IR 05000528/1990043
| ML17305B200 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/05/1990 |
| From: | Cillis M, Miles K, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B199 | List: |
| References | |
| 50-528-90-43, 50-529-90-43, 50-530-90-43, NUDOCS 9011270145 | |
| Download: ML17305B200 (17) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/90-43, 50-529/90-43 and 50-530/90-43 License Nos.
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Public Service Company P..O.
Box 53999 Phoenix, Arizona 85072-3999, Facility Name:
Palo Verde Nuclear Generating Station - Units 1, 2 and
Inspection at:
Mintersburg, Arizona Inspection conduct d: September 17 - September 21, 1990 Inspection by:
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e sgne DA, gO Approved by:
~Summar:
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)e Reactor Radiological Protection Branch a
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Routine, unannounced inspection by two regionally based inspectors of Allegation No.
RV-A-90-0056, occupational exposure, radioactive waste systems, and periodic licensee reports.
Inspection modules 30703, 83729, 84750 and 90713 were used.
Res ults:
In the areas inspected, the licensee's programs appeared adequate to accomplish their safety objectives.
One non-cited violation was identified involving improper labeling of radioactive material and failure to initiate an investigation of the event by preparing a p'roblem resolution sheet or quality deficiency report (see Section 2).
Several weaknesses in addressing long-standing corrective actions in a timely manner are discussed in Section 3.
901127014 901106 PDR ADOCK 05000528 Q
Persons Contacted DETAILS
"W.
C. Marsh, Plant Director, Nuclear Production
"R.
K. Flood, Plant Manager, Unit 2
"P.
W. Hughes, Radiation Protection 8 Chemistry Manager T.
R. Bradish, Compliance Manager
- J.
P. Albers, Radiation Protection Manager, Site Operations
"J.
B. Cedarquist, Site Chemistry Technical Assistant
"J.
H. Sills, Radiation Protection Technical Services Manager
"T.
W. Murphy, Radiation Monitoring System (RHS)/Effluent Supervisor
"H.
D. Ingalsbe, Radiation Support Services Supervisor
"R. J.
Bouquot, equality Audits Supervisor T.
P. Hilmer, Radwaste Support Manager
"K. Oberdorf, Radiation Protection Manager, Unit 1
"A. G. Ogurek, Radiation Protection Manager, Unit 2
- W. E.
Sneed, Radiation Protection Manager, Unit 3
"T.
R. Bradish, Compliance Supervisor
"J.
A. Scott, General Manager, Site Chemistry A. D. Jackson, Unit 2 Radlatlon Protection Supervisor
"R.
K. Fountain, equality Audits 8 Monitoring Coordinator
"M. S.
Burns, Manager, Operations Computer Software
"T.
R. Albrigo, Engineer, Operations Computer Software R.
F. Collins, RHS System Engineer
"J.
M. Shawver, Corporate Assessment Group Consultant NRC
"D. Coe, Resident Inspector Contractors
- W. H. Barley, Bartlett Nuclear, Inc. - Chemistry 8 Radiation Protection Consultant W. Wattson, Impell, Inc. - Radiation Monitoring System (RHS)
Consultant
"Denotes those personnel in attendance at the exit interview held on September 21, 1990.
In addition, the inspectors met "and held discussions with other licensee and contractor personnel.
Alle ation File RV-90-A-0056 HC 83729 General Information On September 17, 1990, Region Y received an anonymous, undated letter.
The letter stated that on September 10, 1990, two workers tasked with making preparations to load a radioactive material cask for shipment had encountered difficulty in locating the radioactive material.
This difficulty, the letter stated, was due to improper labeling of the temporary container in which the material was store Necessary preparations had included transferring a high integrity container (HIC) into an appropriate shipping cask.
The HIC had been stored in a temporary shielded container in the Unit 2 radioactive material storage yard.
The HIC was known to have radiation levels of about 3 - 5 rem/hr on the sides and a hot spot of about 12 rem/hr on the top.
Initially, the worker's had not been able to locate the temporary container storing the HIC because it had not been properly labeled as radioactive material.
The container had been subsequently tracked and located using its radwaste label serial number (a label system normally used only by the radwaste group).
