IR 05000397/1995011
| ML17291A798 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/26/1995 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A795 | List: |
| References | |
| 50-397-95-11, NUDOCS 9505180215 | |
| Download: ML17291A798 (9) | |
Text
ENCLOSURE U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-397/95-11 License:
NPF-21 Licensee:
Washington Public Power Supply System 3000 George Washington Way P.O.
Box 968, MD 1023 Richland, Washington Facility Name:
Washington Nuclear Project-2 Inspection At:
Richland, Washington Inspection Conducted:
April 10-14, 1995 Inspector:
L. T. Ricketson, P.E.,
Senior Radiation Specialist Facilities Inspection Programs Branch Approved:
rray, C
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,
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itches nspectson Programs Branch ate Ins ection Summar Areas Ins ected:
Routine, announced inspection of the licensee's implementation of the revised
CFR Part 20 and selected portions of the irradiation protection program implementation, including audits and appraisals, changes, and control of radioactive materials and contamination.
Results:
The training program properly addressed revised
CFR Part
implementation for the specific area covered during this inspection (Sections 1.1.1, 1.2.1, 1.3.1, and 1.4)
Procedures needed minor revisions and additions to implement all aspects of the
CFR Part 20 revisions (Sections 1. 1.2 and 1.2.2).
Implementation of the revised
CFR Part 20 was generally good (Sections 1. 1.3, 1.2.3, 1.3.3, and 1.4).
Radiation protection personnel were not aggress ve in their review of conditions in the radiological controlled area (Section 2.2).
9505i802i5 9505i0 PDR AOOCK 05000397 PDR
-2-Attachments:
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Attachment - Persons Contacted and Exit Meeting
DETAILS
IMPLEMENTATION OF THE REVISED 10 CFR PART 20 (TI 2515/123)
The inspector reviewed selected portions of the licensee's training and radiation protection programs using the guidance in Temporary Instruction 2525/123 to evaluate the licensee's radiological controls for implementing the revised
CFR Part 20.
The areas reviewed were programmatic controls with respect to high radiation areas, very high radiation areas, dose to the embryo/fetus, maintaining total effective dose equivalent as low as is reasonably achievable while working in airborne radioactivity areas, and planned special exposures.
'. 1 Hi h and Ver Hi h Radiation Areas 1.1.1 Training The inspector interviewed training representatives and reviewed training handouts and lesson plans and determined the following:
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In Radiation Worker Training, terms were defined, and posting and controls were discussed.
Worker responsibilities and consequences of procedure violations were included.
Areas with radiation levels greater than 1000 millirems per hour were defined as high high radiation areas.
Examples of very high radiation areas were included.
~
Radiation Protection Technician Continuing Training included discussion of 10 CFR Part 20 revisions and industry events related to high radiation area problems.
Additionally, the inspector determined that licensed reactor operators were provided training with respect to operations which could change radiological conditions within the plant and which may result in the creation of high radiation areas.
1.1.2 Procedures The inspector compared the licensee's implementing procedures for control of access to high radiation areas (in accordance with 10 CFR 20,1601)
and control of access to very high radiation areas (in accordance with 10 CFR 1602) with the guidance contained in Regulatory Guide 8.38.
Other procedures with related guidance included:
PPM 1.7. 1,
"Access Key Control," Revision
PPM 1. 11.8,
"Radiation Work Permit," Revision
PPM 11.2.2.5,
"ALARA Job Planning and Reviews," Revision
PPM 11.2.24. 1, "Health Physics Work Routines,"
Revision
The procedures provided guidance as discussed in Section 1.2 of Regulatory Guide 8.38 'owever, Section 1.2.5 of Regulatory Guide 8.38 states,
"Procedures should be provided to verify, at least on a weekly basis, that proper controls such as posting and barriers are in place for restricting access to high and very high radiation areas."
PPN 11.2.24.
