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| issue date = 08/28/1989 | | issue date = 08/28/1989 | ||
| title = Responds to Violations Noted in Insp Rept 50-528/89-24. Corrective Actions:Detailed Review of Receipt Records & Work History Currently in Process to Ensure No Sources Inadvertently Disposed of as Radwaste | | title = Responds to Violations Noted in Insp Rept 50-528/89-24. Corrective Actions:Detailed Review of Receipt Records & Work History Currently in Process to Ensure No Sources Inadvertently Disposed of as Radwaste | ||
| author name = | | author name = Conway W | ||
| author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR | | author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR | ||
| addressee name = | | addressee name = |
Revision as of 20:35, 18 June 2019
ML17304B412 | |
Person / Time | |
---|---|
Site: | Palo Verde ![]() |
Issue date: | 08/28/1989 |
From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
102-01383-WFC-T, 102-1383-WFC-T, NUDOCS 8909010268 | |
Download: ML17304B412 (54) | |
See also: IR 05000528/1989024
Text
WILLIAM F.CONWAY EXECUTIVE VICE PAESI CENT NVCl.EAR Arizona Public Service Company P.O, BOX 53999~PHOENIX, ARIZONA 85072-3999
102-01383-WFC/TDS/TRB
~August 28,'1989~~~v.~U.S.Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, DC 20555 Reference: (a)Letter from R.A.Scarano, Director, Division of Radiation Safety and Safeguards, NRC to W.-F.Conway, Executive Vice President Nuclear, Arizona Public Service dated July 28, 1989 (b)Letter from A.Chaffee, Deputy Director, Division of Reactor Safety and Projects, NRC to W.F.Conway, Executive Vice President Nuclear, Arizona Public Service dated August ll, 1989 Dear Sir: Subject: Palo Verde Nuclear Generating
Station (PVNGS)Units 1, 2, and 3 Docket No.STN 50-528 (License No.NPF-41)STN 50-529 (License No.NPF-51)STN-50-530 (License No'.NPF-74)Reply to Notice oE Violation-528/89-24-03
File'9-070-026
This letter is provided in response to the routine inspection
conducted by Messrs.M.Cillis, G.Cicotte, and L.Carson from June 5-15, 1989, June 26-30, 1989, and a telephone conversation
on July 5, 1989.Based upon the results oE the inspection, a violation of NRC requirements
was identified.
The violation is discussed in Appendix A of reference (a).A restatement
oE the violation and PVNGS's response are provided in Appendix A and Attachment
1, respectively, to this letter.Reference (a)expresses concern with respect to the lack oE timeliness
with which corrective
actions are taken in addressing
self-identified
problems.The point is emphasized
in paragraph 2.G of the report where it is noted that the Incident Investigation
Report (IIR), which detailed the results of an investigation
of the failure to control sealed sources,'as
submitted for approval on May 8, 1989, but that, as of June 30, 1989, the IIR had not been distributed
to the licensee's
staff and the corrective
actions recommended
in the IIR had not been initiated.
I Eully agree that there was an inordinate
delay in the review and approval of the IIR.Such a delay is not acceptable
and steps have been taken to assure a more timely review of IIR's and initiation
of corrective
actions.These actions are described in the following paragraphs.
't
Document Control Desk Page 2 of 3 102-01383-WFC/TDS/TRB
August 28, 1989 The Incident Investigation
Procedure has been revised and was approved on August 23, 1989.The changes to this procedure will result in a more timely method of conducting, documenting, and disseminating
investigation
results.and assist in expediting
the implementation
of recommended
corrective
actions.The revision streamlines
the investigative
process for Category 3 investigations
while retaining the current depth of investigation.
This is being done by simplifying
the format requirements
and eliminating
redundant reviews while maintaining
the thoroughness
of the investigation
and reviews.Additionally, the responsibility
for the actual scheduling
and implementation
of the recommended
corrective
actions has been assigned specifically
to the responsible
directors.
Additionally, corrective
actions resulting from incident investigations
are being segregated
into separate categories, one for each director's
area of responsibility.
This will enable management
to immediately
identify specific responsibilities
for each director and effectively
track the resolution
of the actions.Executive management
has also directed that for the current backlog of actions resulting from incident investigations
the responsible
director will have 90 days, upon assignment
of the actions, to disposition
all items assigned to him.Further, executive management
has established
a goal to achieve resolution
of incident investigation
action items within 120 days of the incident occurrence.
A peiiodic report of the status of these actions will be provided to executive management.
In order to ensure that the entire scope of this issue is fu1ly understood
and that the corrective
actions are sufficiently
comprehensive, an evaluation
is currently being conducted.
