ML20198C585
| ML20198C585 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/07/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| TASK-2.B.3, TASK-TM ANPP-33948-WFQ, NUDOCS 8511120122 | |
| Download: ML20198C585 (4) | |
Text
.I Arizona Nuclear Power Project P.o. BOX 52034
- PHOENIX, ARIZONA 85072-2034 November 7, 1985 ANPP-33948 WFQ/KIII Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report No. 50-528/85-22),
dated October 8,1985 File: 85-070-026
Dear Sir:
Pursuant to the provisions of 10CFR2.201, Arizona Public Service Ccmpany hereby submits the response to the Notice of Violation and Proposed Imposition of Civil Penalty, dated October 8, 1985.
The response is contained in the Attachment to this letter.
The check of Arizona Public Service Company, holder of License No. NPF-41, in the amount of $50,000, payable to the Treasurer of the United States, is also submitted.
This check is in payment of the imposed civil penalty, issued by the NRC on October 8, 1985.
Very truly yours, d
E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/KLM/ dim Attachment cc:
J. B.* Martin, Region V, NRC R. P. Zimmerman, NRC G. W. Knighton, NRC E. A. Licitra, NRC 851112012L
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t ANPP-33948 kTQ/KUI STATE OF ARIZONA )
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COUNTY OF MARICOPA)
I, Donald B. Karner, represent that I am Assistant Vice President, Nuclear Production of Arizona Nuclear Power Project, tha t the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, tha t I have read such document and know its contents, and that to the best of my knowledge and belief, the s tatements made therein are trua.
naw Donald B. Ka,rner Sworn to before me this f
day ofbt/vrhu,1985.
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ATTACHNENT ARIZONA PUBLIC SERVICE Q)MPANY (APS)
RESPONSE TO THE NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY DATED OCTOBER 8, 1985 1.
APS Admission of Alleged Violation Although APS believes that at no time during the period of the violation, June 6,1985 until July 5,1985, was the public health, safety or interest jeopardized, APS does not contest the violation as stated in the October 8, 1985 Notice of Violation.
2.
Reason for Violation The root cause of this violation was the use of equipment for other than its' original design intent without appropriate design review.
APS identified two major contributing factors to the root cause, which are a lack of clear task force charter and a lack of adequate compliance /
technical review of the final design and implementation.
3.
Corrective Steps Which Have Been Taken and Results Achieved Modifications to the Palo Verde Nuclear Generating Station (PVNGS) Unit 1 post accident sampling capability as described in ANPP-33238, dated August 19, 1985, have been completed and tested. The PVNGS post accident sampling and analysis procedures have been properly revised and the necessary personnel have been traiced on the modified post accident sampling system and related implementing procedures.
These corrective actions have resulted in a modified PVNGS Unit 1 post accident sampling program that satisfies the requirements of NUREG-0737, Item II.B.3 and the successful completion of surveillance testing of the post accident sampling system.
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i ATTACHMENT (Continued) 4 4.
Corrective Steps Which Will Be Taken To Avoid Further Violations APS is taking additional corrective actions beyond those already taken, as described in Section 3, to prevent future incidents of a similar nature.
These additional actions include:
- 1) applying the procedure review process to address changes in design criteria or design intent, 2) applying the procedures for the formal review process for plant changes to q
changes in design criteris or design intent,
- 3) formalizing the creation of task forces and requiring a charter describing their responsibility and authority, and 4) implementing a more rigorous and formalized process for review of NRC submittals.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on August 19, 1985, as described in ANPP-33238, dated August 19, 1985.
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u Arizor,a Nuclear Power Project
'T P.o. box 52034 e PHOENIX. ARIZONA 85072-2034
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Mr. John B. Martin, Regional Administrator' August 19, 1985 Office of Inspection and Enforcement ANPP-33238-EEVB/MAJ U.S. Nuclear Re8ulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368
Subject:
Palo Verde Nuclear Gen'erating Station (PVNGS)
Unit 1 Docket No. STN-50-528 (License NPF-41)
Post Accident Sampling Program File: 85-056-026: G.l.01.10: 85-001-762 I
References:
(1) Letter to J. B. Martin, USNRC Region V, from E. E. Van Brunt, ANPP, dated July 26, 1985 (ANPP-33110).
Subject:
Post Accident Sampling Program (2) Letter to E. E. Var: 3 runt, ANPP, from J. B. Martin, USNRC Region V, dated Jtily 29, 1985.
