ML17304A585
| ML17304A585 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/06/1988 |
| From: | Cillis M, Tenbrook W, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304A581 | List: |
| References | |
| 50-528-88-27, 50-529-88-26, 50-530-88-25, NUDOCS 8809300147 | |
| Download: ML17304A585 (28) | |
See also: IR 05000528/1988027
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos. 50-528/88-27,
50-529/88-26
and 50-530/88-25
Docket Nos. 50-528,
50-529
and 50-530
License
Nos.
and NPF-74
Licensee:
Arizona Nuclear
Power Project
P. 0.
Box 52304
Phoenix, Arizona
85072-2034
Facility Name:
Palo Verde Nuclear Generating Station,
Units 1,
2 and
3
Inspection at:
Palo Verde Site - Wintersburg, Arizona
Inspection
by:
Inspection
Conducted:
August 1-11,
1988
6 iLap
)s,
r.
a iat)on
pec~a
est
7C Ef
a
e
)gne
Approved by:
~Summer:
en roo
,
a
s
son
pecsa
>st
u
s,
ie
,
mergency
repare
ness
an
adiological Protection
Branch
te
cygne
a
e
cygne
Ins ection durin
the
eriod of Au ust 1-11
1988
Re ort Nos. 50-528/88-27,
and
-5 /
A~Id:
R
i
di
p
i
i
1 dig:
on prev>ous inspection findings; radiation protection, chemistry and radwaste
organization
and management; facilities and equipment;
review of LERs and
licensee
reports related to radiation protection matters;
and
a tour 'of the
licensee's facilities.
Inspection
procedures
30703,
83722,
83727,
92701
and
92702 were addressed.
88093VOlff/ VVVVV/
AQOCK 05000528
Q
-2-
Results:
The licensee's
ALARA (As Low As Reasonably
Achievable)
Committee
has
not carried out its responsibilities
as required
by procedure
(Section 2).
Members of the licensee's staff perceive that the reorganization of radiation
protection,
chemistry
and radwaste
personnel
has
reduced
the effectiveness
of
their respective
programs
(Section 3).
A new facility for respiratory
equipment
decontamination
and processing
had
been established
without a
required
10 CFR 50.59 safety evaluation
(Section 6.a).
Missing or improperly
maintained
posting
and barricades
were identified in the
Unit 2 auxiliary building Technical Specification 6.12 (Section 6.f).
The findings of this inspection
and other recent
inspections
indicate
a
declining trend in the radiological controls area, failure to take timely
corrective action in response
to licensee identified findings and
a
significant need for additional
high level licensee
management
involvement
and
oversight.
DETAILS
1.
Persons
Contacted
a.
Licensee Staff
- J
- W.
- J
- R
- J
- L
- J
- J
- T
- L
- E
- K.
- W.
- R.
R.
- D
J.
L.
T.
D.
T.
L.
J.
D. Driscoll, Assistant
Vice President,
Nuclear Production
Quinn, Director, Nuclear Safety
and Licensing
J. Scott, Acting Unit II Plant Manager
M. Butler, Director, Standards
and Technical
Support
M. Allen, Unit 1, Plant Manager
G. Papworth, Director, Quality Assurance/Quality
Control
R. Mann, Central
Radiation Protection
Manager
M. Sills, Manager Radiation Protection
and Chemistry
D. Shriver,
Compliance
Manager
A. Souza,
Manager, Quality Audits and Monitoring
D. Griswold, Acting Radiation Protection
Manager,
Unit 2
Oberdorf, Radiation Protection
Manager,
Unit
1
E. Sneed,
Radiation Protection
Manager, Unit 3
L. Selman,
ALARA Supervisor
V. Logan, Dosimetry Supervisor
Stover, Acting Nuclear Safety Department
Manager
C. Schlag,
Supervisor,
Radwaste
Standards
J. Grusecki,
Lead Radiation Protection Technician
Phillips,
OCS Engineer
Wickline, Operations
Engineer
Haggard,
Lead Radiation Protection Technician
Hughes,
Central
Radiation Protection Technician
B. Steward,
Standards
Radiation Protection
Engineer
Support
b.
Contractor Staff
A
lied Radiolo ical Controls
M. Hedgecock,
Senior Radiation Protection Technician
c.
Nuclear
Re ulator
Commission
T. J. Polich, Senior Resident
Inspector
Denotes
attendance
at the August ll, 1988, exit interview.
In addition, the inspectors
met and held discussions
with other licensee
and contractor personnel.
2.
Followu
of 0 en Items
and Items of Noncom liance
92701,
92702
0 en
Followu
(50-528/86-08-03 '0-529/87-19-01
50-530/87-19-01
.These
items concerned
the operability of the combustible
gas monitors in
the gaseous
radwaste
system
(GRS).
