ML17292A681
| ML17292A681 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 02/07/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A677 | List: |
| References | |
| 50-397-97-01, 50-397-97-1, NUDOCS 9702120200 | |
| Download: ML17292A681 (27) | |
See also: IR 05000397/1997001
Text
ENCLOSURE
U,S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
License No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved By:
50-397
50-397/97-01
Washington Public Power Supply System
Washington Nuclear Project-2
3000 George Washington Way
Richland, Washington
January 6-9, 1997
Larry T. Ricketson, P.E., Senior Radiation Specialist
Thomas H. Andrews, Radiation Specialist
Blaine Murray, Chief, Plant Support Branch
Attachment:
Supplemental Information
~70a<ZO200
970a07
ADOCK 05000397
8
ess
-2-
EXECUTIVE SUMMARY
Washington Nuclear Project-2
NRC Inspection Report 50-397/97-01
One area of the inspection reviewed changes
in the staffing and structure of the radiation
protection organization and the results of the program to maintain occupational radiation
exposure
as low as is reasonably achievable (ALARA)~ The second area of inspection
reviewed the implementation of the solid radioactive waste management
program and the
program for transportation of radioactive materials and radioactive wastes.
Both areas of
inspection reviewed training and qualifications of personnel involved and the audits,
appraisals,
and other means of maintaining quality.
Ensnineerinq
Inconsistencies
were noted between the wording of the final safety analysis report
and the plant practices, procedures
and/or parameters
(Section E2.1).
Plant Su
ort
Improvements were made in reducing the plant source term.
Person-rem totals
trended downward, although they were still higher than the national average for
boiling water reactors.
The ALARAsuggestion program results indicated worker
support.
ALARAcommittee record keeping needed improvement (Section R1.1).
~
The amount of radioactive waste disposed decreased
from 1994 through 1996.
A good solid radioactive waste program was implemented (Section R1.2).
A proper procedure for shipping low specific activity materials had been established;
however, the procedure did not include guidance for evaluating surface
contaminated objects or for the transport of fissile material (Section R3.1).
~
Radiation protection technician training was implemented properly.
Support for
professional advancement
of radiation protection technicians improved
(Section R5.1).
The effluent minimization supervisor did not fully satisfy the existing qualification
requirements contained within the final safety analysis report (Section R5.2).
Individuals designated
as primary shippers were very knowledgeable of regulations,
requirements,
and associated
procedures
related to the transfer, packaging, and
transport of radioactive material.
The licensee committed to providing the effluent
minimization supervisor with training in the Department of Transportation and NRC
regulations associated
with the transport of radioactive material by March 31, 1997
(Section R5.3).
ess
-3-
~
There was significant turnover in personnel and a reduction in staffing within the
radiation protection organization.
However, there were no indications that the
changes
adversely effected radiation safety or the safe operation of the plant
(Section R6.1).
'I
Organization changes were not reflected in the licensee's administrative procedure
that described the interfaces and individual responsibilities associated with the
radioactive waste program (Section R6.2).
Overall, improvement was noted in the performance of self-assessments
by the
radiation protection organization.
However, followup on the self-assessment
findings was not timely (Section R7.1)
The licensee was not proactive in conducting audits, surveillances,
or self-
assessments
associated with the extensive changes to the transportation
regulations effective April 1, 1996 (Section R7.2)
-4-
Re ort Details
III. En ineerin
E2
Engineering Support of Facilities and Equipment
E2.1
Review of Final Safet
Anal sis Re ort Commitments
a.
Ins ection Sco
e
A recent discovery of a licensee operating their facility in a manner contrary to the
final safety analysis report description highlighted the need for a special focused
review that compares plant practices, procedures and/or parameters to the final
safety analysis report description.
While performing the inspections discussed
in
this report, the inspectors reviewed the applicable portions of the final safety
analysis report that related to the areas inspected.
b.
Observations
and Findin s
The following inconsistencies
were noted between the wording of the final safety
analysis report and the plant practices, procedures and/or parameters
observed by
the inspectors.
The effluent minimization supervisor did not fully satisfy the qualification
requirements listed in the final safety analysis report (Section R5.2).
