ML17284A651
| ML17284A651 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/04/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| 50-397-98-04, 50-397-98-4, EA-98-311, NUDOCS 9806100301 | |
| Download: ML17284A651 (16) | |
See also: IR 05000397/1998004
Text
UNITEDSTATES
NUCLEAR REGULATORY COMMISSION,
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011 8064
3une 4,1998
EA 98-311
Mr. J. V. Parrish (Mail Drop 1023)
Chief Executive Officer
Washington Public Power Supply System
P.O. Box 968
Richland, Washington
99352-0968
SUBJECT:
NRC INSPECTION REPORT 50-397/98-04 AND NOTICE OF VIOLATION
Dear Mr. Parrish:
Thank you for your letter of May 6, 1998, in response to our letter and Notice of Violation dated
April 8, 1998. We have reviewed your reply and noted your denial of the violation related to the
quality assurance
oversight of the radioactive eNuent monitoring program. We also reviewed
the information you provided concerning the actions taken or proposed as a result of the
violation. As a result of our review of the information, we concluded that the violation occurred
as stated in the Notice of Violation. Our analysis of your response
is included in the enclosures
to this letter.
We find the actions you have taken and those you have proposed responsive to the concern
raised in our Notice of Violation. As a result, no further response to the violation is necessary.
We willreview the implementation of your corrective actions during a future inspection to
determine that full compliance has been achieved and willbe maintained.
Sincerely,
Arthur T. Howell III, Director
Division,of Reactor Safety
Docket No.:, 50-397
License No.:
cc w/enclosures:
Chairman
Energy Facility Site Evaluation Council
P.O. Box 43172
Olympia, Washington
98504-3172
98065.0030i'80604
ADOCK 05000397
6
Washington Public Power
Supply System
Mr. Greg O. Smith (Mail Drop 927M)
WNP-2 Plant General Manager
Washington Public Power Supply System
P.O. Box 968
Richland, Washington
99352-0968
Mr. D. W. Coleman (Mail Drop PE20)
Manager, Regulatory Affairs
Washington Public Power Supply System
P.O. Box 968
Richland, Washington
99352-0968
Mr. Albert E. Mouncer (Mail Drop 396)
Chief Counsel
Washington Public Power Supply System
P.O. Box 968
Richland, Washington
99352-0968
Mr. Paul Inserra (Mail Drop PE20)
Manager, Licensing
Washington Public Power Supply System
P.O. Box 968
Richland, Washington
99352-0968
Perry D. Robinson, Esq.
Winston & Strawn
1400 L Street, N.W.
Washington, D.C. 20005-3502
0
Washington Public Power
Supply System
DISTR BUTI
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WNP-2 Resident Inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
WCFO File
MIS System
RIV File
RIVAl File (¹98 -185)
DRS Al File (¹98-185)(98-G-0059)
OEDO RIVCoordinator (MS 17G21)
OE:EA File
G. F. Sanborn, EA File
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WNP-2 Resident Inspector
DRS Director
DRS Deputy Director
DRP Director
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Dl TRIB TION w
nclosures:
DCD (IE06)
WNP-2 Resident Inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
WCFO File
MIS System
RIV File
RIVAI File (¹98 -185)
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OEDO RIV Coordinator (MS 17G21)
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ENCLOSURE
During NRC Inspection 50-397/98-04 conducted on March 17-1 9, 1998, a violation of NRC
requirements involving the quality assurance
oversight of the radioactive effluent monitoring
program was identified.
Res at men of the Viol ion:
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, QuaiiTication, 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."
Contrary to the above, personnel reviewing the Radiological Effluent Monitoring Program as part
of the 1997 Quality Assurance Audit 297-073 did not have experience or training in the special
nature of the activities audited.
Specifically, the auditors did not have chemistry sampling and
analysis experience or training dealing with the Offsite Dose Calculation Manual requirements.
0
ENCLOSURE 2
The licensee denied that a violation occurred and provided the following response:
License
's Res
onse:
The Supply System denies this violation because the WNP-2 licensing basis contains no
specific requirement that an eNuent audit team include a radiochemist.
In conducting NRC Inspection 50-397/98-04, the NRC compared a 1996 audit which included
the Offsite Dose Calculation Manual as well as the Radiological Environmental Monitoring
Program and the Radiological ENuent Monitoring Program to the 1997 audit of only the
Radiological Environmental Monitoring Program and Radiological Effluent Monitoring Program.
After a review of procedures and audit scope of the 1997 Quality Assurance Audit 297-073, the
Supply System believes that the requirements in Quality Assurance Procedure QAP-7,
"Personnel Indoctrination, Training, Qualification, and Certification," Revision 6, were met.
The audit was performed in accordance with the written procedures and checklists.
Personnel
selected to perform the eNuent monitoring portion of the audit had the experience and training
commensurate with the scope, complexity, and nature of the activities to be audited.
Subsequent to receipt of the inspection report, an evaluation of the qualifications of the
individuals assigned to the checklist questions for eNuent, monitoring activities was performed.
This comparison verified that appropriately trained and qualified individuals had been assigned.
