IR 05000528/1997019
| ML17312B676 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/17/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| 50-528-97-19, 50-529-97-19, 50-530-97-19, NUDOCS 9709230043 | |
| Download: ML17312B676 (32) | |
Text
CATEGORY 2 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
- ACCESSION NBR
- 9709230043 DOC.DATE: 97/09/17 NOTARIZED:
NO DOCKET IL:STN-50-528 Palo Verde Nuclear, Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION HOWELL,A.T.
Region 4 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION LEVINE J.M.
Arizona Public Service Co.
(formerly Arizona Nuclear Power SUBJECT:
Ack receipt of 970820 ltr informing NRC of steps taken to correct violations noted in insp repts 50-528/97-19, 50-529/97-19 a 50-530/97-19 on 970721.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR L ENCL t
SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
05000528 05000529 05000530 RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS HHFB NRR/DRPM/PERB OE DIR RGN4 FILE
EXTERNAL: LITCO BRYCEPJ H
NRC PDR COPIES LTTR ENCL
1
2
1
1
1
1
1
1
1
1 RECIPIENT
" ID CODE/NAME THOMASPK AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRPM/PECB NUDOCS-ABSTRACT OGC/HDS2 NOAC NUDOCS FULLTEXT COPIES LTTR ENCL
1
1
1
1
1
1
1
1
1 D
o t
C NOTE TO ALL "RIDS" RECIPIENTS:
LEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME'OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS R REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES
SUBJECT:
'RC INSPECTION REPORT 50-528;-529;-530/97-19
Dear Mr. Levine:
Thank you for your letter of August 20,.1997, in response to our letter and Notice of Violation dated July 21, 1997.
We. have reviewed your reply and find it responsive to the concerns raised in our'Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been
~
achieved and will be maintained.
Sincerely, Art ur T. Howell III, Director Division of Reactor Safety Docket Nos.:
50-528; 50-529; 50-530 License Nos.:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law'epartment, Generation Resources P.O. Box 800 Rosemead, California 91770 9709230043 9709i7 PDR ADOCK 05000528 PDR llllllllllllllllllllllllllllllllllllllll
Arizona Public Service Company Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O. Box 52034 Phoenix, Arizona 85072-2034 John C. Horne, Vice President Power Supply El Paso Electric Company 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Terry Bassham, Esq.
General Counsel
~
El Paso Electric Company 123 W. Mills El Paso, Texas 79901 Mr. Robert Burt Los Angeles Department of Water 5 Power Southern California Public Power Authority 111 North Hope Street, Room 'l255-B Los Angeles, California 90051 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, ¹0604 Albuquerque, New Mexico 87102 Mr. Brian Katz Southern California Edison Company...
14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672
Arizona Public Service Company Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251
Arizona Public Service Company-4-E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bcc to DCD (IE01)
bcc distrib..by RIV:
Regional Administrator DRP Director Branch Chief (DRP/F, WCFO)
Senior Project Inspector (DRP/F, WCFO)
Branch Chief (DRP/TSS)
WCFO File Resident Inspector DRS-PSB MIS System RIV File
'. Hammond (PAO, WCFO)
DRS AI 97-G-0081 h.
'V DOCUMENT NAME: R:$ PV>PV719ak.ANG qI,
To receive copy of document, Indicate in box: "C" ~ Copy without 8osures
"E" = Copy with enctosures
"N" = No copy SRI:EB AC'EB D:DRP D:DR ATH III 09/ /97 OF ICIALRECOR COPY WAng/Imb g TFStetka.
TPG 09k /97 e~
09/It/97 t
09/i,
Arizona Public Service Company-4-E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bcc to DCD (IE01)
bcc distrib. by RIV:
Regional Administrator DRP Director Branch Chief (DRP/F, WCFO)
Senior Project Inspector (DRP/F, WCFO)
Branch Chief (DRP/TSS)
WCFO File Resident Inspector DRS-PSB MIS System RIV File M. Hammond (PAO, WCFO)
DRS AI 97-G-0081 DOCUMENT NAIVIE: R:3 PV<PV719ak.ANG To receive copy of document, indicate in box: "C" = Copy without 4osures
"E" = Copy with enciosures "N""-No copy SRI:EB AC:EB D:DRP D:DR WAng/Imb.g TFStetka
'
TPG ATH 094 /97 e,~
09/it/97 t
> 09/i
.
