ML17312B401

Forwards Response to Violations Noted in Insp Repts 50-528/97-07,50-529/97-07 & 50-530/97-07.Corrective Actions:Discussions on Event Held W/Rp Personnel During Shift Turnover Meetings on 970313

ML17312B401
Person / Time
Site:	Palo Verde
Issue date:	04/29/1997
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-03919-JML-A, 102-3919-JML-A, NUDOCS 9705050110
Download: ML17312B401 (26)

Text

MAY g> 897 Commrrrrienr. Innovation. &ertiy.

Palo Verde! tuclear Generating Station James M. Levine Senior Vice > esidert Nuclear

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102-03919-JML/AKK/DRL April 29, 1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555<001

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Subject:

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Palo Verde Nuclear Generating Station (FROGS)

Units 1, 2, and 3 Docket Nos. STN 0 Reply to Notice of Violationgi~gO)9jgQ@8,<

Arizona Public Service Company (APS) has reviewed NRC inspection Report 50-l 528/529/530/97-07 and the Notice of Violation (NOV) dated March 31, 1997.

Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.

Enclosure 1 to this letter is a restatement of the NOV. APS'esponse is provided in Enclosure 2.

Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421.

Sincerely, f

/

JML/AKK/DRL

Enclosures:

1. Restatement of Notice of Violation

2. Reply to Notice of Violation 0

J. W. Clifford K. E. Johnston K. E. Perkins 1

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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-530/97-07-03 NRC INSPECTION CONDUCTED MARCH 10 THROUGH MARCH 14, 1997 INSPECTION REPORT No. 50-528/529/530/97-07

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0 RESTATEMENT OF NOTICE OF VIOLATION50-530/97-07-03 During an NRC inspection conducted on March 10-14, 1997, one violation of NRC requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:.

10 CFR 20.1003 defines a radiation area as an area accessible to individuals in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

10 CFR 20.1902 (a) requires that radiation areas be posted with a conspicuous sign or signs bearing the radiation symbol and the words."CAUTION RADIATIONAREA."

Contrary to the above, on March 12, 1997, the inspector identified that the Unit 3 fuel building west stairway leading to the 140 foot elevation, which involved radiation levels of 10 millirem per hour at 30 centimeters, was not posted as "Caution Radiation Area" from March 4-12, 1997.

This is a Severity Level IVviolation (Supplement IV) (530/9707-03).

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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION60-630/97-07-03 NRC INSPECTION CONDUCTED MARCH 10 THROUGH MARCH 14, 1997 INSPECTION REPORT Nos. 50-528/529/630/97-07

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REPLY TO NOTICE OF VIOLATION50-530/97-07-03 Reason For The Violation Prior to February 28, 1997, the 100'nd 140'levations of the Unit 3 Fuel Building were,considered'radiation areas.

Access points to these

areas, including the west stairwell, were properly posted as "Caution Radiation Area". This is best understood (envisioned) as two radiation area islands connected by a non-radiation area stairwell (west). This west stairwell connects the 140'o the 100'nd nothing else.

Incident investigators determined that on February 28, 1997, Radiation Protection (RP) personnel removed an apparent extra posting on the 140'est stairwell while failing to identify and remove the 100'est stairwell posting. The investigators found that RP personnel envisioned, with the removal of the apparent extra

posting, one large radiation area consisting of the 100', 140'nd the connecting west stairwell.

On March 12, 1997, an NRC inspector identified the 100'est stairwell radiation area posting with no posting at the connecting 140'levation. Under this condition, a worker ascending the west stairwell, starting at the 100'levation, would conclude that they had exited one radiation area island, were climbing a non-radiation area stairwell and would arrive at a 140'on-radiation area even though the 140'as actually a radiation area.

This created an unposted access point to the 140'adiation area.

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Follow'ing NRC identification, the 100'est stairwell radiation area posting was removed which resulted in a configuration of one large radiation area: the 100'.

140'nd the connecting stairwell.

The root cause of this event is attributed to personnel error due to a lack of attention to detail which occurred on February 28, 1997 when RP personnel failed to identify and remove the radiation area posting at the 100'f the Unit 3 Fuel Building west stairwell.

Corrective Ste s That Have Been Taken and Results Achieved Upon identification, the additional radiation area posting located on the 100'levation of the Unit 3 Fuel Building was promptly removed resulting in compliance with 10 CFR Discussions on this event were held with RP personnel during shift turnover meetings on March 13, 1997.

Corrective Ste s That WillBe Taken To Avoid Further Violations This event, the importance of attention to detail and considering adjacent areas when performing posting changes will be covered with RP personnel during upcoming quarterly training.

U Date When Full Com liance Will Be Achieved Full compliance was achieved on March 12, 1997 when the additional radiation area posting was removed.

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CATEGORY j.

5050110 DOC.DATE: 97/04/29 NOTARIZED:

NO DOCKET Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTHOR AFFILIATION Arizona Public Service Co. (formerly Arizona Nuclea Power RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to violations noted in insp repts 50-528/97-07,50-529/97-07

& 50-530-97/-07.Corrective actions:discussions on event held w/RP personnel during

,shift turnover meetings on 970313.