The workers then found a radioactive material label on the container; the label, however, had been crossed out with a heavy black marker, incorrectly indicating that the container was empty.
The radwaste label had not been crossed out.
The letter also stated that only one lock had been installed on the lifting ear of the temporary container s cover, making it possible to raise the cover at one end.
One other temporary container holding Trinuke filters reading about 90 rem/hr on contact had been found in the same condition.
The letter stated that the condition being reported could have been more serious if some individual, assuming the
'containers were empty, had moved them for another job.
The letter stated that the Unit 2 radiation protection group had been notified and the containers had been promptly labeled.
NRC Review j0 CFR 20.203, (f)(l) and (2) state in part:
Containers.
(1)
Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents.
(2)
A label required pursuant to paragraph (f)(l) of this section shall bear the radiation caution symbol and the words
"CAUTION, RADIOACTIVE MATERIAL," or "DANGER, RADIOACTIVE MATERIAL." It shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
CFR 20.203 requires that the information on the label include radiation levels, kinds of material, estimate of activity, date for which activity is estimated, mass enrichment, etc.
Licensee procedure requires that each container be labeled in accordance with 10 CFR 20.203 (f)(l) and (2) requirements.
The procedure also requires labels on empty containers to be removed or defaced or to otherwise clearly indicate that the container no longer contains radioactive materia The inspectors'eview revealed the following additional information:
The condition of the radioactive material label on the container in question could not be determined, because the container had been shipped offsite on September ll, 1990.
However, an inspection of the container in which the Trinuke filters were stored was commensurate with what had been reported by the anonymous individual.
The radioactive material label-still affixed on the container had been crossed over with a heavy black marker.
Part of the information on the crossed-out label was still legible; however, the inspectors concluded that persons in the vicinity of the container could have reasonably believed that the container was empty.
The container shipped on September ll, 1990, contained the following radioactivity:
Radionuclide Iron-55 Cobalt-60 Cobalt-58 Chromium-51 Antimony-124 Ce's ium-137 Niobium-95
~aanti t 3.34 Curies 1.34 Curies 0.805 Curies 0.825 Curies 0.650 Curies 0.103 Curies 0.513 Curies Survey records of the containers substantiated the radiation levels reported in the letter.
The containers were stored in an approved radioactive material storage area during the time that information on the labels had been marked over with the heavy black marker.
Radiological Exposure Permits (REPs) 0-90-0021-A and 2-90-0263-A had been implemented to control work required to transfer the material into the shipping cask.
The REPs required that continuous coverage be provided by the radiation protection staff.
The inspectors interviewed the two individuals that had prepared the shipment.
The two individuals verified the information provided by the anonymous individual.
The two individuals had at first believed the two containers with the defaced labels to be empty.
They had reported the condition to radiation protection and a joint search had been conducted.
The material had subsequently been found and relabeled as described in the letter.
No further 'licensee investigation had been conducted, even though Licensee Procedures 75AC-9RP03, "Radiological Controls Problem Reporting,"
and 60AC-OQQ03, "Quality Deficiency Report," require that either a
problem resolution sheet (PRS) or a Quality Deficiency Report (QDR)
be initiated for reporting the degradation of established radiological controls or for reporting conditions adverse to quality when they are identified.
The radiation protection staff stated that the reason no PRS or QDR had been prepared was that, with all
C'
work covered by an REP and the material in question remaining in an approved storage area, they had not considered the situation to constitute a degradation of radiological controls.
The inspectors noted that the cover of the temporary storage container could not have been moved without the use"of a crane, which would have required contacting the radiation protection group before performing work.
The inspectors reviewed Licensee Procedure 76DP-OAP05,
"Storage, Accountability, and Control of Radwaste Naterials."
This procedure gives the licensee's radwaste group responsibility for maintaining accountability of radwaste packages'ithin the unit storage areas.
The procedure does not clearly define a required inventory frequency.
The licensee's staff indicated that they conduct inventories of radwaste records monthly.
The radioactive material labels had been blacked over with a heavy black marker on September 5, 1990.
The labeling had remained in that condition until the two workers reported it on September 11',
1990.
