IR 05000528/1989051
| ML17300B226 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1989 |
| From: | Cillis M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17300B222 | List: |
| References | |
| 50-528-89-51, 50-529-89-51, 50-530-89-51, NUDOCS 9001040057 | |
| Download: ML17300B226 (24) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/89-51, 50-529/89-51 and 50-530/89-51 License Nos.
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Public Service Company P.
0.
Box 53999 Phoenix, Arizona 85072-3999 Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at:
Miniersburg, Arizona Inspection conducted:
November 20, 1989 through November 22, 1989, November
through Oecember 1,
1989 and telephone calls of Oecember 5,
6 and 7, 1989 Inspection by:
~
i ss endor a
>a
>on pecla 1s ae inc PZ/y'pproved by:
arson, a la 1on pecla >st ate sgne
~Summer:
~AE tt:
ens aws l, se Facilities Radiological Protection Section a
gne Routine unannounced inspection of radioactive material transportation activities, radioactive waste management, tours of licensee s facilities and followup items of nonroutine events.
Inspection procedures 30703, 86721, 83750, 84850, 83729 and 92700 were addressed.
Results':
In the areas inspected, the licensee's programs appeared adequate to accomplish their safety objectives.
One unresolved item involving the possible failure for reporting changes that were made to ihe licensee's Process Control Program is discussed in paragraph 3.
A weakness in the area of conducting surveys in the receipt of radioactive materials is discussed in paragraph 2 (C).
Two nonroutine events reported by ihe licensee are discussed in paragraph 5.
e00i040057 S9i219 pDR ADOCK 0. s00052'-
Pl)C
DETAILS 1.
Persons Contacted
+J.
M. Levine, Yice President, Nuclear Production
+M.
C; Marsh, Plant Director
+P.
M. Hughes, Radiation Protection 8 Chemistry Manager R. J.
Adney, Plant Manager
- J.
R.
Mann, Central Radiation Protection Manager
~T.
P.
Hi lmer, Radwaste Support Manager
+T. Shriver, Compliance Manager
.~J.
M. Kester, Radwaste Support Supervisor D.
T. Leith, Radwaste Support Lead Technician
- K, Dberdorf, Radiation Protection Manager, Unit 1
- A. G.
Ogurek, Radi.ation Protection Manager, Unit 2
"M.
E.
Sneed, Radiation Protection Manager, Unit 3
~J.
C. Schlag, Radwaste Standards Supervisor
~C.
N.
Russo, equality Assurance/
equality Control Assistant Director
"J.
M. Si lls, Radiation Protection Standards Supervisor
~R. J.
Hazelwood, equality Assurance Supervisor T.
H. Cogburn, Standards 8 Technical Support Director R.
A. Badsgard, Nuclear Engineering Department Supervisor
~T.
R. Bradish, Compliance Supervisor b.
NRC D.
Coe, Resident Inspector F.
Ringwald, Resident Inspector J
~ Sloan, Resident Inspector
+G.
P.
Yuhas, Chief, Emergency Preparedness 4 Radiological Protection Branch, Region Y
c.
Contractors M.
H. Barley, Bartlett Nuclear, Inc. - Acting Chemistry Standards Supervisor
+Denotes those personnel in attendance at the exit interview held on November 30, 1989.
- Denotes those personnel in attendance at the exit interview held on December 1, 1989.
In addition the inspectors mei and held discussions with other licensee and contractor personne.
Occu A.
ational Ex osure Shi in and Trans ortation (83750 86721)
Audits and A
raisals Licensee audit reports and quality assurance monitoring reports related to shipping and transportation activities and the licensee's radioactive waste management programs which had been established for assuring compliance with 10 CFR Parts 20, 61.and 71, and 49 CFR Parts 100-171 were reviewed.
Discussions related to the findings identified in the reports were held with the licensee's staff.
The following audit reports were reviewed:
Audit Report 89-16, Radioactive Material Trans ort, dated July Audit Report 89-21, Process Control Pro ram Audit Re ort, dated.
c o er Radwaste Support Group internal audit reports for the 1st, 2nd and third quarters of 1989 Radwaste Standards audit reports for audits performed during
- 1989 B.
