ML20036A811
| ML20036A811 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/27/1993 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML20036A812 | List: |
| References | |
| EA-93-039, EA-93-39, NUDOCS 9305170037 | |
| Download: ML20036A811 (3) | |
See also: IR 05000528/1993003
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NUCLEAR REGULATOhY COMMISSION
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REGION V
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1450 MAR!A LANE
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WALNUT CREEK, CAUFORN!A MSM-5368
..PR 2 71993
Dockets:
50-528, 50-529, 50-530
Licenses: NPF-41, NPF-51, and NPF-74
EA 93-039
Arizona Public Service Company
AITN: Mr. William F. Conway
Executive Vice President, Nuclear
P. O. Box 53999, Sta. 9012
Phoenix, Arizona 85072-3999
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-528/93-03, 50-
529/93-03, and 50-530/93-03)
This letter refers to our inspection, conducted at your Palo Verde Nuclear
Generating Station from January 11 to February 12, 1993, that reviewed an
instance of worker radiation exposure that occurred on December 21, 1992.
The
incident was reported by telephone to NRC as a potential overexposure on
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December 24, 1992, and in Licensee Event Report 1-92-17, dated January 20,
1993.
Several violations related to the incident were identified by your
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investigation and confirmed by our inspection, as reported in Inspection
Report 50-528/93-03, 50-529/93-03, and 50-530/93-03, transmitted by cover
letter dated March 1, 1993. These violations, and your subsequent corrective
actions, were the topic of an enforcement conference held at our Region V NRC
office on March 16, 1993, as reported in Enforcement Conference Report 50-
528/93-16, 50-529/93-16, and 50-530/93-16, transmitted by cover letter dated
March 24, 1993.
Each of the violations addressed in the enclosed Notice of Violation (Notice)
relates to circumstances surrounding the December 21, 1992, incident.
Violation A involved the whole-body radiation exposure of 2.445 rems to a
contract worker during the fourth quarter of 1992, an exposure in excess of
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the 10 CFR 20.101(a) limit of 1.25 rems per calendar quarter.
Violation B-
involved your failure to conduct a radiation survey, as required by 10 CFR 20.201(b), in a manner appropriate for evaluating the job-specific radiation
hazards incident to removal of a resin fill-head and capping the resin liner.
Violation C involved your failure to supply appropriate personnel monitoring
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equipment as specified in 10 CFR 20.202(a).
Violation D involved ten
instances of failure to follow procedures for personnel radiation protection,
as required by Technical Specification 6.11.1.
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Your corrective actions for these violations included a thorough investigation
of the circumstances leading to the incident, re-training and discipline for
the individuals responsible, restructuring of your ALAPA planning
organization, and a revision of major aspects of your radiation protection
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(RP) management controls. We have reviewed both the corrective actions you
have already taken and those proposed for the near future, and they should be
effective in preventing recurrence of similar incidents involving radiation
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We will continue to monitor your implementation of these corrective
exposure.
actions as well as your efforts to address previous quality assurance audit
findings in the radiological controls area.
We recognize that the exposure received by the contract worker would have been
within the limits provided by 10 CFR 20.101(b), had certain specified
administrative conditions been met prior to the exposure. However, an
inadequate pre-job survey, the multiple failures to follow procedures, the
lack of croper dosimetry, and apparent less stringent standards for health
physics monitoring of activities performed entirely within your RP
organization contributed to what we believe was a substantial potential for
the worker to have received a significantly higher exposure than was actually
incurred. Therefore, in accordance with the " General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2,
Appendix C, these violations are classified in the aggregate as a Severity
Level III problem. The decision to include the procedural violations as part
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of the Severity Level III problem was made not only to emphasize the number of
such violations but also the fact that those violations were committed by
numerous personnel, including a number of supervisors in your RP organization.
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In accordance with the Enforcement Policy, a civil penalty is considered for a
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Severity Level III problem.
However, after consultation with the Director,
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Office of Enforcement and the Deputy Executive Director for Nuclear Reactor
Regulation, Regional Operations, and Research, I have decided that a civil
penalty will not be proposed in this case.
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The base civil penalty was fully mitigated based on your identification of the
excessive exposure which resulted from the thoroughness of your investigation
of a dosimeter discrepancy, the broad scope and promptness of your corrective
actions which addressed multiple aspects of management controls needing
improvement, and despite seven violations in radiological controls since the
last SALP report, your past overall good performance in Health Physics.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
In your
response, you should document the specific actions taken and any additional
actions you plan to prevent recurrence. After reviewing your response to this
Notice, including your proposed corrective actions and the results of future
inspections, the f;RC will determine whether further NRC enforcement action is
necessary to ensure compliance with NRC regulatory requirements.
In accordance with 10 CFR ?.790 of the NRC's " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this g* letter and the enclosed Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, Pub. L. No.95-511.
Sincerely,
hs
WM
John B. Martin
Ecgicnal Administratcr
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Enclosure:
cc w/ enclosure:
Mr. Steve Olea, Arizona Corporation Commission
James A. Beoletto, Esq., Southern California Edison Company
Mr. Charles B. Brinkman, Manager, ABB Combustion Engineering Nuclear Power
Mr. Aubrey Godwin, Director, Arizona Radiation Regulatory Agency
Chairman, Maricopa County Board of Supervisors
Jack R. Newman, Esq., Newman & Holtzinger, P.C.
Mr. Curtis Hoskins, Executive Vice President and Chief Operating Officer,
Palo Verde Services
Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld
Bradley W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld
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