IR 05000528/1988033
| ML17304A782 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/15/1988 |
| From: | Cillis M, North H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304A781 | List: |
| References | |
| 50-528-88-33, 50-529-88-32, 50-530-88-31, IEIN-88-063, IEIN-88-63, NUDOCS 8812050204 | |
| Download: ML17304A782 (20) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-528/88-33;: 50-529/88-32 and 50-530/88-31 License Nos.: NPF-41, NPF-51 and'NPF-74:
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'icensee:
Arizona Nuclear Power Project P.
0.
Box 52034 Phoenix, Arizona 85072-2034 Facility Name:
Palo. Verde Nuclear Generating Station -.Units Inspection at:
Palo Verde Site'- Wintersburg, Arizona a
Inspection Conducted:
September 19-23, 198& and October 3-7, Inspection by:
M. Cillis, Senior. Radiation Spe'cialist Approved by:
H.
S. North, Acting Chief.
Facilities Radiological Protection. Section
1,2and3 1588
<</IHIP Date Signed
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Date igned
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~Summar:
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.a.,
Areas Ins ected This was a routine, unannounced inspection covering the licensee s
followup of open items and Informption,Notices, followup of enforcement items, review of Allegation 88-RV-A-0041,.and tours of the licensee's facilities.
Inspection procedures 30703, 92701, 92702,. 92700 and 83729 were covered.
b.
Results In the areas inspected, the licensee's programs exhibited weakness as described in paragraphs 5 and 6.
Of particular concern, is the lack of specificity in the licensee's radiation protection program implementing procedures which tend to lead to inconsistencies in implementation of the program from Unit to Unit.
However, the areas appeared marginally adequate to accomplish their safety objectives.
No violations or.
deviations.were identified.
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DETAILS Persons Contacted a ~
Licensee Staff
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Haynes, Vice-President;,, Nuclear Production D. Driscoll, Assistant Vice President, Nuclear Production Support F. guinn, Director, Nuclear Safety and Licensing J. Zeringue, Plant Manager, Unit 3 E. Ide, Plant Manager, Unit 2 M. Butler, Director, ANPP Standards and Technical'Support M. Allen, Plant Manager, Unit 1 A. Sousa, Manager, guality Audits."and 'Monitoring D. Shriver, Manager, ANPP Compliance R.
Mann, Manager, Central Radiation Protection M. Sills, Supervisor, Radiation Protection Standards P. Hilmer, Manager, Radwaste Support.,
H. Doyle, Manager, Radiation Protection, Unit 2 E.
Sneed, Manager, Radiation Protection, Unit 3 R.
Oberdcn f, Manager 'Radiation Protection, Unit 1, Mimmicks, Manager, Maintenance, Unit 3 Kirby, Manager, Site Services Brown, Supervisor, Training Legoy, Electrical Supervisor, 'Unit 3 Waldrep, Lead Shift Technical Advisor (STA); Unit 3 Rackley, STA, Unit 3 R.'Rodriguez, Affirmative Action Supervisor, Employee Relations G.
Papworth.,
Director', guality Assurance McGee, Central Radiation Protection, Support Supervisor b.
Contractor Staff 1.
Bartlett Nuclear Inc.
+~W.
H. Bailey, C.R.H.P.,
Vice President, Health Physics Engineer/Consultant 2.
Volt Electrical C.
W. Gray, Electrical Technician A. A. Beemiller, Electrical Technician C.
Nuclear Re ulator Commission
+"T.'J. Polich, Senior Resident Inspector
+ D.
H.
Coe, Resident Inspector
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F. Melfi, Reactor Inspector, Region V Office Denotes attendance at the September 23, 1988, exit interview.
+
Denotes attendance at the October 7, 1988, exit intervie and cont In addition, the inspector met and held discussions with other licensee ractor personnel.
92701 The following followup items were examined:
h A.
Information Notices INs B.
received and was in the process of reviewing IN 88-63,
"High Radiation Hazards from Irradiated Incore Oetectors and Cables."
This matter is closed at Units 1, 2 and 3.
Ins ector Identi.fied. Followu
. Items N
0 en 50-528/87-24-02 and 50-529/87-25-01:
These items involve the number and the significance of problems and personnel contamination events that occurred in Units 1 and 2 in 1987.
