ML17304A279
| ML17304A279 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/01/1988 |
| From: | Cicotte G, Cillis M, North H, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304A276 | List: |
| References | |
| 50-528-88-13, 50-529-88-14, 50-530-88-13, NUDOCS 8807200205 | |
| Download: ML17304A279 (47) | |
See also: IR 05000528/1988013
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Repo'rt
Nos.
50-528/88-13,
50-529/88-14
and 50-530/88-13
Docket Nos.
50-528,
50-529
and 50-530
License
Nos.
Licensee:
Arizona Nuclear Power Project
P.
0.
Box 52034
Phoenix,
85072-2034
Facility Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection at:
Palo Verde Site - Mintersburg, Arizona
Inspection
Conducted:
May 16-27,
1988
Inspected
by:
H.
M. Cillis,
S
. Radiation Specialist
Approved by:
~Summar:
G.
R. Cicott
, Radiation Specialist
G.
P.
uh s, Chief
Facili 'adiological
Protection Section
Date Signed
tt,'g
VZ
Date
igned
g )dt's
Date Signed
7 I
Da e Signed
Ins ection durin
the
eriod of Ma
16-27
1988
Re ort Nos.
50-528/88-13
50-529/88-14
50-530/88"13
on previous inspection findings; onsite followup of reports of nonroutine
events;
onsite followup of events at operating. reactors;
radiation protection
. and management;
external
and internal
exposure control; control of radioactive
material,
contamination
and surveys;
maintaining occupational
exposures
occupational
exposure
during extended
outages; facility tours;
review of
licensee
reports;
in office review of nonroutine events.
Inspection
procedures
92701,
92700,
93702,
83722,
83724,
83725,
83726,
83728,
83729,
90713,
90712,
and 30703 were addressed.
Results:
In ll of the
13. areas
addressed,
no apparent violations were
identified.
In one area
a violation of 10 CFR 20.201 was identified (see
section 3.B.),
and in a second
area
a violation DOT regulations
49
CFR 173.425
and 173.448
was identified (see section 4.C.).
In addition two unresolved
items related to an apparent
exposure
in excess
of the limits of 10 CFR 20. 101
and failure to perform surveys in accordance
with 10 CFR 20.201 were
identified (see section 4.B.).
8807200205
88070i
ADOCK 05000528
9
Details
Persons
Contacted
"R.
M. Butler, Director,
ANPP Standards
and Technical. Support
"P.
L. Brandjes,
Manager,
Central
Maintenance
"W.
H. Doyle, Jr.,
Manager,
Radiation Protection
(RP) Unit 1
J ~
D. Driscoll, Assistant Vice President,
Nuclear Production Support
"L. A. Fitz Randolph,
Lead Health Physicist-,
Radiation Protection
Standards
(RPS)
"T.
P. Hillmer, Manager,
Radwaste
Support
"W.
E. Ide, Plant Manager,
Unit 2
K.
M. Johnson,
Shift Technical Advisor Unit 2, Engineering Evaluations
"M.
W. Lantz, Senior Radiation Consultant,
"J.
R.
Mann, Manager,
Central
- K. L. McCandless
Clark,
Lead,
ANPP Compliance
"K.
R. Oberdorf,
Manager,
RP Unit 1
"R.
B.
Ochoa.,
Lead Health Physicist,
RP Standards
"R. J.
Rouse,
Engineer,
ANPP Compliance
"J.
C. Schlag,
Supervisor,
Radwaste
Standards
"T.
D. Shriver,
Manager,
ANPP Compliance
~W.
E.
Sneed,
Manager,
RP Unit 3
- L. A. Souza;
Manager, guality Audits and Monitoring
"0. J. Zeringue,
Plant Manager,
Unit 3
"Denotes personnel
present at the exit interview held on May 27, 1988.
Preliminary discussions
of inspection findings were held with J.
G.
Haynes,
Vice President
Nuclear Production
on May 25, 1988,
and with
E.
E.
Van Brunt, Jr.,
Executive Vice President
ANPP on May 26, 1988,
since neither were able to be present at the
May 27, 1988, exit
interview.
In addition, the inspectors
met and held discussions
with other licensee
and contractor personnel.
Licensee Action on Previous
Ins ection Findin
s
92701
Closed
Enforcement
50"528/87-40" 01 and 87-40-02
92702
This matter concerned
the failure to properly post or barricade
Radiation
pursuant to 10 CFR 20.203 "Caution signs,
labels,
signals
and controls." (b), "Radiation areas.",
and Technical Specification 6.12 "High Radiation Areas".
The licensee
responded
to the
Notice of Violation in a timely'ashion.
During the inspection of May
16-27,
1988, tours of Unit 1 identified no failures to properly post or
barricade
areas.
Viewing of a videotape
concerning
safe radiological
work practices,
which addressed
posting and maintenance
of barriers
was
required before entry into the radiation control area.
Closed
Enfold cement
50-528/88-03" 01'2702
This matter concerned
the failure to post
a Notice of Violation in a
timely fashion pursuant to 10 CFR 19. 11 "Posting of notices to workers."
It was verified that the licensee
had
amended
the administrative
procedures
related to posting such
documents
to assure
compliance with
the requirements.
0 en
Followu
50-528/86-08-03
50-529/87-19-01
and 50-530/87-20-01
~92701
The licensee
submitted (letter dated April 6, 1988)
a request for
Technical Specification
amendment
which proposes
the replacement of the
and oxygen sequential
monitoring of the chemical. and volume
control system
(CVCS) tanks
and waste
gas
decay tank
(MGDT) with oxygen
only monitoring of the waste
gas
surge tank header.
Closed
Followu
50-528
529 and 530/88"03-03
92701
The licensee
reported that replacement
pump impellers
with non cobalt containing wear rings
had been ordered for Unit 3.
The
Unit 3 impeller wear rings will be replaced with non cobalt containing
material for use in Unit 1.
The use of the Unit 3 impellers in Unit 1 is
dependent
on the length of the interval between
the next Unit 3 and Unit
1 outages.
The licensee
reported that. new impellers
may be required for
Unit 1 in order to meet outage
schedules.
Closed
Fol 1 owu
50-529/01-28-87
92701
The licensee
had received
and reviewed the contractor 'reports related to
the migration of noble gases
from the lower levels of the auxiliary
building to the 140 ft. elevation..
The licensee
had developed
and
approved
a three
phase
program to address
the gas migration problem.
Following each
phase of the program,
studies will be performed to
determine
the effectiveness
of corrective actions before proceeding to
the next phase.
The report of the contractor's
tests
were briyfly
reviewed
and the licensee's
plans were discussed.
Mork orders
had been
issued for the first phase.
Closed
Fol 1 owu
50"530/88" 05-01
92701
The licensee's
Test Results
Review Group
(TRRG) had
recommended
a
resurvey of the Unit 3 Radiation
Zone
1 areas
because
the radiation
levels observed
during the initial surveys
were several
orders of
magnitude
below those that would be present with the design IX fuel
defect.
The initial surveys
had been performed with an ion chamber
survey instrument with a minimum sensitivity of 0.2 mr/hr.
A subsequent
survey was performed with a
GM type instrument with a minimum sensitivity
of less
than 0. 1 mr/hr.
The repeat
survey substantiated
the results of
the earlier survey which had resulted in the conclusion that the facility
shielding met design
and regulatory criteria.
No violations or deviations
were identified.
