IR 05000528/1999007
| ML17313A917 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/04/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17313A916 | List: |
| References | |
| 50-528-99-07, 50-528-99-7, 50-529-99-07, 50-529-99-7, 50-530-99-07, 50-530-99-7, NUDOCS 9905110287 | |
| Download: ML17313A917 (22) | |
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ENCLOSURE U.S. NUCLEAR REGULATORYCOMMISSION
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 50-528/99-07 50-529/99-07 50-530/99-07 Arizona Public Service Company Palo Verde'Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona April5-9, 1999 Larry Ricketson, P.E., Senior Radiation Specialist Plant Support Branch Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment:
Supplemental Information e
P905ii0287 990504 PDR ADOCK 05000528
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-2-EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report No. 50-528/99-07; 50-529/99-07; 50-530/99-07 The NRC conducted an inspection of the radiation protection organization's support of refueling outage activities. The inspection focused on planning and preparation for the refueling outage, radiation exposure controls, control of radioactive materials and contamination, surveying and monitoring, personnel qualifications, and the program to maintain radiation doses as low as is reasonably achievable (ALARA).
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The licensee's preparations for the outage demonstrated strong support for the ALARA concept.
Radiological work packages included dose saving measures.
Chemistry controls, temporary shielding, and hot spot flushing reduced dose rates in work areas.
The licensee established a challenging ALARAgoal for Unit 2 Refueling Outage 8 (Section R1.1) ~
The licensee implemented good radiation exposure controls.
Radiation workers were thoroughly instructed in the radiation hazards and precautions to reduce radiation dose.
The radiation work permit authorization process was not implemented properly, but the licensee addressed the situation promptly. Radiation protection personnel provided good support and oversight of radiological controlled area work activities (Section R1.2).
Good radioactive material controls were maintained.
Radiation workers generally used good contamination control practices.
Radiation protection personnel surveyed items correctly before releasing them from the radiological controlled area.
The licensee maintained a sufficient supply of calibrated radiation detection instruments.
Radiation dose rates and airborne radioactivity concentrations were evaluated correctly (Section R 1.3).
The licensee supplemented its radiation protection staff with qualified contract radiation protection technicians.
Although the licensee did not employ as many contract radiation protection technicians as planned, the inspector identified no related safety concerns (Section R 5).
e-3-Re ort Details Summa of Plant Status Units 1 and 3 were operating.
Unit 2 was shut down for Refueling Outage 8 (U2R8). The inspection was conducted during days 9 through 13 of a scheduled 37-day refueling outage.
IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Plannin and Pre aration a.
Ins ection Sco e 83750 The inspector interviewed licensee personnel and reviewed the following:
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Radiation work packages Chemistry controls Work scheduling Temporary shielding and hot spot flushing ALARAgoals Observations and Findin s Radiation Work Packa es Radiation work packages for repetitive outage activities were well planned.
The work packages contained radiological data and dose-saving lessons learned from previous, similar work. The inspector interviewed two radiation protection planners about the work packages they had prepared and concluded that the planners were knowledgeable of the radiological hazards and associated precautions.
The inspector selected exa'mples of lessons learned included in the work packages and confirmed that the licensee implemented them through radiation exposure permit instructions or other means, such as procedure revisions.
For the activities not previously conducted, such as steam generator replacement laser measurements and control element assembly removal and replacement, the licensee contacted experienced licensees and obtained information and insights that enabled them to plan the work and estimate the dose.
At the time of the inspection, actual work activity doses approximated the projected doses.
Chemist Controls The licensee reduced radiation levels in the plant by using good chemistry controls during reactor shutdown.
Prompted by relatively poor shutdown chemistry at the start of a previous refueling outage (U3R6), the licensee implemented shutdown chemistry
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-4-processes that facilitated an early crud burst and thorough cleanup of radioactivity in the reactor coolant system.
The inspector compared the latest post shutdown dose rates with those of previous outages and concluded that the license'e's latest results were relatively good.
Work Schedulin Licensee representatives stated that certain activities were scheduled so that total
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personnel dose was reduced.
The licensee allowed sufficient time after the crud burst for cleanup of the radioactivity in the reactor coolant system before starting the bulk of the work. The inspector confirmed the representatives'tatements through personnel interviews, reviews of documented dose totals, and worker-hours in the radiological controlled area.
