IR 05000397/1998004
| ML17292B324 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B322 | List: |
| References | |
| 50-397-98-04, 50-397-98-4, NUDOCS 9804150265 | |
| Download: ML17292B324 (19) | |
Text
ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-397 NPF-21 50-397/98-04 Washington Public Power Supply System Washington Nuclear Project-2 Richland, Washington March 17-19, 1998 L. T. Ricketson, P.E., Senior Radiation Specialist, Plant Support Branch M. P. Shannon, Senior Radiation Specialist Plant Support Branch Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:
Supplemental Information 9804i50265 980408 PDR ADCICK 05000397 G
-2-TIV MMA Y Washington Nuclear Project-2 NRC Inspection Report 50-397/98-04 This announced, routine inspection reviewed engineered safety feature filterventilation systems maintenance and in-place filtertesting; implementation of the liquid, gaseous, and particulate radioactive eNuent monitoring program; status of eNuent monitors and chemistry counting equipment; training and qualifications of personnel; and quality assurance oversight.
~nini~ri The licensee's engineered safety feature filterventilation systems were properly designed and maintained.
(Section E2)
An adequate ventilation filtertesting program was implemented.
The engineered safety feature filterventilation systems were tested as required by technical specifications.
(Section E3)
Individuals required to have knowledge of in-place filtertesting were properly trained.
(Section E5)
The licensee maintained a good radioactive eNuent monitoring program.
The licensee's radioactive eNuent sampling, analysis, and dose projection program met the requirements of the offsite dose calculation manual.
The licensee demonstrated an improving trend in the reduction of radioactive eNuents during 1995-1997.
(Section R1.1)
Licensee personnel performed well in identifying and correcting a problem dealing with the calibration of the radwaste building exhaust monitor. Aside from this monitor, eNuent monitors were properly calibrated.
(Section R2)
A noncited violation related to the calibration of the radwaste building exhaust monitor was identified. (Section R2)
The quality of oversight of the radioactive eNuent monitoring program by the quality assurance organization declined.
The 1996 quality assurance audit was good, but the 1997 audit was weaker because the review lacked depth and performance-based input.
(Section R7)
A 10 CFR Part 50, Appendix B, Criterion XVIII,violation was identified because the audit team members did not have experience or training in the special nature of the radioactive eNuent monitoring program.
(Section R7)
-3-I I. En ineerin E2 Engineering Support of Facilities and Equipment E2.1 n ineer d af Fea r Filer Venil ion S a.
I i n co 847 The inspectors performed visual inspections of.the control room emergency filtration system and the standby gas treatment system and interviewed the engineers assigned to the systems.
b.
s ai n andFi di The inspectors noted during walkdowns of the air cleaning systems that equipment appeared to have been properly maintained and that there was no obvious physical damage to the air cleaning systems that would have prevented them from performing their required functions.
Redundant systems were available, as required.
Permanent test ports for in-place filtertesting were installed and relatively easy to access.
The engineered safety feature filterventilation systems met the general design criteria outlined in Regulatory Guide 1.52, Revision 2, and ASME N509-1980.
C.
~CIUSItIS The licensee's engineered safety feature filterventilation systems were properly designed and maintained.
E3 Engineering Procedures and Documentation E3.1 En inee af F a eFil rV nil i n s
rn i
n Te in a.
In c i n S 8 7 The inspectors reviewed the following:
~
Records of in-place filtertesting of high efficiency particulate air filters and charcoal adsorbers
~
Records of laboratory tests of charcoal adsorbers b.
Observa i n and Fi d'he licensee's surveillance procedures for in-place testing of high efficiency particulate air filters and charcoal adsorbers followed the guidance in Regulatory Guide 1.52, Revision 2, and ASME N 510-1989.
Through a review of test results, the inspectors
confirmed that the licensee complied with Technical Specifications 5.5.7(a) and (b),
which require in-place testing once per 24 months and demonstration that high efficiency particulate air filters and charcoal adsorbers show less than 0.05 percent penetration and bypass.
The inspectors also confirmed that laboratory testing of charcoal adsorber samples was performed in accordance with Technical Specification 5.5.7(c).
c.
~nli~si n An adequate ventilation filtertesting program was implemented.
The engineered safety feature filterventilation systems were tested as required by technical specifications.
E5 Engineering Staff Training and Qualification a.
