ML17292B148
| ML17292B148 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/18/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292B145 | List: |
| References | |
| 50-397-97-19, NUDOCS 9712230287 | |
| Download: ML17292B148 (16) | |
See also: IR 05000397/1997019
Text
Docket No
License, No.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved By:
Attachment:
ENCLOSURE 2
U.S. NUCLEAR REGULATORYCOMMISSION
REGION IV
50-397
50-397/97-19
Washington Public Power Supply System
Washington Nuclear Project-2
3000 George Washington Way
Richland, Washington
November 17-21, 1997
L. T. Ricketson, P.E., Senior Radiation Specialist
Plant Support Branch
Blaine Murray, Chief, Plant Support Branch,
Division of Reactor Safety
Supplemental Information
9712230287
9'71218
ADQCK 05000397
8
P
-2-
EXECUTIVE SUMMARY
Washington Nuclear Project-2
NRC Inspection Report 50-397/97-19
The announced,'routine
inspection reviewed radiation protection activities. Areas reviewed
included: exposure controls, controls of radioactive material and contamination, surveying and
monitoring, training and qualifications, and quality assurance
in radiation protection activities.
lan
A violation involving the control of access to a high high radiation area was identified.
Other exposure controls were implemented appropriately. (Section R1.1).
A violation involving the failure to evaluate radiological hazards associated with potential
intakes of radioactive material was identified (Section R1.2).
Problems with high radiation area controls and radiological hazard evaluations were
identified; however, exposure controls were adequate,
overall (Sections R1.1 and
R1.2).
The radioactive material control program needed improved procedural guidance to
ensure accountability of items conditionally released from the radiological controlled
area.
Sealed radioactive sources were maintained and leak tested properly (Section
R1.3).
Significant improvement was made in reducing the number of personnel contamination
events (Section R1.3).
Improved guidance was needed in implementing procedures involving the evaluation of
potential internal radiological hazards, radioactive materials control, personnel
contamination events, and portable radiation instruments (Section R3).
The new radiation protection manager's qualifications met regulatory requirements
(Section R5).
An excellent audit of the radiation protection program was conducted by the quality
department.
The audit was comprehensive
and effective in identifying areas of potential
improvement (Section R7).
Corrective actions by the radiation protection organization were slow and sometimes
ineffective (Section R7).
-3-
'L
R1
Radiological Protection and Chemistry (RP&C) Controls
~
R1.1
er
a Ex o ur
onr Is
ns
in
pe 8750
The inspector interviewed radiation protection personnel and reviewed the following:
Control of high radiation areas
High radiation area key control
Radiological posting
Radiation work permits
Radiological controlled area access controls
Dosimetry use
serva ion
d
i din s 837 0
One of the requirements of Technical Specification 5.7.2.a is that each entryway to areas
with dose rates greater than
1 rem per hour be provided with a locked door, locked gate,
or guard that prevents unauthorized entry. The licensee designated areas with dose
rates greater than
1 rem per hour as high high radiation areas.
On October 6, 1997, the senior resident inspector identified a high high radiation area
that was not locked and not guarded.
The area was the radwaste liner storage room on
the 437-foot elevation of the radwaste building. Before securing the area gate with a pad
lock and chain, a radiation protection technician failed to ensure that the chain passed
through both the gate and a chain-link fence.
Therefore, even though the pad lock was
closed, the gate was not secured.
Second-person
verification that the area was properly
secured was not performed promptly. The licensee determined the area was unlocked
for approximately 70 minutes.
The radiation dose rates within the area were as high as 3 rems per hour. However,
because of the low occupancy of the area, the time required to exceed regulatory dose
limits, and the required use of electronic, alarming dosimeters by individuals entering the
radiological controlled area, the inspector concluded that the potential for individuals
exceeding regulatory dose limits was not substantial.
The failure to provide an area with
dose rates greater than
1 rem per hour with a locked door, locked gate, or guard was a
violation of Technical Specification 5.7.2.a (50-397/9717-01).
NRC Inspection Report
50-397/95-30 described similar violations, occurring May 7 and August 8, 1995. The
licensee initiated Problem Evaluation Request 297-0807 to document the problem and
track corrective actions.
Allother elements of exposure controls reviewed during this inspection were performed
appropriately.
No major changes were noted since the previous review.
c.
~on
i sions
A violation involving the failure to control access to a high high radiation area was
identified. Other exposure controls were implemented appropriately.
R1.2
In em
I Ex o
r Conr Is
a.
