ML17289B082
| ML17289B082 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/23/1992 |
| From: | Louis Carson, Coblentz L, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17289B079 | List: |
| References | |
| 50-397-92-35, NUDOCS 9212300044 | |
| Download: ML17289B082 (31) | |
See also: IR 05000397/1992035
Text
.
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report:
License:
Licensee:
Facility:
Inspection location:
Inspection duration:
Inspected
by:
50-397
Washington Public Power Supply System
(WPPSS)
P.O.
Box 968
3000 George
Way
Richland,
WA
99352
Washington Nuclear Project
2
(WNP-2)
WNP-2 Site,
Benton County, Washington
October
19
23,
1992
October
26 30,
1992
.
C. Carson
eactor
a saticon
pec>a
>st
a
e
gne
>I
.
Co
entz,
e
r
a >ation Spectra
est
ate
sgne
Approved by:
~Summar:
am
i
eese,
C se
ties Radiological Protection
Branch
II sa
a
e
S gne
Areas
Ins ected:
This routine unannounced
inspection
covered followup items
and the licensee's
radioactive waste
management
program.
The inspection
included gaseous
radwaste
(GRW) management,
liquid radwaste
(LRW) management,
and the Radiological
Environmental
Monitoring Program
(REMP).
Inspection
procedures
92701, 92702,'nd
84750 were used.
Results:
The licensee's
programs for radioactive waste
management
appeared
adequate
in meeting the licensee's
safety objectives.
Three violations,
however,
were identified:
The licensee
had released
low levels of radioactivity in liquids
to the onsite storm drain pond,
a method of disposal
not approved
by 10 CFR 20.301.
2."
3.
The licensee
had not performed
a written safety evaluation for
continuing to operate
the "non-radioactive" Turbine Building sumps
as
a radioactive
system.
Operators
had failed to respond appropriately to alarms
on
WOA-
RIS-31A, the Control'Room ventilation system
remote air intake
radiation monitor.
9212300044 92ii23
ADOCK 050003'P7
8
One non-cited violation was identified; regarding the failure of
radiation protection technicians
to maintain positive control of doors
to "high-high" radiation areas,
as required
by Technical Specification 6.12.1.
In addition,
two items were opened for future inspection,
regarding
(1)
the lack of timeliness in resolving the unanticipated
presence
of low-
level radioactivity in the storm drain pond,
and (2) the alternate
acceptance
criteria used for completing the calibration of the
meteorological
wind speed
and wind direction instruments with the output
computer inoperable.
Finally, the inspection identified as
a strength the comprehensive
and
well-documented efforts of the Radiological
Environmental
Monitoring
Program,
which exceeded
the requirements
of the Offsite Dose Calculation
Manual for maintaining effective oversight of radiological conditions in
the immediate site environs.
l
DETAILS
Persons
Contacted
Licensee
- J
R.
- C
- J
- J
- A.
- W.
C.
- D
- J
- S
- L
- S
- p
- C
- C
- Q
- J
- D
+M.
- J
- W.
- Q
- G
- R
NRC
Baker, Plant Manager
Barbee,
Instrumentation
and Controls
(I&C) Technical
Supervisor
Card, Supervisor,
Radiological
Environmental
Monitoring Program
Chasse,
Regulatory
Programs
Environmental
Engineer
Dabney,
Work Control Hanager
Davis, Principal Health 'Physicist
and Radiochemist
Davison,
Plant Quality Assurance
Manager
Halbfoster,
Chemistry Manager (Institute of Nuclear
Power
Operations)
Feldman,
Assistant
Maintenance
Manager
Gearhart,
Director, Quality Assurance
Grundhauser,
I&C Supervisor
Harrold, Assistant
Plant Manager
Kim, ALARA Engineer
HacBeth,
Radwaste
Supervisor
McGilton, Operational
Assurance
Programs
Manager
Madden, Quality Assurance
Engineer
(QAE)
Parrish,
Assistant Director of Operations
Peters,
Plant Administration Manager
Pisarcik,
Radiation Protection
(RP) Manager
Reis,
Plant Engineering/Compliance
Supervisor
Rhoads,
Operations
Event Assessment
Manager
Shaeffer,'perations
Manager
Shockley,
Health Physics
Manager,
Corporate
Sorensen,
Regulatory
Programs
Manager
Webring, Technical
Manager
- S. Richards,
Deputy Division Director, Division of Reactor Safety
and
Projects,
Region
V
- W. Ang, Acting Senior Resident
Inspector
D. Proulx, Resident
Inspector
I
(*) Denotes
those individuals who attended
the exit meeting
on October
23,
1992.
The inspectors
met and held discussions
with additional
members of the licensee's staff during the inspection.
Followu
92701
tern 50-397
Closed
The inspectors verified that the
licensee
had received,
reviewed,
and taken action
Supplement
2, "High Radiation Hazards
from Incore Detectors
and
Cables."
Item 50-397 91-36-02
Closed
This item involved the licensee's
Updated Final, Safety Analysis Report
(UFSAR).
The inspector
had found
that the
UFSAR Chapter
11, "Radioactive
Waste Hanagement,"
did not
reflect the licensee's
latest
computer
code method
used in quantifying
gaseous-
and liquid radioactive waste effluent releases.
The Offsite
Dose Calculation Manual
(ODCH) had stated that the licensee
used
a
computer
code called
LADTAP II; however,
the
UFSAR had still reflected
that the licensee
used the
GALE computer code.
