ML20036A815
| ML20036A815 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/27/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20036A812 | List: |
| References | |
| 50-528-93-03, 50-528-93-3, EA-93-039, EA-93-39, NUDOCS 9305170041 | |
| Download: ML20036A815 (8) | |
Text
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t NOTICE OF VIOLATION Arizona Public Service Company Docket 50-528 Palo Verde Unit 1 License NPF-41 EA 93-039 During an NRC inspection conducted on January 11 through February 12, 1993, 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, the violations are listed below:
A.
10 CFR 20.101(a) requires that the licensee limit the whole body radiation dose of an individual in a restricted area to one and one quarter rems per calendar quarter, except as provided by 10 CFR 20.101(b).
10 CFR 20.101(b) allows a licensee to permit an individual in a restricted area to receive a whole body radiation dose of three rems per calendar quarter provided the dose when added to the individual's accumulated occupational dose to the whole body does not exceed the applicable limit and the individual has a completed Form NRC-4 or equivalent record on file.
Contrary to the above, on December 21, 1992, the licensee did not limit the whole body radiation dose of an individual in the Unit I radwaste truck bay, a restricted area, to one and one quarter rems per calendar quarter and the conditions of 10 CFR 20.101(b) were not met.
Specifically, the individ"al received a whole body dose of 2.445 rems during the fourth calendar quarter of 1992 without a completed form NRC-4 or equivalent record on file.
B.
10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of Part 20 and which are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions.
Contrary to the above, as of December 21, 1992, the licensee did not make surveys to assure compliance with the limits of 10 CFR 20.101 for the radiation exposure to the whole body. Specifically, during the fill head removal and capping of the high-integrity container, the radiation hazards incident to removing the resin fill head and the worker putting l
his hand in the fill hole were not evaluated.
C.
10 CFR 20.202(a)(3) requires that each li,censee supply appropriate personnel monitoring equipment to, and require the use of such equipment by, each individual who enters a high radiation area.
Contrary to the above, on December 21, 1992, the licensee did not supply appropriate personnel monitoring equipment to a contract worker who entered a high radiation area. Specifically, the dosimetry issued to the f
9305170041 930427 DR ADOCK 05000528 PDR
t worker was not appropriate in that the portion of the worker's body i
receiving the highest whole body dose, the left upper arm, was not monitored.
t D.
Technical Specification 6.11.1 states, " Procedures for personnel i
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."
1.
Procedure 75PR-0RP03, Revision 2, "ALARA Program," states:
3.8.2 Station modifications or equipment l
changes which may affect radiation i
exposure shall receive an ALARA review j
based on Regulatory Guide 8.8.
Contrary to the above, in January 1992, the licensee changed radwaste disposal containers for high radiation area applications from metal Enviralloy to polyethylene high-integrity containers (HIC), a modification which could affect radiation exposure, and did not perform an ALARA review of this equipment change.
2.
Procedure 75PR-9ALO3, Revision 3.00, "ALARA Pre-job Planning,"
contains instructions for the Radiation Exposure Permit (REP)Section i
preparer to follow as part of the pre-job planning process.
3.1, " Pre-Job Planning," makes the following statements:
3.1.2 Determination of Job Scope 3.1.2.1 The job scope should be determined such that the REP, when written, adequately addresses specific radiological conditions nd protective requirements.
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Section 3.1, " Pre-Job Planning," further states:
l 3.1.6 RP Interface with Planners / Work Group 3.1.6.2 Address aspects of the job that might l
affect personnel exposures such as l
body position, special tools. etc.
Contrary to the above, on December 15 - 21, 1992, a work planner did not determine the scope of the work to be performed and did not communicate with the work group so as to address aspects of the job t
I that might affect personnel exposures, when preparing REP l-92-1059-A.
Specifically, the planner was not aware that the job involved working in the prone position on top of the HIC or that the worker j
would be inserting his hand into the HIC's resin fill hole (the i
location of the highest exposure rates).
3.
Procedure 75RP-9RP02, Revision 2.00, " Radiation Exposure Permits,'
5ection 2.1.1 provides that RP Supervision /Managoment are l
f f
" responsible for required reviews and approvals of REPS [ radiation exposure permits) per Appendix F, the Job Hazard Evaluation System (JHES) Category Index."
Appendix F states that Category 1 tasks:
... are considered the most radiologically hazardous work that we encounter.
When REP's are written for Category 1 work, the Manager, Unit RP shall sign the approval section of the REP. The Manager, RP Operations shall also review and sign the REP.
Contrary to the above, the Unit RP Manager's approval signature did not appear on REP 1-92-1059-A on December 21, 1992, when the REP was issued, even though the job was classified as JHES Category 1.
4.
Section I of the ALARA Review Form states that when an REP meets JHES Category I criteria, a Site ALARA review is required.
Contrary to the above, on December 21, 1992, the Acting ALARA/ Work Control Supervisor did not forward REP package 1-92-1059-A, a JHES Category 1 REP, to Site ALARA for review.
5.
Section I of the ALARA Review Form states that when a REP meets JHES Category I criteria, a Site ALARA review is required.
Procedure 75RP-9RP02, Revision 2.00, " Radiation Exposure Permits," states in Section 3.2, " REP Preparation," the following:
3.2.21 RPS - The signature in the RPS block verifies that the controls identified on the REP ensure adequate radiological protection and that the REP is a complete document (e.g., required ALARA Reviews are complete, etc.)
Contrary to the above, on December 18, 1992, the Acting ALARA/ Work Control Supervisor signed the RPS block on REP 1-92-1059-A prior to Site ALARA review being completed.
5.