~
~
3.
Onsite Followu
of Written
Re orts of Nonroutine Events
92700
A.
Closed
Followu
50-529/88-08-LO
A timely Unit 2 Licensee
Event Report 88-008-00,
dated April 7,
1988, reported the actuation of the Fuel Building Essential
Ventilation System
(FBEVS) Train "A" with a designed
cross trip of
FBEYS Train "B". and Control
Room Essential Filtration System Trains
"A" and "B".
All equipment operated
as designed.
The actuation
resulted
from a radiation level'of 10 mr/hr which was
above the
"Alarm/Trip" setpoint
(5 mr/hr) of Fuel
Pool Area Radiation Monitor,
RU-31.
The "Alarm/Trip" setpoint
had been set at a conservative
low
level with respect to that permitted by Technical Specification 3.3.3. 1 (< 15 mr/hr).
The level of 10 mr/hr observed
by the monitor
was caused
by the removal of an underwater
vacuum cleaning device
from the pool in close proximity to monitor RU-31.
The vacuum
cleaning device exhibited
a dose rate of 800 mr/hr as verified by
surveys.
Monitor RU-31 setpoint
was raised to 10 mr/hr.
The removal of the
vacuum cleaning device from the, fuel pool
was part of normal planned
work activities.
No violations or deviations
were identified.
B.
Closed Followu
50-529/87-22-XO
This matter was first addressed
in Inspection
Report. 50-529/88-05.
On August 28,
1987, the licensee
reported through the
Emergency
Notification System to the
NRC Operations
Center the declaration of
Notification of Unusual
Event
(NOUE) due to a Unit 2 noble
gas
release.
Licensee
Special
Report 2-SR-87-022
(50-529/87-22-XO)
dated
September
1, 1987, provided written documentation of the
earlier telephonic report.
In the Special
Report the Licensee
stated,
"An investigation of the cause of the event is currently in
process.
Corrective action necessary
to prevent recurrence will be
developed
based
on the results of the investigation."
During the current inspection the licensee's
Special
Plant Event
Evaluation Report,
"SPEER 87-02-015,
Unit Two Radioactive
Release
and Notification of Unusual
Event,
Event Date:
August 28, 1987",
Work Order,
"WO ¹00245756"
and Radiation
Exposure Permit,
"REP.
No.
2-87-0362",
were reviewed.
The work order specified that Waste
Gas
Decay Tank
(WGDT) 2B relief
valve (GR-PSV-27)
was leaking and was to be'reworked.
The work order
addressed
contact with Operations
and g.C. prior to starting work,
maintaining housekeeping
and system cleanliness
and obtaining and
verifying clearance.
REP 2-87-0362 r'eported
surveys
around the
valve and general
area
and required
a survey
and gas
sample
and beta
readings
upon system breach.
REP-Section
V "Specific Instructions"
noted:
"3)
When breaching
system,
open slowly to vent off radioactive
gases.
Depending
on levels of gas, -it may be necessary
to
leave the
room until the gas
has dispersed.
4)
Ensure
Radwaste
has isolated
and vented
systems. properly prior
to start of job."
SPEER 87-02-015 reported that prior to the start of work the
contents of WGDT X02B had been transferred to another tank and
a
nitrogen purge of WGDT X02B and the surge
had been performed.
Discussion with licensee
personnel
established
that the nitrogen
purge
was performed three times from a fill pressure
of 5 psig to
about 0.5 or 1.0 psig.
The
SPEER noted that the surge
system
included
a 720 cubic foot tank and that at a pressure
of 1 psig
approximately
50 standard
cubic feet of gas would have
been released
upon equalizing
system pressure
with atmospheric
pressure.
The
system
was depressurized
through drain vales to the Radwaste
Building sump which also received the floor drain system.
Because
of plant ventilation system
anomalies
(see
Report Details section
2
Followup Item 50-529/01-28-87)
the licensee
stated they believed the
released
noble gases
flowed from the
sump through the drain system
to the 140 foot elevation
and then into the
HVAC exhaust to the
plant vent.
The
SPEER reported that a post system
breach
sample of the gas
remaining in the system
had an activity of approximately'0 pCi/cc.
Other documents identified the presence
of Xe-133,
Xe-133m,
and
Xe-135 in the system
and
an estimated
15.3 curie total for the
release.
In addition the
SPEER i.dentified four concerns
and
provided
recommended
corrective actions.
The venting of portions of the gaseous
radwaste
system which
resulted in the declaration of an
NOUE was caused
by a failure to
evaluate
both the concentration
of radioactive
gases
in the system
and the volume of gas which would be released.
The failure to
evaluate
the potential for release
and the concentration of gases
to
be released
appeared
to. be contrary to the requirements
of 10 CFR 20. 201 "Surveys." which states
in part:
"(a) "As used in the
regulations
in this part, "survey" means
an evaluation of the
radiation hazards
incident to the ... release,
disposal
or presence
of radioactive materials ...
under
a specific set of conditions.
When appropriate,
such evaluation includes ...
measurements
of ...
concentrations
of radioactive materials
present.
(b) Each licensee
shall
make or cause to be made
such surveys
as ... (2) are
reasonable
under the circumstances
to evaluate
the extent of
radiation hazards that may be present."
(50-529/88-14-01)
4.
Onsite Followu
of Events at 0 eratin
Reactors
93702
-
A.
Unit 2 Fuel
Pool
D ed Green
On March 16,
1988, licensee
personnel
and
a resident
inspector
observed that the Unit 2 spent fuel pool
had a green tint.
The Unit
was in a refueling outage at the time.
Analysis of normal chemistry
parameters
found all to be within specified limits.
The licensees
chemistry staff continued efforts to identify a possible
contaminant.
By March 17, 1988, conflicting reports indicated that
the green color had migrated
as far as the containment refueling
cavity.
Licensee
representatives
discussed
the matter with resident
and regional
inspection staff.
Subsequently
the licensee's
onsite
chemistry staff identified the green color as
a "dye".
Samples
were
submitted to an offsite laboratory.
By March 23, 1988, the
laboratory identified the contaminant
as
a "sulfonated azo-triphenyl
methane
dye stuff".
Comparison with commercially available fabric
dyes
found good comparison with "RITv Kelly or Emerald Green dyes.
The color had disappeared
by 'th'e morning of March 18,
1988.
The matter
was turned over to the licensee's
security staff when it
became
apparent that the green color was
due to the addition of
material to the pool rather than
some unidentified natural
phenomenon
(e. g. algae
growth, process
chemical interaction,
etc. ).
The security staff was continuing to pursue
the matter at the time
of the inspection.
The licensee's
chemistry staff concluded that the "dye" added to the
pool would have
no deleterious effect on the fuel or plant systems.
This matter is closed.
A
arent
Ex osure in Excess of Re ulator
Limits
On the morning of May 23, 1988, the licensee
reported to the Senior
Resident Inspector,
the apparent
exposure of a contract worker in
Unit 2, in excess
of 3 rems whole body during the night shift,
May
22-23,
1988.
A Radiation Specialist,
onsite for a routine
inspection
began
an immediate inquiry into the event.
Details
In preparation for the containment Integrated
Leak Rate Test (ILRT)
the licensee
had elected to have tPe floor and lower 6-8 feet of the
refueling cavity sprayed with strippable paint.to fix residual
contamination.
The apparent
occurred during masking of
certain areas
in the upender cavity before painting.
