IR 05000397/1993022
| ML17290A541 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/15/1993 |
| From: | Cillis M, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A540 | List: |
| References | |
| 50-397-93-22, NUDOCS 9308030132 | |
| Download: ML17290A541 (14) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No.:
License:
Licensee:
50-397/93-22 NPF-21 Washington Public Power Supply System (WPPSS)
P.O.
Box 968 3000 George Washington Way Richland, WA 99352 Facility:
Inspection-location:
Inspection duration:
Inspected by:
M.
Washington Nuclear Project 2 (WNP-2)
WNP-2 Site, Benton County, Washington June 7-11, 1993 I rm illis, Senior Radiation Specialist
+>S Date igned Approved by:
~Summar:
Jame H
Reese, Chi Faci ities Radiolog cal Protection Branch
.
Da e Signed Areas Ins ected:
Routine announced inspection of corrective actions for violations, followup items, occupational exposure during extended outages, and tours of the licensee's facility.
Inspection procedures 92702, 92701, and 83729 were addressed.
Results:
The licensee's performance appeared adequate in the area of occupational exposure control.. Weaknesses were identified in the areas of effective corrective actions for past violations, radiological work practices in contaminated areas, cleanliness and general housekeeping, and ALARA program implementation.
No violations or deviations were identified.
9308030i32 930715 PDR ADOCN 05000397 PDR
DETAILS 1.
Persons Contacted a.
Licensee J.
Baker, Plant Manager V. Parrish, Assistant Managing Director for Operation
- J. Albers, Corporate Health Physics Officer
- C. Madden, guality Assurance Engineer (gAE)
- D. Pisarcik, Radiation Protection Manager (RPM)
- W. Shaeffer, Operations Manager
- V. Shockley, Health Physics Manager, Nuclear Support Services (NSS)
G. Smith, Operations Division Manager
- G.. Sorensen, Regulatory Programs Manager
- J. Hunter, HP Operations Supervisor
- M. Tuel, HP Planning Supervisor (Acting)
- K. Pisarcik, Licensing
- R. Webring, Technical Division Manager
- L. Harrold, Maintenance Division Manager D. Truman, HP Craft Supervisor J. Wyrick, Outage Manager.
- M. Nolan, Principal Health Physicist/RadWaste, NSS
- P. Macbeth, Radwaste Supervisor
- L. Grumme, Manager, Nuclear Safety Assurance
'J.
Irish, Bonneville Power Authority, Operations Branch b.
NRC 2.
R. Barr, Senior Resident Inspector
- Denotes those individuals who attended the exit meeting on June ll, 1993.
The inspectors met and held discussions with additional members of the licensee's staff during the inspection.
Follow on Corrective Actions for Violations and Deviations 92702 Item 50-397 92-41-01 Closed:
The inspector verified that the corrective actions, described in the licensee's timely response, dated April 26, 1993, associated with this violation had been implemented.
The violation involved the transport of licensed material in a package that arrived at its destination with radiation levels in excess of limits allowed in Department of Transportatiog (DOT) regulations.
Corrective actions taken included training and a revision to PPM 11.2.23.4.
The WNP-2 Business Plan was modified to include actions to improve the Radwaste program utilizing independent resources for program review and internal resources for program self assessment.
This matter is close Item 50-397 92-41-02 0 en
The inspector reviewed the status of the corrective actions, described in the licensee's response, dated April 26, 1993, associated with this violation.
The violation involved the failure to make appropriate surveys for radionuclide identity and quantification involving Licensee Shipment 92-61-02.
The review disclosed all of the immediate corrective actions taken had been completed as stated in the licensee's response; however, long term corrective actions were still in the process of being implemented.
Full implementation was not expected to be completed until July 20, 1993..
The inspector noted that the licensee's Shipping Coordinator had only attended a two day course on 49 CFR compliance instead of the one week course addressed in the licensee's response.
This matter is still open and will be reviewed during a subsequent inspection.
Item 50-397 92-41-05 Closed
The inspector verified during the previous inspection (Inspection Report 50-397/93-14)
and this inspection that the corrective actions described in the licensee's timely response associated with this violation had been implemented.
The violation involved the removal of service air check valves designed for permanent installation without the required approvals, engineering evaluations, or required documentation.