The licensee
continued to operate
in
a technical specification action statement
with regard to these monitors,
4
4
pending
NRC approval of a proposed
amendment
to the technical
specifications.
NRC is expected
to act
on the proposal
on or about
September
30,
1988.
Upon approval of the amendment,
the
GRS oxygen
monitors would be modified during the
1989 refueling outages.
Closed)
The inspectors verified that the
scensee
a
receive
an
was
eva uating/had
evaluated
the following
Information Notices:
IN No.
Tit1e
87-07
guality Control of Onsite Dewatering/Solidification Operations
by Outside Contractors
88-08
Chemical
Reactions with Radioactive
Maste Solidification Agents
88-22
Disposal of Sludge
from Onsite
Sewage
Treatment Facilities at
Nuclear Power Stations
These matters
are closed at Units I,
2 and 3.
0 en
Followu
(50-528/88-24-03
..An examination
was performed for the
purpose
o
eterm~n~ng
w at e
ect the reorganization of December
1987
had in the area of radiation protection,
chemistry and radwaste.
The
examination disclosed that the licensee's
performance
in the area of
radiation protection
and
ALARA had deteriorated
as is indicated
by the
findings in the subsequent
paragraphs
of this report and as identified in
Inspection
Reports
50-528/88-13
and 50-528/88-22.
This item will be
examined during
a subsequent
inspection.
Closed
Followu
50-529
GC-88-01
The inspector verified by a review
o
snspectson
reports t at t ese
>tems
had
been previously reviewed
and
closed.
0 en) Enforcement
50-529/88-22-01,
50-529/88-22-02
These
items concerned
the apparent
of a Unit 2 contract
worker during the second
calendar quarter of 1988.
The licensee
reported
the event in Licensee
Event Report
(LER) 88-011-LO, dated
June
22,
1988.
The licensee's
staff performed
an evaluation of the event.
The results
of the evaluation
were documented
in the licensee's
Special
Plant Event
Evaluation Report
(SPEER)
Ho. 88-02-004,
dated July 7, 1988.
Additional
information related to this matter
was provided in Region
V Inspection
Reports
50-529/88-14
and 50-529/88-22.
The licensee
acknowledged
the
violations contained
in Inspection
Report 50-529/88-22 during an
enforcement
conference
held in the Region
V office, August 17,
1988.
A.
~8ack round
The Region
V onsite examination of this event continued during this
inspection period.
The examination disclosed
the following
information:'
A recent licensee guality Assurance
audit found deficiencies
in the
licensee
s ALARA program.
The guality Assurance deficiencies
were
not reflected in the
SPEER report.
The guality Assurance
audit had
concluded that the
ALARA objectives
and work practices
were not
being adequately
met.
Specifically, the audit report dated
May 26,
1988, stated that the ALARA program
was not completely in compliance
with Regulatory
Guides 8.8, 8. 10,
and
The report
identified that monthly ALARA committee meetings
had not been held
in over
a year.
The
SPEER identified that the planning for the job was
incomplete
and insufficient to prevent the overexposure
of the contractor.
Based
on the above information, the inspector held additional
discussions
with personnel
involved in the overexposure,
reviewed
the licensee's
ALARA implementing procedures
and other licensee
documents
related to the overexposure
event for the purpose of
verifying the previous
information and to determine
what involvement
the guality Assurance
Group had
had in the
ALARA program prior to
the overexposure.
Controllin
Documents
10 CFR Part 20.1(c) requires that licensee's
engaged
in activities
under licenses
issued
by the Nuclear Regulatory
Commission
make
every reasonable effort to maintain radiation exposures
as
low as is
reasonably
achievable.
Technical Specifications 6.8.1 requires
in part that, "Written
procedures
shall be...implemented...covering
procedures
referenced
below:
a.
The applicable
procedures
recommended
in Appendix A of
Regulatory Guide 1.33, Revision 2, February
1978, ...."
Regulatory
Guide 1.33, Appendix A, Section 7.e(9), requires
procedures
addressing
implementation of an ALARA Program.
Procedure
75PR-9ZZ03 Section
5. 1,
"Management
Commitment" states
in
part:
"ALARA Public Service upper leve'I management
is firmly
committed to an aggressive
ALARA program..."
Procedures
and other documents
reviewed are
as follows:
(1)
Procedure
"ALARA Program"
(2)
Procedure
"ALARA Committee"
(3)
Procedure
"ALARA Pre Job Review"
(4)
Procedure
.75RP-9ZZ97,
"ALARA Post Job Review"
(5)
ALARA Prejob Review records for 1987
and
1988
(6)
ANPP Letter, dated
June
15,
1988, from a Unit 2 Lead Technician
to the Unit 2 Radiation Protection
Manager
(7)
ANPP Letter No. 215-00555-JRM/JMS/RDM,
dated July 29,
1988
(8)
LER 88-011-00,
dated
June
22,
1988
(9)
ALARA 1987 Annual Report
(10)
ANPP Letter No. 222-00152-RBO/JH,
dated
March 21,
1988
(11) Regulatory Guide 8.8, "Information Relevant to Ensuring that
Occupational
Exposures
at Nuclear
Power Stations will be
ALARA."
