IR 05000528/1995007
| ML17311A764 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/27/1995 |
| From: | Guerra G, Murray B, Ricketson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17311A762 | List: |
| References | |
| 50-528-95-07, 50-528-95-7, 50-529-95-07, 50-529-95-7, 50-530-95-07, 50-530-95-7, NUDOCS 9504130208 | |
| Download: ML17311A764 (22) | |
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION
REGION IV
Inspection Report:
50-528/95-07 50-529/95-07 50-530/95-07 Licenses:
NPF-41 NPF-51 NPF-74 Licensee:
Arizona Public Service Company P.O.
Box 53999 Phoenix, Arizona Facility Name:
Palo Verde Nuclear Generating Station, Units 1, 2,
and
Inspection At:
Wintersburg, Arizona Inspection Conducted:
March 6-10, 1995 Inspectors:
L. T. Ricketson, P.E.,
Senior Radiation Specialist Facilities Inspection Programs Branch G. L. Guerra, Radiation Specialist Facilities Inspection Programs Branch Approved:
. Murray, C ie
,
aci i ies nspection Programs Branch Oate Ins ection Summar Areas Ins ected Units
2 and
Routine, announced inspection of radiation protection activities associated with Unit 2 Refueling Outage (U2R5).
Areas reviewed included audits and appraisals, changes, planning and preparation, training and qualifications, exposure controls, control of radioactive materials and contamination, surveying and monitoring, and the program to maintain radiation exposure as low as reasonably achievable (ALARA).
Results Units
2 and
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Management oversight of Unit 2 outage activities.
through quality assurance surveillances and radiation protection management tours, was appropriate.
(Section 2. 1)
9504i30208 9'504iO PDR ADQCK 05000528
Although the permanent radiation protection staff was reduced as a
result of the licensee's re-engineering initiative, the staffing level remained at a level sufficient to ensure radiation safety (Section 2.2).
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Overall, the radiation protection organization planned appropriately for the refueling outage.
Preparation for individual tasks, in the form of prejob briefings, improved through the course of the inspection (Section 2.3)
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Radiation exposure controls were generally good.
Radiation exposure permits were made easier to use and understand.
Performance by radiation protection technicians was consistently good when they were assigned to specific tasks, such as job coverage.
Additional attention was needed in monitoring the change of local radiation levels and the affect hot spots had on the general radiation levels in surrounding areas (Section 2.5).
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Control of radioactive materials and contamination was the weakest area of the licensee's program.
A violation was identified by the inspectors for failure to post a high contamination area.
Additional problems have been identified by the licensee (Section 2.6).
ALARA goals for tasks projected to accrue the most exposure were challenging and the licensee's performance in relation to its goals was good (Section 2.7).
Summar of Ins ection Findin s:
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Violation 529/9507-01 was identified (Section 2.6).
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Violation 528/9318-02 was closed (Section 3. 1).
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Violation 528/9318-03 was closed (Section 3.2).
Unresolved Item 528/9318-04 was closed (Section 3.3).
Violation 528/9352-01 was closed (Section 3.4).
Violation 528/9352-02 was closed (Section 3.5).
Inspection Followup Item 528/9352-03 was closed (Section 3.6).
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Inspection Followup Item 528/9424-01 was closed (Section 3.7).
Attachment:
Attachment Persons Contacted and Exit Meeting
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-3-DETAILS
PLANT STATUS During the inspection, Unit 2 was involved in a refueling outage.
This inspection covered days 30-34 of a projected 56-day outage.
OCCUPATION RADIATION EXPOSURE CONTROL (83729 AND 83750)
The licensee's program was inspected to determine compliance with Technical Specification 6.8 and the requirements of 10 CFR Part 20, and agreement with the commitments of Chapter 12 of the Final Safety Analysis Report.
2. 1 Audits and A
raisals The inspectors reviewed surveillances of outage activities conducted by the quality assurance organization.
The surveillances evaluated radworker practices, radiation protection support, industrial safety, and housekeeping.
The surveillances were productive, noting poor radworker practices, leaking water, and safety hazards.
The inspectors determined that the surveillance provided management with accurate information regarding working conditions and radiation worker practices in containment.
