ML17285B128
| ML17285B128 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/12/1990 |
| From: | Cicotte G, Coblentz L, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285B125 | List: |
| References | |
| 50-397-90-01, 50-397-90-1, NUDOCS 9003290218 | |
| Download: ML17285B128 (22) | |
See also: IR 05000397/1990001
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
Docket No.
License
No.
Licensee:
50-397/90-01
50-397
Washington Public Power Supply System
P.
0.
Box 968
Richland,
99352
Facility Name:
Washington Nuclear Project
No.
2
Inspection at:
WNP-2 Site,
Benton County, Washington
Inspection
Conducted:
January
29-February
2 and February 12-16,
1990
Inspected
by:
Inspected
by:
lc
te,
a latlon
ecla lst
0
tz,
la
1
n
pecla ls
P~ l-Ro
ate
lgne
3-~~ -P~
a
e
lgne
Approved by:
ens
aws l,
le
Facilities Radiological Protection Section
a
e
lgne
~Summer:
Ins ection durin
the
eriod of Januar
29-Februar
2 and Februar
12-16
e ort
o.
Areas Ins ected:
Routine
unannounced
inspection
by two regionally based
lnspec ors
o
occupational
exposure,
shipping,
and transportation;
r'adioactive
waste
systems,
radiological environmental
monitoring;
and followup.
Inspection procedures
30703,
83750,
84750,
and 93702 were addressed.
Results:
No cited violations were identified in two of the three
areas
aaaressed.
In one area,
a non-cited violation was identified regarding
representative
environmental
sampling (Section 3.D).
In another area,
a
weakness
was identified in the area of radiological controls exercised
over
radioactive filter replacement,
resulting in a violation for inadequate
radiation surveys
(Section 4).
Overall, the licensee's
programs
appeared
capable of meeting their safety objectives.
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.
'
DETAILS
1.
Persons
Contacted
+G.
y*C
- J
- J
- J
+J.
+C.
++R.
- D
+R.
q*D
++R.
+K.
S.
NRC
yAC
C.
C.
Sorensen,
Manager,
Regulatory
Programs
M.'owers, Plant Manager
A. Baker, Assistant Plant Manager
R. Allen, Health Physics
(HP) Craft Supervisor
D. Arbuckle, Compliance
Engineer
C. Bell, Manager,
Health
and Sciences
L. Bradford,
HP Supervisor
J.
Card, Senior Health Physicist (Radiological
Environmental
Monitoring Program
(REMP) Health Physicist)
G. Graybeal,
HP/Chemistry
(HP/C) Manager
A. Kerlee, Principal Quality Assurance
(QA) Engineer
R.
Kobus, Plant
QA Manager
L. Koenigs, Technical
Manager
E.
Larson,
Radiological
Programs
and Instrument Calibrations
(RPIC)
Manager
F. Patch,
ALARA Coordinator
J. Pisarcik,
HP Support Supervisor
A. Pritchard,
HP Craft Supervisor
A. Smith,
Radwaste
Program
Leader
L. Wardlow, Radiological
Services
Supervisor
L. Washington,
Plant Compliance Supervisor
J.
Bosted,
Senior Resident
Inspector
A. Sorensen,
Resident
Inspector
"Denotes
those present at the exit interview held
on February 2,
1990.
+Denotes
those present at the exit interview held on February
16,
1990.
In addition .to the individuals identified above,
the inspector
met and
held discussions
with other
members of the licensee's
staff.
2.
Occu
A.
ational
Ex osure
Shi
in
and Trans ortation (83750
Audits and
A
raisals
Several
Non-Conformance
Reports
(NCRs), Plant Deficiency Reports
(PDRs),
Problem Evaluation
Requests
(PERs),
and Technical
Evaluation
Requests
(TERs), for 1989 and 1990,
were reviewed.
The
NCR/PDR
system
had been replaced
by the
PER/TER form of problem
identification and resolution.
The licensee
had significantly
reduced
the number of outstanding deficiencies
from the older
system.
However,
some of the resolutions
approved for both the old
and
new systems
did not appear to address
the original concern
as
stated
in the tracking document.
See Section 3.D, below.
The licensee
s audit of,health physics activities,
by the Licensing
and Assurance
Group, will be examined in a subsequent
inspection,
as
it had not been completed at the time of the inspection.
~Chan
ea
No major changes
in equipment or procedures
had taken place since
the last inspection of this program area.
Some minor in-plant
organizational
changes
were briefly reviewed.
I
External
Ex osure Control
Representative
radiation
and contamination
survey records for
November
1989 through February
1990 were reviewed.
Radiation survey
techniques
were discussed
with several
health physics technicians
(HPTs).
