ML17300A760
| ML17300A760 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/09/1987 |
| From: | Hooker C, North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17300A758 | List: |
| References | |
| 50-528-87-03, 50-528-87-3, 50-529-87-04, 50-529-87-4, 50-530-87-04, 50-530-87-4, NUDOCS 8704210291 | |
| Download: ML17300A760 (65) | |
See also: IR 05000528/1987003
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
Nos.
50-528/87-03,
50-529,87-04
and 50-530/87-04
Docket Nos.
50-528,
50-529 and'50-530
a
License
No.
NPF-51 and
CPPR-143
Construction
Permit No.
CPPR-143
Licensee:
Arizona Public Service
Company
P.
0.3 Box 21'666
Phoenix,
85836'acility
Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection at:
Palo Verde Site - Mintersburg, Arizona
Inspection
Conducted:
February
2-6', 23-27,
March 2-6 and telephone calls of
March 17-18,
1987
Inspected
by:
Approved by:
H.
S. North, Senior Radiation Specialist
/
J
C.
A. Hooker, Radiatio
Specialist
G.
P.
Yuhas, Chief
Facilities Radiological Protection Section
Date Signed
Date Signed
Date Signed
~Summar:
Ins ection durin
the
eriod of Februar
2-6
23-27
March 2-6 and tele
hone
calls of March 17-18
1987
Re ort Nos.
50-528 87-03
50-529 87-04,
50-530 87-04
~AI:
3
3
dd
3
3
f3d
3
did
d
d
equipment,
solid wastes,
gaseous
waste
system,
liquids and liquid wastes,
external
occupational
exposure
and personal
dosimetry, internal
exposure
control
and assessment,
plant systems affecting plant water chemistry, Units
1 and
2
LMR water chemistry control
and chemical analysis,
occupational
exposure
control during extended
outages,
Unit 1 solid wastes,
liquids and
liquid wastes,
gaseous
waste
system,
Units 1 and 2, quality assurance
and
confirmatory measurement
for in-plant radiochemical
analysis,
Unit 3 control
of radioactive materials
and contamination,
surveys
and monitoring,
maintaining occupational
exposures
ALARA, quality assurance
and confirmatory
measurements
for in-plant radiochemical
analysis,
a transportation
incident'nd
plant tours.
Inspection procedures
30703,
83527,
84522,
84524,
84523,
83524,
83525,
79502,
79701, .83729,
84722,
84723,
84724,
84725,
83526,
83528,
84525,
86721 and 92701 were addressed.
8704210291
870413
ADOCK 050005ZB
8
Results:
In the
18 areas
addressed,
no violations or deviations
were
identified in 17 areas.
In one area,
one apparent violation of 10 CFR 71.5
transport
requirements
for low specific activity radioactive materials,
in
that a strong, tight package
leaked radioactive materials,
was identified
(Report Section 12).
DETAILS
1.
Persons
Contacted
APS-ANPP
+"0. J. Zeringue,
Manager Technical
Support
,
+~R.
R. Baron,
Compliance Supervisor
+ L.
E.
Brown, Manager Radiation Protection
and Chemistry
+ L.
D. Johnson,
Nuclear Safety Engineer
+ D.
M. LeBoeuf,
gA Engineer
"G.
D. Perkins,
Manager Radiological
Services
+ J.
M. Juan,
Licensing Engineer
+ C.
N. Russo,
Manager equality'udits
and Monitoring
"J.
W.
Ryan, Unit 3 Operation's Shift Supervisor
"T.
D. Shriver,
Manager Compliance
+ J.
M. Sills, Senior Compliance
Engineer
"L. A. Souza,
Assistant Director Corporate
gA/gC
NRC
"R.
Zimmerman,
Senior Resident Inspector
"Denotes
attendance
at the February 6,
1987 exit interview.
+Denotes
attenda'nce
at the March 6,
1987 exit interview.
In addition to the individuals identified above,
the inspectors
met and
held discussions
with other members of the licensee's
staff.
During the inquiry into the Transportation
Incident, the following
individuals were interviewed by telephone:
R.
K. Ferrar,
Manager,
Design Engineering,
Associated
Technologies
Incorporated
F.
L. Wolking, Supervisor,
Plant Radiation Protection,
Clinton
Station, Illinois Power
Company
2.
R.
A. Paul,
Radiation Specialist,
NRC Region III
(Closed)
Followu
(50-530/86-16-02) - Facilities
and
E ui ment - Unit 3
83527)
Facilities
The facilities provided for radiation protection activities include
an area for the decontamination
of instruments
and small equipment.
A separate
dedicated facility was
used to support respirator
cleaning, testing,
maintenance
and repair for all three Units.
In
addition,
a protective clothing laundry (dry cleaning) facility and
- separate
decontamination facility were constructed
and equipped
as
a
part of Unit l.
Two separate
decontamination
showers with sinks
and appropriate
supplies. were located in the radiation protection area.
Appropriate change
rooms/locker
rooms were provided for both men and
women.
The facilities, while more than adequate for normal
operations,
would not be adequate
for a major outage.
The licensee
had prepared,
and used during
a Unit 1 outage,
a portable
change/access
control facility for use during major outages.
Appropriate storage facilities for instruments, air samplers
and
miscellaneous
radiation protection related supplies
were available
and stocked.
A well equipped medical/first aid facility was available
on site.
The facility was staffed by a physician
and two registered
nurses
during dayshift, five days per week with emergency'edical
technician
coverage
during back shifts
and weekends.
Formal
agreements
have
been executed with Maryvale and Good Samaritan
Hospitals.
Two ful'ly equipped
ambulances
were available
on site
although principal reliance
was placed
on West Valley or Buckeye
'mbulance
service.
Air evacuation
service
was available
and
had
been
used in drills to evacuate
to Good Samaritan Hospital.
In the
event of contaminated patients,
a health physics technician
accompanies
the patient
as well as medical staff members.
The
facility was equipped with two trauma areas
and
had available
portable
drug supplies, defibrillator,
EKG radiophone
patch at,
Maryvale Hospital,
IV solutions
and supplies for casting.
Communications
included base
station/ambulance
CB radio and radio to
the onsite fire department.
In addition, first aid supplies
and
facilities were provided in the radiation protection
space in Unit
3; however, principal reliance
was placed
on the medical facility.
~Eui ment
Several
Copus blowers were available for use with HEPA filter units
for localized ventilation.
The
HEPA filter containers
were
on order
but had not been received.
Transportable
temporary shielding
materials
were onsite stored in the warehouse.
Communications
systems
available included telephones,
plant paging system
and
individual pagers.
a
No deviations or violations were identified.
Closed)
Followu
(50-530/86-16-03) - Solid Mastes - Unit 3 (84522)
~Sam
1 ln
Oiscussion with the licensee
established
that provisions for
sampling solid waste
streams
were the
same in Unit 3 as in Units j.
and 2.
A potential for scalding type accidents
had been identified
with respect
to sampling hot concentrates
from the liquid waste
evaporator.
A Oesign
Change
Package
(OCP) was issued
March 18,
1986
and work was budgeted for 1988, to install specialized
sampling
equipment in all three units.
The equipment would permit safe
sampling from a recirculating stream with flush capability.
A
similar device will be used to sample flowing, but not recirculating
resin streams.
The device
can collect multiple equal
samples
at
selected
intervals to assure
representative
samples.
Test Pro
ram and
Com letion for Solid Waste
S stem
The test program included three tests
which encompassed
the entire
solid waste
system.
The licensee
had been using the services of
contractors for solidification and/or dewatering of spent resins
and
bitumen dewatering
and solidification of evaporator
concentrates.
A
compactor
was
used for loading dry active compactible waste.
The
licensee
was not using (Units 1 and 2) the installed
cement
solidification systems
but considered
those
systems
in all three
units to be
a viable option depending
on economic considerations.
Test,
73TI-1SROl, Revision 00, Solid Radwaste
Ca
in
Verification,
designed to test the automatic
capping capability of the cement
solidification system
was not complete.
Testing
had been terminated
and testing responsibility transferred
to operations.
The licensee
had the capability to cap manually, the test
was to verify the
automatic capping capability.
Test,
Revision 0, Resin Transfer/Dewaterin
S stem,
was
examined
and found to be
90+% complete.
Outstanding
were sluicing
CVCS and deborating
ion exchange
resins
and sluicing boric acid
evaporator
condensate
ion exchange
resins.
Testing
had verified the
ability 'to transfer resin to both the low and high activity resin
tanks
and the resin feed tank and the feed tank to the contractor
truck connection.
Test,
Revision 0, Solid Radwaste
S stem,
awaiting Test
Working Group
(TWG) review was examined.
Testing was complete except
for resin slurry and boric acid solidification testing.
Letter
ANPM-00075-BJG-97.35,
dated
February
16,
1987 requested
that the
testing
be stopped
and the uncompleted tests
be identified as test
exceptions.
The letter also requested
that startup verify the
sluicing of spent resin tanks to the contractor supplied portable
radwaste
system.
The uncompleted testing
was to be completed
by
Operations prior to use.
The licensee
was planning to use
contractor
supplied mobile systems.
