IR 05000528/2007010
| ML070780258 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/16/2007 |
| From: | Shannon M Plant Support Branch Region IV |
| To: | Edington R Arizona Public Service Co |
| References | |
| IR-07-010 | |
| Download: ML070780258 (18) | |
Text
rch 16, 2007
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION - NRC RADIATION SAFETY TEAM INSPECTION REPORT 05000528/2007010, 05000529/2007010, AND 05000530/2007010
Dear Mr. Edington:
On February 22, 2007, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station. The enclosed report documents the inspection findings, which were discussed at the conclusion of the on site inspection on February 2, 2007, with Mr. C. Eubanks, Vice President, Nuclear Operations, and other members of your staff. An additional telephonic exit was held on February 22, 2007, with Mr. J. Gaffney, Director, Radiation Protection after we had reviewed the additional information that your staff provided.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The team reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, the team evaluated the inspection areas within the Radiation Protection Strategic Performance Area that are scheduled for review every two years. These areas are:
- Radiation Monitoring Instrumentation
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
- Radioactive Material Processing and Transportation
- Radiological Environmental Monitoring Program and Radioactive Material Control Program This inspection report documents one self-revealing, noncited violation of very low safety significance (Green). However, because the finding was of very low safety significance and it was entered into your corrective action program, the NRC is treating this finding as a noncited violation consistent with Section VI.A of the NRC Enforcement Policy. Additionally, one licensee-identified violation which was determined to be of very low safety significance is listed in this report. If you contest any noncited violation in this report, you should provide a response
Arizona Public Service Company -2-within 30 days of the date of this inspection report, with the basis for your denial, to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington DC 20555-001; and the NRC Resident Inspector at the Palo Verde Generating Station.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Dockets: 50-528, 50-529, 50-530 Licenses: NPF-41, NPF-51, NPF-74
Enclosure:
NRC Inspection Report 05000528/2007010; 05000529/2007010; 05000530/2007010 w/attachment: Supplemental Information
REGION IV==
Dockets: 50-528, 50-529, 50-530 Licenses: NPF-41, NPF-51, NPF-74 Report: 05000528/2007010, 05000529/2007010, 05000530/2007010 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location: 5951 S. Wintersburg Tonopah, Arizona Dates: January 29 through February 22, 2007 Inspectors: Gilbert Guerra, C.H.P., Health Physicist, Plant Support Branch Larry Ricketson, P.E., Senior Health Physicist, Plant Support Branch Bernadette Baca, Health Physicist, Plant Support Branch Binesh Tharakan, C.H.P, Health Physicist, Plant Support Branch Donald Stearns, Health Physicist, Plant Support Branch Approved By: Michael P. Shannon, Chief Plant Support Branch Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000528/2007010, 05000529/2007010, 05000530/2007010; 1/29/07 - 2/22/07; Palo Verde
Nuclear Generating Station Units 1, 2, and 3; Radiation Safety Team Inspection; Radioactive Material Control Program The report coverers an on site inspection by a team of five region-based health physics inspectors. A finding of very low safety significance (Green) was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609,
Significance Determination Process. Findings for which the Significance Determination Process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
A self-revealing, noncited violation of Technical Specification 5.4.1 was reviewed regarding the failure to control the release of radioactive material. On February 2, 2006, the licensee was notified by another site that equipment received was labeled as radioactive material. Specifically, five items, with a maximum activity of 280 counts per minute, were inappropriately released from the radiologically controlled area and subsequently the protected area. The licensee's corrective actions include evaluating and implementing changes to the material release program and processes.
The finding is greater than minor because it was associated with the Public Radiation Safety cornerstone attribute of human performance and affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using the Public Radiation Safety Significance Determination Process, the team determined that the finding had very low safety significance because: (1) it was a radioactive material control finding, (2) it was not a transportation finding, (3) it did not result in public dose greater than 0.005 rem, and (4) the number of occurrences was not greater than five. In addition, this finding had a human performance cross-cutting aspect associated with work practices because the licensee failed to ensure supervisory and management oversight of work activities, including contractors (Section 2PS3).
Licensee-Identified Violations
A violation of very low safety significance, which was identified by the licensee has been reviewed by the team. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. The violation and corrective actions is listed in Section 4OA7 of this report.
