IR 05000528/1989007
| ML17304B115 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/31/1989 |
| From: | Block S, Cillis M, Essig T, Garcia E, Prendergast K, Tenbrook W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B114 | List: |
| References | |
| 50-528-89-07, 50-528-89-7, 50-529-89-07, 50-529-89-7, 50-530-89-07, 50-530-89-7, NUDOCS 8904240154 | |
| Download: ML17304B115 (56) | |
Text
U ~
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.:
50-528/89-07, 50-529/89-07 and 50-530/89-07 License Nos.:
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Public Service Company P.
0.
Box 21666 Phoenix, Arizona 85836 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at: Wintersburg, Arizona Inspection Conducted:
February 13-17, 1989 Inspectors:
M. Cillis, Senior Radiation Specialist Team Leader, Region V
-~.P =4 T.
H. Essig, Chief, Radiation Protection and He 1th Effects Section, NRR S.
Bl ck, Health Physicist, Region V
K.
M. Prendergast, Emer ncy Preparedness Analyst, Region V
W.
K. Tenbrook, Radiation Specialist, Region V
Approved by:
E.
M. Garcia, Acting Chief Facilities Radiological Protection Section mls Date Signed a ~uk Date Signed 338 g Da e
igned
3 Date Signed 3 po/g Date Signed Ol~r/'rr Date Signed
~Summar a ~
corrective actions for violations and deviations, routine followup actions, occupational exposure during extended outages, radiation protection, chemistry and radwaste organization and management controls, training and qualifications, maintaining occupational exposures As Low As Reasonably Achievable (ALARA), external occupatio&l exposure control, internal exposure control and assessment; shipping and transportation, emergency preparedness program and tours of licensee facilities.
Inspection procedures 30703, 82701, 83722, 83723, 83724, 83725, 83728, 83729, 83750, 92701 and 92702 were addressed.
8904240154 890403 PDR ADQCK 05000528
S
b.
Results:
No violations were identified in ten of the eleven areas addressed.
One unresolved item was identified regarding the adequacy of interim corrective actions implemented for deficiencies in the site-wide Public Address/Emergency Warning System (see section 5).
Licensee commitments for remaining inspection findings are summarized in section 7.
The licensee had made significant progress towards improving their radiation protection program and in the planning and preparations for the Unit 1 and Unit 3 refueling outages scheduled to start in March 1989.
Overall the licensee's programs were capable of meeting their safety objective DETAILS Persons Contacted
"J.
B. Haynes, Vice President, Nuclear Production
- W. C. Marsh, Plant Director, Nuclear Production
- L. G. Papworth, gA/gC Director
"W.
F. guinn, Director, Nuclear Safety and Licensing
"W.
E. Ide, Unit 1 Plant Manager
"D.
R. Heinicke, Unit 2 Plant Manager
"J.
E. Kirby, Director, Nuclear Production Support
"R.
M. Butler, Director, Standards and Technical Support
~T.
D. Shriver, Compliance Manager
"J.
N. Tench, Acting Director, Site Services
"D.
N. Stover, Acting Manager, Nuclear Safety
", K.
R. Oberdorf, Unit 1 Radiation Protection Manager A.
G. Ogurek, Unit 2 Radiation Protection Manager
"W.
E.
Sneed, Unit 3 Radiation Protection Manager H.
F. Bieling, Manager, Emergency Preparedness and Fire Protection
"J.
R.
Mann, Manager, Central Radiation Protection
"J.
M. Sills, Supervisor, Radiation Protection Standards
- T. S.
Barsuk, Lead Coordinator, Emergency Preparedness G. -Jones, Unit 2 Lead Radiation Protection Technician J. Gaffney, Unit 3 Lead Radiation Protection Technician K. Coon, Unit 1 Lead Radiation Protection Technician
.C.
F.
Brown, Training, Lead Instructor J.
W. Kestor, Supervisor, Radwaste Support R.
A. Buckhalter, Acting-Manager; Outage Management R.
B. Ochoa, Central Radiation Protection Dosimetry Supervisor M.
W. Lantz, Senior Radiation Consultant R.
V.
War nock, Radiation Protection Consultant to Plant Director (Southern California Edison)
"W.
H. Barley, Acting Site Radiation Protection Manager (Bartlett Nuclear)
K. Contois, Lead Dosimetry Analyst
"D. Coe, Resident Inspector (NRC)
"Denotes personnel present at the exit interview held on February 17, 1989.
In addition, the inspectors met and held discussions with other licensee and contractor personnel.
Ins ection Ob ectives The special team inspection was conducted to determine the effectiveness of recent licensee actions regarding:
a ~
Corrective actions to improve th'e radiation protection program as described in ANPP's timely responses, numbers 102-01070-DBK/TDS, dated December 19, 1988, and 102-01079-DBK/TDS, dated December 29, 1988, to the NRC s Notice of Violation (NOV) and Imposition of Civil Penalties report, dated December 1, 198 b.
ANPP's staffing, organization, planning and preparations to safely and effectively respond to the increased work load and operational challenges imposed by the overlapping outages scheduled to start at Unit 3 on or about March 6, 1989 and at Unit 1 on or about April 8, 1989.
C.
The effect of recent personnel management changes in ANPP's Emergency Preparedness organization.
3.
Followu of Previous Ins ection Findin s
a.
Followu Items 92701 Closed 50-528/87-24-03 and 50-528/88-13-04:
Inspection report 50-528/87-24 stated that the effects of major organizational changes on radiation protection, chemistry and radwaste would be examined during a subsequent inspection.
Inspection Report 50-528/88-13 identified that the Manager of Radiation Protection and Chemistry (RP&CM) and the Manager, Central Radiation Protection, had resigned from ANPP and stated that the licensee's actions to fill the vacancies would be reviewed during a subsequent inspection.
Section 4 describes the organization of the radiation protection, radwaste, and chemistry programs and what actions were being taken to fill the vacant RP8CM position, and other key positions.
The licensee's organization was consistent with Technical Specification 6.2 requirements, and the actions taken to fill vacant management positions were acceptable.
Closed 50-529/88-22-08:
-Radiation worker training and familiarity problems were identified during interviews to ascertain worker knowledge of contamination control, radiation areas and high radiation areas.
Corrective action had been implemented to improve the General Employee Training and Radiation Work Practices Training programs (see section 4.d. 1).
Closed 50-529/88-22-02:
This item concerned 'corrective actions taken to resolve problems associated with an over exposure reported by the licensee on May 23, 1988.
The implementation of these corrective actions is discussed in section 3.b of this report.
The licensee's performance in the areas addressed above was improving and was capable of meeting safety objectives.
No violations or deviations were identified.
b.
Followu on Corrective Actions for Violations and Deviations 92702)
The inspector examined corrective actions in response to violations described in the Notice of Violation and Proposed Imposition of Civil Penalties dated December 1, 1988.
The examination included:
Discussions with the licensee's staff.
Direct observations.
Review of licensee procedures and other related documents.
The following observations were made:
Closed Violation 50-529/88-22-04:
Pursuant to 10 CFR 20.409(b),
the licensee failed to provide a written statement of exposure to a worker who had received a whole body exposure in excess of the quarterly limits prescribed in 10 CFR 20.101(b)(1).
