ML17286B074
| ML17286B074 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 09/20/1991 |
| From: | Cillis M, Resides H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286B072 | List: |
| References | |
| 50-397-91-26, NUDOCS 9110070207 | |
| Download: ML17286B074 (18) | |
See also: IR 05000397/1991026
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.:
50-397/91-26
License No.:
Licensee:
Washington Public Power Supply System (Supply System)
P.O.
Box 968
3000 George Mashington
Way
Richland,
MA
99352
Facility Name:
Mashington Nuclear Project
No.
2 (MNP-2)
Inspection Location:
MNP-2 Site,
Benton County, Mashington
Inspection
Conducted:
August 5-9,
1991
Inspected
by:
es
d s,
a iation
pecia ist
G.P.
is,
en)or
a )a )on
pec)a is
ae
)ne
V(po q(
a
e
)gne
~Summer:
G.P.
U
s,
le
Reacto
adiological Protection
Branch
a
e
igne
Areas Ins ected:
A routine unannounced
inspection
was conducted of the
)censee
s ra )ation protection
(RP) program,
including: high radiation area
controls,
occupational
radiation exposure,
control of radioactive material,
radiological surveys,
radioactive
source inventories
and leak checks,
maintenance
of respiratory protection equipment,
and followup of previous
inspection findings.
Inspection procedures
83524,
83726,
83750,
and 92701
were addressed.
Results:
The licensee's
program for control of external
exposure
was
saSS>s
actory.
Strengths
were exhibited in the iicensee
key control practices,
radiological
survey accuracy
and administration,
and
review of dose extension
requests.
One violation involving the failure to
label licensed material in accordance
with the requirements
of 10 CFR 20. 203(f) was identified (see Section 50l.
A weakness
was exhibited in the
lack of timely resolution of previously identified radioloqical
issues
regarding radioactive material control
and inventory, respirator fit-testing,
and issuance
of procedures
(see Sections
4 and 5).
9<.>0070~07 9somo
ADOCK 05000397
Q
Persons
Contacted
Licensee
DETAILS
"L. Harrold
Assistant Plant Manager
"R, Graybea),
Manager
Health Physics/Chemistry
(HP/Chem)
- J.
Harmon, Manager, f'lant Maintenance
D. Pisarclk, Assistant
Manager,
HP/Chem
"M. Davidson,
Manager,
Plant Quality Assurance
(QA)
- L. Pritchard,
Supervisor,
J. Hunter, Supervisor,
HP Craft
- R. Mardlow, Supervisor,
Radiological
Services
.
J. Arbuckle, Compliance
Engineer
A. Davis, Principle Radiochemist/Effluents,Engineer
NRC
- C. Sorensen,
NRC Senior
Resident Inspector
"Denotes
personnel
attending the exit interview on August 9, 1991.
The inspectors
met and held discussions
with additional
members of the
licensee's
staff during the inspection.
Follow-u
(92701
and 92702)
(Closed)
Follow-u
Item 50-397/91-07-05
This item concerned
an
au i
o
e
licensee
s ra was
e program performed
by an independent
contractor.
The inspectors
reviewed the corrective actions outlined in
the Supply System Interoffice Memorandum
(IOM) dated July 30, 1991,
held
discussions
with cognizant personnel,
and reviewed supportive
documentation of management
commitments.
The corrective actions
taken
by
the licensee
appear to be satisfactory.
The inspectors
had
no further
questions
in this matter.
(Closed) Notice of Violation 50-397/91-10-03:
This item involved the
licensee
s
as
ure
o a equa
e y pos
a
)g
radiation area
and is
discussed
in NRC Inspection
Report 50-397/91-10.
The inspectors
reviewed
the licensee's
response,
dated
June 12, 1991,
and verified that
corrective
actions
had been adequately
implemented.
The inspectors
had
no further questions
in this matter.
