ML17289B172

Responds to NRC 930112 Enforcement Conference Re Violations Noted in Insp Rept 50-397/92-41.Disputes Violation.Rw Personnel Did Not Enter 0 Values But Entered Positively Identified Nuclides & Allowed Computer Codes to Be Used

ML17289B172
Person / Time
Site:	Columbia
Issue date:	02/11/1993
From:	SORENSEN G C WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	MARTIN J B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GO2-93-030, GO2-93-30, NUDOCS 9302240109
Download: ML17289B172 (13)

See also: IR 05000397/1992041

Text

~CCKr,Kju.r

oOCv~m arses mrs SVSrmm REGULA Y INFORMATION

DISTRIBUTIO

YSTEM (RIDS)DEACCESSION

NBR:9302240109

DOC.DATE: 93/02/ll NOTARIZED:

NO DOCKET ACIL:50-397

WPPSS.Nuclear Project, Unit 2, Washington

Public Powe 05000397 AUTH.NAME AUTHOR AFFILIATION

SORENSEN,G.C.

Washington

Public Power Supply System RECIP.NAME

RECIPIENT AFFILIATION

MARTIN,J.B., Region 5 (Post 820201)SUBJECT: Responds to NRC 930112 Enforcement

Conference

re violations

noted in insp rept 50-397/92-41.Corrective

actions:RW

personnel did not enter"0" values but entered positively

identified

nuclides a allowed computer codes to be used.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: D RECIPIENT ID CODE/NAME PD5 PD INTERNAL: ACRS AEOD/DEIB AEOD/TTC NRR MORISSEAUi

D--NRR/DOEA/OEAB

NRR/DRIL/RPEB10

NRR/PMAS/ILPB

2 NUDOCS-ABSTRACT

OGC/HDS1 RGN5 FILE 01 EXTERNAL: EG6G/BRYCEiJ.H.

NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME CLIFFORD,J

02 NRC PDR AEOD AEOD/DSP/TPAB

DEDRO NRR/DLPQ/LHFBPT

NRR/DREP/PEPB9H

NRR/PMAS/ILPB

1 NRR/PMAS/ILRB12

'R REG FILE COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 A NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACI" TIIE DOCUME!"I COY I'I'OI.U!'.ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME f'f<OM 1)IS'fR!I!

UTlt3N LISTS FOR DOCUMENTS YOU DON'T NEED!II TOTAL NUMBER OF COPIES REQUIRED: LTTR 25 ENCL 25

A WASHINGTON

PUBLIC POWER SUPPLY SYSTEM"" (~/t r P.O.Bax'968

~5OOOGeotge

Wasbtngton

Way~Rtcbland, Wasbtngton

99352-0968

~O9)97&5te!p.

3 February 11, 1993 G02-93-030

Docket No.50-397 Mr.J.B.Martin, Regional Administrator

U.S.Nuclear Regulatory

Commission

Region V 1450 Maria Lane Walnut Creek, CA 94596-5368

Dear Mr.Martin: Subject: WNP-2, OPERATING LICENSE NPF-21 NRC INSPECTION

REPORT 50-397/92-41

At the conclusion

of the January 12, 1993 Enforcement

Conference

held in the NRC regional office to discuss the subject inspection

report findings, Mr.Faulkenberry

requested that the Supply System provide specifics on areas where the Supply System felt that the report required clarification.

The attachment

to this letter provides the requested information.

In addition, the material provided to the NRC at the January 12 Enforcement

Conference

provided details on each of the apparent violations

and the Supply System's basis for concluding

that certain of the apparent violations

were not, in our view, violations

of NRC regulations

or Supply System Technical Specifications, Policies or Procedures.

9302240109

9302ii PDR ADOCK 05000397 Q PDR

0 , f 5 ij~,i,

j Page Two NRC INSPECTION

REPORT 50-397/92-41

We appreciated

the opportunity

to meet with members of your staff and provide our perspective

on the issues raised in the subject inspection

report.As stated in the enforcement

conference, the issues raised in the inspection

report are of concern to us and we are taking aggressive

actions to resolve the issues.We expect that our performance

in the forthcoming

refueling outage (R-8)and ensuing reactor startup will reflect the results of the actions we have been taking to improve procedural

compliance

in all areas, including adherence to health physics policies.Sincerely, G.C.Sorensen, Manager Regulatory

Programs (Mail Drop 280)r GCS/bk Attachments

CC: JB Martin-NRC RV NS Reynolds-Winston&Strawn JW Clifford-NRC R Copeland-Siemens DL Williams-BPA/399 NRC Site Inspector-901A

0'0 1!It

ATTACHMi22IT

The following items reflect areas where the Supply System feels clarification

to NRC Inspection

Report 50-397/92-41

is needed: 1)Page 4, first paragraph, states: "The audit identijfed

approximately

90 adverse ftndings in this area,..." Supply System comment: The report by our consultant, Mr.Deltete contained 91 recommendation, many of which were organization

and efficiency

related and were not characterized

as"adverse findings".

2)Page 4, seventh paragraph, states: "As one example, an HP technician

involved in RW activities

was not properly trained or qualtfted.

" Supply System comment: The HP technician

was properly trained and qualified to perform a survey, the task he was sent to perform.He was not trained or qualified to perform radwaste shipping, nor was he asked to perform this task.3)Page 5;item (d)(ii)states: "One of the HP supervisors

had not received training in accordance

with IEB 79-19." Supply System comment: The HP supervisor

had received training in accordance

with IEB 79-19 as a technician

prior to his promotion to supervisor.

