ML17305B031
| ML17305B031 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/29/1990 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9009120186 | |
| Download: ML17305B031 (19) | |
See also: IR 05000528/1990012
Text
'0
- >'- 2 9
1990
Docket Nos.
50-528,
50-529,
50-530
Arizona Public Service
Company
P.
0.
Box 53999,
Sta.
9012
Phoenix,
85072-3999
Attn:
Mr. Milliam F.
Conway
Executive Vice President,
Nuclear
Gentlemen:
Thank you-for your letter of June
20,
1990 in response
to our Notice of
Violation and Inspection
Report Nos.
50-528/90-12,
50-529/90-12,
and
50-530/90-12,
dated
May 21,
1990, informing us of the steps
you have taken to
correct the items which we brought to your attention.
Your corrective actions
will be verified during
a future inspection.
Your cooperation with us is appreciated.
Sincerely,
/ ) jj +f (
S.
A. Richards,
Chief
Reactor Projects
Branch
CC:
J.
Levine,
J
~
N. Bailey,
T. Bradish,
bcc w/copy of ltr. dated 6/20/90:
Docket File
Resident
Inspector
Project Inspector
G.
Cook
B. Faulkenberry
J. Martin
A. Johnson
J. Zollicoffer
State of Arizona
bcc w/o copy of letter dated 6/20/90:
H. Smith
REGION V ~)
D. Coe/jg ~
HMong
v'/M/90
P />f90
SRichards
e,/g/90
e
9009i20i8/i
Q
AQQgg 90<.)ip y
0 400528
F'DC
S /
NO
]
C
ES / .NO
]
S /
NO
YES /
NO
]
6 jg',
WILLIAMF. CONWAY
EXECUTIVEVICE PRESIDENT
NUCLEAR
Arizona Public Service Company
P.O. BOX 53999
~
PHOENIX. AIIIZONA85072-3999
102-01738-MFC/TRB/JJN
June
20,
1990
v
U. S. Nuclear Regulatory Commission
Document Control Desk
20555
Reference:
Letter from S. A. Richards,
Chief Reactor Projects
Branch,
to W. F.
Conway,
Executive Vice President
Nuclear,
Arizona Public Service
dated
May 21,
1990
Dear Sirs:
Subj ect.:
Palo Verde Nuclear Generating Station
(PVNGS)
Unit 1,
2,
and
3
Docket No.
STN 50-528
(License
No. NPF-41)
Docket No.
STN 50-529
(License
No. NPF-51)
Docket No.
STN 50-530 (License
No. NPF-74)
Reply to Notice of Violations 50-528/90-12-01, 50-530/90-12-01,
and
50-530/90-12-02
File
90-070-026
This letter is provided in response
to the inspection conducted
by Messrs,
D.
Coe, J. Ringwald, J. Sloan,
C. Myers, and P. Quells from March 4 th
h A
'1
ased
upon the results of the inspection,
three apparent violations
of NRC requirements
were identified.
The violations are discussed
in Appendix
A of the, referenced letter.
A restatement of the violations 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.
D. H.
T
L.
A. H.
A. C.
Martin
Coe
Chan
Gutterman
Gehr
Document Control Desk
Page
1 of 2
102-01738-WFC-TRB/J JN
June
20,
1990
APPENDIX A
Arizona Nuclear
Power Project
Palo Verde Unit 1 and
3
Docket Number 50-528
and 50-530
License
Numbers
During an
NRC inspection conducted
on March 4 through April 14,
1990,
three
violations of NRC requirements
were identified.
In accordance
with the
"General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix
C (1989),
the violations are listed below:
A.
Unit 1 Technical Specifications, Section 3.3.1, requires in part that
a
minimum of two Excore Neutron Flux Logarithmic Power Level - High
instrument will be operable in Mode 5,
and allows for operation with
only one channel provided certain Action Statement
requirements
are met.
Contrary to the above,
from March 21,
1990, until March 24,
1990, all
four channels
of Excore Neutron Flux Logarithmic Power Level
instrumentation
were deenergized
by licensee
personnel
to perform
cabinet
and drawer repairs while Unit 1 was in Mode 5.
This is
a Severity Level IV violation applicable to Unit 1 (Supplement
I) ~
B.
10 CFR Part 50, Appendix B, Criterion V, states
in part that
instructions,
procedures,
or drawing shall include appropriate
quantitative or qualitative acceptance
criteria for determining that
important activities have been satisfactorily accomplished.
Contrary to the above, Material Non-Compliance [sic] Report,
90-RC-
0009, Conditional Request
Release,
did not include an appropriate
quantitative
acceptance
criteria in that it did not specify the maximum
allowable torque for us> on valve 3PRC-B-V-207.
The conditional release
appeared
to allow a maximum torque of 75 ft-lbs, whereas
the proper
maximum allowable
was
30 ft-lbs.
This is a Severity Level IV Violation applicable to Unit 3 (Supplement
I).