The checklist questions were focused on activities such as ensuring written procedures or
instructions were in place and reflected base requirements and that problem trending was
performed and corrective actions identified.
The auditor evaluated performance-based
activities on a limited scope due to scheduling
restraints that provided only a few opportunities to make these type of assessments.
Those that
were performed did not include activities that would require a specific knowledge of chemistry or
offsite dose calculations.
The Supply System conducted this audit to include both the Radiological Environmental
Monitoring Program as well as the Radiological ENuent Monitoring Program, but [the audit] was
not scoped to satisfy the 24-month Offsite Dose Calculation Manual audit. A qualified
radiochemist was assigned to this joint team with the primary responsibility to assess
activities in
the Radiological Environmental Monitoring Program portion of. the audit. However, this individual
performed informal reviews of the overall audit plan, checklist questions, and final report
including the effluent monitoring portion. He attended all team meetings where audit activities
and concerns were discussed.
These team meetings are designed to serve as an information
sharing forum and allow for expertise and knowledge of individual team members to be used as
a resource by the entire team.
Although it is the Supply System position that the procedure requirements were met, the quality
and scope of the audit did not meet with management expectations.
The basis for including
radiochemistry experience on eNuents audits can be traced to Regulatory Guide 4.15.
WNP-2
does not currently have a licensing basis position on Regulatory Guide 4.15.
However, Quality
Management believes it is appropriate to include a person with experience in radiochemistry and
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monitoring techniques on Radiological Environmental Monitoring Program and Radiological
Effluent Monitoring Program audits in the future.
To address concerns with the scope of the 1997 audit, Quality Management has directed that
the audit be reopened to include performance-based
observations of selected chemistry
activities associated with radiological effluents. The increased scope willinclude counting room
quality control, process monitor calibrations, sample collection and analysis, and laboratory
equipment functional checks and calibrations. The expanded audit willbe completed by May 7,
1998, and willinclude a qualified radiochemist on the team.
The following additional actions willbe taken to address management concerns:
1.
Revision to SWP-ASU-01 to require a radiochemist be assigned to effluent audits.
If
both audits are performed at the same time, one radiochemist would be sufficient to
provide technical exp'ertise.
Ifthese audits are performed independently, a radiochemist
willparticipate in each audit.
2.
Review of WNP-2 required audits to determine ifany additional audits need
supplementing with subject matter experts.
3.
Establishment of a WNP-2 licensing basis position statement of Regulatory Guide 4.15.
ENCLOSURE 3
NRC's R view of the Licensee's Res
o se:
The licensee denies the violation because the licensing bases contain no speciTic requirement
that an effluent audit team include a radiochemist.
The licensee, states that the basis for
including radiochemistry experience on effluents audits can be traced to Regulatory Guide 4.15,
to which the licensee was not committed.
The NRC acknowledges that there was no requirement for a radiochemist to be included on the
audit team.
During the inspection, the inspectors acknowledged that the licensee had not
committed to followthe guidance of Regulatory Guide 4.15. Neither radiochemists nor
Regulatory Guide 4.15 were referenced
in the Notice of Violation. The Notice of Violation stated
that auditors had neither experience nor training in the major areas being reviewed during the
audit.
Through the "Operational Quality Assurance Program Description (WPPSS-QA-004),"
Revision 11, the licensee committed to the qualification requirements for audit personnel as
outlined in Regulatory Guide 1.146, "Qualification of Quality Assurance Program Audit
Personnel for Nuclear Power Plants," August 1980.
Regulatory Guide 1.146 states that the
requirements in ANSI/ASME N45.2.23-1978 are acceptable.
The licensee implements the
qualification requirements in ANSI/ASME N45.2.23-1978 through Quality Assurance
Pro'cedure QAP-7, "Personnel Indoctrination, Training, Qualification, and Certification,"
Revision 6. As stated in'the Notice of Violation, Quality Assurance Procedure QAP-7 requires,
"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."
According to quality assurance
personnel interviewed during the inspection, auditors that
conducted the Radiological Effluents Program audit had no experience or training related to
radiological effluent monitoring.
The licensee argues that ifthe scope of the audit is made sufficiently narrow, auditors with no
knowledge of the activities audited meet the qualification requirements.
The NRC does not find
this approach acceptable.
10 CFR Part 50, Appendix B, Criterion XVIII,requires, in part, that
audits be conducted to determine the effectiveness of the program. An audit in which the
auditors are not familiarwith the activities audited provides little insight into the effectiveness of
the program.
The Radiological Environmental Monitoring Program audit and the Radiological Effluent
Monitoring Program audit were conducted simultaneously.
The licensee argues that a
radiochemist assigned to the Radiological Environmental Monitoring Program audit performed
informal reviews of the overall audit plan, checklist questions, and final report, including the
effluent monitoring portion. The licensee also states that the radiochemist attended audit team
meetings in which audit activities and concerns were discussed.
However, presumably because
of the informality of these interactions, the inspectors identified no objective evidence to
demonstrate that the radiochemist offered any input into the Radiological Effluent Monitoring
Program audit.
.1&
~ ~ '
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Conclusion:
A violation of regulatory requirements occurred as described.