IR 05000528/1982011

IE Insp Rept 50-528/82-11 on 820510-14.No Noncompliance Noted.Major Areas Inspected:Radiation Protection,Chemistry Organization & Staffing,Environ Protection,Training, Procedures,Facilities & Equipment & Respiratory Protection

ML20054L733
Person / Time
Site:	Palo Verde
Issue date:	06/16/1982
From:	Book H, North H, Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20054L723	List: IR 05000528/1982011 ML20054L722
References
50-528-82-11, NUDOCS 8207080416
Download: ML20054L733 (10)

Text

U. S. NUCLEAR REGULATORY COMf11SSION

REGION V

Report No. 50-528/82-11 Docket No. 50-528 License No. CPPR-141 Safeguards Group Licensee: Arizonia Public Service Company P. O. Box 21666 Phoenix, Arizona 85036 Facility Name: Palo Verde Site-Wintersburg, Arizona and APS Corporate Office Phoenix, Arizona Inspection conducte : May 10-14, 1982 Inspectors: e

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H. S. ~ North, Radiation Specialist Date Signed Approved by: w j w--c $ /tl TZ F. A. Wenslawski, Chief Reactor Radiation Safety Irate Signed Section L I> I #

Approved by: *

H. E. Book, Chief, Radiological Safety Branch 'Date Signed Summary:

Inspection May 10-14, 1982 (Report No. 50-528/82-11)

Areas Inspected: Routine, announced inspection by a regionally based inspector of radiation protection and chemistry organization and staffing, environmental protection, training, procedures, facilities, instruments and equipment and the respiratory protection program. The inspection included a tour of several offsite air and TLD monitoring stations and an on-site tour of the laundry, decontamination, radwaste, auxiliary, control, containment and calibration buildings and portions of the service building The inspection involved 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> onsite by the inspecto Results: In the 8 areas inspected no items of noncompliance or deviations were identified.

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DETAILS Persons Contacted

• J. Allen, Technical Support Manager T. Barsuk, Radiation Protection Technician (RPT)

• L. Brown, Radiation Protection and Chemistry Manager K. Byers, RPT B. Cederquist, Chemistry Supervisor P. Egebrecht, Radiological Engineer

• W. Fernow, Administrative Support Manager G. Hampton, RPT

• F. Hicks, Training Manager L. Hopson, RPT

• J. Kirby, Maintenance-0perations Manager

• R. Kramer, Licensing Supervisor M. Lantz, Radiological Engineer J. Mann, Corporate Health Physicist and Emergency Planner B. McCaskey, Instructor

• J. McDuffee, Radiation Protection Supervisor

• J. Sarver, Licensing Engineer

• J. Schlag, Supervising Radiation Physicist-Unit 1 W. Simmons, Supervisor, General Training

• J. Vorees, Nuclear Operations Support Manager

• Denotes attendance at the exit interview on May-14,1982. Organization -

Arizona Public Service Company (APS) announced a reorganization affecting Palo Verde Nuclear Generating Station (PVNGS) on April 1, 1982. The reorganization is described in paragraph 3 of Inspection Report No. 50-528/82-09. Organizational changes in the radiation protection and chemistry areas include the appointment of a PVNGS, Radiation Protection and Chemistry Manager (RPCM) who has been designated as the Radiation Protection Manager (Regulatory Guide 1.8).

The RPCM reports to the Technical Support , Manager who in turn reports to the Vice President, Electric Operations. Reporting to the RPCM are the Supervisors of Radiation Protection.and Chemistr At the corporate level the Senior Health Physicist formerly assigned to Nuclear Projects has been designated as the Corporate Health Physicist and Emergency Planner (CHPEP) reporting through the Nuclear Operations Support Manager to the Vice President, Flectric Operations. The vacated health physicist position in Nuclear Projects is to be fille The CHPEP has responsibility for the radiological-environmental monitoring program, the Radiological Effluent Technical Specifications (RETS),

