ML17311A832
| ML17311A832 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/27/1995 |
| From: | STEWART W L ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9505020298 | |
| Download: ML17311A832 (11) | |
See also: IR 05000528/1995007
Text
I'll)(i I'l<OC:I:.SSli('3
REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)CCESSION NBR:9505020298
DOC.DATE: 95/04/27 NOTARIZED:
NO DOCKET N FACIL: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
F STEWART,W.L.
Arizona Public Service Co.(formerly Arizona Nuclear Power RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)F SUBJECT: Forwards response to NRC 950410 ltr re violations
noted in insp repts 50-528/95-07-01,50-529/95-07-01
&50-530/95-07-01
on 950306-10.Corrective
actions:surveyed
area&posted as high contamination
area.DISTRIBUTION
CODE: IEOID COPIES RECEIVED:LTR
I ENCL I SIZE:/TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES:STANDARDIZED
PLANT Standardized
plant.Standardized
plant.05000528 I 05000529 05000530 RECIPIENT ID CODE/NAME PD4-2 PD TRAN,L ERNAL: ACRS AEOD/SPD/RAB
AEOD/TTC gZM CENTER P NRR/DORS/OEAB'UDOCS-ABSTRACT
OGC/HDS2 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME HOLIAN, B THOMAS, C AEOD/DEIB AEOD/SPD/RRAB
DEDRO NRR/DIS P/PI PB NRR/DRCH/HHFB
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TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 22
Arizona Public Service Companv 10CFR2.201
102-03335-WLS/AKK/R
JH April 27, 1995 U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001
Dear Sirs: SubJect: Palo Verde Nuclear Generating
Station (PVNGS)Units 1, 2, and 3 Docket Nos.STN 50-528/529/530
Reply to Notice of Violation 50-528/529/530/9&071
Arizona Public Service Company (APS)has reviewed NRC Inspection
Report 50-528/529/530/95-07
and the Notice of Violation (NOV)dated April 10, 1995.Pursuant to the provisions
of 10 CFR 2.201, APS'esponse
is enclosed.Enclosure 1 to this letter is a restatement
is provided in Enclosure 2.This NRC inspection
focused on radiation protection
activities
associated
with the Unit 2 Refueling Outage.The NRC inspectors
noted that the APS Radiation Protection
program was satisfactory
overall to support outage related activities
and noted improvements
in establishment
of more challenging
ALARA goals and more detailed pre-job briefings.
However, a need exists for additional
improvement
in radioactive
material and contamination
control.As stated by the NRC, although general housekeeping
was adequate, improvements
are necessary in staging and control of outage equipment and tools.Minor problems were observed in the control of trash and extra protective
clothing items.The inspectors
concluded that this area of the program needs additional
attention and that Radiation Protection
Technicians
should be more aggressive
in their efforts to identify problems.ln an effort to improve radioactive
material control, Radiation Protection
and Maintenance
Management
are forming a group to address contaminated
tool issues.The current guidelines
are under evaluation
to include necessary enhancements
identified
by the Palo Verde corrective
action program.Radiation Protection
Management
has increased monitoring
of this area to ensure improvements
are effective.
t 9505020298
950427 PDR ADOCK 05000528 9 PDR
U.S.Nuclear Regulatory
Commission
~~ATlN: Document Control Desk Reply to NOV 50-528/95-07-01
Page 3 bcc: J.M.Levine (7602)M.D.Shea (7297)J.B.Steward (7902)J.P.Gaffney (7397)A.K.Krainik (7636)B.A.Grabo (7636)G.R.Overbeck (7602)J.C.Velotta (6156)C.K.Seaman (7992)C.E.Williams (7992)J.A.Scott (7295)J.H.Thompson (7602)R.E.Younger (7997)T.R.Bradish (7962)N.E.Meador (7636)P.M.Myers (7636)Source Document Library (7747)
U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Reply to NOV 50-528/95-07-01
Page 2 Should you have any questions, please contact Angela Krainik at (602)393-5421.Sincerely,/I'/~RI5 WLS/AKK/R JH/pv Enclosures:
Restatement
of Notice of Violation 2.Reply to Notice of Violation CC: L.J.Callan K.E.Perkins B.E.Holian K.E, Johnston
ENCLOSURE 1 RESTATEMENT
OF NOTICE OF VIOLATION 50-529/95%71
NRC INSPECTION
CONDUCTED MARCH 6 THROUGH MARCH 10, 1995 INSPECTION
REPORT NOs.50-528/529/530/957
Restatement
of Notice of Violation 50-529 9&47%1 During an NRC inspection
conducted on March 6 through March 10, 1995, one vio'lation
of NRC requirements
was identwed.ln accordance
with the"General Statement of Policy and Procedures
for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C, the violation is listed below: Section 6.8.1 of the Palo Verde, Unit 2, Technical Specifications
states in part, that written procedures
shall be established, implemented, and maintained
covering the activities
referenced
in Regulatory
Guide 1.33, Revision 2, February 1978.Appendix A, Section 7.e.(4)of Regulatory
Guide 1.33 references
contamination
control.Palo Verde Radiation Protection
procedure 75RP-ORP01,"Radiological
Posting," Revision 7, Section 3.5, requires that areas identified
as having contamination
levels greater than 100,000 disintegrations
per minute per 100 square centimeters
be posted with radiation warning sign(s)bearing the words: "Caution or Danger, High Contamination
Area." Where practical, radiological
hazard tape should be used to further define area boundaries.