REPORT DETAILS
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety [OS] and Public Radiation Safety [PS] 2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
a. Inspection Scope
This area was inspected to determine the accuracy and operability of radiation monitoring instruments that are used for the protection of occupational workers and the adequacy of the program to provide self-contained breathing apparatus (SCBA) to workers. The team used the requirements in 10 CFR Part 20 and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Calibration of area radiation monitors associated with transient high and very high radiation areas and post accident monitors used for remote emergency assessment
- Calibration of portable radiation detection instrumentation, electronic alarming dosimetry, and continuous air monitors used for job coverage
- Calibration of whole body counting equipment and radiation detection instruments utilized for personnel and material release from the radiologically controlled area
- Self-assessments, audits, and licensee event reports
- Corrective action program reports since the last inspection
- Licensee action in cases of repetitive deficiencies or significant individual deficiencies
- Calibration expiration and source response check currency on radiation detection instruments staged for use
- The licensees capability for refilling and transporting SCBA air bottles to and from the control room and operations support center during emergency conditions, status of SCBA staged and ready for use in the plant and associated surveillance records, and personnel qualification and training
- Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units The team completed 9 of the required 9 samples.
b. Findings
No findings of significance were identified.
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)
a. Inspection Scope
This area was inspected to ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored, and evaluated with respect to public exposure. The team used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendices A and I, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed:
- Radiological effluent release reports since the last inspection, changes to the Offsite Dose Calculation Manual, radiation monitor setpoint calculation methodology, anomalous sampling results, effluent radiological occurrence performance indicator incidents, program for identifying contaminated spills and leakage and the licensee's process for control and assessment, self-assessments, audits, and licensee event reports
- Gaseous and liquid release system component configurations
- Routine processing, sample collection, sample analysis, and release of radioactive liquid and gaseous effluent; and radioactive liquid and gaseous effluent release permits and dose projections to members of the public
- The licensee's understanding of the location and construction of underground pipes and tanks and storage pools that contain radioactive contaminated liquids; the technical bases for onsite monitoring, the licensee's capabilities of detecting spills or leaks and identifying groundwater radiological contamination both on site and beyond the owner-controlled area
- Changes made by the licensee to the Offsite Dose Calculation Manual, the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection
- Monthly, quarterly, and annual dose calculations
- Surveillance test results involving air cleaning systems and stack or vent flow rates
- Instrument calibrations of discharge effluent radiation monitors and flow measurement devices, effluent monitoring system modifications, effluent radiation monitor alarm setpoint values, and counting room instrumentation calibration and quality control
- Interlaboratory comparison program results
- Licensee event reports, special reports, audits, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Abnormal releases The team completed 11 of the required 11 samples.
b. Findings
No findings of significance were identified.
2PS2 Radioactive Material Processing and Transportation (71122.02)
a. Inspection Scope
This area was inspected to verify that the licensees radioactive material processing and transportation program complies with the requirements of 10 CFR Parts 20, 61, and 71 and Department of Transportation regulations contained in 49 CFR Parts 171-180. The team interviewed licensee personnel and reviewed:
- The radioactive waste system description, recent radiological effluent release reports, and the scope of the licensees audit program
- Liquid and solid radioactive waste processing systems configurations, the status and control of any radioactive waste process equipment that is not operational or is abandoned in place, changes made to the radioactive waste processing systems since the last inspection, and current processes for transferring radioactive waste resin and sludge discharges
- Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides
- Shipping records for nonexcepted package shipments
- Licensee event reports, special reports, audits, state agency reports, self-assessments and corrective action reports performed since the last inspection Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:
- Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting The team completed 6 of the required 6 samples.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material Control Program (71122.03)
a. Inspection Scope
This area was inspected to ensure that the REMP verifies the impact of radioactive effluent releases to the environment and sufficiently validates the integrity of the radioactive gaseous and liquid effluent release program; and that the licensees surveys and controls are adequate to prevent the inadvertent release of licensed materials into the public domain. The team used the requirements in 10 CFR Part 20, Appendix I of 10 CFR Part 50, the Offsite Dose Calculation Manual, and the licensees procedures required by technical specifications as criteria for determining compliance. The team interviewed licensee personnel and reviewed
- Annual environmental monitoring reports
- Selected air sampling and thermoluminescence dosimeter monitoring stations
- Collection and preparation of environmental samples
- Operability, calibration, and maintenance of meteorological instruments
- Each event documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement
- Significant changes made by the licensee to the Offsite Dose Calculation Manual as the result of changes to the land census or sampler station modifications since the last inspection
- Calibration and maintenance records for air samplers, composite water samplers, and environmental sample radiation measurement instrumentation, quality control program, and interlaboratory comparison program results
- Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area and the methods used for control, survey, and release from these areas
- Type of radiation monitoring instrumentation used to monitor items released, survey and release criteria of potentially contaminated material, radiation detection sensitivities, procedural guidance, and material release records
- Audits, self-assessments, and corrective action reports performed since the last inspection
The team completed 10 of the required 10 samples.