The inspector concluded that this demonstrated management's support of the ALARAconcept.
Tem ora Shieldin and Hot S ot Flushin One of the work activities that the licensee performed early in the outage was the placement of temporary shielding to further reduce dose rates in the radiological controlled area.
The inspector observed that the use of temporary shielding was extensive.
The licensee also reduced radiation dose rates in the work areas through a hot spot flushing program.
The inspector reviewed dose rates measured before and after flushing and concluded that the licensee implemented good dose reduction practices.
ALARAGoals In preparation for the outage, the licensee established an ALARAgoal of 68 person-rems.
The inspector concluded that the goal was aggressive, because the licensee's best previous outage exposure total was 72.7 person-rems, accrued during Unit 3 Refueling Outage 7. The work activities in both outages were similar. The previous best performance by Unit 2 was 73.4 person-rems, accrued during Refueling Outage 7.
Conclusions The licensee's preparations for the outage demonstrated strong support for the ALARA concept.
Radiological work packages included dose saving measures.
Chemistry controls, temporary shielding, and hot spot flushing 'reduced dose rates in work areas.
The licensee established a challenging ALARAgoal for Unit 2 Refueling Outage 8.
Ex osure Controls Ins ection Sco e 83750 The inspector interviewed radiation protection personnel and reviewed the following:
Instructions to radiation workers
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-5-Radiological controlled area access controls High radiation area controls Radiation protection job coverage Observations and Findin s 83750 Instructions to Radiation Workers The licensee's radiation exposure permits were easy to read and understand.
The radiation exposure permits contained comprehensive radiological survey information and task-related special instructions.
Radiation workers were well instructed by radiation protection personnel.
The inspector attended pre-job briefings presented before refueling cavity decontamination activities (conducted in accordance with Radiation Exposure Permit 2-3015, Task 1) and steam generator sludge lancing (conducted in accordance with Radiation Exposure Permit 2-3310 B, Task 2). In both pre-job briefings, radiation protection personnel thoroughly discussed the radiological hazards in the work area and the precautions that would reduce radiation dose.
Radiation protection personnel used visual aids effectively during the discussions and solicited questions and comments from the workers.
Radiolo ical Controlled Area Access Control Radiation workers generally used the licensee's computerized radiological controlled area access computer system correctly to select their designated radiation exposure permits, acknowledge their understanding of the related requirements, and enter the radiological controlled area.
The licensee's computer system controlled worker access to radiation exposure permits for complex or high dose work activities. Individuals were briefed or instructed in the radiological hazards, and their names were added to a computerized list of "authorized" personnel.
The authorization list was radiation exposure permit-specific.
If an individual's name did not appear on the computerized list, the individual was not allowed by the licensee's computer system to sign in (log in) on the radiation exposure permit.
The process was intended to ensure that workers were briefed on the radiological hazards before performing work activities with the potential for high radiation doses.
However, the radiation exposure permit authorization process that followed the refueling cavity decontamination pre-job briefing was not conducted properly. Approximately 12 people attended the pre-job briefing. Radiation protection personnel did not collect the signatures of the pre-job briefing attendees, and they did not maintain visual control of the workers after the meeting. The authorization process was not conducted immediately after the briefing, and workers were allowed to leave the immediate area.
The inspector expressed a concern that the lack of pre-job briefing attendance documentation or positive visual control made it impossible to ensure that only workers that had been briefed would be authorized to use the specific radiation exposure permit.
Unless radiation protection personnel remembered every briefing attendee, workers not attending the pre-job briefing could seek and perhaps be granted authorizatio I f
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-6-Licensee representatives acknowledged the inspector's concern and, following the steam generator sludge lancing briefing, radiation protection personnel escorted the briefing attendees until the authorization process was completed.
Hi h Radiation Area Controls High radiation area access controls within the containment building were good.
The inspector conducted independent measurements and confirmed that high radiation areas were identified and posted correctly. Postings were clearly visible. Areas with radiation dose rates greater than 1 rem per hour were locked ol controlled as required by Technical Specification 5.7. Control point radiation protection technicians provided good oversight.
During a tour inside the containment building, the inspector observed an in-service inspection worker ask a control point radiation protection technician for permission to enter a pump bay, high radiation area.
