IR 05000397/1998010
| ML17292B413 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/18/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B409 | List: |
| References | |
| 50-397-98-10, NUDOCS 9806220350 | |
| Download: ML17292B413 (23) | |
Text
E CLO U.S. NUCLEAR REGULATORYCOMMISSION
REGION IV
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
'ocation:
Dates:
Inspector(s):
Approved By:
50-397 NPF-21 50-397/98-10 Washington Public Power Supply System Washington Nuclear Project-2 Richland, Washington June 1-5, 1998 Michael P. Shannon, Senior Radiation Specialist, Plant Support Branch Blaine Murray, Chief, Plant Support Branch Attachment:
Supplemental Information 9806220350 9806i8 PDR ADGCK 05000397
> g L
-2-X C TIVE Washington Nuclear Project-2 NRC Inspection Report 50-397/98-10 This announced, routine inspection reviewed external exposure controls, controls for radioactive materials and contamination, surveying and monitoring activities, staff training, radiation protection oversight activities, and the as low as is reasonably achievable program.
In general, the external exposure control program was effectively implemented.
Personnel wore their dosimetry properly and knew to contact radiation protection personnel iftheir electronic dosimeter alarmed.
Radiological areas were properly controlled and posted (Section R1.1)..
Housekeeping within the radiological controlled area was good. Trash and laundry containers were properly maintained (Section R1.1).
The content of ALARAwork packages needed improvement.
Site lessons learned for similar work were properly recorded in ALARAwork history packages; however, industry lessons learned were not included. Job improvement ideas and suggestions not were normally captured from craft level licensee or contractor personnel at the completion of job activities. The radiation protection department provided proper staff, equipment, and protective clothing to support radiological work (Section R1.2).
Personnel exiting radiological contaminated areas used proper health physics practices during the removal of protective clothing. Radiation protection personnel stationed at the radiological controlled area egress point provided appropriate and timely guidance to workers who alarmed the personnel contamination monitors.
In general, the radioactive source leak testing and inventory programs were properly implemented; however, the source inventory notations were not consistently documented (Section R1.3)..
The senior site ALARAcommittee was not fullysupported by the operations department.
Between January 1, 1997, and June 3, 1998, the operations representative only attended three of five ALARACommittee meetings.
The station had not established a
hot spot reduction program.
Therefore, the licensee did not know how many hot spots were present or which contributed significant exposure to station workers. The licensee did not have an ALARAsuggestion tracking system to ensure that suggestions were not misplaced or forgotten (Section R1.4).
i A violation of Technical Specification 5.4.1 was identified involving the failure of the senior site ALARACommittee to review the 1998 refueling outage (R-13) exposure goal
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and ALARAreviews and exposure reduction effectiveness evaluations were not performed for shielding installations (Section R1.4).
-3-Overall, a good training program was effectively implemented.
Lesson plans were well organized, developed, and site and industry lessons learned were incorporated.
The radiation protection department was appropriately involved in developing the training topics to ensure that the practical and technical competence of the radiation protection staff was maintained (Section R5.1).
Overall, quality department oversight of radiation protection activities was good. The quality department included a member with a strong operational radiation protection background.
Quality department operational radiation protection surveillances performed since January 1997 were intrusive and provided management with a very good assessment of the program performance.
However, no quality department audits of the radiation protection program had been performed since January 1, 1997 (Section R7.1).
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A site wide self-assessment which included the majority of radiation protection program areas provided management with a critical assessment of the radiation protection program.
The timeliness of problem evaluation requests improved during the past 6 months (Section R7.1).
During the inspection the plant was in the final week of Refueling Outage R13.
IV PJllld R1 Radiological Protection and Chemistry Controls R1.1 a.
Selected radiation workers and radiation protection personnel involved in the external exposure control program were interviewed. A number of tours of the radiological controlled area were performed.
The following items were reviewed:
Dosimetry use Control of high radiation areas Housekeeping within the radiological controlled area b.
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The inspector conducted several tours of the radiological controlled area and performed independent radiation measurements to verify the appropriateness of radiological postings.