I i
The inspectors interviewed systems engineers and maintenance supervisors and reviewed training records for selected maintenance personnel.
a
'
Findin In-place filtertesting of the engineered safety feature filterventilation system systems was performed by licensee designated maintenance personnel.
The inspectors confirmed through a review of training records that the individuals had received specialized training to qualify them to perform the in-place filtertests.
The systems engineers assigned to the control room emergency filtration system and the standby gas treatment system stated during interviews that they were not trained in the in-place filtertesting procedures.
The inspectors determined the systems engineers were not required to review or approve the testing results, although they were required to be notified ifthe systems failed the tests.
The inspectors concluded that the systems engineers'ack of training did not constitute a.violation of regulatory requirements.
.Engineering management representatives stated that they hoped to provide in-place filter testing training to the engineers in the future as a program enhancement.
c.
Conc~lip@.>
Individuals required to have knowledge of in-place filtertesting were properly trained.
E7 Quality Assurance in Engineering Activities The inspectors confirmed that audits were performed of the vendor performing laboratory testing of samples of the charcoal adsorber material. The licensee took credit for audits performed by the Nuclear Procurement Issues Committee.
There were no adverse findings significant enough to render the vendor laboratory's test results invalid.
-5-V a
Su o
R1 Radiological Protection and Chemistry Controls R1.1 Im I men ion f h Li uid as ou and ul lo IV r
ra a.'
i n e
475 The inspectors interviewed licensee person'nel and reviewed the following:
~
1996 and 1997 annual eNuent release reports Release permits
~
Quarterly and monthly sampling results b.
rv ins n
Fin in s The annual eNuent release reports documented a decreasing trend in the volume of liquid eNuent released.
Correspondingly, there was a decrease in the radioactivity released through liquid eNuents.
From the annual reports, the inspectors determined that releases of radioactive eNuents were within regulatory requirements and did not exceed the commitments within the Final Safety Analysis Report.
On a relative basis, the quantity of both liquid and gaseous effluents released by the licensee had declined over the last few years.
Through a review of information, supplied by the licensee, related to radioactive eNuent releases by other boiling water reactors, the inspectors determined gaseous releases by the licensee were low compared to similar facilities and liquid releases were at or just below the median value.
The inspectors reviewed selected release permits for batch releases of liquid radioactive eNuent and periodic sampling results and confirmed that sampling was performed in accordance with Table 6.2.1.1.1-I of the Offsite Dose Calculation Manual. Pre-release and post-release calculations followed the methodology of Section 2.3 of the Offsite Dose Calculation Manual.
Gaseous eNuents were released on a continuous basis.
The inspectors reviewed selected sampling results and confirmed that sampling and analysis were performed in accordance with Table 6.2.2.1.2-1 of the Offsite Dose Calculation Manual.
Cumulative dose contributions from liquid and gaseous eNuents were determined at least once per 31 days in accordance with the methodologies and parameters in the Offsite Dose Calculation Manua c.
~Con lumin The licensee maintained a good radioactive eNuent monitoring program.
The licensee's radioactive eNuent sampling, analysis, and dose projection program met the requirements of the Offsite Dose Calculation Manual. The licensee demonstrated an improving trend in the reduction of radioactive eNuents during 1995-1997.
R2 Status of Radiation Protection and Chemistry Facilities and Equipment In
'
The inspectors interviewed licensee personnel and reviewed the following:
ENuent monitor physical condition ENuent monitor calibrations Counting equipment calibrations b.
rv I
n In Vi I In i
During walkdowns of the eNuent monitors, the inspectors found all monitors to be operable, but there were minor material conditions that needed attention. These included dripping oil, indicator lights that didn't function, and missing labeling on valves.
Licensee representatives stated that these items would be addressed.
The inspectors determined that the current reactor building iodine and particulate sampler configurations differed from the original. The modification resulted in the sampling lines having additional bends.
The inspectors asked ifthe licensee had conducted an evaluation of the effect of the additional bends on the efficiency of the sampling devices.
After reviewing design drawing and engineering files, licensee representatives stated that such an evaluation had not been performed.
At the exit meeting on March 19, 1998, the Vice President of Operations Support, committed to review the effects on collection efficiency caused by the relocation of the main vent particulate and iodine samplers.