Discussions with the licensee's staff revealed that a lead radiation protection technician (RPT) had been tasked with correcting an audit finding identifying certain labels that were becoming illegible.
The lead RPT had instructed two junior RPTs to either "blackover" or replace the labels.
The lead RPT stated that the term "blackover" had meant to darken or blacken the existing labels by tracing over existing information on the label with a black marker.
The junior RPTs had assumed that "blackover" meant they were to cross out the information, because the containers may have been empty.
The lead RPT did not conduct a followup to determine if the junior RPTs had followed his instructions.
NRC Conclusions The inspectors concluded that although the radiation protection group had taken action to properly relabel the containers, they had failed to determine if there were any lessons to be learned because of the decision not to initiate a PRS or a (DR.
The inspectors also concluded that individuals seeing the defaced labels might reasonably have assumed that the containers were empty, and that this assumption could have led to a more hazardous situation.
The above findings were brought to the licensee's attention at the exit interview.
The licensee was informed that one apparent violation had been identified for not maintaining the containers properly labeled and for not initiating a PRS or (DR.
This violation is not being cited because the criteria specified in 10 CFR Part 2, Appendix C, Section V.
G. were satisfied (50-529/90-43-01).
~
'adioactive Waste S stems Water Chemistr and Radiolo ical nvlronmenta onstorsn This program area was reviewed by observation, review of applicable procedures and records, and interviews with responsible personnel.
The inspectors also conducted a walkdown of the Unit 2 heating, ventilation, and air-conditioning (HYAC) systems and the Condenser Vacuum Pump/Gland Seal Exhaust and Plant Vent radiation monitoring systems (RMSs).
Audits and A
raisals The inspectors reviewed licensee Audit Report 90-003, which addressed sampling of gaseous effluent and the radiological environmental monitoring program (REMP).
The audit scope included a review of the following areas:
0
0
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Evaluation of Licensee Event Reports (LERs)
Evaluation of EED long range RMS improvement plans Performance of effluent technicians Effluent monitor setpoint verifications Comparison of programs to Regulatory Guides (RGs) 1.21 and 4.15 Corrective action effectiveness Performance of REMP activities The audit resulted in one deficiency in the radiological effluent program, but identified no major program breakdowns.
The inspectors concluded that the 'licensee's auditing and monitoring
, activities provided management with a viable tool for measuring performance in the areas appraised.
~Chan ee No major changes to the licensee's chemistry. facilities had occurred since the last inspection.
One major change involving the reorganization of the chemistry group was in progress at the time of this inspection (see also Inspection Report 50-528/90-27, Section 4).
Another major change in progress included an effort to review and revise all chemistry program implementing procedures.
The licensee's chemistry staff expected to have the procedures revised by November 1, 1990, and ready for implementation by January 1, 1991.
Procedures This topic is discussed under "Changes,"
above.
Pro ram Im lementation The following items were identified during the review of this program area:
F (A)
An Arizona Nuclear Power Project (ANPP) memorandum dated April 1,
'986, stated that the radiation protection support group was aware that determining radioiodine deposition in RMS sample lines for
monitors RU-141, RU-143 and RU-145 was necessary, and that such a
determination would be made.
A review of Inspection Reports 50-528/83-12, 50-528/83-41, 50-528/84-49, and 50-528/86-07 revealed that at least two additional commitments had been made by ANPP to develop iodine correction factors.
These items had been addressed as NRC open items that were closed based on commitments made to develop the iodine correction factors.
The licensee's staff had made an unsuccessful attempt to perform the plateout determination.
Engineering Evaluation Requests (EERs)
89-SQ-057 and 89-SQ-060 were then initiated to perform the plateout determinations.
The inspectors found that no additional attempts had been made to develop the iodine correction factors and therefore a resolution of the EERs had not been completed as of September 21, 1990.
At the exit interview, the inspectors noted the lack of timeliness in the licensee's efforts to resolve this problem.
The licensee stated that they would reevaluate their previous commitment to determine if the plateout study should be performed by a vendor or if the determination could be made by the calculational method recommended in Electric Power Research Institute Report NP-939,
"Sources of Radioiodine at Pressurized Mater Reactors."
This item will be examined during a subsequent inspection (50-528/90-43-02).
