ML17310A438
| ML17310A438 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/12/1993 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02564-WFC-T, 102-2564-WFC-T, NUDOCS 9307200214 | |
| Download: ML17310A438 (23) | |
Text
Arizona Public Service Compa'ny
'.O.
BOX 53999
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PHOENIX, ARIZONA85012.3999
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7 WILLIAMF CONWAY EXEcutIVEWCEr REsiOENT NUCLEAR 102-02564-WFCfI'RB/DLK July 12, 1993 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Docket Nos. STN 50-528/529/530 Reply to Notice of Violation 50-529/93-13-01 File: 93-070-026
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Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-529/93-13 and the Notice of Violation dated June 11, 1993. Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
Enclosure 1 to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Enclosure 2.
Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, WFC/TRB/DLK/rv
Enclosures:
1.
Restatement of Notice of Violation 2.
Reply to Notice of Violation cc:
B. H. Faulkenberry J. A. Sloan
ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-529/93-1 3-01 NRC INSPECTION CONDUCTED APRIL 19 THROUGH APRIL 30, 1993 INSPECTION REPORT NO. 50-529/93-13
Restatement of Notice of Violation 50-529 93-13-01 During an NRC inspection conducted during the period of April 19 through 30, 1993, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1993), the violation is listed below:
10 CFR 50.55a (g)(3)(ii) states that components classified as American Society of Mechanical Engineers (ASME) Code Class 1, 2 and 3 shall meet the inservice requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda applied to that particular component (including supports).
Arizona Public Service Company, inservice inspection program for Palo Verde Unit 2, invokes the requirements of ASME Code,Section XI, 1980 Edition including Addenda through the Winter 1981, para.
IWA-2213(a) which states that the visual examination shall be conducted to determine the general mechanical and structural integrity of components and their supports, such as the presence of loose parts, etc.
The licensee's procedure,
'Visual Examination of Support Components,"
73TI-9ZZ1 8, Revision 4, dated 1/1 4/91, states that all accessible bolted connections shall be checked manually ( by hand ) for tightness and abnormal conditions shall be identified and evaluated on an examination report.
Contrary to the above, on April 22, 1993, Palo Verde Inservice Visual Examination Report 93-2316, for steam generator blowndown
[sic]
piping support SG-048-H017, reported that the component associated with this support was examined and evaluated as acceptable.
On April 27, 1993, NRC inspectors performed an independent followup examination of support SG-048-H017 and discovered a nut could be turned by hand on this component, and this abnormal condition was not identified and evaluated in examination report 93-2316 by the licensee.
-This is a Severity Level V violation (Supplement 1), applicable to Unit 2.
Page1 of1
ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION50-529/93-13-01 NRC INSPECTION CONDUCTED APRIL 19 THROUGH APRIL 30, 1993 INSPECTION REPORT NO. 50-529/93-43
0
Re I to Notice of Violation 50-529 93-13-01 Reason for the'iolation On April 22, 1993, APS evaluated the physical condition of pipe support 2SG-048-H017 and determined the mechanical and structural integrity of the support was satisfactory.
On April 27, 1993, the NRC located a loose jam nut on 2SG-048-H017.
Subsequent to the NRC finding, three PVNGS inspectors independently checked the loose jam nut on pipe support 2SG-048-H01 7. Two of the inspectors considered the jam nut tight, the third however, considered it loose.
Each inspector had different physical abilities and each positioned himself differently, relative to the pipe support; when performing the inspections.
APS has concluded that the reasons for the mixed inspection results and the Notice of Violation were the differences in the physical abilities of the inspectors, and the differences in the positions assumed by inspectors when performing these inspections.
Corrective Actions Taken and Results Achieved A Material Non-Conformance Report (MNCR) was written against 2SG-048-H017, the support's jam nut was retightened, and the support was satisfactorily reinspected.
Page 1 of 3
Additionally, approximately 112 pipesupports in Unit 2 were reinspected by an independent third party. The third party inspectors found two loose bolting discrepancies that were not previously identified, and accepted two loose bolting discrepancies that were previously identified. This demonstrates the subjectivity of the inspection criteria.