Ins eci
Sco
e 87
Internal exposure evaluations
b.
bserva ions a d Findi
s
While reviewing the licensee's personnel contamination event log, the inspector noted
inconsistencies
in the evaluation of individuals found to have facial contaminations.
The
presence of contamination on the face indicated that radioactive material may have been
taken internally. Generally, such individuals were provided whole-body counts as a
means of evaluating the potential for internal contamination.
However, the inspector
identified four examples (Personnel Contamination Events97-153, -154, -230, and -273)
in which the individuals were not provided whole-body counts.
The first two personnel
contamination events occurred on April30, 1997. The other two occurred on May 30
and July 2, 1997, respectively.
The following regulations are applicable to this situation:
10 CFR 20.1501(a) requires that each licensee make or cause to be made surveys that
may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and
are reasonable
to evaluate the quantities of radioactive material and the potential
radiological hazards that could be present.
10 CFR 20.1003 defines a survey as an evaluation of radiological conditions and
potential hazards incident to the production, use, transfer, release, disposal, or presence
of radioactive material or other sources of radiation.
10 CFR 20.1201 requires each licensee to control the occupational dose to individual
adults to 5 rems for the total effective dose equivalent or the 50 rems for the sum of the
deep-dose equivalent and the committed dose equivalent to any individual organ or
tissue other than the lens of the eye.
In order to comply with 10 CFR 20.1201 and to evaluate the potential radiological
hazards,
in this situation, the licensee must perform surveys, such as whole-body counts,
to evaluate the extent of internal contamination and determine the committed dose
equivalent resulting from the presence of the radioactive material.
Radiation protection
representatives
stated that there was no record of whole-body counts for the four
-5-
examples listed. The inspector identified the four examples,
in which no evaluations
were performed on individuals with potential internal contamination, as a violation of
10 CFR 1501(a) (50-397/9717-02).
After reviewing the licensee's implementing procedures applicable to this situation, the
inspector concluded that a possible cause for the violation was the use of a poorly
worded or illogicallyconstructed procedure.
This is discussed
in Section R3.
The radiation protection manager stated, during a telephone conversation on
December 5, 1997, that, since the onsite portion of the inspection, radiation protection
representatives
reviewed the personnel contamination event log and identified two
additional individuals who had not been provided whole-body counts.
Allsix individuals
were contacted and provided whole-body counts.
No significant intakes of radioactive
material were identified. However, more than 6 months had elapsed since the
identification of the earliest example.
Therefore, it might have been difficultfor the
licensee to identify the presence of radionuclides with short effective half-lifes, ifthey had
been taken internally.
c.
~Co
us'ons
A violation involving the failure to evaluate radiological hazards associated with potential
intakes of radioactive material was identified.
R1.3
Con rol f R
io
iv
a
'a
nd Con ami a i
in
a d
oni orin
s
cio
S
37 0
The inspector interviewed radiation protection personnel and reviewed the following:
Release of items from the radiological controlled area
Sealed radioactive source accountability
Sealed radioactive source leak testing
Personnel contamination events
Portable survey instrument calibration
Whole-body counter calibration
bse
a i ns and
ind'
Co
rol o
adioac ive
a e
a
During a review of problem evaluation requests, the inspector noted that the licensee
identified minor problems involving the release of radioactive materials from the
radiological controlled area in December 1996 and May 1997. The inspector observed
radiation protection technicians as they performed radiation surveys and released items
from the radiological controlled area.
No problems were identified. Items released
unconditionally were recorded in the licensee's material release log.
-6-
Also, some items with radioactive contamination were released from the radiological
controlled area.
Procedure 11.2.15.7, "Release of Material From Radiologically [sic]
Controlled Areas," Revision 12, established guidelines for the "conditional release" of
such items. The procedure required that:
Items be adequately enclosed, ifappropriate, to prevent potential spread of
contamination,
Items be labeled with the appropriate radiological information,
Health physics supervision/radiation protection manager be notified ifthe material
was to be moved from the protected area/owner controlled area.
However, Procedure 11.2.15.7 did not require documentation of conditionally released
items, even though it required documentation of unconditionally released items. The
procedure did not address acceptable rationale for removing radioactive material from
the radiological controlled area or address expectations of individuals removing
radioactive material. The inspector concluded that the guidance of Procedure 11.2.15.7
was weak because
it allowed 'radioactive material to be released from the radiological
controlled area, but did not ensure that the radioactive material was controlled after it
was released.
The inspector also concluded that the weak procedural guidance and the
resultant lack of accountability could have contributed to the radioactive material control
problems identified by the licensee through problem evaluation requests.