The worker was denied access after the radiation protection technician reviewed the governing radiation exposure permit, determined that the individual's task did not allow high radiation area entries, and that the individual had not been briefed on the dose rates within the pump bay.
As part of the review of high radiation area controls, the inspector conducted an inventory of all locked high radiation area keys. The licensee accounted for all keys.
Radiation Protection Job Covera e
Radiation protection job coverage was good. Job-coverage radiation protection technicians attended the pre-job briefings discussed above with the radiation workers.
This allowed the workers to become familiar with the radiation protection technicians and to ask them questions.
In the containment building, radiation protection personnel were easy to identify, because they wore magenta-colored hoods with their protective clothing. The inspector observed continuous radiation protection coverage in the containment building and identified no problems.
Radiation protection technicians, who provided intermittent job coverage, responded quickly to workers'elp requests.
The inspector also noted that the licensee provided remote job oversight by using television cameras extensively in the containment building.
Conclusions The licensee implemented good radiation exposure controls.
Radiation workers were thoroughly instructed in the radiation hazards and precautions to reduce radiation dose.
The radiation work permit authorization process was not implemented properly, but the licensee addressed the situation promptly. Radiation protection personnel provided good support and oversight of radiological controlled area work activities.
Control of Radioactive Material and Contamination Surve in and Monitorin Ins ection Sco e 83750 The inspector interviewed radiation protection personnel and reviewed the following:
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e-7-Personnel contamination events Material releases Portable survey instrument calibration Radiological survey results b.
Observations and Findin s Personnel Contamination Events Radiation workers generally implemented good contamination controls while working in and exiting from contaminated areas.
As a result, personnel contamination events
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occurred infrequently. Through 12 days of the outage, there were 14 personnel contamination events.
This was noteworthy because the licensee's definition of a personnel contamination event was conservative.
The personnel contamination total included modesty clothing contaminations as well as skin contaminations.
The inspector confirmed through dosimetry record review that the licensee conducted whole-body counts (when appropriate to assess the internal deposition) or skin dose calculations to evaluate the effect of personnel contamination events.
Material Releases The inspector observed the release of tools and materials from the radiological controlled area and identified no problems.
Workers exiting the radiological controlled area used tool monitors correctly to release personal items.
Radiation protection personnel provided sufficient oversight of the radiation workers to ensure contaminated items were not removed from the radiological controlled area.
Radiation protection technicians performed contamination surveys correctly on tools and containers removed from the radiological controlled area.
Surve Instrumentation Calibration The inspector observed radiation survey instruments used in the containment building and confirmed that they were within the required calibration intervals and were response-tested before use.'uring interviews, radiation protection technicians stated that there was no shortage of calibrated radiation survey instruments.
Radiolo ical Surve Results The inspector performed independent radiation measurements and compared the results with the licensee's radiation survey information. No discrepancies were
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Radiation protection personnel placed air sampling equipment correctly to measure airborne radioactivity concentrations in breathing zones.
The inspector reviewed air sampling documentation and verified selected calculation I I
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-8-Conclusions Good radioactive material controls were maintained.
Radiation workers generally used good contamination control practices.
Radiation protection personnel surveyed items correctly before releasing them from the radiological controlled area.
The licensee maintained a sufficient supply of calibrated radiation detection instruments.
Radiation dose rates and airborne radioactivity concentration were evaluated correctly Staff Training and Qualification Sco e 83750 The inspector reviewed resumes of selected contract radiation protection technicians.
Findin s and Observations The licensee supplemented the radiation protection staff with contract radiation protection technicians; however, the licensee was unable to hire as many as it planned.
Because of the high number of concurrent refueling outages and the accompanying competition for contract workers, the licensee employed only 25 contract radiation protection technicians, instead of the planned 33. For comparison, the licensee supplemented the radiation protection staff with 51 contract technicians during the previous refueling outage.
Licensee representatives stated that some work was delayed because of the shortage of radiation protection staff; however, the staff shortage had not affected the timing of critical path work activities. The inspector did not identify safety concerns related to the shortage of radiation protection technicians.,
The inspector compared contract radiation protection technicians'ork experience with the qualification requirements in Technical Specification 5.3.1. Technical Specification 5.3.1 requires that each member of the unit staff meet or exceed the minimum qualifications of Regulatory Guide 1.8, September 1975 and ANSI/ANS 3.1-1978.
