IR 05000528/1997003
| ML17312B257 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17312B256 | List: |
| References | |
| 50-528-97-03, 50-528-97-3, 50-529-97-03, 50-529-97-3, 50-530-97-03, 50-530-97-3, NUDOCS 9702270102 | |
| Download: ML17312B257 (28) | |
Text
ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved By:
50-528 50-529 50-530 NPF-41 NPF-51 NPF-74 50-528/97-03 50-529/97-03 50-530/97-03 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and. 3 5951 S. Wintersburg Road Tonopah, Arizona January 27-31, 1997 Gilbert L. Guerra, Jr.
Radiation Specialist Blaine Murray, Chief Plant Support Branch ATTACHMENT:
Supplemental Information 9702270i02 970220 PDR ADOCK 05000528
l
-2-EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report 50-528/97-03; 50-529/97-03; 50-530/97-03
~En ineerin
~
Reviewed practices, procedures, and parameters were consistent with UFSAR commitments (Section E2.1)
~
Plant Su or
~
An excellent liquid and gaseous radioactive waste effluent management program was implemented (Section R1.1).
An excellent safety-related air cleaning ventilation systems surveillance program was implemented (Section R1.2).
The post-accident sampling system was operational, properly maintained, and operated periodically (Section R2.2)
~
Liquid and gaseous effluent radiation monitoring instrumentation was operational and properly maintained, tested, and calibrated in compliance with the surveillance requirements specified in the Offsite Dose Calculation Manual (Section R2.3).
Effective procedures with sufficient detail were used.
No revisions to the Offsite Dose Calculation Manual had been implemented since the last inspection (Section R3.1).
Radiation monitoring and chemistry personnel had an excellent understanding of the radioactive liquid and gaseous waste management procedures, Offsite Dose Calculation Manual, and regulatory requirements (Section R4.1).
The inspector determined that the experience, training, and working knowledge of the personnel responsible for implementing the radioactive waste effluent program met the training and qualification requirements (Section R5.1).
The chemistry organization and 'staffing met Technical Specification requirements (Section R6.1).
Excellent quality assurance audit and surveillances of the radioactive waste effluent management program activities were technically comprehensive and provided good program evaluation and oversight (Section R7.1).
-3-Ap excellent Annual Radioactive Effluent Release Report for 1995 was submitted in a timely manner and contained the required information presented in the required format (Section R8.1).
The licensee effectively identified, tracked, and'implemented corrective actions for any identified problems (Section R8.2).
t
Re ort Details Summar of Plant S atus Units 1, 2, and 3 were at power operations during the inspection.
There were no operational occurrences that impacted the results of the inspection.
III. En Ineerin E2 Engineering Support of Facilities and Equipment E2.1 U dated Final Safet Anal sis Re or Review UFSAR a.
Ins ec ion Sco e
The inspector reviewed selected topics presented in the UFSAR to ensure agreement with any commitments contained therein pertaining to this inspection.
b.
Observations and Findin s A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special review that compares plant practices, procedures and/or parameters to the UFSAR descriptions.
While performing the inspection discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected.
The inspector did not note any discrepancy between the UFSAR wording and the observed plant practices, procedures, and/or parameters.
Conclusion Reviewed practices, procedures, and parameters were consistent with UFSAR commitments.
IV. Plant Su ort R1 Radiological Protection and Chemistry (RP&C) Controls R1.1 Radiolo ical Waste Effluent Mana ement Pro rams a.
Ins ection Sco e 84750 Implementation of the liquid and gaseous radioactive waste effluent management programs, as described in the Technical Specifications and the Offsite Dose Calculation Manual were reviewed.
This review included: radioactive effluent waste processing; radioactive effluent waste sampling and analyses; analyses sensitivities and results; offsite dose results; and performance of required surveillance test b.
Observations and Findin s The inspector determined that the processing, sampling, and analyses of radioactive liquid and gaseous waste effluents and the approval and performance of waste discharges were conducted in accordance with Offsite Dose Calculation Manual requirements.
Quantities of radionuclides released were within the limits specified in the Offsite Dose Calculation Manual.
Offsite doses were calculated according to Offsite Dose Calculation Manual methodologies and were within regulatory limits.
There were no liquid radioactive waste effluents released from the site.
The disposition of liquid waste effluents was to the retention basins with subsequent discharges from the retention basins to the evaporation ponds on site.