In practice, even though it was not required by Procedure 11.2.15.7, most of the
licensee's radiation protection technicians said they recorded the unconditional release
of items in the health physics log. However, the log entries sometimes provided minimal
information. For example, an entry made November 11, 1997, noted that an oxygen
monitor was tagged and released from the radiological controlled area.
The log entry did
not list the radiation or contamination levels associated with the item, the reason the item
was released, the destination of the item, the date the item would be returned, or the
individual(s) to whom the item was released.
Radiation p'rotection technicians were not consistent in their understanding of the
process for conditionally releasing items.
One technician stated that ifitems
contaminated with radioactive materials were released,
a note should be placed in the
licensee's material release log, rather than the health physics log, with an explanation
that the material was conditional released with the permission of a radiation protection
supervisor.
Because of the difficultyin identifying sufficient examples through reviews of the health
physics log, the inspector's review of the licensee's ability to control conditionally
released items was inconclusive.
However, the radiation protection manager stated,
during a telephone conversation on December 5, 1997, that radiation protection
representatives
followed up on thy inspector's comments by reviewing log entries for the
previous 3 months and verifying that listed items were in the licensee's control.
-7-
With respect to other radioactive materials, the inspector reviewed the licensee's
program of sealed source accountability and leak testing.
The inspector randomly
verified that selected sealed sources were stored in the locations indicated on the most
recent inventory records.
Random review of sealed source leak testing results indicated
that sources were tested within the required interval. Good records were kept. The
responsible individual was knowledgeable of program requirements.
Personnel
C n
ming ion Even s
The number of personnel contamination events declined significantly from the total in
1996.
In 1996, the licensee documented over 800 personnel contamination events.
Through the date of the inspection, the licensee had documented 273 personnel
contamination events in 1997.
Radi
ion De
c ion lns rum
n
While reviewing the portable radiation instrument calibration program, the inspector
determined through personnel interviews that a large part of the instrument inventory
may have been unaccounted for or unusable.
For example, a licensee audit of purchase
orders of extendable-probe,
radiation detection instruments indicated that there should
be approximately 40 instruments.
After conducting physical inventories, licensee
representatives
stated they.could not locate 9 instruments, and they determined another
9 or 10 were not operable and not repairable.
Information concerning other portable
radiation instruments was not available at the time of inspection, but the licensee
representatives
stated the same situation could exist for other instrumentation.
Despite
this situation, the inspector confirmed that the licensee met the commitments in the final
safety analysis report for the availability of portable radiation detection instruments.
The inspector determined that a procedure had not been established concerning
calibration of the whole body counters.
Licensee representatives
stated that the
whole-body counters were not calibrated at intervals in accordance with the
manufacturer's recommendations.
The manufacturer recommended
annual calibrations.
The radiation protection manager stated that the site would c'alibrate whole-body
counters according to the manufacturer's recommendation or develop and maintain a
technical basis for exceeding the manufacturers suggested
calibration interval.
No
regulatory issues were identified.
Conclusions
Improved guidance was necessary to ensure the control of radioactive materials
conditionally released from the radiological controlled area.
Sealed radioactive sources
were maintained and tested properly. The supply of radiation detection instruments was
adequate to meet regulatory commitments, but a large percentage of instruments were
unavailable for use.
Significant improvement was made in reducing the number of
personnel contamination events.
-
-8-
Status of RPB C Facilities and Equipment
In late 1995, the licensee contracted with a vendor to provide and process dosimetry
devices.
This change was not documented
in earlier inspection reports.
R3
RP8C Procedures and Documentation
Ins
ion S o e 83750
The inspector reviewed the procedures listed in the attachment to this report.
Observa ions and Findi
s
Pro
re 11 2 15.1
The licensee's inconsistent handling of potential radioactive material intakes is discussed
in Section R1.2.
Procedure 11.2.15.12, "Evaluation of Personnel Contamination Alarms,"
Revision 1, provided guidance applicable to this situation.
However, the procedure's
structure may have obscured important instructions.
The procedural steps were
arranged hierarchically. The instruction to perform whole-body counting was not given a
significant level of importance by the procedural hierarchy. Additionally, the instruction to
perform whole-body counting was neither assertive nor clear.
Section 7.3.5.1 of the
procedure states,
in part, "The individual should be directed when and where to report for
a whole body count." The use of the word "should" does not convey to radiation
protection technicians that the instruction is for the purpose of implementing a regulatory
requirement (10 CFR 20.1501(a)).
The radiation protection manager stated, during a telephone conversation on
December 5, 1997, that the procedural guidance would be revised to make the
instructions clear.