ANSI/ANS 3.1-1978 requires that technicians have 3 years of work experience in their speciality.
The inspector concluded that all contract radiation protection technicians, except one, met technical specification requirements.
The inspector could not determine from the resume review if one individual had the required 3 years of experience.
The individual's resume stated that the individual had worked from 1983 to 1994 at a naval shipyard for the Department of Defense.
However, in addition to radiation protection duties, the individual supervised repair and preventive maintenance, reviewed engineering blueprints and drawings, and determined work force requirements.
The resume did not state the number of years or the percentage of the total time devoted to any duty.
Licensee representatives acknowledged the inspector's finding but stated that their agreement with their contractor allowed the contractor 30 days from the contract technician's initial employment date to provide qualification confirmation. The 30-day period had not passe l I
The inspector asked if the individual had already performed the duties of a qualified radiation protection technician.
Licensee representatives acknowledged that the individual had released radioactive material from the radiological controlled area and may have provided radiological job coverage.
The licensee representatives stated that they would interview the individual in question and quantify the individual's applicable experience.
During the exit meeting on April 9, 1999, the inspector identified this issue as an unresolved item pending further review of the individual's qualifications by the licensee and the NRC to determine if the contract radiation protection technician met Technical Specification 5.3.1 requirements.
An unresolved item is a matter about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation.
A licensee representative interviewed the individual on April 10, 1999, and determined the individual had 192 weeks of radiation protection related experience.
The licensee used its established, written guidance to evaluate the contract.technician's experience.
The inspector was unable to review the licensee's analysis before the exit meeting.
However, after reviewing the licensee's findings, the inspector concluded that the contract radiation protection technician met the requirements of Technical Specification 5.3.1 and that there was no violation.
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Conclusions The licensee supplemented its radiation protection staff with qualified contract radiation protection technicians.
Although the licensee did not employ as many contract radiation protection technicians as planned, the inspector identified no related safety concerns.
X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on April 9, 1999. The licensee acknowledged the findings presented.
No proprietary information was identifie l t
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ATTACHMENT PARTIALLIST OF PERSONS CONTACTED Licensee J. Bungard, Self-Assessment Coordinator, Radiation Protection R. Buzard, Senior Consultant, Nuclear Regulatory Affairs M. Fladager, Section Leader, Radioactive Materials Control J. Gaffney, Department Leader, Radiation Protection A. Krainik, Department Leader, Nuclear Regulatory Affairs G. Nelson, Training Coordinator, Radiation Protection J.
Levine, Senior Vice President, Nuclear Operations J. Steward, Director, Radiation Protection NRC J. Moorman, Senior Resident Inspector INSPECTION PROCEDURES USED 83750 Occupational Radiation Exposure LIST OF DOCUMENTS REVIEWED U2R8 Refueling Outage 37-Day 'Work Plan" (4/06/99)
List of active/suspended radiation exposure permits (4/06/99)
Outage to Date Comparison Chart (Days 0-'11)
Outage Exposure Comparison Graphs Post Shutdown Dose Rate Comparison U1R7, U2R7, U3R7, U2R8 Post Shutdown Dose Rate Comparison U2R6, U2R7, U2R8 U2R8 Cumulative Exposure vs. Goal (Days 0-9)
U2R8 Daily Exposure vs. Goal (Days 0-9)
ALARAOutage Update (Day 12)
ALARACommittee Meeting Minutes (12/10/98)
Memo from J. Wolfe (ID¹ 299-00688-JAW), "Chemistry Preparation and Plans for 2R8"
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-2-Memo from J. Santi (ID¹ 237-02583-JRS),
"Revised Unit Three 3R7 Refueling Shutdown Chemistry Report" Memo from J. Santi (ID¹ 237-02510-JRS),
"Unit Two 2R7 Refueling Shutdown Chemistry Report" List of corrective action documents assigned to the radiation protection organization (10/01/98 - 3/31/98)
Procedures 01DP-OEM08
"Experience and Education Verification," Revision 2 75RP-9RP02
"Radiation Exposure Permits," Revision 14
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