IR 05000397/1995016
| ML17291A859 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/12/1995 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17291A858 | List: |
| References | |
| 50-397-95-16, NUDOCS 9506200247 | |
| Download: ML17291A859 (18) | |
Text
ENCLOSURE U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-397/95-16 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 (WNP-2)
Inspection At:
Richland, Washington Inspection Conducted:
May 22-25, 1995 Inspectors:
Blaine Murray, Chief Facilities Inspection Programs Branch Michael P.
Shannon, Radiation Specialist Facilities Inspection Programs Branch Approved:
o
. Scarano, Deputy Director Division of Radiation Safety
& Safeguards Areas Ins ected:
Routine, announced inspection of the licensee's radiation protection program during the 1995 refueling outage which included the following activities:
audits and appraisals; planning and preparation; training and qualifications; external exposure control; internal exposure control; control of radioactive materials and contamination, surveys, and monitoring; maintaining radiation exposures as low as is reasonably achievable (ALARA); and facility tours.
Results:
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An effective self-assessment program was in place.
The use of well qualified audit personnel was a program strength (Section 2. 1).
~
An improving trend was noted in ALARA outage planning (Section 2.2).
9506200247 9506l3 PDR ADOCK 050003'P7
The training and qualification program for contractor health physics technicians was very good.
The health physics training.staff's knowledge and experience level were program strengths (Section 2.3).
~
An apparent violation was identified involving the failure to provide continuous health physics coverage for work in a high radiation area (Section 2.4.4).
~
An apparent violation was identified involving the failure to provide proper instructions to workers (Section 2.4.5).
Several problems were identified with the specific radiation work permit program (Section 2.4.6).
~
A noncited violation was identified involving workers entering the radiologically controlled area without proper dosimetry (Section 2.4.7).
Internal exposure controls were effectively maintained (Section 2.5).
Radioactive material and contamination controls were effectively maintained (Section 2.6).
~
The shielding and source term program was effectively implemented.
The Senior Site ALARA Committee needs improved support by station management (Section 2.7).
~
Radiological postings and controls were properly maintained to inform workers of radiological hazards.
Radiological housekeeping was well maintained (Section 2.8).
Summar of Ins ection Findin s:
Apparent violation 397/9516-01 was opened (Section 2.4.4).
Apparent violation 397/9516-02 was opened (Section 2.4.5).
A noncited violation was identified (Section 2.4.7).
Attachments; Attachment
Persons Contacted and Exit Meeting Attachment 2 - Enforcement Conference Agenda
(~r
-3-DETAILS
PLANT STATUS During the inspection, the plant was conducting its tenth scheduled refueling outage (denoted as R10).
OCCUPATIONAL EXPOSURE DURING EXTENDED OUTAGES (83729)
The licensee's program was inspected to determine compliance with Technical Specifications and
CFR Part 20.
2. 1 Self-Assessment Audits Surveillance and A
raisals The inspectors reviewed the licensee's self-assessment program to determine oversight of radiation protection activities.
Particular attention was devoted to licensee's self-assessment activities that probe for programmatic weaknesses and assess the quality of the radiation protection program.
The quality of the responses to self-assessment findings were also reviewed.
The inspectors reviewed the following 9 surveillance reports issued by the guality Assurance Department that involved outage radiation protection activities:
Surveillance Report 294-037,
"R-9 Health Physics Program Compliance,"
dated 7/13/94 Surveillance Report 294-039,
"ALARA Awareness,"
dated 5/11/94 Surveillance Report 294-042,
"Wetwell Desludging," dated 9/12/94 Surveillance Report 294-049,
"Transportation/Training,"
dated 7/26/94 Surveillance Report 294-055,
"Emergent Issues Assessment,"
dated 9/23/94 Surveillance Report 294-068,
"Health Physics Free-Release Policy and Practices,"
dated 12/7/94 Surveillance Report 295-005,
"ALARA Interface In Design Modifications and Source Term Reduction Program," dated 2/16/95 Surveillance Report 295-006,
"Nanagement Support of ALARA Activities,"
dated 1/24/95 Surveillance Report 295-007,
"ALARA Program Observations,"
dated 1/27/95 The inspectors noted that appropriate reference and guidance documents were included as part of the various surveillance reports.
