ML17299A912
| ML17299A912 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/19/1985 |
| From: | Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17299A911 | List: |
| References | |
| 50-528-85-31, NUDOCS 8601080528 | |
| Download: ML17299A912 (5) | |
Text
I.
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~voce osaoosas PSR APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company P. 0.
Box 21666
- Phoenix, Arizona 85036 Docket No. 50-528 License No. NPF-41 As a result of the inspection conducted during the period of October 28-November 8,
- 1985, two violations of NRC requirements were identified.
The violations involved failure to follow the procedure controlling temporary modifications and failure to properly evaluate a change to a plant system.
In accordance with the NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violations are listed below:
A.
10 CFR 50 Appendix B, Criterion V, as addressed in Section 17 of the Final Safety Analysis Report (FSAR), requires that activities affecting quality be prescribed by and accomplished in accordance with documented procedures.
Station manual procedure number 73AC-9ZZ05, "Temporary Modification Control," section 5.1.13, requires that independent verification of quality related temporary modifications be performed within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the time the temporary modification is implemented.
Contrary to the above, temporary modifications 1-85-CH-320, which altered the capacity of various snubbers on quality related systems and was installed on July 27, 1985 but not verified until October 25, 1985 and temporary modification 1-85-RC-181, which altered a pipe support for the pressurizer spray line was installed but not independently verified (at the time of the inspection) to be properly implemented within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of their implementation.
This is a Severity Level IV Violation (Supplement I).
B.
10 CFR 50.59, paragraph (b) requires in part that, changes to the facility as described in the Safety Analysis Report include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, on October 31, 1985, the independent air receiver tanks of the 'A'mergency diesel generator air start system were cross connected by a temporary jumper hose without a written safety evaluation being performed.
This is a Severity Ievel V Violation (Supplement I).
"2-Pursuant to the provisions of 10 CFR 2.201, Arizona Public Service&ompany is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including:
(1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
Consideration may be given to extending your response time for good cause shown.
DEC ls >ss5 Dated Young, Jr.,
ief Engineering Sec ion
RESPONSE
TO NOTICE OF VIOLATION (50-528/85-31-09)
ITEM A CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED As a result of this violation, a review of Temporary Modifications (TMs) 1-85-RC-181 and 1-85-CH-320 was performed which revealed:
1)
Only one TM was required to be installed to Revision 3
of 73AC-9ZZ05, and 2)
On the date of each TMs installation, there were at least three verifications of each modification.
Temporary Modification 1-85-RC-181 was installed to Revision 2
of 73AC-9ZZ05 per Contractor Work Order (CWO) 86071 on 5/15/85.
Since Revision 3 of this procedure did not become effective until 6/20/85, Revision 2 was required to be used for this modification.
Revision 2 of 73AC-9ZZ05 Paragraph 5.3.3 required the installer to have an independent verifier designated.
This paragraph required verification of installation by signing page 4
of Appendix A of the Temporary Modification
- Request, but not within the 8
hour time restriction presently in Revision 3 of 73AC-9ZZ05.
The revision of the procedure in effect at the time of the modification (Revision 2) did not require the 8
hour time limit.
Additionally, the Temporary Modification was installed per CWO 86071 which required the Bechtel Area Field Engineer (AFE) and equality Control Engineer (QCE) to verify the work performed.
The work was verified upon completion by the Bechtel AFE and FACE in the CWO and by ANPP Ops Engineering in Block 34 of the Temporary Modification Request; all signed on 5/15/85.
ANPP, therefore, believes the Notice of Violation cited for this temporary modification is inappropriate.
Temporary Modification 1-85-CH-320 was installed to Revision 3
of 73AC-9ZZ05 per CWO 98018 on 7/27/85.
The CWO required a verification and signature for the installation by the Bechtel Area Field Engineer and equality Control Engineer.
These steps were signed upon completion of the installation on 7/27/85.
The ANPP Ops Engineer signed on Block 34 of the TMR also on 7/27/85.
A discussion with the ANPP Outage Management Engineer (OME) revealed he did not realize the requirement of Paragraph 5.1.10 of 73AC-9ZZ05 Rev.
3 at the time of installation.
This paragraph states that an ANPP Outage Management Group (OMG) member is responsible for compliance to the Procedure for Temporary Modifications installed or removed by use of CWO's.
The OME erred in not ensuring Block 35 was signed within the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> time limit because the procedure had been recently revised from Revision 2 to Revision 3 prior to the work.
This temporary modification was ultimately independently verified by an ANPP Ops Engineer on 11/25/85.
(Note:
The Notice of Violation states '10/25/85).
The information presented above indicates that no procedural violation occurred during installation of 1-85-RC-181,
- however, a minor procedural violation did occur during the installation of 1-85-CH-320.
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he conditions stated in this violation have been addressed and the following corrective steps have been taken.
1.
OMG will review all Temporary Modifications installed or restored using a Contractor Work Order to ensure compliance with 73AC-9ZZ05 Rev.
3.
This review will include all Temporary Modifications installed/restored since 6/20/85.
II.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE l.
ANPP Memo ANPM-00449/PLB-94.05 has been issued to require retraining to 73AC-9ZZ05 Rev.
3 by all Outage Management Personnel.
2.
A Procedural Change Notice (PCN) is being initiated to 73ACHZZ05 to further clarify the Outage Management Department responsibility with respect to this issue.
III.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1.
The review of Temporary Modifications installed as 6/20/85 is expected to be completed by 2/15/86.
- 2.,Retraining of Outage Management Personnel to 73AC-9ZZ05 will'e
'ompleted 'by,1/31/86.
3.
The PCN issued to clarify 73ACHZZ05 is expected to be completed by
,2/1/86.
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RESPONSE
TO NOTICE OF VIOLATION (50-528/85-31-06)
ITEM B CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED ANPP is currently investigating the implications of this violation with respect to the approach in the performance of written safety evaluation as required by 10CFR50.59 and with respect to operational activities.
As discussed in a
telephone conversation between Mr.
L.
F. Miller (Region V) and Mr. T. A. Petersen (ANPP) on January 14, 1986, Mr. Miller explained that it would be acceptable to transmit a final response to this violation to the NRC at a later date provided a justification and a
proposed schedule for resolution be provided in the initial 30 day response letter required.
The preceding information provides the ANPP justification for a subsequent final response; the final response is scheduled to be submitted as provided below.
II.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE This item will be fully addressed in the ANPP final response to this violation.
III.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The ANPP final response to this violation is scheduled to be submitted by February 5, 1986.
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