ML17286B119
| ML17286B119 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/13/1991 |
| From: | Louis Carson, Chaney H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17286B117 | List: |
| References | |
| 50-397-91-31, NUDOCS 9111040055 | |
| Download: ML17286B119 (15) | |
See also: IR 05000397/1991031
Text
0
INSPECTION
REPORT
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.:
50-397/91-31
License No.:
Licensee:
Washington Public
Power
Supply System
(Supply System)
P.
0.
Box 968
3000 George Washington
May
Richland,
WA
99352
Facility Name:
Washington Nuclear Project
No.
2 (WNP-2)
Inspection at:
WNP-2 site,
Benton County, Mashington
Inspection
Conducted:
Septem er 2-6,
1991
Inspected
by:
aney,
Senior Rad'a
ion
S ecialist
d 137/
a
soigne
Ioi3 7
Approved by:
~
~
~
arson
Radiation Specialist
Reacto
adi ol ogi cal
Pr otecti on
Branch
a
>gne
a
e
gne
~Summar:
Areas Ins ected:
Routine
unannounced
inspection of the licensee
s radiation
pro ec ion
program including aspects
of: occupational
radiation
protection, radiological environmental
monitoring, transportation
of
radioactive materials,
control of radioactive materials
and contamination,
and
follow-up on previous inspections
findings.
Inspection procedures
92701,
92702,
84750,
90713,
86750,
83729,
and 83750 were used.
Results:
The licensee's
root cause
analysis
(evaluation) of the April 17,
.PKL, exposure
incident had not yet been completed
nor had long term
corrective actions
implemented.
From review of the evaluation
as
completed-to-date
and discussion with licensee
representatives
violations
involving inadequate
radiation surveys
and failure to instruct w'orkers are
discussed
in Section
2.
Section
5 describes
poor air sampling practices,
problems with radiation monitors
and storage of a sealed
source.
91110
o
5000397
ADOCK 0500
0
-2-
No violations were identified in the Radiological
Environmental Monitoring
Program.
Inspection results indicate that this portion of the licensee's
program is being
implemented very well.
'verall, it does
not appear that the licensee's
performance
nor its evaluation
of activities in the radiation control area
are improving.
DETAILS
Persons
Contacted:
Licensee:
~J.
Baker,
Plant Manager
J. Allen, Supervisor,
Radioactive
Maste
(RW)
~J. Arbuckle, Compliance
Engineer
- J. Bell, Manager,
Plant Services
C.
Card,
Supervisor,
Radiologi'cal
Environmental
Monitoring
Program
~R. Graybeal,
Manager,
Health Physics/Chemistry
(HP/Chem)
D. Pisarci k, Assistant
Manager,
HP/Chem
- R. Haiqht, Corporate Radiological Health Officer
~S.
Davidson,
Manager,
Plant equality Assurance
- L. Bradford, Supervisor,
HP Planning
Others:
~D. Mill-iams, Nuclear Engineer,
Bonneville Power
Administration
(*) Denotes
some of the personnel
attending
the exit meeting held
on
September
6,
1991.
Other licensee
personnel
attended
the exit meeting
,
and other licensee
personnel
were contacted. during the inspection,
and
not reflected in the above list.
Follow-u
on Previous
Ins ection. Findin
s
(92701
(Closed)
Ins ector Follow-u
Item 397/91-10-02:
"Administrative Exposure
>m>
verexposure
oo
ause
na ys>s
ev>ew
- This item was previously
discussed
in NRC Inspection
Report
No. 50-397/91-10,
and involved the
licensee
performance
of a root cause
analysis
for the April 17, 1991,
radiation exposure
incident involving three workers.
This item is being
closed
and
a Notice of Violation issued
because
of licensee's
delay in
Mi enHfying the cause(s)
of the incident and implementation of long term
corrective actions.
