ML17304B383
| ML17304B383 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/28/1989 |
| From: | Louis Carson, Cicotte G, Cillis M, Garcia E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17304B380 | List: |
| References | |
| 50-528-89-24, 50-529-89-24, 50-530-89-24, IEIN-89-044, IEIN-89-047, IEIN-89-44, IEIN-89-47, NUDOCS 8908150319 | |
| Download: ML17304B383 (31) | |
See also: IR 05000528/1989024
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report
Nos.
50-528/89-24,
50-529/89-24
and 50-530/89-24
License
Nos.
and
Licensee:
Arizona Public Service
Company
P.
0.
Box 53999
Phoenix,
85072-3999
Inspection
Conducted:
June 5-15,
1989,
June 26-30,
1989 and telephone
conversations
of 7/5/89
Inspected
by:
M. C111is,
Senior Radiation Specialist
>
ned
Facility Name:
Palo Verde Nuclear Generating Station - Units 1,
2 and
3
Inspection At:
Mintersburg, Arizona
L.
C.
Carson II, Radiation Specialist
Date
igned
Approved by:
E.
M. Garcia, Acting Chief
Facilities Radiological Protection Section
Date
igned
~Summar:
Routine
unannounced
inspection of occupational
exposure
during extended
refueling outages,
including external
and internal
exposure control; training
and qualification of
adiation of non-licensed plant staff;
ALARA; followup of
open items; Informati: n Notices (IN); licensee
reported
items
and licensee
reports including:
radioactive
waste
systems,
water chemistry,
and
radiological
environmental
monitoring;
and facility tours.
Inspection
procedures
30703,
83723,
83728,
83729,
83750,
84750,
92701,
92702
and
90713
were addressed.
Results:
In the areas
inspected,
the licensee's
programs
appeared
adequate
to
accomplish thei r safety objectives.
One unresolved
item involving a potential
of a contract worker is discussed
in paragraph
2. E.
A second
unresolved
item involving the receipt, transfer
and disposal
of non-exempt
sealed
sources
is discussed
in paragraph
2.G.
A third unresolved
item,
regarding the licensee's
problem resolution methodology
and procedural
adequacy,
was also identified (see
paragraph
2.G).
One violation, involving
the failure to maintain accountability of, and label,
non-exempt
sealed
sources
was identified in paragraph
2.G.
A non-cited violation related
an
unauthorized
entry of a worker into a high radiation area is discussed
in
paragraph
4.
One final item involving weaknesses
with the Post Accident
Sampling surveillance
test program is discussed
in paragraph
5.A.
50319 890728
8
< O~OOOSP8
PNU
m
I
Details
1.
Persons
Contacted
A.
Licensee
Re resentatives
J.
G.
Haynes,
Vice President,
Nuclear Production
+W.
C.
Marsh, Plant Director
+J.
E. Kirby, Nuclear Support Director
+T. Shriver,
Compliance
Manager
+W.
E.
Ide, Plant Manager,
Unit 1
"+P.
W.
Hughes,
Radiation Protection
and Chemistry Manager
"+K. Oberdor'f, Unit 1 Radiation Protection
Manager
- +A. G.
Ogu'rek, Unit 2 Radiation Protection
Manager
~+W.
E.
Sneed,
Unit 3 Radiation Protection
Manager
~+J.
M.
Si lls, Radiation Protection
Standards
Supervisor
~ J.
B. Cedarquist,
Chemistry Standards
Supervisor
~+W.
F.
Fernow, Training Manager
~+D.
M. Fuller, Unit 1 Chemistry Manager
"+R.
D. Sorensen,
Acting Unit 2 Chemistry Manager
~+J.
A. Scott, Unit 3 Chemistry Manager
- M.
W. Lantz, Standards
Senior Radiation Consultant
+J.
R.
Mann, Central Radiation Protection
Manager
+R.
B.
Ochoa,
Central
Radiation Protection Supervisor
~
R.
V. Warnock,
Southern California Edison
Company
B.
NRC
- T. Polich, Senior Resident
Inspector
~ Denotes
personnel
present at the exit interview held on
June
15,
1989.
+Denotes
personnel
present at the exit interview held on
June
30,
1989.
In addition,
the inspectors
met and held discussions
with other licensee
and contractor personnel.
2.
Occu ational
Ex osure Durin
Extended
Outa es
83723
83728
83729 and
83750)
Shipping
and transportation
were examined during a previous inspection
(see
Region
V Inspection
Reports 50-528/88-42,
50-529/88-41
and
50-530/88-40).