Miscellaneous quality assurance monitoring reports for activities witnessed during 1989 Some delays in responding to audit findings were noted which resulted in delaying the implementation of corrective actions.
This observation was brought to the licensee's attention by the inspectors.
The audit and monitoring reports conducted did not identify any violations or deviations of regulatory requirements.
The inspectors concluded that the licensee's audit and monitoring
- activities provided ANPP management with a viable tool for measuring the licensee's performance in the areas that were appraised.
Cha~ches No significant changes were identified in the'area of shipping and transportation activities.
C.
Procedures Procedures covering packaging, delivery and transport of radioactive material and wastes were reviewed.
The following procedures were reviewed:
12DP-OMC25, Material Receivin 76AC-ORM01, Recei t Stora e and Shi ment of Radioactive Materials 76DP-OAP05, Stora e
Accountabilit and Control of Radioactive a er>a s
76DP-ORM04, Recei t of Radioactive Material 76DP-ORM05, Initial Packa in of Radioactive Maste for Burial 76DP-ORM08, Handlin of Shi in Casks Containers and Su ortin ocumentat~on 76DP-ORM07, Shi in of Radioactive Naterial 76DP-OTR01, Radwaste Technician Trainin and uglification 76PR-ORM01, Radwaste Su
'ort Pro ram 76PR-ORM02, Radioactive Maste Minimization Pro ram The inspectors examined records associated with the receipt of radioactive materials to determine if-applicable procedures were adequate and being maintained.
The examination disclosed the following:
(1)
Procedure 12DP-OHC25 requires that the Radwaste Support group be contacted whenever shipments containing radioactive material are received at the warehouse so that the shipment can be examined in accordance with procedure 76DP-ORM04.
Procedure 76AC-ORM01 which has also'been established for the receipt of a mixed lading shipment or the arrival of an Exclusive Use Transport Vehicle requires that'he Radwaste Support group be notified so that the shipment can be examined in accordance with procedure 76DP-ORM04.
Paragraph 3.5.2 of procedure 76DP-ORM04 requires that radiation and contamination surveys be performed not later than three hours after receipt, if received during normal working hours, or eighteen hours if received after normal working hours.
(2)
A problem report prepared by an individual from the Radwaste Support group on December 2, 1988, identified that licensee procedures failed to provide adequate documentation that surveys are performed within the time constraints prescribed in
CFR Pari 20.205.
Under certain conditions,
CFR 20.205 requires that such surveys be performed within ihe three hour and/or eighteen hour time frame; as is identified in the licensee's procedures.
Discussions with the licensee's staff revealed that the time limits established in procedure 76DP-ORM04 were applicable for all shipments of radioactive materials received, regardless of the exemptions and/or other conditions specified under
CFR 20.205.
The reason for the licensee's more restrictive requirements were to ensure the requirements of 10 CFR 20.205 were met.
However, procedure 76DP-ORM04 did not include instructions for assuring that the time radioactive material is 'received'nd
'surveyed'ets documented.
(3)
The review of surveys that were performed for radioactive materials received between the period of June 1988 and December
1989, disclosed two instances where timely surveys were not performed.- Surveys for radioactive materials received at the warehouse on June 23, 1988, were not performed until June 30, 1988.
A radioactive material shipment received on October 27, 1988, was not surveyed until a period of approximately twenty-four hours had elapsed.
Neither shipment -involved ihe necessity for surveys as -identified in 10 CFR 20.205; however, surveys were noi performed within the time constraints of the licensee's procedure.
The inspector was unable to determine if Exclusive Use Transport Vehicle shipments that were received were surveyed within the time limits prescribed in 10 CFR 20.205.
Surveys of such shipments did not include sufficient information io adequately determine when ihe material was surveyed after it was received.
However, discussions with the licensee's staff disclosed that Exclusive Use shipments receive their immediate attention since the licensee's staff is informed of the shipment before hand by the shipper and immediately upon arrival at the site by the Security group.