The inspector had verified during the previous and also during this inspection that all service air lines observed during daily tours of the Turbine Building, Radwaste Building, and the Reactor Building had a
check valve installed with an attached white label identifying it as a
service air check valve with the words "S.A., CHECK VALVE f-] DO NOT REHOVE [-] CONTACT SHIFT MANAGER."
This matter is closed.
Items 50-397 92-41-08 and 50-397 92-41-09 0 en
The inspector reviewed the status of the corrective actions taken by the licensee in regards to these violations.
One violation included two examples of workers failing to adhere to posted health physics instructions and the other violation involved the failure of workers to record their radiation doses in accordance with'PPH 11.2.6.2 on January 27, April 29, and December 6,
1992.
The inspector determined that Items number 1 through 5 and Item number
listed under "corrective steps taken" of the licensee's response dated, April 26, 1993, had been completed.
However, the licensee staff did not know the status of corrective action taken with respect to Item 6 of the licensee's response.
Item 6 of the licensee's response stated:
"Specific detailed training has been given to,all Supply System employees with unescorted access into an RCA on the proper use of REC's."
The inspector held discussions with several members from the licensee's staff to determine what corrective actions were taken with respect to Item number 6.
The licensee did not maintain any records to indicate that all WNP-2 employees with unescorted access into an RCA were provided with the site specific training.
Discussions held with the
licensee training staff disclosed that the training group had not provided the "specific detailed training."
The inspector was informed by the training supervisor that copies of WNP-2 Interoffice Memorandums dated January 18, 1993,
"Radiation Exposure Card Usage,"
and January 19, 1993,
"Radiation Protection Program Adherence,"
were issued to the staff by the Plant Manager; however, he was not sure if the memorandums were issued in response to Item number 6.
Records were not available to determine if all employees with unescorted access to RCA's had received and read the memorandums.
The inspector was also informed that Item number 6 may have been addressed at one of several
"time outs" which were held with the plant staff by the plant manager between June of 1992 and February of 1993 to discuss plant issues.
Additional long term corrective actions addressed in the licensee's response included commitments to revise the General Information Handbook (GIH) by June 30, 1993, and to incorporate the lessons learned from the violations into General Employee Training (GET) by June 1,
1993.
The inspector was informed that the GIH may not be revised and that the changes to the GET had already been completed and was in the process of being implemented.
The licensee stated that a revision to the NOV response would be submitted if the GIH is not revised as originally planned.
The inspector noted that the change to the GET did not address how the lessons learned would be conveyed to workers who challenge the GET refresher training course.
This observation was discussed with the training supervisor.
The inspector discussed the above observation at the exit interview.
The licensee informed the inspector that an evaluation would be conducted to determine what corrective actions were taken with respect to Item 6.
These items are still open and will be reviewed during a
subsequent inspection.
Item 50-397 92-41-10 Closed
The inspector verified that the corrective actions described in the licensee's response, dated April 26, 1993, associated with this violation had been implemented.
The violation involved the failure determine the waste burial classification for radw'aste shipment of Liner 5'338 prior to using the shipping cask.
Corrective actions taken to prevent a recurrence included the training of the licensee's Radwaste Shipping Coordinators.
This matter is closed.
Item 50-397 93-07-01 0 en
The violation identified in Inspection Report 50-397/93-07-01, dated March 25, 1993,,reported four instances in which the licensee did not comply with PPM 1.3. 19, Section 4.2. 11(a),
"Rubber/Tygon Hose Tagging." Section 4.2. 11(a) of PPM 1.3. 19 was implemented as a part of the licensee's corrective actions to a previous violation identified in Region V Inspection Report 50-397/92-35.
As a part of WNP-2's corrective actions in response to the 50-397/92-35 violation, WNP-2 stated that "a program will be established to control the movement and use of hoses in the plant [which will] include the use
of hoses for temporary routing of fluids."
The date for full compliance with this hose control program (established by PPH 1.3. 19, Section 4.2.))(a),
"Rubber/Tygon Hose Tagging" was February 1,
1993.
On January 29, 1993, PPH 1.3.)9, Revision 3, "Plant Material Condition Inspection Program,"
was issued.
The licensee's response to violation 50-397/93-07-01 stated:
"Although steps were taken to prepare for the new procedural requirement of the program, personnel training and compliance verification by plant supervision had been inadequate to properly implement it."