Records of entries into containment by selected radiation protection management were reviewed, and the inspectors determined that an adequate number of entries were made by the managers to observe conditions and maintain an appropriate level of work oversight.
2.2
~Chan es The licensee had recently completed its re-engineering initiative with regard to the radiation protection organization.
The number of authorized, permanent staff members was reduced from 168 to 155.
The major change involved the consolidation of the radiation protection operations group with the radiation protection outage and maintenance group, under one department leader.
2.3 Plannin and Pre aration The inspectors verified that the licensee stocked ample supplies of protective clothing, radiation survey instrumentation, and consumable supplies.
The inspectors identified no work delays because of shortages in radiation protection support and concluded that the permanent radiation protection staff was appropriately supplemented for the outage by contract technicians.
As part of the evaluation of the licensee's preparation for outage work, the inspectors attended prejob briefings presented to the workers before performance of jobs expected to accrue significant radiation exposures.
The first briefing attended was in preparation for the decontamination of the upper cavity and reactor vessel flange.
The briefing was required by Radiation Exposure Permit 2-95-3016B.
The inspectors determined that the briefing was adequate.
It included discussions of dosimetry requirements, protective clothing requirements, radiation protection job coverage, area dose
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rates, and special radiation dose prevention instructions such as those dealing with objects found on the cavity floor.
However, the briefing was not given under the optimum conditions.
For example, the room was crowded, and the speaker could not be heard at times.
Ringing telephones and people entering the room during the briefing added to the distractions.
Radiation protection representatives conducting the meeting stated that they had not expected the large number of personnel that attended.
The inspectors later attended a briefing presented prior to reactor head replacement.
The briefing was required by Radiation Exposure Permit 2-95-3010A.
A good briefing was conducted.
The briefing area was larger and better able to accommodate those being briefed and there were fewer distractions.
The radiation protection instructions presented during the two briefings observed by the inspectors were presented by the same individual.
The inspectors inquired as to the means of ensuring that briefings were comprehensive and consistent if presented by other individuals, since the licensee did not use a checklist or scripted notes.
In response, radiation protection representatives stated that this was addressed by only allowing section leaders, the more experienced personnel, to present briefings for work activities having the highest potential for exposure (designated as Category
work).
Separate lists were not maintained to document attendance of prejob briefings which were presented as a requirement of some radiation exposure permits.
Attendees were required only to sign the radiation exposure permit list following the briefing.
However, the inspectors determined that workers could have their names added to the exposure permit list, at a later time, simply by stating that they had attended the briefing.
Radiation protection personnel had no means of verifying the workers'ttendance of briefings.
This was determined to be a potential weakness in the radiation exposure permit program.
The inspectors attended radiation protection supervisor turnover meetings and subsequent staff briefings at shift changes and noted that communication was good.
Upcoming work activities were listed, and priorities were clearly stated.
2.4 Trainin and ualifications The inspectors reviewed selected resumes of contract radiation protection technicians.
No problems were identified with regard to individuals meeting the licensee's qualification requirements.
2.5 Ex osure Controls The inspectors reviewed radiation exposure permits and observed that the permits had been simplified and were easier to understand than during the previous inspection.
The inspectors determined that the exposure permits continued to offer good guidance in maintaining low radiation exposur J
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-5-The inspectors conducted tours of the containment building and observed work activities associated with steam generator eddy current testing, cavity decontamination, and reactor head replacement.
Numerous jobs of smaller scope were also observed.
The inspectors determined that radiation protection coverage was good.
Proper use of dosimetry was noted.
Alarming dosimeters were worn by individuals entering areas identified as having high radiation levels.
Air sampling was performed appropriately.
Health physics practices are discussed in Section 2.6.
During tours of the containment building, the inspectors conducted independent radiation surveys and, on one occasion, identified a small area, near a posted hot spot on the 80-foot elevation, in which the radiation level was approximately 110 to 120 millirems per hour.
The area was on the floor, directly under safety injection piping.
This reading was confirmed by licensee personnel.
Licensee personnel posted and barricaded the spot as a
high radiation area until additional surveys could be performed.
Detailed surveys of the area and distance measurements were performed.
