ML17303A541
| ML17303A541 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/27/1987 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 102-00485-EEVB, 102-485-EEVB, NUDOCS 8709030419 | |
| Download: ML17303A541 (38) | |
Text
DEsIGNATED OBICBIAL Cert.'.i.ieQ By Arizona Nuciear Power Project P.O. BOX 52034
~
PHOENIX. ARIZONA85072-2034 102- 00485-EE VB/TDS August 27, l987 NRC Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 2 Docket No. STN 50-529 (License NPF-51)
Response to Notice of Violation:
50-529/87-19 Fi le:
87-001-493
Reference:
Letter from F. A. Wenslawski (NRC) to E. E. Van Brunt, Jr.
(ANPP),
dated July 30, 1987.
NRC Inspection Reports 50-528/87-18, 50-529/87-19, and 50-530/87-20 This letter is provided in response to the inspection conducted by Messrs.
M. S. North and G. R. Cicotte on May 26 - 29 and June 22 - 26, 1987.
Based on the results of the inspection, one (1) violation of NRC requirements was identified.
The violation is discussed in Appendix A, of the referenced letter.
The violation and ANPP's response are provided in Attachment l.
Additionally, in the cover letter of the referenced letter, a request was made to advise the NRC of the steps ANPP has taken or will take to ensure appropriate tests of the Post Accident Sampling System are performed to verify the system is fully operable prior to being returned to service.
These steps are described in Attachment 2.
Very truly yours, cd
. E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/TDS/kj Attachments cc:
J.
G. Haynes J.
B. Martin J.
R. Ball E. A. Licitra A. C. Gehr 87'~sar PDR
@DOCK 0 pDR n y (w/attachment)
(w/attachment)
(w/attachment)
(w/attachment)
(w/attachment)
NRC Document Control Desk Page 1 of 5 102-00485-EEVB/TDS August 27, 1987 ATTACHMENT 1 NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating Station Unit 2 Docket No. 50-529 License No. NPF-51 During an NRC inspection conducted on May 26-29 and June 22-26, 1987 a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
( 1987), the violation is listed below:
A.
1 requires in part that, "Written procedures shall be...implemented,
...covering the activities referenced below:
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978,...."
Regulatory Guide 1.33, Appendix A, section 1.
Administrative Procedures, requires procedures addressing Equipment Control (e.g. locking and tagging) in item C.
Licensee procedure 40AC-9ZZ15, Rev.
1, Station Tagging and Clearance (Operating License) in section 3.1 PVNGS Clearance, requires in part, "A clearance
...so that work ma be done with safet to ersonnel and e ui ment."
Further section 3.4 Red Danger Tag (Appendix D), requires that, "A red danger tag shall be placed on equipment (mechanical or electrical) which, if the equipment was operated, would endanger personnel or damage equipment."
I I
l f
NRC Document Control Desk Page 2 of 5 102-00485-EEVB/TDS August 27, 1987 Contrary to the above, during the period Hay 20 to May 21, 1987, remotely actuated valve (V-22), providing single boundary isolation from the reactor coolant at normal operating pressure during maintenance of Post I
Accident Sampling System (PASS) HV-23, was not danger tagged to ensure protection of personnel and equipment.
This is a Severity Level IV Violation (Supplement I).
0
NRC Document Control Desk Page 3 of 5
102- 00485-EEVB/TDS August 27, 1967 ATTACHMENT 1 CONTINUED
RESPONSE
TO NOTICE OF VIOLATION 1.
REASON FOR THE VIOLATION Although unrelated to this violation, the event discussed in the letter transmitting the violation resulted in a detailed evaluation of various programmatic areas, one of which was the station tagging and clearance controls.
As required by PVNGS Technical Specifications Section 6.8.1 and Appendix A of Regulatory Guide 1.33 revision 2,
- 1978, ANPP developed and implemented procedural controls for Station Tagging and Clearance on March 3, 1983.
The revision in use at the time of the event, rev'ision 1
to 40AC-9ZZ15, was approved on January 31, 1987.
