ML20045H530

Responds to NRC 930603 Ltr Re Violations Noted in Insp Rept 50-528/93-18.C/As:disciplinary Action Administered to Radiation Protection Technicians & Supervisors & Manual Being Formulated for Lead Technicians

ML20045H530
Person / Time
Site:	Palo Verde
Issue date:	07/06/1993
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02557-WFC-T, 102-2557-WFC-T, NUDOCS 9307200336
Download: ML20045H530 (11)

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t g Arizona Public Service Company P O BOX 53999

• PHOENIX, AR:ZON A 65072-3499 WILLIAM F CONWAY f

• f CUTNE VfCf PPCSIM P 102-02557-WFC/TRB/SAB July 6,1993 /

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notices of Violation 50-528/93-18-02 and 50-528/93-18-03 File: 93-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/93-18 and the Notices of Violation dated June 3,1993. Pursuant to the provisions of 10 CFR 2.201, APS' responses are enclosed. Enclosure 1 to this letter is a restatement of the Notices of Violation. APS' responses are provided in Enclosure 2.

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Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.

Sincerely,

.h

, SS WFC/TRB/SAB/rv

Enclosures:

1. Restatement of Notices of Violation

2. Reply to Notices of Violation cc: B. H. Faulkenberry J. A. Sloan '

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// d 9307200336 930706 DR ADDCK 0500 B

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ENCLOSURE 1 RESTATEMENT OF NOTICES OF VIOLATION 50-528/93-18-02 AND 50-528/93-18-03 NRC INSPECTION CONDUCTED MAY 3 THROUGH MAY 7,1993 INSPECTION REPORT NO. 50-528/529/530/93-18 l

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' Restatement of Notices of Violation'50-528/93-18-02 and 50-528/93-18-03 During an NRC inspection ' conducted the week of May 3 through May' 7,;1993, two' -i violations of NRC requirements were identified in accordance with the " General Statement--

of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C.  :

The violations are identified below:

A. Violation 50-528/93-18-02 RADIOLOGICAL SURVEYS 10 CFR 20.201(b) requires that each licens_ee 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:

1. On November 19-20,1992, twelve 55-gallon drums of potentially radioactive oil were not surveyed as necessary to comply with the requirements of 10 CFR 20.301, in that nonrepresentative samples of the drummed oil were ,

used as the basis for determining whether the oil could be released for unrestricted use.

2. On November 20,1992, six 55-gallon drums of potentially radioactive oil -

were not surveyed as necessary to comply with the requirements of - 1 10 CFR 20.301, in that radiation and contamination surveys of the external '

surface of the drums did not detect radiation levels as high as 4 millirem per hour on contact with the surface of the drum. ,

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3. On November 20,1992, a bag marked as containing radioactive material; was not surveyed as necessary to comply with' the requirements of i 10 CFR 20.301, in that the bag was disposed of in an uncontrolled manner and no radiation or contamination surveys'of the bag were performed. ,

This is a Severity Level IV violation (Supplement IV).

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B. Violation 50-528/93-18-03 PROCEDURAL COMPLIANCE TS 6.8.1 requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of _

Regulatory Guide (RG) 1.33, Revision 2, February 1978. ],

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_l RG 1.33, February 1978, lists in Appendix A the following:

"7. Procedures for the Control of Radioactivity (For limiting materials released to environment and limiting personnel exposure)"

Licensee Procedure 75AC-9RP03, " Radiological Controls Problem Reporting,"

dated April 5,1991, Section 2.1.3 requires that radiation protection department personnel investigate reported concerns and initiate appropriate documentation.

Section 3.1.1.6 requires that a Condition Report / Disposition Request (CRDR) be written when radioactive materialis found to be outside of a radioactive materials area. Section 3.1.1.15 requires that a CRDR be written if a personnel error is made that has adverse consequences.

Ucensee Procedure 75AC-9RP02, " Radioactive Contamination Control," dated July 8,1991, Section 3.2, " Yellow, Magenta, or Yellow and Magenta Material Controls," establishes controls for use of such materials. Section 3.2.2 states that these materials shall only be used within the radiologically controlled area (RCA) or in suitably controlled and posted areas outside the RCA.

Contrary to the above:

1. On November 24,1992, radiation protection department personnel failed to initiate a CRDR when concerns were reported involving personnel error and involving radioactive material released outside of a radioactive materials area.

2. On November 20,1992, yellow and magenta material was released for use outside the radiologically controlled area, and suitable controls and posting were not put in place to authorize such use.

This is a Severity Level N volanon (Supplement IV).

