IR 05000528/1988022
| ML17304A332 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/20/1988 |
| From: | Cicotte G, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304A331 | List: |
| References | |
| 50-528-88-22, 50-529-88-22, 50-530-88-21, NUDOCS 8808100322 | |
| Download: ML17304A332 (28) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.:
50-528/88-22, 50-529/88-22 and 50-530/88-21 Docket Nos.:
50-528, 50-529 and 50-530 License Nos.:
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Nuclear Power Project P.
0.
Box 52034 Phoenix, Arizona 85072-2034 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at:
Palo Verde Site - Wintersburg, Arizona Approved by Inspection Conducted:
June 27 - July -1, 1988 Inspected by:
Pc
.
M. Cillis, Sr. Radiation Specialist c~R..
G.
R. Cicotte, Radiation Specialist
,i(. C,'8 G.
P.
Yuhas, Chief Facilities Radiological Protection Section Date Signed 7's d
Date Signed Date Signed
~Summer Ins ection durin the eriod of June
Jul
1988 Re ort Nos. 50-528/
88-22 50-529/88-22 50-530/88-21)
'll *
of written reports of nonroutine events; onsite followup of events at operating reactors; radiation protection, plant chemistry, radwaste and transportation:
training and qualification; control of radioactive material, contamination and surveys; solid wastes; liquids and liquid wastes; gaseous waste systems and a tour of Units 1, 2, and 3.
Inspection procedures 30703, 92700, 93702, 83723, 83726, 84722, 84723 and 84724 were addressed.
Results:
In five of the seven areas addressed, no violations or deviations were identified.
In one area, violations of 10 CFR Part 20.101(b)(l),
CFR Part 20.201 and 10 CFR Part 20.409(b)
were identified (paragraph 2), and in a second area a violation of Technical Specifications, Section 6.12.2, was identified (paragraph 8).
In addition one unresolved item related to Technical Specification, Section 6.5.3.5(b),
"Audits," was identified (paragraph 3).
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DETAILS 1.
Persons Contacted a.
Licensee Staff AD
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Karner, Executive Vice President D. Driscoll, Assistant Vice President, Nuclear Production ED Ide, Plant Manager, Unit 2 M. Butler, Director, ANPP Standards and Technical Support H. Doyle, Jr.,
Manager, Radiation Protection Unit 2 R.
Ober dorf, Manager, Radiation Protection Unit 1 E.
Sneed, Manager, Radiation Protection Unit 3 Logan, Central Radiation Protection Supervisor Souza, Auditing and Monitoring, gA/gC M. Sills, Radiation Protection Standards Supervisor F.
Fernow, Manager, Training Department guinn, Nuclear Safety and Licensing G.
Papworth, Director, guality Assurance/guality Control Selman, ALARA Supervisor L. McCandless Clark, Lead, ANPP Compliance M. Allen, Plant Manager, Unit 1 C. Schlag, Supervisor, Radiation Protection and Chemistry Standards A. Scott, Chemistry Manager, Unit 3 M. Fuller, Chemistry Manager, Unit 1 Shriver, Manager, Compliance D. Sorensen, Acting Chemistry Manager, Unit 2 D. Bolle, Acting Unit 2 Radiation Protection Manager B. Cerderquist, Supervisor, Radiation Protection and Chem Standards J. Gurescki, Lead Radiation Protection Technician H. Kluge, Operations Engineering Bethke, Shift Supervisor, Unit 2 A. Hackbert, gA Supervisor Support istry b.
Contractor Staff lied Radiolo ical Controls M.
D.
Hedgecock, Senior Radiation Protection Technician Rickett, Decontamination Technician Denotes attendance at the July 1, 1988, exit interview.
In addition, the inspectors met and held discussions with other licensee and contractor personne Unresolved Items 50-529/88-14-02 and 50-529/88-14-03:
These items are associated with an apparent exposure of a Unit 2 contract worker in excess of the 3 rem whole body limit prescribed in 10 CFR 20.101(b)(l) during the evening of May 22-23, 1988.
An immediate licensee notification of the potential overexposure was made on May 23, 1988.
Subsequently, a Licensee Event Report (LER) 88-011-00, dated June 22, 1988, describing the event was received by the Region V office on June 27, 1988, pursuant to the requirements of 10 CFR 20.405(a)(l)(i)
and
CFR Part 50.73.
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.
A.
~Back round An initial NRC onsite review of the event was conducted during the week of May 23-27, 1988.
The findings were discussed in paragraph 4(b) of Inspection Report 50-529/88-14.
The inspection report identified that an apparent overexposure, occurred during masking of certain areas in the upender cavity in preparation for painting the surfaces with strippable latex.
The inspection report provides a
detailed description of the event and the licensee's dose evaluation.
The licensee had concluded that a contractor had received a total cumulative whole body dose of 3.209 rem during the second quarter of 1988.
B.
