ML17305B690
| ML17305B690 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/13/1991 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02055-WFC-T, 102-2055-WFC-T, NUDOCS 9108220240 | |
| Download: ML17305B690 (29) | |
Text
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
~
PHOENIX, ARIZONA85072-3999 102-02055-WFC/TRB/PJC AIigust 13.
1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station: P1-37 Washington, DC 20555
~
~
Reference:
Letter from D. F. Kirsch, Chief, Reactor Safety Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, Arizona Public Service, dated July 16, 1991.
Gentlemen:
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION50-528/91-21-0'I NRC INSPECTION REPORT NOS. 50-528/91-21, 50-529/91-21 and 50-530/91-21 File: 91-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528, 529, 530/91-2$ and the Notice of Violation dated July 16, 1991.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is attached.
Appendix A to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Attachment 1.
The referenced letter and attendant Inspection Report note that the NRC considers additional management attention to be required in the area of fire protection.
APS had recognized that the range of activities necessary to attain a successful fire protection program was large enough to warrant separate departmental status. Accordingly, on July 3, 1991, a new Fire Protection Program Department was formed, and a dedicated manager with extensive fire protection experience was appointed.
The Manager of the Fire Protection Program Department is accountable for all aspects of the program including engineering support, on-site implementation of fire prevention activities, and emergency response.
For example, he is responsible for the resolution of APS-identified, programmatic issues such as thermo-lag configuration control.
Three specific items were identified in the Inspection Report as needing improvement:
(1) procedures addressing allowed volumes of combustible liquids and verification of backup fire pump operability need clarification; (2) fire brigade lesson plans need to focus upon problems and hazards unique to Palo Verde; (3) fire brigade practices
~o>
0 8g
l l
NRC Document Control Desk Page 2 102-02055-MFC/TRB/PJC August 13, 1991 and performance need attention and improvement.
APS acknowledged these concerns at the exit meeting and resolution has been initiated. A major effort is currently underway to revise and enhance Fire Protection Program procedures.
Fire Department lesson
- plans, practices, and performance are being evaluated.
Upon completion of the evaluation the appropriate course of action will be taken.
Should you have any questions regarding this response, please contact me.
Very truly yours, WFC/TRB/PJC/dmn Attachments Appendix A - Notice of Violation 2.
Attachment 1 - Reply to Notice of Violation CC:
J. B. Martin D. H. Coe A. H. Gutterman A. C. Gehr
APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION60-528/91-21-01 NRC INSPECTION CONDUCTED JUNE 3, 1991 - JUNE 12, 1991 INSPECTION REPORT NOS. 60-628/9'I-21, 629/91-21 AND 630/91-21
RESTATEMENT OF NOTlCE OF VlOLATION50-528 91-21-01 During an NRC inspection conducted from June 3 to June 12, 1991, a 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 (1991), the violation is listed below:
NPF-41 License Condition C (7), Fire Protection Program, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility.
Contrary to the above, on June 6, 1991, fire barrier material, required by the approved fire protection program, was missing from an HVACspool piece for a damper in the Unit 1 "B"auxiliary feedwater pump room. This material had been removed during October 1990 in accordance with Work Request 778204 to permit inspection of the damper.
This is a Severity Level IV Violation, Supplement I.
P Page 1
I, I'
t
~;i
ATTACHMENT1 REPLY TO NOTICE OF VIOLATION50-628/91-21-01 NRC INSPECTION CONDUCTED JUNE 3, 1991 - JUNE 12, 1991 INSPECTION REPORT NOS. 60-528/91-21, 529/91-21 AND 630/91-2'f
l,
REPLY TO NOTICE OF VIOLATION50-528 91-21-01 Reason for the Violation The concern addressed by this violation is that an Appendix R thermo-lag fire barrier protecting train A auxiliary feedwater pump conduits ARK 66 and 67 was breached without implementation ofthe fire system impairment program. APS has determined the violation occurred because thermo-lag found during an in-process work order was not properly designated as an Appendix R requirement by Work Planning personnel who were advising the workers in the field. The error was the result of an incomplete review of design documents by the Work Planners.
