ML17305A713

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Responds to NRC 900321 Ltr Re Violations Noted in Insp Rept 50-530/90-08.Corrective Action:Plant Guideline Providing Addl Guidance Re Prioritization of Work Promulgated
ML17305A713
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 04/20/1990
From: Conway W
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-01674-WFC-T, 102-1674-WFC-T, NUDOCS 9004270114
Download: ML17305A713 (26)


Text

Qi' C.'LI Arizona Public-Service Company.'( V P(O. BOX 53999 ~ .PHOENIX. ARIZONA 85072-3999 WILLIAMF. CONWAY lOQQ) I,gfi-+c/AS'34 EXECUTIVEVICE PAESIOENT NUCI.EAR April 20, 1990 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Reference:

Letter from. R. P. Zimmerman, Director, Division of;Reactor Safety and Projects to W. F. Conway, .Executive Vice President Nuclear, Arizona Publi'c Service, dated March 21, 1990

Dear Sirs:

Subj ect: Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Docket No. STN 50-530 (License No. NPF,'-,74)

Reply to Notice .o'f Violation.50-530/90-08-'02

-1 '0-070-0 6 This letter is provided in response,to, the inspection conducted by 'Messrs. A.

Johnson and W. P. Ang on January 29 through February 2, 1990 and February 12 through, 16, 1990. Based upon the. results of .the inspection, one (1) violation; of NRC requirements was. identified. The violation is discussed in Appendix .A of the referenced 1'etter. A restatement of the violation and PVNGS's response are provided in Appendix A'nd Attachment 1, respectively, to this letter.

Should you have any questions regarding this response, please contact me.

Very truly yours, WFC/TRB/J J N/tl'g Attachments CC: P, B. Martin A. H. Gutterman.

T. L. Chan.

D. H'. Coe E. E. Van Brunt A. C..Cehr

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Document Control Desk 102-01674-VFC- TRB/JJN Page 1 of 1 April 20, 1990 APPENDIX A OTICE OF VIOLATION Arizona Nuclear Power Project Docket Number 50-530 Palo Verde Unit 3 License Number NPF'-74 During an NRC inspection conducted January k9 - February 2, 1990 and February 12-16, 1990, one violation of NRC requirements was id'entified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation i's listed below:

License NPF-74, Condition F, for the Palo Verde Unit 3 Nuclear Generating Station, reads in part, "APS shall implement and maintain in effect all provisons of the approved fire protection program as described in the Final Safety Analysis Report (FSAR) for the facility, as supplemented and amended, and as approved in the SER through Supplement 11 FSAR Table 9.5-.1c., Quality Assurance, Item 8, Corrective Actions, states that "measures shall be established to assure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material and nonconformances are promptly identified, reported and'orrected."

Contrary to the above, measures did not assure conditions adverse to fire protection vere promptly corrected in that on February 14, 1990, emergency light 3EQN002-G and emergency light inverter 3EQBN004, required'y License 'NPF-74, Condition F, had been inoperable in excess of 35 days and had not been promptly repaired or replaced.

'This is a Severity Level IV violation (Supplement I).

i Document Control Desk 102-016,74-WFC/TRB/JJN Page 1 of 4 April 20, 1990 ATTACHMENT 1 Re l to Notice of Uiolation 50-528 90-08-02 REASON FOR VTOLATION Emer enc Li t 3E BN002-G On January 5, 1990, Work Request 382867 was initiated to replace the ballast for emergency light 3EQBN002-G. The Work'Request was processed as a priority 3A (schedulable work which can be accomplished i;n any mode and not affect plant operation) in accordance with APS procedures.

Prior to and during the time that the Work Request was being processed, emergent work was being performed to repl'ace the "A" Phase Main Transformer and return Unit. 3 to service. This work involved priority 1 Emergent Work (personnel or pl'ant safety) and priority 2 Emergent Work (required to assure continued power production or continued unit availability). The replacement of the ballast for the Emergency light was scheduled'o follow.higher priority work.

APS has developed the administrative controls to provide for the general I

prioritization of maintenance activities. Detailed prioritization and scheduling is accomplished by plant management and Work Control direction. However, as noted below, plane management had not provided

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Document Control Desk. 102 01674-WFC/TRB/J JN Page 2 of 4 April 20', 1990 sufficient direction to reflect the necessary priority of Emergency Lighting concerns.

ez enc Li ht Tnverter 3E BN004 On January 7, 1990; Work Request 388112 was 'initiated to calibrate the display board for emergency light 'inverter 3EQBN004. The display board was indi'cating that the batteries were supplying twenty to thirty'ercent load. However,, Work Control believed'he display board was out of, calibration based on other'ndications on the 'inverter and their experience'ith minor cal'ibration -drift. APS believes this condition did .not affect the operability of the inverter at this time.