b. Findings
Introduction.
A self-revealing, noncited violation of Technical Specification 5.4.1 was reviewed regarding the failure to control the release of radioactive material. The violation had very low safety significance.
Description.
On February 2, 2006, the licensee was notified by another site that equipment received was labeled as radioactive material. The licensees investigation determined that two sealand containers used during the Unit 1 refueling outage were not consistently controlled for the storage and release of radioactive material. Specifically, five items, with a maximum activity of 280 counts per minute, were inappropriately released from the radiologically controlled area and subsequently the protected area. The licensees corrective actions included evaluating and implementing changes to their material release program and processes.
Analysis.
The failure to control the release of radioactive material is a performance deficiency. The finding is greater than minor because it was associated with the Public Radiation Safety cornerstone attribute of human performance and affected the associated cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. Using the Public Radiation Safety Significance Determination Process, the team determined the finding had very low safety significance because:
- (1) it was a radioactive material control finding,
- (2) it was not a transportation finding,
- (3) it did not result in public dose greater than 0.005 rem, and
- (4) the number of occurrences was not greater than five. In addition, this finding had a human performance cross-cutting aspect associated with work practices because the licensee failed to ensure supervisory and management oversight of work activities, including contractors.
Enforcement.
Technical Specification 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained which cover applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Section 7(e) of the regulatory guide requires procedures for radiation surveys which would limit personnel exposure and materials released into the environment.
Procedure 75RP-9RP09, Release of Vehicles, Equipment, and Material from Radiological Controlled Areas, Section 3.1.2 states, in part, that all liquid and solid materials that have the potential for being contaminated with radioactive material must be evaluated by radiation protection prior to being unconditionally released. Section 3.2 of the same procedure states, in part, that tools, equipment, and material exiting the radiological controlled areas shall be evaluated for the presence of radioactive material by a qualified individual and that each item which is to be unconditionally released by survey shall be evaluated against the criteria listed in Appendix B, "PVNGS Limits for Unconditional Release by Survey. Appendix B provides a limit of no detectable activity for tools, material, and equipment. Contrary to the technical specification, the licensee unconditionally released radioactive material from the radiological controlled areas.
Because this finding is of very low safety significance and has been entered into the licensees corrective action program (Condition Report/Disposition Request (CRDR)2866065), this violation is being treated as an noncited violation, consistent with
Section VI.A of the NRC Enforcement Policy: NCV 05000528; 529; 530/2007010-01, Failure to control the release of radioactive material.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
a. Inspection Scope
The team evaluated the effectiveness of the licensees problem identification and resolution process with respect to the following inspection areas:
- Radiation Monitoring Instrumentation (Section 2OS3)
- Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (Section 2PS1)
- Radioactive Material Processing and Transportation (Section 2PS2)
- Radiological Environmental Monitoring Program and Radioactive Material Control Program (Section 2PS3)
b. Findings and Observations
No findings of significance were identified. However, the team noted in reviewing prior public radiation safety inspections a trend with regard to radioactive material control issues. Specifically, in NRC Inspection Report 50-528; 529; 530/2003-008 four examples were identified; in NRC Inspection Report 50-528; 529; 530/2005-009 three examples were identified; and in this report another three examples were identified in Sections 2PS3 and 4OA7. In reviewing the corrective action documents related to these examples the team noted poor documentation in recording the corrective actions taken and that corrective actions were not effective in preventing similar occurrences. Additionally, the causes of some of the previous radioactive material control issues were related to the conduct of inadequate surveys for items released and the failure to control radioactive material in accordance with approved site procedures. Inadequate surveys and the failure to control radioactive material are the causes of the findings in Sections 2PS3 and 4OA7 of this report supporting that past corrective actions were narrowly focused and did not preclude reoccurrence.
