ML17278A248
| ML17278A248 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/11/1985 |
| From: | Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17278A245 | List: |
| References | |
| 50-397-85-20, NUDOCS 8507010228 | |
| Download: ML17278A248 (18) | |
See also: IR 05000397/1985020
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No. 50-397/85-20
Docket No. 50-397
License No. NPF-21
Licensee:
Washington Public Power Supply System
(WPPSS)
P. 0. Box 968
Richland, Washington
99352
Facility Name:
Washington Nuclear Project No.
2
(WNP-2)
Inspection at:
WNP-2 Site,
Benton County, Washington
Inspection
conducted:
May 29-31,
1985,
telephone
conversation
Inspectors:
C. I. Sherman,
Radiation Specialist
June '6,
1985
Q usa///fg~
Date Signed
Approved by:
G. P.
Y ha
, Chief
Faciliti
Radiological Protection Section
s
Date
S gned
Summar
Ins ection on Ma
29-31,
1985 and tele hone conversation
June 6,
1985
Areas Ins ected:
Routine unannounced
inspection of health physics
program
during an extended
outage.
Results:
Of the six areas
inspected,
violations were identified in three
areas:
T.S. 6.22, control of overtime(5 2); T.S. 6.11.1,
adherence
to health
physics procedures(5
3); and T.S. 6.8.1, tool control around
open plant
systems, fire protection
and housekeeping(5
5).
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DETAILS
e
Persons
Contacted
Martin, Assistant
Managing Director for Operations
Powers,
Plant Manager
Baker, Assistant Plant
Manager'reybeal,
Health Physics/Chemistry
Manager
Peters,
Plant Administration Manager
Feldman, Plant guality Assurance
Manager
Berry, Health Physics Supervisor
Bradford, Health Physicist
Shockley, Health Physics/Radiochemistry
Support Supervisor
Davis, Senior Radiochemist
Ehlert, Lead Health Physics Technician
"
Tuel, Lead Health Physics Technician
Frank, Bechtel Power Corporation
Allen, Health Physicist
Smith, Health Physics Technician
Jacobson,
Maintenance
Foreman
Anderson,
Maintenance
Supervisor
Larson,
Manager Radiological Programs
Denotes
those individuals participating in the exit interview on May 31,1985
2 '. Telephone
conversation
June 6,
1985
2.
Overtime
Administrative Technical Specification(TS) 6.2.2.f sets forth
requirements for administrative approval of overtime when certain values
are exceeded.
Based
on discussion with licensee
personnel,
the inspector
learned that health physics
and chemistry personnel
were working large
amounts of overtime.
The inspector selected for examination,
the records
of several
chemistry and health physics personnel.
One chemistry
technician
was identified as working 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day on May 2-17.
One health physics technician identified as working in the reactor
building and drywell as health physics coordinator worked
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
on
'pril
29-30,
May 1-3, May 5-18 and 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />
on May 4.
This represents
a total of 20 consecutive
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> work days for this individual.
Technical specification 6.2.2.f.2 sets forth the approval criteria as
72
hours in any
7 day period.
The individuals identified worked 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />
over several
7 day periods.
This
TS states
that the plant manager, in accordance with established
procedures
and with documentation of the basis for granting the
deviation, shall authorize
any deviation.
Plant procedure
1.3.27 has
been established
to implement the TS.
Step 1.3.27.5.F states
that any
deviation shall be approved
and documented prior to exceeding
the
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overtime restrictions.
Attachment
A includes
a provision for including
justification of the authorization.
By memo dated
May 10,
1985, the
plant manager
approved overtime in excess
of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for a seven
day
period for 72 licensee
and contractor Health Physics
and Chemistry
personnel.
The letter stated that approval'covered
the period May 3 to
July 12,
1985.
The memorandum did not provide documentation of the basis
for granting the deviation.