MNCRs have been written for the rejected supports and the discrepancies have been corrected.
APS considered revising the inspection criteria in'73TI-9ZZ18, 'Visual Examination of Support Components," to eliminate the additional manual check of accessible bolted connections, however, this additional check has been effective in identifying loose components that a visual examination, by itself, would not have detected.
Therefore, APS chose not to change the inspection criteria currently in 73TI-9ZZ18.
Corrective Actions That Wilt Be Taken To Avoid Further Violations The following corrective actions will be performed:
1)
Notice ofViolation 50-529/93-13-01 and this response willbe reviewed with PVNGS Inservice inspection (ISI) Engineers by September 1, 1993.
2)
A briefing will be developed describing the proper technique to use and the optimum position to take when manually checking accessible bolted connections Page 2 of 3
ACCELERATED DOCUMENT DISTRIBUTIONSYSTEM
~I REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
I" 1
ACCESSION NBR:9307200214 DOC.DATE: 93/07/12 NOTARIZED:
NO DOCKET t ACIL:STN-50-529 Palo Verde Nuclear Station, Unit, 2, Arizona Publi 05000529 UTH.NAME AUTHOR AFFILIATION ONWAY,W.F.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 930611 ltr re violations noted in insp rept 50-529/93-13 on 930419-30.C/As:MNCR written aganist 2SG-048-H017,retightened support jam nut
& reinspected support satisfactorily.
DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR l ENCL g SIZE:
7 TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Standardized plant.
t 05000529 RECIPIENT ID CODE/NAME PDV PD TRAN,L INTERNAL: ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/DRIL/RPEB NRR/PMAS/ILPBl NUDOCS-ABSTRACT OGC/HDS1 RES/HFB EXTERNAL: EG&G/BRYCEIJ.H.
NSIC 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 RECIPIENT ID CODE/NAME TRAMMELL,C AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NRR/DRSS/PEPB NRR/PMAS/ILPB2 OE DIR
~EGGILE 0 2 RGNS 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 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR.NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
0
e Arizona Public Service Company P.O 8OX 53999
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PHOENIX, ARIZONA85072-3999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 102-02564-WFC/1 RB/DLK July 12, 1993 U. S. Nuclear Regulatory Commission ATlN: Document Control Desk Mail Station P1-37 Washington, DC 20555
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3
Docket Nos. STN 50-528/529/530 Reply to Notice of Violation 50-529/93-13-01 File: 93-070-026
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.,Arizona Public Service Company (APS) has reviewed NRC Inspection Report
'50-529/93-1 3 and the Notice of Violation dated June 11, 1993. Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
Enclosure 1 to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Enclosure 2.
Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, WFC/TRB/DLK/rv
Enclosures:
1.
Restatement of Notice of Violation 2.
Reply to Notice of Violation cc:
B. H. Faulkenberry J. A. Sloan 150I.'6
-'a7Xe>Q/O
.S07i2 gpss ~o~ 05000529 PDR
I I
l
ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION50-529/93-13-01 NRC INSPECTION CONDUCTED APRIL 19 THROUGH APRIL 30, 1993 INSPECTION REPORT NO. 50-529/93-13
0 I
Restatement of Notice of Violation 50-529 93-13-01 During an NRC inspection conducted during the period of April 19 through 30, 1993, a violation of NRC requirements was identified. In accordance. with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1993), the violation is listed below:
10 CFR 50.55a (g)(3)(ii) states that components classified as American Society of Mechanical Engineers (ASME) Code Class 1, 2 and 3 shall meet the inservice requirements set forth in Section XI of the ASME Boiler and Pressure Vessel Code and Addenda applied to that particular component (including supports).
Arizona Public Service Company, inservice inspection program for Palo Verde Unit 2, invokes the requirements of ASME Code,Section XI, 1980 Edition including Addenda through the Winter 1981, para.