A.
Audits
Licensee audits
and monitoring activities during the extended
refueling outages
in Units
1 and
3 were examined.
The inspectors
observed that audits,
monitoring and oversight of
work activities in progress
during the inspection period were being
conductd
by the licensee's
equality Assurance,
Radiation Protection,
Radiological
Engineering
and Management/Supervisory
staffs in all
three units.
The 'licensee's
audit program
was conducted
by
qualified personnel.
The inspectors
reviewed the findings reported
by the above
groups
during the inspection.
Discussions
were also held with each of the
groups that were assigned
to perform oversight functions.
The inspectors
concluded that the licensee's
program in this subject
area provided
ANPP management
with a viable tool for measuring
the
quality and performance of refueling activities conducted
by the
plant staff and contractor personnel.
Ptl
i
i Itp,R
2'I,T~l
g
t'ai i,
1
" ", 98
audit report identified:
(1)
Radwaste
Support personnel
involved in the transfer,
packaging
and transport of radioactive material,
had not attended
Initial/Continuing training.
(2)
Unit Radiation Protection Technicians
have not attended
Initial/Continuing training as identified in the accredited
"Training Program Description for Radiation Protection
Technician."
Also,
no training program
was identified for
department
"Leads" to enhance their technical
and supervisory
ski 1 ls.
(3)
Unit Chemistry Technicians
have not attended Initial/Continuing
training as identified in the accredited,
"Training Program
Description for Chemistry Technicians."
Also,
no training
program
was identified .for Department
Leads to enhance their
technical
and supervisory skills.
Corrective Action Reports
(CARs) CA88-0092,
CA88-0093,
CA88-0094 and
CA88-0095
and CA88-0096 were issued
as
a result of the identified
problems.
No problems
were identified-in the area of personnel
qualifications.
The inspector verified that the licensee's
Radwaste,
Chemistry and
Radiation Protection
groups
were supporting the training program at
the time of this inspection.
Discussions with the site
RPM revealed
that the Radwaste,
Chemistry
and Radiation Protection
groups were
instructed
by ANPP management
that all personnel
would be required
to attend initial/continuing training programs that are scheduled
during the refueling outage
by the training group.
~Chan
es
No major changes
to the licensee's
organization
and equipment
had
been
made since the previous inspection.
Plannin
and Pre arations
No major
changes
had occurred in this area since the previous
inspection.
Planning
and preparation activities for Unit 1 and Unit
3 refueling work were essentially
complete.
Planning
and
preparations
for the Unit 2 refueling outage
were in progress
at the
time of this inspection
The licensee's
efforts associated
with the planning
and preparations
for Unit 2 refueling outage will be examined further during
a
subsequent
inspection.
Trainin
and
uglification
The training and qualifications for selected
personnel
in the
licensee
radiation protection,
and training organizations
were
examined for adherence
to -Technical Specifications
6.3 Unit
Staff
ua'llflcatlona
and S.a,
~Tralnln
.
The resumes
for Units 1,
2 and
3 Radi ati on Protecti on Managers
(RPMs) and selected
Lead Radiation Protection Technicians
(LRPTs)
were reviewed.
Resumes
and training records of training instructors
were reviewed for the following training categories
in:
(on-the-job
and formal training)
(1)
Chemistry Technicians training.
(2)
Radiation Protection Technicians.
(3)
General
Employee Training (GET).
(4)
Radwaste/Transportation.
The inspector
concluded that the individuals met the qualifications
prescribed
in ANSI/ANS 3. 1-1978,
American National
Standard for
Selection
and Trainin
of Nuclear
Power Plant Personnel.
External
Radiation
Ex osure
Representative
radiation exposure
records
were reviewed.
One potential radiation overexposure
was brought to the inspectors
attention
by the Unit 1 Plant Manager
(PM) on June
13,
1989.
The
reported that
a "fuel fragment"
was found on a contract worker who
had been staging
equipment for inspection of Steam Generator
No.
2
on June
13,
1989.
The "fuel fragment" with an activity of
approximately 0.4 microcuries
was located
on the skin of the
worker's left shoulder.
The initial estimate of the dose received
by the worker was reported
as 9.7 rads to a small area of the skin
of the whole body.
The estimated
dose
was based
on wor st case
assumptions.
The licensee's
investigation into this matter
was ongoing at the
conclusion of this i nspection
on June
30,
1989.
The licensee's
staff reported that the "fuel fragment"
was sent to Battelle
Northwest Laboratories for an independent
analysis.