(12)
ANPP Letter No. 215-00526-JRM,
dated
June
15,
1988
(13)
ANPP Letter from a Unit 2 Lead Radiation Protection Technician
dated August 6, 1988, with ANPP Letter No. 215-00514-JRM/RLS,
dated
May 20,
1988,
as
an attachment.
(14)
ANPP Letter No. 222-00287-JMS/JLH,
dated July 20,
1988
(15)
ANPP Letter No. 030-00906-LAS/DAH/CTS, dated
May 26,
1988
C.
Procedural
Re uirements/Commitments
(1)
Procedure
75AC-9ZZ05, Revision 2, dated
November 26,
1986
establishes
an
ALARA Committee
composed of the following
members:
1
The Manager of Radiation Protection
and Chemistry-
Chairman
2
The ALARA Supervisor - Alternate Chairman
3
The Compliance
Manager
4
The Manager of Operations
5
The Manager of the Maintenance
Department
6
The Manager of the
PVNGS Operations
Engineering
Department
7
The Manager of Outage
Management
8
The Radiological Services
Manager
9
The Radioactive Material Control Manager
10
The Chemistry Services
Manager
11
A Corporate
ALARA Representative
12
The Nuclear Construction
Manager
13
The Plant Services
Manager
The procedure
also requires that alternate
members
be
designated
in writing by the department
members.
Section 4.0
of the procedure identifies
a list of eleven
items for which
the ALARA Committee
have responsibility.
Section 5.2. 1 states
in part:
"The ALARA Committee should meet at least monthly at
the discretion of the ALARA Committee Chairman."
~Findin s:
The
ALARA committee
had
gone through
two refueling
outages
without conducting
a meeting.
The ALARA
supervisor stated that the last ALARA Committee
meeting
was held in March 1987.
Many ALARA Committee
members
had
been assigned
new
responsibilities
between
November
1987 and Apri1
1988.
No action
was
taken to redesignate
the
Committee's
membership until May 1988.
The ALARA
Committee
Chairman
had submitted his resignation
in
January
1988.
The Chairman's
termination
became
effective in April 1988.
At the time of this inspection
the ALARA Supervisor
informed the inspector that there were only three of
thirteen alternate
ALARA Committee
members that were
designated
in writing.
The ALARA supervisor
stated that the
ALARA Committee
stopped functioning as
a group since March
1987 and
could not have functioned
as
a group because
of the
reorganization of December
1988.
The ALARA
supervisor
added that
he
had verbally informed the
ALARA Committee
Chairman
on numerous
occasions
between
March 1987 and April 1988 that the
comnittee responsibilities
were not being
implemented.
The supervisor
added that other
Committee
members
were aware of the situation
and
no
one
had informed management
of the situation until
May 1988 (see
paragraph
D, below).
a
2.
Procedure
75RP-9ZZ94 states
in part:
"... 6.1.3.4
6.1.3.5
If the final man-rem estimate is less
than
10,
the
ALARA Supervisor
shou Id review and approve
all formal
ALARA reviews, final man-rem
estimates,
and pre-job briefing checklists
as
soon
as practical.
If the final man-rem estimate is greater
than
10, the ALARA Supervisor will complete
the ALARA
Evaluation
Form (Appendix D) and will forward
both the Prejob-Review
Form and the
Evaluation
Form to the Chairman of the ALARA
Committee for final review and approval....
6.1.4.5
Findings
The ALARA Representative
shall also perform
a
final man-rem estimate.
If the estimate
is
10
man-rem or greater,
the pre-job review shall
be
forwarded to the
ALARA Committee,
by the
Supervisor, for their review and approval."
During 1987, of 126 jobs requiring pre-job review and
approval of the
ALARA supervisor,
approximately
61 were
not reviewed
and approved.
For 1988 of 73 jobs,
50 were
not reviewed
and approved.
In 1987, there were eleven pre-job estimates
of greater
than
10 man-rem.
Two of the eleven
had not received
the
final review and approval of the ALARA Committee
Chairman.
In 1988, there were eight pre-job estimates
of greater
than
10 man-rem
and two of the eight had not been reviewed
and approved
by the
ALARA Committee Chairman.
In 1987, there were eleven pre-job estimates
of greater
'han
10 man-rem.
None of the eleven were reviewed
and
approved
in advance
by the
ALARA Committee.
In 1988, to
the date of the inspection,
there were eight pre-job
estimates
of greater
than
10 man-rem.
None of the eight
were approved in advance
by the ALARA Committee.
The
eight included the pre-job estimate that involved the work
performed
by the individual that was overexposed.