Offsite Dose Calculation Manual (0DCM), Emergency Planning and corporate level health physics and ALARA. Presently a support staff of three is planne The FSAR will be revised to reflect the changed organization when the reorganization has been complete No items of noncompliance or deviations were identifie . Staffing-Radiation Protection and Chemistry The recently designated Manager, Radiation Protection and Chemistry has a B.S. in chemistry and an M.S. in nuclear engineering. In addition this individual has held increasingly responsible positions in chemistry-radiation protection aspects of nuclear power plants and corporate utility organizations and with a NSSS supplier since 196 Practical experience has included 6 or 7 refueling outages, a steam generator tube failure occurrence and the problems associated with fuel failures. This individual appears to be well qualified for this position by reason of training and experienc The radiological engineering staff reporting to the RPS now consists of five academically qualified individuals with experience ranging to approximately 15 years. A total of eleven ANSI qual 1fied RPTs are on the staff as well as four entry level RPTs with A.A. degrees in radiation protection technolog The chemistry staff, consisting of a Chemistry Supervisor reporting to the RPCM, includes two supervising chemists, two chemists, two senior chemistry technicans, and four chemistry technicians. Training and experience in this group is divided between B.S.-B.A., nuclear navy or commercial nuclear power experienced personnel. In addition four degreed beginning level chemistry technicians are on the staff. A number of offers of employment are outstandin . The licensees present level of staffing in the radiation protection and chemistry groups equals or exceeds that specified in Figure 13.1-6 of the FSAR (82-05-01).

No items of noncompliance or deviations were identifie . Environmental Protection The licensee began the preoperational radiological environmental monitoring program during the period late 1979 to late 1981. The sampling and analysis program has been described in the PVNGS Environmental Report, Operating License phase, and the NRC's Final Environmental Statement, NUREG-0841.

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-3-The responsibility for administration of the program within APS moved from Nuclear Protects to the Corporate Health Physicist (CHPEP) concurrently with the organizational changes noted in paragraph 2. In addition, responsibility for sample collection may be transferred to the PVNGS radiation protection and chemistry groups. Following collection, samnles are sent to the analytical contractor, Controls for Environmental Pollution Inc. (CEP),

Santa Fe, H.M. for analyse During the inspection the installation and operation of air samoling station 14A at the General Store on the Buckeye-Salome highway at approximately 371st Avenue was verified. The sampling system consists of a Schmidt 2-APX constant flow air sampler operating at 2 cfm using a Gast air pump. In addition installation and operation of air sampling stations 40, Transmission Road at Wintersburg, and 29, Wintersburg Road west of PVNGS was confirmed. A number of licensee TLD monitoring stations were also observe Based on an examination of CEP reports to APS, Pre-Operational Radiological Monitoring Program-Renort for 1979 and 1980 and a draft. copy of, Pre-Operational Radiological Monitoring Program-Report for 1981, the licensee is substantially meeting their commitments as "' monitoring and sample types, locations, frequencies, and interpretations and evaluation of the data. Some minor irregularities in sample collection frequency have occurred but are expected to be resolved as the program settles into a routine. Based on an examination of the CEP reports no anomalous measurements, missing data or trends were observe The environmental program is subject to annual QA audits. The audits have included the construction phase environmental program under Nuclear Projects and presently include the radiological program and the analytical contractor. Audit reports are prepared which are submitted to management at the vice presidential level. When the possible changes in responsibility for sample collection are completed the audit program will be adjusted to accommodate those changes. Deficiencies identified in audit rai:or's require written response documenting corrective actions with verification during subsequent audit Construction Permit Nos. CPPR-141, CPPR-142 and CPPR-143 which authorize construction of PVNGS Units 1, 2 and 3 respectively, impose conditions for the protection of the environment during construction. The conditions are specifically identified as those contained in ections 4. and 4.5.2 of the Final Environmental Statement (FES) (NUREG-75/078).