The licensee's
final calculated
dose,
based
on the laboratory
analysis,
time and motion studies
and interviews with the workers,
may be less
than the 7.5
Rem limit prescribed
in 10 CFR Part 20. 101.
The licensee's
staff expects to submit
a Licensee
Event Report
(LER)
reporting the incident in the event
a final dose determination
has
not been
made within 30 days.
The
LER will serve
as the
30 day
'eport
prescribed
under
'ending
receipt
and evaluation of the licensee's
report pursuant to
10 CFR Part 20.405 this matter is considered
to be unresolved
(50-528/89-24-01).
An unresolved
item is one about which more information is required
in order to ascertain
whether it is an acceptable
item,
a violation,
or a deviation.
No other personnel
were observed
or reported to have
exceeded
the
dose limits prescribed
in 10 CFR Part 20. 101.
Internal
Ex osure Control
Representative
Unit 1,
2 and
3 records of air samples
collected for
work activities,
whole body counting and calculations of airborne
radioactivity, were reviewed.
No concerns
were identified.
Control of Radioactive Materials
and Contamination
Surve
s and
~Monitonin
A review of the licensee's
records of sealed
sources
containing
radioactive material in excess
of the quantities
provided in 10 CFR 20, Appendix C,
was performed for the purpose of verifying adherence
to the following requirements:
(1)
30. and
31
(2)
Technical Specifications
(TS), 4.7. 10', 6.8. 1,
6. 10. 1 and
6. 11. 1
(3)
Licensee
procedure
75RP-9ÃC08,
Leak Testin
and Inventor
of
Radioactive
Sources
(4)
Licensee
procedure
Source Control
Procedure
75RP-9ÃC08 states
in part:
"6. 4. l. 1
The accountability
of radioactive
sources
shall
be
performed
on
a semi-annual
basis.
The inventory shall
physically account for all sources."
Procedure
75AC-9RP05 states
in part:
The Central
RP Group shall
be responsible for the
following:..."
"2. 1. 3
Entering each
non-exempt quantity source in its custody
in its Source Tracking System... "
"2.1.6
Semi
Annual inventory of all non-exempt quantity sources
in their custody..."
112
3
The Unit Radiation Protection
Group is responsible
for the
following:..."
"2.3.2
Entering each
non-exempt quantity source in its custody
in its Source Tracking System...."
"2.3.3
Semi-Annual
inventory of all non-exempt quantity sources
in their custody...."
"3.2.4
All sources
or source containers
shall
be labeled with a
durable, clearly visible label which shall include at
least the radiation trefoil, source i. d.
number,
the words
"Caution Radioactive Materials", the isotope or isotopes,
and the activity of each isotope."
The
(2)
following were observations
were
made:,
Removable
contamination
surveys
were performed for all sealed
sources
noted
on the licensee's
current sealed
source
accountability records.
Removable contamination
levels
reported
were below the limits prescribed
in the
The inspector
was informed that all non-exempt
sealed
sources
were not being controlled in accordance
with procedures
and
nor were they noted
on the above
accountability
records.
The staff members
stated that
a
non-exempt
Americium-241 (Am-241) source
(80 nanocuries)
was
found in the licensee's
Dry Active Waste Processing Facility
(DAWP) on March 30,
1989.
10 CFR 30. 15(c)(9)(iii) states
that
0.05 microcuries
(50 nanocuries)
is the upper limit for an
exempt quantity of Am-241 pursuant to 10 CFR 30.71,
Schedule
B.
An internal
licensee
memo,
¹ANPM-00296-GDP-96.55,
dated October
14, 1986,
issued
by the Manager of Radiological
Services,
includes
an attached list of Radiation Monitoring System
detectors
with low-level exempt radiation sources.
Included
on
the list were Am-241 sources
ranging from 80 to 150 nanocuries.
The
memo went on to state that such sources
emit levels
equivalent to smoke detectors
and could be treated
as
such
and
therefore
could be stored without radiation protection
controls.
The
memo appeared
to provide information that is
incorrect with respect to 10 CFR Part 30 and Part
31
requirements.
In response
tothe discovery of the Am-241 source at the
DAWP
facility a Problem Resolution
Sheet
(PRS)
was initiated by the
Unit 2
RPM on March 30,
1989, pursuant to licensee
procedure
79AC-OIP05, Incident Investi ation Action Trackin
and
Distribution.
PRS ¹00236, identified the Am-241 source
found
in the
DAMP facility.
The
PRS
was reviewed
and signed
by the
Unit 2 Plant Manager
on April 3,
1989.
