IR 05000528/1981019
| ML17297B152 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/07/1981 |
| From: | Book H, North H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17297B151 | List: |
| References | |
| 50-528-81-19, NUDOCS 8201120463 | |
| Download: ML17297B152 (16) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-52 Docket No. 50-52 License No.
CPPR-141 Safeguards Group Licensee:
Arizona P blic Service Com an P, 0.
B x 21666 Ph n'x r'zona 85036 Facility Name:
Inspection at:
clear neratin Station - Unit
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'ntersbur Arizona Inspection conducted:
Inspectors:
1 r/a gy H.
S. North, Radiation Specialist Da e Signed Date Signed
."=.'"Approved by:
Date Signed Approved Summary:
F. A.
enslawski, Chief Rea adi on P
tection Section by:
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B ok, hief Radiological Safety Branch Dat Signed Iz 8)
Date Signed Iris ection on October 19-23 1981 Re ort No.. 50-528/81-19 d:
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inspector of radiation protection and chemistry organization and staffing, training, procedures,.facilities, instruments and equipment, and the respiratory protection program.
The NRC TLD offsite monitoring program was discussed with Arizona State and licensee representatives and proposed TLD posting locations were identified.
The inspection involved 24 inspector hours on site and 12 inspector hours associated with the TLD program by one inspector.
Results:
No items of noncompliance were identified.
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RV Form 219 (2)
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DETAILS Persons Contacted Palo Verde Nuclear Generatin Station PVNGS
- W. Hartley, Manager, Nuclear Operations
- C. Russo, Operations, gA Manager
"T. Cotton, Manager, Engineering and Technical Services
- R. Kramer, Licensing Supervisor
- J. McDuffee, Radiation Protection Supervisor
- W. Rogers, Supervising Radiation Physicist M. Hill, Radiological Engineer B. Cederquist, Chemistry Supervisor T. Warren, Supervising Chemist
- W. Fernow, Training Manager R. Siraaons, Supervisor, General Training Arizona Public Service APS Cor orate Staff J.
Roedel, Manager, guality Assurance J. Allen, Manager, Nuclear Engineering J.
Mann, Senior Health Physicist
- L. Brown, Corporate Health Physicist and Emergency Planner
- S. Frost, Nuclear Licensing Supervisor State of Arizona/Arizona Radiation Re ulator A enc ARRA P.
Weeden, Program Manager S. Smith, Health Physicist P. Mclay, Laboratory Supervisor (*Denotes attendance at the exit interview on October 23, 1981 at PVNGS.)
Or anization E Staffin
- Radiation Protection and Chemistr The staffing and organizational structure related to health physics in the APS corporate, Nuclear Projects Management'group is as shown in Figure 13.1-4 of the FSAR, Amendment 4, May 1981.
The basic organizational structure of the radiation protection and chemistry groups in the PVNGS operating organization are substantially as shown in Figure 13. 1-6, of the FSAR, Amendment 5, August 1981.
A Radiation Protection Super visor..(RPS),
Supervising Radiation Physicist (SRP)
and eleven Radiation Protection Technicians (RPT),as described in FSAR Section 13. 1.2.2.2.2 "and Figure 13. 1-6,are
"on staff.
In addition to the staff described in t)e'FSAR, two Radiological Engi'neers (Dosimetry and Site Emergency Planqing) report to the RP l.
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The licensee is presently planning a significant increase in the professional level radiation protection personnel reporting as staff to the RPS.
Additional SRPs and RPTs will be added for additional units.
One SRP and several RPTs are to be assigned for laundry and radwaste duties.
The laundry-radwaste RPT assignment is presently being considered as a post academic training, entry level, technician on the job training (OJT) assignment.
The licensee has established an Or anization and Res onsibi lities Manual (ORM) which defines the duties, responsibilities, chain of command and delegation of duties.
The RPS is designated as the RPM as defined in Reg Guide 8.8.
The ORM addresses all positions in the Radiation Protection and Chemistry groups.
The FSAR described organization specifies that the RPS will report to the Manager, Engineering 8 Technical Services.
In response to NRC guestion 471. 1 (FSAR page 12A-1, Amendment 5, August 1981) the licensee stated that the RPS has direct access to the Manager, Nuclear Operations in matters related to radi ation protection and ALARA.
The RPS is a permanent member of the Plant Review Board (PRB).
The training and experience of the RPS, SRP and RPTs was examined.
Based on the inspector's evaluation of the RPS's training and experience the incumbent meets the qualification requirements of Reg.
Guide 1.8 as RPM.
The licensee committed to Reg.
Guide 1.8 in FSAR Sections 1.8 and 13. 1.3. 1.
The SRP and the eleven RPTs meet the qualification requirements of ANSI N18.1-1971 to which the licensee committed in FSAR Section 13. 1.3. 1 with respect to the SRP.
