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CESSION NBR:9201220011 DOC.DATE: 92/01/17 NOTARIZED: NO DOCKETACIL:STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529

STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530AUTH.NAME AUTHOR AFFILIATION

CONWAY,W.F. Arizona Public Service Co. (formerly Arizona Nuclear PowerRECIP.NAME RECIPIENT AFFILIATION R

Document Control Branch (Document Control Desk)

SUBJECT: Responds to NRC 911218 ltr re violations noted in Insp Repts50-529/91-40 6 50-530/91-40 on 911013-1114.Correctiveactions:reactor startup procedures revised re withdrawal ofregulating group control element assembly.

DISTRIBUTION CODE: IE06D COPIES RECEIVED:LTR ENCL SIZE:TITLE: Environ 6 Radiological (50 DKT)-Insp Rept/Notice of Violate.on Respons /NOTES:Standardized plant. 05000529 A

Standardized plant. 05000530D

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WILLIAMF. CONWAYEXECUTIVEVlCEPRESIDENT

NUCI.EAR

Arizona Public Service CompanyP.O. BOX 53999 ~ PHOENIX;ARIZONA

85072-3999'02-02105-MFC/TRB/JRB

January 17. 1992

U. S. Nuclear Regulatory CommissionAttention: Document Control DeskMail Station: P1-37Washington, DC 20555

Reference: Letter dated December 18, 1991 from S. A. Richards,.Chief, ReactorProjects Branch, NRC to W. F. Conway, Executive Vice President, Nuclear,APS.

Gentlemen:

SUBJECT'ALO VERDE NUCLEAR GENERATING STATION (PVNGS)UNITS 1, 2 AND 3REPLY TO NOTICES OF VIOLATION50-529/91<0-01 and 530/91-40-02File: 92-070-026

Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528, 529,530/91-40 and the Notices of Violation dated December 18, 1991. Pursuant to theprovisions of 10 CFR 2.201, APS'esponse is attached. Appendix A to this letter is arestatement of the Notices of Violation. APS'esponse is provided in Attachment 1.

Should you have any questions regarding this response, please contact me.

Very truly yours,

WFC/TRB/JRB/dmnAttachments

Appendix A - Notices of.Violation2. Attachment 1 - Reply t'o Notices of'Violation

cc: J. B. MartinD. H. Coe

>ok';12012200K l '7=0117I""DR ADOCK 05000529I ~l PD~'r

APPENDIX A

RESTATEMENT OF NOTICES OF VIOLATION50-529/91%0-01 AND 50-530/91%0-02

NRC INSPECTION CONDUCTED OCTOBER 13, 1991-NOVEMBER 14, 1991

INSPECTION REPORT NOS. 50-528, 529, 530/91%0

RESTATEMENT OF NOTICES OF VIOLATION .

50-529/914041 AND 50-530/9140-02

During an NRC inspection conducted on October 13 through November 14; 1991,violations of NRC'requirements were identified. In accordance with the "Gen'eralStatement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2,Appendix C (1991)," the violations are listed below:

A. Unit 2 Technical Specification 6.8.1 states in part: Written procedures shall beestablished, implemented, and maintained covering the" activitiesrecommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,1978."

Regulatory Guide 1.33, Revision 2, Appendix A, includes

"7.e Radiation Protection Procedures (1) Access Control to Radiation AreasIncluding a Radiation Work Permit System."

This is implemented, in part, by licensee procedure 75AC-9RP01, "RadiationExposure and Access Control," which makes each individual responsible for~ .. "2.1.5 Reading the applicable Radiation Exposure Permit (REP) for theirspecific job or task and obeying all instructions and requirements (i,e.dosimetry and protective clothing requirements)."

The REP 2-91-3024B required a pre-job briefing, which required personnelto wear double gloves in the hot particle control areas around the refuelingmachine.

The REP required the conduct of hot particle checks approximately every30 minutes for workers in the Multi-Stud Tensioner area.

Contrary to the above, REPs requirements were not followed as evidencedby the following examples:

(1) On October 30, 1991, double gloves were not worn by severalrefueling team members in the hot particle control areas around therefueling machine.