'9/ /97 OF ICIAL RECOR COPY
ski I MD V I
$ IVll l I
~ rO UhO tNlL lCUVII
~nunc kecnadoa~
l'Hli HU.
HbU82]2 P. 04
?ao Vo ae Nr;clear Qrrnt.'e6~r7 srnric."
James M. Livinc
$ C ter V>ca?reSRBn:
i'r&i<sr
= I '512'JM.SKO FAX(602)&3 6C77 ir ",.lion 7602 P.O. Scx 62";&
? -.Oe,".x AZ6~72-2334 U. S. Nuclear Regulatory Commission ATVN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001 102-03996 -JML/AKK/RAS August 20, 1997 l
Dear Sirs:
Sui7jact; Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50428/529/530 Reply to Notices ofViofation 60-628;N29;430/9719-04, and 50%28;%29;-530/975646 Arizona Pubilc Servfce Company (APS)
has reviewed NRC inspection Report 50-528/529/530/97-19 and the Notices of Vfofation (NOV) dated July 21, 1997.
Pursuant to the provisions of 10 CFR 2201, APS'esponse is enclosed.
Enclosure 1 to this letter is a restatement of the NOVs.
Encfoswe 2 contains APS'esponse to the violations.
Should you have any further questions, please contact Angela K. Krainikat (602) 393-5421.
Sincerely
.
JML/AKK/RAS/mah Fnclosures 1, Restatement of Notice ofViolation 2. Reply to Notice ofViolation 1.i-r ZO 'd 9980 9L6 Ot5
'QH XV3 Q30ti hl NQIO3H 8G'Of AHL LB-1l-d3S
P. 05 U.'S. Nuclear Regulatory Comrr.ission ATTN: Document Control Desk Reply to Notices of Violation 50-528;-529;430/971944 and 50428;-529;-530/971946 Page 2 co: a:w..~-:.
K. E.'erkrns D. F. Kirsch K. M. Thomas PVMGS Sr. Resident 80 'd 9980 SL6 015
'OH XV3 030t1 hl HOIO3H 88'01 AHL L6-11-d3S
I
P. 06 ENCLOSURE 1 RESTATEMENT OF NOTICES OF VIOLATION 50-528; - 629; - 530/971 9-04 and 60-528'
529 - 530/S71946
NRC iNSPECTION CONDUt TED MAY19, THROUGH JUNE 19, 1997 INSPECT)ON REPORT NO. 60-528/629/530/97-49 10 'd SSEO 5LB 015
'OH %3 0308 hl H0103H BB'.01 AHL LB-11-d3S
i'. Ur RESTATE ENTOF NOTI ES OF VlO ION During an NRC tnspection conducted on May 19 through June 19, 1997, two violations of NRC requirements were identified. tn accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed betow:
A.
10 CFR Part 50, Appendix 8, Criterion XN, "Corrective Action," requires that measures shall be established to assure that conditions adverse to quality, such es failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and co'rrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to prectude repetition.
Contrary to the above, as of on fsic) June 19, 1997, the licensee had failed to take corrective actions to identify tt e extent and scope of a procedural deficiency that led.to a water hammer event in the Unit 3 containment spray system, The licensee determined that the cause of the event was a confusing
"if/then" procedurat step, which was misinterpreted by the operators.
However, the licensee fattecf to determine whether additional
"if/then" statements contained tn other plant procedures could cause simitar events.
Following NRC identification, the licensee's review identified several other examples of confusing "if/then" statements, Including an additional example in the procedure in question.
This IS a Severity Level Vviolation (Supplement 3)(50428;N29;-530/971841'),
B.
10 CFR 50.73(a)(2)(vii) states, In part, that the licensee shall report any event where two independent trains or channels become inoperable ln a single system designed to mitigate the consequences of an accident.
Contrary to the above, on February 15, 1997, an event involving a single condition that caused two independent trains to become inoperable was not reported.
This event involved surveillance tests of the main steam safety valves that resulted in 6 out of 20 of these valves failing their as-found setpolnt tests with setpoints greater than their technical specwcation setpoint tolerance of +3 percent.
This is a Severity Level IVviolation (Supplement 1)(50426;-529;-530/971&2').