This matter was.
brought to the licensee's attention at the exit interviews held on July 17, 1987, and August 6', 1987, when the inspector was informed that the licensee would investigate the matter and respond to the inspector's concerns.
An'.examination was. conducted to eval.uate
.the resul.ts of the licensee s investigation,into thiS. matter...The matter was reviewed with the Unit l,and 2 Radiation Protection Managers (RPMs).
The examination disclosed the following:
Clothing and skin cohtamination events in Cnit 1 through approximately the same period discussed in Inspection Report 50-528/87-24 increased from 125 to 251 for the first eight months of 1988.
A greater increase was noted at Unit 2 for the same period, e.g.
91 cases reported in 1987 to 361 reported for the first
. eight months of 1988.
Both RPM's stated that the Units had been through refueling outages and were experiencing problems with "Hot Particles."
The RPMs indicated that "Hot Particle" contamination events probably account for 40 to 50X of the contamination occurrences.
The Unit 1 RPM conducted an indepth investigation of the concerns raised in inspection report 50-528/87-24.
A copy of the Unit 1 investigation report was provided to the inspector.
The report describes the actions and programs that are being undertaken in Unit 1 to reduce personnel contamination occurrences.
A similar investigation of the concern raised in Inspection Report 50-529/88-25 had not been conducted by the Unit 2 RPM.
However, the Unit 2 RPM stated that all contamination occurrences are taken very seriously.
He added that each occurrence is documented,. evaluated
J
and discussed with each involved individual and his/her supervisor.
The RPM added that the collected data is trended to determine if there are any repeat offenders and where improvements can be made to reduce the number of occurrences.
The inspector informed the licensee that, the number of skin/clothing contamination occurrences reported in 1988, to date, appeared to be excessive.
The inspector added that if 50K of the contamination occurrences are related to "Hot Particles,"
then it may be worth while determining.whether.or not-. improvements.cap be, made',to reduce the number of occur rences.'
The jnspector was informed that the liceqsee would investigate the matter and respond to the inspectors.concerns.
These items will remain open.
Closed 50-529/88-09-01:
Inspection Report 50-529/88-09 includes a
discussion which provides a comparison of the antimony removal program at Units 1 and 2.
The report states that the effect of the antimony removal program on Unit 2 steam generatdr work would be evaluated during a subsequent inspection.
C A discussion related to this matter was hei.d with the licensee's staff. 'The staff informed the inspector that approximately 94.2 person-rem was expended,to,i,nspect and repair two, Unit.2 steam
~ generators during the first refueling cycle.
, The staff added that problems were gxperienced during the rem'oval of the nozzle dams.
The estimate for nozzle dam installation and removal was
person-rem; whereas, approximately 30 person-rem was expended.
e Discussions with the staff indicated that the 94.2 person-rem expended was considerably 1'ess than the dose expended during the steam generator iasgection and repair conducted in 1987.
The project ALARA engineer stated, that, the dose rates in the steam generator bowls were approximately the same~before and after the antimony removal process.
The ALARA engineer stated that the reduction in Person-Rem between the 1987 and 1988 steam generator work was due to improved mock-up training and performing mechanical tube plu'gging in 1988 versus manual during the 1987 repairs.
The licensee's staff added that lOOX of the tubes were inspected in one generator and somewhat greater than the standard lOX were inspected in the other steam generator.
Average dose rates in.the bowl ranged up to approximately 10 rem/hr in the hot leg and '6 rem/hr in the cold leg.
Hot spots of up to 65 rem/hr were also seen inside the steam generator bowls.
While the 94.2 person-rem appears to be high, it should be noted that other plants not having the antimony or nozzle dam removal problems may expend on the order of 50-70 person-rem conducting a
routine steam generator inspection and repair evolution.
The licensee's staff hopes to improve their performance in this area during future steam generator inspection and'epair work.
This item Hill be examined as part of the routine inspection program during
e each refueling outage in which steam generator inspection and repair work is conducted.
This matter is closed.
Closed 50-528/88-13-02:
This matter is being tracked as unresolved item 50-529/88-22-05; therefore this matter is closed.
