate site gA personnel performance based surveillance findings where applicable to the audit subject.
Auditors and technical specialists used for the audits appear to be well qualified and are not functionally responsible for the areas being audited.
Audits routinely identified isolated as well as minor programmatic deficiencies in areas of both environmental monitoring programs.
The scope of the audits addressed industrial safety findings.
Findings appear to be corrected in a timely and adequate manner.
The licensee's future audit plans were also reviewed; The State of Washington periodically audits the licensee's implementation of the ecological monitoring program (discussed in paragraph 3.c(3) below).
This area was last audited in June 1991.
~Chan es No major changes to the Offsite Dose Calculation Manual (ODCM),
Process Control Program, or radwaste system design and operation have occurred since the last inspection of this area.
Changes to the management structure of the WPPSS Corporate group, assigned responsibility for REMP implementation, was previously discussed in detail in NRC Inspection Report No.
50-397/91-07.
The inspector visited two sampling stations:
one air (21) sampling station arid the circulating water discharge to river (27) sampling station.
The inspector determined that the licensee had placed into service a
new flow-proportional effluent sampler for the circulating water discharge system that was the subject of a noncited violation in NRC Inspect>on Report No. 50-397/90-01.
The gA Department's Audit N discussed, at length, WNP-2 plant management's failure to ensure that the inoperable sampler was replaced in a more timely manner.
Or anization and Im lementin Procedures Responsibilities and authorities for implementation and auditing of the REMP are established in WPPSS Functional Manual for Nuclear Operation, standards NOS-37, "Radiological Environmental Monitoring Program,"
and NOS-20, "Audits."
These standards were examined for purpose, content, and applicability.
These=- two standards are currently being revised to a'ddress new activities and organizational structures.
The REMP and EPP activities are implemented by WPPSS Support Services-General Service's departmental procedures.
General Services Environmental Program Instructions (EPI), Series 1 and 12, provided detailed administrative and functional activity performance instructions for the REMP and EPP.
These procedures were'developed and approved in accordance with the requirements of TS 6.8.2.
The inspector examined approximately 20 out of 32 REMP implementing procedures that were changed since the last inspection of this area.
gA Audit No.90-506 discussed a programmatic deficiency concerning the performance of 10 CFR'art 50.59 evaluations when changes to REMP procedures were made by the Plant Services group.
The licensee's ODCM was reviewed (through Amendment 8) by an NRC contractor (EG&G Idaho, Inc.).
EG8G's questions arising out of this review and licensee responses to those questions were forwarded to the Region V office; These findings concerning the ODCM will be discussed with the licensee during future inspections of this area.
This review will be considered an Inspector Follow-up Item (397/91-21-01).
Trainin and ualifications The inspector reviewed the qualifications of selected personnel implementing the radiological and non-radiological environmental monitoring programs to determine agreement with industry standard
, ANSI N18. 1-1979 guidance.
Licensee procedure EPI 12. 1. 1, "Personnel qualifications and Training," Revision 3, establishes interdepartmental qualification and training standards for REMP and
.. EMP personnel.
The inspector examined the resumes and functional assignment position descriptions for supervisors and technicians.
Interviews held with management, supervisory, and technician personnel showed that personnel implementing the REMP and EMP satisfied ANSI and interdepartmental standards for their functional assignment d.
Radiolo ical and Non-radiolo ical Environmental Monitorin Pro ram
~co@
s REMP The inspector examined the licensee's 1989 and 1990 REMP reports for'ompliance with TS 6.9. 1. 10 requirements and agreement with NRC Radiological Assessment Branch Technical Position, Revision 1, dated November 1979.
The licensee's 1989 and 1990 reports continued to find that the MNP-2 plant was not radiologically affecting the environs around MNP-2, and results of the reports were similar to those noted during preoperational studies.
The inspector noted that the licensee was continually refining individual monitoring programs, e'specially in the environmental dosimetry and food pathway sampling program areas.
The reports provide sufficient and technically adequate discussions on the resolution of anomalies identified during REMP sampling analysis evaluations.
REMP reports were submitted in a timely manner, and their contents met TS 6,9.1.10 requirements.
(2)
(3)
EPP The inspector examined the licensee's EPP reports for the years 1988, 1989, and 1990'he licensee's EPP reports adequately address the'eporting requirements specified in Section 5.4. 1 of the EPP.
Minor NPDES violations are adequately addressed in the reports.
The -inspector researched the licensee evaluations concerning the site clearing and construction of a large two-story-building on the west side of the plant just outside the protected area.
In accordance with the EPP and Mashington State Energy Facility Site Evaluation Council (EFSEC) Site Certification Agreements with MNP-2, an environmental evaluation of the proposed construction was performed.