The evaluation concluded that the controls implemented meet the intent of current regulatory and industry guidance provided in this area.
In the specific event discussed in the Notice of Violation, the actions taken by the responsible individuals were compared with the procedural controls provided.
It was concluded that each action in the sequence of events was completed within the guidance provided in the Work Control Program (30AC-9ZZ01).
During the initial development of the work package the responsible
- planner, through his review, concluded that a clearance and associated tagging was required.
This conclusion was conservative in
0
NRC 'Document Control Desk Page 4 of 5 102-00485-EE VB/TDS August 27, 1987 nature and was based upon the information available at the time.
When the work package was released to the field for implementation the responsible craft personnel conferred with the releasing organization which was responsible for the specific system and its operation and concluded that a clearance would not be required.
This conclusion was based upon the type of activity (troubleshooting) being conducted and the ability of both the craft personnel and the responsible operators to adequately control the system and its operation.
Therefore a clearance was not issued.
This decision was subsequently documented in the work package.
This action was permitted within the established work control program (30AC-9ZZ01) which states in part; "...the requesting organization may choose to perform the work without a clearance, provided the Shift Supervisor s concurrence is obtained, and all parties involved agree that any safety hazard has been minimized."
2.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN'AND THE RESULTS ACHIEVED
'I The results of the overall evaluation indicated that the action taken violated neither the intent nor actual controls and in no way jeopardized the safety of personnel or equipment.
However, in r etrospect ANPP does believe that the issuance of a clearance would have provided a more positive control for system operation and would have been a more conservative approach.
In light of ANPP's established policy to enhance each program whenever possible, the PVNGS Plant Manager issued a
memo to
0
NRC-Document Control Desk Page 5 of 5 102-00485-EEVB/TDS August 27, 1987 all personnel reemphasizing the importance of personnel and equipment safety with specific attention being paid to adherence with the controls and intent established in 40AC-9ZZ15.
Historically ANPP has demonstrated excellent compliance in this area.
For example, in 1986, approximately 13,000 work orders requiring clearances were issued for Units 1, 2 and 3.
During this period the ANPP Safety Department identified only one (1) tagging violation.
ANPP believes that existing controls and practices will ensure continued excellence.
I 3.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Because of ANPP's commitment to excellence, we will continue to closely monitor our performance in this area.
4.
DATE WHEN FULL COH'LIANCE WILL BE ACHIEVED Actions discussed above were completed in July and August,
'l987.
NRC Document Control Desk Page 1 of 3 102-00485-EEVB/TDS August 27, 1987 e
ATTACHNENT 2 In'the cover letter transmitting the inspection report, a request was made to advise the NRC of the steps ANPP has taken or will take to ensure appropriate tests of the Post Accident Sampling System (PASS) are performed to verify the PASS is fully operable prior to being returned to service.
The following provides ANPP's process for determining retest requirements following maintenance and the evaluation of the retest used for the personnel contamination event in Unit 2.
Im accordance with ANPP's established procedural controls the maintenance planner coordinator in conjunction with maintenance or system engineers, STA and/or the shift supervisor determine the retest requirements necessary to verify the correct performance of maintenance activities and demonstrate component/system operability.
In most cases involving minor corrective maintenance or preventive maintenance, the retest is accomplished by the performance of applicable portions of the appropriate surveillance test.
Obviously the type of retest required and the amount of guidance necessary in the work documents are dependent upon the complexity of the work activity.
The specific event involving the personnel contamination in Unit 2 occurred during the conduct of a surveillance test.
The test conducted, if successfully completed, would have verified the integrity of the Post Accident
e 0
NRC Document Control Desk Page 2 of 3 102-00485-EEVB/TDS August 27.
1987
'ampling System (PASS), the proper operation of the PASS valves replaced during the maintenance activity and the operability of the PASS.
In the opinion of the individuals involved, the replacement of threaded 1/2" valves was not complex in natur e and the use of the surveillance test to verify the correct performance of the maintenance activity was appropriate.
The surveillance test required the pressurization of the sample line which would have identified any potential leaks caused as a result of the valve replacement.