Onsite Ins ection An onsite inspection was conducted to review and verify the
.information contained in LER 88-011-00 and to determine the status of the licensee's evaluation of the event.
The inspection included a review of the worker's occupational exposure records, applicable procedures, personnel qualification records, survey records, and discussions with licensee staff.
(1)
Event Related Information Provided in the LER The LER provided the following information:
The worker received 2a607 rem whole body dose to his right thigh/upper leg which resulted in the cumulative whole body dose of 3.209 rem for the second quarter of 1988.
The principal causes identified in the LER and SPEER report (see paragraph 2.B.2 below) were characterized as:
(1)
Personnel error by the contractor Radiation Protection Technician (RPT) who performed and utilized an inadequate survey.
(2)
Personnel error on the part of the Lead Radiation Protection Technician for insufficient understanding
and planning of the work scope and not stopping the job when it was felt to be unsafe.
(3)
Personnel error by Radiation Protection Manager for not ensuring adequate radiological controls were in place to perform the work safely.
(4)
Deficient administrative controls defining requirements and responsibilities for performing job planning and work.
Contributing causes were characterized as:
(1)
Job-planning was not adequate to keep the exposure ALARA.
(2)
Inappropriate surveys were used to plan and perform the work.
(3)
Job planning did not adequately provide the appropriate step by step sequence and the positioning of workers to perform the task.
(4)
Job allowed to proceed although Radiation Protection personnel had concerns about the job.
(5)
Insufficient teledosimetry.
(6)
Decontamination of the work area was not performed to the maximum extent practicable.
Discussions with the licensee's staff and a review of the information provided in the LER disclosed the following information:
Beginning approximately two weeks prior to the event, the radiation protection technicians (RPTs)
and licensee's lead RPT's associated with the work all expressed a
similar concern that painting the cavity with strippable latex was an unnecessary expenditure of exposure.
However, none of the RPTs raised a concern to the effect that the job was unsafe or could not be done.
A management decision to perform the application of strippable coating was made on May 20, 1988, with the concurrence of the Plant Manager, ALARA Supervisor and the Unit 2 Radiation Protection Manager (RPM).
The ALARA Supervisor stated that during an ALARA meeting on or about May 20; an in-depth survey to assess dose was determined to be necessary to properly assess the work in the pre-job review.
He further stated that the ALARA representative who conducted the pre-job review, and the Unit 2 RPM, were present at that meeting.
The Unit 2 RPM
did not recall any special emphasis being placed on that decontamination effort or post-decon survey.
The Radiation Protection Technician (RPT) and Lead RPT (LRPT)
were not present at the meeting nor was either. informed of the emphasis placed on the need for a detailed survey.
The Radiation Exposure Permit (REP) to apply the strippable latex paint was originated by the decontamination contractor's site coordinator and reviewed by the LRPT on Saturday, May 21, 1988.
The REP was then submitted for ALARA pre-job review to the on shift ALARA engineer.
An ALARA engineer discussed the review by telephone with the ALARA Supervisor.
The survey used to write the REP and conduct the pre-job review did not contain detailed dose rates in the northwest corner of the cavity.
When the LRPT and RPT returned from a scheduled day off, they were informed that the work was to progress without changing the scope of the work.
The inspectors noted that the decontamination contractors'PT assigned to cover the work had a dual role in that he was responsible for monitoring the work from both a radiation safety and from a production perspective.
The LRPT stated that survey data taken from a survey performed on May 21, 1988, was used to conduct the pre-job briefing.
The May 21 survey showed that levels in the northwest corner did not exceed 10 rem/hr.
The survey did not identify the 75 rem/hr hot spot that was identified from ear lier surveys and a post event survey.
The contractor RPT who conducted the May 21, 1988 survey and who also covered the work at the time of the event stated:
(a)
A geiger-mueller instrument with an extended probe, rather than an ion chamber instrument, was used to conduct the survey.
(b)
Scaffolding was in the area.
Because of this he was unable to perform a good survey.
He added that he had informed a day shift RPT that the scaffolding interference prevented him from taking a detailed survey.
(c)
When the scaffolding was removed on dayshift, another survey was not performed.
(d)
He was aware that another survey had not been taken after the scaffolding was removed.
He felt that he could adequately control the work performed on May 22-23 based on his previous knowledge of the dose rates in the work area.
He added that he did not see the need for receiving any additional exposure in taking another survey and that he had been
'pecifically instructed to minimize his dose.
He added that he wanted to avoid any further delays because of management's emphasis to get the job done without further delay or change.
The RPT assigned to cover the work stated that, prior to staring the work on Nay 22-23, 1988, he informed the LRPT that it would be very difficult to accurately monitor the job properly due to fluctuating dose rates, the number of people involved and from hot particles in the area.
The the LRPT informed the RPT that she was told to do the job and not change any of the instructions.
No action was taken by the LRPT to stop the job.
The LRPT thought it would be useless to address the issue further based on previous discussions with management.
