ML17284A562
| ML17284A562 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/04/1988 |
| From: | Cicotte G, North H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17284A560 | List: |
| References | |
| 50-397-88-33, NUDOCS 8810210612 | |
| Download: ML17284A562 (14) | |
See also: IR 05000397/1988033
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No. 50-397/88-33
Docket No. 50-397
License
No.
Licensee:
Washington Public Power Supply System
P.
0.
Box 968
Richland,
99352
Facility Name:
Washington Nuclear Project
No.
2
Inspection at:
WNP-2, Benton County, Washington
Inspection
Conducted:
September
6-9,
1988
Inspectors:
Approved by:
G.
R. Cicotte, Radiation Specialist
H.
S. North, Acting Chief
Facilities Radiological
Protection Section
ro sag
Date Signed
Pz
Date
igned
~Summar:
Ins ection durin
eriod of Se tember 6-9
1988
Re ort No. 50-397/88-33
Areas Ins ected:
Routine,
unannounced
inspection
by a regionally based
inspector of organization
and management
controls,
followup, gaseous
waste,
and tours of the facility.
Inspection procedures
30703,
83722,
92701,
84724,
and 83726 were addressed.
Results:
Of the four areas
addressed,
no violations were identified in three
areas.
In one area,
a violation of Technical Specification 3.3.7. 12 was
identified, regarding failure to sample the main plant vent for radioactivity
(see paragraph
4).
Additionally, it was noted that housekeeping
procedures
do
not appear to address
material condition of the primary containment during
plant operation
(see
paragraph
5).
Overall, the licensee's
programs
appeared
capable of meeting the safety objectives.
SS102i06i2
SSi006
ADOCK 05000397
Q
DETAILS
1.
Persons
Contacted
C.
M. Powers,
Plant Manager
"J.
W. Baker, Assistant Plant Manager
"J.
D. Arbuckle, Plant Compliance
Engineer'L.
Bradford, Health Physics Supervisor
"T. A. Brun, Plant guality Assurance
Engineer
A. I. Davis, Senior Radiochemist
"R.
G. Graybeal,
Health Physics/Chemistry
Manager
- A. G. Hosier,
Licensing Manager
"R.
L. Koenigs, Technical
Manager
"D. A. Larson, Radiological
Programs/Instrument
Calibration Manager
"C.
H. McGilton, Manager Operational
Assurance
and Programs
S.
L. McKay, Operations
Manager
J.
D. Mills, Senior Health Physicist
D.
A. Pisarci k,
ALARA Supervisor
"V. E. Shockley,
Health Physics
Support Supervisor
Contractors
"W.
E.
Milbrot, Engineer,
Bonneville Power Authority
In addition to the individuals identified above,
the inspectors
met and
held'iscussions
with other
members of the licensee's
staff and
personnel.
"Denotes those present at the exit interview held on September
9,
1988.
2.
Or anization
and
Mana ement Controls
The following procedures
were reviewed
and aspects
thereof discussed
with licensee
personnel:
Procedure
Revision
Date
111
l. 1.2,
1.1.3,
1.1.6,
Management Organization
Plant Organization
Plant Responsibilities
Plant
ALARA Committee
3
6
10
3
3-2-87
3-23"87
3-23"88
3-31-87
The licensee
had
made several
recent
management
assignments,
including a new ALARA Supervisor,
a new Manager of the Nuclear
Safety Assurance
Group
(NSAG), a new Plant Technical
Manager,
and
a
new Assistant Maintenance
Manager.
The above
noted individuals
appeared
to meet the qualification requirements
of ANSI/ANS 3. 1,
Selection
uglification
and Trainin
of Personnel
for Nuclear
Power Plants, with respect to radiological safety responsibilities.
Those individuals with whom responsibilities
were discussed
were
observed to be aware of their responsibilities.
B.
~Staff in
Several
of the licensee's
Health Physics
(HP) staff stated that the
HP department
was understaffed relative to the unplanned
outage
then
in progress.
The inspector
noted that almost all the
HP technicians
had worked the maximum overtime hours allowed by the licensee's
procedures,
during the outage which had occurred
due to valve
leakage
exceeding
the Technical Specification
(TS) limit.
Although
some delays
were experienced
as
a result of technician assignments,
no examples of failure to provide adequate
HP surveillance
were
observed.
The licensee
normally hires
and trains contractor Health
Physics Technicians
(HPT) during extended
outages.
C.