The results of that evaluation
and any additional
corrective
actions will be provided in response to reference (b).Reference (a)also discusses procedural
weaknesses, failure to comply with procedures, inadequate
review of surveillance
test results, and inattention
to detail referring to paragraph 5 of the inspection
report.As previously
discussed with the NRC staff, findings such as those identified
by the NRC inspectors
are considered
unacceptable
and indicate a failure'o meet the established
expectations.
Based upon the inspectors'bservations, it is apparent that the latitude permitted within the procedural
controls contributed
to or directly caused the documented
findings.Therefore, in addition to the corrective
a'ctions previously
committed to and documented
in the inspection
report, PVNGS has revised procedure 73AC-9ZZ04,"Surveillance
Testing", providing more explicit guidance for the documentation
and review of surveillance
tests.I recognize that improved procedural
guidance is only one step in upgrading the overall performance
of individuals.
The most important aspect is that each individual
fully understands
management's
expectations, his individual
responsibilities
for them, and is committed to meeting his responsibilities.
I have recently issued my expectations
to each employee.In order to reinforce my expectations, I have prepared an additional
memorandum
which discusses the observations
documented
in the inspection
report and clearly identifies
how the examples are direct indications
that my expectations
are
Document Control Desk Page 3 of 3 102-01383-WFC/TDS/TRB
August 28, 1989 not being met.In summary, I believe that the actions described in this letter and the attached response, in con)unction
with my personal commitment
to hold responsible
individuals
accountable
for meeting my expectations, will ensure not only effective but timely corrective
action.If you should have any questions regarding this response, please contact me: Very truly yours, WFC/TDS/TRB/kj
Attachments
cc: J.B.T.J.T.L.M.J.E.E.A.C.Martin Polich Chan Davis Van Brunt, Jr.Gehr
t I~h
D ocument Control Desk Page 1 oE 2 102-01383-WFC/TDS/TRB
August 28, 1989 APPENDIX A Not ce of Violation Arizona Public Service Company Palo Verde Nuclear Genera<ing
Station Units 1, 2, and 3 Docket Nos.50-528, 50-529, 50-530 License Nos.NPF-41, NPF-51 and NPF-74 During an NRC inspection
conducted June 5-15 and June 26-30, 1989, and in telephone conversations
on July 5, 1989, a violation oE NRC requirements
was identiEied.
In accordance
with the"General Statement of Policy and Procedure for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1988), as modified by 53 Fed.Reg.40019 (October 13, 1988), the violation is listed below: A.Technical Specification 6.11.1 requires procedures
for personnel radiation protection
to be prepared consistent
with the requirements
oE 10 CFR Part 20 and to be approved, maintained
and adhered to for all operations
involving personnel radiation exposure.Licensee Procedure 75RP-9XC08, Leak Testin and Inventor of Radioactive
Sources, and licensee Procedure 75AC-9RP05, Source Control provide in part that the Central RP Group and Unit RP Groups shall inventory on a semi-annual
basis all non-exempt
quanti.ty sources in their custody, respectively, and that the inventory shall physically
account for all such sources.Procedure 75AC-9RP05, Source Control, requires in part that the Central RP Group and the Unit Radiation Protection
Groups enter into their
Document Control Desk Page 2 of 2 102-01383-MFC/TDS/TRB
August 28, 1989 Source Tracking Systems a record of each non-exempt
quantity source.This procedure further requires that all sources or source containers
shall be labeled with a durable, clearly visible label which shall include at least the trefoil, source i.d.number, the words"Caution Radioactive
Material," the isotope or isotopes, and the activity of each isotope.Contrary to the above, as of June 28, 1989: 1.Neither the Central Radiation Protecti.on
nor the Unit Radiation Protection
Groups'ource
Tracking System records included non-exempt
quantities
of Americium-241.
At least 31 non-exempt
Am-241 sealed sources were located in each of the three Units, and 37 non-exempt
Am-241 sealed sources were located in the site warehouse Neither the Central Radiation Protection
Groups nor the Unit Radiation Protection
Groups conducted required semi-annual
inventories
of non-exempt
Am-241 sources that were in their custody.At least eight non-exempt
Am-241 sources in Units-2 and 3 had illegible labels.Another source was found to have a label that was completely
obstructed
by a metal bracket.
i
I Document Control Desk Page 1 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 Attachment
1~Re)alto Notice of Violat on 5 8 89-24-03 I.REASON FOR VIOLATION On March 30, 1989 a Radwaste technician
at the Dry Active Waste Processing
and Storage (DAWPS)Facility discovered
a high range dete'ctor in a CONEX box from Unit 2 designated
for radioactive
waste.In response to this discovery, an Incident Investigation
was initiated on March 30, 1989.The summary results of that investigation
are presented in the following paragraphs.