The use of the mobile systems
had been demonstrated
successfully at Unit 1.
Process
Monitors
The preoperational
test program identified the process
monitors
and
verified operability and calibration using calibrated test
equipment.
Test equipment records
were maintained
showing
calibration
due dates.
No discrepancies
were identii'ied.
No violations or deviations
were identified.
t
4
p ~+ (
)
Closed
Followu
(50-530/86-16-05
- Gaseous
Maste
S stem - Unit 3
84524
~Sam lin
Plant vent sampling
systems
and monitors were provided
as described
in FSAR Table 11.5-1.
The installed
systems
were comparable
to
those installed in Units 1 and 2.
The licensee
had performed
evaluations of sampling
system deposition in Unit 1 which were
applicable to Unit 3.
In addition, the licensee
had operating
experience
in the use of the comparable
Unit 1 and
2 systems.
A
shielded,
chemical
fume hood type sampling station
was provided for
collection of samples
from the gaseous
waste
system.
Test Pro
ram and Test
Com le'tion
The licensee
had developed
and approved preoperational
test
procedures
for the gaseous
waste
system.
Preoperational
tests
reviewed included:
Procedure
Revision 0,
Gaseous
Radwaste
S stem,
which addressed
I testing,
had been completed
and approved.
The test incorporated
complementary tests
Gaseous
Radwaste
Flush,
73PE-3S(03,
Radiation
Monitorin
Prep
and 92PE-3HROl,
Radwaste Buildin
HVAC.
91PE-3HAOl, Revision 0, Auxiliar Buildin
HVAC S stem,
which
addressed
the testing requirements
91PE-3HR01,
Revision 0,
Radwaste Buildin
HVAC Prep erational
Test Procedure,
which addressed
the testing requirements
of
The licensee
had established
an
HVAC group responsible
for the
overall coordination
and testing of all
HVAC systems
including
monitoring operating times for charcoal
sampling
and monitoring
painting, welding and solvent
use.
The
HVAC staff included
an engineer certified as
a Level
3 Test
Director in accordance
with ANSI N45.2.6.
The licensee
had
purchased
the equipment required to perform
HEPA and charcoal
adsorber testing
and
had prepared,
approved
and implemented the
surveillance test proce'dures
for Units 1 and 2.
The licensee
stated
that Unit 3
HEPA and charcoal
surveillance tests
on systems
HJ,
Control
Room Essential
Ventilation System
and
HF, Fuel Building
Essential
Ventilation System
had been
completed.
The test report
on
the
HF system
had been submitted to the Test Results
Review Group
(TRRG) and the Test Results report on the
HJ system
was in
preparation.
The HP,
hydrogen purge system,
was tested only in Unit
1 since the hydrogen recombiner
and HEPA-adsorber train was
a
portable
system designed
for use at any of the three units.
The
results of the in-place
HEPA and adsorber
tests
were examined for
systems
HF and HJ.
The results
met the requirements
of ANSI-N-510.
The system testing satisfied the testing commitments of FSAR 14B-21,
Auxiliary Building Essential
HVAC and Fuel Building Essential.
Exhaust
Systems
and 14B-23, Control Building Essential
HVAC.
A
training course in filter-adsorber testing
and maintenance
was
scheduled for March 16-25,
1987.
Process
and Effluent Monitors
On March 6, 1987, the licensee
stated that preoperational
testing
on
all Technical Specification identified monitors except
RU-145 and
146,
low and high range
Fuel Building Exhaust Monitors had been
completed.
Thirteen of the monitors not identified in the Technical
Specifications
remained
incomplete.
Following completion of the
preoperational
testing,
the completed test packages
were to be
reviewed by TRRG.
On completion of testing the Technical
Specification monitors were placed
on the surveillance test schedule
and the non-.Technical
Specification monitors were placed
on the
preventive maintenance
schedule.
The results of testing of the
radiation monitors will be examined during a subsequent
inspection
(50-530/87"04-02).
No violations or deviations
were identified.
(Closed)
Followu
50-530/86-16-06) - Li uids
and Li uid Wastes - Unit 3
84523
Li uid Sam lin
Liquid sampling
was discussed
with Unit 3 chemistry
and radwaste
group'representatives.
The
and secondary
sampling
systems
were
used during the hot functional tests
and were found to be operable
and serviceable.
Some problems associated
with secondary
system
valve mislabeling were identified and resolved.
The liquid radwaste
system
sampling points consist of spigots
on various
systems.
No
central
sampling station
was provided.
The licensee
stated,
based
on observations
in Units 1 and 2, that the sampling capability was
adequate
and serviceable
and while improvements
could be
made they
were not required for safety of operations.
The licensee's
procedures
require circulation of 2< tank volumes prior to sampling.
The radwaste
system
sampling line runs were very short.
The points
of origin had been verified and purge
volumes for primary and
secondary
sampling lines
had been determined.
The Post Accident Sampling
System
(PASS)
was not operational.
Preoperational
testing
was just starting.
The staff planned to use
a hydrolaser to supply high pressure
to the
PASS during testing.
The chemistry group planned to conduct
hands-on
PASS training during
the preoperational
PASS testing phase.
Test Pro
ram and Results
Com letion for Li uid Waste
S stem
Test procedures
were reviewed
and approved
by the Test Working Group
(TWG) with test exception
review by Operations.
Completed tests
were referred to the Test Results
Review Group
(TRRG) for final
review and approval.
The liquid waste
system tests
included:
Revision 00, Boric Acid Concentrator
Test
Revision 00, Holdu
Tank and
Pum
s Includin
Gas
~Stri
er
91PE-3LROl, Revision 00,
Ls
used
Radwaste
Tanks
and Ion
Exchan ers
Revision 00,
va orator Packa
e
Revision 00,
L
oncentrate
on)tor Tanks
Revision 00, Chemical
Drain Tanks
and
Pum
s
Revision 00, Radioactive
Waste Draina
e
S stem
Revision 0,
Nuclear
Sam lin
Test
Revision 0,
Secondar
Sam le Test
Test,
Test,
was
90K complete.
Faulty screens
in the associated
ion exchanger
required repair.
It
was estimated that
3 to 4 weeks would be required to complete the
repairs
and the testing.
The. following test procedures/reports
were
examined:
91P E-3LR01
91- E"3LR02
91P E-3LR03
91P E-3SS01
Testing complete,
results
reviewed
and approved
TWG and Startup
Manager
Testing complete,
no outstanding test exceptions,
awaiting
TWG review
Testing complete,
results
reviewed
and approved
by
TWG
Testing complete, 'results
reviewed
and approved
by
TWG and Startup
Manager
Testing complete,
TWG meeting held, report
awaiting incorporation of TWG comments
Testing
and results
review complete
Li uid Process
and Effluent Monitors
The liquid waste
system includes
no plant effluent or essential
safety system monitors since the plant design
does
not provide for
the discharge of radioactive liquid wastes.
FSAR Table 11.5-1
identifies the following liquid monitors:
Monitor Desi nation
RU-2 and
RU-3
Function
Essential
Cooling Water
System Monitors
~Te
Offline-1 iqui d
RU-4 and
RU-5
Blowdown
Offline-liquid
Monitors
RU-6
Nuclear Cooling Water
System Monitor
Offline-l iqui d
RU-7
Auxiliary Steam
Condensate
Receiver
Tank Inlet Monitor
Tank Recir c-
1 i quid
RU-204
NSSS Process
Radi ation
Inlinc-1 iquid
.Monitor
RU-265
Gas Stripper
Effluent Monitor
Inline- 1 iqui d
None of the above
comparable
Unit 1 and
2 monitors were identified
by. the Technical Specifications.
The licensee
stated that of the non-Technical
Specification
identified Unit 3 monitors, preoperational
testing
was incomplete
on
13 monitors.
Testing
on
6 of the
13 monitors
was90-99K complete
with an overall completion of approximately
70K.
The licensee
expected to complete all testing
by March 9, 1987.
The licensee
was
informed that
NRR would be advised to require
a Justification for
Interim Operation if the preoperational
testing of the radiation
monitoring system
was not complete
by March 16,
1987.
The results
of preoperational
testing of the previously identified radiation
monitors will be examined during a subsequent
inspection
(50-530/87-04-01).
No violations or deviations
were identified.
Closed
Followu
50-530/86-30-01
- External
Occu ational
Ex osure
Control
and Personal
Dosimetr
- Unit 3 (83524)
Procedures
for emergency operation's
were contained in EPIP-16,
Revision
4, In-Plant Surve
s and Monitorin
, which provided for initial dose rate
evaluations
from the
RMS or ERFDADS, addressed
emergency
exposure limits
of EPIP-18
and provided for the
use of emergency kit equipment.
EPIP-18,
Revision 3,
Emer enc
Ex osure Guidelines,
provides
guidance for
exceeding
both
ANPP administrative
and
10 CFR 20 exposure limits during
an emergency
and lists maximum exposures
for accident conditions,
corrective actions
and life saving with reference
to the source of the
information.
The procedure
also specified that monitoring devices
and
protective equipment were to be appropriate for the conditions expected,
including various dosimetry devices,
KI, protective clothing and
respirators.