Closed 50-528/88-13-03: ---This matter was addressed in Inspection Report 50-528/88-22.
This-matter is closed.
Closed 50-528/87-'8-,:Ol:::/'nspection, Report 50-.528/87-. 18 noted that the licensee had established a committee to evaluate methods for handling problems associated with radioactive particles.
The rapport went on to state that the results of the committee's actions would
'e reviewed during 'a:subseqQent inspection.
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.The inspection'isclosed that the committee activities'were disbanded.after the Hot Particle program procedures were established and implemented.
Currently, periodic reviews of the licensee's
"Hot Particle" program are performed by the Radiation Protection Standards group.
This matter is closed.
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3.
Followu on Corrective Action for Violations 92702 losed 50-528/88-13-01: 'his item concerned a violation related to
.
radioactive waste shipments 88-.RW-.21, arfd'88-...RW.-.,23 that arrived at the Beatty, Nevada, burial site with loose.restraint's and one of tbe shipments was observed.to have shifted during transfer as was evidenced.
by loosened or broken bracing.
The inspector verified that the licensee's corrective actions documented in the response to the Notice of Violatibn had been completed.
Licensee actions to prevent a possible recurrence'ncluded a requirement for the
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driver to perform periodic checks (e.g.
every 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />) of the shipment.
In addition ANPP has..requested carriers to reinforce the carriers responsibilities concer'ning the lading during transport.
Personnel had been instructed in the licensee's corrective actions.
These actions appeared appropriate to prevent recurrence.
4.
Licensee Action on Licensee Event Re orts LERs /S ecial Re orts:
Closed LER 50-529/88-ll-LO:
This item is related to the Unit 2 over exposure discussed in Inspection Reports 50-529/88-14, 50-529/88-22 and
.
50-529/88-26.
Followup actions related to the inspection report findings are being tr'acked under other enforcement and followup open item numbers.
This matter is closed.
5.
Alle ation RV-88-A-0041 This matter refers to an allegation made by an ANPP worker regarding the licensee's respiratory, protection program.
The worker raised concerns about the compliance of ANPP with their respiratory protection program implementing procedures.
The worker provided information which indicated that 50K of the Unit 2.Operations
Support Group staff were not qualified to utilize respiratory protective equipment during an emergency.
The worker stated that he had been attempting to be reinstated to a position in the Operations Support Group following a serious accident.
The worker was qualified to wear a
respirator prior to the accident.
The worker was unable to qualify as a
respirator user after the accident'due to facial injuries in that he was unable to maintain a cleanly shaven. face.as-required by. the licensee'-s Plant Policy No. 19, dated January 25, 1985.. The worker questioned the need to qualify as a respirator user.
He felt that, in the event that he
,,had to. don a respirator,, he would be,willing;to maigtai,n,shaving, equipment readily available so 'Ch'at'"h'e"'c'ould 'shave.
The licensee
'nformed the worker that it was their policy that everyone entering the licensee's protected area comply with Plant Policy No.. 19 requirements.
The worker was also informed that hisold position required that he be resp'irqtor qualified.
He was informed that he could have his old position back if he was willing to comply with the respiratory
~ protection
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program requirements.
It should be noted that the worker wanted to be reinstated to his old position because he feels that it offers him a better chance for,promotional opporturrities.
The licensee reiterated that each respirator us'er is required to demonstrate that he or she can obtain a good facial seal when donning a respirator which was the basis for.the requirements'peqified in Plant Policy No. 19.
The worker stated that he could not comply with this requirement because of the pain encountered if he had.to ~have daily.
These circumstances raised the questions, noted in the opening sentence, of, this paragraph, after the workers discovery that 50K of the Operations Support Group staff were currently not respirator qualified.
An examination of the licensee's respiratory protection program was conducted.
The exa'mination included:
Review and participation of the NRC inspector in the licensee's Basic Radiolqgical and SCBA/Confined Spaces respiratory protection training program and respirator qualification program.
Review of training and qualification records Review of respirator equipment issue records Review of applicable licensee implementing procedures:
"Radiation Protection Program" and 75PR-OZZ02 "Respiratory Protection Program."