On April 26, 1984, a high range detector (S/N¹22707)for RU-151, Unit 1 Primary Coolant Monitor'B', was received from Kaman Instrumentation
Corporation.
The detector is an ion chamber detector whose design incorporates
a small"keep alive" radiation source to maintain a minimum constant signal from, the detector.The isotope utilized in this detector, as well as 30 other RHS channels in each Unit (total of 31 similar detectors required for each Unit)is Am-241 in the amount of 80 nanocuries (range for all detectors is80-150 nanocuries);
this amount is in excess of the exempt quantity limit set forth in 10 CFR 30.15(a)(9)(iii)
of 50 nanocuries
(0.05 microcuries).
An initial receipt survey for the detector.was performed in accordance
with procedure 75RP-9ZZ56,"Receipt of Radioactive.
Material," by the Radioactive
Waste Support Group and the material was identified
as a
I ll II
D ocument Control Desk Page 2 of 8'02-01383-WFC/TDS/TRB
August 28, 1989 radioactive
source.The Radiation Protection
Support Calibration
Facility, the organization
responsible
for source control in 1984, was notified of the receipt of the radioactive
source by the Radioactive
Waste Support group.These actions were documented
on the Radioactive
Source Receipt Record.A Calibration
Facility technician
then examined the shipment and inappropriately
determined
the detector to be an exempt quantity.On March 24, 1986, an I&C technician
removed the high range detector'S/N
@22707)from Radiation Monitor RU-151, during the conduct of routine maintenance.
Attempts were made to decontaminate
the detector in preparation
for shipping the unit to the manufacturer.
These attempts were unsuccessful
and RP personnel were informed.It is assumed that the detector was placed in the CONEX box to be disposed of with other contaminated
material.On March 30, 1989, a contract Rad Waste technician
at Dry Active Waste Processing
and Storage (DAWPS)Facility discovered
the detector in a CONEX box from Unit 2 designated
for radioactive
waste.Unit 2 RP was notified at 1000, on March 30, 1989, of the discovery of the detector.Unit 2 RP recovered the detector and transported
it to the Central RP Calibration
Facility for disposal per the requirements
of 75AC-9RP05,"Source Control." As a result of the determination
in 1984 made by the Calibration
Facility technician
that the source was an exempt quantity, the detector was not entered into the Source Tracking System, and therefore, the
Document Control Desk Page 3 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 requirements
for accountability
and special handling were not implemented.
Also, because of the misclassification
there was no documentation
which would substantiate
that the required source labeling had been verified.To ensure that the detectors are labeled in accordance
with procedural
requirements, detector S/N¹22707, new detectors stored in the warehouse, and accessible
installed detectors were examined for correct labeling.The detectoxs reviewed were labeled"CAUTION RADIOACTIVE
MATERIAL," and listed the isotope (Am-241), amount (generally,80-150 nanocuxies), and the date of activity determination.
The labeling contained on the detectors examined was in accordance
with the approved station requirements
contained in procedure 75RP-9ZZ61,"Radioactive
Material Storage and Control." However, detector cans were identified
that had labels that contained information
that could not be read.Additionally, installed detectors were identified
that had the radioactive
material label partially or largely obscured by the detector mounting bracket.In these cases, the detectors were relabeled.
The root cause of this event is attributed
to the failure of the Radiation Protection
Calibration
Support personnel to correctly identify upon initial receipt in 1984 that the subject RMS detectors
Document Control Desk Page 4 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 contained non-exempt
quantities
of Am-241, and, as such, required accountability, special handling, and clearly visible labeling.The persistence
of this problem for an extended period of time is attributed
to inadequate
knowledge of the requirements
for exempt and non-exempt
sources by personnel who were responsible
for various aspects of source accountability.
Further, it was determined
that responsible
PVNGS personnel were unaware that, regardless
of whether the detectors containing
the Am-241 were exempt or non-exempt, the detectors could not be disposed of as radioactive
waste.Procedures
in place for receipt of radioactive
material at the time of this event required that personnel refer to the Code of Federal Regulations
to determine what constitutes
exempt or non-exempt
sources.Based upon the investigation
results, there is no indication
that the Code of Federal Regulations
was used to determine source status which was contrary to the approved procedure.
The initial failure to properly classify the detectors resulted in the subsequent
documented
procedural
violations
discussed in this notice.II.CORRFCTIVE
ACTIONS TAKEN AND RESULTS ACHIEVED RMS detector S/N 422707 was recovered by the Central Radiation Protection
Calibration
Facility and retained for proper handling/disposition.
Central Radiation Protection
Calibration
Facility personnel;
1)initiated a physical inspection
of the warehouse, units,
Document Control Desk Page 5 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 and rework facility to establish the current inventory of SQ detectors containing
sources;2)entered the detectors on hand into the Source Tracking System (STS);and 3)assured that the sources contained in detectors at the warehouse were under positive control of the Central 1 Radiation Protection
Calibration
Facility to preclude further improper handling or disposition.