The inspectors
reviewed the latest
UFSAR change
(Amendment 44),
and
found that the licensee
had incorporated
the appropriate
ODCH references
into the
UFSAR, Chapter ll.
The inspectors
had no further concerns
in
this matter.
tern 50-39
2- 3-03
Clos'ed
This item involved the Radiological
Environmental Monitoring (REHP) group's report that samples of the plant
storm drain pond
had contained
State of Washington reportable levels of
cerium-141,
and cobalt-60.'n
addition, the iodine-131
levels exceeded
the
NRC reporting criterion.
The licensee
had held
meetings with officials of the Washington State
Departments
of Health
and Ecology, in June
1992.
The licensee
had issued
a root cause
and
corrective action report
on storm drain pond, discharge
operations.
The inspectors
completed
an assessment
of the
pond contamination
and the
licensee's
evaluation.
This matter is discussed
in detail in Section
4(d) of this report.
Followu
of Items of Noncom liance
92702
Item 50-397 91-36-03
Closed
This violation involved an engineer's
failure to follow written radiation monitor calibration procedures.
Also, the procedure
had
been technically incorrect,
and the engineer
had
not written a procedure deviation
as required
by administrative
procedures.
Both instances
were violations of Technical Specification (TS) 6.8.1.
The inspectors verified that corrective actions listed in the licensee's
January
24,
1992,
"Response
to the Notice of Violation," had been
implemented.
Also, the licensee's
radiation protection department
had
performed
a self-assessment
on procedural
adherance
in September
1992.
The inspectors
examined
the status of the self-assessment
as presented
in a memorandum,
"Status of Radiation Protection
Department
Procedure
Compliance Plan," dated October 22,
1992.
Based
on the status of the
procedure
adherence
self-assessment
and the corrective actions in the
'esponse,
the inspectors
had
no furthe} concerns
in this matter.
Item 50-397 92-13-02
Closed
This violation involved the licensee's
failure to have written and approved procedures'for
the calibration of
installed personnel
contamination monitors (IPHs).
The
WNP-2 plant had
had at least
12
IPHs in service,
and the corporate organization
had
had
one
IPH in-service.
The violations had
been against
TS 6.8. 1 for not
establishing written and approved
procedures
for calibrating
IPHs.
The inspectors verified that the corrective actions,
as listed in the
licensee's
July 24,
1992,
"Response
to the Notice of Violation," had
4.
been
implemented.
The inspectors verified that radiation protection,
maintenance,
and corporate health physics
had developed
procedures
for
calibrating
IPMs owned by the Supply System.
Based
on the
inspectors'eview
of the
IPH calibration procedures,
there is no further concern in
this matter.
Radioactive'Waste
Treatment
Effluents
and the Radiolo ical
Environmental Nonitorin
Pro ram
RENP
84750
a.
Off as Radiation Honitorin
S stem
(1)
Performance Honitorin
The inspectors
reviewed offgas system data from the licensee's
performance
monitor
(PHE) program,
including graphs trending six
parameters
from September
1990-to,Harch
1992.
In addition, the
inspectors
examined
Procedure
PPH 8.4.46,
"Offgas System
Performance Honitoring," and reviewed efficiency and reliability
test results
from October
1991 to September
1992.
In discussions
with the system engineer
and performance
monitor
engineer,
the inspectors
observed that the
PHE program did not
trend
any radiological
parameter for offgas.
The
PNE engineer
acknowledged
the inspectors'bservation,
and stated that
consideration
would be given to trending offgas radiological
performance.
(2)
Ex losive
Gas Honitorin
TS 3.3.7.12 requires that the explosive
gas monitoring
instrumentation
channel
be operable to detect
hydrogen buildup in
the offgas system.
TS Action Statement ill'requires that offgas
grab. samples
be collected
and analyzed within an 8-hour period if
the minimum number of hydrogen analyzer
channels
are not operable.
The inspectors
reviewed applicable
records related to operation
and reliability of OG-AY-12A, the offgas hydrogen analyzer.
In
addition, discussions
were held with cognizant maintenance
and
engineering
perso'nnel,
and observations
were
made of work in
progress.
The inspectors
noted the following items:
(a)
OG-AY-12A had
been in and out of service several
times in
October
1992.
Review of the licensee's
Limited Condition
for Operations
(LCO) Logbook revealed
LCO entries for OG-AY-
12A dated October
4 and
19,
1992.
In addition,
Problem Evaluation
Request
(PER) 292-1170
stated that
a violation of TS 3.3.7. 12 had occurred
on
October
14,
1992,
when the chemistry department
had missed
the 4-hour offgas hydrogen analysis.
PER 292-1170 stated
that the missed
hydrogen analysis
had
been
caused
by
a
-problem with the gas
chromatograph.
The licensee
'
subsequently
issued
Licensee
Event Report
(LER) 50-397/92-
38-01
on this matter.
(b)
On October 20,
1992,
a chemistry technician
was observed
performing
an offgas hydrogen
sample
and analysis pursuant,
to TS 3.3.7. 12.
The chemistry technician collected the
sample
and performed the analysis in accordance
with
surveillance test
PPH 12.5.23A,
"Recombiner
Sampling
and
Analysis."
(c)
Maintenance
Work Request
(HWR) AP-0911
had
been written for
repairs to OG-AY-12A.