With the exception of those
noted in Section
4 below,
no
concerns
were identified.
II
Use of personnel
dosimetry
was observed.
Representative
radiation
exposure
cards
(RECs), in use for individual radiation
dose
tracking,
were examined.
Thermoluminescent
dosimeter
(TLD) issuance
and
use
were reviewed.
No concerns
were identified.
Internal
Ex osure
Control
Representative
air sampling data log sheets
for 1990 were reviewed.
All of the
11 HPTs with whom air sampling techniques
were discussed
were in general
agreement
as to what constituted
an adequate
sample
of the breathing
zone for workers in areas
containing potentially
high airborne radioactivity.
However, three of the
HPTs with whom
air sampling
was discussed
stated that they believed that air
samples
conducted
during the breach of highly contaminated
system
boundaries
would be representative
of the airborne radioactivity
'concentrations
resulting from subsequent
disassembly
or
decontamination
of internal
components within those
system
boundaries.
The inspector
reminded the
HPTs that the differing
conditions described
above could, result in significantly different
concentrations
of airborne contaminants.
Representative
records of bioassay for 1990 were briefly reviewed.
No concerns
regarding
minimum detectable activity or the capability
to detect significant uptake of airborne radioactivity were
identified.
Control of Radioactive Materials
and Contamination
Surve
s
and
~oni or>n
Tours of the Radwaste
Building (RMB), Reactor Building (RB), and
Turbine Building (TB) were conducted.
Independent
radiation surveys
were performed with NRC ion chamber
survey instrument
model ¹R0-2,
serial
¹022906,
due for calibration
on April 16,
1990.
Radiological postings,
contamination control stepoff pads,
and other
access
controls that were observed
appeared
to have
improved over
-F.
previous inspections
and were consistent with the licensee's
procedures
and
TS requirements.
Housekeeping
appeared
adequate.
Only one area,
on the 522'levation of the
RB, was observed to have
significant accumulation of used contamination control materials
left on the floor.
However,
some contaminated
areas
appeared
to
have increased
in size..
The condition of the traversing in-core
probe (TIP) drive machine
area
appeared
to be much improved,
although the size of the contaminated
area
was unchanged.
For a
discussion of radiation surveys,
see Section 4, below.
For the
areas
toured,
no concerns
were identified.
Shi
in
of Low-Level Wastes for Dis osal
and Trans ortation
Radioactive solid waste
shipments for 1990 were reviewed.
The
records
indicated that all the shipments
had been
conducted in
accordance
with licensee
procedures
and quality assurance
requirements.
The licensee
stated that
no transportation
incidents
had occurred during 'the
18 mile trip to the commercial
disposal
facility.
No recent violations of transportation
or waste disposal
regulations
ha'd been identified by the State of Mashington.
The licensee's
program appeared fully capable of meeting its safety
objectives.
No violations or deviations
were identified.
3.
Radioactive
Maste
S stems
Radiolo ical Environmental Monitorin
(84750
A.
Audits and
A
raisals
B.
Corporate
Licensing and Assurance
Audit 89-490, "Radiological/
Nonradiological
Environmental
and Effluent Monitoring," was
reviewed.
The audit appeared
to be thorough
and of sufficient depth
to adequately
assess
the program.
Audit 89-500,
"Radwaste
Process
Control Program,"
was also reviewed.
The audit results
showed
marked
improvement over the previous audit of this program area.
The audit stated that the most significant findings were the high
volume of solid waste generated,
adherence
to health physics work
rules,
and
some program changes
which had not been
reviewed in
accordance
with procedure.
Most of the program change
reviews
had
been
completed
and procedural
changes
had been incorporated at the
time of the inspection.
Responses
to findi'ngs from the above audits
were timely.
No
significant concerns
were identified.
~Chan
es
No major changes
in procedures
had taken, place since the last
inspection of this program area.
However,
some organizational
changes
in radiological
support organizations
had occurred.
The
RPIC manager
was
no longer responsible
for environmental
monitoring.
Those duties
had
been
assumed
by the Manager,
Health and Sciences,
who reports directly to the Manager,
Support Services.
The main condenser
off-gas treatment
system
equipment
had been
upgraded
such that it could be operated
in sub-cooled
mode.
This
provides
more cleanup of gaseous
effluents,
by increasing
the
ability of the charcoal
adsorber
beds to adsorb radioactive
noble
gases
and iodines.
C.
Im lementation of Radioactive
Waste
Pro
rams
2)
3)
Solids
The licensee's
program for determining the quantity and
composition of solid wastes
was reviewed.
The licensee
conducts
dewatering operations
through
use of a contractor.
However, the licensee
recently incorporated contractor
procedures
into plant procedures,
for review and control.