EPIP-38,
Revision 8,
Emer enc
E ui ment and
Su
lies Inventor
, listed
the supplies to be available in various
emergency kits.
The dosimetry
and survey instrument
and protective clothing, air samplers,
and
respirator supplies
in the Unit 3 Technical
Support Center
(TSC) and
Operations
Support Center
(OSC) were examined
and compared with the
inventory lists.
The dosimeter
chargers
were verified to be serviceable.
No deviations
or violations were identified.
0
'1
Closed
Followu
(50-530/86-30-02) - Internal
Ex osure Control
and
Assessment
- Unit 3
83525
Air Sam lin for Assessin
Individual
Ex osure
Procedure
Revision 4, Airborne Radioactivit
Sam lin
,
addressed
noble gas, particulate,
iodine and trit>urn.sampling,
provisions for use of silver zeolite cartr idges in high noble gas
concentrations,
delimits
on iodine cartridge airflows and breathing
zone sampling.
Sample analysis
was to be provided by the unit
radiation protection counting
room in accordance
with 75RP-9ZZ70',
Revision 0,
0 eration of Canberra
Series
90 Multichannel Anal zer.
The sample data sheet provided for review of the sample analytical
result.
A lower tier procedure
RP-007,
Revision 2, Evaluation of
Airborne Radioactivit
, addressed
MPC calculation,
MPC hour
tracking, determination of skin dose
from noble gases
and document
control.
quarterly air sampler calibration was required
by 75RP-9XC05,
Revision 4,
Flow Calibration and Maintenance of Air Sam lers.
This
procedure
also speclfsed
ca sbratson
to erances,
required annual
calibration of the air flow calibrator and provided for calibration
documentation
and record retention.
Adequate supplies of
appropriate
types of air sampling equipment
were available in Unit
3.
No violations or deviations
were identified.
Closed
Followu
(50-530/86-30-03
- Plant
S stems Affectin
Plant Water
Chemistr
- Unit 3
79502
Primar
and Secondar
Water
S stems
Discussion with the chemistry staff established
that the Unit 3
systems
were the
same
as Units 1 and 2.
The licensee
stated that
the Unit 3 systems
had not been modified.
On January
17, 1987, Unit
j. experienced
tube failure.
Subsequent
eddy
current testing in both Units 1 and
2 identified the problem to be
tube to support wear resulting from flow induced tube vibration.
The locations of flow induced wear in Units 1 and
2 were bounded
and
the bounded locations in the Unit 3 steam generators
were staked
and
plugged
as
a precautionary
measure.
The licensee
reported that from
a chemistry viewpoint, the Unit 1 and
2 primary and secondary
systems
had performed well.
Auxiliar
Water
S stems
The licensee
stated that Unit 1 and
2 operating experience
and Unit
3 testing established
that the system flows met design criteria and
that the quality of the water was adequate.
Some of the secondary
side instrumentation
maintenance
was too labor intensive
and the
licensee
elected
not to continue using the equipment.
In some
cases,
the instruments
were of old design
and upgrading
was
underway.
Demineralizers
The licensee
stated that in Unit 1 all primary system resins
had
been disposed
as waste rather than recharged.
Secondary
side resins
were recharged until the primary to secondary
leak of January
17,
1987 occurred.
Then the resins
were disposed
as waste.
The
uncontaminated
effluent from resin regeneration
was transferred
to
the retention basin for sampling
and analysis prior to discharge
to
the evaporation
pond.
Contaminated
high TDS waste
were transferred
to the liquid. radwaste
system evaporator.
The licensee's
procedure
S stem Chemistr
S ecification, provides
system
operating,
makeup,
standby
and layup parameters
for the following
systems:
Condensate
Auxiliary Steam Boiler
Spent
Fuel
Pool
Flush Water Criteria
Inhibited Water
Closed Cooling Systems
Circulating Water
Essential
Spray
Pond
Storage
Tanks
and Miscellaneous
Systems
No violations or deviations
were identified.
3.
LWR Water Chemistr
Control
and Chemical
Anal sis
Units 1 and
2
79701)
Audits and
A
raisals
The only audit in the Chemistry area,
Audit No.86-013,
"PVNGS Plant
Chemistry," is addressed
in report Section
8.
During 1986
a total
of 129 Monitoring Reports
were generated
by the equality Audit's and
Monitoring staff in the area of chemistry.
A random
sample of 25
Unit 1 and
20 Unit 2 Monitoring Reports
were examined.
The topics
addressed
included:
Unit
1/2
1
1/2
1
1
1/2
1
1/2
1/2
~To ic
Waste
Gas
Decay Tank Curie Content
Effluent Monitoring Daily Surveillance Test
Liquid Holdup Tank Surveillance Test
Reactor Coolant System Chloride Analysis
Backup
PASS Functional Test
Diesel Fire
Pump Fuel Oil
Refueling Water Storage
Tank Boron Surveillance
Test
Spent
Fuel
Pool
Reactor Coolant System Specific Activity
System Chemistry
10
1/2
1
1/2
2
2
Chemical
Waste Neutralization Tank Surveillance
Test
Safety Injection Tank Boron Surveillance Test
Secondary
System Activity Surveillance Test
Effluent Monitor Monthly Source
Check
Liquid Radwaste
System Monitor Tank Surveillance
Test
Diesel
Generator
Fuel Oil
ECCS-TSP Surveillance Test
Liquid Radwaste
System
Recycle Monitor Tank .
Surveillance Test
~Chan
ea
The licensee
reported that the Steam Generator
Owners
Group
(SGOG)
and
Combustion Engineering
(CE) guidance
on chemistry
had been incorporated
into procedure
S stems
Chemistr
S ecifications.
Guidance
provided by CE's
document
CENPD-28 was being augmented with applicable
portions
of., EPRI guidance
on water chemistry.
Im lementation of the
ualit
Assurance
Pro
ram for Chemical
Measurements
This topic is addressed
in Report Section
8.
No violations or deviations
were identified.
Occu ational
Ex osure Durin
Extended
Outa
es - Units 1 and
2
83729
'Fi 1
i
During the inspection
both Units 1 and
2 were engaged
in outage
activities, Unit 1 in steam generator
tube staking
and plugging and Unit 2 was in a 55-day maintenance/surveillance
outage.
As a result of the Unit 1 steam generator
tube failure and eddy current
findings, 'precautionary
tube
staking
and plugging were also'erformed
at Unit 2.
During the
inspection,
one inspector toured Units 1 and
2 extensively,
February 2-4,
1987.
During the tours,
surveys
were performed using
an ion chamber
survey meter,
due for calibration
on March 18,
1987.
No
significant differences
between the licensee's
survey instrument readings
and the
NRC instrument were noted.
Observations
Durin Facilit
Tours
During a tour of the Unit 1 containment
on February 2, 1987, the
inspector
found a High Radiation Area posting (sign) lying face
down at
the entrance
to the pressurizer
cubicle on the 120 ft. elevation level.
Tape
used to secure
a rope with this posting attached
across
the entrance
had
come loose
from the wall.
The inspector
dna not enter
the cubicle to
make radiation measurements
due to
RWP restrictions.
The licensee
was
unable to immediately present
the inspector with a recent survey of the
cubicle.
However,
a licensee
survey of the cubicle on February
3, 1987,
indicated that the
maximum whole body dose in the cubicle
was
65 mR/hr
with hot spots
up to 160 mR/hr.
The dose rates
in the cubicle were less
<<4
than
100 mR/hr, therefore, nullifying a potential violation of TS 6.12.1
In this case,
the containment posting "Radiation
Area" satisfied the posting requirements.
The inspector also noted that
a High Radiation Area posting attached
to
the door of the regenerative
heat exchanger
room door was almost
down.
The tape securing this posting
on the door was coming loose.
The inspector
expressed
concerns to the licensee
on the
use of tape for
securing postings.
The licensee
acknowledged
the inspector's
concerns
and agreed to find a better
method for securing postings of plant areas.
Unit 2 Tours
During a tour of the Unit 2 Auxiliary Building on February 3, 1987, it
was observed that the local audible high and low flow alarm speaker
on
RU-003, Essential
Coolin
Mater
ECW
Radiation Monitor - Train "B", was
covered over with a sticky-backed
wipe pad.
The inspector
removed the
wipe pad and heard the audible alarm signal.
The inspector
placed the
wipe pad back over the alarm speaker.
The inspector discussed
this
matter with a cognizant licensee's
representative,
who stated that, the
flow alarms
were actuated
when the respective
ECW trains were placed
on
line and must be reset with a portable
alarm reset instrument.
The alarm
reset function was performed
by the Radiation Protection
(RP) department
upon notification from the control
room when
ECM trains were placed
on
line.
However, in this case
the
RP department
had not been notified when
the
ECW "B" Train was placed
on line,
and apparently
no one
was
aware
that the alarm was signalling due to the wipe pad covering the alarm
speaker.
This matter was discussed
with the control
room foreman
on February 4,
1987.
The inspector's
expressed
concerns
on the licensee
resorting to
covering
up the speaker to silence the local flow alarms.
Covering
up
the alarm speaker
would negate their purpose
during normal operations if
the speaker
were covered.