The upender
cavity was highly contaminated
because
the underwater
vacuuming of
the cavity had been limited to approximately two rather than eight
to ten hours.
At an earlier, unidentified, time the Radiation Protection
(RP) and
ALARA staffs
had planned for extensive
vacuuming of the flooded
refueling cavity to remove particulate activated stellite (Co-60).
On the night shift during which the vacuuming
was to occur the
decision for delayed cavity draining to permit vacuuming
had been
changed,
apparently without the concurrence
of RP and
The
licensee's
staff believed the change in plans
was
due to the need to
pull the reactor coolant
pumps
(RCP) to retorque
the impeller nuts,
a critical path activity.
Following the draining of the cavity,
decon activities included the use .of hydrolasing
and squeeging
%he
floor of the cavity, which moved particulate activity into the
upender pit.
Hydrolasing in the upender pit in an attempt to move
solid contaminants
to a drain was only marginally successful.
Surveys
performed in the upender
cavity,over the period
May 5
through Nay 23, 1988, provided the following information:
Survey
Oate/Time
~Serve
No.
5/5/88 - 1545
2-88-04332
Summary "of
Conditions
~Re orted
f ~
Maist level dose rates to 20 R/hr,
1000 R/hr contact with upender with 30
R/hr at 18 inches.
5/19/88 - 2100 2-88-04597
Post-hydrolase
1000 R/hr contact with
floor southwest
corner of cavity,
70
R/hr contact with floor north west
corner of cavity, both near transfer
tube.
1000 R/hr contact
and
30 R/hr
at 18 inches
from bottom of upender
basket in horizontal position.
'/11/88 - 0700 2-88-04618
Post hydrolase,
southwest
corner
3
R/hr, northwest corner not surveyed.
Drain 25 R/hr contact.
Upender
basket
unchanged.
General
area
dose rates
appear
to have
been
reduced.
5/13/88 - 1620 2-88-04762
Mith one inch of water
on the floor
of the upender cavity ankle level
dose
rates of 30 R/hr were reported at the
west end of the upender adjacent to
the transfer tube,
3 R/hr at the drain
and 30-80 R/hr from the bottom of the
upender
basket.
5/14/88 - 2100 2"88"4791
Prejob survey for transfer tube blind
flange installation,
2 R/hr in the
center of the plane of the end of the
transfer tube
and 1, 1,
2 and
5 R/hr
at the head,
chest, waist and
knee
levels respectively,
at the west end
of the upender adjacent to the
transfer tubes.
5/21/88 " 2230 2-88-05115
Post-decon
survey,
dose rates at
head, waist and ankle were 1.5, 1.5
and 10 R/hr respectively in the
southwest corner of the cavity near
the transfer tube
end of the upender,
5 R/hr contact over the drain and
no
data for the northwest corner of the
cavity.
5/22/88 " 1330 2-88-05141
Survey of contamination levels to
evaluate
need for strippable paint
coating in the upender cavity.
Levels
ranged
from 1EG disintegrations
per
minute
(dpm) away from the transfer
tube to > 5E6
dpm and 600 mrad/hr beta
near the transfer tube.
Post exposure
investigation surveys
5/23/88 - 0530 2-88-05161
2-3 R/hr near transfer tube blind
and 10-50 R/hr contact with
grit on floor in northwest corner near
blind flange with 5 R/hr at 18 inches.
5/23/88 - 1700 2-88"05197
Contact - 18 inch dose rates
on floor
near blind flange ranged
from 6 R/hr-
1 R/hr in the southwest
corner to 75
R/hr - 2 R/hr in northwest corner at
visible crud on the floor.
It was noted that following the survey of May 10, 1988, at 2100
(Survey 2-88-04597)
when a contact
dose rate of 70 R/hr was noted in
the northwest corner until the surveys
performed
as
a part of the
licensee's
investigation
on May 23,
1988, the radiation levels in
the northwest corner of the upender cavity had not been reverified.
The licensee staff members
stated that scaffolding
had been
installed in the northwest corner of the cavity which made that area
inaccessible
for surveys.
On the night shift of May 22, 1988, contract
decon technicians
were
directed to remove the underwater
vacuum cleaner
from the upender
cavity and paint the upender floor and cavity up to five feet above
the floor.
The work was to be performed
under Radiation
Exposure
Permit No. 2-88-0280B.
ALARA Pre-Job
Review No. 2-66, in support of
REP 2-88-0280B,
was performed
on May 5, 1988 with an estimated
12.0
man-rem exposure.
Pre-Job
Review No. 2-66 noted that general
area
dose rates
were from 200 mr/hr to 50 R/hr with up to > 1000 R/hr at
the bottom of the upender to 50 R/hr general
area.
Masking the
blank flange was estimated to require two men for 10 minutes
each in
a 1 R/hr field for a total exposure of 0.333
rem.
The previously
observed
70 R/hr dose rate in contact with the crud on the floor in
this northwest corner of the cavity was not addressed.
A Pre-Job Briefing checklist was prepared
which noted the expected
radiation levels
and mrad smearable
contamination levels throughout
the area.
Protective clothing was to be as specified
on the
REP.
Job Prerequisite
addressed:
1.
Staging equipment
and operator familiarity with equipment;
2.
Advice to workers concerning work area
dose rates
and changing
dose rates
due to accumulation of strippable paint;
8
3.
Preparations
for removal of contaminated
trash;
4.
Establishment
of positive
means for monitoring exposure
and
maintenance
of communication.
Job Accomplishment addressed:
1.
Personnel
control during movement of bagged stripped paint;
2.
Storage of high radiation level trash;
3.
Continuous
Radiation Protection
coverage
required;
4.
Awareness
of potential for heat stress.
The worker team included four persons,
with two individuals "A" and
"B" at the 100 foot elevation of the fuel transfer canal,
and two
other persons
on the 140 foot elevation in sight and shouting
distance.*
The latter
two were assigned
one at the stepoff pad
(Individual "C") and one at the Teledose station (Individual "D").
Individual "A" wore full length paper modesty pants,
cloth
protective coveralls,
a plastic suit,
head coverings,
protective
footwear, cotton and rubber gloves
and
a filter respirator.
Cavity
worker dosimetry included
TLDs on the chest,
head,
gonad area,
back,
right and left thighs,
upper. arms, wrists and ankles.
Self
indicating dosimeters
(SID) (0-1
R and 0-5
R ranges)
were worn on
the chest,
head,
back and right and left thighs and upper arms.
A
Teledose
device (remotely monitored incrementing dosimeter)
was- worn
in the region of the right shoulder.
The workers'lothing
and
personnel
monitoring equipment were
as required
by the
REP.
An
earlier
REP,
No. 2-88-0274B
had required the use of an additional
Teledose
device
on the right thigh for cavity decon
and associated
activities.
The required dosimetry required
was referred to as
a
jump pack".
REP No. 2-88-0280B covering the work on the night of
May 22-23,
1988, called for "jump packs" with modification to be
made by the lead
RP technician
as necessary.
No modifications to
"jump packs" were
made for the work in the cavity.
The
REP noted
that several
hot spots of 10-150 R/hr on contact were located
on the
upender
and floor and that hot particles
reading
up to 2.5 R/hr were
located
on the cavity floor near the Upper
Guide Structure liftrig.
The workers entered
the cavity at approximately
2320 and exited at
2355
on May 22,
1988.