Because of the timing of this finding, the inspectors did not have time to review the requirements within licensee's design change program to determine ifthe requirement applied to such changes as those made to the effluent samplers.
The review of the licensee's evaluation of sampler changes and a review of the licensee's compliance with its design change program requirements are considered an inspection followup item (50-397/9804-01).
-7-The inspectors reviewed calibration records for eNuent monitors and determined that the monitors were properly calibrated.
The inspectors reviewed selected problem evaluation requests related to the radioactive eNuent monitoring program and the calibration and operability of the eNuent monitors.
In Problem Evaluation Request 297-0221, the licensee identified that the efficiency of the radwaste building intermediate range noble gas monitor (WEA-RIS-14A) was unacceptably low. This resulted in a change in the operating range of the monitor that eliminated the required overlap in ranges of this monitor and the radwaste building low range noble gas monitor. A gap developed in the ranges of the Iow and intermediate range monitors because of the decreasing intermediate range monitor efficiency. By definition, a gap meant there was no operable monitor for the entire range.
Therefore,
,monitoring was not performed in accordance with Offsite Dose Calculation Manual 6.1.2, Table 6.1.2.1-1, which requires an operable monitor.
The licensee had previously identified problems with the reactor building stack monitor (PRM-RE-1B). The reactor building stack monitor problem was discussed in Inspection Report 50-397/96-1 5.
The inspectors compared the two problems and concluded the corrective action to prevent recurrence of the first problem could not reasonably have been expected to have prevented the second problem. The problem with the reactor building stack monitor involved an error during the primary calibration of the monitor. The problem with the radwaste building monitor was degraded instrument performance and surveillance procedures inadequate to identify the degraded performance.
The reactor building stack monitor problem was of concern because it could have resulted in delays in assessing the significance of the offsite consequences during an emergency event had one occurred.
Therefore, the licensee was not able to meet one of the emergency planning standards involving assessment (10 CFR 50.47(b)).
In contrast, the radwaste building monitor calibration problem would not have prevented the licensee from meeting the planning standards.
The low range of the monitor was unaffected and would have provided information sufficient to classify emergencies up to the "general emergency
" classification.
In this case, the intermediate range was superfluous.
The inspectors determined that licensee representatives revised the calibration procedure for the radioactive waste building monitor to correct the calibration methodology and reviewed the acceptance criteria and key calculation methods of the calibration procedures for other instruments to verify that they are technically accurate.
The inspectors concluded the licensee's actions should prevent recurrence of the problem.
This nonrepetitive, licensee-identified and corrected violation of Offsite Dose Calculation Manual requirements is being treated as a noncited violation consistent with Section VII.B.1 of the NRC Enforcement Policy (50-397/9804-02).
e c.
~on lu ions-8-Licensee personnel performed well in identifying and correcting a problem dealing with the calibration of an eNuent monitor. Aside from the intermediate range of the radioactive building ventilation exhaust monitor, eNuent monitors were properly calibrated.
RS Staff Training and Qualification There were no newly qualified chemistry technicians.
Allchemistry personnel had at least 7 years experience.
R6 Radiation Protection and Chemistry Organization and Administration The chemistry and radiation protection organizations were no longer under the supervision of one individual. The licensee was in the process of preparing an amendment to the Final Safety Analysis Report.
R7 Quality Assurance in Radiation Protection and Chemistry Activities a.
Ins n
8 75 The inspectors interviewed quality assurance personnel and reviewed the following:
~
1996 and 1997 quality assurance audits of the radioactive eNuent monitoring programs
~
Selected vendor audits
~
ENuent audit plan
~
Auditor resumes bs rv i n and Findin Audits 296-073 (1996) and 297-073 (1997) included reviews of the radiological environmental monitoring program and the radiological eNuent monitoring program.
The inspectors focused only on the eNuent monitoring portion of the audit.
The inspectors noted that the 1996 audit team included technical experts that had knowledge of radioactive effluent monitoring activities.
However, the audit team members that reviewed radioactive eNuent monitoring during the 1997 audit had no technical expertise in the subject.
10 CFR Part 50, Appendix B, Criterion XVIII,requires a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program.
The audits shall be performed in accordance with the written
procedures or checklists by appropriately trained personnel not having responsibility in the areas being audited., Quality Assurance Procedure QAP-7, "Personnel Indoctrination, Training, Qualification, and Certification," Revision 6, states, "Personnel selected for quality assurance auditing assignments shall have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."
