IR 05000528/1993037

Insp Repts 50-528/93-37,50-529/93-37 & 50-530/93-37 on 930920-24.One Unresolved Item Identified.Major Areas Inspected:Licensee Radiation Protection Program & Followup of Safety Evaluation Rept

ML20059A337
Person / Time
Site:	Palo Verde
Issue date:	10/01/1993
From:	Beaston V, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20059A332	List: IR 05000528/1993037 ML20059A329
References
50-528-93-37, 50-529-93-37, 50-530-93-37, NUDOCS 9310260302
Download: ML20059A337 (10)

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REGION V

r Report Nos. 50-528/93-37, 50-529/93-37, 50-530/93-37

License Nos. NPF-41, NPF-51, NPF-74

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Licensee: Arizona Public Service Company P. O. Box 53999, Station 9012 '

Phoenix, Arizona 85072-3999

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Facility Name: Palo Verde Nuclear Generating Station Units 1, 2, and 3 Inspection at: Wintersburg, Arizona Inspection Conducted: September 20-24, 1993 Inspected by: hurl b %

{aston, Re'a'to Radiation Specialist

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jddN D' ate Sitjned ,

Approved by: /N} /0!/ /93 Ja ,mes'O.'Reese, Chief Date Signed ,

F~acilities Radiological Protection Branch Summary:

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Areas Inspected: Routine, announced inspection of the licensee's radiation protection program, and followup of a safety evaluation report. Inspection procedures 83729, 83750, 92701, and 92719 were use Results: The licensee's occupational exposure program for the Unit I refueling outage (1R4) appeared fully capable of meeting its objective of protecting workers. Strengths were noted in the staffing level of senior radiation protection technical advisors for the outage, the Quality Assurance Monitoring Program, and the licensee's methods for controlling alpha '

contaminatio No violations or deviations of NRC requirements were identified within the scope of this inspection. One inspection followup item remains unresolved pending final review of licensee Incident Investigation Report No. 1-3-0375, and all the corrective actions planned by the licensee to prevent recurrer.u (Section 2.c). Two inspection followup items were closed (Sections 2.a and 2.b) and one followup item was opened (Section 2.d).

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9310260302 931001 PDR ADOCK 05000528 G PDR

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DETAILS l Persons Contacted ,

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Licensee '

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• K. Akers, QA Specialist, Quality Auditing and Monitorin *K. Coon, Sr. Technical Advisor, Unit 2 Radiation Protection-

• J. Gaffney, RP Manager, Unit 2 W. Hoey, Manager, RP Technical Service  :

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• P. Hughes, Corporate HP, Nuclear Safety

• W.-Ide, Plant Manager, Unit 1

• D. Kanitz, Sr. Engineer, Nuclear Regulatory Affairs

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• L. Johnson, Manager, Unit 2 Chemistry

• M. Lantz, Supervisor, Dosimetry W. McMurry, RP Supervisor, Unit 1 ,

• S. Sawschenko, RP Supervisor, Unit 2

• Shea, General Manager, Site Radiation Protection

• Sneed, Manager, Unit 1 Radiation Protection

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ILu_gjfar Reaulatory Commission J. Sloan, Sr. Resident Inspector (*) Denotes the individuals who attended the exit meeting held September-24, 1993. The inspector also held discussions with other personnel during the inspectio . Lollowup , NRC Information Notice C2-69 (Closed)

The inspector verified that~ the licensee had receiveci NRC Information Notice 93-69, " Radiography Events at Operating Power ,

Reactors." A member of the licensee's staff informed the i inspector that a review was being conducted by the licensee to '

determine what, if any, actions would be required as a result of the information contained in the notice. The inspector.had no further questions regarding this matte i Palo Verde LER No.92-017 (Closed)

This LER involved a whole body exposure in. excess of 10 CFR Part l 20 limits. The exposure occurred during operations to prepare a l polyethylene High Integrity Container of radioactive waste resin for transfer to a storage culvert in the Unit 1 Radwaste Storage Yard. The final analysis of time / motion studies conducted by the !

licensee resulted in the individual involved receiving an 'i unplanned whole body exposure of 1.924 Rem to the upper left ar j '

(See Palo Verde inspection reports 93-03 and 93-29 for'more information regarding this event).

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The inspector reviewed the LER and documents provided by the .:

license, and determined that the licensee had completed the )

actions specified in the LER to prevent recu/rence. This item is considered close Unit 1 Personnel Contamination Event (Unresolvedl On August 13, 1993, a member of the licensee's site management called NRC Region V to inform NRC management of a hot particle -;

contamination event which occurred on July 22, 199 The license was in the process of issuing a final report of the event; Incident Investigation Report (IIR) No. 1-3-0375, Titled

" Unit 1 Personnel Contamination and Significant Skin exposure during a Charging Pump Discharge Dampener' Bladder Replacement."