As part of WNP-2's corrective steps taken in response to 50-397/93-07-01, WNP-2 line management were asked to conduct walkdowns to ensure compliance with the procedure revision and an Inter-Office-Memorandum was issued to all employee's on April 22, 1993, by the Plant Manager, clarifying the requirements for "Work in Progress/Hose Control" tags.
Additional corrective action described in the licensee's response dated Hay 13, 1993, included:
o Frequent plant walkdowns to ensure compliance with PPH 1.3. 19 and to provide feedback to upper management.
o A revision of PPH 1.3. 19 by June 1,
1993, to incorporate recommended clarifications and improvements.
o The development of guidelines by June 15, 1993, which are to be used as an aid in planning and implementing major changes.
The response to 50-397/93-07-01 stated that WNP-2 would be in full compliance on August 1,
1993.
As a result of a conference call held with a member of the licensee's staff on Hay 14, 1993, several Region V members were informed that WNP-2's hose control program was a high priority issue and that much progress had been made in the implementation of this program.
A followup inspection was conducted during the week of May 17-21, 1993, to determine the extent of progress that had been made towards improving the licensee's hose control problem.
Inspection Report 50-397/93-14, described similar problems as were reported in inspection report 50-397/93-07.
During this inspection, a tour of the turbine generator building on June 7,
1993, resulted in similar findings reported in inspection reports 50-397/93-07 and 50-397/93-14.
The inspector found additional hoses that were being used to temporarily reroute fluids that were not tagged in accordance with the instructions provided in PPH 1.3. 19.
The inspector brought the observation to the attention licensee's staff who then took immediate actions to correct the untagged hoses.
The inspector also discussed the above observation at the exit interview.
The inspector informed the licensee that corrective actions taken prior to this inspection had not been effective.
The inspectors continue to
have concerns in this matter.
This matter is still open and will be reviewed during a future inspection.
Followu Items NRC Information Notice IN 93-01 Closed:
The inspector verified that the licensee had received the following IN for evaluation:
"Unplanned Intakes of Airborne RAM" This matter is closed.
Item 50-397 93-14-03 0 en
Weaknesses with the licensee's ALARA and personnel contamination programs during the performance of refueling outage R-8 are discussed in Region V Inspection Report 50-397/93-14, Section 4(d).
a ~
The WNP-2 Final Safety Analysis Report (FSAR), Chapter 12 states in part that the licensee's ALARA program is: "based, when practicable and feasible, on Regulatory Guide(s)
(RG) 8.8, Revision 3, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations will be As Low A's Is Reasonably Achievable" and RG 8. 10, Revision 1, "Operating Philosophy for Maintaining Radiation Exposures As Low As is Reasonably Achievable."
The Operational Health Physics Program provides for the majority of the recommended actions in both regulatory guides..."
FSAR, Chapter 12. 1.3. 1, "Procedures and Method of Operation,"
states in part: "At WNP-2, a positive means of assuring that occupational exposures are as low as is reasonably achievable has been incorporated into the Plant Procedure Manual (PPH)
Preparation Program.
Procedures are formally reviewed for ALARA considerations as part of the approval process....
The guidance provided by RG 8.8 is considered during the review."
A review of the licensee's performance since the conclusion of the previous inspection was performed.
The following observations were made:
o At the start of this inspection, June 7,
1993, the licensee had expended a total of 298 person-rem and by June ll, 1993, had expended a total of 355 person-rem for the outage.
Subsequent telephone calls with the licensee's staff during the week of June 28, 1993, disclosed that the final person-rem reported for the outage was approximately 385 person-rem.
The plant ALARA group informed the inspector that the original ALARA exposure goal for the outage submitted for management approval was 277 person-rem.
Management changed the original 277 person-rem goal to 220 person-rem to make
I j j
i>)
!
the goal more challenging.
The ALARA group also stated that the dose rates after chemical cleaning were higher than the values that were-used for establishing the original 277 person-rem goal.
The inspector questioned licensee staff as to the reason for the increase in exposure.
The ALARA group informed the inspector that the R-8 refueling work force did not possess the same level of experience as'the R-7 refueling work force which may have contributed towards the higher exposures.
