ML20153H028
| ML20153H028 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/14/1986 |
| From: | Sherman C, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20153G995 | List: |
| References | |
| 50-397-86-02, 50-397-86-2, NUDOCS 8602280574 | |
| Download: ML20153H028 (8) | |
See also: IR 05000397/1986002
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S.'. NUCLEAR REGULATORY COMMISSION
REGION V~
Report No.
50-397/86-02'
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' Docket No.
50-397
License No.
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Licensee:
Washington Public Power Supply System
P. 0? Cox 968
Richland, Washington 99352
. ashington Nuclear Project No. 2 (WNP-2)
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Facility Name:
W
., NP-2 Site, Benton County, Washington
Inspection at:-
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Inspect [ ion con' ducted:
, January 13-17, 1986 and in office inspection-
effort between January 21 and February 3, 1986-
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Inspectors:.
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Approved Byi
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G. P.
u as, Chief
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Ddte'!iigned
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Facili
Radiological Protection Section-
Summary:
Inspection on January 13-17,.1986 and in office inspection effort'between
January 21 and February 3, 1986 (Report 50-397/86-02)
Areas Inspected: Routine unannounced inspection of the radiological controls
area including: solid radioactive waste processing and disposal (84722,
84850), surveys (83726), facilities (83727), ALARA (83728), liquid effluents-
(84723), gaseous effluents (84724) and chemistry (79701). This inspection
involved 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> onsite by one regionally based inspector and 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of in
office inspection effort.
Results: Of the areas inspected, no violations or deviations were identified.
One allegation involving an example of failure to make every reasonable effort
to maintain radiation exposures "as low as is reasonably achievable" (ALARA)
was substantiated.(paragraph 9).
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DETAILS
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1.
Persons' Contacted !'
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- J.
Martin, Assistant Managing Director for Operations
- C. Powers, Plant Manager
- J. Baker, Assistant Plant Manager
- R. Graybeal, Health Physics / Chemistry Manager
D. Feldman, Plant Quality Assurance Manager
L. Berry, Health Physics Supervisor
L. Bradford, Assistant' Health Physics Supervisor
V. Shockley, Health Physics Support Supervisor
A. Davis, Senior Radiochemist
J. Allen, Health Physicist
D. Bennett, Radiochemist
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G. Oldfield, Senior Health Physicist
- D. Kidder, Chemistry Support Supervisor
V. Coleman, Chemical Process Engineer
D. Larson, Manager, Radiological Programs
- G.
Bouchey, Director, Support Services
- Denotes those individuals participating in the exit interview on
January 17, 1986.
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2.
Follow-up on Inspector Identified Items
NRC Inspection Report 85-29 identified a weakness in the transportation
program for shipment of Type B quantities of RAM. By letter dated
September 18, 1985, G. Sorensen (SS) to J. Martin (NRC), the licensee
committed to review their program and make appropriate changes by
November 1, 1985. The inspector verified that program changes were
included in Plant Procedure Manual (PPM) 1-12.2, " Radioactive Waste
Process Control Programs" revision 1 dated October 4, 1985. This matter
is considered closed (85-29-02).
NRC Inspection Report 85-29 identified deficiencies in the area of the
radioactive waste management program.
In the above referenced letter,
the licensee also committed to review its radioactive waste management
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program and process control program and to make appropriate procedural
changes by November 1, 1985. The inspector exar. ined PPM 1.12.1,
" Radioactive Waste Management Program", revision 1, dated October 4,
1985, and the above referenced procedure to verify completion of the
commitment. This matter is closed (85-29-02).
NRC Inspection Report 84-22 identified a poor practice with respect to
granting of verbal exceptions to. radiation work permits (RWP).
In
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discussion with the health physics supervisor, the inspector verified
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that a RWP procedure to be issued shortly will resolve this matter.
(Closed, 84-22-01)
NRC Inspection Report 85-37 identified an ALARA concern in that certain
valves in the drywell were difficult to locate.
The inspector determined
by discussion with the operations manager that either the valves in
question or the azimuthal locations within the drywell will be better
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marked and that this will be accomplished during the~ forthcoming
refueling outage.
(closed, 85-37-01)
NRC Inspection Report 85-03 identified a concern that the licensee's
ALARA program was not being accomplished with an acceptable' degree of
formality. Concerns identified in 85-03 have been resolved.
(Closed,
85-03-03).
3.
LWR Water Chemistry Control and Chemical Analysis-(79701)
The inspector examined the licensee's programs to control primary plant
process water so that integrity of.the reactor coolant pressure-boundary
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is ensured, the chemistry quality analysis program was also examined.
The following. program changes have occurred.
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A reorganization placing a Chemistry Support Supervisor under the-
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Chemistry / Health Physics Manager effective November 15, 1985.
This organizapion. included eight individuals with responsibility for
various~ aspects of the water; chemistry program.
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Revision of PPM's- 1.1.2,'1'.1.3, 1.13.1
to reflect changes in
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organization'and' responsibility,for plant chemistry is in progress.