The inspector verified that the actions described in the licensee's reply, dated December 19, 1988, had been implemented.
Procedure 75AC-9RP01, Rev.
0 had been revised as indicated in the licensee's response to.the NOV.
Closed Violation 50-528/88-27-01 50-529/88-26-01 50-530/
88-25-01 and 50-529/88-37-01:
This violation concerned the failure of the licensee's staff to implement the ALARA program in accordance with established procedures.
Problems identified included the following:
Failure to conduct monthly ALARA committee meetings.
Failure to conduct pre-job and post-job ALARA reviews.
Failure to conduct an annual evaluation to determine the ALARA program effectiveness.
The following documents were reviewed to determine actions taken by the licensee to prevent recurrence:
Memorandum (Memo) ¹215-00501-JRM, dated April 28, 1988, entitled:
"ALARA Committee Meeting" Memo ¹215-00502-JRM, dard May 9, 1988, entitled:
"ALARA Committee Meeting" ALARA Committee Meeting minutes, No. 88-1, dated May 11, 1988 Memo ¹215-00526-JRM, dated June 15, 1988, entitled:
"ALARA Committee Meeting" ALARA Committee Meeting minutes, No. 88-2 dated June 24, 1988 Memo ¹215-00552-JRM, dated July 28, 1988, entitled:
"ALARA Committee Meeting" ALARA Committee Meeting minutes, No. 88-3, dated August 5, 1988 Memo ¹215-00575-JRM, dated September 8, 1988, entitled:
"September ALARA Committee Meeting".
ALARA Committee Meeting minutes, No. 88-4 dated September 14, 198 Memo ¹215-00628-JRM, dated November 18, 1988, entitled:
"Clarification of Central Radiation Protection Organization" with memo ¹215-00571-JRM, of September 20, 1988 as an attachment.
Memo entitled "Central Radiation Protection - Radiological Engineering/Outage Support Groups - Organization Plan" Procedure 75PR-ORP03, Rev.
0,
"ALARA Program" Procedure 75AC-9RP11, Rev.
0,
"ALARA Committee" Procedure 75AC-9RP12, Rev.
0,
"ALARA Reports" Procedure 75RP-9ZZ94, Rev. 4,
"ALARA Pre-Job Review" Corrective action taken by the licensee included revisions to the above listed procedures.
The revisions redefined the ALARA Committee membership.
The ALARA group was reorganized with clarified responsibilities, and a
new ALARA supervisor was appointed.
Procedure 75RP-9ZZ44,
"Radiation Exposure Permits" was revised to provide clear guidance to radiation protection technicians and redefined their roles in completing ALARA pre-job reviews.
The revised procedure tasked each Unit Radiation Protection Manager with assuring that all required pre-job reviews are completed before the job begins.
Additional information related to this subject is included in section 4.c of this report.
The inspector concluded that the corrective actions taken were consistent with the commitments documented in the licensee's response to the NOV.
Closed Violations 50-529/88-22-01 and 50-529/88-22-03:
The licensee failed to make surveys necessary to evaluate the extent of a radiation hazard, resulting in an individual receiving a whole body dose in excess of 10 CFR Part 20.101(b)(1) limits.
The inspector verified that the following corrective actions had been implemented:
Prohibiting the individual receiving the overexposure from working within a radiation controlled area for the remainder of the second quarter of 1988.
Providing the individual receiving the overexposure with a copy of his exposure record in accordance with 10 CFR 20.409.
Revising the "Radiological Surveys" procedure 75RP-9ZZ46 to clearly define the proper methodology to be used in conducting pre-job surveys.
Developing a plan to adequately decontaminate the fuel transfer canal during future outage Evaluating the design of the Spent Fuel Pool Cooling System for improvements to the filter and drain system.
A memo issued to all radiation protection personnel reminding them of their responsibility to monitor working conditions and stop work if warranted.
Personnel were reminded of their right to elevate concerns to the appropriate level of management until resolution is obtained.
A memo issued by the Unit 2 Plant Manager to the Radiation Protection Manager (RPM), directing him to maintain open communication within the radiation protection department.
A memo issued by the Radiation Protection Standards Supervisor to Unit RPMs and Lead Technicians discussing thumb rules and the need to perform detailed surveys in potential hot particle areas.
A policy statement concerning the definition of pre-job survey (versus a routine survey)
was issued to all radiation protection personnel.
The policy statement emphasized the need to identify all interferences and radiological hazards in the work environment.
Radiation protection personnel were trained on procedure revisions and were required to review the Special Plant Event Evaluation Report (SPEER) associated with the overexposure incident.
The Radiation Protection Standards Group increased the frequency of Unit tours to assist in the identification and correction of observed deficiencies.
Enhancements in the area of pre-job planning were implemented.
These enhancements included the involvement of all levels of personnel ranging from the worker to the Plant Manager.
An evaluation of the ALARA and Radiation Protection Programs was completed.
The details of this evaluation and the corrective action implementation schedule are discussed in section 4.b.2 of this report.
Completion of the corrective actions described in Attachment 4 of the licensee's December 29, 1988 response to the NOV, were found to be tracking on schedule.
Items I, II, III, IV, VI and VII have been completed.
Item V was scheduled for completion in December, 1989.
Item VIII, involving the need for supervisory skills training, had been approved.
However, the training was not expected to be completed until June or July 1989.
Discussions were held with the licensee's staff regarding the selection, promotion, and training of Senior Radiation Protecti'on Technicians (RPT) to Lead RPTs in support of the Unit 1 and Unit 3 outages.
The Unit 3 RPM had been counseling the Lead RPTs that he had selected for the outage,
but formal supervisory training had not been given.
The licensee committed to provide the Unit 1 and 3 Lead RPTs with formal supervisory skills training prior to the start of the outages (50-528/89-07-01, 50-530/89-07-01).
Closed Violations 50-529/88-22-07 and 50-529/88-26-03:
The licensee failed to properly post and maintain high radiation areas locked in accordance with Technical Specification 6. 12.
The inspector verified that the actions indicated in Sections II.A.4, II.B.3 and II.B.4 of the licensee's reply, dated December 29, 1988, were complete and sufficient to prevent recurrence.
0 en Violation 50-530/88-33-01:
The licensee failed to control personnel access to a locked high radiation area in accordance with Technical Specification 6. 12.2.
The inspector reviewed the status of corrective actions delineated in Attachment 3,Section II.C.4 of the licensee's reply to the NOV.
The following observations were made:
Corrective actions involving items II.C.4. 1, II.C.4.2, II.C. 4. 3, II.C. 4. 6 and II.C.4. 7 of Attachment 3 to the NOV have been completed.
Corrective action on item II.C.4.5, involved the replacement of locking mechanisms to prevent entry into current locked high radiation areas.
The licensee had decided to replace the locking mechanisms.
Installation of the locking mechanisms would be completed after receipt.of the hardware in May 1989.
Cerrective action II;6:4.3.involved-the development of administrative controls for issuing dose rate instrumentation.
The resolution of this item was still pending.
The inspector expressed concern over the timeliness in resolving this item, in view of the fact that the incident involving inadequate control over the issuance of dose rate instrumentation occurred in September 1988.
