IR 05000528/1993018

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-528/93-18, 50-529/93-18 & 50-530/93-18

ML20056C910
Person / Time
Site:	Palo Verde
Issue date:	07/15/1993
From:	Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 9307260125
Download: ML20056C910 (3)

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fq"".8tQ UNITED STATES -

NUCLEAR REGULATORY COMMISSION -

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. Dockets.50-528, 50-529,land 50-530

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Arizona Public Service Compan P. 0.LBox 53999, Sta. 9082 i Phoenix, Arizona 85072-3999 Y Atiiention: William F? Conwa) .

Executive Vice P esident, Nuclear Thank 'you for your ' letter, dated July 6,1993, in response to our Notice of Violation-issued by letter, dated-June 3,1993. Your response informed us of ithe steps you have taken to correct'the items we brought to your attentio Your corrective actions will.be verified during a future inspectio .

Sincerely e

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f Jam s . Reese,. Chief i Facilities' Radiologi al Protection Branch :

a-cc:

'Mr.LSteve-Olea, Arizona Corporation Commission

~ James A. ..Beoletto,1 Esq'., . Southern California ~ Edison Company

Mr.4 Charles B. Brinkman, Managar, Washington- Nuclear Operations Mr?: Aubrey. Godwin,' Director, Arizona' Radiation Regulatory Age'ncy-Chairman,'Maricopa County Board.of Supervisors

. Jack R. Newman,.Esq., Newman & Holtzinger, P.C.- .

Mr;;Curtis Hoskins, Executive Vice President and Chief Operating Officer,.

Palo Verde. Services .

. Roy P. LLessey, Jr.,: Esq., Akin, Gump, ' Strauss, Hauer and Feld-Bradley W. Jones, .Esq., Akin, Gomp, Strauss, Hauer and Feld

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. Thomas R..Bradish, Manager, Nuclear Regulatory Affairs, APS

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19307260125 930715 T  ;

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Dockets 50-528, 50-529, and 50-530 L Arizona Public Service Company P. O. Box 53999, Sta. 9082 Phoenix, Arizona 85072-3999 Attention: William F. Conway Executive Vice President, Nuclear

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Thank you for your letter, dated July 6,1993, in response to our Notice of Violation issued by letter, dated June 3,1993. Your response informed us of the steps you have taken-to correct the items we brought to your attentia Your corrective. actions will be verified during a future inspectio

Sincerely James H. Reese, Chief Facilities Radiological Protection Branch cc:

Mr. Steve Olea, Arizona Corporation Commission James A. Beoletto, Esq.,- Southern California Edison Compuny Mr. Charles B. Brinkman, Manager, Washington Nuclear Operations Mr. Aubrey Godwin, Director, Arizona Radiation Regulatory Agency CFairman, Maricopa County Board of Supervisors

~ Jack R. Newman, Esq., Newman & Holtzinger, Mr. Curtis Hoskins, Executive Vice President'and Chief Operating Officer, Palo Verde Services

- Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld

- Bradley,W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld Thomas R. Bradish, Manager, Nuclear Regulatt / Affairs, APS-bec w/ copy of letter dated July 6,1993:

Docket File Resident Inspector Project Inspector G. Cook

- R. Huey B. Faulkenberry ,

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J. Zollicoffer bec w/o copy of letter dated July 6,1993:

M. Smith-

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Arizona Public Service Company ;,,- ,. .. . ..

P.O. BOX 53999 * PHOENIX. ARIZONA 85072 3999

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. WILLIAM F. CONWAY EKECUTivE vtCE PAC.SfDENT

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102-02557-WFC/TRB/SAB July 6,1993 U. S. Nuclear Regulatory Commission ATFN: Document Control Desk Mail Station P1-37 _

Washington, DC 20555

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ear Sirs:  :

Subject: Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3

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Docket Nos. STN 50-528/529/530 Reply to Notices of Violation 50-528/93-18-02 and 50-528/93-18-03 File: 93-070-026 ,

