ML17306A578
| ML17306A578 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/06/1992 |
| From: | Bocanegra R, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A576 | List: |
| References | |
| 50-528-92-02, 50-528-92-2, 50-529-92-02, 50-529-92-2, 50-530-92-02, 50-530-92-2, NUDOCS 9203230026 | |
| Download: ML17306A578 (16) | |
See also: IR 05000528/1992002
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/92002,
50-529/92002,
50-530/92002
License
No.
Licensee:
Arizona Public Service
Company
P. 0.
Box 53999, Station
9012
Phoenix, Arizona
85072-3999
Facility Name:
Palo Verde Nuclear Generating Station Units 1, 2,
and
3
Inspection at: Mintersburg,.Arizona
Inspection Conducted:
January
13-17,
1992,
and February 3-7,
1992
Inspected
by:
oc
Approved by:
Q.P.
negra,
a
s
)on
pec)a
>s
ate
) gne
u as,
se
Reacto
adiological Protection
Branch
a
e
sgne
Areas Ins ected:
Routine
unannounced
Radiation Protection
(RP) inspection of
s nspec
son
o
owup items, radioactive material control,
RP organization
and
management
controls,
and outage preparation.
Inspection procedures
92701,
83526,
83722,
and 83729 were used.
Results:
The licensee's
radiation protection program was generally found to
5e very good in the areas
inspected.
The licensee
used
good
ALARA philosophy
in planning and preparin~ for the Unit 1 refueling outage.
Examples
were
cited where the licensee
s investigation of problems
was very thorough
and
well documented.
An incident where radiofrequency
(RF) interference
caused
an
- alarming dosimeter to malfunction appeared
to be an isolated
case.
A lack of
attention to detail to
RP activities
was noted.
A violation was cited
regarding
an air sampling device that was located
such that the air samples
taken were not representative
of the workers'reathing
zone.
'F203230026
'920306
ADOCK 05000528
8
~,
Persons
Contacted
Licensee
=" .
DETAILS
J.
p.
E.
J.
D.
"" '"
R.
.a i
e
J,
R.
, T.
R.
p.
M.
M.
R.
M.
J.
Albers, Manager,
Radiation Protection Operations
Coffin, Compliance Engineer
Dotson, Director Engineering
Draper,
Southern California Edison Site Representative
Elkinton, gA Technical Specialist
Fullner, Manager; guality Assurance
and Monitoring
Gaffney,
RP Supervisor
Henry, Salt River Project Site -Representative
Hillmer, Manager
RP Support Services
Horton,
gA Auditor
Hughes, Site Radiation Protection
Manager
Lantz, Manager Technical
Services
,McMurry
RP Supp@visor
Rouse,
'Pomp'liance 'Supervisor
.Shea,
RP Manager,
Unit 2
SH ls,
RP Manager,
Unit 1
Nuclear
Re ulator
Commission
J. %loan Jr., Resident
Inspector
" F. Riagwald, Resident Inspector
Mr.
G.
P.
Yuhas,
Reactor Radiological Protection
Branch Chief,
NRC Region
V,.-.was on-.site to observe portions of the inspection.
The indiv'iduals'isted
above attended
the exit meetings
held January
17,
and/or February 7, 1992.
The inspector also held discussions
with other
personnel
during the inspection.
. 2...Follow-u
(92701)
" Item '50-528/90056-01
50-529/90056-01
50-530/90056-02
Closed):
This
-;=. o
ow-up
a
em )nvo ve
e resu
s
o
s ron
sum
r
ana ysss
performed
on a split sample.
The item was followed up in NRC Inspection
Report
No.
" 50-528/91039
and remained
open pending completion of the licensee's
- .':corrective -actions';
The corrective actions included reviewing the Sr
. analysis
procedure for possible
enhancements,
dedicating individuals to
. do the analysis,
and reviewing past cross-check
data.
The inspector
inte'rviewed licensee
personnel
and reviewed documents
associated
with
""this 'item. " The'inspector
established
the following:
o
- The licensee
evaluated
a revised calculation method
and compared
strontium chemical yield determination
by atomic absorption
(AA)
versus inductive coupled (IC) plasma emission.