The inspectors interviewed the two quality assurance personnel that performed the above surveillances.
Both individuals had worked as radiation protection technicians and, as a result, had strong technical expertise in the radiation protection are The surveillance findings identified several significant issues for program improvements'he quality assurance personnel stated that, in the past, radiation protection management was reluctant to accept and initiate proper corrective actions for problems identified during surveillance; however, the new management organization was receptive to discuss potential problem areas and implemented prompt corrective actions for identified weaknesses.
guality assurance personnel stated that the overall performance in the radiation protection department had improved during the past 2 years.
Conclusion An effective self-assessment program was in place.
The use of well qualified technical experts for both audits and surveillances was considered a program strength.
2.2 Plannin and Pre aration The inspectors held discussions with licensee's upper management; representatives in the radiation protection, maintenance, operations, and outage departments; and contract radiation protection personnel to review planning and preparation activities for the refueling outage.
2.2. 1 Outage ALARA planning The inspectors conducted interviews with the ALARA planners responsible for radiological work in the drywell, the refueling floor, radiological shielding, and the reactor building and balance of the plant.
These individuals were responsible to estimate total exposures, set exposure goals, review procedures/work packages, apply lessons learn from previous similar work, and capture both positive and negative occurrences for radiological work in their assigned areas.
The inspectors determined that the exposure goal set by the area ALARA planners for major evolutions was normally taken at face value and not challenged by the licensee's ALARA management or reviewed by the station ALARA committee as long as estimated exposure fit within the station ALARA goal estimate.
In addition, the inspectors determined that although the area ALARA planners perform post-job reviews of major evolutions to capture lessons learned, these reviews were extrapolated from their logs and did not always include all the major participants involved in the task.
For example, a
stripable coating (paint)
was applied to the reactor cavity wall to aid in the radiological decontamination by a contract vendor.
However, vendor personnel were not interviewed to capture lessons learned prior to leaving site.
Through discussions with licensee's personnel and review of licensee's documentation, the inspectors determined that the radiation protection department was more involved in up-front planning, and working closer with the station planning group than in the past.
The people assigned to the area ALARA planner positions were experienced plant personnel from the health physics organization.
An improving trend was noted, although this improving trend seemed to be because of the people involved rather then the system itsel.2.2 Outage Radiological Controls Organization As a result of discussions held with licensee's upper management; representatives in the radiation protection, maintenance, operations, and outage departments; the inspectors determined that the licensee provided adequate staff, equipment, and protective clothing to support work activities during the outage.
General comments were that there was a much improved working relationship among all station work groups and radiation protection than in the past and that the radiation protection organization had the best interests of worker safety in mind.
The permanent radiation protection staff was supplemented with contract personnel which included 8 ALARA engineers, 61 senior health physics technicians, and 19 junior health physics technicians.
During the refueling outage, health physics support functions were staffed for continuous outage support.
The outage health physics organization was properly staffed to support the outage workload.
Conclusion The health physics organization was more involved in outage ALARA planning than in the past.
The people assigned as area ALARA planners were experienced health physics personnel.
In general, an improving trend was noted in outage ALARA planning.
2.3 Trainin and ualifications of Personnel The inspectors reviewed the training and qualifications for contract radiation protection technicians and other personnel brought on site to support outage activities.
The inspectors interviewed health physics training department personnel, reviewed contractor health physics technician training lesson plans, resumes, and station procedures to determine whether contract health physics personnel were appropriately qualified to perform their assigned responsibilities.
The health physics training personnel were well experienced and qualified to perform their training function.
Training lesson plans were well organized, documented, and included lesson learned from both the industry and WNP-2.
The Northeast Utilities'ealth physics screening program, which was reviewed by the inspectors, was used to evaluate the general radiological knowledge of the contract health physics technicians brought on site to support outage activities.
This test was properly controlled to ensure that it was not compromised and had a sufficient bank of appropriate questions needed to establish a technician's basic health physics knowledge.
The Northeast Utilities program is recognized and approved by a number of utilities as an acceptable method to evaluate health physics technician's general radiological knowledge.
The inspectors reviewed several contractor senior health physics technicians resumes.
All resumes reviewed met or exceeded the requirements of ANSI/ANS N18. 1-1971.
