IR 05000528/1986036
| ML20212R517 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/13/1987 |
| From: | Brown G, North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20212R472 | List: |
| References | |
| 50-528-86-36, 50-529-86-36, 50-530-86-36, GL-85-08, GL-85-8, IEIN-86-020, IEIN-86-022, IEIN-86-032, IEIN-86-042, IEIN-86-043, IEIN-86-044, IEIN-86-046, IEIN-86-20, IEIN-86-22, IEIN-86-32, IEIN-86-42, IEIN-86-43, IEIN-86-44, IEIN-86-46, NUDOCS 8702020691 | |
| Download: ML20212R517 (18) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-528/86-36, 50-529/86-36 and 50-530/86-30 Docket Nos. 50-528, 50-529 and 50-530 License Nos. NPF-41, NPF-51 and CPPR-143 Licensee: Arizona Public Service Company P. O. Box 21666 Phoenix, Arizona 85836 Facility Name: Palo Verde Nuclear Generating Station - Units 1, 2 and 3 Inspection at: Palo Verde Site - Wintersburg, Arizona and ANPP Corporate Office Inspection Conducted:
December 1-12, 1986, and a telephone call on December 23, 1986 Inspected by:
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H. S'.j North, Senior Radiation Specialist Dat Signed Inspected tiy:
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G. At Brown, Emergency Preparedness Analyst Date Signed Approved'by:
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Y Chief Date Signed Faciliti adiological Protection Section Summary:
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Inspection during the period of December 1-12, 1986, and a telephone call on December 23, 1986 (Report Nos. 50-528/86-36, 50-529/86-36 and 50-530/86-30)
Areas Inspected:
Routine unannounced inspection of licensee action on
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previous inspection findings, Unit 3 LWR chemistry and plant systems affecting
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chemistry, radiation protection and chemistry organization, management i
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controls, training and qualifications, external exposure control and dosimetry
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and internal exposure control and assessment, Unit 1, 2 and 3 radiological l
environmental monitoring and Unit 1 radioactive waste management, followup on information notices and generic letters and plant tours.
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l Inspection procedures addressed included:
30703, 79501, 79502, 83522, 83523, i
83524, 83525, 80521, 80721, 84850, 92701 and 92702.
Results:
In the eleven areas examined, no violations or deviations were
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identified.
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DETAILS 1.
Persons Contacted APS/ANPP
- J. D. Driscoll - Assistant Vice President - Nuclear Production
- J. R. Bynum.- PVNGS Plant Manager
'*R. R. Baron - Compliance. Supervisor L. E. Brown - Radiation Protection and Chemistry Manager J. B. Cederquist - Chemical Services Manager T. Hillmer - Radioactive Materials Control Supervisor
- W. E. Ide - Director' Corporate QA/QC J. Mann - Corporate Health Physicist D. Nichols - General Training Supervisor G. Perkins - Radiological Services Manager D. Phillips - Manager, Operation Computer Systems
- T. D. Shriver - Compliance Manager
- J. Vorees - Manager Nuclear Safety I. Zeringue - Technical Support Manager NRC
- R. Zimmerman, Senior Resident Inspector, Palo Verde (*) Denotes attendance at the December 12, 1986, exit interview.
In addition to the individuals identified above, the inspectors met and held discussions with other members of the licensee staff.
2.
Licensee Action on Previous Inspection Findings (Closed) Enforcement (50-528/86-22-01)
Licensee action with respect to this matter has been previously addressed in Inspection Report Nos. 50-528/85-22, 86-08, 86-13, 86-22 and 86-28.
In response to the Notice of Violation the licensee committed to the establishment and implementation of four procedures.
The last procedure
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i of the four, Task Force Utilization, IN 202.08.00 was completed and
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became effective November 5,1986.
The procedure was reviewed and found to satisfy the licensee's commitments in this area.
This matter is considered closed.
(Closed) Enforcement (50-528/86-28-01)
The licensee's timely response to the Notice of Violation (Van Brunt to Martin, ANPP-38853-EEVB/TDS-96.03, October 24,1986,) reported that Unit 1 and 2 Containment Atmosphere Particulate Monitors, RU-1, declared
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inoperable on June 25, 1986, were declared operable on June 27, 1986, and I
returned to service.
The licensee demonstrated operability by comparison of monitor readings with grab sample results.
The required corrective action was the correction of certain conversion factors used by the monitors data processing system.
The conversion factor entry error resulted from the vendor's unidentified change of the programming of an L
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electrically programmable read only memory (E, PROM).
This matter is considered closed.
In part, as a result of this event, the licensee had undertaken an evaluation of the surveillance tests used to verify monitor operability, established a program to independently verify the validity of radiation monitoring system (RMS)' software changes whether vendor or ANPP originated and an evaluation of configuration control applicable to the RMS.