This
was
done to address
audit findings with respect to the level of
review provided for contractor procedures.
Dewatering
activities were observed.
No concerns
were identified.
Li uid and Gaseous
Effluents
The most recent
Semiannual
Radiological Effluent Release
Report, for the period of January-June,
1989,
was reviewed in
Inspection
Report 50-397/89-29.
Approximately 30
representative
radioactive liquid and gaseous
release
reports
for 1989
and 1990 were reviewed.
All the reports indicated
that effluents were
ALARA in acc'ordance
with 10 CFR 50
Appendix I and
TS limits, and were
much less
than
Appendix
B limits.
The licensee's
Offsite Dose Calculation Manual
(ODCM),
delineates
how doses
are calculated,
and describes
the various
methods
for obtaining environmental
and effluent information.
See Section
D, below, for further discussion.
No unmonitored release
paths
were identified as
a result of
this inspection.
The magnitude of gaseous
effluents
had been
reduced
as
a result of the change to the treatment
system
noted
in Section
B, above.
Instrumentation
Representative
recent radioactive effluent monitor channel
checks,
channel
functional checks,
routine tests,
and
some
corrective maintenance,
were reviewed for the main steam line
radiation monitors, radioactive liquid effluent monitors,
and
the air ejector off-gas post-treatment
radiation monitors.
Effluent sample
data indicated adequate
agreement with effluent
monitor readings.
Instrument readouts
had improved in
readability.
Operabi 1ity of monitors
was adequate,
with few
periods of unavailability for the effluent radioactivity
monitors.
No significant maintenance
problems
were identified.
4)
Air Cleanin
S stems
4
The inspectors
reviewed the two most recent test records for
charcoal
adsorber
and
HEPA filtration units, including the
standby
gas treatment
system.
Also, tests of both the radwaste
building and reactor building exhaust ventilation systems
were
reviewed.
No concerns
were identified.
On February 12,
1990,
the inspector
observed that the control
room intake ventilation
units exhibited several
small leaks or degraded
access
doors.
Mhen this was brought to the attention of the licensee,
an
operator
was dispatched
to examine the units and several
deficiency tracking numbers
were assigned
to identify the
problems.
Lab test results for charcoal
adsorber
media were briefly
reviewed.
The licensee
had identified a situation in which the
test requested
had been inadvertently assigned
commercial
~rade
versus quality grade test criteria.
However, the licensee
s
followup indicated that the
same criteria had been
used for
both quality and commercial
grade,
and that only the reporting
and warranty of results varied with the commercial/quality
grade
assessment.
D.
Radiolo ical Environmental Honitorin
Pro
ram
The inspector
observed
the performance of Environmental
Program
Instruction (EPI) 12.4.8,
"Drinking and River Mater
Sample
Collection," by the Radiological
Environmental Monitoring Program
(REMP) technician.
Samples
were taken at the following locations:
Station 26, surface water upstream (circulating water system
intake);
27, surface water downstream (circulating water system
blowdown (CMBD)); 28, drinking water near site (Hanford site "300"
area);
and 29, drinking water location (Richland Mater Treatment
Plant).
Although the composited
samples
which were observed
were collected
in accordance
with the EPI,
a review of licensee
records
and
discussion with RENP personnel
revealed that there
had been
disagreement
within the:licensee's
organization
as to whether
the
RENP was being conducted
in accordance
with the TS.
TS 3. 12, "Radiological Environmental Monitoring," states
in part
that the radiological environmental
monitoring program shall
be
conducted
in accordance
with TS Table 3. 12-1.
TS Table 3. 12-1
states
in part that the surface water samples
shall
be collected
as
composites,
such that the quantity (aliquot) of liquid 'sampled is
proportional to the quantity of flowing liquid and in which the
method of sampling
employed results in a specimen that is
representative
of the liquid flow.
Sample aliquots are to be
collected at time intervals that are very short (e.g.,
hourly)
relative to the compositing period (e.g., monthly).
According to
footnote (a) of the table, deviations
are permitted from the
required sampling schedule if specimens
are unobtainable
due to
malfunction of automatic
sampling equipment.
However, if specimens
are unobtainable
due to sampling equipment malfunction, effort shall
be
made to complete corrective action prior to the end of the next
sampling period.
The inspectors
noted that Stations
26, 28,
and 29 sample
from lines
in which'he flowrate is relatively constant,
and for which a
timed-interval compositor is used.
Flow in the
CWBD, however,
regularly changes
by a factor of about
800 (typically 50 to 4000
gpm); Station
27 uses
a compositor which varies the time interval in
proportion to the
CWBD flowrate.
