ML17292A404
| ML17292A404 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/09/1996 |
| From: | Murray B, Nicholas J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A403 | List: |
| References | |
| 50-397-96-15, NUDOCS 9608130319 | |
| Download: ML17292A404 (22) | |
See also: IR 05000397/1996015
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector:
50-397
50-397/96-15
Washington Public Power Supply System
Washington Nuclear Project-2
3000 George Washington
Way
Richland,
June
24 through July 29.
1996
J. Blair Nicholas.
Ph.D.
~ Senior Radiation Specialist
Plant, Support
Branch
Approved By:
Blaine Murray, Chief. Plant Support
Branch
Division of Reactor Safety
ATTACHMENT:
Partial List of Persons
Contacted
List of Inspection
Procedures
Used,
List of Items Opened'losed'nd
Discussed
9608130319
960809
ADQCK 05000397
8
-2-
EXECUTIVE SUMMARY
Washington Nuclear Project-2
NRC Inspection Report 50-397/96-15
This routine,
announced
inspection
focused
on the licensee's
radiological
waste effluent management
programs.
En ineerin
No deviations to commitments in the Updated Final Safety Analysis Report
were identified (Section
E2. 1).
Plant
Su
ort
The liquid and gaseous
radioactive waste effluent management
programs
were properly implemented
(Section Rl. 1).
I
The radiochemistry counting facility was equipped with state-of-the-art
analytical instrumentation to perform. the required analyses.
Liquid and
gaseous
radioactive waste
management
systems
were installed
and operated
properly (Section
R2. 1).
Several effluent radiation monitors were out-of-service in excess of
Technical Specification requirements
during 1994 and
1995 indicating
poor system reliability. lack of timely engineering
support,
and poor
receipt inspection
performance
(Section R2.2).
An apparent violation involving the incor rect and non-conservative
calibration of the intermediate
range radiation monitor (PRM-RE-18) of
the reactor building stack effluent monitoring system,
which served
as
the required accident noble gas monitor,
was identified (Section R2.3).
Procedures
established
to implement the liquid and gaseous
radioactive
waste effluent management
programs
provided proper guidance.
The
radioactive waste effluent management
programs
were properly
implemented.
Amendments to the Offsite Dose Calculation
Manual were
properly documented.
The Annual Radioactive Effluent Release
Reports
for 1994 and
1995 were submitted in a timely manner
and contained the
required information presented
in the required format (Section
R3. 1)
The chemistry operations
supervisor,
effluents leader,
chemistry
technicians,
and equipment operators
had
an excellent understanding
of
the radioactive waste
management
procedures.
Offsite Dose Calculation
Manual,
and regulatory requirements
(Section
R4. 1).
Training programs
were properly implemented.
The chemistry
and
operations
departments
had well trained
and qualified staffs for
conducting radioactive waste effluent processing
and release
operations
(Section R5.1).
The chemistry technical staff reduction,
during the past
17 months. did
not appear to have
a negative affect on the performance of the
'adiological
waste effluent management
programs
(Section
R6. 1).
Oversight of the radioactive waste effluent management
programs
was
good.
Quality assurance
audits
and survei llances of the radioactive
waste effluent management
programs
and Offsite Dose Calculation
Manual
were technically comprehensive
and provided good program evaluation
and
oversight. identified deficiencies,
and
made
recommendations
for program
improvement.
The corrective action program was proper ly implemented
(Section R7.1).
Re ort Details
Summar
of Plant Status
The plant was undergoing startup testing from a refueling outage during the
inspection period.
There were no operational
occurrences
that impacted the
inspection.
III. En ineerin
E2
Engineering Support of Facilities and Equipment
E2. 1
U dated Final Safet
Anal sis
Re ort Review
a.
Ins ection Sco
e
A recent discovery of a licensee
operating their facility in a manner
contrary to the Updated Final Safety Analysis Report description
highlighted the need for a special
focused
review that compares
plant
practices,
procedures,
and/or parameters
to the Updated Final Safety
Analysis Report descriptions.
While performing the inspections
discussed
in this report, the inspector
reviewed the applicable portions
of the Updated Final Safety Analysis Report that related to the areas
inspected.to
ensure
agreement
with any commitments contained therein
pertaining to this inspection.
b. Observations
and Findin s
The inspector verified that the Updated Final Safety Analysis Report
wording was consistent with the observed plant practices.
procedures,
and/or parameters.
c. Conclusion
No deviations to commitments in the Updated Final Safety Analysis Report
were identified.
-5-
IV.