Subject:
< Confirmatory Action Letter-Post Accident Sampling System-PVNGS Unit 1 (3) Letter to G. W. Knighton, NRC, ' rom E. E. Van Brunt, ANPP, dated December 5, 1984 (. WP-31333).
Subject:
Schedular Exemption - Post Accident Sampling System
Dear Mr. Martin:
In the Reference (1) letter, we informed you that "PVNGS Unit 1 will not return to' Mode 3, per the requirements of Technical Specification 3/4.3.3, until the sampling deficiency is corrected and a post accident sampling system is deemed operable." Additionally, we stated that applicable procedures would be revised and personnel trained once modifications to the post accident sampling program were completed.
In response, you provided us with Reference (2).
Since the submittal of Reference (1), the PVNGS post accident sampling program has'baen modified to obtain the containment air grab sample from j
a source other than Radiation Monitor RU-1.
This modification is depicted in the attached simplified flow diagram. The change involves obtaining the containment atmosphere grab sample directly from a septum located at the remote grab sampler in the Hot Lab Sample Room, 140 Ft. elevation, Auxiliary Building. The containment atmosphere sample is taken directly from the containment utilizing the sample piping common to the Hydrogen Analyzer and Hydrogen Recombiner. Neither the Hydrogen Analyzer or the Hydrogen Recombiner are required to be operated to obtain the containment atmosphere grab sample for post accident analysis.
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J. B. Martin Post Accident Sampling Program ANPP-33238 Page 2 t
Additionally, APS initiated a Licensing and Technical / Design Verification -
Review, including an independent verification by Quality Assurance (QA) beyond the normal QA progrca requirements, to ensure that the requirements of NUREG-0737 Item II.B.3 were met. This review included such areas as procedures, training, testing, dose calculations, licensing requirements, and previous regulatory commitments. The results of this 1
review conclude that the modified post accident sampling program at PVNGS Unit 1 satisfies the requirements of NUREG-0737, Item II.B.3. provides for your information, the verified post accident sample analysis capability available at PVNGS. It should be noted that there are differences between the' verified analysis capabilities described in Attachment 1 to this letter and the design capabilities in Table B of Reference (3). These differences have been evaluated, and we have determined that our present analytical capability is adequate to neet NUREG-0737 Item II.B.3 and provide pertinent daca to the operator, which describes the radiological and chemical states
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of the reactor coolant system and containment atmosphere. Attachment 3
1 supercedes Table B of Reference (3).
Modifications to the PVNGS post accident sampling capability, as depicted 1
in the attached diagram, are complete and the analysis capabilities, i
as described in Attachment 1; have.been verified. The PVNGS post accident sampling and analysis procedures have been revised and necessary personnel have been trained on the modified post accident sampling system and the related implementing procedures. The surveillance testing has been completed and the PVNGS Unit 1 post accident program is considered operable, per the requirements of Technical Specifications 3/4.3.3 and 6.8.4(e).
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If you have any questions or require further information concerning this 4
subject, please call me.
Very trul you
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E. E. Var. Brunt, Jr.
Executive Vice President Project Director.
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J. Crews A. Johnson G. Yuhas i
E. Licitra M. Ley j-R. Zimmerman A. Gehr a
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- 4' ATTACHMENT 1 PASS SAMPLE ANALYSIS INFORMATION ANALYSIS RANGE SENS.
ACCURACY pH 1-13 1
>5,
<9 10.3
<5,>9 10.5 Dissolved 10-2000 10.
<50 ec/kg 15cc/kg
. Hydrogen ec/kg
> 50 cc/kg 110%
1 011oride Ion 0.02-20 ppm 0.02 ppm Full Range 125%
Boron 100-6000 ppm 100 ppm 150 ppm <1000. ppm 15% >1000 ppm Total Dis.
11-2000 11 cc/kg-ill cc/kg a
Gas cc/kg i
Radio-SE-7 pCi/cc SE-7
+15%
Isotope to 1.4 mC1 pCi/cc Tutilizing calibration (Liquid)
(dilution verification) capability to 10 Ci/cc)
Gaseous 0.1%-20%
0.1%
125%
Hydrogen Gaseous 0.5%-20%
0.5%
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110%
+15%
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Isotope to 1.4 mci pCi/cc Iut111zingcalibration (Gas)
(dilution verification) capability to 10 C1/cc) e 8
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