On January 11, ,1990, Work Order 403303 was issued to recalibrate the display board. The work order was prioritized in accordance with APS administrative controls as discussed above. Other higher'riority work was already in progress which affected the scheduling of the work.

On January 31,, 1990, the System Engineer walked down the Emergency Lights and noted that the,l'oad indication Had, increased to 80 to 90 I

percent. This higher load indication identified an, additional problem than originally anticipated. This condition was di'scussed with, Work Control and Maintenance personnel. On February 8, 1990, wor'k was commenced on 3EQBN004. At this ti'me,the ind'ication had returned to

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Document Control Desk '102-016 /4- WFC/TRB/J JN Page 3 of 4 April 20, 1990 normal. This is believed to be the result of the .internal isolation of one'f the two redundant inverter boards. During the performance of the .

calibration, the failed inverter,board was identifi'ed. Once the replacement inverter board was, issued from the warehouse, the work was expeditiously performed, and work was completed on. February 16, 1990.

The reason for. the violation was that the admini'strative controls for the prioritization of work and subsequent schedul'ing did not adequately reflect APS's. commitment in FSAR Table 9.S-lc., Quality Assurance,, Iteg,

-8, Corrective 'Actions, which states that "measures shall be establ'ished to assure'.that conditions adverse- to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material',,and nonconformances are promptly identified, reported, and corrected.."

ZZ. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND -THE RESULTS ACHIEVED The Director of Operations and Maintenance has promulgated a plant guideline providing additional guidance regarding the prioritization of work. Corrective maintenance for the operability of Emergency lights will be 'treated as. priority 2 (i.e., work should commence within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). This guideline will remain in effect until the scheduling process is, reviewed to verify that non-producti'on equipment i's being properly prioritized.,

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Document Control'esk 102-01674-WFC/TRB/JJN Page 4 of 4 April 20, 1990 III. CORRECTIVE STEPS THAT VILL BE TAKEN TO AVOID FURTHER VIOLATIONS APS believes the actions taken as described above are adequate to prevent recurrence.

IV,. DATE %HEN FULL COMPLIANCE WAS ACHIEVED On February 16, 1990 work was completed on the inverter. Full compliance was achieved on February 26, 1990 when 'the ballast was replaced,on emergency light 3EQBN002-G.

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ACCELERATED DISTRlBUTION DEMONSHRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ESSION NBR:9004270114 DOC.DATE: 90/04/20 NOTARIZED: NO DOCKET FACIL:STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION CONWAY,W.F. Arizona Public Service Co. (formerly Arizona Nuclear Power, RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 900420 50-530/90-08.

ltr re violations'oted in Insp Rept DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Standardized. plant. 05000530 RECIPIENT RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 PD 1 1 PETERSON,S. 1 1 CHAN,T 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1 1 AEOD/TPAD 1 1 DEDRO 1 1 NRR SHANKMAN,S 1 1 NRR/DLPQ/LPEB10 NRR/DOEA DIR 11 l. 1 NOTES'OPIES NRR/DREP/PEPB9D NRR/DST/DIR SE2 NUDOCS-ABSTRACT 1

1 1

1 1

1 1

1 NRR/DRIS/DIR I

NRR/PMAS/ LRB1 2 OE DIR 1

1 1

1 1

1 OGC/HDS 1 1 1 02 1 1 RES/DSR/HFB/HFS 1 1 RGN E 01 1 1 EXTERNAL: LPDR 1 1 NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WAFK! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENIS YOU DON'T NEED!

OTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26

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Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX,'ARI2ONA85072-3999 WILLIAMF. CONWAY 102-01674-WFC/TRB/JJN EXECUTIVEVICEPAESIDEHT NUCLEAR April 20, 1990 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Reference:

Letter from R. P. Zimmerman, Director', Division of Reactor Safety and Proj'ects to W. F. Conway, Executive Vice President Nuclear, Arizona Publi'c Service, dated March 21, 1990

Dear Sirs:

Subj ect: Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Docket No. STN 50-530 (License No. 'NPF'-74)

Reply to Notice of Violation 50-530/90-08-02 File'0-070-026 This letter is provided in response to the inspection conducted by Messrs'.

Johnson and W. P. Ang on January 29 through February 2, 1990 and February 12 through 16, 1990. Based upon the results of the inspection, one (1) violation of NRC requirements was identified. The violation is discussed in Appendix A of the referenced letter. A restatement of the violation and PVNGS',s response are provided in Appendix A and Attachment 1, respectively, to .this letter.

Should you have any questions regarding this response, please contact me.