The evaluation determined that such activities would not involve an unreviewed environmental question.
EFSEC 0 erational Ecolo ical Monitorin Pro ram (EPM) Annual e or A brief examination of the 1989 and 1990 reports disclosed that the licensee has continued to perform cooling tower plume drift studies, and aquatic and water quality studies previously required by the EPP.
The licensee also performs aerial photographic evaluations of the environment around MNP-2.
The inspector noted that 1990 terrestrial monitorinq results show a
38 percent decline in vegetation cover and density over that measured in 1989.
The 1989 results showed a 126 percent increase in vegetation cover and density over the 1988 results.
Both changes were attributed to climatological related
conditions.
None of the studies showed that WNP-2 was producing an adverse impact on the environment.
e.
Records The inspector determined that the licensee maintains REMP records in accordance with the requirements of TS 6. 10.3, in file cabinets appropriately rated for withstanding penetration by fire or radiological sabotage.
The licensee's performance in this area is considered fully adequate.
4.
Solid Radioactive Waste Mana ement and Trans ortation of Radioactive a er>a s
The licensee's solid radwaste management and radioactive material (RAM)
transportation programs were examined to determine compliance with the requirements of WNP-2 Technical Specifications (TS) 3. 11.3, 6.8. l.h, 6.9.1.11, and 6.13;
CFR Parts 20.311 30.41(c)-(d),
61.55, 61.56, and 71.5; Department of Transportation (DOT) regulations contained in 49 CFR Parts 170 through 189; agreement with the guidance provided in NRC Inspection and Enforcement Bulletin (IEB) No. 79-19,
"Packaging of Low-Level Radioactive Waste for Transport and Burial;" and various NRC Inspection and Enforcement Information Notices (IEIN) related to radwaste and RAM transportation activities.
The inspector examined the activities associated with the licensee's resumption of shipping radioactive wastes to the Washington State licensed low-level radioactive waste disposal facility.
The licensee's authority to use the disposal facility was suspended indefinitely when site inspectors determined that the licensee had misclassified a shipment of dewatered resins.
This incident was previously discussed in NRC Inspection Report No. 50-397/91-07, and paragraph 2 above.
a.
~Chan es The licensee purchased a replacement radwaste management and shipping computerized program for the classification and shipping of RAM/waste.
The licensee had the replacement computer program validated by an independent consultant usinq two other independently developed computer programs for the classif)cation and shipping of radwaste per the requirements of 10 CFR Part 61 and 71.
Selected WNP-2 procedures that were revised/upgraded to implement the licensee's corrective action commitments to deficiencies, weaknesses, deviations, or violations resulting from State (Washington) inspections, independent consultant appraisals, gA audits, or NRC inspections were examined.
11.2.23.2,
"Radioactive Waste Classification,"
R-8, Deviation 91-439, May 22, 1991 11.2.23.3,
"Radioactive Material Shipping Names,"
R-5, Deviation 91-440, May 22, 1991 11.2.23.4,
"LSA Radioactive Material Shipments,"
R-5,
March 26, 1991 11.2.23.5,
"Testing & Adsorption/Solidification of Radioactive Waste Liquids & Sludges, R-4, June 6, 1991 11.2.23.6,
"Shipping Other Than LSA Radioactive Materials, R-9, January 21, 1991 11.2.23.21,
"Use of NUPAC Services Transportation Cask Model 10/142 R-2 March 26, 1991 11.2.23.24,
"Use of UE Ecology Transport Cask Model 14D/210, R-2, March 26, 1991 11.2.23.28,
"Transferring Possession of Radioactive Material to Another Licensee, R-O, May 20, 1991 Trainin and uglification of Personnel The inspector examined the corrective actions committed to by. the licensee in their May 9, 1991, letter to the NRC in response to the Notice of Yiolation issued in NRC Inspection Report No. 50-397/91-07.
In this letter, the. licensee committed to improving their erformance with regulatory requirements involving the shipping of AM/LLRW (radioactive material/low-level radioactive waste)
through the annual retraining of appropriate staff members on radwaste shipping and disposal regulations.
The inspector reviewed and discussed with training department representatives the remedial traininq conducted with radwaste personnel and future plans for specialized radwaste and RAH shipping training of plant staff personnel.
The inspector verified that all'personnel associated with shippinq activities since the issuance of the.letter had received training on shipping and disposal regulations, plant procedures, and radwaste processes.
The RP Radwaste Supervisor was noted to be using an employee training matrix for determining work assignments.
Shi in of Low-Level Waste for Ois osal and Trans ortation of RAN Selected RAM/waste shipments occurring during the period May 24-June 27, 1991 were examined, in detail, during this inspection.
Shi ment No.