Additionally, RMS detectors were examined to ensure the labeling of detectors containing
sources was in accordance
with station procedures
and federal requirements.
Identified
deficiencies
have been corrected.
On July 6, 1989, the Plant Director issued a memo to the Unit Plant Managers, Unit and Central Maintenance
Managers, Unit Radiation Protection
Managers, and Unit and Central Maintenance
I&C Supervisors
that specifically
advised them of the requirements
to handle, account for, and ensure proper disposition
of SQ system detectors containing
radioactive
sources.A change has been initiated to 76AC-ORW01,"Receipt, Storage, and Shipment of Radioactive
Material," to require specific notification
of Central Radiation Protection
Calibration
Facility personnel upon receipt of any radioactive
material to ensure initial determination
of accountability
and handling requirements.
This change is expected to be implemented
by September 15, 1989.As an interim measure, a memo has been issued by the Site RPM which requires the additional
notifications.
Document Control Desk Page 6 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 To ensure that no other detector sources at PVNGS have been inappropriately
classified
as exempt, a review of receipt records and the Source Tracking System has been performed for all sources.No additional
deficiencies
other than those with the Am-241 sources were identified
during the review.III.'ORRECTIVE
ACTIONS WHICH WILL BF.TAKEN TO AVOID FURTHER VIOLATIONS
To ensure that no sources have been inadvertently
disposed of as radioactive
waste, a detailed review of receipt records and work history is currently in process.Should the review determine that a source was inadvertently
disposed of, applicable
reporting requirements
will be followed.This review is expected to be completed by September 5, 1989.Radiation Protection
personnel responsible
for source receipt, accountability, handling, and disposal, and I&C personnel responsible
for RMS maintenance
will be familiarized
with this event through required reading of the PVNGS Incident Investigation
Report that addresses the events discussed in this violation.
The review of the subject investigation
is expected to be completed by September 1, 1989.Station procedures
that deal with various aspects of source receipt, accountability, handling;and disposal will be revised to reflect a specific position with responsibility
for all determinations
involving radioactive
sources, regardless
of the quantities.
These procedure
'
Document Control Desk Page 7 of 8'102-01383-WFC/TDS/TRB
August 28, 1989 changes, as well as other changes to Radiation Protection
procedures
required by the PIGS Incident Investigation
Report, are expected to be completed by September 30, 1989.Maintenance
Procedures
and repetitive
maintenance
tasks will be reviewed and those tasks where it is anticipated
that an affected RMS.detector could be replaced or physically
manipulated
will be revised to reflectappropriate
points of contact for disposition
of the detector source and necessary precautions
to prevent damaging or obscuring of detector radioactive
material labels.The review and implementation
of the required changes'are expected to be completed by October 15, 1989.As an interim measure a directive has been issued to the work control managers requiring that the Central Radiation Protection
Calibration
Facility be notified anytime a work order involves the removal of an item containing
radioactive
sources regardless
of quantity to ensure appropriate
instructions
have been included.In order to ensure the proper precautions
are addressed in corrective
maintenance
work orders, this response will be required reading for each work planner.A copy of the response will be provided to each individual
by September 1, 1989.Responsible
Radiation Protection
personnel will be trained in the proper handling and control of sources.This training will be completed by'v October 15, 1989.In order to ensure continued compliance
in"this area
Document Control Desk Page 8 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 this topic will be added to the continuing
training program.IV.DATE KlEN FULL COMPLIANCE
WILL BE ACNIEVED Accessible
RHS detectors were examined for proper labeling during a walkdown conducted by Central Radiation Protection
Calibration
Facility personnel..
Based upon the walkdown the initial source accountability
was established
and existing labeling deficiencies
were corrected.
However, detectors are located inside the Unit 2 containment.
Those detectors located inside the containment
of Unit 2, which is currently at power, have not been verified.Initial accountability
for those detectors and subsequent
entry into the STS was based upon a review of the monitors'ork
history.Visual verification
of the monitors will be conducted at the next opportunity
that the reactor is subcritical
or during the Unit 2 refueling outage whichever operational
mode occurs first.In accordance
with the source control program, these detectors will be inventoried
on a semi-annual
basis.
gl
R EGULATORY INFORMATION
DISTRIBUTION
SYSTEM (RIDS)CESSION NBR:8909010268
DOC.DATE: 89/08/28 NOTARIZED:
NO DOCKET ACIL:STN-50-528
Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529
Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530
Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION
CONWAY,W.F.
Arizona Public Service Co.(formerly Arizona Nuclear Power RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to violation noted in Insp Repts 50-528/89-24, 50-529/89-24
&50-530/89-24.