Additionally, during the inspection a Lead Operations Support Technician in Unit 1 was asked if he would loan a dose rate instrument to another worker or an NRC inspector, if so requested.
The Technician's reply was yes.
It should be noted that the licensee's evaluation of the unauthorized high radiation area entry recommended that a policy be established to require personnel to obtain dose rate instruments strictly from the radiation protection group.
The policy was established in Unit 3 shortly after the incident occurred.
However, it was not clear to the workers that the policy had been established at Units 1 and 2 as well.
This observation was brought to the licensee's attention.
A "night order" was issued in Units 1,
and 3 during the inspection.
The "night order" assigned the licensee's radiation protection staff as the only group authorized to loan dose rate instruments to groups and/or workers requiring their us '
The inspector will verify the licensee's corrective actions for high radiation area locks and control df dose rate'nstruments during a subsequent inspection.
This item will remain open.
The licensee's performance in this area showed a slight improvement.
The program was capable of meeting its safety objectives.
No violations or deviations were identified.
4.
Occu ational Ex osure Durin Extended Outa es/Shi in and Trans ortation 83722 83723 83724 83725 83728 83729 and 83750 a.
Audits and A
raisals Audits and appraisals are addressed in Region V Inspection Report 50"528/89-03, section 2. a and other sections of this report.
b.
Chan es Involvin Radiation Protection Or anization and Mana ement Controls l.
Evolution of Current Controls As initially discussed in Inspection Report No. 50-528/87-24, the licensee s radiation protection organization, along with other major components of the licensee's onsite management configuration, underwent major changes in November 1987.
In summary, these changes entailed restructuring from a totally centralized radiation protection function to a matrix organization.
The matrix organization consisted principally of three components which have responsibility for various facets of the radiation protection program.. One component of the organization was the assignment of a Unit Radiation Protection Manager at each of the three units.
The Unit RPMs were responsible for the day-to-day implementation of the radiation protection program for the Unit to which they were assigned.
A second component of the radiation protection organization was the Central Radiation Protection Department.
This Department provided site-wide support, such as dosimetry, instrument calibration, radiological engineering (ALARA technical support),
and procurement of major support equipment for outages.
The third component of the radiation protection function was vested in the Radiation Protection and Chemistry Department (RP8C).
In addition to radiation protection, RP8C Department also had programmatic responsibilities for chemistry and radwaste.
Radiation protection activities for which the RP8C Department was responsible included procedure and program development, engineering assistance, and oversight (auditing)
of the Unit radiation protection programs.
The manager of the RP8C Department was also designated as Site RPM.
As such, he established the radiation protection policy and program which was implemented by the Unit RPMs as matrix subordinates.
A memorandum dated October 4, 1988 from J.
G.
Haynes (File 0
88-001-731)
was issued to key management staff in order to clarify the division of responsibilities amongst the three components of the radiation protection organization.
Following its creation in November 1987, the new radiation protection organization experienced difficulties during its implementation.
In early 1988, managers of two key positions, Central Radiation Protection and Radiation Protection and Chemistry, resigned their positions, as noted in Inspection Report No. 50-529/88-13.
In addition, numerous staff voiced their unsolicited:opinion, as referenced in Inspection Report No. 50-528/88-27, that the new organization was not working well and that the effectiveness of the program had been reduced.
Because of these perceptions and the fact that major outages were due to begin during March and April 1989 for Units 3 and 1, respectively, a key aspect of the current inspection included an examination of the effectiveness of the current radiation protection organization and its ability to support the upcoming outages.
Or anizational Effectiveness Interviews and reviews were conducted with the Vice President, Nuclear Production, and selected members of the management hierarchy to determine:
(1) management philosophy and attitude towards radiation protection, i.e., the extent 'to which radiation protection, including ALARA practices, was a part of each individual's responsibilities; and (2) whether organizational functioning difficulties had been remedied sufficiently to ensure effective functioning and support during the Spring 1989 outages.
The licensee had established company-wide goals and objectives which address broad topics, including radiation protection, and which cover a 5-year period.
These goals and objectives were updated on an annual basis and were implemented throughout the organization by way of an "Action Plan" which ensures that every employee shared in the overall goals and objectives.
This Plan ensured support and accountability across the entire organization through the inclusion of a proportionate share of goal-meeting responsibility in each employee's annual performance appraisal.
The two vacant management positions mentioned previously had been filled, one permanently and one on an interim basis.
The position of Manager, Central Radiation Protection Department, had been filled by an experienced Certified Health Physicist from the corporate staff.
This individual met the Regulatory Guide 1.8 qualifications for the site RPM and had acted in this capacity on an interim basis.
An individual designated to permanently fill the position of Site RPM and Manager, RP8C had been hired and was due to begin his employment with the licensee on or about March 13, 1989'uring the inspection, this individual was serving as the Regulatory Guide Cl
supplement its staff with individuals obtained from contractors.
However, the management wi 11 be entirely in-house.
For the Unit 1 outage (scheduled to begin on April 8, 1989) the licensee had purchased an Integrated Work Package from Westinghouse; therefore, the management and staffing would be a mixture of in-house and contracted resources.
Licensee management staff members indicated that the integrated work package approach was necessary in order to effectively manage two outages which were nearly concurrent.
At the time of this inspection, Unit 3 outage planning was in its final stages.
Nearly all outage tasks having an estimated collective dose in excess of 10 man-rem (the licensee's threshold for ALARA Committee review)
had been reviewed by'he ALARA Committee; the last 8-10 tasks were under review at the time of the inspection.
Key outage management positions to support two 12-hour shifts per day had been identified and a staffing plan formulated.
Routine outage meetings were held to discuss and resolve any last-minute questions or concerns.
Members of the radiation protection staff attended each meeting.
Members of the inspection team attended a Unit 3 outage meeting which was held during the inspection.
During this meeting, the Vice President for Nuclear Production outlined corporate philosophy for the outage in the areas of safety (radiological and industrial), cooperation among staff, control of outage scope, and cost control.
He specifically emphasized that if a procedure is not understood by the individual performing the work, the work should not be continued; he also emphasized that radiation protection responsibilities go well beyond the organizations having radiation protection in their title.
Unit 1-outage pl.arming had-not progressed as -far as -that for Unit 3 primarily because the outage:
(1) was scheduled to begin one month later, and (2) would have a large fraction of the work entailing radiation exposure performed and supervised by contractors under an integrated work package arrangement.
The licensee had not attempted such an approach previously.
Under the contract terms, The Westinghouse supervisors for radiation protection activities would report to the Unit 1 RPM, rather than the contractor's project manager.
Other key organization interfaces and points of control were identified by the licensee during a meeting with the inspectors.
Licensee representatives stated that the contractor would be required to follow ANPP radiation protection procedures.
In addition to staffing and organization issues, the licensee had also been addressing facilities and equipment needs.
Non-expendable items, such as auxiliary ventilation equipment, respiratory protective equipment, and instrumentytion, were procured and maintained through the Central Radiation Protection Department.
The inspectors noted that a considerable number (approximately half) of the nearly 1400 items in the radiation protection equipment inventory were located at the calibration facility, most of which were tagged out of service and awaiting repair.
