ML17310B032
| ML17310B032 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/03/1994 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02811-EFC-R, 102-2811-EFC-R, NUDOCS 9402150363 | |
| Download: ML17310B032 (19) | |
Text
ACCELERATED DISTIUBUTION DEMONSTPA.TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
.'ESSION NBR-9402150363 DOC.DATE: 94/02/03 NOTARIZED: NO DOCKET ACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power R
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
I
SUBJECT:
Responds to NRC 940104 ltr re violations noted in insp rept 50-528/93-52,50-529/93-52
& 50-530/93-52 on 931129-1203.
Corrective actions:terminated
& revised REP 1-93-0109-A.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR ENCL f
SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response D
NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PDV PD TRAN,L INTERNAL: ACRS t
AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPB1 NUDOCS-ABSTRACT OGC/HDS1 RES/HFB EXTERNAL: EG&G/BRYCE,J.H.
NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME
- POLICH, T
AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE G
02 RGN5 FILE Ol NRC PDR COPIES LTTR ENCL 1
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05000528 A 05000529 05000530 D
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NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENIS YOU DON'T NEED!
OTAL NUMBER OF COPIES REQUIRED-LTTR 25 ENCL 25 D
D
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
~
PHOENIX. ARIZONA96072-3999 102-02811-WFC/RAB/DLK February 3, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Docket Nos. STN 50-528/629/630 Reply to Notice of Violations 60-528/93-52-01 and 50-528/93-52-02 File: 94-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report
'0-528/529/530/93-52 and the Notice of Violations (NOV) dated January 4, 1994.
Pursuant to the'provisions of 10 CFR 2.201, APS'esponses are enclosed.
Enclosure 1
to this letter is a restatement of the NOVs. APS'esponses are provided in Enclosure 2.
The inspection report suggested that similarities existed between the overexposure that occurred at Palo Verde in December 1992 and the contamination event discussed in the NOVs. One of the corrective actions taken by APS, in response to the December 1992 overexposure, was the Radiation Protection Organizational and Programmatic Assessment (RP 08PA) which was conducted in September 1993. is a
'ummary of the actions developed to address the findings of the RP 08PA that are applicable to the subject NOVs.
94021503b3 940203 PDR ADOCK 05000528 PDR ggo I
't/
U. S. Nuclear Regulatory Commission.
ATTN: Document Control Desk Reply to NOVs 50-528/93-52-01 and 50-528/93-52-02 Page 2 Should you have any questions, please contact Richard A. Bernier at (602) 393-5882.
Sincerely, WFC/RAB/DLK/rv
Enclosures:
1.
Restatement of Notice of Violations 2.
Reply to Notice of Violations 3., Selected Actions from the RP ORPA cc:
K. E. Perkins K. E. Johnston
ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATIONS50-528/93-52-01 AND 50-528/93-52-02 NRC INSPECTION CONDUCTED NOVEMBER 29 THROUGH DECEMBER 3, 1993 INSPECTION REPORT NOs. 50-628/629/530/93-52
Restatement of Notice of Violations 60-528/93-52-01 and 50-528/93-52-02 During an NRC inspection conducted on November 29 through December 3, 1993, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
A. Violation 60-528/93-62-01 Procedural Com liance Technical Specification 6.11.1
- states, "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."
1.
Licensee Procedure 75RP-9RP02, Revision 2.04, "Radiation Exposure Permits," contains instructions for the preparation of Radiation Exposure Permits (REP).
Section 3.2, "REP Preparation," states the following:
3.2 REP Preparation The following information shall be identified on the REP...
3.2.18.2 Special
- hazards, restrictions, and precautions.
Contrary to the above, on January 5, 1993, REP 1-93-0109-A, "AUX:
Charging Pump 'A', '8', 8 'E'.Maintenance and Associated Work," was issued for use without providing specific instructions regarding the special hazard of elevated contamination levels within the discharge side of the charging pump and the necessary precautions while working on the discharge side of the charging pumps.
Licensee Procedure 75RP-9RP02, Revision 2.04, "Radiation Exposure Permits," contains the following statement regarding stop work authority:
4.1.12 Stop Work Authority -
the authority to temporarily stop work in order to evaluate conditions.
Page 1 of 3
Additionally, Radiation Protection Technicians are empowered with the authority to stop work as follows:
4.1.12.1 This authority will be exercised by qualified Radiation Protection representatives when radiological conditions and job practices could endanger the worker, or could violate NRC regulations, station procedures, or ALARA controls for the job.
Contrary to the
- above, on July 22,
- 1993, the Radiation Protection Technician assigned to provide coverage of charging pump work authorized by REP 1-93-0109-A, failed to exercise his stop work authority when he recognized that radiation contamination readings from the discharge dampener bladder were significantly higher than expected and could have violated station procedures and NRC regulations.