Sampling records
indicated that
the
CWBD compositor
had been subject to chronic failures,
due to
repeated
pump failures, flow indicator malfunctions,
and other
similar causes.
For example,
the compositor could not collect
representative
samples
during more than
one third of 1989:
Dates
Compositor Not Sampling
Total
Days
Month
b
Flow-Pro ortional Method
Out of Service
January
May
June
July
August
.
September
October
November
13th to 30th
10th to 30th
1st to 4th; 6th to 21st
12th to 31st
1st; 16th to 31st
entire month
1st to 5th; 28th to 31st
1st to 7th
17
20
19
19
16
30
8
7
Difficulty in obtaining
a representative
surface water downstream
sample
had
been
documented
in two PERs,
three
TERs,
NCR 288-0365,
and the licensee's
internal monthly
REMP Status
Reports for May to
September
1989.
During each of the above periods,
REMP personnel
obtained
at the compositor
sample point.
The issue of
whether
manual
grab sampling provided
an acceptable
alternative
during times
when the compositor
was out of service
had been
a topic
of frequent disagreement
within the licensee's
organization.
288-0365,
originated
by the
REMP Health Physicist in August 1988,
included
one of several
clear statements
by
REMP personnel
that grab
sampling did not comply with TS 3. 12. 1.
The "immediate disposition"
block for this
NCR was not approved until March 1989.
Technical
review and final disposition approval
were not completed until
February
1990.
The plant compliance supervisor
(PCS)
acknowledged that the
TS
requires
the sampling technique to be flow-proportional.
An
Inter-Office Memorandum
(IOM) from the
PCS to the plant manager,
dated
December
13,
1989, stated that grab sampling did not meet this
requirement.
The
PCS stated to the inspectors that,,at the request
of plant management,
his department
had agreed to revise the
IOM to
state that grab sampling satisfies
the TS; however,
he also stated
'hat
the revised
IOM, when issued,
would clearly state that
TS Table
3. 12-1 could only be satisfied if the grab sampling is frequent
'
relative to the compositing period,
as required
by footnote (f) of
TS Table 3. 12-1.
In addition, the
PCS stated that the grab samples
obtained
had never
been performed for compositing,
nor had they been
obtained for the purpose of meeting the flow proportionality
requirement.
At the exit interview, the
HP/C manager
and the plant manager stated
that manual
grab sampling is an acceptable
alternative
method for
obtaininq
a representative
sample
when the compositor is
malfunctioning.
The plant manager
acknowledged that the
CWBD
compositor problems
needed to be addressed,
and committed to a
"speedy resolution" of chronic compositor failures, including
consideration of the feasibility of obtaining
a compositor of more
reliable design.
The inspectors
noted that deviations
from the required sampling
schedule
are permitted by Footnote (a) of TS Table 3. 12-1 only if
the samples
are unobtainable.
The failure to obtain composited
samples
from aliquots proportional to the flow rate of the
CWBD line
appears
to be
a violation of Technical Specification
4. 12. 1 and
Table 3. 12-1.
However, the violation is not cited because
the
criteria of Subpart V.A'of the Enforcement Policy were met
((NCV)50-397/90-01-01)
.
The
AEOR for 1988 was reviewed.
Except for a certain lack of
discussion
of licensee
plans for preventing recurrence
of the
compositor failures,
no concerns
were identified.
See Section
5
below.
E.
Meteorolo ical Monitorin
Pro
ram
Meteorological monitoring equipment maintenance
records
were briefly
reviewed.
Operation of the equipment
was observed.
No concerns
were identified.
The licensee's
program appeared fully capable of meeting its safety
objectives.
No cited violations or deviations
were identified.
4.
Onsite Followu
of Events at 0 eratin
Power'eactors
(93702)
Introduction
On January
10,
1990, while replacing radioactive resin filter
elements for the equipment drain--radioactive
(EDR) system,
the
licensee
discovered
an in-plant spread of contamination,
which
resulted in contaminated
footwear and the
need to decontaminate
a
large portion of the floor on the 507'levation of the Radwaste
Building (RWB).
The licensee
determined that-the contamination
spread
was the result of poor contamination control during the
filter element
(septum)
replacement
work.
After the
NRC resident
inspector
asked the licensee
what the airborne radioactivity
exposure
was,
the licensee
conducted further evaluation.
On January
12,
1990,
the licensee
conducted
whole body counts
on the workers to
confirm whether there
had
been
exposure
to high airborne
I
radioactivity.
A chronology of events,
based
on review of records
and interviews with personnel,
follows:
January
9,
1990
(times are approximate)
0900 All work was conducted
on Radiation Work Permit
(RWP) 2-90-00043.