The licensee had recognized this problem and had plans underway to address it.
Expendable items, such as protective clothing and plastic bags, were procured by each uni The Central Radiation Protection Department had also been providing pre-outage support to both units in the radiological en'gineering and ALARA areas.
Several individuals were interviewed to determine their knowledge of the current ALARA program and to ascertain if the individuals understood their responsibilities associated with the implementation of the ALARA program as described in procedure 75PR-ORP03,
"ALARA Program" and in several
"position descriptions" for selected individuals.
Workers that were questioned appeared to have a good understanding of the ALARA concept and were generally aware of their need to use good work practices to maintain their exposures ALARA.
However, the current. ALARA supervisor, several lead radiation protection technicians and some individuals from the ALARA support group did not clearly understand their responsibilities in the implementation of the ALARA program and several felt that the current program was in need of improvement.
This observation was brought to the licensee's attention during the inspection.
The inspectors were informed that plans had been initiated to redefine the ALARA organization and to implement a new ALARA program.
The licensee had expected to implement the new program by March 31, 1989.
The licensee added that the previous program was being enforced as the new ALARA program was initiated in. parallel.
The inspector expressed concern over the knowledge of the ALARA program by key individuals in responsible positions.
The inspector also expressed concern over the timeliness of the new ALARA program implementation, considering that Unit 3 was to begin an outage before the new program was formally implemented.
In response to these concerns, the Vice President, Nuclear Production, committed to completion of ALARA-training and to the.issuance of-the new ALARA program implementing procedures by March 1, 1989.
This item will be examined during a subsequent inspection (50-528/89-07-03).
The proposed reorganization of the ALARA program involved two first-line supervisors in charge of ALARA activities.
The ALARA Supervisor would become the Radiological Engineering Supervisor in support of Unit R. P.
and ALARA planning during normal operations.
The Outage Support Supervisor would be assigned to direct ALARA activities and R.P.
support for outages.
The licensee was proceeding with this organization as consistent with current ALARA procedures.
The reorganization effort was expected to bring additional first-line supervisory attention to ALARA for outage work and to place more responsibility for implementing the ALARA program in the Unit Operation and Radiation Protection Organizations.
The inspector evaluated the system for issuance, administration and tracking of Radiation Exposure Permits (REP).
The evaluation included examination of Unit REPs during visits to the Unit controlled area access points, interviews of Unit R.P.
personnel regarding REPs, and queries for information from the Radiological Records and Access Control System (RRACS).
The following weaknesses were identified:
No REPs were observed at specific job sites, whereby workers could review protective requirements and take appropriate precautions to minimize their exposure.
General data on radiological conditions (e.g.,
contamination, airborne levels, radiation levels)
was omitted from virtually all Unit 3 REPs.
This same observation was made at Unit 1 and 2.
Unit 3 REPs required that workers contact radiation protection personnel for recent survey data prior to entry.
The inspector observed workers requesting access to controlled areas.
These workers were granted access without consultation as to current radiological conditions.
The inspectors brought the above observations to the licensee's attention during the inspection and at the exit interview.
The licensee committed to evaluating methods for disseminating the radiological conditions to workers at the job site and on the REPs.
This item will be examined during a subsequent inspection (50-528/89"07"04).
Procedure 75RP-9ZZ44,
"Radiation Exposure Permits,"
Procedure Change Notice Ol, provided for initial person-rem estimates for each REP by Unit R. P.
The inspector observed that all collective exposure estimates for Unit 3 REPs were less than one person-rem.
These estimates were inconsistent with the estimates on Unit 1 REPs.
The inspector inquired which Unit 3 REP had the greatest collective exposure and requested that Unit R.P.
determine the actual collective exposure for the year to date using RRACS.
REP 3-89-001A, "Radiation Protection Tours,"
had incurred 1.785 rem of actual collective dose between December 31, 1988 and February 16, 1989.
The REP expiration date was December 31, 1989, with a collective dose estimate of less than one person-rem.
The actual collective exposure was significantly higher than the anticipated annual-collective exposure:-
The inspector inquired as to the methods used to track collective exposure to reveal problems with initial collective dose estimates on Unit REPs.
The ALARA Supervisor, Central R.P., stated that Unit R. P.
had been receiving weekly reports of exposure incurred under active REPs.
The inspector examined the report for the week of February 9,
1989 to February 15, 1989.
Dose incurred for each REP during the week-long report period was presented, but total collective dose, year to date, was tracked only for the entire Unit, not by REP.
Graphs supplied with the report revealed that Unit 3 possessed a much higher percentage of REPs identified as "no collective exposure estimate" than other Units.
The ALARA Supervisor stated that discussions had been held between Central R.P.
and Unit 3 R.P.
regarding REP collective exposures.
These discussions had resulted in restrictions on the use of REP 3-89-001A for minor work coverage by R.P.
personnel.
No mechanism existed to modify REPs to reflect actual collective e>tposure data prior to incurring ten person-rem on an REP, the threshold for Central R. PE ALARA review.
The inspector, Unit 3 R. P.
Manager and Central R. P.
Manager discussed the weaknesses observed in collective dose estimation, tracking and corrective action for Unit REPs.
The Unit 3 R. P.
Manager and Central R. P.
Manager committed to address the weaknesses observed in their respective
areas.
Completion of licensee's corrective action will be tracked as a followup item (50-530/89-07-02).
The inspectors examined the implementation of the current ALARA program in support of the planned outages.
The licensee's Outage Support Group, Central Radiation Protection, had developed a list of outage tasks for ALARA review, drawn from work orders which had received initial collective dose estimates approaching or exceeding 10 person-rem.
The inspector examined the list of tasks and verified that the list contained all major outage work which would incur high collective exposures.
The following tasks were listed:
Reactor head removal and replacement.
Reactor cavity decontamination.
Steam generator eddy current testing.
Steam generator tube plugging.
Reactor coolant pump disassembly, decontamination and replacement.
Unit One pressurizer maintenance, unspecified.
Unit One low-pressure safety injection system work, unspecified.
Upender cavity work.
The inspector examined the ALARA review packages for steam generator eddy current testing, which included damming, surveys and other preparation, and the package involving reactor coolant pump decontamination.
The steam generator work package had been reviewed by the ALARA committee and returned to the Outage Support Group for additional detai-l." -The remaining packages were due -for review on February 16, 1989, with final approvals by the end of February 1989.
The licensee was successfully implementing the ALARA program in preparation for the outages.
The inspector and the Outage Support Supervisor, Central Radiation Protection, discussed the measures that would be in-place for control of work addressed by ALARA review.
The following activities were described:
Around-the"clock site presence by the Central R.P.
ALARA staff.
Tours by the Central. R.P.
Outage Support Staff to observe work for which ALARA reviews were performed, including interviews with workers and the radiation protection staff.
Most outage jobs would merit round-the-clock presence in the affected Unit.
Outage Support ALARA participation in job briefings and debriefings.
Daily dose evaluation and tracking by Unit, Radiation Exposure Permit (REP), work group, and individual.
The proposed actions to monitor work from an ALARA standpoint were acceptable.
