ML17305A742

Responds to 900330 Enforcement Conference Re Violations Noted in Insp Repts 50-528/90-04,50-529/90-13 & 50-530/90-13.Corrective Action:Special Locking Mechanisms Installed on Currently Posted Radiation Area Doors & Gates

ML17305A742
Person / Time
Site:	Palo Verde
Issue date:	05/03/1990
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-01682-WFC-T, 102-1682-WFC-T, EA-90-056, EA-90-56, NUDOCS 9005100247
Download: ML17305A742 (11)

Text

ACCELERATED DISTjUBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9005100247 'OC ~

FACIL:STN-50-528 Palo Verde Nuclear Station, DATE- 90/05/03 NOTARIZED: NO DOCKET 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 1 RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to 900330 enforcement conference re violations noted in IRs 50-528/90-04,50-529/90-13 & 50-530/90-13.

DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR Q ENCL J SIZE:

TITLE: General (50 Dkt) -Insp Rept/Notice of Violation Response I NOTES: 05000528 Standardized plant. 05000529 Standardized plant. 05000530 I

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 1 PETERSON,S. 1 1 CHAN,T 1 1 ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1' NRR/DLPQ/LPEB10 1 1 NRR/DOEA DIR 11 1 1 NRR/DREP/PEPB9D 1 1 NRR/DRIS/DIR 1 1 NRR/DST/DIR 8E2 1 1 I NRR/PMAS/ LRB1 2 1 1 NUDOCS-ABSTRACT 1 1 OE 1 1 OGC/HDS1 1 1 1 1 RES/DSR/HFB/HFS 1 1 RGN5 FILE 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

P~ HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LIBIB FOR DOCUMBNIS YOU DON'I NBBD!

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e TOTAL NUMBER OF COPIES REQUIRED: LTTR 26

Arizona Public Service Company P,O, BOX 53999 ~ PHOENIX. ARIZONA 85072.3999 WILLIAMF, CONWAY 102-01682-WFC/TRB EXECUTIVEVICEPRESIOENT NUCLEAR May 3, 1990 U. ST Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Reference:

Letter from R. A. Scarano, Director, Division of Radiation Safety and Safeguards to W. F. Conway, Executive Vice President Nuclear, Arizona Public Service, dated April 6, 1990

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

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 Notice of Violation 50-528/90-04-02, 50-530/90-13-01 and 50-530/90-13-02 File'0-070-026 This letter is provided in response to an enforcement conference held on March .

30, 1990 and inspections conducted by NRC inspectors during January - March, 1990. Based on the results of the inspections, four (4) violations of NRC requirements were identified. The violations are discussed in Appendix A of the referenced letter. A restatement of the violations and PVNGS's responses are provided in Appendix A and Attachment 1 and 2, respectively, to this letter.

Should you have any questions regarding this response, please contact me.

Very truly yours, WFC/TRB/tlg Attachments cc: J. B. Martin A. H. Gutterman D. H. Coe T. L. Chan A. C. Gehr 900 00247

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Document Control Desk 102-01682-WFC/TRB Page 1 of 2 May 3, 1990 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Docket Nos. 50-528, 50-529 and 50-530 Palo Verde Unit 1, 2, and 3 License Nos. NPF-41, NPF-51 and NPF-74 EA No. 90-56 During an NRC inspection conducted on January 31, 1990 through February 9, 1990, and February 28, 1990 through March 9, 1990, four violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"10 CFR Part 2, Appendix C (1990), as modified by 53 Fed. Reg. 40019 (October 13, 1988), the violations are listed below:

A. Technical Specifications, Section 6.12.2, provides in part that doors to areas where the dose rate is greater than 1000 mrem/hour shall remain locked except during periods of access control by personnel under an approved REP.

Contrary to the above, (1). On November 6, 1989, a Unit 3 locked high radiation area (LHRA) gate (¹A-B07), that provides access to the "A" shutdown cooling heat exchanger room located on the 70'levation of the Auxiliary Building, was open, unoccupied and unguarded. Maximum radiation levels measured in the room when the discovery was made were 2000 mrem/hr at 18" from the source of radioactive material located in the room.

(2) On November 9, 1989, a Unit 1 LHRA gate (¹R-132) that provides access to the high level storage area located on the of the Radwaste Building, was open, unoccupied, and 112'levation unguarded. Maximum radiation levels measured in the room when the discovery was made were 2000 mrem/hr at 18" (3). On February 22, 1990, a Unit 3 LHRA gate (¹A-B07, see Item 1 above) that provides access to the "A" shutdown cooling heat exchanger room located on the 70'levation of the Auxiliary Building, was open, unoccupied and unguarded. Maximum radiation levels measured in the room upon discovery were 2200 mrem/hr at 18".

These are repetitive Severity Level IV Violations. (Supplement IV)

Document Control Desk 102-01682-WFC/TRB Page 2 of 2 May 3, 1990 B. Technical Specifications, Section 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."

Licensee procedure 75RP-90P02, "Control of Locked High Radiation Areas" identifies responsibilities and actions for the control of locked high radiation areas. The procedure provides that the radiation protection shift lead technician shall be responsible for the control of locked high radiation area (LHRA) keys and radiation protection technicians issued keys for entry to LHRA are responsible to verify that the area is properly secured upon exit and that the keys are returned and the key control log is initialed in the "secured by" block.

