IR 05000528/1991019
| ML17305B741 | |
| 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 9109230005 | |
| Download: ML17305B741 (23) | |
Text
~Docket Nos.
50-528, 50-529, 50-530 Arizona Public Service Company P.
0.
Box 53999, Sta.
9012 Phoenix, Arizona 85072-3999 8EP
~ >>sSi Attention:
Nr.
M.
F.
Conway Executive Vice President, Nuclear Gentlemen:
Thank you for your letter of August 21, 1991, in response to our Notice of Violation and Inspection Report Nos.
50-528/91-19, 50-529/91-19, 50-530/91-19; dated July 23, 1991, informing us of the steps you have taken to correct the items which were brought to your attention.
Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
Sincerely, bcc w/copy of letter dated 8/21/91:
docket file Project Inspector Resident Inspector G.
Cook B. Faulkenberry J. tlartin J. Zollicoffer
.l1.
Smith (w/o letter)
State of Arizona S.
A. Richards, Chief Reactor Projects Branch REGION V/dot DCoe 9/
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WILLIAMF. CONWAY EXEClftlVEVICEPRESIOENT NUCLEAR Q~W~~~
~ I II~v'<hi RFQIQIl V Arizona Public Service Company PO.BOX53999
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PHOENIX,ARIZONA85072-3999 Iifl Ii.J 23 9 Ig: Q9 102-02057-MFC/TRB/RJR August 21, 1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station: P1-37 Washington, DC 20555 Reference:
1.
Letter from S. A. Richards, Chief Reactor Projects Branch, NRC to W. F. Conway, Executive Vice President Nuclear, APS, dated July 23, 1991.
Gentlemen:
2.
Letter from W. F. Conway, Executive Vice President Nuclear, APS to J. B. Martin, Regional Administrator, NRC dated May 31, 1SS1.
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNIT 'I, 2, AND 3 REPLY TO NOTICE OF VIOLATIONS50-529,530/91-19-01 AND 50-528/91-'1 9-01 NRC INSPECTION REPORT NOS 50-528/91-1 9, 50-529/91-19 and 50-530/91-1 9 File: 91-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528,529, 530/91-19 and the Notice of Violation dated July 23, 1991.
Pursuant to the provisions of 10CFR2.201, APS'esponse is attached.
Appendix A to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Attachment 1.
Reference 1 discussed examples relating to the improper performance of work practices.
APS has taken actions to reduce the frequency of these occurrences as discussed in the attached response and with Regional Management on August 2,.1SS NRC Document Control Desk Page 2 102-02057-WFC/TRB/R JR August 21, 1991 lf you have any questio'ns regarding this response, please contact me.
r Very truly yours, WFC/TRB/RJR Attachments 1.
Appendix A - Notice of Violation 2.
Attachment 1 - Reply to Notice of Violation cc:
J. B. Martin D. H. Coe
APPENDIX A RESTATEMENT OF NOTICE OF VIOLATIONS50-529, 530/91-19-01 AND 50-528/91-1 9-01 NRC INSPECTION CONDVCTED MAY12, 1991 - JVNE 15, l991 INSPECTION REPORT NOS. 50-528/91-1 9, 529/91-1 9 AND 530/91-19
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RESTATEMENT OF NOTICE OF VIOLATIONS50-529 530 91-'t 9-01 AND 50-528 91-1 9-01 During an NRC inspection conducted on May 12 through June 15, 1991, three violations of NRC requirements were identified.
tTwo of the Violations are listed herein.
With regard to Violation B, the cover letter (Ref.1) stated, " no response is required for violation B"]. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violations are listed below:
A.
Units 2 and 3 Technical Specifications 6.8.1 state in part:
'Written procedures shall be established, implemented, and maintained covering the activities...
recommended in Appendix A, of Regulatory Guide 1-.33, Revision'2, February, 1978."
Regulatory Guide 1.33, Revision 2, Appendix A, covers maintenance that can affect the performance of safety related equipment.
APS Conduct of Maintenance Procedure, 30DP-9MP01, step 3.5.15 states:
'Work group personnel shall verify that station component ideritification matches the component specified as requiring maintenance in the work document."