Plant specific training for the radiation protection staff has not been completed.
The chenmistry qyroup staff includes a Chemistry Supervisor (CS), Supervising Chemist (SC) (Unit 1) and seven Chemistry Technicians (CT).
The licensee's present staffing planning for one SC and six CTs per unit is greater than that specified on Figure 13. 1-6, FSAR, Amendment 5, August 1981.
The chemistry staff meets the qualification requirements of ANSI N18. 1-1971.
The chemistry staff has not completed required plant specific training.
No items of noncompliance were identified.
~Trainin The on-site training organization consists of a Training Manager, three training supervisors and a staff of instructors and specialists.
At the time of the inspection the training organization included
individuals.
The three supervisors are responsible for licensed operator training, general employee traiping and training support.
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When the Training Manager arrived on-site in February 1981 the training staff totaled nine individuals.
At'that time specific technical training was considered to be a departmental responsibility (e.g.
RPTs to be trained by radiation protection group).
In May 1981 the training philosophy was changed and the responsibility for specific technical training as well as general employee training was assigned to the training organization.
The general employee training staff presently includes four instructors with one additional unfilled position.
This staff is expected to double during 1982.
Because of the change in the assignment of training responsibilities, much of the training staffs effort has been devoted to the development of programs and procedures.
Three levels of general employee tr aining (GET) are planned; approximately 4,
8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of instruction for escorted, unescorted non radiation exposure permit (REP) qualified and unescorted REP qualified workers, respectively.
The licensee is presently planning to start GET in January 1982 with two 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and one each 8 and 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> courses per month.
The present concept for, training of entry level RPT and CT personnel is based on inexperienced high school graduates.
The trainees are to be administratively assigned to the training group after selection by the functional (e.g. radiation protection)
group.
Once assigned to training the trainees may not be withdrawn from the control of the training group for work assignments without the concur rence of the training Manager.
The full course of training for entry level technicians, is to consist of approximately six, six month training'odules.
The first module is to be principally academic with increasing OJT in succeeding modules.'he OJT is to be monitored by the training group.
Each module is to incorporate performance standards and examinations.
The content of the modules is being developed by a staff Training Analyst (Ph.D., Education, Instructional Development)
based on a job task analysis performed by a contractor at and for another utility.
With respect to the ANSI qualified technici ans presently on staff, the training group is presently examining methods to evaluate individual technicians in order to permit special training in areas of identified weakness.
In the case of maintenance personnel, mechanical, electrical and I and C, all candidates for positions were tested by Memphis State personnel for ability to learn, basic knowledge and in job specific matters.
The result of this testing provided a matrix of strengths and'eakness on which supplementary training could be based.
In the case of radiation protection and chemistry technicians this type of basic information is not available.
The, method(s)
to be used for evaluation of RPTs and CTs had not been identified at the time of the inspection.
In the event that the licensee is unable to develop and implement the necessary supplementary training programs for technicians presently on the staff, within the required. time frame, contractor developed and supplied programs'r ealso, being e'valuated.
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The training group will address retraining after the initial training programs have been developed and implemented.'
No items of noncompliance were identified.
S stems Tr ainin The licensee has implemented a contractor developed Qualification Standard (Q.S.) program which is described in procedure 70 PR-92216 Personnel uglification Standard Pro ram.
For RPTs the Q.S. consists o
a Basic Nuc ear Q.S.
and a Radiation Protection Q.S.
A four member Qualification Board, chaired by the Manager, Engineering and Technical Services, examines candidates in specific areas of the Q.S.
When accepted as qualified by the Board, individual candidates may then examined and affirm qualification for that specific topic for other members of the staff.
The Q.S. specifies the level of detail required for acceptance including specific plant component parts, systems, pumps, valves, tanks, monitors, etc., which must be physically located and with which the candidate must be sufficiently familiar to describe, find or diagram.
The Basic Nuclear Q.S. is specifically directed to plant staff personnel that will routinely enter the plant but that are not qualified to an Auxiliary Operator or Professional/Technical Q.S.
The goal is to assure that such individuals will have demonstrated a general knowledge of plant systems, radi ation protection, fire protection, industrial safety, station security, QA and site emergency plan.
The goal of the Radiation Protection Q.S. is to assure that personnel who qualify to the standard have demonstrated a comprehensive knowledge of plant systems, radiological hazards, r adiation monitoring equipment, alarms and readout locations, as well as the ability to operate and maintain radiation monitoring instruments, perform surveys and conduct personnel and material decontamination.
The Basic Nuclear and Radiation Protection Q.S. include substantially the same topic areas but with varied emphasis.
The main topic areas addressed in the Q.S. include:
A.
Mechanical Systems 1.
2.
3.
