IR 05000528/1991006
| ML17305B411 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/08/1991 |
| From: | Louis Carson, Cillis M, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B410 | List: |
| References | |
| 50-528-91-06, 50-528-91-6, 50-529-91-06, 50-529-91-6, 50-530-91-06, 50-530-91-6, NUDOCS 9103270161 | |
| Download: ML17305B411 (16) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-528/91-06, 50-529/91-06 and 50-530/91-06 License Nos.
NPF-41, NPF-51 and NPF-74 Licensee:
Arizona Public Service Company P.
0.
Box 53999 Sta.
9012 Phoenix, Arizona 85072-3999
.Facility Name:
Palo Verde Nuclear Generating Station (PVNGS), Units 1,
8
Inspection at:
PVNGS Site at Wintersburg, Arizona Inspection conducted:
February 11-15, 1991 Inspection by:
ss, n) r a sa )on pecsa ss e
igne
.
C.
C rso I
Rad)a on Spec)a )st t
ate Signed
~Summar:
Areas Inspected:
G.
P; u as, hsef Reactor Radiological P
tection Branch e
signed Routi.ne unannounced inspection of the licensee's radiation protection program (RP); including occupational exposures, contamination control practices during extended outages, tours of licensee's facilities, and followup of previous inspection findings.
Inspection procedures 83729, 83750, and 92701 were addressed.
Results:
In the areas inspected, the licensee's program appeared adequate to accomplish their safety objectives.
Concerns associated with portions of the licensee s
respiratory protection program and improvements with the licensee's performance during Unit 1's 1991 maintenance outage are discussed in Section 2.
No violations or deviations were identified.
9103270i6i 9i0308 PDR ADOCK 05000528
l
DETAILS Persons Contacted J.
M. Levine, Vice President, Nuclear Production P.
W. Hughes, Radiation Protection 8 Chemistry Manager (RP8CM)
"J.
P. Albers, Manager, RP Operations
"W.
E. Ide, Plant Manager, Unit 1
- R.
K. Flood, Plant Manager, Unit 2
- R. J.
Adney, Plant Manager, Unit 3
"T.
P. Hilmer, 'Radwaste Support Manager
"M. D. Shea,
'RP Manager, Unit 2
~K. Oberdorf, RP Manager, Unit 1
"A. G. Ogurek, Corporate Assessment Manager
"W. E.
Sneed, RP Manager, Unit 3
"T.
R. Bradish, Compliance Supervisor
"J.
A. Scott, General Manager, Site Chemistry
"C. T. Seliga, Lead Auditor, equality Assurance
- W. H. Barley, Site RP, Acting Manager, Technical Services D.
Mc Gee, ALARA/RP Outage Planning, Supervisor J.
B. Steward, Radiological Engineer A.
D. Jackson, Unit 2 Radiation Protection Supervisor
"R. Rouse, Compliance Supervisor
"M. Radoccia, Manager, Site Nuclear Engineering Division
"M. Winsor, System Engineer
"R. Ful lmer, Manager, equality Assurance and Monitoring (/A&M)
"R. J.
Hazelwood, Supervisor, gAQl V. S.
Huntsman, Supervisor, Radioactive Material Control A. L. Haugen, Lead Technician, Respiratory Protection R.
G. Barringer, Primary Instructor NRC D.
Coe, Senior Resident Inspector F.
F. Ringwald, Resident Inspector
"Denotes those personnel'n attendance at the exit interview held on February 15,1991.
In addition the inspectors met and held discussions with other licensee and contractor personnel.
Occu ational Radiation Ex osure Durin Extended Outa es -( 83729 and a.
Audits and A
raisals Recent licensee audits of this program area were previously discussed in NRC Inspection Report Nos. 50-528/90-55, 50-529/90-55, and 50-530/90-55.
The inspectors reviewed licensee monitoring
I
activities that were conducted since the previous inspection of these activities.