The inspectors
observed
a portion of
these repairs in progress,
and discussed
monitor reliability
with I&C personnel
performing the repairs.
Later review of the
HWR results
revealed that OG-AY-12A was
satisfactorily repaired,
tested,
and returned to service.
In addition, the results of surveillance test
PPH
7.4.3.7. 12.23,
"Offgas Hydrogen Analyzers
A and
B Monthly
Channel
Functional
Test/Channel
Calibration," indicated that
the calibration
was satisfactorily completed.
(3)
Off as Radiation Monitorin
The inspector reviewed surveillance test procedures
PPH
7.4. 11.2.7.2,
"Isotopic Analysis of Gases
at the Hain Condenser,"
and
PPH 7.4.4.5.4,
"Isotopic Analysis of Offgas Samples,"
used for
performing isotopic analysis
on offgas.
The inspector
found both
procedures
were adequate for quantifying offga's.
The inspector
observed
a chemistry technician perform surveillance
test
PPH 7. 1. 1, "HP/Chemistry Shift Channel
Check."
This test
provided
a method for routinely ensuring the operability of
process
and effluent radiation monitors
as required
by TS 3.3,
TS 3.4.3. 1,
and
ODCM 6.2.2.6.3.
The inspector
compared
the
results of three
PPH 7.1. 1 radiation monitor surveillances.
No
notable differences
were found in the data examined.
(4)
REA-RIS-609
A
B
C
and
D WNP-2 Isolation
and Actuation Si nals
The REA-RIS-609 Reactor Building Vent Monitors provide WNP-2's "1"
isolation
and actuation signals
when the Reactor Building Exhaust
Plenum radiation level measures
13 millirad/hour. The isolation.
signal
closes
the Reactor Building secondary
containment
system
isolation valves
ROA-V-1 and 2,
and
REA-V-1 and 2.
The actuation
signal starts
the standby
gas treatment
system.
TS Table 3.3.2-2a,
TS Table 4.3.2.1-1,
and
TS Table 3.6.5.2-1
require the Reactor Building Exhaust
Plenum radiation monitors to
be demonstrated
by testing the isolation
and actuation
functions.
The inspectors
examined the licensee's
test
program
for demonstrating
the REA-RIS-609 "Z" isolation
and actuation
functions operable.
(a)
"Z" Si nal Surveillance Testin
The inspectors
held discussions
with plant system engineers
about the surveillance test
programs for verifying REA-RIS-
609 "Z" signal functions.
The system engineers
discussed
the following surveillance test procedures:
PPM 7.4.6.5.2. 1, "Reactor Building Ventilation
Isolation Valve Operability"
PPH 7.4.3.2.2.11,
"Balance of Plant Logic System
Functional Test"
PPH 7.4.3.2.3.7,
"Secondary
Containment Isolation on
Reactor Building Exhaust High"
The inspectors
found the system engineers
knowledgeable
about the test requirements,
and the surveillance tests
adequately
tested
the "Z" signal functions.
(b)
REA-RIS-609
A
8
C
and
D Calibrations
The inspectors
examined the calibration program for REA-RIS-
609 radiation monitors,
and held discussions
with the
responsible
engineer.
The engineer
discussed
the following
calibration
and surveillance test procedures:
Instrument Haster Data Sheet for REA-RIS-609 A, B,
C,
and
D
PPH 12.3.7,
"Reactor Building HVAC Exhaust
Plenum
. Monitor Calibration"
PPH 7.4.3.2.1. 15A, "Secondary
Containment Isolation
Reactor Building Channel
Functional Test"
PPH 7.4.3.2. 1. 16,
"Secondary
Contaiment Isolation
Reactor Building Vent Channel
A Channel
Calibration"
PPH 7.4.3.2. 1.81,
"Radiation Calibration of Reactor
Building Exhaust
Plenum Monitor REA-RIS-609A"
The system engineer
was knowledgeable
about the calibration
and test programs for the REA-RIS-609 monitors.
The
inspectors
reviewed results
from the June
1992 calibrations
of REA-RIS-609A and REA-RIS-609B,
and did not find any
problems.
The inspectors
concluded that the REA-RIS-609
radiation monitor calibration program was adequate.
(c)
Set oint Calculation for t e REA-RIS-609 Mon'tors
The licensee
was implementing
a program for re-verifying
setpoint calculations of var,ious instruments,
including the
REA-RIS-609 monitors.
The inspectors
compared the licensee's
February
1985
setpoint calculation for the REA-RIS-609 monitors to the
updated setpoint calculations
from Hay 1992.
The
- inspectors'eview
of the two REA-RIS-609 setpoint
calculation methods did not reveal
any concerns.
The
inspectors
considered
the licensee's
setpoint calculation
method program
a positive effort.
The licensee's
program for offgas radiation monitoring, in the aspects
reviewed,
was adequate
in meeting the licensee's
safety objectives.
No
violations of NRC requirements
were identified.
b.
Standb
Gas Treatment
S stem
The inspector
examined
the licensee's
standby
gas treatment
(SBGT)
system surveillance test program.
The
SBGT system is
a engineered-
safety-feature
atmosphere
clean-up
system that has high efficency
particulate air
(HEPA) filtration units and charcoal
adsorption units.
