IR 05000528/2009007

IR 05000528-09-007, 05000529-09-007, 05000530-09-007, on 01/26/2009 - 01/30/2009, Palo Verde, Units 1, 2, and 3, Radiation Safety Team Inspection

ML090650648
Person / Time
Site:	Palo Verde
Issue date:	03/05/2009
From:	Greg Werner NRC/RGN-IV/DRS/PSB-2
To:	Edington R Arizona Public Service Co
References
FOIA/PA-2010-0209 IR-09-007
Download: ML090650648 (23)

Text

UNITED STATES NUC LE AR RE G UL AT O RY C O M M I S S I O N rch 5, 2009

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC RADIATION SAFETY TEAM INSPECTION 05000528/2009007, 05000529/2009007, AND 05000530/2009007

Dear Mr. Edington:

On January 30, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station. The enclosed Radiation Safety Team inspection report documents the inspection findings which were discussed with Mr. R. Bement, Vice President, Nuclear Operations, and other members of your staff.

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 On the basis of the results of this inspection, no findings of significance were identified.

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

Arizona Public Service Company -2-of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Docket Nos. 50-528, 50-529, 50-530 License Nos. NPF-41, NPF-51, NPF-74

Enclosure:

NRC Inspection Report 05000528/2009007, 05000529/2009007, and 05000530/2009007

REGION IV==

Dockets: 50-528, 50-529, 50-530 Licenses: NPF-41, NPF-51, NPF-74 Report: 05000528/2009007, 05000529/2009007, 05000530/2009007 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Location: 5951 S. Wintersburg Road Tonopah, Arizona Dates: January 26 - 30, 2009 Inspectors: L. C. Carson II, Senior Health Physicist and Team Leader L. T. Ricketson, P.E., Senior Health Physicist D. C. Graves, Health Physicist D. L. Stearns, Health Physicist Approved By: Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS IR 05000528/2009007, 05000529/2009007, 05000530/2009007; 01/26/2009 - 01/30/2009; Palo Verde Nuclear Generating Station Units 1, 2, and 3; Radiation Safety Team Inspection The report covered a 5-day period of inspection onsite by a team of four region-based health physics inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified and Self-Revealing Findings No findings of significance were identified.

B. Licensee-Identified Violations None-2- Enclosure

Report Details 2. 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;

• Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection;

• 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;

-3- Enclosure

• Qualification documentation for onsite personnel designated to perform maintenance on the vendor-designated vital components, and the vital component maintenance records for SCBA units; Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports or special reports Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of nine of the required nine samples, as defined in Inspection Procedure 71121.03-05.

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: (1) ensure that the gaseous and liquid effluent processing systems are maintained so that radiological discharges are properly mitigated, monitored, and evaluated with respect to public exposure; (2) ensure that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors are out-of-service, are controlled in accordance with the applicable regulatory requirements and licensee procedures; (3) verify that the licensee=s quality control program ensures that the radioactive effluent sampling and analysis requirements are satisfied so that discharges of radioactive materials are adequately quantified and evaluated; and (4) verify the adequacy of public dose projections resulting from radioactive effluent discharges. The team used the requirements in: 10 CFR Part 20; 10 CFR Part 50, Appendices A and I; 40 CFR Part 190; the Offsite Dose Calculation Manual; and licensee procedures required by the Technical Specifications as criteria for determining compliance.

The team conducted in-office inspection and reviewed:

• Appropriate program documents, procedures and evaluations related to the radiological effluent controls program listed in the attachment to this report;

• The implementation of the Radiological Effluent Controls Program requirements as described in Radiological Effluent Technical Specifications;

-4- Enclosure

• Changes, if any, to the liquid or gaseous radioactive waste system design, procedures, or operation as described in the Final Safety Analysis Report Update;

• Changes, if any, to the Offsite Dose Calculation Manual made by the licensee since the last inspection;

• Effluent monitoring instrumentation documentation to ensure adequate methods and monitoring of effluents;

• The program for identifying, assessing, and controlling contaminated spills and leaks;

• The annual effluent release reports and the correlation to the environmental monitoring results;

• The results from quality assurance audits.