DISTRIBUTION CODE:

IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response

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REGULATORY INFORMATjON DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:970 FACIL:STN"50-528 STN-50-529 STN-50-530 AUTH.NAME.

LEVINE,J.M.

RECIP.NAME NOTES:STANDARDIZED PLANT Standardized plant.

Standardized plant.

05000528 05000529 05000536 C

INTERNAL:

RECIPIENT ID CODE/NAME PD4-2 PD ACRS AEO LE CENT HHFB NRR/DRPM/PERB OE DIR RGN4 FILE 01 COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

1 1

1 1

1 1

1 RECIPIENT ID CODE/NAME CLIFFORDiJ AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 COPIES LTTR ENCL 1

1 1

1 1

1 1

1 1

1 1

1 1

1 EXTERNAL: LITCO BRYCEgJ H

NRC PDR 1

1 1

1 NOAC NUDOCS FULLTEXT 1

1 1

1 C

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)

ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:

LTTR 20 ENCL 20

Commttment. tnnmrnttnn. Energy.

Palo Verde Nuclear Generating Station James M. Levine Senior Vice President Nuclear TEL (602)393-5300 FAX (602)393-6077 Mail Station 7602 P.O. Box 52034 Phoenix, AZ 85072-2034 102-03919-JML/AKK/DRL April 29, 1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notice of Violation 50-530/97-07-03 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/97-07 and the Notice ofViolation (NOV) dated March 31, 1997.

Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.

Enclosure 1 to this letter is a restatement of the NOV. APS'esponse is provided in Enclosure 2.

Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421.

Sincerely, JML/AKK/DRL

Enclosures:

1. Restatement of Notice of Violation

2. Reply to Notice of Violation cc:

E. W. Merschoff J. W. Clifford K. E. Johnston K. E. Perkins

'tt705050i i0 970429 PDR ADOCK 05000528 PDR

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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-530/97-07-03 NRC INSPECTION CONDUCTED MARCH 10 THROUGH MARCH 14, 1997 INSPECTION REPORT No. 60-628/529/630/97-07

RESTATEMENT OF NOTICE OF VIOLATION50-530/97-07-03 During an NRC inspection conducted on March 10-14, 1997, one violation of NRC requirements was identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

10 CFR 20.1003 defines a radiation area as an area accessible to individuals in which radiation levels could result in an individual receiving a dose equivalent in excess of 5 millirem in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates.

10 CFR 20.1902 (a) requires that radiation areas be posted with a conspicuous sign or signs bearing the radiation symbol and the words "CAUTION RADIATIONAREA."

Contrary to the above, on March 12, 1997, the inspector identified that the Unit 3 fuel building west stairway leading to the 140 foot elevation, which involved radiation levels of 10 millirem per hour at 30 centimeters, was not posted as "Caution Radiation Area" from March 4-12, 1997.

This is a Severity Level IVviolation (Supplement IV) (530/9707-03).

i

ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION60-530/97-07-03 NRC INSPECTION CONDUCTED MARCH 10 THROUGH MARCH 14, 1997 INSPECTION REPORT Nos. 60-628/629/630/97-07

REPLY TO NOTICE OF VIOLATION50-530/97-07-03 Reason For The Violation Prior to February 28, 1997, the 100'nd 140'levations of the Unit 3 Fuel Building were considered radiation areas.

Access points to these

areas, including the west stairwell, were properly posted as "Caution Radiation Area". This is best understood (envisioned) as two radiation area islands connected by a non-radiation area stairwell (west). This west stairwell connects the 140'o the 100'nd nothing else.

Incident investigators determined that on February 28, 1997, Radiation Protection (RP)

I personnel removed an apparent extra posting on the 140'est stairwell while failing to identify and remove the 100'est stairwell posting. The investigators found that RP personnel envisioned, with the removal of the apparent extra

posting, one large radiation area consisting of the 100', 140'nd the connecting west stairwell.

On March 12, 1997, an NRC inspector identified the 100'est stairwell radiation area posting with no posting at the connecting 140'levation. Under this condition, a worker ascending the west stairwell, starting at the 100'levation, would conclude that they had exited one radiation area island, were climbing a non-radiation area stairwell and would arrive at a 140'on-radiation area even though the 140'as actually a radiation area.

This created an unposted access point to the 140'adiation area.

i i

(g 4

Following NRC identification, the 100'est stairwell radiation area posting was I

removed which resulted in a configuration of one large radiation area; the 100',

140'nd the connecting stairwell.

The root cause of this event is attributed to personnel error due to a lack of attention to detail which occurred on February 28, 1997 when RP personnel failed to identify and remove the radiation area posting at the 100'f the Unit 3 Fuel Building west stairwell.

Corrective Ste s That Have Been Taken and Result+ Achieved Upon identification, the additional radiation area posting located on the 100'levation of the Unit 3 Fuel Building was promptly removed resulting in compliance with 10 CFR 20.1902(a) requirements.

Discussions on this event were held with RP personnel during shift turnover meetings on March 13, 1997.

Corrective Ste s That WillBe Taken To Avoid Further Violations This event, the importance of attention to detail and considering adjacent areas when performing posting changes will be covered with RP personnel during upcoming quarterly training.

Date When Full Com liance WillBe Achieved Full compliance was achieved on March 12, 1997 when the additional radiation area posting was removed.