Arizona Public Service Company (APS) has reviewed NRC Inspection Report _50-528/529/530/93-18 and the Notices of Violation dated June 3,1993. Pursuarit to the ~

provisions of 10 CFR 2.201, APS' responses are enclosed. Enclosure 1 to this letter is a restatement of the Notices of Violation. APS' responses are provided in Enclosure Shouid you have any questions, pleasel contact Thomas R. Bradish at (602) 393-542

Sincerely,

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jflW WFC/TRB/SAB/rv Enclosures: " Restatement of Notices of Violation Reply to Notices of Violation cc: B. H. Faulkenberry J. A. Sloan

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ENCLOSURE 1  ;

RESTATEMENT OF NOTICES OF VIOLATION 50-528/93-18-02

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AND 50-528/93-18-03 NRC INSPECTION CONDUCTED MAY 3 THR'OUGH MAY 7,1993 -

I INSPECTION REPORT NO. 50-528/529/530/93-18-.

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Restatement of Notices of Violation 50-528/93-18-02 and 50-528/93-18-03 -

During an NRC inspection conducted the week of May 3 through May 7,1993, two violations of NRC requirements were identified in accordance with the General Statement i of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix ~ The violations are identified below:

A. Viohtion 50-528/93-18-02 RADIOLOGICAL SURVEYS  ;

10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the requirements of Part 20 and which are reasonable  :

under the circumstances to evaluate the extent of radiation hazards that may be ' ,

present. As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of l condition '

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Contrary to the above: On November 19-20,1992, twelve 55-gallon drums of potentially radioactive oil were not surveyed as necessary to comply with the requirements of .

10 CFR 20.301,in that nonrepresentative samples of the drummed oil were used as the basis for determining whether the oil could be released for .

unrestricted us .! On November 20,1992, six 55-gallon drums of potentially radioactive oit  :

v!ere not surveyed as necessary to comply with the requirements of ,

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10 CFR 20.301, in that radiation and contamination surveys of the external surface of the drums did not detect radiation levels as high as 4 millirem per hour on contact with the surface of ;he dru , On November 20,1992, a bag marked as containing radioactive material ,

was not surveyed as necessary to comply with the requirements of 10 CFR 20.301, in that the bag was disposed of in an uncontrolled manner- -

and no radiation or contamination surveys of the bag were performe This is a Severity Level IV violation (Supplement IV). i B. Violation 50-528/93-18-03 PROCEDURAL COMPLIANCE  :

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TS 6.8.1 requires that written procedures be established, implemented and .

maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 197 Page 1 of 2-i i

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

" Procedures for the Control of Radioactivity (For limiting ,

materials released to environment and limiting personnel exposure)"

a Licensee Procedure 75AC-9RP03, " Radiological Controls Problem Reporting dated April 5,1991, Section 2.1.3 requires that radiation protection department personnelinvestigate reported concerns and initiate appropriate documentatio ,

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

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Licensee Procedure 75AC-9RP02, " Radioactive Contamination Control," dated l

July 8,1991, Section 3.2, " Yellow, Magenta, or Yellow and Magenta Material Controls," establishes controls for use of such materials. Section 3.2.2 states that

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these materials shall only be used within the radiologically controlled area (RCA)

or in suitably controlled and posted areas outside the RC Contrary to the above: 1 On November 24,1992, radiation protection department personnel failed to initiate a CRDR when concerns were reported involving personnel error and involving radioactive material released outside of a radioactive material are . On November 20,1992, yellow and magenta material was released for use outside the radiologically controlled area, and suitable controls and posting .

were not put in place to authorire such us .

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

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ENCLOSURE 2  ;

i REPLY TO NOTICES OF VIOLATION 50-528/93-18-0 '!

AND 50-528/93-18-03  !

NRC INSPECTION CONDUCTED MAY 3 THROUGH MAY 7,1993 -  !

INSPECTION REPORT NO. 50-528/529/530/93-18 ,

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

Admission or Denial of the Alleaed Violation l APS admits the violation. The concerns identified in this violation were identified by APS in December 1992 and a thorough investigation and evaluation of these concerns was

performe The violations were cited following the inspector's review of the APS investigation repor ,

Reason for the Violation Notice of Violation (NOV) 93-18-02 cites three examples of failure to perform surveys that

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were adequate to evaluate the extent of the radiation hazards present. The reasons for the violation are:

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1) Failure to follow existing station operating procedure .

