ML17285A231

Responds to NRC 890105 Ltr Re Violation Noted in Insp Rept 50-397/88-41.Corrective Actions:Applicable Operations & Chemistry Procedures Re Timing for Sampling & Analysis of Drywell for All Venting & Purging Operations Changed

ML17285A231
Person / Time
Site:	Columbia
Issue date:	02/03/1989
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GO2-89-014, GO2-89-14, NUDOCS 8902100248
Download: ML17285A231 (13)

Text

WASHINGTON PUBLIC POWER SUPPLY SYSTEM .

P.O, Box 968 ~ 3000 George ll'ashinglon Nay ~ Richland, 'il'ashhtgto>r 993SZ February 3, 1989 G02-89-014 i+ ~ ~+ ft ~ ~ e t Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk, Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21 NRC INSPECTION REPORT 88-41 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in your letter dated january 5, 1989. Our reply, pursuant to the provi-sions of Section 2.201, Title 10,,Code of Federal Regulations, consists of this letter and Appendix A {attached).

In Appendix A, each violation is addressed with an explanation of our position regar ding validity, corrective action and date of full compliance.

Very truly yours, G. C. Sorensen, n er Regulator y Progr am JDA/bk Attachments cc; JB Martin - NRC RY NS Reynolds - BCPgR RB Samworth - NRC DL Williams - BPA NRC Site Inspector

- 901A

tKVFI OVV Oil CONC '89 ~ 92m l5 l5l 47 (e Appendix Page 1 of A

4 APPENDIX A Dur ing an NRC inspection conducted November 28-December 2, and December 12-16, 1988, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), as modified by 53 Fed. Reg. 40019 (October 13, 1988),

the violations are listed below:

Technical Specification 3/4.11.2.1 requires, in part, that in order to deter-

'ine that the dose rate limits of 3.11.2.1 ar'e not exceeded, samples must be obtained in accordance with Table 4.11-2, and the dose rates determined in accordance with the methodology and parameters of the Offsite Dose Calculation Manual (ODCM). Table 4.11-2 requires, in part, that iodine and particulate grab samples be obtained prior to each vent and/or purge of the Primary Con-tainment atmosphere. Table 4. 11-2 further requires, in part, that these samples be analyzed for principal gaoea emitter's, as specified therein.

Contrary to the above, from November 27, l985, to December 16, 1988, with the exception of those samples which were obtained for startup, shutdown, or greater than 15% thermal power changes, grab samples of iodine and particulates were not obtained and analyzed prior to each vent and/or purge of the Primary Containment.

This is a Severity Level IY Violation (Supplement IV),

Yalidit of Violation The Supply System acknowledges the validity of this violation. The basis for the violation is a WHP-2 Technical Specification Interpretation (TSI) imple-mented on November 27, 1985 which provided clarification r'egarding the neces-sity to sample and analyze the drywell atmosphere prior to the star of ventingt and purging through the Standby Gas Treatment (SGT) System. The TSI was re-quested due to the conflict between Technical Specification sections 4.11.2,1.2 and 4.11.2,8,3. Section 4.11.2,8.3 requires that the containment drywell be sampled and analyzed (per Table 4.11-2) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the star't of, and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, during venting and purging of the dr'ywell through other than the SGT System, The implication here was that no sampling was necessary while purging/venting through SGT and this LCO contr'oiled system configuration during venting/purging. Section 4.11,2.1.2 requir'es the dose rate to iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents, be determined to be within specific limits by obtaining samples and performing analyses in accordance with Table 4. 11-2 (Radioactive Gaseous Waste Sampling and Analysis Program). This section does not specifically exclude the sampling and analyz-

'ing r equirement when venting and purging through the SGT System, and was viewed as representing the type of sample required.

Appendix A Page 2 of 4 The YSI concluded that sampling was not required prior to or during venting and purging through the SGT System. However, the TSI also concluded that sampling and the associated analysis would be required within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to inter" action of a vent or purge through other than SGT, and repeated on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequen'cy during such a vent and purge oper ation.

