ML17290A470
| ML17290A470 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/09/1993 |
| From: | Beaston V, Cillis M, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17290A469 | List: |
| References | |
| 50-397-93-14, NUDOCS 9306240086 | |
| Download: ML17290A470 (10) | |
See also: IR 05000397/1993014
Text
Report No.:
License:
Licensee:
Facility:
U. S.
NUCLEAR REGULATORY COMMISSION
REGION
V
50-397/93-14
Washington Public Power Supply System
(WPPSS)
P.O.
Box 968
3000 George
Way
Richland,
WA 99352
Washington Nuclear Project
2
(WNP-2)
Inspection duration:
May 17-21,
1993
4
. L.
aston,
a iation Spectra
est
/
6
4>>
ames
.
eese,
e
Facilities Radiological Protection
Branch
Inspected
by:
tor
a sat~on
Spectra
~st
Approved by:
~Summar:
Inspection location:
WNP-2 Site,
Benton County,
4-t-13
ate
>gne
ate
>gne
ate
>gne
Areas
Ins ected.
Routine
announced
inspection covering followup of corrective
actions for violations, followup of written reports of nonroutine events,
occupational
exposure
during extended
outages,
and tours of the licensee's
facility.
Inspection
procedures
92702,
92700,
and 83729 were used.
Results:
The licensee's
performance
appeared
adequate
in the area of
occupational
exposure control.
Weaknesses
were identified in the areas of
effective corrective actions for past violations (section 2.b), radiological
work practices
in contaminated
areas
(section 4.b.(1)(iii)), and
ALARA program
implementation
(section 4.d.(1)).
No violations of NRC requirements
were identified within the scope of this
inspection.
Three
items were opened,
regarding the licensee's
method for: (1) evaluating
and complying with revisions to
NRC Certificates of Compliance
(section 3);
(2) response
checking air monitors (section 4.c.(3));
and (3) controlling the
installation
and removal of temporary lead shielding (section 4.d.(1)).
a
9306240086
930609
ADDCK 05000397
8
The inspectors
presented
their findings to the licensee's
staff
who then took immediate actions to correct the untagged
hoses.
A
subsequent
walkdown of the plant by members of the licensee's
staff also identified other instances
of failure to comply with
PPH 1.3.19.
The inspectors
informed the licensee that corrective actions
taken
prior to this inspection
had not been effective.
The inspectors
continued to have concerns
in this matter.
This matter is still
open
and will be reviewed
again during
a future inspection.
Onsite Followu
of Written
Re orts of Nonroutine
Events
92700
Licensee
Problem Evaluation
Request
(PER)
293-504
issued
on Hay 6,
1993,
identified two radioactive
waste
shipments
(93-03-02
and 93-13-02)
which
did not fully comply with the changes
made in Certificate of Compliance
(CofC) No. 9208, revision 4;
and retained
in revision 5.
Shipment
No.
93-03-02
was
made
on January
20,
1993 (revision
4 was in effect);
and
shipment
No. 93-13-02
was
made
on April 19,
1993 (revision
5 was in
effect).
The container
used to make these
two shipments
was
a
NUPAC 10-
142 Type
B cask which was certified by CofC No. 9208.
CofC 9208,
Revision 4, issued
on June
20,
1991,
excluded the shipment of
more than
a "Type A quantity of fissile material" in a
NUPAC 10-142
cask.
This change to CofC 9208 was intentionally made
by the
NRC to
prohibit fuel facility licensees
from using this cask to ship Type
B
quantities of fissile materials,
since the cask
had not been evaluated
for that purpose.
However, this cask
was also
used
by nuclear
power
facility licensees
to ship low specific activity (LSA) materials
(such
as spent
ion-exchange
resins),
and the
no more than
a "Type A quantity
of fissile material" clause technically eliminated the shipment of any
plutonium in this Type
B cask (including very small quantities of
plutonium included
as part of an
LSA shipment)
by not specifically
allowing for the "Fissile material
exemption" in 10 CFR 71.53.
Followup by the inspectors verified that it was never the intent of the
NRC to prohibit the shipment of LSA materials
in
a Type
B cask.
Furthermore,
the
NRC issued revision
6 to CofC No.
9208
on Hay 26,
1993,
which included the fissile material
exemption contained
in 10 CFR 71.53.
Had
WNP-2 made
shipments
No. 93-03-02
and No.93-13-02 prior to June
20,
.1991,
or after Hay 26,
1993,
they would have
been in full compliance
with NRC requirements.
The inspectors
questioned
members of the licensee's
staff (responsible
for the shipment of radioactive materials
and for regulatory compliance)
to determine
why WNP-2 had not taken
measures
to comply with CofC 9208,
Revision 4,
when the approval
record attached
to Revision
4 stated
in a
separate
paragraph:
"Condition 5(b)(2) of the Certificate of Compliance
was modified
to clarify that fissile material is limited to no greater
than
a
Type A quantity."
0
The responses
to the inspectors
questions
were that
no one
had
been
aware of the changes
made in CofC 9208,
Revision 4.