ALARA collective dose goals of 304 person-rem for Unit 1 and 140 person-rem for Unit 3 had been established strictly for the
refueling outages covering an approximate 69 days in Unit 1 and
days in Unit 3.
The goals were satisfactory for keeping radiation dose ALARA.
The licensee had included provisions for augmenting the staff of Unit 1, Unit 3 and Central Radiation Protection organizations with contractors during the outages.
These provisions included the following:
140 Senior Radiation Protection Technicians 81 Junior Radiation Protection Technicians 15 Dosimetry Technicians and Clerks 10 Senior Radwaste Support Technicians 29 Junior Radwaste Support Technicians 2 Health Physics Advisors (Unit 3)
6 Lead Radiation Specialists (Unit 1)
The above values did not include the contractor radiation protection staff that are expected to support the Unit 1 integrated refueling work package discussed above.
An additional contractor staff of 51 Senior Radiation Protection Technicians and four ALARA Engineers was included as part of the Unit 1 Westinghouse integrated work package.
The Unit 1 Westinghouse Integrated Work Package contract contained several incentive penalties specified by the licensee.
The incentives included penalties for poor work performance in the area of ALARA and penalties for failure to comply with regulatory requirements.
Based ~n a review of work. in progress, radiation protection support.
equipment on-hand and in various stages of procurement, and planned staff augmentation, it was concluded that the licensee's state of preparation for the Unit 1 and 3 outages was adequate.
No violations or deviations were identified.
Trainin and uglification of New Personnel 1.
General Em lo ee Trainin GET and Mocku Trainin The inspector examined the licensee's training program for personnel having responsibilities within Radiologically Controlled Areas (RCA), particularly during the refueling outages scheduled at Units 1 and 3.
Members of the licensee's training staff were interviewed, training lesson plans and examinations were reviewed, and the licensee's enhanced Radiation Work Practices (RWP) training program classes were observed.
Mockup training classes for steam generator eddy current testing were also observed.
The following observations were noted:
There were 9 permanent full-time instructors and 7 contractor instructors involved in general employee and mock-up training.
The contractor instructors were recently hired to support the heavy demand placed on training in preparation for the upcoming
outages for Units 1 and 3.
Discussions with training program management indicated that plant management had bee'n very supportive of the training program and that staffing levels were adequate to complete the necessary training for the outage.
Instructor qualifications were discussed.
The lead instructor verified that all permanent instructors had completed Initial Instructor Training and the required annual retraining on Techniques of Instruction.
In addition, all instructors were stated to have at least 3 years experience in their respective disciplines.
The instructor qualifications met ANSI requirements.
RWP lesson plans and Advanced RWP lesson plans had been recently upgraded to place more emphasis on posting of High Radiation Areas (HRA) and to include a discussion of radiological problems encountered by the licensee.
Advanced RWP training had been lengthened from 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to ll hours to provide increased emphasis on the posting of Radiation Areas, precautions for hot particle areas, special requirements for entry into HRAs, radiation exposure permits and the significance. of reading and signing the REP.
The lesson plans also included discussions of recent incidents at the site including overexposures, unauthorized entry into a HRA, and problems identified by site RP.
.Hands-on practical training included a practical dress out exercise involving equipment repairs in a simulated contaminated area, monitoring for contamination, passing samples or equipment across a step-off pad, removal of protective.clothing. and proper-survey techniques.
After the tasks were performed, discussions were held to identify the mistakes made and to demonstrate correct methods.
The instructors also stated that personnel have been requested to go through the practical exercise again if they do not demonstrate acceptable performance.
The examinations for RWP and Advanced RWP training contained questions from the topics mentioned above, and were adequate.
The inspector also observed mock-up training for personnel working on Steam Generators during the outage.
The training was scheduled to take approximately 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> and was conducted under conditions similar to those which the workers will be subjected to during the outage.
The facility contained a scale replica of a steam generator and associated tools and equipment that would be used during the outage.
Part of the training for the installation of nozzle dams was observed.
The tr aining was completed in stages, with each step becoming more difficult as proficiency was gained.
The training was escalated to performing the required tasks in full working gear once proficiency had been achieved.
The instructors timed the tasks and tested the adequacy of the work done.
Video replays and discussions were effectively used to improve proficiency.
Radiation Protection personnel, for the outage also participated in the mock up training.
The instructors were knowledgeable in
their discipline and professional in their methods.
Interviews with the students revealed that some individuals had previously worked on steam generator maintenance during previous outages.
Inspection Reports 50-528/88-33 and 50-528/88-42 identified several concerns raised by ANPP and contractor staff about being cautioned not to speak to NRC personnel.
At a December 1,
1988 Management Meeting, the Executive Vice President committed to initiate an independent investigation to determine the validity of the concerns raised by the ANPP and contractor staff.
A review of the licensee's General Employee's Training program and the independent investigation was conducted.
The following observations were noted:
The licensee polled 169 persons by questionnaire to determine if they had been intimidated or discouraged from bringing safety concerns to the NRC's attention.
Sixty-five employees stated that no intimidation was perceived.
One anonymous response was received which indicated an employee suffered repercussions for identifying concerns to the NRC.
The licensee's investigation concluded personnel had not been discouraged from or reprimanded for presenting problems to the NRC.
During a review of the materials presented during the licensee's site access training course, the inspectors noted that a certain hierarchy had been recommended to employees regarding the processing of employee's concerns relative to gA problems/nonconformances.
This hierarchy stated that the"employee should voize-such concerns in the following order:
1) employee's immediate supervisor, 2)
gA Hot Line, 3)
ANPP top management (Vice President and above),
and 4) the NRC.
The foregoing scheme for reporting of concerns had the potential for hindering the reporting of safety concerns by employees to the NRC in accordance with 10 CFR 19. 15(b)..
Some employees may have viewed the requirement to discuss their concerns with ANPP top management prior to informing the NRC as intimidating.
The above observation was brought to the licensee's attention.
The licensee took immediate steps to review the training program lesson plans and video tapes.
From the review of the training lesson plans and video tapes, the licensee's staff stated they could see where ANPP's open door policy for workers to express concerns to the NRC without fear of recrimination may be miconstrued as being intimidating.
The staff added that the training program will be revised accordingly.
This item will be examined during a subsequent inspection (50-528/89-07-05).
Additional improvements planned for the training program included increased in-plant time for instructors to maintain proficiency in their discipline and methods to expedite processing of new personne Licensee performance in this program area indicated improvement in the GET and mockup training.
The GET program was consistent with 10 CFR 19. 12, "Instruction to Workers" regulatory requirements.
No violation or deviations were identified.
ualifications and Trainin of Contractor Radiation Protection Technicians The licensee had taken steps to enhance the selection criteria for contractor Radiation Protection Technicians meeting the qualifications prescribed in ANSI/ANS 3. 1-1978,
"American National Standard for Selection and Training of Nuclear Power Plant Personnel."
The inspector reviewed resumes for Senior Radiation Protection Technicians (SRPT) candidates and Junior Radiation Protection Technician candidates for the Unit 1 and Unit 3 outages.
The licensee selection criteria was much improved over the selection criteria used during the outage at Unit 2 in the spring of 1988.
In addition, a pre-employment screening examination had been established and an enhanced training program had been implemented as discussed herein.