Item 12 on the ALARA pre-job review check list used for the pre-job briefing required the use of special dosimetry.
The check list did not identify the type of dosimetry, quantity and/or location to place dosimetry on workers entering the cavity.
Licensee procedures require that the radiation protection group prescribe the type and placement of dosimetry on the REP.
Kneeling was not considered in the ALARA pre-job review or REP.
REP 2-88-0274B, dated Nay 10, 1988, required teledosimetry devices be placed on the thigh and chest or workers assigned to hydrolase the cavity.
REP 2-88-02808 required eithe'r an alarming dosimeter or teledosimetry device for all entries into the cavity.
The REP did not specify the type and number of devices and/or the placement.
The RPT assigned to control the work stated that since there were only four teledosimetry devices available he decided that the devices would be placed at chest level since he was concerned about a 1000 R/hr, chest level,
"hot spot" reading located at the 'south end of the cavity.
The RPT stated he decided to have the workers place their teledosimetry devices at chest level and control the workers thigh dose by applying a
5 to 1 ratio to the reading obtained from the device.
When the decontamination worker knelt in the area, his teledosimetry device registered a rapidly increasing dose.
The RPT ordered him to move to a lower dose area, but allowed him to continue for approximately 5 minutes until another rapidly increasing dose was observed, at which time he ordered the worker to exit the area.
The inspector concluded that the LER contained all of the information required by 10 CFR Part 20.405 and
CFR Part 50.7 The inspectors verified that the licensee was in the process of implementing the corrective actions discussed in the LER.
The adequacy of implementation will be examined during a subsequent inspection (50-529/88-22-01).
(2)
Other Information The inspectors were informed that an indepth evaluation of the occurrence was initiated immediately after the event occurred on May 23, 1988.
The evaluation was still in progress at the conclusion of the inspection.
The licensee will document the results of their evaluation in Special Plant Event Evaluation Report (SPEER) 88-02-04.
The qualifications of the LRPT and contractor RPT covering the work associated with the overexposure were examined and were found to meet ANSI/ANS 3. 1-1978,
"American National Standard for Selection, gualification, and Training for Nuclear Power Plant Personnel."
It was noted that, although the involved contract RPT met the minimum requirements of ANSI/ANS 3. 1-1978, he had not worked at a commercial nuclear power plant before joining the RP group in February 1988.
The RPT's primary experience had been in chemistry rather than in radiation protection.
From a review of resumes, it was noted there were several other contractor RPT's on the licensee's staff who had performed reactor cavity decontamination at other commercial nuclear power facilities.
Discussions held with the involved LRPT and contractor RPT disclosed the following:
(1)
The LRPT stated they had read the station procedures, listed below, which authorize RPT's to stop work when, in their judgement, the radiological conditions warrant such action:
75PR-OZZ1, "Radiation Protection Program" 75PR-9ZZ03,
"ALARA Program" 75AC-9ZZ12, "Radiological Controls Problem Reports" The inspector verified that the contractor RPT had read procedure 75AC-9ZZ12 and was aware of his authority to stop work when conditions are unsafe.
(2)
The contractor RPT and LRPT stated that they felt they would have received disciplinary action if they had not done the job.
(3)
The inspectors noted that the same LRPT had stopped a job approximately three'eeks earlier and was not reprimanded.
The inspectors also noted other instances of RPTs exercising their authority to stop work at Units 1 and 2, without being reprimanded for their action (4)
The contractor RPT stated that the scope of the work had changed, in that, the planned work was to remove a Trinuke vacuum, cover the fuel transfer tube flange with staged visqueen sheet and tape it down, place a tape line on the walls, cover and tape visqueen on the fuel racks, and a
ladder.
However; when personnel arrived in the work area, they found the left rig was uncovered and did not find staged visqueen covers.
The RPT stated that he did not anticipate that the workers would have to kneel down as they covered and taped the equipment.
A review of the worker's occupational exposure records disclosed that the 2.607 rem exposure received from the event had been entered in the workers records.
However, discussions with the licensee's staff and the involved worker disclosed that as of June 27, 1988 no written notice had been sent to the worker pursuant to 10 CFR Part 20.409 even though written notification of the workers exposure had been transmitted to the NRC on June 22, 1988.
The inspectors verified that he had been verbally informed of the exposure on several occasions after the event occurred.
This matter was brought to the licensee's attention and the inspector verified that their staff took immediate action to make the appropriate notification, in accordance with 10 CFR Part 19. 13(a), within three hours.
A licensee representative informed the inspector that station procedures would be revised to clarify the 10 CFR Part 20.409 requirements.
The revised procedures were expected to be issued by the week of July 11, 1988.
C.
Conclusions The inspectors concluded that the approach taken by the licensee to determine the worker's final exposure as described in Inspection Report 50-529/88-14 was reasonable and that their investigation of the event was both timely and thorough.