ANPP Memorandum 219-00783-PMH/THV, dated September 29, 1989, stated that Licensee Procedure 74CH-9SQ04,
"Abnormal/Nuisance Pathway Evaluations," would be completed by November 1, 1989, and fully implemented by January 2, 1990.
This memorandum was in response to Audit Report 89-015, which had reviewed Licensee Procedure 75RP-9ZZ92 and thereby identified a weakness in evaluation of unplanned releases.
The memorandum also stated that 74CH-9SQ04 would ensure implementation of Technical Specification (TS) 6.5.2.8.
Discussions with licensee staff revealed that 74CH-9SQ04 had not been completed as of the time of this inspection.
In addition, the staff stated that the existing procedure, 75RP-9ZZ92, Revision 7, was not very clear with respect to defining unplanned releases.
The inspectors noted that Section 6.7.4.4 of 75RP-9ZZ92 states in part, "If isotopic concentrations are less than 10 CFR 20 (Appendix B, Table 2, Column 1),
no permit is required."
Section 6.7.4.5 of the procedure states in part, "If isotopic concentrations are equal to or greater than 10 CFR 20 (Appendix B, Table 2, Column 1),
generate a release permit using the training version of the ETS."
The inspectors also noted that the Lower Limit of Detection (LLD)
listed in Table Al of the Semiannual Radioactive Effluent Release Report for the six month period ending June 30, 1990, listed LLD values for gaseous effluents, including tritium, that were generally much lower than the values listed in 10 CFR 20, Appendix B, Table 2, Column 1.
The inspectors concluded that radioactive releases above the LLD values but below the values listed in 10 CFR 20, Appendix B, Table 2, Column 1 would not be reported.
This condition would represent noncompliance with TS 3/4..11 and possibly 10 CFR 50,
Appendix I.
Further discussions with each of the unit chemistry managers revealed that the guidance provided in the procedure had not been implemented.
The above observations were discussed with the licensee's staff during the inspection and at the exit interview.
'The inspectors informed the licensee that their program could have led to noncompliance and that their corrective actions did not appear to be timely.
The licensee took immediate action to revise 75RP-9ZZ02 to be consistent with TS requirements.
The licensee also initiated action to define abnormal/unplanned releases as described in Regulatory Guide 1.21.
A review of Licensee Procedure 75RP-9ZZ89,
"Radiation Monitor Alarm Setpoint Determination," revealed that the purpose for the procedure is to provide methods for determination and control of alarm settings for installed radiation monitors, and to provide the mechanism for evaluating radiation monitor performance during power ascension and routine operations.
The procedure also states that alarm setpoints should be assessed periodically, using appropriate data from the Semiannual Effluent Release Reports from the previous year.
Discussion with licensee staff disclosed that the procedure does not provide clear and concise guidance for determining alarm setpoints.
In addition, the staff was unable to provide the inspector with any documentation of the recommended periodic assessments.
The inspectors noted that APS Memorandum 222-01015-KWK and Licensee Audit Report 90-003, dated May 23, 1990, also reported the weaknesses in 75RP-9ZZ89.
The inspectors brought this observation to the attention of the licensee's staff attending the exit interview.
The inspectors again stated that corrective action to resolve the problem did not appear to be timely.
The inspectors were informed that, the procedure was under revision and that the inspectors'indings would be addressed in the revision.
This item will be examined during a subsequent inspection (50-528/90-43-03).
During a technical evaluation of the disposition of EER-88-S(-158, the licensee's staff discovered that Post-Accident High Range Monitors RU-142, "Condenser Vacuum Pump/Gland Seal Monitor,"
RU-144, "Plant Vent Monitor," and RU-146, "Fuel Building Ventilation Exhaust Monitor," had never had isokinetic flow control and hence could not follow changes in the main sample flowrate.
The sample, therefore, is extracted from the process isokinetically only to have an anisokinetic error introduced when the second sample is extracted.
It was concluded that the flow control of the high range monitors is still not in accordance with NUREG-0737, Item II.F.1,
"Additional Accident-Monitoring Instrumentation."