Areas were found to be properly controlled and posted.
Allpersonnel observed by the inspector wore their dosimetry devises properly and knew to contact radiation protection personnel iftheir electronic dosimeter alarmed.
Technical Specification high radiation areas were locked and properly posted.
Flashing lights were used where appropriate and were operating properly. During the review of the radiation protection shift turnover log, the inspector identified that from May 15 until June 4, 1998 (a 20-day period), there were three occasions (May 17, May 23, and May 27, 1998) in which the Technical Specification high and very high radiation area keys were not accounted for during radiation protection shift turnovers.
Technical Specification 5.4.1.a. states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.1, requires procedures for access control to radiation areas.
Section 5.2.8 of Procedure 11.2.7.3, "High and Very High Radiation Controls," Revision 15, requires that high-high radiation area keys be accounted for at shift turnover and appropriate log entries made.
The inspector reviewed the high-high radiation area key issue sheets for the 3 days in question and noted that all
-5-Technical Specification high radiation keys were properly issued and returned, but the keys were not accounted for as part of shift turnover activities.
The inspector determined that the failure to account for the keys at shift turnover, in accordance with the above procedure, constitutes a violation of minor significance and is not subject to formal enforcement action.
Housekeeping within the radiological controlled area was good. Alltrash and laundry containers were properly maintained.
However, the inspector noted that areas further from the main walkways needed more attention to housekeeping then well traveled areas.
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In general, the external exposure control program was effectively implemented.
Personnel wore their dosimetry properly and knew to contact radiation protection personnel iftheir dosimeter alarmed.
Radiological areas were properly controlled and posted.
However, Technical Specification high radiation area keys were not always accounted for during shift turnovers.
Housekeeping within the radiological controlled area was good. Alltrash and laundry containers were properly maintained.
R1.2 Pl nin I'
co e Radiation protection department personnel involved in radiation protection planning and preparation were interviewed. The following items were reviewed:
ALARAwork packages Incorporation of lessons-learned from similar work w
i an in 'n A review of ALARAwork history packages revealed that site lessons learned for repeat work were properly recorded in the packages; however, industry lessons learned were not included.
The inspector noted that in some cases; such as, the emergency core cooling system work, ALARAplanners had hard copies of industry information in their file drawer; however, this information was not captured in the work package history file. The inspector commented that not maintaining all lessons learned in the work packages could hamper ALARAplanning of future similar work. Radiation protection management acknowledged the inspector's comment.
Post job reviews included lessons learned; however, ideas and suggestions were not always captured from craft level licensee or contractor personnel at the completion ofjob activities. Job improvement items were typically taken from in-progress job reviews, ALARAplanner's knowledge, and field logs. The inspector commented that not capturing ideas and suggestions from workers involved in job activities could result in
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-6-missed opportunities to improve the ALARAjob performance of a given task. The licensee acknowledged, the inspector's comment.
Based on interviews with radiation protection personnel, maintenance and operations management, and field observations, the inspector determined that the radiation protection department provided proper staff, equipment, and protective clothing to support radiological work.
ALARAwork packages needed improvement.
Site lessons learned were properly recorded in ALARAwork history packages; however, industry lessons learned were not.
Job improvement ideas and suggestions were normally not captured from craft level licensee or contractor personnel at the completion ofjob activities. The radiation protection department provided proper staff, equipment, and protective clothing to support radiological work.
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i Areas reviewed included:
Contamination monitor use and response to alarms.
Radioactive source control and leak testing programs.
Portable instrumentation calibration and performance checking programs.
During tours of the radiological controlled area, the inspector observed that personnel exiting radiological controlled areas used proper health physics practices during the removal of protective clothing. Additionally, workers used the personnel contamination monitors properly, and radiation protection personnel stationed at the radiological controlled area egress point provided appropriate and timely guidance to workers who alarmed the monitors. The inspector concluded that personnel contamination events were properly handled and recorded.
The inspector reviewed the source leak testing and inventory records for the last 12 months.
