ML17304A839
| ML17304A839 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1988 |
| From: | KARNER D B ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 102-01069-DBK-T, 102-1069-DBK-T, NUDOCS 8901050059 | |
| Download: ML17304A839 (34) | |
See also: IR 05000528/1988040
Text
'pi DONAI.O B.KARNER EXECUTIVE VICE PRESIDENT PiFQJQI(gr Arizona Nuclear Power Project P.O.BOX 52034~PHOENIX.ARIZONA I5072-%34~0 (.l.f t 102-01069-DBK/TDS7kf!
kC December 19, 1988 U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Washington, DC 20555 Reference:
Letter from G.P.Yuhas, Chief, Emergency Preparedness
and Radiological
Protection
Branch, U.S.Nuclear Regulatory
Commission
to Arizona Nuclear Power Project, Attn.D.B.Karner, Executive Vice President, dated December 2, 1988.Dear Sir: Subject: Palo Verde Nuclear Generating
Station Units 1, 2 and 3 Docket No.STN 50-528 (License No.NPF-41)STN 50-529 (License No.NPF-51 STN 50-530 (License No.NPF-74)Reply to a Notice of.Violation-528/88-40-01
File: 88-056-026
S This letter is provided in response to the routine inspection
conducted by Hr.G.Cicotte from October 31 through November 4, 19&8.Based upon the results of this inspection
a violation of NRC requirements
was identified.
The violation is discussed in Appendix A of the referenced
letter.The violation and ANPP's response are provided.in the attachment
to this letter.If you should have any questions regarding this response, contact Hr.Timothy Shriver of my staff at (602)393-2521.DBK/TDS/KLHC/kj
Attachments
CC: J.G.J.B.T.J.M.J.T.L.A.C.Haynes (all w/attachments)
Martin Polich Davis Chan Gehr
t
NRC Document Control Desk Page 1 of 2 102-01069-DBK/TDS/KLHC
December 19, 1988 APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating
Station Units 12;and 3.-Docket Hos.50-528, 50-529, 50-530 License Nos.NPF-41, 51, 74 During an inspection
conducted October 31-November 4, 1988, a violation of NRC requirements
was:identified.
In accordance
with the"General Statement of Policy and Procedure for,4RC.-Enforcement
Actions," 10 CFR Part 2, Appendix C (1988), as modified by 53 Fed.Reg.40019 (October 13, 1988), the violation is listed below: A.Technical Specification 6.8,"Procedures
and Programs," states in part: Written procedures
shall be established, implemented, and pa.i,ntained
covering the...""i.Offsite Dose Calculation
Manual tODCM]...." Licensee Procedure 75RP-OZ108,"Radiological
Environmental
Air Sample Collection," Revision 0, dated 3-4-88, states in part:
NRC Document Control Desk Page 2 of 2 102-01069-DBK/TDS/KLHC
December 19, 1988 APPENDIX A NOTICE OF VIOLATION (Continued)
"1.0~Per ose 1.1 This procedure provides the requirements
for the weekly issue and exchange of particulate
air filters and charcoal cartridges
as required by the ODCH and the REHP[Radiological
Environmental
Honitoring
Program]....""6.1.3.4 Flowmeter reading (If reading is 1.5 CFH no adjustments
are necessary, otherwise adjust to 1.5 CFH)." Contrary to the above, at approximately
12:45 p.m.HST, on November 2, l 1988, the flowmeter for environmental
sampling station Nos.15 and 14a was returned to service without having been adjusted to 1.5 CFH.I This is a Severity Level IV Violation (Supplement
IV).
NRC Document Control Desk Page 1 of 5 102-01069-
DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
I.REASON FOR VIOLATION On November 2, 1988, the weekly environmental
air sampling was performed by an ANPP contract employee.The air sampling was performed using procedure 75RP-OZZ08,"Radiological
Environmental
Air Sample Collection", Revision 0, dated Harch 4, 1988.During the performance
of the air sampling at predetermined
sites 14a and 15a, the inspector observed that the flowmeter reading recorded prior to adjustments
was 2.1 CFH and 2.0 CFH respectively.