The Unit 2
RPM was
, I
assigned
responsibility
as Investigation Director.
The
investigation
schedule
report date assigned
by the Plant
Manager
was
May 2,'989.
A review of the licensee's
Incident Investigation Report,
dated
May 8,
1989,
was conducted.
The report provided
a description
of the incident involving the Am-241 sealed
source
found in the
DAMP facility. It also included
a summary of causes
and
assigned
corrective
actions
as follows:
"Conduct
an audit of all
Sg system
sources
and other
source material
received onsite
as non-exempt by-product
material for the purpose of locating all receipt
documentation
required
by federal regulations,
the total
number
and identity of .trackable
sources
at
Due by
14 days after approval of this report."
(May 14, 1989)
"Account for all non-exempt by-product material
received
by
PVNGS and enter into Source Tracking system.
Due by 30
days after approval of this report."
(May 31,
1989)
"Investigate the circumstances
surrounding
any missing
non-exempt byproduct material
and identify any corrective
actions
necessary
to resolve lost material
issues.
Notify
Compliance of any deficiencies
in receipt
and
accountability recovery for evaluation
as
a possible
violation of Title 10, Part
30 or 31,
Code of Federal
Regulations.
Due by 35 days after the issue of this
report."
(June
5,
1989)
"Review 75AC-9RP05,
Source Control,
Leak
Testing
and Inventory of Radioactive
Sources,
for possible
evision.
Due by 30 days after the issue of this report."
{'y 31,
1989)
"Route copy of this report for review by all
RP and
18C
technicians,
foremen,
and supervisors.
Due by 30
days after the issue of this report."
(May 31, 1989)
"Review
RP and
I8C continuing and initial training for
revision to include requirements
for handling non-exempt
by-product material.
Due by 60 days after the issue of
this report."
(July 31,
1989)
"Emphasize
necessity for prompt determination of
disposition of material
generated
during work, and prompt
handling of material
once disposition is determined.
Due
by 30 days after the issue of this report."
(May 31,
1989)
As of June
30,
1989,
the Incident Investigation Report and
PRS
had not been distributed to the licensee's
staff for initiation
of the assigned
corrective actions.
The
RPM stated that the
PRS
and Incident Investigation Report was still under
investigation
and therefore
the
PRS
and accompanying
report
had
not been distributed.
The inspector
noted that procedure
79AC-OIP05 requires that the
Assistant/Plant
Supervisor
be responsible for ensuring that
immediate. corrective actions
are taken
as required for
conditions identified by a
PRS.
This procedure further
requires that the Plant Manager,
in order to invalidate
a
PRS,
must write "cancel"
on the
PRS in his signature
block.
Step 3.2.1 of 79AC-OIP05 states,
in part:
"Overdue investigations will be tracked with a report of all
overdue investigations distributed to Senior Management
and
Directors affected."
(3)
On May 1,
1989,
an internal
licensee
memorandum
issued to the
Unit 2
RPM from the Radiation Protection Standards
Group,
0'222-00630-JMS/LGB,
identified that
PVNGS was currently in
violation of radiation protection procedures
for non-exempt
source accountability.
The following corrective actions
were
recommended
by the
RP Standards
Supervisor
to restore
compliance:
"A.
An audit of all
Sg System
sources
should
be performed
by
the Central
RP Group to determine:
(1)
the total
number of sources
purchased
and received
by
(2)
the total
number of sources currently installed in Sg
systems,
stored onsite,
or stored in warehouse
facilities,
(3)
the total
number of missing sources (if any),
and
(4) if the requirements
of 10 CFR 31. 8 are being met in
regards
to storage
container designs,
total source
strength,
labeling,
use
and disposal.
B.
All source activity levels should
be determined
by the
Central
RP Group and correctly categorized
as to exempt or
non-exempt quantities.
C.
All non-exempt quantity sources
should
be logged into the
appropriate
Unit or Central
RP Groups'ource
Tracking
System in accordance
with the requirements
contained in
procedure
and tracked for accountability
purposes.
D.
An investigation should
be performed
by the Central
Group to determine
the circumstances
surrounding missing
non-exempt
sources (if any)
and identify any corrective
actions
necessary
to resolve lost source material issues."
As of June
26,
1989, all members
of the licensee staff assigned
corrective action
had not seen this correspondence.
The corrective
actions
taken
up to this point had been to contact the vendor who
had transferred
the sources
to ANPP.
The vendor
was contacted for
the purpose of determining the quantity of Am-241 sources
that were
=received or that should
be
on hand.