3.
Procedure
75RP-9ZZ97 states
in part:
The ALARA supervisor shall determine whether
a post-job review
is required for jobs with exposures
of 1.0 man-rem to 10.0
man-rem.
Jobs with exposures
of 10.0 man-rem or more shall
be
reviewed
and
a presentation
of the review shall
be
made to the
ALARA Committee.
~Findin:
In 1987, there were nine (9) jobs with exposures
in
excess of 10 man-rem
and
as of August 11,
1988
a
presentation
of the post job reviews
had not been
made to the ALARA Coranittee.
4.
Procedure
75PR-9ZZ03 states
in part:
"...5.9
Program Evaluation
An annual
evaluation of the
ALARA Program's
effectiveness
shall
be performed to ensure
a
continuing commitment to maintaining personnel
radiation exposure
The ALARA Supervisor shall
be responsible for assimilating
the information
provided
by the Radiological Services
Manager,
0
~Findin:
Licensee Audit
preparing
the evaluation
and making recommendations
for program
improvement
based
on this information.
The
PVNGS Plant Manager
and the Vice President of
Nuclear Production shall review and approve,
as
appropriate,
the evaluation
and any recommended
improvements...."
An evaluation
was not performed for 1987.
The ALARA
supervisor stated that he had
recommended
that the
evaluation
be performed
by an independent
group.
He
added that he had prepared
to have the evaluation
conducted
by an independent
group; however,
the
contract
was subsequently
cancelled.
A review of references
B(10) and B(15) above disclosed that the
licensee's
Radiation Protection
and Chemistry Standards
group and
guality Assurance
group
had performed
a review of the ALARA program
in February
and April 1988.
Both audits
had identified similar
conditions discussed
in paragraph
C, above.
Reference
B(10) had
been submitted to the
ALARA Committee Chairman,
Standards
and
Technical
Support Director and Central
Radiation Protection
Manager.
The text of the report states
that
a potential
item of noncompliance
was identified.
The item referred to was the lack of the monthly
meetings.
The concluding statement
in the report appears
contradictory in that it states
that the
ALARA program is fully
established
and in compliance with NRC Regulatory Guide 8.8
guidelines.
The Director of Standards
and Technical
Support
concluded that the
ALARA program
was being implemented.
The
Director of Standards felt that there were
no major problems with
the ALARA program based
on the concluding statement
in the report;
therefore,
no immediate corrective actions
were taken to resolve the
findings identified in reference
B(10).
The guality Assurance audit reference
B(15), which was dated
May 26,
1988 was debriefed with the licensee's
staff on April 27,
1988.
Both the ALARA Chairman
and alternate
ALARA Chairman
were in
attendance
at the debriefing.
Distribution of the audit report to
upper management
was not made until May 26,
1988.
The quality
Assurance audit report had identified the
same
problems identified
by the audit performed
by the Radiation Protection
and Chemistry
Standards
audit.
The guality Assurance
audit findings were
documented
in CAR No. CA88-0036.
The
CAR reported
the findings
discussed
in paragraph
(A)-above.
The licensee
response
to the
was
made
on June
10,
1988.
The response
revealed that
an attempt
was
made to conduct
an
ALARA Committee meeting
on May 9,
1988,
however,
no quorum was achieved,
and
a second
meeting
was scheduled
for May 11,
1988; again
no quorum was achieved.
Subsequently,
the
ALARA committee procedure
was revised to clearly define the ALARA
Committee membership
and
ALARA Committee meetings
were held on June
24,
1988, July 20,
1988 and August 5,
1988.
The three meetings
have
been
devoted to reestablishing
the
ALARA committee responsibilities
that had
been
ignored for the previous
15 months.
E'.
Miscellaneous
Information
The pre-job review for the work involving the contractor that
had received
the overexposure
disclosed that the man-rem
estimate
was calculated
to be 12.0 man-rem.
The ALARA
Committee did not review and approve
the pre-job review package
prior to performing the work as required
by reference
B(3),
above.
(2)
This observation
was discussed
with the licensee's
staff.
The
licensee
stated that the ALARA Committee's
review and approval
in itself would not have prevented
the overexposure
since it
was decided at
a meeting held
on May 20,
1988, that the job
could
be done safely.
Personnel
in attendance
at the meeting
included:
ALARA Supervisor,
Unit 2 Work Control Manager, Unit
2 Radiation Protection
Manager, Unit 2 Plant Manager
and
Committee Chairman.
The inspector
informed the staff that the
attachment
to reference
B(13), also dated
May 20,
1988,
and
prepared
by the ALARA Supervisor
and approved
by the ALARA
Committee
Chairman stated
in part:
"Due to the high dose
rates,
I feel the proposed
plan will not work and will cause
further delays
in the outage."
The ALARA supervisor
recommends
that the water level
be raised in the upender pit to place the
underwater
vacuum under water,
and the pit be vacuumed prior to
drain down."