A large number of senior health physics technicians on site for the 1995 outage had previously worked at WNP-The inspectors noted that only a small number (5 percent)
of the licensee's health physics technicians were presently National Registry of Radiation Protection Technologists (NRRPT), certified.
When this was discussed with the licensee, it was brought to the inspectors'ttention that the licensee had developed an in-house voluntary training program to prepare personnel for the written examination.
Conclusion A very good training and qualification program was in place for contractor health physics technicians, The health physics training department training staff's knowledge and experience level were a program strength.
2.4 External Ex osure Control The inspectors reviewed the external exposure control program including:
the Radiation Work Permit program, personnel dosimetry, work practices and procedures, posting and labelling, exposure summary reports, and licensee supervisory oversight of radiological work activities.
Additionally, the inspectors conducted several tours of the radiologically controlled area to observe work in progress.
The inspectors conducted several independent radiation surveys within the radiologically controlled area and found that these areas had been appropriately established, posted, and controlled in accordance with regulatory requirements.
2.4. 1 Radiological Event During this inspection, the inspectors followed up on an event that happened on May 14, 1995, at approximately 5 a.m., involving the removal and transport of highly radioactive filters (80 rem/hr)
from the reactor water cleanup (RWCU) system skid located on the 471-foot elevation of the reactor building.
CFR 20. 1003 defines a high radiation area as
"an area, accessible to individuals, in which radiation levels could result in an individual receiving a dose equivalent in excess of 0. 1 rem (100 mrem) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters
.
from the radiation source."
The RWCU skid was a temporary system used to chemically remove radioactivity from the RWCU system.
The information gathered by the inspectors pertaining to this event was from a combination of interviews held on site with both licensee and contractor personnel involved directly with the work.
The inspectors also reviewed the radiation work permit, health physics logbook entries, and ALARA pre-job briefing; each of which was documented on the Total Exposure System which is the computerized entry system used at WNP-2.
Reviews of the licensee's health physics technician's (task coordinator)
logbook, health physics reactor building logbook, and radiological survey maps concerning this event were performed.
The inspectors also reviewed the Incident Review Board assessment of this event dated May 24, 1995.
The inspectors noted that there was no radiation protection department individuals assigned to this Incident Review Board.
2.4.2 Sequence of Events On May 13, 1995, at 12:53 p.m., Radiation Work Permit 95000076 02,
"RWCU System Chemical Decon,"
was revised to include ALARA Task:
TW98 01 05, ALARA
Desc:
Change Filter and Transport to radwaste.
Dosimetry requirements were also changed to include finger dosimetry as was the type of health physics coverage (continuous coverage was added).
In the special instructions and hold points section, the following additions were noted:
(1)
a health physics pre-job brief required prior to entry, (2) double rubber gloves and faceshield required for removal of filters, (3)
bag filters upon removal, (4) health physics escort required for transport of material
> or
= 100 mrem/HR at 12 inches, and (5) utilize shielded cart/container for filter transport.
The hold point"description was not revised.
The licensee stated that this task was originally planned to be accomplished on the day shift of May 13, 1995, but was postponed until the night shift of May 13-14, 1995.
A lead shielded 55-gallon barrel, which was placed on a hand pulled cart, was staged near the filter change out area during the afternoon of May 13, 1995.
At 3 a.m.
on the morning of May 14, 1995, a meeting was held to brief personnel involved with the filter change out and transport.
The briefing was given by the licensee's health physics technician (task coordinator)
and documented in the task coordinator's logbook.
It stated:
"Talked about how we were going to pull the filters, movement of the cart including getting it through the airlocks.
Everyone said it could be done."
The licensee's health physics technician informed the inspectors that the alarm set points on the electronic dosimetry were set at 1000 mrem dose rate and 100 mrem dose accumulated for all workers involved in the task, except for the contractor RWCU individual pulling the filters which was set at 3000 mrem dose rate and 300 mrem dose accumulated.
The licensee's health physics technician stated that the plans were for the contractor RWCU individual responsible for operating the chemical decontamination process to pull the filters, place them in a plastic bag, and then place the bag in the staged leaded drum.
The filter removal process involved the transfer of about 22 individual 3-inch diameter by 30-inch long filters from the RWCU system, place them in two bags, and then place the two bags in the shielded barrel.