The administrative procedure that described the organization and assigned
responsibilities for the implementation of the solid radioactive waste program
was not consistent with the current organization and the final safety analysis
report (Section R6.2).
c.
Conclusions
Inconsistencies
were noted between the wording of the final safety analysis report
and the plant practices, procedures,
and/or parameters.
-5-
IV. Plant Su
ort
R1
Radiological Protection and Chemistry Controls
R1.1
Maintainin
Occu ational Ex osures ALARA
a 0
Ins ection Sco
e 83750
The ALARAsupervisor was interviewed.
The following items were reviewed:
Person-rem totals for 1994, 19S5, 1996
ALARAcommittee meeting minutes for the second, third, and fourth quarter
of 1996
b.
Obse vations and Findin s
The licensee's
1994, 1995, and 1996 person-rem totals are shown below:
Licensee's
Results
Licensee's 3-Year
Average
National BWR
Average
1994
867
649
327
1995
427
588
256
1996
370
555
Not yet
available
The total annual exposure had declined since 1994.
Licensee representatives
attributed much of the decline to an aggressive
shielding program.
Flushing and hot
spot removal also achieved good results.
According to licensee personnel, flushes
were routinely included on the outage schedule and implemented through procedural
guidance.
Also according to licensee personnel,
all hot spots were cut out,
shielded, or removed through flushing.
Despite these efforts, exposure totals,
although declining, were still significantly above the national average for boiling
water reactors.
During NRC Inspection 50-397/96-10,the
inspectors identified a noncited violation
because
the ALARAsuggestion program was not implemented.
The ALARA
suggestion program was reinstated during the last half of 1996.
The ALARA
-6-
supervisor stated that approximately 15 suggestions
had been received and were
being reviewed to determine if they were viable.
The inspectors concluded that, for
a period in which there was no refueling outage, the number of ALARAsuggestions
indicated good acceptance
and support for the program by radiation workers.
The inspectors confirmed, through a review of ALARAcommittee meeting minutes,
that the committee met management expectations
by meeting quarterly.
However,
record keeping of committee meetings became lax during the second half of 1996
and records of meetings were not kept in accordance with management
expectations included in Plant Procedure
1.11.2, Section 6. The record for the third
quarter 1996 meeting was not filed properly and had to be reconstructed
during the
inspection from notes maintained by the health physic/chemistry manager.
The
record provided for the fourth quarter 1996 was a copy of an electronic mail
message
in a different format. The plant support services manager stated that
future records of ALARAcommittee meetings would conform to management
expectations.
Conclusions
Improvements were made in reducing the plant source term.
Person-rem totals
trended downward, although they were still higher than the national average for
boiling water reactors.
The ALARAsuggestion program results indicated worker
support.
ALARAcommittee record keeping needed improvement.
R1.2
Im lementation of the Solid Radioactive Waste Mana ement and Trans ortation
~Pro rams
Ins ection Sco
e 86750
The inspectors observed or reviewed the following:
Quantities of radioactive waste disposal,
Availabilityof copies of regulations and state licenses,
Availabilityof copies of topical reports associated with radioactive waste
processing systems,
Availabilityof copies of current licenses for recipients of shipments of
radioactive materials,
Use of computer program to generate shipping papers,
Use of scaling factors to account for isotopes that were difficultto detect or
measure,
and
Copies of shipping documents for previous shipments of radioactive materials
and radioactive waste.
-7-
45~II
b.
Observations
and Findin s
The licensee provided the following information related to the quantities of
radioactive waste disposed.
The inspectors noted the trend of decreasing
volume
and curies.
Resin
Dry Active Waste
Total
Year
Volume
(ft')
Activity
(Ci)
Volume
(ft')
Activity
(Ci)
Volume
Activity
(ft')
(Ci)
1994
1995
1996
6815
5367
4728
1130
877
518
5614
4378
3313
70
57
12429
9745
8041
1200
884
575
The inspectors determined that the licensee maintained current copies of regulations
and state licenses, copies of topical reports associated
with radioactive waste
processing systems,
and copies of current licenses for recipients of shipments of
radioactive materials.