An advanced copy of this report was provided to the inspector for r revie The inspector noted the licensee appeared to have conducted a thorough investigation of the event, which identified procedural non-compliance and personnel errors as the root causes of the event. The licensee's report indicated that corrective actions for this event would be based on ar, organizational and'

programmatic assessment report of the RP Department. The inspector was not provided a cooy of that report, as it was still in draf The inspector held a meeting with the acting Site Manager, '

Radiation Protection, to discuss the personnel contamination "

event. Since the organizational and programmatic assessment was not complete and the RP Manager had not formalized.any planned corrective actions to prevent recurrence, the inspector determined this issue to be unresolved. This issue will be review again after the licensee provides NRC a final copy of IIR No. 1-3-0375- ;

and the final corrective actions planned to prevent recurrence of '

this event. An unresolved item is a matter about which more information is required to ascertain whether it is an acceptable

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item, a deviation, or a violation (50-528/93-37-01).

Unit 2 Safety Evaluation Report (SER) (00en)

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The inspector interviewed responsible members of the licensee's staff to determine the status of corrective actions addressed in an NRC SER, dated August 19, 1993, related to chemistry, radiation +

monitoring, and emergency operations. The title of the report is

" Safety Evaluation by the Office of Nuclear Reactor Regulation Related to the Startup and Operation.of Palo Verde Nuclea- ,

Generation Station.. Unit 2, following the Steam Generator Tube 3 Rupture of March 14, 1993, Arizona Public Service Compatiy, Docket No. 50-529."

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'l The SER addressed several corrective actions the licensee planned to implement as a result of the steam generator tube rupture. The !

inspector verified that the corrective actichs related to chemistry in the SER had been implemented by the license In the area of radiation monitoring, the licensee had implemented the items addressed in the SER, and was still considering the addition of a Nitrogen-16 (N-16) monitor to its leak rate progra ,

The licensee was in the process of evaluating a prototype 3"x 3" Nal detector for the detection of N-16. Members of the licensee's staff indicated that the N-16 detector may be a useful diagnostic t means for leak-rate detection, but stated that chemistry methods I would still be needed to quantify any leak-rat The inspector reviewed the following emergency operating procedures for changes made by the licensee as a result of items addressed in the SER:

• 41EP-lR003, Rev. 1; " Steam Generator Tube Rupture"

• 41EP-lR004, Rev 00.08; " Excess Steam Demand"

• 41EP-lR008, Rev. 00.13; " Functional Recovery"

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The inspector was informed that the changes made to these procedures had not been finalize. Therefore, the inspector determined that this item should remain open until the procedures '

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are issued in final form. These procedures will be reviewed again during a future inspection. This item is open (50-529/93-37-02).

, Occupational Exposure Durina Extended Outaaes During this inspection, Unit I was shut down for its forth refueling.and maintenance cycle (IR4). The inspector therefore conducted an extensive ,

review of the Unit I radiation protection program, giving particular '

attention to the licensee's methods for controlling workers' internal exposure to alpha radiation. The inspector reviewed the program for compliance with 10 CFR Part 20 requirements and licensee procedure ; Quality Assurance. Audits. and Aooraisals

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Assurance (QA) organization and reviewed the licensee's " Quality l Assurance Division's Integrated Outage Oversight Plan for 1R4," to l

. gain an understanding of QA's involvement in assuring the quality of Unit l's radiation protection program during the outag The QA organization's oversight plan for the IR4 outage appeared well organized, and it included both night-shift and weekend coverage of outage activities. An appendit to this plan, titled

"lR4 QA Integrated Oversite Matrix," identified that the Quality i

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~ 4 Monitoring group (QM) was expected to observe the following radiation protection activities during the ou,tage:

• Temporary Shielding

• Alpha Contamination Controls and Detection

• Control and Use of HEPA filters

• Maximum Permissible Concentration (MPC) Tracking

• Airborne Sampling, and

• Maintenance RP Practice The inspector reviewed QA monitoring reports covering the IR4 refueling outage. The reports reviewed were well written and provided a very detailed account of the activities observed. The inspector noted that the reports covered activities identified by '

QA for monitoring during the outage, and appeared to be effective in assessing Unit l's performance in the area of radiation protectio .