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.Re' vision of Nuclear, Operation Standard (NOS) 36 should include
incorporationyfthe:BWRownersjroupwaterchemistryguidelines.-
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The inspector' discussed primary plant chemistry performance with'the
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licensee' representatives and examined the health physics'and chemistry
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report'for Novembe'r 1985. This reports identified important parameters.
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Of note was the-low"value for primary coolant (I-131 dose equivalent)
activity which ranged from a monthly maximum in February 1985 of 1.2E-4
microcuries per gram ofireactor coolant to 1.27E-5 uCi/gm in May 1985.
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The Technical Specification limit'is 2E-1 uCi per gram. This measure is
an indicator of fuel integrity.
The licensee has continued to improve the condenser air in-leakage
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problem which has been of concern since the plant began operation. The
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plant plans to make modifications during the forthcoming outage to reduce
in-leakage to within the design value for the system.
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NRC Inspection Report 85-25 identified the need to institute more
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internal quality. control and/or blind split samples in the measurement
program. NRC Inspection Report 85-11 identified severa1' concerns
regarding implementation of the laboratory analytical control (LAC)
program. The licensee'has modified their program to include a more
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extensive outside cross checks with their contractor laboratory.
Additionally, one of'the chemistry support engineers has been assigned
responsibility.for overseeing the LAC and chemistry quality assurance
programs.
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The inspector discussed with the licensea the importance of internal
quality control in the form of blind, replicate and spike samples as an
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adjunct to the external cross check program. The licensee
representatives agreed to consider the matter.
The licensee has implemented a program to control chemicals that may
affect the reactor systems. This satisfies a commitment made in response
to an NRC Notice of Violation in a letter dated July 11, 1985,
G. Sorensen (SS) to J. Martin (NRC).
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The following documents were examined in this topical area:
Memorandum dated December 27, 1985, R. Mazurkiewicz to D. Larson,
' Subject: Air In-Leakage Evaluation;
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Memorandum dated December 17, 1985, R. Moen to J. Martin, Subject:
WNP-2 Chemical Control Evaluation;
Memorandum dated January'8, 1986, D. Larson to R. Graybeal, Subject:
Health Physics and'Chemir.try Trend Report - November 1985.
The licensee's" programs and it alementation in the area of chemistry
control were considered _ accept.ble at this time based upon discussion
with licensee representatives, review of procedures and chemistry data.
In addition, based on discussion with licensee representatives, the
inspector concluded that an appropriate level of management attention was
focused on this area.
No violations or deviations were identified.
4.
Liquid Radioactive Waste (84723) and Gaseous Radioactive Waste (84724)
This area was inspected to determine if the licensee effectively controls
and quantifies radioactive effluents.
Previous examination of this area
identified a deficiency in that computer codes were not adequately
documented and validated. NRC Inspection Report 85-11 stated that
documentation and verification of computer codes; procedural changes to
implement this commitment; and provisions for verification of computer
input would be examined in a subsequent inspection. The inspector
examined the documentation and verification packages for several
chemistry calculation routines and also reviewed PPM 12.11.2, " Chemistry
Verification of Calculation Routines". The inspector also verified that
provision for review of input data was also included in procedures. This
matter is closed (85-11-09)
The inspector examined summary liquid effluent release data for 1985 in
the form of the semiannual effluent report for the first half of 1985 and
the HP and Chemistry Trend Report through November 1985. Several minor
errors were identified in the semiannual report, these were discussed
with a licensee representative who stated that the licensee was aware of
th.t errors ami plans to correct them in the forthcoming report.
The maximum individual whole body dose to an adult from combined liquid
pathways through November was 0.15 percent of the Technical Specification 3.11.1.2 limit of 3 millirem on an annual basis to the total body. The
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licensee released 310,820 gallons of liquid effluent in 1985 through
November 1985 at an average fission and activation product concentration
(through June) of 1.8E-6 microcuries per cubic centimeter of water.
The inspector examined selected liquid release dose calculations and
release authorization permits for releases performed in 1985. Based on
review of documentation this area was considered acceptable.
The inspector examined monthly gaseous effluent release dose calculations
performed by the plant chemistry staff and verified that selected
calculations were in accordance with the ODCM. The inspector examined
records of calibrations of the offgas post-treatment radiation monitor
and the reactor building elevated release radiation monitor performed in
1985. Based upon review of calibration procedure 12.13.2, the inspector
suggested that clarifying changes to the calculational and acceptance
criteria steps would improve the usefulness of this procedure. This was
discussed at the exit interview. Review of these calibrations was
otherwise acceptable.
Review of the HP and Chemistry Trend Report showed that gaseous releases
as calculated by Gamma Air Dose at 1.2 miles as required by TS 3.11.2.2
averaged over 1985 through November are about 3% of the technical
specification limit.
Based on the results of this review, the inspector concluded that
effluent releases are documented, instrumentation is calibrated and
releases of radioactive materials remain ALARA.
No violations or deviations were identified.
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Air Cleaning Systems (84724)
The inspector examined procedures, records of surveillance tests and
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discussed with cognizant personnel implementation.of Technical
Specification surveillance requirements 4.7.2.c&e for the control room
emergency filtration system. The inspector discussed with licensee
representatives and at the exit interview the need to improve test
documentation to clearly show tests were performed as described in the
appropriate standard. The inspector noted that procedures for leak
testing are oriented for performance by a contractor, while the licensee
now performs the test. Completion of surveillance test requirements were
satisfactory.