The inspectors identified the lack of chemistry sampling and analysis experience or training dealing with the special nature of the activities dealing with the Offsite Dose Calculation Manual requirements as a violation of 10 CFR Part 50, Appendix B requirements (50-397/9804-03).
Quality assurance representatives acknowledged that the 1997 audit was primarily compliance-based because the auditors lacked technical expertise.
The inspectors-reviewed the 1996 and 1997 audit reports to determine ifthe change in auditing philosophy affected the type of audit findings. During the 1996 audit, team members performed manual calculations to confirm dose values generated by the in-house computer code; identified a failure to include calculated skin doses in the annual eNuent release report; and completed performance-based observations of eNuent sample collection, preparation, and analysis.
During the 1997 audit, team members determined that proper procedures were in place for collecting samples, analyzing results, and performing dose calculations; identified that dose calculations were not identical to the procedure direction; and determined that procedures were in place for testing and maintaining instruments and equipment used for measurement of radioactive eNuents.
The inspectors concluded that the depth of review of the 1997 audit did not match that of the 1996 audit because it was not designed to ensure performance-based reviews were included.
g~nl i~in The quality of oversight of the radioactive eNuent monitoring program by the quality assurance organization declined.
The 1996 quality assurance audit was good, but the 1997 audit was weaker because the review lacked depth and performance-based input.
A 10 CFR Part 50, Appendix B, Criterion XVIII,violation was identified because the 1997 audit team members did not have experience or training in the special nature of the radioactive eNuent monitoring program.
R8 Miscellaneous Radiation Protection and chemistry Issues 3.1 Cl Viol tion 50-3 7/96-15 EA 9 -2 R
r Buildin S
c u
o i or alibra ion Erro The inspectors verified the corrective actions described in the licensee's response letter, dated September 9, 1996, were implemented.
The problem had not recurred.
See Section R2 for a discussion of problem involving the radwaste building exhaust monito V Nla a erne t Meetin X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting on March 19, 1998. The licensee acknowledged the findings presented.
No proprietary information was identified. The licensee committed to review the effects on collection efficiency caused by the relocation of the main vent particulate and iodine sampler P TI T
FP RON T
T D
~igni~~
A. Alexander, Effluents Technical Specialist D. Atkinson, Quality Manager A. Barber, Quality Services Supervisor D. Bennett, Effluents Minimization Supervisor Y. Derrer, Licensing Engineer D. Giroux, Standby Gas Treatment System Engineer J. Hanson, Chemistry Manager J. Lakey, Chemistry Operations Supervisor G. Smith, Plant General Manager R. Webring, Vice President, Operations Support C. Zeamer, Control Room Emergency Filtration System Engineer S. Boynton, Senior Resident Inspector D
D 84750 Radioactive Waste Systems P
D D
D 50-397/9804-01 50-397/9804-02 50-397/9804-03 G~ld IFI Review of effects of modification on reactor building sampler efficiency and review of modification program compliance NCV Radwaste Building Effluent Monitor Efficiency Calibration Error VIO Auditor experience and qualifications 50-397/9615-01 VIO Reactor Building Stack Effluent Monitor Calibration Error 50-397/9804-02 NCV Radwaste Building Effluent Monitor Efficiency Calibration Error
e
-2-LI T F D UME TS EVIEW D WNP-2 Organization Chart (10/1 0/97)
1996 and 1997 WNP-2 Radioactive ENuent Release Report Quality Department Audit Report 296-073 Quality Department Audit Report 297-073 Problem Evaluation Request 297-0221 r
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ram MSP-WMA-B101 Control Room DIV-AEmergency Filtration System HEPA Filter Test, Revision 0 MSP-WMA-B102 Control Room DIV-BEmergency Filtration System HEPA Filter Test, Revision 0 MSP-WMA-B103 Control Room DIV-AFiltration System - Carbon Adsorber Test, Revision 0 MSP-SGT-B101 MSP-SGT-B102 MSP-SGT-B104 Standby Gas Treatment System Unit A HEPA Filter Test, Revision 0 Standby Gas Treatment System Unit B HEPA Filter Test, Revision 0 Standby Gas Treatment Filtration System - Unit B Carbon Adsorber Test, Revision 0