1 included the checking of high high and very high radiation area.locked door s as a task to be performed monthly.
The licensee was not committed to implementing the provisions of Regulatory Guide 8.38, but representatives stated that they would review their practice and determine if an increase in frequency of surveillances of such -areas, to make them as rigorous as those discussed in regulatory guidance, was warranted.
1. 1.3 Implementation The inspector reviewed Problem Evaluation Requests generated as results of licensee-identified problems related to high and very high radiation areas.
The problems were diverse and indicated no particular adverse trend.
The inspector determined that corrective actions were appropriate.
The inspector toured the radiological controlled area and reviewed the control and posting of high and very high radiation areas.
No problems were identified.
The licensee identified and controlled two areas as potentially meeting the definition of very high radiation areas.
The areas were the drywell and the traversing incore probe room.
In general, the inspector noted the presence of many high radiation areas controlled through the use of radiation postings and rope barricades.
The radiation protection manager was unsure of the number of high radiation areas controlled in this manner, but he stated the reason this was necessary was because of the design and construction of the facility.
Components that are often in lockable rooms or cubicles at other sites were in open areas at the licensee's facility.
There were two areas in which radiation levels exceeded 1000 millirems per hour that were controlled by the use of rope barricades and flashing lights.
The areas surrounded the reactor water cleanup system precoat tank located on the 467-foot level of the radwaste building, and an instrument panel (P004)
located on the 522-foot level of the reactor building.
The areas had been controlled in this manner for, at least, 3 months and 7 years, respectively.
Technical Specification 6. 12.2 includes requirements for areas with radiation levels greater than 1000 mi llirems per hour.
It allows the use of barricades, posting, and flashing lights within large areas such as containment where no enclosure exists for the purposes of locking, and no enclosure can be reasonably constructed around the individual areas.
The inspector noted no obvious reason why enclosures could not be constructed around the areas and discussed the matter with licensee representatives.
Licensee representatives evaluated the situation and stated that their policy will be that high high radiation areas will be eliminated or shielded to reduce the radiation field to less than 1000 mr/hr.
Problem Evaluation Request No. 295-289 was initiated to address the two existing high high radiation areas that were controlled by the use of flashing lights and a barricade.
The resolution of the problem
evaluation request will define the actions the station will take to eliminate these areas.
The inspector also reviewed the licensee's key control program for high and very high radiation areas.
Keys for high high radiation areas and very high radiation areas were locked in separate cabinets.
The keys to the cabinets were maintained by the duty health physics supervisor.
Keys were issued only to radiation protection personnel, and records were maintained of key issue.
The inspector reviewed key issue logs and determined that the records properly indicated date and time of issue and return.
PPM 11.2.7.3, Section 5.3.9, stated that access to very high radiation areas shall be approved by the radiation protection manager.
The inspector noted examples of entries in the Health Physics Log that indicated a person other than the radiation protection manager authorized access.
In other examples, the Health Physics Log did not include the name of the individual authorizing entry into very high radiation areas.
The radiation protection manager stated that the other individuals had been designated by him to act in his absence.
The radiation protection manager added that PPM 11.'.7.3 would be revised to reflect that access would be approved by the radiation protection manager or designee and to provide guidance indicating that the individual's name would be required as part of the Health Physics Log entry.
1.2 Declared Pre nant Women and Embr o Fetus Doses 1.2.1 Training The effects of prenatal exposure were discussed in Protected Area Access Training.
The option to declare a pregnancy and the accompanying lower radiation exposure limits were also discussed.
These topics were repeated in Radiation Worker Training.
In all training material, it was emphasized that the declaration of pregnancy was voluntary.
1.2.2 Procedures The inspector reviewed PPM 1. 11. 19, "Monitoring of Declared Pregnant Women and Authorized Minors," Revision 0, and Health Physics Instruction (HPI) 5.9,
"Evaluation of In-Vivo Bioassay Results Following Exposure Incident with Indication of Potential Intake," Revision 6, and noted that the procedure did not include guidance on the method to be used by the licensee to determine the exposure to the embryo/fetus as a result of internal exposure.