The memorandum
was submitted to the plant
manager for approval prior to May 5,
1985 but approval documentation
was
delayed for correction of the document and,resubmission
to the plant
manager.
Failure to document approval of'deviation from overtime requirements
prior to the overtime exceeding
the criteria, represents
an apparent
violation of a procedural",requirement
for a T.S. required procedure.
I
Failure to document
the basis represents
an apparent violation of T.S.
6.2.2.f (50-397/85-20-01).
Postin
and Labelin
T.S. 6.11.1 sets forth the requirement'to
prepare
procedures
consistent
with 10 CFR 20 and to approve, maintain and adhere
to these for all
operations involving personnel radiation exposure.
(e)
and (f) set forth posting requirements for radioactive materials
and
radiation areas
and for containers
containing radioactive material.
Plant Procedures
Manual
(PPM) 11.2.7.1,
'Area Posting'tates
in part,
"11.2.7.1.5 ... Radiation Area ... ensure that radiation levels in the
area to be posted are greater
than 2.5 mrem/hour and less than
100
mrem/hour.
All such areas
accessible
to personnel
where
a major portion
of the body could be exposed
to radiation levels greater
than or equal to
2.5 mrem/hr shall be included....
The boundaries
should be at the
perimeter of the 2.5 mrem/hour area.
At each accessible
perimeter...post
a sign bearing the radiation symbol and the words
'CAUTION RADIATION
AREA'."
Plant Procedures
Manual 11.2.14.3
'Storage of Radioactive
Material'tates
in part, "11.2.13.3.5
Procedure ... C.l. The storage
area shall be
labeled at...any accessible side....
Each container shall also be
labeled with...type of material...radiation
levels at contact
and three
feet."
On May 30 at 2:00 p.m. the inspector
observed
the outdoor liquid
solidification work area
was being used to store full radioactive
material shipping containers.
This area is located at the corner of the
radwaste building near the truck bay entrance.
Two barriers,
a chain
with a sign, "Caution Radioactive Material", and a yellow and magenta
rope were both down, both signs were face
down.
Three unlabeled
containers
were observed in the area,
numerous
labeled containers
were
also observed.
The inspector
entered
the area
and made radiation
exposure rate measurements
using
NRC instrument
8015844,
due for
calibration June
15,
1985, Model Eberline
RO-2
SN 2694.
The inspector
measured
a dose rate of 2.9 mR/hr at 18" from the side of a container
identified as 836770.
A contact
(2 inch) measurement
identified a
maximum reading of ll mR/hour.
The inspector contacted
the licensee
and
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requested
that
a survey be performed.
The area
was posted
on the other
sides
as
a radioactive materials area.
No posting was visible as the
inspector walked from the
NRC resident office to the area.
The inspector requested
a copy of the licensee's
survey.
The licensee
provided Survey No. 5-1535-85 which confirmed the inspector's
measurement.
The survey also identified the fact that the containers
were unlabeled.
The exposure rate at the reestablished
barrier was 1.5
mR/hr.
The licensee
used
an Eberline R022,
5'38068,
due for calibration
on September
1,
1985 to perform the survey.
Licensee
measurements
indicated 3.0 to 4.0 mr per hour and a contact reading of 14 mr per hour
at the highest location.
At the exit interview, the licensee
confirmed
that at least
one of the containers
contained
licensed material in excess
of 10 CFR 20 Appendix
C quantities.
The condition existed
as
a result of a job crew and health physics
technician being called to perform a higher priority job before finishing
work with the waste containers.
The condition appeared
to be an isolated
example.
The situation described
above represents
a violation of TS 6.11.1 in that
procedures
implementing
10 CFR 20 requirements
were not adhered
to as
stated
below:
Failure to post
a radiation area represents
a failure to follow PPM
11.2.7.1;
Failure to conspicuously post an area containing radioactive
material exceeding
ten times Appendix
C quantities
represents
a
failure to follow PPM 11.2.14;
Failure to label three containers
represents
a failure to follow PPM
11.2.14.3;
The exemptions permitted by PPM 11.2.14.3
as contained in 10 CFR 20.203(f)(3)
and 20.204 did not apply(50-397/85-20-02)
.