'er WilliamAng (Sr. Reactor Inspector, Engineering Branch), the actual numbers forthese violations are 97ts-04 and 87ts-06, as @entitled in the body of the inspeciion Report.
'I
&
90 'd SBBO 9L6 015
'ON $3 0300 hl NOIMtI 68'01 flHL L6-11-d3S
vt I vV 0 I IIV1'I 1 I
~ VV I/50 lll1lL nfl I N HU.
8608212 P. 08 ENCLOSURE 2 REPLY TO NOTlCES OP Y/OLATION 50-628;-629;-630/9?19<<04 and 50-628;-529;-630/971 9-06 NRC INSPECT}ON CONDUCTED MAY'll, THROUGH JUNE 19, 1997 tNSPECTfON REPORT NO. 50-528/629I530/97-1 9 90 'd SEBO 9L6 019
'ON $3 030ti hl NOIO3H 68'Ot flHl L6-tt-d3S
I
REPLY TO NOTICE OF VIOLATION"4" 50-528 -529'-530/9719-04 r. uv Reason Fo The Violation From July 21, 1995 through July 26, 1995 the Unit 2 "A"train Containment Spray (CS)
system experienced water hammer events during surveillance testing. Investigation of these events revealed that air was entrapped or. the discharge side of the pump.
As a corrective action, changes were implemented in procecure 40OP-9SI02 "Recovery from Shutdown Cooling to Normal Operating Lineup," to provide additional guidance on wh!ch CS vaives were to be vented and when the venting was to occur.
On April25, 1997 during routine surveillance testing of the Unit 3 Train A Containment Spray (CS) pump, operators heard a loud noise when the pump was started.
Based on a comparison of Emergency Response Facility Data Acquisition and Display System (ERFDAOS) equipment performance data between the Unit 2 and Unit 3 events, the
~
system engineer recommended venting the system.
Operations personnel subsequently vented. the CS header and engineering personnel performed
~ system walkdown and determined that the event did not damage plant equipment.
During the 'investigation of the April 25, 1997 event, It was determined that the procedural changes implemented as part of the corrective actions for the Unit 2 event, could be misinterpreted and result in the CS header not being vented.
Specifically, the procedure changes required the venting of the CS system, if the Safety Injection {Sl)
system was being "restored from an outage/maintenance condition."
Since the CS venting procedure could be performed after surveillance testing had been completed on LO 'd 9580 SL6 OIS
'ON $3 030/1 hl NOIGBH ol:ol AHL L6-ll-d3S
t I
~ oui lxv OVVOCIC the Sl system (not an outagelmaintenance,condition),
it was concluded by operations personnel that the CS piping had previously been restored and venting of the CS header was not required.
Afterreviewing these two events, APS concurs vtith the NRC finding that the corrective actions implemented as a result of the Uriit 2 water hammer event were ineffective in preventing recurrence of a similar event However, APS'nvestigation revealed that the use of conditional type "if/then"statements was not the root cause of this event.
These types of "logic" and "action" steps are routinely implemented in station Operating, Abnormal and Emergency Procedures and comprehensive training has been conducted to ensure personnel are familiarwith the use af these statements.
More correctly, it vras the conditional part of the procedural step (is the system being restored from an outage/maintenance condition) that caused operators to misinterpret the need to vent the GS header.
Co ective Ste s That Have Been Taken d Results Ac ieved
'I Unit 1, 2, and 3 procedures for Containment Spray Valve Verification have been revised to require the venting of the CS system on a monthly basis. This action was completed on June 27, 1897.
2 ofB 80 '(I 95EO 9L6 015
'OH NV3 030f1 hl HOIO3H 05'Oi AHL ).6-ii-d38
~
us
~ awe VVVVC,I C The conditional "if/then" statement was removed from <OOP-9Sf02 and now requires venting of the CS system anytime there is a recovery from shutdown cooffng, This action was completed on June 4, 199?.
Corrective Ste s That WillSe Taken To Avoid Further Violations Applicable procedures are being reviewed to identify instances where simffar conditional statements are being used.
Procedural changes will be initiated where similar conditional statements could be misinterpreted.
This action will be compfeted by October 17, 1997.
Licensed and non-licensed Operations staff will be briefed on the importance of adequately ventfng systems following maintenance.