The control
room foreman stated that
he would
expedite
a change to procedure
Shutdown Coolin
Initiation,
to ensure that the
RP department
would be informed when an
ECW train was
placed in service
so that the system radiation monitor flow alarms could
be reset in a timely manner.
Step-off pads
were properly utilized, personnel
contamination
and survey
instruments
wer e working properly and the instruments
displayed current
calibration dates.
Workers were observed to be properly dressed
in
protective clothing,
and equipped with required personnel
monitoring
devices.
In addition to the above observations,
the inspector
observed that all
radiation
were posted
as required
by 10 CFR Part 20 and that access
controls
wer'e consistent with TS, Section
6. 12,
and licensee
procedures.
Audits and
A
raisals
Three Monitoring Reports related to outage activities were examined:
0
<<~ 4
0
12
SM-87-0311, Unit 1, conducted
January
29-February
18,
1987,
addressed
radiation protection
and
ALARA activities.
Specific
topics included
Reg.
Guide 8.8 (ALARA), preparation of ALARA reports
and radiation exposure permits.
Dose assessment
surveys
and steam
generator
surveys
were also reviewed.
No deficiencies
were
identified.
SM-87-0169, Unit 1, conducted
January
29,
1987,
addressed
radiation
protection,
ALARA, nuclear
and operation's
engineering
in the areas
of radiation protection,
contamination control, housekeeping
and
REPs.
A total of 36 items were examined.
No deficiencies
were
identified.
Monitor Report in the review cycle,
no number assigned,
Unit 1,
conducted
February 13-16,
1987.
A 24 item checklist,
cross-referenced
to procedures,
addressed
Reg.
Guide 8.8
(ALARA)
associated
with steam generator
work.
One unsatisfactory
item was
noted; failure to coordinate air samples with steam generator
jumps
prior to February 10,
1987.
Subsequently,
an air sample
was
collected during each
jump.
Whole body counts
were to be performed
on all individuals performing jumps prior to February
10,
1987.
Trainin
and
uglification
The inspector
observed
the facilities for training steam generator
jumpers.
A mockup was
used which provided for training and
qualification of all jumpers.
Training included
use of protective
clothing and equipment,
tube staking
and plug welding and weld
certification.
External
Ex osure Control
The licensee
reported that beta exposure
was the controlling factor
work due to the high energy Antimony (Sb)-122
and SB-124 beta
component.
The initial beta to gamma
dose rate
ratios observed
were 5. 5 or 6 to 1.
The lens of the eye
was
considered
to be the critical organ
and special
studies
were
performed to identify the required protective clothing and equipment
shielding.
TLDs and
diaphram were used in the
study.
TLDs were exposed to the unscattered
radiation from the
diaphram with various combinations of shielding materials including,
cloth and plastic protective clothing, full face respirators,
bubble
hood,
and glasses.
The milligrams/square
centimeter
(mg/cm~) for
the various materials
was determined,
the dose delivered to a TLD
from the source to the
TLD through various combinations of shielding
materials
was determined
and the results
were plotted,
dose
vs.
shielding.
The licensee
found that beyond
672 mg/cm~
no significant
reduction in dose resulted with increasing shielding.
The licensee
included the 18 mg/cm~ covering
on element
1 of the Panasonic
and the
300 mg/cm~ water content of the eye between
the surface of
the eye
and the crystalline lens of the eye in the determination
(as
represented
by TLD element
2 which provided 300 mg/cm~ filtration).
The licensee
noted that the best
TLD was
a compromise for shallow,
7
mg/cm~,
measurements'(ANSI
13.11-1983Property "ANSI code" (as page type) with input value "ANSI</br></br>13.11-1983" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.)
since the minimum filtration
t+~
P'
13
'n
TLO element
1 was
18 mg/cm2.
The required lens of the eye
shielding was achieved either with glasses
(300 mg/cm2)
and bubble
hood (72 mg/cm2) or for welders
a full face welding respirator.
The.
water layer to the lens of the eye (300 mg/cm2)
was also included
as
a constant part of the shielding.
During the outage,
the licensee's
dosimetry group provided
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />
turn around
TLD data to management
and working groups,
in spite of
the fact that
a computer
based
dose tracking system
was not in use.
Special
dosimetry packets for jumpers
and platform workers were
.
prepared
by the dosimetry group.
Special,
individual dosimetry log
sheets
were prepared
and used for jumpers
and platform workers.
The
licensee
found that the thighs or upper
arms generally received the
highest
exposures
since
much of the work was concentrated
in the
corners of the steam generators.
A listing of personnel
with greater
than 1000
mrem whole body or
'000
mrem skin exposures
(total 64) was provided by the licensee.
Records for 6 randomly selected
individuals were examined.
No
discrepancies
were identified.
Additional aspects
of this inspection procedure will be examined
during a subsequent
inspection
(50-528/87-03-02,
50-529/87-04-01).
No violations or deviations
were identified.
5.
Solid Wastes - Unit 1 (84722)
Audits and
A
raisals
Audit No.86-014,
Process
Control
Pro
ram (Radioactive
Waste
Mana ement
, dated April 7-24,
1986,
was reviewed
and discussed
in
Inspection
Report
No. 50-528/86-13.
No other licensee
audits in
this area
had been conducted.
Quality Monitoring Report SM-87-0323,
of February 11-20,
1987,
documented
a licensee
review of the
contractor provided bitumen solidification activity.
The report
addressed
contractor
conformance to ANPP controlled documents
and
Quality Control
(QC) check points,
Process
Control
Program
(PCP)
adherence,
and compliance with 10 CFR 61.55
and 61.56
and IE
Two licensee
documentation
related
and
one
QC program related discrepancies
were identified.
Proposed
corrective actions
and planned but uncompleted
followup
verifications were identified.
~Chan
ea
The licensee
stated that
no significant changes
had been
made in the
installed system.
Contracts exist with two contractors,
one
providing onsite dewatering
and solidification of liquids and
evaporator
concentrates
in bitumen
and the other providing both
cement solidification or dewatering of resins.
Both vendors
use
mobile systems.
The bitumen system provides
a 5.6/1 volume
reduction
compared to cement solidification of evaporator
bottoms.
Resin dewatering provides
a 2/1 volume reduction over cement
14
solidification.
The cement solidification process
uses
the approved
site
PCP.
Proposed
changes
to include Envirostone
had been
submitted to the Plant Review Board
(PRB) in December
1986;
however,
the revised
had not yet been
approved.
The vendor supplied
bitumen solidification
and
a 10 CFR 50.59 were reviewed
and
approved
by the licensee.
The vendor staff operates
the bitumen
solidification system.
The operators
meet
ANPP qualification
standards
and ANSI-3. 1 requirements.
Processin
and Stora
e
Compacted
dry radioactive waste
was stored inside the
Radwaste
Building and larger containers
were stored in a fenced,
posted
area
inside the protected
area.
The licensee
stated that
an onsite waste
storage facility was being constructed with completion expected
in
November 1987.
The facility was to be used for the storage of low
level dry active waste.
The licensee
plans to ship all higher level
waste for disposal.
The licensee's
Semiannual
Radioactive Effluent
Release
Reports for the last half of 1985 and all of 1986 were
reviewed.
The monthly Radwaste
Group reports for 1986 and early
1987 were examined.
. A December
5, 1986,
memo to "All Radioactive
Materials Control Employees,"
stated
the licensee's
radwaste
corporate
goals for 1987 were
as follow:
Unit 1,
397 Ms, Unit 2,
397
Ms and Unit 3, 42.5
Ms.
The licensee's
representative
stated
that waste site allocations to the middle of 1988
had been
used.
A
short fall of disposal
capacity of 40,000
fthm by 1991 was projected,
including volume reductions
expected
due to the
use of bitumen
solidification and
a super compactor.
Dis osal of Low-Level Waste
Licensee
procedures
required to implement the requirements
of 10 CFR 61.55
and 61.56
and
10 CFR 20.311 were examined
and documented
in
Inspection
Report
No. 50-528/86-36.
No violations or deviations
were identified.
6.
Li uids
and Li uid Wastes
Unit 1 (84723)
Audits and
A
raisals
No audits in the area of liquid wastes
were identified.
A total of
129 monitoring reports
were generated
by the
ANPP equality Audits and
Monitoring Department in the areas of chemistry
and radiation
protection during 1986.
A random
sample of 25 monitoring reports of
surveillance tests for Unit 1 were examined.
Of the total,, 2 were
related to the liquid waste
system.
Monitor report numbers
ST86-0527,
Chemical
Waste Neutralization Tank Surveillance Test,
and
ST86-1122,
Li uid Holdu
Tank Surveillance Test,
addressed
conformance with surveillance test requirements.
Report
number
ST86-0527
was identified as unsatisfactory
because
of an
administrative
problem which was subsequently
resolved.
15
~Chan
ea
The licensee
stated that
no changes
had been
made in the liquid
radwaste
system
(LRS).
Distillate from the
LRS evaporator
was
transferred
to the refueling,
makeup or CVCS holdup tanks.
From the
CVCS holdup tank, liquid could be transferred to the boric acid
evaporator.
Steam,
discharged
from the boric acid evaporator,
could
be discharged
to the Radwaste
Building vent to dispose of tritiated
water.