The licensee used a vendor-supplied computer program to generate shipping papers.
The inspectors reviewed the table of A, and A, values used by the program and
compared selected isotope values to those provided in the regulations.
The values
~ compared were determined to be correct.
The inspectors reviewed the method by which the licensee entered scaling factor
information into the program.
The data was reviewed and no discrepancies
were
noted.
The licensee was in the process of documenting the latest data for the waste
stream analysis values.
The inspectors discussed the methodology used and
compared this with the licensee's
procedures.
The methodology used was
consistent with the licensee's procedural guidance.
During the inspection period, no shipments of radioactive material or radioactive
wastes were conducted.
The inspectors reviewed selected shipping packages for
shipments completed after April 1, 1996.
Packages
were reviewed to confirm
proper content and to ensure proper characterization
and classification.
No
problems were noted with these documents.
-8-
c.
Conclusions
The licensee continually reduced the amount of radioactive waste disposed from
1994 through 1996.
The licensee's
solid radioactive waste program was
adequately implemented.
R3
Radiological Protection and Chemistry Procedures
and Documentation
R3.1
Trans ortation Procedures
a.
Ins ection Sco
e Tl 2515 133
The inspectors reviewed the following:
Changes
made to the licensee's procedures for the processing
and packaging
of low specific activity material,
The licensee's plans for the use of packaging for shipments of low
specific-activity material,
The licensee's process for shipments of surface contaminated objects,
Selected shipping packages,
and
The licensee's process for shipments of fissile material.
b.
Observations
and Findin s
The procedure for shipping low specific activity adequately addressed
packaging,
labeling, placarding, shipping papers, proper shipping name, and information to be
included in shipping documents.
No discrepancies
were identified.
The licensee did not have procedural guidance for classifying shipments as surface
contaminated objects or for assessing
contamination levels on inaccessible
areas of
an object.
The licensee stated that appropriate guidance would be developed
should the need to ship surface contaminated objects arise.
Through a review of shipping documentation, the inspectors confirmed that the
licensee had made no shipments classified as surface contaminated objects.
The inspectors identified items that were shipped as low specific activity shipments
that initially appeared
may have been more appropriately classified as surface
contaminated objects.
However, the inspectors confirmed that the licensee's
method for determining that the contamination was "distributed throughout" was
valid for these items and that the licensee had properly classified the shipments.
The licensee did not have procedural guidance for classifying shipments as fissile
material.
There was no guidance provided to assess
the transport index for this
material.
The licensee stated that appropriate guidance would be developed should
the need to ship fissile material arise.
-9-
Through a review of shipping documentation, the inspectors confiimed that the
licensee had made no shipments classified as fissile material or shipment that
should have been classified as fissile material.
c.
Conclusions
The licensee's
procedure for shipping low specific activity materials was consistent
with Department of Transportation regulations.
The licensee did not have procedural guidance for evaluating surface contaminated
objects or for the transport of fissile material.
R5
Staff Training and Qualification
R5.1
Radiation Protection
a.
Ins ection Sco
e 83750
The radiation protection/chemistry/general
employee training supervisor and the
radiation protection manager were interviewed.
The following items were reviewed:
Problem evaluation requests,
Radiation protection technician training lesson plans,
Class attendance
lists,
Instructor evaluations, and
Selected training procedures.
b.
Observations
and Findin s
Four of 59 problem evaluation requests
assigned to the radiation protection
organization for disposition in 1996 listed problems with training as the primary or a
contributing cause.
Based on this information, the inspectors concluded that
inadequate
or improper training was not a major contributor to the identified
radiation protection concerns.
The inspectors reviewed training topics presented to radiation protection technicians
in 1995 and 1996 and determined that they were appropriate.
Training topics
included discussions of current industry events and training on plant systems and
components.
With regard to the latter item, the low power radiation monitoring
system, fuel pool cooling system, and control rod drive mechanisms were reviewed.
The training representative
stated that there was designated
classroom space for
radiation protection technician training. The inspectors noted that this was an
improvement made since NRC Inspection 50-397/94-25.