A contributing factor to the incomplete review was the lack of cross-references on the two design drawings needed to determine Appendix R requirements at the 81'-
0" and 100'-0" elevations of the Main Steam Support Structure (MSSS).
Work Request No. 778204 (Work Order No. 00453382) was written to remove spool pieces from various Unit 1 fire dampers to permit visual inspection of the dampers in accordance with procedure 14FT-1FP30, "Inspection of Fire Area Boundaries, Thermo-lag, Spray-on Fireproofing, and Fire Dampers."
The original scope of work identified did not involve thermo-lag removal.
Therefore, the Fire Protection Program requirement for 'an approved Fire Barrier Seal Removal Request was not applicable to the initial work package.
During work on damper 1-M-HAN-M40in Auxiliary Feedwater Pump (AFP)
Room "B" at the 81'-0" elevation of the Unit 1 MSSS building, thermo-lag conduit Page 1 of 3
I, 1
insulation was found which would have to be removed in order to allow access to the bolting which secured the damper spool piece. Work was suspended and the package returned to the Planning Department to determine Appendix R
applicability.
Planning personnel reviewed drawing 01-E-ZCC-076, Revision 11, MSSS 10 CFR 50 A x "R" Installation Plan at El. 81'0" 8 El. 100'-0" and concluded there were no Appendix R-required thermo-lag installations at the 81-0" elevation; therefore, authorization was given to remove the section of thermo-lag for access to the damper without the initiation of appropriate compensatory measures.
The investigation following the event revealed that a second drawing, 01-E-ZCC-079, with the same title does identify Appendix R-required thermo-lag
~ C installations at the MSSS 81 '-0" elevation. The information provided in each of the drawings is correct, but in order to obtain full information both drawings are needed to determine Appendix R requirements.
Planning personnel were 'not aware of the second drawing, and neither drawing 01-E-ZCC-076 nor 01-E-ZCC-079 contains a reference to advise the user of the existence of the other.
Corrective Ste s That Have Been Taken and the Results Achieved Although a fire impairment was not specifically implemented to control this degraded barrier, a firewatch with hourly tours was already established on the MSSS 81'-0" elevation for other considerations.
Upon discovery and identification of the degraded barrier, Fire Impairment 1-91-125 which identified the impairment Page 2 of 3
1
to the firewatch was issued. The thermo-lag was reinstalled on July 6, 1991, under an approved work document in accordance with procedure 14AC-9FP02, "Fire Barrier Seal and Structural Steel Fireproofing Removal and Reinstallation."
3.
Corrective Ste s That Will Be Taken To Avoid Further Violations On June 24, 1991, appropriate Work Planning personnel were briefed on the potential for confusion in working with fire barrier design drawings.
The briefing emphasized the need to perform thorough design document reviews and to seek Engineering assistance when questions arise.
Design change notices (DCN's) to add reference notes to the MSSS 81 '-0" and 100'-0" elevation Appendix R thermo-lag drawings were approved on July 25,
~ 4 1991.
These references will alert users to the existence of both documents.
In addition, the drawings which reflect Appendix R thermo-lag configuration were reviewed for similar cases where more than one drawing is needed to determine Appendix R installation requirements.
The review was completed on July 25, 1991.
No additional cases were identified.
4.
Date When Full Com liance Will be Achieved Full compliance was achieved on June 6, 1991, when Fire Impairment No.
1-91-1 25 was implemented.
Page 3 of 3
P
, ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DXSTRIBUTION SYSTEM (RXDS)
CESSION NBR:9108220240 DOC.DATE-91/08/13 NOTARXZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 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 910716 ltr re violations noted in Insp Rept
- 50-528/91-21.,Corrective actions
- fire watch,w/hourly tours, established on main steam support structure
& thermolog reinstalled on 910706 under approved work document.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt}-Xnsp Rept/Notice of Violation Response D
NOTES:STANDARDIZED PLANT RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M INTERNAL: ACRS AEOD/DEIIB DEDRO NRR SHANKMAN,S t
NRR/DOEA/OEAB NRR/DST/DIR 8E2 NRR/PMAS/XLRB12 Ok~))~
REG FXLE 02 EXTERNAL: EGGG/BRYCE,J.H.