During 1986,
1.212EG gallons of water were disposed
in this
fashion at Unit 1. It was reported that this volume of water
represented
only 1/15 of the potential
maximum capacity of this
disposal
mode.
During 1986, the licensee identified a dead leg at
the base of the plant vent.
Mater which had accumulated
was drained
and collected.
Analysis of the water established
that it was not
contaminated.
The licensee
stated that construction of a second
evaporation
pond will st'art shortly.
A new training program for radwaste
personnel
was being developed
in
preparation for INPO accreditation.
The radwaste
and training
staffs coordinated in the development of the program.
Effluents
Technical Specification,
Section
3. 11. 1. 1, limits discharges
from
the secondary
system to the evaporation
pond to the lower limit of
'etectability (LLD) defined
as
5 x 10-7 microcuries per milliliter
(pCi/ml) for the principal
gamma emitters or 1 x 10-6 pCi/ml for
The licensee
imposed
a limit on tritium discharges
to the
evaporation
pond equal to the
EPA drinking water standard.
Since
the Technical Specifications
were silent with respect to tritium and
noble
gas releases
to the evaporation
pond, the licensee
was
considering requesting
an amendment to the Technical Specification
clarifying this matter.
Evaporation
pond tritium concentrations
and
losses
due to evaporation
and the dose calculations
associated
with
this
mode of release
were tracked
by the licensee's
corporate office
staff.
Data generated
by the corporate office was provided to the
site staff for inclusion in the Semiannual
Radioactive Effluent
Release
Reports.
The corporate office program for accounting for
tritium released
due to evaporation
and calculation of doses
was not
examined.
These matters will be examined during a subsequent
inspection
(50-528/87-03-01).
The Semiannual
Radioactive Effluent
Release
Reports for July-December
1985 and all of 1986 were
examined.
The licensee
reported that
no liquid radioactive
materials
were discharged
from the site.
Instrumentation
The facility had
no liquid effluent monitors.
The liquid process
monitors were not specifically identified in the Technical
Specifications.
Such monitors were entered in the Preventive
Maintenance
schedule
and calibrated
and maintained in accordance
with that schedule.
No records of calibration or testing of these
monitors were examined during this inspection.
16
Reactor Coolant and Secondar
Mater
Chemistry limits for the primary system
were specified in Technical
Specification,
Table 3.4-2,
and surveillance
requirements
in Table
4.4-3.
Primary system activity limits were specified in Technical Specification, Section 3.4.7.
Based
on an examination of licensee
records
primary system chemical
and radiochemical
conditions
met the
Technical Specification limits.
Limitations on discharges
from the
secondary
system to the evaporation
ponds will be examined during a
subsequent
inspection
(50-528/87-03-01).
No violations or deviations
were identified.
7.
Gaseous
Maste
S stem - Unit 1
84724)
Audits and
A
raisals
No audits of the gaseous
waste
system operation
had
been
completed.
Randomly selected
surveillance test monitoring reports
prepared
by
ANPP equality Audits and Monitoring Department related to the gaseous
waste
system
were examined.
Maste
Gas
Deca
Tank Curie Content
Monitorin
Re ort No.
Date
January
15,
1986
January
16,
1986
February
15,
1986
March 14,
1986
~Findin
s
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Effluent Monitor Dail
Surveillance Test
Monitorin
Re ort No.
Date
January
24,
1986
January
29,
1986
January
30,
1986
January
30,
1986
February
5,
1986
April 4,
1986
April ll, 1986
June 9,
1986
September
5,
1986
Findin<is
Unsatisfactory
Unsatisfactory
Unsatisfactory
Unsatisfactory
Satisfactory
Satisfactory
Satisfactory
Satisfactory
Satisfactory
The four unsatisfactory
findings were related to problems in
documentation.
The problems
were corrected.
~Chan
es
The licensee
stated that the only changes
consisted of the addition
of some drain lines and collection pots to the hydrogen-oxygen
analyzer
and waste
gas
compressor
systems.
It was reported that in
spite of the additions
some water was still observed in the
hydrogen-oxygen
analyzer lines when the gas stripper was operated.
17
Effluents
The licensee's
Semiannual
Radioactive Effluent Release
Reports for
the second half of 1985 and all of 1986 were examined.
No obvious
mistakes
or anomalous
measurements
were identified.
The trends in
fission and activation gases,
particulates
with half-life values
greater
than 8 days
and iodines were reflective of the operating
status of the reactor.
The tritium released
following fourth
quarter
1985
has
shown
a continuing upward trend reflective of both
increasing tritium concentrations
and the licensee's
practice
of.
disposing of steam
from the boric acid evaporator to the Radwaste
Building ventilation system.
Procedure
Revision.4,
Gaseous
Radioactive
Release
Permits
and Offsite Dose Assessment,
was
used to generate
gaseous
release
permits.
The permits were numbered in serial
fashion
without regard to the source of the gaseous
release.
Gaseous
release
permits were retained
by the Radiation Protection Effluents
Group for approximately six months prior. to transfer to permanent
storage.
Selected
reports prepared for releases
from the Fuel
Building, condenser off gas, plant vent,
NSCP (nonstandard
containment purge-pressure
relief) and waste
gas
decay tanks during
the period July 1 through
November 25,
1986,
were examined.
The
release
permit packages
were legible, complete
and included the
results of beta-gamma air dose,
organ
dose
and whole body, skin and
organ
dose rate calculations.
The inspector
calculated
the total
gamma
and beta air doses for
Release
Permit 861224,
waste
gas
decay tank, using
ODCM, Revision 1,
September
20,
1985.
No discrepancies
were identified.
No concerns
in the use
or maintenance
of the gaseous
or particulate
process
systems
were noted.
On January
17, 1987,
tube failure occurred.
The
event was documented
in a memorandum to file dated January
20, 1987,
"Gaseous
Effluent Release
Associated with ¹1 S/G Tube
Leak in Unit
1," File 87-004-419.5.
The memorandum provided
a sequence
of events
for the period 1715 hours0.0198 days <br />0.476 hours <br />0.00284 weeks <br />6.525575e-4 months <br />
on January
17,
1987, through
0918 hours0.0106 days <br />0.255 hours <br />0.00152 weeks <br />3.49299e-4 months <br />
on
January
20, 1987.
Two effluent release
reports
871013
and 871014
were generated
to account for the initial release
and dose
and dose
rate data.
The total
gamma,
beta
and organ
doses attributed to the
early portion of the event,
3.43E-3,
2. 14E-3 and 3.38E-5
mrem
respectively,
were small fractions of the Technical specification
quarterly limit.
Two additional
release
permits were generated,
871019
and 871026, to account for releases
resulting from condenser
flushing activities.
The doses attributable to these additional
releases
were
a small fraction of those calculated for the initial
rel ease.
For the period July 1985, through
December
1986, effluents were
within Appendix I, 10 CFR 50 design objectives
and were, therefore,
0
18
Instrumentation
Technical Specification, Section 3.3.3.9, identifies gaseous
effluent monitors
and in Table 4.3-8 specifies
the frequency for the
performance of channel
checks,
source
checks,
channel calibrations
and channel
functional tests.
Surveillance test procedures
specific
to the monitors
had been prepared,
were implemented
and m'aintained.
The surveillance tests
applicable to channel calibrations
and
functional tests
were performed
by the
18C Radiation Monitoring
System
(RMS) maintenance
engineering staff.
The surveillance tests
applicable to channel
and source
checks
were performed
by a Unit 1
shift radiation protection technician.
Records
showing the
completion of channel
calibrations
and functional tests for monitors
RU-12, 141, 142,
143,
144,
145 and 146 were examined for 1986.
No
discrepancies
were identified.
The performance of channel
and
source
check surveillance tests
were discussed
with a duty radiation
protection technician.
Records of recently performed
channel
and
source
checks
were examined.
No discrepancies
were identified.
When the applicable surveillance tests
have
been completed,
reviewed
and approved,
the complete surveillance test packages
were submitted
to the licensee's
Corporate
Document Management
(CDM) group for
archival storage.
Air Cleanin
S stems
The licensee
had established
an onsite capability for the
performance of tests of air cleaning
systems including'n place
testing of HEPA filters and charcoal
absorbers
which 'is addressed
in
report Section
2 (50-530/86-16-05).
The licensee
had adopted
=a
system designation
coding for HVAC systems:
For Technical Specification identified systems
the coding was:
HJ - Control
Room Essential
Ventilation System
HF - Fuel Building Essential
Ventilation System
Surveillance tests for these
systems
were designated:
73 ST-9 (System
Coding Designation)
(numerical
designation
of the specific test).
For the systems
not identified in the Technical Specifications",
the system coding was:
'R - Condenser Air Removal
,CP - Containment
Purge
HC - Containment Filtration
HA - Auxiliary Building Normal Ventilation
HR - Radwaste
Building
P%
19
HS - Unit 1 Laundry Facility Ventilation
HN -
EOF and
TSC (considered part of Unit 1).
Testing of these
systems
was performed using Generic Test
Instructions.