Health
Ph sics/Chemistr
Mana er
(HP/CM)
The qualifications of the
HP/CM were observed to be consistent with
ANSI/ANS 3. 1.
Licensee
procedures
(such
as in paragraph
2.A, above)
address
the HP/CM's responsibility and authority to carry out the
Health Physics
and Chemistry Programs.
See also Inspection
Report
50-397/88-26,
paragraph
5.
The organization
appeared
capable of
meeting their safety objectives.
Other aspects
of the licensee's
organization
and management
controls will
be examined in a subsequent
inspection.
No violations or deviations
were identified.
3.
~fol 1 owo
50-397/88-22-03
(Open) Strip chart recorder operation
on ARM-RR-600, for
Area Radiation Monitors (ARMs), was observed
(see Inspection
Report
50-397/88-22).
The three ink colors
had again
begun to merge
such that
banks of ARMs were difficult to distinguish.
This matter will remain
open for review of pending maintenance/modifications
(50-397/88-22-03
Open).
50-397/88-22-06
(Closed) This matter concerns
an observed
tendency
by
plant personnel
to leave radiological postings
down after removal for
access.
The licensee
had proceduralized
a requirement that all personnel
accept responsibility for replacing postings after exiting or entering
a
posted
area.
One instance of workers leaving the posting
down for
a
radiation area
was observed.
This was immediately corrected
by the
individual responsible
when it was brought to their attention.
Since the
incidence of such posting removals
had declined significantly, this
matter is considered
closed
(50-397/88-22-06
Closed).
50-397/85-20-'4
(Unresolved) This matter refers to evaluation of iodine
plateout in plant effluent sampling lines under accident conditions.
The
licensee
had issued
a Request
for Proposal
(RFP) to a contractor
who had
previously done
some preliminary work on the issue.
The
RFP encompassed
testing which would require outage conditions.
The licensee
stated
they
expected to do the work during the 1989 refueling outage.
The licensee
further stated that computational
studies of iodine behavior within the
sample lines
and equipment would await an evaluation of the test data.
This matter will remain
open pending the licensee's
test results
(50-397/85-20-04
Unresolved).
An unresolved
item is one about which more information is required in
order to determine if it is an acceptable
item,
a deviation, or a
violation.
Inspection
Report 50-397/88-26,
paragraph
6,. discussed
the licensee's
respiratory protection training.
During the inspection,
the General
Employee Training (GET) Supervisor
discussed
a concern
expressed
by the
inspector in regard to special training for self-contained
breathing
apparati
(SCBA).
The discussion
resulted in the conclusion that the
footnote of 10 CFR 20 Appendix A, referred to in the report,
was
applicable for a type of SCBA not used
by the licensee,
and that the
licensee's
training meets
the minimum requirements
of 10 CFR 20. 103(c).
No violations or deviations
were identified.
Gaseous
Waste
S stems
On September
7, 1988, at approximately
6:ll P.M.
PDT, the Reactor
Building (RB) exhaust ventilation fan,
REA-FN-lB, failed and normal
ventilation
was secured.
The Standby
Gas Treatment
System
(SGTS)
was
started at 6: 19 P.M.,
PDT on September
7,
1988, in order to partially
restore ventilation flow.
Discussion with the licensee
revealed
the
following:
The licensee identified a failure to initiate alternate
sampling
within four hours in accordance
with Technical Specifications (TS) 3.3.7. 12,
and stopped
the unmonitored release
at 4:48 A.M., PDT on
September
8, 1988.
o
The licensee
restored
normal
RB ventilation and sampling after
making repairs at approximately 5:00 A.M., PDT on September
8,
1988.
TS 3. 3. 7. 12 states,
in part:
"3.3.7. 12 The radioactive
gaseous, effluent monitoring instrumentation
channels
shown in Table 3.3.7. 12-1 shall
be
OPERABLE with their
alarm/trip setpoints
set to ensure that the limits of Specification
3. 11.2. 1 are not exceeded.
The alarm/trip setpoint of these
channels
shall
be determined in accordance
with the methodology
and parameters
described
in the
ODCM.
APPLICABILITY:
As shown in Table 3. 3. 7. 12-1.
ACTION: "
"b.
With less than the minimum number of radioactive
gaseous
effluent
monitoring instrumentation
channels
OPERABLE, take the
ACTION shown
i n Tab 1 e 3. 3. 7. 12-1. "
I'TABLE 3. 3. 7. 12-1
RADIOACTIVE GASEOUS
EFFLUENT MONITORING INSTRUMENTATION
INSTRUMENT
MINIMUM
CHANNELS
APPLICABILITY ACTION..."