Technical Specification (TS) 3.6.5.3 sets the requirement for testing
the
SBGT system consistent
with Regulatory
Guide
(RG) '1.52,
"Design,
Testing,
and Haintenance Criteria for Post-Accident
Engineered-Safety-
Feature
Atmosphere
Clean-up
System Air Filtration and Adsorption Units
of Light Water. Cooled Nuclear
Power Plants."
The inspector
performed
a system walkdown with the
SBGT system engineer,
and reviewed the following surveillance tests:
PPM 7.4.6.5.3. 1, "Standby
Gas Treatment
System Operability Test"
PPH 7.4.6.5.3.5,
"Standby
Gas Treatment
System
and
Visual Inspection"
PPH 7.4.6.5.3.5B,
"Standby
Gas Treatment
System Unit "B" .HEPA
Filter Test"
PPM 7.4.6.5.3.6B,
"Standby
Gas Treatment
System Unit "B"
Filtration System
Carbon Adsorber Test"
PPH 7.4.6.5.3.6,
"Standby
Gas Treatment
System Adsorber Bypass
Leakage Test"
The inspector
examined
SBGT system performance monitoring evaluation
(PHE) data.
The licensee's
PHE group had trended
several
SBGT filter
parameters
that were based
on
PPH 7.4.6.5.3.
1 test data from February
1991 to August 1992.
The inspector
found the trended data
on
a
positive indication of system performance.
it
7
The surveillance tests
reviewed
had
been
conducted
in a timely manner,
and had
been
performed successfully
in accordance
with TS 3.6.5.3
and
The inspector concluded that the licensee's
SBGT program was
fully capable of meeting -the licensee's
safety objectives.
No
violations of NRC requirements
were identified.-
c.
Control
Room Ventilation
S stems
The inspectors
reviewed the status of the Control
Room normal
and
emergency ventilations
systems
by system walkdowns, discussions
with the
system engineer,
and reviews of procedures
and calibrations.
Selected
surveillances
required
by TS 4.7.2 were reviewed,
including the
following tests:
7.4.7.2. 1, "Control
Room Emergency Ventil-ation System Operability"
7.4.7.2.2B,
"Control
Room Div-B Emergency Filtration System
Filter Test"
7.4.7.2.3B,
"Control
Room Div-B Filtration System
Adsorber Test"
7.4.7.2.5;
"Control
Room Emergency Filtration Heater Operability"
7.4.7.2.8,
"Control
Room Ventilation Pressurization
Flow Test"
7.4.3.7. 1.25,
"Radiological Calibration of Remote Air Intake
Nonitor WOA-RIS-31A"
The surveillance tests
reviewed
had
been conducted, in a timely manner,
and
had
been
performed successfully
in accordance
with TS requirements.
During a system walkdown, the inspectors
noted
a deficiency tag,
dated
October
12,
1992, for WOA-RIS-31A (a control
room emergency ventilation
"
system remote intake radiation monitor).
The deficiency tag indicated
that the monitor was spuriously alarming every
5 minutes.
I
To understand
the significance of this condition, the inspectors
reviewed several
procedures
and records,
and held discussions
with
operators,
system engineers,
and
RP personnel.
(1)
Ins ector Followu
The inspectors
asked the on-shift Control
Room supervisor
whether
WOA-RIS-31A was considered
The supervisor stated that
the spurious
alarms
had not been
observed recently,
and that the
monitor appeared
to be operating normally.
The supervisor stated
further that based
on these observations
the monitor should
be
considered
The supervisor stated that, to his
knowledge,
had
been performed for the
monitor.
l
0
I
1I
The inspectors
reviewed the Control
Room log for TS Limiting
Conditions for Operation
(LCOs),
and verified that no entry had
been
made in the
LCO log for WOA-RIS-31A. 'n addition, the
inspectors
reviewed the Control
Room operator's
log for October
12,
1992,
but were unable to find any entry regarding
alarms or
abnormal
performance related to WOA-RIS-31A.
The inspectors
also discussed
the condition of the monitor with
the
RP effluent analyst
and the
IKC Technical Supervisor.
Both
individuals stated that they had only recently
been
informed of
the monitor's condition.
The inspectors
were also informed that
the monitor's behavior indicated
a possible detector failure,
and
that
a detector replacement
and monitor calibration were scheduled
for October 22,
1992.
Licensee
Followu
On Wednesday,
October
21, the inspectors
were informed that the
detector
replacement
would be delayed,
due to performance of a
written safety evaluation
(per
10 CFR 50.59) for voluntary entry
into an
LCO, occasioned
by taking the monitor out of service for
repair.
The inspectors
were informed, further, that detector
replacement
might not be necessary,
because
welding had
been going
on near the monitor,
and electronic noise
engendered
by the
welding was seen
as
a possible
cause of the spurious monitor
alarms.
On October 22, the inspectors
were informed that the
RP effluent
analyst
had compiled data from computer records of October
12.
These
records
indicated that the alarms
on WOA-RIS-31A had not, in
fact,
been spurious,
but had
been
due to the actual
presence
of
radioactivity.
The inspectors
reviewed these
records with the
RP effluent
analyst.
The monitor records
showed
a build-up and decrease
in
radioactivity over approximately
a 4-hour period.
Other radiation
monitors with sample points in the
same general
area of the site
showed
a similar rise
and fall in activity levels (although
no
other monitors were recorded
as alarming).
The
RP effluent analyst -had also reviewed records of
meteorological
data for the
same 4-hour period.
