IR 05000528/1991016
| ML17305B548 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/13/1991 |
| From: | Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B544 | List: |
| References | |
| 50-528-91-16, 50-529-91-16, 50-530-91-16, NUDOCS 9105300141 | |
| Download: ML17305B548 (16) | |
Text
U, S,
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/91-16, 50-529/91-16, and 50-530/91-16 License Nos.
NPF-41, NPF-51, and NPF-74 Licensee:
Arizona Nuclear Power Project (ANPP)
P.
0.
Box 52034 Phoenix, Arizona 85072-3999 Facility Name:
Palo Verde Nuclear Generating Station (PVNGS), Units 1,
8
Inspection at:
PVNGS Site at Mintersburg, Arizona Inspection conducted:
April 8-12, 1991 I
Inspection by:
Approved by:
~Summar:
A~itd:
>s, endor a )a
>on pec)a
)s u as le Reactor R
ological Protection Branch a
e sgne Rl ate gne Routine unannounced inspection of the licensee's radiation protection program (RP); including occupational exposures, contamination control practices during extended outages, and tours of licensee's facilities.
Inspection procedure 83729 was addressed.
Results:
In the areas inspected, the licensee's program appeared adequate to accomplish their satety objectives.
Improvements in the licensee's ALARA program are discussed in Section 2, an OSHA safety concern and the failure to identify and post a high radiation area are discussed in Section 3(g) and (h),
respectively.
9105300i4f 910523 PDR ADQCK 05000M8 G
PDR d
Persons Contacted DETAILS J.
Levine, Yice President, Nuclear Production P.
Hughes, Radiation Protection 8 Chemistry Manager (RP8CM)
W, Ide, Plant Manager (PM), Unit 1 R. Flood, PM, Unit 2 J.
Si lls, Radiation Protection Manager (RPM)
, Unit 1
"M. Shea, RPM, Unit 2 K. Oberdorf, Radiological Engineer
- A. Ogurek, Corporate Assessment Manager
"W. Sneed, RPM, Unit 3 T. Bradish, Compliance Manager J. Scott, Assistant Plant Manager, Unit 3 W. Barley, Acting RPM, Technical Services
- D. Mc Gee, ALARA/RP Outage Planning, Supervisor J.
Steward, Radiological Engineer
- R. Rouse, Compliance Superv)sor
- R. Fullmer, Quality Assurance 8 Monitoring (QAQ1) Manager
"T. Shirver, Assistant. Plant Manager, Unit 2
"R. Badsgard, Site Nuclear Engineering Department, Supervisor T. Gober, Lead Radiation Protection Technician, Unit 3
"R. Schuller, Assistant Plant Manager, Unit 1
"S. Guthrie, Quality Assurance (QA)/Quality Control (QC), Department Director Others D.. Coe, NRC Senior Resident Inspector J.
Sloan, NRC Resident Inspector
"K. Hall, El Paso Electric, Site Representative
- J. Draper, Southern California Edison, Site Representative
"S. Kanter, Owner Services, Site Representative
"Denotes those personnel in attendance at the exit interview held on April 12,1991.
In addition the inspector met and held discussions with other licensee and contractor personnel.
Occu ational Radiation Ex osure Durin Extended Outa es-(MC 83729)
a.
Audits and A
raisals Recent licensee audits of this program area were previously discussed in NRC Inspection Report Nos. 50-528/90-55, 50-529/90-55, and 50-530/90-55.
The inspector reviewed licensee monitoring activities that were conducted since the previous inspection.
Approximately ninety-nine (99) surveillances (monitoring) of radiation protection/ALARA related activities were performed by the licensee's. quality assurance monitoring staff between the period of
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February 25, 1991, and March 29, 1991.
In addition, an audit of Unit 3's refueling outage, NO.91-006,'as in progress at the time of this inspection.
A total of, five equality Deficiency Reports. ((DRs) were issued as a
result of the 99 surveil,lances that were conducted.
A review of the gDRs and monitoring reports disclosed that no violations of regulatory requirements had been identified.
The inspector noted that the licensee's (AM staff continues to perform an indepth review of the areas that were examined during the performance of monitoring activities.
The inspector concluded that the licensee's (AM program implementation continues to provide the licen'see with a viable tool for measuring their performance.
~Chan ee One organizational change involving the reassignment of personnel within the radiation protection organization was brought to the inspectors attention during the inspection.
The Unit 1 Radiation Protection Manager (RPM) was replaced by another individual from within the licensee's radiation protection organization.