The statement,
"the proposed
plan will not work"
referred to the licensee's
plan to apply and
remove strippable
paint in the upender pit.
The inspector stated that it
appeared
that there
were
some doubts
as to whether or not the
job could
be done safety which had
been
expressed
by several
other members of the licensee's
Radiation Protection
and
work group staff.-
The inspector
was informed that the letter
attached
to reference
B(13) had not been officially issued.
The ALARA supervisor
and
ALARA Committee
Chairman stated that
the letter was typed and signed
on May 19,
1988.
It was their
intention to make the recommendations
discussed
in the letter;
however, after attending
the meeting of May 20,
1988, they had
changed their minds
and thought that they had retracted
the
letter.
The ALARA Supervisor
suspected
that
a copy of the
letter was
made
by an individual he had discussed it with and
shown it to.
Both the ALARA supervisor
and
ALARA Corrmittee
chairman stated that their decision of May 20 to proceed with
the work was
based
on
a review of survey data which
subsequently
turned out to be inadequate
and on information
presented
by other individuals that attended
the May 20
meeting.
The inspection disclosed that
some
key individuals involved in
the job planning,
review and approval of work had not visited
the work area
where the worker received
the overexposure.
Some
had only made
one entry into the containment building the
(3)
(~)
(5)
entire month of May.
The maximum number of entries
into the
containment
by some of the key individuals involved was four.
At least
two members of the ALARA group informed the inspector
that they had verbally expressed
an opinion that painting the
refueling pit was not necessary.
Several
members of the
radiation protection
group had voiced
a similar opinion;
however,
none of the individuals, including the
Lead Radiation
Protection Technician
and the contract Radiation Protection
Technician covering the work on the day that the overexposure
occurred,
made
an effort to officially stop the work in
accordance
with station procedures.
This was identified in
NRC
Inspection
Report 50-529/88-22
and the licensee's
evaluation.
The
SPEER did not address
the status of the licensee's
program discussed
herein.
The
SPEER states
that the
reviewer was remiss
because it was felt that
he could have
been
more involved in the pre job planning.
The
SPEER did not
address
the lack of involvement by the
ALARA Committee.
The
SPEER identified that the assigned
ARC Radiation Protection
Technician performed the functions of Radiation Protection
Technician
and decontamination
foreman for the job,
Reference
B(7) was
issued
on July 29,
1988,
as
a result of this finding.
The letter essentially
requested
that workers should not be
assigned
to perform dual responsibilities.
On August 9, 1988,
the inspector
spoke to two workers working in the Unit 2
Auxiliary Building.
The
ARC Radiation Protection Technician
that had provided the coverage
during the work involving the
was providing radiation protection
coverage
for
the August
9 job.
The workers informed the inspector that the
ARC Radiation Protection Technician
was also the
Foreman for
the job.
Based
on
a further discussion with the contract Radiation
Protection Technician,
the observation
regarding
a second rapid
rise
on the teledosimetry
device
was determined
to be incorrect
due to
a misunderstanding
on the part of the
NRC inspector.
The exposed
individual was told to exit the area
based
on the
expiration of his staytime.
The teledosimetry
device
had only
registered
a rapidly increasing
dose
on one occasion,
not two
as is indicated
on page
5 of Inspection
Report 50-529/88-22.
F.
Conclusions
The inspector discussed
the above observations
with the licensee's
staff.
The staff acknowledged
the inspector's
observations.
The
following areas
were discussed:
Failure of the ALARA program to function in accordance
with
ALARA implementing procedures.
Failure of key staff members
to notify management
of the
deterior'ation of the
ALARA program in a timely manner.
10
Failure to take timely corrective actions.
Failure of the licensee's
investigation (e.g.
SPEER)
to surface
the findings identified by licensee
internal audits
and the
inspector.
The failure of the
ALARA Committee
and other portions of the
ALARA program
may be germane
to the overexposure
event.
The licensee's
staff acknowledged
the inspectors
observations.
The
staff felt that the failure of the
ALARA Committee did not have
a
direct affect on the overexposure
of May 23,
1988.
The inspector
informed the licensee
that failure to implement the
ALARA program procedura'1
requirements
as described
in paragraph
(c)
above
was
an apparent violation (50-528/88-27-01,
50-529/88-26-01
and 50-530/88-25-01).
3.
Radiation Protection,
Plant Chemistr
, and Radwaste:
Or anization
and
ana
ement Contro
s
An examination
was conducted
to determinine if the licensee's
radiation
protection,
chemistry
and radwaste
groups
are organized,
staffed
and
motivated to effectively control radiation, radioactive material
and
plant chemistry.
Discussion related to this subject
were held with the
Manager,
Central
Radiation Protection
and the inspector
reviewed
applicable portions of Region
V Inspection
Reports
50-528/87-24
and
50-528/88-13.
