ML17304B412

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

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