Between
June
26,
1989
and July 5, 1989,
the following information
related to this matter
was identified:
The requirements
for maintaining source control pursuant to the
requirements
established
in 75AC-9RP05,
paragraph
2, were
discussed
with the licensee's
staff.
At least
two managers
were not aware of their responsibilities for entering
each
non-exempt quantity Am-241. source in their custody into the
appropriate
Source Tracking System
and for conducting the
semi-annual
inventories of all such
non-exempt quantity
sources.
(2)
(3)
The instructions provided in Procedure
75AC-9RP05 involving the
storage of Am-241 sources
does not include all of the
provisions prescribed
in 10 CFR 31.8(c), which provides
specific requirements
for the storage
and control of Am-241
sources.
The Am-241 sources
are check sources
used in each Unit's Area
Radiation Monitoring (ARM) system.
There are
31
ARMs in each
Unit.
Each of the
ARMs contain
a 100 nanocurie
Am-241 source.
(4)
I
(5)
None of the
31 sources
in any of the Units had been
accounted
for since the sources
were received.
Some sources
had been
received
as early as
1982.
Thirty-seven
(37) Am-241 sources,
ranging from 80 to 150
nanocuries,
were found in the licensee's
warehouse.
Warehouse
records
indicated that there should
have
been
47 Am-241 sources
in storage.
None of the warehouse
sources
had been
accounted
for on
a semi-annual
basis.
10 CFR Parts 20. 401,
20.402
and
10 CFR 30.51 prescribe
the types of records that are required to
be maintained
showing the receipt, transfer,
disposal
and/or
loss of byproduct material.
The licensee's
staff was still in
the pr'ocess
of determining the accountability
and disposition
of Am-241 sources
that were received
from the vendor.
This
item will remain unresolved
pending completion of the
licensee's
investigation (50-528/89-24-02).
The licensee's
delays in taking action
and in distributing
information, regarding what were clearly recognized
by the
licensee's
staff as potential violations of Technical
Specifications
and federal regulations,
appeared
untimely and
directly attributable to licensee
management's
failure to
achieve
the intent of their procedures.
The matter of whether
licensee
procedure
79AC-OIP05 is adequate,
or was adhered to
for PRS ¹00236, is unresolved
(50-529/89-24-01).
TS 6. 11. 1 states
in part that procedures
for personnel
radiation
protection shall
be prepared consistent with the requirements
of 10 CFR Part 20 and shall
be approved,
maintained,
and adhered
to for
all operations
involving personnel
radiation exposure.
TS 6. 10. 1(h) states
in part that records of annual
physical
inventory of all sealed
source material of record shall
be retained
for a period of five years.
A tour of Units
2 and
3 was conducted
for the purpose of verifying
the
ARNs containing the Am-241 sources
were properly labeled in
accordance
with procedure
The inspection
revealed that
all of the
ARM detectors
had affixed. labels.
The information on
approximately half the detectors
was not legible as prescribed
in
procedure
and
One label
was found
to be completely hidden
by a bracket.
The regulatory requirements
are that labels
be clearly visible and that sufficient information
be provided to permit personnel
to take appropriate
precautions
to
avoid or minimize their exposure.
The inspector
informed the
licensee that failure to properly maintain labeling, accountability
and control of non-exempt quantity Am-241 sources
was
an apparent
violation (50-528/89-24-03).
The above observations
were brought to the licensee's
attention at
the exit interview.
The inspectors
stated that the above findings
indicated:
There
was inattention to detail
on the part of involved
personnel
to 'follow procedures
and other written instructions
Procedures
are weak and did not appear
to be consistent with
regulatory requirements.
Personnel
did not have
a clear
understanding
of the procedures
and their responsibilities.
There were several
missed opportunities to implement corrective
actions in a timely manner.
There
may be
a need to evaluate
the adequacy
of procedure
75AC-OIP05 to insure that
PRSs are
processed
in a timely manner.
The licensee's
staff attending the exit interview acknowledged
the
inspectors'oncerns.
Maintainin
Radiation
Ex osures
Several
discussions
were held with workers
and Unit ALARA
coordinators
to determine whether they understood
the
ALARA program,
understood their role in the program,
and if they were actively
involved in the program.
The inspector
determined that workers were aware of the
program
and were implementing
good
ALARA work practices.
The inspectors
also observed
work practices
by workers involved in
refueling activities
such
as
work, main coolant
pump
10
work, cutup of Incore Instrumentation,
performance
of routine
surveys,
and during plant tours.
No concerns
were identified in
this area.
