IR 05000528/1998003
| ML17313A485 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/01/1998 |
| From: | Harrell P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| 50-528-98-03, 50-528-98-3, 50-529-98-03, 50-529-98-3, 50-530-98-03, 50-530-98-3, NUDOCS 9807100139 | |
| Download: ML17313A485 (30) | |
Text
Pg N
n CA.TEGORY
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESS1ON NBR:9807100139 DOC.DATE: 98/07/01 NOTARIZED: NO DOCKET FACIL,: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 HARRELL,P.H.
Region 4 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION LEVINE,J.M.
Arizona Public Service Co.
(formerly Arizona Nuclear Po~er C
SUBJECT:
Ack receipt of 980625 ltr informing NRC of steps taken to correct violations noted in insp repts 50-528/98-03, 50-529/98-03 6 50-530/98-03 on 980522.
DISTRIBUTION CODE'.
IEOID COPIES RECEIVED:LTR J ENCLj SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS A QD.
FI E CENTER NR PECB NUDOCS-ABSTRACT OGC/HDS2 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL
1
2
1
1
1
1
1
1
1 RECIPIENT ID CODE/NAME FIELDS,M AEOD/SPD/RAB DEDRO
, NRR/DRCH/HOHB NRR/DRPM/PERB OE DIR RGN4 FILE
NOAC NUDOCS FULLTEXT COPIES LTTR ENCL
1
1
1
1
1
1
1
1
1 05000528 G
05000529G 05000530 R
NOTE TO ALL "RIDS" RECIPIENT P >SE
<E P US O R-
. UC VeAS
"
'ITA'2 OUR NAME OR ORGAN ZA ION REMOVED FROM DISTRIBUTION LIS DESK iDCD'N EX'ENSICN 4 S-ZCS3 e
TOTAL NUMBER OF COPIES
SUBJECT:
NRC INSPECTION REPORT 50-528/98-03; 50-529/98-03; 50-530/98-03
Dear Mr. Levine:
Thank you for your letter of June 25, 1998, in response to our May 22, 1998, letter and Notice of Violation concerning the failure to obtain appropriate authorization prior to initiation of work on the emergency diesel generator, and the failure to provide appropriate procedural criteria for determining the minimum level in the transfer canal for movement of spent fuel. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.
We willreview the implementation of your corrective actions during a future inspection to C
determine that full compliance has been achieved and will be maintained.
Si er Ph'. Harrell Chief I
oje t Branch D Divisi of Reactor Projects Docket Nos.:
50-528 50-529 50-530 License Nos.: NPF-41 NPF-51 NPF-74 9807i00i39 98070i PDR ADOCK 05000528
l e
I (
Arizona Public Service Company CC:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, California 91770 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 & Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051
Il
Arizona Public Service Company Mr. David Summers Public Service Company of New Mexico 414 Silver SW, ¹1206 Albuquerque, New Mexico 87102 Mr. Brian Katz Southern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251
I<
ll
Arizona Public Service Company bcc to DCD (IE01)
bcc distrib. by RIV:
Regional Administrator DRP Director Branch Chief (DRP/D)
Senior Project Inspector (DRP/D)
Branch Chief (DRP/TSS)
Resident Inspector DRS-PSB MIS System RIV File DOCUMENT NAME: R: t PNPV803AK.JHM To receive copy ot document, indicate in box: "C" = Copy wit t enclosures
"E" = Copy with enclosures "N"= No copy E:DRP/D GAPick phase C:DRP PHH r II 07/ /98 OFFICIAL RECORD COPY
t t4
I
co mnmern. rnnonrrrrr.~
Pato Verde Nuctear Generating Station James Senior Vice President Nuclear TEL (602)393-5300 FAX (602)393-6077'ailStation 7602 P.O. Box 52034 Phoenix, AZ 65072-2034 102-04140-JML/AKK/DLK June 25, 1998
~ U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units1,2and
Docket Nos. STN 50-528/529/530 Reply to Notices of Violation 50-528/98-03-03 and 50-528/98-03-04 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/98-03 and the Notices of Violation (NOVs) dated May 22, 1998.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
Enclosure
to this letter is a restatement of the NOVs. APS'esponse is provided'in Enclosure 2.
During a telephone conversation on June 19, 1998, between.K. E. Brockman, NRC, and A. K. Krainik, APS, an extension of the due date for this response from June 21, 1998 to June 26, 1998, was granted.
This reply includes commitments to develop "Conduct of Engineering" guidance and revise the "Spent Fuel Handling Machine" procedure.
