ML17304A625
| ML17304A625 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/07/1988 |
| From: | Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 102-00698-DBK-T, 102-698-DBK-T, NUDOCS 8810120182 | |
| Download: ML17304A625 (19) | |
Text
e OONALO 8. KARNER EXECUTIVEVICE PRESIOENT Arizona Nuclear. Power Project P.O. 8OX $2034
~
PHOENIX. ARIZONA85072-2034 102-00968-DBK/TDS/KLMC October 7,
1988 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555
Reference:
..Letter from R. A. Scarano, NRC, to D. B. Karner, ANPP, dated September 7,
1988;
Subject:
NRC Inspection of Palo Verde Units 1, 2 and 3 (50-528/88-27, 50-529/88-26 and 50-530/88-25)
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3
Docket Nos.
STN 50-528 (License No. NPF-41)
STN 50-529 (License No. NPF-51)
STN 50-530 (License No. NPF-74)
Response
to Notice of Violation, 50-528/88-27-02, 50-529/88-26-02 and 50-530/88-25-02 File:
88-070-026 This letter is provided in response to a routine inspection conducted by Messrs.
H. Cillis and W. K. Tenbrook of Region V from August 1 through August ll, 1988.
Based on the results of the inspection, a violation of NRC requirements was identified.
The violation is discussed in Appendix A of the i 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, please contact Hr. Timothy Shriver of my staff at (602) 393-2521.
DBK/TDS/KLHC/kj Attachment CC:
E.
E.
J.
G.
T. J.
T. L.
H. J.
A. C.
Van Brunt, Jr.
Haynes Pol i ch Chan Davis Gehr I
(all w/attachment) 0 t: 0)y p~
I "n r
<<v'J 4 h HGic.
O'I"". ~(
(7<<w >-. r,~I,
L
Document Control Desk Page 1 of 1
102-00968-DBK/TDS/KLHC October 7, 1988
~Aeedix A
Notice of Violation Arizona Public Service Company Palo Verde Nuclear Generating Station Unit 2.
Docket Nos. 50-528, 50-529, 50-530 License Nos.
NPF-41, NPF-51, NPF-74 During an inspection conducted on August 1-11, 1988, three violations of NRC requirements were identified.
Two'of the violations will be the subject of separate correspondence.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the remaining violation is listed below:
10 CFR 50.59(b)(1) states in par't, that:
"The licensee shall maintain records of changes in the facility...made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report....
These records must include a written evaluation...."
Sections 11.4 and 12.5 of the licensee's Final Safety Analysis Report (FSAR) identify systems and facilities that are within the site boundary that have been approved for handling and processing of radioactively contaminated material.
Contrary to the above, Trailer 3-2 was recently converted into a respiratory processing facility.
At the time of the inspection, the trailer was being used to temporarily store and process radioactively contaminated respirators.
As of August 11,
- 1988, the licensee had not performed a written safety evaluation addressing the processing of radioactive equipment in Trailer 3-2.
This is a Severity Level IV Violation (Supplement 1).
Document Control Desk Page 1 of 3 102-00968-DBK/TDS/KLMC October 7, 1988
RESPONSE
TO NOTICE OF VIOLATION A.
Reason for Violation In response to questions raised by NRC inspectors during a routine inspection conducted on August 1 through August ll, 1988, ANPP initiated a 10CFR50.59 review in accordance with procedure 79AC-9ZZ07, "10CFR50.59 Review and Evaluation", to determine if the placement of trailer 3-2 and the activities being conducted in the trailer could constitute an unreviewed safety question.
In conjunction with the initiation of the 10CFR50.59 review, an evaluation was conducted to identify the root cause of not performing the required evaluation.
4 On October 1,
- 1987, a Temporary Facilities Work Request was initiated to modify a trailer, install vendor supplied respiratory cleaning equipment
.in the trailer and install the trailer for use in its current location.
On July 27, 1988, the modified trailer had been set up and was established as a Radiological Controlled Area (RCA) in accordance with procedure 75AC-9ZZ01, "Radiation Exposure and Access Control",
and 75RP-OZZOl, "Radiological Posting".
The appropriate Radiation Exposure Permits (REP's) were issued in accordance with procedure 75RP-9ZZ44, "Radiation Exposure Permits" and the trailer was placed in service to decontaminate respirators.
A review of the process which controls the location and installation of temporary facilities identified that no internal requirements exist to perform an evaluation in accordance with 10CFR50.59 prior to the installation or modification of temporary facilities.
The lack of
l l
Document Control Desk Page 2 of 3 102-00968-DBK/TDS/KLHC October 7, 1988 procedural guidance to perform the 10CFR50.59 evaluation when installing or modifying temporary facilities (trailers) external to the'nits has been identified as the root cause of the cited deficiency.