D DISTRIBUTION
CODE'E06D COPIES RECEIVED:LTR
ENCL SIZE: S TITLE: Environ&Radiological
(50 DKT)-Insp Rept/Notice
of Violation Respons NOTES: 05000528 Standardized
plant.05000529 g Standardized
plant.05000530 D INTERNAL: 0 RECIPIENT ID CODE/NAME PD5 LA CHAN,T ACRS AEOD/DSP NMSS/LLOB 5E4 NRR/DLPQ/PEB
10 NRR/DREP/EPB
10 NRR/PMAS/ILRB12
OGC/HDS1 RES RGN5 FILE 01 RGN4 MURRAY,B COPIES LTTR ENCL 1 0 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD5 PD DAVIS,M.AEOD/ANDERSON, R LOIS, ERASMIA NMSS/SGDB 4E4 NRR/DOEA/EAB
11 NRR/DREP/RPB
10 NUDOCS-ABSTRACT
~EG-F~02 RGN5 DRSS/RPB RGN2 COLLINS~D COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 2 2 1 1 1 1 2 2 1 1 EXTERNAL: EG&G SIMPSON, F NRC PDR NOTES 2 2 1 1 1 1 LPDR NSIC 1 1 1 1 h D OTAL NUMBER OF COPIES REQUIRED: LTTR 32 ENCL 31
Arizona Public Service Company P o BOX 53'B9~>voskfX AP Z" N~g=",'02-01383-WFC/TDS/TRB
August 28, 1989 U.S.Nuclear Regulatory
Commission
Attn: Document Control Desk Washington, DC 20555 Reference: (a)Letter from R.A.Scarano, Director, Division of Radiation Safety and Safeguards, NRC to W.F.Conway, Executive Vice President Nuclear, Arizona Public Service dated July 28, 1989 (b)Letter from A.Chaffee, Deputy Director, Division of Reactor Safety and Projects, NRC to W.F.Conway, Executive Vice President Nuclear, Arizona Public Service dated August 11, 1989 Dear Sir Subj ect: Palo Verde Nuclear Generating
Station (PVNGS)Units 1, 2, and 3 Docket No.STN 50-528 (License No.NPF-41)STN 50-529 (License No.NPF-51)STN-50-530 (License No.NPF-74)Reply to Notice of Violation-528/89-24-03
File;89-070-026
This letter is provided in response to the routine inspection
conducted by Messrs.M.Cillis, G.Cicotte, and L.Carson from June 5-15, 1989, June 26'-30, 1989, and a telephone conversation
on July 5, 1989.Based upon the results of the inspection, a violation of NRC requirements
was identified.
The violation is discussed in Appendix A of reference (a).A restatement
of the violation and PVNGS's response are provided in Appendix A and Attachment
1, respectively, to this letter.Reference (a)expresses concern with respect to the lack of timeliness
with which corrective
actions are taken in addressing
self-identified
problems.The point is emphasized
in paragraph 2.G of the report where it is noted that the Incident Investigation
Report (IIR), which detailed the results of an investigation
of the failure to control sealed sources, was submitted for approval on May 8, 1989, but that, as of June 30, 1989, the IIR had not been distributed
to the licensee's
staff and the corrective
actions recommended
in the IIR had not been initiated.
I fully agree that there was an inordinate
delay in the review and approval of the IIR.Such a delay is not acceptable
and steps have been taken to assure a more timely review of IIR's and initiation
of corrective
actions.These actions are desex'ibed
in the following paragraphs.
~8+05'0102<>~ri
~@pe~z.;rD~~DOCl: O~OOO 0 PDC r;~/II)
0 Document Control Desk Page 2 of 3 102-01383-WFC/TDS/TRB
August 28, 1989 The Incident Investigation
Procedure has been revised and was approved on August 23, 1989.The changes to this procedure will result in a more timely method of conducting, documenting, and disseminating
investigation
results and assist in expediting
the implementation
of recommended
corrective
actions.The revision streamlines
the investigative
process for Category 3 investigations
while retaining the current depth of investigation.
This is being done by simplifying
the format requirements
and eliminating
redundant reviews while maintaining
the thoroughness
of the investigation
and reviews.Additionally, the responsibility
for the actual scheduling
and implementation
of the recommended
corrective
actions has been assigned specifically
to the responsible
directors.
Additionally, corrective
actions resulting from incident investigations
are being segregated
into separate categories, one for each director's
area of responsibility.
This will enable management
to immediately
identify specific responsibilities
for each director and effectively
track the resolution
of the actions.Executive management
has also directed that for the current backlog of actions resulting from incident investigations
the responsible
director will have 90 days, upon assignment
of the actions, to disposition
all items assigned to him.Further, executive management
has establ'ished
a goal to achieve resolution
of incident investigation
action items within 120 days of the incident occurrence.