Shielding plugs
on the 507'WB were removed, after which the
filter/demineralizer (F/D) vessel
head
was
removed
and the support
plate with 50 long narrow cylindrical filter septums
suspended
from
it was lifted up to the 507'WB.
The
HPT took one contact
gamma
reading,
recorded
on the survey
map as "20 mr" [20 mi lliroentgens
per hour (mr/h)] with a geiger-mueller
(GM) survey instrument [later
found to be 225 mr/h], and recorded
a large area
smear with
removable contamination of 500,000 disintegrations
per minute (dpm).
The inspector later noted that this was the upper limit of the
highest meter range for the counting instrument
used
by the
HPT.
1300 After observing the septum/support
plate lift, a safety department
representative
informed the workers that work could not proceed
until improvements
in scaffolding/handrails
were made.
The
HPT who
was monitoring the job had the mechanical
maintenance
(MM) workers
place the filter assembly
back in the vessel.
Work on the filters
was delayed until the requisite handrail
work was complete.
January
10,
1990
0800
The filter assembly
was again
removed
from the vessel
and brought to
the 507'levation,
where half of the 50 individual elements
were
removed
by hand from the support plate.
The elements
were placed in
a wooden
box located just inside the posted
contaminated
area.
After decontamination
and monitoring, the box was transported
to the
decontamination facility.
The
HPT obtained
gamma radiation exposure
rate measurements
of 225 mr/h on contact,
and
25 mr/h at
3 ft
relative to the box.
Further disassembly
awaited the construction
of another,
larger box.
1230
The other
25 septums
were
removed
and placed in a box located just
outside the posted
contaminated
area.
The
HPT obtained
gamma
measurements
with an ion chamber
survey instrument of 50 mr/h on
contact
and
15 mr/h at 3 ft.
According to the survey by the
HPT,
large area
smears
on the septums
in the box measured
60 to
200 mrad/h.
1400 The two
MM personnel,
who had been providing support outside the
posted
contaminated
area,
caused portal contamination monitors to
alarm.
Surveys of the individuals revealed
low level (less than the
limit of 100 counts
per minute) contamination
on their shoes.
No
individuals were found to have skin contamination.
1500 The
HPT who had. controlled the job conducted
a paper
smear
survey
and found
a maximum contamination
level outside the posted
contaminated
area of 5000 dpm/100
sq
cm, in the vicinity of the
boundary.
The
HPT posted
a larger area,
reported the results of the
survey to the lead
HPT,
and ended the shift.
Two other
HPTs were
sent
by the lead
HPT to perform followup surveys,
and found small
particles of contamination of up to 30,000
dpm/100
sq
cm in several
locations
on the floor leading from the posted
area to the elevator,
an area of about
2800 sq ft.
The area
from the elevator to the F/D
removal area,
and the area itself, were barricaded
and posted
as
contaminated until decontamination
was conducted later in the shift.
Decontamination
and reinstallation of cleaned filter elements
was
conducted later using respiratory protection
and contamination
control techniques
consistent with licensee
procedure
and the
potential
hazards.
The
HPTs who performed that decontamination
effort informed the inspector that pre-decon
readings
had
shown
up
to 400 mrad/h per large area
smear
on the floor next to the-
assemblies.
Li'censee
Evaluation
The inspector
asked 'the licensee if their evaluation of the matter
was complete.
The
HP supervisor stated that
a Report of
Radiological
Occurrence
(RRO) had been completed,
that several
performance
issues for the
HPT had
been identified,
and that
some
planning issues
had also contributed to the incident.
The
licensee's
RRO, dated January
12,
1990,
and
a "Category 3" root
cause
evaluation,
made the following observations:
1)
The
HPT did not follow good
HP job coverage practices.
2)
Contamination control work practices
were not followed.
3)
Pre-job planning did not happen.
The job was
'made up's it
went along (licensee
emphasis).
4)
HP supervision
was told by the
HPT that the job was not well
coordinated,
but did not feel it was out of control.
5)
Specific job planning problems which resulted in the area
becoming highly contaminated
were listed as:
the manner of
handling and packaging
septums,
delays
due to waiting for
replacement
septums,
and allowing the old septums
to dry out.
6)
The
HPT did not keep
up with increasing
contamination levels,
due to lack of surveys
inside and outside the area,
resulting
in loss of contamination control.
The
RRO stated that the corrective actions
taken to prevent
a
similar occurrence
were to provide better Health Physics pre-job
planning
and to counsel
the
HPT.
The inspector discussed
the evaluation with the
HP supervisor,
who
had concurred in the
RRO corrective action.