B.
Corrective Ste s Which Have Been Taken and Results Achieved As immediate corrective action, an evaluation in accordance with 10CFR50.59 was initiated.
The results of the evaluation concluded that no unreviewed safety question exists and that the installation of the trailer and the activities performed within the trailer are permissible under the provisions of 10CFR50.59.
C.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The violation issued addressed the performance of radiological work in locations other than those described in the Final Safety Analysis Report (FSAR).
- However, based upon the results of the evaluation discussed in section A of this response, ANPP has expanded the scope of the concern to ensure all aspects of the 10CFR50.59 evaluation process are considered.
As a result, the following actions are being taken:
k 1)
A survey will be conducted to'valuate existing temporary facilities.
Based upon the results of the survey, the appropriate 10CFR50.59 reviews will be conducted.
2)
The 10CFR50.59 evaluation process will be evaluated by the tluclear
Document Control Desk Page 3 of 3 102-00968-DBK/TDS/KLMC October 7, 1988 Safety Group (NSG).
The results of the evaluation will be forwarded to the responsible department for consideration with respect to enhancing the overall program.
3)
The process which initiates the installation or modification of temporary facilities will be evaluated under the direction of the lead manager.
Based upon the results of the evaluation, procedural guidance will be provided to specifically address the requirement to consider the applicability of ANPP's requirements under the provisions of 10CFR50.59.
D.
Date When Corrective Actions Will Be Com leted Because the planned corrective actions are dependent upon the completion of the evaluations the following implementation schedule has been established:
a)
The survey discussed in section C item 1 of this response is currently scheduled for completion in November 1988.
The required 10CFR50.59 evaluations will be initiated as appropriate.
b)
The evaluation of the 10CFR50.59 process discussed in section C item 2 of this response is currently scheduled for completion in December 1988.
c)
The process evaluation discussed in section C item 3 of this response is currently scheduled for completion in December 1988.
P
~
t
ACCELHMTZD IHSXRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CESSION NBR:8810120182 DOC ~ DATE: 88/10/07 NOTARIZED: NO, DOCKET 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 KARNER,D.B.
Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 880907 ltr re violations noted in Insp Repts 50-528/88-27,50-529/88-26
& 50-530/88-25.
DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Standardized plant.
Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PD5 PD DAVIS,M INTERNAL: ACRS DEDRO NRR/DLPQ/PEB ll NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 OE LgEBERMAN,J EgG
~
02 RGN ILE 01 EXTERNAL: LPDR NSIC NOTES COPIES LTTR ENCL 1
1 1
1 2
2 1
1 1
1 1
1 2
2 1
1 1
1 1
1 1
1 1
1 1
1 1
1 RECIPIENT ID CODE/NAME CHAN,T LICITRA,E AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS 1 RES/DSIR DEPY NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 05000528 S
05000529 05000530 j A
j A
TOTAL NUMBER OF COPIES REQUIRED:,LTTR 27 ENCL 27
DONALD 8. KARNER EXECUTIVE VICE PRESIDENT Arizona Nuclear Power Project P.O. BOX 52034
~
PHOENIX, ARIZONA85072-2034 102-00968-DBK/TDS/KLHC October 7,
1988 Document Control Desk U.
S. Nuclear Regulatory Commission Washington, DC 20555
Reference:
Letter from R. A. Scarano, NRC, to D. B. Karner, ANPP, dated September 7,
1988;
Subject:
NRC Inspection of Palo Verde Units 1, 2 and 3 (50-528/88-27, 50-529/88-26 and 50-530/88-25)
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3
Docket Nos.
STN 50-528 (License No. NPF-41)
STN 50-529 (License No.
STN 50-530 (License No.
Response
to Notice of Violation, 50-528/88-27-02, 50-529/88-26-02 and 50-530/88-25-02 File:
88-070-026 This letter is provided in response to a routine inspection conducted by Hessrs.
H. Cillis and W. K. Tenbrook of Region V from August 1 through August 11, 1988.
Based on the results of the 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 respo'nse, please contact Hr. Timothy Shriver of my staff at (602) 393-2521.
DBK/TDS/KLHC/kj Attachment cc:
E.
E.
Van Brunt, Jr.
J.
G., Haynes J.
B. Hartin T. J. Polich T. L. Chan H, J.
Davis A.
C.
Gehr 33i0220i32 331007 Poli ADOCK'5000 23 0
PDC (all w/attachment)
Document Control Desk Page 1 of 1
102-00968-DBK/TDS/KLHC October 7, 1988
~Aeedix A
Notice of Violation Arizona Public Service Company Palo Verde Nuclear Generating Station Unit 2 Docket Nos.