The tests
on the essential
systems
included:
HJ or HFOl, Buildin
Pressure
and Airflow
Verification Test
HJ or
HF02,
HEPA In- lace Test
HJ or HF03, Charcoal
In- lace Test
HJ or HF04, "A" Train Charcoal
Laborator
Anal sis
HJ or HF05, "B" Train Charcoal
Laborator
Anal sis
For the
HP System the tests
included:
73ST-9 ZZ14,
S stem Performance
Test
and Airflow
Verification
(includes
HEPA and Charcoal)
73ST-9 ZZ15, Heater
Performance
Test
I
73ST-9 HPOl, Charcoal
Laborator
Anal sis
The Test Instructions (TI) provide the
same
scope of coverage for
the non-Technical
Specification
systems.
With respect to Unit 1,
the only required tests at the time of the inspection,
were the
charcoal
laboratory analysis
on the
HF,
HJ and
HP systems.
The
inspector verified that the tests
were performed.
In addition, the
inspector
reviewed the licensee's
schedule for performing
Surveillance
Tests
and Test Instructions
on the various
systems.
No violations or deviations
were identfied.
8.
ualit
Assurance
and Confirmator
Measurements
for In-Plant
Radiochemical
Anal sis - Units 1 and
2 (84725)
Audits and
A
raisals
equality Assurance
Audit Report
Audit No.86-013,
"PVNGS Plant
Chemistry," conducted
May 5-23,
1986, applicable to Units 1 and 2,
was reviewed.
The audit addressed:
Laboratory Analytical Control
Program
II
I
20
Secondary
Water Chemistry
Training and qualifications
Corrective Actions for LERs
Interface
Requirements
between
Chemistry,
Operations
and
Radiation Protection
Primary Chemistry (Technical Specifications,
Sections 3/4.4.6
and 3/4.4.7)
Laboratory
and Warehouse
Control of Chemicals
and Reagents
The audit appeared
to be both thorough
and extensive,
including
examination of multiple examples
under
each topic.
Three findings were identified, documented
in Corrective Action
Requests
(CAR) and subsequently
closed.
The
CARs addressed
the
following topics:
CA86-0097,
Hydrazine not meeting the bulk chemical
specifications
was accepted;
CA86-0100,
Two signatures
on a Chemistry Technician
qualification card were not dated;
and
CA86-0101,
Chemistry personnel
failed to follow procedures
when tr ansferring
hydrazine.
The audit also resulted in the issuance
of six Monitoring Report
findings.
It was verified that corrective action
on five of the
items
had been
completed at the time of the inspection.
The sixth
item related to "Enclosed or Confined Space Entry," training for
chemistry technicians.
Action had been taken to revise the
technician training program;
however,
the item had not been closed
by equality Audits.
~Chan
ea
No significant changes
in the laboratory facilities were identified.
The licensee
had established
a laboratory,
equipped
as the Unit
laboratories,
for training purposes.
Confirmator
Measurement
Evaluation
documented
in Inspection
Report Nos.
50-528/87-04
and
50-529/87-05.
Post Accident
Sam le Anal sis
Three surveillance test procedures
were applicable to
PASS:
L
21
74ST-(U.D.")SS02,
Post Accident
Sam lin
S stem
Leaka
e Monitorin
(18-month frequency;
"(U.D.) - Unit designation,
e.g.
1 or 2
Backu
Post Accident
Sam lin
S stem Surveillance (Unit
1, 18-month frequency)
Post Accident
Sam lin
S stem Surveillance (Unit 2,
1 -mont
requency
Backu
PASS Functional Test (Unit 1, monthly frequency)
PASS Functional Test (Unit 2, monthly frequency)
The 18-month frequency
PASS sampling
system surveillance called for
analysis of a complete
range of samples.
The monthly surveillance
required only boron, isotopic analysis,
dissolved
gas,
containment
and oxygen
and isotopic.
Unit specific
PASS procedures
were
used
because
the Unit 1 and
2
PASS systems
were different and
also
because
certain
components
in the individual
PASS systems
differ in important parameters
(e. g. volume).
Procedure
Post Accident Radioactive
Sam lin
Anal sis
~Hd i,
dd
d
y
q, p>>
g
d
transportation
guidance.
The licensee
reported
good correlation
with routine samples for boron.
Correlation for dissolved
gas
was
not as
good due to the sample size
(40 cc) and the error of +
llcc/kg.
The Unit 1 PASS was
an interim system
scheduled
to be
replaced with a full scale
system
comparable
to that installed in
Unit 3.
The samples
collected for the monthly surveillance
vary
between Units 1 and 2:
Unit 1
Depressurized
Liquid RCS
Pressurized
Liquid (Gas)
Unit 2
Same
Same
Let down sample
depressurized
Let down sample
pressurized
(gas)
Containment
Atmosphere
Safety Injection Train "A"
Same
Same
Safety Injection Train
I I B
II
Auxiliary Building
Radwaste
During a tour of the Unit 1 chemistry laboratory,
the inspector
observed
two technicians
performing portions of the monthly
surveillance test,
gas analysis.
22
Im lementation of the
ualit
Assurance
Pro
ram
The licensee
had established
and was implementing
a laboratory
analytical control program.
The procedures
applicable to the
program included:
S ecifications for Bulk Chemicals
74AC-9ZZOl; Laborator
Anal tical Control - defined the
Laboratory Analytical Control
program (provided
a
systematic
approach
to analytical control to assure valid
analytical results,
made
no distinction between
Technical
Specification required analyses
and any other analysis
performed
by the chemistry section).
Labor ator
0 erations
Anal tical Control
Sam les (described
the type of
analytical control samples,
addressed
standards,
spiked
samples,
duplicates,
replicates,
blind samples,
sample
schedules
developed
by Unit laboratories).
Anal tical Control Chart Develo ment
Anal tical Instrument Calibration Verification
Rea ent Pre aration
Sam lin
Instructions
Sam lin
and Anal tical Schedule
(applicable to
safety-related
and nonsafety-related
systems).
The
LAC program was
implemented
by the Chemistry Support
Group
(CSG), consisting of one supervisor,
five engineers
and four
technicians
and nine contractor personnel
(two
CE engineers
and
seven technicians).
The
CSG had responsibility for the circulating
water
and spray pond systems,
ordering
and receiving (certification
verification) bulk chemicals,
escorting
chemical delivery trucks
and
the
LAC.
A Ph.D., Nuclear Chemistry Process
Engineer administers,
coordinates
and monitors the
LAC program.
The
LAC program includes
controls
and verifications
on balances,
instrumentation
and
analytical techniques.
Control charts
were maintained,
where applicable, principally by the
Unit chemistry staff.
The
LAC program includes both
knowns
and
unknowns,
spikes,
duplicates
and replicate
samples.
The sources
of
samples
used include:
NMT Corporation - supplied blind samples,
distributed to the
Units by and analytical results
reported to
NMT by the
CSG.
NMT provides
a report of the result of comparison to the
licensee.
This program supports
the
INPO Good Practice,
P
1
23
0
CY-702, "Verification of Analytical Performance,"
May 1983.
Analytics Inc. - supplies quarterly radiochemical
samples
including gamma,
gross
beta,
tritium (with interferences)
and iodine cartridges.
NUS Operating
Systems
Corporation
supplies,
quarterly,
concentrated
chemical
standards
which were diluted by the
CSG.
~
The analytical results
were scored
by the
CSG.
ERA (Environmental
Resource
Associates)
- provides
samples of
the
same type as
NUS, but with an environmental
orientation.
Arizona Association of Certified Laboratories -'ample drinking
water standards
provided to the site and certified laboratories
in Arizona.
The
LAC program requires daily verification of calibration or use of
control standards
on the following instruments
or equipment:
Balance
Spectrophotometer
Ion Chromatograph
Specific Ion Electrodes
Titration
Atomic Absorption Spectrophotometer
Total Organic Carbon
Gas Chromatograph
Turbidimeter
pH Meter
The licensee
had
made several
revisions to procedure
S stem Chemistr
S ecifications,
in that the specifications
were
initially too conservative.
In addition, revision of the
QA-QC
procedures
were planned,
in an attempt to reduce activities which
did not produce either significant information or enhanced
QA-QC.
Chemistry management
estimated that 20-25K of the Unit laboratory
time was spent
on QA-QC.
The goal
was
a less costly and more
productive program.
No violations or deviations
were identified.
9.
Control of Radioactive Materials
and Contamination
Surve
s and
Monitorin - Unit 3
83526
Area Radiation
and Airborne Radioactivit
Monitors
Monitor calibrations
were addressed
either
by Surveillance Test (ST)
procedures
for Technical Specification identified monitors or
preventive maintenance
(PM) procedures
for other monitors.
The
procedures
were contained in the Station Information Management
System
(SIMS).
The
and
PMs have essentially
the
same format and
content;
however,
they were not identical since
some Technical
24
Specification monitors
have specific functions which the other
monitors lack.
Alarm points (alert and high) were set by radiation
protection.
On completion of maintenance
or calibration,
alarm
setpoints
were set at lower values until reset in the computer
by
the radiation protection staff.
Each Unit maintained
an alarm
setpoint
logbook which was
used to update setpoints if the computer
contained setpoints
were lost and the default (more restrictive)
values
remained.