4.
~lza1nfn
Technical Specification 6.4 states in part that a retraining program for
the unit staff shall meet or exceed section 5.5 of ANSI/ANS N18.1-1971.
The inspector
became
aware that eight HP/Chemistry personnel
have not
begun the retraining program.
The two year program is considered
to begin
at the
OL date of Dec'ember
20,1983.
The lisensee
program is described
by
interoffice memorandum dated January
13,
1983, Rhinehart to Graybeal.
This matter was discussed
at the exit interview.
5.
Inde endent Ins ection Effort
The inspector
conducted
tour's
regulatory requirements.
to observe
work and verify compliance with
a.
Tool Control
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Technical Specification 6.8.1.a states
that procedures
shall be
established,
implemented
and maintained for applicable procedures
referenced
by R.G. 1;33,
Rev. 2.
R.G. 1.33,
Rev. 2, Appendix A.9.C
states
that procedures for repair should
be" pr'epared prior to
beginning work.
Section 9'.C.5 lists repair of safety valves
as an
example of such procedures.
Plant procedures
manuaL 1.3.18,
"Tool
and Equipment Control Around Open Plant Systems" is identified by
the licensee
as
"a "safety related" maintenance
pr'ocedure.
This
procedure
references
PPM 10.1.13,. "System Cleanlin'ess
Control".
Procedure
1.3.18 states in part that the purpose is to minimize the
risk of accidental introduction of foreign matter into components of
the primary system by establishing
an accountability
system for
tools and small items of equipment
used in or near (close
enough to
drop in) an open system or component.
Step 1.3.18.4 Precautions
states
that the use of this procedure is .mandatory
when a component
is opened for rework.
Step 1.3.18.7 states in part that all tools
and equipment shall be inventoried and listed as
each tool is carried
into and removed from the work area boundary
and that tools shall be
equipped with a lanyard which is securely fastened
to the operator.
Procedure
PPM 10.1.13 step 8.B.l states
that loose items that could
fall in should be removed.
On Wednesday,
May 29,
1985, between 3:00 p.m.
and 5:00 p.m. the
inspector
conducted
a tour of the drywell to observe posting,
labeling, control of radioactive material and control of work
practice in radiologically controlled areas.
The inspector
observed
work on the feedwater
check valves that was in progress
during the
tour.
The inspector
made the following observations.
Two employees in full protective covering and full face respirators
were working on the valve.
The valve was open, work in progress
appeared
to be removal of the flapper shaft.
Above and
approximately five feet from the open valve were several
deck
grating clips and securing nuts.
The nuts present
appeared
to be
less
than the number of securing clips present.
Loose paper
and
plastic in the general vicinity of the job was present.
The
inspector
observed
the workers attempt to loosen
a large nut on the
valve by striking an adjustable
(crescent)
wrench with a large
hammer.
The inspector
observed
no lanyards
on the hammer
and wrench.
The
inspector did not observe
a tool control or cleanliness barrier in
place.
The inspector discussed
these observations
with a Maintenance
Department Supervisor
and with the, responsible
foreman.
These
individuals told the inspector that abrasive
pads
and crocus cloth
had been introduced into the valve body.
These individuals
confirmed that procedure
1.3.18 had not been implemented for the
check valve gob.
The foreman took immediate steps to
remove loose material from the vicinity of work.
The inspector
was
told that the Maintenance
Supervisor
had not entered
the drywell
during the current outage.
The foreman had not observed
the work
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since prior to the time the valve was opened,
about
2 days.
The
Maintenance
Supervisor attributed the problem of failing to
implement tool control procedures
to the use of a generic procedure,
PPM 10.2.7, for valve maintenance
on safety related
equipment.
