ML17304A607
| ML17304A607 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/15/1988 |
| From: | Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 8810040073 | |
| Download: ML17304A607 (6) | |
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0 ACCEIZRATZD DISI'RIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT:
Requests util evaluate approach toward assessing event reportability,per LER 528/88-014-00.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR ENCL
( SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response J
NOTES:Standardized plant.
,Standardized plant.
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~ p ACCESSION NBR:8810040073 DOC.DATE:- 88/09/15 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, AUTH.NAME AUTHOR AFFILIATION CHAFFEE,A.E.
Region 5, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION KARNER,D.B.
Arizona Nuclear Power'roject (formerly Arizona Public Serv RECIPIENT ID CODE/NAME PD5 PD DAVIS,M INTERNAL: ACRS DEDRO NRR/DLPQ/PEB ll NRR/DOEA DIR 11 NRR/DREP/RPB 10 NRR/PMAS/ILRB12 0
EB N,J G FILE 02 RGN E
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RECIPIENT ID CODE/NAME CHAN,T AEOD NRR MORISSEAU,D NRR/DLPQ/QAB 10 NRR/DREP/EPB 10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT OGC/HDS1 RES/DSIR DEPY NRC PDR COPIES LTTR ENCL 2
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TOTAL NUMBER OF COPIES REQUIRED:
LTTR 28 ENCL 28
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Docket Nos. 50-528 50-529 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 September 15, 1988 Arizona Nuclear Power Project P.O.
Box 52034 Phoenix, Arizona 85072-2034 Attention:
Nr.
D. B. Karner Executive-Vice. President Gentlemen:
Subject:
Reportability Determination of Licensee Event Report 528/88-014-00 We have reviewed Unit 1 Licensee Event Report (LER) 528/88-014-00, which was submitted on June 6, 1988.
This LER documents the results of surveillance testing of the.main steam safety valves at Units 1
and 2 during September 1987 and February 1988, respectively.
In both instances, the results of the surveillance testing, which were performed at power, identified that a high percentage of the safety valves had settings which were out of tolerance with the limits specified in the Technical Specifications.
The LER, which was submitted late, documents in some detail the thought process which initially led to the determination that the condition was not reportable.
We differ with your initial reportabi lity. determination which appears to have-been based on a rather narrow approach toward assessing the event's reportability.
Specifically, 10 CFR 50.72(a)(2)(i)(B) requires any operation or condition prohibited by the plant's Technical Specifications to be reported within 30 days after discovery of the event.
Your description of the event as provided in the LER indicates that the maximum number of safety valves inoperable at any given time was maintained within allowable limits since each valve found out of tolerance was properly adjusted prior to returning it to an operable status and proceeding to the next valve.
In situations such as this where multiple components are tested within a short period of time and a number of the components do not meet Technical Specification requirements, it is considered that concurrent failures or inoperabilities existed.
Any other determination, unless supported by relevant facts is inappropriate.
Therefore, we have concluded that more than the permitted number of safety valves were inoperable at one time during the period since last tested, resulting in the plant being operated outside the Technical Specifications.
With regard to your reference in the LER to NUREG-1022,.Supplement 1, Licensee Event Report System,
(}uestion 2.3, the answer supplied'.in':the:,NUREG was not intended to provide a basis for treating multiple component'failures or inoperabilities as a series of individual events.
It addressed the "time of occurrence" issue for a single situation.
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I September 15, 1988 We are concerned about the quality of your review of this event.
The fact that your quality support organizations (i.e., Compliance Department) and responsible management staff failed to recognize a valid technical issue of safety significance that merited reporting, warrants further attention.
We request that you evaluate your approach toward assessing event reportability to determine whether the deficiencies associated with this LER evaluation are isolated to the circumstances of this event, or indicative of the need for broader corrective action.
Please provide us with the results of your review within 30 days of receipt of this letter.
We recognize that ANPP concluded no safety consequences or implications resulted from these specific events based on the limited amount of setpoint error which occurred.
Our technical review of this LER will be completed and documented in a future inspection report.
The response requested by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Sincerely,
~St A. E. Chaffee, Deputy Director Division of Reactor Safety and
- Projects, RV CC:
J.
G. Haynes,.
ANPP W. F. guinn, ANPP R. Papworth, ANPP J.
- Souza, ANPP T.
D. Shriver, ANPP C.
N. Russo, ANPP D. Canady, ANPP L. Bernabei, GAP T. Hogan, ACC A. C. Gehr, Esq., Snell and Wilmer RZimmerman/nw Ric ards ate 9/I'I/88 9/) /88 9/&/88 AChaffee 9/ >f/88 RE UEST C
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NO RE(VEST P
YES NO ST C
P STCP YE
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NO ND T PDR YE NO
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