Other contributing factors for the higher exposures were attributed the addition of emergent work packages and less than optimum planning (e.g.,
poor person-hour and person-rem estimates)'nd scheduling (e.g, coordination of work packages).
A review by the inspector of the licensee's ALARA log book appeared to confirm these statements.
For example:
An ALARA log book entry dated Hay 28, 1993, stated in part:
"The scaffold should never have been built and the dose received by the persons involved should not have been expended."
A review of the log entry disclosed that on May 24, 1993, a
request was made to have the scaffolding i.nstalled for the purpose of performing an In-Service-Inspection (ISI) on the 548'levation of the reactor building.
The ALARA group recommended that the job be deferred because of high dose rates in the work area.
The recommendation was over ruled and the scaffolding was subsequently installed.
A radiation survey performed after the scaffolding was installed indicated that the dose rates were higher than what was originally expected.
The ALARA group did some additional checking and found out that there were alternate locations that could be inspected if the dose rates were too high.
Therefore, the ISI inspection was subsequently canceled.
An ALARA log book entry identified that some problems were encountered associated with the installation of insulation on RRC-V-23B and RRC-P-1B.
The log entry states in part:
"Twice the man-hours and exposure was spent for this job because of in-experienced personnel and inadequate briefings on insulation installation to these personnel."
Regulatory Guide 8.8, Part C.l.b.(l)(c),states in part:
"Ensuring that the measurement system results are reviewed on a periodic basis and that corrective actions are taken when attainment of the specific objectives appear to be jeopardized; and..."
PPH 11.2.2.6 Paragraphs 5.5 and 5.5.2 requires in-progress reviews to be performed for cases where the estimated person-hour or person-rem are being approached or substantially exceeded in an
attempt to identify where improvements can be made to maintain activities ALARA.
PPH 1. 11.2,
"ALARA Program Description,"
Paragraph 6 states that the Health Physics Planning Group Supervisor is responsible for maintaining the Plant ALARA files and that the Plant ALARA files shall include, but are not limited to: Outage planning materials, planning meeting minutes, in-progress and post-job reviews, and post-outage reports.
The licensee informed the inspector that documentation of the in-progress review was contained in the ALARA log book.
A review of licensee records dated June 11, 1993, used to track person-rem and person-hours by Radiation Work Permit numbers for R-8 refueling activities disclosed a variance in the person-rem and person-hours expended for at least eleven refueling activities.
Two examples of the eleven are as follows:
o The estimated number of person-rem and person-hours for RWP 2-93-00142 was 16.5 person-rem and 1100 person-hours respectively.
As of June 11, 1993, the person-rem expended was reported as 38.972 and the person-hours expended was reported as 2427.
o The ALARA estimated person-rem and person-hours for RWP 2-93-00144 was 9.000 person-rem and 758 person-hours respectively.
As of June 11, 1993, the person-rem expended was 13.652 and the person-hours expended was reported as 618.
The inspector reviewed the ALARA log book in an effort to review in-progress reviews.
The ALARA log book indicated that it was primarily being used by the ALARA group to record what occurred on shift and the problems that were encountered.
The ALARA log notes did not assess why the person-rem and person-hours estimates had been or were in the process of being exceeded for the above noted jobs.
The inspector noted that the ALARA log book entries did not reference an applicable RWP to which a "log entry" was referring.
The inspector could not determine if a log entry could be considered as an "in-progress review".
The licensee's radiation protection and ALARA group informed the inspector that PPH 11.2.2.6 did not provide sufficient instructions as to how to conduct the in-progress reviews and how to document them.
The licensee did perform an in-progress review on RPV nozzle penetration shield doors because of ALARA concerns associated with these work activities to support In-Service-Inspection(ISI).
This review was well documented.
The licensee did not have any similar formal in-progress reviews for the two examples discussed above.
The ALARA group stated that the in-progress reviews for the two examples had been covered by the daily "log entries."
~
'
The inspector concluded that certain portions of the licenses ALARA program were weak and implementation does not appear to be consistent with instructions provided in PPH 1. 11.2 and 11.2.2.6 and RG 8.8.
The above observations were discussed at the exit interview.
The licensee acknowledged the inspectors concerns.
This matter is still open and will be reviewed again during a future inspection.
Occu ational Ex osure Durin Extended Outa es 83729 a ~
Audits and A
raisals b.