IWA-2213(a) which states that the visual examination shall be conducted to determine the general mechanical and structural integrity of components and their supports, such as the presence of loose parts, etc.
The licensee's procedure,
'Visual Examination of
- Support Components,"
73TI-9ZZ1 8, Revision 4, dated 1/1 4/91, states that all accessible bolted connections shall be checked manually ( by hand ) for tightness and abnormal conditions shall be identified and evaluated on an examination report.
Contrary to the above, on April22, 1993, Palo Verde Inservice Visual Examination Report 93-231 6, for steam generator blowndown
[sic]
piping support SG-048-H017, reported that the component associated with this support was examined and evaluated as acceptable.
On April 27, 1993, NRC inspectors performed an independent followup examination of support SG-048-H017 and discovered a nut could be turned by hand on this component, and this abnormal condition was not identified and evaluated in examination report 93-2316 by the licensee.
This is a Severity Level V violation (Supplement 1), applicable to Unit 2.
Page 1 of 1
I(
ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION50-529/93-13-0 I NRC INSPECTION CONDUCTED APRIL 19 THROUGH APRIL 30, 1993 INSPECTION REPORT NO. 50-529/93-13
H I
l i
)I 1
Re I to Notice of Violation 50-529 93-13-01 Reason for the Violation On April 22, 1993, APS evaluated the physical condition of pipe support 2SG-048-H017 and determined the mechanical and structural integrity of the support was satisfactory.
On April 27, 1993, the NRC located a loose jam nut on 2SG-048-H017.
Subsequent to the NRC finding, three PVNGS inspectors independently checked the loose jam nut on pipe support 2SG-048-H01 7. Two ofthe inspectors considered the jam nut tight, the third however, considered it loose.
Each inspector had different physical abilities and each positioned himself differently, relative to the pipe
- support, when performing the inspections.
APS has concluded that the reasons for the mixed inspection results and
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the Notice of Violation were the differences in the physical abilities of the inspectors, and the differences in the positions assumed by inspectors when performing these inspections.
Corrective Actions Taken and Results Achieved A Material Non-Conformance Report (MNCR) was written against 2SG-048-H017, the support's jam nut was retightened, and the support was satisfactorily reinspected.
Page 1 of 3
Additionally, approximately 112 pipe supports in Unit 2 were reinspected by an independent third party. The third party inspectors found two loose bolting discrepancies that were not previously identified, and accepted two loose bolting discrepancies that were previously identified.
This demonstrates the subjectivity of the inspection criteria.
MNCRs have been written for the rejected supports and the discrepancies have been corrected.
APS considered revising the inspection criteria in 73TI-9ZZ18, 'Visual Examination of Support Components," to eliminate the additional manual check of accessible bolted connections,
- however, this additional check has been effective in identifying loose components that a visual examination, by itself, would not have detected.
Therefore, APS chose not to change the inspection criteria currently in 73TI-9ZZ18.
Corrective Actions That Will Be Taken To Avoid Further Violations The following corrective actions will be performed:
1)
Notice ofViolation 50-529/93-13-01 and this response willbe reviewed with PVNGS Inservice Inspection (ISI) Engineers by September 1, 1993.
2)
A briefing will be developed describing the proper technique to use and the optimum position to take when manually checking accessible bolted connections Page 2 of 3
e-
for tightness.
The briefing will also include a discussion on documenting the technique used and limitations encountered when inspecting bolted connections that are not fully accessible.
The briefing, described above, will be provided to PVNGS ISI Engineers by September 1, 1993.
Contract ISI Inspectors will be briefed during orientation.
3)
Procedure 73TI-9ZZ18 will be revised by September 1, 1993, to include guidance on the proper technique to use and optimum position to take when checking accessible bolted connections for tightness.
Full compliance was achieved on May 18, 1993, when pipe support 2SG-048-H017 was reworked and satisfactorily reinspected, and June 9,
- 1993, when the remaining discrepancies were corrected.
Page 3 of 3