The examination disclosed that the organizational
structure
had not
changed
from what is discussed
in Inspection
Reports
50-528/87-24
and
50-529/88-13.
The Manager,
Central Radiation Protection is designated
as
the acting Regulatory Guide 1.8 qualified Radiation Protection
Manager
pursuant to the operating license for Units I, 2 and 3.
This position
was previously held by the Manager,
Radiation Protection
and Chemistry
(RP8C),
who resigned
in April 1988.
The central
RPM does
not have any
direct supervisory authority over each of the
RPMs assigned
in Units I, 2
and
3 even
though Section 4.6.1. 1 of procedure
"Radiation
Protection
Program" states
that the site
RPM is responsible
for ensuring
the radiation protection
program
and station operations
meet the
radiation protection requirements
10
CFR Part
20 and
The acting central
RPb) stated
that he held
weekly meetings with each of the Unit RPMs to ensure
the station
radiation protection requirements
were being met.
Procedure
75PR-OZZOI assigns
each of the Unit Managers
the responsibility
and authority for implementing the Unit Radiation Protection
Program.
The examination also disclosed:
t
Not all of the Unit RPMs meet Regulatory
Guide 1.8 qualification
requirements.
11
The Radiation Protection
Standards
supervisor
was assigned
as acting
Manager,
Radiation Protection
and Chemistry.
The acting Manager,
RP&C has
been assigned
as
a back
up central
RPM;
Weekly counter-part
meetings
in the area of Chemistry are not
normally held with each of the Unit 1,
2 and
3 Chemistry Managers.
The Director, Standards
and Technical
Support stated that
a program,
similar to that adopted
by the Site
RPM, is being considered
in the
Chemistry area to ensure
consistency
and to ensure that the
Chemistry program requirements
are being met.
Staffing in the area of Chemistry,
Radiation Protection
and Radwaste
was consistent with licensee's
procedures.
The inspector
concluded that the licensee's
organization
was consistent
with Technical Specifications 6.2 as
amended
in December of 1987.
The
amendment
involved a complete reorganization of the Radiation Protection,
Chemistry and Radwaste
organizations,
as described
in the Inspection
Reports
referenced
herein.
Many members
(e.g. fifteen to twenty) of the licensee's staff expressed
their opinion to the inspector that the reorganization
has
had
a negative
effect on the radiation protection,
chemistry and radwaste
groups.
The
opinions were not solicited by the inspector.
The staff members (i.e.
from management
level to working level) freely expressed
their personal
opinions that they felt the reorganization
was not working well and the
effectiveness
of the programs
had been
reduced.
This observation
was brought to the licensee's
attention at the exit
interview.
4.
Units
1
2 and
3 Facilities
(83727
The radiation protection,
radwaste,
'laundry and chemistry laboratory
areas
of the three units were toured during the inspection.
Discussion
with the plant staff'evealed
that
a
new respiratory processing facility
was placed in service
on or about July 28,
1988 (see
paragraph
7,
herein).
The respiratory processing facility represents
a change
from
what was previously reported in Region
V Inspection
Reports
50-528/87-18,
50-529/87-19
and 50-530/87-20.
The licensee 'ry Act.ve Waste Processing
and Storage
(DAWPS) facility
was a'Iso placed in service since this subject
was last examined.
A
description of the
DAWPS is provided in Section 11.4.2.5 of the Updated
Final Safety Analysis Report.
Discussions
with the licensee's staff revealed that
no further additions
or major changes
in radiation protection facilities are being planned for
or considered.
The staff stated that current facilities appear
to
adequately
support the radiation protection
program.
5.
Onsite Followu
of Re orts of Nonroutine Events
92700
Closed
Licensee
Event
Re ort 50-529/88-07-LO
4
I
i
12
This report concerned
an actuation of the fuel building essential
ventilation system
(FBEVS) and control
room essential
ventilation system
(CREVS) by a fuel building ventilation exhaust radiation monitor (RU-145)
mal function.
Engineered
safety features
functioned
as designed.
The
inspector verified that the fuel building was evacuated,
locked and
posted
upon
FBEVS actuation
and control
room recognition of a saturation
indication on RU-145.
No fuel movements
occurred while RU-145 and
RU-146
were inoperable.
Gas
were obtained shiftly while the
monitors were inoperable,
as required..
The faulty system microprocessor
board
was replaced,
and
no further problems
had been observed.
An
Engineering Evaluation Request
(EER)
had
been
issued for a previous
system
board malfunction observed
during
a functional test of the
monitor.
The System E'ngineer stated that root cause of failure of the
system
board for the
FBEVS actuation
event would be determined
under the
prior EER.
This item is closed.
The inspectors
conducted
several
tours of Units
1 and
2 radiologically
controlled areas,
outside radioactive material
storage
areas
adjacent
to
Units 1,
2 and 3,
and of the respiratory processing facility located in
trailers 3-2 and 41.