I.
Conclusion
Overall, the licensee's
radiation protection program is capable of
meeting its objectives,
however,
management
attention is needed to
ensure
procedure
compliance
and identified problems
are handled in a
timely manner.
Follow-u
of Licensee Action on 0 en Items
and Enforcement
Items
92701
and 92702)
0 en Item 50-528/88-42-01(Closed):
Inspection
Report 50-528/88-42
identified that involvement of the Quality Assurance/Quality
Control
group, in activities related to the receipt
and shipment of radioactive
material,
was marginal.
A review of this item indicated Quality Assurance/Quality
Control
involvement in receipt
and transportation activities
had increased
(see
paragraph
2.A).
This matter is closed.
0 en Items 50-528/IN-89-44
50-528/IN-89-47
50-529/
50-529/
50-530/IN-89-44
and 50-530 IN-89-47
Closed
This item refers
to two Information Notices.
The topics of these
Information Notices are,
respectively,
H dro en Stora
e on the Roof of the Control
Room and
Potential
Problem with Worn or D>storted
Hose
Clam
s on Self-Contained
Breathin
A
aratus.
The licensee
had received
and distr)buted the
notices
in accordance
with established
procedures.
This matter is
closed.
0 en Item 50-530/88-39-02
(Closed):
This item is also being tracked
under enforcement
item number
50-529/89-03-01;
therefore,
future
reference
and/or review of this item will be tracked
under
open item
50-529/89-03-01.
This matter is closed.
Licensee Action on Written
Re orts of Non-Routine Events
92700
Licensee
Event
Re ort 50-528/89-11-00
(Closed
LER 89-11-00 for Unit 1
identified that
a Unit 1 worker entered
a high radiation area without the
proper radiation monitoring devices
required
by Technical Specification
6. 12. 1.
The Radiation
Exposure
Permit
(REP)
used
by the worker did not
permit entry into the high radiation area.
The licensee's
investigation
disclosed that the worker thought that the
REP did allow entry into high
radiation areas.
The worker had
been discovered
by an
RP Technician
upon
exit from the high radiation area.
A review of the worker's self
indicating dosimeter
revealed that his exposure for the entry was zero.
The inspector verified that the corrective actions prescribed
in the
LER
had been
implemented.
This violation is not being cited because
the
criteria specified in Section
V.G of the Enforcement Policy were
satisfied
(NCV-50-528/89-24-05).
This matter is closed.
11
5.
Radioactive
Waste
S stems
Water Chemistr
and Radiolo ical
Environmental Monitorin
84750
and 90713
A.
Post Accident
Sam lin
S stem
(PASS)
The licensee's
programs for training, maintenance,
and operation of
the
PASS were examined for compliance with Technical Specification (TS) 6.8.4.e,
Post-Accident
Sam lin
.
It was determined that the licensee
had
an adequate staff
qualified in PASS procedures
and methodology.
PASS training
course descriptions,
records of training conducted,
and
one
course
on
PASS objectives
and capabilities,
which was examined
in detail, did not disclose
any significant concerns.
However,
the. licensee
stated that
some of the on-the-job
(OJT) training
was still under development.
No specific audits or quality assurance
(gA) monitoring had
been
conducted for the
PASS.
However,
a critique of the
licensee's
most recent
emergency
exercise,
in which the
capability to obtain
a
PASS sample
was tested,
was reviewed.
No major concerns
were identified by the critique.
Representative
records of the following documents,
in
particular for the period of June
1988 to May 1989,
were
reviewed:
EPIP-27,
Post Accident
Sam lin
and Anal sis
74CH-9ÃC33, Post Accident Radioactive
Sam lin
Anal sis
and
~Handlin
Pre lanned Alternate
Sam lin
74CH-9ZZ98, Unit Chemsstr
Techn)c>an
On The-Job Trainin
9"""""""
0 eration of the Post Accident
Sam lin
S stem
Post Accident
Sam lin
S stem Pro
ram
Post Acc>dent
Sam
1>n
S stem
Leaka
e Monitorin
PASS Functional
Test
(where "x" means
each unit
On October 22,
1987,
the
18 month
PASS surveillance
for Unit 3,
was performed.
The first re-test
was
due in April
1989,
by which time Unit 3 was in a mode in which the full test
could not be performed.
The time for completion of the
Containment
Radwaste
(CRWS) analysis,
the sample
and
analysis duration,
and whether the
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> sample analysis
criteria was met,
were not filled in.
The data
was not
obtainable
from other records.
