ML17304B270
| ML17304B270 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/02/1989 |
| From: | Scarano R, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B267 | List: |
| References | |
| 50-528-89-25, 50-529-89-25, 50-530-89-25, NUDOCS 8906270060 | |
| Download: ML17304B270 (14) | |
See also: IR 05000528/1989025
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
Nos.
50-528/89-25,
50-529/89-25
and 50-530/89-25
Docket Nos.
50-528,
50-529 and 50-530
License
Nos.
NPF-51 and
Licensee:
Arizona Public Service
Company
P.
0.
Box 53999
Phoenix, Arizona
85072-3999
Facility Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection at:
Wintersburg,
Inspection
Conducted:
May 15-18,
1989
Inspected
by:
.
G.
P.
Yu as,
Chief
Emerg icy Preparedness
and Radiological
Pro ection Branch
Date Signed
Approved by:
oss
A. Scarano; Director
Division of Radiation Safety
and Safeguards
Date Signed
~Summar:
This was
a special
unannounced
inspection
by a regional
based
manager to
review implementation of the occupational
radiation protection program
oversight function during outage conditions at Unit 1 and to review matters
described
in allegation
RV-89-A-0025.
Inspection procedures
30703,
83729
and
93001 were utilized.
Results:
One apparent violation involving failure to post
a high radiation
area at Unit 1 was identified and
one occupational
health
and safety concern
related to egress
from the Unit 1 containment building was brought to the
licensees'ttention
(paragraph
2).
No evidence to 'substantiate
the concern
expressed
in allegation
no.
RV-89-A-0025 was identified.
While the
radiological controls program being implemented to support the Unit 1 outage
was satisfactory,
the level of management
attention in developing
and
implementing the oversight function appears
to have. been less satisfactory.
Specifically the lack of management
direction, and poor communications early in
the outage resulted in considerable
frustration
among work groups,
declining
morale in the radiation protection organization
and the perception
by some
workers that they may be reprimanded for bringing safety concerns
to the
NRC's
attention.
8906270060
890607
ADOCK 05000528
6
PNU
tee
J
DETAILS
1 ~
Persons
Contacted:
a.
Licensee
Re resentatives:
W.
F.
Conway,
Executive Vice President,
Nuclear
D.
B. Karner, Executive Vice President
R.
W. Waught,
El
Paso Electric, Assistant Vice President
W.
C. Marsh, Plant Director
J.
E. Kirby, Director
C.
N.
Russo,
Assistant Director,
QA/QC
W.
E. Ide, Unit 1, Plant Manager
T. Shriver,
Compliance
Manager
K. Oberdorf, Unit 1, Radiation Protection
Manager
W.
E.
Sneed,
Unit 3, Radiation Protection
Manager
P.
W. Hughes,
Central
Radiation Protection
and Chemistry Manager
R.
V. Warnock,
Southern California Edison
Company
b.
NRC
T. Polich, Senior Resident
Inspector
D.
Coe,
Resident
Inspector
In addition, the inspector
met and held discussions
with other licensee
and contractor personnel.
2.
Occu ational
Ex osure Durin
Outa
es
(83729)
The focus of this inspection effort was to observe
implementation of the
licensee's
radiation protection oversight program at Unit 1 under outage
conditions.
Unit 1 was
shutdown
on March 5,
1989's
of this
inspection,
the licensee
was finalizing preparations
to remove the
reactor
head
and begin defueling.
The inspector toured Unit 1 turbine, auxiliary, fuel handling
and
containment buildings making radiation measurements
with NRC ion-chamber
survey instrument serial
no.
15843,
due for recalibration
on July 18,
1989.
The inspector
observed
the night shift turnover meeting at Unit 1
on the evening of May 15; accompanied
the Unit 1 oversight technician
on
his tour of radiologically controlled areas,
reviewed surveys,
Radiation
Exposure Authorizations,
log books
and discussed
work activities with
various individuals.
~Findin e:
A.
~0verei ht
The licensee
contracted
an outage work package that included
contractor provided radiation protection technicians.
The licensee
established
an oversight group composed of radiation protection
technicians.