Should you have any further questions, please contact Ms. Angela K. Krainik at (602)
393-5421.
Sincerely, JML/AKK/DLK/mah Enclosure
Enclosure 2 Restatement of Notices of Violation Reply to Notices of Violation p, S~c cc:
E. W. Merschoff K. E. Perkins M. B. Fields J. H. Moorman
ENCLOSURE 1 RESTATEMENT Of NOTICES OF VIOLATION 50-528/98-03-03 and 50-528/98-03-04 NRC INSPECTION CONDUCTED MARCH 8 THROUGH APRIL 18, 1998 INSP ECTION REPORT NO. 50-528/529/530/98-03
RESTATEMENT OF NOTICES OF VIOLATION60-628/98-03-03 "A"and 50-528/98-03-04 "B" During a NRC inspection conducted on March 8 through April 18, 1998, violations of P
RC requirements were identified.
In accordance with the "General Statem t f aemen o
listed below.
olicy and Procedure for NRC Enforcement Actions" NUREG-1600 the vi I t'
vio a ions are A..
Technical Specification 6.8.1 requires, in part, that written procedures shall be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Section 9 requires that the licensee have procedures for maintenance that can affect the performance of safety-related equipment.
Procedure 31ST-9DG01, "Diesel Engine Surveillance Inspection," Revision 16, stated in part, in Prerequisite Step 7.11 that permission is required from the shift supervisor/assistant shift supervisor prior to start of the procedure.
Contrary to the above, on March 31, 1998, licensee engineering personnel failed to implement a procedure, issued to perform maintenance on safety-related.
equipment, in that work on the emergency diesel generator was initiated without first obtaining permission from the shift supervisor/assistant shift supervisor.
This is a Severity Level IVviolation (Supplement 1) 50-528/98-03-03.
B.
Technical Specification 6.8.1 requires, in pari, that written procedures shall be maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Section 2 requires that the licensee have procedures for refueling equipment.
Procedure 78OP-QFX03, "Spent Fuel Handling Machine," Revision 8, Prerequisite Step 4.2.1 required personnel to check the level in the cask loading pit and fuel transfer canal prior to moving spent fuel.
Contrary to the above, on March 26, 1998, the licensee failed to maintain lic Procedure 78OP-9FX03 in that the procedure did not provide specific criteria f ri ria or icensee personnel to determine the minimum water level required in the transfer canal for movement of spent fuel..
This is a Severity Level IVviolation (Supplement 1) 50-528/98-03-04.
il I
I
ENCLOSURE 2 REPLY TO NOTICES OF VIOLATION 50-528/98-03-03 and 50-528/98-03-04 NRC INSPECTION CONDUCTED MARCH 8 THROUGH APRIL 18, 1998 INSPECTION REPORT NO. 50-528/529/530/98-03
REPLY TO NOTICE OF VIOLATION"A" Reason For the Violation On March 31, 1998, during the performance of work on emergency diesel generator 1MDGAH01, engineering personnel prematurely initiated an inspection of the cylinder liners through the injector ports on the head of the diesel.
The Emergency Diesel Generator Team planned to work two work orders that day one removed the injectors, the other contained the instructions to inspect the cylinder liners. The work order that removed the injectors was properly authorized and performed.
The work order containing the instructions to inspect the cylinder liners did not have the appropriate prerequisite steps signed prior to beginning the inspection.
The team leader was in the process of performing the final walkdown prior to obtaining written authorization to commence work when engineering personnel prematurely initiated the cylinder inspection.
Contrary to the procedure "Conduct of Maintenance," the responsible engineers did not ensure the applicable work order was at the job site nor did they verify that the prerequisites were completed prior to starting work. The procedural violation was administrative in nature and was of low safety significance.
The reason for the violation was personnel error on the part of the responsible engineers for failing to follow the "Conduct of Maintenance" procedure.
A contributing reason for the violation was the failure of the Emergency Diesel
!
l
Generator Team Leader to adequately instruct the engineers not to proceed with the cylinder inspection until the prerequisite steps of the applicable work order were signed and the work order returned to the job site.
Corrective Steps That Have Been Taken and Results Achieved The cylinder inspection was stopped until the work order prerequisites were completed.
Maintenance and engineering personnel, including the Emergency Diesel Generator Team Leader, were briefed on following the "Conduct of Maintenance" procedure prior to resuming the cylinder inspections.
