ML17310B221
| ML17310B221 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/13/1994 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02908-WFC-A, 102-2908-WFC-A, NUDOCS 9404190313 | |
| Download: ML17310B221 (14) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM 05000528 D
05000529 05000530 D
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9404190313 DOC.DATE: 94/04/13 NOTARIZED: NO DOCKET I 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 R
CONWAY,W. F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFXLIATION I
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to violation noted in insp repts 50-528/94-02, 50-529/94-02
& 50-530/94-02.Corrective actions: work suspended
& remaining crew members briefed to emphasize S
responsibility to wear
& control ACADs dosimetry.
/
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE'ITLE:
General (50 Dkt)-Xnsp Rept/Notice of Violation esponse A
NOTES:STANDARDXZED PLANT Standardized plant.
Standardized plant.
RECIPIENT XD CODE/NAME PDXV-3 PD TRAN,L ERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB
~ NRR/PMAS/ILPB1 NUDOCS-ABSTRACT OGC/HDS1 RES/HFB EXTERNAL EG&G/BRYCEIJ ~ H ~
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1 RECIPIENT XD CODE/NAME HOLIAN, B AEOD/DEXB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 REG~
02 RGN4 FILE 01 NRC PDR COPIES LTTR ENCL 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE iVASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. M79) TO ELIMINATEYOUR NAME FROM DISTRIBUTION t
LISTS FOR DOCUMENTS YOU DON'T NEED TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25.
ENCL 25 D
D
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WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
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PHOENIX, ARIZONA85072-3999 102-02908-WFC/AKK/PJC April 13, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, D. C. 20555
Reference:
Letter dated March 16, 1994, from C. A. VanDenburgh, Acting Deputy Director, Division of Reactor Safety and Projects, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS
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 50-529/94-02-01 File: 94-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/94-02 and the Notice of Violation dated March 16, 1994.
Enclosure 1 to this letter is a restatement of the Notice of Violation.
APS'esponse is provided in.
Should you have any questions, please call Angela K. Krainik (602) 393-5421.
Sincerely, WFC/AKK/PJC
Enclosures:
1.
Restatement of Notice of Violation 2.
Reply to Notice of Violation cc:
L. J. Callan K. E. Perkins, Jr.
K. E. Johnston 94041TI0313 940414 PDR ADOCK 05000528 9
i
ENCLOSURE 1
RESTATEMENT OF NOTICE OF VIOLATION50-529/94-02-0 t NRC INSPECTION CONDUCTED JANUARY 11 THROUGH FEBRUARY 14, 1994
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e Restatement of Notice of Violation 50-529 94-02-01 During an NRC inspection conducted on January 11 through February 14, 1994, one 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, the violation is listed below:
A.
Unit 2 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978.
Regulatory Guide 1.33, Appendix A, requires, in part, that procedures be prepared for (1) access control to radiation areas and (2) security and visitor control.
Procedure 75AC-9RO01, revision 2, "Radiation Exposure and Access Control,"
Step 3.2.3, requires that personnel be issued dosimetry which shall be worn at all times within the radiological controlled area (RCA).
Step 3.2.4.1 requires that dosimetry shall normally be worn on the front of the body between the thigh and head, unless directed otherwise by radiation protection (RP).
Procedure 20AC-OSK04, revision 9, "Protected/Vital Area Personnel Access Control," Step 3.2.1, requires that automatic controlled access devices (ACADs),
shall be displayed by all individuals while inside protected/vital areas and shall be positioned on the front of the outermost garment, between the neck and the waist, photograph side out.
Contrary to the above, on January 25, 1994, a contract employee who had been issued dosimetry for work within the RCA and had been issued an ACADfor work inside the protected area was not wearing the dosimetry on the front of his body between the thigh and head and was not wearing the ACAD between the neck and waist.
The employee had removed his ACAD and dosimetry and placed it several feet away.
This is a Severity Level IV violation (Supplements III and'IV) applicable to Unit 2.
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ENCLOSURE 2 REPLY TO NOTICE OF YIOLATION50-529/94-02-01 NRC INSPECTION CONDUCTED
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JANUARY 11 THROUGH FEBRUARY 14, 1994
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0 REPLY TO YIOLATiONA 50-529 94-02-04 Reason For The Violation The violation was the result of a personnel error by a contract employee working in the Steam Generator Chemical Cleaning Tank Farm area.
The APS investigation found that the individual had been attempting to operate a valve associated with chemical cleaning.
The lanyard to which his Automated Controlled Access Device (ACAD) and dosimetry were attached interfered with the performance of the task, so the individual removed it and placed it aside, approximately three to four feet away, in order to complete the task.
This action was not in accordance with the governing administrative controls for personnel access to the protected area and the radiologically controlled area.
Corrective Ste s That Have Been Taken And Results Achieved As immediate corrective action, Radiation Protection personnel surveyed the area in which the individual was working, denied him further access to the radiologically controlled area (RCA), pulled and read his dosimetry, and performed an exposure evaluation.
Based upon the survey and the exposure evaluation, APS determined that the individual could have received a maximum, unmonitored exposure of.003 millirem.
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S curity Department personnel suspended the individual's protected area access.
A security computer transaction log was run which verified that no unauthorized use of the individual's ACAD had occurred while it was not within his immediate control.
The contract company released the worker, and he is no longer employed at the PVNGS site.
Corrective Ste s That Will Be Taken To Avoid Further Violations K
Work was suspended, and the remaining crew members were briefed to Date When Full Com liance Will Be Achieved Full compliance was achieved on January 25, 1994, when the individual's access was revoked, and the remaining crew members were briefed by their supervision.
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