In addition the licensee confirmed the operability of other monitors by comparison of monitor data with grab sample results.
In connection with independent verification of software changes, the licensee had established the capability to read and program EPROM's to assure that those devices installed in monitors were as described by the vendor.
In addition this capability permits the preparation of unit and monitor specific, serialized EPROMs, for component control.
The licensee presently has the vendor's program applicable to the EPROM's and is purchasing the vendor's source code (programming to machine language conversions).
When the source code is available the licensee plans a complete validation and verification of the RMS programs including the algorithms.
At the time of the inspection the procedures to implement the program were in draft form, except for the EPROM verification procedure.
The computer group had control of all RMS EPROM's,.which were issued to I&C on an as needed basis. The program being implemented by the licensee is to be extended to all process control programs (excluding
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personal computers) used in the Units. With respect to this event the licensee's response in the areas of management involvement in assuring quality, resolution of technical issues from a safety standpoint and responsiveness to NRC initiatives was of the highest order.
Full implementation of this program was not expected before fourth quarter of 1987.
The licensee's activities with respect to this developing program will be examined during subsequent inspections (50-528/86-36-01).
(Closed) Followup (50-529/85-35-01)
Inspector identified item related to apparent differences between licensee and Arizona Radiation Regulatory Agency (ARRA) gross beta environmental monitoring results.
The licensee documented differences between the ANPP and ARRA programs (e.g. different sampling equipment, different orientation of air sampling heads, ARRA samples closer to the ground than ANPP) in a memorandum dated November 27, 1985, Subject:
USNRC Inspection of PVNGS Radiological Environmental Monitoring Report:
50-529/85-35-01 File:
85-127-419.
In addition the memorandum noted that Controls for Environmental Pollution Inc. the ANPP contractor and ARRA consistently agree on the EPA cross-check program.
The NRC Inspectors concern was discussed with ARRA by ANPP.
A March 17, 1986, ARRA memorandum, Subject:
Review of Environmental Data by ANPP and ARRA, concluded that, "A review of data, statistical uncertainty,
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detection limits, and use of gross beta activity as a screening analysis, indicated no significant difference between ANPP and ARRA results." This matter is considered closed.
(Closed) Followup (50-528/85-41-01)
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The implementation of_the Laboratory Analytical Control (LAC) was discussed. The licensee plans to complete an evaluation of the first year's implementation of the program by March-1987. -The evaluation will be designed to identify the program elements effective and necessary to
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The manpower requirements to support LAC had been approximately 25% vs the goal of 10-15%.
A member of the Chemistry Support Group was providing overall program coordination, result correlation and evaluation. The program identified a lack of consistency between the Units in analyses performed using the atomic absorption spectrophotometer, ion chromatograph and total organic carbon equipment.
The inconsistencies appeared to be. technician-related.
j The licensee responded by using work station assignments to assure that appropriately skilled technicians were assigned to specific instruments.
This matter is considered closed.
The licensee's evaluation of program implementation will be examined during a subsequent inspection (50-528/86-36-02).
(Closed) Followup (50-528/85-05-01)
Inspector-identified item related to environmental TLD measurements. ~ It had been noted that licensee environmental-TLD measurements were higher
'than NRC environmental TLD values for the same stations.
Discussion with licensee personnel established that in the 1986 participation in the Eighth DOE-EML (Environmental Monitoring Laboratory) International Intercomparison of Environmental Dosimeters, the licensee's results were not significantly different from those obtained by the EML.
The NRC environmental TLD program also participated in the Eighth' International Intercomparison.
Results obtained by the various participants are shown below:
Field Field Participant TLD Type Station #1 Station #2 Lab #3 mr mr mr Palo Verde CaSO 28.116.1 8.413.3 17.1 4.0
Palo Verde Li 0 0 28.8111.2 10.8 7.8 17.5 4.2 247 EML LiF 27.9 8.7 17.2 l_
~NRC Li B 0 29.0 1.0 10.111.5 16.3 0.5 anbhadO l
All Participants 28.9 6.2 10.114.5 16.213.4 Mean (without i
outliers)
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Pressurized Ion 29.7 10.4 17.2 Chamber
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i The calculation of systematic error for the Palo Verde results includes calibration source error, chip standard deviation, transit and control I
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TLD error, energy response error estimate and fade error estimate..This
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matter is considered closed.
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(Closed) Followup (50-528/86-08-02)
Related to' comparison of effluent monitor indications with grab sample
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data.
In accordance with procedure 75RP-9ZZ89 Radiation Monitor Alarm Setpoint Determination, attempts to make comparisons were documented in an August 29, 1986, memorandum, File 86-047-419 Radiation Monitor Calibration Verification (Unit 1).
All attempts to make comparisons during initial criticality to 100% power were unsuccessful since all grab samples were less than LLD.