Review of Incident
On April 13,
1991,
a resin spill occurred (overflow of the Condensate
Resin
Backwash
Tank) that spread
radioactive
spent resin over nearly the
entire surface
area of the 437 foot elevation of the Radwaste Building.
Cleanup of the affected
areas
commenced
immediately.
On April 17, 1991,
during the cleanup of the shield cubicles
housing the Reactor Mater
Cleanup
(RMCU) System
spent resin tanks three workers
became
aware that
they had exceeded their weekly administrative
dose limit of 300 millirem.
NRC Inspection
Report
No. 50-397/91-10
discusses
the resin spill and
exposure
incident in detail.
Following a management
stop work order and
a review of the radiological controls in place,
the licensee
implemented
immediate corrective actions to their radiological controls for the
cleanup.
These
temporary
changes
to the cleanup Radiation
Work
Permits
(RWPs) were found by the onsite
Regional
NRC inspectors
to be
sufficient to allow continuation of the cleanup activities'he
licensee
documented
the incidents
and initiated
a root cause
analysis of both
incidents.
No changes
or modifications were
made to permanent plant
rograms or procedures
as
a result'f the exposure incident.
The
icensee
elected to await the findings and
recommended
corrective actions
of the root cause
analysis.
The inspectors
determined
the following information during interviews
with licensee
representatives
during the previous inspection
and this
inspection;
The
HP Technician
(HPT) assigned
by the
HPT to "cover the
. decontamination
work within the
RWCU s'pent resin tank. room had not
attended
the special
prework briefings for this portion of the
cleanup.
0
The alarming type dosimeters
used
by the cleanup workers were
~
~
~
~
laced inside their. protective clothing (cloth and plastic suits)
y the
HPT without consideration
of the ambient noise levels
or the
need to periodically view the readout.
Consequently,
the
cleanup workers did not know that their dosimeters
were alarming
'(at least
one
had entered
the intermittent
mode of alarming to
conserve
power) until it was accidently overheard
by one of the
other workers in the
room.
The
HP Planning Supervisor
who briefed the workers did not include,
in the Radiation
Work Permit
(RWP) the verbal instructions
presented, at the prework briefings concerning the'conduct of
initial radiation surveys in the
RWCU spent resin tank room and
actions to be taken
when exposure
rates
exceeded
a predetermined
1 evel.
No historical radiological
surveys 'of the tank rooms were
used
during the briefings.
The coverage
HPT did not accurately identify the ambient radiation
exposure
rates within the
RWCU tank room or stay in the
room
providing continuous
exposure
status
and controls for the workers.
The inspectors
were informed that the coverage
HPT assigned
by the
HPT had
a previously demonstrated
weakness
for implementing effective
radiological controls.
The turnover- briefing to the coverage
HPT by the
HPT was apparently
marginal at best - no information on "worker
,back-out" radiation exposure
levels or the
need to continually monitor
general
area
exposure
rates within the spent resin tank rooms
was
presented.
As discussed
in the aforementioned
NRC Report, the post incident
radiation surveys
indicated that general
area
gamma radiation exposure
0
I[
0
rates
in the
room ranged
between
0.6 Roentgen
per hour (R/hr) to 70 R/hr
'instead of the coverage
HPT's documented
exposure
rates of 0.2 to'8 R/hr
As of the completion of this inspection
the licensee
had not completed
the root cause
analysis of the expos'ure
incident and development of
corrective actions for the incident.
All gathering of statements
and
documentation
of personnel
inter rogations
had been
completed shortly
.following the incident.
However,
due to the pressing
problems with the
Licensed Operator
Requalification
Program the analyst
having
responsibility
to complete this evaluation
was reassigned
to the group
working on the operator requalification failures root cause analysis..
Based
on discussions
with licensee .representatives
on September
5 and 6,
1991, the inspectors
determined that after approximately
5 months,
no
corrective actions
had
been permanently
incorporated into the
RP program
at. WNP-2 (other than the job specific corrective actions applied to the
completion of the decontamination
of the Radioactive
Waste
(RW) Building)
to prevent
a similar occurrence
during future work in high radiation
areas.