NUREG-0737 recommends that the accident-monitoring system design consider the recommendations provided in ANSI N13.1-1969,
"Guide to Sampling Airborne Radioactive Material in Nuclear Facilities," for isokinetic samplin The inspectors examined the high range accident monitors, and verified the conditions described in EER-88-S(-158.
The EER had originally been issued on September 14, 1988, identifying twelve items of concern.
Technical review had revealed that RU-142, RU-144, and RU-146 had never had the isokinetic flow control currently described in the Final Safety Analysis Report (FSAR), Section 18. II.F.1.2, and were not consistent with the description provided in Section 11.5 of the FSAR.
This condition had been known to exist since March 1989.
At the time of this inspection the licensee had not resolved this issue, except to recommend that a variance to the requirement be requested and that the FSAR be updated to reflect current conditions.
The above finding was discussed during a meeting held with the licensee's staff.
The inspectors were informed that Material Nonconformance Report (MNCR) 90-Sg-0010 had been initiated on September 20, 1990, to resolve the matter.
In addition a 10 CFR 50.59 review and evaluation had been performed to consider any unreviewed safety questions.
This item will be examined further during a subsequent inspection (50-528/90-43-04).
At the exit interview, the inspectors informed the licensee that the timeliness of actions taken to resolve the findings described in Items A-D, above, appeared to be an area that needed improvement.
The licensee staff attending the exit interview acknowledged the insp'ectors'oncerns, and informed the inspectors that action would be'initiated to resolve the matters identified.
The inspectors concluded that the licensee's performance in this area was in need of improvement; however, the program appeared adequate to accomplish its safety objectives.
No violations or deviations were identified.
4.
In-Office and Onsite Review of Periodic and S ecial Re orts (MC 90713 The inspectors performed an in-office review of the January 1, 1990, through June 30, 1990, Semiannual Radioactive Effluent Release Report (SRERR), submitted in accordance with TS 6.9.1.8.
,Radiation doses reported were below the limits of TS 3/4.11.
The licensee's assessment of doses to members of the public was made in accordance with methods specified in the licensee s Offsite Dose Calculation Manual (ODCM).
The ODCM references the GASPAR code methods of performing dose calculations.
The inspectors reviewed the SRERR for consistency with the recommendations of RG 1.21,
"Measuring, Evaluating, and Reporting Radioactivity in Solid Mastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Mater-Cooled Nuclear Power Plants."
The report was consistent with the format recommended in RG 1.21; however, two discrepancies with the collation and documentation of data involving first and second quarter tritium releases from Unit 1 were noted in Table A3.
The inspectors brought this observation to the licensee's attention.
The licensee agreed that the data was in error, I
'C
II
and stated that a revision to the report would be submitted in the next SRERR.
The review disclosed that radioactive releases and resulting doses were significantly below the limits of TS 3/4. 11.
Using data and methods provided in the ODCN, the inspectors calculated thyroid dose for a child.
The results were within the limits prescribed
CFR 50, Appendix I, and the calculation revealed no procedural concerns.
The SRERR reported that one unplanned release had occurred at Unit 3 during the report period.
The inspectors concluded the release was not radiologically significant.
The licensee was maintaining its previous level of performance in this program area.
Observed aspects of the program were adequate in meeting the licensee's safety objectives.
No violations or deviations were identified.
5.
Facil.it 'Tours MC 83729 The inspectors conducted tours of the licensee's facilities, including radioactive waste storage areas and the radioactive material receipt areas at the warehouse.
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 inspectors made the following observations:
Posting and labeling practices were consistent with 10 CFR Parts, 19.ll and 20. 203.
Mor ker practices observed were in accordance with applicable Radiation Exposure Permits and with the licensee's ALARA program.
Cleanliness was excellent in the areas toured.
All portable instr uments observed were in current calibration.
All personnel observed in the licensee's controlled areas were equipped with appropriate dosimetry devices.
In the areas inspected, the licensee's program appeared capable of meeting its safety objectives.
No violations or deviations were identified.
6.
Exit Interview MC 30703 The inspectors met with the individuals denoted in Section 1 at the conclusion of the inspection on September 21, 1990.
The scope and findings of the inspection were summarized.
The licensee was informed of the non-cited violation discussed in Section 2, and the findings discussed in Section 3.