The surveillance test also required that a sample be drawn which in turn would have verified the correct operation of the valves.
Therefore as
- stated, the surveillance test being conducted at the time of the event would have provided the proper mechanism to demonstrate the functioning and operability of the PASS.
The error in judgment occurred when the decision was made to conduct the surveillance test, without modification, using primary coolant as the source of water to pressurize the PASS lines.
Discussions with the responsible individuals substantiated that this would not be considered an abnormal technique under the circumstances involved in this event.
ANPP believes the use of surveillance tests to verify maintenance activities and to demonstrate post maintenance operability to be a prudent and conclusive testing technique.
However, the use of primary coolant or any other contaminated medium to conduct the the test is considered unacceptable unless no other means is available.
0
NRC Document Control Desk Page 3 of 3 102-00485-EEVB/TDS August 27, 1987 0
V As a result of the evaluation conducted in response to this event the following corrective actions have been completed by ANPP management:
a.
Personnel involved in the event have been counseled (non disciplinary) on the specific actions that led to the event.
b.
Instructions have been issued to both the maintenance planners and the shift supervisors discussing the details of the event and the necessity to ensure that the safest possible environment is established during retest activities to protect'oth personnel and equipment.
~ ~ "
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P
/
REGUL RY INFORMATION DISTRIBUTI SYSTEM (BIDS)
ACCESSION NBR: 8709030419 DOC. DATE: 87/08/27 NOTARIZED:
NO DOCKET FACIL: STN-50-52'D Palo Verde Nuclear Station.
Unit 21 Arizona Publ i 05000529 AUTH. NAME AUTHOR AFFILIAT1 ON VAN BRUNTI E. E.
Arizona Nuclear Poujer ProJect
( formerly Arizona Public Serv RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 870730 ltr re violation noted in Insp Rept 50-529/87-19. Corrective actions: memo emphasizing importance of personnel Kc equipment safetgi monitoring performance issued.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTRj ENCL
( SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Standardized plant. M. Davisi NRR: iCg.
05000529
~y
, ~
INTERNAL:
REC IP IENT ID CODE/NAME PD5 PD DAVIS' ACRS DEDRO NRR/DOEA DlR NRR/DREP/RPB NRR/PMAS/ ILRB OGC/HDSi RES DEPY GI COPIES LTTR ENCL i
i 2
2 2
2 i
i i
i 2
2 i
i i
i i
i REC IP IENT ID CODE/NAME LICITRA.E AEOD NRR MOR ISSEAUI D NRR/DREP/EPB NRR/DRIS DIR OE LlEBERMANIJ
~E~
RGN5 FILE Oi COPIES LTTR ENCL 2
2 ii i
i
'i i
i i
i i
i i
EXTERNAL:
E NOTES:
LPDR NSIC ii i
NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
0
Arizona Nuclear Power Project P.O. 8OX 52034
~
PHOENIX. AAIZONA 85072-2034 102- 00485-EE VB/TDS August 27, 1987 NRC Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 2 Docket No. STN 50-529 (License NPF-51)
Response
to Notice of Violation.'0-529/87-19 Fi 1 e:
87-001-493
'eference:
Letter from F. A. Wenslawski (NRC) to E. E. Van Brunt, Jr.
(ANPP),
dated July 30, 1987.
NRC Inspection Reports 50-528/87-18, 50-529/87-19, and 50-530/87-20 This letter is provided in response to the inspection conducted by Hessrs.
H. S. North and G. R. Cicotte on Hay 26 - 29 and June 22 - 26, 1987.
Based on the results of the inspection, one (1) violation of NRC requirements was identified.
The violation is discussed in Appendix A, of the referenced letter.
The violation and ANPP's response are provided in Attachment 1.
Additionally, in the cover letter of the referenced letter, a request was made to advise the NRC of the steps ANPP has taken or will take to ensure appropriate tests of the Post Accident Sampling System are performed to verify the system is fully operable prior to being returned to service.
These steps are described in Attachment 2.
Very truly yours, EEVB/TDS/kj Attachments cc:
J.