Plant
Su
ort
Radiological Protection
and Chemistry Controls
Radiolo ical Waste Effluent Mana ement
Pro rams
Ins ection Sco
e
84750
Implementation of the liquid and gaseous
radioactive waste effluent
management
programs
as described
in the Offsite Dose Calculation
Manual
including effluent waste processing.
effluent waste sampling
and
analyses,
analyses sensitivities,
analytical results. offsite dose
results,
and performance of required surveillance tests
were reviewed.
Observations
and Findin s
The inspector
reviewed approximately
12 batch radioactive liquid waste
effluent release
permits for the period January
1995 through
May 1996.
The inspector determined that the processing,
sampling,
and analyses
of
radioactive liquid waste effluent and the approval
and performance of
batch radioactive liquid waste discharges
were conducted in accordance
with Offsite Dose Calculation
Manual requirements.
'guantities of
radionuclides
released
in the radioactive liquid waste effluents were
within the limits specified in the Offsite Dose Calculation Manual.
Offsite doses
were calculated
according to the Offsite Dose Calculation
Manual
and were within the requi red limits.
Offsite Dose Calculation
Manual requi red analyses
on composite
samples of batch radioactive
liquid waste effluent releases
for gross alpha. tritium, strontium-89,
and iron-55 were performed.
The inspector
observed
a chemistry technician collect
a sample from
Equipment Drain Tank 4B on June 26.
1996,
perform. a radiochemistry
analysis
(principal
gamma emitters)
on the sample,
and prepare the
radioactive liquid waste effluent batch release
permit.
The inspector
also accompanied
an equipment operator while performing the discharge
valve lineup and visited the control
room to verify that the instrument
and controls technicians
had properly set the alarm setpoints for the
liquid radwaste effluent radiation monitor as required
by the release
permit.
All aspects
of the equipment drain tank release
were performed
in accordance
with approved
procedures.
Selected
gaseous
waste effluent sample analyses
for samples
from the
main plant vent, turbine building vent,
and
r adwaste building vent
continuous
releases
and selected
gaseous
waste release
permits for batch
releases
for containment
vents
and purges
for the period January
1995
through
May 1996 were reviewed.
Sampling. analyses'nd
discharge of
the radioactive
gaseous
effluents
and the approval of the radioactive
gaseous
waste containment
vents
and purges
were conducted in accordance
with Offsite Dose Calculation
Manual requirements
and station
procedures.
-6-
R2
R2.1
It was noted that the sampling
and analysis
requirements
for containment
vents were changed in the Offsite Dose Calculation Manual since the
~ prior NRC inspection of this area.
This change stated,
that prior to
venting containment,
sampling
and analysis
were not required for primary
containment
vents. when the vent path was through the standby
gas
treatment
system,
and when containment
noble gas monitoring
instrumentation
indicated less than the alarm setpoint.
Therefore,
the
previous
requirement
to always sample the containment
atmosphere prior
to venting containment
had been eliminated.
This change
was part of
Amendment
18 to the Offsite Dose Calculation
Manual that was approved
by
the Plant Operations
Committee in April 1995.
This change to the
sampling
and analysis
requi rements for containment
vents in the Offsite
Dose Calculation
Manual
was unique to this licensee.
Quantities of gaseous
and airborne particulate radionuclides
released
were within the limits specified in the Offsite Dose Calculation Manual.
Offsite doses
were calculated
according to Offsite Dose Calculation
Manual methodologies
and were within required limits.
Particulate
effluent composite
sample analyses
for gross alpha,
strontium-89,
and
strontium-90 were performed
and met Offsite Dose Calculation
Manual
requirements.
The licensee
reported
no abnormal
releases
of radioactive liquid or
gaseous
waste during 1994 and 1995.
Conclusions
The liquid and gaseous
radioactive waste effluent management
programs
were properly implemented.
Quantities of radionuclides
released
in the
liquid and gaseous
radioactive waste effluents were within the Offsite
Dose Calculation
Manual limits.
Offsite doses to the environment
from
the liquid and gaseous
radioactive waste effluents were calculated
using
Offsite Dose Calculation
Manual methodologies,
and the dose results
were
within Offsite Dose Calculation
Manual limits.
Status of Radiological Protection
and Chemistry Facilities and Equipment
Radiochemistr
Countin
Facilit
and Radioactive
Waste Effluent
Processin
S stems
Ins ection
Sco
e
84750
The radiochemistry counting facility and associated
analytical
instrumentation
were inspected to verify if adequate calibration and
quality control programs
were in place.
The radioactive liquid waste
processing
equipment
was inspected to ensure
compliance with Updated
Final Safety Analysis Report
and Offsite Dose Calculation
Manual
requirements.