Setpoints
were controlled by station procedure,
Revision 2, Radiation Monitor Set oint Determination.
The procedure
addressed
a
1 monitors
and sdentsfsed
specif)c
Technical Specification monitors, limits and setpoints.
Por table Surve
Sam
1 in
and Contamination Monitorin
Instruments
The inspector
examined the instruments
available to the radiation
protection staff at Unit 3.
The licensee's
representative
commented
that not all of the instruments
to be stocked in the Unit had been
received
from the onsite calibration facility at that time.
The
inventory included:
22
3
3
12
4.
3
4
3
RM-20, Radiation monitor,
GM
Ludlum Model
3
GM survey meters
Extendable
probe high range
survey meters
Staplex type, high volume air samplers
R0-2,
Ion chamber,
survey meter
PIC-G, Ion chamber,
survey meter
PNR-4, Neutron monitors
FAG, multipurpose
GM,survey meters
AMS-3, Beta-Gamma Air Particulate Monitoring System
Gas air samplers
Instruments
in use in the Fuel Building during fuel receipt were
a
SAM-2, stabilized
assay
meter;
BC-4, beta counter;
and
a SAC-4,
alpha counter.
The licensee
had installed two PCM-lA, high
sensitivity, half body,
gas flow proportional, frisking booths at
the access
control point.
The inspector verified that emergency
kits contained
instruments
an'd dosimeters
consistent with the
published inventory.
The instrument calibrations
were current.
The
licensee
had
a fully equipped
and staffed portable instrument
calibration
and repair facility adjacent to Unit 1.
Protective Clothin
and
E ui ment
Adequate
supplies of appropriate
types of protective clothing and
equipment were available for normal
and emergency
operations.
Procedure
Radiation Protection
Pro ram,
addressed
the
use of protective clothing and equipment.
Proper
use of protective clothing arid equipment
was addressed
in the
Radiolo ical Work Practices training required for entry into
radiologically controlled access
areas.
Y
1
25
Radioactive Material
and Contamination
Control
The licensee
had developed,
implemented
and maintained
procedures
in
Units 1 and 2, applicable to Unit 3 addressing
control of
radioactive material
and contamination control.
These
procedures
included:'5PR-OZZOl,
Radiation Protection
Pro
ram
a watson
x osure
an
ccess
Control
Radsoactsve
Contamsnatlon
Contro
Shi ment
Recei t and Stora
e of Radioactive
75AC"9ZZ12,
Materials
Radiolo ical Controls
Problem
Re orts
Control of a Contaminated
'Clean
S stem
Decontamination
The procedures
established
personnel,
area
and equipment
contamination limits and decontamination
methods.
The procedures
provided for skin beta
dose estimates
at skin contamination levels
of 20,000 counts per minute (cpm).
The instrument type to be used
for contamination
measurements
was specified.
Evaluation
by the
Unit Radiation Protection Supervisor
was required if the calculated
skin dose
exceeded
375
mr ads
(5%%uo of the allowable quarterly
exposure).
A licensee
representative
stated that all personnel
contamination
occurrences
were evaluated
by the Radiation Protection
Support Supervisor.
In-Plant Surve
s and Monitorin
Procedures
inclu'de:
Radiolo ical Surve
Schedule,
which addressed
routine air, radiation
and contamination
surveys,
assigned
responsibility to the Unit Radiation Protection
Supervisor
and
specified that high radiation area
surveys
are to be performed
on an as-needed
basis,
rather than routine.
Radiolo ical Surve s,
addressed
the methods
and
'nstrument
types to be used, calibration and performance
testing of instruments,
review of previous survey results,
beta
surveys
and documentation
of results.
Procedure
Airborne Radioactivit
Sam lin ,
addressed
particulate,
iodine, noble
gas
and tritium sampling,
equipment calibration and specified
a maximum flow of 4
CFM for
iodine sampling.
The procedures
to be used at Unit 3 had been in use at Units 1 and
2
and had been revised
based
on previous operating experience.
No violations or deviations
were identified.
26
10.
Maintainin
Occu ational
Ex osures
ALARA - Unit 3 (83528
Mana ement Polic
The
ANPP policy addressing
ALARA was
documented
in Policy No.
4P411.00.00,
Revision 2, Health
Ph sics
Radiolo ical Protection
~dph
d
.
Yh pl'Y
d
p
h
p
and program
and required support of the
ALARA program by all
departments.
Assi
nment of Res onsibilities
and Authorities
The
ANPP Policy and Procedures
manual,
Procedure
No. 4N411.05.00,
Revision 1,
ALARA Pro
ram Descri tion, assigned
individual
responsibilities
to all workers,
documented
ALARA responsibilities
from the Executive Vice Presidential
level to all levels of the
organization
and specified
ALARA organizational
structure,
authorities
and responsibilities.
Procedures
and Standards
Procedures
had been developed,
implemented,
maintained
and
demonstrated
effective in the startup
and operation of Units 1 and
2.
The procedures
implementing the
ALARA program were reviewed:
Revision 1,
ALARA Pre 'ob Review
Revision 2,
ALARA Ins ections
Revision 2,
Ex osure Trackin
(ALARA)
Revision 2,
ALARA Post
ob Review
Revision 0,
Pre aration of ALARA Re orts
Revision 1,
ALARA Desi
n Review
ALARA Benefit/Cost Evaluation
Indoctrination and Instruction
The Radiological
Mork Practices training, required for all workers
entering radiologically controlled areas,
incorporated
an overview
of the
ALARA concept
and program.
Specific
ALARA training programs
had been
developed
and presented
to site
and corporate
engineering
and supervisory personnel.
Approximately 30K of the engineers
and
50-60K of the supervisors
had completed the training.
An ALARA for
operators
class
had
been presented
to groups of 6 auxiliary
operators,
6 to 7 times.
Specialized training on steam generator
mockups in the
use of the multistud tensioner in manway removal
and
installation (reduces
manway removal time to one hour)
and the
use
of the reactor vessel
head multistud tensioner
had been developed
and presented.
An awards
program,
"Idea Line-ALARA," was being
established
to acknowledge
new ALARA ideas
and techniques.
Posters
d
'
'
27
promoting
ALARA were being prepared.
One of the regular "equality
Talks-Safety Speaks,"
presentations
had addressed
Prejob
briefings of mechanics
manway removal,
incorporated
review of a video tape of an earlier
manway removal.
The mechanics
identified methods to improve the removal procedure
as
a result of the viewing.
Reviews of Desi
n and
E ui ment Selection
The
ALARA staff had completed the Unit 3 walkdown.
Problems
identified were addressed
on Engineering Evaluation
Requests
(EER)
or Plant
Change
Request,
depending
on the significance of the
findings.
The licensee's
equipment reliability group evaluations
of
frequency of repair data
and operations
engineering
feedback
on
operating
equipment were available to the
ALARA group.
The
organization
was part of the Change Control Group and must sign off
on preliminary and final designs
and installation if potential
significant exposure
could occur during installation.
The corporate
ALARA function was incorporated in the corporate
health physics/radiation
protection organization.
The corporate
staff audits the site
ALARA group and works with the corporate
engineering staff on the design
phase of long term projects.
The
site
ALARA staff retains
primary preliminary and final design review
responsibility.
No violations or deviations
were identified.
ll.
ualit
Assurance
and Confirmator
Measurements
for In-Plant
Radiochemical
Anal sis - Unit 3
84525
Facilities
E ui ment and
Su
lies
The chemistry cold and hot laboratory facilities layout, equipment
and supplies
have
been
addressed
in Inspection
Report
Nos.
50-530/86-16
(Section 10), 86-30 (Section 3),
and 87-05 (Section 2).
Procedures
The licensee
had developed,
implemented
and maintained
normal
and
emergency
operating
procedures
for Units 1 and 2.
The procedures
were extensive in scope
and content
and were generally applicable to
all three Units.
The procedures
address
laboratory operations
(75AC-9ZZ02), bulk chemical specifications
(74AC-OZZOl), analytical
control
(74AC-9ZZOl), systems
chemistry specifications
and the sampling
and analytical
schedule
(74CH-9XC16).
In addition,
numerous
procedures
address
specific analyses,
instrument operation,
maintenance
and calibration activities,
system operating activities
and surveillance tests.
The procedures
in effect'at the time of the
inspection
had been previously used
and verified during Unit 1 and
2
operations.
~ M
28
Confirmator
Measurements
Evaluation
documented
in Inspection
Report
No. 50-530/87-05.
Post Accident
Sam le Anal sis
The Unit 3
PASS preoperational
tests,
PASS Performance
Test for Unit 3, was starting at the time of the inspection.
Unit
PPd'
kg
i i,
i11
ig
d
functional testing will be developed
in conjunction with or after
the preoperational
testing phase is completed.
Procedure
74CH-
9XC33, Post Accident Radioactive
Sam lin
Anal sis
and Handlin
,
provided detailed handling and transportation
precautions
for PASS
samples.
The results of the
PASS preoperational
testing
and the
PASS procedures
for Unit 3 will be examined during a subsequent
inspection
(50-530/87-04-03).
ualit
Assurance
A Pro
ram
The Laboratory Analytical Control
(LAC) program, previously
implemented at Units
1 and
2 will be implemented at Unit 3.