Based on interviews with QA personnel and a review of documents, the inspector concluded that the li'censee's QA coverage for the IR4 outage appeared comprehensive in the area of radiation protection. The activities identified above for monitoring during the outage should give licensee management a clear indication of how well Unit 1 performs in the area of radiation protection. The inspector had no concerns in this are Internal Exposure Control The inspector conducted an extensive review of the licensee's alpha contamination monitoring and control program. This review included an in-depth examination of the licensee's air sampling program, MPC-hours tracking program, and material release program for Unit The licensee's radiation protection organization appeared to have a good understanding of the Unit 1 alpha source term, and the potential hazard it presented. The inspector noted that licensee management had assigned both the Unit 2 and Unit 3 Senior Radiation Protection Technical Advisors to assist with the alpha contamination control and MPC-hours- tracking programs in Unit I during the outag (1) Aloha Source Term Evaluation The inspector interviewed several members of the licensee's radiation protection staff and reviewed documents to determine the bases of the alpha source term used by the licensee for the Unit I radiation protection progra The inspector learned that the alpha source term used in Unit I was based on the results of a vender supplied 10 CFR Part 61 radiological analysis, and an in-house study of 50

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smears obtained from the Unit 1 Spent Resin Transfer Dewatering Pump Room. Additionally, the licensee had sent -

Unit I smear samples from various components within the reactor coolant system pressure boundary off-site for 10 CFR Part 61 radiological analysis to reconfirm the alpha source term present in Unit Based on the 10 CFR Part 61 radiological analysis and the in-house study, the license determined the following: ,

• The Ce-144 to Alpha ration was 15-to-1, and

• The Gross Beta-Gamma contamination to Gross Alpha contamination ratio was 200-to- The inspector determined that these ratics appeared reasonable based on the data collected by the licensee, and

- had no further question (2) Aloha Contamination Control Program ,

Based on the alpha source term present in Unit 1, the licensee determined the controlling radiological hazards, and made the following conclusions which were documented in a licensee memorandum titled, " Unit 1 Alpha Contamination Study,":

(a) It was not necessary to count smears for alpha contamination when releasing tools and equipment f rom the RCA if no gross beta-gamma contamination was detected using a G-M tube. In the worst-case ratio of gross beta-gamma to alpha contamination, gross beta-gamma contamination would be detectable if alpha contamination was present in an amount requiring further evaluatio (b) It was not necessary to perform alpha counts on smears which indicated less than 5,000 dpm/100 cm' to determine alpha contamination posting requirement This level of gross Beta-gamma activity would correspond to a conservative level of gross alpha activity, below the required posting limit for alpha ,

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(c) Air samples indicating a Ce-144 activity of less than 1.5E-11 uti/cc (the LLD for Ce-144) may be assumed to contain less than 0.25 MPC Pu-239/240 (the controlling isotopes for posting airborne radiation areas).

The inspector reviewed the licensee's method for making the preceding conclusions, and determined the assumptions were

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6 l conservative. The inspector had no further questions regarding these licensee conclusions. * \

j (3) Air Samplina Proaram The inspector reviewed the licensee's air sampling program ;

for compliance with 10 CFR Part 20 requirements; licensee procedures 75RP-9RP07, " Radiological Surveys," and 75RP-9RP21, " Airborne Evaluation;" and licensee management guidance regarding the Unit 1 alpha contamination control and monitoring progra j The inspector noted that the licensee appeared to be using a !

conservative composite MPC number to determine airborne radiation area postings. For air samples identified as containing possible alpha contamination, the licensee was counting the samples at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and 5 days to allow short lived, naturally occurring radionuclides to deca The licensee had developed special alpha contamination area postings for use in the plant to alert radiation protection (RP) technicians of possible alpha contamination problems, and to ensure that workers were being properly evaluated for alpha MPC-hours, i

Based on a review of records, interviews with licensee personnel, and observations in Unit 1, the inspector had no concerns in this are (4) MPC-hours Trackina Proaram

The inspector reviewed the licensee's program for tracking and assigning MPC-hours to workers during the IR4 refueling outag The inspector noted that licensee management was aware of the potential alpha MPC-hours tracking problem that ,

the IR4 refueling outage presented, and had reassigned the Unit 2 Senior RP Technical Advisor to organize and coordinate an MPC-hours tracking program for the outag While interviewing the Senior Technical Advisor, the inspector learned that approximately 70 workers were being '.

tracked for MPC-hours. This individual was familiar with the Unit I alpha control program and frequently communicated with Unit 1 RP personnel to ensure workers were being properly assigned MPC-hours when an air sample indicated concentrations of greater than 0.25 MP >