Proc dure 11.2.15.7
Procedure 11.2.15.7, "Release of Material From Radiologically Controlled Areas,"
Revision 12, was discussed
in Section R1.3. Because the procedure did not ensure the
accountability necessary to control conditionally release items, the inspector concluded
that the guidance provided was weak.
The inspector reviewed the method by which personnel contaminations events were
identified and documented.
During personnel interviews, the inspector asked radiation
protection technicians what constituted a documentable personnel contamination event.
Technicians uniformly defined a documentable personnel contamination event as one
involving contamination levels of more than 100 net counts per minute per frisker probe
area (or approximately 1000 disintegrations per minute/frisker probe area).
Licensee
personnel were not able to provide a procedural basis for this definition.
Procedure 11.2.13.9, "Personnel Skin and/or Clothing Contamination Survey," Revision
7, did not address this question.
In fact, Section 6.5 of the procedure states, "Document
all contamination events by completing an entry in the Skin/Clothing Contamination Log."
Since setting a lower threshold for documentation of personnel contamination events is
common practice and no regulatory requirements apply, the inspector concluded that the
technicians were knowledgeable, but the procedural guidance was weak because
it did
not ensure consistency by providing an expectation related to the documentation of
personnel contamination events.
HPI 12,23
Health Physics Instruction 12.23, "Out of Tolerance Reporting," Revision 5,
Section 12.23.5, states:
Any out of tolerance reading found during the precalibration response or electron
calibration a red asterisk (*) placed beside it.
An asterisk (*) and the words "Out of Tolerance" shall be written in red in the
remarks section on the data sheet.
A copy of the instrument calibration data sheet with all the asterisks circled in red
shall be sent to the user with the calibrated instrument.
This should alert the user
of his/her need to reevaluate past data taken with said instrument.
Health
physics willalso be able to determine more easily which instruments are
chronically "out of tolerance."
Radiation protection technicians were unsure of the specific meaning of "user" and did
not know who had the responsibility for performing the evaluation discussed
in
Section 12.23.5.C.
c.
Qgnclusions
Improved guidance was needed in procedures. involving the evaluation of potential
internal radiological hazards, radioactive materials control, personnel contamination
events, and portable radiation instruments.
R5
Staff Training and Qualification
A new radiation protection manager was appointed August 25, 1997. Through interviews
and resume reviews, the inspector determined the radiation protection manager'
qualifications met the requirements of Technical Specification 5.3.1.b.
-10-
R6
RP&C Organization and Administration
In NRC Inspection Report 50-397/96-05, it was reported that the radiation protection
organization and the chemistry organization were combined under the responsibility of
the chemistry manager.
As of August 9, 1997, the two organizations were split from one
another, each having a separate
manager.
R7
Quality Assurance in RP&C Activities
The inspector reviewed the following:
Quality Department Technical Assessment
297-028
Problem Evaluation Requests
b.
bserv
i ns and Findin s
The latest quality department audit of radiation protection activities was issued July 16,
1997.
The audit team included a technical specialist from a vendor organization.
The
contractor's resume detailed extensive experience as a radiation protection technician.
The audit was a comprehensive review of radiation protection activities. The audit
identified deficiencies related to the investigation of personnel contamination events,
contaminated area boundaries, radioactive material handling, training of contract
radiation protection technicians, radioactive material labeling, and documentation of
ALARAreviews.
Numerous recommendations for program improvement were provided
by the audit team.
The quality department concluded, "The radiation protection program
meets the requirements of 10 CFR Part 20, but prompt and effective improvements are
warranted to address long standing issues."
Problem evaluation requests were used by the quality department to document the
deficiencies identified during the audit. The inspector verified that the radiation protection
organization had responded with proposed corrective actions to these problem
evaluation requests.
The inspector reviewed the radiation protection organization's corrective action
timeliness, overall, and compared the information with similar information for the
operations and maintenance organizations.
The following information was supplied by
licensing personnel:
-11-
Organization
.Radiation Protection
Problem Evaluation
Reports Initiated in 1997
96
Problem Evaluation
Reports Open
38
Operations
Maintenance
98
96
35
31
The number of problems evaluation reports assigned to each organization was
approximately equal.
The number of problem evaluation reports that remained open was
slightly higher for the radiation protection organization.
Problem evaluation reports typically included multiple corrective actions that needed to
be dispositioned by the responsible organization.
When the total number of corrective
actions associated
with the problem evaluation reports were considered, the percentage
of open items decreased
but the disparity between the radiation protection organization
and the other two organizations increased.