G. Haynes J. B. Hartin J.
R. Ball E. A. Licitra A. C. Gehr (w/attachment)
(w/attachment)
(w/attachment)
(w/attachment)
(w/attachment) cuM n~
E. E. Van Brunt, Jr.
Executive Vice President Project Director 870903041~
nppp529 pDR
>DOCK 05 pDR 9
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NRC Document Control Desk Page 1 of 5 1O2-00485-EEVB/TDS August 27, 1987 ATTACHMENT 1 NOTICE OF VIOLATION Ar izona Public Service Company Palo Verde Nuclear Generating Station Unit 2 Docket No. 50-529 License No. NPF-51 During an NRC inspection conducted on May 26-29 and June 22-26, 1987 a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1987), the violation is listed below:
A.
1 requires in part that, "Wr itten procedures shall be... implemented,
...covering the activities referenced below:
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978,...."
Regulatory Guide 1.33, Appendix A, section 1.
Administrative Procedures, requires procedures addressing Equipment Control (e.g. locking and tagging) in item C.
Licensee procedure 4OAC-9ZZ15, Rev.
1, Station Tagging and Clearance (Operating License) in section 3. 1 PVNGS Clearance, requires in part, "A clearance
...so that work ma be done with safet to ersonnel and e ui ment."
Further section 3.4 Red Danger Tag (Appendix D), requires that, "A red danger tag shall be placed on equipment (mechanical or electrical) which, if the equipment was operated; would endanger personnel or damage equipment."
NRC Document Control Desk Page 2 of 5 102-00485-EEVB/TDS August 27, 1987 Contrary to the above, during the period tlay 20 to Hay 21, 1987, remotely actuated valve (V-22), providing single boundary isolation from the reactor coolant at normal operating pressure during maintenance of Post Accident Sampling System (PASS) HV-23, was not danger tagged to ensure protection of personnel and equipment.
This is a Severity Level IY Violation (Supplement I).
f
,fi I
1
NRC Document Control Desk Page 3 of 5
102- 00485-EE Y8/TDS August 27, 1987 ATTACHMENT 1 CONTINUED
RESPONSE
TO NOTICE OF VIOLATION 1.
REASON FOR THE VIOLATION P
~
-C
.~
I I
5 4l' Although unrelated to this violation, the event discussed in the letter transmitting the violation resulted in a detailed evaluation of various programmatic areas, one of which was the station tagging and clearance controls.
As required by PVNGS Technical Specifications Section 6.8.1 and Appendix A of Regulatory Guide 1.33 revision 2,
- 1978, ANPP developed and implemented procedural controls for Station Tagging and Clearance on March 3, 1983.
The revision in use at the time of the event, revision I to 40AC-9ZZ15, was approved on January 31, 1987.
The evaluation concluded that the controls implemented meet the intent of current regulatory and industry guidance provided in this area.
In the specific event discussed in the Notice of Violation, the actions taken by the responsible individuals were compared with the procedural controls provided.
It was concluded that each action in the sequence of events was completed within the guidance provided in the Work Control Program (30AC-9ZZ01).
During the initial development of the work package the responsible
- planner, through his review, concluded that a clearance and associated tagging was required.
This conclusion was conservative in
i
NRC Document Control Desk Page 4 of 5 102-00485-EEVB/TDS August 27, 1987
~(
- I C ~
0%
e1
.t nature and was based upon the information available at the time.
When the work package was released to the field for implementation the responsible craft personnel conferred with the releasing organization which was responsible for the specific system and its operation and concluded that a clearance would not be required.
This conclusion was based upon the type of activity (troubleshooting) being conducted and the ability of both the craft personnel and the responsible operators to adequately control the system and its operation.
Therefore a clearance was not issued.
This decision was subsequently documented in the work package.
This action was permitted within the established work control program (30AC-9ZZ01) which states in part; "...the requesting organization may choose to perform the work without a clearance, provided the Shift Supervisor's concurrence is obtained, and all parties involved agree that any safety hazard has been minimized."
2.