Review of records Exclusive Use shipment surveys appeared to support this statement.
The observations discussed in paragraphs 2.C (2) and {3) were brought to the licensee's attention during the inspection and at the exit interview.
The licensee acknowledged the inspectors observations.
Immediate action was taken to correct the findings observed by the inspector.
The licensee's staff discussed their proposed corrective actions with the inspector.
The inspector concluded that the proposed corrective actions were satisfactory.
Corrective actions to assure that the'surveys are performed within the time constraints currently specified in existing'rocedures, were expected to be completed by mid December 1989.
Remaining procedures appeared to be adequate.
Im lementation The inspectors verified through discussions and through review of shipping documents and procedures that the licensee had a
transportation program in place that is consistent with regulatory requirements prescribed in 10 CFR Parts 20 and 71, and Department of Transportation requirements prescribed in 49 CFR Parts 171-177.
Maste Shi ments and Stora e
Radioactive waste shipments for the period of January 1,
1989 through November 29, 1989, primarily consisied of compressed dry active wastes, solidified and dewatered resins and spent filters.
There were three shipments of wastes that were greater than Type A
quantities and there were several LSA waste shipments of greater than Type A quantities.
These shipments were made in NRC certified casks, usually USA/9208/B, USA/9176/A and USA/9079/A.
Current Certificates of Compliance for these packages were available.
The inspector verified that ANPP was a registered user of the casks.
The inspector also reviewed certificates for 55 gallon containers
embossed with DOT 7A by the manufacturer showing that the drums had satisfactorily passed the testing requirements of 49 CFR 173.465 and 173.466.
The licensee had shipped a total of 27;000 cubic feet of radioactive wastes for disposal during 1989.
This amount is slightly more than
'as shipped for the entire year of 1988.
The licensee,had approximately 15,000 cubic feet of wastes in storage.
The licensee's staff stated that the 27,000 cubic feet shipped in 1989 and the 15,000 cubic feet in storage represented a backlog of wastes generated as far back as 1985.
The licensee's staff expects that the quantities of wastes will be reduced within the next, year or two.
I F.
Trans ortation Incidents The licensee had completed approximately 175 radioactive material shipments from the period of January 1,
1989 through November 30, 1989, without any reported incidents.
The licensee's performance in this subject area appeared to be improving since it was previously inspected.
The licensee's radioactive material transportation program seemed fully capable of meeting its safety objectives.
No violations or deviations were, identified.
3.
Radioactive Maste Mana ement (84850)
The licensee's program established for assuring compliance with ihe the following requirements were reviewed:
o
CFR Part 20.311 o
CFR Part
o Technical Specifications, Sections:
(a)
3/4. 11.3, Solid Radioactive Maste (b)
6.9, Re ortin Re uirements (c)
6. 13, Process Control Pro ram (PCP)
(d)
6. 15, Ma or Chan es to Radioactive Li uid Gaseous and o i as e
rea ment s
ems Licensee procedures for radwasie processing and assuring compliance with the requirements of'0 CFR Parts 20 and 61, applicable to low-activity waste form, classification, stabilization and shipment manifests/tracking were reviewed.
The procedures reviewed were as follows:
76AC-9RM01, Review and Control of the Solid Radwasie Process Control
~ro ram 76DP-OAP02, Review of Radwaste and Radwasie Process Control Pro ram
76DP-OAP07, Control of Vendor Documents and 0 erations 76DP-ORM01, Maste Stream Sam lin and Data Base Maintenance 76DP-ORM03, Classification of Radioactive Maste 76DP-OTROl, Radwaste Technician Trainin and ualifications 76PR-ORM01, Radwaste Su ort Pro ram 76PR-ORM02, Radioactive Maste Minimization Pro ram 76PR-90M01, Solid Radwaste Control Pro ram
- The procedures appeared to adequately define and delineate individual and organizational responsibilities.
The licensee's equality Control program to assure compliance with waste classification and characterization requirements of 10 CFR &1.55 and 61.56 was reviewed.
No concerns were identified in this area.