Organization
Radiation protection
Operations
Maintenance
Total Corrective
Actions Related to
Problem Evaluation
Requests
227
136
151
Open
Corrective
Actions
66
17
27
Percent
Open
29
12.5
18
The inspector concluded that the radiation protection organization's implementation of
corrective action was not as timely as some site organizations.
The inspector determined that the quality department had identified concerns involving
the timeliness of corrective actions by the radiation protection organization.
Memoranda
to the radiation protection manager from the quality manager dated October
1 and
November 4, 1997, addressed
radiation protection program corrective actions.
In a memorandum to the radiation protection manager from the quality manager dated
October 1, 1997, the quality manager expressed
concern over the need for prompter
corrective actions by the radiation protection organization.
The quality manager
discussed,
"a radiation protection program in serious need of prompt and decisive
corrective actions," and noted, "... it is apparent that long standing serious deficiencies
in the radiation protection program remain unsolved...."
In a memorandum to the radiation protection manager from the quality manager dated
November 4, 1997, the quality manager stated, "...resolution of problem evaluation
-12-
requests has been unacceptably slow," and, "The radiation protection department is
routinely late in completing corrective actions."
e
In addition to timeliness, the November 4, 1997, memorandum addressed
the
effectiveness of corrective actions.
The quality manager stated, "The radiation protection
department has demonstrated
a pattern of failure to disposition problem evaluation
requests on time, failuie to adequately identify corrective actions to prevent repetition,
and failure to meet the commitments reflected in those corrective actions."
The November 4, 1997, memorandum required the radiation protection organization to
complete the dispositioning of certain problem evaluation requests by
November 10, 1997, or have program activities suspended,
in accordance with,the stop
work authority in QAP-6. The radiation protection organization complied with the quality
department instructions.
c.
~Con clus'
An excellent audit of the radiation protection activities was conducted by the quality
department.
The audit was comprehensive
and effective in identifying areas of potential
improvement.
Corrective actions by the radiation protection organization were slow and sometimes
ineffective.
RS
Miscellaneous RPBC Issues
8.1
Iosed V'on 3979 30-01'F iu etoloc
hi hhi h
'o
area
oors
The inspector verified that the corrective actions described in the licensee's response
letters dated December 12, 1995, and February 22, 1996, were implemented. 'A similar
problem is discussed
in Section R1.1.
V.
Mana
emen
Mee i
X1
Exit Meeting Summary
The inspector presented the inspection results to members of licensee management
at
an exit meeting on November 21, 1997. The licensee acknowledged the findings
presented.
No proprietary information was identified.
ATTACHMEN
SU
LEIIENTALINFORMATION
PARTIALLIST OF PERSONS CONTACTED
~LI gg~ee
D. Atkinson, Quality Manager
P. Bemis, Vice President Nuclear Operations
I. Borland, ALARA/Health Physics Support Supervisor
D. Hillyer, Radiation Protection Manager
P.'Inserra, Licensing Manager
J. Liles, Health Physics Operations Supervisor
M. Shepherd,
Health Physics Operations Supervisor
G. Smith, Plant General Manager
R. Webring, Vice President Operations Support
S. Boynton, Senior Resident Inspector
G. Johnston, Senior Project Engineer
NS
ECT 0
ROCEDU
ES USED
83750
Occupational Radiation Exposure
~Oened
50-397/9717-01
50-397/9717-02
Closed
50-397/9530-01
E
S 0
E
ED CLOSED
D DISC
SSED
Failure to control access to areas with radiation dose rates
greater than
1 rem per hour
Failure to evaluate radiological hazards related to potential
internal contaminations
Failure to control access to areas with radiation dose rates
greater than
1 rem per hour
Discussed
NONE
-2-
LIST OF DOCUMENTS REVIEWED
Quality Department Technical Assessment/WNP-2
Radiation Protection Program (Technical
Assessment
297-028, July 16, 1997)
Interoffice memorandum from quality manager to radiation protection manager,
10/01/97
Interoffice memorandum from quality manager to radiation protection manager, 11/04/97
Interoffice memorandum from plant general manager to quality manager, 11/10/97
List of problem evaluation requests,
11/96 - 11/97
1997 Personnel contamination log
Health physics log
Prrc~ed
i~re
SWP-RPP-01,
1.11.15,
11.2.14.9,
11.2.15.7,
11.2.15.12
HPI 12.23
"Radiation Protection Program;" Revision
1
"Receipt, Storage, and Control of Radioactive Material," Revision 2
"Control and Labeling of Radioactive Material," Revision 6
"Release of Material From Radiologically Controlled Areas," Revision 12
"Evaluation of Personnel Contamination Alarms," Revision
1
"Out of Tolerance Reporting," Revision 5