The inspector also reviewed selected sources to ensure labeling and posting controls were proper.
No problems were identified with the radioactive source leak testing and inventory programs.
However, the inspector observed that the source inventory notations were not consistently documented.
For example, sometimes a
check mark was placed along side the source number; the next time it was highlighted.
The radiation protection manager stated that they would review the source inventory program to address the inspector's observation.
Portable radiation survey instrumentation was properly source response teste c.
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Personnel exiting radiological contaminated areas used proper health physics practices during the removal of protective clothing. Radiation protection personnel stationed at the radiological controlled area egress point provided appropriate and timely guidance to workers who alarmed the personnel contamination monitors.
No problems were identified with the radioactive source leak testing and inventory programs.
However, the source inventory notations were not consistently documented.
R1.4
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h'adiation protection personnel involved with the ALARAprogram were interviewed. The following areas were reviewed:
Senior site ALARAcommittee activities Hot spot reduction program Temporary shielding program ALARAsuggestion program b.
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Find'ni LARA mmi c ivi ie A review of the meeting minutes of the Senior Site ALARACommittee from January 1, 1997 until June 3, 1998, revealed that there were 5 ALARAcommittee meetings during this period. The inspector noted that the committee discussed appropriate ALARAtopics such as support of long and short range projects to reduce component and station'xposure.
Except for the operation department, all other station department ALARA committee representatives attended the five meetings.
The operations department ALARAcommittee representative only attended three of the five meetings.
Technical Specification 5.4.1.a. states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, Feb'ruary 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.9, requires procedures for the implementation of the ALARAprogram.
Section 2.3 of Procedure GEN-RPP-13, "ALARA Committee," Revision 1, states, in part, that the senior site ALARAcommittee is responsible for the review of outage exposure goals.
During the review of the senior site ALARAcommittee meeting minutes, the inspector determined that the R-13 outage exposure goal was not reviewed by the senior site ALARAcommittee.
The inspector noted during the review of the December 19, 1997, senior site ALARAcommittee meeting minutes that the engineering manager, who was representing the quality manager, requested that an item pertaining to how the Refueling
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-8-Outage 13 exposure goal was established be put on the committee's agenda.
The inspector reviewed the senior site ALARACommittee Meeting minutes for January 19, 1998, which was the last meeting prior to Refueling Outage 13, and determined that the exposure goal for Refueling Outage 13 was not reviewed prior to the outage.
The failure to review the Refueling Outage 13 exposure goals in accordance with the above procedure is identified as a first example of a Violation of Technical, Specification 5.4.1 (50-397/9810-01).
The inspector noted that the licensee had not established a hot spot reduction program.
The licensee did not know how many hot spots were present and which contributed significant exposure to station workers.
Radiation protection supervision stated that hot spots were prioritized on a case-by-case bases for removal, flushing, or shielding after the area/component was brought to the attention of the radiation protection ALARA organization.
The inspector noted that there was no regulatory requirement to have a hot spot reduction program, but commented that this was atypical. The licensee acknowledged the inspector's comment.
There were 94 temporary shielding packages installed throughout the radiological controlled area as of June 3, 1998. Seven shielding packages were randomly selected for review. The inspector noted that all the shielding packages contained a drawing or photograph of the installation, and pre-and post-radiological shielding surveys of the area/component shielded.
However, two of the seven packages did not include an, engineering evaluation of the installation in accordance with management's expectations.
A copy of these evaluations was later retrieved from the engineering department and placed in the shielding packages.
Additionally, none of the shielding packages contained an ALARAreview or exposure reduction effectiveness evaluation.
The licensee was not able.to locate shielding evaluation documents.
Technical Specification 5.4.1.a. states, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Regulatory Guide 1.33, Appendix A, Section 7.e.9, requires procedures for the implementation of the ALARAprogram.
Section 5.1.4 of Procedure GEN-RPP-14,
"Control of Temporary Shielding," Revision 1, states, in part, that the ALARAshielding coordinator is responsible for ensuring that ALARAreviews are performed to determine shielding requirements and evaluating the exposure reduction effectiveness (ofthe shielding).