(2) On November 8, 1991, hot particle checks were not conducted forover 90 minutes on one occasion in the multi-stud tensioner area.

This is a Severity Level IV violation (Supplement IV) applicable to Unit 2.

Unit 3 Technical Specification 6.8.1 states in part: 'Written procedures shall beestablished, implemented, and maintained covering the activitiesrecommended in Appendix A of Regulatory Guide 1.33, Revision 2, February,1978."

Regulatory Guide 1.33, Revision 2, Appendix A, covers General Plant OperatingProcedures for Hot Standby to Minimum Load (nuclear startup). Procedure 430P-3ZZ03, "Reactor Startup," step 4.3.22.17, states:

From Group 3 at 60" withdrawn to the ECRP [Estimated Critical Rod Position] -500pcm position, OR until conditions indicate criticality is near WHICHEVER OCCURSFIRST:

Assistant Shift Supervisor's "Evaluation of 1/m," per step 4.3.10, determinesthat this withdrawal is permitted:

Withdraw Regulating Group CEAs [Control Element Assemblies] in ManualSequential in no more that 15 inch increments pausing after each 15 inchincrement to permit count rate to stabilize and SUR [Startup Rate] to decayto zero.

\

Contrary to the above, on Gctober 30, 1991, operators withdrew CEAs from belowthe ECRP -500 pcm position to two inches above the ECRP -500 pcm positionwithout stopping at the ECRP -500 pcm position.

This is a Severity Level IV violation (Supplement I) applicable to Unit 3.

ATIACHMENT 1

REPLY TO NOTICES OF VIOLATION. 50-529/9140-01 AND 50-530/9140-02

NRC INSPECTION CONDUCTED OCTOBER 13, 1991-NOVEMBER 14, 1991

INSPECTION REPORT NOS. 50-528, 529, 530/91-40

VIOLATION50-529 91<0-01

Reason for the Violation

Exam le 1

The reason for the violation was an error by the Radiation Protection Department

in not assuring that the implementation of a proactive Radiation Protection practice would

fully meet the requirements of a Radiation Exposure Permit.

In an effort to create a less stressful and safer work environment for operations

refuel personnel working on the refueling bridge and also to, reduce the hot particle

radwaste volume generation, the Radiation Protection Department developed a plan to

allow personnel to work on the refueling bridge without being in disposable outer

protective clothing.. The refueling bridge was designated as a contaminated area,

however, the path to and from the refueling bridge was through a hot particle control

area, which required additional controls. The solution developed by the Radiation

Protection Department was to wear addition'al disposable outer gloves and shoe covers

for traversing the hot particle control area enroute to and from the refueling bridge. This

requirement was incorporated into the required ALARApre-job briefing conducted for the

Radiation Exposure Permit for fuel movement and associated work in containment.

However, Radiation Protection personnel did not recognize that operations refuel

personnel would need one set of disposable outer gloves and shoe'covers to traverse

the hot particle control area to the refueling bridge and an additional set to traverse the

hot particle control area from the refueling bridge.

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On October 30, 1991, during the first four hours of implementation of the Radiation

Exposure Permit, an NRC inspector observed operations refuel personnel traversing the

hot particle control area from the refueling bridge without disposable outer gloves

required by the Radiation Exposure. Permit. These operations refuel personnel were

using one extra set of disposable outer gloves for traversing the hot particle control area

to the refueling bridge, but these articles of protective clothing were discarded upon entry

onto the refueling bridge. Consequently, these personnel did not have an additional s'et

of disposable outer gloves for their egress from the refueling bridge.

Exam Ie 2

The reason for the violation was a failure to follow the requirements of a Radiation.

Exposure Permit by a Radiation Protection technician.