The team conducted an onsite inspection which included interviewing cognizant licensee personnel, performing walkdowns of facilities and equipment, and observing licensee activities to review:

• The gaseous and liquid discharge system configuration;

• Selected point of discharge effluent radiation monitoring systems and flow measurement devices;

• The observation of selected portions of the routine processing and discharge of radioactive gaseous and liquid effluent (sample collection and analysis) including a selection of radioactive gaseous and liquid waste effluent discharge permits;

• Effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors including the projected doses to members of the public;

• Surveillance test results on non-safety related ventilation and gaseous discharge systems (high efficiency particulate air and charcoal filtration) including the methodology to determine the stack and vent flow rates;

• The identification of non-radioactive systems that have become contaminated, if applicable;

• Effluent monitoring instrument (installed and counting room) maintenance, quality control, and calibration;

-5- Enclosure

• The methods used to determine the isotopes in the plant source term, meteorological dispersion and deposition factors, and hydrogeologic characteristics used in the Offsite Dose Calculation Manual and effluent dose calculations including a selection of monthly, quarterly, and annual dose calculations;

• The land-use census;

• Records of abnormal gaseous or liquid discharges, if any, including the evaluation and analysis of events involving spills or discharges, dose assessments to members of the public, required (or voluntary) offsite notifications, and assessments and reporting of abnormal discharges in the Annual Radiological Effluent Release Report;

• Evaluations of discharges from onsite surface water bodies, if any;

• Routine groundwater monitoring results;

• Audits and self-assessments; licensee event reports or special reports, if any were required since the previous inspection;

• The results of the inter-laboratory comparison program;

• Effluent sampling records;

• The calibration of post-accident effluent monitoring instrumentation and expected accident source.

The team reviewed the licensees program of problem identification and resolution, including:

• Placement of problems identified through audits, self assessments, and monitoring results into the corrective action program and adequacy of immediate and long term corrective actions;

• Problem identification and resolution follow-up activities;

• Identification of repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified by the licensee=s self-assessment activities.

Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three of the required three samples, as defined in Inspection Procedure 71122.01-05.

-6- Enclosure

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 licensee=s 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 licensee=s 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;

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and disposal manifesting;

• Shipping records for non-excepted package shipments;

• Audits and self-assessments, licensee event reports, special reports, audits, and state agency reports, if any were required since the previous inspection.

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports or special reports Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of six of the required six samples, as defined in Inspection Procedure 71122.02-05.

b. Findings No findings of significance were identified.

-7- Enclosure

2PS3 Radiological Environmental Monitoring Program and Radioactive Material Control Program (71122.03)

a. Inspection Scope This area was inspected to ensure that the radiological environmental monitoring program 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 and licensee event reports, if any were required since the previous inspection;

• Selected air sampling and thermoluminescence dosimeter monitoring stations;

• Collection and preparation of environmental samples;

• Operability, calibration, and maintenance of meteorological instruments;

• Each event, if any, documented in the Annual Environmental Monitoring Report which involved a missed sample, inoperable sampler, lost thermoluminescence dosimeter, or anomalous measurement;

• Significant changes, if any, 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, interlaboratory comparison program results, and vendor audits;

• Locations where the licensee monitors potentially contaminated material leaving the radiological controlled area [or controlled access 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, corrective action documents and licensee event reports or special reports, if any were required, since the previous inspection.

-8- Enclosure

Either because the conditions did not exist or an event had not occurred, no opportunities were available to review the following items:

• Licensee event reports or special reports Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of ten of the required ten samples, as defined in Inspection Procedure 71122.03-05.

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES 4OA2 Problem Identification and Resolution Annual Sample Review 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.

-9- Enclosure

4OA5 Other Activities

.1 (Closed) Temporary Instruction (TI) 2515/173, Review of the Implementation of the Industry Groundwater Protection Voluntary Initiative a. Inspection Scope An NRC assessment was performed of the licensees groundwater protection program to determine whether the licensee implemented the voluntary Industry Groundwater Protection Initiative, dated August 2007 (Nuclear Energy Institute 07-07, ADAMS accession number ML072610036). Inspectors interviewed personnel, performed walk-downs of selected areas, and reviewed the following items:

• Records of the site characterization of geology and hydrology;

• Evaluations of systems, structures, and or components that contain or could contain licensed material and evaluations of work practices that involve licensed material for which there is a credible mechanism for the licensed material to reach the groundwater;

• Implementation of an onsite groundwater monitoring program to monitor for potential licensed radioactive leakage into groundwater;

• Procedures for the decision making process for potential remediation of leaks and spills, including consideration of the long term decommissioning impacts;

• Records of leaks and spills recorded, if any, in the licensees decommissioning files in accordance with 10 CFR 50.75(g);

• Licensee briefings of local and state officials on the licensees groundwater protection initiative;

• Protocols for notification to the local and state officials, and to the NRC regarding detection of leaks and spills;

• Protocols and/or procedures for thirty day reports if an onsite groundwater sample exceeds the criteria in the radiological environmental monitoring program;

• Groundwater monitoring results as reported in the annual effluent and/or environmental monitoring report;

• Licensee and industry assessments of implementation of the groundwater protection initiative.