-7-
R2.2
a.
Observations
and Findin s
The radiochemistry counting facility maintained sufficient
state-of-the-art
analytical
instrumentation to perform the required
radiochemistry analytical
measurements
of the radioactive waste
effluents.
The radwaste building and the liquid radioactive waste
processing
equipment were inspected.
The floor drain tank, the two
equipment drain tanks'nd
the local sample points at each of the
radioactive liquid waste storage
tanks were inspected.
The liquid
radioactive waste processing
and storage
systems
were installed
as
described
in the Updated Final Safety Analysis Report
and were operated
in accordance
with station procedures.
No major equipment or design modifications were
made to the liquid or
gaseous
radioactive waste
managem'ent
systems
during 1995.
Conclusions
The radiochemistry counting facility was equipped with state-of-the-art
analytical instrumentation to perform the required analyses.
Liquid and
gaseous
radioactive waste
management
systems
were installed
and operated
properly.
Li uid and Gaseous
Effluent Radiation Monitors
Ins ection Sco
e
84750
The liquid and gaseous
effluent radiation monitors were inspected for
operation. calibration
~
and reliability.
Observations
and Findin s
The main plant vent release
monitor (reactor building effluent monitor)
was out-of-service for greater
than 30 days
from May 14.
1994. through
September
23." 1994.
A loss of vacuum
on the high purity germanium
detector
caused
the monitor to be inoperable.
The detector
is located
on the station's
refueling floor.
Therefore. it was not accessible
during refueling operations.
When the detector
repairs
began after
refueling operations
were completed.
the exact nature
and reason for the
detector failure was not known.
This resulted in an extended repair and
testing period.
The circumstances
which caused this extended
outage of
the monitor were documented
in Plant Evaluation Request
294-0563.
The turbine building ventilation exhaust
monitor was out-of-service for
greater than
30 days
from May 6,
1994, through July 24.
1994.
During
this equipment outage,
the turbine building exhaust
fan motors were
modified.
The modification increased
the maximum exhaust flow rate for
the turbine building from 320
F 000 cubic feet per minute (cfm) to 360,000
cfm.
This modification also required
a modification in the sampling
-8-
system to retain its ability to collect an isokinetic sample.
These
modifications required the monitor to be out-of-service for greater than
30 days.
The circumstances
which caused this extended
outage of the
monitor were documented
in Plant Evaluation Request
294-0702.
The reactor building effluent monitor (low range channel)
was
out-of-service greater
than 30 days
from October
19,
1995, through
December
27,
1995.
The replacement 'for the failed part, which was
stored in the onsite warehouse,
was
damaged in shipment.
This damage
was not recognized during the receipt inspection.
This extended the
monitor outage
because
the part was unique to the system.
and it had to
be returned to the manufacturer for repai r.
A detailed description of
the circumstances
associated
with the extended
outage of the monitor
were documented in Plant Evaluation Request
295-1207-01.
Conclusions
Each of the three Technical Specification required stack ventilation
effluent radiation monitors were out-of-service in excess of Technical
Specification requirements
during 1994 and 1995.
This indicated poor
system reliability, lack of timely engineering
support.
and poor receipt
inspection
performance.
Reactor
Bui ldin
Stack Effluent Monitor
PRM-RE-1B
Calibration Error
Ins ection Sco
e
84750
The inspector
reviewed the licensee's
preoperational
testing
and initial
primary calibration of the intermediate
range of the reactor building
stack effluent monitor (PRM-RE-lB), which was incorrectly and
non-conservatively calibrated.
Observations
and Findin s
Plant Modification Request
90-0305 (reactor building stack effluent
monitor) was developed to replace the original post-accident
system with an on-line. continuous operating,
gamma spectroscopy
system
that would monitor both the normal operating
and post-accident
elevated
effluent releases
from the reactor building.
The intermediate
and high
range monitors of the reactor building stack effluent monitoring system.
governed
by the Technical Specifications.
were to provide the reactor
accident noble gas effluent monitoring capability required for
compliance with the requirements
in NUREG-0737
and Regulatory
Guide 1.97.
This complex, first of a kind, system design
was developed
and engineered
by the licensee
and completed in February
1993.
Three high purity germanium detectors
were installed in the reactor
building elevated
release
discharge
duct to identify and quantify
gaseous
radionuclide releases.
Installation of the reactor building
stack effluent monitoring system
was completed during the station's
refueling outage in the spring of 1993.
Preoperational
testing of the
system
was started
on June
20,
1993,
using Procedure
PPM 8.3.286,
"Reactor Building Stack Effluent Radiation Monitoring System
Preoperational
Test." issued
June
19.