While in the cavity Individuals "A" and "B"
continued preparations
for the application of strippable paint.
The
underwater
vacuum hose
was drained
and remoVed,
and paint line tape
masking
was applied to portions of the cavity wall.
Next the
workers
masked the transfer tube blank flange, working on the top of
the flange while standing
on the upender,
then standing
on the floor
and later kneeling
on the floor to reach the bottom of the flange.
These activities required from about
3 to
5 minutes
each,
except for
the kneeling portion which required about
5 minutes.
.Individual "A"
was working in the northwest corner of the cavity and Individual "B"
in the southwest corner by the transfer tube.
The estimated
dose
rate from Individual "A"'s Teledose
device
was
2 R/hr while kneeling
on the floor.
As Individual "A" completed the flange taping
he
twisted his torso
and lowered his right shoulder to tape the nearby
upender
legs.
At that time a sudden
increase
in Teledose
device
indicated
dose rate to about
7 R/hr was noted.
At,that time
Individual "D", monitoring
the Teledose
device instructed
Individual "A" to move out of the area.
Individual "A" moved along
the north side of the upender
where
he continued to work for about
5
minutes
when both Individuals "A" and "B" were instructed to leave
the cavity.
Upon leaving the cavity Individual "A"'s plastic suit
exhibited visible crud over the knees.
I
Upon undressing
Individual "A" noted that the thigh dosimetry packs
'n
both legs,
attached
to the paper modesty garments,
had slipped to
just above the
knee.
Individual "A"'s Teledose
exposure
indicated
330
mR while Individual "B"'s was
300
mR.
Individual "A"'s right
and left thigh 0-5
R SIDs indicated
2
R and 1.9
R respectively at
0005 on May 23, 1988.
Individual "B"'s high range SID's indicated
a
maximum 700
mR to the right thigh.
All TLDs were collected
and
promptly processed
and both individuals were denied further access
to the Radiation Control Area.
Initial evaluation of the
TLDs was completed during the early
morning of May 23, 1988, which indicated
an exposure of 2981 mrem to
Individual "A"'s right thigh.
On May 23, 1988, the energy
correction factors
and fading characteristics
of the
TLDs used
by
Individuals "A" and "B" were determined
and
an exposure
scenario
was
developed.
On May 24,
1988,
a TLD tree duplicating
a bent
knee with
the lower leg parallel to the floor was exposed
in the area where
Individual "A" had knelt by the transfer tube.
Good agreement with
Individual "A"'s measured
exposure
was achieved.
'ased
on the licensee's* evaluation of the TLD's a corrected
deep
dose to Individual "A"'s right thigh was reported to be 2607
mrem.
Individual "A"'s previous whole body exposure for the quarter
was
602 mrem.
This represents
a total whole body exposure of 3209 mrem.
The licensee's
evaluation of the dosimetry was subjected
to peer
review by the Assistant Health Physics
Manager
and the head of the
dosimetry program at San Onofre Nuclear Generating Station
who were
invited to the Palo Verde site by the licensee for that purpose.
The licensee
had
commenced
an investigation of the event
on the
morning of Ray 23, 1988,
and
had assigned
investigation
and
reporting responsibilities.
Among the topics to be addressed
by the
investigation
was the decision to abandon
the cavity vacuuming prior
to drain
down and the reason that special
emphasis
had not been
placed
on the 70 R/hr contamination in the northwest corner of the
upender cavity prior to permitting work in the area.
In addition
written statements
were obtained
from Individuals "A", "C" and "D"
on the morning of May 23, 1988.
The statement
by Individual "A"
addressed
only his work activities in the cavity and the observation
that the thigh dosimetry packs
had slipped to his knees.
10
The statement
by Individual "8" described 'his work activities
and
noted that:
It was his understanding that radiological conditions in the
cavity could have
changed
due to
day., shift activities =but that,
"No new survey was done."
(2)
On arrival at the refueling cavity 140 foot elevation it was
found that work supposedly
completed earlier had in fact not
been completed
and that on-the-spot
adjustments
to the job
scope
were
made
due to the "high priority and visibility of the
job."
The statement
by Individual "0", described
his work activities
and
noted that:
He "complained" to the
RP technician that monitoring
personnel
would be difficult due to "fluctuating dose rates,"
the
number of people
and the hot particles in the area.
He
stated that the
ANPP technician said the work was to be done
without changing
any of the instructions.
(2)
He reported that the
ALARA briefing given by the
technician consisted of reading
a paragraph
of general
statements,
"which meant in other words
'Be Careful'".
(3)
(4)
He reported that on arrival in containment,
previously
scheduled
work had not been completed
and adaptations
to the
work plan were necessary.
He reported that at one point he instructed Individual "A" to
move from the area
where
he was kneeling while he taped the
blind flange, which he did promptly.
He reported that Individuals "A" and "B" were instructed to
leave the cavity when they reached their allotted stay time of
30 minutes.
Individual "D" concluded his statement with the following main job
concerns:
I made it very clear that I didn't think it was safe
and that
it was
a poor expenditure of dose.
I also stated that monitoring the job effectively would be
.
impossible
and went by agreed
upon methodology.
I do not approve of the
ALARA program at Palo Verde and that
they would allow us to do this job under the stated conditions.
The contamination
parameters
very likely changed
since the last
survey
due to the removal of scaffolding in the area.
I stated
weeks earlier that the canal
needed
more
decontamination
before work progressed
in the area.
I was told
we were to paint it as it layed.
I object to constantly
deconning
areas
in futilityjust so
some
operator
does
not have to wear papers.
HPCA "(Hot Particle
Contaminated
Area)" areas
have
been released
in the cavity
where I have
shown hot particles still exist.
The R.P.
Department
should
have
more influence over expenditure of dose
and effort than they are given."
The licensee
plans to submit
a report pursuant to the requirements
of 10 CFR 20.405 "Reports of overexposures
and excessive
levels
and
concentrations."
It appears
that the apparent
exposure of Individual "A" to 3209
mrem
to the whole body during the second quarter of 1988, was'ontrary to
the requirement of 10 CFR 20. 101 "Radiation dose standards
for
individuals in restricted areas".
section (b)(1), which state's
in
part:
"During any calendar quarter the total occupational
dose to
the whole body shall not exceed
3 rems;
Pending receipt
and evaluation of the licensee's
report pursuant to
10 CFR 20..405 this matter is considered
to be unresolved
(50"529/88-14-02).
In the survey of the upender
cavity performed
on May 19, 1988,
(2-88-04597),.
a contact
dose rate of 70 R/hr was observed
in the
northwest corner.
At some unidentified time after that survey,
scaffolding was installed in the northwest corner of the cavity,
which interfered with subsequent
decon
and survey activities.
Prior
to the work in the cavity on the night of May 22-23,
1988, the dose
rate in contact with the floor in that area
was neither reevaluated,
nor was information available from the ear lier survey
used in
controlling worker activities.
This failure appears
to be contrary
to the requirements
of 10 CFR 20.201 "Surveys." which states,
in
part:
"(a) As used in the regulations in this part,
"survey" means
an evaluation of the radiation hazards
incident to the ... presence
of radioactive materials or other sources
of radiation under
a
specific set of conditions.
Mhen appropriate,
such evaluation
includes
a physical
survey of the location of materials
and
.equipment,
and measurements
of levels of radiation....