The licensee
-determined that
no practical
improvement could be realized
from the
revised calculation
method or by selectively using
a specific
instrument for chemical yield determination.
o
The licensee
dedicated specific chemistry personnel
in each unit to
be responsible for strontium analysis.
o
Review of strontium analysis
cross-check
data from 1988 to the first
quarter of 1991 suggested
that overall performance
was adequate.
A
noticeable
improvement
was
seen
from the 4th quarter
1990 to the end
of the period.
The inspector concluded that, the licensee's
corrective actions
should
lead to improved strontium analysis.
The inspector concurred with the
licensee that the analytical
method
used
was not an important factor in
improving strontium analyses.
The important factors
appeared
to be the
infrequency of the analysis,
low Sr concentrations,
and. the complexity of
the procedure.
The licensee
took a suitable
approach to improving their
Sr analysis
by assigning
dedicated
analysts.
This item 'is closed.
Item 50-528/91033-01
(Closed):
This follow-up item involved the
'icensee
s
comm>
men
o ana yze Evaporation
Pond No.
1 sludge
samples
after the pond was drained to replace the liner.
Oetails of the initial
review of this item were discussed
in NRC Inspection
Report Nos.
50-
528/91039
and 50-528/91043.
The sludge
samples
showed
no licensee
generated
radioactivity.
After examining,a licensee
10
CFR 50.59 review
on this item, the inspector
found the review to be well prepared
and
concluded that no further followup action was necessary.
This item is
closed.
Item 50-528/91027-01
(Closed):
This follow-up item involved Sedimentation
assn
o.
an
csrcu
a
1ng water system
samples that appeared
to contain
The inspector interviewed licensee
personnel
and reviewed
the investigation report.
The inspector
found the investigation to be
very thorough
and well documented.
The licensee's
investigation found
that actua1
levels of H-3 in the sedimentation
basin were less than the
lower limit of detection
(LLD).
The licensee
established
that the H-3
activity found in the samples
was falsely positive based
on the following
investigation findings:
o
The contract laboratory that performed .H-3 analysis for the licensee
did not follow their procedures
for the analysis.
A licensee
equality Assurance
(gA) audit found inconsistencies
in the type of
scintillator cocktail, vial material, vial size,
and sample ratio.
o
The licensee's
laboratory procedures
for H-3 analysis
were
inadequate
to do environmental
samples.
The samples
were not given
enough time for darkness
adaptation prior to counting and the liquid
scintillation standards
were prepared prior to sample preparation
increasing the probability of cocktail separation.
o
Using improved procedures,
the licensee
reanalyzed circulating water
samples that initially showed
The inspector determined that the licensee
had identified the root cause
for the apparent
H-3 in the samples
and that satisfactory corrective
actions
were taken,
This item is closed.
H
ochlorite
S il,l
Re ortable Event No. 22587)
. The inspector
reviewed the circumstances
surrounding
a sodium
hypochlorite spill on-site.
The inspector held discussions
with the
licensee
and reviewed
a written report
on the spill.
The following
information was established:
o
On January
10,
1991
at approximately 10:30 a.m. the licensee
discovered
a hypoch/orite spill resulting from a ruptured
underground
supply line to the Unit 3 spray pond day tank.
The ruptured, underground line released
approximately
200 gallons of
8 percent
sodium hypochlorite solution with the majority spillin~
into a ditch.
The amount released
exceeded
the State of Arizona s
reporting requirements.
The licensee
reported the event to
NRC under 10
CFR 50.72(b)(2)(vi)
requirements after the State of Arizona was notified.
o
., Due to the small
amount spilled and since it occurred outdoors,
chlorine gas did not pose
an immediate health hazard to personnel
or
threaten
the safe operation of the plant.
o
Similar spills occurred in the past.
The licensee
stated that
because
of the recurrent spills,
a root cause investigation will
focus
on preventing recurrence.
