ML17303B083
| ML17303B083 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/21/1988 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 102-00723-EEVB, 102-723-EEVB, NUDOCS 8805030204 | |
| Download: ML17303B083 (8) | |
Text
REGULATORY INFORNATIQN DISTR IBUTION SYSTEM (R IDS)
ACCESSION NBR: 8805030204 DOC. DATE: 88/04/21 NOTARIZED:
NO DOCKET FACIL: STN-50-529 Palo Verde hluc lear Station Unit 2, Arizona Pub 1 i 05000529 AUTH. NAME AUTHOR AFFILIATION dAN.BRUNT E. E.
Arizona Nuclear Power Prospect (formerly Ar i zona Public Serv REC IP. NAI'lE PEC IP IENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 880330 ltr re violations noted in Insp Rept 50-528/88-08. Corrective actions: revised release permit generated ii r evised permit inserted LLD values obtained as ac tual values discharge.
DISTRIBUTION CODE:
IE06D COPIES RECEIVED: LTR l
ENCL f
SIZE:
TITLE: Environ
'c Radiological (50 DKT)-Insp Rept/Notice of Violation Respons NOTES: Standardi zed plant.
0500C529 RECIPIENT ID CODE/NAME PD5 LA LICITRAiE INTERNAL:
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EXTERNAL:
1 NOTES:
TQTAL NUMBER OF COPIES REQUIRED:
LTTR 27 ENCL 26
Arizona Nuclear Power Project P.O. BOX 52034
~
PHOENIX, ARIZONA85072-2034 102-00723-EEVB/TDS/KLMC April 21, 1988 NRC Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 0
Subject:
Palo Verde Nuclear Generating Station Unit 2 Docket No.
STN-529 (License NPF-51)
Response
to Notice of Violation 50-529/88-08-02 File:
88-056-026
Reference:
Letter from F. A. Wenslawski (NRC) to E.
E.
Van Brunt, Jr.
(ANPP),
dated March 30, 1988; NRC Inspection Reports 50-528/88-08, 50-529/88-08) 50-530/88-08.
Dear Sirs:
Pursuant to 10CFR2.201, this letter is provided in response to the Notice of Violation as contained in Appendix A of the referenced letter.
The violation was based on the results of the routine onsite inspection conducted by Mr.
W. K. Tenbrook on February 23-24, February 29 and March 1-3, 1988.
The violation and ANPP's response are provided in the attachment to this letter.
If you have any questions, please contact Hr. Timothy Shriver of my staff at (602) 393-2521.
Very truly y rs EEVB/TDS/KLHC/kj Attachment E.
E.
Van Brunt, Jr.
Executive Vice President Project Director e
CC:
0.
M. DeMichele J.
G. Haynes J.
B. Hartin T. J. Polich E. A. Licitra A. C.
Gehr (all w/a) 8805030204 880421 PDR ADOCN, 05000529 G
NRC Document Control Desk Page 1 of 6 102-00723-EEVB/TDS/KLHC April 21, 1988 APPENDIX A NOTICE OF VIOLATION During an inspection conducted on February 24-26 and February 29-March 3,
- 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," 10CFR 2, Appendix C, the following violation is listed below:
A.
Technical Specification 6.8. 1 requires in part that, "Written procedures shall be...implemented,...covering the activities referenced below:
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978,..."
Regulatory Guide 1.33, Appendix A, Section 7, "Procedures for Control of Radioactivity", Item c(2), requires procedures addressing sampling and monitoring of Pressurized Water Reactor (PWR)
Gaseous Effluent Systems.
Licensee procedure 75AC-9ZZ02, Rev.
5, "Gaseous Radioactive Effluent Release Administrative Control",
Section 4.3.13, requires in part "...that samples of Radwaste Systems are collected as per Appendix C, Effluent Sampling Schedule, Procedure 75AC-9ZZ02, Appendix B, "Effluent Sampling Schedule",
requires in part
- that, "gas grab sample...principle gamma emitter analyses...possess a
Lower Limit of Detection (LLD) of 1 E-4 uCi/ml.
Principle gamma emitters include Kr-87, Kr-88, Xe-133, Xe-133m, Xe-138 for gas samples..."
Contrary to the above, on February 25,
- 1988, a principal gamma emitter
'analysis performed on a gas grab sample from Waste Gas Decay Tank (WGDT)
"B" did not achieve the required Lower Limit of Detection for the.
NRC Document Control Desk Page 2 of 6 102-00723-EEVB/TDS/KLMC April 21, 1988 APPENDIX A NOTICE OF VIOLATION CONTINUED following radionuclides:
Kr-87, Kr-88 and Xe-138.