This action will be completed by November 30, 199?,
Date When Full Com liance VNfl e Achieved The required procedural changes wil}be implemented by April18,
$ 998.
3of6 60 'J SEBO 9L6 019
'OH WR 030ti hl HOI03tl 00'Ol flHL LG-11-d3S
l l
e
~ pcs
<au>
uVVOC!C REPLY TO NOTlCE OF VfOLATION"8"80-82S %29'-530197%SAG Reasa For e Violation Prior to the Unit 3 sixth refueling outage, the Main Steam Safety Valves (MSSY) were tested using the Trevitest methodology to determine the as-found sefpoints.
On February 11, 1997 Condition Report Disposition Request (CRDR) 3700M was written to document an out of tolerance setpoint for MSSV 3J-SGE-UV@91.
The CROR was reviewed by the GRDR Review Committee {CRC) on February 12, 1997 and Was cfassfffed as a "potentially" significant condition requiring a determination if the condition represented a Maintenance Rufe functional failure.
On February 18, 1997 GRDR 370056 was written to document that six of the MSSYs (including 3J-SGE-UV-691) astound setpoints were outside the tolerance allowed by Technfcal Specification (TS) 3.7.1.
This CRDR was reviewed by the CRC on February 25, 1997 and was classified as a "potentially" sfgnfflcant condition requiring a safety analysis evaluation be performed in order to determine ifthe condition would have placed Unit 3 outside of the safety analysis.
The safety anafysfs would also be used for determining the final CRDR classNcation.
No review for reportability was requested by the CRC, however, the Compliance department was aware of the as-found MSSV setpoint condition.
The Maintenance Rule Determination evaluation for CRDR 370050 was completed on February 26, 1997 and concluded that no Maintenance Rule Functional Failure had occurred.
The safety analysis eva)uatlon for CRDR 370056 was completed on April 2, 1997 and revealed that the MSSY setpoint condition would not have resulted in-A 4ofB Ql 'd 9980 5L6 015
'OH XV3 030M hf N0103H IP:Qt AHI lR-lf-4~~
f I
I
r. <a exceeding the primary or secondary peak pressure criteria.
Both evaluations were reviewed by the CRC and the CRDRs were subsequently classified as "adverse" and root cause of failure and reportabiiity evaluations were not required.
During the Engineering Team inspection conducted during May and June of 1997, an NRC inspector questioned why the MSSVs setpoint condition had not been reported pursuant to 10CFR50.73.
Compliance personnel subsequently performed a
reportability evaluation and determined that the condition was reportable and discovered that there were actually seven MSSVs with as-found setpoints which exceeded the TS limit On Juiy 7, 1997 LER 50-530/9740340
"Seven Main Steam Safety Valves Found Out ofTolerance Prior To Refueling Outage" was submitted to the NRC.
ln evaluating this condition, APS has determined that the CRC relied on the safety analysis evaluation when determining if the condition was reportable, and did not understand that other reportability requirements could be applicable.
APS also determined that Complfance personnel had an inadequate understanding of NUREG 1022, and erroneously concluded that an equipment root cause of failure analysis was required before determining reportability of the MSSV condition.
Based upon a reviev/
of NRC findings and plant corrective action documents, there is no evidence to suggest this is a programmatic problem.
5of6 ll 'd SBSO SL6 Ol5
'ON 03 OZONE AI NOIO3H lt"Ol AHL L6-11-d38
~ Illl llvi OOUOCld Corrective Ste s That Have Been Taken and Results Achieved On July 31, 4997 Compliance personnel were briefed on this event and were informed of APS'osition on reporting multiple safety valve (Main Steam and Pressurirer)
failures.
On August 19, 1997 the Comp!!ance department issued a letter to the CRC requesting that a reportability review'e required far any instance where a MSSV or Pressurizer Relief Valve fails to meet the Technical SpecNcation tolerances, Co act e Ste s That VWliBe Take To Avoid Further ol ons No additional corrective actions willbe taken.
Dat en FQl Cpm liance W'llBe Achieved Full compliaree was achieved on July 7, 1997 when APS submitted LER 50-53QI9?40340.
Zl 'd 9980 5l.6 019
'OH 03 OQQN AI H01QBH it 'Ot AHl L6-11-d3S