External
Occu ational
Ex osure Control
and Personal
Dosimetr
(83524)
The inspectors
reviewed the licensee's
program for controlling external
exposure,
which included the control of high (100 mrem/hr
up to < 1000
mrem/hr)and high-high (> 1000 mrem/hr) radiation areas
and personnel
exposure
extension
requests,
to verify compliance with 10 CFR 20.101,
10
CFR 20.203,
T.S. 6.12,
Sect>on 12.5.3.1 of the Final Safety Analysis
Report
(FSAR); and with the guidance
contained in Regulatory Guides
(RG)
8.2, "Guide for Administrative Practices
in Radiation Monitoring" and
0
AI
p
f
I
fr
8. 10, "Operating Philosophy for Maintaining Occupational
Radiation
Exposures
As Low As Is Reasonably
Achievable".
The following licensee
procedures
were reviewed:
PPM 11.2.5.2,
"Authorization to Exceed Administrative Exposure
Guides"
PPM 11.2.7.1,
"Area Posting"
PPM 11.2.7.3,
"Entry Into and Egress
From High Radiation Areas"
Based
on review of these
procedures,
discussions
with HP technicians
and
supervisors,
and observation of the licensee's
control practices,
the
licensee
appears
to be implementing its program satisfactorily.
Positive control of locked high and high-high radiation areas
was
demonstrated
by strict established
key controls, routine observation of
all high and high-high radiation areas,
supervisory review of documented
observations,
and control
and maintenance
Radiological
Work Permits
(RWP).
All control factors evaluated
by the
inspectors
appeared
to be in accordance
with both
NRC and licensee
requirements.
The inspectors
reviewed
10 percent of the dose extension
requests
issued this year,
A cross section of site
and contract personnel
requests
were reviewed for accuracy,
completeness,
and compliance with
licensee
procedures
and
NRC requirements.
No discrepancies
were noted.
The licensee's
program in this subject
area continues to meet their
safety objectives.
No violations or deviations
were identified.
4.
Occu ational Radiation
Ex osure
(83750)
A.
Cleanin
and Stora
e of Res irator
E ui ment
Cl
The inspectors
reviewed the licensee's
program for the maintenance
of respiratory protection equipment
(RPE) to verify conformance with
RG 8. 15, Acceptable
Programs for Respiratory Protection",
ANSI
Z88.2-1980Property "ANSI code" (as page type) with input value "ANSI</br></br>Z88.2-1980" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
"Practices for Respiratory Protection",
and
"Manual of Respiratory Protection Against Airborne Radioactive
Materials".
The inspectors
reviewed the following licensee
procedures:
RSI 3.0
"Repair of MSA Respirators"
PPM 1. 9.8
"Plant Breathing Air equality"
PPM l. 9.4
"Use of Industrial Respiratory Protection"
Section
8 of ANSI Z88.2-1980
and Section
9 of NUREG 0041 give
specific guidance for the collection, cleaning
and decontamination,
repair,
and storage of RPE.
The inspectors
noted that these
functions are being performed at the Plant Support Facility (PSF) in
accordance
with accepted
industry standards
and plant procedures.
One
RPE manufacturer's
equipment,
is used
by the Supply System to
maintain continuity and quality control.
Section 8.5 of ANSI
Z88.2-1980Property "ANSI code" (as page type) with input value "ANSI</br></br>Z88.2-1980" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. states,
in part, "Respirators
shall
be stored to prevent
)'f
>
distortion of rubber or other elastomeric
parts.
Respirators
shall
not be stored in such places
as lockers
and tool boxes
unless
they
are protected
from contamination, distortion,
and damage."
The
inspectors
observed that ready-for-use
respirators
in the
RPE issue
room on the 467 foot level of the radwaste building were found in
bins and piled on each other in a manner which could distort the
face piece
and result in an improper seal.
This observation
was
brought to the licensee's
attention.
The licensee
acknowledged
the
inspectors'bservation.