The licensee's
regulatory
programs
group was unable to produce
a copy of CofC 9208,
Revision 4, from WNP-2's records
and identify who had
been provided
a
copy of it and what actions
were
taken'he
inspectors
obtained
a copy of CofC 9208,
Revision 5,
and noted that
it was routed to the Radiation Protection
Manager
and the Corporate
Health Physics
Manager with what appeared
to be
a
memo routing sheet
by
the regulatory programs
group.
The inspectors
also noted that the
"ACTION ASSIGNED TO:" block on this sheet
was blank,
and that
no
followup action
was required
by the routing sheet.
Based
on interviews with members of the licensee's
staff and
a review of
WNP-2's procedures,
the inspectors
determined that
WNP-2 did not have
a
method in place to properly handle revisions to the CofC's governing the
casks
used to ship radioactive materials.
The inspectors
also concluded
WNP-2 had not evaluated
the changes
made in CofC 9208,
Revision 4.
The inspectors
determined that although there
were
no safety significant
issues
involved with shipments
No. 93-03-02
and
No. 93-13-02,
the
licensee's
failure to evaluate
revisions
4 and
5 to CofC 9208
and ensure
that
WNP-2 was complying with NRC requirements
is
a concern.
The licensee's
method for evaluating
and complying with CofC revisions
will be reviewed during'
future inspection
(50-397/93-14-01).
Occu ational
Ex osure
Durin
Extended
Outa
es
83729
'a ~
Audits and
A
raisals
The inspectors
reviewed several
Nuclear Safety Assurance
(NSA)
Activity Records
and Daily Observation
Checklists
provided
by WNP-
2's guality Assurance
(gA) Department.
Each of these
records
or
checklists
covered
up to a four-hour period of time, during which
a gA inspector toured the plant
and
made observations
of plant
conditions
and general
work practices.
These
NSA activity records
and daily observation checklists
documented
the actual
day-to-day
work practices of individuals during outage
R-8,
and provided the
inspectors
a description of WNP-2's performance
during the outage.
The inspectors
noted that the
NSA activity records
and daily
observation checklists identified several
procedural
violations,
and in particular the inspectors
noted
an observation
which
identified
a procedural
violation involving the issuance
of
alarming dosimeters.
This observation
involved
an instance
in
which Digital Alarming Dosimeters
(DADs) were issued to
individuals on the 606'efueling floor without playing the alarm
pre-recorded
tape
as required
by
PPM 11.2.6.2.
The observation
further indicated that the lead health physics technician stated
that, to his knowledge,
the alarm demonstration
tape
had not been
used
on eithel
May 2 or May 3,
1993.
The inspectors
noted that
The inspectors
determined that this practice could
lead to possible facial contaminations.
In discussions
with members of the licensee's
health
physics
(HP) staff concerning this matter,
the
inspectors
were informed that the licensee
would
normally expect the face shields
and safety glasses
to
be hung vertically after use
by
a worker.
However,
the members of the licensee's
HP staff also pointed
out that the areas specifically mentioned
by the
inspectors
were normally low contamination
areas.
The
inspectors
determined that the practice of allowing
workers to perform one
way in a conservatively
posted
contamination
area could lead to workers continuing to
perform the
same
way in
a non-conservatively
posted
area in another part of the plant.
(2)
Postin
and Labelin
During
a tour of the Reactor Drywell, 512'levation,
the
inspectors
and
a member of the licensee's
gA department
noted
a "High High Radiation Area [-] Contact Health Physics
Prior to Entry f-] Below Grating Level" posting without a
yellow flashing light nearby.
The inspectors
then checked
the posting
on the level
directly below, the 501'levation,
and observed that the
area
was posted
as
a "High High Radiation Area" with
flashing yellow lights at both ends of the rope barrier.
The inspectors
questioned
members of the licensee's
staff
about the need for a flashing yellow light near the posting
on the 512'levation,
and were informed that
no flashing
yellow light was required
as long as the flashing yellow
lights on the 501'levation'ere
visible from the
512'levation.
There
was
a difference of opinion between
the inspectors
and
the licensee's
health physics staff as to whether the
flashing yellow lights were visible on the 512'levation.
WNP-2 procedure
PPH 11.2.7. 1, did not clearly identify how
flashing yellow lights were to be used to comply with the
requirement of Technical Specification (T.S.) 6, 12.2.
As
a result of the inspectors
concerns,
the licensee's
health physics
group placed
a yellow flashing light near the
"High High Radiation Area" posting
on the 512'levation
and
initiated
PER 293-670 to request
a clarification on the use
of flashing yellow lights in
PPH 11.2.7. l.
The Health
Physics
Operation Supervisor also informed the inspectors
he
was evaluating the possible
use of flashing string lights,
which would eliminate the problem of where to place the
flashing yellow lights WNP-2 used.
The inspectors
had
no
other concerns
in this matter.
Internal
Ex osure Control
Whole Bod
Countin
S stem
(2)
The inspectors
interviewed the individual responsible for
WNP-2's Whole Body Counting
(WBC) system,
and discussed
the
means
used to calibrate
and response
check the
WBC system.
The inspectors
identified no concerns
in this matter.