NRC, Position
and Ade uac
of Corrective Actions
The inspectors
noted that
no actions
had been taken to implement controls
that would ensure that:
Alarming dosimeters
can
be heard in high noise
areas
and read
by
the workers.
That instructions
and methods
are provided to ensure
the mandatory
attendance
of all workers at prework briefings, including cognizant
HP technicians.
The instructions
and procedures
for briefings
and procedures
are
enhanced
to emphasize
the necessity for conducting special
briefings of replacement
workers, including HPTs, for high dose
rate jobs.
Specific action points
based
on area
dose rates
are
documented
on
the
RWP.
That significant points covered at briefings are incorporated into
RWPs.
Re ulator
As ects
10
CFR 19. 12 requires,
in part, that all individuals working in a
restricted
area
be instructed
sn the precautions
and procedures
to
minimize exposure to radioactive materials,
in the purpose
and functions
of protective devices
employed,
and in the applicable provisions of the
Commission's
regulations
and licenses.,
The licensee's
failure to ensure that the replacement
HPT was
properly instructed
as to his assignment
is considered
a violation
of 10
CFR 19.12.
(397/91-31-01).
10
CFR 20.201(b) requires that each licensee
make
such surveys
as
may be
necessary
to comply with the requirements- of Part'0
and which are
'easonable
under
the circumstances
to evaluate
the extent of'radiation
hazards that
may be present.
As defined in 10=-CFR 20.201(a),
"survey"
means
an evaluation of the radiation hazards
incident to the production,
use,
release,
disposal,
or presence
of radioactive materials
or other
sources
of radiation under
a specific set of conditions.
The licensee's
fai lure to obtain accurate
radiation surveys during
the initial entry into the
RWCU spent resin
room is considered
an
. apparent violation of 10
CFR Part 20.201(a).
(397/91-31-02)
(0 en) Unresolved
Item 397/85-20-04:
"Post Accident Radioactive
amp in's
em
-
is i
em
as
een previously discussed
in
NRC
Inspection
Reports
Nos.
50-397/85-20,
87-05, 87-29, 88-33, 89-20, 89-29,
89-32,
90-07,
and 90-29
and involved the licensee's
compliance with the
requirements
of NUREG-0/37 regarding the licensee
having the ability to
sample
and quantify the effluent release
rate of gaseous/particulate
radioiodine
under reactor accident conditions (Item II.F. 1, Attachment 2,
"Sampling and Analysis of Plant Effluents").
Subsequent
vendor testing
of the system configuration determined that the sampling efficiency for
the system
was approximately 0.2 percent (requiring
a correction factor
of 500).
In NRC report 90-29 the licensee
was, requested
to provide the
NRC with a schedule for correcting the system's
performance.
The
licensee
responded
with a letter
dated January
23,
1991, stating that
even though the correction factor is large
and the system's
performance
is considered
undesirable
for long term use,
they would use the system
until a state-of-the-art
online radionuclide analyzer could be procured
and installed.
The Manager,
Health. Physics
and Chemistry
and the Manager,
Regulatory
Programs
stated that
a letter describing the schedule of
corrective action implementation will be submitted to the
NRC by Octob'er
31,
1991.
Radioactive
Waste Treatment
and Effluent and.Environmental
Monitorin
The licensee's
Radiological
Environmental
Monitoring Program
(REMP) was
previously examined in part and discussed
in NRC Inspection
Report
No.
50-397/91-21.