NSXC 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 1
1 RECXPXENT ID CODE/NAME TRAMMELL,C AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/OTSB 11E22 NUDOCS-ABSTRACT OGC/HDSl RGN5 FILE 01 NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
1
/
05000528 A
D D
1 1
NOTES P~ fl>7<5/ f D
D NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, t
ROOM PI-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL 26
~f
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
~
PHOENIX. ARIZONA85072-3999 102-02055-MFC/TRB/PJC August 13, 1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station: P1-37 Washington, DC 20555
Reference:
Letter from D. F. Kirsch, Chief, Reactor Safety Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, Arizona Public Service, dated July 16, 1991.
Gentlemen:
SUBJECT'ALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION50-528/91-21-01 NRC INSPECTION REPORT NOS. 50-528/91-21) 50-529/91-21 and 50-530/91-21 File: 91-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528, 529, 530/91-21 and the Notice of Violation dated July 16, 1991.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is attached.
Appendix A to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Attachment 1.
The referenced letter and attendant Inspection Report note that the NRC considers additional management attention to be required in the area of fire protection.
APS had recognized that the range of activities necessary to attain a successful fire protection program was large enough to warrant separate departmental status. Accordingly, on July 3, 1991, a new Fire Protection Program Department was formed, and a dedicated manager with extensive fire protection experience was appointed.
The Manager of the Fire Protection Program Department is accountable for all aspects of the program including engineering support, on-site implementation of fire prevention activities, and emergency response.
For example, he is responsible for the resolution of APS-identified, programmatic issues such as thermo-lag configuration control.
Three specific items were identified in the Inspection Report as needing improvement:
(1) procedures addressing allowed volumes of combustible liquids and verification of backup fire pump operability need clarification; (2) fire brigade lesson plans need to focus upon problems and hazards unique to Palo Verde; (3) fire brigade practices 91082202 K o~opp52 po 910813 PDR ADOC pDp 9
o
NRC Document Control Desk Page 2 102-02055-MFC/TRB/PJC August 13, 1991 and performance need attention and improvement.
APS acknowledged these concerns at the exit meeting and resolution has been initiated. A major effort is currently underway to revise and enhance Fire Protection Program procedures.
Fire Department lesson
- plans, practices, and performance are being evaluated.
Upon completion of the evaluation the appropriate course of action will be taken.
Should you have any questions regarding this response, please contact me.
Very truly yours, WFC/TRB/PJC/dmn Attachments 1.
Appendix A - Notice of Violation 2.
'ttachment 1 - Reply to Notice of Violation cc:
J. B. Martin D. H. Coe A. H. Gutterman A. C. Gehr
APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION50-528/91-21-01 NRC INSPECTION CONDUCTED JUNE 3, 1991 - JUNE 12, 1991 INSPECTION REPORT NOS. 50-528/91-21, 529/91-21 AND 530/91-21
RESTATEIVlENT OF NOTICE OF VIOLATION50-528 95-21-01 During an NRC inspection conducted from June 3 to June 12, 1991, a violation of NRC requirements was identified.
tn accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1 991), the violation is listed below:
NPF-41 License Condition C (7), Fire Protection Program, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility.
Contrary to the above, on June 6, 1991, fire barrier material, required by the approved fire protection program, was missing from an HVACspool piece for a damper in the Unit 1 "B"auxiliary feedwater pump room. This material had been removed during October 1990 in accordance with Work Request 778204 to permit inspection of the damper.
This is a Severity Level IV Violation, Supplement I.
