IR 05000528/1993015
| ML20056C838 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/06/1993 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9307260005 | |
| Download: ML20056C838 (3) | |
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UNITED STATES
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'k NUCLEAR REGULATORY COMMISSION
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REGION V
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1450 MARIA LANE
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WALNUT CREEK, CALIFORNIA 94596-5368
JUL - 61993 Docket No. 50-528 50-529 50-530 Arizona Public Service Company P. O. Box 53999, Station 9082 Phoenix, Arizona 85072-3999 Attention:
Mr. W. F. Conway Executive Vice President, Nuclear Gentlemen:
i Thank you for your letter of June 8,1993, in response to our Notice of Violation (NOV) and Inspection Report Nos. 50-528/529/530/93-15, dated May 5, 1993, informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions to the first violation (50-529/93-15-01) will be verified during a future inspection.
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Your response denied the second violation (50-529/93-15-02). This violation identified that the Palo Verde Updated Safety Analysis Report (UFSAR),
Revision 5, dated March 1993 did not include a Unit 2 modification completed in 1991, in violation of the timeliness requirements of 10 CFR 50.71 for updating the UFSAR.
In your response you acknowledged that the UFSAR had not been updated. However, you noted that the same modification had been completed in Unit 3 in October 1992, and that the Foreword to the UFSAR stated that physical changes at Palo Verde are included in the UFSAR after the
changes are operable in all units.
Based on the'UFSAR Foreword and the fact
that the Unit 3 modification was not required by 10 CFR 50.71 to be included in Revision 5 of the UFSAR, you concluded that no violation existed.
Neither the exception to the 10 CFR 50.71 reporting requirements contained in the UFSAR Foreword nor the status of the Unit 3 modification were discussed with the inspector during the inspection. Based on your response, we have withdrawn the violation. However, we are concerned about the time between completion of design changes in the first unit and the UFSAR update subsequent to ccmpletion of the changes in the last unit. We will review this concern during a future inspection.
Your cooperation with us is appreciated.
Sincerely,
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L. F. Miller)Jr., Chief
9307260005 930706
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Reactor Safety Branch PDR-ADOCK 05000528 l
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cc:
Mr. Steve Olea, Arizona Corporation Commission James A. Beoletto, Esq., Southern California Edison Company Mr. Charles B. Brinkman, Manager, Washington Nuclear Operations -
Mr. Aubrey Godwin, Director, Arizona Radiation Regulatory Agency-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 Veide 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 Regulatory Affairs, APS
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bec w/ copy of letter dated June 8,1993 C. Trammell, NRR Docket File-Resident Inspector Project Inspector G. Cook R. Huey B. Faulkenberry
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IJ l 3 !3 !j:-l 3 Arizona Public Service Company PHOENIX AAl2ONA B5072-3999 P O BOX $3999
102-02531-WFC/TRB/DLK WILLIAM F CONWAY June 8,1993 txteinugtegesoria U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37
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Washington, DC 20555
Dear 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 Notice of Violations 50-529/93-15-01 and 50-529/93-15-02 FIIe: 93-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/93-15 and the Notice of Violations dated May 5,1993. Pursuant to the -
provisions of 10 CFR 2.201, APS' responses aro enclosed. Enclosure 1 to this letter is a restatement of the Notice of Violations. APS' responses are provided in Enclosure 2.
The due date for this response was extended from June 4,1993,- to June 9,1993, during a telephone conversation with Mr. L F. Miller on June 4,1993, in order to allow adequate time for senior management review.
Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely,
+kW LN&
WFC/TRB/DLK/rv Enclosures:
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Restatement of Notice of Violations 2.
Reply to Notice of Violations cc:
- B. H. Faulkenberry J. A. Sloan
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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATIONS 50-529/93-15-01
AND 50-529/93-15-02
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NRC INSPECTION CONDUCTED APRIL 5 THROUGH APRIL 9,1993 INSPECTION REPORT NOS. 50-528/529/530/93-15
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Restatement of Notice of Violations 50-529/93-15-01 and 50-529/93-15-02
During an NRC 'nspection conducted during the week of April 5 through April 9,1993, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are identified below:
A. Violation 50-529/93-15-01 PROCEDURAL COMPLIANCE Technical Specification 6.8.1 states in part that, ' Written procedures shall be established, implemented, and maintained covering... applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
February 1978...." Appendix A of Regulatory Guide 1.33 specifies procedures for procedure adherence in performing tests and inspections.
Palo Verde Nuclear Administrative and Technical Manual (NATM) Procedure l
01PR-0AP01, Revision 01.03, " Administrative Controls Program," Section 3.7.3 l
requires that, " Procedures shall be used, adhered to and enforced."