(b) Each
licensee
shall
make or cause to be made
such surveys
as (1) may be
necessary
for the licensee
to comply with the regulations
in this
part,
and (2) are reasonable
under the circumstances
to evaluate
the
extent of radiation hazards that may be present."
\\
Pending receipt
and evaluation of the licensee's
report pursuant to
10 CFR 20.405 this matter is. considered
to be unresolved
(50"529/88-14-03).
12
Unresolved
Items
Unresolved
items are matters
about which more information is
required in order to ascertain
whether
they are acceptable
items,
violations or deviations.
Closed
Followu
50-528/88-Ol-GC
Im ro erl
Braced
and Secured
Radwaste
Shi ments
Copies of two State of Nevada,
Department of Human Resources,
Health
Division, Radiological
Health Section letters to Arizona Nuclear
Power Project dated April 12, 1988,
were received. by 'the Region
Y
office of the U.S.N.R.C.
on April 13,
1988.
The letters reported
that two radwaste
shipments
from the Palo Verde site
had arrived at
the Beatty,
NV waste disposal site.
The first, on March 23,
1988,
showed evidence of shipment
movement in that 2" x 4" lumber bracing
had broken or loosened
apparently
due to inadequate
chaining
(Shipment 88-RM-21),
and the second
on April 8, 1988, exhibited
loose chain restraints
(Shipment 88-RW-23).
Both events
were
identified by the State of Nevada
as Severity Level III violations
of U.S.
Department of Transportation
(DOT) regulations
49
CFR
173.425(b)(6) related to bracing
and 49
CFR 173.448(a)
related to
preventing shifting under conditions normally incident to transport.
The State of Nevada letter dated April 12,
1988, concerning
shipment
88-RM-21 required
a response
from the licensee
concerning corrective
actions.
The letter dated April 12, 1988, concerning
shipment
88-RM-23, noted that this represented
the second Severity Level III
violation and required
a response
concerning corrective actions
and
requested
that
ANPP refrain from further shipments
to the Beatty
site until the bracing problem had been resolved.
The licensee's
"Radwaste
Standards
Problem Report,
Report
Number:
RMS-88-001,:
and "Radwaste Instruction 0017, Instruction Title:
Shipping of Radioactive Material" dated
Nay 15,
1988,
were reviewed.
The documents
reported the results of the licensee's
inquiry into
the events
and included in the Instruction measures
designed
to
correct the problems
observed.
In addition past
and revised waste
shipment loading practices
were discussed
with licensee
personnel.
During the 6-8 months preceding the problem with the shipments to
Beatty,
NV the licensee
had used the following waste
shipment
loading practice.
The flatbed trailer to be used for the shipment
was taken into the protected
area using
an
ANPP tractor and driver.
After loading the waste,
the load was chained in place using chains
belonging-to
ANPP.
The
ANPP tractor and trailer then left the
protected
area where the contract carrier's tractor was attached.
The
ANPP chains
were removed
and the carrier's
chains
were attached
by the driver under
ANPP supervision.
The driver was then verbally
instructed to check chain tension regularly and retighten
as
necessary.
The revised,
"Radwaste Instruction 8017," attachment
K,
"Carrier/Driver Instructions", contains
the following items:
13
"4.
All Drivers Carrying Radioactive Materials
a.
You have inspected
the load and agree that it is properly
secured
against movement....
8.
During transport,
"STOP
EVERY 2
OR 3
HOURS, to inspect the
blocking including bracing
and tighten
as necessary."
With respect to the liners contained in the two shipments,
the
licensee
stated that liners supplied
by two different companies
were
used.
Shipment
88-RW-21 was
a liner incorporating three
upper lugs.
This was the package
which had shifted in transit.
The shipment
was
chained with two diagonally crossed
chains at the front and
a single
chain at the rear attached
to opposite
sides of the trailer and
passing
through the single lug.
The licensee
stated
double chaining
will be used for the three lug liners in the future.
The liners
constituting shipment
88-RW-23 were equipped with four lugs and were
diagonally cross
chained fore and aft.
The licensee
plans to have
loads chained
by licensee
radwaste
personnel
in the future.
Title 49
CFR 173.425,
"Transport requirements
for low specific
activity (LSA) radioactive materials."
states
in section (b)(6):
"Shipment must be braced
so as to prevent shifting of lading under
conditions normally .incident to transportation."
Further, Title 49
CFR 173.448,
"General Transportation
requirements."
states
in
section (a):
"Each shipment of radioactive materials shall
be
secured
in order to prevent shifting during normal transport
conditions."
Contrary to the above requirements,
the onsite inspector for the
State of Nevada observed that licensee
radwaste
shipments
88-RW-21
and 88-RW-23 arrived at the Beatty,
Nevada waste disposal
site with
loose chain shipment restraints
and further that shipment
88-RW-21
exhibited apparent
movement
on the trailer in that the bracing
had
been broken or loosened.
These failures appear to constitute
a
violation of Title 10 CFR 71.5, "Transportation of licensed
materials." which require in part that:
"(a) Each licensee ...
who
delivers licensed material to a carrier for transport,
shall
comply
with the applicable
requirements
of the regulations
appropriate to
the
mode of transport of DOT in 49
CFR Parts
170 through 189."
(50-528/88"13-01)
5.
Radiation Protection - Or anization
and Mana ement
83722
On April 22, 1988, the Region
V office was notified that the Manager,
Radiation Protection
and Chemistry
(RP&C),. was resigning from ANPP.
The
individual filling that position had been designated
by the licensee,
and
was qualified as the Regulatory Guide 1.8 Radiation Protection
Manager.
During the inspection the licensee's
representatives
stated that the
recently appointed
Manager,
Central
Radiation Protection
was acting
as
the Manager,
ROC for management
functions.
The Supervisor,
Radwaste
Standards
was acting
as the Manager,
ROC for administrative functions.
14
The licensee
had begun the recruiting and selection
process
to fill the
Manager,
RP&C position.
The Manager,
Central
Radiation Protection,
had resigned effective January
29,
1988.
At the time of the inspection
the former Supervisor,
Health
Physics Controls
had been designated
as the Manager,
Central
Radiation
Protection.
The position of Supervisor,
Health Physics Controls
was
being filled by a Health Physics
Controls staff member
on an acting
basis.
The licensee
s actions. with respect to filling the vacant
positions
and qualifications of selectees will be reviewed during
subsequent
inspections
(50-528/88-13-01).
No violations or deviations
were identified.
6.
Audits and
A
raisals
Audits and Appraisals in the following areas
were reviewed:
for Units 1,
2 and 3;
External
and Internal Occupational
Exposure
(83724,
83725)
Control of Radioactive Material, Contamination
and Surveys
(83726)
Maintaining Occupational
Exposures
ALARA (83728)
and for Unit 2;
Occupational
Exposures
During Extended
Outages
(83729)
The Quality Audits and Monitoring (QA&M) Department
conducts
preplanned
audits
on a scheduled
basis
and performs monitoring activities
on a live
time basis
depending
on the work in progress.
The scope of work for monitoring activities was specified in a
QA&M
Department Monitoring Ability Evaluation
(MAE) checklist which identifies
the functional areas
(e. g.
Emergency
Plan (Q-20), Radiation Protection
(T-22), Chemistry (T-25), etc.) which were further subdivided into topic
areas,
(e.g.
T-22 Radiation Protection
a 0
b.
C.
d.