Work order 495993 required that the filter cover for 3MCHNF02A be unbolted.
Contrary to the above, on May 24, 1991, Unit 3 Mechanics unbolted 3MCHNF02B, during performance of work order 495993.
2.
Regulatory Guide 1.33, Revision 2, Appendix A, covers surveillance tests to meet technical specifications.
3.
Surveillance test procedure 36ST-9SA11, ESFAS Train A High Risk Subgroup Relay Monthly Functional Test, used to satisfy Technical Specification 4.3.2.1 specifies in steps 8.6.2.1 and 8.6.2.2 to perform actions at cabinet J-SAA-C01.
Contrary to the above, on May 16, 1991, an Instrument and Controls Technician failed'o implement procedure 31ST-9SA11, in Unit 3, when steps 8.6.2.1 and 8.6.2.2 were performed on the B train cabinet J-SA8-C01.
Regulatory Guide 1.33, Revision 2, Appendix A, covers the gaseous effluent system.
Procedure 74RM-9EF20, Gaseous Radioactive Release Permits and Offsite Page 1 of 2
Dose Assessment, Step 10.2.2 states that "lf RU-34 setpoints were changed, ensure that the ALERT and HIGH alarm set points are restored and documented...
"
Contrary to the above, on June 5, 1991, a Unit 2 Chemistry Effluent Technician'failed to implement procedure 74RM-9EF20 when the alarm setpoint on RU-38 was reset rather than RU-34 as required.
These examples represent a Severity Level IV violation applicable to Units 2 and 3 (Supplement I).
C.
Units 1, 2, and 3 Technical Specifications 6.8.1 state in part:
Written procedures shall be established, implemented, and maintained covering the activities...
recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February, 1978."
Regulatory Guide 1.33, Revision 2, Appendix A, covers administrative procedures for the plant fire protection program.
Procedure 14AC-OFP04, Revision 2, states in section 2.2,2.1 that, "InitialFire Watch training shall be given to those employees who will perform firewatch duties,", and in section 2.2.2.2, "Fire Watch CBT retraining and a practical will be given, on an annual basis, to those employees who will perform fire watch duties."
Procedure 15AC-OTRO9, Revision 1, states in section 3.5.1 that fire watch course NGF16 is required for all personnel who will be involved with fire watch duties.
Contrary to the above, as of January,- February 1991 twelve fire watches failed to implement procedure 14AC-OFPO4 when they performed fire watch duties prior to fully completing fire watch course NGF16 or completing annual retraining.
This is a Severity Level IV violation applicable to Units 1, 2, and 3 (Supplement I).
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ATTACHMENT1 REPLY TO NOTICE OF VIOLATIONS50-529,530/91-19-01 (A)
AND 50-528/91-1 9-01 (C)
NRC INSPECTION CONDUCTED MAY12, 1991 - JUNE 15, 1991 INSPECTION REPORT NOS. 50-528/91-1 9, 529/91-1 9 AND 530/91-1 9
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REPLY TO NOTICE OF VIOLATION50-529 530 9'I-'I9-01 (A)
1.
Reason for the Violation The reasons for the three examples constituting the violation are discussed below.
Example 1:
The principal reasons for this example were the failure to followprocedures step by step and inattention to detail in that the'esponsible individuals did not properly review the procedure to ensure that they were working on the correct equipment.
Example 2:
The principal reason for this example was inattention to detail in that the instrument and Control (I8 C) technicians were aware that they should have been doing testing on equipment in the train A cabinet but inadvertently went to the train B cabinet.
Example 3:
The principal reason for this example was inattention to detail in that the effluent technician was aware of the proper radiation monitor to be adjusted but inadvertently adjusted the setpoints on the radiation monitor immediately below the intended monitor.
2.
CORRECTlVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Each of the above individuals was counseled in accordance with the APS Pageos of2
Positive Discipline Program regarding attention to detail and/or following and performing procedures step by step.