Accurate measurement confirmed that it was not possible to taRe radiation measurements at 30 centimeters (as per
CFR 20. 1003) in the vertical plane because of the proximity of the pipe to the floor.
Radiation levels at other points
centimeters from the source were lower than those of a high radiation area.
Therefore, the area did not meet the definition of high radiation area in accordance with 10 CFR 20. 1003 and posting was not required in accordance with
CFR 20. 1902(b).
As followup, the inspectors reviewed existing survey records of the hot spot and noted that the job-related surveys of the piping conducted February 16 and 20, 1995, indicated lower radiation levels.
This meant that radiation levels in the piping were again increasing.
Routine general area surveys of the 80-foot elevation were performed weekly.
The two most recent general area surveys, conducted February 25 and March 3, 1995, did not indicate the presence of this area but the inspectors noted also that no work was being performed in the vicinity.
Therefore, the need for special surveys and the potential for personnel exposure was low.
However, the finding illustrated the need for radiation personnel to maintain 'closer surveillance over known hot spots or areas known to be subject to changing radiation levels.
2.6 Control of Radioactive Materials and Contamination Surve in and
~Honitorin The inspectors verified that radiation detecting and measuring instruments used by radiation protection personnel were within the calibration interval and had been response tested prior to use.
The inspectors observed radiation protection personnel performing response tests on personnel contamination monitors.
No problems were noted.
Before exiting the radiological controlled area, personnel were required to perform whole body frisks in order to check for contamination on skin or clothing.
The inspectors noted that only personnel contamination monitors sensitive to beta radiation were stationed at the exit.
The inspectors discussed with radiation protection personnel the possibility of contamination on certain areas of the body, such as the tops of the feet, going undetected
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until the individual passed through a
gamma sensitive monitor at the exit of the protected area.
No problems were identi Fied and the this matter was left for the licensee's evaluation.
During tours of the containment building, the inspectors noted examples of poor health physics practices by radiation workers'hese included:
A worker performing grinding work removed and redonned a protective visor.
Such an act could increase the risk of facial contamination.
The inspectors alerted a radiation protection representative who took immediate action to instruct the individual in proper health physics procedures.
Safety glasses were leFt in contaminated areas.
Reuse could cause personnel contamination.
A worker was observed watching work activities conducted by another worker.
The first worker had lost one of his rubber shoe covers without knowing it.
The shoe cover lay nearby.
A worker performing valve work near the pressurizer removed his hard hat and did not have the hood of his protective clothing closed at the neck as he worked near the sources of contamination.
Tools were observed in various areas of containment on consecutive days, rather than being gathered for survey and return to hot tool storage area.
The inspectors concluded that, although general housekeeping could be classified as adequate, there was room for improvement in the staging and control of outage equipment and tools.
Minor problems were observed in the control of trash and extra protective clothing items.
guality assurance surveillance reports noted that general conditions had declined since the start of the outage.
On a tour of the containment building on March 8, 1995, the inspectors noted water on the floor of the 80-foot level of containment.
The water was dripping from a check valve (SIBV-332).
Licensee personnel were alerted and a
radiation protection technician collected smear samples and determined that the contamination levels were as high as 150,000 disintegrations per minute per 100 square centimeters.
The area was immediately posted as a high contamination area.
Technical Specification 6.8. 1 requires that procedures be established, implemented, and maintained covering the activities referenced in Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A, Section 7.e.(4), of Regulatory Guide 1.33 references contamination control as one of the activities.
Licensee Procedure 75RP-ORP01 requires that areas identified as having contamination levels greater than 100,000 disintegrations per minute
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-7-per 100 square centimeters be posted with radiation warning sign(s)
bearing the words:
Caution or Danger, High Contamination Area The failure to post a high contamination area was identified as a violation of Technical Specification 6.8.1.
(529/9507-01).
In response, the licensee initiated Condition Report/Disposition Request 2-5-0165 and conducted an investigation.
The licensee determined that the Unit 2 Control Room Log documented that the system with the leaking valve was placed into service approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the identification of the leaking water by inspectors.
The licensee also determined that only one crew entered the containment building specifically destined for the 80-foot elevation, and they did not work in this area.
No personnel contamination events could be attributed to this area of contamination.