The inspector observed a radiological monitoring technician collect a liquid waste sample from the Unit 3 Chemical Waste Neutralizatio'n Tank A on January 28, 1997, and perform chemical (pH) and radiochemistry analyses (principal gamma emitters and tritium) on the sample in preparation for discharge to the retention basins on site.
All aspects of the chemical waste neutralization tank sampling and analyses were performed in accordance with approved procedures.
Liquid waste discharges were conducted in accordance with Technical Specification and Offsite Dose Calculation Manual requirements.
Sampling from the plant ventilation exhaust stack and the fuel building ventilation exhaust stack continuous releases was conducted.
The sampling, analyses, and monitoring of the continuous discharges of radioactive gaseous effluents were conducted in accordance with Offsite Dose Calculation Manual requirements and station procedures.
The inspector observed a radiological monitoring technician collect continuous release ventilation samples from the Unit 3 plant ventilation exhaust system on January 28, 1997, and the Unit 2 fuel building exhaust system on January 29, 1997, for analyses of particulates, iodine, and noble gases to update the continuous release permit for those effluent release points.
The inspector also observed a
radiological monitoring technician collect a grab sample from the Unit 2 waste gas decay tank for analysis of noble gases (principal gamma emitters) on January 30, 1997, in preparation for release of the waste gas decay tank.
The inspector noted during these observations that the radiation monitoring technicians carried, referred to, and followed the appropriate sampling procedures while performing the sample collections.
All aspects of these sample collections and analyses were performed in accordance with approved procedure "6-Conclusions An excellent liquid and gaseous radioactive waste effluent management program was implemented.
Quantities of radionuclides released in the liquid and gaseous radioactive waste effluents were within the Offsite Dose Calculation Manual limits.
Offsite doses to the environment from the liquid and gaseous radioactive waste effluents were calculated using Offsite Dose Calculation Manual methodologies, and the dose results were within regulatory limits.
En ineered S fe Fea ure Fil ra ion and Control Room Habi abili
~Ss ems Ins ection Sco e 84750 Surveillance and test results for the safety-related air cleaning ventilation systems testing program were reviewed to determine agreement with the commitments in the UFSAR and compliance with the requirements in the Technical Specifications.
Observations and Findin s The inspector performed a walkdown visual inspection with the system engineer of the control room essential filtration system, engineered safety features pump room air exhaust cleanup system, and the fuef building essential ventilation system.
These systems contained high efficiency particulate air filters and activated charcoal adsorbers.
The walkdown external inspection of the identified ventilation systems indicated no visual problems with the systems'ousing and ducts and all doors
. were tightly closed and locked with tamper-proof seals.
No external damage to the ventilation units was identified.
All filter housings and ducts were well maintained.
The areas surrounding the ventilation units were clean, free of debris, and the ventilation units were adequately lighted inside and outside to provide for visual inspection of housings and components.
The licensee's surveillance testing program provided for the required periodic functional checking of the ventilation systems'omponents, evaluation of the high efficiency particulate air filters and activated charcoal adsorbers, and in-place filter testing of the filter systems.
The inspector reviewed records for these systems.
Since some of the surveillance tests were only required to be performed at 18-month frequencies, the inspector verified that the previous two surveillance tests were performed as required at the 18-month frequency.
The activated charcoal surveillance tests were performed by a contract laboratory.
The inspector noted that the Technical Specification requirement for testing the various air cleaning ventilation systems'ctivated charcoal adsorber material after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation following previous laboratory testing was being tracked by the control room and the system engineer on a surveillance test performed monthly.
Run-time meters were installed on all of the filter trains for the
l
-7-control room essential filtration system the fuel building essential ventilation system.
The meters registered the number of starts and run time since the performance of the previous charcoal adsorber surveillance test on each filter train.
c.
Conclusions An excellent safety-related air cleaning ventilation systems surveillance program was implemented.
The testing of the safety-related air cleaning systems met Technical Specification requirements.
R2 Status of Radiological, Protection and Chemistry Facilities and Equipment R2.1 Radiochemis r
Countin Room The radiochemistry counting room was equipped with state-of-the-art analytical instrumentation to perform the required analyses.
The analytical instrumentation was properly maintained, tested, and calibrated.
R2.2 Post-Accident Sam lin S s em a.
Ins ec ion Sco e 84750 The post-accident sampling system instrumentation was inspected to verify if adequate operation and surveillance programs were in place.
b.