Fit Testin
of RPE
Discussions
were held with licensee
representatives
concerning the
frequency of fit-testing of respirators,
License representatives
stated that fit-testing is performed
on
initial respirator fit only, and that
no prescribed
frequency for
subsequent 'fit-testing of respirators
has
been established.
Section
6.ll of ANSI Z88.2-1980
recommends
that
a qualitative
and
quantitative "respirator fitting test shall
be carried out for each
wearer of a negative pressure
respirator at least annually".
Several staff members
informed the inspectors that they had not been
fit-tested since
1984 and were still qualified for respirator
use.
Subsequent
to the inspectors'bservations,
the licensee
conducted
a
survey of the other licensees
in Region
V and found that all have
a
regular fit-test frequency.
All but one perform a fit-test for all
qualified personnel
on an annual
basis.
Discussions
with the
licensee
revealed that the
need for a formalized fit-test program
delineating fit-testing frequency
and techniques,
had been
determined at least
two years
ago.
As yet,
no procedure is in place
to meet that need.
The licensee
does,
however,
conduct annual
medical
screenings
to determine if fit-testing should
be performed
again.
The screening
is done using
a detailed history form designed
by a physician to identify conditions (substantial
weight gain or
loss,
dentures,
surgery, etc.) that would change
the effectiveness
of the face seal.
These
forms are reviewed by a Supply System nurse
and any questionable
items are discussed
with the physician.
Based
'n
the inspector's
findings,
a licensee
representative
stated that
current practices
would be re-evaluated
regarding fit-testing and
procedure
issuance.
This is viewed by the inspector
as
a positive
step,
and will be reviewed during
a subsequent
inspection.
(50-397/91-26-01)
Breathin
Air S stem Radiolo ical Surve
s
Another
item reviewed involved the breathing air quality,
specifically, radioactive contamination of the breathing air supply
system.
This was reported to the inspectors
by the licensee
during
the inspection period.
This was first identified when the desiccant
was
removed from the
Control
and Service Air (CAS) dryers
as part 'of the post R-4 outage
clean-up.
Isotopic analysis
revealed trace
amounts of Co-60 and
,gh
Zn-65 in the desiccant
and in the Service Air (SA) header.
A
Problem Evaluation
Request
(PER) 289-0627
was issued
on July 26
1989.
The
PER identified the cause of the contamination
as being
from the "wake effect" associated
with reactor building effluent
release
stack
and the intake for the
SA system.
Recommendations
were
made to study the wake effect, determine
the source
term in the air
system,
examine possibilities of increasing the stack height,
and
g
erform isotopic analysis of the air filter elements
on a reqular
asis.
To date
no changes
are planned to increase
the height of the
stack,
nor have
any procedures
been
issued to accommodate
isotopic
analysis of the air filters.
The radiochemist stated that
he
currently performs
an isotopic analysis
on the inlet filters, but no
plant procedure currently requires the analysis or documentation
of
the results.
The second
occurrence
indicating contamination in the
SA System
occurred
June
19,
1991 when
a "substantial
amount of water drained
from the service air supply to
RMCU F/D (from SA-V-22)."
There
was
no qualitative radiochemical
analysis
performed
on the water, but
the area it touched,
and the outlet fittinq, according to
Supervision,
when surveyed
was approximateTy
1000
dpm.
PER 291-539
was issued
and,
based
on an evaluation of samples
taken after
re-opening the system,
a work control stoppage
was placed
on the
system.
No contamination
was detected
when samples
were taken
downstream.
The system
has not been
opened since then.
Maintenance
Mork Request
(tQR) nos.
AR 4913,
AR 4914,
and
AR 4849 have
been
flagged to preclude
use or maintenance
of the system without prior
rad>ological
surveys.
The need to establish
routine radiological
survey practices
as part of SA system maintenance
was acknowledged
by the licensee.
Currently,
PPM 1.9.8,
Rev.