Two licensee laborers along with a contractor senior health physics technician, escorting the laborers, would then transport the filters to the elevator in the reactor building to the 441-foot elevation, through the airlock to the 441-foot elevation of the radwaste building and then to a
temporary storage area on the 437-foot elevation of the radwaste building to wait final disposal.
The task started at approximately 5 a.m.
The filters were pulled according to plans, except that the electronic dosimeter worn by the contract RWCU worker and the licensee's health physics technician monitoring the task alarmed, due to dose rate alarm set point being exceeded.
It was noted by the inspectors that General Employee Training (GET) lesson plans state that if a workers electronic dosimeter alarms, leave the area and notify health physics.
However, at the direction of the licensee's health physics technician, the task continued.
Near the completion of the pulling of the filters, the contractor worker's electronic dosimeter alarmed, because it exceeded the dose accumulated alarm setpoint (300 mrem).
Procedure PPM 11.2.9.31,
"Operation of the MG DMC-100 Electronic Dosimeter,"
Revision 0, Section 5. 1. 1 states, in
part, a worker should immediately leave the work area and report to health physics when the accumulated dose alarm sounds.
Again at the.direction of the licensee's health physics technician, the task continued.
The task involved placing approximately 22 filters in two plastic bags, that due to the filter's length (30 inches)
and the absorbent material in the bottom of the 55-gallon barrel, did not fit in the barrel completely (the filters were about 6 inches above the lip of the barrel) which precluded a lid from being placed on top.
The unshielded, contact radiation levels on the two bags prior to being placed in the barrel were 50,000 mrem/hr on one bag and 80,000 mrem/hr on the other bag.
A lead blanket was placed on top of the filters to reduce the dose rate, The contractor health physics technician stated that the shielded barrel dose rates were 20,000 mrem/hr on contact and 10,000 mrem/hr general area (30 centimeter reading)
at time of transport.
After the filters were placed in the barrel, laborers with the contract health physics technician escort proceeded to transport the barrel.
The laborers and the contract health physics technician stated that their electronic dosimeters were in the dose rate alarm condition while they were transporting the barrel, except for the period of time the barrel/cart was on the elevator.
The laborers along with the contractor health physics technician met the elevator on the 441-foot elevation of the reactor building where they retrieved the barrel and cart and again their electronic dosimeters alarmed due to exceeding the dose rate alarm set point.
The laborers proceeded to move the barrel through the airlock with the help of the contractor health physics technician who held the inner door of the airlock open.
This allowed the laborers to control the cart as it was pushed over the inner lip (about 4 inches high) of the airlock door.
The contractor health physics technician stated there was not enough room in the airlock fo; all three individuals and the cart.
The contractor health physics technician stated that he shut the inner airlock door and remained outside the airlock in the reactor building, The airlock door system does not allow both doors to be opened at the same time without being mechanically defeated.
At this point, continuous health physics coverage was not provided for the job.
In an attempt to get the cart through the airlock, the laborers stated that one of them decided to hold the outer door of the airlock open while the other laborer would make a running start (approximately 2 I/2 feet) to get the barrel and the cart over the outer airlock door lip (also about 4 inches high).
As the laborer pushed the cart towards the outer airlock door, the cart stopped when the wheels hit the 4-inch inner lip of the airlock and the barrel containing the two bags of highly radioactive (80 rem/hr) filters tipped over.
When the barrel tipped over, the lead shielding blanket was displaced.
This caused the unshielded filters to partially fall out (about 2 feet) of the barrel, blocking the outer airlock door open.
Since the contract health physics technician was locked outside of the airlock, no health physics'overage was present when the barrel tipped over.
The laborers left the airlock area and called the control room for assistance.
The contractor health physics technician while waiting for the outer airlock door to close heard an announcement over the public address system from the control room "man down at the airlock."
Believing something wrong, the contractor health physics technician stated that he left his position outside
the locked inner airlock door and proceeded to the radwaste building through another airlock and responded to the event.