The inter pretation was discussed with the Special Pro)ects 8ranch of NRR.

Corrective Ste s Taken/Results Achieved Upon notification that this unresolved issue was to become a potential enforce-ment item, our. process was immediately changed such that sampling and evaluat-ing the primary containment would be performed prior, to venting or pur.ging.

Applicable Operations and Chemistry procedures were changed to requine that,.

for all venting and purging operations, the drywell be sampled and analyzed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior. to the start of and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during venting and purging.

In addition, the TSI involved was cancelled.

Corrective Action to be Taken Ho fur ther. corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

Appendix A Page 3 of 4 Technical Specification 6.12.l states, in part:

"...each high radiation area in which the intensity of radiation is greater than 100 mrems/h but less than 1000 mrems/h shall be barricaded and conspi-cuously posted as a high radiation area..."

"...Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or. more of the following:

a, A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. "

c. A health physics qualified individual (i,e 'ualified in radiation protection procedures) with a radiation dose rate monitoring device..."

Contrary to the above, on Oecember 1, 1988, two individuals entered an area on the 501'levation of the Reactor Building, where the intensity of radia-tion measured up to 130 mrems/h, without either. the equipment specified above or being accompanied by an individual qualified in radiation protection procedure es, This is a Severity Level IY Violation (Supplement IV).

Validit of Violation The Supply, System acknowledges the validity of this violation, The reasons for the violation are as follows:

e The laborers involved failed to read and understand the Radiation work Permits (RHP), and also failed to realize that Health Physics (HP) personnel are responsible for directing the movement of Hi-Rad boun" daries.

~ The pre-work brief for the containment tent construction did not address how the tent wall was to be built through the Hi-Rad boundary, Corr ective Ste s Taken/Results Achieved

1) On January 10, 1989, in a letter to all Plant personnel, the Plant Manager'ommunicated his expectations r egarding compliance with radiolo-gical controls and discussed the consequences for individuals who fail to comply with such controls.

-, Appendix A Page 4 of 4

2) The RWP policy has been .modified such that greater emphasis is being placed on gob-specific RWPs for work in Hi-Rad areas,

3) Pr ior to performing work in radiological controlled areas, the laborers involved were required to;

~ Successfully complete the two"day General Employee Training (GET) class e Review the Hi-Rad area video training tape, e Review, with Health Physics super'vision, their. responsibilities when working in radiological controlled areas.

4) All RWPs specifically written for Hi-Rad areas have been placed at HP access control and require a br iefing on the requirements for'hose areas.

Corrective Action to be Taken

1) A programmatic change to the ALARA process will be made to r'educe the threshold of those RWPS which require a pre-gob briefing.

2) All line managers reporting to the Plant Manager will tr'ain, with assis-tance from the Plant HP/Chemistry Manager, their personnel on radio- .

logical control r'equirements.

Oate of Full Com liance

1) Changes to the ALARA process will be made by Mar ch 15; 1989.

2) Training will be completed prior to the 1989 maintenance and refueling outage.

gc (.P~ P ZTED Dl.')~ Bt 'Tl 0~ DF M 0% iTRXTl04 SYs TEk REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

CCESSION NBR:8902100248 DOC.DATE: 89/02/03 NOTARIZED: NO DOCKET g FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 890105 50-397/88-41.