The inspector had reviewed the. new RPM's qualifications during a previous inspection for compliance with Technical Specifications 6.3.
The outgoing RPM was assigned as a technical assistant in the radiation protection operations manager's office.
No concerns were identified.
Tr ainin and ualifications of Personnel The training and qualification of contractor radiation protection technicians (RPT) hired for Unit 1 and 3 outages was previously addressed in NRC Inspection Report 50-528/90-55 and 50-528/91-06.
The inspector toured the licensee's mockup training facility during the inspection.
The inspector noted that the licensee had acquired sufficient reactor coolant pump spare parts to construct a reactor coolant pump mockup for training of personnel who will be assigned to support the refueling outage at Unit 2 in September 1991.
There were many other training mockups in the facility; such as valves, a
charging pump block, electrical panels, steam generator, etc.
External Ex osure Control The licensee's program involvinq external radiation dosimeters and exposure contro1 was addressed
)n NRC Inspection Reports 50-528/91-06 and 50-528/91-11.
Use of external dosimeters were observed and representative radiation exposure records were also reviewed during this inspection for compliance with the regulatory requirements and licensee procedures listed below:
e
"Radiation Exposure and Access Control" 75RP-9ME21,
"TLD Issue, Exchange and Termination" 75RP-9RP05,
"Contamination Dose Evaluation" 75RP-9RP06,
"Hot Particle Control" No examples of whole body, skin or extremity exposures in excess of administrative limits were observed.
The inspector noted that some workers were not returning their self-indicating-dosimeters (SID) to the dosimetry clerk upon exiting from controlled areas as is recommended by licensee procedures.
This same observation was made by the licensee's (AM staff during the performance of monitoring activities that were conducted during March 1991.
(DR 91-032 describes in detail the (AM finding )nvolving the failure of workers exiting from radiologically controlled areas (RCA) to return their
'IDs so that proper personnel accountability is maintained and the individuals exposure is immediately documented before it is accidentally lost or is inappropriately charged to the wrong radiation exposure permit.
Discussions held with the licensee s
radiation protection staff disclosed that they were still in the process of evaluating methods for ensuring personnel return their SIDs immediately upon exiting from the RCA.
The licensee stated that they were in the process moving the location of their personnel monitors at the RCA exit so that the dosimetry clerks have a better view of. workers as they exit from the RCA.
The inspector noted that the personnel monitors at Unit 2 had already been moved.
The licensee's staff stated that the same changes may be made at Units 1 and 3 after they have thoroughly evaluated the effectiveness of the changes made at Unit 2.
The inspector noted that (AM reports. also identified several instances involving fai lure of personnel to sign in on the correct'adiation exposure permit (REP) or failure to sign in on an REP.
The licensee intends to implement a computer "bar code" system for recording personnel entries and egress from RCAs.
This system will be tried at Unit 2 first and will be initially limited to the radiation protection staff.
The licensee expects that this system will provide them with more positive controls.
If the new system proves to be successful it will be revised to include all work groups and extended to Units 1 and 3.
Internal Ex osure Control The inspector examined the licensee's internal exposure practices during the inspection.
General area and grab sampling for airborne radioactivity during the following wor k operations were examined:
, Motor Operated Valve Analysis and Test Systems (MOVATs)
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. Incore cutting
. Control Equipment Drive Mechanism (CEDM)
Licensee activities observed appeared to comply with 10 CFR Part 20. 103 requirement t y I
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Control of Radioactive Material and Contamination Surve s
and on> orsn Radiological control point access monitoring practices were observed at the 140 foot level of Unit 3's auxiliary building.
All tools and equipment removed from the radiologically controlled area (RCA) are monitored by a qualified radiation protection technician.
The licensee's contamination control program implements the recommendations provided in IE Circular 81-07, "Control of Radioactively Contaminated Material" and IE Information Notice 85-92,
"Survey of Wastes Before Disposal from Nuclear Reactor Facilities" for releasing all equipment from their RCA areas.
In addition the inspector conducted confirmatory radiation measurements in the clean areas identified in Section 3 of this report.
The licensee's monitoring program appears to be effective in preventing the inadvertent release of radioactive material to unrestricted areas.
The inspector examined selected radiation, contamination, and air particulate survey records to determine compliance with 10CFR Part 20.201 and applicable licensee requirements.
The inspector found surveys to be complete, accurate, and management reviews were timely.
