ML17286A305
| ML17286A305 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/24/1990 |
| From: | Chaney H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286A303 | List: |
| References | |
| 50-397-90-22, IEIN-82-18, IEIN-86-023, IEIN-86-23, IEIN-87-039, IEIN-87-39, IEIN-90-031, IEIN-90-033, IEIN-90-035, IEIN-90-31, IEIN-90-33, IEIN-90-35, NUDOCS 9009140150 | |
| Download: ML17286A305 (10) | |
See also: IR 05000397/1990022
Text
APPENDIX B
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
No.
50-397/90-22
License
No.
Licensee:
Mashington Public Power Supply System
(MPPSS)
P.
0.
Box 968
3000 George Washington
May
Richland,
MA
99352
Facility Name:
MPPSS Nuclear Project
No.
2 (WNP-2)
Inspection at:
MNP-2 site,
Benton County, Washington
Inspection
Conducted:
August 8-10,
1990
Inspected
by:
Approved by:
~Summar:
an
,
en>or
a sa ion
pecia 1st
u
s,
1e
eac
or
a )o og~ca
Reactor
diological Protection
Branch
Hzz
8
a
e
sgne
a
e
)gne
Areas Ins ected:
Routine
unannounced
inspection of the licensee's
radiation
pro ec
son
program including:
radioactive material transportation
activities,
review of RP staff assignments,
follow-up on previous inspection
findings,
and the follow-up on the licensee's
reported
broken fuel rod
incident.
NRC Inspection procedures
83750,
86721,
93701,
and 93702 were used.
Results:
One violation (two examples)
concerning the timely assessment
of
personnel
exposures
to airborne radioactivity was identified (see
paragraphs
2.a and 3.c) and
one unresolved
item concerning maintaininq
on file
Specification
7A package tests,
(see
paragraph
5).
No deviations
were
identified.
The licensee
s program appears
to be adequately
implemented to
ensure
compliance with most
NRC requirements.
Licensee
management
described
to the inspector actions that have
been initiated and those planned to address
both
NRC and licensee self identified weaknesses
in the
RP program.
The
licensee
has initiated a comprehensive
and critical self assessment
of the
program.
The licensee's
onsite equality Assurance
(gA) surveillance
group
staffing, staff experience,
and scheduled
surveillances
appear
adequate
to
ensure that
RP activities receive
adequate
performance
based
reviews in,
addition to any programmatic audits
by the Corporate
gA group.
The licensee
s
initial actions
and long term
RP action plan for surveillance of spent fuel
pool work activities, following the breaking of a fuel rod on July 31, 1990,
appear to be adequate
to ensure possible
hot particles/fuel
debris are quickly
identified and personnel
exposures
are minimized (see
paragraph
2.b for
further discussion of this item).
p
i4015'0 9008~~
9009
ADOCK 05000397
DETAILS
Persons
Contacted
Licensee
"J. Baker, Plant Manager
"J.
Harmon,
Maintenance
Manager
- S. Washington,
Compliance Supervisor
- D. Pisarc1k,
Health Physics
(HP) Support Supervisor
"L. Pritchard,
HP Craft Supervisor
- R. Graybeal,
HP/Chemistry
Manager
"R. Madden, Acting Plant
gA Manager
~C.
Madden,
gA Engineer
"R. Higgins,
gA Engineer
"D. Larson,
Radiological
Programs
Manager
"S.
Regev,
Senior Health Physicist
- R. Wardlow, Radiological
Services
Supervisor
- J. Allen,
HP Craft Supervisor
L. Bradford, Health Physics Supervisor
D.,Werlau, Technical Training Department
Manager
R.
Day Phalen,
Principal Training Specialist
R. Utter, Principal
HP Instructor
Others
- P. Capin,
NRC Inspector-in-Training
C. Bosted,
Senior
NRC Resident
Inspector
C. Sorensen,
NRC Resident
Inspector
P. Ing,
NRC Project
Manager
"Denotes
those attending the exit meeting
on August 10,
1990.
Additional
licensee
personnel
were contacted
during the course of the inspection,
and on August 15 and 17,
1990.
~Fo1 'I ow- o
a.
Previous
Ins ection Findin
s (92701)
Unresolved
Item 397/90-18-01
(Closed):
This item involved a
posse
e
a)
ure
o
e
licensee
o properly assess
in a timely
manner the exposure
on May 20, 1990, of an individual to airborne
radioactivity.