Atapproximately 0730 on November 08, 1991, two Radiation Protection technicians

assisted two Inservice Inspection personnel in dressing out in protective clothing for a

Unit 2 containment entry. The purpose of the containment entry was to conduct

ultrasonic testing activities in the multi-stud tensioner tent. The Radiation Exposure Permit

under which the Inservice Inspection activities were being conducted required hot particle

checks at least every thirty minutes in hot particle control areas. The multi-stud tensioner .

tent was posted as a hot particle control area. One of the Radiation Protection

technicians assisting with the dress out initiated a hot particle monitoring log sheet and

both Radiation Protection technicians returned to their roving duties, It is normal practice

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for the Radiation Protection technician who initiates the hot particle monitoring log sheet

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to perform any required hot particle checks.

~ At approximately 0758 on November 08, 1991, a,third roving Radiation

Protection technician was in the vicinityof the multi-stud tensioner tent and noticed on the

hot particle monitoring log sheet that the Inservice Inspection personnel inside the multi-

stud tensioner tent needed a hot particle check. The Radiation Protection technician

performed the check, discovered no hot particles, and logged the results on the hot

particle monitoring log sheet.P

At approximately 0930 on November 08, 1991,'n NRC inspector was in the vicinity

of the multi-stud tensioner tent and observed that hot particle checks of the Inservice

Inspection personnel had not been conducted since 0800. The NRC inspector informed

a Radiation Protection technician of the delinquent hot particle checks.

The Radiation Exposure Permit required personnel working within a hot particle

control area to be monitored by Radiation Protection personnel at least every thirty

minutes. In this case, the responsible roving Radiation Protection technician inside

containment failed to comply with these controls.

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Correc lve S e s That Have Been Taken and Results Achieved

Exam le 1

Upon identification of the above problem, the Radiation Protection Department

evaluated the process to determine a method for the operations refuel personnel to have

access to an extra set of disposable outer gloves and shoe covers to traverse the hot

particle control area upon exiting the refueling bridge. This evaluation determined the

best corrective action was to require operations refuel personnel to wear two sets of '.

disposable outer gloves and shoe covers. One set of disposable outer gloves and shoe

covers was to be discarded upon entry to the refueling bridge and one set was to bet discarded upon exit of the hot particle control area after completion of work on the

refueling bridge. This process was implemented immediately through pre-job briefings

conducted at the Radiation Protection island.

In addition, to raise the aw'areness of this process by the Radiation Protection

technicians escorting personnel to and from the refueling bridge, a copy of the pre-job

briefing from the Radiation Exposure Permit was posted at the entrance to the hot particle

control area.

Exam le 2

t Upon notification of the cognizant Radiation Protection technician by the NRC

resident inspector, hot particle checks of the lnservice Inspection personnel were

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performed at approximately 0937 and no hot particles were discovered. Additional hot

particle checks were performed at 1000, again, with no hot particles being discovered.

. The Inservice Inspection personnel exited containment at approximately 1000 on

November 08, 1991.

Radiation Protection supervision discussed APS'xpectations on the responsibility

for hot particle checks with the Radiation Protection technicians involved and emphasized

the importance of awareness of required hot particle checks.

Unit 2 Radiation Protection personnel have been reminded of the requirements

for performing hot particle checks during work activities in hot particle control areas.

Applicable Unit 2 contract Radiation Protection technicians have reviewed a

required reading document describing this incident and emphasizing the requirements

for performing hot particle checks during work in hot particle control areas.

A Radiological Controls Problem Report was completed on this incident and

forwarded to the Units 1 and 3 Radiation Protection Managers.

Corrective'Ste s That Will'Be Taken to Avoid Further Violations

In Example (1), APS considers the failure to comply with the requirements of a

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Radiation Exposure Permit described a problem which occurred for only a short period

of time during early implementation of a Radiation Exposure Permit. In Example (2), APS

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considers the Radiation Exposure Permit noncompliance described an isolated incident.

In both examples, the corrective actions taken and described above are considered

adequate to avoid recurrence of these violations and no further corrective actions are

planned at this time.

Da e When Full Cpm Ilance Will Be Achieved

Exam Ie 1

APS was in full compliance on October 30, 1991, when the pre-job briefings being

conducted at the Radiation Protection island incorporated the requirement for wearingt two sets of disposable outer gloves and shoe covers prior to traversing the path throughr

the hot particle control area to the refueling bridge.