ltr re violations noted in Insp. Rept R I

DISTRIBUTION CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Environ & Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES: S RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME'D5 LTTR ENCL ID CODE/NAME LTTR ENCL LA 1 0 PD5 PD 1 1 SAMWORTH,R 1 1 INTERNAL: ACRS 2 2 AEOD/DSP 1 1 NMSS/LLOB 5E4 1 1 NMSS/SGOB 4E4 1 1 NRR/DLPQ/PEB 11 1 1 NRR/DOEA/EAB 11 1 1 NRR/DREP/EPB 10 1 1 NRR DREP/RPB 10 2 2 NRR/PMAS/ILRB12 1 1 GS~ STRACT 1 1 OGC/HDS2 1 1 REGALE 02 1 1 RES 1 1 G DRSS/RPB 2 2 RGN5 FILE 01 1 1 RGN2 COLLINS,D 1 1 RGN4 MURRAY,B 1 1 EXTERNAL: EG&G SIMPSON,F 2 2 LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE IO ALL "RIDS>> RECIPIEZIS PLEASE HELP US 'IO REDUCE ~! CGNI'ACT 'IHE DOCUMEÃI'D&ROL DESKi ROON Pl-37 (EXT. 20079) IO EZJMZNATE KXlR NME FRY DISTRIBUTION S

LISTS H)R DOCUMENI'S YOU DON'T NEEDt TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL 27

WASHINGTON PUBLIC POWER SUPPLY SYSTEM I'.O. Box 968 ~ 3000 George 11'ashington Way ~ Richland, Washington 99352 February 3, 1989 G02-89-014 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-137 Washington, D.C. 20555 Gentlemen:

Subject:

NUCLEAR PLANT NO. 2 LICENSE NO. NPF-21

. NRC INSPECTION REPORT 88"41 RESPONSE TO NOTICE OF VIOLATION The Washington Public Power Supply System hereby replies to the Notice of Violation contained in. your letter dated January 5, 1989. Our reply, pursuant to the provi-sions of Section 2.201, Title 10, Code of Federal Regulations, consists of this letter and Appendix A (attached).

In Appendix A, each violation is addressed with an explanation of our position regarding validity, corrective action and date of full compliance.

Very truly yours, G. C. Sorensen, n er Regulatory Program JDA/bk Attachments cc: JB Martin - NRC RV NS Reynolds - BCP8R RB Samworth

- NRC DL Williams - BPA NRC Site Inspector - 901A

Appendix A Page 1 of 4 APPENDIX A During an NRC inspection conducted November 28-December 2, and December 12-16, 1988, two violations of NRC requirements were identified. In accordance with the "Gener al Statement of Policy and Procedure for NRC Enfor cement Actions," 10 CFR Part, 2, Appendix C (1988), as modified by 53 Fed. Reg. 40019 (October 13, 1988),

the v'iolations are listed below:

A. Technical Specification 3/4. 11.2. 1 requires, in part, that in order to deter-mine that the dose rate limits of 3.11.2.1 are not exceeded, samples must be obtained in accordance with Table 4.11-2, and the dose r ates determined in accordance with the methodology and parameters of the Offsite Dose Calculation Manual (ODCM). Table 4. 11-2 requires, in par t, that iodine and particulate grab samples be obtained prior to each vent and/or purge of the Primary Con-tainment,atmosphere. Table 4. 11-2 further requires, in part, that these samples be analyzed for principal gamma emitters, as specified therein.

Contrary to the above, from November 27, 1985, to December 16, 1988, with the exception of those samples which were obtained for startup, shutdown, or greater than 15% thermal power changes, grab samples of iodine and particulates were not obtained and analyzed prior to each vent and/or purge of the Primary Containment.

h This is a Severity Level IV Violation (Supplement IV).