3, - "Plant Breathing
Air equality", is the only procedure
used for evaluation of air
contaminants.
No isotopic analysis
or radiological
surveys
are
indicated or required
by this procedure.
The licensee
has indicated
that action will be taken to implement periodic radiological
surveys
of the
SA system.
Licensee actions to resolve
SA system
contamination
problems will be reviewed during a subsequent
inspection
(50-397/91-26-02).
The inspectors
concluded that the licensee's
occupational
exposure
control program was fully capable of meeting their safety objectives
for the protection of personnel
from exposure to radiation.
However,
weaknesses
were identified in the timely resolution of
respirator fit-testing and
SA system contamination.
No violations
were identified.
5.
Control of Radioactive Materials
and Contamination
Surve
s
and
on1 or>n
~SUrve
s
The inspectors
reviewed the licensee
s radiological survey program,
radioactive
source inventory and leak checks,
and
RAM control to
verify compliance with 10 CFR 20.201,
10
CFR 20.203,
4.7.5. 1, 4.7.5.2, 4.7.5.3,
and site procedures.
The following plant procedures
were reviewed.
PPM 11.2. 13. 1, "Direct Area Radiation
and Contamination
Surveys"
PPM 11.2. 14.7,
"Leak Testing of Radioactive
Sources"
PPM 11.2.7.1,
"Area Posting
PPN ll.2. 14.3, "Storage of Radioactive Material"
PPM 11.2. 14.4, "Inventory Control of Radioactive Material"
PPN 11.2.24.1,
"Health Physics
Work
Routines"'he
inspector
reviewed selected
radiation, contamination,
and air
particulate activity surveys to verify compliance with procedures
PPM 11.2. 13. 1, 11.2.14.4,
and 11.2.14.7
and found no deviations
from
the procedures.
Selected radiation surveys of areas within the
reactor building and the radwaste building were compared with the
results of independent
surveys
performed
by the inspector (Ion
Chamber
Model R0-2, serial
number 009154,
due for calibration
on
9/10/91,
survey meter
was used).
No marked differences
were noted.
Surveys
were reviewed for completeness
and accuracy,
the logs were
current
and lead technician
and supervisory
checks
were
made
as
required.
The licensee's
performance in this area is considered
satisfactory.
Licensed Material
Inconsistency
in the terminology used to describe radioactive
material
verses
licensed material
was noted.
This is significant in
so far as
members of the licensee staff were confused
over what
constitutes
radioactive material
and
how it should
be accounted for
and labelled.
10 CFR 20.3 defines "licensed materials"
as "source
material,
special
nuclear material, or by-product material
received,
~ossessed,
used,
or transferred
under
a general
or specific
icense...", yet two procedures
concerning radioactive material
storage or inventory
PPM 11.2. 14.3 and
PPN 11.2. 14.4, specifically
exclude by-product material.
Discussion with HP management
revealed
an understanding
consistent with 10 CFR 20.3 regarding what is or is
not radioactive material, but first line supervision perceived
by-product material
as non-licensed
material
and therefore not
subject to the controls delineated
in site radioactive material
control
and accountability procedures,
This confusion lead to
improper implementation of site procedures
and the resultant
problems
described
in paragraphs
5C and
5D.
Accountabilit
Radioactive
source accountability
and leak checks
were reviewed for
compliance with TS and plant procedures.
Leak checks of licensed
radioactive
sources
were performed in accordance
with procedure
PPN
11.2. 14.7,
and copies of the surveys
were attached to the source
inventory sheet for verification and ease of reference.
However,
the inspector considered
the licensee's
over-all accountability
program to be marginal regarding
source labelling and verification
by physical identification of radioactive material
as
noted below.