"3.
Main Plant Vent Release Monitor..."
~
IIb
C.
d.
e.
Iodine Sampler
Particulate
Sampler
Effluent System
Flow Rate
Monitor
Sampler
Flow Rate Monitor
"TABLE NOTATIONS"
112
112
113
113"
""At al 1 times. "
"ACTION 112
ACTION 113
With the number of channels
OPERABLE less
than
required
by the Minimum Channels
requirement,
effluent releases
via this pathway
may
continue for up to 30 days provided that within 4
hours after the channel
has
been declared
samples
are continuously collected with auxiliary
sampling equipment
as required in Table 4. 11-2.
With the
number of channels
OPERABLE less
than
required
by the Minimum Channels
requirement,
effluent releases
via this pathway
may
continue for up to 30 days provided that the flow
rate is estimated at least
once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."
The Senior Resident Inspector's
(SRI) discussion with the
on shift
operations
personnel
revealed that the chemistry department,
which is
responsible
for obtaining effluent samples
and for maintaining the
auxiliary sampling equipment
as called for by ACTION 112 of TS 3.3.7.12,
was not specifically informed that the main plant release
monitor,
REA-SR-37,
was inoperable.
The specific operator
involved stated to the
SRI that
he had missed the procedural
step to declare
REA-SR-37
Licensee
procedure
PPM 2. 10. 1, Reactor Buildin
HVAC,
Revision B,,dated 6-17-88, states
in part:
"2.10.1.4 Limitations..."
"...E. If Reactor Building ventilation is lost and
SGT is supplying
Reactor Building ventilation, declare
REA-SR-37
INOP (too low flow),
Technical Specification 3.3.7.12."
PPM 4. 10. l. 1, Reactor Buildin Ventilation Failure,
Revision 5, dated
8-2-88, states
in part:
"4. 10. 1. 1.4 Subse
uent
0 erator Action..."
"...C.
Declare
REA-SR-37
INOP.
(Not enough flow through the sample rack
with only SGT running.)"
Through discussion with the Senior Radiochemist
(SRC),
and review of
previous revisions of PPMs
2. 10. 1 and 4. 10. 1. 1, it was determined that
REA-SR-37
becomes
inoperable with only SGTS flow while in automatic flow
control.
The automatic function is designed to meet the requirement to
know the sample/effluent flow ratio,
as delineated
in TS Table 4. 11-2,
table notation "e.", by holding the ratio'onstant.
The automatic
function becomes
less accurate at lower flow rates,
such
as 10,000
CFM,
and apparently
does not function at a flow of 4,000
CFM, which is the
maximum
SGTS flow.
As a result of the occurrence,
the
SRC had submitted
a Technical
Evaluation Request
(TER) for evaluation of a proposed
modification that would hold sample flow rate constant
below a specified
effluent flow rate.
The ratio would then
have to be calculated for each
period in which the effluent flow varied, but would remain operable at
low effluent flow rates.
Further review revealed that the procedures
had
been revised
as corrective
action for Non-Conformance
Report
(NCR)
¹288-153,
dated 5-7-88.
During testing of
RB normal ventilation on May
7, 1988,
the licensee
secured
the ventilation
fans
and started
SGT to
maintain ventilation.
In this instance also,
the Chemistry Department
was not informed that REA-SR-37 was inoperable,
and main plant vent
release
continued for approximately six hours without continuous
sampling
with the auxiliary equipment.
The licensee
stated that the procedural
change
had been
intended to prevent recurrence.
Although in both events,
the noble gas low/intermediate
range monitoring channels
were also
the time limitation of eight hours to obtain
a grab
sample
was not exceeded.
The high range
noble
gas monitor is situated in the
effluent stream
and was thus not affected,
and very large releases
could
have
been detected.
The May 7, 1988, event was not reported in the January to June
1988
Semi-Annual Effluent Re ort
SAER
, dated August 10,
1988.
It was,
however,
reported in an addendum
dated
August 26,
1988, within the
60 day
time limit for the
SAER.
Also, in the July to December
1987
SAER, the
licensee
reported that on August 11, 1987, action
112 of TS Table
3.3.7. 12-1 for the
Radwaste
Building (RWB) was not met, in that the
sample rack was
removed from service for maintenance,
the auxiliary rack
was not used,
and
an unmonitored release
continued for seven
hours.
