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Insp Rept 50-397/86-02 on 860113-17 & 21 & 0203.No Violation or Deviation Noted.Major Area Inspected:Radiological Controls.Allegation Re Failure to Make Every Effort to Maintain Radiation Exposures ALARA Substantiated
	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: ML20153G992; ML20153H028;
References
	50-397-86-02, 50-397-86-2, NUDOCS 8602280574
	Download: ML20153H028 (8)
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U. S.'. NUCLEAR REGULATORY COMMISSION

REGION V~

. Report No. 50-397/86-02'

' Docket No. 50-397

License No. NPF-21

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Licensee: Washington Public Power Supply System

P. 0? Cox 968

Richland, Washington 99352

.Washington Nuclear Project No. 2 (WNP-2)

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Facility Name:

Inspection at:- .,WNP-2 Site, Benton County, Washington

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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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Approved Byi

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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 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months onsite by one regionally based inspector and 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months 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

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D. Bennett, Radiochemist

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 5

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

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

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process water so that integrity of.the reactor coolant pressure-boundary

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

organization'and' responsibility,for plant chemistry is in progress.

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.Re' vision of Nuclear, Operation Standard (NOS) 36 should include

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incorporationyfthe:BWRownersjroupwaterchemistryguidelines.- ,

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The inspector' discussed primary plant chemistry performance with'the

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

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microcuries per gram ofireactor coolant to 1.27E-5 uCi/gm in May 1985. -

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

! plant plans to make modifications during the forthcoming outage to reduce

in-leakage to within the design value for the system.

l NRC Inspection Report 85-25 identified the need to institute more :

) 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)

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program. The licensee'has modified their program to include a more

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;

- 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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5. 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

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

l 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

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period in question. "The alleger stated this was'out of fear of

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. "

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 ,

An exit interview was held with the individuals denoted in paragraph I at

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the conclusion.of_the inspection on' January 17, 1986. The scope and

findings of the inspection were discussed at that time.

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