Independent
radiation measurements
were conducted
using
a Model
RO-2 ion chamber survey instrument,
Serial
82691,
due for
calibration
on October
14,
1988.
The inspectors
made the following observations:
a.
The stripchart for the Eberline
AMS-3 monitoring Trailer 3-2 exhaust
had apparently
run out during the weekend of July 30 - August 1,
1988.
The licensee's
staff immediately replaced
the strip chart
after it was brought to their attention
by the inspector.
Discussions
held with the licensee's
staff disclosed that Trailer
3-2 was recently modified for the purpose of decontaminating
and
processing of respiratory equipment that are required for reuse.
The inspector
was informed that Trailer 3-2 was put into service
on
or about July 28,
1988.
The trailer is equipped with all of the
necessary
equipment
needed for cleaning
and processing
respiratory
equipment that are
used site wide.
Previously, this function was
performed in a mobile laboratory.
The trailer is equipped with its
own
HVAC system which is continuously monitored with an Eberline
AVES-3 continuous air monitoring system.
Respirators
requiring
processing
are stored in the facility until such time that they are
returned to the units for reuse.
10 CFR 50.59(b)(1) states
4a part, that:
"The licensee
shall
maintain records of changes
in the facility...made pursuant
to this
section,
to the extent that these
changes
constitute
changes
in the
facility as described
in the safety analysis report....
These
records
must include
a written evaluation...."
Sections
11.4
and 12.5 of the licensee's
Final Safety Analysis
Report
(FSAR) identify systems
and facilities that are within the
13
site boundary that have
been
approved for handling
and processing
of
radioactively contaminated material.
Contrary to the above, Trailer 3-2 was recently converted into a
respiratory processing facility.
At the time of this inspection,
the trailer was being used to temporarily store
and process
radioactively contaminated
respirators.
As of August ll, 1988, the
licensee
had not performed
a written safety evaluation
addressing
the processing of radioactive
equipment
in Trailer 3-2.
This observation
was brought to the licensee's
attention
who agreed
that
a safety evaluation
should
have
been performed.
The inspector
was
informed that the licensee's
staff has
been
requested
to perform
a written safety evaluation.
The inspector
informed the licensee
that failure to perform the written evaluation
was
an apparent
violation (50-528/88-27-02,
50-529/88-26-02,
50-530/88-25-02).
. b.
10 CFR Part 19. 11, "Posting of Notices to Workers", states
in part:
"(a)
Each licensee
shall post current copies of the following
documents..."-
"...(4)
Any notice of violation involving radiological working
II
conditions, ...
"...(d)
Documents,
notices,
or forms posted pursuant to this
section shall appear in
a sufficient number of places
to permit
individuals engaged
in licensed activities to observe
them
on the
way to or from any particular licensed activity location to which
the document applies,
shall
be conspicuous,
and shall
be replaced if
defaced or altered.
"(e)
Commission
documents
posted pursuant
to paragraph
(a)(4) of
this section shall
be posted within 2 working days after receipt of
the documents
from the Commission;
the licensee's,response,
if any,
shall
be posted within 2 working days after dispatch
by the
licensee.
Such
documents
shall
remain posted for a minimum of 5
working days or until action correcting the violation has
been
completed,
whichever is later."
On August 4, 1988,
the inspectors
noted that copies of a Notice of
Violation accompanying
Inspection
Report 50-529/88-14
dated July ~,
1988,
and the licensee's
response
to the
NOY, dated August 1, 1988,
were not posted
on the way to licensed activity locations within
Units 1,
2 and 3.
Discussions
held with the licensee's
staff and
a
review of the inspection report revealed
the following:
The violations identified in the
NOV involved:
(1)
a shipment
of radioactive
waste which arrived at the burial site with
loose chain restraints,
and the shipment
was observed
to have
shifted during shipment
as evidenced
by loosened
or broken
bracing,
and (2) the failure to perform an evaluation prior to
a release
of 15.3 curies of noble gases
that had
been vented
from portions of the gaseous
radwaste
system.
4
14
C.
The licensee's
Compliance Supervisor stated that
he had
reviewed the
NOV and determined that the violation, as
described
in Appendix A, did not involve
a violation of
radiological working conditions.
He concluded that no
Technical Specifications limits were exceeded
and the release
did not have
any effect on workers within or outside
the site
boundary.
The inspector. noted that the text of the inspection
report revealed that the release
involved the venting the
gaseous
radwaste
system
by the depressurization
through drain
valves to the Radwaste
Building Sump.
It is believed that the
released
noble gases
flowed from the
sump through the drain
system to the
140 foot elevation
and into the
HVAC system to
the plant vent.
The inspector
concluded that radiological
working conditions of the plant workers could have
been
affected; but, agrees
that the release
was not that significant
and that
no plant workers
became
contaminated.