Corrective Ste s That Will Be Taken To Avoid Further Violations Engineering willdevelop "Conduct of Engineering" guidance that willinclude engineering responsibilities relative to performing inspections, testing and support of maintenance activities in the field. The "Conduct of Engineering" guidance willbe presented to appropriate engineering personnel prior to September 12, 1998.
Date when Full Com liance Will Be Achieved Compliance was achieved on March 31, 1998, when engineering personnel removed the boroscope probe from the EDG cylinder and stopped work.
t I
REPLY TO NOTICE OF VIOLATION"B" Reason For the Violation On March 25, 1998, during the performance of fuel inspection activities, Refueling and Mechanical Services (RAMS) personnel lifted an irradiated fuel assembly and were in the process of moving it to its assigned storage location when a radiation monitoring alarm triggered.
The irradiated fuel assembly was immediately lowered into its assigned storage location and radiation levels returned to normal. The time elapsed for the duration of the alarm was 20 to 30 seconds.
Personnel in the area received no additional'measurable dose as a result of the event.
Water level in the fuel transfer canal at the time of the event was approximately 7 feet lower than water level in the spent fuel pool. The "Spent Fuel Handling Machine" procedure provided guidance relative to lower water levels in the fuel transfer canal, but did not include the specific criteria to be used in determining the minimum water level in the transfer canal for movement of spent fuel. Based on past experience, the RAMS Team Leader determined that the water level in the transfer canal was adequate to safely perform the fuel inspections and move the irradiated fuel assemblies to their assigned storage locations.
The Team Leader discussed the fuel transfer canal water level condition with the Shift Manager at the pre-job briefing and made the recommendation to proceed without raising water level in the fuel transfer canal.
The Team Leader's recommendation was
I
acceptable to the Shift Manager who also preferred to proceed without raising water level. At the time, the refueling pool level was being maintained below 114 feet to support unrelated work on the reactor coolant pumps.
The lower water level in transfer canal would minimize the pressure differential across the fuel transfer valve and reduce the possibility of water leakage into the refueling pool. The Shift Manager granted permission to proceed.
As the assigned spent fuel assembly approached the transfer canal gate, the lower water level on the opposite side of the gate did not provide sufficient shielding to prevent the radiation monitor from alarming. The controlling procedure did not contain enough guidance to ensure that water level in the transfer canal provided the shielding necessary to prevent radiation monitors from alarming while moving spent fuel.
The reason for the violation was the prerequisite section of the "Spent Fuel Handling Machine" procedure did not provide adequate precautions or additional actions to be taken if level within the transfer canal was "not full"when moving fuel near the spent fuel pool transfer canal gate.
Additionally, no guidance was provided regarding factors that must be considered when evaluating adequate water level for planned evolutions.
Corrective Ste s That Have Been Taken and Results Achieved As an interim corrective step, no irradiated fuel was moved in the vicinityof the transfer canal gate until water level in the transfer canal was equalized with the spent fuel pool.
This eliminated the potential for elevated radiation levels as a result of a lower water level in the transfer canal.
t I
f I
,(~
Corrective Ste s That Will Be Taken To Avoid Further Violations The "Spent Fuel Handling Machine" procedure willbe revised to include a limitation that no irradiated fuel will be moved in the spent fuel pool unless water level in the fuel transfer canal is equalized with the spent fuel pool. The revision willbe effective prior to September 1, 1998.
Date when Full Com liance Will Be Achieved Full compliance will be achieved by September 1, 1998 (prior to the next Palo Verde refueling outage) when the "Spent Fuel Handling Machine" procedure is revised.
t
Kanitz, Duane L(Z54999)
From:
Kanitz, Duane Sent:
Friday, June
To:
Ide WIlliam E Cc:
Subject:
Importance:
L(Z54999)
9, 1998 8:12 AM (Z53314)
Krainik, Angela K(V21680); Studer, Paul M(Z92847); Muhs, Michael K(Z69505); Winsor, Michael J(Z98382); Rash, Bruce J(Z77439)
RE: NOV Response High Bill Thank you.
I incorporated your comment by changing the word "process" to,"guidance."
I asked on the front end why we were using the term "process" instead of "procedure."
I was told that we were not sure what form
"Conduct of Engineering "was going to take.
Thanks Duane From:
Ide, William E(Z53314)
Sent:
Thursday, June 18, 1998 4:12 PM To:
Kanitz, Duane L(Z54999); Rash, Bruce J(Z77439); Krainik, Angela K(V21680)
subject:
NOV Response I have reviewed NOV 98-03 and 04 response (6/16 version ) and have one comment, the conduct of engineering item is not a process but a procedure or guideline.
Page
t I
l t
l I
jO