Tests were reperformed on July 4 and 31, 1986. On July 31, 1986, the activity was below the range of monitor RU-143, Plant Vent low range gas monitor, however using grab sample data an alarm set point of 6.03 E-3 uCi/cc was calculated.
The monitor alarm set point was 6.662 E-4 uCi/cc at that time.
The licensee plans to re perform the comparison during a containment purge.
On the basis that the licensee had established a program to provide for comparison of effluent instrumentation data with grab samples this matter is considered closed.
(Closed) Followup (50-528/86-08-04)
Related to the inability to transfer resins from the spent resin storage tank. The licensee reported that the transfer system was modified (e.g.
changes in screen size and flow rates).
The system now operates as designed and the spent resin tank was being used for resin decay.
This matter is considered closed.
(Closed) Followup (50-528/86-08-05 and 50-529/86-22-03)
Related to waste solidification system deficiencies which prevented the use of the systems in the solidification of class
"B" and "C" wastes and Unit 2 system operating experience.
The licensee had incorporated use of a mobile liquid volume reduction system in Unit 1 through the use of the ATI asphalt solidification system.
At Unit 1 a total of 7189 gallons of evaporator concentrates were solidified with a reduction of 1200 cubic feet of waste over the cement solidification process.
The distillate from the ATI system was charcoal filtered and returned to the plant for further cleanup.
The licensee was evaluating modification of the installed waste solidification system to the Envirostone system for use in filter solidification for disposal.
At Unit 2 only dry active waste had been generated.
The liquid waste solidification system had been tested.
The solidification system, was evaluated by Chem-Nuclear and a PCP was developed which was acceptable for classes "A", "B" and "C" waste, however the required modifications for additives had not been made. The PCP had been approved and was to be implemented by December 31, 1986.
Vendor services were to be used for all liquid and resin solidifications.
Two contracts were in place, ATI for asphalt solidification of liquids and Pacific Nuclear for oil and resin solidification.
These matters are considered closed.
(Closed) Followup (50-528/86-08-06)
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Related to the licensee's efforts to' reduce the content of Sb-122, 124 in the primary coolant.
The licensee stated that an internal topical report
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will probably not be generated.
When. completed a report will.be submitted for publication in'a technical / professional journal.
The licensee was continuing the investigation.
Information received from Europe related to pH adjustments to overcome temperature' effects was
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being e, valuated.
The licensee had observed that the Unit 2, Sb 122, 124 primary coolant concentration was approximately two orders of magnitude lower than in Unit 1.
The effort to reduce the Unit-1 Sb-122, -124 concentration, was only partially successful.
The attempt was initially successful, however, a portion of the Sb removed by~demineralizers was returned to the primary system when the temperature plateau was passed.
This matter is considered closed.
(Closed) Followup (50-530/86-16-01)
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The Unit 3 radwaste compactor had been moved to a lockable, enclosed, low level waste storage area, outside of traffic pathways.
The compactors in Units 1 and 2 had also been relocated in the same fashion.
The exhaust from the Unit I and 2 compactors had been connected to the building exhaust ventilation system with flexible ducting.
Prior to operation of the Unit 3 compactor, flexible. ducting will be installed.
This matter is considered closed.
(Closed) Followup (50-529/86-22-01)
The documentation of 75PA-2ZZ01 Biological Shield Survey was examined.
The tests had been completed, documented and submitted to the Test Results Review Group (TRRG) for approval.
The test objectives were as specified in CESSAR 14.2.12.4.1 and 14.2.12.5.10.
The tests confirmed the'FSAR described zone radiation levels.
Surveys were performed on the following dates at the noted power levels:
Date Reactor Power l
January 28, 1986 Prior to initial criticality l
April 19, 1986 0%
April 22, 1986 3%
May 21, 1986 20%
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June 13, 1986 50%
l August 31, 1986 80%
September 5, 1986 100%
The test findings were that all areas met the acceptance criteria, no I
deficiencies were identified and all values were acceptable when compared l
with Unit 1.
All objectives of' test 75PA-2ZZ01 and the CESSAR were met.
The matter is considered closed.
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(Closed) Followup (50-529/86-22-02)
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The licensee had established.a program providing'for the comparison of
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effluent monitor readings with grab sample results.
The requirement was i
specified in 75RP-9ZZ89 Radiation Monitor Alarm Setpoint Determination.
The results of tests were documented in memorandums; File:
86-047-419
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Subject:
Radiation Monitor Calibration Verification (Unit 2).
Tests were performed on September 4, 6 and November 11, 1986.
The September 4 result was unsuccessful. On September 6 the activity was too low and greater than a 25% difference was observed however an alarm set point was calculated (1.603 E-3 uCi/cc).
The monitor alarm setpoint was 1.57 E-4
uCi/cc at that time.
The test was repeated on November 7, 1986, and the l
results were within 25%.