-10-
During NRC Inspection 50-397/94-25,the
inspectors noted 3 individuals were
registered by the National Registry of Radiation Protection Technologists.
In 1995,
11 people were tested and registered.
An additional 10 people took the
examination in 1996 and were awaiting the results.
A review of the training for supervisors
and professionals
in the radiation protection
organization was inconclusive.
Four of the supervisors were newly appointed to
their positions and had not attended continuing training in their fields of expertise.
The training records of the individuals they replaced were not reviewed because,
in
most cases, the individuals maintained the records of these trips and the individuals
were no longer employed.
The remaining supervisors
and professionals
had
received appropriate training.
C.
Conclusions
Radiation'protection technician training was implemented properly and resulted in
few problems.
Support for professional advancement of radiation protection
technicians improved.
R5.2
Solid Radioactive Waste Pro ram Personnel Qualifications 86750
a.
Ins ection Sco
e
The inspectors interviewed the plant support services manager, the general
chemistry supervisor, and the effluent minimization supervisor.
The plant support
services organization chart was reviewed.
b.
Observations
and Findin s
Since the last inspection of the solid radioactive waste program, the organizational
alignment for the solid waste program changed significantly. A new department
was created called the Plant Support Services Department.
The solid radioactive
waste program was moved from the radiation protection organization to the effluent
minimization supervisor.
This supervisor reports to the chemistry general
supervisor, who in turn, reports to the plant support services manager.
Qualification requirements for the effluent minimization supervisor, chemistry
general supervisor, and plant support services manager were contained in
Section 13.1.3.1
~ 5 of the final safety analysis report.
These individuals were
interviewed by the inspectors regarding their background and experience.
Based on
these interviews, the inspectors determined that the plant support services manager
and the chemistry general supervisor met the experience commitments in
Section 13.1.3.1.5 of the final safety analysis report.
-11-
The effluent minimization supervisor had diverse areas of responsibility reporting to
him.
He was responsible for gaseous
and liquid effluents, and had been assigned
the responsibility for the solid radioactive waste program.
Sections 12.3.1.4.3 and
12.5.3.6 of the final safety analysis report each contained the following statement,
"The effluent minimization supervisor is responsible for minimization of
radioactive waste and the preparation, offsite shipment, and disposal of
radioactive materials and radwaste."
Final safety analysis report, Section 13.1.3.1.5, described qualification requirements
for the plant support services organization.
Specific requirements were stated for
the plant support services manager, radiation protection manager,
and the chemistry
general supervisor.
A paragraph
in this section addressed
requirements for "Other
Plant Support Services Supervisors."
This was the paragraph that the inspectors
used to evaluate the qualifications of the effluent minimization supervisor.
This
paragraph stated,
"Other Plant Support Services supervisors who are responsible for directing
the actions of technicians shall, in accordance with ANSI 18.1-1971, have a
high school diploma or equivalent and a minimum of four years of related
service."
Based upon interviews with the effluent minimization supervisor, the inspectors
determined that the individual did not have direct experience
in the offsite shipment
and disposal of materials and radioactive waste.
The licensee contended that the
individual was qualified since he had sufficient experience performing support
functions, such as isotopic analysis of resins, procuring and transferring resins
within the plant, etc.
The licensee also stated that the individual had sufficient
experience
in the liquid and gaseous effluents processes
to be considered qualified
for the position.
The inspectors acknowledged the licensee's position, but
contended that the cited areas of experience did not directly apply to the offsite
shipment and transportation of radioactive materials.
At the time the effluent minimization supervisor was appointed, the licensee issued
a memorandum that designated specific individuals as having the authority to
transport radioactive materials.
The effluent minimization supervisor was not
designated
as having this authority.
The inspectors noted that the licensee had two individuals that were qualified to
ship radioactive materials.
These individuals reported to the effluent minimization
supervisor.
They had received the necessary
training and had sufficient experience
to ensure that shipment of radioactive materials could be performed safely and in
compliance with NRC and Department of Transportation regulations.
-12-
In the memorandum designating these two individuals as having signature authority
for shipment of radioactive materials, specific guidance was given that they were
not to review their own work. It further stated that all other responsibilities
assigned to the effluents minimization supervisor were retained by the effluents
minimization supervisor.