2) Multiple personnel errors, including inadequate supervisory contro ) Inadequacies in the program for handling and classifying used oi ,

4) Lack of procedural guidance for obtaining representative samples of oi Page 1 of G

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r'orrective Actions Taken and Results Achieved The oil involved in the incident was either quarantined or returned to the protected are The oil was not released offsit :

APS conducted a thorough investigation of this incident and' developed a comprehensive .

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response to the concerns identified. Corrective actions taken in response to reasons 1)

and 2) above are as follows: 9 Appropriate disciplinary action was administered to the radiation protection technicians and supervisors responsible for the release of the oil drums without adequate samples and survey Radiation protection management reiterated to supervisors the necessity of .

l reporting incidents of this nature through the station procedures developed for that purpos .

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

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and dispositio ,

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^ ~ This' incident 'was included in the second quarter industry. eventsitraining for f radiation protect'an personnel. The need to perform adequate surveys and the  ;

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consequences of inadequate surveys were emphasized. in addition, lessons learned from this incident were presented to contract radiation protection personnel hired for the Unit 2 outag .

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

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I A waste task force was created to develop guidance for the control of waste' oil to -

L ensure that the waste streams are appropriately segregated (i.e., radioactive.-

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material, mixed waste, and hazardous waste), in addition, the task _ force .

addressed the programmatic deficiencies identified during the evaluation of this

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Corrective Actions That Will Be Taken To Avoid Further Violations

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Corrective actions to be taken in response to reasons 1) and 2) above are as follows: .

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

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management delineating expectations when performing assigned tasks.' . it.is ' ,

expected that the manual will be completed by September 30,1993.'

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

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The findings of the. task force will be used to revise oil sampling and handling'-

procedures, as appropriate. The technicians will then be trained to the reviced'

pr,ocedures. These actions are expected to be completed by August 3,199 l

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Procedure 75RP-9RP09, Vehicle, Equipment and Material Release, will be revised j

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by August 3,1993. The revision will, in part, modify the form used to release materialin order to include such information as waste characterization and material dispositio !

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

conservative assumption that this problem existed previously and went undetecte j

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This analysis will be completed by' July 23,199 :

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Date When Full Compilance Will Be Achieved

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Full compliance was achieved on January 11,1993, when the oil and oil drums had been surveyed, accurately depicting the extent of the radiation hazard, and the contaminated -!

oil and drums were placed under the proper radiological control ,

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

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Admission or Denial of the Alleaed Violation

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- APS admits the violation. The concerns identified in this violation were identified by APS ,

in December 1992 and a thorough investigation and evaluation of these concerns was ,

performe The violations were cited following the inspector's review of the APS

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investigation repor ..

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

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Corrective Actions Taken and Results Achieved

' APS conducted a thorough investigation of this incident and developed a comprehensive j response to the concerns identifie The oil involved in the incident was either .

quarantined or returned to the protected area. The oil was not released offsit .

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< ' Appropriate disciplinary action was administered to the radiation protection technicians .

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and supervisors responsible for the release of the oil drums without adequate samples - y i

and survey Radiation protection management reiterated to supervisors the necessity of reporting -

incidents of this nature through the station procedures developed for that purpos _

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This incident was included in the second quarter industry events training for radiation !

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protection personnel. The need to report incidents of this nature and to comply with  !

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procedures for the control of radioactive material were emphasized. In addition, lessons l

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learned from this incident were presented to contract radiation protection personnel hired ;

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Corrective Actions That Will Be Taken To Avoid Further Violations- i The actions discussed above are adequate to avoid further violation q

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Date When Full Compliance Will Be Achieved 1 l

f Full compliance was achieved on January 11,1993, after CRDR 920758 was written to evaluate this incident, and the contaminated oil and drums were adequately survey $d and placed under the proper radiological control !

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