Review of Records
The inspectors
examined
selected
records of contractors
hired by WNP-2 for the R-8 outage.
They verified that each
record reviewed
had
an initial and termination
WBC form,
indication of having met General
Employee Training and Site
Access Training,
a current
a current
and
a qualifying certificate for respirator
use
as
appropriate
in, each
instance.
The inspectors
had
no
concerns
in this matter.
(3)
In-Service
AHS-3 Units
On Hay 20,
1993, the inspectors
brought to the licensee's
attention that none of the weekly source
check tags attached
to the in-service
AHS-3 units
had
been
signed off as having
been
response
checked in accordance
with
PPM 11.2.24. 1.
Further followup by the inspectors verified that the weekly
response
checks that were indicated
as having
been
done
on
Hay 17,
1993,
by the licensee's
records
had not been
performed.
The inspectors verified this fact by requesting
the on-duty Health Physics Craft Supervisor to unroll the
recording paper in the strip chart recorders for four of the
in-service
AHS-3 units
and identify the last date
on which
these in-service
AHS-3 units
had
been
response
checked.
All
four of. the units
had last
been
response
checked
on Hay 10,
1993.
The supervisor
acknowledged
the inspectors
observation that
the weekly response
check required
by
PPH 11.2.24.
1 had not
been performed,
and scheduled all the in-service
AHS-3 units
to be response
checked during the night of Hay 20,
1993.
The licensee's
staff concluded that the weekly response
checks
would not have
been
accomplished
had it not been for
the NRC's observation.
The licensee's
method for response
checking air monitors
will be followed up during
a future inspection
(50-397/93-
14-02).
Maintainin
Occu ational
Ex osures
Worker Awareness
and
Involvement
The inspectors
questioned
approximately
40 workers during
this inspection
(including health physics technicians)
and
only one of the individuals questioned
knew the plant's
ALARA goal.
The inspectors
concluded
based
on the response
to their question,
there
was little worker awareness
of WNP-
2's
ALARA goal for this outage.
The inspectors
reviewed the
ALARA log book and the
gA daily
observation checklists
(see section 4.a.)
and noted several
entries
which stated that shielding or scaffolding
had
been
unnecessarily
installed or prematurely
removed, resulting in
unnecessary
exposure
to the workers involved.
Some entries
in the
ALARA log identified instances
of continued work
control problems,
The three
problem areas
identified were
In-Service Inspection work,
N4 Nozzle work,
and Inner
Annulus Drain work.
In each of these
problem areas,
the
inspectors
determined that shielding
had
been installed
on
one shift and
removed
by another shift (prior to completion
of the work for which the shielding
was originally
intended),
only to be reinstalled
again.
The inspectors
questioned
the acting Health Physics
Planning
Supervisor
about the
ALARA log entries
and whether
he had
determined
how much additional
dose
had
been received
by the
shielding workers
due to poor work control during this
outage.
The supervisor did not have
an exact
number,
but he
did acknowledge
the inspectors
observation that additional
dose
had
been unnecessarily
received
by workers
due to poor
work control planning
and scheduling for the R-8 outage.
The inspectors
noted the inner annulus drain work did not
consider shielding in the initial work package,
but that
shielding
had
been requested
after it was apparent that the
job would not meet its ALARA goal.
The inspectors
were
informed that
a stop work order
had not been
issued for this
job,
and that work on the inner annulus drain continued for
at least
one Full shift while shielding
was being installed.
The inspectors
noted
one entry in the
ALARA log for Hay 15,
1993,
which indicated that shielding which was
used to cover
a 25 R/hr "hot spot"
had
been
removed without the proper
authorization.
The inspectors
questioned
the acting Health
Physics
Planning Supervisor
and other members of the
licensee's
staff about
WNP-2's method for installing and
removing shielding.
These discussions
indicated that
WNP-2
did not have
a procedure
which clearly identified who was
authorized to install
and
remove shielding, or a procedure
which clearly identified how the shielding
was to be
installed or removed.
The inspectors
concluded that while WNP-2 had identified
these
problems with their ALARA program,
they had not taken
effective actions to improve their ALARA program.
The
inspectors
presented
these findings to the licensee's
management
during the exit meeting
on Hay 21,
1993.
The licensee's
method for controlling the installation
and
removal of shielding will be followed up during
a future
inspection
(50-397/93-14-03).
(2)
ALARA Goals
and Ob'ectives
The licensee's initial goals for this planned
45 day outage
were
100 skin/clothing contaminations
and
140 person-rem.
The initial 140 person-rem
goal
had later been revised to
220 person-rem prior to the inspection.
As of Hay 21,
1993,
the licensee
was
one day behind in scheduled
work,
had
recorded
a total of 103 skin/clothing contaminations,
and
had reached
a total of 170 person-rem for the outage.
The licensee's
program appeared
to be adequate
in meeting
its safety objectives.
No violations or deviations
were
identified.
Exit Interview
The inspectors
met with members of licensee's
management
at the
conclusion of the inspection
on Hay 21,
1993.
The scope
and findings of
the inspection
were summarized.
The licensee
acknowledged
the
inspectors'bservations.
0
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