IR 05000397/1991045
| ML17289A283 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/16/1992 |
| From: | Louis Carson, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289A282 | List: |
| References | |
| 50-397-91-45, NUDOCS 9202040161 | |
| Download: ML17289A283 (16) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Repor t No.
50-397/91-45 License No.
NPF-21 Licensee:
Mashington Public Power Supply System P.O.
Box 968 3000 George Washington Way Richland, MA 99352 Facility name:
Mashington Nuclear Project No.
2 (WNP-2)
Inspection at:
MNP-2 Site and Corporate Office, Benton County, Washington Approved by:
~Summar:
~AI AA:
Inspection conducted:
December 10 through 13, 1991 Inspected by:
arson
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s, le, eac or a lo og>ca Protect>on Branch a
igne I tbq~
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igne Routine unannounced inspection of the licensee's radiation protection activities that included occupational exposure control, training and retraining of health physics staff, general employee training (GET), chemistry oversight, radwaste management, and follow-up on previous inspection findings.
Inspection procedures 83723, 83725, 83726, 83728, 83729, 86750, and 92701 were used.
Results:
The licensee's quality assurance programs with regard to plant chemistry had improved since June 1989; however, the Corporate Chemistry Committee has not been fully utilized.
The licensee has enhanced its efforts towards training personnel in good radiological practices.
No violations or deviation were identified.
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Persons Contacted Licensee DETAILS
- J. Baker, Plant Manager
"G. Sorensen, Regulatory Programs Manager
"R. Graybeal, Health Physics (HP)/Chemistry Manager
- D. Pisarci k, Assistant HP/Chemistry Manager
"M. Monopoli, Support Services Manager
- R. Haight, Corporate Radiological Health Officer
- J. Harmon, Maintenance Manager
"R. Webring, Plant Technical Manager
"D.
Wer lau, HP, Chemistry and General Employee Training Manager
- L. Grumm, Nuclear Safety Assurance Manager
- S. Davison, WNP-2 equality Assurance (gA) Manager J.
Rhoads, WNP-2 Operations Event Assessment Manager
- B. Twitty, Technical Assessments
"C. Becker Operations Shift Manager
- M. Reis, I lant Engineering/Compliance Supervisor
"B. Pesek, Plant Technical Balance of Plant Supervisor
"R. Barbee, Control Systems Supervisor
- D. Kerlee, Principal gA Engineer
"R. Fuller, Compliance Engineer
- J. Irish, Bonneville Power Authority
"L. Morrison, Chemistry Supervisor
- J. Hunter, HP Craft Supervisor
"P.
MacBeth, Radwaste Supervisor
- R. James, ALARA Coordinator M. Eades, Licensing A. Carlyle, Corporate gA (*)
Denotes personnel who were present at the exit meeting held on December 13, 1991.
In addition to those individuals listed above, the inspector met and held discussions with other licensee personnel.
NRC G. Yuhas, Reactor Radiological Protection Branch Chief, Region V
P.
Eng, WNP-2 Project Manager, Nuclear Reactor Regulation 2.
Follow-u of Previous Ins ection Findin s (92701)
a.
Radiochemistr /Chemistr (84750)
Follow-u Item 50-397/91-40-03
{Closed): This item concerned the percep son a
e licensee s p an c emistry program lacked oversight of its activities by the Corporate Chemistry Committee.
The inspectors re-examined the activities of both quality assurance (gA) and the Corporate Chemistry Committee, during this inspection,
in order to understand the depth of management oversight afforded to the chemistry program.
A's Chemistr Activities NRC Region V Inspection Report 50-397/89-15 characterized the licensee's QA oversight as declining, weak, and in need of management attention.
The inspector examined the licensee's chemistry program for compliance with Technical Specification (TS) 6.5.2. 1.(e) "Chemistry and radiochemistry,"
and TS 6.5.2.8.(d),
"Operational QA Programs," for meeting
CFR 50, Appendix B, requirements for audits.
The licensee's QA program description utilizes Nuclear Operations Standards (NOS) to implement the 18 criteria of 10 CFR 50, Appendix B.
NOS 18, "Plant QA Surveillance Program,"
and NOS 20, "Audits," apply to the licensee's chemistry program.
NOS 36 "Chemistry," establishes MNP-2's policy for chemistry controls.
Under NOS 36, chemistry activities applied to five of the eighteen criteria in Appendix B of 10 CFR 50.
The inspector examined the Corporate QA and Plant QA chemistry programs related to audits surveillances, and technical assessments.
Since July 1)89, QA conducted nine audits that indirectly examined chemistry activities.