Observa ions and Findin s The inspector observed the operation of the post-accident sampling system.
A chemistry technician operated the post-accident sampling system to obtain a reactor coolant sample and verify the operability of the post-accident sampling system.
The licensee had established a monthly surveillance for testing all of the sampling capabilities of the post-accident sampling system.
Almost all of the chemistry technicians had completed the training on the use of the post-accident sampling system.
Conclusions The post-accident sampling system was operational, properly maintained, and operated periodically.
R2.3 Li uid and Ga eous Effl en Radi i n Moni ors a.
Ins ec ion Sco e 84750 The liquid and gaseous effluent radiation monitors were inspected for operation, calibration, and reliabilit b.
Observations and Findin s All gaseous waste effluent radiation monitor source check, channel check, channel functional test, and channel calibration records for each unit were performed in compliance with Offsite Dose Calculation Manual, Table 2-2, requirements.
All records reviewed indicated that the gaseous waste effluent radiation monitoring instrumentation was properly maintained, tested, and calibrated in compliance with Offsite Dose Calculation Manual requirements at the proper frequencies.
The reliability of the effluent monitors was greater than 99 percent.
Conclusions All liquid and gaseous effluent radiation monitoring instrumentation was operable and properly maintained, tested, and calibrated in compliance with the surveillance requirements specified in the Offsite Dose Calculation Manual.
R3 Radiological Protection and Chemistry Procedures and Documentation R3.1 Chan es in the Offsite Dose Calculation Manual nd Radwas e S stem Desi n
Revisions to the Offsite Dose Calculation Manual were reviewed for any changes to the radioactive waste effluents program and the radwaste system design and operation, including the performance of proper 10 CFR 50.59 reviews.
b.
Observa ions and Findin s No changes to the Offsite Dose Calculation Manual, Revision 10, were made since the last inspection.
The radioactive waste effluent program's implementing procedures described the responsibilities for collection and analyses of liquid and gaseous radioactive waste effluent samples.
The procedures were written with sufficient detail to effectively conduct the required radioactive waste effluent program activities.
The inspector reviewe'd the licensee's sample collection procedures and identified no concerns.
C.
Conclusions Effective procedures with sufficient detail were used.
No revisions to the Offsite Dose Calculation Manual had been implemented since the last inspectio R4 Staff Knowledge and Performance a.
Ins ec ion Sco e 84750 Personnel in the radiological monitoring department were interviewed with regard to regulatory and Offsite Dose Calculation Manual requirements for the implementation of the liquid and gaseous radioactive waste effluent management programs.
b.
Observa ions and Findin s Radiation monitoring and chemistry personnel including supervisors and technicians were knowledgeable of the programmatic procedures, Offsite Dose Calculation Manual requirements, and regulatory requirements and maintained a high level of performance.
Conclusions Radiation monitoring and chemistry personnel had an excellent understanding of the radioactive liquid and gaseous waste management procedures, Offsite Dose e
Calculation Manual, and regulatory requirements.
R5 Staff Training and Qualification R5.1 Trainin and Qu lifi a ion of Chemistr and Ra iation Moni orin Personnel a.
Ins ec ion Sco e 84750 Training and qualification programs for chemistry and radiation monitoring technicians involved with conducting the radioactive waste effluent management programs were reviewed.
Observa ions and Findin s The inspector verified that all of the chemistry and radiation monitoring technicians were well along in their training programs.
The inspector reviewed the initial and continuing training programs for the radiological monitoring technicians.
It was determined that the licensee's training program was implemented in accordance with station procedures.
The inspector determined that the experience, training, and working knowledge of the personnel responsible for implementing the radioactive waste effluent program met the training and qualification requirement e-1 0-R6 Radiological Protection and Chemistry Organization and Administration R6.1 Chemistr Or anization and Staffin a.
Ins ection Sco e 84750 The inspector reviewed the licensee's organization, staffing, and lines of authority as they related to the chemistry department, which was responsible for implementing the radioactive waste effluent program.
b.
Observations and Findin s The chemistry department, headed by the site chemistry director, was divided into three departments:
chemistry operations, chemistry support, and radiological monitoring.
The radiological monitoring department was responsible for conducting the radioactive waste effluent program.
The chemistry department organizational structure satisfied the requirements of the Technical Specifications.
The staffing of the radiological monitoring department was adequate to conduct its assigned duties.
