ML17305B494

Responds to Potential Violation Noted During NRC 910222 Exit Meeting Re Insp Repts 50-528/91-05,50-529/91-05 & 50-530/91-05.Disputes Violation Re Failure of Maint Personnel to Comply W/Util Conduct of Maint Procedure

ML17305B494
Person / Time
Site:	Palo Verde
Issue date:	04/15/1991
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
102-02008-WFC-T, 102-2008-WFC-T, NUDOCS 9104300217
Download: ML17305B494 (6)

Text

ACCELERATED RETRIBUTION DEMONSATION SYSTEM

SUBJECT:

Responds to potential violation noted during NRC 910222 exit meeting re Insp Repts 50-528/91-05,50-529/91-05 6

50-530/91-05.Disputes violation re failure of maint personnel to comply w/util, conduct of maint procedure.

DISTRIBUTION CODE:

IE01D COPIES RECEXVED:LTR t

ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Via%ation Response NOTES:STANDARDIZED PLANT Standardized plant.

Standardized plant.

A 05000528 05000529 D

05000530 D

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9104300217 DOC.DATE: "91/04/15 NOTARXZED: NO DOCKET FACXL:STN-50-528 Palo Verde Nuclear Stat'ion, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 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 MARTXN,J.B.

,Region 5 (Post 820201)

RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M RNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DRIS/DXR NRR/PMAS/ILRB12 OE DIR RE FI EXTERNAL: EGGG/BRYCE, J.H.

NSIC NOTES COPIES LTTR ENCL 1

1 1

.1 2

2, 1

1 1

1 1

1

.1 1

1 1

1 1

1 1

1 1

1 1

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1 1

RECIPIENT ID CODE/NAME TRAMMELL,C AEOD AEOD/TPAB NRR MORISSEAUiD NRR/DLPQ/LPEB10

'NRR/DREP/PEPB9D NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDS 1 RGN5 FILE 01 NRC PDR COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

A D

D PLEASE HELP US TO REDUCE iVASFE! CONTACT THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 20079) TO ELlivIINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

OTAL NUMBER OF COPXES REQUIRED:

LTTR 26 ENCL 26

II WILLIAMF, CONWAY EXECUTIVEVICEPRESIDEIIT NVCI.EAR RI:I f..t'<<ED I'r'C ti""GIO;I V Arizona Public Service Company P.O. 8OX 53999

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PHOENIX, ARIZONA85072.3999 Pfl IIji]( t P Ql P

q 2 102-02008-WFC/TRB/JRB Apr'il'15, 1991 Mr. John B. Martin Regional Administrator, Region V

U.

S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368

Subject:

PaloVerde Nuclear Generating Station (PVNGS)

Units 1, 2,

3

'ocket Nos.

STN 50-528 (License No.

NPF 41)

Docket Nos.

STN 50-529 (License No.

NPF 51)

Docket Nos.

STN 50-530 (License No.

NPF 74)

Potential Violation Identified in NRC Exit Meeting'onducted February 22, 1991

- Inspe'ction Report Nos.

528, 529, 530/91-05 File:- 91-019-026; 91-070-026 During the NRC Exit Meeting conducted February 22,

1991, a potential violation was identified concerning the failure of maintenance personnel to comply with the APS Conduct of Maintenance procedure.

This'xit meeting was at the conclusion of a routine unannounced inspection of maintenance and inservice inspection activities conducted by Inspectors C. A. Clark and D. E. Corporandy from February 5 through February 22, 1991.

APS has subsequently evaluated this NRC concern.

The results of this evaluation are provided as an attachment to this lette'r -for your consideration.

C If you have any questions, please contact T. R. Bradish at (602) 393-2521.

Sincerely, WFC/TRB/JRB/dmn Attachment cc:

Document Control Desk D. H.

Coe A. H. Gutterman A.,C. Gehr 5'104300217 5'10415 PDR ADOCK %000528 0

PDF(

ATTACHMENT NRC Concerns The inspector observed work being performed in conjunction with maintenance work orders (00454762 and 00454763) to install new thinner gauge rings at the inlet flanges for the Unit 1 pressurizer relief valves PSV-200 and PSV-201.

Work was observed to have proceeded to removal of the studs,

nuts, and gasket from the discharge flange of the pressurizer relief valves but there was no signature on the first step of the work order instructions section showing that it was completed.

This step was 'to verify the equipment to be worked on is the same equipment specified by the maintenance instruction.

The inspector also noted that insulation had been removed from the equipment approximately fourteen days prior to the work he observed, but there was no signature showing that the work was preceded by verification that the work was being performed on the correct equipment.

Both examples were characterized as a

failure to comply with the APS departmental procedure 30DP-9MP01, "Conduct of Maintenance",

which states that maintenance instruction steps should be done in sequence unless the work instructions specify otherwise.

APS Evaluation APS believes the inspector's concern was based on his observation of the original copies of work orders 00454762 and 00454763.

As discussed below,and in accordance with established

practice, the original copies of both work orders were left at the radiation protection desk outside of containment and working copies of the appropriate pages of 31MT-9RC11, "Pressurizer Code Safety Valve Removal and Installation", were taken into containment by maintenance personnel.

Work orders were prepared November 15, 1990, for removal of Unit 1 pressurizer relief valves (PSV-200 and PSV-201), inspection of the flanges, and reinstallation with new thinner gauge rings at the valves'nlet flanges.

On January 21 and 22,

1991, a step was added to both work orders in accordance with 30DP-9WP02, "Work Order Development",

as a pen and ink change to remove

'nsulation at the pr'essurizer relief valves'nlet flanges.

Insulation was removed from both valves by the Central Maintenance Insulators on January 22, 1991, per the signed off work order steps and work continuation sheets dated January 22, 1991.

The work continuation sheets documenting the activities performed on January 22, 1991 clearly state that the equipment tags for'the equipment being worked matched the work orders.

This work was documented in accordance with established practices for preparative activities.

On the evening of February 4, 1991, working copies of the work orde'r cover sheets and the applicable pages of 31MT-9RC11 were taken into containment by maintenance personnel and the original copies of the work orders and maintenance procedures were left at the radiation protection desk outside of containment.

Prerequisite 5.8 of 31MT-9RC11, which requires the performer to walk down the component to ensure the component identification number matches the work order and clearance, was signed off by maintenance personnel on the working copies of the maintenance procedures prior to beginning disassembly of the valves'ischarge flanges.

At the end of the shift, signatures were

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B. Martin Attachment, Page 2 of 2 transferred from the working copies of 31MT-9RC11 to the original copies.

Upon reinstallation of the pressurizer relief valves, maintenance personnel realized that step 4.1 of the work orders had not been signed off and signed it off as complete on February 6,

1991.

APS does not believe a violation of departmental procedure 30DP-9MPOl occurred.

Objective evidence exists that maintenance instruction steps were actually completed in sequence, as required; i.e', maintenance personnel did verify they were working on the correct equipment prior to work progressing.

Although APS has concluded that a procedural violation did not occur, the NRC inspector did identify a lack of attention to detail by maintenance personnel in transferring signatures from the working copies of procedures to the original copies.

The potential for problems of this nature has previously been identified by APS and is currently being addressed by tasks intended to simplify the work control process.