This subject was previously addressed in Region V Inspection Report 50-397/93-14.
Additionally, discussions held with the licensee*s staff revealed that the guality Assurance Group was planning to conduct an audit of the licensee's ALARA program upon completion of the refueling outage.
This audit was originally planned to be performed during the R-8 outage; however, it was rescheduled because of other priorities.
The gA group plans to focus on the concerns addressed in Section 3 of this report and similar areas in Inspection Report 50-397/93-14.
The inspector agreed that a post outage audit of the licensee's ALARA program would be an effective method for improving the licensee's ALARA program prior to the start of refueling outage R-9.
External Ex osure Control C.
The inspector observed diving operations that were performed in the suppression pool for conformance to WNP-2's procedures and Radiation Work Permit requirements.
The divers were assigned to vacuum debris that had accumulated on the suppression pool bottom.
A thorough ALARA pre-job briefing was held with the workers prior to the start of the operation.
The inspector toured the drywell with the NRC senior resident inspector to check for cleanlin'ess prior to plant restart.
All wo'rk activities observed during the tour appeared to be consistent with the applicable Radiation Work Permits (RWP).
Contamination Area Work Practices During tours, the inspector noted that workers were leaving their plastic face shields and safety glasses lying on the floor or horizontal surfaces in areas posted as contaminated areas at the end of each shift.
The inspector determined that this practice could lead to possible facial contamination since it would be doubtful that each of these items would be surveyed prior to reuse by another worker.
This same work practice was brought to the licensee's attention during a previous inspection (Inspection Report 50-397/93-I4).
In discussions with members of the licensee's health physics (HP)
staff concerning this matter, the inspector was informed that the licensee is in the process of purchasing a disposable type of face shield.
The licensee added that steps would be taken to improve the practice of leaving the plastic face shields in a contaminated area.
Postin and Labelin Posting and labeling practices observed during tours of the licensee's restricted areas were noted to be consistent with 10 CFR Part 19. 11 and
CFR Part 20.203 requirements.
Maintainin Occu ational Ex osures ALARA This matter is discussed in Section 3,
above.
talk On June 7,
1993, the inspector noted that housekeeping conditions on the 507 foot elevation of the Radwaste Building (RW) was very cluttered and disorganized.
There were a large number of
"Controlled Surface Contaminated Areas (CSCA)" with very little separation between them for personnel to maneuver around without accidental stepping into a
CSCA or on a bag containing radioactive material.
The area was cluttered with both non-radioactive and radioactive materials.
Several polyethylene bags containing radioactive material were open and/or were tom thereby reducing their effectiveness in the containment of contaminated radioactive material.
A four-wheeled laundry cart was being used to collect rain water.
An inspection performed by another licensee group on June 10, 1993, documented the following statement:
"RW507 foot has turned into a receptacle zone for everyone unwanted equipment.
Several efforts in the last two years have failed to resolve this housekeeping dilemma."
On June 10, 1993, the inspector conducted another tour of the 507'evel with two members of the licensee's staff.
Both individuals agreed that housekeeping condition did not meet managements expectations provided in PPH 1.3. 19, "Plant Material Condition Inspection Program" and PPH 1. 12.7,
"Extended Term Radioactive Material Storage."
PPH 1. 12.7 establishes licensee requirements for extended term storage of radioactive materials.
A licensee representative accompanying the inspector initiated a Plant Evaluation Request (PER-293-833).
On June ll, 1993, the inspector and NRC senior resident inspector toured the RW507 foot level again.
The senior resident inspector agreed that improvements in housekeeping were neede The above observations were brought to the licensee's attention at the exit interview.
The licensee informed the inspector that immediate action would be taken to resolve the housekeeping problems noted.
The licensee's program appeared to be adequate in meeting its safety objectives.
Weaknesses with the licensee's ALARA and housekeeping programs were identified.
No violations were identified.
Exit Interview The inspector met with members of licensee's management at the conclusion of the inspection on June ll, 1993.
The scope and findings of the inspection were summarized.
The inspector notified the licensee that no violations were identified.
The concerns with the ALARA program discussed in Section 3 and the poor housekeeping concern discussed in Section 4 were brought to the licensee's attention.
The licensee acknowledged the inspectors concerns.