In 1991 the Plant QA group conducted three surveillances of chemistry related activities.
Additionally, a number of QA assessments were performed on chemistry activities.
The inspector was concerned with the lack of direct and specific QA/QC audits and surveillances of chemistry activities.
QA stated that they were enhancing their chemistry QA/quality control programs because they were not satisfied with the present level of specificity in them.
The inspector concluded that the licensee met the requirements of TS 6.5.2. 1.(e)
and TS 6.5.2.8.(d).
The inspectors had no further concerns in this matter.
Cor orate Chemistr Committee In December 1990 the licensee established a Corporate Chemistry Committee to provide management oversight of MNP-2's chemistry program controls and long-range improvements.
NOS 36 set the goals and responsibilities of the Committee.
During previous inspections, it seemed that plant chemistry initiated and implemented improvement programs without corporate oversight.
Some of these improvements such as condensate demineralizer resin changes and filter element changes had a significant
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otential of impacting radiological conditions in the plant.
he inspector looked for evidence that the Committee was active in chemistry programmatic decisions.
NOS 36 requires the Committee to report quarterly to plant management and annually to senior management s Quality Council.
The inspector reviewed Quality Council meeting minutes for 1991 and found no reports by the Corporate Chemistry Committee.
NOS 36 requires the Committee to have a five year, chemistry plan.
The inspector reviewed the Committee's draft five year chemistry plan, dated
July 1991, the plan had 46 specific initiatives.
As of Oecember 1991, the licensee had not decided when the plan would be finalized and approved.
However, the Committee selected ten initiatives from the five year plan that senior management needed to budget for 1993.
The inspector noted that the August 1991 Licensing 8 Assurance Annual Report stated that the Committee failed to meet on a regular basis and there had been little or no Committee oversight of chemistry activities.
The inspector attempted to review Committee meeting minutes, however, there were none.
Since November 1991, the Committee had convened five meetings, also, a new Committee chairmen was being appointed by senior management.
Licensee senior management and the Committee were taking positive steps to improve the effectiveness of this oversight group.
The inspectors had no further concerns in this matter.
Internal Ex osure Control and Assessment 83725 Follow-u Item 50-397/91-26-02 (Closed):
This item concerned the con ro an serv>ce air sys em and the finding that filter units and dessicant had trace amounts of radioactive contamination on them.
The licensee uses the CSAS as a source of breathing air.
The licensee uses filter units between the breathing air manifold connections and the CSAS compressors as a backup for removing contaminants.
Licensee analysis of the filter units, showed that three filters had trace amounts of cobalt-60.
The calculated air.
isotopic concentrations ranged from 2.7 E-14 microCuries/cubic centimeters (uCi/cc) to 1.9 E-13 uCi/cc.
This level of contamination was not significant when compared to the allowed maximum permissible concentration (MPC) in air of cobalt-60, 3.0 E-07 uCi/cc.
The licensee plans to continue implementing the CSAS isotopic sampling program on the filter units.
Compressors used for breathing air are required to produce grade
"D" quality air, according to ANSI Z88.2-1980, Section 5.2, on compressed gaseous air.
The licensee periodically samples the air quality produced by CSAS, and they continue to demostrate that the air quality standard is met.
The inspector reviewed July 1989 Problem Evaluation Report (PER) 289-067, that thoroughly evaluated the source of CSAS contamination.
PER 289-067 stated that the CSAS pulled contaminated air from the Reactor Building effluent stack into the Turbine Building and CSAS compressor intakes.
This was due to the "building wake effect" created by the winds and the two buildings.
The PER recommended that the CSAS air intakes be modified to reduce the effect of Reactor Building effluents.
The standards listed below on breathing air compressors stated the following:
CFR 1910.134(d)(2)(ii) requires that compressors shall be constructed and situated so as to avoid entry of contaminated air into system and suitable in line air purifying sorbent beds and filters installed to assure air qualit l t
Compressed Gas Association Pamphlet G-7, Section 3. 15, recommends that the quality of air taken into the compressor intake is a major factor in governing the quality of air which will be delivered from the compressor.
When the inspector discussed the above observation with the licensee, they stated that they were going to take this concern to their health and safety department for further evaluation.
The inspector concluded that licensee's administrative controls and sampling programs on CSAS met NRC requirements.
The inspector had no further concerns in this matter, Unresolved Item 50-397/91-31-03 (Closed):
This item concerned severa asr orne ra soac
>vs y samp ing units that were operating in a manner which would lead to non representative sampling.
The exhaust from the samplers were blowing across the sampling filter which interfered with the effective sampling.