The individual
then adjusted the flowrate to obtain a flowmeter reading at site 14a of 2.0 CFH.As discussed in the inspection
report, procedure 75RP-OZZ08
paragraph 6.1.3.3 states;"Flowmeter
reading (If reading is 1.5 CFH no adjustments
are necessary;
otherwise adjust to 1.5 CFH).A preliminary
evaluation
conducted by ANPP confirmed the inspector's
observations
that the sample station flowrate was adjusted to obtain a flowmeter reading of 2.0 CFH or was left in the as found condition of 2.0 CFH.As a result, ANPP initiated an evaluation
to determine the root cause of the deficiency
and to identify the necessary corrective
actions.The results of that evaluation
are discussed in the following paragraphs.
NRC Document Control Desk 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
.....Prior.
to November, 1987 the contractor
had been supplied flowmeters, used to verify/adjust
the flowrates at the various sampling sites, which measured air flow on a percentage
scale.The scale range is 0-100%with 100%equaling 2.5 CFH+5%.In November;1987 the contractor
was supplied replacement
meters which could be permanently
installed at the collection
sites.The replacement
meters measured air flow on a scale ranging from 0-6 CFH+10%.The contractor
independently
evaluated the two devices and determined
that a reading of 2.0 CFH on the replacement
meter equated to a reading of 60%on the original meter and would therefore provide a true measurement
of 1.5 CFH.The procedural
controls, as previously
discussed, were revised to address the~replacement:
meters and-required, the air flow to be adjusted to obtain a meter reading of 1.5 CFH.The intent of the procedure was to ensure a sample flow rate through the'collection
equipment'I of 1.5 CFH.Therefore, based upon the unapproved
evaluation, the contractor
utilized a flowmeter reading of 2.0 to adjust the sampling site flowrates.
This decision was discussed with and , concurred with by an ANPP representative.
Based upon these events, the"root causes" of the identified
violation are the failure of the contract organization
to adhere to established
procedural
controls and the failure of the ANPP representative
to initiate the required evaluations
and procedural
changes that would have authorized
the contractor's
actions.
NRC Document Control Desk 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40>>01
II.CORRECTIVE
ACTIONS TAKEN AND RESULTS ACHIEVED As an immediate corrective
action, an evaluation
was performed to determine the effect of using 2.0 CFH vice the required 1.5 CFH flowrate.The difference
in the calculated
activity results is approximately
25 percent in the conservative
direction.
Additionally, the original flowmeters
which were utilized by the contractor
have been returned to the contractor
for use.The meters'alibration
stickers have been specifically
annotated that a 100%scale reading equates to a 2.5 CFH flowrate.A change has been approved to the governing procedure, 75RP-OZZ08, clarifying
the readings required to obtain the appropriate
flowrate.I I I.CORRECTIVE
ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS
To address the fact that the contract individual
believed he could deviate from established
procedural
controls based upon an unapproved
technical justification, a letter was issued to the contractor
from-ANPP on November 10, 1988.The letter informed the contractor
of this event and emphasized
that any deviation from procedural
controls was unacceptable.
The letter also provided instructions
that whenever an individual
performing
a procedure has a question or concern regarding the procedure's
adequacy, technical accuracy, or requirements
he shall stop the activity and resolve the matter with ANPP management
prior to
NRC Document Control Desk 102-01069-DBK/TDS/KLMC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-0l
proceeding, ANPP has requested that the contractor
brief the responsible
personnel to ensure they understand
and comply with these instructions.
In addition, a meeting was held by ANPP on December 1, 1988 with the re'sponsible
contract personnel to reinforce the ANPP requirements
for procedural
compliance.
As an additional
corrective
action, ANPP has evaluated the other ANPP procedures
utilized by the contractor
to implement the REHP.The evaluation
identified
no technical deficiencies.