In accordance
with 10 CFR 2 Appendix C, Part V, Enforcement Actions,
Subpart
G, Exercise of Discretion, notices of violation are not normally
issued for licensee-identified
violations meeting certain criter ia.
However, criterion "e." thereof reads:
"e. It was not a violation that could reasonably
be expected to have
been prevented
by the licensee's
corrective action for a previous
violation."
As the corrective action for the
May 7, 1988,
event did not appear to be
effective in preventing the September
7, 1988, event,
which appears
to be
a violation of TS 3.3.7. 12 (50-397/88-33-01).
No other violations or deviations
were identified.
s.
Faci1 it
Tours
Tours of the
RWB,
RB, and Turbine Building (TB) were conducted.
Independent
radiation surveys
were performed with an
NRC ion chamber
survey instrument
model
R0-2, Serial
No.
009154, calibrated 8-12-88
and
due for calibration 11-12-88.
The licensee
stated that during power level increase
above
20K to 30K,
the
HPTs replace certain radiation area postings in the
TB with high
radiation area postings in anticipation of dose rate changes
as power
increases.
One sign,
on a locked door on a stair landing leading to the
reactor feedwater
heater
bay,
appeared
to have
been missed.
A survey of
the area to which the door lead,
however,
revealed that dose rates
had
not yet resulted in an actual
high radiation area outside posted
areas.
At 40K power,
readings at 18" from several
components
were approximately
95 mr/hr on both the
NRC and licensee
instruments.
Housekeeping,
with the exception of the matter discussed
below exhibited
evidence of continued attention
(see
Inspection
Report 50-397/88-28
paragraph
5).
Some areas
which had remained
contaminated for long
periods
had been decontaminated,
and the licensee
was in the process
of
repainting several
pump
rooms in the
RB.
Personnel
actions at the Primary Containment ("Drywell") (D/W) control
point were observed.
Three individuals just exiting the
D/W touched
their faces,
glasses,
or other exposed parts while undressing.
The
HPT
was informed,
and counseled
the workers.
None appeared
to be
contaminated
when performing whole body frisks.
One appeared
to be
suffering from heat stress,
and
was treated
by accepted
methods.
The
worker appeared
to improve slightly, but the Safety Department
was
informed and the worker was evacuated
on a stretcher.
The licensee later
stated that the worker had suffered
a mild heart attack.
Licensee
briefings
and measures
to control heat stress,
such
as ice vests,
heat
stress
stay times,
and careful observation
by HPTs and safety personnel
appeared
appropriate
to the level of hazard present.
The
HP Supervisor
later stated
to the inspector that the individual who had experienced
the
heart attack
had been briefed,
had been specifically counseled
by his
supervisor that his entry was inadvisable,
and
had objected to being
prevented
from making the entry on the basis that it would be
age
discrimination should
he be so prevented.
The licensee
had
removed the flashing yellow lights from the east
and
west valve galleries of the 467'levation
RWB, without removing the
scaffolding from above the locking gate (east) or installing the
anti-tamper device (west)
as discussed
in Inspection
Report 50-397/88-28,
and as committed to by the licensee
as corrective action for a violation
of TS 6. 12.
A survey conducted jointly by the licensee
and the inspector
determined that dose rates in the east valve gallery did not exceed
1000
mr/hr at 18" from the source.
Although a similar survey in the west
valve gallery revealed
a dose rate of 1200 mr/hr at 18" from the source
on both the licensee
and
NRC instruments,
the inspector determined
upon
entering
the
room that the lock was not of the
same type as in the east
valve gallery,
and
was of a design
such that it appeared
to adequately
prevent unauthorized entry (the lock could not be operated
from either
side without a key).
The
HPT accompanying
the inspector
and the
Supervisor
had not previously been
aware of the type of lock used.
The matter described
above
was discussed
with the
HP Supervisor,
who
stated that the scaffolding would be removed
as
soon
as possible
and that
in spite of the non-tamper
nature of the lock on the west valve gallery,
a non-tamper
screen
would still be installed.
Licensee
procedure
PPM 1. 11.3, Health
Ph sics
Pro ram, Revision 4, dated
4-4-88, provides authority to HPTs to stop work or otherwise direct the
activities of others
under their surveillance.