This data
indicated that the source of radioactivity had probably
been the
"building wake effect,"
as observed
on previous occasions
under
similar meteorological
conditions.
Levels of radioactivity, wind
speed
and direction,
and ventilation system configuration
supported this conclusion.
The licensee's
evaluation
concluded that the October
12,
1992,
alarms
on WOA-RIS-31A had
been valid alarms,
and that the monitor
had
been operable at all times.
(3)
NRC Assessment
and Conclusion
In review of applicable
TSs, licensee
procedures,
and records,
the
inspectors
noted the following:
TS 3.3.7. 1 requires
a minimum of two monitor channels to be
per remote intake. If one of the required monitors
is inoperable,
isolation of the associated
remote air intake
is required within
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
TS 6.8. 1 requires that written procedures
shall
be
established,
implemented,
and maintained covering the
activities referenced
Appendix A.
Regulatory
Guide 1.33,
Appendix A, Section
5, references
procedures for abnormal,
off-normal, or alarm conditions.
Licensee
Procedure
4.826.Pl,
Revision
1, describes
the
following required action for responding to a control
room
emergency ventilation system remote intake radiation monitor
alarm:
2.
Determine the source of radioactivity in
the remote intake.
The inspectors
noted that the Control
Room operators
had not
responded
appropriately to the October
12,
1992 alarms
on MOA-RIS-
31A, in several
ways:
(a)
The operators
had mistakenly
assumed that the alarms
were
invalid, and therefore failed to determine
the source of
'adioactivity in the remote intake.
(b)
Even if the operators'ssumptions
had
been correct
(such
that the alarms
were invalid and the monitor inoperable),
,their response
would not have
been justified," because
they
had not followed TS requirements
for an inoperable monitor.
(c)
Because of the lack of operator action, the analysis of the
source of radioactivity had not taken place until 10 days
after the alarm condition.
The inspectors
also noted that plant design,
as currently
~ configured,
depended
on operator action, for manual isolation of
the air intake valves
under adverse
radiological conditions.
This
action was
based
on maintaining
a habitable Control
Room during
accident conditions in accordance
with General
Design Criterion 19
The inspectors
observed that prudent
operator
response
to alarms
was
an essential
feature in
determining the source of radioactivity and responding
appropriately.
10
The inspectors
concluded, further, that the failure of Control
Room operators to follow Licensee
Procedure
4.826.P1,
as given
above,
constituted
a violation of TS 6.8. 1 (50-397/92-35-01).
Mith the exceptions
noted,
the licensee's
programs for maintenance
and
operation of the Control
Room ventilation systems
appeared
adequate
in
accomplishing the licensee's
safety objectives.
One violation was
identifi.ed.
d.
Li uid Effluent Monitorin
The inspectors
reviewed aspects
of the licensee's
liquid effluent
monitoring'program
by performance
of, system walkdowns, discussions
with
system engineers
and
RP personnel,
and review of applicable
procedures
and records.
The following surveillance tests
were reviewed:
16.5.3,
"Turbine Sump
1 Radiation Monitor Channel
Functional
Test"
16.5.6,. "Turbine Sump
2 Radiation Monitor - Channel
Functional
Test"
16.5.9,
"Turbine Sump
3 Radiation Monitor - Channel
Functional
Test"
16.5. 1; "Turbine
1 Radiation Monitor - Channel Calibration"
16.5.4,
"Turbine
2 Radiation Monitor - Channel Calibration"
In review of the Turbine Building sump drain system,
the inspectors
raised
several
concerns,
as presented
in the following discussion.
(1)
S stem Descri tion
\\
Drains in the Turbine Building flow to five major sumps.
Sumps T-
1, T-2,
and T-3 are non-radioactive
by design.
Sumps T-4 and T-5
are radioactive
by design.
Discharge
from the radioactive
sumps is normally routed to
radwaste.
Discharge
from the non-radioactive
sumps is normally
routed (via the roof drain system) to the storm drain pond,
located outside the protected
area,
near the
MNP-2 warehouse.
During normal operation,
the storm drain pond receives
approximately 30,000 gallons of liquid per day.
The storm drain
pond is unlined,
and
has
no outlet.
The non-radioactive
have radiation monitors, set at 80X of
the liquid effluent- limits of 10 CFR 20, Appendix B, Table II.
Exceeding
these setpoints will automatically redirect
discharge
to radwaste.
0
~
~
(2)
Back round
and Timeline
On July 30,
1992, the licensee
had sent the
NRC a Special
Report
regarding unanticipated
levels of radioactivity that
had
been
detected
in the storm drain ponds
(see discussion
in Section
2,
above).
During the onsite inspection,
the inspectors
reviewed the
=licensee's
history of storm drain pond sampling,
in order to
determine the timeliness of the licensee's
actions in responding
to the unanticipated
levels of radioactivity.
(a)
Technical
Evaluation Request
(TER) 88-0157, April 1988:
This TER stated that low levels of radioactivity had
been
found in the storm drain pond.
It recommended
a thorough
investigation
and corrective actions to determine
and
eli'minate the source of unanticipated radioactivity.
(b)
Problem Evaluation
Request
(PER) 289-0731,
September
1989:
This
PER stated that low levels of zinc-65
and other
nuclides
had
been
found in soil samples
from the storm drain
pond.
These
concerns
were incorporated into the ongoing
action for TER 88-0157
(discussed
above).