Because of the size of the licensee's qualified staff and the experience of the
effluent minimization supervisor, the inspectors were concerned that future
procedure revisions may not receive adequate
technical review if they were
reviewed by the effluent minimization supervisor.
The licensee stated that the
memorandum would be revised to ensure that technical reviews of procedure
changes related to the shipment would be performed by an individual with the
necessary
expertise.
The review of delegation of responsibilities from the effluents
minimization supervisor to ensure adherence
to commitments to the NRC is an
inspection followup item (50-397/9701-01).
During NRC Inspection 50-397/95-04,the
experience of supervisory personnel
in
the solid radioactive waste group was considered
a strength.
Because of changes
in personnel, the area is no longer considered
a strength.
c.
Conclusions
The plant support services manager and the chemistry general supervisor satisfied
the qualification commitments listed in the final safety analysis report.
The effluent
minimization supervisor, did not fully satisfy the existing qualification commitments
in the final safety analysis report.
R5.3
Solid Radioactive Waste Pro ram Personnel Trainin
86750
a.
Ins ection Sco
e
The inspectors reviewed the training records for personnel involved in the transfer,
packaging, and transport of radioactive material.
b.
Observations and Findin s
In licensee letter G02-'79-147, dated August 28, 1979, the licensee committed to
meet the recommendations
contained in Items 1-7 of IE Bulletin 79-19.
Item 5 of
this bulletin states,
"Provide training and periodic retraining in the DOT and NRC regulatory
requirements, the waste burial license requirements,
and in your instructions
and operating procedures for all personnel involved in the transfer, packaging
and transport of radioactive material. Maintain a record of training dates,
attendees,
and subject material for future inspections by NRC personnel."
'
-13-
The two individuals designated
as the primary shippers for the licensee completed
this training in February 1996.
The effluent minimization supervisor had not completed training related to regulatory
requirements for transportation or disposal of radioactive material or radioactive
waste.
While not a designated
shipper, this individual would be responsible for
assigning priorities, scheduling, budget, approving purchases
of items related to
transportation of radioactive materials, etc.
The inspectors determined that his role
as direct supervisor of the designated
shippers constituted involvement in the
transfer, packaging, and transport of radioactive material.
Combined with the issue
associated with the lack of experience
in this area (see Section 5.1), Mr. Greg
Smith, Plant General Manager committed during the exit meeting on January 9,
1997, to providing this training by March 31, 1997.
C.
Conclusions
Individuals designated
as primary shippers were knowledgeable of regulations,
requirements,
and associated
procedures
related to the transfer, packaging and
transport of radioactive material.
The licensee committed to providing the effluent
minimization supervisor with training in the Department of Transportation and NRC
regulations associated with the transport of radioactive material by March 31,
1997.
R6
Radiological Protection and Chemistry Organization and Administration
R6.1
Radiation Protection Or anization
a e
Ins ection Sco
e 83750
The radiation protection manager and the ALARAsupervisor were interviewed.
Organization charts for June and October 1996 were reviewed.
b.
Observations
and Findin s
Significant changes occurred within the radiation protection organization during
this assessment
period.
As reported in NRC Inspection 50-397/96-10,the
radiation
protection organization was placed under the supervision of the chemistry manager,
who became the plant support services manager in April 1996.
The radiation
protection manager was appointed as the nuclear training manager.
During this
inspection, the licensee announced that the individual was replaced as nuclear
training manager.
Two other individuals have acted as radiation protection
manager in the interim. The second individual was selected
as radiation
protection manager and assumed
the duties on June 29, 1996.
The inspectors
reviewed the qualifications of the acting radiation protection manager during NRC
Inspection 50-397/96-10, and determined that the individual met the requirements
of Technical Specification 6.3.
i
-14-
During calendar year 1996, the organization reduced the number of technicians by
11 individuals.
Six supervisors or professionals terminated employment.
The
number of radiation protection technician instructors was reduced from two to one.
With regard to the reduction in radiation protection technician instructors, the
radiation protection manager stated the radiation protection organization would
support the training organization by supplying individuals to provide training. Two
members of the radiation protection organization were former instructors who
maintained active instructor qualifications.