The
Unit 1 and
2
LAC program is discussed
in report Section 8.
No violations or deviations
were identified;
12.
Trans ortation Incident - Unit 1 (86721
On January
30,
1986, the
NRC Region
V office received
a memorandum
from
the
NRC Region III office, describing
a potential violation of 49
CFR
173.425(b)(l) in regard to the shipment of a mobile radioactive waste
solidification Unit (WSU) from Palo Verde to Clinton Power Station,
Clinton, Illinois.
a ~
Details of Incident (Shi ment
No. 86-SH-034
Based
on documents
provided by the Region III office, onsite records
review and discussions
with licensee's
representatives;
and
subsequent
telephone
conversations
with the Region III office,
a
representative
of Associated
Technologies,
Inc. (ATI), a
representative
of Clinton Power Station
and
a member of the NRC's
I&E staff in headquarters,
the following observations
were made:
'I
(1)
The
WSU was operated
by ATI under
NRC Materials
License
No.
32-23067-01
(NRC Region II), Charlotte,
had been operating the
WSU at the licensee's
(Palo Verde)
facility for several
months prior to shipment
on October 7,
1986.
In August 1986, while operating the
WSU at the
licensee's facility, a flush valve failed that resulted in
overflowing the WSU's catch
sump from Palo Verde's
concento aie
monitor tank.
(2)
On October 7, 1986, the licensee,
via exclusive
use,
shipped
the
WSU to Clinton Station.
The shipment consisted of residual
contamination in and
on the processing
equipment.
According to
k
29
n
the licensee's
records,
and through discussions
with licensee's
representatives
and
an ATI representative
(onsite),
the system
had been properly drained
and penetrations
flanged.
The
licensee
estimated that 0.124 millicuries of LSA material
was
being transported within the mobile unit, also considered
as
the transport
package.
The licensee's
survey records
showed that radiation levels
on
the package
surface
were minimal and
no loose surface
contamination
was detected
on the day of shipment.
On October 15, 1987, the shipment
(MSU) arrived at Clinton
Station.
An initial receipt survey of the shipping package at
1:00 p.m.
on October 15, 1986,
confirmed that radiation levels
were minimal and
no loose surface
contamination
could be
detected.
However, Clinton representatives
did note
some
apparent
physical
damage
(loose and/or missing bolts and
rivets, cracked side panel
sheets
and
a bent left rear wheel
on
the trailer).
The damage
area
was primarily localized to the
rear of the trailer,
on each side,
and next to the MSU's
processing
area.
Clinton Station personnel
also noted that on
the right side of the unit, at the
damaged
area,
there
was
an
appearance
that
some
leakage
had occurred;
however
as before
no
loose contamination
was detected.
After the initial receipt survey,
the
MSU was
moved and parked
on an incline at the Clinton Station facility, outside of the
controlled area.
At about 1:30 p.m.
on October
15, 1986, after
being parked
on an incline, Clinton Station representatives
observed liquid leaking from the
MSU (also the shipping
package)
at the
damaged
areas.
Based
on
a telephone
conversation with a Clinton Station representative
on March 18,
1987,
review of Clinton's survey data
and Region III Inspection
Report
No.
50-461/86068(DRSS), it was noted that:
2400 disintegrations
per minute
(dpm) of loose
contamination
was detected
at
a bolt hole,
an area of less
than
100
cm~.
1000 to 1200 dpm/100cm
from about
900
cm
area
on each
side of the unit.
About one pint of liquid leaked from the unit, with sample
analysis indicating cesium-137 activity of 2E-6 pCi/cc.
Direct scan
surveys of the tractor/trailer route from
Clinton's northgate to the receiving area indicated less
than
1000 dpm/probe
area (thin window pancake detector).
Surveys of the asphalt
where the liquid had leaked, after
the
MSU was
moved into the protected
area,
less
than 1000
dpm/probe
area
by direct scans
and less
than 1000 dpm/100
cm~ on wipes.
h
30
(4)
During a telephone
conversation with an ATI representative
(Manager,
Design Engineering)
on March 4, 1987,
who was also at
Clinton Station
when the
WSU arrived, the inspector
was
informed that the apparent
damage,
excluding the bent wheel,
had occurred
due to strains
and flexing during normal
highway
travel.
The damage to the wheel occurred at
a weigh station in
route to Clinton Station.
The
WSU is on
a 10 ft wide trailer
which is too wide for most weigh stations.
The ATI
representative
also stated that the problem at the weigh
station only resulted
in a bent wheel
and
some reflectors being
knocked off.
The damage at the weigh station
was not the cause
of the broken bolts,
loose rivets and parting at the seams,
where the leakage
occurred.
The inspector
was also informed
that, when the side panels of the
WSU were subsequently
removed
at Clinton Station, liquid was found trapped in the space
between
the panel wall and the process
area catch basin walls.
According to the ATI representative,
the overflow from the
flush valve failure in August 1986, resulted in entrapment of
liquid in this area.
It was the ATI representative
s opinion
that the liquid was not from intrusion of rainwater during
transport.
The inspector
was also informed of improvements
made in sealing of the catch basin
and outside wall panels,
and
other modifications to strengthen
the
WSU in order to minimize
flexing and strains
encountered
during transport.
This
information was also
documented
in a memorandum
dated
December
29,
1986,
from R. Ferrar,
ATI, to D. Sykes, Illinois Power
Co.
(5)
49
CFR 173.425,
"Transport requirements
for low specific (LSA)
radioactive materials,"
requires in part (b)(1), that materials
must be packaged
in strong, tight packages
so that there will
be
no leakage of radioactive material
under conditions normally
incident to transportation.
Based
on all of the above observations,
either from entrapment of
radioactive liquid from the August 1986 overflow or intrusion from
rainwater during transport,
leakage
did occur from the transport
package
(WSU) under conditions normally incident to transportation.
- Regardless
of the fact that the low levels of loose surface contamination
and low
concentration
of the leaking liquid, the fact that leakage
occurred
negated
the
WSU as
a strong, tight package
in this particular case.
Since Palo Verde acted
as the shipper in this case,
the licensee's
failure to provide
a strong, tight package for shipment of LSA material
was identified as
an apparent violation of 49
CFR 173.425(b)(1),
(50-528/87-03-03).
It should also
be noted that
had ATI acted
as the shipper, this matter
would have
been referred to the
NRC Region II office for enforcement
considerations.
49
CFR 173.443 states,
in part, that for packages
transported
as
exclusive
use shipments,
the removable radioactive contamination
on any
package
at any time during transport shall not exceed ten times the
levels prescribed
in paragraph
(a) of this section
(2200 dpm/100
cm~ for
beta-gamma
emitting radionuclides).
The contamination levels identified
C
I
31
at Clinton Station did not exceed this limit. It can
be safely assumed
that any leakage that may have occurred in route to Clinton Station would
not represent
a hazard to the general public, based
on the sample
analysis of the leaking liquid at Clinton Station which indicated
a very
low level of activity (2E-6 pCi/cc of cesium-137).
One apparent violation was identified in this area.
Exit Interview
The scope
and findings of the inspection
were discussed
with the
individuals denoted in report section
one.
The licensee's
representatives
were informed that
no violations or deviations
had been
identified.
The licensee
was informed that one matter relating to the
ATI transportation
incident did hold the potential for a violation and
that if a violation was identified, the licensee
would be informed by
telephone.
Mr. T. Shriver of the licensee's
staff was informed by
telephone
on April 2,
1987 that
a violation had been identified with
respect to the ATI matter.
Because of the extended
length of the inspection,
two exit interviews
were held as noted in report section
one.
The licensee's
staff was informed that two areas
of possible licensing
concern
had been
addressed.
The first matter related to the availability of carbon reactor
coolant
pump bearings
and the possibility that the antimony-carbon
bearings
in
Unit 3 might be replaced prior to initial criticality.
This matter
was
discussed
with representatives
of NRR who stated that they would discuss
ANPP's plans in this regard with ANPP licensing.
The second matter was related to the concerns
identified with respect to
the
HVAC systems of all units.
This matter concerned
the apparent
potential for migration of airborne activity from the lower elevations
of
the Auxiliary Building to the 140 ft elevation.
This matter was also
discussed
with representative
of NRR,
who were informed that
ANPP would
rather address
this problem in the form of a commitment rather than
a
Unit 3 license condition since planning for corrective action was in a
formative stage.
The licensee
was informed that two matters
had been
proposed to the
NRC
Regional office staff for consideration
concerning Unit 3 readiness
for
operation.
It was proposed that
a Unit 3 license
be conditioned to require
an
PASS prior to exceeding
S%%uo power as
was
done
on the Unit 2
license.
Second,
although the
RMS was expected to be fully operable
by
the date of license
issuance, it was
recommended that
NRR require
a
Justification for Interim Operation prior to license
issuance
in the
event that the
as expected.
32
The inspector's
concerns
relate'd to the
use of an adhesive
smear
pad to
silence the monitor audible alarm and the methods
used to attach
radiation/high radiation area signs were also identified.
0