This item was previously discussed
in
NRC Inspection
Reports
50-397/90-15
and 50/397/90-18.
Since the licensee's
performance
in this area is considered
a violation of 10 CFR Part 20. 103, this unresolved
item is being closed.
See paragraph
3.c of
this report for further details.
b.
Licensee
Events
(93702)
0 en Item 397/90-22-01
(0 en):
This item concerns
the licensee's
ac sons
a en
upon
e
rea
sng of a used fuel rod during fuel
integrity inspections
in the spent fuel pool
on July 31,
1990.
A
1
'f
2
standard
twelve foot fuel rod was broken apart at approximately
3
feet from the bottom of the rod while pushing of the rod through
a
cleaning funnel.
HP technicians
covering the job immediately
assessed
radiation
and airborne radioactivity levels.
No change
was
noted
due to the rod breakage.
The spent fuel pool circulating
activity had been
on the increase
since the start of the fuel
integrity inspections.
This was primarily due to deposition of
corrosion products into the spent fuel pool water during cleaning of
fuel rods prior to visual inspection with underwater
cameras.
Currently the dose rates
around piping of the spent fuel clean
up
and cooling system are approximately four times normal, creating
'everal
extended
around spent fuel pool cleanup
and cooling equipment.
The spent fuel pool area,
encompassing
the
fuel integrity inspection area,
was already
a hot particle control
ar'ea
and special
surveys of materials
and personnel
were being
performed.
The lower portion of the rod has
been replaced into the
'uel
assembly matrix and the longer upper portion of the broken fuel
rod has
been placed in a special
spent fuel rod holder that is
designed to hold 26 fuel rods.
The licensee's
engineers
have
determined that it was unlikely that any fuel pellets
had fell or
escaped
from the severed
fuel rod pieces.
This was determined
by
the size
and type of the break.
The licensee
had determined that
a
License
Event Report
was not required
and all aspects
of the event
were documented
in fuel surveillance
procedures
and
a plant Problem
Event Report.
As to the elevated
spent fuel pool piping dose rates,
the
ALARA coordinator
had initiated a design
change
request for the
piping modifications to eliminate excessive
horizontal
runs
and
provide system flushing points.
HP group have
an increased
level of
attention directed at the spent fuel pool areas
involving the
monitorinq and identifying operations that may cause
exposure to
fuel debris
and hot particles.
This item will remain
open pending
further
NRC inspector review of long term actions to clean
up the
spent fuel pool circulating and deposited radioactivity that is
impacting the general
area
dose rates.
3.
Occu ational
Ex osure
Shi
in
and Trans ortation (83750)
The licensee's
RP program
was examined to determined
compliance with the
requirements
of Technical Specifications (TS) 6.2,
6. 10,
6. 11,
and 6. 12;
10 CFR Parts 20. 101,
20. 103, 20.201,
20.203,
and 20.409;
and agreement
with the commitments contained
in Sections
12.5.2
and 12.5.3.7 of the
Final Safety Analysis Report for MNP-2 (FSAR); and agreement
with the
guidance
contained in NRC Regulatory Guides 1.8, 8.8, 8.9, 8. 10, 8. 15,
and 8.26, Industry Standard
ANSI N343-1978,
and
NRC Inspection
and
Enforcement Information Notices (IEINs) 82-18, 86-23, 87-39,
and 90-33.
a.
Audits and
A
raisals
. The
NRC inspector
examined the licensee's
onsite equality Assurance
Surveillance
Groups staffing, staff qualification, schedule of
'urveillance,
and selective surveillance reports.
The licensee
had
recently hired two new gA engineers
with experience
in
RP programs
and auditing of RP programs.
The inspector
reviewed
a surveillance
performed
by one of the
new gA engineers
(SR 2-90-057,
dated July 3,
1990).
The surveillance
examined
HP work practices
during the MNP-2
R-5 refueling outage.
The surveillance
was comprehensive
and
probing in nature
and resulted in the issuance
of one equality
Finding Report 2-90-057-01 concerning the need of additional
HP work
practice training for workers, supervisory oversight in work, areas,
and
a higher level of individual accountability regarding
requirement
compliance.
~Chan
ea
The
NRC inspector
reviewed the licensee's
HP group staffing,
and
discussed
current staffing levels
(26
HP technicians).