The
CRWS is an alternate
channel
and is not one of the channels
required
by the
Technical Specifications.
Those channels 'specifically delineated
in the
TS had been
performed satisfactorily.
However, in the event that any one
Technical Specification
channel
is not operable,
the licensee
12
depends
on the alternate
channels
for the information necessary
to assess
core
damage.
The record indicated that the licensee
had not determined
whether the,3.0
hour criteria for sample/analysis
completion,
as required
by
had been achieved.
The record
had
been signed
by the test performers.
Four reviews
had been
signed:
the Acceptance
Reviewer,
the Shift Supervisor,
the
Unit 3 Chemistry Supervisor,
and the Technical
Reviewer.
Licensee
procedure
73AC-9Z204, Surveillance
Testin
, Revision
6, dated
November 1, 1988, states
in part that omissions
are
allowed if the information is not required to achieve
applicable Technical Specifications
acceptance
criteria or if
the equipment is inoperable.
However, the procedure further
states
that the omission:
"...shall
be documented
in the
Log unless
the
ST procedure specifically explains,
infers or
justifies the.'..spaces
that were omitted."
The omission noted
above
was not specified
by the
ST.
When the matter
was discussed
with the Chemistry Standards
Supervisor,
he acknowledged
the inspectors'bservations.
The
discussion
revealed
also that the instructions regarding
whether
or not a valve lineup would be required prior to
sampling were in conflict.
The licensee
committed to revision
of the
procedures
to make
them consistent with each
other:
The licensee further committed to revision of EPIP-27
to remove the valve lineup -requirement during an accident,
as
many of the valves would not be accessible
under accident
conditions.
In reviewing other surveillance
tests
(STs)
as noted above, it
was c. served that numerous test steps,
checklists,
and other
recorc
had
been left blank.
Host of the records specified the
reason.
such
as channels
inoperable or staggered
test
scheduling.
However,
some records
did not specify the reason
for the omissions.
Pursuant
to TS 6.8. 1, Procedures
and Pro rams,
the licensee
is
committed to adherence
to Regulatory Guide
RG) 1.33, Revision
2,
ualit
Assurance
Pro
ram
Re uirements
0 eration
, of
February
1978.
This guide refers to ANS-3.2 ANSI-N18.7-1976,
Administrative Controls for Nuclear
Power Plants,
which. states
that the manner in which procedures will be implemented is to
be identified.
One of the examples
stated in step
5. 1.2,
Procedure
Adherence,
is:
"(3) verification of completion of significant steps,
by
initials or signatures
on checkoff lists.
The above also specifies that data is to be recorded
as the
task is performed.
With the exception of 74ST-3SS03,
however,
none of the examples
noted appeared
to have
been the result of
13
either 1) failure to document
a performed step,
or 2) failure
to perform
a step required in order to meet
a
TS requirement.
The examples of blank data/signoff steps
in surveillance tests,
without accompanying
explanation
in the
ST Log, did not appear
to meet the intent of
RG 1.33'or
The approved
wording of 73AC-9ZZ04, regarding omissions,
indicates that this
is acceptable
to the licensee.
This could lead test performers
to fail to properly annotate
records
in the
ST Log.
Also,
persons
reviewing surveillance
tests
could become
accustomed
to
incomplete or non-specific
forms of retaining records for
retrieval.
The inspectors
expressed
this concern to the
licensee.
The licensee
acknowledged
the
inspectors'bservations.
In summary,
three concerns
were identified:
A non-TS channel
was never fully tested
since startup of
Unit 3.
Some procedures
were in 'conflict with each other.
Licensee
methods of noting which portions of surveillance
tests
are performed,
were inconsistent
and procedural
guidance
appeared
deficient.
The above matters
were discussed
with the licensee at the exit
interview held on June
15,
1989.
The licensee
committed to the
procedural
changes
noted above.
The licensee
acknowledged
the
observations
regarding the wording of 73AC-9ZZ04.
In general,
the licensee's
program appeared
capable of meeting
its'afety objectives.
No violations or deviations
were
identified.
Review of 1988 Radiolo ical Environmental
0 eratin
Re ort (90713)
A review of the 1988 Annual Environmental Monitoring Program Report
shows that the Palo Verde Nuclear Generating Station provided their
data
and analysis of radiological
environmental
samples
and
measurements,
made during this period, in accordance
with the
program
as described
in the technical specifications
Section 3/4. 12.
Comparison with preoperational
data
and previous environmental
surveillance
reports,
data
from the 1988 report
shows that
no
significant changes
have
been
observed
on plant environs
from PVNGS
operations.