Review of 10 CFR Part 20.103,
"Exposure of Individuals to Concentrations of Radioactive Materials in Air in Restricted Areas."
Review of NUREG-0041,
"Manual of Respiratory Protection Against Airborne Rad'ioactive Materials" Discussions with the licensee's staff.
It should be noted that the licensee's Plant Policy No.
19 specifically states:
PALO VERDE NUCLEAR GENERATING STATION PLANT POLICY NO.
SUBJECT:
Facial Seal of Respiratory Protective Equipment PURPOSE:
1.
To establish face.piece-to-face seal policy for all employees whose work requires, or may.require, the use of respiratory protective*equipment.
OSHA Regulation 1910. 134(e) (5) (i), states, in part:
"Respirators shall not be worn when conditions prevent a good face seal'.
Such conditions may 'be a growth -of beard, sideburns, a skull cap that projects under the face p'iece or temple piece on glasses".
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'UREG-0041, Chapter 13.3 "Facial Hair" states, in part:
"Any worker who has facial hair that intrudes into the area where the respirator seals against the face shall not be fitted with a respirator".
POLICY:
<<l.
All persbns issued permanent ACAD's for unescorted access into the protected area must maintain, at all times, facial chair,
~ styles so as,to not interfere with.the sealing surface of. a respirator.
A11 other employees whose work requires, or 'may require the use of respiratory protection equipment, must successfully complete
'a respiratory fit fest and following this fit test must maintain, at all times, facial hair styles which do not interfere with the sealing surface of a respirator.
The managers, supervisors, and foreman, are responsible for ensuring that their affected employees comply with this policy."
Discussions with the licensee's staff disclosed that personnel entering the protected area with a beard, must obtain an exemption, such as the alleger has for entering the protected area.
The staff added that some exemptions have been issued for various reasons; however, respiratory protection devices are not issued to individuals having a beard or facial hair styles which interfere with the sealing surface of a respirator and to individuals who have not been qualified in accordance with the licensee's procedures.
The licensee's staff said Policy No.
19 applies to NRC inspectors as well as to ANPP employee's.
The rev'iew disclosed that licensee procedures do not specifically state which workers or groups need to be respirator qualified.
Procedures state that it is up to each supervisor to determine who needs to be qualified.
Discussions with the Unit 2 Operations Support Supervisor disclosed that he had made it an oral policy to require everyone i'n the Unit 2 Operations Support Group to be respirator qualified.
He stated
that this policy had been in effect for several years and he was under the impression that all members of his staff were qualified.
The inspection disclosed that 8 of 14 Unit 2 Operations Support Group personnel on his staff were not qualified as of the start of this inspection.
Some staff members had not maintained their qualifications since 1986.
The examination also disclosed that the licensee enforces Plant Policy No. 19, which requires everyone'*entering the protected area to be clean shaven, and further that respiratory protective equipment not be issued to workers that'are
'n'ot qual,ified; 'he examination further disclosed that the licensee's training program was consistent with NUREG 0041.
CFR 20.103 addresses the use of respiratory protective equipment to limit the inhalati.on of airbgrne radioactive material.
Mhile this NRC requirement doeq not specifically require the absence of facial hair as'
prerequisite for site protected area access',"'sections 20.103(b)(2)
and (c)(2) provide in part, that each licensee must maintain and implement a
respiratory protection program that includes writtdn procedures regarding selection, fitting, and maintenance of respirators.
It should be noted that if a licensee elects to use a respiratory protection device that requires a 'tight facial seal to achieve the level of protection, then the NRC would expect the licensee's procedures to include the guidance expressed in NUREG 0041, paragraph 13.3, which states that "Persons using tight;fitting (facepiece)
respirators shall not have any facial hair that interferes with the sealing surface of-the respirator.".
The licensee's Policy Number 19 was estab1ished for the. purpose of assuring compliance with the guidance provided in NUREG 0041.
The inspector verified that respiratory protection devices had not been
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issued to personnel who had not attended the licensee's respiratory protectio'n qualification program, which included training, a medical examination and a respirator fit test.
The inspector concluded that the licensee's respirator program was consistent with station implementing procedures, NUREG 0041 and 10 CFR 20. 103.