Contrary to the above, on March 8, 1995, the inspectors
identified
an unposted area on the 80-foot elevation of the Unit 2 containment
building where contamination
levels were as high as 150,000 disintegrations
per minute per 100 square centimeters, This is a Severity Level IV violation, applicable
to Unit 2 (Supplement
IV)(529/95-07-01).
Page1 of1
ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION 50-529/95%7%1
NRC INSPECTION
CONDUCTED MARCH 6 THROUGH MARCH 10, 4995 INSPECTION
REPORT NOs.50-528/529/530/95%7
Re I to Notice of Violation 50-529 9&0MB Reason for the Violation APS admits the violation.
At the time of the inspection, Unit 2 was in a refueling outage, where ASME XI testing was performed on Safety Injection System valve 2JSIB-UV332, and the valve was returned to an operable condition.
The Radiation Protection
Department
performed the required weekly survey of the 80-foot containment
which was posted as a contaminated
area on March 3, 1995, at approximately
11:30 hours and found no leaks or high contamination
levels in the general area of valve 2JSIB-UV332.
On March 7, 1995, at approximately
16:22 hours the Shutdown Cooling (SDC)"B" train was placed in operation.
On March 8, 1995, at approximately
16:00 hours the NRC inspector observed water leaking from valve 2JSIB-UV332, and subsequent
survey results indicated that this was a high contamination
area.The previous contamination
survey performed on March 3, 1995, did not indicate any leaks on or around the area of valve 2JSIB-UV332.
Additional
surveys were performed on March 6th and 7th, 1995, by the Radiation Protection
Operations
Manager to verify a"Hot Spot" dose rate in close proximity to valve 2JSIB-UV332, and no leakage was identified
during these surveys.Therefore, it is concluded that the valve leak occurred at the approximate
time the SDC train"B" was placed in service.The duration that this condition existed fell between the time that the SDC train"B" was placed in service on March 7, 1995, at 16:22 hours until the condition was Identified
on March 8, 1995, at 16:00 hours, approximately
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.Page 1 of 4
Radiation Protection
Technicians
missed an opportunity
to identify the condition during routine Containment
walkdowns which are conducted on a shiftly basis.The cause of this condition has been determined
to be that management
expectations
were not met by"roving" Containment
Radiation Protection
Technicians
to ensure that routine surveys provide the level of detail and are comprehensive
in identifying
changing plant conditions.
Although Radiation Technicians
typically tour all major elevations
of Containment
including the 80-foot elevation, no documentation
existed to determine whether this particular
area had been checked or toured on a shiftly basis during the time the valve was leaking.Corrective
Actions Taken and Results Achlev d APS Radiation Protection
initiated the following actions to immediately
correct the condition:
~The area was surveyed and posted as a High Contamination
Area (HCA)~~A drip catch was installed under the valve to contain the leakage until the valve was repaired.~The area was decontaminated
and released from HCA controls.~Work request No.887461 was generated to repair the valve.~All elevations
of the Unit 2 Containment (including
grating)were surveyed for loose contamination.
No other unposted areas were discovered
that required HCA controls.Page 2 of 4
~Night Order¹95-003 was generated to immediately
to communicate
Radiation Protection
Management's
expectations
regarding"Roving" Radiation Protection
duties in Containment.
The Radiation Protection
Operations
staff was briefed by management
on March 9, 1995, regarding these expectations.
Corrective
Actions That WIII Be Taken To Avoid Fu her Violations
APS will implement the following actions to prevent recurrence:
Night Order¹95-003 was revised on April 21, 1995, to provide further clarification
on management
expectations
for performing
routine surveys, performing
toursfinspections
of plant areas, and personal accountability.
The Radiation Protection
Operations
Department
Leader distributed
these expectations
to each member of the Radiation Protection
staff on April 21, 1995.This condition will be reviewed in Industry Events Training as part of the second quarter Radiation Protection
Technician
Continuing
Training Program.As part of the review, Radiation Protection
Management
will re-enforce
expectations
for the"level of detail" and comprehensiveness
that is expected when performing
routine surveys and conducting
shiftly tours or"roving" checks of plant areas.Page 3 of 4
Date When Full Com llance Will Be Achieved Full compliance
was achieved on March 8, 1995, when the area was surveved and posted as a HCA.The area was decontaminated
and released from HCA controls on March 9, 1995.Page 4 of 4