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ENCLOSURE 2 REPLY TO NOTICES OF VIOLATION 50-528/93-18-02 AND 50-528/93-18-03 NRC INSPECTION CONDUCTED MAY 3 THROUGH MAY 7,1993 INSPECTION REPORT NO. 50-528/529/530/93-18 i

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I Reply to Notice of Violation (A) 50-528/93-18-02 l

Admission or Denial of the Alleaed Violation APS admits the violation. The concerns identified in this violation were identified by APS in December 1992 and a thorough investigation and evaluation of these concerns was performed. The violations were cited following the inspector's review of the APS investigation report.

Reason for the Violation Notice of Violation (NOV) 93-18-02 cites three examples of failure to perform surveys that were adequate to evaluate the extent of the radiation hazards present. The reasons for the violation are:

1) Failure to follow existing station operating procedures.

2) Multiple personnel errors, including inadequate supervisory control.

3) Inadequacies in the program for handling and classifying used oil.

4) Lack of procedural guidance for obtaining representative samples of oil.

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Corrective Actions Taken and Results Achieved The oil involved in the incident was either quarantined or returned to the protected area.

The oil was not released offsite.

APS conducted a thorough investigation of this incident and developed a (:omprehensive

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response to the concerns identified. Corrective actions taken in response h reasons 1) and 2) above are as follows:  ;

Appropriate disciplinary action was administered to the radiation protection technicians and supervisors responsible for the release of the oil drums without adequate samples and surveys.

Radiation protection management reiterated to supervisors the necessity of reporting incidents of this nature through the station procedures developed for that purpose.

The Radiation Protection Support Services Manager reviewed with supervisors and senior technicians the requirements for waste sampling prior to unrestricted release. In addition, interim guidance was issued regarding waste characterization and disposition. )

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This incident was included in the second quarter industry events training for radiation protection personnel. The need to perform adequate surveys and the consequences of inadequate surveys were emphasized. In addition, lessons learned from this incident were presented to contract radiation protection personnel hired for the Unit 2 outage.

Corrective actions taken in response to reasons 3) and 4) above are as follows: ,

A waste task force was created to develop guidance for the control of waste oil to ensure that the waste streams are appropriately segregated (i.e., radioactive material, mixed waste, and hazardous waste). In addition, the task force addressed the programmatic deficiencies identified during the evaluation of this incident. ,

Corrective Actions That Will Be Taken To Avoid Further Violations Corrective actions to be taken in response to reasons 1) and 2) above are as follows:

A manual is being formulated for lead technicians by radiation protection l

management delineating expectations when performing assigned tasks. It is 1 expected that the manual will be completed by September 30,1993. .

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4 Corrective' actions to be taken in response to reasons 3) and 4) above are as follows:

The findings of the task force will be used to revise oil sampling _and handling procedures, as appropriate. The technicians will then be trained to the revised procedures. These actions are expected to be completed by August 3,1993.

Procedure 75RP-9RP09, Vehicle, Equipment and Material Release, will be revised I by August 3,1993. The revision will, in part, modify the form used to release i

I materialin order to include such information as waste characterization and material l disposition.

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l An analysis will be performed to determine how much radioactivity could have-l been released in previous oil delivered to the recycling agency based upon the -

conservative assumption that this problem existed previously and went undetected.

This analysis will be completed by July 23,1993.

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i Date When Full Compliance Will Be Achieved L Full compliance was achieved on January 11,1993, when the oil and oil drums had been surveyed, accurately depicting the extent of the radiation hazard, and the contaminated oil and drums were placed under the proper radiological controls.

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Reply to Notice of Violation (B) 50-528/93-18-03 i

l Admission or Denial of the Alleaed Violation l

l APS admits the violation. The concerns identified in this violation were identified by APS in December 1992 and a thorough investigation and evaluation of these concerns was performed. The violations were cited following the inspector's review of the APS

' investigation report.

Reason for the Violation NOV 93-18-03 cites two examples of failure to follow procedures which contributed to the near offsite release of radioactively contaminated oil. The reason for the violation is personnel error.

Corrective Actions Taken and Results Achieved APS conducted a thorough investigation of this incident and developed a comprehensive response to the concerns identified. The oil involved in the incident was either quarantined or returned to the protected area. The oil was not released offsite.

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- Appropriate disciplinary action was administered to the radiation protection technicians ,

1 and supervisors responsible for the release of the oil drums without adequate samples and surveys.

Radiation protection management reiterated to supervisors the necessity of reporting incidents of this nature through the station procedures developed for that purpose.

This incident was included in the second quarter industry events training for radiation protection personnel. The need to report incidents of this nature and to comply with procedures for the control of radioactive material were emphasized. In addition, lessons learned from this incident were presented to contract radiation protection personnel hired for the Unit 2 outage.

Corrective Actions That Will Be Taken To Avoid Further Violations The actions discussed above are adequate to avoid further violations.

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l Full compliance was achieved on January 11,1993, after CRDR 920758 was written to evaluate this incident, and the contaminated oil and drums were adequately surveyed and placed under the proper radiological controls.

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