2.4.3 Inspectors'eview The inspectors reviewed the Radiological Surveys 5-1138-95 and 5-1148-95 dated May 13, 1995, which were performed at 2:20 a.m.
and 3:30 p.m. of the work area and noted that the dose rate readings on the outside of the lead on the RWCU skid filter housing read 13,000 mrem/hr on contact, 2,800 mrem/hr general area, 10,000 mrem/hr on contact, and 1,600 mrem/hr general area (respectively).
The inspectors also reviewed the radiation work permit used for this task and noted that the radiological conditions noted earlier by the licensee (Survey Nos.
5-1138-95 and 5-1148-95)
were not on the radiation work permit.
General radiation levels on the radiation work permit were noted as20-500 mrem/hr which were last updated by the licensee on May 13, 1995.
The inspectors were unable to determine from what radiological survey these general radiation levels were taken, except to note that every radiation work permit written (either before or after this event) with the radiation work permit, Title:
"RWCU System Chemical Decon," reflected the same radiological conditions.
The inspectors also reviewed the ALARA pre-job briefing and health physics logbook entries associated with this radiation work permit which was documented in the Total Exposure System.
The inspectors found no evidence that the radiation work permit, ALARA pre-job briefing, health physics logbook entries or task coordinator's logbook included instructions to workers involving:
(1) the actual radiation levels in the work area, (2) that the electronic dosimeter alarms were likely to be in the alarmed condition and what actions to take, (3) the missing ramps in the airlock, (4) what actions or precautions should be taken in the event of a mishap, or (5) reinforcement that continuous health physics coverage was required.
The inspectors determined from a review of exposure records that the maximum exposure received by any worker was 410 mRem and that 1.455 person-rem was expended during this task.
During the interview with the laborers, the inspectors noted that they expressed concern regarding their alarming dosimetry and were in a hurry to complete the task.
The inspectors determined that the contractor health physics technician involved in the task was not interviewed by the licensee during their investigation.
The inspectors also noted, through discussions held with the radiation protection manager, that the radiation protection manager was not aware that the contractor health physics technician escorting the laborers was outside of the airlock when the barrel tipped over until informed by the inspector The inspectors also reviewed the following plant procedures:
~
PPM 1. 11.2, Revision 8,
"ALARA Program Description"
~
PPM 1.11.8, Revision 7, "Radiation Work Permit" PPM 1. 11.22, Revision 3,
"Use of the Total Exposure System (TES) for Access Control" PPM 11.2.2.5, Revision 3,
"ALARA Job Planning and Review" 2.4.4 Continuous Health Physics Coverage Technical Specification 6. 12 states, in part, that:
"Any individual or group of individuals permitted to enter a high radiation area shall be provided with or accompanied by one or more of the following:"
a.
A radiation monitoring device which continuously indicates the radiation dose rate in the area.
b.
C.
A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received.
Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them.
A health physics qualified individual with a radiation dose rate monitoring device who is responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the health physicist in the radiation work permit.
Based on interviews with licensee and contractor personnel, the inspectors determined that:
(1) the laborers in the airlock area were not provided a
radiation monitoring device which continuously indicates the radiation dose, (2) the dose rates in the airlock area after the barrel tipped over were not known, and (3) continuous health physics coverage was not provided.
The failure to provide continuous health physics coverage is an apparent violation of Technical Specification 6. 12 (397/9516-01).
The inspectors determined that the two laborers involved with the event were experienced radiation workers that had been employed at WNP-2 for several years.
These particular laborers made the decision to leave the airlock area when the barrel tipped over; however, the same decision may not have been made by other less experienced laborers.
In a similar situation without health physics coverage, other laborers may have believed that the most important, course of action would be to up-right the barrel and place the spilled filters in the barrel.
Even though this event did not result in any exposures in excess of the applicable limits, work activities with radiation levels of
-11-80 rem/hr without continuous health physcis coverage involved a substantial potential for an overexposure to occur within a few minutes.
2.4.5 Instructions to Workers Technical Specification 6.8.1.k.
states, in part, that written procedures shall be established, implemented, and maintained covering the activities of the Health Physics Program.
Licensee's Procedure PPH 1. 11.8, Revision 7,
"Radiation Work Permit," Section 3. 1 states, in part, that:
"The process for initiating and preparing radiation work permits ensures that jobs are adequately planned and reviewed for ALARA considerations; and that the radiological conditions are evaluated to establish appropriate radiation protection requirements and measures.