The licensee had experienced low turnover of personnel implementing the radioactive waste effluen't program and had only lost two technicians through attrition. The licensee compensated by adjusting schedules.
The inspector was briefed on changes to the organization which were to be effective February 1, 1997.
It was noted that the radiological monitoring department was to be deleted from the organizational chart and radiological monitoring staff would be moved into the chemistry operations department.
The radiological monitoring staff would stay intact but only report to a different manager.
This move should not affect the effective implementation of the radioactive waste effluent program.
c.
Conclusions The chemistry organization and staffing met Technical Specification requirements.
The chemistry technical staff had experienced little change and low reduction during the past year.
R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Radioactive Waste Effluent Qualit Assurance Pro ram a.
Ins ection Sco e 84750 The quality assurance audit and surveillance programs regarding the radioactive waste effluent management program activities were reviewed for scope,
-1 1-thoroughness of program evaluation, and timely followup of identified deficiencies.
The review included the audit and surveillances performed since January 1, 1996.
b.
Observations and Findin s Audit schedules for 1995, 1996, and 1997, indicated that the audits of the radioactive waste effluent and the Offsite Dose Calculation Manual were performed on an annual basis.
This audit schedule was in compliance with the Technical Specification audit frequency requirements.
The audits and surveillances were of good quality, technically comprehensive, and provided excellent oversight and evaluation of the licensee's performance in implementing the radioactive waste effluent management programs and meeting the Technical Specification and Offsite Dose Calculation Manual requirements.
The radiological monitoring department had also implemented several integrated self-assessment modules which were performed by both nuclear assurance auditors and chemistry staff. These integrated self-assessment modules provided for a detailed scope for surveillances in specified program areas.
This was an enhancement to the quality assurance program.
The licensee used a contractor laboratory to perform required radiochemistry analyses on radioactive waste effluent composite samples.
The licensee also used another contractor to perform in-place filter testing and laboratory charcoal adsorber
"
analyses on the station's safety-related air cleaning ventilation systems.
The licensee participated in and obtained Nuclear Procurement Issues Committee audits for the review of contractor adherence to nuclear standards.
c.
Conclusions Quality assurance audit and surveillarices of the radioactive waste effluent management program activities were technically comprehensive and provided good program evaluation and oversight.
RS Miscellaneous RPRC Issues RS.t
~Re orts Ins ection Sco e 84750 The annual report concerning radioactive waste effluent releases was reviewed for omissions, obvious mistakes, anomalous measurements, observed biases, and trends in the data.
I
t
-1 2-b.
Observations and Findin s The Annual Radioactive Effluent Release Report for 1995 included meteorological data and changes to the Offsite Dose Calculation Manual, as required.
The report was written in the format described in NRC Regulatory Guide 1.21, Revision 1, June 1974, and contained the information required by the Technical Specifications.
Effluent monitoring instrumentation had not been out of service in excess of Technical Specification requirements during the time period reviewed.
Summaries of the quantities of radioactive liquid and gaseous effluents released to the environment, and their associated doses to members of the public for 1995, were properly documented in the annual report.
No unplanned releases of radioactive liquid or gaseous waste were reported during 1995.
Conclusi ns An excellent Annual Radioactive Effluent Release Report for 1995 was submitted in a timely manner and contained the required information presented in the required format.
R8.2 Effluent Issues a.
Ins ec ion Sco e 84750 The inspector evaluated the effectiveness of the licensee's controls in identifying, resolving, and preventing problems in the are'a of radwaste treatment and effluent monitoring, based on issues, events, or problems identified though the licensee's condition reporting system.
b.
Observations and Findin s Condition reports written during 1996 revealed that management expectations were not always adhered to in the performance of radiological monitoring activities.
Specifically, errors in procedural adherence and documentation were identified.
It is noted that these errors were minor in nature.
The inspector found that the licensee's response, corrective actions, and reevaluation of the above item was appropriate.
A condition report (96-1129) requested an evaluation be performed of the plant ventilation systems.
This evaluation was to determine the number of doors that could be allowed to be opened before building ventilation integrity would be lost to avoid the creation of an unmonitored release pathway.
This evaluation was not performed because to many variables (which and how many exterior and interior
H
e-1 3-doors could be open at any one time) were involved.
The response to this condition report determined that "most releases through an open door would be considered a
nuisance pathway in accordance with Offsite Dose Calculation Manual Section 1.3 and did not require offsite dose assessment."