Very truly yours, WFC/TRB/JJN/tlg Attachments cc: J. B. Martin A. H. Gutterman D. H. Coe T. L. Chan E. E. Van Brunt A. C. Gehr

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Document Control Desk 102-01674-WFC-TRB/JJN Page 1 of 1 April 20, 1990 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Docket Number 50-530 Palo Verde Unit: 3 License Number NPF-74 During an NRC inspection conducted January 29 - February 2, 1990 and February 12-16, 1990,, one 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 (1989), the violation is listed 'below:

License NPF-74, Condition F, for the Palo Verde Unit 3 Nuclear Generating Station, reads in part, "APS shall implement and maintain in effect all provisons of the approved fire protection program as described in the Final Safety Analysis Report (FSAR). for the facility, as supplemented and amended, and as approved in the SER through Supplement ll FSAR Table 9.5-1c , Quality Assurance, Item 8, .Corrective Actions, states that "measures shall be established to assure that conditions

.adverse to fire protection, such as failures, malfunctions, deficiencies, deviations,, defective components, uncontrolled combustible

,material and nonconformances are promptly identified, reported and corrected."

Contrary to the above, measures did not assure conditions adverse to fire protection were promptly corrected in that on February 14, 1990, emergency light 3EQN002-G and emergency light inverter 3EQBN004, required by License NPF-74, Condition F, had been inoperable in excess of 35 days and had not been promptly repaired or replaced.

This is a Severity Level IV violation (Supplement I)..

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Document Control Desk 102-016 74- WFC/TRB/J JN Page 1 of 4 April 20, 1990 ATTACHMENT 1 Re l to Notice of Violation 50-528 90-08-02 I. 'EASON FOR VIOLATION Emer enc Li ht 3E BN002-G On January 5, 1990, Work Request 382867 was initiated to replace the ballast for emergency light 3EQBN002-G. The Work, Request was processed as a priority 3A (schedulable work which can be accomplished in any mode and not affect plant operation) in accordance with APS procedures.

Prior to and during the time that the Work Request was being processed, emergent work was being performed to replace the "A" Phase Main Transformer and return Unit 3 to service. This work involved priority 1 Emergent Work (personnel or plant safety) and priority 2 Emergent Work (required'o assure continued power production or continued unit availability). The replacement of the ballast for the Emergency light was scheduled to follow higher priority work.

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APS has developed the administrative controls to provide for the general I

prioritization of maintenance activities. Detailed prioritization and scheduling is accomplished by plant management and Work Control direction. However, as noted below, plant management had not provided

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Document Control Desk 102-01674-WFC/TRB/JJN Page 2 of 4 April 20, 1990 sufficient direction to reflect the .necessary priority of Emergency Lighting concerns.

Emer enc Li ht Inverter 3E BN004 On January 7, 1990, Work Request 388112 was initiated to cal'ibrate the display board for emergency light inverter 3EQBN004. The display board was indicating that the batteries were supplying twenty to thirty percent load. However, Work Control believed the display board was out of calibration based on other indications on the inverter and their experience with minor calibration, drift. APS believes this condition did not affect the operability of the inverter at this time.

On January 11, 1990, Work Order 403303'as issued to recalibrate the display board. The work order was prioritized in accordance with APS administrative controls as discussed above. Other higher priority work was already in progress which affected the scheduling of the work.

On January 31, 1990, the System Engineer walked down the Emergency Lights and noted that the load indication had increased to 80 to 90 percent. This higher load indication identified an. additional, problem than originally anti:cipated. This condition was. discussed with Work Control and Maintenance personnel. On February 8, 1990; work was commenced on 3EQBN004. At this time the indication had returned'o

~ll'O Document Control Desk 102-01674-WFC/TRB/JJN Page 3 of 4 April 20, 1990 normal. This is believed to be the result of the internal isolation of one of the two redundant inverter boards. During the performance of the calibration, the failed inverter board was identified. Once the replacement inverter board was issued from the warehouse, the work was expeditiously performed, and work was completed on February 16, 1990.

The reason for the violation was that the administrative controls for the prioritization of work and subsequent scheduling did not adequately reflect APS's commitment in FSAR Table 9.5-lc., Quality Assurance, Item 8, Corrective Actions, which states that "measures shall be established to assure that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material, and nonconformances are promptly identified, reported, and corrected."

II. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The Director of Operations and Maintenance has promulgated a plant guideline providing additional guidance regarding the prioritization of work. Corrective maintenance for the operability of Emergency 'lights will be treated as priority 2 (i.e., work should commence within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). This guideline will remain in effect until the scheduling process is reviewed to verify that non-production equipment is being properly prioritized.

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Document Control Desk 102-01'674-WFC/TRB/JJN Page 4 of 4 April 20, 1990 III.. CORRECTIVE STEPS'HAT WILL BE 'TAKEN TO AVOID FURTHER VIOLATIONS APS believes the actions taken as described above are adequate to prevent recurrence.

IV. DATE WHEN FULL COMPLIANCE WAS ACHIEVED On February 16, 1990 work was completed on the inverter. Full compliance was achieved on February 26, 1990 when the ballast was replaced on emergency light 3EQBN002-G.

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