The ANPP representative
who was made aware of the procedural
deviation by the contractor
and failed to..take appropriate
action has been counseled.
Based upon the individual's
previous performance, no additional
actions are deemed necessary at this time.However, the Radiation Protection
Standards section responsible
for the Radiological
Environmental
Monitoring
Program (REHP)will be briefed on the necessity to properly overview a contractor's
performance
and to conduct a careful review of the documentation
submitted by the contractor
placing particular
emphasis on ensuring procedural
compliance.
IV.DATE WHEN FULL COMPLIANCE
WILL BE ACHIEVED All the corrective
actions stated in Sections II and III have been implemented
with the exception of the briefings to be given to the contract personnel and the Radiation Protection
Standards section
t!'1
NRC Document Control Desk Page 5 of 5 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
personnel responsible
for the implementation
of the RENP.ANPP estimates the completion
of these briefings by February 1989.
C (L Qj H r t f,
.;gCcp~~TH)DISTRIBUTION.DEMOYSTRXTION
SYSTEM>j I REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ESSION NBR:8901050059
DOC.DATE: 88/12/19 NOTARIZED:
NO DOCKET CIL:STN-50-528
Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 AUTH.NAME AUTHOR AFFILIATION
KARNER,D.B.
Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)R SUBJECT: Responds to violations
noted in Insp Rept 50-528/88-40
on 881031-1104.
I DISTRIBUTION
CODE: IE06D COPIES RECEIVED:LTR
ENCL SIZE: D TITLE: Environ&Radiological
(50 DKT)-Znsp Rept/Notice
of Violation Respons NOTES:Standardized
plant.05000528 8 RECIPIENT ID CODE/NAME PD5 LA CHAN,T INTERNAL: ACRS NMSS/LLOB 5E4 NRR/DLPQ/PEB
11 NRR/DREP/EPB
10'RR/PMAS/ILRB12
OGC/HDS 1 RES RGN2/DRSS/EPRPB
E ERNAL: LPDR NSIC NOTES: COPIES LTTR ENCL 1 0 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD5 PD DAVIS,M AEOD/DSP NMSS/SGOB 4E4 NRR/DOEA/EAB
11 NRR/DREP/RPB
10 NUDO~S=A TRACT~ERGŽ02 KGE5 FILE 01 RGN4 MURRAY, B NRC PDR RESL MARTIN,D COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 2 2.1 1 1 1 1 1 1 1 1 1 1 1 NOXE TO ALLRZDS" RECZPZENIS
PIZASE HELP US TO REDUCE TQLSTH CONIACT IHE DOCUMENI CONIBOL DESKF RXM.Pl-37 (EXT.20079)1O ELZK2VLER YOUR NAME PRQH DZSTIKBVTZGN
LISTS H)R DOCUMENIS YOU DONFT HEEDs D S TOTAL NUMBER OF COPIES REQUIRED: LTTR 27 ENCL 26
gt
OONALO B.KARNER EXECUTIVE VICE PRESIDENT Arizona Nuclear Power Project P.O.BOX 52034~PHOENIX.ARIZONA 85072-2034
102-01069-DBK/TDS/KL'HC
December 19, 1988 U.S.Nuclear Regulatory
Commission
ATTN: Document Control Desk Washington, DC 20555 Reference:
Letter from G.P.Yuhas, Chief, Emergency Preparedness
and Radiological
Protection
Branch, U.S.Nuclear Regulatory
Commission
to Arizona Nuclear Power Project, Attn.D.B.Karner, Executive Vice President, dated December 2, 1988.Dear Sir: 0 Subject: Palo Verde Nuclear Generating
Station Units 1, 2 and 3 Docket No.STN 50-528 (License No.NPF-41)STN 50-529 (License No.NPF-51)STN 50-530 (License No.NPF-74)Reply to a Notice of Violation-528/88-40-01
File: 88-056-026
This letter is provided in response to the routine inspection
conducted by Hr.G..Cicotte from October 31 through November 4, 1988.Based upon the results of this inspection
a violation of NRC requirements
was identified.
