IR 05000528/1991004
| ML17305B742 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/11/1991 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9109230016 | |
| Download: ML17305B742 (15) | |
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Docket Nos.
50-528, 50-529, 50-530 Arizona Public Service Company P.O.
Box 53999, Sta.
9012 Phoenix, Arizona 85072-3999 Attention:
Mr.
M.
F.
Conway Executive Vice President, Nuclear Gentlemen:
Thank you for your letters of June 13, 1991 and August 8; 1991 in response to our Notice of Violation and Inspection Report Nos.
50-528/91-04, 50-529/91-04, 50-530/91-04 dated May 2, 1991, informing us of the steps you
'ave taken to correct the items we brought to your attention.
Your corrective actions will be verified dunng a future inspection.
Your cooperation with us is appreciated.
Sincerely, Cd/g~
HMong S.
A. Richards, Chief Reactor Projects Branch bcc w/copy of letter dtd 6/13/91 and 8/8/91:
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NRC Document Control Desk Attachment 1,
Page 1 of 8 102-02041-WFC/TRB/RJR June 13, 1991 ATTACHMENT
.REPLY TO NOTICE OF VIOLATION 50-528 91-04-01 I.
REASON FOR THE VIOLATION Example 1:
The fire extinguisher was issued for use without the required monthly check because the individual who removed the extinguisher from service failed to ensure that the monthly check was performed and/or that the extinguisher was properly controlled.
As a result, this extinguisher was inadvertently commingled with properly checked fire extinguishers and subsequently issued.
Example 2:
The fire extinguisher did not receive an annual check because the individual responsible for the preparation of the annual checklist used a monthly checklist in error.
The fire extinguisher was not included on the monthly checklist because it was out of service, and therefore, was
~
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not given an annual check.
IZ.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The fire extinguisher which had not received its monthly check was immediately removed from service and checked.
This fire extinguisher was.
found to be satisfactory and acceptable for use.
The fire extinguisher which had missed its annual check was immediately inspected.
This fire extinguisher was found to be satisfactory and acceptable for us ~I
NRC Document Control Desk Attachment 1,
Page 2 of 8 102-02041-WFC/TRB/RJR June 13, 1991 Approximately 1500 permanent plant fire extinguishers and transient fire extinguishers (those maintained in a central location and issued for'emporary use)
were inspected between March 7, 1991, and March 19, 1991.
The permanent plant fire extinguishers were found to be current on their required maintenance checks.
However, 15 transient fire extinguishers were found to be overdue on their required annual maintenance check, and eleven transient fire extinguishers could not be located.
The overdue maintenance checks were performed, and..each fire extinguisher was found M
requesting that the'extinguishers be located and the fire department be acceptable for use.
With respect to the missing extinguishers, on arch 19, 1991, a
memo 'was distributed to the maintenance managers.
contacted for inspection of the extinguishers.
By April 4, 1991, four of the missing extinguishers had been located and inspected As of June 6,
g+vcpj
'991, no additional missing extinguishers had been located.
Missing fire
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~
extinguishers are identified on the monthly fire extinguisher inspection list.
The monthly fire extinguisher check includes a search for these missing extinguishers.
Instructions were issued on April 10, 1991, directing fire watch personnel to ensure that the transient fire extinguishers are checked and acceptable prior to field us yC
lg NRC Document Control Desk Attachment 1,
Page 3 of 8 102-02041-WFC/TRB/RJR June 13, 1991 ZZI.
CORRECTIVE-STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The instructions discussed in Section II above, will be incorporated into Administrative Control Procedure 14AC-OFP04 by July 15, 1991.
This procedure will ensure that personnel error of the type identified above willnot.result in fire extinguishers being used in the field with overdue maintenance checks.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Compliance for the two instances identified in the Notice of Viol.ation was achieved on the dates'f discovery (i.e., March 5 and March 6, 1991),
and by March 19, 1991, compliance was achieved for the 15 transient fire extinguishers found to be overdue on their required annual maintenance chec ~I
~ ~
NRC Document Control Desk Attachment, 1,
Page 4,of
102-02041-WFC/TRB/RJR June 13, 1991 ATTACHMENT 1 CONTINUED REPLY TO NOTICE OF VIOLATION 50-528 91-04-04 I.
REASON FOR THE VIOLATION The corrective actions implemented in response to the Notice. of Violation to the Diagnostic Evaluation Report (102-01825, dated August 31, 1990),
were ineffective in accommodating numerous changes to drawings over short periods of time because of two potentially conflicting policies.
These policies were (1) the requirement to revise non-key drawings with five or more drawing change notices (DCNs), or DCNs outstanding longer than six
'months, and (2) the policy of not issuing an updated drawing that had any outstanding incorporable DCNs against it.