The licensee maintained that data gathered by these samplers were being used for trending Reactor Building airborne activity only, and not for establishing worker maximum permissible concentration hours (MPC-hrs) per 10 CFR 20. 103.
During facility tours, the inspector verified that the licensee installed exhaust suppressing mufflers on the air samplers.
The inspector had no further concerns in this matter.
Trainin and ualifications:
General Em lo ee Trainin
[GET]
Radiation a
e an em>s r a was e
an rans or a son The inspector reviewed licensee efforts that e'mphasized worker adherence to health physics procedural requirements and good radiation work practices.
Licensee management had taken many initiatives to communicate radiological expectations to workers.
Management issued letters to all contractors to comply with the radiation protection program, "Personally Preventable."
Letters were also issued to health physics staff on
"Procedural Compliance,"
and to workers on "Radiation Safety,"
and
"Radiological Accountability."
The licensee established a radwaste sorting program to reduce the number of radwaste shipments, and they began emphasizing this program in GET, and by using videos, and posters.
The Senior ALARA Committee was assured that ALARA principles were part of GET as well as health physics technician training.
The inspector discussed the GET and HP training programs with the training manager of GET, HP and chemistry.
The manager showed the inspector several examples where licensee management and staff training request were incorporated into the training programs.
The meeting minutes of the Training Advisory Group (TAG) and the equality Action Team ((AT) were reviewed.
These groups made recommendations to the training department for program enhancements.
The inspector reviewed the HP training schedule for Winter 1992, and schedules for GET and retraining.
The inspector reviewed the context of revisions to several GET courses.
The inspector reviewed the content of selected training materials such as:
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82-RDT-0908-RT 82-THP-0700 82-THP-1600 GET Category II Refresher Issuing Respiratory Protection Equipment Bag Monitor Operations The inspector concluded that management's emphasis on training was a
meaningful continuous effort, The licensee's training program was fully capable of meeting its safety objectives.
No violations or deviations were identified.
Control of Radioactive Materials and Contamination Surve s
and one orsn The inspector reviewed the licensee's efforts to reduce the volume of solid radwaste, and the first meeting minutes of the WNP-2 Waste Minimization Committee.
Several good ideas were proposed for minimizing the introduction of non-contaminated trash into contaminated areas.
One idea by this Committee was to solicit ideas by distributing a questionnaire to all workers.
Overall, the licensee reduced the amount of SRW processed from 15,247 cubic feet in 1990 to 10,722 cubic feet in 1991.
The number of personal contaminations and the amount of WNP-2 contaminated floor surface area were reduced.
The April 1991 resin spill resulted in the Radwaste Building basement getting decontaminated and repainted.
The inspector wanted to know how the licensee concluded that a 10 CFR 20.403(b) report did not apply to the resin spill.
Licensee representatives stated that they evaluated whether the April 1991 resin spill was a reportable event during that time period, but it was not documented.
On December 12, 1991, the licensee completed a reportability evaluation of that resin spill event.
The licensee determined that the facility was not significantly impacted by the event, and that part of one floor of the Radwaste Building facility was impacted.
This impact was limited to the loss of normal access to the waste compaction and sorting area.
WNP-2 said there was no damage to their property.
There was some contamination of the impacted area and management elected to deal with that contamination by utilizing paint as part of the clean up effort.
The licensee s reportibility evaluation on the resin spill was adequate and the inspector had no further concerns on this matter.
The inspector questioned whether the liquid radwaste (LRW) floor and equipment drain (FDR 8 EDR) sumps and collection systems were able to meet the intent of the safety evaluation in Chapter 9.3.3.3 of the Updated Final Safety Analysis Report (UFSAR), and, prevent spills similar to the April 1991 resin spill.
The inspector based this concern on three points:
Plant Design Change Package (PDCP)
No. 86-0621-0A, removed the leak detection alarms from the FDR/EDR systems, which otherwise detected abnormal flow.
- The 10 CFR 50.59 Design Safety Evaluation for PDCP No. 86-0621-OA justified the removal of the leak detection alarms from the FDR/EDR systems based on the reliability of sumps level switches and
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alarms, and plant walkdowns to identify the location of plant spills.
Problem Evaluation Reports (PER) 291-00l3, 0067, and 0594 identified many operational failures with the sump pumps and level switches.
PER 291-0283 will evaluate the Reactor Building sump R-5 over filling that occurred 8 days after the April 1991 resin spi 1 l.
Discussions were held with the LRW system engineer, radwaste supervisor, assistant HP/chemistry manager, mechanical maintenance supervisor, and the operations event manager on the condition of the LRW FDR/EDR sumps, alarms, and drains.
