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Insp Repts 50-528/97-20,50-529/97-20 & 50-530/97-20 on 970623-27.No Violations Noted.Major Areas Inspected:External & Internal Exposure Control Programs,Planning & Preparation, Control of Radioactive Matl & Contamination
	ML17312B620
Person / Time
Site:	Palo Verde
Issue date:	08/01/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML17312B619	List: IR 05000528/1997020; ML17312B618;
References
	50-528-97-20, 50-529-97-20, 50-530-97-20, NUDOCS 9708080188
	Download: ML17312B620 (12)
	v • d • e

ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

'ates:

Inspectors:

Approved By:

50-528'0-529; 50-530 NPF-4'I; NPF-51; NPF-74 50-528/97-20; 50-529/97-20; 50-530/97-20 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona June 23-27, 1997 J. Blair Nicholas, Ph.D., Senior Radiation Specialist Gilbert L. Guerra, Jr., Radiation Specialist Michael C. Hay, Radiation Specialist Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety ATTACHMENT:

Supplemental Information 9708080i88 970801 PDR ADOCK 05000528 G

PDR

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EXECUTIVE SUMMARY

Palo Verde Nuclear Generating Station, Units 1, 2, and 3

NRC Inspection Report 50-528/97-20; 50-529/97-20; 50-530/97-20 This routine announced inspection focused upon the licensee's radiation protection program.

Areas inspected included:

external and internal exposure control programs, planning and preparation, control of radioactive material and contamination, and nuclear assurance audits and evaluations.

Plant Su or Radiological conditions in the three units were properly controlled and posted as required.

Housekeeping within the radiological controlled areas was very good.

All personnel observed wore their dosimetry properly.

An excellent thermoluminescent dosimeter processing program was implemented (Section R1.1).

An excellent internal dosimetry program was implemented.

Appropriate evaluations of internal intakes were performed (Section R1.2).

A good pre-job briefing was conducted.

Radiation protection personnel provided good support to other craft personnel.

Source term reduction efforts were effective (Section R1.3).

Station workers used the personnel contamination monitors properly.

Proper radiological controls were used (Section R1.4).

A non-cited violation was identified regarding the failure to perform surveys and control licensed material (Section R1.4).

An excellent audit of radiation protection activities was performed.

The number of evaluations performed by the nuclear assurance department was a strength.

The licensee effectively implemented corrective actions in a timely manner for identified conditions (Section R7.1).

REPORT DETAILS

Summar of Plant Status Units 1, 2 and 3 operated at full power during the inspection.

No events occurred during this inspection that adversely affected the inspection.

R1 Radiological Protection and Chemistry Controls R1.1 External Ex osure Controls a.

Ins ection Sco e 83750 The inspectors toured the radiological controlled areas of all three Palo Verde units.

Discussions were held with radiation protection personnel.

The following items were reviewed:

Radiological controlled area access/egress controls Control of high radiation areas Issuance and control of locked high radiation area keys Job coverage by radiation protection personnel Housekeeping within the radiological controlled area Dosimetry use Observations and Findin s Tours of the radiological controlled areas of the three units revealed that radiation areas, contamination areas, and high radiation areas were properly controlled and posted.

All Technical Specification required locked high radiation area doors were locked and properly posted.

The proper use of locked high radiation area flashing lights was noted.

The inspectors reviewed locked/very high radiation area key control and found that all locked/very high radiation area keys were currently inventoried and that the master keys assigned to operations had been removed from the shift supervisor's office in each unit. All locked/very high radiation area keys were in the control of authorized radiation protection personnel.

Housekeeping within the radiological controlled areas was very good.

The radwaste building associated with each of the three units were in different stages of being cleaned and painted with a special epoxy paint used to facilitate decontamination.

The Unit 1 radwaste building was completed, Unit 2 radwaste building was in the process of being painted, and the Unit 3 radwaste building was being cleaned by

using high pressure water in preparation for painting.

The inspectors observed that proper radiological controls were implemented by the workers using the high pressure water.

Full protective clothing and a wet suit were worn by personnel performing the work to prevent possible personnel contamination.

Personnel observed wore dosimetry properly.

The inspectors observed radiation protection technicians monitor a job in the Unit 1 containment.

Neutron and gamma surveys conducted by the radiation protection personnel were appropriate for the job.

The thermoluminescent dosimeter processing program was reviewed.

The program was National Voluntary Laboratory Accreditation Program accredited insight categories.

The electronic dosimeter calibration program was National Voluntary Laboratory Accreditation Program accredited in four categories.

Close agreement was noted between the dose results from the electronic dosimeters and the thermoluminescent dosimeters.

C.

Conclusions Radiological conditions in the three units were properly controlled and posted as required.

Housekeeping within the radiological controlled areas was very good.

All personnel observed wore their dosimetry properly.

An excellent thermoluminescent dosimeter processing program was implemented.

R1.2 Internal Ex osure Controls a.

Ins ection Sco e 83750 Selected radiation protection personnel involved with the internal exposure control program were interviewed.

The following items were reviewed:

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Respiratory protection program

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Whole body counting program

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Internal dose assessment program b.