Licensee representatives took the following immediate corrective actions:
Installation of a drip catch under the leaking valve,
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Decontamination and release of the area from high contamination area controls,
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Generation of a night order providing specific instruction with regard the duties of radiation protection "roving" technicians.
The inspectors reviewed selected Condition Reports/Disposition Requests during the course of the inspection and determined that there was a declining trend involving radioactive material and contamination control.
This combined with the findings of the quality assurance organization (discussed in Section 2. 1)
and the inspectors'indings, led the inspectors to conclude that this area of the licensee's program needed additional attention and that radiation protection technicians should be more aggressive in their efforts to identify problems.
2.7 ALARA The inspectors reviewed job histories and exposure totals for outage tasks and determined that exposure goals for work projected to accrue the highest doses, such as pressurizer lower nozzle replacement, were challenging.
Exposure goals for some of the lesser work, such as cavity decontamination, were less challenging; however, the inspectors noted improvement in this area.
Previously, goals were determined to be "reasonable based on historic data" rather than challenging.
Radiation control personnel reviewed, daily, the accrued exposure each outage task to determine if the person-rem totals agreed with those projected.
Daily reports of exposure totals were furnished to the managers of the various departments for their revie ~,
The licensee's goal for outage work was 215 person-rems.
Some work, such as steam generator secondary modifications, was canceled.
However, the scope of other work, such as eddy current testing and tube plugging had been expanded.
Management's strong stance on maintaining the scope of the outage, as planned, aided greatly in setting meaningful exposure goals'fter 33 days, the licensee had accrued 96 person-rems.
2.8 Conclusions Management's oversight of outage activities, through quality assurance surveillances and radiation protection management tours, was adequate.
Although the permanent radiation protection staff was reduced as a result of the licensee's re-engineering initiative, the staffing level remained at a
level sufficient to ensure radiation safety.
Overall, the radiation protection organization planned appropriately for the refueling outage.
Preparation for individual tasks, in the form of prejob briefings, improved through the course of the inspection.
Radiation exposure controls were generally good.
Radiation exposure permits were made easier to use and understand.
Performance by radiation protection technicians was consistently good when they were assigned to specific tasks, such as job coverage'dditional attention was needed in monitoring the change of local radiation levels and the affect hot spots had on the general radiation levels in surrounding areas.
Control of radioactive materials and contamination was the weakest area of the licensee's program.
A violation was identified by the inspectors for failure to post a high contamination area.
Additional problems have been identified by the licensee.
ALARA goals for tasks projected to accrue the most exposure were challenging, and the licensee's performance in relation to its goals was good.
FOLLOWUP PLANT SUPPORT (92904)
3.1 Closed Violation 528 9318-02:
Failure to Surve Potentiall Contaminated Oil Drums The licensee failed to take representative samples from barrels of oil and failed to survey the exterior of the barrels for radioactive contamination.
Also, a bag marked as containing radioactive materials was not surveyed as required and was disposed in an unapproved manner.
The incidents were investigated by the licensee and disciplinary action was administered to the radiation protection personnel responsible for the incidents.
The licensee reviewed with supervisors and senior technicians the requirements for waste sampling prior to unrestricted release.
Interim guidance was issued regarding waste characterization and disposition.
The incidents were discussed in industry events training for radiation protection
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personnel.
A waste task force was created to develop guidance for the control of waste to ensure that the waste streams were appropriately segregated.
A manual for lead technicians was established delineating management expectations when performing assigned tasks.
Procedure 75RP-9RP09,
"Vehicle, Equipment, and Material Release,"
was revised (to Revision 9) in order to include information addressing waste characterization and material disposition.
3.2 Closed Violation 528 9318-03.:
Failure to Follow Procedures Radiation protection personnel failed to initiate a Condition Report/Disposition Request when concerns were reported involving personnel error and radioactive material released outside of a radioactive materials area.
Also, contaminated items, marked with the colors yellow and magenta, were not secured for use only within the radiological controlled area.
The licensee administered disciplinary action to the radiation protection personnel involved, reiterated to supervisors the necessity of reporting incidents of this nature through the use of existing station procedures, and included a discussion of the incidents in the industry events training for radiation protection personnel.