The inspector discussed
the above observation with the
Compliance supervisor
and at the exit interview.
The
Compliance supervisor
iranediately posted
the
NOV and
implemented
a policy that all
NOV involving radiation
protection activities would be posted
in the future.
The
inspector
concluded that the licensee's
actions
were both
appropriate
and timely under the circumstances.
The inspector
noted
some inconsistencies
in the policies established
in radiation protection
programs
being implemented at Units
1 and 2.
The inspector noted that Unit 2 unit allows personnel
to don
protective clothing (PC) at various satellite stations
located at
various locations within the controlled area,
such
as
the Radwaste
Building.
The Unit
1 Radiation Protection
Manager
does
not allow
workers to use satellite stations for donning protective clothing.
Personnel
required to don
PCs in unit
1 must
don their clothing at
the radiation protection control entry point.
Similarly, one Unit
displays instructions for the removal of PC's while another Unit has
done
away with the posted instructions.
These observations
were brought to the attention of the licensee's
staff during the inspection
and at the exit interview.
d.
No unmonitored personnel
were observed
in the areas
that were
toured.
e.
All portable radiation detection
instruments
observed
were in
current calibration.
On August 9, 1988, the inspector
noted
some inconsistencies
in the
barricading
and posting of high radiation
and contaminated
areas
located in Unit 2 "A" and "B" Shutdown Cooling Pipe Gallery and Heat
Exchanger
rooms.
The following observations
were made.
(1)
The outlet end of the Unit 2 "A" Shutdown
Heat exchanger
had
whole body radiation levels of 140 mrem/hr at eighteen
inches.
The area
was not barricaded
in that the installed barricade
had
0
15
come loose
from the heat
exchanger
casing
and part of it was
on
the floor.
(2)
Radiation levels of 120 mrem/hr at eighteen
inches
from Unit 2
"B" Shutdown cooling valve S1B-V910 were not conspicuously
posted
and one side
was, not barricaded.
(3)
Radiation levels of 150 mrem/hr at eighteen
inches
from Unit 2
"A" Shutdown Cooling valve SlA-V172 and piping EW-UV65 were not
conspicuously
posted
and two sides of the area
were not
barricaded.
One side, consisting of a four to five foot pipe
opening adjacent
to this area,
had not been
posted
at all.
The opening provided access
to both the high radiation
area
and
a contaminated
area
located in the pipe gallery side
of the Heat Exchanger.
The inspector
noted that personnel
could have entered
areas
(2) and
(3) without observing
the one sign that was installed in both areas.
The inspector notified the acting Radiation Protection
Manager
who
took immediate action to have the area
resurveyed
and reposted.
Independent
radiation mea'surements
were obtained
by the
RPM with an
identical survey instrument
used
by the inspector.
The licensee's
radiation measurements
were in agreement with the inspector's.
The
RPM stated that the areas
had not been properly posted,
as
prescribed
in station radiation protection procedures.
The
subsequently
reported that one barricade
in "A" Heat Exchanger
pipe
gallery (e.g.
item (3), above),
had
become
loose,and
part of it was
on the floor.
Technical Specifications,
6. 12. 1 states,
in part:
"In lieu of the "control devices" or "alarm signal" required
by
paragraph
20.203(c)(2) of 10 CFR Part 20,
each high radiation area
in which the dose rate is greater
than
100 mrem/hr but less
than
1000 mrem/hr shall
be barricaded
and conspicuously
posted.
Additionally,'icensee
procedure
75RP-OZZOl, "Radiological Posting",
Section 6. 1, requires that radiologically controlled areas
shall
be
identified by prominently displayed
signs at all accessible
sides,
specifying the types of hazards
(e.g. radiation, airborne,
contaminated,
etc.).
Section 6.2 of the procedure
requires
that
radiation
p) otection shall
segregate
radio'logically controlled area
by enclosing
the area
boundaries
with magenta
and yellow ribbon,
rope or tape.
The above observations
were brought to the licensee 's attention at
the exit interview.
The licensee's
staff acknowledged
the
inspectors
observations.
The inspector
informed the licensee that
failure to conspicuously
post
and barricade
was
an apparent violation (50-529/88-26-03).
7.
Exit Interview
e
16
The inspectors
met with the individuals denoted
in paragraph
1 at the
completion of the inspection
on August 11,
1988.
The scope
and findings
of the inspection
were summarized.
The licensee
was informed of the
apparent violations discussed
in paragraphs
2, 6(a)
and 6(f).
The inspector
informed the licensee
that the apparent violations
discussed
in paragraphs
2 and 6(f) would be discussed
during the August
17,
1988,
Enforcement
Conference
and the apparent violation discussed
in
paragraph
6(a) would be addressed
in this inspection report.
The licensee
acknowledged
the apparent violations.