The radiation work permit serves as the mechanism for ensuring that personnel are adequately informed of, and protected against the radiological hazards in the work area."
Section 5.5. 1 states, in part, that:
"An RWP issued for entries into High Radiation Areas shall specify the dose rates in the immediate work area
.
Section 6.2.1.e.
states, in part, that:
"Enter RWP Title, which should adequately describe the job or task to be performed."
Section 6.2. l.q.
states, in part, that:
"Record requirements for an health physics Pre-job briefing and additional radiation requirements, instructions, precautions, or information, including ALARA recommendations, if any, in the Special Instructions Sections of the RWP."
The inspectors determined that the actual radiological conditions in the area prior to the task being started were not included on the radiation work permit, Additional radiological requirements, instructions or precautions such as the securing of the barrel to the cart and the expected dose rate from the filters were not identified on the radiation work permit.
Licensee Procedure PPH 11.2.2.5, Revision 3,
"ALARA Job Planning and Reviews,"
Section 6.3. 1 states, in part, that:
"ALARA prejob briefings are performed to ensure workers understand the radiological conditions, radiation work permit requirements, and work instructions associated with specific tasks and evolutions when:
"The potential exists for sudden changes in radiological conditions."
Section 6.3.3, states, in part, that:
"If an ALARA prejob briefing is required, record prejob briefing discussions topics in health physics logbook text within TES or manually on a Prejob Briefing Record."
The inspectors determined that a documented ALARA prejob briefing in the Total Exposure System was not performed pertaining to the changing and transport of the RWCU filters.
Additionally, a walkdown of the travel route was not performed by the individuals assigned the task of transporting the barrel to identify potential problem areas that might be encountered.
In addition,
CFR 19. 12 requires, in part, that:
"All individuals working in or frequenting any portion of a restricted area
.
.
. shall be instructed in the appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation."
The failure to provided instruction to workers and adhere to Procedures PPN 1. 11.8 and PPN 11.2.2.5 is an apparent violation of Technical Specification 6.8. l.k (397/9516-02).
-12-2.4.6 Radiation Work Permit Program The inspectors determined that the radiation work permit system was difficult to understand and not designed for effective control of radiological work activities.
Licensee's radiation protection management stated in discussion with the inspectors that the radiation work permit system was more of a maintenance work system than a radiation work permit system.
The inspectors noted that specific radiation work permits were not being written as stated in Station Procedure PPH 1. 11.8, Revision 7, "Radiation Work Permit."
Section 5.5. 1 states, in part, that:
"An RWP issued for entries into High Radiation Areas shall specify the dose rates in the immediate work area
.
.
.."
Section 6.2. l.e. states, in part, that:
"RWP Title",
should adequately describe the job or task to be performed."
Section 6.2. l.q states, in part, that:
"Record requirements for an health physics Pre-job briefing and additional radiation requirements, instructions, precautions, or information, including ALARA recommendations, if any, in the Special Instructions Sections of the RWP."
2.4.7 Electronic Dosimeters The inspectors followed up on 14 events where individuals entered the radiological controlled area during this refueling outage with a direct reading dosimeter turned off or without a direct reading dosimeter.
In all cases individuals had a primary dosimetry thermoluminescent device (TLD).
An Incident Review Board Report was generated by the licensee to evaluate Problem Evaluation Request 295-0600.
This Problem Evaluation Request involved the one event that violated Technical Specification 6. 12. 1.
The event involved a
contractor laborer foreman that entered a high radiation area without his Electronic Dosimeter turned on.
The inspectors reviewed the other 13 events that did not involve an entry into a high radiation area and found them in violation of Procedure PPM 1. 11.8, Revision 7, Section 6.2. 1.1 which states, in part, that:
"The minimum dosimetry required (on RWP) is a
thermoluminescent dosimeter and a direct reading dosimeter,"
The inspectors reviewed the licensee's corrective actions regarding the events and found the corrective actions to be satisfactory to prevent a similar occurrence.
All 14 of these events were licensee identified and the event which violated Technical Specification 6. 12. 1 was an isolated event.
Thus, this violation will not be subject to enforcement action because the licensee's efforts in identifying and correcting the violation meet the criteria specified in Section VII.B.2 of Appendix C to
CFR Part 2.