Validit of Violation The Supply System acknowledges the validity of this violation. The basis for the violation is a WNP-2 Technical Specification Inter pretation (TSI) imple-mented on November 27, 1985 which provided clarification regarding the neces-sity to sample and analyze the drywell atmosphere prior to the start of venting and purging through the Standby Gas Treatment (SGT) System. The TSI was re-quested due to the conflict between Technical Specification sections 4. 11.2.1.2 and 4.11.2.8.3. Section 4.11.2.8.3 requires that the containment drywell be sampled and analyzed (per Table 4.11-2) within 8 hour s prior to the start of, and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, during venting and purging of the drywell through other than the SGT System. The implication here was that no sampling was necessary while purging/venting through SGT and this LCO controlled system configuration during venting/purging. Section 4. 11.2.1.2 requires the dose rate to iodine-.31, iodine-133, tritium, and all radioruclides in particulate form with half-lives greater than 8 days in gaseous effluents, be determined to be within specific limits by obtaining samples and performing analyses in accordance with Table 4. 11-2 (Radioactive Gaseous Haste Sampling and Analysis Program). This section does not specifically exclude the sampling and analyz-ing r equirement when venting and purging through the SGT System, and was viewed as representing the type of sample required.

Appendix A ~

Page 2 of 4 The TSI concluded that sampling was not required prior. to or during venting and purging through the SGT System. However, the TSI also concluded that sampling and the associated analysis would be required within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior. to inter-action of a vent or purge through other than SGT, and repeated on a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> frequency during such a vent and purge operation.

The interpretation was discussed with the Special Projects Branch of NRR.

Corrective Ste s Taken/Results Achieved Upon notification that this unresolved issue was to become a potential enforce-ment item, our process was immediately changed such that sampling and evaluat-ing the primary containment would be performed prior. to venting or purging.

I Applicable Operations and Chemistry procedures were changed to require that, for all venting and purging operations, the drywell be sampled and analyzed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the star t of and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during venting and purging.

In addition, the TSI involved was cancelled.

Corrective Action to be Taken No fur ther corrective action is planned.

Date of Full Com liance The Supply System is currently in full compliance.

'Appendix A Page 3 of 4 B. Technical Specification 6.12. 1 states, in part:

"...each high r adiation area in which the intensity of radiation is greater than 100 mrems/h but less than 1000 mrems/h shall be barricaded and conspi-cuously posted as a high radiation area..."

"...Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received..."

c. A health physics qualified individual (i.e., qualified in radiation protection procedures) wit". a radiation dose rate monitoring device..."

Contr ary to the above, on December 1, 1988, two individuals entered an area on the 501'levation of the Reactor Building, where the intensity of radia-tion measured up to 130 mrems/h, without either the equipment specified above or being accompanied by an individual qualified in radiation protection procedures.

This is a Severity Level IV Violation (Supplement IV).

Yalidit of Violation The Supply System acknowledges the validity of this violation. The reasons for the violation are as follows:

o The laborers involved failed to read and understand the Radiation Work Per mits (RWP), and also failed to realize that Health Physics (HP) personnel are responsible for directing the movement of Hi-Rad boun-daries.

~ The pre-work brief for the containment tent construction did not address how the tent wall was to be built through the Hi-Rad boundary.

Corrective Steps Taken/Results Achieved

1) On January 10, 1989, in a letter to all Plant personnel, the Plant Manager communicated his expectations regarding compliance with radiolo-gical controls and discussed the consequences for individuals who fail to comply with such controls.

Appendix A Page 4 of 4

2) The RWP policy has been modified such that greater emphasis is being placed on job-specific RWPs for work in Hi-Rad areas.

3) Prior to performing work in radiological controlled areas, the laborers involved were required to:

o Successfully complete the two-day General Employee Training (GET) class o Review the Hi-Rad area video trai ning tape.

e Review, with Healti; Physics super vision, tneir responsibilities when working in radiological controlled areas.

4) All RWPs specifically written for Hi-Rad areas have been placed at HP access control and require a briefing on the requirements for those areas.

Corrective Action to be Taken

1) A programmatic change to the ALARA process will be made to reduce the threshold of those RWPS which require a pre-job briefing.

2) All line managers reporting to the Plant Manager will train, with assis-tance from the Plant HP/Chemistry Manager, their personnel on radio-logical control requirements'ate of Full Com liance

1) Changes t'o the ALARA process will be made by March 15, 1989.

2) Training will be completed prior to the 1989 maintenance and refueling outage.