Based
on the inspector's
review, it appeared
that the sodium hypochlorite
spill had minor significance
from a safety perspective.
e
Alarmin
Dosimeter Radiofre
uenc
(RF) Interference
During a plant tour, the inspector
was issued
an electronic alarming
dosimeter,
DOSI-TECH model
502A, as part of the Radiation
Exposure
Permit
(REP) requirement to enter
While observing work in
progress
in the Unit 1 auxiliary building 129'outh valve gallery, the
inspector's
alarming dosimeter malfunctioned
when
a nearby auxiliary
operator
keyed his two-way communication radio.
The'inspector
noticed
that the dosimeter's
audible alarm activated
and the dose readings
rapidly increased
to 316
mR.
The inspector,
using
an
R02 survey meter,
verified that actual
dose rates in the area
were approximately 0.2 mR/hr.
The inspector left the area
and exchanged
the defective dosimeter.
The
inspector's
self-reading
dosimeter
read approximately
2 mR.
Information Notice (IN) 91-60, "False Alarms of Alarm Rate Meters
Because
of Radiofrequency
Interference,"
was issued
by NRC on September
24, 1991.
IN 91-60 -reported that users. of electronic alarm ratemeters
had
experienced
false alarms.
When the information notice was issued,
the
licensee
reviewed it for applicability to Palo Verde.
The inspector
.
reviewed documentation
and interviewed licensee
personnel
and noted the
following items:
o
Alarming dosimeters
used
by the licensee
are manufactured
by DOSI-
TECH.
In September
1987, the manufacturer
began installing brass
0
shields in the dosimeters
to protect against
RF interference.
Dosimeters
used at the site
have the brass shield installed.
In response
to IN 91-60, the licensee
performed
RF interference
tests
on alarming dosimeters
and did not identify any problems.
The licensee verified that the alarming dosimeter
used by the
inspector contained
the brass shield.
Initially, the licensee
was
unable to reproduce
the false alar'm experienced
by the inspector.
Later, the licensee
informed the inspector that after further tests,
the false alarms were reproduced
several
times.
Discussions
with licensee
Radiation Protection personnel
indicated
that, in the past,
radiofrequency
induced false-alarms
occurred
on
very rare occasions.
The auxiliary operator stated that
he -was not
aware of having caused
.any other dosimeter to malfunction.
The licensee's
procedure
on the use of instruments
contains
a
caution
on
RF interference.
The inspector concluded that the licensee
had adequately
addressed
the
concerns
in IN 91-60.
The
RF induced false alarm appeared
to be an
isolated event.
The licensee
concluded that the alarming dosimeter
issued to the inspector
was probably defective.
/
Hot Particle'on Anti-contamination Clothin
A contract
RP technician
found a hot particle
on his anti-contamination
clothing while working in the radiological control area
(RCA).
The event
occurred
on December
16, 1991,
and was documented in the licensee's
Skin
Dose Evaluation Report
No. 2-91-1006.
The inspector
reviewed the report
and held discussions
with licensee
representatives.
The licensee
performed
a dose evaluation,
including a time motion study,
and
determined that the dose to the skin of the whole body was approximately
960 mrem.
The dose received
by the
RP technician did not exceed
any
regulatory limits.
The technician
appeared
to have followed procedures
and used
good radioloqical practices
before
and after the contamination
was di.scovered.
The inspector
had
no further questions
regarding this
matter.
No violations or deviations
were identified.
3.
Control of Radioactive Haterials
and Contamination
Surve
s
and
onl orln
The inspector toured the site's radiological control areas
(RCAs) in the
auxiliary, fuel, and radwaste buildings in all three units.
The
inspector also discussed
radiation protection practices with workers
and
observed radiation protection practices
related to work in the Unit 1
auxiliary building 129'outh valve gallery.
The inspector
reviewed
a
sampling of personnel
monitoring records
and contamination
survey
"
records.
The following items were noted:
o
A pre-job briefing associated
with the south valve gallery job
included radiation protection
and
ALARA considerations.
0
Radiation protection support was present 'and actively involved.
Precautions
were taken to prevent unexpected
exposure
by locking
pipe chases
and other areas affected by the work in progress.
Housekeeping -in the
RCAs was generally. good,
however, the inspector
identified to the licensee
some areas in 'the Unit 2 auxiliary
building where housekeeping
deficiencies
were noted.