No violations or deviations were identified.
6.
Maintaining occupational Exposures ALARA (83728)
The inspector examined the licensee's program to verify efforts to
maintain exposures ALARA.
The inspector examined or verified the following program areas considered
important to maintaining exposure ALARA.
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Establishing and tracking ALARA goals and objectives
Annual collective dose goal
Tracking of high dose individuals
Reviews of work packages and procedures
Planning and preparation for outages
This area was considered satisfactory by the inspector.
No violations or deviations were identified.
7.
Control of Radioactive Material, Surveys, Monitoring (83726)
The -inspector examin'ed several audits performed in the operational
radiation protection area. The inspector examined selected survey
records and reviewed radiological occurrences and contaminations. No
significant incidents were identified in this area in 1985. Audits were
of satisfactory quality and did not' identify any significant problems.
No violatiNns or deviations were identified.
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8.
Radioactive Waste Management (84850)
As identified in paragraph 2, the licensee has revised the radioactive
waste management program. The inspector examined selected waste records
and discussed with cognizant' individuals various aspects of and changes
to.the waste management program.
No violations or dev,iations were identified.
9.
Allegation
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NRC Region V received an allegation by telephone on July 18, 1985, from a
licensee contractor employee regarding radiological working conditions.
This is the summary of an ongoing inquiry initiated in August, 1985. The
substance of the allegation was that the individual received unnecessary
radiation exposure b,ecause he was told to remain in radiation areas
within the turbine building and the reactor containment drywell to wait
for additional work. This individual additionally stated that'he was
told by a supervisor to hide in some locations to avoid looking idle.
The inspector conducted a review of worker training records, drywell
access records and radiation protection logs as well as discussion with
the alleger, his supervisor and contractor management, radiation
protection personnel, the outage work coordinator and several craf t
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personnel performing similar work at the time of the outage and other
individuals. The inspector verified that radiation protection training
was provided to the alleger and the supervisor in question.
The inspection revealed the following information. The supervisor in
question denied the substance of the allegation. The licensee
representatives including the health physics drywell work coordinator
stated that such a situation would be unlikely due to the controls placed
on drywell work. The alleger could not provide specific dates and
locations for specific detailed examination by the inspector. Review of
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entries, work and estimated radiation exposures did not reveal any
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unusual events. The jalleger and' other craft personnel did not raise a
concer'n to their management or to, licensee personnel during the work
period in question. "The alleger stated this was'out of fear of
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discrimination'regarding future employment by the supervisor in question.
Several-other individuals also mentioned this concern in regard to this
supervisor in particular. Discussion with contractor craft personnel
onsite during the period in question with two exceptions indicated no
recollection of facts that would tend to substantiate the allegation.
One individual recalled being told by his foreman to stay out of sight on
at least one occasion,=and recalled being told to wait inside either the
drywell or the controlled areas of the turbine building on at least one
occasion. Both the alleger and these other individuals mentioned above
did not believe any direction received was with the intent to cause any
persons to receive unnecessary radiation exposure.
Another individual specifically recalled one instance where he and two
other workers were directed to wait on the 471 elevation of the Turbine
Generator Building in the vicinity of coordinate B-8 for four to five
hours. This individual recalled this area was a radiation and
contamination area, that individuals were suited up in anti-contamination
clothing and that he believed doses received in the period were
negligible. The individual stated that several other similar instances
had occurred. This individual believed that' direction to wait was for
the purpose of not appearing idle and that this direction came from the
supervisor described in the allegation.
In conclusion, some information was developed that would tend to
substantiate the alleger's statement that direction was given to hide in
controlled or restricted areas. The allegers radiation dose for the
quarter in question was reported by the licensee at less than 20% of the
NRC quarterly limit.
Based on review of facts developed in this matter,
the allegation is considered substantiated. Title 10, Code of Federal
Regulation, Part 20.1 (c) states in part that, " persons engaged in
activities under licenses issued by the Nuclear Regulatory Commission
pursuant to the Atomic Energy Act of 1954 . . . should, in addition to
complying with the requirements set forth in this part, make every
reasonable effort to maintain radiation exposures, and releases of
radioactive materials in effluents to unrestricted areas, as low as is
reasonably achievable. The term 'as low as is reasonably achievable'
means as low as is reasonably acheivable taking into account the state of
technology, and the economics of improvements in relation to benefits to
the public health and safety, and other societal and socioeconomic
considerations, and in relation to the utilization of atomic energy in
the public interest.
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This section admonishes each licensee to act in accordance with the ALARA
principles. It appears, based on the results of inquiry into this
allegation that this goal was not achieved.
This matter was brought to the licensee's attention so that they could
take appropriate steps to prevent any recurrence.
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10. l Exit Interview
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An exit interview was held with the individuals denoted in paragraph I at
the conclusion.of_the inspection on' January 17, 1986. The scope and
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findings of the inspection were discussed at that time.
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