1993.
In order to verify the
performance of the three high purity germanium detectors
(low,
intermediate,
and high range) with the collimators in place, it was
necessary
to maximize the amount of radioactivity seen
by the detectors
in the reactor building stack.
Therefore.
the station
had to be at
power to conduct the reactor building stack effluent monitoring system's
preoperational
testing
and initial primary calibration.
When the monitor readings for the detectors
stabilized
about midnight on
July 4,
1993. calibration of the low, intermediate,
and high range
channels
commenced.
Monitor readings for the detectors
were taken from
the logarithmic rate meter located
on the 525-foot level of the reactor
building and were recorded
on Attachment
6 of the reactor building stack
effluent monitor's preoperational
test procedure.
Grab samples of the
reactor building stack effluent were collected
and analyzed
by the
chemistry department.
This test evolution was completed
about
0500 on
July 5,
1993.
During the reading
and recording of the gross
count rate
value from the intermediate
range monitor, the wrong logarithmic rate
meter scale
was referenced.
This resulted in recording
an erroneous
value of 8,000 counts per second
(cps) instead of the correct value of
2.400 cps.
The data
recorded
was not verified as correct against other
alternate
sources of data.
The erroneous
data
was subsequently
used to
develop
a relationship
between the detector
response
and the gaseous
radioactivity in the stack
as determined
by the grab samples
analyzed
by
the chemistry department.
The intermediate detector efficiency factor
was calculated to be
1.457E+7 counts
per second
per microcurie per cubic centimeter
(cps/pCi/cc)
using the erroneous
data
recorded in the preoperational
test procedure.
This resulted in a non-conservative
gas calibration
efficiency factor and an incorrect.
non-conservative
alarm setpoint.
The correct detector efficiency factor was later determined to be 3.3E+6
cps/yCi/cc.
The erroneous
detector efficiency factor
was put into the reactor
building stack effluent monitoring system's
software to convert future
detector
readings to an equivalent radioactivity concentration.
This
erroneous
detector efficiency factor was also used in the emergency
dose
projection system software to calculate the source term and offsite
doses
during and following an accident.
The result of the erroneous
detector efficiency factor
was that the monitoring system's
software
would have calculated
a lower level of radioactivity released
from the
stack for a given detector
response.
This would have resulted in
offsite dose projections during an accident
being under-estimated
by
a
factor of approximately five.
NRC Inspection Report 50-397/96-03
had
previously identified the under-estimation
of dose
as
20 times lower
than the actual
dose values.
The under-estimating of the offsite doses
-10-
during an accident could have resulted in a failure to correctly
classify an emergency
event,
and also
a failure to correctly establish
appropriate protective action recommendations
to the offsite agencies
in
accordance
with the licensee's
emergency
plan implementing procedures.
The reactor building stack effluent monitor preoperational
test
procedure
was completed
on July 13,
1993.
The test results
were
approved
by the Plant Operations
Committee
on July 14,
1993,
and the
monitor was declared
The inspector
observed that this
appeared to be insufficient time to properly review the approximately
400 pages of data
and calculations.
When the preoperational
test procedure
was completed.
two of the
acceptance criteria were not completed.
One acceptance criteria was for
an additional modification to the monitoring system's
software,
which
was to be made later but in fact,
was never performed.
The other
acceptance
criteria requi red verification of the monitoring system's
performance
standards
against
ANSI N42. 18-1980 criteria.
This was not
performed in a timely manner.
After placing the reactor building effluent stack monitor in operation,
the preoperational
test procedure results
were not reviewed in detail
until the responsibility to review the preoperational
test data
was
assigned to the chemistry department
on December
20,
1995.
While
performing the ANSI N42. 18 review of the monitoring system's
preoperational
test results,
the discrepancy
in the intermediate
range
detector
response
and efficiency calculation
was discovered
by the
licensee.
Based
on the review of the original calibration data for the
intermediate
and high range radiation monitors. the licensee
determined
that both monitors were incorrectly calibrated in July 1993.
Subsequent
calibrations,
which were based
on the original calibration,
were also
determined to be invalid since July 1993.
It was determined that both
monitors detected
and correctly counted
gaseous
radioactivity levels in
the reactor building elevated
release
discharge
duct.
However, the
erroneous calibration efficiency factor resulted in a non-conservative
correlation
between the intermediate
and high range radiation
'monitors'ount
rate
and the specific gaseous
radionuclide concentration
in the
discharge
duct.