Considering
the size of MNP-2 and the
need for the licensee
to improve
radiological work performance
and staff adherence
to radiological
pr'ocedures
and instructions
(as indicated in recent
gA
surveillances)
the
HP staffing level appears
to be marginal for all
but routine plant operations..
The licensee
has
been filling
vacancies
in an expedient
manner
and tightly controls the
utilization of contractual
help.
Management is awaiting the results
of a critical self assessment
of the
RP program, that includes
evaluation of HP staff manning,
before committing to increasing
the
HP staff manning.
The were
no major organization
changes
implemented since the last review of this area
(50-397/90-01).
A
review of HP technician terminations
indicated that the licensee
holds
HP technicians
to an adequate
performance
level
and
effectively implements administrative disciplinary actions
as
warranted.
Internal
Ex osure Control
The inspector
examined the licensee's
actions
regarding the NRC's
identification of an error in calculating
and tracking MPC-hrs
(Maximum Permissible
Concentration - hour) of. exposure for a worker
involved in a radioactive materials
contamination
loss of control
event
on May 20,
1990.
This event
was documented
by the licensee
on
Report of Radiological
Occurrence
(ROR) No. 2-70-021,
dated
May 20,
1990.
The licensee
is still conducting
a formal root cause
analysis/investigation
into the
May 20th event.
Back round
NRC inspection reports previously noted in paragraph
2.b of this
report provide sufficient discussion of the events
leading up'o and
surrounding the personal
contamination of a contract worker and the
spread of contamination in the spent fuel pool area
on May 20,
1990;
and also the circumstances
surrounding
a personal
contamination
event and subsequent
assessment
of possible airborne radioactivity
uptake
on April 30,
1990.
The licensee
has completed
a root cause
analysis/investigation
into the April 30 event.
The
NRC issued
a
Notice of Violation (NOV) in NRC Inspection
Report
No. 50-397/90-15,
following an inspector
review of the event,
concerning the failure
to properly perform surveys prior to the April 30th event.
NRC
Inspection
Report
No. 50-397/90-18
acknowledges
the receipt of the
licensee's
acceptance
of the
NOV, their response
to the
NOV, and
partial verification of the licensee corrective actions
by the
NRC.
Re uirements
10 CFR Part 20. 103(a)(3) requires,
in part, that for the purpose of
determining compliance with the requirements
of this section the
licensee
shall
use suitable
measurements
of concentrations
of
radioactive materials in air for detecting
and evaluating airborne
radioactivity in restricted
areas
and in addition,
as appropriate
shall
use measurements
of radioactivity in the body ...
as
may be
necessary
for timely detection
and assessment
of individual intakes
of radioactivity by exposed individuals.
Furthermore, this part
requires that when assessment
of a particular individual's intake of
radioactive material is necessary,
intakes
less
than those
w'hich
would result from inhalation for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any one day or for 10
hours in any one week at uniform concentrations
specified in
Appendix B, Table I; Column
1 need not be included in such
.
assessment,
provided that for any assessment
in excess
of these
amounts
the entire
amount is included.
, Ma
20
1990 Event
The licensee's
HP support
group performed whole body counting
(WBC)
of the worker in accordance
with WNP-2 procedures
(RPI 5.7, 5.8,
and
5. 9) on May 20-21,
1990.
WBC consisted of WNP-2 counting and having
a local contracted
laboratory also perform
WBC counting of the
worker.
The licensee
issued
a formal assessment
report of the
individual's uptake
on June
27,
1990.
Even though the licensee
had
documentation that
some of the activity attributed to a lung burden
by the licensee
was in fact a gastrointestinal
burden (identified by
the contract
WBC laboratory),
the licensee
elected to treat the
uptake activity conservatively
as representing
a lung burden of
0. 160 microCurie (uCi) of insoluble cobalt 60.
The
NRC inspector
noted that the licensee's
formal assessment
narrative erroneously
referenced
WBC results
using nCi (nanoCuries)
when the values in
fact represented
microCurie quantities.
The official WBC results
attached
to the report provided the correct quantities.
Values
contained in the narrative yielded meaningless
results.
Prior to the
May 20th
WBC, the subject worker s activities in the
spent fuel pool area
had resulted in the worker being exposed to
approximately 1.2 MPC-hrs of airborne radioactivity on May 20th,
as
determined
by air sampling.