A review of this section of the'ffsite Dose Calculation Manual revealed that doses would not need to be included in the annual dose total if they were not likely to exceed 10 percent of the doses evaluated in the manual.
Discussions with licensee personnel reveled that adequate controls exist for allowing exterior doors to be opened for an extended period of time. Such openings would be evaluated for the possibility of the creation of an unmonitored release pathway.
Review of Section 1.3 of the licensees Offsite Dose Calculation Manual by NRC staff concluded that any doses, however small, should be included in the summation of the annual offsite dose.
The licensee assured the inspector that in practice all release pathways, including unmonitored release pathways if known are evaluated for offsite dose consequences and included in the annual offsite dose.
The licensee indicated that they would review their procedures for possible clarification.
C.
Conclusions The licensee effectively identified, tracked, and implemented corrective actions for any identified problems.
V. Mana ement Meetin s
X1 Exit Meeting Summary The inspector presented the results of the inspection to members of licensee management at the conclusion of the inspection on January 31, 1997.
The licensee acknowledged the findings presented.
No proprietary information was identifie ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee
"J. Levine, Senior Vice President
"G. Overback, Vice President, Production
"D. Marks, Section Leader, Nuclear Regulatory Affairs - Compliance
"A. Krainik, Department Leader, Nuclear Regulatory Affairs
"R. Bouquot, Section Leader, Nuclear Assurance L. Drinovsky, Senior Advisor, Radiological Environmental Monitoring Program
"D. Elkinton, Senior Evaluator, Nuclear Assurance
"R. Henry, Site Representative, Salt River Project
"L. Johnson, Department Leader, Chemistry Support - Chemistry
"D. Larkin, Senior Engineer, Nuclear Regulatory Affairs - Compliance K. Korst, Site Chemistry, Training Coordinator
"T. Murphy, Section Leader, Radiological Monitoring - Chemistry
"R. Routolo, Senior Technician, Radiological Monitoring - Chemistry P. Smith, Radiological Monitoring Technician
"J. Scott, Director, Site Chemistry
"R. Sorensen, Department Leader, Radiological Monitoring - Chemistry NRC
"K. Johnson, Senior Resident Inspector
"Indicates those present at the exit meeting on January 31, 1997.
In addition to the personnel listed above, the inspector contacted other personnel during this inspection.
LIST OF INSPECTION PROCEDURES USED IP'84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring LIST OF ACRONYMS USED ODCM UFSAR TS Offsite Dose Calculation Manual Updated Final Safety Analysis Report Technical Specifications
t
-1 5-Li of Documen s Reviewed PROCEDURES 40DP-9ZZ17 74AC-9CY08 74RM-9EF20 74RM-9EF60 74RM-9E F80 Control of Doors, Hatches and Floor Plugs, Revision 5, November 1, 1996 Gaseous Radioactive Effluent Release Administrative Control, Revision 3, December 16, 1994 Gaseous Radioactive Release Permits and Offsite Dose Assessment, Revision 4, May 1, 1996 RMS Sample Collection, Revision 11, October 15, 1996 RMS/Effluents Action Determination, Revision 2, August 14, 1996 AUDITS AND SURVEILLANCES Surveillance ER-97-001 9 ER-96-0078 ER-96-01 97 ER-96-0382 ER-96-0426 ER-96-0547 ER-96-0786 ER-96-0822 ER-96-0822 Radiological Monitoring, January 17, 1997 RMS Technician Training/Qualification, February 8, 1996 RU-33/16 Setpoint Determination/UFSAR Compliance, April 4, 1996 Gaseous Radiological Effluent Release Permits/Effluent Sampling/RMS operations, June 25, 1996 Radiological Effluent and Environmental Reporting, July 17, 1996 Radiological Environmental Administrative Control, September 6, 1996 On Site Liquid Releases, November 27, 1996 RMS Operations, December 18, 1996 RMS Operations (follow up)
Qualit Assurance Audi s96-003, Radiological Effluent and Environmental Monitoring Program, February 13-23, 1996
~*"i NUPIC audits of Vendors REPORTS Annual Radioactive Effluent Release Reports - 1995 OTHER Offsite Dose Calculation Manual
- Revision 10, December, 6, 1995 Chemistry department training records Condition Report 9-6-1129 Organizational Charts
, t