A periodic report of the status of these actions will be provided to executive management.
In order to ensure that the entire scope of this issue is fully understood
and that the corrective
actions are sufficiently
comprehensive, an evaluation
is currently being conducted.
The results of that evaluation
and any additional
corrective
actions will be provided in response to reference (b).Reference (a)also discusses procedural
weaknesses, failure to comply with*procedures, inadequate
review of surveillance
test results, and inattention
to detail referring to paragraph 5 of the inspection
report.As previously
discussed with the NRC staff, findings such as those identified
by the NRC inspectors
are considered
unacceptable
and indicate a failure to meet the established
expectations.
Based upon the inspectors'bservations, it is apparent that the latitude permitted within the procedural
controls contributed
to or directly caused the documented
findings.Therefore, in addition to the corrective
actions previously
committed to and documented
in the inspection
report, PVNGS has revised procedure 73AC-9ZZ04,"Surveillance
Testing", providing more explicit guidance for the documentation
and review of surveillance
tests.I recognize that improved procedural
guidance is only one step in upgrading the overall performance
of individuals.
The most important aspect is that each individual
fully understands
management's
expectations, his individual
responsibilities
for them, and is committed to meeting his responsibilities.
I have recently issued my expectations
to each employee.In order to reinforce my expectations, I have prepared an additional
memorandum
which discusses the observations
documented
in the inspection
report and clearly identifies
how the examples are direct indications
that my expectations
are
I I I l l
Document Control Desk Page 3 of 3 102-01383-WFC/TDS/TRB
August 28, 1989 not being met.In summary, I believe that the actions described in this letter and the attached response, in conjunction
with my personal commitment
to hold responsible
individuals
accountable
for meeting my expectations, will ensure not only effective but timely corrective
action.If you should have any questions regarding this response, please contact me.Very truly yours, WFC/TDS/TRB/kj
Attachments
CC: J.B.Martin T.J.Polich T.L.Chan M.J.Davis E.E.Van Brunt, Jr.A.C.Gehr
Document Control Desk Page 1 oE 2 102-01383-WFC/TDS/TRB
August 28, 1989 APPFNDIX A Notice of Violation Arizona Public Service Company Palo Verde Nuclear Generating
Station Units 1, 2, and 3 Docket Nos.50-528, 50-529, 50-530 License Nos.NPF-41, NPF-51 and NPF-74 During an NRC inspection
conducted June 5-15 and June 26-30, 1989, and in telephone conversations
on July 5, 1989, a violation of NRC requirements
was identified.
In accordance
with the"General Statement of Policy and Procedure Eor NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1988), as modified by 53 Fed.Reg.40019 (October 13, 1988), the violation is listed below: t A.Technical SpeciEication
6.11.1 requires procedures
for personnel radiation protection
to be prepared consistent
with the requirements
oE 10 CFR Part 20 and to be approved, maintained
and adhered to for all operations
involving personnel radiation exposure.I Licensee Procedure 75RP-9XC08, Leak Testin and Inventor of Radioactive
Sources, and licensee Procedure 75AC-9RP05, Source Control provide in part that the Central RP Group and Unit RP Groups shall inventory on a semi-annual
basis all non-exempt
quantity sources in their custody, respectively, and that the inventory shall physically
account for all such sources.Procedure 75AC-9RP05, Source Control, requires in part that the Central RP Group and the Unit Radiation Protection
Groups enter into their
f
t Document Control Desk Page 2 of 2 102-01383-WFC/TDS/TRB
August 28, 1989 Source Tracking Systems a record of each non-exempt
quantity source.This procedure further requires that all sources or source containers
shall be labeled with a durable, clearly visible label which shall include at least the trefoil, source i.d.number, the words"Caution Radioactive
Material," the isotope or isotopes, and the activity of each isotope.Contrary to the above, as of June 28, 1989: Neither the Central Radiation Protection
nor the Unit Radiation Protection
Groups'ource
Tracking System records included non-exempt
quantities
of Americium-241.
At least 31 non-exempt
Am-241 sealed sources were located in each of the three Units, and 37 non-exempt
Am-241 sealed sources were located in the site warehouse.
Neither the Central Radiation Protection
Groups nor the Unit Radiation Protection
Groups conducted required semi-annual
inventories
of non-exempt
Am-241 sources that were in their custody.3.At least eight non-exempt
Am-241 sources in Units 2 and 3 had illegible labels.Another source was found to have a label that was completely
obstructed
by a metal bracket.