Exam Ie 2

APS was in full compliance at approximately 0937 on November 08, 1991, when

the required hot particle checks were conducted on the Inservice Inspection personnel

performing work in the multi-stud tensioner tent,

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Reason for the VIolatlon

k

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The reason for the violation was a personnel error by the Assistant Shift Supervisor

due to the misunderstanding of a procedural step in the reactor startup procedure (430P-

3ZZ03).

On October 30, 1991, Regulating Group Control Element Assemblies were being

withdrawn during an approach to criticality. An Assistant Shift Supervisor was

eadministering. the reactor startup procedure with no collateral duties.. The Reactor

Operator assigned responsibility to perform the reactor startup=had no collateral duties.

Regulating Group Control Element Assembly Group 1 was withdrawn to 120 inches,

Group 2 was withdrawn to 90 inches, and Group 3 was being withdrawn from 60 inches

withdrawn to the Estimated Critical Rod Position {ECRP)-500 pcm position. The ECRP-

500 pcm position had been calculated to be 92 inches withdrawn. Regulating Group

'ontrol Element Assembly Group 3 had been withdrawn to 79 inches withdrawn, the

count rate had stabilized, and the startup rate had decayed to zero. Step 4.3.22.17 of

the reactor startup procedure stated in part, "From Gr 3 at 60 withdrawn to the ECRP-500

pcm position... withdraw Regulating Group CEAs in Manual Sequential in no more than

15 inch increments pausing after each 15 inch increment to permit count rate to stabilize

and SUR to decay to zero." Following the stop at 79 inches withdrawn, the Assistant Shift

Supervisor administering the reactor. startup procedure instructed the Reactor Operator

performing the reactor startup to withdraw Regulating Group Control Element Assembly

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Group 3 an additional 15 inches. This withdrawal resulted in Group 3 being positioned

at 94 inches withdrawn. This position was 2 inches beyond the calculated ECRP-500

pcm position of 92 inches withdrawn. The Assistant Shift Supervisor administering theh

reactor startup procedure interpreted step 4.3.22.17 to allow a full 15 inch withdrawal from

any position of Group 3 between 60 inches withdrawn and the ECRP-500 pcm position.

The count rate stabilized and the startup rate decayed to zero. As stated in the subject

inspection report, this additional two inch withdrawal was not signTiicant from a nuclear

safety perspective.

An NRC inspector who was present in the control room during this evolution

equestioned the withdrawal of Regulating Group Control Element Assembly Group 3 per

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step 4.3.22.17 of the reactor startup procedure to the Operations Supervisor, who was

also in the control room,

Corrective Ste s That Have Been Taken and Results Achieved

The Operations Supervisor, upon being informed of the NRC inspector's question

concerning procedural step 4.3.22.17 of the reactor startup procedure, immediately

directed the Shift Supervisor to have the Regulating Group Control Element Assembly

Group 3 inserted to the ECRP-500 pcm position pending a review of the procedural step.

The control room personnel reviewed step 4.3.22.17 of the reactor startup

procedure and determined that the intent of the step was to withdraw Regulating Group

Control Element Assembly Group 3 from 60 inches withdrawn to the ECRP-500 pcm in

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no more than 15 inch increments=until,the ECRP-500 pcm position is reached, at which

point the withdrawal should be stopped.

This event was discussed with the Assistant Shift Supervisor by the Operations=

Supervisor.

The reactor startup procedures for all three Units have been revised to clearly state

that Regulating Group Control Element Assembly Group 3, when being withdrawn from

60 inches withdrawn to the ECRP-500 pcm position, is withdrawn in less than 15 inch

increments to the calculated ECRP-500 pcm position.

APS considers the corrective actions taken and described above are adequate to

avoid recurrence of this violation and no further corrective actions are planned at this

time.

Date When Full Com liance Will Be Achieved,

APS was in full compliance on October 30,.1991, when Regulating Group Control

Element Assembly Group 3 was reinserted to the ECRP-500 pcm position.

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