The
HP supervisor
stated that the issues
regarding job planning included the delay due
to safety, that the wait for replacement
septums
had not been
necessary,
but had occurred
due to miscommunication,
and that as
a
result of the incident each involved department
had participated in
10
a post-job review, with specific action
needed
by departmental
management.
The
HP supervisor
and the
HP/C manager
both stated that
the method of counseling the
HPT was still under review, but that
the incident had clearly occurred
due to failure of the
HPT to
conduct necessary
contamination
surveys.
C.
NRC Review of Licensee
Evaluation
The following licensee
records
and documents
were related to the
licensee's
evaluation:
RRO 2-90-001;
RWPs 2-90-0043
(EDR system
filter element replacement),
2-89-00432 (reactor water cleanup
system
(RWCU) filter element replacement),
and 2-89-00419 (floor
drain--radioactive
(FDR) system filter element replacement);
Health
Physics
Log, January 4-30,
1990.
Other
RWPs and associated
program review records
(APRR), were briefly reviewed,
as
appropriate.
The inspector
made the following observations
with respect
to issues
addressed
by the licensee's
evaluation:
1)
The lack of survey referred to by the licensee
was, according
to the licensee,
the exercise of bad judgment by the
HPT
regarding
when and
how extensively to take surveys,
particularly for contamination control purposes.
Licensee
procedure
(PPM) 11.2. 13. 1 requires
the surveyor to exercise
good judgment--strict verbatim compliance is not required.
The licensee
stated that they rely on the good judgment of
their
HP personnel,
due to the difficulty of foreseeing
every
contingency regarding inaccessibility of areas
to be surveyed,
applicability of a particularly survey technique,
and other
similar aspects.
The inspector
reminded the licensee that
reliance. on the good judgment of personnel
is fully effective
only when personnel
perform above the level required
by their
procedures.
The licensee
stated that the performance of the
individual
HPT was considered
to be anomalous
and thus
an
individual performance
issue.
2)
Although not iterated in the
RRO or root cause analysis,
the
supervisor
informed the inspector that
a post-job review had
been
conducted specifically to address
job planning issues,
and
that actions
by
MM department
personnel
had been specified,
so
as to prevent recurrence.
The inspector discussed
the matter
with MM supervisory
personnel
who had been at the post-job
review.
The inspector
asked
them what method of tracking was
being
used to assure
that the problems did not recur.
They
stated that their method of ensuring that similar jobs would
have better engineering controls
and
be better planned
was that
everyone there
knew about it and wouldn't forget.
P.
I~lk 11
Licensee
procedure
(PPM) 1. 11. 8, "Radiati on Work Permi t, "
Revision 2, dated
March 20, 1989, states,
in part:
Pre-job briefings are required for all activities involving
work within High Radiation Areas.
The Job Supervisor...initiates
an
RMP as follows... Enter job
description...Be specific... to give a clear understanding
of
work to be performed...Obtain
an
ALARA Scope
Sheet
and complete
all but the shaded portion...Submit the
RMP and
ALARA Scope
Sheet to Health Physics...for
processing.
LHP/C] Representative
shall:...For jobs with work area
exposure
rates greater
than or equal to 100 mR/hr, but less than
300
mR/hr,...Greater
than 0.3 man-rem,
but less
than 5.0 man-rem
total... the
ALARA Coordinator ...will complete the evaluation,
and document the
ALARA requirements
on an
ALARA Program
Review
Record.
[HP/C] Representative
shall:...Determine
radiological
conditions
and enter onto the
RWP.
Be specific to provide
adequate
information.... (i.e, radiation levels, contamination
levels,
hot spot locations
and airborne activity, etc).
Provide
comments to warn or guide workers of radiological
conditions.....Enter
any special
instructions or precautions
as
appropriate,
including ALARA recommendations.
Be specific,
provide all Health Physics
information required to control
and
guide the workers...
The [HP] Supervisor or Designated Alternate shall:...Review the
RWP and resolve
any questions with the appropriate
personnel...Sign
and date the
RWP indicating acceptance
of the
RWP requirements.
The inspector
noted the following regarding the
ALARA Scope
Sheet,
the
ALARA Program
Review Record,
and the
RWP:
j.)
The
ALARA Scope
Sheet contains
an unshaded
block titled:
"Are there
any other aspects
of the work that are
important for ALARA planning?
Describe..."
The block had
been filled in with the word "none."
2)
The
ALARA Program
Review Record contains
a checklist of
items to be considered.