Approximately forty-eight appraisals of radiation protection/ALARA related activities at all three units had been performed by the licensee's quality assurance staff from January 1, 1991, to the date of this inspection.
Although some weaknesses were found, no violations of applicable regulatory requirements were identified.
The inspectors noted that licensee monitoring activities were in depth and covered a broad spectrum of radiation protection/ALARA activities that are normally accomplished during an outage.
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.
~Chan ea No significant organizational or facility changes had occurred since the previous inspection of this area.
Trainin and ualifications of Personnel The training and qualification of contract radiation protection technicians (RPTs) hired for facility outages was previously addressed in NRC Inspection Report 50-528/90-55.
The inspectors were informed that the contract RPTs currently working in Unit 1 will b'e used to support the Unit 3 outage which is scheduled to start ia mid-March 199l.
The Unit 3 outage RP staff will be further supplemented with licensee RPTs from Units 1 and 2, and additional contract RPTs.
Contract RPTs hired to support the Unit 3 outage will be provided with the same site specific training as were the contract RPTs hired for the Unit 1 outage.
The inspectors also examined the licensee's general employee training (GET) and respiratory protection training programs for compliance with 10 CFR Part 19.12 and 20.103 requirements.
Related lesson plans, examinations, and hand-out reference material were reviewed.
The inspectors concluded that the GET met or exceeded
CFR 19. 12 requirements.
It was also concluded that the respiratory protection training program also met or exceeded the requirements/recommendations prescribed in the following documents:
CFR Part 20.103,
"Exposure of Individuals to Concentrations of Radioactive Materials in air in Restricted Areas" Regulatory Guide (R.G.) 8.15, "Acceptable Programs for Respiratory Protection" NUREG-0041,
"Manual of Respiratory Protection Against Airborne Radioactive Materials" ANSI 288.2, "Practices for Respiratory Protection"
d.
External Ex osure Control Changes that had occurred in licensee's external exposure control program were examined for compliance with the requirements of 10 CFR Parts 20. 101, 20. 102, 20. 202, 20. 407 and 20. 408.
Use of external dosimeters were observed and representative radiation exposure records were reviewed.
In addition, the following licensee procedures related to occupational exposure control were reviewed:
75AC-9RP01, 75RP-9ME21, 75RP-9ME24, 75RP-9RP05, 75RP-9RP06,
"Radiation Exposure and Access Control"
"TLD Issue, Exchange and Termination"
"Dosimetry Processing, Evaluation and Documentation"
"Contamination Dose Evaluation"
"Hot Particle Control" No examples of whole body, skin or extremity exposures over administrative limits were observed to have occurred.
e.
Internal Ex osure Control The licensee's respiratory protection program was examined for compliance with 10 CFR Part 20.103,
CFR Part 1910.134(d)(2)(ii)
requirements; and agreement with the. recommendations of R.G.
8'5, NUREG-0041, and ANSI-288.2.
The examination included a tour of the licensee respirator processing facility, review of the applicable respiratory protection program implementing procedures, review of the respiratory protection training program (as discussed above),
observation of respirator fit-up activities, and inspection of the breathing air supply system.
In addition, discussions related to this program area were held with responsible licensee staff members.
Selected records related to breathing air quality analyses, respirator issue and return, and inspections of respiratory protection equipment in storage were also examined.
I Documents reviewed included the following:
"ANPP Facial Seal Protective Policy" 75AC-9RP06, "Respiratory Equipment Usage in the RCA" 75PR-ORP02,
"Respiratory Protection Program" 75RP-9EE01,
"Respirator Fit Testing" 75RP-9EE03, "Air equality Determination" 75RP-9EE02,
"Respiratory Equipment Maintenance, Inspection and Repair" 75RP-ORP02,
"Respiratory Protection Program" 75RP-9RP21,
"Airborne Radioactivity Sampling Methodology Evaluation, and Exposure Tracking" 75RP-9ZZ49,
"Issue and Return of Respirators" NRC Information Notice (IN) 85-87,
"Hazards of Inerting Atmospheres" NRC IN-85-06, "Contamination of 8reathing Air Systems"
The RICH has ultimate responsibility for the respiratory protection program.