Records of waste classification and characterization and manifests for transportation activities that were conducted from January 1,
1989 through November 29, 1989 were reviewed and found to be consistent with
CFR 20.311 (b), (c) and (d) (1) and (2).
The training program and qualifications for selected Radwaste Support group technicians were reviewed and noted to have improved sincethis area was last inspected.
The inspector witnessed a training course that was in progress during the inspection.
Personnel from the Radwaste Support group were required to attend the course.
The course being given was entitled:
RADMAN AND REGULATORY COMPLIANCE.
k The licensee's staff maintains a file which identifies each of the Units waste streams and the waste types associated with each waste stream.
The location and logs of the most recent sample date for each waste stream sampling and analysis are maintained for each Unit.
Each waste stream are normally sampled annually.
Five major waste streams are normally sampled.
The waste streams sampled are:
(a)
Dry Active Maste
{DAM)
(b)
High Activity Resins (c)
Low Activity Resins (d)
Evaporator Bottoms (e)
Cartridge Filters Sampled waste streams are normally analyzed by the licensee and an off-site vendor.
Each sample is analyzed for each isoiope required by 10 CFR 61.55.
The vendors sample analysis results are compared to in-house lab results and to results obtained from previous sampling of the waste
streams.
If the specific activity varies by more than a factor of ten, the cause is investigated and the waste stream is required to be resampled.
The licensee's staff reported that recent sample analysis results obtained from Unit 1's low activity resin and Unit 3's high activity resin showed a significant incr ease in the level of Carbon-14
. activity.
The following is a comparison of Carbon-14 activity levels between 1988 and 1989:
1988 (u~igm)
1989 (u~igm)
Low Activity Resins High Activity Resins 7.26E-4 (Unit 1)
8.9E-2 3. 28E-3 (Unit 3)
4. DE-1 The licensee's staff had not yet determined the reason for the higher carbon-14 levels.
The staff informed the inspector that the results have been turned over to their technical staff for evaluation and that plans
.
have been developed to obtain another set of waste stream samples for analysis.
The licensee's staff 'stated that they are planning to have the carbon-14 analysis conducted by two separate off-site vendors.
This item will be examined during a subsequent inspection (50-528/89-51-01 and 50-530/89-51-01).
l The licensee appeared to be adequately maintaining current copies of the disposal site license.
License procedures appeared to address adherence to disposal site requirements.
Recent changes to the following vendors documents which had been adopted and approved by the licensee pursuant to Technical Specifications 6. 13, Process Control Pro ram (PCP) were also reviewed:
76CP-9NP01, Solidification Process Control Procedure for PYNGS, ev, -,
ae This procedure change notice changed the emulsifier'nits from "grams" to "milliliters."
76CP-9NPD2, Process Control Pro ram For Class A Unstable Maste o >>
scat>on -
o rum u
ate an ax aste, ev 0 ate This change provided the authorization for the use of an accelerator in the body of the procedure.
76CP-9NP03, Process Control Pro ram for Class A Unstable Maste o
>
>
>ca ion -
orle cl
,
ev
,
-
,
a e
This change allowed the inspection of a solidified sample be performed after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> instead of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that was previously specified.
76CP-9US01, CFT-I PCP for Class A Unstable Concentrate Maste, Rev
a e
)
This change incorporated process parameter adjustments for waste processing improvements.
76CP-9US02, CFT-I-S stem 0 eraiion, Rev 1, dated 6/19/89 This change incorporated procedural clarifications td allow for improved waste processing.
76CP-9US04, CFT-I Mixer Dischar e Pressure Calibration, Rev 1, a
e This change added the ability to use any 300 psig pressure source to calibrate the CFT-I mixer discharge pressure and it incorporated vendor procedure CPN-2, Rev 1, dated 5/12/89.
Each of the above six vendor-procedures referenced above had been reviewed by the licensee's staff for 10 CFR 50.59 considerations in accordance with licensee procedures prior to being changed.
The reviewers determined thai the changes did not involve an intent change or a change to an established
"acceptance criteria"; therefore, decided a
50.59 review was not necessary.