(c)
PER 292-0531,
May 1992:
This
PER stated that elevated
activity and abnormal
red color had
been
observed
in surface
water samples
from the pond.
This
PER resulted in the
Special
Report being sent to NRC.
(d)
Quality Finding Report
(QFR) 292-014,
June
12,
1992:
This
QFR stated that unmonitored releases
(such
as those to the
storm drain pond) indicated
a programmatic failure.
The
made
numerous
references
to the licensee's
NRC
regulations,"
and
NRC bulletins
and information notices.
(e)
PER 292-0781,
June
27,
1992:
This
PER stated that temporary
drain lines
had
been inadvertently routed from main
condenser
conductivity cell taps to the non-radioactive
Turbine Building sumps without prior sampling.
The
PER also stated,
as part of the evaluation,
that
followup sample results
had found the T-2 (non-radioactive)
sump to contain 4.6 E-7 microcuries/milliter (uci/ml).
Since this level
was less
than the limits of 10 CFR 20,
Appendix B, however,
the
had
been realigned to the
storm drain pond (with the apparent
concurrence
of the
PER
evaluators).
(f)
Response
to
QFR 292-014,
August 3,
1992:
This response
stated that
a root cause
analysis of the problem had
been
- completed.
Host of the radioactivity in the storm drain
ponds
was attributed to liquids from turbine overhaul.
The root cause
analysis
attached
to the response
cited
12
specific transfers of red liquid that
had
been
made from the
T-5 (radioacti.ve)
sump to the T-2 (non-radioactive)
on
Hay 3 and
May 12.
The activity of the liquid, as recorded,
had.been
approximately 7.0 E-6 uci/ml.
A total, of
approximately
1000 gallons
had
been transferred
to T-2 (and
subsequently
discharged
to the storm drain pond).
As one corrective action, the response
recommended
a
thorough evaluation of potential leak paths into the non-
radioactive Turbine Building drain system
by September
7,
1992.
(3)
Re ulator
and License
Re uirements
10 CFR 20.301 requires that no licensee
dispose of licensed
radioactive material
except
by certain specified
methods (i.e.,
by
approved transfer methods or via approved effluent discharge
paths).
10 CFR 20.302 allows licensees
to apply for approval of
procedures
for alternate
methods of disposal
not otherwise
authorized.
10 CFR 50.59 requires-,
in part, that the licensee
shal-l maintain
records of changes
to the facility or procedures
described
in the
UFSAR, including
a written safety evaluation that provides the
basis for determining that the change
does not involve an
unreviewed safety question.
'FSAR Section 9.3.3,
"Equipment
and Floor Drainage Systems,"
states
in part:
Equipment
and floor drainage
systems
are provided to
handle radioactive
and non-radioactive
wastes
in
separate
systems.
Radioactive
wastes
are collected in
the building sumps
and
and transferred
to the radwaste
system for treatment,
sampling
and disposal
or reuse
within the plant.
Roof drains
and non-radioactive
floor drains are drained
by gravity or pumped to the
storm drain system.
UFSAR Section 9.3.3.2.3.
1 describes
the non-radioactive
Turbine
Building sumps that are routed to the storm drain system.
NRC IE Bulletin 80-10,
"Contamination of Nonradioactive
System
and
Resulting Potential for Unmonitored, Uncontrolled Release
of
Radioactivity to Environment," requests
operating licensees
to
take several
actions.
Specific action is designated
for
situations in which nonradioactive
systems
become radioactively
contaminated:
(a)
Use of, the system
must
be restricted until the cause of
contamination is identified and corrected,
and the system
~ decontaminated.
13
(b)
If continued operation is necessary
with the system
contaminated,
a safety evaluation
must
be performed per
(as given above).
(c)
If the evaluation
concludes that the system
may be operated
as
a radioactive
system,
any potential
releases
must
be
controlled
and maintained to the levels
addressed
(4)
Discussions
With Plant
RP Mana ement
On October 22,
1992, the inspectors
discussed
with members of
plant
RP management
the levels of radioactivity found in the storm
drain pond samples.
The inspectors
noted the following points of
discussion:
(a)
Plant
RP management
stated that, to their knowledge,
issues
surrounding the radioactivity in the storm drain pond did
not represent
a non-compliance with NRC requirements
or a
non-conformance
to license conditions.
(b)
Based
on their belief that this matter did not constitute
a
non-compliance,
plant
RP management
also felt that the storm-
drain radioactivity concerns
had
been
addressed
in
a timely
manner.
(c)
Plant
RP management
was not aware of any instances
in which
radioactive liquid had knowingly been routed to the non-
radioactive Turbine Building sumps or discharged
to the
storm drain pond.
On October
23,
1992, the inspectors
discussed
with plant
management
the response
to (FR 292-014
and the associated
root
cause
analysis
(see Section 4.d(2),
above).
The inspectors
pointed out that the root cause
analysis
described
instances
in
which radioactive liquid had knowingly been
sent to the storm
drain pond.
After review, plant
RP management
acknowledged
the
statements
in the root cause analysis,
but stated that neither the
(FR response
nor the root cause
analysis
had ever
been routed to
them.
(5)
NRC Assessment
After review of the documents
discussed
above,
and after
discussions
with plant
RP management
and other members of the
plant staff, the inspectors
noted the following points:
(a)
Sample results
from the storm drain pond indicated the
presence
of radioactivity in levels well above environmental
background;
however,
none of the sample results or surveys
of the
pond indicated radioactivity in levels that would
pose
a significant radiological
hazard
by
a reasonable
t,(
14
pathway of exposure.