This would have resulted in under-estimating
the amount
of gaseous
radioactive effluent had there
been
an accident.
Consequently,
based
on the results of the licensee's
review, the reactor
building stack effluent monitoring system
was declared
from
July 1993 to March 1996 (approximately
32 months)
due to the incorrect
calibration of the intermediate
and high range radiation monitors.
Technical Specification 3.3.7.5,
Table 3.3.7.5-1,
Item 31, requires
both
the intermediate
and high range radiation monitors of the reactor
building stack effluent monitoring system to be operable during Modes
1,
2
~
and 3.
The intermediate
and high range radiation monitors of the
reactor building stack effluent monitoring system were declared
inoperable at
1531 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.825455e-4 months <br />
PST on March 6.
1996.
The plant was in Mode 4
-11-
at the time.
The plant was not returned to power
(Modes
1, 2, or 3)
until the vendor
recommended
conservative detector efficiency factor was
installed in the appropriate monitoring system
and emergency
dose
projection system software programs.
Subsequently,
the licensee
calculated
and installed the correct calibration efficiency factor in
the appropriate monitoring system
and emergency
dose projection system
software programs.
The licensee notified the
NRC via the event notification system at
1630 hours0.0189 days <br />0.453 hours <br />0.0027 weeks <br />6.20215e-4 months <br />
PST on March 6,
1996, of a loss-of-emergency
assessment
capability, in accordance
with 10
CFR 50.72(b)(v).
The licensee
took
the action required
by Action 81 in Table 3.3.7.5-1
and initiated the
preplanned alternate
method of monitoring the appropriate
parameters
as
described
in Plant Procedures
Manual
Procedure
13.8.2.
"Backup Emergency
Dose Projection System Operations,"
Revision 16, dated
October
30,
1995.
The licensee
also issued
a Special
Report to the
NRC. dated
March 20,
1996, pursuant to Technical Specification 6.9.2 within 14 days following
the event.
10 CFR 50.54(q) states.
"A licensee
authorized to possess
and operate
a
nuclear
power reactor shall follow and maintain in effect emergency
plans which meet the standards
in 10
CFR 50 '7(b)
.
.
. ."
10
CFR
50.47(b) states,
"The onsite
and
.
.
. offsite emergency
response
plans
for nuclear
power reactors
must meet the following standards:
.
.
. (9)
Adequate
methods,
systems,
and equipment for assessing
and monitoring
actual or potential offsite consequences
of a radiological
emergency
condition are in use."
Based
on the review of the initial calibration
and operability status of the reactor building stack effluent monitoring
system.
the intermediate
range monitor PRM-RE-1B and high range monitor
PRM-RE-1C were found to be incorrectly calibrated.
Therefore.
the
reactor building stack effluent accident monitors were inoperable
and
not capable of accurately
measuring concentrations
of noble gas fission
products in plant gaseous
effluents during and following an accident
from July 14, '1993,
through March 6.
1996, resulting in the failure to
implement planning standard
10
CFR 50.47(b)(9).
This is considered
an
apparent violation.
(397/9615-01)
c. Conclusions
An apparent violation involving the incorrect and non-conservative
calibration of the intermediate
range radiation monitor
(PRM-RE-1B) of
the reactor building stack effluent monitoring system,
which served
as
the required accident
noble gas monitor,
was identified (Section R2.3).
-12-
R3
Radiological Protection
and Chemistry Procedures
and Documentation
R3. 1
Radioactive
Waste Effluent Procedures
Offsite Dose Calculation Manual
and Annual
Re orts
a.
Ins ection
Sco
e
84750
Procedures
for the sampling,
analysis,
and release of radioactive liquid
and gaseous
waste effluents were reviewed.
Amendments to the Offsite
Dose Calculation
Manual were reviewed.
The annual
reports concerning
radioactive waste
systems
and effluent releases
were reviewed.
b.
Observations
and Findin s
Procedures
governing the release of liquid radioactive waste effluents
were reviewed.
These procedures
provided for the following:
Prior to release:
recirculation,
sampling,
and
r adionuclide analysis of the
radioactive liquid waste
~
calculations of effluent release
rate, effluent radiation monitor
setpoints,
projected offsite radionuclide concentrations,
and
offsite doses
During the release:
~
verification and recording of effluent discharge
flow rates,
effluent volume discharged,
effluent discharge
radiation monitor
readings.
and dilution parameters
Procedures
governing the continuous
and batch releases
of gaseous
radioactive waste effluents were reviewed.