During this inspection additional portions of the
licensee's
REMP were examined to determine
compliance with 10
CFR Part
20. 106(g), Facility .Operating
Licensee
Condition 2. C(29), Appendix A,
Technical Specifications
(TSs) 3.3.7.3,
3.12.1,
3.12,2, 3.12.3, 4.12.1,
4.12.2, 6.3, 6.4, 6.5.1, 6.5.2.1, 6.5.2.8.j,
6.5.2.8.m, 6.5.2.9.c,
6.8.'l.i-k, 6.9. l. 10, and.6. 10.3.m;
and agreement with the commitments
contained
in Sections
2. 3. 3. 1,
and
2. 3. 3. 2.4 of the Updated Final Safety
Analysis Report
(UFSAR) guidance
contained in NRC Regulatory Guides
(RGs)
1.23, 4.1,
and 4.15.
The licensee's
implementation of the
REMP sampling program for well and
surface waters,
and land use
census
were examined.
Selected
sampling
e
sites
were visited (approximately
12
including air sampler,
dosimeter,
and proportional
water sampler sites)
and found to be
as described
in the
Offsite Dose Calculation
Manual.(ODCM) and the Annual Radiological
Environmental Monitoring Program Report for 1990.
Several
downwind sectors
were
examined
by automobile
as verification of
'he
1990
Land
Use
Census
(TS 3. 12.2).
No anomalies, were identified.
The
inspectors
also examined
the licensee's
primary and backup meteorological
monitoring instrumentation
and documentation.
Equipment calibration and
data collection programs
adequately satisfy
requirements
and
RG 1.23. recommendatsons.
The inspectors
noted that the licensee
was conducting
a self-initiated
interlaboratory
comparison of environmental
dosimeters
involving MNP-2,
the
NRC,
a local accredited
laboratory,
and the health organizations
in
the states
of Mashington
and Oregon.
The'icensee's
contracted
environmental
laboratory performed satisfactorily
in. the
TS 3. 12.3
required interlaboratory
comparison
program.
The licensee's
audits
have
identified minor biases
in the chemical extraction of iodines in milk due,
to staff turnovers in the contracted
laboratory.
The licensee
had not conducted
any s,ignificant construction other than
the onsite engineering facility referenced
in NRC Inspection
Report
50-397/91-21.
This part of the licensee's
RP program is well managed
and staffed
by
highly qualified and conscientious
personnel.
No violations or
deviations
were identified in this area of the inspection.
Solid Radioactive
Waste
Mana ement
and Trans ortation of Radioactive
a erma
s
One shipment of low-level radioactive
waste
was examined to determine
compliance with the requirements
of MNP-2 Technical Specifications (TS) 3.11. 3, 6.8.1. h, 6.9.1.11,
and 6. 13,
10
CFR Parts
20. 311,
30. 41(c)-(d),
61.55,
61.56,
and 71.5,
and Department of Transportation
'(DOT)
reg'ulations
contained
in 49
CFR Parts
170 through 189;
and agreement with
the guidance
provided in NRC Inspection
and Enforcement Bulletin (IEB)
No. 79-19,
"Packaging of Low-Level Radioactive
Maste for Transport
and
Burial," and various
NRC Inspection
and Enforcement Information Notices
~
(IEINs) related to radwaste
and
RAN transportation activities.
Licensee
shipment
No. 91-35-02,
(a steel liner of Class
A radioactive
wastes,
shipped
as
low specific activity-L'SA exclusive-use carrier, with
a radionuclide content greater
than
DOT Type A2 quantity)
was
made in an
NRC certif'ied shipping cask (USA/9176/A).
The inspectors
examined the
licensee's
completed
shipment bill of lading and waste manifest,
and
pr'ocedures
(11.2.23.20,
'Use of the
NUPAC Services
Transport
Cask Model
14/210L or 14/210H," Revision 2,
and 11.2.23.2,
"Radioactive
Waste
Classification," Revision 8)
~
The licensee's
performance
in this area is satisfactory to ensure
the
health
and safety of the public.
No violations of deviations
were
identified in this area.
5,
.