This was
documented
in the site MPC-hr
Log maintained
by the plant
HP group.
The licensee's
subsequent
assessment
of the worker's
WBC results stated that, via
calculations,
using
a total uptake to the lungs of 0. 160 uCi of
cobalt 60, the worker was exposed to approximately 0.58 MPC-hrs of
airborne radioactivity.
This value is less
than that already
documented for the individual prior to whole body counting which is
a.routine finding, but incongruous with the determination that the
worker had
a 0. 160 uCi uptake which was approximately
13 percent of
a maximum permissible
organ burden -
MPOB (1.2 uCi - Table 5,
ANSI
N343).
4
J
Cl
The inspector determined
on August 1, 1990, during an examination of
the licensee's
assessment
report that an error
had been
made in the
back calculating of the airborne radioactivity concentrations
necessary
to produce
an uptake of 0. 160 uCi to the lungs.
NRC
calculations
using the guidance
contained in NRC Regulatory Guide 8.26, "Applications of Bioassay for Fission
and Activation
Products, 'ndustry standard
ANSI N343-1978,
"American National
Standard for Internal Dosimetry for Mixed Fission
and Activation
Products,"
and
ICRP II, "Report of International
Commission
on
Radiation Protection
Committee II on Permissible
Dose for Internal
Radiation,"
(1959) indicated, that the worker involved in the
May
20th event
was exposed to, at the minimum,
114 MPC-hrs of airborne
radioactivity.
The methodology
used
by both the
NRC and the
licensee
was in agreement with the guidance
contained in IEIN No.
82-18,
"Assessment
of Intakes of Radioactive Materials
by Workers,"
which establishes
the methodology for determining compliance with 10 CFR Part 20. 103 requirements.
On August 2, 1990, the
NRC inspector
and the Region
V Reactor
Radiological Protection
Branch Chief contacted
the individual
(HP
support group licensee
employee) that performed the
MBC assessment
and wrote the narrative
report of the worker's uptake calculations,
to discuss
the apparent
discrepancies
in the licensee's
assessment
calculations.
The licensee
representative
stated that they
(licensee)
were aware of the error and the MPC-hrs of exposure for
the worker
had been revised to approximately
113 MPC-hrs,
and that
the initial low MPC-hr value
was
due to a mathematical
manipulation
error.
The licensee's
assessment
of resultant
annual
and
50 year
committed dose to the worker's lungs
was determined to be less
than
a total of 1
REM with the majority of the dose being experienced
in
the first year following the uptake.
There were
no discrepancies
noted with these calculations.
These calculations
are not
specifically required
by 10 CFR Part 20.
A 50 year committed dose
equivalence limitation of less that 15
REM per year limitation is
discussed
in ICRP literature
(1978
ICRP 30),
The overall risk
associated
with this dose to the worker is negligible considering
the worker's life time exposure to date.
However, the inspector is
concerned
about the licensee's ability to properly assess
and track
workers'xposures
to airborne radioactivity as required
by 10 CFR Part 20. 103.
The licensee
provided the worker with a statement
of
exposure
to radioactive materials while employed at WNP-2 (via mail)
as required
by 10 CFR Part 20.408, stating that an uptake of 0. 160
uCi had been
measured.
The inspector determined that the site
HP Supervisor
was informed on
May 21, 1990,
by the
HP support group
that the worker had received
less that
1 MPC-hr of exposure
due to the
May 20th event.
As of
August 9, 1990, the
HP Supervisor
was still unaware of the corrected
exposure to the individual involved in the
May 20th event
and MPC-hr
logs still indicated that the worker had only received approximately
1.2 MPC-hrs of exposure for that particular job.
Even though the
onsite
HP group was
unaware of the corrected
exposure of the worker
and the worker had completed his work at the site
and departed
the
State,
a reevaluation of the radiological protection requirements
for continued work operations
was accomplished
on May 20,
1990,
prior to allowing work to resume.
This evaluation
was documented
on
ROR 2-70-021.
During this inspection, it was determined that an independent
review
of the initial calculations
was not provided prior to issuance
of
the assessment
report.
The inspector also determined that
identification of positive uptakes
using
WBC results
do not result
in calculations
being
made to determine
the MPC-hr of exposure for
personnel.
This was verified by the review of the documentation
associated
with another personnel
contamination incident that
occurred
on April 30,
1990.