Implementation of the program is shared by the training group, the central radiation protection support group and by each unit's radiation protection managers.
The source of breathing air used by the licensee is each unit's service air system (SAS).
The compressors are located on the 100 foot level of the Turbine Building in each unit.
During a tour of Unit 2 Turbine Building the inspectors noted a strong ammonia odor which was located approximately 75 to'100 feet from the air compressor intake.
In addition the inspectors noted other types of machinery/equipment were in proximity t'o the compressor and that could have a potential for contaminating the breathing air supply system.
This observation was discussed with the breathing air system engineer (SE) and mechanical engineering supervisor.
The SE provided the inspector with the following documents that are related to this matter:
Document Date/Revision Plant Change Request (PRC) 89-13-1A-009 Service/Breathing Air Procedure 43DP-3IA02 Engineering Evaluation Report (EER) 89-lA-009 EER 89"1A-010 Certified Industriai hygienist (CIH) Letter Breathing Air Compressor Letter PCR Letter to Relocate Air Intakes Limited Use of Breathing.Air Letter Cancellation Request ot PCR 89-13-1A-009 02/15/89 Revision
03/14/89 03/22/89 08/10/89 08/29/89 06/25/90 09/21/90 10/02/90 It should be noted noted that 29 CFR Part 1910.134(d)(2)(ii) states, in part, the following concerning breathing air supplying compressors:
"Compressors shall be constructed and situated so as to avoid entry of contaminated air into the system and suitable in-line air purifying sorbent beds and filters installed to assure air quality..."
In addition the Compressed Gas Association, Inc.'s Pamphlet G-7, Section 3.15, states, in part, concerning breathing air quality:
"The quality of the air taken into the compressor intake is a major factor in governing the quality of air which will be delivered from the compressor.
The location of the compressor intake is most important. It should be so located that the air taken in will be as uncontaminated as the general atmosphere in the area.
This means that the intake must be located where it will not become contaminated by exhausts of automotive vehicles (or the exhaust of a gasoline or diesel engine used to drive the compressor),
that it
does not take in strong localized odors, or undesirable contaminates."
The principal recommendation made by, the initial PCR was to relocate the compressor intake to a location outside the Turbine Building as recommended by 29 CFR 1910.134.
The recommendation was subsequently turned down by the Plant Modification Committee (PMC).
The PMC's action was justified by a cost-benefit analysis.
The licensee did approve another PCR to relocate the vent lines on the ammonia and hydrazine tanks to the Turbine Building exhaust ventilation.
Additionally, the licensee approved safety recommendations for the implementation of administrative controls in procedures as a means of minimizing the potential for the introduction of contaminates into the breathing air system.
The inspectors noted that the licensee routinely utilized special filter systems between SAS connections and breathing air line manifolds that will warn of and remove toxic aerosols from breathing air.
The above observation was discussed at the exit inter view.
The inspectors were informed that the issue of rerouting the compressor's intake to a location outside the Turbine Building was still under evaluation.
The Unit 1 Plant Manager stated that an agreement has not been reached as to where to reroute the intake.
The inspectors emphasized the importance for reaching a timely resolution to the problem.
The inspectors informed the licensee that this matter would referred to OSHA in accordance with the memorandum of understanding between the NRC and OSHA.
Discussions held with the licensee's staff disclosed that the respiratory protection program does not include any provision for monitoring the service air system for possible radioactive contamination.
The licensee's staff felt confident the introduction of radioactive contaminates was not likely to occur based on system design and administrative controls.
The licensee's staff stated that they would reevaluate the need to establish some kind of periodic monitoring requirements for checking the service air system for radioactivity.
