ML17306B087

Responds to NRC 920706 Ltr Re Violations Noted in Insp Rept 50-528/92-14,50-529/92-14 & 50-530/92-14.Corrective Actions Taken:Review I&C Surveillance Procedures Verifying Required M&TE Is Properly Identified in Special Test Section

ML17306B087
Person / Time
Site:	Palo Verde
Issue date:	08/31/1992
From:	Conway W ALABAMA PUBLIC SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17306B086	List: ML17306B087
References
102-02261-WFC-T, 102-2261-WFC-T, NUDOCS 9211020090
Download: ML17306B087 (5)

Text

RECEl ".Ei HRC 0 WII.UAMF. CONWAY Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX. ARIZONA85072-3999 REGION V

'92 SEP 102-02261-MFC/TRB/DLK

-3 Alo:03 EXECUTIVEVICEP4ESOENT NUCI.EA4 August 31, 1992 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

References:

1) NRC Inspection Report 50-528, 529, and 530/92-14, dated July 6, 1992

2) Letter 102-02230, dated August 7, 1992, from W. F. Conway, APS, to NRC, "Reply to Notice of Violation 50-528/92-14-03"

Subject:

Palo Verde Nuclear Generating Station {PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50/528/529/530 Assessment of Compliance with Procedural Requirements for Measuring and Test Equipment {M&TE) Usage File: 92-056-026 Arizona Public Service Company (APS) has completed the assessment of compliance with procedural requirements for M8 TE usage, as requested in the letter that transmitted Reference 1. The enclosure to this letter provides the results of that assessment, including the planned corrective actions as committed to in Reference 2.

lf you should have any questions, please contact Thomas R. Bradish at (602) 393-5421.

Sincerely,

'&'~~/$ 4 Arc' p,.

WFC/TRB/DLK/pmm

Enclosure:

Assessment Results of Compliance with Procedural Requirements for Measuring and Test Equipment (M8TE) Usage cc: J. B. Martin J. A. Sloan

'II21 10200'IIO 'II21021 PDR ADOCK 05000528 8 PDR

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> l ENCLOSURE 1 ASSESSMENT RESULTS OF COMPLIANCE WITH PROCEDURAL REQUIREMENTS FOR MEASURING AND TEST EQUlPMENT (M&TE) USAGE NRC INSPECTION CONDUCTED APRIL 27 - JUNE 5, 1992 INSPECTION REPORT NOS. 50-RN, 529, AND 530/92-14

ASSESSMENT RESULTS OF COMPLIANCE WITH PROCEDURAL REQUIREMENTS FOR MEASURING AND TEST EQUIPMENT (M&TE) USAGE The urve'llance procedures I used to calibrate safety-related instrumentation at PVNGS, define the range and accuracy requirements for MT&E needed to satisfacto oril'y accomplish the procedure in the "Special Test Equipment" section. This section also frequently includes suggested M8TE that is generally readily available, meets the defined range and accuracy requirements, but Is.not required to satisfactorily accomplish the procedure. The majority of I8C surveillance procedures, that require the use of a pressure gauge, do not specify the M&TE in the "instruction" section of the procedure.

The test performer selects the proper M&TE using the guidance provided in the "Special Test Equip 'ent" section and basic craft knowledge and skNs obtained through training 4 ~

and work experience. Basic craft knowledge and skills are not considered an alter native to following procedural requirements and should not have been used to substitute M8TE that was procedurally spec Tiied, as discussed in References 1 and 2.

Finally, a review was performed on a selected sample of completed surveillance tests

{approximately 20) in which the M&TE used was different than the suggested M8TE. In all cases, the M&TE used met the procedurally defined M&TE requirements.

Based on these facts, Arizona Public Service Company Is confident that M&TE used at PVNGS Is of the proper range and accuracy to optimally calibrate and maintain safety-related Instrumentation in compliance with Technical Specifications. Furthermore, ualified test iformers St PYNGS possess the necessary skills to properly select M8TE using procedural guidance l that defines the range and accuracy requirements. Howeve, to avoid further violations similar to 528/92-14-03 the following corrective actions will be taken:

1) The I&C surveillance' procedures, that require the use of a pressure gauge, will be reviews d to ve rify the required MBTE is properly identified in the "Special Test Equipment" section. tn order to provide consistency, where there is no justification to specify M&TE in the "instruction" section, the surveillance procedures will be revised to allow the test performer to select the appropriate M8TE based on the guidance provided in the "Special Test Equipment" section. These revisions will be completed by July 31, 1993.

2) The l&C Safety System Functional Inspection Report (92-14) and Condition Re ort/Disposition Request 920356 will be incorporated into the Training Change System for evaluation and inclusion in appropriate training by D

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