All supervisors reporting to the radiation protection manager were replaced.
This
included the appointment of a new ALARAsupervisor.
The individual was the third
person to act as the ALARAsupervisor in the last 2 years.
The responsibility for implementing the solid waste management
and transportation
program was shifted to the chemistry organization.
This changes
is discussed
in
Section R6.2.
The inspectors identified nothing to indicate that these changes adversely affected
plant safety.
c.
Conclusions
There was significant turnover in personnel and a reduction in staffing within the
radiation protection organization.
However, there were no indications that the
changes adversely effected radiation safety or the safe operation of the plant.
R6.2
Solid Radioactive Waste Or anization
a.
Ins ection Sco
e 86750
The inspectors reviewed changes to the licensee's solid radioactive waste program.
The most significant changes involved organizational changes.
b.
Observations
and Findin s
In October 1996, the licensee reassigned
the solid radioactive waste organization
from the radiation protection manager to the chemistry general supervisor.
This
resulted in a change in the reporting chain and assignment of responsibilities for the
direct implementation of the solid radioactive waste program.
The licensee prepared
a safety evaluation of the organization change and performed an evaluation in
accordance
with the requirements of 10 CFR 50.59.
As part of this evaluation,
changes to the final safety analysis report were prepared and reviewed.
-15-
The organization was consistent with the information within the final safety analysis
report.
However, Procedure 1.12.1, "Radioactive Waste Management Program,"
Revision 7, was not revised to demonstrate
the current organization structure and
assignment of responsibilities.
At the time of the inspection, procedure changes were in progress.
Because of the
ongoing procedure revision process, this was considered to be a minor deviation
between the plant procedure and the final safety analysis report.
During the exit
meeting on January 9, 1997, Mr. Greg Smith, Plant General Manager, committed to
complete this procedure change by February 14, 1997.
c.
Conclusions
Organization changes that occurred were not reflected in the licensee's
administrative procedure that described the interfaces and individual responsibilities
associated with the radioactive waste program.
R7
Quality Assurance in Radiological Protection and Chemistry Activities
R7.1
Radiation Protection Pro ram
Ins ection Sco
e 83750
The following items were reviewed:
Quality assurance
surveillances,
Radiation protection self-assessments,
Independent assessments,
and
Problems evaluation requests.
b.
Observations
and Findin s
During NRC Inspection 50-397/96-10,the
inspectors were informed by the licensee
that audits of the radiation protection program would no longer be performed.
Instead, oversight would consist of quality assurance
surveillances and self-
assessments
by the radiation protection organization.
At that time, the inspectors
noted that no self-assessments
had been performed.
Since June 28, 1996, the radiation protection organization had performed numerous
self-assessments.
The self-assessments
reviewed are listed in the attachment to
this report.
-1 6-
The self-assessments,
along with one independent assessment,
identified many
opportunities for improvement.
Although the assessments
were performed in July,
August, September,
and October 1996, radiation protection management
had not
evaluated the findings for viability and had not assigned actions necessary to
implement viable recommendations.
The plant tracking log was the method used by
the licensee to track action items.
The inspectors determined through interviews with the radiation protection manager
that actions related to assessments,
performed by other than quality assurance
personnel, were not included on the plant tracking log until January 7, 1996. At
that time, actions to address the findings of one of the self-assessments
were
included on the plant tracking log. Actions to address the findings of other self-
assessments
had not been included on the plant tracking log by the end of the
inspection.
The inspectors considered tardy dispositioning of self-assessment
findings to be a
weak area in the radiation protection program.
Following the inspection, during an in-office review of the self-assessments
findings, the inspectors determined that most recommendations
did not involve
regulatory compliance issues.
Most were suggestions
intended to enhance
operation of the applicable program area.
However, in the radiation work permit
self-assessment,
performed October 9-19, 1996, the assessment
team concluded,
"... current ALARAplanning and RWP administration processes
are not in full
compliance with prior Supply System commitments to the NRC." The assessment
team referenced examples of commitments in licensee responses
to notices of
violation and to systematic assessment
of licensee performance reports in 1989,
1991, and 1995 and identified procedures that had not been revised to implement
the commitments.