The inspectors brought the observations of the previous section to the licensee's attention at the exit interview.
The inspectors and the licensee's staff agreed that the overexposure should not have occurred.
The licensee was informed that unresolved items 50-529/88-14-02 and 50-529/88-14-03 were closed and added:
(1)
The exposure of the worker to 3209 mrem during the second quarter of 1988, was an apparent violation of 10 CFR Part 20.101(b)(l) which states in part:
"During any calendar quarter the total occupational dose to the whole body shall not exceed 3 rems;..." (50-529/88-22-02)
(2)
The failure to perform a survey prior to the work in the reactor cavity on the night of May 22-23 to determine the dose
rate in contact with the floor after scaffolding removal on May 21, 1988 was an apparent violation of 10 CFR Part 20.201, which states in part:
"(a) As used in the regulations in this part, "survey" means an evaluation of the radiation hazards incident to the...
presence of radioactive materials or other sources of radiation under a specific set of conditions.
When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation....
(b) Each licensee shall make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present" (50-529/88-22-03).
(3)
The failure to provide a written statement of exposure to the worker on June 22, 1988, was an apparent violation of 10 CFR Part 20.409(b) which states:
"When a licensee is required pursuant to paragraphs 20.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual.
Such notice shall be transmitted at a time not later than the transmittal to the Commission, and shall comply with the provisions of paragraph 19. 13(a) of this chapter" (50-529/88-22-04).
3.
Radiation Protection Plant Chemistr Radwaste and Trans ortation Trainin and ualifications:
Unit 1, 2 and 3 Technical Specification (TS) 6.5.3.5(b), "Audits," states in part that the licensee's Nuclear Safety Group (NSG) shall perform audits of unit activities encompassing:
"The performance, training, and qualifications of the unit staff once per 12 months."
The inspectors met with the licensee's guality Assurance group at the start of the inspection period to discuss the scope of NSG audits that were performed pursuant to TS 6.5.3.5(b) for the period of 1986 and 1987 and requested copies of these audits.
gA audits86-015, dated July 2, 1986, and 87-14, dated June 24, 1987, audit reports were provided.
A review of the audit reports disclosed the following:
Neither audit addressed all disciplines within the Unit 1, 2 and
organizations.
Audit report 86-015 indicated that training and qualification of the radiation protection staff was addressed but the audit checklists did not include any unit staff members from the radiation protection organization.
Audit report 87-014 only addressed the training and qualifications of one member of the Unit 3 radiation protection staff.
Unit 1 and Unit 2 staff members were excluded.
Neither report addressed performanc These observations were brought to the attention of the licensee's gA staff who informed the inspectors that the performance of the unit staff was addressed in other audits and monitoring reports.
A copy of Audit Report 87-017, dated July 29, 1987, was provided to the inspectors.
The report addressed the performance of the radiation protection organization.
Maintenance, non-licensed operators, and chemistry disciplines were not addressed.
The gA staff stated that other 1987 audits and monitoring reports were conducted that addressed the performance of these disciplines.
The gA staff said license conditions were different in 1986 and were changed again in 1987.
Plant and gA administrative functions and responsibilities were also changed in 1986, 1987 and 1988.
The method of'onducting and documenting gA audits'nd monitoring reports changed during this period as well.
The staff contended that performance, training and qualifications were verified during this period but stated that it would take some time to gather the information because of the changes described above.
A separate audit, to verify compliance with TS, 6.5.3.5(b)
may not have been conducted for Units 1 and 2 in 1986 or 1987 because Chemistry and Radiation Protection staff members are part of a site-wide organization and may be assigned to any one of the three Units at any given time.
Because of this the staff contended that verifying the performance, training and qualifications of Unit 3 staff members in 1987 also satisfied similar requirements prescribed in Unit 1 and 2, TS.
ANPP training programs and Human Resource programs have been established to incorporate the ANSI/ANS-3. 1-1978 requirements; therefore, gA audits and monitoring activities are geared to verify that the tr aining program and Human Resource program have not changed.
Because these apply to the entire site, gA audits and monitoring address the site wide programs rather than each Unit separately.
The inspectors were informed that more information that may satisfy TS 6. 5. 3. 5(b) could be made available at a later date.
The inspectors discussed the above observations at the exit interview.
The licensee was informed that, pending receipt and evaluation of the additional information, this matter is considered unresolved (50-529/88-22-05).
The inspectors reviewed representative resumes of the Unit 1, 2 and
chemistry, radiation protection, radwaste and transportation staff.
The inspector concluded that the individuals selected met the qualifications of ANSI/ANS 3.1-1978.
A recent event was reviewed for potential training deficiencies.
Individuals involved met ANSI/ANS 3. 1-1978 qualifications and had received periodic retraining in the procedures used.
Several persons were polled on various aspects of ANPP procedures for posting and controlling high radiation areas.
The results of the poll (see paragraph 8, herein) disclosed that the worker knowledge with respect to this matter was marginal.