The
generic procedure
provided steps addressing
cleanliness
and tool
control but did not specifically address
the tool control
requirements in order to adequately
implement 1.3.18
and 10.1.13.
The matter of use of generic procedures for work on safety related
equipment
was referred to the resident inspector
and Region
V
Project Manager for followup inspection.
Inspector observations
related to management
and supervisory
involvement with an oversight of work activities are discussed
in
section
b of this paragraph.
Failure to implement procedure
1.3.18 represents
an apparent
violation of TS 6.8.1.a
(50-397/85-20-03).
Regulatory Guide 1.33 Appendix A identifies typical safety related
activities that should be covered by procedures
and states
that this
Appendix is not inclusive.
T.S. 6.8.1.g sets forth the requirement
for fire protection program implementation.
The licensee
has
implemented
PPM 1.3.19 housekeeping
to address:
safety; fire
protection;
clean working environment;
equipment protection;
and
contamination control.
This procedure is designated
as safety
related by the licensee.
During plant and drywell tours the inspector
made observations
in
addition to those noted in section
A of this paragraph
as follows:,
inside the drywell, bags of material tools and waste including
broken glass were left at various locations after shift change
on May 29,
1985;
C
inside the drywell, loose plastic presented
a slip hazard;
individuals left contaminated
gloves at the work site
on the
check valve gob after work for the shift had been
'completed;
inside drywell, loose wire used to secure
temporary flooring
presented
a,,'trip hazard;
in the reactor building, wire'nd hose were not always routed
to.prevent
a trip hazard
plastic wire ties
and wire pieces
were observed
on the floors
in the reactor building;
what appeared
to be
a clay mineral sorbent
was used in a catch
pan for pipe threading work on the 572 foot elevation of the
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reactor building near the standby
gas treatment
system.
Some
of the material had spilled from its retaining pan.
Procedure
1.2.19 section 4.A.2 addressed
cleanliness,
storage of
equipment
and the prohibition of "kitty litter" or similar clay
mineral sorbents.
Section B.l address
the requirements
to keep work
areas free of tripping hazards.
Section B.3, Fire Prevention
reiterates
the prohibition of "kitty litter" or similar materials
within the power block.
Regarding
the use of prohibited clay sorbant,
the inspector
identified the individual who brought the material in from the
Bechtel fabrication shop.
This individual and his supervisor,
both
Bechtel employees
were not aware of the prohibition.
The inspector
observed this material in place
on May 29 and 30.
The
material was in place for an indeterminate
period of time prior to
the inspector's
observation.
The material is clearly visible and
should have been noticed by licensee
employees.
Use of this
material, prohibited by PPM 1.3.19, represents
an apparent violation
of TS 6.8.1
(50-397/85-20-03
).
In attempting to determine
a root cause for these violations, the
inspector noted that numerous individuals should have had the opportunity
to observe this condition.
Regarding general housekeeping
observations,
the inspector noted that the Maintenance
Supervisor questioned
had not
entered
the drywell since the beginning of the outage about
May 1st.
Of
the Health Physics Manager,
HP Supervisor
and
HP Foremen,
only the
Supervisor
had made
one entry since the beginning of the outage.
The
Plant Manager
and Assistant Plant Manager had not entered
the drywell
either.
The inspector also noted that the Health Physics
Manager delegated his
responsibility to perform a monthly housekeeping
inspection.
Procedure
1.3.19
does not identify this responsibility as
one that may be
delegated.
The factors contributing to the violations identified in this paragraph
appear related in part to a lack 'of management
attention to work in
progress
as evidenced
by failure of several, management
individuals to
observe work within the drywell.
This matter was discussed
at the exit
interview.
Two examples of failure to follow procedures
required by TS 6.8.1 were
identified (50-397/85-20-03'.