Conclusions Two apparent violations were identified for the failure to provide continuous health physics coverage and instructions to workers.
A noncited violation was identified involving the use of electronic dosimeters.
Several problems were identified with the Specific Radiation Work Permit progra.5 Internal Ex osure Controls The inspectors reviewed the internal exposure control program including:
use of respiratory protection equipment, whole-body counting program, air sampling, and the calculation of committed doses from airborne intakes.
During tours of the radiological controlled areas, the inspectors observed air sampling equipment in the work place.
In addition to job specific air samplers, the licensee also has appropriately positioned, continuous air monitorers throughout the radiological controlled area.
All air sampling equipment in the work place had current calibration dates.
No respirators had been issued for protection against airborne radioactive materials for outage related work at the time of this inspection.
The licensee's whole-body counting program indicated that largest uptake of radioactive material by a
worker during this outage resulted in a committed dose equivalent of 6 mrem.
Conclusion Internal exposure controls were effectively maintained and implemented.
2.6 Control of Radioactive Materials Contamination Surve s
and Monitorin The inspectors reviewed the inventory of portable surveys instruments, portal monitors and friskers, skin contamination events, dissemination of survey data, records of survey results, control of contaminated trash, and the release of potentially contaminated materials.
The licensee provided good controls to prevent the spread of radioactive contamination.
Contaminated areas were well posted and marked with tape or rope.
Step-off pads were placed at the entries/exits to these areas to alert workers of the change from a contaminated area to a cleaner area.
A sufficient inventory of protective clothing was available for work in contaminated areas.
Personnel monitors were used to detect radiological contamination or potential intakes when workers exited the radiologically controlled area.
The frisking and monitoring equipment was calibrated and had current calibration stickers.
Receptacles provided for the collection of potentially contaminated protective clothing were periodically emptied and the undressing areas were neatly kept to prevent inadvertent spread of contamination.
Conclusion Radioactive material and contamination controls were effectively maintained during outage activities.
2.7 Maintainin Occu ational Ex osure The inspectors reviewed the licensee's awareness and involvement, ALARA goals activities, and ALARA results.
ALARA ALARA program including:
worker and objectives, ALARA Committee
During plant tours, the inspectors noted the aggressive permanent shielding program the licensee had put in place to reduce general radiation level throughout the drywell and reactor building.
Additionally, the licensee had purchased portable see-through water shields with a work station mounted in place for high radiation area work that needs to be monitored.
This type of shield was good initiative to maintain occupational exposure ALARA.
The licensee had initiated a program to flush systems of radioactive material, such as the chemical decontamination of the RWCU system.
Although, the inspectors noted that chemical decontamination of radiological systems was coordinated by the corporate staff and not the ALARA supervisor.
The licensee's work planning process had improved.
Health physics personnel were more involved in the up-front planning of outage related high exposure jobs than in the past.
Although, from interviews held by the inspectors with licensee's ALARA planning personnel, a number of outage related work packages were still given to them with little time to properly plan the work.
Failure to involve ALARA personnel at the early stage did not allow for the proper planning needed to incorporate exposure saving techniques in the work instructions without causing delays resulting from revisions to work packages.
The inspectors noted that outage collective dose trending was updated daily and listed by organization, depicting daily exposure, exposure to date, department goal, and percentage of goal used.
Additionally, the station published a daily plant news information sheet highlighting the previous days outage events, which included a station summary of total radiation exposure accumulated during the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, exposure to date, outage exposure goal and percent of goal used.
The inspectors reviewed minutes of the Senior Site ALARA Committee meetings held during the last 10 months and noted that the station held five meetings.
The inspectors also noted that of the five meetings held, the plant manager, who also serves as the chairman, and the corporate radiological health officer were in attendance at only one of these meetings.
Additionally, the radiation protection manager was in attendance only twice.
Both the corporate radiological health officer and the radiation protection manager are designated as serving on the Senior Site ALARA Committee according to Procedure PPH 1. 11.2,
"ALARA Program Description."
Noted by the inspectors was that both the October
and November 17, 1994, Senior Site ALARA Committee meeting minutes were not written and distributed until April 10, 1995.