A review of the licensee's General
Employee Training (GET) program disclosed that the subject matter is included in the GET lesson plan.
The programs appeared adequate to accomplish their safety objectives.
However, resolution of the weaknesses described above would strengthen the program.
4.
Control of Radioactive Materials and Contamination Surve s
and
~onitarin a
~
Audits and A
raisals The inspectors reviewed the following audit and monitoring reports for adequacy and corrective action:
Number 88-008 ST-88-0062 ST-88-0123 ST-88-0164 ST-88-0241 ST-88-0354 ST-88-0385 ST-88-0386 ST-88-0602 ST-88-0619 ST-88-0627 ST-88-0628 Title Radiation Protection (Audit)
Radiological Posting Radiation Protection/Radiological Surveys Radiation Protection/Radiological Schedule Radiation Protection/Material Release Equipment/Yehicle Release Radioactive Material Storage Radiological Instrument Calibration Instrument Calibration and Response Check Problem Reports Posting Contamination Log Date 4/4-22/88 1/12-14/88 2/3 - 8/88 1/27/88 2/16-22/88 2/25-'/10/88 3/23/88 3/23/88 5/25/88 6/6/88 6/7/88 6/7/88 Licensee Audit 88-008 concluded that program objectives in the areas of ALARA and work practices were not being adequately met.
Specifically, the audit found that ALARA goals had not been incorporated into the program, no ALARA committee meetings had been held in over a year, and unit inspections were not being performed in accordance with 75RP-92Z95,
"ALARA Inspections,"
Revision 2.
,Many similar findings concerning adherence to proper work practices have been noted in previous NRC inspections.
The depth and scope of the above audits were observed to be capable of assessing the licensee's program.
The inspectors noted that the findings of the investigation of the May 23, 1988, overexposure incident coincided with the findings of the audit in the area of ALARA (see paragraph 2.8.2 above).
At the time of the inspection, Corrective Action Records (CARs)
had been initiated to address the deficiencies identified in audit 88-008.
Some items had been closed, some had had their response dates extended, and the remainder were still awaiting response.
No initial responses were observed to have been late.
The licensee ALARA group's response to the lack of unit ALARA inspections concluded that outage job reviews met the intent of the procedur However, the audit identified a missed ALARA inspection during non-outage conditions in January of 1988.
The ALARA group stated that corrective actions were being implemented.
Monitoring reports addressing Radiation Protection, Radwaste and Chemistry Department performance appeared appropriate to meet the performance review requirements of TS 6.5.3.5.b for these disciplines for 1988 (see paragraph 3, above).
Corrective actions appeared timely with the exception of a recurring problem with lack of adherence to good radiological work practices applicable to both licensee and contractor RP personnel.
The licensee's audit and monitoring personnel were observed to be qualified in accordance with Regulatory Guide 1. 146, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
QA audit personnel had experience in the subject areas.
b)
Sealed Source Contamination Sealed source accountability and contamination leak tests pursuant to TS 4.7. 10. 1 for the period of January 1987, through June 1988, were examined.
The examination included a review of station procedure 75RP-9XC08,
"Leak Testing and Inventory of Radioactive Sources."
The examination disclosed that the tests had been successfully performed in a timely manner.
In the areas inspected, the licensee's programs appeared adequate to accomplish their safety objectives.
No violations or deviations were identified.
5.
Solid Wastes a ~
Audits and A
raisals The following monitoring reports were reviewed:
Number Title Date s
ST-88-0256 Radwaste/Empty Package Shipment 2/15-23/88 ST-88-0625 Package Binding to Transport Trailer 6/1-6/88 The above were in response to'ransportation incidents.
Licensee representatives stated that other monitoring reports for 1988 had not identified unsatisfactory conditions.
The responses to the above appeared appropriate and timely.
A review of qualification files confirmed that the persons that conducted audits were qualified in accordance with Regulatory Guide (R.6.) 1. 146,
"Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
b.
~Chan ee The licensee had made no recent major changes to the progra Processin and Stora e
The licensee uses the services of a qualified contractor, in accordance with their procedures, for solidification of wastes, rather than their installed system.
Representative waste classification and analysis records were briefly reviewed to determine if the requirements of 10 CFR Parts 61.55 and 61.56,
CFR 71.5,
CFR 172, and 49 CFR 173 were being met.
No obvious mistakes, omissions, or trends were observed.
Representative shipping documents for solidified wastes contained sufficient information to identify the material in accordance with the above requirements.
A physical examination of mobile solidification equipment used in units 1 and 2 revealed no problems, except for clutter within the temporary shield walls.
Control of casks after filling is discussed further in paragraph 8 below.
Dis osal of Low-Level Waste Representative shipping records were reviewed.'arkings, and investigation of a temporarily lost shipment (licensee monitoring report ST"88-0256) were appropriate to meet the requirements of 10 CFR 20.311.