After confirming with licensee personnel that such guidance was not included in other procedures, the inspector determined that the licensee had not had a
need to perform internal exposure calculations on an embryo/fetus.
However, radiation protection representatives stated that the guidance in Regulatory Guide 8.36 would be used, and the radiation protection manager stated that a
contract specialist would probably be employed to confirm such calculations.
PPM 1. 11. 19 did not include guidance to implement the requirements of
CFR 20.2106(e),
which requires that the licensee maintain the records of dose to an embryo/fetus with the records of dose to the declared pregnant woman.
PPM 1. 11. 19 required that the declaration of pregnancy be kept in the
individual's dosimetry file.
Section V of Attachment 9. 1 to PPH 1. 11. 19 included a space for the recording of external and internal dose to the embryo/fetus; however, there was no guidance in the procedures instructing dosimetry personnel to use this portion of the attachment to record exposures.
PPH 1. 11. 19 included the responsibilities for both the radiation protection manager and the health physics manager.
The inspector determined that the position of health physics manager had been discontinued by the licensee.
" Licensee representatives indicated that PPH 1. 11. 19 would be revised to provide additional guidance and eliminate outdated terms.
1.2.3 Implementation Two women had elected to sign declarations of pregnancy.
One terminated employment before giving birth.
Neither were available for interview.
The inspector reviewed records and determined that copies of declarations were maintained.
1 '
Total Effective Dose E uivalent ALARA and Res irator Protection 1.3.1 Training The inspector reviewed lesson plans and noted that Radiation Worker Training discussed the concept of total effective dose equivalent and included examples demonstrating that, at times, not wearing a respirator resulted in a lower total dose.
Respiratory Protection Training also included a discussion of the Total Effective Dose Equivalent concept and the possible disadvantages of wearing respirators.
1.3.2 Procedures The inspector reviewed PPH 11.2.2. 11,
"Exposure Evaluations for Haintaining TEDE ALARA," Revision 1,
and determined that it provided radiation protection technicians with sufficient guidance to enable them to determine when the use of respiratory protection equipment was beneficial in maintaining total exposures low.
The procedure called for the use of a 20 percent loss in worker efficiency because of the use of respiratory protection equipment.
1.3.3 Implementation Licensee's representatives stated that no full-face, negative pressure respirators were issued during the 1994 refueling outage for the purpose of radiological protection.
Such respirators were issued for industrial safety reasons, and supplied-air respirators were sometimes issued for worker comfort when the respirator evaluation determined that it was beneficial or had no effect on the total effective dose expected.
During the 1993 refueling outage, prior to the implementation of the revised
CFR Part
requirements, approximately 5200 respirators were issued.
Radiation protection representatives stated that most of the respirators were issued because contamination levels exceeded action levels in use at the time, not
because of high airborne concentrations.
The licensee noted an increase in facial contamination events but no increase in internal dose.
The inspector reviewed examples of respirator evaluations and identified no problems.
1.4 Planned S ecial Ex osures Planned special exposures are discussed and the term is defined in Radiation Worker Training.
PPH 1. 11. 17,
"Planned Special Exposures,"
Revision 0, addressed all the requirements of 10 CFR 20. 1206.
Licensee representatives stated that no planned special exposures had been conducted and that they did not anticipate the use of such exposures.
~ 5 Conclusions The training program properly addressed all reviewed areas of the revised
CFR Part 20 implementation.
Procedures needed minor revisions and additions to implement all aspects of the
CFR Part 20 revisions.
Implementation of the revised
CFR Part 20 was generally good.
OCCUPATION RADIATION EXPOSURE CONTROL (83750)
The licensee's program was inspected to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapter 12 of the Final Safety Analysis Report.