The alert alarm set point on RU-143 based on l
a gas grab sample was 2.53 E-3 uCi/cc when the monitor alarm was set at 1.57 E-4 uCi/cc.
This matter is considered closed.
(Closed) Followup (50-530/86-16-04)
Radiation Protection, Plant Chemistry, Radwaste and Environmental Organization and Management Controls Staffing During the inspection the staffing for operation of Unit 3 described in
" Forecast-20", was approved.
The approval authorized filling permanent positions as acceptable candidates were idsntified and authority to fill positions with contractor personnel until positions were filled with permanent personnel.
In addition authority was provided to add contractor personnel to support planned outage activities.
Identification and Correction of Weakness The licensee had implemented several programs in support of this topic:
APS Idea Line provides for awards for several categories of suggestions.
An ALARA-Idea Line was planned but had not been formally initiated at the time of the inspection.
Procedure Feedback program currently being implemented by I&C.
When the system has been proved in practice the licensee plans to implement the program in the areas of radiation protection, radwaste and chemistry.
The implementation of this program would replace the use of the Engineering Evaluation Request (EER) in this area.
Non-Confidential Hot Lines - Radiation Protection Problem Reports -
usually initiated by radiation protection technicians when workers fail to adhere to radiation protection requirements or good practices.
Results in notification to the workers supervisor. An ALARA Problem Report - results from cases where unnecessary exposure was received.
Confidential - QA Hot Line provides for confidential handling of issues and concerns.
Audits and Appraisals The licensee's QA program provides for audits in this topic area at 24 month intervals.
The most recent audit in this area was completed approximately one year ago.
The QA staff incorporates independent specialists in the areas of radiation protection, chemistry and rad l
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waste, qualified to the same requirements as those employed in those activities in the operating organization.
Communication to Employees Available means to communicate policy, program and procedural changes to the staffs include:
Memos to all employees, signed by the Plant Manager or lower management level depending on the group addressed; Required Safety Meetings - can be used to convey a specific message; A monthly newsletter to employees, "The Reactor," provides a more general mode of communication; and Annual retraining - can incorporate specialized messages, for example, a licensee produced video tape was in use addressing two topics:
the fertile female and working with radiation (risk / benefit).
Documentation and Implementation The licensee's programs have been documented in policies, procedures and organizational charts.
These programs have been implemented and refined during the startup and operational phases at Units 1 and 2.
(Closed) Followup (50-528/86-28-03)
The Radiological Record and Access Control System (RRACS) computer which will provide for dosimetry records storage and processing was expected to be delivered by the time of the Unit 1, 1987, refueling outage.
The licensee was supporting the system development with two full time staff representatives at the contractors facility, one a radiological engineer and one a computer specialist.
This matter is considered closed.
No violations or deviations were identified.
3.
LWR Water Chemistry Control and Chemical Analysis Establishment of a Water Chemistry Control Program Policy No. 4P411.00.00 Rev. 2, July 29, 1986, Health Physics, Radiological Protection and Chemistry Policy, identified responsibilities, program scope and sets policy in the identified functional areas.
Policy No. 4P411.01.00, Review of Radiological Protection and Chemistry Program Performance, provided for complete program reviews by the Director of Technical Services at two year intervals.
Procedure 74PR-9ZZ01, Rev. 1, Chemistry Control Program, established managements commitment to chemistry control, responsibilities, instructions, laboratory operations and control, laboratory conduct,
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safety, training, analytical control, control program verification, sampling, specifications and documentation.
Procedure 74AC-9ZZ01, Rev. 2, Laboratory Analytical Control, provided a systematic approach to assure valid analytical results.
Procedure 74AC-9ZZ02, Rev. 3, Laboratory Operations, specified guidelines
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by which the goals of the Chemistry Control Program may be achieved.
Procedure 74AC 9ZZ03, Rev. 1, Chemistry Control Instrumentation, provided for chronological documentation of and the mechanism for affecting changes to chemical systems.
Proceduce 74AC-9ZZ04, Rev. 2, Systems Chemistry Specifications, provided system operation, makeup, standby and lay up parameters for systems requiring chemistry control.
The procedure addressed RCS, RCS refueling / refueling pool, RCS post core hot functional test, precore hot functional test, steam generator blowdown, lay up, feedwater, condensate, demineralizer influent and effluent, aux steam boiler, flush water criteria, water quality, closed cooling systems, essential spray pond and storage tanks and miscellaneous systems.
Procedure 74CH-9XC10, Rev. 1, Analytical Control Samples, provided analytical control sampling schedules and frequencies used to verify instrument calibration and precision and accuracy of laboratory analytical results.
The procedures addressed the use of check standards, spike and duplicate samples.
Procedure 74CH-9XC11, Rev. 1, Analytical Control Chart Development, described the method used for graphical representation of analytical precision.