Although the Process Control Program for solid wastes was in place, no recent reviews had been conducted of the PCP in accordance with Technical Specification 6. 5. 2. 9.
The licensee had already begun corrective action, taken as a result of an internal gA audit (see paragraph 7.a).
The licensee seemed to be maintaining their previous level of performance in this area and their program appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
Li uids and Li uid Wastes Audits and A
raisals The following audit and monitoring reports were reviewed:
Number Title Date s
ST-88-0135 ST-88-0168 ST-88-0195 88-009 Chemistry-Chemistry Control Instruction 1/22/88 Chemistry-Laboratory Analytical Control 2/9/88 Chemistry-Surveillance Testing 2/11-15/88 ANPP Plant Chemistry 4/11-25/88 The licensee identified no major deficiencies.
The licensee did, however, note that some procedurally required valve lineup verifications were still not being performed (see Inspection Report 50-529/88-05).
The licensee was implementing procedural changes to correct the problem.
Licensee findings identified in the above audits were corrected in a timely manner.
Audit personnel were qualified in accordance with R.G.
1. 14 b..
~Chan ea No major changes had been made to the licensee's equipment or procedures since the last inspection.
Reference to the impact of the reorganization was made in audit 88-009 and Inspection Reports 50-528/88-05, 50-529/88-05, and 50-530/88-05
'.
Effluents The Semi-Annual Effluent Release Reports for 1987 were reviewed.
No obvious omissions or trends were noted.
No liquid pathways are included in the Licensee's Offsite Dose Calculation Manual (ODCM).
The licensee performs sampling prior to discharge of secondary liquids to the onsite evaporation ponds.
Primary liquids are evaporated and the concentrates solidified.
d.
Instrumentation associated with the distillation and concentration of liquid wastes is discussed in paragraph 7.
Representative primary and secondary chemistry and radiochemistry results were reviewed for 1987 and 1988 for all three units.
Results reviewed produced no concerns.
Out of specification chemistry parameters observed by the licensee for Unit 3 are discussed in Inspection Report 50-530/88-03.
Units 1 and 3 had identified small increases in fission product activities, which trended up then back down to a higher stabilized level than had previously been observed.
Typical activities are shown:
Unit 1 E-bar Date
. 794 4/28/88 Dose 9.52 E-2 Equivalent Iodine (uCi/gm)
Unit 2
.99 12/18/87*
2.25 E"2 Unit 3 1. 01 1/20/88 1.92 E"3 Gross Activity 5.75 (uCi/gm)
l. 37
.229
Unit 2 had not yet achieved the prerequisite conditions for determination of E-bar at the time it became due on 6/18/88.
The licensee stated that concentrations of chloride, fluoride, boron, dissolved oxygen, and radioactivity had not been outside the limits of the technical specifications.
No examples of out-of-specification results were observed in the reviewed records.
The licensee seemed to be maintaining their previous level of performance in this area and their program appeared fully capable of accomplishing its safety objective No violations or deviations were identified.
7.
Gaseous Waste S stem Audits and A
raisals The following licensee audits and monitoring report were reviewed:
Number Title Date s87-006 88-006 88-008 ST-88-0195 Preplanned Alternate Sampling Program (PASP) 3/9-16/87 Gaseous Effluents Process Control Program 3/7-25/88 Radiation Protection 4/4-22/88 Chemistry-Surveillance Testing 2/11-15/88 Corrective actions for findings related to gaseous wastes from the'bove audits were implemented in a timely manner.
A CAR was issued to request development of a program to review the Process Control Program (PCP), Offsite Dose Calculation Manual (ODCM), and the PASP, in order to meet Technical Specifications (TS) 6. 5. 2. 9 and 6. 5. 2. 10.
Audit personnel were qualified in accordance with R.G.
1. 146.
b.
~Chan ea Licensee representatives stated that they were making several changes to sample lines and to hardware and software.
The Plant Vent Monitors, RU-143/144, and Condenser Vacuum Pump Gland Seal Exhaust Monitors, RU-141/142, were having the high range power supplies and sample lines modified in order to allow the units to be removed from service without affecting the corresponding normal range channels, and vice versa.
Work requests and design change packages were briefly reviewed to verify the above modifications.
c.
Effluents The Semiannual Radioactive Effluent Release Reports for 1987 were reviewed.
No omissions, trends, obvious mistakes or anomalous measurements were noted.
Representative release permits, including one of an Integrated Leak Rate Test (ILRT) for Unit 2 containment depressurization were reviewed.
The Chemistry Department has responsibility for effluents.
The unit Chemistry Managers each stated that no unplanned releases in excess of the Technical Specifications had occurred.
No gaseous releases in excess of the Technical Specifications were observed to have occurred.
Dose calculations for Sb-124 in Cow, milk (to a child) and Co-60 inhalation (to a teen)
were verified using the licensee's ODCM.