C.
Unit 3 Technical Specifications, Section 6.8.1, states
in part:
..."Written Procedures
shall
be established,
implemented,
and maintained
.covering the activities referenced
below:
'
Document Control Desk
Page
2 of 2
102-01738-WFC-TRB/JJN
June
20,
1990
This program is implemented,
in part,
by licensee
Procedure
"Control of Combustible/Flammable
Materials
and Liquids" which states
in
part in paragraph
3.2.10, that "combustible material shall not be stored
next to outdoor safety-related
water storage
tanks."
Contrary to the above,
on March 5, 1990,
two apparently untreated
wood
packing crates,
an apparently full 55 gallon drum with a National Fire
Protection Association tag labeled
3 for flammability (extreme hazard),
and a number of other
55 gallon drums similarly marked were stacked
immediately adjacent to the Unit 3 Condensate'torage
Tank (a safety-
related tank required for safe shutdown).
This is a Severity Level IV Violation applicable
to Unit 3 (Supplement
I).
Document Control Desk
Page
1 of 8
102-01738-I"FC/TRB/JJN
June
20,
1990
ATTACIIMENT 1
Re
1
to Notice of Violation 50-
28 90-12-01
I.
REASON FOR THE VIOIATION
The event
was
a result of a misinterpretation of the Technical
Specifications.
Unit 1 Management
reviewed Technical Specifications 3.3.1,
3.3.1
ACTION 4 (which describes
the action to be taken with only
one channel
operable but does not address
having no operable
channels),
and 3.0.3
(which describes
actions to be taken if a limiting condition
of operation is not met).
Based
on the fact that Technical
Speci.fication 3.0.3 is not applicable in Mode 5,
and that the action
statement for the condition with only one operable
charm'el
was being
met, unit management
concluded that removal from service of all the log
channels
would be consistent with the intent of the Technical
Specifications.
However, unit management
did not recognize that it
would not be acceptable
to voluntarily enter into a condition that is
not defined by the Technical Specifications.
CORRECTIVE STEPS
THAT HhVF. BEFN TAKEN AND THE RESULTS hCIIYI:,VED
The wiring in the
PPS cabinet'nd
the cabinet drafters
were reworked in
.accordance
with approved
work <<uthorization'documents.
Document Control Desk
Page
2 of 8
102-01738-WFC/TRB/JJN
June
20,
1990
On March 23,
1990,
the Plant Review Board
(PRB) reviewed the event,
the
Updated Final Safety Analysis Report (sections
7.1, 7.2,
and 15.4.6),
Combustion Engineering
Standard
Safety Analysis Report (sections
7.1,
7.2, 15.4.6),
and
0800,
and 0857.
The
PRB determined that
there was no safety significance in having all log power channels
based largely on the plant conditions
and the operabilty of
the startup
channels
and the Boron Dilution Alarm System.
There
was no
impact on the health and safety of the public.
Log channel
D was declared
operable at approximately
0938
MST on March
26,
1990.
This placed the unit within the Technical Specifications 3.3.1 Action 4,
a condition defined by Technical Specifications.
On
March 26,
1990 at approximately
1554 MST, log channel
A was declared
This placed the unit in compliance with Technical
Specification
Log channel
B was declared operable at
approximately
1955
MST on March 26,
1990.
At approximately
2132
on'arch
26-,
1990,
Log channel
C was declared
A plant guideline applicable
to Units 1, 2,
and
3 has been promulgated
defining APS's position on voluntarily entering
a condition not defined
by the Technical Specifications.
The plant guideline clearly
communicates
hPS's position that it is not acceptable
to voluntarily
enter
a condition not defined by tho Technical Specifications.
If such
a condition is experienced
because
of equipment failure,
.:".:::.ed!ate
Document Control Desk
Page
3 of 8
102-01738-WFC/TRB/JJv,
June
20,
1990
action must be taken to return to a condition defined by the Technical
Specifications.
III.
CORRECTIVE"STEPS
THAT WILL BE TAKEN TO AVOID VIOLATIONS
APS believes
the actions
taken
as described
above
are adequate
to
prevent recurrence.
IV.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance
was achieved
on March 26,
1990,
when the
Log channel
D
was declared
I
f
Document Control Desk
Page
4 of 8
102-01738-WFC/TRB/JJN
June
20,
1990
Re
1
to Notice of Violation 50-530 90-12-01
I.
REASON FOR THE VIOLATION
Material Nonconformance
Report
(MNCR) 90-RC-0009
was initiated to
document
the packing leakage
on the Reactor Coolant System
(RCS)
Pressurizer
instrument root valve
3PRCBV207.
The nut and eyebolt
on the
packing gland follower were galled which limited the ability to adjust
the valve packing to reduce
leakage.
Engineering analyzed
the
feasibility of installing a spacer
around the existing eyebolt/nut
and
threading
an oversized nut on the remaining eyebolt threads.