The inspectors confirmed that the actions taken by the licensee agreed with the commitments made in response to the violation.
3.3 Closed Unresolved Item 528 9318-04:
Licensee Anal sis of Released Contaminated Oil The issue is related to the violation identified in Section 3. 1 and involved the question of whether the licensee could have released, in oil, radioactive materials in excess of the lower limits of detection used in accordance with environmental technical specifications.
The inspectors reviewed with radiation protection personnel the results of the analysis and the assumptions used and concluded that the unresolved item did not involve a violation of regulations requirements.
3.4 Closed Violation 528 9352-01:
Failure to Follow Radiation Protection Procedures A radiation exposure permit was issued without providing specific instructions regarding the special hazard of elevated contamination levels within the discharge side of the charging pump.
Additionally, the radiation protection technician providing coverage for the charging pump work failed to exercise authority to stop the work when it was determined that the contamination levels were significantly higher than expected.
As corrective action, the licensee discussed the event in Radiation Protection Industry Events Training, and the technician involved was counseled regarding management's expectations for the use of stop work authority.
The inspectors confirmed that the licensee's actions agreed with its commitment in response to the Notice of Violatio l e
-10-3.5 Closed Violation 528 9352-02:
Failure to Surve Surveys were not made to determine if individuals were exposed to airborne concentrations exceeding the limits specified in 10 CFR Part 20, during the opening of the discharge side of the "E" charging pump and the subsequent removal of the dampener bladder.
The corrective actions were the same as for Violation 528/9352-01.
3.6 Closed Ins ection Followu Item 528 9352-03:
Steam Generator Worker Ex osure Controls This concern involved the licensee's lack of formal procedural guidance on the monitoring of steam generator worker exposure.
In response, the licensee reviewed this situation and (1) developed a new dose tracking calculation sheet or "jump sheet,"
(2) revised procedural guidance (Procedure 75RP-9RP02,
"Radiation Exposure Permits" )
and included instructions on the use of the dose tracking sheets, (3) incorporated hold points into the Model Radiation Exposure Permits, and (4) developed and presented a training film for radiation protection technicians, illustrating the potential radiation gradients associated with steam generator work.
3.7 Closed Ins ection Followu Item 528 9424-01:
Control of Thermoluminescent Dosimeters The licensee implemented the use of palm readers as a security measure and discontinued the practice of relinquishing security badges, as individuals exited the protected area.
A policy had not been developed to maintain positive control over the issuance and collection of thermoluminescent dosimeters.
The inspectors confirmed that radiation workers were required to leave their thermoluminescent dosimeters in a rack near the entrance/exit of the protected area.
The inspectors observed workers leaving the area but did not identify individuals failing to leave their dosimetry on sit,
ATTACHMENT
PERSONS CONTACTED 1. 1 Licensee Pe. sonnel
- S. Bauer, Licensing Supervisor, Regulatory Affairs
- R. Bouquot, Section Leader, Nuclear Assurance J.
Bungard, ALARA Section Leader, Radiation Protection
- R. Fullmer, Department Leader, Nuclear Assurance
- J. Gaffney, Manager, Radiation Protection
- B. Grabo, Section Leader, Nuclear Regulatory Affairs
- T. Gray, Supervisor, Radiological Engineering
- R. Hazelwood, Engineer, Regulatory Affairs
- A. Krainik, Department Leader, Nuclear Regulatory Affairs J.
McDonnel, Section Leader, Radiation Protection
- W. Monteour, Senior Representative, Owner Services
- M. Shea, Director, Radiation Protection
- J. Steward, Manager, Radiation Protection Technical Support 1.2 NRC Personnel
- K. Johnson, Senior Resident Inspector A. MacDougall, Resident Inspector J.
Kramer, Resident Inspector
- Denotes personnel that attended the exit meeting.
In addition to the personnel listed, the inspectors contacted other personnel during this inspection period.
EXIT MEETING An exit meeting was conducted on March 10, 1995.
During this meeting, the inspectors reviewed the scope and findings of the report.
The licensee did not express a position on the inspection findings documented in this report.
The licensee did not identify as proprietary, any information provided to, or reviewed by the inspector