These procedures
provided
for the sampling
and analysis of the radioactive
gaseous
and airborne
particulate waste effluents; verification of effluent discharge
flow
rates, effluent volume discharged'nd
dilution parameters
during the
release;
and calculation of effluent release
rate
and offsite
radionuclide concentrations
and doses.
The inspector
reviewed changes
(Amendments
17-23) to the Offsite Dose,
Calculation Manual, which were made
and approved
by the Plant Operations
Committee during 1994 and 1995.
The changes
were documented
in the
Radioactive Effluent Release
Reports
as required
by the Offsite Dose
Calculation Manual.
The Annual Radioactive Effluent Release
Reports for 1994 and
1995 were
reviewed.
The reports
were written in the format described in NRC
Regulatory Guide 1.21, Revision
1. June
1974,
and contained the
information required
by the Offsite Dose Calculation Manual.
-13-
R4
R4.1
C.
Summaries of the quantities of radioactive liquid and gaseous
effluents
released to the environment
and their associated
doses to members of the
public for 1994 and 1995 were properly presented
in the annual
reports.
Conclusions
Procedures
established to implement the liquid and gaseous
radioactive
waste effluent management
programs
provided proper guidance.
The
radioactive waste effluent management
programs
were properly
implemented.
Amendments to the Offsite Dose Calculation Manual were
properly documented.
The Annual Radioactive Effluent Release
Reports
for
1994 and
1995 were submitted in a timely manner
and contained the
required information presented
in the requi red format.
Staff Knowledge and Performance
Chemistr
Staff
Ins ection Sco
e
84750
The chemistry operations
supervisor,
effluents leader.
chemistry
technicians.
and equipment operators
were interviewed with regard to
regulatory
and Offsite Dose Calculation Manual requirements
for the
implementation of the radiological waste effluent management
programs.
Observations
and Findin s
The chemistry operations
supervisor,
effluents leader,
chemistry
technicians,
and equipment operators
were knowledgeable of the
programmatic procedures,
Offsite Dose Calculation
Manual requirements,
and regulatory requirements
and maintained
a high level of performance.
Batch radioactive liquid waste effluent releases
and continuous
radioactive
gaseous
waste effluent releases
were properly performed
during the inspection.
Conclusions
The chemistry'perations
supervisor,
effluents leader,
chemistry
technicians,
and equipment operators
had an excellent understanding
of
the radioactive waste
management
procedures,
Offsite Dose Calculation
Manual,
and regulatory requirements.
-14-
R5.1
R6
R6.1
b.
Staff Training and gualification
Chemistr /Radioactive
Waste Effluent Trainin
and
uglification
Ins ection Sco
e
84750
Training and qualification programs for chemistry technicians
and
equipment operators
involved with conducting the radioactive waste
effluent management
programs
were reviewed.
Training and qualifications
of the chemistry technicians
and equipment operators
were verified.
Observations
and Findin s
The chemistry technician qualification matrix and personnel training
records for all
15 chemistry technicians
and for 22 equipment operators
were reviewed.
It was verified that all of the chemistry technicians
had completed the training required to perform radioactive waste
effluent releases.
Similarly, the equipment operators
assigned to six
rotating shifts were trained
and qualified to conduct radioactive waste
effluent batch releases
and operate radioactive waste processing
equipment.
Conclusions
Training programs
were properly implemented.
The chemistry
and
operations
departments
had well trained
and qualified staffs for
conducting radioactive waste effluent processing
and release
operations.
Radiological Protection
and Chemistry Organization
and Administration
Chemi str
Or ani zati on and Sta ffin
,Ins ection Sco
e
84750
The organization
and staffing regarding the radioactive waste effluent
management
programs
were reviewed.
Observations
and Findin s
The inspector
verified that the chemistry organization
and staff, which
are responsible for the implementation of the radioactive waste effluent
management
programs,
was recently combined with the radiation protection
organization
and staff into one department
under the direction of a
newly appointed radiation protection/chemistry
manager.
The chemistry
organization
was assigned
the sole responsibility for implementing the
radioactive waste effluent management
programs effective October
1993.
The chemistry organization
was divided into four functional areas
each
R7
R7.1
a.
-15-
headed
by a supervisor
or the effluents leader,
who reported directly to
the chemistry operations
supervisor.
The functional area
headed
by the
effluents leader
was responsible for implementing the radioactive waste
effluent management
programs.
Administrative and departmental
procedures
were reviewed for the
assignment of responsibilities
for the management
and implementation of
the radioactive waste effluent management
programs.
The chemistry
organization
was assigned
the responsibility for preparing radioactive
waste effluent release
permits. evaluating the radioactive waste
effluent releases,
calculating the radiation
doses resulting from the
effluent releases
to the environment,
and maintaining the radioactive
waste effluent release
data.