The changes that were made to procedures 76CP-9NP01, 76CP-9NPD2 and 76CP-9NP03 had not yet been formally. approved by the vendor before they were issued.
The licensee's staff stated that the changes had been discussed with the vendor prior to issue and the vendor had verbally agreed to the proposed changes.
The licensee's staff added that two of the changes were clerical in nature and the third was consistent with other process control program procedures.
Vendor approval for these three changes was received on November 29, 1989.
It should be noted that Technical Specifications 6. 13 states:
"6. 13. 1 The PCP shall be approved by ihe Commission prior io implementation.
"6; 13.2 Licensee initiated changes to the PCP:
"Shall be submitted io ihe Commission in the Semiannual Radioactive Effluent Report for the period in which the changes was made.
This submittal shall contain:
"(1)
Sufficiently detailed information to totally support the change without benefit of additional or supplemental information; and
"(2)
A determination that the change did not reduce the overall conformance of ihe solidified waste product to existing criteria for solid wastes."
The semi.annual radioactive effluent release report, dated August 29,1989, for ihe six month period ending on June 30, 1989 does not include a
description of the changes that were incorporated in the above six
procedures.
Paragraph 7.0 of the report states in part:
"There were no revisions to the ODCM or the PCP.
There were no major changes to the radwaste system."
Discussions were held with the licensee's staff during. the inspection and by telephone on December 5-7, 1989, for the purpose of determining why the changes were not reported in the recent semiannual radioactive effluent release report.
The licensee's staff stated that they were not sure why the changes were not reported.
They stated that they would look into the matter
.and report their findings to the Region V staff upon completing their investigation.
The above observation was discussed with the licensee's staff attending exit interviews on November 30, 1989 and December 1, 1989, and during the telephone calls of December 5-7,1989.
The licensee was informed that this matter would be considered unresolved pending the receipt and evaluation of the information disclosed from their investigation (50-528/89-51-02).
An unresolved item is one about which more information is'equired in order to ascertain whether it is an acceptable item, a violation or a deviation.
4.
Faci lit Tours (83729)
Tours of ihe licensee's facilities were conducied during the inspection period.
Radioactive waste storage areas and the radioactive material receipt areas at the warehouse were included in the tours.
Independent radiation measurements were made using an ion chamber survey instrument, Model R0-2, serial number 897, due for calibration on February 3,
1990.
The following observations were made:
(a)
Posting and labeling practices were consistent with 10 CFR Parts 19.11 and 20.203.
(b)
Mork practices were in accordance with the licensee's ALARA program.
(c)
An E-520 survey meter located at the containment building exii point had not been source checked for one week.
The licensee's staff informed ihe inspectors that the instrument had not been used to conduct any surveys since it was last source checked.
(d)
The inspeciors noted some inconsistencies in the methods used for controlling equipment and materials within a radioactively contaminated area (RCA).
Some tools
.and equipment were marked with a magenta colored paint while some others were noi marked.
Some of ihe equipment appeared to have inaccessible surfaces which normally can not be monitored unless the equipment is disassembled.
Several personnel were asked if they understood the requirements established in licensee procedure 75RP-9RP09, Vehicle E ui ment and Material Release From the RCA, for releasing s
ems rom an a
ave snaccessi e sur aces.
Responses were
'ot consistent with the instructions in procedure 75RP-9RP09.
The
I
inspector also noted that ihe procedure did not specifically address how materials will be controlled within an RCA.
(e)
The lights in Room 109 of Unit 1's Truckbay area located in the Radwaste Building were not working.
This item was brought to the attention of the licensee's staff.
All of the above observations were brought to the attention of ihe Radiation Protection and Chemistry Manager.
The licensee's program in this subject area seemed capable of meeting its safety objectives.
No violations or deviations were identified.
5.
Followu Items (92700)
A.
Unlocked Hi h Radiation Area Events The inspector reviewed the status of two nonroutine'events which the licensee had reported to the NRC resident staff shortly after they occurred on November 6,
1989 and November 9, 1989, respectively.