Page 1
ATTACHMENT1 REPLY TO NOTICE OF VIOLATION50-528!91-21-01 NRC INSPECTION CONDUCTED JUNE 3, 1991 - JUNE 12, 1991 INSPECTION REPORT NOS 50-528l91-21, 529l91 "21 AND 530/91-21
REPLY TO NOTICE OF VIOLATION50-528 91-21-01 Reason for the Violation The concern addressed by this violation is that an Appendix R thermo-lag fire barrier protecting train A auxiliary feedwater pump conduits ARK 66 and 67 was breached without implementation ofthe fire system impairment program. APS has determined the violation occurred because thermo-lag found during an in-process work order was not properly designated as an Appendix R requirement by Work Planning personnel who were advising the workers in the field. The error was the result of an incomplete review of design documents by the Work Planners.
A contributing factor to the incomplete review was the lack of cross-references on the two design drawings needed to determine Appendix R requirements at the 81'-
0" and 100'-0" elevations of the Main Steam Support Structure (MSSS).
Work Request No. 778204 (Work Order No. 00453382) was written to remove spool pieces from various Unit 1 fire dampers to permit visual inspection ofthe dampers in accordance with procedure 14FT-1 FP30, "Inspection of Fire Area Boundaries, Thermo-lag, Spray-on Fireproofing, and Fire Dampers."
The original scope of work identified did not involve thermo-lag removal ~ Therefore, the Fire Protection Program requirement for an approved Fire Barrier Seal Removal Request was not applicable to the initial work package.
During work on damper 1-M-HAN-M40in Auxiliary Feedwater Pump (AFP)
Room "B" at the 81'-0" elevation of the Unit 1 MSSS building, thermo-lag conduit Page1 of3
insulation was found which would have to be removed in order to allow access to the bolting which secured the damper spool piece. Work was suspended and the package returned to the Planning Department to determine Appendix R
applicability.
Planning personnel reviewed drawing 01-E-ZCG-076, Revision 11, MSSS 10 CFR 50 A x "R" Installation Plan at El. 81'0" 8 El. 100'-0" and concluded there were no Appendix R-required thermo-lag installations at the 81-0" elevation; therefore, authorization was given to remove the section of thermo-lag I
for access to the damper without the initiation of appropriate compensatory I
measures.
The investigation following the event revealed that a second drawing, 01-E-ZGC-079, with the same title does identify Appendix R-required thermo-lag installations at the MSSS 81 '-0" elevation. The information provided in each of the drawings is correct, but in order to obtain full information both drawings are needed to determine Appendix R requirements.
Planning personnel were not aware of the second drawing, and neither drawing 01-E-ZCC-076 nor 01-E-ZCC-079 contains a reference to advise the user of the existence of the other.
2.
Corrective Ste s That Have Been Taken and the Results Achieved Although a fire impairment was not specifically implemented to control this degraded barrier, a firewatch with hourly tours was already established on the MSSS 81'-0" elevation for other considerations.
Upon discovery and identification of the degraded barrier, Fire Impairment 1-91-125 which identified the impairment Page 2 of 3
to the firewatch was issued.
The thermo-lag was reinstalled on July 6, 1991, under an approved work document in accordance with procedure 14AC-9FP02, "Fire Barrier Seal and Structural Steel Fireproofing Removal and Reinstallation."
3.
Corrective Ste s That Will Be Taken To Avoid Further Violations On June 24, 1991, appropriate Work Planning personnel were briefed on the potential for confusion in working with fire barrier design drawings.
The briefing emphasized the need to perform thorough design document reviews and to seek Engineering assistance when questions arise.
Design change notices (DCN's) to add reference notes to the MSSS 81 '-0" and 100'-0" elevation Appendix R thermo-lag drawings were approved on July 25, 1991.
These references will alert users to the existence of both documents.
In addition, the drawings which reflect Appendix R thermo-lag configuration were reviewed for similar cases where more than one drawing is needed to determine Appendix R installation requirements.
The review was completed on July 25, 1991.
No additional cases were identified.
4.
Date When Full Com liance Will be Achieved Full compliance was achieved on June 6, 1991, when Fire Impairment No.
1-91-125 was implemented.
Page 3 of 3