The
analysis
was performed to calculate
1) the compressive
forces
and
potential buckling of the spacer
and 2) tensile/shear
forces
and
potential stripping of the eyebolt and the
new nut which was
made of a
material different than the original nut.
To assure
that the
calculation was conservative,
Engineering applied
a factor of 2.5 to the
nominal
30 ft-lbs field specification and then analyzed for a torque of
75 ft-lbs.
The calculations
demonstrated
that the installation of the
spacer
and new nut was acceptable.
An analysis of the pins which connect
the eyebolts
to .the valve body was
not performed nor required because
the existing analysis of the pins::as
still valid.
The change
involved only new spacers
and nuts.
An
increased
was not requested
for the conditional rel.',u:
. "Ie
l
I
Document Control Desk
Page
5 of 8
102-01738-WFC/TRB/JJN
June
20,
1990
assumption
was correctly made that the valve would be torqued using
"good mechanical
judgement" in accordance
with procedure
"Fastener
Tightening/Preload"
step 3.1.8
and 3.1.9.
This procedure
provides detailed guidance
on torquing based
on material,
dimensions,
application, etc.
Therefore,
no torque specification
was required.
The original preparation of the work order did not include
a value for
the torque specification other than the use of "good mechanical
judgement".
Attached to the work order
was
a copy of the
flNCR
conditional release for the installation of the spacer
and oversized
nut.,
During the review process of the work order
(and therefore
the
MNCR conditional release),
the bounding analysis of 75 ft-lbs in the
disposition for the
MNCR conditional release
was misinterpreted
to mean
a limiting field specification.
The work order was subsequently
revised
to include the restriction of 75 ft-lbs.
The misinterpretation of the
MNCR disposition
was caused
by Engineering including bounding design
calculations within the conditional release
and not specifying that the
information was for analysis only.
II.
CORRECTIVE STEPS
Tl'fAT 1fAVE BFl'.N TAKEN AND THE RFSULTS AClfTFVFD
As a result of this event,
an investigation
was conducted.
A
description of the event
and
f.he lessons
learned
were distr buted to the
site technical support personnel.
These
lessons
learned
w;","
..:,"crated
Document Control Desk
Page
6 of 8
102-01738-WFC/TRB/JJN
June
20,
1990
in site technical support group communication meetings.
In summary,
the
lessons
learned which were discussed with Engineering included:
1)
Precisely stating the problem and scope
(which should be
appropriately
documented),
2)
Clearly stating the required
"as left" condition,
3)
Technically reviewing dispositions with a questioning attitude,
and
4)
Following up Engineering dispositions/analysis
work with formal
verbal communication
when appropriate
to ensure
understanding
of
the issues
and resolution.
III.
CORRECTIVE STFPS
THAT WILL BF. TAKEN TO AVOID VIOLATIONS
APS believes
the actions
taken as described
above are adequate
to
prevent recurrence.
IV.
DATF. WHEN FULL COMPLIANCE WAS ACHIFVFD
Full compliance
was achieved
o>> April 17,
1990,
when the Work Order was
revised to specify
30 ft-lbs.
c~
Document Control Desk
Page
7 of 8
102 - 01 7 38 - WFC/TR8/J J N
June
20,
1990
Re
1
to Notice of Violation 50-530 90-12-02
EASON FOR THE VIOLATION
The fifty-fivegallon drums of flammable material,
temporarily located
adjacent
to the Unit 3 Condensate
Storage
Tank, contained
tendon grease
which was staged for pickup and disposal.
The individuals responsible
for conducting the surveillance test were not aware of the requirement
to obtain a transient combustible/flammable
permit for interim staging
adjacent
to t."he condensate
storage
tank.
II.
CORRECTIVE STEPS
THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
The Director of Operations
and Maintenance
issued
a
memo to onsite
supervisors
and managers
identifying the safety related
tanks
and
reiterating the requirement
to not store combustible/flammable
material
within 50 feet of the tanks.
Daily fire prevention tours of the plant have been conducted
to monitor
the control of combustible/flammable
materials
and to initiate
corrective actions.
0
A label request
form has
been initiated to evaluate
posting warning
labels
on the condensate
storage
tanks,
the refueling water
- >>)
- s,
<<>>d
Document Control Desk
Page
8 of 8
102-01738-WFC/TRB/J JN
June
20,
1990
the reactor
makeup water tanks.
III.
CORRECTIVE STEPS
THAT WILL BE TAKEN-TO AVOID VIOLATIONS
The transient
combustible material program will be revised to clarify
the administrative controls for storage
and inspection of transient
combustible materials.
Engineering is conducting
a review and
verification of plant areas
where the storage of flammable material
should be controlled.
Maps will be added to the procedure
to identify
areas
where
combustible permit may be applicable.
Expected completion date:
July 31,
1990.
IV.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED
Full compliance
was achieved
on March 5,
1990,
when the combustible
material
was removed.
.~