Waste gas decay tank "B" was subsequently discharged without an additional gas grab sample analysis meeting the required sensitivity limits.
This is a Severity Level V Violation (Supplement IV)
NRC Document Control Desk Page 3 of 6 102-00723-EEVB/TDS/KLHC April 21, 1988 A.
REASON FOR THE VIOLATION An evaluation was conducted by the responsible management to determine the root cause of the event discussed in the Notice of Violation and to determine the necessary corrective actions.
As a result of this evaluation the following conclusions were made.
On February 25, 1988 a
grab sample was obtained from the Waste Gas Decay Tank (WGDT) "B" at the request of the Operations Department to determine the feasibility of releasing the gas to the environment.
As a result, the determination was made that a release could be performed in accordance with the requirements of Technical Specifications;
- however, the lower limit of detectability (LLD) had not been met for Kra~, Kr>>, and Xe>>a.
At this time no imminent release was anticipated.
Subsequent to the regularly scheduled shift change, a decision was made to release the contents of WGDT "B".
Upon notification, the on-duty Effluent Chemistry Technician obtained particulate,
- iodine, and tritium samples and used these results in conjunction with the gas grab sample results to generate a release permit.
The root cause of the event has been identified as a
personnel error by the Effluent Chemistry Technician.
Contrary to approved procedural controls (75AC-9ZZ02, Rev.
5, "Gaseous Radioactive Effluent Release Administrative Control" ), the technician did not verify the gas grab sample met the LLD requirements for prinicipal gamma emitters prior to issuing the release permit.
However, the evaluation also concluded that there are administrative enhancements which could be implemented to minimize the probability of recurrence.
NRC Document Control Desk Page 4 of 6 102-00723-EEVB/TDS/KLHC April 21, 1988 B.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon identification of this event by an NRC inspector during routine inspection activities, a revised release permit was generated.
Since values from the release would have been less than gas grab sample LLD through decay, and thus recorded as zero, the possibility existed that the isotope levels could have been greater than the Technical Specification LLD, but less than the February 25, 1988 grab sample LLD.
To assure conservatism in the release permit, the revised permit inserted the LLD values obtained February 25, 1988 as the actual values discharged.
The release permit was then reevaluated and assurance made that the Technical Specification Limiting Condition of Operation was not exceeded.
Additionally, a review of other 1988 release permits was conducted in Unit 2 and no other events of this nature were discovered, therefore, this is considered an isolated event.
- However, as a prudent
- measure, additional corrective actions will be implemented as discussed below.
The.responsible technician voluntarily terminated his employment with ANPP the day following the event.
As a result, no specific action was taken with regard to the employee.
This factor was considered in the root cause evaluation.
Although it is believed this factor may have contributed to the event, it was not considered to have a significant influence.
NRC Document Control Desk Page 5 of 6 102-00723-EEVB/TDS/KLHC April 21, 1988 C.
CORRECTIVE STEPS TAKEN TO AVOID FUTURE VIOLATIONS An evaluation into this event was conducted by the responsible management.
As a result, ANPP believes the following additional corrective actions are prudent and should be effective in preventing recurrence of this type of event:
1)
An evaluation will be conducted of procedure 75AC-9ZZ02 and the review requirements strengthened as necessary for approval of gaseous
\\
releases.
2)
A checklist is being developed in all three units for use on all gaseous effluent samples to ensure that samples taken for permits and permit updates meet all Technical Specification requirements.
3)
A review of this Notice of Violation will be performed with Chemistry and Effluent Technicians in all three units.
A previous incident of failure to meet LLD was identified (reference LER 87-016-00).
.Although in this instance the release was liquid, it would appear that a better appreciation of the LLD requirements is warranted.
Therefore, the review of the Notice of Violation will include a
discussion of LLD and the potential impact of a failure to ensure compliance with the Technical Specification.
This review will be conducted in all three (3) units.
NRC document Control Desk Page 6 of 6 102-00723-EEVB/TDS/KLMC April 21, 1988 4)
A standardized listing of all effluent sample geometries,
- volumes, and count times will be prepared to provide the Technicians with data to ensure the "a priori" sample will meet the Technical Specification requirements for LLD.
D.
DUE DAT FO FULL COMPLIANC 1.
The actions described in item 1, section C of this response is expected to be completed July 1, 1988.
2.
The actions described in item 2, Section C of this response will be completed by April 30, 1988.
3.
The review described in item 3, Section C of this response is expected to be completed May 31, 1988.
4.
Implementation of the standardized listing discussed in item 4, Section C of this response is expected by July 1, 1988.