This is a Severity Level IVviolation (Supplement IVI.
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B. Violation 50-528/93-52-02 Radiation Surve s 10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of Part 20 and which are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
As defined in 10 CFR 20.201(a), "survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, the licensee did not make surveys to determine that individuals were not exposed to airborne concentrations exceeding the limits specified in 10 CFR 20.103.
Specifically, on July 22, 1993, during the opening of the discharge side of the "E" charging pump, and the subsequent removal of the dampener bladder, the airborne hazards. were not evaluated.
This is a Severity Level IVviolation (Supplement IV).
Page 3 of 3
ENCLOSURE 2 REPLY TO NOTICE OF VIOLATIONS50-528/93-62-01 AND 50-528/93-52-02 NRC INSPECTION CONDUCTED NOVEMBER 29 THROUGH DECEMBER 3, 1993 INSPECTION REPORT NOs. 50-528/529/630/93-62
Re l
to Notice of Violation A 50-528/93-52-01 Reason for the Violation Notice ofViolation (NOV) 50-528/93-52-01 cites two examples where APS failed to follow the Radiation Exposure Permit (REP) procedure, 75RP-SRP02.
The first example.
occurred during the preparation of a REP for charging pump maintenance (1-93-0109-A).
The second example occurred during charging pump maintenance authorized by REP 1-93-0109-A.
REPs are required to identify special hazards, restrictions, and precautions associated with the work being authorized.
Much of the required information is obtained from past job histories. The Radiation Protection Technician (RPT), who prepared the REP, failed to adequately review the previous job histories and incorporate specific instructions to control the known hazards associated with elevated contamination levels inside the charging pump discharge piping.
Because the elevated contamination level hazards were not identified on the REP, no special precautions were included.
The reason for the first example cited in the NOV, was inattention to detail on the part of the RPT who prepared the REP.
Page 1 of 7
REP 1-93-0109-A required RPT coverage during "system opening." The RPT was not present when the charging pump discharge piping was disassembled.
(More detail on the RPT's physical location is provided in the response to NOV50-528/93-52-02.)
When the RPT returned to the job and realized that the discharge piping had been disassembled, surveys were taken on the'charging pump discharge dampener bladder.
The results of the surveys revealed significantly higher contamination levels than expected; however, the RPT failed to invoke a "stop work order" in accordance with 75RP-9RP02.
The reason for the second example cited in the NOV, was poor judgement on the part of the RPT for assuming that once the dampener bladder was contained, the potential for further spread of contamination was eliminated.
REP 1-93-0109-A was terminated and revised.
The revised REP identified the special hazards associated with the charging pump discharge dampener bladder and included special precautions to be taken when working on the discharge side of the charging pumps.
h Page 2 of 7
The fourth quarter Radiation Protection (RP) Industry Events training contained a
presentation of the events described in Condition Report Disposition Request (CRDR)
- 130375, "Unit 1 Personnel Contamination and Significant Skin Exposure During a Charging Pump Discharge Dampener Bladder Replacement."
Also included was a discussion on the proper use of job histories when preparing a REP.
The RPT, assigned to provide coverage for the work authorized by REP 1-93-0109-A, was restricted from the Radiological Controlled Area until the investigation for CRDR 130375 was complete.
The responsible RPT received positive discipline and was counseled on management expectations regarding the use of stop work authority.
Corrective Actions That Will Be Taken To Avoid Further Violations (I
The corrective actions discussed above are considered adequate and no further actions are planned to specifically address this NOV. However, Enclosure 3 is a summary of selected actions developed to address the findings of an Organizational and Programmatic Assessment conducted subsequent to the overexposure that occurred in December 1992 that are applicable to this NOV. While not specific to this NOV, these actions are expected to better focus the RP organization and individual accountabilities, thereby avoiding NOVs such as this in the future.
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Date When Full Com liance Will Be Achieved Full compliance for the first example cited in the
- NOV, was achieved on August 11, 1993, when REP 1-93-0109-A was revised to include the special hazards and precautions associated with the discharge side of the charging pumps.
Full compliance for the second example cited in the NOV, was achieved on September 7, 1993, when the responsible RPT was. counseled on his responsibilities to invoke stop work authority when unexpected radiological conditions are encountered.
Page 4 of 7
Re I to Notice of Violation B 50-528/93-52-02 Reason for the Violation Acharging pump in Unit 1 required maintenance on the suction and discharge dampener bladders.
The work, authorized by REP 1-93-0109-A, was delayed because of problems encountered with the rigging needed to disassemble the piping on the discharge side of the pump.
The REP required "Intermittent" RP coverage and RP coverage during system opening.