Based
on review of the "Oversight Log", "Guideline For
Tour Checklist"
and
memorandum to:
Kris Oberdorf, Unit 1 Radiation
Protection
Manager,
From:
Gordon Nelson,
RP Oversight
Lead,
dated
May 10,
1989, several
observation
can
be documented:
The oversight function was intended to provide continuous
feedback to licensee
management
on the effectiveness
of
radiological controls.
2.
The oversight function was not developed
on paper prior to
implementation.
Methods
and communication flow paths
evolved
in response
to feedback.
3.
Initial oversight findings resulted in considerable
frustration.
During the first period reported
(March 18-28)
293 "items of concern"
were documented.
This was discussed
in
NRC Inspection
Report
No. 50-528/89-19.
The licensee
management
response
to the findings discussed
in Inspection
Report
No. 50-528/89-19
was to correct the outstanding
deficiencies,
verbally modify the scope of oversight activities
and to become
more involved in the radiation protection
function.
During the second period of oversight, April 28 through
May 9,
1989, the
number of identified concerns
dropped to 142
according to the
May 10,
1989
memorandum
from Gordon Nelson to
Kris Oberdor f.
This memorandum
provided
an analysis of the
type and significance of the findings and the status of
corrective actions.
The 50K decrease
in the identified
concerns
was attributed to an influx of additional contract
work force and increased
experience
gained
by that work force
in licensee
procedures.
According to the analysis,
26K of the
findings involved posting
and control of radiation areas,
16K
contamination control,
12K radioactive material control,
10K
radiation exposure
permits,
10K housekeeping
and the remainder
spread
in small percentages
among other topical areas.
The
inspector's
review of these "identified concerns"
found that
most involved compliance with licensee
procedures
and very few,
perhaps
two, involved potential technical specification high
radiation area control issues.
These
two were being evaluated
pursuant to the licensee's
problem resolution
system.
On May 3 and 4 meetings
were held with the oversight crews to
provide guidance with respect to management's
expectations.
A
log book entry at 2130,
May 3, describes
the night crew'
perception of the meeting (conducted
by a contract health
physicist) in positive terms.
Four log book entries
dated
May
4 describe
the day shift meeting conducted
by the Unit 1
Radiation Protection
Manager in negative
terms.
From the log
entries it appeared
to the inspector that management's
message
was for the oversight crews to focus
on the "Big Picture"
and
corrective actions rather than
on strict procedural
compliance.
The day shift log entries criticized radiation protection
management for what the crew perceived to be
a lack of clear
direction.
3
On May 9, 1989,
Region
V was advised
by the licensee that it
intended to reprimand the four individuals on the day shift
oversight crew for their
May 4,
1989 log entries.
The licensee
representatives
stated that they believed the log entries
were
insubordinate
and contrary to section 7.0,
Instruction For
Lo
Entries,
Procedure
Conduct of Radiation Protection
0 erations.
Two workers were
given letters of reprimand,
one worker was counseled
and the
lead technician
was given
a day off with pay to consider
whether
she wished to remain in a supervisory role.
Based
on discussions. with several
individuals, the inspector
concluded that the reprimands of the Unit 1 day shift oversight
crew were
common
knowledge.
Some individuals felt that the
reprimands
were motivated
by the oversight crew's willingness
to bring its safety concerns
to an
NRC inspector's
attention
rather
than
by the log book entries.
Some individuals
perceived that the message
of the reprimands
was to discourage
employees
from communicating safety concerns to the
NRC.
Others felt that the message
was to not document
adverse
findings.
From discussions
with some of the individuals reprimanded,
the
inspector
learned that the reprimands
are being appealed
through the company process.
The inspector
informed the
individuals of the provisions of 10
CFR 50.7,
Em lo ee Protection.
The individuals stated their continuing
commitment to carry out their oversight responsibilities
and to
document their findings, although with less
enthusiasm.
In another
log book entitled
Su ervisor
Overview,
an entry
dated
March 9,
1989 by the Unit 1 Radiation Protection
Manager
.stated
in part that "Serious problems, criticisms,
and
personnel
problems requiring discipline should
be communicated
in a letter to me."
The day shift oversight lead technician
official log book as defined in section 3.0 of 75RP-9RP10.
On May 17,
1989, the Radiation Protection
and Chemistry Manager
and the Unit 1 Radiation Protection
Manager
(RPM) held a
meeting with contractor
and licensee radiation protection
personnel
to discuss
the oversight-function.