The inspector
determined that the duties
and responsibilities of the chemistry organization specified in the
procedures
were being implemented.
A group of ten chemistry technicians staffing six rotational shifts
within the chemistry operations
functional
area
along with four nonshift
chemistry technicians
and the effluents leader assigned to the
radioactive waste effluents f'unctional
ar ea were responsible for
collecting and analyzing radioactive waste effluent samples,
preparing
the effluent release permits'nd
implementing the radioactive waste
effluent management
programs.
The inspector
reviewed the staffing of the chemistry organization
and
determined it to be adequate
and in accordance
with licensee
commitments.
There
had
been
a reduction in technical staff within the
chemistry organization since the previous
NRC inspection of this area in
January
1995.
This staff reduction did not appear to have
a negative
affect on the performance of the radiological waste effluent management
programs.
Conclusions
The chemistry organizational
structure
and staffing met Technical
Specification requirements.
The chemistry organization
had experienced
a reduction in technical staff during the past
17 months.
This
chemistry technical staff reduction did not appear to have
a negative
affect on the performance of the radiological waste effluent management
programs.
Quality Assurance in Radiological Protection
and Chemistry Activities
Radi oact ive Waste Effluent
ua1 it
Assur ance
Pro
ram
Ins ection Sco
e
84750
The quality assurance
audit and surveillance
programs
regarding the
radioactive waste effluent program activities were reviewed.
The
following quality assurance
audits were reviewed.
-16-
~
Quality Assurance Audit Report 293-618.
"Radiological
and
Non-Radiological
Environmental
and Effluent Monitoring." dated
November
19,
1993
~
Quality Assurance Audit Report 294-066,
"Radiological
and Non-
Radiological
Environmental
and Effluent Monitoring Programs,"
dated
November
18,
1994
~
Quality Assurance Audit Report 295-072,
"Radiological
and
Non-Radiological
Environmental Monitoring Programs."
dated
November
27,
1995
~
Quality Assurance Audit Report 295-061.
"WNP-2 Training and
Qualification," dated
September
19,
1995
The following quality assurance
survei llances
were reviewed.
~
Quality Assurance Surveillance
295-008,
"Radioactive Liquid Batch
Releases
to the Columbia River," dated June
7.
1995
~
Quality Assurance Surveillance
295-026.
"Chemistry Laboratory
Observations."
dated April 19,
1995
~
Quality Assurance Surveillance
296-005,
"Radwaste Deficiency
Identification Stickers,". dated January
14,
1996
~
Quality Assurance Surveillance
296-015,
"Annual Radioactive
Effluent Release
Report," dated
March 22,
1996
~
Quality Assurance Surveillance
296-023,
"Stack Monitoring System
Operation," dated
June
12,
1996
b.
Observations
and Findin s
The inspector
reviewed the quality assurance
audit schedules
for 1995
and 1996. the chemistry functional area planning guide from the
master critical attribute data
base.
and the qualifications of the
quality assurance
auditors,
who performed the audits
and survei llances
of the radiological
and nonradiological
environmental
and effluent
monitoring programs
and Offsite Dose Calculation Manual.
The review of
the quality assurance
audit schedules
indicated that the audits of the
radiological
and nonradiological
environmental
and effluent programs
were scheduled
on
a 12-month frequency in accordance with Technical Specifications 6.5.2.8.j
and 6.5.2.8.m.
The quality assurance
audit
of the Offsite Dose Calculation
Manual
and its implementing procedures
was scheduled
on
a 24 month frequency
(even
number years) in accordance
with Technical Specification 6.5.2.8.k.
The audits were scheduled
in
compliance with Technical Specification audit frequency requirements.
-17-
R8
R8.1
Reports of quality assurance
audits
and surveillances
performed during
the period January
1993 through June
1996 of the areas
related to
the performance. of the radioactive waste effluent management
programs
were performed in accordance
with the quality assurance
procedures
and
schedules
by qualified auditors.
The reviewed audits
and survei llances
of the radiological
and nonradiological
environmental
and effluent
monitoring programs
and the Offsite Dose Calculation
Manual
and its
implementing procedures
were of good quality and provided satisfactory
oversight
and evaluation of the licensee's
performance in implementing
the radioactive waste effluent management
programs
and meeting the
Technical Specification
and Offsite Dose Calculation
Manual
requirements.
To ensure that all aspects
of the station's
programs
were reviewed, the
quality assurance
organization maintained lists of "critical attributes"
associated
with each
program.