The REP also required a Particulate/Gaseous and Iodine air sample when the system w'as breached.
While the Maintenance Technicians (MTs) attempted to solve the problem with the rigging, the RPT left the work area to assist a work crew I
in an adjacent room. Meanwhile, the MTs solved the rigging problem and disassembled the discharge piping before the RPT returned.
No airborne surveys were taken to
'I evaluate the airborne radiation hazards when the discharge side of the'charging pump was breached.
The reason for the violation was poor judgement on the part of the RPT for failure to take an airborne survey as required by the REP, and failure to take an airborne survey when he encountered contamination levels significantly higher than expected on the charging pump discharge dampener bladder.
Page 5 of 7
Corrective Actions Taken and Results Achieved
.A Dose Assessment was performed.
No intake of radioactive material was assigned to the MTs.
The responsible RPT received positive discipline and was counseled on his failure to follow the REP, and his failure to take an airborne survey when he encountered contamination levels higher than expected on the charging pump discharge dampener bladder.
As discussed in the response to NOV 50-528/93-52-01, this event was included in the fourth quarter RP Industry Events training.
Corrective Actions That Will Be Taken To Avoid Further Violations The corrective actions discussed above are considered adequate and no further actions are planned to specifically address this NOV.
However, Enclosure 3 is a summary of selected actions'eveloped to address the.findings of an Organizational and Programmatic Assessment conducted subsequent to the overexposure that occurred in December 1992 that are applicable to this NOV. While not specific to this NOV, these actions 'are expected to better focus the RP organization and individual accountabilities, thereby avoiding NOVs such as this in the future.
Page 6 of 7
Date When Full Com liance Will Be Achieved Full compliance was achieved on September 7, 1993, when the Dose Assessment on the MTs was completed.
Page 7 of 7
ENCLOSURE 3 SELECTED ACTIONS FROM THE RP OLPA NRC INSPECTION CONDUCTED NOVEMBER 29 THROUGH DECEMBER 3, 1993 INSPECTION REPORT NOs. 50-628/529/530/93-62
Selected Actions from the RP 0&PA An overexposure occurred at Palo Verde in December 1992.
As a result, several corrective actions were taken, one of which was a Radiation Protection Organizational and Programmatic Assessment (RP 08PA). The RP 08PA evaluated the effectiveness of the corrective actions specifically developed during the investigation of the overexposure, and identified some areas where further improvements or enhancements were needed.
The selected actions listed below were developed in response to the RP 0&PA findings, but are applicable to both NOVs discussed in Enclosure 2.
Specifically, a larger data base of job histories coupled with the uniform process being used by all three Units to develop Radiation Exposure Permits (REP) would have t
provided a clearer understanding ofthe hazards associated with the job, and more detail regarding the work process and "built in" contingencies to the Maintenance Technicians and the RP Technicians (RPT).
Additionally, a more focused understanding of the responsibilities and accountabilities of frontline employees by the RPTs would have provided the incentive for the RPTs to be more diligent in their attention to detail. APS recognizes that some of the actions listed below are "first steps" and may be subject to change once they are implemented and their effectiveness is evaluated.
Program Managers are being assigned to major functional areas within RP Operations with clearly defined responsibilities. The three functional areas are RP Daily Operations (on-line and shift activities), Outage Operations, and REP/Work Page 1 of 3
Control. Through these Program Managers, specific parts ofthe RP Program are moved closer to the frontline, thereby promoting ownership and accountability as well as a baseline understanding for implementing the RP Program in the field.
2.
A centralized REP/Work Control group will be formed to provide better consistency of REPs, improved job histories, increased use of Model REPs, and a stronger Lessons Learned Program. A pilot centralized group has already been formed.
Formal realignment is expected to be complete by April 30, 1994.
RP resources will be balanced more easily with a centralized REP/Work Control group.
3.
Additional training will be developed with the emphasis placed on basic RP concepts and practices, that is, those baseline tasks that an ANSI 3;1 Radiation Protection Technician (RPT) is expected to perform as skill of the craft.
A different topic willbe covered each quarter in continuing training. Communication was offered in the fourth quarter of 1993.
Control of work in the field, as well as a specific review of the events that led to the NOVs discussed in Enclosure 2 is being presented in the first quarter of 1994.
This additional training will assist in I'educing procedural and personnel errors in the field.
4.
Responsibilities and accountability for the RP Organization will be strengthened and clarified through the Strategic Planning
- Process, the Performance Page 2 of 3
Enhancement
- Process, and the application of the techniques provided to RP Supervision in the training course "Coaching for Superior Performance."
Allthe steps needed to address this action have been completed or have been initiated and are ongoing.
This will reduce personnel errors and procedural non-compliance.
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