Document Control Desk Page 1 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 Attachment
1 Re 1 to Notice of Violation 528 89-24.-03 I.REASON FOR VIOIATION On March 30, 1989 a Radwaste technician
at the Dry Active Waste Processing
and Storage (DAWPS)Facility discovered
a high range detector in a CONEX box from Unit 2 designated
for radioactive
waste.In response to this discovery, an Incident Investigation
was initiated on March 30, 1989.The summary results of that investigation
are presented in the following paragraphs.
On April 26, 1984, a high range detector (S/N 422707)for RU-151, Unit 1 Primary Coolant Monitor'B', was received from Kaman Instrumentation
Corporation.
The detector is an ion chamber detector whose design incorporates
a small"keep alive" radiation source to maintain a minimum constant signal from the detector.The isotope utilized in this detector, as well as 30 other RMS channels in each Unit (total of 31 similar detectors required for each Unit)is Am-241 in the amount of 80 nanocuries (range for all detectors is80-150 nanocuries);
this amount is in excess of the exempt quantity limit set forth in 10 CFR 30.15(a)(9)(iii)
of 50 nanocuries
(0.05 microcuries).
An initial receipt survey for the detector was performed in accordance
with procedure 75RP-9ZZ56,"Receipt of Radioactive
Material," by the Radioactive
Waste Support Group and the material was identified
as a
,
i Document Control Desk Page 2 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 radioactive
source.The Radiation Protection
Support Calibration
Facility, the organization
responsible
for source control in 1984, was notified of the receipt of the radioactive
source by the Radioactive
Waste Support group.These actions were documented
on the Radioactive
Source Receipt Record.A Calibration
Facility technician
then examined the shipment and inappropriately
determined
the detector to be an exempt quantity.On March 24, 1986, an I&C technician
removed the high range detector (S/N 422707)from Radiation Monitor RU-151, during the conduct of routine maintenance.
Attempts were made to decontaminate
the detector in preparation
for shipping the unit to the manufacturer.
These attempts were unsuccessful
and RP personnel were informed.lt is assumed that the detector was placed in the CONEX box to be disposed of with other contaminated
material.On March 30, 1989, a contract Rad Waste technician
at Dry Active Waste Processing
and Storage (DAWPS)Facility discovered
the detector in a CONEX box from Unit 2 designated
for radioactive
waste.Unit 2 RP was notified at 1000, on March 30, 1989, of the discovery of the detector.Unit 2 RP recovered the detector and transported
it to the Central RP Calibration
Facility for disposal per the requirements
of 75AC-9RP05,"Source Control." As a result of the determination
in 1984 made by the Calibration
Facility technician
that the source was an exempt quantity, the detector was not entered into the Source Tracking System, and therefore, the
Document Control Desk Page 3 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 requirements
for accountability
and special handling were not implemented.
Also, because of the misclassification
there was no documentation
which would substantiate
that the required source labeling had been verified.To ensure that the detectors are labeled in accordance
with procedural
requirements, detector S/N 422707, new detectors stored in the warehouse, and accessible
installed detectors were examined for correct labeling.The detectors reviewed were labeled"CAUTION RADIOACTIVE
MATERIAI" and listed the isotope (Am-241), amount (generally,80-150 nanocuries), and the date of activity determination.
The labeling contained on the detectors examined was in accordance
with the approved station requirements
contained in procedure 75RP-9ZZ61,"Radioactive
Material Storage and Control." However, detector cans were identified
that had labels that contained information
that could not be read.Additionally, installed detectors were identified
that had the radioactive
material label partially or largely obscured by the detector mounting bracket.In these cases, the detectors were relabel'ed.
The root cause of this event is attributed
to the failure of the Radiation Protection
Calibration
Support personnel to correctly identify upon initial receipt in 1984 that the subject RMS detectors
1 Document Control Desk Page 4 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 contained non-exempt
quantities
of Am-241, and, as such, required accountability, special handling, and clearly visible labeling.The persistence
of this problem for an extended period of time is attributed
to inadequate
knowledge of the requirements
for exempt and non-exempt
sources by personnel who were responsible
for various aspects of source accountability.
Further, it was determined
that responsible
PVNGS personnel were unaware that, regardless
of whether the detectors containing
the Am-241 were exempt or non-exempt, the detectors could not be disposed of as radioactive
waste.Procedures
in place for receipt of radioactive
material at the time of this event required that personnel refer to the Code of Federal Regulations
to determine what constitutes
exempt or non-exempt
sources.Based upon the investigation
results, there is no indication
that the Code of Federal Regulations
was used to determine source status which was contrary to the approved procedure.
The initial failure to properly classify the detectors resulted in the subsequent
documented
procedural
violations
discussed in this notice.II.CORRECTIVE
ACTIONS TAKEN AND RESULTS ACHIEVED RMS detector S/N 522707 was recovered by the Central Radiation Protection
Calibration
Facility and retained for proper handling/disposition.