The review of resumes disclosed that the majority of SRPT candidates exceeded the qualification requirements prescribed in ANSI/ANS 3. 1-1978.
One SRPT candidate did not meet the qualification requirements of ANSI/ANS 3. 1-1978.
Another was given credit for almost five years more experience than was actually indicated on the individuals'esume.
There were eleven to fourteen others that appeared to be marginally qualified to ANSI/ANS 3. 1-1978 requirements.
Some of these iedividuals had not been involved in radiation-protection duties for several years prior to applying at ANPP.
The above observations were brought to the licensee's attention.
The licensee s staff took immediate action to verify the qualifications of all contractors being considered for SRPT positions.
The inspector was informed that the offer made to the individual not meeting the qualifications of ANSI/ANS 3. 1-1978 would be withdrawn and/or the individual would be offered a position that is commensurate with his actual qualifications.
The inspector commended the licensee for these actions.
The licensee's staff informed the inspector that they would be more observant in the future when reviewing resumes and intend to perform additional reference checks and possibly conduct oral interviews with SRPT candidates.
The inspector reviewed examinations and lesson plans for site-specific contractor radiation protection technician training.
The inspector also interviewed contract R. P.
technicians that had completed the site-specific training.
The course consisted of approximately forty hours of classroom training with job performance measure demonstrations.
Subject matter emphasized the licensee's procedures for decontaminations, surveys, alarm and incident responses, respiratory protection and radioactive material control.
The
inspector's review of the final examination and interviews with students established that the examination was appropriately difficult, although some questions and multiple-choice answers were considered ambiguous.
Interviews with the students indicated that the training was more thorough than the industry norm.
Contractor personnel who were experienced in radiological protection and were being considered for positions such as SRPTs during the outages were required to successfully demonstrate their knowledge of health physics by passing a
pre-employment screening examination.
The examination contained a broad base of health physics and industry-specific radiological questions.
Individuals receiving a score of less than 80 percent on the screening examination were not selected as SRPTs.
Once the screening pre-test was satisfactorily completed, the individuals were given bypass training for site access and RWP training.
Bypass training lasted approximately ll hours, with a portion of the training done by computer.
The practical dress-out and discussions of radiological incidents was still required.
Next, three hours of respirator training and two hours of self-contained breathing apparatus training are performed, as necessary.
The inspector examined the screening test on the plant computer.
Access to the test was tightly controlled.
The questions covered broad areas of health physics, mathematics, radiation protection, and were sufficiently difficult.to be used as a screening tool to insure experienced workers were knowledgeable and had sufficient background in radiation protection to perform their responsibil-it$ es.-
The licensee's program for selecting and training contractor radiation protection technicians was acceptable and improving.
External Ex osure Control/Internal Ex osure Control The inspector examined the licensees'ersonnel external and internal dosimetry program with respect to normal operations and the
'ending Unit 1 and Unit 3 outages.
The inspector reviewed all relevant instrumentation, instrument inventory, procedures for personnel dosimetry (whole body, extremities, skin) and whole body counting, calibration facilities, equipment and procedures, calculational models, instrument maintenance programs, training of contractor radiation protection technicians to use survey instruments, and recordkeeping.
Discussions were held with licensee dosimetry personnel to address the aforementioned review items.
l.
External Dosimetr The licensee's external and internal exposure control programs had not changed from what is described in Region V Inspection Reports 50-528/88-13, paragraph 7 and 50-528/87-38, paragraph 2(E)-2(F).
The licensee's personnel dosimetry program was National Voluntary Laboratory Accreditation Program (NVLAP)-
certified.
A recent NVLAP review confirmed the program was being implemented as required to maintain NVLAP certification.
The external exposure control program consisted of a state-of-the-art thermoluminescent dosimeter (TLD) system.
Self=indicating dosimeters (SID) were used for tracking daily accumulated exposures.
Units 1, 2 and 3 possessed a standard set of procedures for personnel dosimetry management.
The overall dose received by SID's and TLD's were compared against each other to ensure personnel exposures were maintained within the administrative limits established by the licensee's external exposure program.
Anomalous readings were investigated by the licensee's dosimetry staff.
Personnel exposures were closely tracked in all Units by the Radiological Records and Access Control System.
The RRACS system assured accurate records and tracking of personnel beta, gamma and neutron doses to the whole body, extremities and skin.
No anomalies were noted in the records that were reviewed.
The licensee's external dosimetry program employed the use of multi-badging in non-uniform radiation fields, such as in steam generator repair and refueling cavity decontamination operations.
Upon completion of the work, the highest reading whole body dose was recorded as a separate entry and was added to the individual's TLD badge by the RRACS system.
Extremity and skin doses were added as separate entries.
Personnel. SIDs-were-changed for each entry.and-exit from different radiation areas, so readings were computerized to track with the TLD badge.
RRACS provide the tracking necessary to accomplish this.
Records showed that out of 2000 SIDs, only 20 did not track with TLDs (e. g. using different dosimeters at different areas each with a low reading that is recorded as zero dose, would not integrate as a TLD dosimeter would).
Individuals had ready access to their dose records by a phone call or by review of dose records in a ledger available to all personnel.
Internal Dosimetr The licensee's whole body counting system utilized a Canberra Fastscan incorporating two NaI scintillation crystals, each 4" x 4" x 16", which counted personnel in a standing position, and a Canberra Accuscan, a moving bed with a single stationary NaI detector of 4" x 4" x 16".
The Fastscan was normally operated for 2 minutes to whole body count an individual. If a positive count was found, the counting time was extended to 4 minutes.
The Accuscan was typically operated for 6 minutes, but was extended to 12 minutes to investigate 1X body burden results.
At 5X body burden, a followup bioassay was performed.
Calibration was performed with REMCAL phantoms.
There were a
total of 8 radionuclides in the phantom yielding 10 photopeaks
including Cd (88 keV) and Y (1.836 MeV).
All sources were 109
traceable to the National Institute of 'Standards and Technology.
Fastscan system sensitivity was 3 to 5 nCi detectable in a 2 minute count.
Canberra stated an error of
+50% which is acceptable for this type survey.
The whole body counting systems identified radionuclides and calculated body burden.
The organ dose and Maximum Permissible Concentration-hours (MPC-hours) were computed from the body burden results.
ICRP 2 or ICRP 30 were used for the calculations.
The licensee planned to acquire a germanium system to replace the NaI to fulfillrevised Part
requirements for dose evaluation.
Canberra was developing such a system and would provide relevant training.
Whole body counting printouts were stored in personnel files.
For internal dosimetry there was no computer tracking.
All dose calculations were performed manually.
There have been rare uptakes, and MPC-hours had been formulated in accordance with 10 CFR 20. 103 whenever uptakes occurred.
Surve Meter Instrumentation An adequate complement of survey meters was available for the outage (i.e.
120 survey meters of all types at each unit, plus miscellaneous meters available at the waste and EP facilities).
However, about 700 survey meters were in the maintenance shop with 50 available for use.
This significant maintenance load was to be resolved by assignment of five additional contract I&C personnel to support the complement of maintenance technicians; "Also,-a-significant number of new instruments had been ordered to supplement available instruments.