The results of PVNGS participation,
through the Radiation
Measurements
Facility (RMF) of th'eir contractor,
in the
Intercomparison
program,
assures
their quality control.
TLOs are
also intercompared
with Oak Ridge National Laboratory.
Achievement of TLOs at or below the levels required
by the Technical
Specifications
were noted.
No significant deviations in the
monitoring program were addressed
for the 1988 reporting period.
Measurements
made with TLDs at 50 locations out to 45 miles from the
plant showed
no changes
as
compared to previous
annual
reporting
levels.
The Annual
Land Use
Census
results
showed that
no changes
were
required to the environmental
monitoring program
as
a result of the
census.
In conclusion,
the annual
radiological environmental
monitoring
program report
shows
PVNGS to be operating in accordance
with
previous periods
and
no impact was apparent
on the environment.
No
violations or deviations
were identified.
Tours of Units 1, 2,
and
3 were made,
including the Radwaste,
Auxiliary,
Reactor,
and Turbine Buildings.
Independent
radiation measurements
were
made using
NRC ion chamber
survey instruments
model
R0-2, serial
number
022906,
due for calibration
on 10-18-89,
and model
36100, serial
number
10444,
due for calibration 10-25-89.
The following observations
were
made:
In Unit 1, fire door
R122 was propped
open.
Many of the lights were
out in the Essential
Pipe Density Tunnel, located below the
yard.
In Unit 2,
on the 140'levation of the Auxiliary Building, a
modesty
garment
had
been stuffed into a Public Address
(PA) horn at
the AA-A10 area.
The horns
are
used to make emergency notifications
to personnel
throughout the plant,, in addition to normal paging.
A review of computerized
records of Radiologically Controlled Area
(RCA) entries
indicated that one of the inspectors
had entered Unit
3
RCA on
a day when the involved inspector
was not at the site.
A
Health Physics
(HP) number,
used
by the licensee
as
a unique
identifier for exposure
records,
which was similar to that of the
inspector,
appeared
to have
been
improperly entered.
The
individual's entry that day with his work crew had been correctly
input.
The matter of dosimetry personnel
entering data, without
cross-checking
personal
data with the person
being authorized entry,
was discussed
with the licensee.
The licensee retroactively deleted
the incorrect entry.
During a tour of the Unit 3 RB, the buffer zone for a Hot Particle
Control Area
(HPCA) at the
head stud tensioner
mechanism did not
appear
adequate
to prevent migration of particles out of the
HPCA on
the levels below which the mechanism
was suspended.
The inspectors
noted that the licensee's
RP staff uses
tape for
attaching
ribbon and or rope to walls as
a means of establishing
perimeters
around radiation and/or
contaminated
areas.
This method
did not appear to be effective in that the inspectors
noted that
barriers established
around contaminated
areas
had fallen down on
15
one side.
This condition was observed
on two different occasions
during the inspection.
The practice of using tape for installing
barrier ribbon and/or rope
was discussed
with the licensee's
staff.
The inspector
noted that personnel
were not donning protective
clothing properly in that hoods
and coveralls
were not always worn
in accordance
with licensee training to prevent personnel
contamination
occurrences.
The inspectors
observed
the removal
and cutting of irradiated Incore
Instrument assemblies.
Radiation monitoring equipment
observed
were in current calibration.
Posting
and labeling practices
appeared
to be consistent with 10 CFR Parts 19.11
and 20.203.
Mork practices
appeared
to be consistent with the
ALARA concept
Plant cleanliness
continues
to receive attention.
Mork areas,
though
somewhat cluttered in some areas,
were being periodically
cleared of extraneous
material
and equipment.
Overall, the licensee's
program appeared
capable of meeting its'afety
objectives.
No violations or deviations
were identified.
7.
Exit Interview
The inspectors
met with the individuals noted in paragraph
1 at the
conclusion of the inspection
on June
15,
1989
and June
30,
1989.
The
scope
and findings of the inspection
were summarized.
The inspector
informed the licensee of the unresolved
items identified in
paragraphs
2.E and 2.G arid of the potential violation identified in
paragraph
2.G.
The findings of paragraph
5.A were also discussed
at the
exit.
The licensee's
staff acknowledged
the inspectors'indings
by
stating appropriate
action will be taken to strengthen
PASS surveillance
test
and operating procedures,
and by strengthening
procedures
established
for the control of sealed
sources.
The licensee staff
informed the inspector that action to perform an inventory of and label
all non-exempt
sources
had been initiated.
~ ~