50-528, 50-529, 50-530 License Nos.
NPF-41, NPF-51, NPF-74 During an inspection conducted on August 1-11, 1988, three violations of NRC requirements were identified.
Two of the violations will be the subject of separate correspondence.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the remaining violation is listed below:
10 CFR 50.59(b)(1) states in part, that:
"The licensee shall maintain records of changes in the facility...made pursuant to this section, to the extent that these changes constitute changes in the facility as described in the safety analysis report....
These'ecords must include a written evaluation...."
Sections 11.4 and 12.5 of the licensee's Final Safety Analysis Report (FSAR) identify systems and facilities that are within the site boundary that have been approved for handling and processing of radioactively contaminated material.
Contrary to the above, Trailer 3-2 was recently converted into a respiratory processing facility.
At the time of the inspection, the trailer was being used to temporarily store and process radioactively contaminated respirators.
As of August 11, 1988, 'the licensee had not performed a written safety evaluation addressing the processing of radioactive equipment in Trailer 3-2.
This is a Severity Level IV Violation (Supplement 1).
Document Control Desk Page 1 of 3 102-00968-DBK/TDS/KLMC October 7, 1988
RESPONSE
TO NOTICE OF VIOLATION A.
Reason for Violation In response to questions raised by NRC inspectors during a routine inspection conducted on August 1 through August 11,
- 1988, ANPP initiated a 10CFR50.59 review in accordance with procedure 79AC-9ZZ07, "10CFR50.59 Review and Evaluation", to determine if the placement of trailer 3-2 and the activities being conducted in the trailer could constitute an unreviewed safety question.
In conjunction with the initiation of the 10CFR50.59 review, an evaluation was conducted to identify the root cause of not performing the required evaluation.
On October 1,
- 1987, a Temporary Facilities Work Request was initiated to modify a trailer, install vendor supplied respiratory cleaning equipment in the trailer and install the trailer for use in its current location.
On July 27, 1988, the modified trailer had been set up and was established as a Radiological Controlled Area (RCA) in accordance with procedure 75AC-9ZZ01, "Radiation Exposure and Access Control",
and 75RP-OZZ01, "Radiological Posting".
The appr'opriate Radiation Exposure Permits (REP's) were issued in accordance with procedure 75RP-9ZZ44, "Radiation Exposure Permits" and the trailer was placed in service to decontaminate respirators.
A review of the process which controls the location and installation of temporary facilities identified that no internal requirements exist to perform an evaluation in accordance with 10CFR50.59 prior to the installation or modification of temporary facilities.
The lack of
Document Control Desk Page 2 of 3 102-00968-DBK/TDS/KLNC October 7, 1988 procedural guidance to perform the 10CFR50.59 evaluation when installing or modifying temporary facilities (trailers) external to the units has been identified as the root cause of the cited deficiency.
B.
Corrective Ste s Which Have Been Taken and Results Achieved As immediate corrective action, an evaluation in accordance with 10CFR50.59 was initiated.
The results of the evaluation concluded that no unreviewed safety question exists and that the installation of the trailer and the activities performed within the trailer are permissible under the provisions of 10CFR50.59.
C.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The violation issued addressed the performance of radiological work in locations other than those described in the Final Safety Analysis Report (FSAR).
- However, based upon the results of the evaluation discussed in section A of this response, ANPP has expanded the scope of the concern to ensure all aspects of the 10CFR50.59 evaluation process are considered.
As a result, the following actions are being taken:
1)
A survey will be conducted to evaluate existing temporary facilities.
Based upon the results of the survey, the appropriate 10CFR50.59 reviews will be conducted.
2)
The 10CFR50.59 evaluation process will be evaluated by the Nuclear
Document Control Desk Page 3 of 3 102-00968-DBK/TDS/KLHC October 7, 1988 Safety Group (NSG).
The results of the evaluation will be forwarded to the responsible department for consideration with respect to enhancing the overall program.
3)
The process which initiates the installation or modification of temporary facilities will be evaluated under the direction of the lead manager.
Based upon the results of the evaluation, procedural guidance will be provided to specifically address the requirement to consider the applicability of ANPP's requirements under the provisions of 10CFR50.59.
D.
Date When Corrective Actions Will Be Com leted Because the planned corrective actions are dependent upon the completion of the evaluations the following implementation schedule has been established:
a)
The survey discussed in section C item 1 of this response is currently scheduled for completion in November 1988.
The required 10CFR50.59 evaluations will be initiated as appropriate.
b)
The evaluation of the 10CFR50.59 process discussed in section C item 2 of this response is currently scheduled for completion in December 1988.
c)
The process evaluation discussed in section C item 3 of this response is currently scheduled for completion in December 1988.