The inspector concluded that
several
of those
items, if given more consideration
than
was apparent
from discussion with personnel
involved in
12
the work, could have prevented
the problems
encountered
or
otherwise mitigated the situation:
Item
Checklist
1.8
"Lessons-Learned"
reviewed
2.7
Radiological Controls:
Radiological Conditions
Known and
RMP Issued
Ventilation
Flushing/Filling
Decontamination
2.8
Protective
Equipment:
. Respiratory Protection
Face/Eye
Protection
yes
es
not applicable]
[not applicable]
[not applicable]
yes [as required
by HP]
[not applicable]
3)
The three records
noted above did not contain discussion
'of decontamination efforts to be conducted
on the filter
housing,
support plate,
and other internals.
The pre-job
briefing documentation,
required
by the "yes" check
on the
review record,
did not contain
any reference
to
decontamination
in the list of topics discussed.
4)
RMP 2-90-00043,
under
"Special Instructions," stated in
part:
Respirators
required in areas
[greater than or equal
to] 25K HPC or for job evolutions which could create
airborne radioactivity as determined
by H. P.
5)
The
HPT who had covered the job had also approved
the
as
HP supervisory
designee.
The
HP supervisor
stated that
most of the senior
HPTs are
on the list of authorized
individuals to sign
RWPs.
He further stated that
HPTs
will routinely come to him for guidance
on specific
matters pertaining to
RWPs under pre-job review, but that
they will still approve the
RWPs themselves
when those
- questions
are resolved.
The
HP supervisor did not recall
having been consulted
regarding
RWP 2-90-00043.
-The lead
HPT who had been in charge during the work, and whose
responsibilities
included oversight of HPTs assigned
to tasks,
stated that
he had not visited the job site prior to the
contamination
instances.
The lead
HPT further stated that this was
because
the
HPT had relayed the problems
encountered,
but had stated
that he did not believe
he
had lost control of the work.
E.
Health
Ph sics Procedures
The inspector interviewed the personnel
who had conducted
the work,
including supervisory
and planning personnel.
The inspector
noted
that several
licensee
procedures
governing the work had
recommendations
or guidelines
which were not followed.
However,
the
13
procedures
did not require compliance,
as they stipulated that
individual steps
were to be followed when appropriate
in the
judgment of, or at the discretion of, the procedure
user.
The
procedures
contained wording such
as "guideline," "typically,"
'should," "appropriate," "normally," and "usually," as noted below.
PPM 1. 11. 11, "Entry Into, Conduct In, and Exit From Radiologically
Controlled Areas," Revision 0, dated
May 15, 1989, states
in part
that individuals exiting the radio1ogically controlled area should,
if applicable,
complete self frisking or proceed
through the whole
body frisking booths.
One of the two individuals whose
shoes
caused
the frisking booths to alarm stated
he had not performed
a
subsequent
whole body frisk.
The inspector
noted that this was
contrary to an
HP night order regarding
response
to frisking booth
alarms.
PPM 11.2.4. 1,
"MPC-Hour Assessment
and Documentation,"
Revision 4,
dated April 26,
1989, states
in part that the required
RWP for areas
entered shall provide adequate
documentation for entries into and
exits from such areas for the purpose of determining
exposure
times.
- Discussion with the workers
on
RWP 2-90-00043
revealed that only two
of the workers were regularly in an area with a significant
potential for high airborne radioactivity,
and that they were in the
area
much less time than
was indicated
on the
RWP entry record or
their radiation exposure
record cards.
PPM 11.2. 12.2, "Selection of Protective Clothing,"'evision 5, dated
September
7, 1988, states
in part that the radiological work
conditions should
be
known prior to selection of protective
clothing.
Respiratory protection equipment is included in the
listing of protective clothing.
Table
1 to the procedure
indicates
that for smearable
contamination levels of 10-30 mrad/h per 100 sq
cm,
a negative pressure air purifying respirator
should
be selected.
PPM 11.2. 13. 1, "Area Radiation
and Contamination Surveys,"
Revision
4, dated
November 14,
1988, states
in part that the surveyor
should
ensure that the survey accurately
and clearly portrays the
radiological conditions present.
The
HPT who performed the pre-job
survey
and wrote the
RWP indicated
on the
RWP that airborne
radioactivity concentrations
were:
"assumed to be [less than]
7.5 x 10E-10 [microcuries per milliliter (uc/ml)] based
on low
contamination levels; airborne radioactivity will be determined
during various job evolutions."
The contamination
survey did not
include the internals of the F/D, as the system
had not been
breached
at that time.
PPM 11.2.9.8,
"Eberline Teletector
Model 6112," Revision 3, dated
April 10,
1989, states
in part in the limitations section that the
instrument is not normally used to set work area
dose rates,
that
applications
are for hard to reach areas,
and that it is to be
used
as
an
"ALARA tool" to check dose rates
once they have
been
established
with an ionization chamber
instrument.
The survey
instrument
Model 6112 is
a
GM survey meter.