The failure to perform ALARAreviews and exposure reduction effectiveness evaluations is identified as a second example of a Violation of Technical Specification 5.4.1 (50-397/9810-01).
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-9-LARA u
i Pr r m Nineteen ALARAsuggestions were submitted between July 1, 1997, and June 2, 1998.
The inspector noted that 16 of the 19 had been evaluated in a timely manner.
The remaining three had not been evaluated as of June 2, 1998. One of these suggestions was submitted on December 9, 1997, another was not dated.
Of the 16 evaluated, 3 had been implemented.
Additionally, the inspector determined that the licensee did not have an ALARAsuggestion tracking system to ensure that suggestions were not misplaced or forgotten. The inspector noted that there was no regulatory requirement to have an ALARAsuggestion program; however, the inspector commented that timely evaluation and response were a major part of a successful ALARAsuggestion program.
The licensee acknowledged the inspector's comment.
Q~nl gjgns The senior site ALARAcommittee was not fullysupported by the operations department; A first example of a violation of Technical Specification 5.4.1 was identified for the failure of the senior site ALARAcommittee to review Refueling Outage 13's exposure goal. The station did not have a hot spot reduction program.
Therefore, the licensee did not know how many hot spots were located throughout the power block, or which, ifany, contributed a significant amount of exposure to station workers. A second example of a violation of Technical Specification 5.4.1 was identified, because ALARAreviews and exposure reduction effectiveness evaluations were not performed for shielding
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installations.
In general, ALARAsuggestions were reviewed in a timely manner.
However, the licensee did not have an ALARAsuggestion tracking system to help ensure suggestions were not misplaced or forgotten.
R2 Status of Radiological Protection and Chemistry Facilities and Equipment(83750)
The licensee had changed and remodeled the normal radiological controlled entrance and radiation protection supervisor/technician office areas since January 1998. The inspector determined that the change provided the licensee with a professional, efficient, user friendly entrance to the radiological controlled area.
R5 Staff Training and Qualification in Radiological Protection and Chemistry R5.1 R di io P
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Ins tion
Personnel involved with radiation protection technician training were interviewed. The following items were reviewed:
Radiation protection instructor qualifications Radiation protection technician continuing training lesson plans Radiation protection management over sight of the training program
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-10-rv io nd Findi The inspector reviewed the qualifications of the instructor assigned to provide continuing training to the radiation protection staff. The instructor had a strong operational radiation protection background, a number of years of radiological experience, and was registered by the National Registry of Radiation Protection Technologists.
Additionally, the instructor was used to supplement the radiation protection staff during outages.
A review of the training schedule and training advisory group meeting minutes revealed that appropriate topics were identified to ensure that the practical and technical competence of the staff was maintained.
Lesson plans were well organized, developed, and site and industry lessons learned were incorporated.
The inspector determined that radiation protection management was appropriately involved in developing the training topics.
Overall, a good training program was effectively implemented.
Lesson plans were well organized, developed, and site and industry lessons learned were incorporated.
The radiation protection department was appropriately involved in developing the training topics to help ensure that the practical and technical competence of the'staff was maintained.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 li D
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IPr lemEva aio 837 0 ion
Selected personnel involved with the performance of quality department audits and surveillances and radiation department self-assessments were interviewed. The following items were reviewed:
Qualifications of personnel who performed quality department audits and surveillances Quality department audits Quality department surveillances Radiation protection department self-assessments Radiological problem evaluation request reports
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-11-I nd A review of the qualifications of the auditors involved in the oversight of the radiation protection program identified no problems.
The inspector noted that the primary auditor had a number of years of operational radiation protection experience and was registered by the National Registry of Radiation Protection Technologists.
No quality department radiation protection program audits had been performed since January 1, 1997.
However, the inspector noted that a comprehensive plant performance self-assessment of all station departments was performed during October 1997, which included an overview of the radiation protection program.
The inspector determined that this review covered a majority of the radiation protection department program areas and provided management with an effective assessment of the radiation protection program performance.
