IR 05000528/1992014

Provides Results of Assessment of Compliance W/Procedural Requirements for Measuring & Test Equipment Usage,Per NRC Request in 920706 Transmittal of Insp Repts 50-528/92-14, 50-529/92-14 & 50-530/92-14 & Util 920807 Ltr

ML17306A950
Person / Time
Site:	Palo Verde
Issue date:	08/31/1992
From:	CONWAY W F ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02261-WFC-T, 102-2261-WFC-T, NUDOCS 9209100058
Download: ML17306A950 (8)

Text

Hl ACCELERATED DISTRISUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)DOCKET¹05000528 05000529 05000530 ACCESSION NBR: 9209100058 DOC.DATE: 92/08/31 NOTARIZED:

NO FACIL: STN-50-528 Palo Verde Nucleav Station.Unit i.Av i zona Publi e SThf-'50-529 Palo Vev de Nuc 1eav Station>Unit 2i Av'i zona Pub li STN-50-530 Palo Vev de Nuclear Stationi Unit 3>Av i zona Publi AUTH.NAME AUTHOR AFF IL I ATI QN CONMAYi N.F.Av i zona Public Service Co.(formerly Arizona Nucleav'oeer RECIP.NAME RECIPIENT AFFILIATION Document Control Bvanch (Document Contv ol Desk)SUBJECT: Provides v esults of assessment including planned corrective actions as committed to 920807 ltv.DISTRIBUTION CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: STANDARDIZED PLANT Standav'd i zed p lant.Standard i zed p lant.05000528 05000529 05000530 A REC IP IENT ID CODE/NAME PD5 PD THOMPSON~C COPIES LTTR ENCL 1 1 1 RECIPIENT ID CODE/NAME TRAMMELLED C CQP lES LTTR ENCL 1 1 INTERNAL: ACRS t AEOD/DEIB*EOD/TTC NRR MOR I SSEAUi D NRR/DLPG/LPEB10 NRR/DREP/PEPB9H NUDOCS-ABSTRACT OGC/HDS1 RGN5 FILE 01 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1 AEQD AEOD/DSP/TPAB DEDRO NRR/DLPG/LHFBPT NRR/DOEA/OE*B NRR/PMAS/I LRB 12 O~E CRAG-F-02 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 EXTERNAL: EGG(G/BRYCEz J.H.NSIC 1 1 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK.ROOM Pl-37 (EXT.504-2065)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: I TTR 25 ENCL 25 l g gi t WILLIAM F.CONWAY EXECVTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O.BOX 53999~PHOENIX, ARIZONA 850724999 102-02261-MFC/TRB/DLK August 31, 1992 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555 References:

1)NRC Inspection Report 50-528, 529, and 530/92-14, dated July 6, 1992 2)Letter 102-02230, dated August 7, 1992, from W.F.Conway, APS;to NRC,"Reply to Notice of Violation 50-528/92-14-03"

Dear Sirs:

Subject: Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Oocket Nos.STN 50/528/529/530 Assessment of Compliance with Procedural Requirements for Measuring and Test Equipment (M&TE)Usage File: 92-056-026 Arizona Public Service Company (APS)has completed the assessment of compliance with procedural requirements for M&TE usage, as requested in the letter that transmitted

-Reference 1.The enclosure to this letter provides the results of that assessment, including the planned corrective actions as committed to in Reference 2.If you should have any questions, please contact Thomas R.Bradish at (602)393-5421.

Sincerely, WFC/TRB/DLK/pmm Enclosure:

Assessment Results of Compliance with Procedural Requirements for Measuring and Test Equipment (M&TE)Usage I cc: J.B.Martin J.A, Sloan qppqfppp58 92083 PDR ADOCK 0500~&p0 ti l I I t ENCLOSURE 1 ASSESSMENT RESULTS OF COMPLIANCE WITH PROCEDURAL REQUIREMENTS FOR MEASURING AND TEST EQUIPMENT (M&TE)USAGE NRC INSPECTION CONDUCTED APRIL 27-JUNE 5, 1992 INSPECTION REPORT NOS.50-528, 529, AND 530/92-44

ASSESSMENT RESULTS OF COMPUANCE WITH PROCEDURAL t REQUIREMENTS FOR MEASURING AND TEST EQUIPMENT (M&TE)USAGE The surveillance procedures, used to calibrate safety-related instrumentation at PVNGS, define the range and accuracy requirements for MT&E needed to satisfactorily accomplish the procedure in the"Special Test Equipment" section.This section also frequently includes suggested M&TE that is generally readily available, meets the defined range and accuracy requirements, but is not required to satisfactorily accomplish the procedure.

The majority of I&C surveillance procedures, that require the use of a pressure gauge, do not specify the M&TE in the"Instruction" section of the procedure.

The test performer selects the proper M&TE using the guidance provided in the"Special Test Equipment'ection, and basic craft knowledge and skills obtained through training and work experience.

Basic craft knowledge and skills are not considered an alternative to following procedural requirements and should not have been used to substitute M&TE that was procedurally specified, as discussed in References 1 and 2.Finally, a review was performed on a selected sample of completed surveillance tests (approximately 20)in which the M&TE used was different than the suggested M&TE.In all cases, the M&TE used met the procedurally defined M&TE requirements.

Based on these facts, Arizona Public Service Company is confident that M&TE used at PVNGS is of the proper range and accuracy to optimally calibrate and maintain safety-related instrumentation in compliance with Technical Specifications.

Furthermore, qualified test performers at PVNGS possess the necessary skills to properly select M&TE using procedural.

guidance that defines the range and accuracy requirements.

However, to avoid further violations similar to 528/92-14-03 the following corrective actions will be taken: 1)The I&C surveillance procedures, that require the use of a pressure gauge, will be reviewed to verify the required M&TE is properly identified in the"Special Test Equipment" section.In order to provide consistency, where there is no technical justification to specify M&TE in the"Instruction" section, the surveillance procedures will be revised to allow the test performer to select the appropriate M&TE based on the guidance provided in the"Special Test Equipment" section.These revisions will be completed by July 31, 1993.2)The l&C Safety System Functional Inspection Report (92-14)and Condition Report/Disposition Request 920356 will be incorporated into the Training Change System for evaluation and inclusion in appropriate training by December 31, 1992.