Procedure 74CH-9XC13, Rev. 2, Analytical Instrument Calibration Verification, was applicable to laboratory instruments requiring calibration verification as specified in procedure 74CH-9ZZ01.
Procedure 74CH-9XC14, Rev. 1, Reagent Preparation, provided guidelines for preparation, maintenance of logs and records and labeling, including shelf life, of reagents.
Procedures 74AC-9ZZ04 and 74CH-9XC16, Sampling and Analytical Schedule, were developed from EPRI SG0G (Steam Generator Owners Group) guidelines.
Procedures had been revised in accordance with CE manual CENPD-28, Rev.
3, September 1982.
The procedures were developed by the Chemistry Support Group based on SG0G and CENPD-28 guidelines for a copper-free system.
The licensee views adherence to SG0G and CE guidelines the same as adherence to Technical Specification requirements.
The licensee had assigned and documented, responsibilities and authority to implement the program. With the approval and implementation of the
" Forecast-20" staffing plan, adequate staff to implement the program should be available.
The laboratories were well equipped and adequate resources to implement the program appeared to be available.
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Implementation of the Water Chemistry Control Program Based on discussions with licensee personnel and review of the laboratory analytical control program it appeared that the program was being properly implemented.
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Water Sampling Procedures 74CH-9XC15, Sampling Instructions, 740P-3SS01, Nuclear Sampling Instructions and 740P-3SC02, Secondary Sampling Instructions, provide generic and specific instructions regarding sampling.
Sample line purge times were determined based on review of piping isometric
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drawings.
Tankage recirculation times were the minimum after verification by consecutive sample analysis.
' Chemistry Measurements:
Facilities and Equipment A tour of the Unit 3 hot and cold labt-atories established that laboratory layouts were appropriate and the equipment was as described in the FSAR.
On-line instrumentation for monitoring chemical variables had been installed.
Conductivity, pH, sodium and oxygen monitors were operating reliably.
The licensee stated that the hydrazine and chloride monitors were unreliable and the silica monitor required significant manpower to maintain the equipment operable.
The licensee reported that upgrading of some systems was in progress.
Establishment and Implementation of a Quality Assurance Program for Chemical Measurements
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A chemical measurements quality assurance program had been established and implemented pursuant to procedure 74AC-9ZZ01.
The program provided for spike, duplicate and replicate samples and daily, instrument calibration verification with control charts where applicable.
A pilot program, implemented at Unit 3 only, called for analysis of yearly blind samples by all technicians for all types of analyses performed on a routine basis.
Blind samples, supplied by vendors, were provided by the Chemistry Support Group.
The unit laboratory analytical control (LAC)
coordinator was responsible for examination of results. -Criteria for result evaluation had been established.
The licensee was evaluating the manpower commitment required to continue support of a program of this scope.
Laboratory Safety A Chemistry Safety Committee meets weekly.
Eyewashers and emergency showers were tested regularly.
Fire extinguishers were maintained by the onsite fire department.
Training provides first aid /CPR training which had been completed by some technicians.
Appropriate controls on smoking, eating and drinking were being implemented in both the hot and cold laboratories.
No deviations from acceptable laboratory safety practicas were identified.
No violations or deviations were identified.
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Plant Systems Affecting Plant Water Chemistry Audits and Appraisals I
The most recent QA audit No.85-006, Plant Chemistry, was conducted'at.
L Unit 1, February 25 - March 15, 1985.
It addressed quality monitoring i
activities at Unit 3 as it related to chemistry, and included SM-86-0424, Spray Pond Sampling.
No deficiencies were identified.
It also included
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SM-86-0603, Chemistry / Housekeeping, where a number of discrepancies were identified.
These discrepancies were appropriately addressed.
Primary, secondary and auxiliary water systems and demineralizers will be examined during a subsequent inspection (86-30-03).
No violations or deviations were identified.
5.
Racnological Environmental Monitoring Pursuant to Criterion 64 of Appendix A to 10 CFR Part 50, this area was inspected to determine whether the radiological environmental monitoring program (REMP) for Unit 3 was operational and adequate and to ensure that the radiological environmental monitoring program for Units 1 and 2 was effectively implemented.
In determining the status of the implementation of the REMP by the licensee, the inspector reviewed the following documents:
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Procedure Nos. 75ST-9ZZ01, 75ST-9ZZ04, 75ST-9ZZ05, 75ST-9ZZ06 b.
" Environmental Surveillance Program for 1985" c.
Radiological air, milk, water and food sample data sheets d.
Panasonic TLD reader daily response check and operation logs 2.
" Third Quarter 1986 Panasonic Environmental TLD Report" The results of this review indicated that the licensee satisfied appropriate commitments and technical specifications.
The REMP remains much the same as that described in NRC Inspection Report 50-528/85-41 with the exception of the following changes:
a.