During a walkdown
inspection
by the licensee,
performed to confirm material condition of
and to verify repairs to reactor
coolant
boundaries, it was observed that the Shift Support Supervisor
(SSS) did
not quickly respond to requests
by the
HPT assigned
as escort in the high
radiation area.
Several
times the
HPT requested
that he and another
individual pass
through or quickly exit very high radiation fields.
The
HPT repeated
one
such request
three times before the
SSS complied.
Efforts to work expeditiously appeared
to be affected
by a lack of
familiarity by the
and operator with the location of some of the
components
being inspected.
The inspector
expressed
concern to the Shift Manager
(SM) that personnel
appeared
to be unresponsive
to
HP requests
during work involving very
high radiation
dose rates.
The
SM stated that the matter would be
discussed
with the
SSS.
During the walkdown of the
D/W noted above,
on September
6, 1988, the
inspector
and
a resident
inspector
had accompanied
licensee
personnel.
The reactor
was at approximately
3X power in order to maintain
temperature
and pressure
consistent with the normal operating condition
of the components
which were repaired during the outage.
Access controls
and
HPT coverage
were observed
to be consistent with licensee
procedures.
While in the
D/W, the inspector
observed that
some equipment
and
materials
remained in the
D/W, apparently left over
from the outage
work.
The material
was brought to the attention of the
SM after the inspectors
exited the
D/W.
Subsequent
to that
D/W inspection,
the licensee
shut
down the reactor
and
performed minor corrective maintenance
in the
D/W, then started
the
reactor
and conducted
a subsequent
3X power (1000 psi reactor pressure)
entry and walkdown.
The inspector again accompanied
the licensee,
and
noted that most of the material previously observed
had remained in the
D/W.
As the
HP, the operator,
and the inspector were about to exit the
548'levation of the
D/W, the inspector
asked the operator if the
material visible on that elevation
was allowed to remain in the
D/W
during operation of the reactor.
He stated that it was not,
and the
following material
was
removed:
2 pieces of 3/4" rope approximately 25'ong
1 piece tangled bailing wire
1 desk telephone with approximately 100'f cable
1 piece of U-channel
bracket,
approximately
2" x 2" x 14"
1 extension light, bagged in yellow polyethylene plastic
2 small plastic bottles
(empty)
2 small plastic
bags containing debris
Additionally, a string of waterproof lights had been
observed at the
handrail
near
the
2A2 recirculation
pump motor.
This light string
appeared
capable of withstanding
D/W conditions during operation,
and was
attached
to the handrail with plastic tie-wrap type looms.
This was not
removed prior to reactor
power operation..
The matter
was discussed
with the licensee.
The licensee
stated at the
exit interview that they were aware of no specific analysis of material
left in the
D/W during operation, with respect to internal missile
hazards,
downcomer restriction, or equipment
impairment.
The Final
Safety Analysis Report
(FSAR) does
not address
the situation of unsecured
material
being left in the
D/W.
Given the small
volume of material,
and
based
on discussion with the Region
V Reactor Projects
Section Chief, it
was later determined that the safety significance
from the above noted
Revision 9, dated 5-29-87,
does
not address
specific areas
as to
responsibility.
It states
that responsibilities
are divided among work
groups
based
on normal
occupancy.
The
D/W is not a normally occupied
area during operation.
No other licensee
procedures
appeared
to address
the issue.
The resident
inspectors will continue to conduct routine
inspection of this area.
Surveys of material exiting the Radiologically Controlled Area
(RCA) were
observed.
Examples of equipment
being briefly surveyed
were observed.
The extent of each survey appeared
to be dependent primarily upon the
amount of material to be surveyed, i.e.,
more material
received less
surveying per item.
This was discussed
with lead
HPTs on shift at the
time of the observations,
who then issued instructions to be more
thorough.
With the exception of the matter discussed
in paragraph
3, radiological
postings
were observed to be in compliance with 10 CFR 20.203,
Caution
si
ns
labels
si nals
and controls.
The licensee's
program appeared
capable of meeting the safety objectives.
No violations or deviations
were identified.
Exit Interview
The inspector
met with those individuals denoted in paragraph
1 at the
conclusion of the inspection
on September
9, 1988.
The scope
and
findings of the inspection
were summarized.
The licensee
acknowledged
the apparent violation discussed
in paragraph
4, above.
The licensee
was
informed that the unsecured
material in the primary containment during
operation
was considered
to be an unresolved
item.
Subsequent
post-inspection
review resolved the matter
as noted in paragraph
5,
above.