Radiation Protection Activities
The inspector
observed
exposure control practices,
use of respiratory
protective equipment, air sampling
and sample results,
surveys for work,
survey records, radiation work permits,
surveys for release of material,
use of improved portal monitors and control of work in radiologically
controlled areas.
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The inspector did not identify any problems in control of work in
radiologically controlled areas
and noted the'P
programs
appear
to be
effectively implemented for outage activities.
Three observations
were
brought to their attention:
No procedure or program to control temporary shielding is in place.
The inspector discussed
industry practice with the
HP manager;
Documentation of airborne surveys
does not adequately
describe
the
type of sample,
e.g. breathing
zone,
work area,
general area.
requires that concentrations
inhaled through
respirator
be known.
Surveys
should therefore specifically identify
breathing
zone samples
as such;
Records of surveys required for release
of potentially radioactive
material from licensee control may not be adequate
in some cases.
Procedures
to implement the documentation
requirement for surveys of
material being released
may not be adequate.
Inspection item 85-03-01 regarding portal monitor sensitivity is closed
with the licensee installation of frisking booths.
No violations or deviations were identified.
7.
Post Accident
Sam lin
Pro ram
During the inspection,
data to support independent
evaluation of
potential iodine plate out in the reactor building post
LOCA sampler
(NUREG 0737, Item II.F.1.2) was requested.
Subsequent
to the inspection,
the licensee
reported
by telephone that in gathering this data they
became
aware that the sample line is heat traced for freeze protection to
only fifty degrees
F.
The licensee
also confirmed the fact that no
plateout correction factors are applied to the iodine sample result.
The
licensee
stated their verbal position that none are required for this
monitor and agreed
to forward in about
two weeks the basis of their
position.
The inspector considers this matter unresolved until the. licensee's
evaluation
and other information can be examined.
This matter was
discussed
in a telephone
conversation
on June 6,
1985 (unresolved,
50-397/85-20-04).
8.
Unresolved Item
An unresolved
item is one about which more information is required in
order to ascertain
whether it is an acceptable
item,
a violation , or a
deviation.
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8.
Exit Interview
An exit interview was conducted
on May 31,
1985.
Individuals in
attendance
are identified in paragraph
one of this report.
The scope
and
findings of the inspection were summarized
by the inspector at that time.
Findings in the radiation protection area related to program improvement
were presented.
Regarding overtime,
the inspector noted that two individuals had worked
15 and
20 consecutive
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days.'he
inspector also noted that
failure to document
the basis for granting the exemption represented
an
example of not paying adequate
attention to the letter of a regulatory
requirement
and that this general finding had been identified in previous
inspections.
The licensee
representative
stated
they would examine the
overtime issue.
The licensee representative
also responded
by providing corrective
actions including formal employee contact for corrective action,
completion of a radiolog'ical "occurrence report and prompt correction of
the condition.
The licensee also offered to bring this matter to the
other technicians attention for the value of lessons
learned regarding
compliance after this was suggested
by the inspector.
Regarding tool control, the licensee
agreed that'he procedure identified
applied to work on the feedwater
The inspectors
observations
on housekeeping,
.possible~"improper
use of tools and
isolation of clean systems
was brought to the licensee's
attention.
The inspector's
concern about management failure to observe
and control
work activities within the drywell was expressed.
Regarding
use of prohibited, material within the power block, the plant
manager
described
an ongoing program to identify potential contaminants
and to use
teams to periodically search for prohibited materials.
The
plant manager characterized
the example noted
as a singular occurrance
caused
by a craft person.
The licensee representative
Stated that safety fire protection
and
housekeeping
inspections
would include the drywell in the future.
t
The matter involving plateout correction factors was discussed
subsequent
to the inspection.
The licensee
was not specificallly informed that the
matter is considered
unresolved.
Regarding training of health physics personnel,
the
HP manager
acknowledged
the inspectors
observations
and indicated that action would
be taken.
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