- 10 - Enclosure

b. Findings No findings of significance were identified. Under the Ground Water Protection Initiative, each site was to have developed an effective, technically sound groundwater protection program by August 2008. The licensee completed its Ground Water Protection Initiative program self-assessment on October 28, 2008. The team identified that the licensee had not fully documented agreements on differences to protocols for notification to local and state officials regarding detection of leaks and spills. The findings from the licensees self-assessment and the NRC observations were entered into the corrective action program. The Nuclear Energy Institute self-assessment is scheduled to be completed in July 2009.

4OA6 Management Meetings Exit Meeting Summary On January 30, 2009, the team presented the inspection results to Mr. R. Bement, Vice President, Nuclear Operations, and other members of his staff who acknowledged the findings. The team confirmed that proprietary information was not provided or examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

- 11 - Enclosure

SUPPLEMENTAL INFORMATION Licensee Personnel S. Bauer, Director, Regulatory Affairs R. Bement, Vice President, Nuclear Operations R. Black, Engineer, Operation Computer Support C. Bonhoff; Section Leader, RP Technical Services L. Cortopossi, Plant Manager, Nuclear Operations T. Dickinson; Senior Technical Advisor, Radiation Protection J. Gaffney, Director, Radiation Protection T. Gray, Department Leader, Radiological Support Services D. Hautala, Senior Engineer, Regulatory Affairs H. Lesan, Section Leader, Environmental J. McDonnell, Department Leader, Radiation Protection Operations C. Mcfarlane; Advisor, Radiation Protection/Chemistry D. Mims, Vice President, Regulatory Affairs and Plant Improvement T. Phillips, Engineer, Operation Computer Support C. Podgurski, Section Leader, Dosimetry, Radiation Protection T. Radtke, General Manager, Emergency Services and Support R. Routolo, Section Leader, Radiation Protection M. White, Program Advisor, Fire Protection Administration NRC R. Treadway, Senior Resident Inspector LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened and Closed During this Inspection NONE Previous Items Closed NONE Previous Items Discussed NONE A1-1 Attachment

LIST OF DOCUMENTS REVIEWED Section 2OS3: Radiation Monitoring Instrumentation and Protective Equipment (IP71121.03)

Procedures NUMBER TITLE REVISION 14DP-9IS01 Respiratory Equipment Maintenance, Inspection, and Repair 10 75RP-9EQ13 Canberra Whole Body Counting System Calibration 4 75RP-9EQ20 Calibration Of Portable Gamma And Beta-Gamma Dose Rate 8 Instruments Audits and Self-assessments NUMBER TITLE REVISION 2008-012 Radiation Protection Audit 11/18/08 2006-012 Radiation Safety Audit 11/19/06 Effluent Monitor Calibrations Surveillance Unit Channel No. Monitor Description Procedure Calibration Dates 1 RU-143 Plant vent/low range noble gas 74ST-9SQ26 1/02/07, 7/11/08 2 RU-144 Plant vent/high range noble gas 74ST-9SQ27 3/08/07, 7/25/08 3 RU-145 Fuel building/low range noble gas 74ST-9SQ28 12/04/08 1 RU-146 Fuel building/low range noble gas 74ST-9SQ29 10/03/06, 2/22/08 2 J-CPN-FT0042 Effluent Process Flow 74ST-9SQ12 6/20/07, 11/15/08 3 J-CPN-FT0042 Effluent Process Flow 74ST-9SQ12 12/19/06, 5/07/08 Area Monitor Calibrations Surveillance Unit Channel No. Monitor Description Procedure Calibration Dates 2 RU-148 In Containment Area 74ST-9SQ23 10/03/06, 4/03/08 RU-149 2 RU-150 Primary Coolant 74ST-9SQ23 10/03/06, 4/03/08 RU-151 1 RU-17 Incore Instrument Area WO#3097888 10/04/08 A1-2 Attachment

Radiation Protection Instrumentation Calibrations Model No. Instrument Type Calibration Date Fastscan 1 Whole Body Counter 8/22/08 Fastscan 2 Whole Body Counter 9/02/08 2380 E520 1/04/09 1893 40GL 9/11/08 100143 732GM Probe 9/11/08 563 SAC4 9/10/08 4111 PM-7 10/01/08 410 PM-7 9/04/08 9118 PCM-2 8/07/08 1298 PCM-2 1/20/09 10301 Tool Monitor 9/05/08 322001 Tool Monitor 9/05/08 18301 Tool Monitor 9/23/08 50201 Tool Monitor 9/23/08 Corrective Action Program Documents 2969003 2970616 2973742 3035353 3060232 31011599 3145108 32029 71 3244247 3266828 Section 2PS1: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (IP71122.01)