Arizona Nuclear Power Project is taking over responsibility of the REMP from Palo Verde Nuclear Generating Station.
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Responsibility for collection and processing of the licensee's environmental samples has been added to the Arizona State University's contract.
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One residence sampling location was changed.
The inspector observed collection of environmental air samples at stations 29, 40 and 44 and examined nearby TLD 1ccations.
The samples were collected in accordance with the licensee's procedure.
The stations observed were operational and well maintained.
A review of the
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licensee's records indicated that samples were collected at the proper frequencies and processed in a timely manner.
In determining the frequencies in which required reports had been submitted since this program was last inspected, the inspector reviewed the following reports in addition to those previously mentioned:
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" Operational Environmental Report for 1985" b.
" Arizona Nuclear Power Project Palo Verde Nuclear Generating Station Pre-Operational Radiological Environmental Monitoring Program Summary Report 1979-1985".
The inspector found that required reports had been submitted on schedule and observed no omissions, anomalous measurements, biases or trends in the data.
Responsibility for maintaining the meteorological monitoring program was contracted to the N.U.S. Corporation and documents pertaining to that portion of the REMP were maintained at that facility.
The meteorological monitoring program received a comprehensive inspection during the pre-operational inspection for Unit 1 and has had no significant changes since then, however, the inspector observed the Emergency Response Facility Data Acquisition and Display System (ERFDADS) terminal in Unit 3 to verify that all required meteorological information was available for the new unit. Additionally, the inspector observed equipment at the meteorological tower.
All the equipment appeared to be in operating order and well maintained.
To examine the adequacy of quality' assurance for both the radiological and meteorological monitoring programs, the inspector reviewed the following audit reports:
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Quality Assurance Audit Report No.86-031, " Environmental Monitoring Program", conducted during October 6-24, 1986 I
b.
Quality Assurance Audit Summary Report No.85-032,
" Environmental Monitoring Program", conducted during October 7-11, 1986 i
l Results indicated that the scope of the audits thoroughly covered the licensee's environmental monitoring program and the findings were promptly addressed by the affected management.
Corrective action reports were issued and responded to in a timely fashion.
Management was informed of audit findings.
No violations or deviations were identified.
6.
Radiation Protection, Plant Chemistry, Radwaste, Transportation and Environmental:
Training and Qualification Training and Qualification Program l
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Procedure 75RP-0ZZ01 Radiation Protection Program specifies that training in radiation protection practices, regulations and requirements is.
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required for unescorted access to radiologically controlled areas.
The onsite training group provides the required training.
In preparation for INP0 accreditation the training program had been redesigned based on job task analysis results.
Lesson requirements were identified through joint planning efforts by the training department and involved departmental staffs. Training specialists developed lesson plans which were subject to review by the involved department prior to approval.
At the time of the inspection the status of course preparation and presentation was:
Subject lessons Lessons Lessons Area Planned Developed Taught Chemistry
8 25-30%
Radiation Protection
6 20-30%
Radwaste
6 20%
The licensee had submitted all required SER's (site evaluation reports)
and had received notice.of acceptance-from INP0.
The first accreditation visit was' expected March 9, 1987.
In support of the lesson plan development and training requirements, the training staff in the chemistry, radiation protection and radwaste areas consisted of 14 permanent and four contractor positions.
In the General Employee and professional level training areas the staff was eight permanent and three contract instructors.
The general employee training consisted of Site Access Training which addressed the site description, QA, industrial safety, security, emergency plan and radiation protection.
This training meets the requirements of 10 CFR 19.12, Instructions to Workers, Reg. Guide 8.13 and addresses risks to radiation workers.
Radiation workers were required to complete the Radiological Work Practices training which addressed nuclear fundamentals, external dose limits, radiation detection devices, radiologically controlled areas, contamination control, radiation exposure permits, radioactive waste and ALARA.
Workers requiring the use of respirators received Basic Radiological and Industrial Respiratory Protection training which addressed MPC's, bioassay and protection factors.
Education and Experience Education, experience, training and qualification status of randomly selected individuals in the areas of chemistry, radiation protection, radwaste and training were examined. 'The records were complete and well maintained.
The licensee formally documents ANSI-3.1 qualification with reference to the pertinent section of the standard.
Adequacy
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Based on discussions with licensee personnel, review of the licensee's training program and selected records of training and qualification, it appeared that the licensee had achieved and could be expected to maintain an adequate level and quality of= training for employees, contractors and
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No violations or. deviations were-identified.
7.
External Occupational Exposure Control and Personnel Dosimetry Physical Controls
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Based on Unit 1 and 2 bioshield survey resu'lts during the-power ascension program and the use of temporary shielding during Unit 1 and 2 outage
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maintenance activities, adequate physical controls exist at Unit 3.