A sampling oi instruments
used by the licensee
were checked
and
. found to be currently. calibrated
and in good working order.
o
A comp'uter"pr'intout
used
by indiv'idual'workers to verify their
quarterly:whole body dose -available prior to entering the
RCA was
located at the
RCA entrance.
At Unit 1, the inspector
found that
due to an error, the 'printout 'contained workers'kin dose available
instead of whole body dose, available for the current quarter.
o
A contract worker discovered be.had radioactive contamination of
approximately 15,000 cpm sn 'his shoe
when
he attempted to exit the
RCA.
The- inspector noted that the"RP 'technician
who logged the
event recorded the wrong date
and flailed to initial the
contamination log.
A contract junior RP technician
issued
a portable survey instrument
(R02A) .that had not been
source .checked=per
procedures.
During a tour-of Unit 1, personnel
exposure -tracking was being
performed..manually because
.the. computerized tracking system
was
-=Upon exiting"from the
RCA the inspector
noted that
a
contract.RP .technician.had.~inadvertent]y.,logged
out the wrong
person.
The technician apparently
became
confused
by two persons
with the same, last
name exiting the
RCA.
Although the deficiencies" noted=above
had minor safety significance,
they
do indicate
a lack of..attention:to 'detail.. All the deficiencies
were
brought to management".s
attention
and proiiipt corrective action was taken
in all cases.
The -inspector concluded that"the licensee's
performance in
this area.'met.:-the:-safety;;objectives.sf<.the;:radiation
protection program.
No violations or deviations
were identified.
4.
Inade uate--Air;Sam
1-in -'in an. Airborne .Area
83526)
10
CFR 20.103(a)(3)
requires that each licensee
use suitable
measurements
of concentrations
of radioactive. materials in air for detecting
and
evaluating'airborne'radioactivity
in restricted
areas.
Procedure
75RP-
9RP07 Section
6;-3, which--implements this requirement,
states that
airborne surveys, shall.be taken in such
a manner that the measurements
are representative
of .the breathing .zones of personnel
in the area.
Procedure
75RP-9RP21'Section
3. 3. 4 instructs
RP to locate the air sampler
inlet as near to the actual breathing
zone
as possible without
interfering with the work.
On February 6, 1992, during a tour of the Unit 1 radioactive waste
building 100'evel,
the inspector
observed
work being performed in a
decontamination
room;
The job, which was started
on February 5, 1992,
involved refurbishing contaminated
nozzle
dams to be used
in the upcoming refueling outage.
Labels
on the plastic wrapping
covering the nozzle
dam parts indicated
removable contamination levels
up
to 1E6
dpm per 100 square
centimeters.
The workers were wearing full-
face respirators
and an air sampler
was located in the room.
The inspector
noted that the air sampler
appeared
to be located
such that,
a representative
sample of the workers'reathing
zone
was not being
taken.
The sampler
was located inside the
room next to.a wall; however,
most of the work, including unwrapping of the contaminated parts,
was
being performed
on a work bench in the middle of the room.
The air
sampler
was relocated to the workers'reathing
zone
when
a licensee
manager
accompanying
the inspector
was informed of the apparent
discrepancy.
According to the licensee,
the sampler
had been in the
same
'ocation since the job started
on December 5, 1992.
The licensee
stated
that the air sampler location was selected
based
on the
RP technician's
best judgement of air flow and mixing in the room.
The licensee
also
stated that the air sampler
was positioned out of the way of the workers
to prevent inadvertent contamination of the sampler.
On February 7,
1992, the'icensee
performed
a verification smoke test in the
room and
confirmed that the air sampler located next to the wall would not have
provided
a suitable
measurement
of the airborne radioactivity in the
workers
breathing
zone.
Analysis of the air filter placed within the
workers'reathing
zone
showed minute quantities of Co-60 far below the
regulatory
maximum permissible concentration for workers in an airborne
radiation area.
In response
to the inspector
s finding, the licensee
took the following
prompt corrective actions:
o
Relocated
the air sampler to the workers'reathing
zone.
o
Analyzed the air filter at the end of the shift.
o
Mhole body counted the workers involved.
o
Re-instructed
the
RP technician
on proper placement of the air
sampler.
