IR 05000397/1993026
| ML17290A583 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/12/1993 |
| From: | Chaney H, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A582 | List: |
| References | |
| 50-397-93-26, NUDOCS 9308250157 | |
| Download: ML17290A583 (10) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No.:
License:
Licensee:
50-397/93-26 NPF-2I Washington Public Power Supply System (WPPSS)
P.O.
Box 968 3000 George Washington Way Richland, WA 99352 Facility:
Washington Nuclear Project
(WNP-2)
Inspection location:
WNP-2 Site, Benton County, Washington Inspection duration:
June 28 through July 2, 1993 Inspected by:
Approved by:
f
~Summ mr:
aney, r.
ea or a >ation pecia est am s
.
eese, C
e Facilities Radiological Protection Branch ate cygne grz ~
ate cygne Areas Ins ected:
Routine announced inspection of the licensee's radiation protection program, organization, and staff qualifications, occupational exposure controls, and the licensee's ALARA performance during refueling outage R-8.
NRC inspection procedure 83750 was used.
Results:
The licensee's Radiation Protection program appeared capable of maintaining an adequate level of public and worker safety.
There is still a conspicuous absence of permanent professional level health physics support (other than the RPH) in the plant staff for day to day activities. Similar type findings that have been previously reported in NRC Inspection Reports 50-397/90-29 and 91-10.
No violations of NRC requirements were identified within the scope of this inspection.
9308250157 9308i2 PDR ADOCK 05000397
,
Persons Contacted DETAILS Licensee
- V. Parrish, Assistant Director of Operation J. Albers, Radiation Protection Manager
- W. Davison, Plant guality Assurance Manager
- C. Fies, Licensing Engineer
- J. Gearhart, Director, guality Assurance R. James, HP Planning Supervisor
- J. Hunter, HP Operations Supervisor
- L. Harrold, Maintenance Division Manager
- P. MacBeth, Radwaste Supervisor C. Madden, guality Assurance Engineer (gAE)
B. Nordhaus, Sr.,HP Technician
- K. Pisarcik, Licensing N. Price, Radwaste Operator
- J. Sampson, Manager, Maintenance Production
- G. Sorensen, Regulatory Programs Manager
- J. Swailes, Plant Manager B. Teller, Senior Shift Supervisor, Operations (BOP)
- D. Truman, HP Craft Supervisor
- R. Webring, Technical Division Manager NRC 2.
R. Barr, NRC, Sr. Resident Inspector
- D. Proulx, NRC, Resident Inspector
- Denotes some of those individuals who attended the exit meeting on July 2,
1993.
The inspector met and held discussions with additional members of the licensee's staff during the inspection.
Follow-u on Previous Ins ection Findin s 92701 Closed Ins ector Follow-u Item 50-397 92-41-06:
This item was previously discussed in NRC Inspection Report No. 50-397/92-41 and dealt with the licensee's determination that two plant systems (normally not radioactively contaminated)
were radioactively contaminated with tritium.
The inspector reviewed the licensee's actions concerning the finding of tritium in the Plant Heating Steam System (FSAR Section 9.4. 16)
and the Auxiliary Boiler (see Problem Evaluation Report 292-1263).
The Auxiliary Boiler and the Plant Heating Steam System were cross contaminated by leakage from either the feed water heaters or the seal steam evaporator.
The licensee has developed an FSAR change (93-46)
and performed a
CFR Part 50.59 safety review of the situation before implementation of the change.
The licensee's actions reclassify the
auxiliary boiler and plant heating steam system as radioactively contaminated systems with commitments to monitor/control releases via the common drainage paths for both systems.
The licensee's actions are in agreement with the guidance provided by the NRC in NRC Bulletin No. 80-10,
"Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment," dated May 6, 1980.
The inspector concluded that the amount of tritium in these systems can be easily monitored and controlled; and does not pose an unreviewed safety ques'tion.
This item is considered closed.
Occu ational Ex osure 83750 a ~
~Chan es The licensee has been realigning the plant and support group staffs, including plant management since 1990
{see NRC Inspection Reports 50-397/92-41, 91-10, and 90-29).
On June 18, 1993, a new Radiation Protection Manager was appointed.
Review of the new RPMs qualifications was made by the inspector.
Since November 1992 nearly all senior plant management positions have been replaced with experienced personnel from outside WPPSS.
The inspector noted that the current senior management positions in both corporate and plant staffs have an extensive amount of professional radiation protection experience.
However, it was noted that the licensee still had not completed staffing of the
"Principle Health Physicists" positions in the plant Radiation Protection Division.
The inspector also noted that the newly appointed RPM appears to easily meet TS 6.3. 1 experience and education requirements for the position of RPM.