The design drawing (13-J-ZZI-004) and unitized drawings (01,02,03-J-ZZI-004) provide data for motor operated valve (MOV) torque switch setpoints arid limit switch setpoints.
The implementation of NRC IE Bulletin 85-
and Generic Letter 89-10, but'ore specifically, design changes involving the rewiring of MOV.limit switches, created a large quantity of changes to these drawings over short periods of time.
Each valve that was modified resulted in a separate
.DCN to the appropriate drawing(s).
When the violation was discovered, the Nuclear Information Records Management (NIRM)
Department had a
policy which required that all incorporable DCNs be included prior to a drawing revision being issue w4 NRC Document Control Desk Attachment, 1, Page 5 of 8 102-02041-WFC/TRB/RJR June 13, 1991 When the five DCN criteria was met, engineering would update, review, and approve the drawings and send them to NIRM for issue.
If any new DCNs were added during the time required for these activities, NIRM would hend the updated drawings back to engineering requesting that the new DCNs also be included.
The MOV limit switch rewire design changes were adding DCNs on a frequent basis, resulting in a cycling of the updated drawing between NIRM and engineering without issuing the drawing to the field.
These two circumstances (the number of changes and the requirement to include all incorporable DCNs prior to issuing updated drawings)
in
~J combination created a situation where the number of outstanding DCNs evolved into a backlog..
The circumstances were accepted at the working level. for a period of time, and the.situation was eventually brought to the supervisory level.
Engineering supervision recognized the problem with the policies but did not recognize the scope of the backlog, nor take corrective action to resolve the problem.
II.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED APS has updated the Unit 3 and the Unit 1 as-built drawings.
Due to the many differences existing in MOV settings from unit to unit and the fact-that the unitized as-built drawings are current and contain the same information, the design drawing (13-J-ZZI-004) has been archived so that only the as-built drawings are available for use,in the field.
C
'. 4 4't NRC Document Control Desk Attachment 1,
Page 6 of 8 I
102-02041-WFC/TRB/RJR June 13, 1991 III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
To effectively deal with the mechanics of drawing revisions from DCNs, Procedure 81DP-OCC09,
"Drawings" was changed on June 6, 1991, to require revising the unitized as-built drawings (01,02,03-J-ZZI-004) within five working days, upon notice of completion of five DCNs, or 60 days upon completion of any DCN, whichever is sooner.
In addition, Procedure 84DP'-
OCC03,
"Engineering Document Configuration Control Process" will be changed to allow DCNs received during the five working day incorporation period to be held over for the next drawing revision.
This procedure change will be completed by July 15, 1991.
The appropriate supervisor was counseled on the need to meet procedural
\\
requirements, arid when this is not possible, to inform appropriate
. management to allow for prompt resolution.
Additionally, discussions were held with the responsible engineering group on the need to comply with procedural requirements.
IV.
DATE OF FULL COMPLIANCE Full compliance was achieved on April 11, 1991, for Unit 1 and March 15, 1991 for Unit 3,
when the as-built drawings were updated to meet procedural requirement NRC Document Control Desk Attachment 1,
Page 7 of 8 102-02041-WFC/TRB/RJR June 13, 1991 TTACHMENT 1 CONTINUED REPLY TO NOTICE OF VIOLATION 50-530 91-04-01 EASON FOR THE VIOLATION The violation occurred because APS believed that the overtime was permitted by Technical Specification 6.2.2.1 c, which states in part, "...
deviation from the above guidelines shall be authorized... in accordance with established procedures and with documentation of the basis for granting the deviation...
Routine deviation from the above guidelines is not authorized."
However, APS failed to document the non-routine nature
of the required overtime as part of the basis for granting the deviation.
The non-routine nature was the contractor's inability to supply sufficient numbers of qualified Radiation Protection Technicians, as was previously scheduled; in order to provide the necessary shift coverage at the start of the Unit 3 refueling outage which began on March 16, 1991.
II.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED By April 4, 1991, sufficient numbers of qualified Radiation Protection Technicians were on shift, and the Technical Specification requirements for overtime were being me "NRC Document Control Desk Attachment 1; Page 8 of
162;- E26% lg-Wgr;;~~~
June.
3!2,. 39&1 III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHK3.'76idPl~>QNK Administrative Control procedure 03AC-OEM01,
"(hmrci'me; EimItaeio~'" v'3X be changed by July 15, 1991, to include requirenanm for dacuman~'he non-routine nature of required overtime in the tes2s 9am mm~e8'ng Technical. Specification requirements for overtine.
IV.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved by April 4, 1991, whea suZfieiiena numbers of qualified Radiation Protection Technicians were car sErMe, a"M the Technical Specification requirements for overtime w~ hammy me+.