Because this issue was identified after the inspection was
completed, the inspectors did not have the opportunity review the necessary
procedures.
The inspectors learned through telephone discussions with licensing personnel, that
the licensee assigned
a radiation protection supervisor to develop an action plan to
ensure that commitments made to the NRC, concerning ALARAplanning and
radiation work permits, are implemented.
The action item was included in the plant
tracking log with a scheduled date of completion of February 13, 1997.
On
January 23, 1997, the inspectors informed licensee representatives
that the review
of the licensee's procedures to verify compliance with NRC requirements and of the
actions to ensure adherence to commitments to the NRC is an inspection followup
item (50-397/9701-02).
Selected problem evaluation requests were reviewed and no problems were
identified with the timeliness or the thoroughness
of the related corrective actions.
'
-17-
c.
Conclusions
Overall, improvement was noted in the performance of self-assessments
by the
radiation protection organization.
However, followup on the self-assessment
findings was not timely.
R7.2
Solid Radioactive Waste Pro ram
a.
Ins ection Sco
e 86750
The inspectors reviewed audits and assessments
of the solid radioactive waste
program performed by the licensee.
b.
Observations
and Findin s
Since the last inspection, there had been only one audit performed associated
with
the solid radioactive waste program.
This audit was the process control audit
performed in accordance with requirements in the Technical Specification,
scheduled every 2 years.
This audit was performed in early 1996.
The licensee did not have expertise in the quality assurance
organization related to
the processing
and transport of radioactive materials and waste.
The licensee
stated that they would evaluate methods of acquiring support in this area from
other nuclear power facilities. The inspectors confirmed that a technical expert had
been involved with the process control audit.
No surveillances or self-assessments
were performed associated with the solid
radioactive waste program and activities associated with the transport of radioactive
materials.
This meant that there was no assessment
or evaluations performed
regarding the extensive regulatory changes effective April 1, 1996, and the licensee
organizational changes.
According to information provided by the licensee, the next scheduled surveillance
was April 1997.
C.
Conclusions
The licensee was not proactive in conducting audits, surveillances, or self-
assessments
associated with the changes to the procedures related to regulatory
changes
in April 1996.
-18-
a~~
III
R8
Nliscellaneous Radiological Protection and Chemistry Issues
Closed
Violation 50-397 9610-01: Failure to Control a Hi h Hi h Radiation Area
With Flashin
Li hts
The inspectors verified the corrective actions described in the licensee's response
letter, dated August 19, 1996, were implemented.
No similar problems were
identified.
V. IVlana ement IVleetin s
X1
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee management
at an
exit meeting on January 9, 1997. The licensee acknowledged the findings presented.
During the exit meeting, Mr. Greg Smith, Plant General Manger, stated Washington Public
Power Supply System would perform the following actions:
The effluent minimization supervisor will be provided training related to the
Department of Transportation and NRC regulations associated with the transport of
radioactive materials to comply with the previous commitment to IE Bulletin 79-19
by March 31, 1997.
~
Procedure 1.12.1, "Radioactive Waste Management Program," will be revised to
reflect the current organization and assignment of responsibilities related to the solid
radioactive waste program by February 14, 1997.
The inspectors asked the licensee whether materials examined during the inspection should
be considered proprietary.
No proprietary information was identified.
ATTACHMENT1
SUPPLEMENTAL INFORMATION
la
~.