~Te
~Packa e
91-08-02 LLRW, LSA, >Type A2 USA/9079/A, No.
001 91-19-02 LLRW, LSA, Type A2 USA/9079/A, No.
001 91-20-02 LLRW, >Type A
USA/9208/B, No.
004 91-25-02 RAM, LSA, Typl A2 NA The above examined shipments involved spent reactor plant-resins, noncompactible dry active wastes, and a tank/vessel contaminated internally with radioactivity be)ng returned to a vendor.
The inspector noted that the licensee verified that the vendor receiving the tank was properly licensed for such RAN and maintained a copy of the vendor's license on file.
The quality control, procedure compliance, documentation of activities, and RP controls associated with these shipments were
4'i
examined in detail.
RP supervisory and plant quality control personnel, as well as RP protection personnel and a radwaste technical consultant, were involved with all aspects of each shipment.
The licensee appears to have adequately resolved all the NRC's and State of Washington's concerns regarding their radwaste classification and shipping programs.
No violations of deviations were identified in this area.
5.
Occu ational Radiation Ex osure and Occu ational Ex osure Durin x en a.
Plannin and Pre aration The licensee's radiological control planning and preparations for the upcoming (late March 1992) refueling outage (R-7) were examined for agreement with prevailing industry practices.
This outage will entail a significant amount of radiological work, including:
in service inspections (ISIs) of reactor vessel circumferential welds; ISI of reactor vessel penetrations (inconel safe end welds);
low pressure turbine blade replacement; overhaul of reactor coolant recirculatinq flow control valves; plus other person-rem intensive work.
The l)censee's ALARA planning group has estimated the approximately 71 day outage will requ>re an 800 person-rem expenditure.
The inspector determined that the licensee was making continuous refinements to this projection based on considerations of additional exposure reduction techniques.
The licensee is evaluating the viability and cost benefits (exposure versus cost) of full or partial reactor coolant system chemical cleaning.
b.
ALARA Resul ts C.
The licensee's final exposure expenditure results for the R-6 outage (April-June 1991) were reviewed with licensee ALARA planning representatives.
The licensee completed the R-6 outage on June 11, 1991.
Additional discussions concerning the licensee s performance during the R-6 outage are included in NRC Inspection Reports Nos.
50-397/91-10 and 91-15.
The licensee expended 230 person-rem during the 56 day R-6 outage.
The licensee's goal for the outage was to be under 270 person-rem.
The increased ALARA awareness at WNP-2 and by WPPSS management has shown demonstratable improvements in outage performance.
External Ex osure Control The inspector examined the licensee's investigation into two radiological occurrences involving personal dosimeters
'(thermoluminescent dosimeters-TLOs):
Two employees (workers "A" and '-'8") inadvertently used each others personal TLO during a processing period.
This mixup was
discovered during the routine monthly exchange on or about May 31, 1991.
Worker "A" was found to have worker "B's" TLD.
Worker "A'" dosimetry was on a monthly processing frequency and worker "B's" was on a quarterly processing frequency due to worker "B's" less frequent work in radiological areas.
The TLD processor noted that the TLDs had been mixed-up.
A review of pocket ion chamber (self indicating dosimeter-SID)
readings for worker "A" substantiated the appropriate dose to be attributed to worker ",A" was approximately 920 millirem for the period April 1, 1991 through May 31, 1991.
Worker "B's" dose was essentially zero for the period in question.
The mixup was attribute to two areas:
(1) security force personnel mixing security badges and TLDs during exit processing of personnel when both items are separated and reconnected, and (2) workers not verifying that the TLD they are issued at the primary access point (PAP) is their issued TLD.
A Problem Evaluation Report (291-502)
was generated to deal with this problem.
Final resolution to this PER was not completed at the time of this inspection.
Two employees (workers "C" and "D") inadvertently used each others monthly processed personal TLD.
This was discovered by security personnel during the termination of worker "C" at the PAP.
By using SID values for the period April 10, 1991, through May 31, 1991, for "C" and April 17, 1991, through June 6, 1991, for worker "D", the appropriate dose for each worker was estimated and assign to their official dosimetry records.
The licensee feels that these are isolated incidents and has briefed security personnel on the need to ensure that TLDs and security badges are maintained in order.
Further corrective actions will be, accomplished per management discretion.
The inspector agreed with the licensee's findings, and the assigned doses appeared to be accurate.
No violations.or deviations were identified in this area.
S.
~Eit II ti The inspector met with the licensee representatives identified in Section 1 of this report on June 28, 1991.
The scope and findings of the inspection were discussed.
The licensee was congratulated on their R-6 outage radiation exposure expenditure performance and on the fact that they were actively evaluating the possibility of chemically cleaning the primary system to reduce dose rates for the upcoming R-7 outage.