Labels
on radioactive
sources
in storage
wet e not being verified as
required
by site procedure
PPH 11.2. 14.4; which states,
in Section
11.2. 14.4.5 C.5., "Verify sealed
sources
have
been properly labeled,
This includes radioisotope, activity and date of determination,
identification number,
and radiation levels at the exterior surface
of the container
and at
3 feet (or 1 meter
as appropriate - ensure
that paperwork units agree)";
and Section 11.2. 14.4.5.C.2.,
"Verify
that all licensed radioactive material listed in the log book or the
computer
summary of sources
can
be located either at the storage
area or has
been
checked
out of the storage
area
on the Utilization
Log."
The sources
were stored in a locked safe
and in various
wooden
shipping crates
in Warehouse
No.
5.
A list on the outside of the
safe
and labels
on the boxes
were
used to identify the sources
vice
actually sighting the sources.
It was brought to the licensee's
attention that the current practice of verifying source
presence
by
reviewing
a list on a container
does not meet the requirements
of
site procedure
PPH ll.2. 14.4. for sighting of sources
and
verification of label data.
The licensee
has taken steps to verify
all source labels for adequacy of information, condition of sources,
and to update the source inventory.
It was noted that procedure
PPH 11.2
~ 14.4, "Inventory Control of
Radioactive Material", states,
in Section
A. 1.; "Utilization Log for
Sealed
Sources...
shall
be maintained at the radioactive material
storage
area."
Contrary to that, the utilization log for the
Warehouse
No.
5 radioactive material
storage
area is maintained at
the plant access
control point.
gA Surveillance
report 2-88-226
(issued 1/31/89) identified the
same problem and noted that since
the storage
area is under
HP cognizance
and control of the log by
seems practical, alternative
placement of the log should
be
reflected in the procedure.
To date
no action
has
been taken to
either revise the procedure or relocate
the Source log to Warehouse
No.
5.
This observation
was brought to the licensee's
attention
during the exit interview.
The inspectors
noted that two procedures
listed in the Plant
Procedures
Manual
Index
for the accountability of non-source
radioactive material,
(P.P.H.
1. 12.7,
"Extended
Term Radioactive
Material Storage",
and ll.2. 14.9, "Storage
and Control of Site
Generated
Radioactive Material" ) had not been
issued
as of the date
of this inspection.
A licensee
representative
stated that these
procedures
have
been
on the index for approximately two years,
but
only
PPM 1. 12 '
is available in draft form.
This observation
was
brought to the licensee's
attention.
This is an example of the lack of timely resolution in response
to a
self identified problem.
The licensee
informed the inspector that
a
procedure
was being written which specifically addresses
by-product
material
produced
)n the plant.
~Label
1 in
10 CFR 20.203 states,
in part, that "each container of licensed
material shall bear
a durable, clearly visible label identifyinq the
radioactive contents",
and that each label "will include radiation
levels,
kinds of materials,
estimate of activity, date for which
activity is estimated",
etc.
Review of plant procedures
and discussions
with HP management
revealed that procedural
instructions
on labelling of radioactive
material
were not being adhered to.
This is supported
by the
following observations.
On August 7, 1991, multiple examples of non-labelled radioactive
material
were observed
by the inspectors
and the licensee
inside the
radwaste building and outside the protected
area.
Three B-25
shippinq containers
containing greater
than
10 CFR 20, Appendix
C
quantities of licensed radioactive material
were discovered
by the
inspectors
in the waste
compacting
area of the radwaste building.
The area
was posted
as
a radioactive material
storage
area.
No
labels
were
on the B-25 shipping containers
to indicate the
information required
According to the licensee,
radioactive material
had been
packed in
the containers
since 8/5/91,
and were closed
and left unlabelled
by
the radwaste
personnel.
The workers did not realize that the boxes
must
be labelled
when closed.
HP was not contacted
by the radwaste
technicians
to label the containers after closure.
Subsequent
to
notification of the inspectors
observations,
the licensee
labelled
the containers
as required
and counseled
the individuals involved.