During the inspection it was noted that the licensee was meeting the requirements of the following specific conditions, FES section 4.5.1:

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-4-Item 8 - Dust onsite was well controlled through the use of water truck Item 13 - Batch plant and truck wash waste was discharged to a settling pond. l Item 19 - Noise from trucks and other equipment was well controlle The licensee's program for protection of the environment during construction remains unchanged from that previously reported in Inspection Reports 50-528/80-21, 50-528/78-07 and 50-528/77-0 The licensee's analytical contractor, CEP, participates in the EPA Radiological Cross-Check Program. The CEP. report for 1979-1980 and

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draft report for 1981 contain as an appendix reports of the results of the program. CEP has the overall environmental monitoring contract including TLDs. Landauer TLD's are used by CEP who is responsible for review of the Landauer 0A program. At present APS does not submit spiked or blank samples to CEP for analysis. When the APS laboratories have been established the licensee plans to submit such samples. In addition APS is funding under contract, a staff (one PhD and one ,

level) at Arizona State University (ASU) at Tempe and providing equipment, l including a Ge detector based multichannel analyzer system, low beta counter, TLDs and TLD reader. The ASU staff is to be certified by EPA cross-check program, University of Michigan or equivalent for TLD radiation measurements, to the same requirements as those required for APS. The ASU program will be subject to APS QA audits. This auxiliary laboratory capability has been.provided principally as a backup, offsite analytical facility for use in emergencies. As a collateral responsibility i the ASU laboratory will also prepare spike and blank samples for analysis ,

by CE The licensee collected, on a one time basis, nineteen soil samples, 11 onsite and 8 offsite. These samples were subsequently analyzed by CE The samples were counted using a Ge (Li) based multichannel analyzer 4 system and were then analyzed for Pu-239, Sr-90 and tritium. The results of the analysis are contained in a report titled Preconstruction Radio-logical Analysis on Palo Verde Site Soil - August 30, 197 No items of noncompliance or deviations were identifie . Training The reorganization discussed in paragraph 2, included the promotion of the former Manager of Training to the position of Administrative Support Manager. The position of Training Manager was filled from within the Training Department by the former Supervisor, Operating Training. The General Training Supervisor, with an instructor staff of five plus one vacant position, reports to the Training Manager.

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-5-Two levels of general employee training are presently planned. Site Access Training (SAT) is required for all employees requiring unescorted access, excluding radiologically controlled areas. The second level of training, Radiological Work Practices (RWP), is required for all employees reauiring access to or work in, radiologically controlled areas. SAT training requires approximately four hours and addresses the following topic areas; security, station description and layout, procedures, industrial safety, fire protection, nuclear safety, quality assurance, radiation protection and the site emergency plan. It is presently planned that approximately 1200 individuals will receive this training. Class size is to be approximately 30 with three classes per week initially and reducing to once a week later. It is estimated that this training will be substantially complete by the end of the year. The first session of this course, excepting the radiation protection and site emergency plan portions, was presented to the Safety Audit Committee during the inspection. This presentation was observed by the inspecto During the course the APS corporate nuclear safety policy was stated to have the highest priority, that employees were to be trained, and that should any employee at PVNGS feel that a safety matter is not being adequately addressed the employee has the responsibility to bring the matter to the attention of management. An examination will normally be required on completion of the course, however, the examination was not administered following this presentation. As a part of the class an outline titled G.E.T. Objectives was distributed which identified the specific facts which the class is designed to present. An additional handout was a phamphlet titled Working With Radiation prepared by and for APS-PVNGS with the assistance of Dr. Ralph E. Lapp. The phamphlet addresses radiation, risks, cost benefit and a number of highly publicized reports dealing with radiation exposures. That portion of the SAT dealing with radiation protection will be observed during a subsequent inspectio (82-11-01)

