ML17292B369

Responds to NRC 980408 Ltr Re Violations Noted in Insp Rept 50-397/98-04.Corrective Actions:Revision to SWP-ASU-01 to Require Radiochemist Be Assigned to Effluent Audits

ML17292B369
Person / Time
Site:	Columbia
Issue date:	05/06/1998
From:	Mouncer A WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-397-98-04, 50-397-98-4, NUDOCS 9805140271
Download: ML17292B369 (5)

Text

9 CATEGORY 1 ULATORY INFORMATION DZSTRXBUTZO SYSTEM (RXDS)

A ACCESSION NBR:9805140271,

~ 98/05/06 NOTARIZED: NO DOCKE T FAC IL:50-397

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rojec, WPPSS Nuclear Pro'ect Unit Un'OC.DATE:

2, Washington Public Powe 05000397 AUTH NAME AUTHOR AFFILIATION MOUNC;ER,A.E. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Res p o nds to NRC 980408 50-397 /98-04.Corrective 98-04 ltr re violations no t e d in insp actions:revision to SWP-ASU-Ol rept o C require radiochemist be assigned to effluent audits.

A DISTRIBUTION CODE: ZE01D COPIES RECEIVED:LTR ENCL TITLE G l (50 Dk )-Znsp Rept/Notice of Violation Response NOTES:

I RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 PD 1 1 POSLUSNY,C 1 1 INTERNAL: ACRS 2 2 AEOD/SPD/RAB 1 1 1

AE FILE TTC CE R DRPM/PECB 1,

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NUDOCS-ABSTRACT 1 1' OE DIR 1 1 OGC/HDS3 1 RGN4 FILE 01 1 1 TERNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 D

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I NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZA ORGANI AT o , o T TOTAL NUMBER OF COPXES REQUIRED: LTTR 19 ENCL 19

>VASH I. iGTOY PUBLIC POPOVER SUPPLY SYSTEM i'.O. l3ov 968 ~ Ric%lrrrrri, I hrshiwy~torr 99352-0968 May 6, 1998 G02-98-081 Docket No. 50-397 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2 OPERATING LICENSE NPF-21 NRC INSPECTION REPORT 98-04, RESPONSE TO NOTICE OF VIOLATION

Reference:

Letter dated April 8, 1998, B Murray (NRC) to JV Parrish (SS), "NRC Inspection Report 50-397/98-04" The Supply System's response to the Notice Of Violation, pursuant to the provisions of Section 2.201, Title 10, Code of Federal Regulations, is enclosed as Attachment A.

Additionally, as requested in the cover letter to Inspection Report 9844, we confirm the regulatory commitment to review the effects on collection efficiency caused by the relocation of the main vent particulate and iodine sampler. The response is enclosed as Attachment B.

Should you have any questions or desire additional information regarding this matter, please call Mr. PJ Inserra at (509) 377-4147.

lly, A.- E. Mouncer Acting Vice President, Operations Support Mail Drop PE08 Attachments cc: EW Merschoff - NRC RIV NRC Sr. Resident Inspector - 927N KE Perkins, Jr. - NRC WCFO DL Williams - BPA/399 C Poslunsy, Jr. - NRR PD Robinson - Winston & Strawn J Lieberman - NRR 9805i4027'i 'rr80506 05000397 PDR ADQCK 8 PDR

NRC Inspection Report 98-04, Response to Notice of Violation Attachment A Page 1 of2 RESTATEMENT F VI LATI N 10 CFR Part 50, Appendix B, Criterion XVIII, requires a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program. The audits shall be performed'in accordance with the written procedure or checklists by appropriately trained personnel not having responsibility in the areas being audited.

Quality Assurance Procedure QAP-7, "Personnel Indoctrination, Training, Qualification, and Certification," Revision 6, states, "Personnel selected for quality assurance auditing assignments shall have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."

Contrary to the above, personnel reviewing the radiological effluent monitoring program as part of the 1997 Quality Assurance Audit 297-073 did not have experience or training in the special nature of the activities audited. Specifically, the auditors did not have chemistry sampling and analysis experience or training dealing with the Offsite Dose Calculation Manual requirements.

This is a Severity Level IV violation (Supplement 1) (50-397/9804-03).

R P N ET VI LATION The Supply System denies this violation because the WNP-2 licensing basis contains no specific requirement that an effluent audit team include a radiochemist.