The day shift
oversight crew was not asked to attend,
which according to the
Unit 1
RPM was
an oversight.
There presently
are three radiation support contractors
on
site.
From discussions
with representatives
of these
groups
the inspector perceived
some resentment
towards the oversight
crews
and
some reluctance
by contractors
on the oversight crews
to document deficiencies
by fellow contractors.
The inspector
observed
the night shift oversight crew at work
on the evening of May 15,
1989.
During tours-of the auxiliary
and fuel handling building the oversight technician performed
his assignment
in a professional
manner.
He identified several
minor examples of conditions not consistent with the licensee's
procedures.
These
were either immediately corrected
or brought
to the attention of the balance of plant radiation protection
coordinator.
At one point during this tour the inspector
measured
higher
'radiation levels than would be expected
based
on the "Caution
Radiation Area" posting at the entrance 40'levation auxiliary
building "A" safety injection pipe chase
room.
The inspector
and the oversight technician
conducted
independent
radiation
surveys
and confirmed radiation levels
up to 110 mrem/hr at 18"
from the safety injection piping.
One passage
way within the
room had dose rates
between
100 and
150 mrem/hr accessible
to
the whole body as measured
with licensee
survey instruments
serial
nos.
2702
and 3309 and documented
as survey report no.
1-89-05185.
Unit 1 Technical Specification 6.12 states
in part
that:
"In lieu of the 'control device'r
'alarm
signal'equired
by paragraph
20.203(c)(2) of 10
CFR Part 20,
each high
radiation area in which the intensity of radiation is greater
than
100 mrem/hr but less
than 1000 mrem/hr shall
be barricaded
and conspicuously
posted
as
a high radiation area...."
The
oversight technician
immediately posted
the entrances
to this
area with "Caution High Radiation Area" signs
and informed the
balance of plant coordinator.
Following completion of the tour
the inspector
and oversight technici'an
reviewed survey report
no.
1-89-04974 performed at 0530
May 13,
1989.
Survey record
no.
1-89-04974
dated
May 13,
1989 indicates
a
radiation survey
was performed which resulted in downgrading
the control of this area
from a "Locked High Radiation Area" to
a "Radiation Area".
The intensity of radiation recorded
on
this survey was
much less
than the intensity measured
on May
15, 1989:
The Unit 1 Shift Supervisor
informed the inspector
there
had not been
changes
in operational
configuration or
plant transients
since
May 13 which would explain the change in
dose rates.
As of the exit interview, the licensee
had not
determined
why this area
was improperly posted.
Failure to
post
a high radiation area is an apparent violation of
Technical Specification
6. 12 (50-528/89-25-01).
On May 17 the inspector
made
a tour of the Unit 1 reactor
containment building.
Several
observations
were brought to the
licensee's
attention.
The radiological controls
appeared
adequate.
No exits were marked
and access
to exits where the
exit or way to reach it was not immediately visible to
oc'cupants,
were not mar ked (for example inside the biological
shield wall).
The Plant Director was informed of the
requirements
expressed
in 29
CFR 1910.37(q)
(50-528/89-25-02).
Lastly the inspector pointed out potential
problems associated
with using
a single
hose
clamp to secure
the clear plastic
tubing used for reactor water level indication.
The Unit 1
Plant Manager indicated the hose
clamp arrangement
was
acceptable
to him.
14.
Although an article recently published in the Palo Verde
Radiation Protection
Information Notice provided
an excellent
synopsis of October 13,
1988 revision of the
NRC Enforcement
Policy,
none of the oversight crews indicated they had received
any specific training on
how to assure
the necessary
information is collected
and measures
taken to allow NRC to
exercise
B.
Conclusions
1.
The licensee
is implementing
an adequate
occupational
radiation
protection control program.
3.
The. oversight function is effective in improving performance
and minimizing occupational
exposure
to workers.
Inadequate
management
attention in development
and
implementation of the oversight function resulted
in
significant frustration by members
of the licensee
and
contractor staffs.
4.
Disciplinary action taken against
members of the day shift
oversight crew has
been perceived
by some individuals as
a
message
not to bring safety concerns
to the
NRC inspector's
attention.