Administrative Controls The licensee had demonstrated tlie adequacy of' administrative controls in the. operation of Units 1 and 2 in the areas'of radiation work permit program, control of access to high radiation areas', controlling exposure and the adequacy of external exposure control procedures.
Personal Dosimetry
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The licensee implements.an onsite.TLD personal and environmental monitoring program.
The program;is NVLAP certified in all categories.
With respect to the environmental'TLD program see report section 2,
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(Closed) Followup (50-528/85-CS-01).
Program implementation.was documented in procedures:
75AC-9ZZ01 Radiation Exposure' and Ac' cess Control 75RP-9ZZ01, Rev. 1, TLD Issue, Exchange and Termination'.
75RP-9ZZ11, Rev. 1, Special Dosimetry
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75RP-9ZZ12, Rev. 2, Lost or Damaged Dosimetry-As a result of the previously documented (Inspection Report No.
50-528/86-28 and 50-529/86-27)~ failure of-the REM (Radiation Exposure Management) system computer the' licensee had been required to maintain records of exposure manually.
As' a result of the administrative burden imposed by the need for manual record keeping.the licensee' exchanges personal TLD's at quarterly intervals.
Exposures between TLD exchanges were tracked with pocket ionization chambers (PIC).
Examination of records for both Units 1 and 2 established that forms NRC-4 were maintained current and that timely exposure ~ data was available during outage activities.
TLD badges were attached to securit9 badges,-
controlled and issued by the plant security staff.
PIC's were issued on entry and read at the time of exiting from controlled access areas by radiation protection staff personnel.
The o'nsite TLD processing capability can respond to the need for special processing of TLDs.
The licensee maintains a contractual relationship with the Arizona State University (ASU), Tempe, Arizona.
The site supports a continuous intercomparison with ASU consisting of monthly site
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N TLD exposures with reading by ASU and quarterly ASU TLD exposures with reading by the site staff.
The licensee compares all PIC results with TLD results on a quarterly (TLD exchange frequency) basis.
Emergency preparedness aspects of the external exposure contr61 program g1
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will be examined during a subsequent inspection (50-530/86-33 01).
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No violations or deviations were identified.
8.
Internal Exposure Control and Assessment Administrative Controls
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Procedure 75PR-0ZZ02 Respiratory Protection Program establishes the guidelines, principals and authority to limit _ internal exposures.
Additional procedures address respirator training, fit test.ing, physical,
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qualification, respirator maintenance, issue and return, radiati9n exposure permits, air sampling and analysis, airborne area posting,
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bioassay and internal dose assessment.
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Engineering Controls The facility design provides for air flows from areas of low potential airborne contamination to areas of higher potential ccntamination.
Procedures have been developed and implemented at Units 1 and 2 and auxiliary ventilating equipment was available to provi~de for local
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control of airborne activity.
The licensee program provides for ALARA review and recommendations for confinement or reduction of airborne activity.
The procedure specifies that exposures to airborne contaminants are to be ALARA and that the use of respiratory protective equipment shall occur only when engineering controls and/or' operational procedures are found to be impractical.
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Respiratory Protective Equipment The inspector discussed respiratory protective equipment with Jicensee representatives, observed facilities and equipment and examine _d'
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procedures related to fitting, testing, cleaning, inspection,~repM r, V
storage, control, issuance, return of equipment, medical examinations and
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the training of users.
Currently tFe licensee purchases SCBA cylinder
filling services.
The air supplied was certified as grade "D".
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Commercially supplied compressors both high volume (% cfm) - low'
pressure and low volume - high pressure (SCBA cylinder filling) were available on site.
Both systems incorporated appropriate filtering and C0 monitoring systems.
Facilities for SCBA cylinder filling were not available at the time of the inspection.
Rapid turn around of SCBA cylinders requiring filling was available.
The licensee had available approximately 1800 full face NIOSH approved filter respirators.
These respirators could be used in either the filter or airline supplied moce.
All respirators were individually contained in sealed plastic bags.
At the time of the inspection approximately 1200 respirators had been declared out of service to preclude the need for repetitive surveillance tests during a period of low respirator usage.
Air Sampling for Assessing Individual Exposure
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This aspect of the program will be examined during a subsequent inspection (50-530/86-30-02).
Bioassays The licensee's whole body counting systems (Canberra Fastscan and Accuscan) and bioassay program were previously addressed in Inspection Report Nos. 50-528, 529/86-13 and 22, 50-530/86-10 and 16, sections 4.G.
and 50-528/86-28 and 50-529/86-27 followup item 85-22-02 (closed).
Procedure 75RP-9XC24 Canberra Whole Body Counting System Calibration, provides for environmental background counts, daily system source checks, QA background checks, QA verification checks, QA duplicate counts (repeat of every 50th count), and system stability checks.