PARTIALLIST OF PERSONS CONTACTED
Licensee
J. Allen, Radwaste Technician
P. Bemis, Vice President,
Nuclear Operations
D. Bennett, Effluents Minimization Supervisor
Y. Derrer, Regulatory Affairs
L. Fernandez,
Licensing Manager
J. Hanson, Chemistry General Manager
J. Hunter, ALARASupervisor
S. Kim, Quality Assurance
A. Langston, Operations Manager
G. Smith, Plant General Manager
T. Love, Manager, Plant Support Services
C. McDonald, Training
K. Spero, Radwaste Technician
D. Swank, Manager, Regulatory Affairs
R. Winslow, Radiation Protection Manager
R. Barr, Senior Resident Inspector
86750
INSPECTION PROCEDURES USED
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
Tl 2515/133
Implementation of Revised 49 CFR Parts 100-179 and 10 CFR Part 71
83750
I
Occupational Radiation Exposure
ITEMS OPENED, CLOSED, AND DISCUSSED
~Oened
50-397/9701-01
50-397/9701-02
IFI
Review delegation of responsibilities from the effluents
minimization supervisor to ensure adherence to
commitments to the NRC
IFI
Review of the licensee's procedures to verify compliance
with NRC requirements
and of the licensee's actions to
ensure adherence
to commitments to the NRC
-2-
Closed
50-397/9610-01
Failure to Control High High Radiation Area With a Flashing
Light
DOCUMENTS REVIEWED
FSAR Chapter 11.4, "Solid Waste Management System"
FSAR Chapter 13.1, "Conduct of Operations
- Training"
Organization chart for the Radiation Protection/Chemistry Department (June 24, 1996)
Organization chart for the Plant Support Services Department (October 1996)
Supply System Business Plan FY96, FY97, FY98 - Management Initiatives Worksheet
(IDO SOT2, Revision 8 - October 15, 1995)
Trainin
Documents
Health Physics Continuing Training Two Year Schedule (1995 through 1996)
Evaluation/Observation of Training (PQD Code:
PA000010)
Evaluation/Observation of Training (PQD Code:
82-RDT-0200-0300)
HP Teletector Star Training Lesson Plan (PQD Code: .82-HCT-2700-CL)
Control Rod Drive System (Radiological) Lesson Plan (PQD Code:
HP000023-LP)
Sixth Cycle 1996 Recent Industry Events Lesson Plan (PQD Code:
HP001676-HO)
Audits and A
raisals
WNP-2 Performance Self-Assessment
(August 1996) Revision
1 (Performed June 3-28,
1996
Protected Area Portal Monitors (July 15-25, 1996)
ALARAProgram Assessment
(July 22-26, 1996)
Radiation Work Permit (RWP) Self-Assessment
(October 9-19, 1996)
Review of Radiation Protection Program Assessment Activityof 1996 (December 1996)
RWP Post Job Review Assessment
(Draft 12/96)
Quality Directorate Audit Report, Audit 295-106, "WNP-2 Radioactive Waste Process
Control Program"
-3-
Procedures
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Revision 13
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
Plant Procedure
1.1.6, "ALARACommittee," Revision 8
1.3.12, "Problem Evaluation Request," Revision 23
1.3.12A, "Processing of Problem Evaluation Requests,"
Revision 5
1.11.2, "ALARAProgram Description," Revision 9
1.12.1, "Radioactive Waste Management Program," Revision 7
11.2.23.2, "Computerized Radioactive Waste 5 Material Characterization,"
11.2.23.3, "Radioactive Material Shipping Names," Revision 9
11.2.23.4, "LSA Radioactive Materials Shipments," Revision 15
11.2.23.6, "Shipping Other Than LSA Radioactive Materials," Revision 14
11.2.23.7, "Shipping Empty Radioactive Materials Packages,"
Revision 7
11.2.23.14, "Sampling of Radioactive Waste Streams," Revision 7
11.2.23.27, "Operation of the Mixed Waste Storage Area," Revision 3
11.2.23.29, "LSA Contaminated Laundry Shipments," Revision 4
Technical Training Procedure 6.6.1, "Continuous Self-Evaluation Process,"
Revision 0
Me etin
Minutes
Senior Site ALARACommittee Meeting Minutes February 8, 1996
Senior Site ALARACommittee Meeting Minutes June 27, 1996
Senior Site ALARACommittee Meeting Minutes September 30, 1996
Senior Site ALARACommittee Meeting Minutes October 30, 1996
Problem Evaluation Re uests
296-0018
296-0051
296-0053
296-0096
296-0172
296-0238
296-0346
296-0350
296-0357
296-0545
296-6560
296-0593
296-0763
296-0764
296-0765
296-0838
296-0839
296-0867
pe