The licensee informed the inspectors that a change placing the corporate radiological health officer as chairman of the Senior Site ALARA Committee was being considere The following chart shows total exposure for 1990 1994:
,",'-",:'."j','3:::::::::,!.:,:,'":,m'.;;":~Y.EAR.:g"~<:,,i",-:.:.~".::;:h1990:
'::;1993:::
- .::: " i:-':4 !.":1:995';
.:19.9:O': ".GOAl';;
LICENSEE RESULTS 536 390 612 469 866 495 NATIONALBWR AVERAGE 433 314 360 330
~ Not yet available The licensee's outage goal for 1995 is 380 person-rems, exposure to date at the end of the inspection was 251 person-rems, which is 66 percent of their goal, with 10 scheduled outage days remaining.
Licensee's representatives stated they expected to meet their goal.
Conclusion The shielding and source term program was effectively implemented.
Daily outage exposure summaries were provided to workers.
The Senior Site ALARA Committee needs the improved support of management.
~Pili T
The inspectors noted that the licensee used a computerized radiation work permit entry system to access the radiologically controlled area.
Tours of the licensee's facilities were conducted by the inspectors.
Areas toured included the radwaste building, reactor building, drywell, and turbine building.
Tours of these areas indicated that overall, the radiological postings were adequate to inform workers of any radiological hazards.
Although, the inspectors pointed out some posting enhancements were needed on the 512-foot elevation of the drywell.
The licensee responded in a timely manner to the posting enhancements.
The inspectors performed independent confirmatory radiation surveys and the results were in agreement with the licensee.
The inspectors noted that the licensee maintained a strong radiological housekeeping program.
All areas toured were free of trash or overflowing barrels.
Conclusion Radiological postings were adequate to inform workers of radiological hazards.
Good radiological housekeeping was maintaine ATTACHMENT I I
PERSONS CONTACTED 1.1 Licensee Personnel
- P. Bemis, Director Regulatory and Industrial Affairs V. Parrish, Vice President Nuclear Operations
- J. Albers, Radiation Protection Manager
- J. Arbuckle, Technical Specialist
- W. Barley, Corporate Radiological Health Officer J.
Benevides, Station Laborer B. Case, Senior Health Physics Technician (contractor)
- J. Cooke, Health Physics Trainer
- D. Dinger, Health Physics Operations Supervisor C. Hemphill, Health Physics Trainer
- R. James, ALARA Planner
- T. King, Radioactive Material Control Supervisor S.
Lampi, Senior Health Physics Technician
- C. Madden, gualtiy Assurance Engineer C. McDonald, Manager General Employee Training/Health Physics Training
- J. Muth, Manager guality Support
- R. Patch, Health Physics Technical Support Supervisor L. Pritchard, ALARA Planner
- R. Reed, Health Physics Technician
- W. Rigby, ALARA Supervisor
- V. Shockley, Assistant to the Radiation Protection Manager
- K. Spero, Radwaste Staff Specialist
- J. Swailes, Plant General Manager
- D. Swank, Manager Licensing
- F. Vargas, Health Physics Technician
- C. Vosler, Health Physics Technician
- J. Wilies, guality Assurance Engineer P. Williamson, Station Laborer 1.2 NRC Personnel
- R. Barr, Senior Resident Inspector
- Denotes personnel that attended the exit meeting
EXIT MEETING An exit meeting was conducted on May 25, 1995.
During this meeting, the inspectors reviewed the scope and findings of the report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector ATTACHMENT 2 ENFORCEMENT CONFERENCE AGENDA WASHINGTON PUBLIC POWER SUPPLY SYSTEM WASHINGTON NUCLEAR PROJECT-2
REGION IV
June 28, 1995 - 8:30 a.m.
I.
OPENING REMARKS AND INTRODUCTIONS............... ROSS SCARANO II.
DESCRIPTION OF ENFORCEMENT PROCESS..............
GARY SANBORN III.
DESCRIPTION OF APPARENT VIOLATIONS.............. MIKE SHANNON V.
LICENSEE PRESENTATION V.
NRC AND LICENSEE CAUCUSES (IF NEEDED)
VI.
ADDITIONAL QUESTIONS AND ANSWERS VII.
CLOSING REMARKS LICENSEE VIII.
CLOSING REMARKS NRC
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ROSS SCARANO 1'
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