Observations and Findin s Interviews were conducted with personnel who had received radioactive material intakes.

The inspectors noted that appropriate evaluations of these intakes were performed.

The evaluations were based on whole body count results and dose results were calculated using appropriate methods.

The inspectors reviewed several internal dose assessments performed by the licensee and determined that the dose assessments were properly evaluated.

Annual calibrations and daily quality control checks of the whole body counter systems were conducted as required using National Institute of Standards and Technology traceable sources.

The respiratory protection program was properly implemented.

Full face respirators were stored and maintained properly.

The licensee appropriately performed the required reviews for the use of respiratory protection equipment to minimize the total effective dose equivalent (TEDE).

TEDE/ALARAreviews were performed to determine whether respiratory protection equipment would be effective in minimizing the total dose received.

The inspectors found the licensee's TEDE/ALARAreview procedure to be appropriate..

C.

Conclusions An effective internal dosimetry program was implemented.

Appropriate evaluations of internal intakes were performed.

R1.3 Plannin and Pre aration a.

Ins ection Sco e 83750 Radiation protection department personnel and other craft personnel were observed and interviewed regarding radiation protection activities.

ALARAoutage reports were reviewed.

b.

Observations and Findin s A pre-job briefing was observed prior to work in the Unit 1 containment.

It included interface with the affected craft personnel and provided briefings on safety and radiological controls.

The inspectors conducted interviews with section leaders from several crafts regarding radiation protection support to their organizations.

The response from craft personnel was that radiation protection personnel provided appropriate and good support for radiological work activities.

Source term reduction efforts were evident based on the inspectors'valuation of the plant shut down dose rate data from each of the units'n-service low pressure safety injection pump room.

The licensee stated that one major source term reduction effort that resulted in lowering the dose rates involved developing a

procedure to cross tie and flush the safety injection train by circulating the water through the spent fuel pool cleanup system.

Dose rates in the safety injection rooms from refueling outage number 5 were compared to refueling outage number 6 for the three units.

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The Unit 1 approximate dose rate of 60 mrem per hour was reduced to 15 mrem per hour.

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The Unit 2 approximate dose rate of 28 mrem per hour was reduced to 12 mrem per hour.

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The Unit 3 approximate dose rate of 28 mrem per hour was reduced to 22 mrem per hour.

Outage exposure data contained in the ALARAoutage reports from each unit for the last three refueling outages (refueling outages 4 through 6) showed an average reduction in person-rem of 130 rem per unit as a result of improved shutdown chemistry methods, cleaning of the safety injection system via the spent fuel pool cleanup system, and shorter outages.

C.

Conclusions A good pre-job briefing was conducted.

Radiation protection personnel provided good support to other craft personnel.

Source term reduction efforts were effective.

R1.4 Control of Radioactive Materials and Contamination Surve s

and Monitorin a.

Ins ection Sco e 83750 Areas reviewed included:

Personnel contamination monitor use Control of radioactive material Radiological postings Portable instrumentation calibration and performance checking programs Adequacy of the radiation surveys Radioactive source inventories b.

Observations and Findin s Personnel observed by the inspectors used the personnel contamination monitors properly.

Good coverage was provided by the radiation protection technicians stationed at the radiological controlled access area in each unit.

Contaminated areas were well posted and marked with radiation tape or rope.

Step-off pads were placed at the entrances/exits to contaminated areas.

The use of drip catches was minimized.

AII radioactive material observed was properly labeled and posted.

Containers of radioactive materials and contaminated vacuum cleaners were properly labeled and

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controlled.

All instrumentation (survey/contamination monitoring instruments)in use were calibrated and response checked appropriately.

Each unit had ample survey instrumentation ready for immediate use located in a controlled storage area.

The inspectors reviewed a number of radiation surveys and determined that they were documented in a clear and consistent manner.

Radiation surveys posted at entrances to rooms showed accurate radiological conditions.

Flashing tights were appropriately used to control access to a very high radiation area where a lock could not be used.

Inventories of radioactive sources were reviewed.

Annual inventories by source custodians were performed during January and February of 1997 in accordance with station procedures.

The inspectors verified that selected radioactive sources were located at the identified locations.

On June 4, 1997, a technician discovered loose surface contamination on lead blankets in the Unit 3 radiological controlled area yard stored without the proper radiological controls.

The blankets had been transferred from Unit 1.

Upon investigation it was discovered by radiation protection management that procedure violations had occurred due to lack of attention to detail, and/or management expectations were not met by radiation protection technicians.

The licensee's draft evaluation identified the following radiation protection barriers in procedures which were bypassed.

Licensed material removed from a contaminated area to the Unit 1 radiological controlled area yard was surveyed for loose contamination.

However, it was not surveyed for fixed contamiriation.

Hence, proper controls, such as containment and labeling, were not identified and implemented.

Management's expectations were not met in that all radiological conditions were not identified.

When the licensed material was released from the Unit 1 yard, again it was not properly evaluated for fixed contamination.

This resulted in the release of licensed material from the radiological controlled area without the proper radiological controls.