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Palo Verde NATM Procedure 81 AC-0DC01, Revision 04.03, " Procedure for Design Changes," Section 3.2.3.d states, " Design... output (e.g., drawings, databases) documents affected by the design modification and the required changes shall be prepared or identified as part of the design change package."
Contrary to the above, Design Change Package (DCP) 2XE-SG-163," Main Steam isolation Valve Control Console Power," did not identify that Key l
drawing 02-E-PKB-001, " Elementary Diagram 125V DC Class 1E Power i
System," was affected by the design modification and was required to be
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changed. DCP 2XE-SG-163 was completed in Unit 2 in December 1991.
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As of April 5,1993, Key drawing 02-E-PKB-001 ha' not been updated.
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Palo Verde NATM Procedure 81AC-0DC01, Section 3.2.6 states that,
" Documents, processes, trdning, etc.,
affected by the design modification...shall be identified, recorded, statused, and updated...."
Contrary to the above, as of April 5,1993, NATM Procedure 42AL-2RK1 A, l
" Panel B01 A Alarm Response," which was affected by DCP 2XE-SG-163, j
had not been identified, recorded, statused, or updated.
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Palo Verde Design Change Package (DCP) 2XE-SG-163 and implementing
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l Unit 2 Work Order 519134 [ sic) required that the retest for the DCP be performed in accordance with Generic Procedure 70GT-0ZZ01, Revision 1 Preliminary Change Notice 1, " Electrical Circuit Test."
Section 7.2 of 1'
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Procedure 70GT-0ZZ01 required that,"Only Operations / Systems Engineers or Maintenance PC [ Planning Coordinator] shall place N/A's in data sheets where steps are not applicable for required testing."
l Contrary to the above, during performance of 70GT-0ZZ01 for Work Order 519134 [ sic] in Unit 2, the performing mechanic placed an N/A beside a number of procedure testing steps, including verification of proper wiring, with no evidence of System Engineer / Maintenance PC concurrence. The steps that were "NA'd" or " marked N/A" were not performed.
The completed data was inadequate to demonstrate that one of two new 125 volt direct current power sources had been tested to ensure that it would properly supply power to the main steam isolation valves.
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This is a Severity Level IV violation (Supplement 1), applicable to Unit 2.
B. Violation 50-529/93-15-02 UPDATED FINAL SAFETY ANALYSIS REPORT CHANGES 10 CFR Part 50.71, Records and Reports, states in Section e(4) that," Subsequent
[ Updated Final Safety Analysis Report (UFSAR)] revisions must be filed annually or 6 months after each refueling outage.... The revisions must reflect all changes up to a maximum of 6 months prior to the date of filing."
Palo Verde NATM Procedure 81 AC-0DC01, Section 3.1.7 states, " Licensing document changes shall be prepared during development of the appropriate design change packages...and processed in accordance with the requirements of the associated licensing document change implementing procedure (e.g.,
UFSAR...)."
l Contrary to the above, as of April 5,1993, the UFSAR, Revision 5, dated March
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1993, did not include changes to Unit 2 required by DCP 2XE-SG-163, which was completed in Unit 2 in December 1991, during the Unit 2 R3 outage. The Unit 2 R3 outage was completed in January 1992.
This is a Severity Level IV vio!ation (Supplement 1), applicable to Unit 2.
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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATIONS 50-529/93-15-01 AND 50-529/93-15-02 NRC INSPECTION CONDUCTED APRIL-5 THROUGH APRIL 9,1993 INSPECTION REPORT NOS. 50-528/529/530/93-15 Y
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Reniv to Notice of Violation (A) 50-529/93-15-01 Reason for the Violation Notice of Violation (NOV) 50-529/93-15-01 cites three examples where APS failed to fo!Iow procedures during the development and implementation of Design Change Package
(DCP) 2XE-SG-163. The reason for the Violation in all three examples was lack of
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attention to detail on the part of D' sign Engineering, Work Control Planning, and Plant Engineering. An additional reason, for the third example, was personal error on the part of the maintenance technician who, contrary to section 7.2 of 70GT-0ZZO1, " Electric Circuit Test," marked several steps "N/A", while performing Work Order (WO) 519034.
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During the development of DCP 13XE-SG-163, (of which 2XE-SG-163 is the portion applicable to Unit 2), Design Engineering overlooked the need to revise or reference key drawings 1,2,3-E-PKB-001. At the time DCP 13XE-SG-163 was developed, a manual process was used to identify affected drawings. The manual process was cumbersome
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and not always effective in identifying all affected drawings. The key drawing information
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was essential for Operations Standards to identify the operating procedures needing revision. Because drawings 1,2,3-E-PKB-001 were not referenced in the DCP, Operations Standards did not recognize the need to revise the alarm procedure 4(X)AL-(X)RK1A during the DCP impact review.