Contrary to the above, on February 22, 1990, the Unit 3, day shift lead radiation protection technician failed to control keys to LHRA's as required by the procedure, a Unit 3 radiation protection technician failed to return a LHRA key and initial the key control log as required by the procedure, and during the period of February 27, 1990 through March 7, 1990, ten occasions existed at Unit 2 wherein LHRA keys were returned by someone other than the individual to whom the key had been issued.

This is a Severity Level IV Violation (Supplement IV)

Document Control Desk 102-01682-WFC/TRB Page 1 of 7 May 3, 1990 ATTACHMENT 1 Re 1 to Notice of Violation 50-528 90-04-02 TWO EVENTS I. REASON FOR VIOLATIONS NOVEMBER 6 1989 UNIT 3 EVENT The reason for this violation has been determined to be a probable unauthorized forced entry by an individual(s). The gate in Unit 3 and its locking mechanism showed evidence of tampering. This action is contrary to approved administrative controls.

NOVEMBER 9 1989 UNIT 1 EVENT The reason for this violation has been determined to be a probable unauthorized forced entry by an individual(s). The Unit 1 gate could have been opened with common hand tools. This action is contrary to approved administrative controls.

II. CORRECT VE STEPS THAT HAVE BEEN'AKEN AND THE RESULTS ACHIEVED Special locking mechanisms have been installed on currently posted locked high radiation area (LHRA) doors and gates, outside containment, in all 3 units.

Document Control Desk 102-01682-WFC/TRB Page 2 of 7 May 3, 1990 Applicable Radiation Protection procedures have been revised to require dual verification of LHRA door closure upon exit to reduce the probability of personnel error.

III. CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS APS believes that the actions described above are adequate to prevent recurrence.

Additional corrective actions have been taken as detailed in the response to notice of violation 50-530/90-13-01. Although the corrective actions detailed in 90-13-01 are not a direct result of these violations, APS believes that the additional measures taken will also serve to prevent recurrence of these violations.

IV. DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved for the cited violations on November 6, and November 9, 1989, respectively,. when the LHRA gates were shut and locked upon discovery.

Document Control Desk 102-01682-WFC/TRB Page 3 of 7 May 3, 1990 ATTACHMENT 1 (CONTINUED)

Re 1 to Notice of Violation 50-530 90-13-01 I. REASON FOR VIOLATION The reason for the violation has been determined to be the failure of Radiation Protection (RP) personnel to follow approved LHRA control procedures, including dual verification of LHRA door closure.

II. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED RP personnel responsible have received appropriate disciplinary action.

In addition, the individuals conducted briefings with their peers in all three units on the lessons learned.

The Site RP Manager (RPM) has written a memo to RP personnel detailing management's expectations concerning work practices that control access to LHRA's.

The Unit RPMs have instructed their respective RP personnel on management expectations.

Document Control Desk 102-01682-WFC/TRB Page 4 of 7 May 3, 1990 III. CORRECTIVE STEPS THAT VILL BE TAKEN TO AVOID FURTHER VIOLATIONS As an additional response to the events discussed in this attachment, APS will take the following additional actions to strengthen the level of respect for the administrative controls associated with LHRA's:

General Employee Training will be evaluated to ensure specific emphasis is placed on the potential hazards and necessity for control of radiation areas. This evaluation will be completed by May 15, 1990.

An article will be published in the May 1990 issue of "New Era",

which is distributed site wide, detailing the potential hazards and necessity for control of radiation areas.

A videotape will be produced to reinforce management expectations and the potential hazards and necessity for control of radiation areas, This video will be required viewing for personnel currently having access to the RCA by May 31, 1990.

Document Control Desk 102-01682-WFC/TRB Page 5 of 7 May 3; 1990 IV. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance for the cited violation was achieved on February 22, 1990, when the LHRA gate was shut and locked.

Document Control Desk 102-01682-WFC/TRB Page 6 of 7 May 3, 1990 ATTACHMENT 2 Re 1 to Notice of Violation 50-530 90-13-02 I. REASON FOR VIOLATION The reason for the violation has been determined to be the failure of RP personnel to follow approved LHRA key control procedures. As a point of clarification, the violation cites ten (10) occasions wherein someone, other than the individual to whom the LHRA key was issued, returned the key to the key locker. In fact, the individual to whom the key was issued returned the key however, the incorrect block was initialed on the key control log. Although an administrative error occurred, there was no loss of key control.

II'ORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Applicable RP procedures have been revised to include a review by RP supervision of the LHRA Key Control Log to ensure compliance with administrative controls by RP personnel.

Additional instruction in key control requirements has been provided to Unit RP personnel.

Document Control Desk 102-01682-WFC/TRB Page 7 of 7 May 3, 1990 III'ORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS APS believes that the action taken above, in conjunction with the corrective actions taken in response to the violations discussed in Attachment 1, are adequate to prevent recurrence.

IV. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance for the generic issue of control of keys was achieved by April 15, 1990, upon approval of the procedure to require supervisory review of the key control log.