The licensee's efforts to process the survey instrument backlog will be examined in a future inspection (50-528/89-07-06).
Calibration Facilit The calibration facility for instrumentation utilized a Shepherd semi-portable lead shj~)ded calibration system containing 200 Ci and 130 mCi Cs sources.
The 200 Ci source provided dose rate levels from 250 mR/hr to 1000 R/hr.
The 130 mCi source provided dose rates of from 0. 2 to 250 mR/hr.
Tungsten shields were used to change the dose rate levels during calibration.
For personnel dosimetry, a 1.2 Ci Cs source was used as the 137 calibration source.
Dosimeters were arranged in a circular array set at 60 cm with dose rates of 18 mR/min.
Calibration of neutron remballs was performed with a 10 Ci Am-Be source..
Dose rates had been established by Battelle-Pacific Northwest Laboratories at a geometry that considers scattering from adjacent concrete walls.
Calibration of personnel neutron dosimeters employed this source with backscatter phantoms that simulate body albed..
Hot Particle Dosimetr A meeting with ANPP staff was held for discussion of hot particle issues of concern during the outage.
The discussion started with the issue addressed in a memo, D.
B. Karner to J.
B. Martin, dated July 26, 1988, in which sorting trash that might contain hot particles was addressed, and the new procedure that had been adapted to preclude exposure.
This method incorporated survey of trash bags by pushing the detector into the bag to identify specific areas that are "hot" (instead of assuming that all activity is in the center of the bag).
The sorting was then performed, as per the memo, using tongs to remove trash as it was examined (i.e.
no hand contact).
Modified RO-2 ion chamber instruments were used for dose rate measurement.
The modified RO-2 incorporated polyfoam filling of the ion chamber to reduce active volume plus a
window slot to be used as a rectangular collimator.
The surveys were performed by experienced technicians.
All personnel involved in the operation wore extremity dosimeters.
Upon egress from hot particle control areas, a modified RO-2 was used to perform personnel monitoring if background was too high for frisker use.
Most positive readings from modified RO-2 instruments had been identified as radon decay products.
During personnel surveys, the modified RO-2 was used as a count rate monitor and not as a dose rate meter.
A conversion factor between dose rate and count rate was derived from an RO-2 reading 60 mR/hr as equivalent to a personnel frisker reading 250,000 counts per minute.
Wi'th appropriate geometry factors, the dose rate...was..converted to disintegrations per. minute.
Gamma spectrometry was also used to determine particle activity.
For dose estimates, values from Cross were used for mrem-cm~/uCi-hr rather than VARSKIN values, with no significant difference.
All skin dose estimates were from hand calculations since no algorithms have been developed by the licensee.
Personnel were trained for hot particle exposure evaluation by a training film, procedure study and study of rule-of-thumb aides.
All contractor technicians were to be trained as described above.
The licensee radiation protection group provided training oversight.
6.
Beta Surve Meter Dosimetr The procedure describing methods for skin dose estimates by portable survey meter readings was discussed.
The following equation was used to relate beta dose rate to open and closed window survey instrument reading:
Beta dose rate (mrad/hr) = (OW-CW) x BCF where:
I I
'I I
I
OW CW BCF open window reading for RO-2 or RO-7 closed window reading for RO-2 or RO-7 beta correction factor For the R0-2, BCF = 4, while for the 80-7, BCF = 1.
The RO-7 with a beta probe was normally used for steam generator measurements.
These factors were checked against TLD readings and were found to track very well.
Wipe surveys to determine beta energies during steam generator maintenance were planned.
7.
Airborne Radioactivit Nonitorin Fifteen continuous air monitoring systems (CANS) were calibrated and ready to operate for the outage.
8.
~Summar In summary, the internal and external radiation dosimetry programs were suitable for the anticipated work operations during the outages.
There was adequate equipment and facilities for monitoring personnel internal exposures, reading, processing, recording, storing and calibrating dosimeters.
A dedicated group of trained personnel was available to perform these functions and the programs were adequately organized and operated by a technically competent staff.
f.
Shi in and Trans ortation/Dr Active Waste Dis osition The licensee's.shipping and-transportation activities had not changed from what is described in Region V Inspection Report 50-528/88-42, section 3.
Discussions were held with the Radwaste Processing and Radwaste Services supervisors to determine what plans and preparations had been made to process the dry active waste generated during the Unit 1 and Unit 3 outages.
The supervisors stated that arrangements had been made to augment the radwaste support group with contract personnel to handle the increased workload during the outages.
Also, arrangements had been made to train the contractors and to coordinate the efforts of the Central and Unit Radiation Protection groups in support of the radwaste group.
The supervisors added that they had increased their inventory of supplies for the outages.
Both supervisors stated that they were prepared to handle the extra burden placed on them by the overlapping outages.
The back log of dry active waste accumulated during the Unit 2 outage of 1988 had been processed and'ould not present a problem for the Unit 1 and Unit 3 outages.
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5.
Emer The licensee's performance in this area was improving and was fully capable of meeting its safety objectives.
No violations or deviations were identified.
enc Pre aredness 82701 a.
Or anization and Mana ement Control e
The inspector examined changes to the site and emergency planning organizations prior to the Unit 1 and 3 refueling outages, the Emergency Plan and Implementing Procedures, and records of emergency response training.
Changes to the emergency response organization (ERO) that could impact emergency response were discussed with emergency preparedness staff.
The licensee had designated a plant director and director of site services to provide an upper layer of management over all three Units and to improve support of emergency planning functions.
This change was expected to improve the resolution of emergency planning issues affecting all three Units.
Some individuals in the ERO had not completed the training required for their new positions.
However, some of the organizational changes were very recent and Emergency Planning (EP)
had scheduled emergency response training.
The inspector examined records of emergency response training to insure that all key emergency
- response positions were covered by qualified individuals.
A sufficient number of trained individuals were available to fill all key emergency response positions.
However, EP implementing procedures and-administrative procedures-required updating to accommodate the new positions within the site organization.
Emergency Planning personnel stated they were aware of this problem and were planning a review of their procedures once the organization had stabilized.
The inspector will examine EP implementing procedures during the routine inspection program.
The inspector reviewed changes to the organization that had affected staffing for the Operations Support Center (OSC) Coordinator position.
A review of Implementing Procedure EPIP-12,
"Operational Support Center Activation," indicated the OSC Coordinator position would be filled by the I&C Foreman.
However, Administrative Procedure 16AC-OEPOI,
"Emergency Response Organization and Staffing," specified the affected Unit Work Control Manager for this position.
In addition, there had been changes in IBC scheduling affecting the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage of this position.
The EP staff stated that plant management had requested input from Operations and EP to resolve the issue of interim staffing for the OSC.
Records of training indicated there were 14 individuals who were qualified to fill the OSC Coordinator position.
The inspector will examine OSC staffing during the routine inspection program.
The inspector examined changes to the emergency planning organization.
ANPP had hired a new EP manager and had moved the site fire protection organization to the EP group.
The new Manager
of Emergency Preparedness and Fire Protection had been employed in the EP group for many years and was well qualified.
When asked if the incorporation of fire protection into EP presented any problems, the EP Manager replied that his duties for fire protection were primarily administrative, relying on the Supervisor of Fire Protection (FP) to implement the fire protection program.