Selected records of clothing and skin contamination occurrences were reviewed and it was noted that follow-up actions involvirig personnel decontamination, root cause identification, and dose assessment evaluations were appropriate and timely.
The inspector noted that personnel contamination events were well below the projected goals that had been established by the licensee.
The licensee's personnel contamination projections fot 1991 versus the actual events documented by the conclusion of this inspection are as follows:
Unit 1 Personnel contamination goal BIO Actuals as of 4/12/91
Unit 2
'HU Unit 3 IHU
The personnel contamination events are tracked daily for trending purposes.
The inspector noted that PVNGS management were also involved in tracking personnel contamination events and made the staff aware of their desire to maintain the levels in accordance with the ALARA concept.
Maintainin Occu ational Ex osure ALARA The inspector examined the -licensee's ALARA program by observation, discussions with responsible personnel, review of applicable procedures and record Pro ram/Or anization The licensee's ALARA program/organization for the 1991 Unit 1 maintenance outage and Unit 3 refueling outage is discussed in NRC Inspection Reports 50-528/90-55 and 50-528/91-11.
Plannin and Pre arations The planning and preparations for Unit 3's refueling outage is discussed in Inspection Report 50-528/91-11.
Workers Awareness and Involvement The inspector noted that ALARA awareness among workers interviewed had improved from what had been observed during previous inspections.
Licensee programs established to emphasize worker/management awareness of the ALARA program included:
General Employee Training Mock-up Tr'aining Work planning 'suggestion'oxes.
Postings depicting outage exposure goals and their status
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by groups.
The licensee's
"Business Plan".
This plan establishes ALARA goals that cover a five year span.
Outage ALARA planning and preparation meeting.
Post ALARA reviews.
ALARA Results The licensee's cumulative external occupational radiation exposures for Units 1, 2 and 3 were reviewed.
The Unit 3 goal for the refueling outage was 150 person-rem.
The actual radiation exposure expended for the outage was at 89.467 erson-rem as of April ll, 1991.
This value was well below the icensee s projections for April ll, 1991, which was set at 105 person-rem.
The accumulative radiation exposures at Units 1 and 2 were also well below the established ALARA goals of 94 person-rem for Unit 1 and 220 person-rem for Unit 2.
As of April 11,1991, Unit 1 had expended 62.6 person-rem and Unit 2 had only expended 2.58 person-rem.
It should be noted that Unit 1 had just completed a mini maintenance outage in February 1991, and Unit 2 is scheduled to start a refueling outage sometime sn September/October 1991.
The ALARA coordinator stated that the ALARA group and radiation protection group had the full support of station management for maintaining occupational exposures consistent with the ALARA concept prescribed in 10 CFR Part 20. 1(c).
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The review disclosed that there was a noted ALARA awareness on the part of workers and that the licensee's staff were closely monitoring their progress to ensure the ALARA goals and objectives were being met.
The inspector concluded that the licensee's program in this area had improved.
The licensee's programs appeared fully capable of meeting its safety objectives.
No violations or deviations were identified.
3.
Facilit Tours (83729)
Tours of the licensee's facilities were conducted during the inspection period.
Radioactive waste storage areas were included 1n the tours.
Independent radiation measurements were made using an ion chamber survey instrument, Model R0-2, serial number 837, due for calibration on May 6, 1991.
The inspector also made independent radiation measurements during a tour of clean areas such as the warehouse, maintenance building, scrap and trash bins, and the water reclamation facility using a
PRM-7 micro r/hr meter, serial number 453, due for calibration on April 19, 1991.
The following observations were made:
a.
Except for item (g) below, posting and labeling practices were consistent with 10 CFR Parts 19. 11 and 20. 203.
b.
Cleanliness in the areas that were toured was excellent.
c, All portable instruments observed were in current calibration.
d.
Work practices observed were consistent with the applicable Radiation Exposure Permits and the licensee's AlARA program.
e.
All personnel observed in the licensee's controlled areas were equipped with appropriate dosimetry devices.
f.
No radioactive material was found in the clean areas that were surveyed.
g.
On April 10, 1991, the inspector observed a maintenance worker on the 140 foot level of the Unit 3 containment building using unsafe work practices while working at a height 40 to 50 feet above floor level.
The worker was on top of the control equipment drive mechanism (CEOM) stack, dressed in a full set of loose fitting
'rotective clothing and rubber shoe covers.
The inspector saw the individual walk around the polar crane tracks several times without securing his safety harness.
The polar crane track was approximately six inches wide.