4.
5.
6.
7.
8.
Main Power Cycle and Auxiliaries NSSS-Steam Gener ator Controls and Auxiliaries Turbine Generator and Auxiliaries Circulating Water and Cooling Water Auxiliary Steam System Heating, Ventilating and Air Conditioning Radwaste Fuel, Services and Drains B.
Control Systems C.
Station Operations
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Administrative Programs E.
Performance Requirements The completion of a g.S. is required for RPS, SRP and RPTs.
In each case the level of detail in the applicable g,.S. is specified by the supervisory level above the individual required'to complete the g.S.
In the case of the Radiation Protection g.S. 'the performance requirements specify the demonstration
'of individua"I, ski'llsin',variety of ',areas including instrument and equipment us'e, calibration 'andmaintenance, ability to perform calculations, ability'to perform sur veys,,collect samples, set up a control point. and decon equipment, facilities and personnel.
The RPTs on staff,had all completed the Basic Nuclear g.S.
and had started the Radiation Protection g.S. A number of the completed Basic Nuclear and portions of the Radiation Protection g.S.
were examined.
No items of noncompliance were",identifi'ed.
Radiolo ical and Chemical Procedures I
The licensee has established an alpha-numeric system of procedure identification which identifies the affected organizational unit, the type of procedure, system involved and procedure identification number.
Initially radiological and chemical procedures did not require PRB review however a recent site policy change requires PRB review of radiological and most chemical procedures.
A number of procedures which had been previously developed now require PRB review.
The licensee has prepared a list of radiation protection related procedures which includes a Radiation Protection Program and operating and administrative control procedures.
The Radiation Protection Pro ram,
PR 9ZZOl, was examined.
The document inc udes a statement of purpose, references, definitions, identification of responsibilities and a program description.
The stated purpose is to establish a philosophy and basic policy based on 10 CFR's 19, 20, 50 and 71 and appropriate Regulatory Guides, further it is APS policy to maintain exposures within NRC limits and to reduce and limit exposures to ALARA levels.
No items of noncompliance were identified.
Faci 1 i ties The laundry, radwaste, radiation protection and chemistry areas of the auxiliary building, the calibration facility and the location for the whole body counter were examined.
The facility layout with respect
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to these facilities was found to be substanti'ally as 'described in FSAR Section 12.5.2.3 and Figures l.'2-'3,1.2-5;, 1:2-,6,'and 1.2-7.
It was noted that the calibratiog'acility,. item 47 on "FSAR figure 1.2-3 had been relocated from'Uiiit"2 to"Unit 1. It was noted, that equipment and instrument insta],1'gtion was'n progress in the radwaste area while partitions and service~ facilities were incomplete in~the chemistry and radiation protection,.areas
.
No items of noncompliance were identified.
Instruments and E ui ment The various types of equipment,,supplies and instrumentation identified in FSAR Section 12.5.2.1 and 12.5.2.2 were discussed.
Some equipment and supplies have been received and are stored in the warehouse or at other locations on site.
Orders for or bid requests for equipment and instruments were being prepared.
Unti 1 such time as permanent facilities become available, progress in the equipping of facilities is severely limited.
With respect to instruments the licensee has considered using specific instrument types supplied by a single manufacturer, and the advantages afforded in simplified maintenance, repair and calibration and in minimizing the replacement parts inventory.
The licensee's plans provide for the types and quantities of equipment, supplies and instruments described in FSAR Section 12.5.2. 1 and 12.5.2.2.
No items of noncompliance were identified.
Res irator Protective Pro ram The licensee's training organization was preparing a respiratory protection tr aining program and the licensee was expecting delivery of two respirator test booths at the time of the inspection.
The licensee had received some NIOSH approve'd respiratory protective equipment including, MSA Ultra View, full face respirators equipped for filter or air line supply, ultra filters, air hose and manifolds, Bio Marine Air Pak
SCBA devices and air supplied hoods.
The licensee plans to train firefighters and water reclamation facility workers (chlorine and tank entry hazards)
in addition to members of the facility operations and support staff.
The licensee had not, at the time of the inspection, submitted the notice concerning the proposed use of respiratory protective equipment to the Region V
NRC office as required by 10 CFR 20.103(e).
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NRC Thermoluminescent Dos imeter TLD P lacement On October 19-20, 1981, the inspector met with representatives of ARRA and the APS corporate staff concerning the NRC's TLD direct radiation monitoring network planned for the PVNGS area.
ARRA and APS r epresentatives and the inspector toured the area around the PVNGS site identifying locations for TLD placement.
ARRA agreed to act for NRC in the quarterly exchange of NRC TLD's.
10.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on October 23, 1981.
The scope of the inspection and findings were summarized.
The licensee was informed that no items of noncompliance had been identifie C!
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