However, retraining

was not current.4)Page 8, second paragraph of item (b)(ii)states'."RW personnel did not review MDA results, nor did anyone assess whether the LLD achieved for directly measured radionuclides

was reasonable

pursuant to the BTP." Supply System comment: We believe the LLD's achieved were consistent

with the BTP and standard industry practice.They were reviewed in establishing

our classification

program to ensure they were adequate to meet regulatory

requirements.

5)Page 9, second paragraph of item (b)(iii)states: "...RW personnel had entered"0" as the concentration....

" Supply System comment: RW personnel did not enter"0" values, they entered the positively

identified

nuclides and allowed the computer code's default value (0)to be used.

4'l', 0

'6)Page 9, item (iv)states: "...licensee's

RW personnel...had

insisted that WNP-2, as a matter of policy, did not use secondary ratios for waste classification.

" Supply System comment: RW personnel stated that second order scaling was not routinely used, as a matter of practice, (not policy).7)Page 9, item (v)last two sentences state: "...the CS-137 LLD had been approximate-

ly...these

LLDs had been unacceptably

high in relation to the BTP-referenced

values....

" Supply System comment;The values quoted are MDAs, not LLDs.We believe that the a priori LLDs do meet the BTP guidance.8)Page 10, second paragraph of item (vii)states: "These condensate

resin samples showed Ce-144 concentrations

slightly higher....

"9)Supply System comment: As reported at the enforcement

conference, the apparent Ce-144 in the Condensate

resin samples was determined

to be from a misidentified

minor peak of La-140.Therefore, there was no significant

shift in concentrations, and classification

of liner 338 would still have been incorrect had MDA values for Ce-144 been used.(Note that the information

related to the minor peak of La-140 was not available when the inspection

report was prepared.)

Page 11, item (c)(ii)states: "...Prerequisite

4.2, requires that the waste classification

will be determined

prior to using the shipping cask for RW shipments...the

licensee had been unable to comply with this prerequisite....

" Supply System comment: The Supply System has applied this prerequisite

as requiring 8 b I ifiKp'igS kf R~Whi, p'hus the prerequisite

was met for this and all other shipments.

10)Page 11, item (d)(i)states: "The chemistry laboratory

analyses of samples 5750 and 5751 had not achieved an acceptable

LLD as described in the BTP." Supply System comment: As discussed previously

in items (4)and (7)above, we believe that an acceptable

LLD was achieved as described in the BTP.Page 11, item (d)(ii)states: "The practice of entering'0'or scaling radionuclides

with no accompanying

evaluation

of MDA indicated either carelessness

or a lack of understanding

of the BTP and 10CFR61.55.

" Supply System comment: As discussed at the enforcement

conference, zero's were not"entered" by the RW personnel, but were allowed to be used as default values by the computer code.Plant RW staff have a clear understanding

of the BTP and 10CFR61.55

and are not careless in the performance

of their duties related to classification

of waste.C

, I I It~i

12)Page 12, item (iv)states: "The presence of Cs-137 and Ce-144 in unusually high concentrations...

The licensee had not analyzed the reason for the abnormal levels of Cs-137 and Ce-144 in the condensate

resin." As noted above (item 8), the Ce-144 was actually a misidentified

peak of La-140.13)Page 12, third paragraph states: "...failure

to classify the waste for shipment 92-61-02 prior to using the shipping cask for RW shipments....

" The waste for shipment 92-61-02 was classified

prior to using the cask for a RW shipment.14)Page 17, third paragraph states: "...periodicities

were not included in the procedure.

" 15)The frequency (periodicity)

for performing

a procedure is maintained

in our Scheduled Maintenance

System, not in the procedure itself, I Page 21, fifth paragraph under Timeline states: "...he became so disruptive

that the instructor

jfnally called his supervisor.

" This sentence should be revised to read"...the instructor

finally called her, (the instructor's)

supervisor." 16)Page 21, last line and page 22 first line states"An NRC inspector observed an auxiliary operator enter...." The Supply System designation

is an"equipment

operator" versus an"auxiliary

operator".

17)Page 24, item (c).states:

"...the licensee's

program for recording dose depended on...." It is our program for daily dose control, not our program for recording dose that was at issue.Our program for recording doses comes from analysis of workers'LD's, not the pencil dosimeters

which are used for recording the daily dose information

on the REC cards.

Oi I W 0

During the Enforcement

Conference, there were questions about the composition

of the Incident Review Boards (IRB)which the Supply System convenes to investigate

plant events.An IRB is convened to immediately

investigate

WNP-2 Plant events where human performance

is suspected to be a main contributor.

The IRB Chairman is a rotating duty position assigned on a weekly basis by the Plant Manager.Eligible personnel are department

managers within the Plant and Quality Assurance organizations.

The chairman then selects the appropriate

board membership.

Minimum size of the IRB is the chairman and the"Duty Event Analysis Engineer", who is trained in root cause and Human Performance

Enhancement

System (HPES)techniques.

Since the IRB chairman is determined

by a weekly rotation, it is expected that the chairman will, due to the random nature of this assignment, be independent

from the organization

involved in the event.Through questions raised in the inspection

report, a further review of the IRB process has caused us to consider the need to make the following two changes to the IRB process: 1)Develop a two-tier IRB to address the following issues: Low-level issues should be reviewed and documented

by line-management

who are trained in HPES.Significant

issues as presently described in the purpose statement of PPM 1.1.8"Incident Review Board".2)For those items which reach the category of"significant", ensure that there is organizational

independence

on the IRB.That is, ensure that at least one member (other than the Duty Event Analysis Engineer)is not from the organization

whose functional

area is being evaluated.

'