All other aspects of the licensee's respiratory protection program were consistent with regulatory requirements and other documents referenced above.
The inspectors concluded that the licensee's program was fully capable of meeting their safety objectives.
Control of Radioactive Material and Contamination Surve s
and
~Mon)tor>n The inspectors examined selected radiation, contamination, and air particulate survey records to determine compliance with 10 CFR Part 20.201 and applicable licensee requirements.
The inspectors found surveys to be complete, accurate, and management review was timely.
Selected records of clothing and skin contamination occurrences were
reviewed and found that followup actions were appropriate and timely.
The inspectors reviewed contamination control practices associated with the repair of approximately 25 leaking valves in Unit 1 during the 1991 maintenance outage.
Personnel exposure records associated with the repair of the valves were also reviewed.
The review of personnel contamination events that occurred during the Unit 1 outage disclosed the following:
A goal of 25 personnel contamination events was established for the outage.
Thirty-one events actually occurred.
A policy was developed during the outage to establish a
personnel contamination event "awareness" program.
Information regarding each personnel contamination event was posted in a conspicuous location whereby personnel entering the RCA could review the information in order to motivate themselves into taking the necessary precautions for preventing a recurrence.
The policy also included a proactive role be taken by the contaminated individual's supervisor.
Supervisors were tasked with thoroughly evaluating each contamination event with the contaminated individual and staff, and are also required to report the results of their evaluation to the radiation protection group.
The highest personnel contamination event recorded were two
"hot particle" incidents of 220,000 disintegrations per minute (dpm) and 900,000 dpm, respectively.
Neither of these events resulted in any significant personnel exposure.
The inspectors were informed that the personnel contamination awareness program would be established at the all other units during their scheduled outages.
The inspectors concluded that the licensee's program in this area had improved.
g.
Maintainin Occu ational Ex osure ALARA The inspectors examined the licensee's ALARA program by observation, discussions with responsible personnel, review of applicable procedures and records, and by direct participation (e.g., attending ALARA committee and plant management ALARA meetings).
(1)
Pro ram/Or anization The licensee's ALARA program/organization, including the preparations and planning for the 1991 Unit 1 maintenance outage are discussed in NRC Inspection Report 50-528/90-55.'
"I
(2)
Plannin and Pre arations An inspector attended several ALARA planning meetings, that were related to preparations and scheduling for the Unit 3 refueling outage, which is scheduled to start in mid-March 1991.
In addition the inspector held discussions with individuals responsible for Unit 3 outage planning and preparation activities.
The inspector also reviewed selected work packages and work orders that are to be accomplished during the outage.
Other items such as ALARA goals and staffing levels required to support the outage were also rev'iewed and discussed with the licensee's staff.
The following observations were made:
The outage is scheduled to last 70 days.
An ALARA goals of 150 person-rem for the entire outage was established.
A goal of 105 personnel contamination events was established for the entire outage.
The radiation protection staff determined that 175 radiation exposure permits (REPs) would be required to support the 3500 work orders that were planned to be accomplished during the outage.
The inspector expressed some concern because of the late start in preparing the REP's.
e Due to the above concern, approximately 25 contractor radiation protection technicians were reassigned from the Unit 1 outage to support the preparation of the Unit 3 outage REPs.
The Unit-3 ALARA staff focused their planning on critical outage work, such as:
Steam generator inspections Reactor coolant pump work Reactor destack/restack Local Leak Rate Testing/Motor Operate Valve Analysis and Test Systems (LLRT/MOVATs)
Reactor cavity decontamination Snubber Inspections The planning and preparations for the above work began as early as July 1990.
The lessons learned from previous onsite and offsite outages were being factored into the Unit 3's outage planning and preparations work packages.
The licensee had adopted the "war games" concept that is discussed in inspection report 50-312/90-, 55 into planning and preparation efforts associated with Unit 3's outage.
This concept was fully supported by all plant work groups and has received the full support of management.