NBS traceable sources were used in calibration as well as a REMCAL phantom.
Procedure 75RP-9ZZ13 Bioassay Analysis provides for the calculation of the uptake, intake and MPC hr equivalent exposure, fraction of the quarterly limit and fraction of the investigation level and internal dose from whole body counting data.
The procedure addresses bioassay sample containers,
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l sampling and dispatch of samples for in vitro analysis at off site facilities.
In vitro analysis was not a routine procedure at the licensee's facility.
The procedure provides for evaluation of the source of the exposure with detection of greater than 5% of a maximum permissible organ burden (ANSI-343, ANSI and ICRP-2).
No violations or deviations were identified.
9.
Radioactive Waste Management - Inssection of Waste Generator Requirements of 10 CFR 20 and 10 C;R 61 Management Controls Management reviewed and approved lower tier procedures designated as
"Radwaste Directives", identify individual (s) and organizational entities assigned responsibilities in this area with clear delineation of responsibilities and authorities.
Quality Control (QC)
Radwaste Directive No. 24 Rev.0, Radwaste Shipment / Receipt QA/QC, assigns program responsibility to the Radwaste Support Supervisor with actual QA/QC functions to be performed by the Radwaste Support Lead for this area.
The assigned individual reports administratively to the Radwaste Support Supervisor but has direct access to the Managers of Radioactive Materials Control and Radiation Protection and Chemistry and the Plant Manager, if necessary to resolve problems associated with waste shipments.
The radwaste QA/QC function was a full time activity.
Audits by the licensees QA staff were performed at approximately two year intervals.
The last audit 86-014 Process Control Program (Radwaste Management) was conducted April 7-24, 1986.
An inspection addressing this topic was documented in Inspection Report No. 50-528, 529/86-13 and 50-530/86-10.
Waste Manifects
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Manifests for shipments 86-RW-006 and 86-RW-007'were examined. Th'e licensee used the manifest form supplied by U.S. Ecology.
The manifests contained the information required by 10 CFR 20.311 (b) and (c).
Waste Classification and Waste Form and Characterization
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.Radwaste Directives 012, Rev. 1, Waste Stream Scaling Factors and 013,
Rev. 1, Classification of Radioactive Waste were examined as was the supporting documentation for shipments 86-RW-006 and 86-RW-007.
The documentation provided' reasonable assurance that the waste was properly classified and characterized in accordance with 10 CFR 61.55 and 56.
Waste Shipping Labeling The previously identified shipment packages and Radwaste Directive No.
016, Rev. 1, Packaging, Marking and Labeling-of Radioactive Material were examined and found to provide information indicating that appropriate labeling as required by:10 CFR 61.57 had been affixed'to the packages.
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Tracking of Waste Shipment Radwaste Directive No. 017, Rev. O, Ship)ing of Radioactive Material, provides for inclusion of an enclosure () roof of Delivery of Radioactive Material) to accompany each shipment.
In addition the procedure provides for the initiation of an investigation if acknowledgement of receipt is
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not received within 20 days.
In addition the carrier used by the licensee requires' telephone contact with the driver every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The licensee may verify the progress of'the shipment with a telephone call to the carrier at any time.
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Disposal Site License Conditions
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The licensee maintains current copin of disposal site license conditions both through contract provision requiring copies from the disposal site operator and through direct mail.from the licensing state.
No violations or deviations'were identified.
10.
Followup on IE Information Notices and Generic Letters The inspector verified receipt, review for applicability and initiation and/or completion of action with respect to IE Information Notices No.
86-20,.22, 32, 42, 43, 44 and 46.
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Action with respect to Generic Letter 85-08 Subject:
Revised NRC Form 439, " Report of Terminating Individual's Occupational Exposure", was reviewed with the licensee's staff.
The licensee implemented the use of
a computer generated from NRC 439 on approximately October 1, 1986. The-
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licensee had no plans to implement electronic data transmission (50-528/85-08-R1, closed).
11.
Facility Tours i
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The Unit 1 and 2 auxiliary buildings and radwaste facilities were toured.
' Surveys were performed with ion chamber survey meter NRC-008985 due for calibration February 25, 1987. Unit 3. tours included the hot and cold laboratories.
The. respirator fit testing and respirator testing,
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- maintenance and repair and cleaning facilities were toured.
The TLD processing a'd whole body counting facilities were examined.
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No violations or deviations were identified.
12.
Exit Interview The scope and findings of the inspection were discussed with the individuals denoted in report section one: The licensee's representatives were informed that no< violations or deviations were identified. The inspector commented that the corrective actions taken.
-and planned in response to the Notice'-of Violationiconcerning the operability of the containment atmosphere monitor, were exemplary in the.
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areas of management involvement in assuring quality, resolution of technical issues from a safety-standpoint and with respect to
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responsiveness to NRC initiatives.
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