2. 1 Audits and A
raisals The inspector asked to review audits or self-assessments performed by the licensee to ensure readiness to implement the revised
CFR Part
requirements.
Licensee's representatives stated that no documented review was performed.
However, they added that a consultant was retained to oversee the program revisions and quality assurance personnel were included in the procedure review process.
NRC Inspection 50-397/93-49 performed December 1-3, 1993, concluded that the licensee was ready to implement the new requirements.
2.2
~Chan es Since the previous inspection of this area, the radiation protection manager assumed responsibility for certain maintenance and coatings personnel.
Radioactive Material Control and Coatings sections were added to the radiation protection organization.
Included in the additional responsibilities were decontamination, material movement, and material issue.
The number of authorized positions within the organization rose from 79 to 141.
The radiation protection manager expressed the opinion that this change will enable the organization to better handle material control issues.
t
2.3 Control of Radioactive Materials and Contamination Ouring a tour of the radiological controlled area with licensee's personnel on April ll, 1995, the inspector noted water on the step off-pad in front of the reactor water clean up precoat tank.
The water leaked from overhead piping and licensee's personnel initiated a work request to address the problem.
Licensee's personnel determined that the water was not contaminated.
Ouring a
tour of the same area the following day, the inspector again noted water in the same area.
Water was also noted on the floor of Reactor Feed Pump A room.
Licensee's personnel determined that this water, too, was not contaminated.
However, the inspector concluded that radiation protection personnel were not proactive in dealing with potential contamination control problems.
In NRC Inspection Report 50-397/95-04, the inspector reported observing the storage of vacuum cleaners containing radioactive material in Room C225 of the radwaste building.
Radiation levels were measured by the inspector and found to be 25 to 40 millirems per hour at 30 centimeters.
Licensee's representatives acknowledged that this area was not the final staging area for the vacuum cleaners and indicated that the situation would be addressed.
During this inspection, the inspector observed what appeared to be the same vacuum cleaners being stored in the same location.
The inspector verified that a survey record was available to document the radiation 'levels in the area.
Licensee"s personnel again stated that storage of the vacuum cleaners in this manner did not conform to their expectations and that the situation would be addressed.
The inspector noted several examples of minor housekeeping problems in the radiological controlled area and some indications of poor contamination control practice, such as leaving hardhats and face shields for possible reuse in contaminated areas.
2.3 Conclusions Because the material control observations were made by the inspector instead of licensee's personnel, the inspector concluded that radiation protection personnel were not aggressive in their review of conditions in the radiological controlled are ATTACHMENT
PERSONS CONTACTED 1. I Licensee Personnel
- J.
P. Albers, Radiation Protection Manager W. H. Barley, Corporate Radiological Health Officer
- D. L. Dinger, Health Physics Operations Supervisor
- T. I. King, Radioactive Materials Control Supervisor
- K. B. Lewis, Technical Specialist, Compliance
- C. McDonald, Manager, Health Physics, Chemistry, and General Employee Training
- J. J.
Muth, Manager, equality Support
- L. M. Nolan, Solid Waste Supervisor
- J. V. Parrish, Vice President of Nuclear Operations
- R. F. Patch, Health Physics Technical Services Supervisor
- W. F. Rigby, Health Physics Planning/ALARA Supervisor
- D. Swank, Manager Compliance
- V. E. Shockley, Assistant to Radiation Protection Manager
- J.
C. Wiles, Health Physics Craft Supervisor (Acting)
1.2 NRC Personnel
- R. Barr, Senior Resident Inspector D. Prouix, Resident Inspector
- Denotes personnel that attended the exit meeting.
In addition to the personnel listed, the inspector contacted other personnel during this inspection period.
EXIT MEETING An exit meeting was conducted on April 13, 1995, During this meeting, the inspector reviewed the scope and findings of the report.
The licensee did not express a position on the inspection findings documented in this report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector.