IR 05000528/1991023
| ML17305B650 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/08/1991 |
| From: | Coblentz L, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B649 | List: |
| References | |
| 50-528-91-23, 50-529-91-23, 50-530-91-23, NUDOCS 9107230064 | |
| Download: ML17305B650 (15) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Reports 50-528/91-.23, 50-529/91-23, and 50-530/91-23 Licenses NPF-41, NPF-51, and NPF-74 Licensee:
Arizona Public Service Company P. 0. Box 53999, Sta.
9D12 Phoenix, Arizona 85072-3999 Facility: Palo Verde Nuclear Generating Station Units 1, 2, and
Inspection location:
Wintersburg, Arizona Inspection duration:
June 10-14, 1991 Inspected by:
L.
.
o n z, a iatx n pecza est sp'texgne Approved by:
G.
PE Yuha Chief Reactor Radar, ogical Protection Branch
~7 Date Signed
~Summa Areas Ins ected:
Routine, unannounced inspection of followup items and externa exposure controls.
Inspection procedures 92700, 92701, 83724, and 83750 were used.
Results:
The licensee's programs for external exposure control and personal dosimetry appeared to be adequate in meeting the licensee's safety objectives.
Several minor problems were noted in the posting of hot spots and in control of contamination (see Section 4 of the report).
No violations of NRC requirements were identified.
9107230064,910708 PDR ADOCK 05000528
~ ~
DETAILS Persons Contacted Licensee T. Bradish, Manager, Compliance P. Coffin, Engineer, Compliance R. Flood, Plant Manager, Unit 2 R. Pullmer, Manager, Quality Assurance and Monitoring T. Hillmer, Manager, Radiation Protection (RP) Support Services P. Hughes, General Manager, RP A. Ogurek, Corporate Assessment Manager J. Scott, Assistant Plant Manager, Unit 3 M. Shea, Manager, RP, Unit 2 J. Sills, Manager, RP,'nit
W. Sneed, Manager, RP, Unit 3 Others W. Barley, Acting Manager, RP Technical Services, Bartlett Nuclear, Inc.
P. Galon, Inspector Intern, NRC K. Hall, Site Representative, El Paso Electric R. Henry, Site Representative, Salt River Project S. Kanter, Site Representative, Owner Services J. Ringwald, Resident Inspector, NRC The individuals listed above attended the exit interview held on June 14, 1991.
The inspector met and'held discussions with additional members of the licensee's staff during the inspection.
Onsite Followu of S ecial Re orts (92700)
Item 50-529/88-09-Y5 (Closed):
This fifth supplement to a special report SR informed NRC that a radioactive effluent monitor design change package (DCP) development date had been extended.
The licensee's investigation had determined the cause to be "ground looping" (i.e.,
original design had allowed noise on the plant ground to couple with the detector preamplifier along a capacitive feedback path, forcing the preamplifier into oscillation).
Although temporary modifications had effectively eliminated the spiking, delays in procuring the desired wiring insulation had delayed approval of the DCP.
Discussions with the system engineer revealed that, procurement issues had been resolved, and that the DCP had been approved.
In addition, the inspector noted that the licensee had taken steps to resolve other longstanding effluent monitor problems (e.g., moisture accumulation affecting monitor operability).
The inspector had no further questions in this matte.
P~ll (92t0
>
Item 50-529/91-13-01 (Closed):
This item concerned the licensee's manner o
reporting t e cause'o inoperability" (as required by Technical Specification (TS) 3.3.3.8) for radiation monitors inoperable greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The inspector had noted that oversimplification of the causes of monitor inoperability might result in failure to address existing deficiencies that would impact future performance.
The licensee had reexamined three SRs, and'ad agreed that further information was appropriate to describe additional factors that had delayed returning the monitors to service.
In addition, the licensee had revised the SR format to include causes of additional delay under "Actions Taken."
The licensee stated that this practice would allow trending of problems experienced during monitor maintenance and repair.
The inspector had no further questions in this matter.
4.
External E osure Controls (83724 83750)
The inspector examined this program area by review of applicable records and procedures, observation of work in progress, facility tours, and discussions with cognizant personnel.
Within this program area, the inspector examined personal dosimetry, administrative controls, and contamination control.
Personal Dosimetr The inspector examined personnel exposure reports, selected personnel exposure records, the lost or damaged dosimetry log, and procedures for operating and performing quality control checks on the thermoluminescent dosimeter (TLD) reader.
These reviews revealed the following items:
The licensee's equival.cuts to NRC Forms 4 and 5 included all necessary information, and had been properly completed in all instances noted.
Skin exposures identified in personnel contamination reports had been accurately calculated and entered in the individuals'xposure records.
All facial contaminations noted had received appropriate bioassay monitoring, and corresponding information had been entered in the individuals'xposure records.
Personnel dose investigations for lost or damaged dosimetry were thorough, well documented, and adequately reviewed.
Reports issued to various work groups and supervisors appeared useful in tracking personnel exposure and maintaining doses ALARA.
In addition, the inspector held discussions with several representatives of the dosimetry group, and observed performance of TLD reading, quality checks, and exposure record maintenance by several dosimetry technician ~ ~
These observations and discussions revealed the following additional items:
The licensee had maintained National Voluntary Laboratory Accreditation Program (NVLAP) accreditation in all categories of ANSI N13.11, including neutron dosimetry and low-,energy photon accideat dosimetry.
Dosimetry technicians observed were knowledgeable of applicable procedures and famiIiar with monitoring equipment capabilities.
The licensee's methods of ensuring quality control of dosimetry programs appeaied excellent.
In addition to M~ accreditation and internal gC programs, the licensee performed periodic intercomparisons with two university and consultant laboratories.
The licensee's personal dosimetry program appeared fully capable of accomplishing the licensee's safety objectives.
No violations of NRC requirements were observed.
Administrative Controls
CFR 19.12 requires, in part, that all individuals working in a radiologically restricted area shall be kept informed of the radiological hazards present.
The inspector examined the licensee's administrative controls for informing individuals of radiological hazards, including general employee training (GET), radiation exposure permits (REPs),
access control briefings, posted copies of recent surveys, and radiological postings and labels.
The inspector's review revealed the following items:
The licensee's CFT text states that REPs will provide information about radiological conditions to be encountered, such as dose rates, contamination levels, and airborne radioactivity.
The inspector observed, however, that none of, the actual REPs posted at the entrance to the Radiologically Controlled Area (RCA) listed actual radiological hazards to be encountered.
The inspector observed, further, that Licensee Procedure 75AC-9RPOl,
"Radiation Exposure and Access Control," states in part:
3.3.1.2 A REP shall specify... the radiological conditions at the job location...
In response to the inspector's observations, the licensee state'd that Standard REPs (i.e., long-term REPs designated for a routine work function or specific work group) simply referred the worker to current survey results, which might be expected to change from time to time.
The inspector noted that neither the GET text nor the above procedure made this distinction about the lack of dose rate information on Standard REPs.
During a tour of Unit 1, the inspector observed that copies of weekly surveys posted throughout the Radwaste Building and Auxiliary
Building were not in all cases current, and in one instance did not indicate the presence of a high radiation area.
The inspector noted, however, that the high radiation area was posted with the appropriate radiological hazard sign.
In response to the inspector's observations, the licensee stated that posted surveys were to be maintained current, and promptly replaced the out-of-date surveys.
The licensee stated, however, that these posted surveys were only intended as a backup measure, and that current surveys were always maintained at the entrance to the RCA.
The licensee stated, further, that all workers were expected to check in at the access control point, and that the RPT on duty was responsible to inform each worker of current survey information.
The inspector noted that, while checking in at the access control point prior to initial RCA tours at Units 1 and 2, the on-duty RPTs had not provided current survey information.
On all subsequent tours, however, RPTs had been helpful in informing the inspector of radiological hazards to be encountered.
The inspector conducted independent dose rate surveys in Units 1 and 2 using ion chamber survey instrument NRC RO-2 j/022906, due for calibration August 15, 1991.
Posting of radiation areas and high radiation areas in all cases observed was in keeping with licensee procedures, and in accordance with the requirements of 10 CFR 20.203.
For areas inside the RCA in which non-routine operations might cause dose rates to vary extensively, the licensee had initiated use of a new posting that included the word "Caution," the radiation symbol, and an insert reading "Alarming Dosimeter or RP Escort Required."
These areas were not otherwise designated as radiation or high radiation areas.
The inspector observed that most Standard REPs required individuals to wear alarming dosimeters in high radiation areas, but that high radiation area postings were not provided with the above insert.
In addition, several workers questioned by the inspector were not clear as to the reason for requiring alarming dosimeters in areas not otherwise 'posted.
The inspector observed that the GET text covered the use of alarming dosimeters in high radiation areas, but did not cover the new alarming dosimeter posting for areas of variable dose rate.
Finally the inspector noted a recent instance in which the resident NRC inspector, had observed an individual entering a posted high radiation area without the required alarming dosimeter, The, inspector asked the licensee whether workers had been properly trained on the new alarming dosimeter posting.
The licensee stated that such training had been provided, but acknowledged that the posting might in some cases be confusing, and stated that further consideration was being given to alternate means of keeping workers informed of changipg dose conditions.
The licensee stated, further, that the new posting was not intended to be an alternative to
~ ~
properly posting high radiation areas during changing radiological conditions'he licensee's procedure for "Radiological Posting,"
75RP-ORPOl, requires the posting of radiologically hazardous
"hot spots,"
and defines a hot spot as "an accessible localized point wit% a contact radiation level which is 100 mrem/hr or greater.
and is greater than or equal to five (5) times the general area dose rate as measured
inches from the hot spot."
The inspector noted that this definition did not account for normal reduction in dose rate due to distance from the radiation source, except in instances of minute point sources.
As an example, the inspector noted that for a radiation source measuring 300 mrem/hour on contact and 80 mrem/hr at 18 inches, licensee procedure would not require posting the radiation source as a hot spot, even if nearby general area dose rates were negligible.
During tours of Units
and 2, the inspector surveyed three areas in which radiation sources similar to the example above had not been posted.
The inspector asked two RPTs what the requirement was for posting a
hot spot.
Both RPTs stated that a hot spot was an area in which the radiation level at 18 inches was 100 mrem/hr or greater and greater than five times the general area dose rate.
The inspector noted that this criteria was considerably different than the definition provided in the above procedure.
In response to the inspector's observations, the licensee acknowledged that posting of hot spots in accordance with the above procedure might not provide optimal information to workers concerning the level of radiological hazard present.
The licensee stated that consideration would be given to revising the procedural definition.
In addition, the licensee stated that the RPTs mentioned 'above would be retrained on hot spot posting criteria.
With the exception of the deficiencies noted above, the licensee's administrative controls for keeping individuals informed of radiological hazards appeared to be adequate in meeting the licensee's safety objectives.
No violations of NRC requirements were observed.
Contamination Control During facility tours, the inspector noted two problems relating to control of contamination, as follows:
Floor drains in the Unit 2 Radwaste Building did not appear to be consistently posted as having internal contamination.
The inspector conducted a smear survey of several floor drains on the 100'evel which were not marked as having internal contamination.
Contamination levels in the areas surveyed ranged from less than 1000 disintegrations per minute (dpm)/100 square centimeters (sq cm)
to 10,000 dpm/100 sq c !
e
In response to the inspector's observations, the licensee stated that a recent procedural change required all floor drains within the RCA to be posted as having internal contamination.
Floor drains throughout the Unit 2 Auxiliary Building and Radwaste Building were promptly posted.
Housekeeping in several areas of the Radwaste Buildings of Units
and 2 a~peared to be less than adequate.
In the Unit 2 truck bay on the 100 level, the inspector noted that masslin rags, protective clothing, and other items had been discarded outside a posted Contaminated Area.
The inspector surveyed several of these items at the nearest frisker, Model RM-20, Serial 81512, due for calibration September 19, 1991.
The inspector's survey measured contamination levels on one masslin rag at 50,000 dpm/100 sq cm.
The inspector informed the access control point, who immediately sent an RPT to survey the area.
The RPT verified the inspector's measurement of the contaminated masslin rag.
In addition, the RPT found two other contaminated rags that had been discarded outside the posted Contaminated Area.
Surveys of the truck bay revealed no other contamination outside the posted area.
In response to the observations of the inspector and the RPT, the'icensee issued a Radiological Controls Problem Report (RCPR),
promptly corrected housekeeping problems in the truck bay, and conducted supervisory tours to identify any similar problems elsewhere in the RCA.
The inspector noted that the actions of the RPT in surveying the area, disposing of the contaminated items, and informing the access control point were prompt and thorough.
The inspector noted the following additional items revealed by the licensee's investigation of the problem:
+
Two days prior to the inspector's tour, a worker's clothing had been contaminated while setting up resin transfer equipment in the same truck bay.
The worker had not been working inside the posted Contaminated Area.
+
Prior to the inspector's tour, a dewatered resin liner, had been transferred from the posted Contaminated Area to the outside storage yard.
No contamination problems had been encountered.
The inspector's tours of other areas shoved occasional areas where housekeeping warranted improvement; hovever, in no other instances were contaminated itans found outside posted Contaminated Areas.
The inspector concluded that the problem of contamination control in the truck bay appeared to be an isolated instance, and that the licensee was taking aggressive action to ensure the problem was not widesprea I ~
t
The licensee's program for control of contamination, where observed, appeared to be adequate in meeting the licensee's safety objectives.
No violations of NRC requirements were observed.
5.
Exit Interview The inspector met with licensee management at the conclusion of the inspection on June 14, 1991.
The scope and findings of the-'inspection were summarized.
The licensee acknowledged the inspector's observation C ~
l