RWP training is presently scheduled to begin at the end of July. The course is expected to require approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> and to be evenly divided between fundamentals and practical aspects of radiation protectio The training will initially be presented .twice a. week and later at weekly intervals. Class size is planned at 20-25 persons'. A total of approximately 900 persons are expected to require this training. The fundamentals portion of the course is waivabl The licensee has prepared in draft form a procedure titled Chemistry and Radiation Protection Technician Training. This procedure details a training and ongoing training (retraining) program beginning with high school graduate, beginning level (B/L), technicians. The'B/L technician will receive approximately 101/2 months of comon core training in the training department. The comon core training includes mathematics, classical

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-6-physics, introduction to chemistry, health physics fundamentals and familization with common electrical and mechanical plant component During this period each trainee will be assigned for a one week back shift duty tour with all six of the plant functional groups. Based on individual performance in the core training and the job experience phase, trainees will become elegible to select a functional group and be interviewed and possibly selected for special training for work in

that functional area. This training program is presently scheduled to begin in September with a class of about 15. Trainees, selected as chemistry and radiation protection technicians will receive additional specialized formal training and on the job training. The procedure i provides for both speciality training, i.e. special formal training provided at the request of the technicians supervisor, and on going training (commonly termed retraining) consisting of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of classroom training every two years.

! No items of noncompliance or deviations were identifie . Radiological Protection Procedures Selected reviewed and approved procedures were examined for implementation of and compatibility with the FSAR and NRC regulations. The procedures examined included:

Procedure N Title 75RP-9ZZ01 TLD Issue, Exchange and Termination 75RP-9ZZ12 TLD Lost or Damaged -

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! 75RP-9ZZ15 TLD Temporary Badge Service -

75RP-9ZZ40 Response and Performance

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Checks of Portable Radiac Instruments 75RP-9ZZ42 Calibration and Performance Testing of Radiation Protection Laboratory Counting Equipment 75RP-9ZZ47 Radiation Survey Procedure 75RP-9ZZ56 Receipt of Radioactive Materials 75RP-9ZZ60 Coverage of Receipt, Storage and Shipment of Special Nuclear Material 75RP-9ZZ76 Equipment / Material Release from a Controlled Area

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-7-75RP-0ZZ01 Radiation Warning Signs 75RP-0ZZ06 PVNGS Operations Support for Bechtel/ANPP Receipt of Radioactive Material at PVNGS 75RP-9XC08 Leak Testing and Inventory of Radioactive Sources 75AC-9ZZ03 Radioactive Contamination Control 75AC-9ZZ04 Shipment, Receipt and' Storage of Radioactive Materials Procedures associated with respiratory protection are identified in paragraph No items of noncompliance or deviations were identifie . Facilities The office and laboratory facilities located in the auxiliary building are nearing completion. Laboratory benches and chemical fume hoods have been installed. Until the radiation protection organization gains access to the permanent facilities, equipment and supplies necessary for operations will remain undelivered or in storage in the warehous In the decontamination area the decon enclosure and dip tanks are installed. Hood vent systems have been installed in the laundry area which is presently used as a craft work are No items of noncompliance or deviations were identifie . Instruments and Equipment The Area Radiation Monitoring System is discussed in FSAR sections 11.5 and 12.5.2.2.4 and Table 11.5-1. Table 11.5-1 identifies the Central Calibration Facility Monitor (CFA), XJ-SQN-RU-24 as being associated with Unit 2. This facility has been relocated to Unit The plant was toured and the location of the microprocessor (local readout station) for all monitors was identified with the exception of the CFA monitor which has not been installed. In most cases the microprocessor without the associated probe is installed. The micro-processors for monitors RU-16, Operating Level Containment, RU-17, Incore Instrument Area and RU-33, "A" Refueling Machine Area, are located outside containment at a location distant from the personnel access hatch. The readings from all monitors will be available from CRT displays in the control room and the radiation protection office which is reasonably close to the personnel access hatch. Audible and visual alarms from area monitors will occur in both the control roon and the