However, the inspector noted to licensee management, that even though a cognitive evaluation of the new RPM's qualification had been made by senior management, no documentation is available stating that a formal evaluation had been made of the appointees qualifications for the position, and whether all FSAR commitments or TS requirements were satisfied by the appointee.
Senior licensee management acknowledged the inspectors finding and agreed that documentation of an appointee's ability to meet TS and Final Safety Analysis Report
{FSAR)
specifications should be considered.
The NRC inspector noted that the Corporate Support Services had consolidated the Radiological Environmental Monitoring Program Group and the Health Physics Group with direct reporting to the Manager of Support Services.
This effectively eliminates the technical oversight concerns the NRC had with the previous organization
{April 1991),
as discussed in NRC Inspection Report No. 50-397/91-1 The following plant administrative procedures were review during this inspection.
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PPM 1. 1. I, "Management Organization;" Revision
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PPH 1. 1.2,
"Plant Organization," Revision
o PPM 1. 1.3, "Plant Responsibilities,"
Revision
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PPH 1. 1.6,
"ALARA Committee's,"
Revision
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PPH 1. 11.3,
"Health Physics Program," Revision
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PPM 1. 11.4,
"Radiological Support Services,"
Revision
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PPM 1.)1.)), "Entry Into, Conduct in, and Exit from Radiologically Controlled Areas, Revision
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PPM 1. 11. 12,
"Removal of Liquids from the RCA," Revision
Audits and A raisals The inspector reviewed a Corporate Licensing and Assurance Audit Report (92-594) of the WNP-2 Radiation Protection Program.
This audit was conducted in three phases between Hay 1992 and January 1993.
The audit was a comprehensive evaluation of the entire Radiation Protection Program for WNP-2, involving facilities, equipment, procedures, work practices, personnel training, qualifications and performance.
The audit team included an auditor from another nuclear power plant, and several consultants with expertise in radiation protection programs and auditing.
The audit was very critical of the RP Program implementation.
The audit reached the conclusion that the WNP-2 Radiation Protection Program is not fully effective.
The inspector noted that while the audit's findings were numerous and discussed apparently serious problems, when viewed individually, and in aggregate, the findings are not a significant reduction in safety or indicative of a breakdown of the Radiation Protection Program at WNP-2.
Since the finll report of this audit was not issued until June 18, 1993, the inspector was not able to review all corrective actions taken by management (some actions were taken during the audit and appear ed to be effective in resolving the auditors concerns).
WNP-2 Management was still reviewing the audit report at the time of this inspectio The review of the audit by WNP-2 management, establishment of corrective actions for findings, and completion of corrective actions will be considered an inspector follow-up item for future review (50-387/93-26-01).
The following gA surveillances were also examined by the inspector:
gA Surveillance Report No. 292-0011,
"Radioactive Materials Management,"
dated January 6,
1993.
gA Surveillance Report No. 292-0010,
"Contaminated Laundry Shipments,"
dated March 8, 1993.
gA Surveillance Report No. 293-0021,
"Alarming Dosimeters,"
dated May 25, 1993.
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ga Surveillance Report No. 293-0020,
"R-8 Health Physics Program Compliance,"
dated June 21, 1993.
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gA Surveillance Report No. 292-0005,
"Alpha Radiation Surveys,"
dated June 22, 1993.
o gA Surveillance Report,No.
293-0029,
"System Walkdown, Dry Well Cleanliness," draft.
All of the above noted surveillances were performance based evaluations of plant activities.
These surveillances were found to be of sufficient scope (industrial safety, mixed waste, radiological safety, transportation, etc.,).
Several good findings were identified during these surveillances.
For example:
Surveillance 293-0021 identified a deviation from the licensee's commitments in the FSAR and to Regulatory Guide 8.28, concerning the preuse checkout of alarming dosimeters was identified.
Corrective action by the Radiation Protection Division to this finding was executed in a timely and apparently effective manner.
Surveillance 292-0011 was critical of the licensee's ability to properly classify and ship radioactive waste.
This surveillance, when in draft form,.was the basis for an NRC enforcement action, see NRC Inspection Report 50-397/92-41.
The licensee was still completing corrective actions to the surveillance.
Overall, the licensee's audit and surveillance program's are effective in assessing the performance level and identifying problems in the licensee's radiation protection progra The effectiveness of the licensee's corrective action program was not reviewed during this inspection.
Plannin and Pre aration The inspector held discussions with licensee representatives involved in the development and implementation of the newly revised
CFR Part 20 (Radiation Protection Standards).
The licensee is currently striving for implementation of the new Part 20 by October 1,
1993.
The licensee is actively i'nvolved in development of positions and policies regarding the new Part 20 regulations with a formal task group comprised of other Region V
power reactor licensees.
External Ex osure Control The inspector observed licensee performance during the planning and execution of the flushing of a radiation hot spot (greater than 1,000 Roentgens per hour (R/hr) on contact and approximately 3-5 R/hr at 18 inches distance from the valve) in a portion of the liquid radioactive waste processing system (Reactor Water Cleanup System valve RWCU 450).