Central Radiation Protection
Calibration
Facility personnel;
1)initiated a physical inspection
of the warehouse, units,
Document Control Desk Page 5 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 and rework facility to establish the current inventory of SQ detectors containing
sources;2)entered the detectors on hand into the Source Tracking System (STS);and 3)assured that the sources contained in detectors at the warehouse were under positive control of the Central Radiation Protection
Calibration
Facility to preclude further improper handling or disposition..
Additionally, RMS detectors were examined to ensure the labeling of detectors containing
sources was in accordance
with station procedures
and federal requirements.
Identified
deficiencies
have been corrected.
On July 6, 1989, the Plant Director issued a memo to the Unit Plant Managers, Unit and Central Maintenance
Managers, Unit Radiation Protection
Managers, and Unit and Central Maintenance
l&C Supervisors
that specifically
advised them of the requirements
to handle, account for, and ensure proper disposition
of SQ system detectors containing
radioactive
sources.A change has been initiated to 76AC-ORW01,"Receipt, Storage, an'd Shipment of Radioactive
Material," to require specific notification
of Central Radiation'Protection
Calibration
Facility personnel upon receipt of any radioactive
material to ensure initial determination
of accountability
and handling requirements.
This change is expected to be implemented
by September 15, 1989.As an interim measure, a memo has been issued by the Site RPM which requires the additional
notifications.
Document Control Desk Page 6 of 8 102-01383-WFC/TDS/TRB
August 28, 1989 To ensure'hat
no other detector sources at PVNGS have been inappropriately
classified
as exempt, a review of receipt records and the Source Tracking System has been performed for all sources.No additional
deficiencies
other than those with the Am-241 sources were identified
during the review.III.CORRFCTIVE
ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
To ensure that no sources have been inadvertently
disposed of as radioactive
waste, a detailed review of receipt records and work history is currently in process.Should the review determine that a source was inadvertently
disposed of, applicable
reporting requirements
will be followed.This review is expected to be completed by September 5, 1989.Radiation Protection
personnel responsible
for source receipt, accountability, handling, and disposal, and I&C personnel responsible
for RMS maintenance
will be familiarized
with this event through required'reading of the PVNGS Incident Investigation
Report that addresses the events discussed in this violation.
The review of the subject investigation
is expected to be completed by September 1, 1989.Station procedures
that deal with various aspects of source receipt, accountability, handling, and disposal will be revised to reflect a specific position with responsibility
for all determinations
involving radioactive
sources, regardless
of the quantities.
These procedure
Document Control Desk Page 7 of 8 102-01383-MFC/TDS/TRB
August 28, 1989 changes, as well as other changes to Radiation Protection
procedures
required by the PVNGS Incident Investigation
Report, are expected to be completed by September 30, 1989.Maintenance
Procedures
and repetitive
maintenance
tasks will be reviewed and those tasks where it is anticipated
that an affected RMS detector could be replaced or physically
manipulated
will be revised to reflect appropriate
points of contact for disposition
of the detector source and necessary precautions
to prevent damaging or obscuring of detector radioactive
material labels.The review and implementation
of the required changes are expected to be completed by October 15, 1989.As e an interim measure a directive has been issued to the work control managers requiring that the Central Radiation Protection
Calibration
Facility be notified anytime a work order involves the removal of an item containing
radioactive
sources regardless
of quantity to ensure appropriate
instructions
have been included.In order to ensure the proper precautions
are addressed in corrective
maintenance
work orders, this response will be required reading for each work planner.A copy of the response wi.ll be provided to each individual=by
September 1, 1989.Responsible
Radiation Protection
personnel will be trained in the proper handling and control of sources.This training will be completed by October 15, 1989.In order to ensure continued compliance
in this area
Document Control Desk 102-01383-WFC/TDS/TRB
August 28, 1989 this topic will be added to the continuing
training program.IV.DATF.WHEN FULL COMPLIANCE
WILL BE ACHIEVED Accessible
RMS detectors were examined for proper labeling during a walkdown conducted by Central Radiation Protection
Calibration
Facility personnel.
Based upon the walkdown the initial source accountability
was established
and existing labeling deficiencies
were corrected.
However, detectors are located inside the Unit 2 containment.
Those detectors located inside the containment
of Unit 2, which is currently at power, have not been verified.Initial accountability
for those detectors and subsequent
entry into the STS was based upon a review of the monitors'ork
history.Visual verification
of the monitors will be conducted at the next opportunity
that the reactor is subcritical
or during the Unit 2 refueling outage whichever operational
mode occurs first.In accordance
with the source control program, these detectors will be inventoried
on a semi-annual
basis.
4 h 4 I