A ril 30
1990 Event
A worker was
WBC as
a result of being found with extensive facial
contamination following work in the plant as
documented
on
ROR
02-90-0009,
dated April 30,
1990.
Subsequent
WBC on April 30 and
May 1, 1990, positively identified that the worker had received
an
uptake of approximately 0.04 uCi of cobalt 60, 3.35 percent of an
MPOB, which equates
to a lung burden using ANSI N343 Table
5 data.
The licensee's
WBC data did not specifically identify that the
activity was measured
in the lungs but the reference to 3.35 percent
of an
MPOB directly relates
to the lungs.
The
NRC inspector
determined that such
an uptake would have
been the result,
by back
calculation to the estimated
time of exposure,
of being exposed to
the equivalent of 28 MPC-hrs of cobalt
60 airborne radioactivity.
A
review of the work package
associated
with Radiation Work Permit
(RWP) 2-90-00219 (the
RWP that the worker was signed in on at the
time of the April 30th event) did not include any documentation of
MPC-hr tracking for the subject worker based
on work related air
samples
or following the event/WBC.
Air samples
were not obtained
during the April 30,
1990, work operations.
The April 30th event is
another
example of a breakdown in licensee
communications
between
support group and the onsite plant
HP group.
F i ndi nein
The failure to perform accurate
and timely assessments
of
radioactivity uptakes
by workers,
and
a failure to accurately track
personnel
exposures
to airborne radioactive materials
are considered
a violation of 10 CFR Part 20. 103(a)(3) involving two examples.
(397/90-22-02)
~Tt ti
(86721)
The licensee's
program for transportation of radioactive materials
(RAM)
and low level radioactive waste
(LLRW) was examined for compliance with
the requirements
of TS 3.11.3,
and 49
CFR Part 173.401
(Department of Transportation -
DOT regulations);
and agreement with the
commitment contained in Section 11.4.3. 14 of the
FSAR;
and the guidance
contained in NRC IEIN 90-31 and 90-35.
'I
The inspector
examined
licensee
procedures
associated
with the packaging,
delivery,
and shipment of RAN/LLRW.
No major or significant changes
had
been
implemented.
The licensee's
procedures
include detailed checklists
for various types of
RAM shipments
encountered
at MNP-2.
These
procedures
appear to be adequate
to ensure
regulatory
requirements
are
complied with during
RAN/LLRW shipments.
The licensee
had recently
reassigned
responsibility for LLRM and
RAM preparation
and shipment to a
supervisor within the plant
HP group that had previously (3 years
ago)
had responsibility for the
RAM/[.LRW shipping program.
The licensee
had
made approximately
43
LLRM and 8
RAM shipments
since the
beginning of the year.
The licensee
knew of no incidents involving RAM
shipments originating from WNP-2.
lO CFR Part 71.5 requires,
in part, that each licensee
who transports
licensed material outside of the confines of the plant shall
comply with
the regulations
appropriate
to the
mode of transport of DOT in 49
CFR
Parts
170 through 189.
49
CFR Part 173.415(a)
requires,
in part, that each shipper of a
Specification
7A package
must maintain
on file for at least
one year
after the latest shipment,
and shall provide to
DOT on request,
a
completed
documentation tests
and
an engineering evaluation
showing that
the construction
methods,
packaging design,
and materials of construction
comply with that specification.
The inspector
discussed
with the licensee
representatives
a particular
shipment (90-20-02) involving Type
A quantities of non-fissile
radioactive materials to a local contract laboratory usinq
a supposably
DOT Specification
7A package.
The licensee's
representative
having just
taken over the program could not produce
documentation attesting to the
package
meeting Specification
7A performance tests,
but believed since
they routinely use the package that the necessary
documents
were
on file
at WNP-2.
This is considered
an unresolved
item pending further
NRC review of
licensee
documents
during a future inspection.
(397/90-22-03)
An unresolved
item is a matter about which more information is required
to ascertain
whether it is an acceptable
item,
a deviation, or a
violation.
No violations or deviations
were identified in this area.
5.
~Eit
M ti
t3D703)
The inspector
met with licensee
representatives
identified in paragraph
1
of the report on August 10,
1990.
The inspector discussed
the scope
and
findings of the inspection.
The licensee
acknowledged
the inspector's
findings regarding the apparent violation and initiated action to
evaluate
apparent corrective actions that may be necessary.