In Plant Radiation Monitoring Program
ALARA Program
Control of Special
Nuclear Material
Dosimetry, (etc).
Results of quality monitoring activities were documented
in Quality
Monitoring Reports
(QMR).
As of January
1, 1988,
QMRs have
bee'n
summarized in a computer records
system which provides the following
information:
Report
Number
Identity of the monitor performing the activity
Date
Unit where acti vity was performed
Activity from the
MAE listing (e.g.
T-22)
Fol 1 owup
Total
number of items examined,
number of satisfactory
and
unsatisfactory
items,
Brief comment/Problem
description.
The results
from the /MR were summarized in a quarterly report to
licensee
management.
The "guality Assurance
Performance
Report for the
First quarter of 1988", dated
May 2, 1988,
was examined.
Each Unit was
assigned
numerical ratings identified as the guality Assurance
Performance
Ratio
(gAPR) which was determined
by dividing the total
number of satisfactory
items observed
by the total
number of items
observed.
In the radiation protection
a'rea the first quarter
1988 report
provided the following information:
Unit 1
Unit 2
Unit 3
gAP Ratio - Radiation Protection
0. 982
0. 971
0. 994
Total Radiation Protection
items observed
332
511
160
Total Satisfactory Radiation Protection
326
496
160
It was noted that special
emphasis
was placed
on Unit 2 during this
period due to refueling activities.
At the time of the inspection guality Assurance Audit No;88-008
"Radiation Protection",
had been recently completed.
The report was in
draft form and
had not been submitted to the audited organizations.
The
results of this audit will be examined during a subsequent
inspection
(50-528/88-13-02).
The licensee identified a total of 199 monitoring reports
which had been
completed in the previous year in areas
related to radiation protection.
A listing of monitoring report numbers in the following topic areas
was
provided.
Reports
were randomly selected
for review and during the
review the number of reports with no unsatisfactory
findings were noted.
Total
No.
Number
Number
~Tc ic Area
In Plant Radiation Monitoring
Program
Exposure Termination Reports
Radiation Protection
Program
Implementation
Respiratory Protection
Training and qualification
Radiation
Exposure Control from
Emergency
Plan
Radiation Control Problem
Reports/Posting
19
7'3
86
6
2
2
13
138
4
3
181
3
3ll
3
'30
16
It was noted that the persons
performing the monitoring activities were
qualified by reason of training and experience
in the areas
monitored.
The monitoring reports
appeared
to be complete,
appropriately detailed
and documented
followup in unsatisfactory
areas
as complete or pending.
a
a
The licensee
appears
to be conducting
a thorough
and detailed audit and
monitoring program using qualified personnel
with appropriate
documentation.
No violations or deviations
were identified.
External
and Internal
Ex osure Control
and Assessment
- Units 1
2 and
3
83724 and 83725
Audits and
A
raisals
See Report Section
6.
~Chan
aa
The reorganization
placed the dosimetry radiation protection
and
functional
groups
under the Central
Radiation Protection
Manager
(CRPM).
Reporting to the
CRPM was the Dosimetry Supervisor.
The dosimetry
functional responsibilities
were divided between
the Dosimetry Analysis
Lead with technical responsibility for the external
and internal
dosimetry programs
and the Records
Access
Control
Lead with
responsibilities for records
maintenance,
and direction of the records
maintenance
and unit dosimetry technician staffs.
The reorganization
appeared
to create
some problems in that with three unit
RP managers
and
without a single decision
maker the .potential for conflicts exists.
In
addition
some loss in the effectiveness
of inter-.unit communications
appeared
to exist.
These
concerns
were perceived
and had not presented
significant problems at the time of the inspection.
The capability and
support of outage activities had not been
compromised.
The dosimetry
staff had been Working from 60-72 hours per week since approximately
October 1, 1987 with two to three
weeks off at Christmas.
It was
reported that the frequency of errors
had been
hard to assess
since the
Radiological
Record
and Access
Control
System
(RRACS) computer test
program
had been
implemented in January
1988 (Inspection
Report 50-528,
529, 530/88-03).
RRACS has proved to be beneficial.
The Dosimetry staff includes
one
ANPP Dosimetry Technician
and two
contract Dosimetry Technicians.
The Records
Access
Control staff
includes
one aide shared with the Dosimetry Lead,
two ANPP Dosimetry
Technicians,
and five senior
and three junior contractor Dosimetry
Technicians.
Normal unit staffing includes six rotating juhior Dosimetry
Technicians
for
a total of 18.
During outages
the outage unit dosimetry
staff was i.ncreased,
two senior
and six junior Dosimetry Technicians for
a total of 14. It was reported that Dosimetry Technician
responsibilities
in the three units varied depending
on the unit
Manager.
The licensee
reported that a new procedure related to whole body counting
was to be effective soon.
The procedure
was not signific'antly-changed
17
except that calibrations
would be performed using
a mixed
gamma source
In addition the
gamma calibration factors
for the whole body counters
would not be changed routinely after each
calibration as in the past; but would be limited to significant changes.
Experience
had
shown that the
gamma cal-ibration factor changes
in the
past
had been minor.
The mixed
gamma source,
supplied
by Analytics Inc.,
contained the following nuclides,
Ce-139,
Hg-203, Sn-113,
Y-88, and Co-60 which provided a
gamma energy
range of 88 to 1836
Kev.
The licensee
had
a
REMCAL phantom which was counted in all
geometries
in both the Fastscan
and Accuscan
Canberra
whole body
.
counters.
Plannin
and Pre aration
The licensee
reported that the contract Dosimetry Technicians
employed
for the Unit 1 and
2 outages
were excellent.
In addition they were
on
site in September
1987, which provided sufficient time for training by
the dosimetry staff before the Unit 1 outage
began.
Personnel
Dosimetr
The licensee
continued
use of the Panasonic
UD-812, beta-gamma
and
UD-809, neutron
badges
and
UD-710A readers.
The reader results
were
entered in AT computers
which process
the data which then
can either
generate
dosimetry reports
and records directly or create
a file which
was read into the
RRACS system to generate
reports
and maintain personnel
files.
The licensee's
dosimetry program was
NVLAP recertified in 1987
and was
due for recertification in 1989.
Assessin
Individual Intakes of Radioactive Materials
The whole body counting systems
and calibration techniques
were discussed
above in the Changes
section.
The two Canberra
systems
in use generate
individual reports of whole body depositions
of radioactive materials.
These
records
were placed in personal
dosimetry hard copy files and
entered in the
RRACS system.
During record reviews
no intakes greater
than 40 MPC-hr were, identified.
Air sampling data
was used with
individual stay times to calculate
exposures
to airborne radioactive
materials.
During tours
no evidence of nonrepresentative
air sampling
was identified.
Administrative Controls
The licensee
had established
administrative controls including
REP and
ALARA reviews designeC to limit and control exposures.
These
measures
had proved effective until the apparent
event of May 22-23,
1988
(See
Report Section 4.B.).
The licensee
had recently placed
additional
emphasis
on radiological work practices
by means of a video-
tape presentation
and written material.
Regular reports of individual
exposure
studies
were provided to various department
managers.
During
outages
these reports
were generated
and provided on a shiftly basis.
During tours
and surveys in all three units
no discrepancies
with posting
requirements
or control of access
were
identified.
18
Res irator
Protection
E ui ment
The licensee
had relocated
and expanded
the respiratory protection
equipment cleaning,
maintenance,
testing
and storage facility.