For additional perspective
on the sample results,
see
Attachment
-A to this report.
(b)
Although the storm drain pond is located outside the
licensee's
protected
area, it is within the "restricted
area"
as presented
in the
UFSAR, Section
2. 1. 1.3.
The
inspectors
noted,
however, that the licensee
did not control
access
to the storm drain pond area for the purposes
of
minimizing radiation exposure.
(c)
Discussions
with plant staff and review of records
indicated
a lack of understanding
of the legitimate
uses of the non-
radioactive Turbine Building sumps,
as follows:
(i)
Since the
sump monitor alarms
had
been set at 80X of
the limits of 10 CFR 20, Appendix B, Table II, some
members of plant staff had
assumed that any liquids
containing radioactivity in levels less
than the alarm
setpoint could legitimately be disposed of in these
(ii)
The licensee's
evaluation of PER 292-0781
(see Section
4.d(2),
above) clearly demonstrated
this lack of
understanding.
After sample results
from the T-2 sump
had
shown the
sump liquid to be radioactive. (but less
than
10 CFR 20, Appendix
B levels),
the
sump discharge
had been re-routed to the storm drain pond.
(d)
(e)
The licensee
was unable to provide evidence that
TER 88-0157
had ever
been closed,
or that the evaluation of unmonitored
radioactive inputs to the storm drains,
requested
by the
TER,
had ever been performed.
The inspectors
noted,
specifically, that the evaluation
requested
by the
1988
was, in essence,
the
same
as the evaluation
requested
by the
1992
gFR ((FR 292-014,
discussed
above).
'I
The licensee
had not performed
a written safety evaluation,
per
10 CFR 50.59, to justify continued operation of the
"non-radioactive" Turbine Building sumps
as
a radioactive
system.
(f)
The licensee
had not applied to the
NRC, per
for approval of disposal of licensed radioactive material
via the storm drain pond.
The inspectors
concluded, first, that routing radioactive liquids
to the storm drain pond was
an unapproved
method of disposal
of
licensed radioactive'aterial,
and
as
such constituted
a violation
15
(50-397/92-35-02).
The inspectors
concluded,
second,
that the licensee's
failure to
perform
a written safety evaluation for operating
as radioactive
a
system designed to be non-radioactive
constituted
a violation of
10 CFR 50.59 (50-397/92-35-03).
The inspectors
concluded, finally, that the lack of timeliness
surrounding the resolution of this area indicated the need for
improvement
by management
in responding to radiological concerns.
This item will be further addressed
in a future inspection
(50-
397/92-35-04).
(7)
Licensee
Res
onse
At the exit interview on October 23,
1992, the licensee
acknowledged
the inspectors'bservations
related to radioactivity
in the storm drains.
The licensee
stated that priority would be
given to resolving this matter.
In subsequent
telephone
conversations,
the plant
RP Hanager stated
that the non-radioactive
Turbine Building sumps
had
been
redirected
to radwaste until evaluation of the situation could be
more fully completed.
In addition, the licensee
was continuing to
evaluate
(a)
the
amount
and concentration of radioactive material
currently in the storm drain pond,
(b)
the potential
pathways for unmonitored radioactive material
to enter non-radioactive
systems,
and
(c)
- methods of restricting access
to the storm drain pond for
the purposes of minimizing radiation exposure.
The licensee's
programs for monitoring and control of liquid radioactive
waste
appeared
to warrant
improvement in several
areas,
as discussed.
Two violations of NRC requirements
were identified.
V
e.
Radiolo ical Environmental Honitorin
Pro ram
REHP
The inspectors
evaluated
aspects
of this program area
by interviews with
cognizant personnel,
reviews of recent records
and reports,
and
observation of work in progress.
Observations
were
made regarding
(1)
environmental
sampling
and analysis
and
(2) meteorological
monitoring.
Environmental
Sam lin
and Anal sis
The
REHP sampling records
and schedules
indicated that sample
collection had been
conducted
at the locations
and frequencies
prescribed
in the Offsite Dose Calculation Hanual
(ODCH), Table
6:3. l.l-l.
The inspectors
noted the following items:
h
H
fi
L
I'I
0
16
(a)
In addition to the locations specified in the
ODCH, the
REHP
group routinely sampled other site locations,
in a
commendable effort to maintain
a thorough,
comprehensive
oversight of radiological conditions in the site environs.
Sampling history and radiological profiles of each location
had
been well-documented.
(b)
One inspector
observed
performance of Environmental
Program
Instruction
(EPI) 12.4.5,
"Sediment Sampling," at the
upstream
and downstream locations
on the Columbia River
bank.
Sample collection was performed in a technically
sound manner,
and in accordance
with the procedure.
(c)
Review of selected
sampling records
indicated that the
offsite vendor laboratory
used
by the licensee
had
been
able, in all cases
reviewed, to meet the requirements
of the
ODCH for achieving lower limits of detectability
(LLDs).
(2)
Heteorolo ical Honitorin
The inspectors
reviewed recent calibration
and performance
data
for the meteorological
monitoring instruments,
and toured the
licensee's
meteorological
monitoring system with the system
engineer.