THE CORRECTIVE STEPS T'HAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
~~
4 s
I The results of the overa'll evaluation indicated that the action taken violated neither the intent nor actual controls and in no way jeopardized the safety of personnel. or equipment.
However, in retrospect ANPP does believe that the issuance of a clearance would have provided a more positive control for system operation and would have been a more conservative approach.
In light of ANPP's established policy to enhance each program whenever possible, the PVNGS Plant Manager issued a
memo to
.~
NRC Document Control Desk Page 5 of 5 102-00485-EEVB/TDS August 27, 1987 all personnel reemphasizing the importance of personnel and equipment safety with specific attention being paid to adherence with the controls and intent established in 40AC-9ZZ15.
Historically ANPP has demonstrated excellent compliance in this area.
For example, in 1986, approximately 13,000 work orders requiring clearances were issued for Units 1, 2 and 3.
During this period the ANPP Safety Department identified only one (1) tagging violation.
ANPP believes that existing controls and practices will ensure continued excellence.
3.
THE CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Because of ANPP's commitment to excellence, we will continue to closely monitor our performance in this area.
4.
DATE WHEN FULL COHPLIANCE WILL BE ACHIEVED Actions discussed above were completed in July and August, 1987.
NRC Document Control Desk Page 1 of 3 102-00485-EEVB/TDS August 27, 1987 ATTACHMENT 2 In the cover letter transmitting the inspection report, a request was made to advise the NRC of the steps ANPP has taken or will take to ensure appropriate tests of the Post Accident Sampling System (PASS) are performed to verify the PASS is fully operable prior to being returned to service.
The following provides ANPP's process for determining retest requirements following maintenance and the eva'luation of the retest used for the personnel contamination event in Unit 2.
In accordance with ANPP's established procedural controls the maintenance planner coordinator in conjunction with maintenance or system engineers, STA and/or the shift supervisor determine the retest requirements necessary to verify the correct performance of maintenance activities and demonstrate component/system operability.
In most cases involving minor corrective maintenance or preventive maintenance, the retest is accomplished by the performance of applicable portions of the appropriate surveillance test.
Obviously the type of retest required and the amount of guidance necessary in the work documents are dependent upon the complexity of the work activity.
The specific event involving the personnel contamination in Unit 2 occurred during the conduct of a survei'llance test.
The test conducted, if successfully completed, would have verified the integrity of the Post Accident
~I h
i I
f I
j I
I
NRC Document Control Desk Page 2 of 3 102-00485-EEVB/TDS August 27, 1987 Sampling System (PASS), the proper operation of the PASS valves replaced during the maintenance activity and the operability of the PASS.
In the opinion of the individuals involved, the replacement of threaded 1/2" valves was not complex in nature and the use of the surveillance test to verify the correct performance of the maintenance activity was appropriate.
The surveillance test required the pressurization of the sample line which would have identified any potential leaks caused as a result of the valve replacement.
The surveillance test also required that a sample be drawn which in turn would have verified the correct operation of the valves.
Therefore as
- stated, the surveillance test being conducted at the time of the event would have provided the proper mechanism to demonstrate the functioning and operability of the PASS.
The error in judgment occurred when the decision was made to conduct the surveillance test, without modification, using primary coolant as the source of water to pressurize the PASS lines.
Discussions with the responsible individuals substantiated that this would not be considered an abnormal technique under the circumstances involved in this event.
ANPP believes the use of surveillance tests to verify maintenance activities and to demonstrate post maintenance operability to be a prudent and conclusive testing technique.
However, the use of primary coolant or any other contaminated medium to conduct the the test is considered unacceptable unless no other means is available.
i
,~
NRC Document Control Desk Page 3 of 3 102-00485-EEVB/TDS August 27, 1987 As a result of the evaluation conducted in response to thi's event the following corrective actions have been completed by ANPP management:
"~ci
','. <<r prV
'F, E
a.
Personnel involved in the event have been counseled (non disciplinary) on the specific actions that led to the event.
b.
Instructions have been issued to both the maintenance planners and the shift supervisors discussing the details of the event and the necessity to ensure that the safest possible environment is established during retest activities to protect both personnel and equipment.
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