The inspector was subsequently informed that the eight Unit 2 workers had been scheduled to requalify as respirator users.
The inspector observed that the licensee's procedures do not assure. that the respiratory protection program is implemented in a consistent manner from Unit to Unit.
The above observations were brought to the licensee's attention at the exit interview.
This matter is closed.
The licensee's respiratory protection program appeared to be adequate to meet its safety objectives.
No violations or deviations were identifie.
Tour and Inde endent Ins ection Effort 83729 The inspector toured various areas of the licensee's Unit 1, 2 and
facilities.
The inspector made independent radiation measurements using an Eberline RO-2 portable ion chamber radiation detection instrument, S/N 2691, due for calibration on October 14, 1988.
The inspector held discussions with licensee and contractor working'staff.during the tours.
The following observations were made during the tours:
a.
Housekeeping was generally good-in: all three Units;.
'.
Observed radiation monitoring equipment was in current calibration and the required source checks were current.
C.
d.
Posting and labeling practices were in compliance with 10 CFR 19. 11 and
CFR 20.203.-'osting of high radiation areas (HRAs) having dose rates of greater than 100 mrem per hour but less than 1000 mrem per hour and locked high.radiation areas (LHRAs) were consistent with the requirements prescribed in Technical Specifications 6. 12.1 and 6.12.2.
However the inspector noted that there were significant inconsistencies in
'the posting methods used by each unit in the identification of LHRAs.
The following inconsistencies were observed:
High Radiation Area High Radiation Area 1000 MREM/HR SinNo.
0 High Radiation Area ed Contact Radiation Protection Personnel for ection Requirements to be ents met prior to entry High Radiation Area Dose Rate Meter Requir For Entry Contact Radiat'ion Prot Personnel for Requirem to be met prior to entry Additionally, the inspector noted a display that was posted in Unit 3 to remind personnel of the various types of radiological postings.
The inspector noted that the display was not in agreement with any of the postings observed above.
The inspector also noted that Unit 3 had changed the method for posting of Locked High Radiation Areas after an event involving an unauthorized entry into a HRA having dose rates in excess of 1000 mrem per hour (see Inspection Report 50-530/88-33).
Unit 3 started posting such areas as:
Locked High Radiation Area Contact Radiation Protection Personnel for Requirements Prior to Entry
The inspector'concluded that the signs;were;ambiguous.
A review of procedure 75RP-OZZ01,
"Radiological Posting," provides a
categorization and definition of radiation areas and high radiation areas; however, a definition of or categorization for locked high radiation areas is not clearly described in the procedure.
Similarly, the procedure-fails to provide clear-and concise instructions on how to make, a distinction between high radiation areas and locked high radiation areas.
The inspector brought this observation to the attention of the
,licensee staff during the inspection and at the exit interview.
The inspector was informed that the Radiation Protection Standards group was in'the process of evaluating the inspector's concern.
~ e.
The worker who made the."allegation described in paragraph 5, herein, informed the inspector.that he had received some unsavory remarks from the Unit 2 staff for notifying the NRC of his concerns.
Additionally, the inspector was informed by several other workers that they had been cautioned about talking to NRC inspectors and were told they should not talk to NRC inspectors.
The inspector discussed this observation at the exit interview.
The
'Vice President Nuclear Production stated that ANPP management has an'd will always encourage workers to talk freely to the NRC whenever they are unable to res'olve their concerns by first going through the
"Hot Line" or with ANPP supervision and management.
The Vice President added that the inspector's concerns would be taken seriously and efforts will be made to reso'Ive the item.
7.
Exit gnterview 30730 The inspector met with the licensee representatives listed in paragraph
at the conclusion of the inspection on September 23,-1988, and on October 7, 1988.
The scope and findings of the inspection were summarized.
The licensee was informed that no violations or deviations were identified.
The inspector informed the licensee that this and previous inspections, conducted in the past five months, disclosed that procedures lacked the specificity that is necessary to ensure that the radiation protection program is implemented in a consistent manner from Unit to Unit.
The inspector added that the lack of clear and concise instructions in procedures has the potential of leading to violations.