In conducting NRC inspection 50-397/98-04, the NRC compared a 1996 audit which included the Offsite Dose Calculation Manual (ODCM) as well as the Radiological Environmental Monitoring Program (REMP) and Radiological Effluent Monitoring Program to the 1997 audit of only the REMP and Radiological Effluent Monitoring Program. After a review of procedures and audit scope of the 1997 Quality Assurance Audit 297-073, the Supply System believes the requirements in Quality Assurance Procedure QAP-7, "Personnel Indoctrination, Training, Qualification, and Certification," Revision 6 were met.

The audit was performed in accordance with the written procedures and checklists. Personnel selected to perform the effluent monitoring portion of the audit had the experience and training commensurate with the scope, complexity, and nature of the activities to be audited. Subsequent to receipt of the inspection report, an evaluation of the qualifications of the individuals assigned to the checklist questions, for effluent monitoring activities was performed. This comparison verified that appropriately trained and qualified individuals had been assigned.

The checklist questions were focused on activities such as ensuring written procedures or instructions were in place and reflected base requirements, and that problem trending was performed and corrective actions identified.

NRC Inspection Report 98-04, Response to Notice of Violation Attachment A Page2of2 The auditor evaluated performance based activities on a limited scope due to scheduling restraints that provided only a few opportunities to make these type of assessments. Those that were performed did not include activities that would require a specific knowledge of chemistry, radiochemistry or offsite dose calculations.

The Supply System conducted this audit to include both the REMP as well as the Radiological Effluent Monitoring Program but was not scoped to satisfy the 24 month ODCM audit. A qualified radiochemist was assigned to this joint team with the primary responsibility to assess activities in the REMP portion of the audit. However, this individual performed informal reviews of the overall audit plan, checklist questions, and final report including the effluent monitoring portion.

He attended all team meetings where audit activities and concerns'were discussed. These team meetings are designed to serve as an information sharing forum and allow for expertise and knowledge of individual team members to be used as a resource by the entire team.

Although it is the Supply System position that the procedure requirements were met, the quality and scope of the audit did not meet with management expectations, The basis for including radiochemistry experience on effluents audits can be traced to Regulatory Guide 4.15. WNP-2 does not currently have a licensing basis position on Regulatory Guide 4,15. However, Quality Management believes it is appropriate to include a person with experience in radiochemistry and monitoring techniques on REMP and radiological effluents monitoring program audits in the future.

To address concerns with the scope of the 1997 audit, Quality Management has directed that the audit 'be reopened to include performance based observations of selected chemistry activities associated with radiological effluents. The increased scope will include counting room quality control, process monitor calibrations, sample collection and analysis, and laboratory equipment functional checks and calibrations. The expanded audit will be completed by May 7, 1998 and will include a qualified radiochemist on the team.

The following additional actions will be taken to address management concerns:

1. Revision to SWP-ASU-01 to require a radiochemist be assigned to effluent audits. If both audits are performed at the same time, one radiochemist would be sufficient to provide technical expertise. If these audits are performed independently, a radiochemist will participate in each audit.

2. Review of WNP-2 required audits to determine ifany additional audits need supplementing with subject matter experts.

3. Establishment of a WNP-2 licensing basis position statement on Regulatory Guide 4.15.

NRC Iiispection Report 98-04, Response to Notice of Violation Attachment B Page 1 of 1 CONFIRMATIONOF REGULATORY CO R TATEMENT F RE AT RY MMITMENT It is our understanding that during the exit briefing on March 19, 1998, Mr. R. Webring, Vice President of Operations Support, stated Washington Public Power Supply System would review the effects on collection efficiency caused by the relocation of the main vent particulate and iodine samplers.

RESP NSE T RE AT RY MMlTMENT The Supply System agrees that this commitment was made.

The design change for the Reactor Building Process Radiation Monitoring System did not include a calculation for the particulate plateout that may result from additional sample line lengths. In addition, the preparation, verification and review process did not identify a need for a particulate plateout calculation and the Design Input List failed to identify the requirements of ANSI N13.1.

An initial operability assessment determined that the scope of the specific modification was small, and therefore the impact, ifany on the correction factor would not reduce the ability of the system to collect a representative sample.

RRECTIVE A 0 T BE TAKEN Planned corrective actions include:

Preparation of a sample line particulate plateout calculation for Reactor Building Process Radiation Monitoring System gaseous effluent sample line using the methodology presented in ANSI N13.1. To be completed by 8/15/98.

2. Incorporation of calculation(s) generated into PPM 12,11.1a "Radiological Effluent Calculations - Gaseous." To be completed by 8/20/98.

DATE F L IMPLEMENTATI N Allactions will be completed by 8/20/98.