Three qualit'y department operational radiation protection surveillances were performed since January 1997. The inspector determined that these surveillances were intrusive
~ and provided management with a very good assessment of the program areas reviewed.
Weaknesses found during the surveillances were categorized as problem evaluation requests (PERs) or recommendations and were properly tracked and trended by the quality department.
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R The inspector reviewed a summary of radiological problem evaluation requests written since January 1, 1997. This review revealed that the licensee identified issues at the proper threshold to provide management with a good too( to evaluate program areas.
The review also identified that response timeliness improved during the past 6 months.
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If-A Only one radiation protection department self-assessment had been performed since January 1, 1997. This self-assessment was conducted during January 1998 and reviewed the effectiveness of dose reduction methods used at the station during 1997.
Two recommendations were identified during this assessment.
Both recommendations were captured in the station's plant tracking log system and were scheduled to be closed by August 17, 1998. The inspector determined that the self-assessment provided management with a good evaluation of the program area reviewed.
~lignin Overall, quality oversight of radiation protection activities was good. The primary auditor involved with the oversight of the radiation protection activities had a strong operational radiation protection background.
Quality department operational radiation protection
'surveillance reports performed since January 1997 were intrusive and provided
-12-management with a very good assessment of the program areas reviewed.
However, no quality department radiation protection program audits were scheduled or performed since January 1, 1997. A site wide self-assessment which included the majority of radiation protection program areas provided management with a critical assessment of the radiation protection program.
The timeliness of problem evaluation requests improved during the past 6 months.
RS Miscellaneous Radiological Protection and Chemistry Issues 8.1 The inspector determined that actions associated with this item were appropriate.
Specifically, the inspector reviewed Procedure HPI 12.70, "RWP and ALARAPlanning Processes,"
Revision 0, which was developed to define and document management's expectations for the administration ofALARAplanning and RWP processes.
X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on June 5, 1998. The licensee acknowledged the findings presented.
No proprietary information was identifie ATT C E
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F C
T CTED P. Bemis, Vice President, Nuclear Operations I. Borland, Radiation Support Supervisor
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Coleman, Regulatory'Affairs Manager Y. Derrer, Licensing Engineer J. Hanson, Chemistry Manager D. Hillyer, Radiation Protection Manager J. Holder, Program Manager P. Inserra, Licensing Manager R. James, Radiation Protection ALARASupervisor J. Kale, Engineering General Manager R. Morris, Maintenance Supervisor A. Mouncer, Vice President Operations Support W. Oxenford, Operations Manager J. Peters, Assistant Radiation Protection Manager G. Smith, Plant General Manager J. Wyrick, Quality Services Supervisor.
S. Boynton, Sr. Resident Inspector I
P 83750 Occupational Radiation Exposure T M D
50-397/9810-01 VIO Failure to followALARAprogram requirements Quad 50-397/9701-02 IFI Ensure adherence to commitments made to the NRC
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A summary of radiological problem evaluation request reports written since May 1, 1998 Radiation Protection Program Self-Assessment performed January 14-26, 1998 Quality department surveillance report 297-085 Quality department surveillance report 298-029 Quality department surveillance report 298-032 Senior Site ALARACommittee Meeting Minutes dated; March 24, 1997, June 19, 1997, September 29, 1997, December 19, 1997, and January 19, 1998 Procedure GEN-RPP-01, "ALARAProgram Description," Revision
Procedure GEN-RPP-13, "ALARACommittee," Revision
I Procedure GEN-RPP-14, "Control of Temporary Shielding," Revision
Procedure SWP-RPP-01, "Radiation Protection Program," Revision
Procedure 11.2.2.5, "ALARAJob Planning and Reviews," Revision 7 Procedure 11.2.7.1, "Area Posting," Revision 11 Procedure 11.2.7.3, "High and Very High Radiation Area Controls," Revision 15 Procedure 11.2.7.4, "Discrete Radioactive Particle Control," Revision 5 Procedure 11.2.14.4, "Storage and inventory Control of Radioactive Sources," Revision 9