Effluent doses reported were within 10 CFR 50, Appendix I limit Instrumentation Monitor readings for Plant Vent Monitors RU-142/144 for the three units were observed to be consistent with licensee records.
Representative surveillance tests were reviewed.
The licensee's efforts to improve operability and reliability are discussed in paragraph 7.b, above.
Monitor setpoints were discussed with Radiation Protection (RP) and Instrumentation and Controls (I8C) personnel who routinely conduct maintenance on the effluent monitors.
These individuals understood the basis for monitor setpoint determinations.
No concerns were identified and sample results for radionuclide concentrations were consistent with monitor readings.
During a review of the licensee's monitoring requirements for the Dry Active Waste Processing (DAWP) facility, the inspectors noted that the exhaust ventilation did not appear to be addressed as a
potential release path.
In particular, the inspectors noted that the Technical Specifications (TS) and Final Safety Analysis Report (FSAR) had not been amended to reflect the potential release path of the DAMP facility exhaust.
Additionally; the facility exhaust is not addressed as a release point in section 5, "Design Features,"
of the TS.
The facility has a filtered exhaust ventilation system which is monitored continuously for particulates.
This matter will be examined in a subsequent inspection (50-528/88-22-06).
Air Cleanin S stems Records covering the performance of tests of the Control Room Essential Filtration System, in accordance with the requirements of T.S. 4.7.7, ESF Pump Room Air Exhaust Cleanup System, in accordance with the requirements of T. S.
4. 7,. 8, and Fuel Building Essential Ventilation System, in accordance with the requirements of T.S.
4.9. 12, performed in 1987 and 1988 were examined.
The following procedures which had been implemented by the licensee to perform these tests were reviewed:
Number Procedure Title Rev.
Effective Date 3ST-9HF01 FUEL BUILDING AFU AIRFLOW
CAPACITY AND PRESSURIZATION TEST 870522 3ST-9HF02 3ST-9HF03 3ST-9HF04 FUEL BUILDING AFU IN"PLACE
HEPA FILTER LEAK TEST FUEL BUILDING AFU IN-PLACE
ADSORBER STAGE LEAK TEST FUEL BUILDING/ESF PUMP ROOM
840801 861016 851126
3ST-9HF05 ESSENTIAL AIR FILTRATION TRAIN "A" CARBON ANALYSIS FUEL BUILDING/ESF PUMP ROOM
ESSENTIAL AIR FILTRATION TRAIN "B" CARBON ANALYSIS 861126 3ST-9HJOl CONTROL ROOM AFU AIRFLOW CAPACITY AND PRESSURIZATION TEST
840807 3ST-9HJ02 3ST-9HJ03 CONTROL ROOM AFU IN-PLACE
HEPA FILTER LEAK TEST CONTROL ROOM AFU IN-PLACE
ADSORBER STAGE LEAK TEST 880118 870425 3ST-9HJ04 3ST-9HJ05 CONTROL ROOM ESSENTIAL FILTRATION TRAIN "A" CARBON ANALYSIS CONTROL ROOM ESSENTIAL FILTRATION TRAIN "B" CARBON ANALYSIS
00 861126 861126 The examination disclosed that the tests had been successfully performed in accordance with the respective T.S.
requirements.
F.
Meteorolo ical Instrumentation Records covering the performance of tests of site meteorological monitoring instrumentation pursuant to TS 4.3.3.4 for the period of January 1987 through May 1988 were examined.
Station procedures 36ST-9RG03,
"Meteorological System Calibration," and 36ST-9RG02,
"Meteorological System Calibration" (Redundant System)
which implement the requirements of the TS, were reviewed.
The examination disclosed that the surveillance tests were successfully accomplished in a timely manner.
The licensee seemed to be maintaining their previous level of performance in this area and their program appeared
'adequate to accomplish its safety objectives.
No violations or deviations were identified.
Facilit Tour Several tours of the licensee's facilities were conducted during the inspection.
Personnel frisking and entry to and egress from controlled areas and contaminated areas were observed.
Independent radiation measurements were performed during the tour with an Eber line, Model R0-2, ion chamber survey instrument, NRC No.
22906, due for calibration on August 20, 1988.
In addition, personnel were
questioned on various aspects of the radiological control program.
The following observations were made:
With the exception of the Unit 2 Radwaste Building Truck Bay, plant cleanliness in all Units had improved over what was observed during the previous inspection.
No unmonitored personnel were observed in the areas that were toured.
C.
All portable radiation detection instruments observed were in current calibration.
d.
Personnel frisking habits were consistent with posted instructions.
e.
Technical Specification 6. 12.2,
"High Radiation Areas," states in part:
"In addition to the requirements of Specification 6.12.1, areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose greater than 1000 mrem shall be provided with locked doors to prevent unauthorized entry, and the keys shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under the administrative control of the Shift Supervisor on duty and/or radiation protection supervision.