Procedure 75RP-b..t03, Revision 3.00, "ALARA Pre-Job Planning,"
states:
3.4.3 ALARA Reviews (Section 2) require review and approval by the Manager, RP Operations.
Contrary to the above, the RP Operations Manager did not review or approve the Site ALARA review on REP 1-92-1059-A prior to the REP being issued on December 21, 1992.
7.
Procedure 76CP-9f;P06, Revision 2, *0perating Procedure - Resin Drying (Dewatering) System," requires in Section 5.4.1 that workers
'Tollow all instructions on the REP."
REP 1-92-1059-A included the
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follcwing instructions to the workers performing the fill head i
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removal:
"A/S [ air sample] during fill head removal."
e
" Remotely install lid w 'T Handle.' [ sic)"
e "No work other than described above will be permitted e
on this REP" Contrary to the above, on December 21, 1992, workers did not use the "T Handle" to install the HIC lid and no air sample was taken while performing the work authorized by REP 1-92-1059-A. Additionally, RP technicians working under this REP performed a resin sample split, work not authorized under REP l-92-1059-A.
S.
Procedure 75RP-9RP10 Rev. 1.2, " Conduct of Radiation Protection Operations," states the following RP Senior Technician job coverage l
I duties:
2.2.4 Be aware of activities in the designated area of responsibility, provide adequate supervision and radiation protection surveillance to ensure the appropriate procedures are followed, planned precautions are observed, and all potential radiation hazards that develop or are recognized during the operation are addressed in a timely and appropriate manner.
Additional RP Senior Technician duties are listed in REP l-92-1059-A, including the duty to provide
- Continuous covg. [ coverage) during
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any HIC /fillhead move and LHRA entry." Continuous coverage is defined in 75RP-9RP02, Revision 2.00, " Radiation Exposure Permits,"
as:
a 4.1.9.1 A qualified RP technician with a dose rate monitoring device who is responsible for
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providing positive control over the activities within the area.
The RP Senior Technician is also charged with the authority to stop work as defined in 75RP-9RP02, Revision 2.00, " Radiation Exposure i
Permits".
4.1.12.1 This authority will be exercised by i
qualified RP representatives when radiological conditions and job practices could endanger the workers or could violate f
NRC regulations, station procedures, or l
ALARA controls for the job.
Contrary to the above, on December 21, 1992, the primary RP Senior Technician did not exercise his stop work authority when unexpected radiation hazards were recognized while performing work authorized t
r
t by REP 1-92-1059-A.
Specifically, the RP Senior Technician did not stop the job when he recognized that radiation readings were higher than expected after the resin fill head was raised above the HIC.
The RP Senior Technician also failed to ensure that planned precautions to reduce personnel radiation exposure were followed, in that remote tools were not used and an air sample was not taken.
9.
Procedure 76CP-9t?P06, Revision 2, " Operating Procedure - Resin Drying (Dewatering) System," contains instructions for the workers performing the resin fill head removal and capping of the HIC under r
REP l-92-1059-A.
Procedure 76CP-914P06 states-l 6.8.2 Install the container lid in accordance with the container instruction manual or procedure.
Insure that the lid is installed to a leak tight seal.
Attachment H, " Resin Drying Process Memo and Process Data Sheet," is i
an official record that documents the entire resin transfer process
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from filling the HIC and drying the resin to capping the HIC.
l Section VI, " Closure," of Attachment H contains the sign-off check list for closing the HIC and requires the worker's initials l
verifying that the " Threaded lid [was] torqued to min. 50 ft-lbs (if i
applicable)" using a calibrated torque wrench.
l Contrary to the above, on December 21, 1992, a worker performing 3
4 wor k authorized by REP l-92-1059-A installed the HIC lid for final l
l closure by hand without the use of a torque wrench, which is l
l required for final closure, to determine if the minimum torque
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required was achieved.
I 10.
Procedure 75RP-0RP03, Revision 3.00, "ALARA Program," Section 2.15 l
l provides in part that Work Group Supervisors are required to supervise jobs "to ensure that maximum benefit is derived from f
necessary worker radiation exposure" (2.15.1), and "participat[e] in l
pre-planning of work to be performed in Radiological Controlled Areas and Post-Job Reviews" (2.15.4).
Contrary to the above, on December 15-21, 1992, the supervisor j
responsible for the work group performing the fill head removal job j
did not participate in the pre-job planning or pre-job briefing, and
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was not present to supervise during the actual job performance.
l i
This is a Severity Level 111 problem (Supplement IV).
l 4
Pursuant to the provisions of 10 CfR 2.201, Arizona Public Service Company is-i hereby required to submit a written statement or explanation to the U.S.
I!uclear Regulatory Commission, ATTli: Document Control Desk, Washington, D.C.
i 20555 with a copy to the Regional Administrator Region V, and a copy to the i
!;RC Resident inspector at Palo Verde !!uclear Generating Station within 30 days of the date of this flotice of Violation (l'otice).
This reply should be clearly marked as a " Reply to a fictice of Violation" and should include for each alleged violation:
(1) admissica or denial of the alleged violation. (2) 4 i
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I the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have.been taken and the results achieved, (4) the corrective steps that ><ill be taken to avoid further violations, and (5) the
' i i
date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, the Commission may issue an l
order or a demand for information as to why the license should not be modified, suspended, or revoked or why such other action as may be. proper j
should not be taken. Consideration may be given to extending the response i
time for good cause shown. Under the authority of Section 182 of the Act, 42 i
l U.S.C. 2232, this response shall be submitted under oath or affirmation.
l Datedat,SalnutCreek,CA j
this c27 day of April 1993 f
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