4OA6 Management Meetings
Exit Meeting Summary
On February 2, 2007, the team debriefed the inspection results with Mr. C. Eubanks, Vice President, Nuclear Operations, and other members of the staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.
On February 22, 2007, a telephonic exit was held with Mr. J. Gaffney, Director, Radiation Protection and Mr. S. Bauer, Acting General Manager, Regulatory Affairs, and other members of the staff who acknowledged the findings.
4OA7 Licensee-Identified Violations
The following finding of very low significance was identified by the licensee and is a violation of NRC requirements which meet the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600 for being dispositioned as a noncited violation.
- Two examples of a Technical Specification 5.4.1 violation were reviewed by the team. Technical Specification 5.4.1 states, in part, that written procedures shall be established, implemented, and maintained, which cover applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
Section 7(e) of the regulatory guide requires procedures for radiation surveys which would limit personnel exposure and materials released into the environment.
Procedure 75RP-9RP09, Release of Vehicles, Equipment, and Material from Radiological Controlled Areas (RCA), Section 3.1.2 states, in part, that all liquid and solid materials that have the potential for being contaminated with radioactive material must be evaluated by radiation protection prior to being unconditionally released. In addition, Appendix B of the same procedure provides a limit of no detectable activity for tools, material, and equipment. The first example involved a contract welding superintendent removing equipment on a forklift from the RCA yard. The radiation protection technician who performed the release of the forklift did not inspect and survey the entire forklift and only surveyed the tires and forks.
This event was documented in the licensees corrective action program as CRDR 2932821. The second example involved the inadvertent release of radioactive material from the Unit 1 RCA and protected area. Two tool monitors experienced light leaks, which caused detector failures and the unconditional release of radioactive material. The licensee identified and recovered eleven items contaminated with radioactive material. Of the eleven items released, five remained within the protected area and six were found outside the protected area.
This event was documented in the licensees corrective action program as CRDR 2853883. The finding was determined to be of very low safety significance because:
- (1) it was a radioactive material control finding,
- (2) it was not a transportation finding,
- (3) it did not result in public dose greater than 0.005 rem, and
- (4) the number of occurrences was not greater than five.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- S. Bauer, Acting General Manager, Regulatory Affairs
- B. Bement, Vice President, Nuclear Operations
- C. Bonhoff, Radiological Material Control Section Leader, Radiation Protection
- W. Carr, Senior Chemistry Technician, Chemistry Technical Support
- R. Cauley, Senior Chemistry Technician, Chemistry Technical Support
- M. Debolt, Technician, Operations Computer Support
- T. Dickinson, Shipping Senior Technician, Radiation Protection
- C. Eubanks, Vice President, Nuclear Operations
- M. Fladager, Radiological Services Department Leader, Radiation Protection
- D. Fuller, Unit Section Leader, Chemistry
- J. Gaffney, Director, Radiation Protection
- T. Gray, Department Leader, Radiological Support Services
- D. Hautala, Senior Engineer, Regulatory Affairs
- S. Kanter, Technical Management Assistant, Radiation Protection Operations
- J. McDonnel, Department Leader, Radiation Protection Operations
- G. Morrill, Technician, Chemistry
- R. Moxon, Senior Program Advisor, Fire Department
- T. Phillips, Engineer, Operations Computer Support
- C. Podgurski, Section Leader, Dosimetry
- J. Rhodes, Technician, Dosimetry
- R. Routolo, Section Leader, Radiation Protection
- J. Tutora, Technician, Operations Computer Support
- C. Wandell, Consulting Engineer, Design Engineering
NRC
- G. Warnick, Senior Resident Inspector
- J. Melfi, Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None Opened and Closed During this Inspection 5000528; 529; 530/2007010-01 NCV Failure to control the release of radioactive material. (Section 2PS3)
Previous Items
Closed
None Attachment