The events, which are described in APS memorandum number 260-00219-MCM/PMH, 'dated November 11, 1989, are as follows:
(a)
On November 6, 1989, a Radiation Protection Technician (RPT)
found a Locked High Radiation Area (LHRA) gate open and unguarded during a routine LHRA door check.
The gate (A-B07)
. is located in Unit 3 on the 70'levation of the Auxiliary Building at the access point to ihe "A" Shutdown Cooling Heat Exchanger Room.
(b)
On November 9, 1989, an RPT found a
LHRA gate open and unguarded during a routine LHRA door check.
The gate (R-132) is located in Unit 1 on the 112'levation of the Radwaste Building at the access point to the High Level Storage Area.
The November ll, 1989, memorandum provided a description of the immediate actions that were taken by the licensee.
The memorandum disclosed the following:
(1)
The causes for the unlocked and unguarded LHRA were undetermined and were being evaluated by.a Radiation Protection and Security Sub-Team.
An inspection of the gates in both cases indicated that entry into the affected areas may have been made through unauthorized means (e. g.
by tampering with the lock).
The Radiation Proieciion 8 Chemistry Manager was assigned as the team leader.
The Incident Investigation number was assigned a priority code 2 and a report number of 2-1-89-003.
(2)
The locking mechanisms installed on the two cage type gates were determined to be ineffective for use as a secure locked barrier as they could easily be defeated by using commonly available tools.
Some of the immediate corrective action taken included:
(1)
All LHRA doors in the three Units were inspected.
Remaining doors were found to be locked.
(2)
Padlocks and chains were installed, in addition to the existing lock sets, on all LHRA gates.
Administrative controls were implemented in association with the chains and padlocks to ensure no individual will be prevented from exiting a LHRA.
(c)
Anti-pick plates have 'been installed on the hollow metal LHRA doors.
Discussions with The Radiation Protection and Chemistry Manager (RP8CM) disclosed that the Sub-committee's investigation into the two events was nearing completion.
The RP8CM stated that they were unable to determine when and by whom the doors were opened.
He added that it appeared as if the doors and locking mechanisms were-tampered with by unknown parties.
The RP8CM stated that the investigating committee's report was nearing completion and a copy of the report would be provided to the Region V staff.
Discussions with the Compliance Manager revealed that Licensee Event Reports (LER) describing the events were being prepared and would also be distributed to Region V.
The inspector discussed the above information with the RP8CM and at the exit interview.
The inspector informed the'icensee that this was the third time in less than a two year period that events related to control of LHRA have been identified.
The previous events are described in Region V Inspection Reports 50-528/88-35 and 50-528/89-24.
The inspector informed the licensee that this item would be examined further after receipt of the LER and Sub-committee's investigation report (50-528/89-51-03).
Stuck Fuel Assembl The licensee 'reported that a fuel assembly could not be fully seated during core reload.
The assembly, at location L-17, could not be fully lowered because it was bowed.
The inspectors conducted a visual inspection of the stuck fuel assembly and on November 21,1989, asked the licensee's staff if they had evaluated ihe possible radiological consequences which might result if the assembly was inadvertently damaged during their attempts to remove it from the core.
The NRC resident staff had asked ihe licensee similar questions.
The licensee informed the inspectors, that they had increased their chemistry and radiological sampling and survey frequencies and were calculating the potential radiological consequences in the event the assembly was damaged during removal.
The licensee's stiff also reported that no other
, work would be permitted in the containment building during the attempt to remove the stuck assembl II I
t (
l l
i
The licensee's calculation of the expected source term was discussed with'he Region V staff on November 22, 1989.
The Region Y staff reviewed the licensee's, calculation and identified an error of approximately 1000 (the error overestimated the source term).
The licensee's staff acknowledged the error when questioned by the inspector.
The stuck assembly was subsequently removed without incident.
Overall, the licensee's program in this subject area appeared capable of meeting its'afety objectives.
6.
Exit Interview The inspectors met with the individuals denoted in paragraph 1 at the conclusion of the inspection on November 30, 1989 and December 1, 1989.
The scope and findings of the inspection were summarized.
The licensee was informed that no violations or deviations were identifie l