The
organization
was part of the
RP Support group consisting of a lead
technician,
two ANPP senior technicians
and one senior
and from 10-15
junior contractor technicians.
The new facility included
a newly
constructed respirator cleaning facility.
Units 1 and
2 had completed
installation of new service/breathing air systems
plumbed to the
containment.
The compressors
were oilless, Atlas Copco
IAN-C02
discharging to two receiver tanks
{XO-2A88).
The system
was designed
for
the addition of temporary compressors if required.
The system
was
equipped with low oxygen and high carbon monoxide monitors which alarmed
on the control
room Auxiliary System
Panel
7A and 7B.
Alarm response
procedure
42AL-2RK7B, in the control
room, provided as the first priority
action,
a pager
announcement
to all personnel
to remove themselves
to a
safe area
and disconnect
the breathing air.
The second priority was
a
call to
RP to verify that all personnel
using breathing air had heard
and
heeded
the announcement.
It was noted that the air compressor
was in the
turbine building.
No sources
of internal
combustion
engine exhaust
gases
or hazardous
gases
or materials
were, in the immediate area.
The licensee
had standardized
on
MSA filter, airline and
SCBA equipment.
The staff had been trained
and qualified in respirator
and
maintenance
and repair by the manufacturer.
Appropriate repair parts
and
equipment were labeled
and stored in separate
containers.
Following
completion of cleaning,
maintenance
and testing, respirators
were
individually plastic bagged
and sealed.
The respiratory protection group
issued respirators
to the units as required.
In the units respirators
were issued to authorized
persons
after the individual presented
a Palo
Verde Respirator Certification Card and the individual's qualifications
had been verified from a computer printout which listed the dates of the
last medical, fit test
and training.
The printout lists applicable
respirator size
and whether qualified for respirator and/or
SCBA.
Records
Re orts
and Noti'fications
The licensee
was continuing the use of the hard copy records
system
as
the legal record although the
RRACS was operable.
At the time of the
inspection the licensee
had verified that the
RRACS and hard copy records
were consistent.
All hard copy historical
records
were being transferred
to the
RRACS.
Approximately 34K of all whole body counting data
had been
transferred
to the
RRACS.
The contract worker full history files were
being transferred
to
RRACS, with about
GOX complete,
so that the
RRACS
could be used to generate
Termination Letters.
The goal for completion
was about July 1, 1988,
however the end of July was stated
by the
licensee
to be more realistic.
License records
were examined.
The "Fourth quarter
1987, Dosimetry Processing
Package,
Dose File Log,
Complete List of Personnel
TLD Readings,
Extremity Report, Audits,
Controls
and Unused
Badge Readings",
was reviewed.
19
During the fourth quarter 14,931
TLDs were used,
of which 11,146
showed
measurable
exposure.
These totals included 3,619 record whole body TLDs,
7,377 special
whole body TLDs, 226 neutron
305 TLDs used for controls, audits
and visitors.
Sixty-six individuals were assigned
skin doses for a total of 16;681
mrad.
Nineteen of these
were hot particle exposures
for a total of
13,179
mrad which included 11,280
mrad assigned
to extremities
and the
remaining 1,899 mrad as skin exposures.
The remainder
were related to
xenon exposure.
The 4th quarter total
gamma exposure
was 335.646
Rem plus '0.288
neutron for a total of 335.934
Rem.
Extremity dose totals in excess
of
whole body was
171. 264
Rem distributed
among
336 per sons.
The self
indicating dosimeter to TLD ratio was 1.027.
A total of 15 TLD readings
were revised
as
a result of dirt, moisture or loose phosphor.
Dosimetry comparisons
for gamma, interlab with Arizona State University,
Tempe,
AZ., were as follows:
6X low, standard
deviation 2X, intra'lab
comparison with ANPP,
6X low, standard
deviation
2X.
Neutron interlab
comparison with ANPP averaged
9X high, standard
deviation
14K.
The 4th quarter
1987 including annual total exposure
and 1st quar ter 1988
exposure
records
were reviewed.
All individuals with 1987 whole body
exposures
in excess
of 5
Rem and skin doses
in excess
of 3.75
Rem were
identified.
For this group neutron exposures
in 1987 and 1st quarter
1988 whole body, skin and neutron
exposures
were examined.
Individual
hard copy record files of all individuals with whole body exposures
> 5
Rem plus 1/3 of the remainder
(0.38K of the total
number monitored) were
examined.
The record review also included whole body counting records,
administrative approvals for increased
exposures,
forms NRC-4 and
termination reports.
The 1st quarter
1988 report was examined for extremity exposures,
neutron
exposures
and calculated
exposures.
A random sample
from the
"Contamination Reports,
Unit 1, Unit 2, Unit 3,
DAWPS, First quarter
1988," was reviewed.
The sampling indicated that the reports
were
complete.
The licensee
appeared
to be conducting
a technically sophisticated,
aggressive
and effective external
and internal dosimetry program.
No violations or deviations
were identified.
Maintainin
Occu ational
Ex osures
ALARA - Units 1
2 and
3
83728
Audits and
A
raisals
See
Report Section
6.
ALARA Pro
ram Chan
es
The licensee
reported that,the
ALARA committee
met recently for the first
time in about
8 months.
The principal concern
was the makeup of the."
20
committee.
Those positions identified as
ALARA committee
members
had all
been
removed
by the reorganization.
The matter was referred to the Plant
Review Board for a decision.
.
As a result of the reorganization
the
ALARA group
now interfaces with
five radiation protection
(RP) program organizations
(e. g. Units 1,
2 and
3,
RP Standards
and
RP Control) and with a number of different
maintenance
groups.
In response
the
ALARA staff was
made unit specific
with two staff members
assigned
to each unit.
The ALARA staff still
consists
of six engineers
and one supervisor.
For'initial refueling
outages
six ALARA contractors
were employed, with four planned for
subsequent
outages.
Worker Awareness
and Involvement
The licensee
had prepared
a videotape
on radiological work practices
which stressed
proper prejob preparation,
contamination control,
restoration of postings
removed for access,
alertness
to radiological
conditions
and attention to detail in general.
The tape presentation
(observed
in Unit 2) along with written material
were required viewing
and reading before access
to the controlled area
was permitted.
The
ALARA staff had obtained posters
to emphasize
ALARA concerns.
A cash
award program
had been
approved through the "Idea Line" to encourage
the
development of ALARA improvements.
The licensee's
General
Employee
Training program
had been modified to place increased
emphasis
on ALARA.
ALARA Goals
and
Ob ectives
The
PVNGS station goal for 1987 was
750 manrem.
The total exposure
was
690 manrem.
For
1988 the individual unit goals were 325,
450 and 100
manrem respectively for Units 1,
2 and 3.
The ALARA staff did not
believe that the Unit 2 goal
was achievable
since
dose rates
were found
to be higher than expected.
The Unit 2 outage
goal
was
325 manrem,
however
550 manrem
was believed to be more realistic.
A significant
portion of the exposure
was traceable
to two jobs.
nozzle
dams which failed to fit resulted in 50 manrem exposure
and the
need to pull the
a second
time to retorque the impeller nuts
incurred
a 25 manrem exposure.
ALARA Results
The total
manrem
dose for the facility was increasing
due to the fact
that Unit 3 first became operational
in 1987.