Doors shall remain locked except during periods of access by personnel under an approved REP which shall specify the dose rate levels in the immediate work area and the maximum allowable stay time for individuals in that area.
For individual areas accessible to personnel with radiation levels such that a major portion of the body could receive in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> a dose in excess of 1000 mrems", that are located within large areas, such as PWR containment, where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that area shall be roped off, conspicuously posted and a
flashing light shall be activated as a warning device...."
On June 27, 1988, the Unit-2, grave shift LRPT informed the inspectors of an alarming Area Radiation Monitor (ARM), RU-28.
RU-28 monitors the Hi-level storage area of the Radwaste Building, truck bay.
The inspectors determined that as of 4:00 a.m.,
June 27, 1988, no attempt had been made by the RP staff to verify the alarm by taking radiation measurements.
The RU-28 monitor Hi-alarm set point was 110 mrem/hr.
The licensee's staff was unable to determine when the ARM started to alarm.
Their best guess was May 25, 1988 when highly radioactive resin liners were placed in the area.
The RPT stated that the control console for the monitor was located behind a locked door.
As of 5:20 a.m.
MST, June 27, 1988, the staff had been unsuccessful in gaining access to the ARM's control console, as radwaste personnel were stated to be the only group with the correct lock combination, and they were not on shift at the time the alarm was noted by radiation protection personne A tour of the area of the alarming RU-28 ARM was made by the inspectors.
The inspectors noted that this required gaining access to an area that was posted as a "high radiation area" having dose rates in excess 1000 mrem/hr.
The boundaries of the area were posted with flashing yellow lights.
Access to the conspicuously posted boundaries was available through an unlocked door at the mezzanine level of the truck bay or by scaling a portable wooden ladder that provided access over an eight foot high shield wall.
Additional ladders had been installed on the opposite side of the shield wall to allow easier access to areas used for storing highly radioactive material.
At approximately 6:20 a.m.,
June 27, 1988, the licensee's staff obtained a radiation measurement of 2500 mrem/hr at the ARM detector.
The RU-28 alarm set point was subsequently set at 3000 mrem/hr.
Further discussion with the licensee's staff revealed that they considered the truck bay a large area, such as a containment building, which could not be locked.
Subsequently, a joint NRC/licensee survey was taken of the storage area.
The licensee's staff used an Eber line, Model R0-2A, ion chamber survey instrument, Serial No.
2675, due for calibration on September 19, 1988.
Radiation measurements taken in the area by the NRC and licensee were in agreement.
Radiation levels at eighteen inches from the surface of resin liners in the shielded area measured up to 3500 mrem/hr.
Radiation levels at the wire mesh door and base of the portable ladder at the shield wall were measured as less than 2 mrem/hr, whereas radiation measurements taken on the opposite side of the wooden ladder and the open wire mesh door ranged from a few mrem/hr to approximately 300 mrem/hr.
The inspectors noted, and informed the licensee, that the area was designed to be lockable.
The inspectors added that installing the ladders and not locking the doors made it easier for personnel to gain access to the area.
The inspectors verified that the licensee's staff took immediate action to control access to the area by removing the ladder providing access over the eight foot shield wall and locking the door.
This matter was brought to the licensee's attention at the exit interview.
The inspectors informed the licensee that failure to lock the high radiation area was an apparent violation of TS, 6. 12.2 (50-529/88-22-07).
The inspectors discussed high radiation area controls with several personnel whose work could reasonably have been expected to take them either in close proximity to or into locked high radiation
areas and who had received training for work in such areas.
Of 32 persons polled, the results were:
Persons aware of the purpose of the flashing yellow lights, the high radiation area postings and the monitoring requirements of TS 6. 12. 1.
Persons
.somewhat aware of the purpose of high radiation area postings.
Persons aware in varying degrees, ranging from their knowledge of the definition of high radiation areas to an apparent lack of knowledge of the nature of radiation.
Persons acknowledging that they did recall having received training in controlled access to high radiation areas.
28*
Training record review, and previous inspection of licensee training sessions, indicated that the other 4 persons polled had received training, though they did not recall having done so.
The-inspectors discussed the above, in view of the use of flashing lights to control access, with senior licensee management.
The inspectors expressed concern that the licensee may need to determine the extent of the problem.
The licensee's efforts to address an apparent lack of knowledge retention, in the area of high radiation area control, will be examined in a subsequent inspection (50-529/88-22-08).
9.
Exit Interview The inspector s met with the individuals denoted in paragraph 1 at the conclusion of the inspection on July 1, 1988.
The scope and findings of the inspection were summarized.
The licensee was informed of the violations, discussed in paragraphs 2(d) and 8, and of the unresolved item discussed in paragraph 3(d).
The licensee acknowledged the violations and unresolved item.
The inspector informed the licensee that the apparent violations and findings discussed in paragraph 2 of this report and paragraph 3 of Inspection Report 50-529/88-14 would be addressed in separate correspondence.