The inspector
reviewed the chemistry
functional area
planning guide from the master critical attribute data
base
and compared the list of critical attributes
associated
with the
chemistry,
radioactive waste effluents,
and radiological environmental
monitoring programs with areas of inspection included in NRC inspection
procedures
and concluded that the licensee's list of critical attributes
was comprehensive.
The inspector
noted that the list of critical
attributes
was comprehensive.
Conclusions
Oversight of the radioactive waste effluent management
programs
was
good.
In general,
quality assurance
audits
and survei llances of the
radioactive waste effluent management
programs
and Offsite Dose
Calculation Manual were technically comprehensive
and provided good
program evaluation
and oversight, identified deficiencies,
and
made
recommendations
for program improvement.
The corrective
action program
was properly implemented.
Miscellaneous
Radiological Protection
and Chemistry Issues
Closed
Ins ection Fol 1 owu
Item 397/9523-01:
Tr ainin
for
Envi ronmenta
1 Sci enti st
This item involved the lack of meteorological
monitoring technical
training for an environmental scientist recently assigned
the
responsibility for compiling, analyzing,
and reporting the station's
meteorological
data.
This environmental scientist
had not received
specific training on the station's meteorological
monitoring systems
and
was not knowledgeable of the recommendations
contained in the industry
standards
involving meteorological
monitoring activities.
A consultant
was hired to conduct
an independent
audit of the meteorological
monitoring program and present
a 2-day meteorological training seminar.
-18-
The inspector
reviewed the results of the audit and the training seminar
outline and content.
The inspector verified that the environmental
scientist
and other appropriate staff were trained in meteorological
principles
and the interpretation of meteorological
monitoring data.
R8.2
Closed
Unr esolved
Item 397/9603-07:
Reactor Buildin
Effluent Monitor
Calibration Error
This item involved the resident inspectors'eview of the licensee's
notification to the
NRC that the Reactor Building Effluent Monitor
PRM-RE-18 had been incorrectly calibrated since its installation in July
1993 and was, therefore.
inoperable since that time.
The licensee
determined that the gas calibration efficiency factor was incorrectly
calculated
because
a value from the wrong logarithmic scale
on the
monitor's count rate meter was used.
The inspector
reviewed the
licensee's
Plant Evaluation Request
296-0176.
which was issued to
evaluate the problem and determine corrective actions.
A 14-day Special
Report was submitted to the
NRC on March 20.
1996.
The inspector's
review of the problem resulted in the identification of an apparent
violation as discussed
in Section
R2.3 of this report.
V. Mana ement Meetin s
Exit Meeting Summary
The inspector presented
the results of the inspection to members of
licensee
management
at the conclusion of the inspection
on June
28.
1996.
The licensee
acknowledged
the findings presented.
A followup
telephone exit meeting
was also conducted
on July 29,
1996 'to inform
the licensee of the enforcement
panel's disposition of the inspection
results.
The inspector
asked the licensee
whether
any materials
examined during
the inspection
should
be considered proprietary.
No proprietary
information was identified.
Licensee
ATTACHMENT
PARTIAL LIST OF
PERSONS
CONTACTED
R. Abdella.
Lead Training Specialist.
Chemistry
A. Alexander.
Effluents Leader
~ Chemistry
W. Barley,
Manager.
Quality
C. Foley. Licensing Engineer
H. Hedges'cting
Chemistry Manager
R. James.
Acting Supervisor.
T. Love. Manager.
Radiation Protection/Chemistry
C.
McDonald
~
Supervisors'ealth
Physics/Chemistry
Training
J. Huth. Manager. Quality Services
J. Parrish.
Chief Executive Officer
L. Rathbun.
Supervisors'adiation
Protection Support
G. Smith. Plant General
Manager
'.
Swanky
Manager.
Regulatory Affairs
R. Webring. Vice President.
Operations
Support
V. Harris.
Hanager.
Maintenance
L. Fernandez.
Manager,
Licensing
R. Winslow. Acting Radiation Protection
Manager
NRC
~
~
G. Replogle.
Resident
Inspector
H.
Wong, Chief. Reactor
Programs
Branch
E. Division of Reactor Projects
INSPECTION
PROCEDURES
USED
Radioactive
Waste Systems:
Water Chemistry: Confirmatory
Measurements
and Radiological
Environmental
Monitoring
ITEMS OPENED
CLOSED
AND DISCUSSED
O~ened
50-397/9610-01
Reactor Building Stack Effluent Monitor Calibration
Error
Closed
50-397/9523-01
IFI
Training for Environmental Scientist
50-397/9603-07
Effluent Honitor Calibration Error
Discussed