The violation is discussed in Appendix A of the referenced
letter.The violation and ANPP's response are provided in the attachment
to this letter.If you should have any questions regarding this response, contact Hr.Timothy Shriver of my staff at (602)393-2521.DBK/TDS/KLHC/kj
Attachments
CC: J.G.Haynes J.B.Hartin T.J.Polich H.J.'Davis T.L.Chan A.C.Gehr (all w/attachments)
~Ho pqoi050~5 0'500052~a:="1219 QQQCK poc 0
1 i
NRC Document Control Desk Page 1 of 2 102-01069-DBK/TDS/KLMC
December.19, 1988 APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating
Station Units 1, 2, and 3 Docket Nos.50-528, 50-529, 50-530 License Nos.NPF-41, 51, 74 During an inspection
conducted October 31-November 4, 1988, a violation of NRC requirements
was identified.
In accordance
with the"General Statement of Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1988), as modified by 53 Fed.Reg.40019 (October 13, 1988), the violation is listed below: A.Technical Specification 6.8,"Procedures
and Programs," states in part: "6.8.1 Written procedures
shall be established, implemented, and maintained
covering the...""i.Offsite Dose Calculation
Manual[ODCM]...." Licensee Procedure 75RP-OZZ08,"Radiological
Environmental
Air Sample Collection," Revision 0, dated 3-4-88, states in part:
i l I I
NRC Document Control Desk Page 2 of 2 102-01069-DBK/TDS/KLMC
December 19, 1988 APPENDIX A NOTICE OF VIOLATION (Continued)
"1.0~Por ose 1.1 This procedure provides the requirements
for the weekly issue and exchange of particulate
air filters and charcoal cartridges
as required by the ODCM and the REHP I'Radiological
Environmental
Monitoring
Program]....""6.1.3.4 Flowmeter reading (If reading is 1.5 CFH no adjustments
are necessary, otherwise'adjust to 1.5 CFH).." Contrary to the above, at approximately
12:45 p.m.HST, on November 2, 1988, the flowmeter for environmental
sampling station Nos.15 and 14a was returned to service without having been adjusted to 1.5 CFH.This is a Severity Level IV Violation (Supplement
IV).f 4'II~f'lo s, y r PAN A Q'H le~
i
NRC Document Control Desk Page 1 of 5 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
I.REASON FOR VIOLATION On November 2, 1988, the weekly environmental
air sampling was performed by an ANPP contract employee.The air sampling was performed using procedure 75RP-OZZ08,"Radiological
Environmental
Air Sample Collection", Revision 0, dated March 4, 1988.During the performance
of the air sampling at predetermined
sites 14a and 15a, the inspector observed that the flowmeter reading recorded prior to adjustments
was 2.1 CFH and 2.0 CFH respectively.
The individual
then adjusted the flowrate to obtain a flowmeter reading at site 14a of 2.0 CFH.As discussed in the inspection
report, procedure 75RP-OZZ08
paragraph 6.1.3.3 states;"Flowmeter
reading (If reading is 1.5 CFH no adjustments
are necessary;
otherwise adjust to 1.5 CFH).A preliminary
evaluation
conducted by ANPP confirmed the inspector's
observations
that the sample station flowrate was adjusted to obtain a flowmeter reading of 2.0 CFM or was left in the as found condition of 2.0 CFM.As a result>ANPP initiated an evaluation
to determine the root cause of the deficiency
and to identify the necessary corrective
actions.The results of that evaluation
are discussed in the'following
paragraphs.