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-8-radiation protection office. Acknowledgement of the alarm at either location will acknowledge the alarm at both locations. The licensee stated that administrative procedures will be developed to assure that proper procedures exist for identification and response to alarms. The system provides for reflash or multialarm identificatio During the tour the inspector noted that sample line piping for two plantventmgnitorstobelocatedintheturbinebuildingwereequipped with some 90 elbow type turns. The system is designed as a gas, particulate and iodine monitor. The absence of large radius turns in a portion of the system was called to the licensee's attentio FSAR section 11.5.2.1.1.7.2.2 addresses particulate 'and iodine samplers and isokenetic sampling. The FSAR does not address heat tracing of iodine sampling lines and the impact on iodine sample validity of the iodine air-water partition coefficient on a high humidity sample on a cold da The licensee has on order, in storage or is planning to order the types and kinds of portable monitoring and sampling instruments, protective clothing and supplies identified in FSAR sections 12.5.2.1.2 Protective Clothing, 12.5.2.1.3 Contamination Control Equipment,12.5.2.2 Radiation Protection Instrumentation and 12.5.2.2.3 Personnel Monitoring Instrument As supplies and equipment are received by the radiation protection group and become available for examination, conformance with the FSAR will be verified during subsequent inspections (82-11-02).

No items of noncompliance or deviations were identifie . Respiratory Protection Program  ;

The licensee has begun to implement a respiratory protection progra .

Responsibility for respiratory protection training is assigned to the training department. Because of the large number of individuals who ,

may be required to use respiratory protective equipment for industrial hazards the basic respiratory protection training program does i not address airborne radioactive materials. The radiological portion

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of respiratory protection training is to be presented as a part of the 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> RWP training. The inspector observed the 2 1/2 hour respiratory

~ protection training. Mask types addressed were MSA-Ultravue filter and airline supplied and the Biomarine Biopac-60P. Class participants serviced and wore the Biopac-60P. Training in donning and removal of 2 the Ultravue facepiece is presented as part of the fit testing program. ~The respiratory protection program for radiologial concerns includes a medical examination, respirator test, training and fit testing. Routine whole body counts will be a part of the progra i The licensee has requested that a high level of APS management provide

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-9-r a policy statement with respect to respiratory protection. The same

! request has also been made with respect to ALARA and Radioactive i Waste Management. Action on these requests is expected to be com-pleted by early July 1982.

4 The licensee has prepared procedures for the respiratory protection program:

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Procedure N Title 75PR-0ZZO2 Respiratory Protection Program (approved)

i 75RP-9ZZ36 Respiratory Test Booth Operations (approved)

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75RP-9ZZ33 Respiratory Protection Devices Factors, Filtering

and Qualification (in approval process)

75RP-9ZZ34 Respirator Maintenance, Inspection and Repair

(in approval process)

J 75RP-9ZZ49 Respirator Use and MPC Hour Calculation (in lI approval process)

Approved procedures were examined for implementation of and compatibility

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with FSAR and NRC regulations and guidance.

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The licensees program was examined using the guidance contained in

Regulatory Guide 8.15 and NUREG 0041. The licensee has provided training in respirator maintenance and repair and test booth operation to a number

,' of radiation protection technicians. Respirator qualification will be shown by cards issued to individuals. Respirators will be issued l

for radiological purposes by the radiation protection group. The f

inspector will observe the radiation protection aspects of respiratory protection training as a part of the RWP training during a subsequent inspection (82-11-03).

No items of noncompliance or deviations were identifie ;

10. Exit Interview The.results of the inspection were discussed with the individuals denoted i in paragraph 1 at the conclusion of the inspection. ~ The licensee was

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informed that no items of noncompliance or deviations had been identifie ' -

Thefollowingmatters,identifiedinparagraph8wereidengifiedduring the interview: plant vent monitor sample lines contain 90 elbow short radius turns; no apparent provision for heat tracing of iodine sampling lines on plant vent monitor and area monitors located in containment have microprocessor readouts at a distance from the personnel access hatch.

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