This was in violation of Procedure 75RP-9RP09, Vehicle, Equipment and Material Release,'Section 3.2.1, which states, "Items to be unconditional released by survey shall be evaluated against the criteria specified in Appendix B, PVNGS Limits for Unconditional Release by Survey."

The limits in Appendix 8 are less than 1000 dpm/probe area.

Section 3.2.5, states, "Surveys for fixed contamination should be performed in low background areas ((300 cpm), as practical."

The material was not moved to a low background area and surveyed for fixed contamination.

h

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The trailer used to transport the licensed materials, which had been in a radiological controlled area, was not surveyed for free release to its normal storage area.

Licensed material was on the trailer and the proper radiological controls were not taken.

This was in violation of Procedure 75RP-9RP09, Vehicle, Equipment and Material Release, Section 3.2A, which states, "Vehicles entering the RCA to deliver, move or retrieve material outside of contamination areas, the release survey of the vehicle may consist of surveying only those portions of the vehicle which made contact with the radiological controlled area or materials inside the radiological controlled area."

Licensed material did not leave the licensee's controlled area.

The inspectors noted that these procedure violations were licensee identified and that corrective actions had been initiated including extensive evaluation of all trailers on site and clean up of the affected areas.

All radiation protection staff were made aware of management's expectations and procedural controls.

The failure to control licensed material in accordance with the above radiation protection procedure is identified as a non-cited violation of Technical Specification 6.8.1.

This non-repetitive, licensee-identified and corrected violation is being treated as a non-cited violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.

C.

Conclusions Station workers used the personnel contamination monitors properly.

Proper radiological controls were used.

A non-cited violation was identified regarding the failure to perform surveys and control licensed material.

R6 Radiological Protection and Chemistry Organization and Administration No changes were noted in the licensee's radiation protection organization since the previous NRC inspection of the radiation protection area in March 1997.

R7 Quality Assurance in Radiological Protection and Chemistry Activities R7.1 Qualit Assurance Audits and Evaluations and Radiolo ical Occurrence Re orts Ins ection Sco e 83750 The following were reviewed:

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Nuclear assurance audits performed since March 1997

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Nuclear assurance evaluations performed since March 1997

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Radiological condition report/disposition requests written since March 1997 b.

Observations and Findin s The draft of a recently performed nuclear assurance audit was reviewed.

The exit meeting for the audit was performed during this inspection.

The audit findings provided a good assessment of the radiation protection program.

The audit identified several areas for improvement.

Areas for improvement for management's attention were tracked by the licensee's condition reporting system.

Selected nuclear assurance radiation protection evaluation reports were reviewed.

The reports covered a broad range of radiation protection activities and provided management with a good tool to assess the radiation protection program.

The inspectors noted that the number of evaluations performed was a strength.

The inspectors noted that the licensee's identification threshold for generating condition report/disposition requests was proper and that the licensee was effective in evaluating the conditions and taking proper corrective action as warranted.

Corrective actions were initiated in a timely manner.

No negative trends were identified by the inspectors during this review.

C.

Conclusions An excellent audit of radiation protection activities was performed.

The number of evaluations performed by the nuclear assurance department was a strength.

The licensee effectively implemented corrective actions in a timely manner for identified conditions.

RS IVliscellaneous Radiological Protection and Chemistry Issues RS.I Closed Violation 530 9707-03:

Failure to Post Radiation Area During a tour of the Unit 3 fuel building, on March 12, 1997, it was identified that the west stairway leading to the 140-foot elevation was not posted as a radiation area.

Radiation area postings in the Unit 3 fuel handling building were reviewed.

The inspectors noted that proper corrective actions were implemented.

V. Mana ement IVleetin s X1

Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at an exit meeting on June 27, 1997.

The licensee acknowledged the findings presented.

No proprietary information was identified.

ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIALLIST OF PERSONS CONTACTED

Licensee

"

J. Levine, Senior Vice President,

Nuclear Operations

R. Bouquot, Section Leader, Nuclear Assurance

D. Edwards, Section Leader, Technical Training

D. Elkinton, Lead Auditor, Nuclear Assurance

J. Gaffney, Department Leader, Radiation Protection

T. Gray, Section Leader, Radiation Protection

V. Huntsman, Department Leader, Radiation Protection

M. Lantz, Senior Health Physicist

D. Larkin, Senior Engineer, Nuclear Regulatory Affairs

D. Marks, Section Leader, Nuclear Regulatory Affairs

D. McFarlane, Section Leader, Dosimetry

J. Rhodes,

Radiation Protection Technician

S. Sawtschenko,

Section Leader, Radioactive Material Control

M. Shea, Director, Radiation Protection

NRC

D. Carter, Resident Inspector

INSPECTION PROCEDURE USED

IP 83750

Occupational

Radiation Exposure

LIST OF ITEMS OPENED AND CLOSED

~Oened

28; 529; 530/9720-01

Closed

530/9707-03

28;529;530/9720-01

NCV

Failure to Control Licensed Material

VIO

Failure to post radiation area

NCV

Failure to Control Licensed Material

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LIST OF DOCUMENTS REVIEWED