Procedures NUMBER TITLE REVISION 33DP-0AP03 Ventilation Filter Test Program 4 73DP-0AP06 HVAC System Performance Testing Program 6 74ST-9SQ12 Effluent Flowpath Process Flow Calibration 9 74ST-9SQ15 RU-143 and RU-144 Quarterly Function Test Procedure 10 74ST-9SQ01 Effluent Monitoring System Daily Surveillance Test 11 74RM-9EF20 Gaseous Radioactive Release Permits and Offsite Dose 15 Assessment 74RM-9EF42 Radiation Monitor Alarm Setpoint Determination 22 74RM-9EF43 Actions for Inoperable Radiation Monitors: Preplanned 11 Alternate Sampling Program A1-3 Attachment

Miscellaneous Documents 2006 Annual Radioactive Effluent Release Report 2007 Annual Radioactive Effluent Release Report Offsite Dose Calculation Manual, Revision 23 Corrective Action Program Documents 2960165 2964843 3004531 3046218 3060232 3101599 3145108 3150810 3194449 3194449 3244247 Gaseous Release Permits 20071012 20071019 20071027 20071061 20072005 20072017 20073021 2007302 20073052 20081202 20083163 20092004 Section 2PS2: Radioactive Material Processing and Transportation (IP71122.02)

Procedures NUMBER TITLE REVISION 75DP-0RP01 RP Program Overview 8 76DP-0RP01 Radwaste Management Program Overview 4 76DP-0RP03 Radwaste Process Control Program 6 76DP-0RP04 Receipt and Shipment of Radioactive Material 5 76DP-0RW04 Receipt of Radioactive Material 2 76DP-0RW05 Packaging and Classification of Radioactive Waste 3 74DP-9CY08 Radiological Monitoring Program 20 75RP-9RP15 Control and Storage of Radioactive Material and 20 Radioactive Wastes A1-4 Attachment

Section 2PS2: Radioactive Material Processing and Transportation (IP71122.02)

Procedures NUMBER TITLE REVISION 75RP-9RP28 Radioactive Process Filter Management 2 15TD-0TT01 Radiation Protection Training Guide 6 Radioactive Waste Shipments NUMBER TITLE 07-RW-007 Type B Shipment 07-RW-030 Sealand Container LSA 08-SH-021 DOT 7A Type A Package 08-RW-024 Demineralizer Resin 08-RW-030 Sealand Container LSA 08-RW-041 Sealand Container DAW Corrective Action Program Documents 2965984 2968704 2984659 2991660 3026618 3033295 3042985 3048481 3048483 3048487 3071730 3075830 3090121 3090705 3105145 3105460 3157042 3158817 3160980 3164665 3190086 3224218 3246984 3255813 3264527 Miscellaneous Documents 2006 Annual Radioactive Effluent Release Report 2007 Annual Radioactive Effluent Release Report Offsite Dose Calculation Manual, Revision 23 A1-5 Attachment

Section 2PS3: Radiological Environmental Monitoring Program and Radioactive Material Control Program (IP71122.03)

Procedures NUMBER TITLE REVISION 74DP-9CY08 Radiological Monitoring Program 30 74RM-0EN02 Radiological Environmental Air Sampling Program 18 74RM-0EN03 Radiological Environmental Sampling Program 26 74RM-0EN07 Land Use Census, 12 75RP-9RP09 Release of Vehicles, Equipment, and Material from 36 Radiological Controlled Areas, Meteorological Instrument, Environmental Lab, Air Sampler Calibrations NUMBER TITLE DATE 77ST-9RG02 Meteorlogical System Calibration Redundant System 11/17/08 LZ44830 Mass Flow Meter Evaluations 01/14/08 Miscellaneous Documents 2007 Land Use Census, 2008 Land Use Census, 2006 Annual Radioactive Effluent Release Report 2007 Annual Radioactive Effluent Release Report Annual Environmental Operating Report 2007 A1-6 Attachment

Section 4OA5 Temporary Instruction (TI) 2515/173 Procedures NUMBER TITLE REVISION 75PR-9AP01 Groundwater Protection Program 1 Miscellaneous Documents NEI 07-07 Industry Groundwater Protection Initiative - Final Guidance Document CRDR 2874033 Decommissioning Record, July 21, 2008 PVNGS Groundwater Monitoring Program and Compliance with the NEI Groundwater Protection Initiative, April 1, 2008 Retention Basin Clean Closure Report Decommissioning Record, September 16, 2008 Groundwater Protection SWMS No. 3236830, November 2008 Event Reporting Manual , January 2009 Tritium Leak Rate Assessment for Systems, Structures, and Components - Engineering Study 13-CS-A026 Corrective Action Documents 37277512 37277110 2874033 A1-7 Attachment