Several
observations
were
made:
(a)
(b)
The licensee
had upgraded
the Control
Room chart recorders
during the last outage.
The licensee
also planned to
install
a new digitized 7-point recorder in the
meteorological
tower local equipment
shed.
Records
indicated that the system
had
been performing
reliably.
Channel
checks
and channel
calibrations
had
been
performed at the frequencies
specified in TS Table 4.3.7.3-
l.
(c)
In review of the most recent calibration of the 33-foot and
245-foot wind speed
and wind direction channels,
the
inspectors
noted that certain readings
had not been taken at
output points
HET-POl and HET-P02,
due to the computer being
down.
The inspectors
asked the system engineer
what
alternate
acceptance
criteria had
been
used to ensure that
the loop was satisfactorily calibrated.
The system engineer
stated that further research
was necessary
to determine
what
criteria had
been
used.
This matter will be reviewed in a
future inspection
(50-397/92-35-05).
The licensee's
REHP and meteorological
monitoring program appeared
adequate
in meeting the licensee's
safety objectives.
The extra
measures
taken
by the
REHP group, in order to maintain
a comprehensive
and well-documented
status of radiological conditions in the immediate
site. environs,
appeared
to be
a program strength.
No violations or
deviations
were identified.
17
Control of Access to "Hi h-Hi h", Radiation Areas
On October 21,
1992, the licensee notified the inspectors of two
instances
in which individuals violated TS 6.12.1 requirements for
ensuring that doors to "high-high" radiation areas
are controlled by
radiation protection staff.
(A "high-high" radiation area is an area in
which dose rates
measure
1000 millirem/hour or more.)
TS 6. 12. 1 requires that high-high radiation area doors
have continuous
health physics technician
coverage
when open.
If health physics
technicians
are not present,
the doors must
be locked closed,
and the
keys must
be under the control of the radiation protection department.
The inspector
examined
Problem Evaluation Request
(PER) 291-1186
and
PER
291-1187,
which described
both of the high-high radiation area doors
as
having
been discovered
open
on the morning of October
21;
1992.
PER
291-1186 stated that the gate to the "B" Reactor Water Cleanup
Room in
the Radwaste
Building had
been found open.
PER 291-1187 stated that the
gate to the Waste Storage
Area in the Radwaste Building had
been
found
open.
In neither case
had health physics technicians
or other personnel
remained
in the area while the doors were open,
and in both cases
health
physics technicians
had
been responsible for leaving the doors
open.
The licensee's
radiation protection staff had found the doors
open
during
a routine tour.
The licensee
had taken prompt corrective action
to restore
access
control
by locking the doors
and re-establishing
key
control.
The licensee
had determined,
fur ther, that the root cause of
these
incidents
was preventable
personnel
error.
A procedure
change
was
implemented,
requiring 2-person
independent verification when locking
high-high radiation area doors.
The inspectors
concluded that leaving the two doors
open
and unattended
was
a violation of TS 6.12.1.
However,
based
on the isolated nature of
this matter,
and based
on the promptness
and thoroughness
of the
, licensee's
corrective action, the inspectors
concluded that the criteria
in Section
V.G of the
been satisfied.
As a
result, this violation will not be cited (50-397/92-35-06).
Exit Interview
The inspectors
met with members of licensee
management
at the conclusion
of the onsite portion of the inspection
on October 23,
1992.
The scope
and findings of the onsite portion of the inspection
were summarized.
The licensee
acknowledged
the inspectors'bservations.
'
l
~ 'i
'
ATTACHHENT A:
COHPARISON TABLE FOR
STORM DRAIN POND SURFACE
MATER SAMPLES
(all numbers given in picocuries/liter)
Nuclides
Cobalt 60
Cerium 141
137
131
54
Antimony 125
Zinc 65
Appendix
B
Table II*
30,000
90,000
20,000
300
100,000
20,000
100,000
3,000,000
WNP-2 ODCH
Reporting
Levels**
300
50
2',000
300
3P PPP****
State of
Mashington
(DOH)
S
i
L
100
100
100
100
100
100
1,000
Storm Drain
Surface Mater
Sam le Results***
II
124.7
707
5.7
21.1
5.8
20.8
52.9
100 - 270,000-
Values established
for radioactivity in liquids discharged
by approved
effluent pathways-to unrestricted
areas
(e.g., rivers
and oceans
generally releases
to large bodies of water,
assuming
substantial
dilution).
- Standard
reporting values for surface water
(based
on Standard
Technical
Specifications)
as given in the
WNP-2 Offsite Dose Calculation
Manual
(ODCH).
These
values
were derived
based
on (1)
limiting doses
due to liquid effluents,
and (2)
1970 "state-of-the-art"
technology for monitoring and detection capabilities.
NOTE: Reporting is only required
when these
values
are exceeded for all
samples
averaged
over
a calendar quarter.
- Based primarily on May 13,
1992,
sample of the storm drain pond.
Tritium values
are given over the range
seen in 1992 samples.
In
addition:
I.
The T-2 sump contents
were discharged
to the storm drain on tune
27,
1992, at
a concentration of 460 picocuries/liter (pCi/1).
2.
The T-5 sump contents
were transferred
and discharged to the storm
drain
on Hay 3 and Hay 12,
1992, at
a concentration of 7000 pCi/1.
- For drinking water,
a more restrictive value of 20,000 pCi/1 is used,
based
on 40
CFR
141
(EPA drinking water standards).