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During implementation of DCP 2XE-SG-163, Work Control Planning overlooked the need l
to include a voltage polarity test, in addition to 70GT-0ZZ01, as a retest requirement in WO 519034. When the maintenance technician performed 70GT-0ZZO1, as pad of WO
519034, he placed an N/A" next to several steps which, according to the drawings provided in the DCP, were not required to be performed. The absence of a voltage
polarity test and the unauthorized changes made to 70GT-0ZZ01 were overlooked by
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Plant Engineering, during the * inservice Verification" performed upon completion of 2XE-SG-163.
Corrective Actions Taken and Results Achieved
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Condition Report Disposition Request (CRDR) 930277 was written to investigate the three problems identified in NOV 50-529/93-15-01, and to review the adequacy of post-
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modification testing performed for DCPs 1,2,3XE-SG-163.
Post-modification testing
performed in Unit 3 was satisfactory; however, the post-modification testing in Units 1 and 2 was not adequate. A clearance has been hung in Unit 1 which prevents switching Main Steam isolation Valve Control Console Power to the afternate power source until the complete post-modification tests for 1XE-SG-163 can be reperformed (currently scheduled for refueling outage f R4). Unit 2, presently in a refueling outage, will cornplete
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post-modification testing for 2XE-SG-163 prior to restad.
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Other corrective actions completed under CRDR 930277 include the following:
I 4(X)AL-(X)RK1 A," Panel B01 A Alarm Responses,"was revised to include the e
responses for the new alarms added by DCPs 1,2,3XE-SG-163.
- Key uawings 1,2,3-E-PKB-001 have been revised to include the alarm contacts added by DCPs 1,2,3XE-SG-163.
The maintenance technician, who placed an "NA" next to several steps during the
performance of 70GT-0ZZO1 for WO 519034, was counseled, by his direct supervisor, for failing to follow procedure.
In conjunction with the corrective actions taken for the NOV, Engineering is reviewing
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design changes, completed on critical systems and components during the past two years, to verify adequate testing was performed. The review is expected to be completed by June 30,1993.
Finally, two recent changes have occured at PVNGS that should prevent this from recurring. First, an Area Field Engineer (AFE) Program was implemented in 1992, which provides dedicated engineering oversight during DCP implementation. The AFE program
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was effective in identifying and correcting the post-modification testing deficiencies during the implementation of 3XE-SG-163. Second, the Station Information Management System
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(SIMS) was enhanced in 1992, integrating the Drawing Document Registry with the Equipment Document Reference screen..This computerized cross reference readily identifies applicable drawings associated with a specific equipment tag number, thereby reducing the possibility of overlooking a drawing that may be affected by.a DCP.
Corrective Actions That Will Be Taken To Avoid Further Violations
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The actions discussed above are adequate to avoid further violations.
Date When Full Compliance Will Be Achieved
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Full compliance was achieved on June 2,1993, when key drawings 1,2,3-E-PKB-001 were i
revised to include the alarm contacts added by DCPs 1,2,3XE-SG-163.
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Repiv To Notice Of Violation (B) 50-529/93-15-02 Reason for the Violation APS denies the Violation.
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The PVNGS Updated Final Safety Analysis Report (UFSAR) states in the Foreword:
" Descriptions of physical che;iges to PVNGS are included in the UFSAR after the changes have been approved for use and are operable in all units, unless the changes are unique to a speclile unit (or units). For unit-specific changes, the-
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change is identified in the UFSAR upon completion in the affected ' unit (or units)."
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DCPs 1,2,3XE-SG-163 were implemented in all three units. Unit 3 was the last unit to'
complete the DCP. The " Inservice Verification" for 3XE-SG-163, was signed October
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31,1992, which was within six months of the filing date for Revision 5 to the PVNGS UFSAR (March 12,1993). APS was in compliance with 10 CFR Part 50.71.
Corrective Actions Taken And Results Achieved
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Since APS was in compliance with 10 CFR 50.71, no corrective action was required. The i
Ucensing Document Change Request (LDCR) associated with 1,2,3XE-SG-163 has been Page 5 of 6
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submitted to the Nuclear Regulatory Affairs Department for inclusion into Revision 6 of the UFSAR. CRDR 930336 was initiated as a result of the identified concern discussed at the
NRC exit meeting on April 9,1993.
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The investigation, conducted under CRDR 930336, has recommended additional controls over the UFSAR change initiation process to provide added assurance that descriptions of physical changes to PVNGS are incorporated into the annual UFSAR update, in accordance with 10 CFR 50.71. These recommendations are currently being evaluated.
Corrective Actions That Will Be Taken To Avoid Further Violations i
None required.
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Date When Full Compliance Will Be Achieved i
Full compliance was achieved at all times.
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