Failure to maintain his balance could have resulted in a serious injury.
The observation was brought to the immediate attention of the duty radiation protection technician and the containment building coordinator.
The containment building coordinator informed the inspector that the worker's actions were not consistent with the licensee's safety progra The containment building coordinator instructed the worker to follow licensee safety practices which required the use of a safety harness.
The licensee's staff took the following additional action:
The involved worker was counseled.
The observation was brought to attention of other workers at Units 1, 2, and 3 during a standup safety meeting conducted on each work shift on April 12, 1991.
The inspector informed the licensee that the corrective actions taken were satisfactory.
During a tour of the Unit 3 radwaste building on April 3.0, 1991, the inspector found general area radiation levels adjacent to the liquid radwaste system (LRS) concentrate pump reading in excess of 100 mrem/hr.
The posting at the entrance to the concentrate pump room was posted as a radiation area, with general area readings of less than 100 mrem/hr.
General area radiation levels as high as 250 mrem/hr had been observed by the inspector.
The inspector immediately reported his observation to a contractor radiation protectjon technician (CRPT) who happened to be walkinq by the area.
The observation was also reported to the Unit 3 Radiation Protection Manager (RPM).
The'RPT immediately posted the area as high radiation area as.
required by licensee procedure 75RP-ORP01,
"Radiological Posting."
Additional corrective action taken by the licensee is as follows:
A detailed survey of the immediate area and the LRS was conducted at Unit 3.
The radiation levels found by the licensee were consistent with the levels found by the NRC inspector.
Units.1 and 2 were requested to check their LRS for any abnormal radiation levels.
None were reported.
A night order was issued requiring that the licensee's operations group notify the'radiation protection group of any operation that is performed which may result in a change of radiological control conditions.
This requirement was subsequently included in procedure 440P-3LR06,
"Operation of the Liquid Radwaste Evaporator" on April 12, 1991.
A remote area radiation monitoring system was installed adjacent to the concentrate pump, as an interim measure, for the purpose of immediately identifying any change in area radiation levels.
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A Problem Resolution Sheet (PRS),
dated April 10 1991 was initiated.
The Radiation Protection 8 Chemistry Manager
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informed the inspector that a licensee investigation of the inspectors findings would be conducted and that. copies of the investigation would be provided to NRC Region V upon completion.
A review of personnel exposures for the period during of time that the radiation levels may have changed was conducted.
No
,abnormal personnel exposures were identified..
The Unit 3 RPM stated that a preliminary investigation indicated that the operations group reported that a "seal" had failed within the LRS on April 9, 1991, at which time the system was secured.
It was assumed that the concentrates settled out in the concentrate pump which subsequently resulted in the higher radiation levels observed by the NRC inspector on the morning of April 10, 1991.
The RPM stated that there was no prior history of high radiation levels and that the concentrate pump room was last surveyed on April 8, 1991, at which time general radiation levels ranging from approximately 2 mrem/hr to 40 mrem/hr were measured.
The RPM stated that the radiation measurements in the concentrate pump room are normally performed each week.
It should be noted that Technical Specifications 6. 12.1 and licensee procedure 75RP-ORPOl,
"Radiological Posting" require in part that:
'areas greater than 100 mrem/hr shall be conspicuously barricaded and posted as a high radiation area and the entrance thereto be controlled by requiring the issuance of a Radiation Exposure Permit."
Subsequent telephone discussions held with the Unit 3 RPM after the inspection disclosed that a radiation survey of the concentrate pump room taken after resuming operations of the LRS revealed that the general radiation levels adjacent to the concentrate pump decreased to approximately the same levels found during the performance of the weekly survey that was conducted on April 8, 1991 (e.g, approximately 40 mrem/hr).
Based on this discussion, lt could not be determined if the problem would have been identified during the performance of routine surveys of the area unless the LRS was shut down.
The above observations were brought to the licensee's attention during the exit interview.
The inspector informed the licensee that failure to post and control the Unit 3 concentrate pump room was an apparent violation (50-530/91-16-01).
The inspector commended the licensee for the immediate corrective actions taken in resolving the inspectors findings.
The licensee's programs appeared capable of meeting its safety objectives.
No violations or deviations were identified.
4.
Exit Interview (MC 83729 )
The inspectors met with the individuals denoted in Section 1 at the conclusion of the inspection on April, 1991.
The scope and findings of
the inspection were summarized.
The licensee was informed of the safety concern and apparent violation discussed in Section
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