The licensee clearly plans to rework the LRW sump systems and they recognize the reliability problems as well as the potential radiological impact of a poor performing LRW system.
The licensee's operations events and assessments group I root cause/corrective actions] will further evaluate LRW system problems with a Corporate Sr.
HP they are adding to the staff to work radiological evaluations.
The inspector had no further concerns in this area.
The licensee's program was adequate to accomplish its safety objectives.
No violations or deviations were identified.
ALARA 8 Occu ational Ex osure Durin Extended Outa es (83728 8 83729)
The licensee's total collective radiation exposures for 1991 was 400 person-rem, compared to 536 person-rem for 1990.
The boilinq water reactor industry average for 1990 was 436 person-rem.
The licensee recognized that the reduced work scope in the refueling six outage was a
major factor in reducing personnel exposures.
However, they did experience dose reductions in major jobs where radiation levels were higher and workers took more time to complete the jobs.
Additionally, the licensee had a greater commitment to ALARA which included the formation of the HP planning group and the Senior Site ALARA Committee.
The Sr.
ALARA Committee developed a six part "Mission Statement" that was intended to ensure that elements of an effective ALARA program would be communicated to all WNP-2 workers.
The licensee was continuing its preparations for refueling outage seven (R-7).
The inspector reviewed some of the R-7 outage plans.
The ALARA Committee revised its R-7 ALARA goal from 800 person-rem to 600 person-rem.
The ALARA planning group based its R-7 exposure estimates on 25 drywell jobs under three chemical decontamination scenarios:
No Chemical Decontamination, 763 person-rem Decontamination of the reactor recirculation coolant (RRC)
discharge piping, 457 person-rem Decontamination of the RRC suction and discharge piping, 427 person-rem
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The inspector reviewed some of MNP-2's source term reduction efforts.
One review was a progress report on the results of EDR/FDR system flushes from December 2 to 13, 1991, The EDR/FDR drain lines represents a
substantial source of radiation in the Reactor Building.
Out of 27 drain lines flushed, approximately 20K had source term reduction factors of ten or better; the average reduction was five.
The Sr.
ALARA Committee received a joint Corporate HP and HP/chemistry department report on the probable causes of radiation buildup at WNP-2.
The September 1991 report identified that the failure of the reactor recirculation pump 1B wear ring and impeller resulted in the injection of 31 pounds of stainless steel into the reactor recirculation system.
The report attributed CRUD from fuel sipping work during the R-5 outage, however, the larger contributor to dose rates in 1990 was caused by reduced reactor feedwater zinc levels.
Studies found that activated zinc competes with cobalt on piping corrosion layers.
Dose rates from activated zinc are less than cobalt.
MNP-2 s condenser was constructed of admiralty brass which made the condensate system a natural zinc injection plant.
However, changes in the condensate system filter/demineralizers resins changed the plant zinc levels.
The September 1991 report recommended the following: consideration of zinc injection, periodic gamma spectrographic measurements at specific plant locations, chemistry evaluations of inner piping walls, and cobalt minimization programs.
Also, the licensee is planning for a chemical decontamination for the R-7 outage.
The licensee's ALARA and outage planning programs were capable of meeting its safety objectives.
No violations or deviations were identified.
Solid Radioactive Maste Hang ement and Trans 'ortation of Radioactive a er>a s
Audits The inspector reviewed the Radwaste (RW) Process Control Program Audit 91-586 that was conducted the week of November ll, 1991.
Th>s audit was required by WNP-2 TS 6.5.2.8.
The inspector compared the qualifications of the RM quality assurance (gA) audit team to the recommendations of Regulatory Guide 1. 146 and ANSI/ASHE N45. 2. 23 "qualification of equality Assurance Program Audit Personnel for Nuclear Power Plants."
The gA audit team leader provided his gA auditor certification and the resumes of the audit team to the inspector for review.
The RW audit team consisted of a licensee lead gA auditor, gA engineer from another utility, and a Department of Energy compliance engineer.
The audit team qualifications were commensurate with the recommendations of RG l. 146 and ANSI/ASME N45.2.23.
The scope of the RW audit was adequate for identifying program weaknesses and assessing its quality.
The inspector reviewed the preliminary findings of gA RM Audit 91-586..
The gA auditors had findings in the follow>ng areas:
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RW reduction Training of RW personnel Shipping of RW Radiation protection during RW operations The inspector concluded that gA RW Audit 91-586 was adequate and met the requirements of TS 6.5.2.8.
No violations or deviations were identified.
Exit The inspector met with the licensee representatives identified in Section 1 of this report on December 13, 1991.
The scope and findings of the inspection were discusse ~
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