(l'RC Document Control Desk Page 2 of 5 ,102-01069-DBK/TDS/KLHC
December 19, 1988 e REPLY TO NOTICE OF VIOLATION 528/88-40-01
Prior to November, 1987 the contractor
had been supplied flowmeters, used to verify/adjust
the flowrates at the various sampling sites, which measured air flow on a percentage
scale.The scale range is 0-100%with 100%equaling 2.5 CFH+5%.In November, 1987 the contractor
was supplied replacement
meters which could be permanently
installed at the collection
sites.The replacement
meters measured air flow on a'cale ranging from 0-6 CFH+10%.The contractor
independently
evaluated the two devices and determined
that a reading of 2.0 CFH on the replacement
meter equated'o a reading of 60%on the original meter.and would therefore provide a true measurement
of 1.5 CFH.The procedural
controls, as previously
discussed, were revised to address the replacement
meters and required the air flow to be adjusted to obtain a meter reading of 1.5 CFH.The intent of the procedure was to ensure a sample flow rate through the collection
equipment of 1.5 CFH.Therefore, based upon the unapproved
evaluation, the contractor
utilized a flowmeter reading of.2.0 to adjust the sampling site flowrates.
This decision was discussed with and concurred with by an ANPP representative.
Based upon these events, the"root causes" of the identified
violation are the failure of the contract organization
to adhere to established
procedural
controls and the failure of the ANPP representative
to initiate the required evaluations
and procedural
changes that would have authorized
the contractor's
actions.
NRC Document Control Desk Page 3 of 5 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
II.CORRECTIVE
ACTIONS TAKEN AND RESULTS ACHIEVED As an immediate corrective
action, an evaluation
was performed to determine the effect of using 2.0 CFH vice the required 1.5 CFH flowrate.The difference
in the calculated
activity results is approximately
25 percent in the conservative
direction.
Additionally, the original flowmeters
which were utilized by the contractor
have been returned to the contractor
for use.The meters'calibration
stickers have been specifically
annotated that a 100%scale reading equates to a 2.5 CFH flowrate.A change has been ap>roved to the governing procedure, 75RP-OZZ08, clarifying
the readings required to obtain tPe appropriate
flowrate.I I I.CORRECTIVE
ACTIONS TAKEN TO AVOID FURTHER VIOLATIONS
To address the fact that the contract individual
believed he could 0 deviate from established
procedural
controls based upon an unapproved
technical justification, a letter was issued to the contractor
from ANPP on November 10, 1988.The letter informed the contractor
of this event and emphasized
that any deviation from procedural
controls was unacceptable.
The letter also provided instructions
that whenever an individual
performing
a procedure has a question or concern regarding the procedure's
adequacy, technical accuracy, or requirements
he shall stop the activity and resolve the matter with ANPP management
prior to
HRC Document Control Desk Page 4 of 5 102-01069-DBK/TDS/KLMC
December 19, 1988 REPLY T'0 NOTICE OF VIOLATION 528/88-40-01
proceeding.
ANPP has requested that the contractor
brief the responsible
personnel to ensure they understand
and comply with these instructions.
In addition, a meeting was held by ANPP on December 1, 1988 with the responsible
contract personnel to reinforce the ANPP requirements
for procedural
compliance.
As an additional
corrective
action, ANPP has evaluated the other ANPP procedures
utilized by the contractor
to implement the REMP.'The evaluation
identified
no technical deficiencies.
The ANPP representative
who was made aware of the procedural
deviation I by the contractor
and fai'led to take appropriate
action has been counseled.
Based upon the individual's
previous performance, no additional
actions are deemed necessary at this time.However, the Radiation Protection
Standards section responsible
for the Radiological
Environmental
Monitoring
Program (REMP)will be briefed on the necessity to properly overview a contractor's
performance
and to conduct a careful review of the documentation
submitted by the contractor
placing particular
emphas'is on ensuring procedural
compliance.
IV.DATE WHEN FULL COMPLIANCE
WILL BE ACHIEVED All the'corrective
actions stated in Sections II and III have been implemented
with the exception of the briefings to be given to the contract personnel and the Radiation Protection
Standards section
IJ~
5RC Document Control Desk Page 5 of 5 102-01069-DBK/TDS/KLHC
December 19, 1988 REPLY TO NOTICE OF VIOLATION 528/88-40-01
personnel responsible
for the implementation
of the REHP.ANPP estimates the completion
of these briefings by February 1989.