The Vice President Nuclear Production issued a memorandum on July 23, 1991, to site management instructing them to communicate to all personnel the importance of attention to detail and the affects of complacency and poor work practices.
Commencing May 24, 1991, Unit 3 conducted a work stand down as t
directed by the Plant Manager to ensure that all personnel involved in the outage understood management's expectation to work safely, use procedures, and communicate any problems. Subsequently, shop briefings were held to stress the importance of utilizing self-verification techniques.
In addition, maintenance crew members were made aware of the need to be fully cognizant of job/task performance (i.e., double checking one another).
The Unit 2 event has been included as a subject within the third quarter industry events training which began July 1, 1991, for chemistry Radiation
- Monitoring System technicians.
CORRECTIVE STEPS THAT WILLBE TAKEN TO AVOIDVIOLATIONS APS management willcontinue to stress the importance of attention to detail in station activities through the normal interface processes such as the Management Observation Program, tailboard meetings, and plant manager meetings.
~ 4.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on May 16, 1991, when the B train relays we'e restored to their proper position, on May 24, 1991, when the 2B reactor coolant pump (RCP) filterwas replaced, and on June 5, 1991, when the setpoints for radiation monitor, RU-38, were restored.
Page 2 of 2
REPLY TO NOTICE OF VIOLATION50-528 91-'1 9-01 (C)
Reason for the Violation The reason for'the violation was that the individual(s) responsible for the assignment of firewatches did not have available, a formal list of firewatch personnel who had completed all training requirements.
Thus, these individual(s)
utilized their own historical knowledge or an informal qualification card to make such determinations and did not verify that the personnel assigned were fully qualified.
2.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As discussed in Reference 2, APS immediately verified that on-shift personnel performing compensatory firewatch duties in the units had satisfactorily completed training requirements.
On April 11, 1991, the Fire Department developed an interim list of firewatch personnel who had completed all training requirements.
This list was used for the assignment of compensatory firewatches for subsequent shifts.
As an additional measure, daily training reports were printed and reviewed prior to assigning firewatch duties.
Also as discussed in Reference 2, the initial investigation conducted by APS was restricted to determining if there was a valid training concern for compensatory firewatches.
Since the concern was confirmed, APS broadened the investigation to include hot work permit firewatches.
The investigation concluded that similar weaknesses existed with regard to hot work firewatch qualifications.
Thus, the followingcorrective actions are applicable to both compensatory and hot work fire watches A firewatch orientation guide was developed and distributed to firewatch Page 1 of 3
personnel on March 25, 1991, to provide additional guidance which includes:
1)
Summary of duties, 2)
Safety information, 3)
Firewatch run sheet instruction, 4)
Route familiarization maps, and 5)
Firewatch correspondence.
A firewatch training film was developed on March 5, 1991, to enhance the training of personnel performing firewatch duties.
A firewatch qualification card was developed on June 19, 1991, to facilitate identification of qualified firewatches.
Procedure 14AC-OFP04, "Firewatch Duties", was revised on July 18, 1991, to reflect changes in responsibilities and implementation of the firewatch program.
These changes include:
1)
Identifying specific responsibilities of the Fire Department relating to establishing minimum requirements for firewatch training, i.e., initial classroom training, "hands-on" practical evaluation on the use of fire extinguishers, and annual re-training using Computer Based Training (CBT) and practical evaluation.
2)
Provisions for the Fire Department, and other responsible managers, to ensure persons assigned to firewatch duties meet the qualification requirements established by providing information on obtaining records of personnel qualifications from Site Training Records.
3)
Specific information identifying the principal duties and responsibilities for roving and continuous firewatches.
4)
Specific actions to be taken by firewatches when reporting a fire and controlling a fire area until the Fire Department arrives.
5)
Instructions for ensuring fire extinguishers used during firewatch activities are functional and ready for use.
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3.
CORRECTIVE STEPS THATWILLBE TAKEN TO AVOIDVIOLATIONS The actions described in Section 2 are considered adequate to avoid further violations.
I 4.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on April 11, 1991, when personnel performing compensatory firewatch duties were verified to be fully qualified.
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