Flushing was necessary so work could be perform on an adjacent valve (RWCU 231B).
Both valves were located in the west shielded valve gallery on the 467 foot elevation of the Radwaste Building.
This flushing was performed in accordance with Systems Operating Procedure 2.2.3,
"RWCU System,"
Revision 16.
The inspector verified that the operators were using the most current revision of the procedure.
The inspector reviewed the standing Radiation Work Permit (RWP 031) for the evolution, attended prework briefings, and observed the valve line up and flushing of the hot spot.
Radiological controls for the evolution were established in accordance with license procedures.
High radiation area key and exposure controls were in accordance with TS 6. 12. 1 8 2.
After 3-4 flushes the hot spot was reduced to approximately 150 R/hr on contact and
.300 R/hr at 18 inches distance.
Flushing was stopped due to lack of information on how low the radiation levels needed to be reduced.
The job was accomplished without any one exceeding 0. 100 R of whole body exposure.
Operators and the HP Technician utilized good dose reduction practices during their entries.
Appropriate personnel dosimenters were worn by all personnel involved.
The inspector noted to licensee management that during the valve lineup for the flush Equipment Operator s had to e'nter High Radiation Areas to visually verify valve positions.
All such valves were equipped with remote operating devices and all remote operators for the valves requiring visual inspection (3) had deficiency tags attached to them.
The deficiencies were the same on all - "Stop Broken."
With the valve positioning stops broken, equipment operators could not determine from outside the valve
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galleries whether the valve positioning indicator was reading accurately.
The licensee did a review of remote operator
'deficiency tags and determine that 11 valves were tagged and that some tags had been installed as early as May 1992.
Licensee representatives agreed with the inspector that having Equipment Operators enter high radiation areas to verify valve positions defeats the logic behind having remote operating devices on the valves.
Control of Radioactive Materials and Contamination Surve s
and Monitorin The inspector reviewed several specific job type surveys and routine facility surveys, conducted confjrmatory radiation exposure rate surveys, and observed facility radiological posting.
The inspector performed independent gamma radiation exposure rate measurements of areas inside and outside of the licensee's facility.
These measurements were made using a Geiger-Mueller type Xet'ex Model 305B, NRC Serial Nos.
08958, due for calibration July 19, 1993.
Licensee surveys and posting conformed to the requirements of 10 CFR Part 20.201 and 20.203.
Exposure rates obtained by the
'nspector agreed with licensee survey results.
Haintainin Occu ational Ex osure ALARA ALARA Results The inspector discussed with ALARA Group representatives the licensee's performance in meeting forecasted annual and scheduled outage collective personnel exposure goals.
The licensees ALARA performance in refueling outages have been the subject of previous discussions in the following NRC Inspection Reports 50-397/93-12, 92-11, and 92-08.
The inspector noted that during the past 5 years the licensee has only met their fiscal year person-rem goal twice
{1991 8 1992)
and has only once
{1988) been below the national average for similar power plants.
Licensee representatives indicated that the reason they exceeded their latest refueling outage (R-8) goal of 220 person-rem was:
unrealistic expectations were made about the work to be performed; an unexpected amount of rework (shielding/scaffol'ding)
occurred;
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and an in ordinate amount of emergent work took place in the Drywell.
The inspector noted that even though the licensee performed a
limited chemical decontamination of reactor recirculation piping during the last refueling outage (R-7), dose rates in the affected areas have returned to approximately 58 percent of predecon levels, and in some places above the predecon levels.
A detailed discussion of the licensee's accomplishments during the chemical decontamination of the recirculation piping was previously discussed in NRC Inspection Report No. 50-397/92-13.
The ALARA Group was starting post outage (R-8) job evaluations.
The inspector examined an initial draft report on the post R-8 outage evaluation of the initial Drywell shielding activities.
This report was a critical review of their performance on this job, which expended approximately 75 percent more exposure than anticipated.
Some of the problems identified were:
o Failure to coordinate interfering work operations and supporting work in the areas to be shielded.
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Delays in starting the shielding effort due to adverse environmental conditions in the Drywell upon its opening.
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Failure to develop specialized shielding methods for certain hot spot areas.
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Failure to adequately utilize historical exposure and man-hour estimates from past shielding jobs.
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Lack of sufficient involvement by supporting craft supervisors in prejob briefings and job oversight (from an ALARA perspective).
The licensee's program appeared to be adequate in meeting its safety objectives and NRC requirements.
No violations or deviations were identified.
Exit Interview The inspector met with members of licensee's management at the conclusion of the inspection on July 2, 1993.
The scope and findings of the inspection were summarized.
The licensee acknowledged the inspectors'bservations.