ML17292A681

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Insp Rept 50-397/97-01 on 970106-09.No Violations Noted. Major Areas Inspected:Staffing & Structure of Radiation Protection Organization & Results of Program to Maintain Occupational Radiation Exposure ALARA
ML17292A681
Person / Time
Site: Columbia Energy Northwest icon.png
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

NPF-21

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

PDR

ADOCK 05000397

8

PDR

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

ALARAsuggestions

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

VIO

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