Discussion with the licensee
on 9/12/91 revealed
the approximate
curie content to be as follows:
Ce-141
Ce-144
Zn-65
15.6
mCi
5.16
mCi
9.86
mCi
17.2
mCi
.53
mCi
3.5 mCi
20.8 mCi
Outside the the protected
area,
near Marehouse
No. 5, another
B-25
shipping container
was found in a similarly posted
area without any
labelling identification as to the radioactivity or contents of the
container.
The licensee
could not provide the inspectors
with
information as to the contents
or the activity.
Three packages
containing radioactive material
were discovered
in the warehouse
No.
5 storage
area without labels
on them.
The licensee
took immediate
action to correct the labelling deficiencies in the radwaste
building and Marehouse
No. 5. Discussion with HP management
on
August 15, 1991, indicated that the licensee
was implementing
further corrective actions for the other
areas.
g
II
The failure to label containers
of radioactive material
reoresents
an apparent violation of 10 CFR 20.203(f) (50-397/91-26-03).
The licensee's
program for the control of radioactive material
appears
to meet their safety objectives.
Failure of the radiation
protection staff to understand
the requirement for labelling
radioactive material is considered
a weakness.
Tours
Inspection of radioactive material
storage
areas
in the radwaste
building, the turbine generator building, and in Marehouse
No.
5 lead to
concerns
regarding housekeeping,
packag)ng,
and posting of radioactive
material.
Housekeeping,
posting,
and overall maintenance
of the storage
areas within the radwaste
and turbine generator'uilding
was
good with
the exception of cigarette butts found in the turbine generator building
truck bay.
The inspectors
noted that conditions in Marehouse
No.
5 were
not up to the
same
standards
as the radwaste building.
The storage
area
in Marehouse
No.
5 was found to have non-radioactive material stored in
with radioactive material,
boxes
stacked
on boxes bearing warninas not to
stack, radioactive material labels
obscured
by loose pieces of p'fywood,
pallets,
and other boxes,
empty containers,
and, in one instance,
a box
with no indication as to contents
or activity.
This box was later opened
to reveal
a contaminated
turbine bushing wrapped in yellow PVC.
Surveillance
Report 2-88-226
and
ION dated
June
27,
1991 from the Plant
Fire Marshal
addressed
unsatisfactory
and unsafe
housekeeping
conditions
in Marehouse
No. 5, again indicating
a lack of attention to problems in a
timely manner.
These observations
were brought to the licensee's
attention at the exit interview.
The inspection of radioactive material in Marehouse
No.
5 also revealed
multiple examples of inadequate
packaging,
such
as incomplete covering of
items, protective packaging
coming off due to deterioration of tape,
and
holes in protective packag)ng.
This is of concern
because,
in two cases,
the items were unidentifiable
due to inadequate
labelling and
had loose
contamination
on the items.
HP supervision
acknowledged that the
inability to identify the item or the party responsible for that material
presented
both an accountability problem and the
need to improve the
labelling practices.
Inspection of the laydown area
near Marehouse
No.
5 revealed radiological
posting in various stages
of deterioration.
Four sea
vans
each
had at
least
one intact "CAUTION RAOIOACTIVE MATERIALS" sign.
The others
were
either completely faded or missing.
The postinq
on
a B-25 shipping
container
had deteriorated
to the point of total illegibilityand was
literally falling apart.
The licensee's
attention to detail while
conducting tours
was questioned
by H.P. Supervision.
These observations
were brought to the licensee's
attention
and immediate corrective actions
were taken.
The inspectors
concluded that the licensee's
Radiation Protection
Program
continues to meet their safety objectives.
Exit Interview
I
I
~
The inspectors
met with the licensee
representatives
identified in
Section
1 on August 9, 1991 to discuss
the scope
and findings of the
inspection.
The inspectors
described
the apparent violation as noted in
Section
5 and expressed
concerns
involving respiratory fit-testing
labelling and accountability of radioactive material,
and the need for
management
attention regarding timely response
to problems
and the
issuance
of procedures.
~i
!
I