The inspector reviewed records of three workers who were assigned 2.0, 2.0, and 2.65 MPC-hours in one day, based on air sample dat All three individuals had received a whole body count (WBC), which indicated total MPC-hours of 0.87, 0.62, and 1.09 respectively. The final MPC-hours ,

assigned to these individuals was 2.0, 2.0, and 1.0 i

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In an interview with the Dosimetry Supervisor, the inspector was informed that the licensee assigned MPC-hours to workers

using the following method:

(a) If the number of MPC-hours calculated based on air sample results was less than or equal to 2.0, and a WBC was performed, the worker would be assigned the higher of the two MPC-hour (b) If the number of MPC-hours calculated based on air sample results was greater than 2.0, and a WBC was performed, the worker would be assigned the results of the WB The Dosimetry Supervisor had determined that this method was the most accurate way to assign total MPC-hours to' worker This determination was based on the fact that air sample calculations are more accurate than WBC for determining-total MPC-hours at a level below 2.0 HPC-hour Based on a review of records and interviews with licensee personnel, the inspector concluded the. licensee was properly tracking and assigning MPC-hours. The inspector had no <

concerns in this are (5) Tools and Materials Release Prcaram .

The inspector reviewed the licensee's material release program for compliance with procedure 75RP-9RP09, " Vehicle, equipment, and Material Release," and management guidance concerning the Unit I alpha contamination control progra The inspector noted the licensee had developed alpha contamination labels which it used to label tools and materials that were bagged-out of areas posted as alpha contamination areas. These labels served to increase RP technicians awareness of the need to evaluate tools and materials for alpha contamination if they have greater than-detectable amounts of beta-gamma activit Based on a review of records., interviews with radiation protection personnel, and observations of work in progress, the inspector had no concerns in this are The inspector concluded the licensee's program for controlling internal exposure was effective. In particular, the licensee's alpha contamination control and monitoring program appeared to be comprehensive, founded on a sound technical bases, and implemented according to the various letters and management guidance reviewed by the inspector. The inspector had no concerns in this are .

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8 Unit 1 Tours of Containment .

The inspector conducted tours of the Unit l' containment buildin During parts of these tours, the inspector was accompanied by either the Unit 1 RP Supervisor or a QA Inspecto During these tours, the inspector checked general radiation ;

protection conditions (e.g., postings, and labeling), air sampler placement, use of HEPA filters, worker's dosimetry placement, and general worker knowledge of the radiological conditions in which they were working. The inspector also observed several jobs in progress, to include a portion of the hydro-lancing of a stea generator bow During one tour, the inspector noted air monitors were setup to sample the exhaust streams of portable HEPA filters. Because of the placement of the air monitors and the large difference in flow rates between the exhaust streams and the air monitors' sample rate, the inspector questioned whether the samples obtained were-representativ The Unit 1 RP Supervisor informed the inspector that the air samplers were intended to determine whether the HEPA filters were performing properly. The inspector noted however that these monitors were only used as backup indicators of HEPA filter performance. Differential pressure across the filters and dose rates were the primary means of determining when to replace the filters. The licensee was reviewing the benefit of using air monitor samples as backup indicators for filter performanc Because the licensee was considering the elimination of these air monitors, the inspector had no further concerns in this are Based on observations and discussions with workers, the inspector had no concerns, except as noted. No deviations or violations of NRC requirements were identified by the inspecto Overall, the licensee's occupational exposure control program for the IR4 refueling outage appeared adequat The inspector had no concern . Tours of Uni.t 2 and Unit 3 The inspector toured both Unit 2 and Unit 3. During these tours, the inspector checked both units for proper postings, labeling, and general radiological condition The inspector noted that the Unit 2 Turbine Building was being t controlled as an RCA due to the Unit 2 tube rupture event. There had also been a major spill (unrelated to the tube rupture event) of i slightly contaminated water from the secondary side of the plant, which had contaminated an area outside the Unit 2 Turbine Building. The area {

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had been roped off, and was also being controlled as in RCA. The licensee had included this outside area in its,:urvey program, and

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appeared to be addressing the matter properly. The inspector-had no further concerns regarding this matte ,

Based on observations, and interviews with licensee personnel, the -

inspector had no concerns with Unit 2 and Unit 3. No violations of NRC requirements were identifie . Exit Interview The inspector met with members of licensee management at the conclusion  ;

of this inspection on September 24, 1993. The scope and findings of.the inspection were summarized. The inspector identified one unresolve :

item, regarding the Unit 1 per a tel coiltamination and significant skin exposure event involving the Clary'.1g pump discharge dampener bladder replacement. None of the mata ;>*. presented to the inspector was identified as proprietar The licensee acknowledged the inspector's -

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