ML17305B201
| ML17305B201 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 11/06/1990 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17305B202 | List: |
| References | |
| NUDOCS 9011270182 | |
| Download: ML17305B201 (5) | |
See also: IR 05000528/1990038
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION V
1450 MARIALANE,SUITE 210
WALNUTCREEK CALIFORNIA94596
NOV - 4 1890
Docket Nos. 50-528, 50-529,
and 50-530
Arizona Public Service
Company
P. 0.
Box 53999, Sta.
9012
Phoenix, Arizona
85072-3999
Attention:
Mr. M. F.
Conway
Executive Vice President,
Nuclear
Gentlemen:
, SUBJECT".
NRC INSPECTION OF PALO VERDE NUCLEAR GENERATING STATION UNITS
NOS. 1, 2,
AND 3
This refers to the special
inspection conducted
by
NRC inspectors
M. Miller,
D. Proulx, and
P.
Galon of this office during September
10-25,
1990,
and
additional inspection activities conducted in the Region
V office during
October 1-23,
1990.
The special
inspection
examined activities authorized
by NRC License
Nos.
and NPF-74.
This, also, refers to the
discussion of our findings held with members of your staff at the conclusion
of the inspection.
Areas
examined during this inspection are described
in the enclosed
inspection
report.
Mithin these areas,
the inspection consisted of selective
examinations of procedures
and representative
records,
interviews with
personnel,
and observations
by the inspectors.
During the course of this inspection,
the inspectors identified concerns in
the following areas:
the need for improvement. in specific areas of your quality
program; the use of improper engineering
and work control documentation;
errors
in quality program procedures;
and the improper disposition of a nonconforming
condition.
Each area is discussed
below.
a
1
Im rovement In S ecific Areas of
our ualit
Pro ram
Over the past year,
NRC inspections
have identified weaknesses
in your programs
to identify nonconforming situations
and conditions adverse to quality.
At this
time, it appears
that these
programs,
and their implementation,
have improved.
'ased
on this inspection,
you appear to have identified and resolved
nonconforming conditions more quickly and thoroughly than past inspections
have found.
However, there are still weaknesses
in this program, which are
discussed
later in this letter,
and in the enclosed
inspection report.
Im ro er Documentation
Your improved quality program implementation,
as well as
NRC inspector
observations,
have identified several
examples of improper documentation,
both in the use of inappropriate
work control documentation
and in the
inadequate
documentation of engineering evaluations.
In several
cases,
these
types of situations
seem to have occurred
when the individuals involved
perceived
a sense of urgency.'pecific
instances
are discussed
in the
enclosed
inspection report.
The following are two examples:
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Ina
ro riate Work Control Documentation.
During the Unit 2 outage of
January,
1990,
a
mo
fication to snsta
the reactor vessel
level
indication was tested
using incorrect administrative controls.
A
temporary procedure,
rather than work order,
was used.
As
a result, the
final plant configuration
was not set properly.
.A plastic hose
remained
attached
to the pressurizer
and was exposed to reactor
coolant system
pressure after the testing
was finished.
The tube ruptured during
operations
to fill the reactor coolant system.
Your quality programs
have identified corrective action for specific cases,
and for some generic areas.
These
instances
may be precursors
to more
significant events.
Considering
the frequency with which these
problems
have
roblems continue, the generic
been sdentifsed,
and r)sks involved if simslar
p
issues
need to be more thoroughly addressed.
Im ro er Resolution of a Nonconformin
Condition
2.
Failure to Document
a Si nificant En ineerin
Evaluation:
During an
outage
1n
une,
9 , preparations
were
ma
e to remove
a flange to
perform reactor coolant
pump work.
The procedure
required that, before
the flange was removed, the reactor coolant level be below 101'4" to
minimize the effects of reactor coolant leakage.
Because
other work
in the plant at that time required
a higher reactor coolant level,
plant management
and engineering
determined that it was acceptable for
the reactor coolant level to be as high as 103'8" for the flange removal.
The basis for the acceptability of the higher level
was not documented
before the flange was removed.
The flange was removed at 103'8";
Nore
leakage
occurred than was expected..
This inspection found that you initiated power opgrations
apparently without
proper disposition of a nonconforming safety related breaker.
Because
the
improvements
in your quality programs
appear to have implemented appropriate
corrective action, this violation is non-cited.
Errors In Procedures
During review of your procedures,
the inspectors identified several
inaccurate
references
to procedure
steps
and to other plant procedures.
These errors
were noted
as peripheral
observations
during a routine inspection of your
technical
work.
However, the number of these errors
may imply that:
1.
A number of inaccurate
references
may exist in your engineering
and quality
procedures,
and
2.
During routine use of these
procedures
by plant personnel,
these
inaccuracies
were not being identified and fixed.
e
'
We recognize that many of your procedures
have undergone
extensive revision in
the last'ix months.
However, other procedures
which contain these
types of
errors
have
been substantially in place for a year or more.
The need for
accurate
procedure
references
is obvious,
as is the need for the personnel
to
identify inaccuracies
as they are encountered.
Management attention is
required to r educe the number of inaccurate
references
in procedures.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosures
will be placed in the
NRC Public Document
Room.
Should you have
any questions
concerning this inspection,
we will be glad to
discuss
them with you.
Sincerely,
.~
Dennis
F. Kirsch, Chief
Reactor Safety Branch
Enclosures:
Inspection Report Nos. 50-528/90-38,
50-529/90-38,
and 50-528/90-38
cc w/enclosure:
Mr. 0. Mark DeMichele,
Mr. James
M. Levine,
Mr. Jack
N. Bailey,
Mr. E. C. Simpson,
.
Mr. Blaine E. Ballard,
Mr. Thomas
R. Bradish,
Mr. Robert
W. Page,
Mr. Arthur C. Gehr, Esq., Snell
8 Wilmer
Mr. A. Gutterman,
Newman
5 Holtzinger P.
C.
Mr. Charles
R. Kocher, Esq., Assistant Council,
SCE Company
Mr. Charles
A. Boeletto, Esq.,
Company
Mr. Charles
B. Brinkman, Combustion Engineering,
Inc.
Mr. Charles Tedford, Director, Arizona Radiation Regulatory Agency
Chairman, Maricopa County Board of Supervisors
Mr. John
W. Norman, Chief, Arizona Corporation
Commission
bcc w/enclosure:
Docket File
Resident
Inspector
Project Inspector
G.
Cook
B. Faulkenberry
J. Martin
N. Western
.T. Alexion, Project Directorate
IV
AM. McCoy,
SRXB/DST,
DProulx@+
11/ b/9O
bcc w/o enclosure:
M. Smith
J. Zollicoffer"
REGION V
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