The change had also resulted in more contacts with offsite agencies regarding fire protection and medical assistance, resulting in better coordination in response to an emergency.
EP had also acquired a new individual with operations experience, while two individuals had left EP for career advancement.
The licensee was interviewing candidates for their vacancies.
The changes had not resulted in any negative impact on the EP program the staff was qualified and adequate.
Contractor support was also stated to be available should it be needed.
Discussions were held to determine if the concurrent outages for Units 1 and 3 would impair the licensee's emergency response capabilities.
Emergency Planning was following the outage progress, but no changes or precautions were considered necessary.
Special accountability and evacuation arrangements were made for approximately 80 contractors constructing a
new Operations Support Building for Unit 2.
These arrangements would expedite accountability and evacuation using the contractor's personal vehicles.
According to the EP staff, outage personnel come and go from the site daily without encountering any special problems.
If a problem were to occur during the outage, personnel would be expected to go to their respective assembly areas, along with non-essential personnel, and evacuate the site if ordered.
As a positive note regarding the outage, there. would be more radiation
-protection personnel available to support emergency response.
Facilities and E ui ment The inspector examined essential emergency response facilities and equipment.
Instrumentation and supplies were maintained in a state of readiness.
Walkthrough tours of the Satellite Technical Support Centers (STSC)
and Operational Support Centers (OSC) for all 3 units were performed.
Instrumentation and supplies were contained in emergency kits as required by the implementing procedures and the equipment was operable and calibrated.
The OSCs and STSCs were well maintained and the supporting emergency documentation was current.
The inspector examined the licensee's systems for alerting and providing instructions to workers during an emer gency.
The licensee provided the inspector with the results of a study which identified 27 areas occupied on a normal basis where the public address system could not be heard.
Memos dated February 16, 1988 and May 20, 1988 indicated the licensee is planning improvements to the Site Wide Public Address System.
However, one of the memos was critical, stating that some of the problems were identified in 1983, with little positive action to address the safety concerns.
Public address system improvements were not scheduled to be completed until 1991.
Also, the licensee was unable to provide a complete listing
of interim protective measures for all the areas identified.
This program area requires further evaluation to'determine the adequacy of the interim protective measures.
This issue will be tracked as an Unresolved Item in order to ascertain whether it an acceptable item, a violation, or a deviation (50-528/89-07-07).
The Radwaste Buildings, Auxiliary Buildings and Instrument Calibration Facility of all three Units and the Laundry and Decontamination Facilities of Unit 1 were toured.
Independent radiation measurements were made using NRC ion chamber survey instruments, model R0-2, S/Ns 2694 and 2691, due for calibration on March 13, 1989 and April 26, 1989, respectively.
The following observations were made during the tours:
Housekeeping was excellent.
Radiation monitoring equipment was in current calibration.
Posting and labeling practices were in compliance with 10 CFR 19. 11 and
CFR 20.203.
Posting of radiation and high radiation areas was consistent in all three Units.
This represents an improvement from the observations documented in Region V Inspection Report 50-528/88-33, paragraph 6.
Work practices observed were consistent with the ALARA concept.
The gate to.the Unit 1 radiological waste storage yard was found open and unattended.
The inspector notified Unit 1 radiation protection personnel and,. with the assistance of ANPP radiological waste personnel, secured the personnel gate.
The licensee initiated a radiological problem report to document the occurrence and scheduled plant maintenance to repair the personnel gate the following day.
Access to the vital area from the waste yard was also checked and all entry points into the vitA area were noted to be locked.
The open and unattended gate was an isolated incident and satisfactory corrective actions were taken.
All personnel observed on tours were wearing proper dosimetry.
A zone identified as a high contaminated area and a hot particle zone in the Unit One decontamination facility was only partially partitioned from an adjoining clean area by a herculite barrier.
The boundary adjoining an ultrasonic bath near the sump room did not have a herculite barrier, only a posted rope barricade.
The licensee extended the herculite barrier in response to the observation.
Unit 3 Geiger-Mueller frisker instrument 965, located at the 100'evel auxiliary building elevator lobby, had a misprinted calibration due date.
The inspector informed the R.P.
desk of the erro t
During a tour of the Unit 3 control room, the inspector observed that the multipoint chart recorder 3J-SgA-RR-29 did not have a
properly installed strip chart.
This recorder provided a continuous record of indication on monitors RU-29, RU-31, RU-33, RU-37, RU-148 and RU-150, as discussed in the Safety Analysis Report.
Control room personnel obtained the most recent chart and found it to be several days out of date.
Work Order ¹00334725 indicated that a
recorder malfunction had been identified on January 17, 1989, and work was in progress February 20, 1989.
The licensee's methods to maintain records of continuous releases will be examined in a future inspection (50-530/89"07"03).
The licensee's performance in this area was adequate and capable of meeting its safety objectives.
No violations or deviations were identified.
7.
Exit Interview On February 17, 1989, the inspectors met with licensee management to discuss the scope and findings of the inspection.
The inspection findings were summarized by the Chief, Emergency Preparedness and Radiological Protection Branch, Region V, the inspection Team Leader, and the team members.
The licensee was informed of the Unresolved Item (50-528/89-07-08)
and the other Open Items identified.
The Vice President, Nuclear Production and his staff made the following commitments:
a 0 ANPP will verify the adequacy of the interim protective measures for alertieg and providing instructions in the 27-areas -where the public address system can not be heard.
Additional action will be taken to determine if the approved work package for the improvements to the Site-Wide Public Address System can be completed prior to the scheduled 1991 date (Unresolved Item 50-528/89-07-07).
b.
ANPP will provide Lead Radiation Protection Technicians selected for the outage with supervisory skills training prior to the outage.
(See Open Item 50-528/89-07-01, 50-530/89-07-01, section 3.)
C.
ANPP will implement the new ALARA program by March 1, 1989.
This included the issuance of the new ALARA program procedures and training of personnel to the new ALARA program requirements.
(See Open Item 50-528/89-07-03, sections 3.B and 4.C.)
d.
ANPP will complete a schedule of actions in response to the long-term corrective recommendations in memorandum
¹218-00670-JGH/WHB by August 1, 1989.
(See Open Item 50-528/89-07-02, section 4.b.2.)
e.
ANPP will evaluate the adequacy of the General Employee Training program to assure the program does not intimidate employees from reporting safety concerns to the NRC in accordance with 10 CFR 19. 15(b).
(See Open Item 50-528/89-07-05, section 4. d. l. )
ANPP will dissemination of radiological conditions (e.g. radiation levels, contamination levels, special precautions, etc.')
on REPs and survey maps to workers at the job-site.
(See Open Item 50-528/89-07-04, section 4.c.)
g.
ANPP will add additional resources to process the back log of radiation detection instruments requiring maintenance and/or calibration.
(See Open Item 50-528/89-07-06, section 4.e.3.)
The inspector informed the licensee that in spite of the above observations, it appeared that ANPP had made significant progress towards planning and preparing for the Unit 1 and 3 refueling outages.
The inspector added that improvements had been observed in the radiation protection program and that the recent management changes in the Emergency Preparedness organization had not impaired the Emergency Preparedness program.