The licensee
however
effectively reduced the potential
dose through .the antimony removal
program and that contribution to total dose
should continue to decrease
with the removal of the source of antimony.
The licensee
experienced
a
significant contribution to outage
dose
as
a result of the presence
of
The planned
removal of'ome or all of the
on the
RCP impellers should result in a gradual
reduction of
dose
from that source.
The enquiry into the apparent
discussed
in Report Section 4.B. indicates that greater attention to
detail
on the part of the Unit 2 ALARA and
RP staffs could probably have
prevented
the apparent
There
was
some indication that the
21
present organization
may be reducing the effectiveness
of the
ALARA and
RP staffs
due to increased
operational
pressures.
No violations or deviations
were identified.
Occu ational
Ex osure Durin
Extended
Outa
es - Unit 2
83729
Audits and
A
raisals
See Report Section
6.
Chanches
The unit shut
down for refueling on February 19,
1988.
Just prior to
that time three
RP technicians
transferred
to the Central
RP group
and one technician
resigned.
The staff was four technicians
short when
the outage
began.
At the time of the inspection the vacant positions
had
been filled.
The remodeling of the access
control area
had been completed
and
had been
found to provide
a major
improvement.
Plannin
and Pre aration
The
same
methods
used for the Surveillance Test outage in February
1987
were attempted.
It was found that
some of the methods
were not
effective.
For example,
an attempt
was
made to prepare
REPs for all work
orders in advance.
It was found that this technique
was too cumbersome
and
a new system
was being sought.
The Unit 2 staff had reviewed Unit 1 experience with respect to the Unit
1 refueling outage.
The outage
began with 78 senior
and 34 junior RP
contractor technicians
and 25 decontamination
(five teams of 5
technicians with at least
one ANSI 3. 1 qualified technicians
on each
team).
The staffing at the time of the inspection
was
56 senior and
27
junior RP technicians with the
same number~f deconners.
Trainin
and
ualifications
The contract technicians
were onsite from one to three weeks before the
outage.
All contract technicians
provided resumes
and contractor
qualification cards.
All contract technicians
completed Site Access,
Radiological
Work Practices,
Respiratory
and Right to Know (Chemical
Hazards - Hazmat) training.
Station procedures
were reviewed by ANPP senior
RP technicians with the
contract technicians.
External
and Internal
Ex osure Control
See
Report Section
7.
No discrepancies
in the wearing of dosimetry devices
was noted during
tours of the containment, auxiliary, radwaste
and fuel handling
22
buildings.
An apparent
exposure
in excess
of regulatory requirements
which occurred during the inspection is reported in Report Section 4.8.
Maintainin
Occu ational
Ex osures
See
Report Section
8.
An unresolved
item concerning
an apparent
exposure
in excess
of
regulatory requirements
was identified as noted above.
Facilit
Tours
The inspectors
toured the identified areas
in Units 1,
2 and 3.
Location
Unit 1
Unit 2
Unit 3
Auxiliary Building .
Control
Room
Radwaste
Building
Fuel Handling Building
Turbine Building
Contaminated
Laundry Facility
Radiation Protection Instrument
Shop
and
Calibration Facility
X
X
X
X
X
X
X
Non-Unit related facilities included,
the chemistry training laboratory,
visitors center,. evaporation
ponds, water reclamation facility,
administration building and annex,
new respirator cleaning,
maintenance
and testing facility, the maintenance facility and the Dry Active Waste
Processing
(DAWP) facility.
In the units radiation surveys
were performed with an ion chamber
survey
instrument,
due for calibration August 10,
1988.
Postings
and control of access
were observed to be consistent with the
requirements
and Technical Specification
6. 12 ."High
Radiation Areas".
No violations or deviations
were identified.
Review of Licensee
Re orts
90713
Licensee reports
reviewed without onsite followup included:
"Palo Verde Nuclear Generating Station
(PVNGS) Units 1,
2 and
3 Annual
Radiological
Environmental
Operating
Report for 1987"
Our review of the 1987 Annual Environmental Monitoring Program
Report
shows that the Palo Verde Nuclear Generating Station provided their data
and analysis of radiol.ogical environmental
samples
and measurements,
made
during this period, in accordance
with the program as described
in
Technical Specifications
section 3/4. 12.
Comparison with preoperational
data
and previous environmental
surveillance reports
supported
the
licensee
s conclusion that airborne radioactivity, direct radiation,
food
crops,
and water,
among other dose
pathways
from the environment to man,
23
j) not significantly impact on plant environs.
Although the presence
of
I was noted in some milk samples,
a cross
check of the samples
showed
activity to be at or below the lower limit of detection
(LLD).
The dose
impact from the positive results,
however,
were negligible.
No
assessment
was
made relating to. trending since
no conclusions
could be
drawn from the data in this regard.
All sample results
reported
were
below regulatory reporting limits.
The annual
report included
maps
and results of PVNGS participation in the
EPA and Interlaboratory
Comparison
Program.
Achievements of LLDs at or
below the levels required
by the Technical Specifications
were noted.
Departures
from the air particulate monitoring program were addressed
in
the report.
No other program departures
were noted.
The annual
Land Use Census results
showed two changes
in the nearest
resident status.
No changes,
however,
were noted
as
a result of the 1987
Census.
No violations or deviations
were identified.
In-Office Review of Written Re orts of Nonroutine Events
90712
Licensee
Event Reports
(LER) and Special
Reports
(SR) related to
radiation protection
and chemistry matters
were reviewed.
The inspectors
verified that reporting requirements
had been satisfied,
causes
identified and that appropriate corrective'ctions
had been initiate'd or
completed.
These
reviews were completed without onsite followup.
Unit 1
1-SR-88-001
(88-01-XO)
50-528
1-SR-88"002
(88"02-XO)
Unit 2
50-529
LER, 2-87-021"'01 (87-21" L1)
2-SR-88-001
(88-01-XO)
2"SR-88"003
(88"03-XO)
2-SR-88-004
(88-04-XO)
Unit 3
'-SR-88-002
(88-02-XO)
50-530
No violations or deviations
were identified.
Exit Interview (30703)
The inspectors
met with the individuals denoted in paragraph
1 at the
conclusion of the inspection
on May 27, 1988.
The Senior
Radiation
Specialist
assigned
to Palo Verde was introduced.
The scope
and findings
of the inspection
were summarized.
The licensee
was informed that
apparent violations
had been identified in several
areas,
specifically;
Failure ta perform surveys prior to venting portions of the waste
gas
system resulting in the declaration of an Unusual
Event (Report
Section 3.B.);
An apparent
exposure
in excess
of regulatory requirements
on May
22-23,
1988 (Report Section 4.B.).
The licensee
was not informed
with respect to this matter that an apparent violation of 10 CFR 20.201 "Surveys"
was associated
with the apparent
(Report Section 4.B.);
Failure to properly br ace
and secure
shipments
of radioactive
waste'(Report
Section 4.C.).
The inspector
commented that preliminary results of the inspection
had
been discussed
with Messrs.
J.
Haynes,
Vice President, Nuclear Production
and
E.
E.
Van Brunt, Jr.,
Executive Vice President
in the days
immediately preceding the exit interview.
The inspector then stated that
he had informed the previously identified individuals that there appeared
to be an increasing
lack of attention to detail
and that the goal of
excellence
seemed to be lessened.
The inspector stated that it was
necessary
to correct this apparent trend.
I