Occu ational Radiation
and Occu ational
Ex osure Durin
Extended
u
a es
Implementation of the licensee's
radiation protection
(RP) program
w'as
examined to determine
compliance with the requirements
of 10
CFR Part
20. 101,
20. 103, 20.201,
20.202,
and the requirements
of TS 6.8,
6. 11'nd.
6. 12,
a.
b.
Internal
Ex osure Control
During a facility tour on September
2,
1991 (see
Section
6 of this,
report), it was determined that at least
10 general
area airborne
radioactivity samplers
(particulate
and iodine) were configured
such that the exhaust
from the vacuum
pump of the sampler
exhausted
directly across
the inlet of the sampler.
The exhaust flow
appeared
to be influencing the ability of the samplers
to provide
representative
sampling.
These
samplers-were
located in several
locations of the Reactor,
Turbine,
and
RW Buildings.
The licensee
was informed of the inspectors'oncerns
on September
3 and again
on September
6,
1991
and by September
11,
1991 all of the samplers
were reconfigured.
the licensee
indicated that the samplers
in
question
were used for trending purposes
only and quantitative
assessments
of 'airborne radioactivity were obtained
by short term
job specific air sampling.
The licensee's
sampler configuration
could have introduced significant errors in assessment
of low level
airborne radioactivity concentrations.
The inspectors
explained to licensee
representatives
that improper
air sampling
can result in the licensee
being in violation of the
monitoring and surveying requirements
of 10
CFR Part 20. 103 and
20.201.
The licensee's
ability to determine
the airborne
concentrations
within restricted
areas will be considered
an
inspector follow-up item and reviewed in a subsequent
inspection
(397/91-31-03).
Control of Radioactive Materials
and Contamination
Surve
s
and
~on> onn
The inspectors
examined the radiological controls being applied
during the modifications to Residual
Heat
Removal
System
(RHR)
piping.
Workers were found to be following the instructions
contained in the appropriate
Radiation
Work Permit (No.
2-91-00338).
Radiological
surveys of radiation exposure
rates,
airborne radioactivity,
and surface
contamination
were examined
by
'he
inspectors.
Prework and work type surveys
were considered
adequate.
The work involved the cutting of an 18 inch pipe
(RHR-C
system)
and installing a spectacle
The radiological
'ontrols applied during the radiography of the welded joints was
conducted
in accordance
with licensee
procedure
11.2. 18. 1,
"Surveillance of Radiographic Operations."
This procedure
addressed
the concerns
contained in NRC Inspection
and Enforcement
"Radiography
Events at
Power
Reactors."
0
f
K
The inspectors participated in a pre-clos'eout tour of the reactor
containment
on September
5, 199l.
No concerns
were noted.
The results
of the inspections
conducted
so far this year tend to
indicate that the licensee's
RP program appears
to be stagnating.
This
could be the result of the lack of an effective self assessment
program
carried out by independent,
experienced
and technically qualified staff
members.
The licensee's
gA audit program performance
in this area is
satisfactory,
but primarily focuses
on programmatic
aspects.
Only a
small percentage
of gA activities involve performance
based
type reviews
of
RP activities.
These
performance
based
reviews are being conducted
in
a satisfactory
manner
but they only touch
on
a small portion of the
overall
RP program.
The
RP program
has not been comprehensively
reviewed
since startup of WNP-2.
No violati'ons or deviations
were identified in this area.
~Filet
T
The inspectors
performed
independent
gamma radiation
dose
and exposure
rate measurements
utilizing NRC and licensee portable radiation detection
and measurement
instruments.
No anomalies
were identified in general
area
dose rates
and posting of radiation areas.
The inspectors
identified the following during their tour:
A portion of a radiological barrier for a contaminated
area
was
down on the 501 foot elevation of the Reactor Building.
A general
area air sampler
(RB65) on the
572 foot level of the
Reactor Building was found runninq in the bypass
mode, i.e., little
or
no flow through the filter media.