3.
Alle ation RV-89-A-0025
During the period of this inspection
Region
V received
a letter dated
May
ll, 1989 concerning
a possible
unreported
exposure of a radiation
protection technician
involved in the transfer of a Unit 3 reactor
coolant
pump impeller into a decontamination
tank located at Unit 2 on a
night shift.
The alleger stated that
a radiation protection technician
(A) worked
within three feet of the impeller reading
up to 50 rem/hr at contact for
10-15 minutes with no dosimetry.
The alleger suggested
that technician
(B) delivered
a dosimetry pack to (A) immediately after the impeller was
placed in the decontamination
tank and that technicians
(C) and (D) were
informed of the situation.
The alleger stated that-(D) informed the lead
technician
and the lead technician reported to the Unit 2 Radiation-
Protection
Manager but that
no dose
assessment
was
made.
The alleger noted that this matter should
have
been reported through the
Palo Verde chain-of-command,
but that it was important to remain
anonymous
due to a fear of retribution.
A.
~Findin
s
1.
Radiation
Exposure
Permit
No. 3-89-0059-A,
R.
P.
Covera
e of
Computerized
access
logs
show that
A and
8 worked in the
same
location, during the
same period of time,
under
No.
3-89-0059-A.
~ 3.
Radiation Survey records
show predecontamination
dose rates
up
to 50 rem/hr at contact
and
5 rem/hr at three feet from the
impellers.
Review of video tapes of this work activity shows that
radiation protection technicians briefly approached
the
impellers,
but the film does not permit the viewer to confirm
whether dosimetry was,being
worn.
5.
Pocket dosimeter
readings
recorded for the period that
A and
8
worked together
show 20 mrem for A and
10 mrem for B.
The inspector telephoned
8 at
home
on May 16, 1989,
and
confirmed the individual's identity by requesting
8's
number.
The inspector identified himself as
an
NRC employee
and informed
8 of 8's responsibility to answer questions
honestly.
8 stated that
he worked the impeller decontamination
job with A but that radiation protection technicians
were not
required to wear special
dosimetry packs,
and that
8 never
provided
A with dosimetry during the job.
8 was not aware of
any instance
where
A did not wear dosimetry during that task.
The inspector
then called
A at
home
and followed the
same
procedure.
A stated that
he worked the impeller job, that
he
wore regular dosimetry,
and that
8 never approached
him during
the job to provide him dosimetry.
On May 17,
1989 the inspector discussed
this matter with D.
D
confirmed that
he worked the
same
j'ob with A, 8 and
C.
D had
no recollection of any matter involving a failure to wear
dosimetry.
9.
Several
individuals contacted
during review of this matter
indicated that morale in the radiation protection organization
w'as particularly low.
10.
In discussions
with licensee
representatives,
the inspector
was
informed that the licensee's
"guality Hot Line" has only
received four radiological inputs this year.
Conclusions
While the allegation correctly describes
the work activities of
A and 8, the inspector
was unable to substantiate
any
unmonitored or unreported
exposure of A associated
with this
specific task.
The alleger's
statement
regarding reluctance
to report this
concern through the licensee's
chain-of-command
is not in the
interest of safety,'nd
should
be of concern to the licensee.
i
'7
4.
Exit Interview
The inspector
met with the individuals noted in paragraph
1 at the
conclusion of the inspection
on May 18, '1989.
The scope
and findings of
the inspection
were summarized.
The inspector reaffirmed the importance of an oversight function in
verifying implementation of the licensee's
radiation protection program
during outage conditions.
The inspector
was critical of management's
involvement in assuring
quality implementation of the oversight function.
The inspector advised
the licensee
representatives
of his perception that morale
was declining
and that workers
do not feel they can bring safety concerns
to their
supervisor's
attention
and that the licensee's
"guality Hot Line" is not
responsive.
The. licensee
was fully aware of the problems in implementing the
oversight function and is developing
ways to improve the willingness of
workers to bring their concerns
to the licensee's
attention.
The inspector did not specifically address
the chilling effect of the
oversight disciplinary action
on worker's willingness to bring concerns
to NRC's attention.
This matter will be addressed
by
NRC management
in a
future visit planned for May 22 and 23,
1989.