PPM 11.2.13.1 further states
in part:
"Do not use
a
GH survey
instrument without an energy
compensated
probe to set
dose rates
except where high dose rates
or location make it necessary
to use
a
teletector."
The procedure
also states
that direct beta
and
gamma
exposure
rate measurements,
and
maximum and typical dose rates that
would be received
by specified work crew activities,
should
be
included.
The procedure further states:
"usually smears will be
taken of the areas
where contamination is most likely to be found or
spread."
The inspector
noted that the surveys which were conducted
on January
9 and 10, 1990, during the filter element work, did not
include beta readings,
that only a teletector
was
used until the
filter element
removal
was more than half done, that
no smearable
contamination levels in the work area
were indicated
on the surveys,
and that the survey performed
on January
9, 1990,
appeared
to have
been in error by a factor of approximately
10 lower than the actual
gamma radiation
dose rate
on contact with the assembly.
11.2. 13.8, "Airborne Radioactivity Surveys,"
Revision 1, dated
May 23, 1989, states
in part: "Ideally, air samples
taken primarily
for personnel
protection should
be representative
of the air
actually breathed
(breathing
zone samples).
If breathing
zone
samples
are not practical,
samples
that provide conservative
results...may
be used."
From discussion with the
HPT who conducted
the surveys
during the work, the inspector
determined that the
sampler location was
such that it would not have
been representative
of the breathing
zone during filter element disassembly,
and would
have provided non-conservative
results.
However,
subsequent
bioassay
determined that
no significant uptake occurred.
F.
Conclusions
Based
on a sequence
of events
as correlated
between
interviewed
personnel,
comparison with conduct of similar tasks,
and review of
practice
versus
recommendations
of licensee
procedures,
the
following concerns
are
summarized
below:
All the job-specific
RMPs in use at the time of the inspection
had
been
approved
by HPTs,
as
HP supervisory
designees.
The
NN engineer
who had initiated
RMP 2-90-00043 stated that
the
ALARA supervisor did not contact
him to discuss
the job
during planning.
The
HPT who had conducted
the pre-job surveys
also wrote the
RMP, including statements
that indicated
a low hazard potential
for contaminations
or airborne radioactivity.
The
HPT who
approved
the
HPT.
The lead
HPT did
not visit the job site, although significant problems
were
brought to his attention
by the
HPT who was providing job
coverage.
The
ALARA scope
sheet,
APRR,
and
RMP were vague or misleading
in content.
Although these
forms contain provisions for
consideration of radiological
hazards
other than whole body
penetrating radiation,
those provisions
were not used.
The licensee's
HP procedures
contained
many generalizations,
such
as deferring to 'good judgment.'he
procedures
essentially
did not require compliance.
One
HPT with whom survey techniques
were discussed
was not
aware of the special
hazards
associated
with beta radiation.
The licensee
had
done studies for beta penetration of the lens
of the eye, but the studies
did not include analysis of the
specific close disassembly
inherent in F/D filter replacement.
Two other
HPTs stated that although they would have required
respiratory protective devices for workers
on F/0 septum
replacement,
they would only require respirators
during breach
. of the F/0 housing,
and would use air sample results
from the
activity to determine
whether later work could be done without
'espirators.
.Nost of the other
HPTs stated that they would
have required several
contamination control techniques,
any of
which would have contributed significantly to the safety of the
task.
The failure to conduct surveys for beta radiation of the F/D filter
septum
assembly,
adequate
to -fully assess
the radiological
hazards
~rior to or during work, 'appears
to be
a violation of 10 CFR 20.201,
'Surveys."
(50-397/90-01-02)
The level of contamination
recorded
. on a subsequent
survey of the filter septums
was
200 mrad/h of beta
radiation per smear.
A reading of 400 mrad/h of beta radiation
had
been obtained
from the floor, subsequent
to the work.
No other
violations or deviations
were identified.
5 ~
Exit Interview
The inspector
met with those individuals denoted in Section
1, above, at
the conclusion of the inspection
on February
16,
1990.
The scope
and
findings of the inspection
were summarized.
The inspectors
reminded the
licensee
at the exit interview that the 1989 Annual Environmental
Operating
Report would be expected
to contain the licensee's
specific
plans to prevent recurrence
of failure to obtain
a representative
downstream
surface water sample.
The licensee
acknowledged
the
inspectors'bservations.
The licensee
was informed at the exit interview on February 2, 1990, that
several
licensee
procedures
appeared
to have not been followed with
respect to the contamination incident described
in Section 4, above.
The
licensee
acknowledged
the inspector's
observations,
although the licensee
did not agree with all the inspector's
conclusions
as described
at the
end of Section
4.