A commercially manufactured
and shielded
10 Curie cesium
137
calibration source
(sealed)
was found on top of a rollaway cabinet,
approximately
3 foot above the floor.
This large (approximately
three-foot high) cylindrical calibration unit was sitting on
a two
wheel dolly which was sitting on top of the cabinet.
Except for
the source manipulating rod no securing of any of the components
was evident to prevent the unit from falling from its perch.
A portable area radiation monitor (ARM) attached
to the spent fuel
pool cleanup
system piping on the 548 foot elevation of the Reactor
Building was energized
but indicating an exposure
rate of zero.
The detector
was determined to be in an area with background
exposure
rates greater
than 0.05 R/hr.
Litter- comprised of used paper/plastic
wrapping materials,
protective clothing (unused
and used),
containers,
cleanup
rags,
and hand tools were noted in the following areas:
RWCU Pump area
on the 437 (3 areas),
467 foot elevation of
the
RW Building.
Pump
P2 area of the
Low Pressure
(LPCS)
Pump
Room
on the 422 foot elevation of the Reactor Building.
The litter in one area of the 437 foot elevation (elevator
vestibule)
area
covered
a significant portion of the vestibule
area
and appeared
to have
been
1'eft there for one
day or more.
Another
area
on the 437 foot elevation of the
RW Building involved the
fenced off liner storage
area
(posted
High High Radiation Area) - a
significant amount of litter (p] astic containers,
rags,
hand tools,
other expendable
materials, etc.,)
was adrift on the floor inside
of 'the area.
The emergency
shower located in the
drum decontamination
area/alcove
(C-124) of the 437 foot elevation of the
RW Building
had access, to,it blocked
by a forklift and
a drum dolly (the dolly
was secured in'.front of the shower
by a chain
and padlock)-.
-Even though the l.icensee
had established
a high radiation storage
area in a shielded portion of the
RW Building for materials,
only 1
bag
was occupying the area at the time of this inspection.
Several
55 gallon drums of packaged
waste with exposure
rates of 0. 1 R/hr
or greater
on contact were stored in the
eneral
area of the 437
foot elevation adjacent
to the truck bay.
e
rums were properly
posted in accordance
with 10
CFR Part 20.203(c)
and
TS 6. 12.
The lead
HPT on duty at the time of the'tour
was informed of the
malfunction, the
downed barrier,
and the air sampler
running in bypass.,
The
HPT took action to correct the deficient conditions.
The
ARM was
removed
from service.
The contaminated
area barrier was rehung.
The air sampler
was replaced.
Licensee
representatives
attending the inspectors'ntrance
meeting were
appraised
of the above findings.
The inspectors
noted that the debris
observed
would complicate
any cleanup
attempt of an area
and cause
unnecessary
personnel
exposure
and generation of radioactive
waste
following a radiological spill.
As of September
6, 1991, all concerns
had been
addressed
except for the cleanup of the debris in the liner
storage
area.
Exit Meetin
The inspectors
met with the licensee
representatives
identified in
Section
1 of this report
on September
6,
1991.
The scope
and findings of
the inspection
were discussed.
The two violations related to the
administrative
exposure
incident on April 17, 1991,
were discussed.
The
inspectors
expressed their dismay that
no action
had been taken to
resolve the apparent
inoperable air samplers
discussed
at the entrance
meeting
on September
3, 1991.
The Plant Manager
(PM) expressed
his
concern that appropriate
action
had not been taken in regard to the
concerns
raised
by the inspectors;
however,
the breakdown
was attributed
0
to the fact that
he
(PH) did not hold
a post entrance
meeting with
his'taff,
as is done following an inspector's
exsimeeHng,
to assigned
responsibilities for evaluating the inspectors
concerns.
On September
'l, the licensee
contacted
the inspectors
to inform they that the air
samplers
had
been modified to correct the problems identified during the
inspection.