The licensee,
however, did not address
the root cause of the problem.
Mhen placing the air sampler,
the
RP technician's
predominant
concern
was
possible
contamination of the sampler.
Mhile this may be a legitimate
concern, it should not preempt the requirement of making a suitable
measurement
of airborne radioactivity in the workers'reathing
zone.
Another concern
was that the
RP technicians
may not have sufficient
training or resources
to identify the proper location to place, the air
sampler.
Failure to make
a suitable
measurement
of airborne radioactivity in the
workers'reathing
zone is a violation of 10
CFR 20. 103.
(VIO
528/92002-01)
5.
One violation and
no deviations
were identified.
Radiation Protection
Or anization
and Mana ement Controls
83722)
The inspector
reviewed the licensee's
Radiation Protection organization
and 'discussed
changes
with licensee
management.
'Two recent
changes
were noted in the licensee's
organization.
The
Technical
Services
Manager position had been temporarily filled by a
consultant
since
March 1991.
That position is now permanently filled.
The inspector interviewed the
new manager
and reviewed his
qualifications.
The inspector
found the individual to be very competent
and his qualifications far exceeded
requirements.
Two weeks before the start of the Unit 1 refueling
outage,
the Unit 1
RP operations
supervisor position unexpectedly
became
vacant
and was temporarily filled by a qualified replacement.
The
temporary supervisor
has experience
in refueling outage
management;
therefore,
the change
was not expected to adversely affect the outage.
'o violation or deviations
were identified.
6.
Unit 1 Outa
e Plannin
and Pre aration
83729
The inspector
observed
the licensee's
preparation for the Unit 1
refueling outage.
The inspector verified that movement of equipment in
and out of the Radiological
Control Area (RCA) was accomplished
in
accordance
with approved procedures.
The inspector
noted that Radiation
Protection personnel
were actively involved supporting the preparation
activities.
Through discussions
with licensee
management,
plant tours,
and review of records
and procedures,
the inspector
assessed
the planning
and preparation
phase of the Unit 1 refueling outage.
The licensee
used the Job Hazard Evaluation System
(JHES) for Radiation
Exposure
Permit (REP) approval.
JHES is a job classification
system
which dictates
required levels of RP management
review and approval for
REPs,
based
on the radiological conditions
and hazards
associated
with a
job.
Category 1, assigned
to jobs considered
the most hazardous,
must be
reviewed and approved
by both the unit
RP manager
and the
RP operations
manager.
Examples of Category
1 jobs are:
o
Diving activities
o
pump seal
work
o
Cavity decontamination
o
Reactor
lower internals
removal
and reinstallation
o
secondary
side entry
o
Access to fuel transfer path
The inspector
discussed
with the
RP operations
supervisor the licensee's
use of robots
as part of their effort to maintain personnel
exposure.
The licensee
planed to use robots during the Unit 1 refueling
outage for the following evolutions:
o
o
SG tube plugging
o
SG tube staking
o
SG hot leg side surveys
o
Underwater
vacuuming (currently under evaluation)
o
Control Element Assembly inspection
The inspector concluded that the planning
and preparation activities
observed
were adequate
to meet the safety objectives of the p'rogram.
No violations or deviations
were identified in this area.
7.
Exit Interview
The inspector
met with the individuals denoted in Section
1 on January
17, 1992,
and at the conclusion of the inspection
on February 7, 1992.
Mr.
G.
P.
Yuhas,
Reactor Radiological Protection
Branch Chief,
NRC Region
V, also attended
the exit meeting..
The scope
and findings of the
inspection were summarized.
The inspector
informed the licensee that
failure to adequately
sample
near the workers'reathing
zone in Unit 1
was
a potential violation.
The inspector also emphasized
the importance
of paying attention to detail in day-to-day
RP activities.
The licensee
acknowledged
the inspector's
comments
and requested
that written response
to the violation be waived in view of the corrective actions already
taken.
Mr. Yuhas responded that the request
could not be granted
because,
as stated in Section 4,
some concerns
have not yet been
addressed.
At the conclusion of the meeting,
the licensee
did not
identify as proprietary
any of the materials provided to or reviewed
by
the inspector.