Other subjects discussed at ALARA meetings involved:
J(
Plant chemical cleanup.
Degass of the reactor coolant system and pressurizer steam space.
Waste minimization.
(3)
Workers Awareness and Involvement The inspectors noted that ALARA awareness among workers interviewed had improved from what had been, observed during previous inspections.
(4)
ALARA Results A followup to the status of the 1991 Unit 1 outage during the time of this inspection disclosed the following:
The outage was scheduled to last for approximately 45 days.
It was completed in 32 days.
An additional work load of unplanned and unscheduled work
= (e.g.,
emergent work) was incorporated into the outage.
Exposures associated with LLRT were higher than predicted.
An ALARA goal of 54 person-rem was established for the outage.
As of February 12, 1991, with greater than 99.5X of the outage completed, a total of 48.5 person-rem had been expended.
The 48.5 person-rem was based Self Indicating Dosimeters (SID)
readings.
This value will probably decrease after the personnel thermoluninescent dosimeters (TLD) are processed.
It was apparent that the entire Unit 1 staff were prepared to support any contingencies that arose and still maintained an effective ALARA program.
Generally, the exposures ass'ociated with most activities were lower than the projections.
The inspectors commended the licensee's staff for'heir accomplishment associated with Unit 1's outage.
The licensee's performance in this area showed signs of improvement.
The inspectors concluded that the licensee's programs under this subject area were capable of meeting their safety objectives for protection of personnel from radiation and reducing personnel
'xposures.
3.
Followu 92701 Closed Followu Item 50-528/90-51-02:
This item concerned the measurement of gaseous radioactsvlty releases from the boric acid concentrator (BAC) to the plant vent.
An NRC confirmatory measurements inspection (conducted in late 1990) of the BAC feed from the chemical and volume control system hold-up tank and the BAC determined that the decontamination factor for Co-60 was approximately 1000, which was consistent with licensee results previously referenced in NRC Inspection Report 50-528/90-5 The inspectors also performed independent calculations of the potential gaseous radioactivity release.
This calculation was consistent with the licensee's chemistry department's evaluation of this item and confirmed their observation that no radioactivity had been detected in the plant vent.
4.
Facilit Tours 83729 and 83750 Tours of the licensee's facilities were conducted during the inspection.
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, 1991.
Discussions were held with workers to evaluate aspects related to the effectiveness of the radiation protection program.
A licensee quality assurance momtor ((AM) accompanied the inspectors during a tour of Unit 1.
During the tour, the inspectors observed efforts taken by the licensee's staff to minimize generation of radioactive materials/waste, including efforts to preclude the introduction of clean materials into contaminated areas during Unit-1's post outage activities.
The following observations were made:
t a.
Posting and labeling practices were consistent with 10 CFR Parts 19.11 and 20.203.
b.
Cleanliness in the areas that were toured was excellent.
c.
,All portable instruments observed were in current calibration.
d.
Work practices observed were consistent with the applicable Radiation Exposure Permits and the Licensee's A1ARA program.
The Unit.l decontamination facility was found to be cluttered with material used during the outage.
Bags containing contaminated materials were lying across the step-off pads where sharp items could easily damage the bags.
The (AM photographed the untidy conditions and documented it as a deficient condition.
The licensee's staff took immediate action to correct the problem.
f.
An uncontained leaky air valve within a posted radioactively contaminated area was noted to be blowing freely.
Without proper containment this can spread contamination beyond the contaminated area boundary.
The (AM who accompanied the inspector stated that this condition had existed for a few days.
The (AM wrote the observation as a deficiency report.
The licensee's programs appeared capable of meeting their safety objectives.
No violations or deviations were identified.
5.
Exit Interview 83729 and 83750 The inspectors met with the individuals denoted in Section 1 at the conclusion of the inspection on February 15, 1991.
The scope and findings of the inspection were summarized.
The licensee was informed that no violations or deviations were identified.