ML17311A166
| ML17311A166 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/01/1994 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-03072-WLS-A, 102-3072-WLS-A, NUDOCS 9408100027 | |
| Download: ML17311A166 (34) | |
Text
j. ~i~~i. j. 7 (ACCELERATED RIDS PROCESSING)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9408100027 DOC.DATE: 94/08/01 NOTARIZED:
NO DOCKET g
FACIL:STN-50-528 Palo Verde Nuclear Station, 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 TH.NAME AUTHOR AFFILIATION STEWART,W.L.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 940624 ltr re violations 6 deviations noted in insp rept 50-528/94-13,50-529/94-13 a 50-530/94-13.
Corrective actions:all breakers identified as being out of position were restored to proper positions.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation esponse P
NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PDIV-3 PD TRAN,L I
ERNAL:
ACRS AEOD/DSP/ROAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E OE ~D
~REG FILE 02 RGN4 FILE 01 EXTERNAL: EGGG/BRYCEiJ.H.
NSIC COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME HOLIAN, B AEOD/DEIB AEOD/DSP/TPAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 RES/HFB NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL'RIDS'ECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACTTHE DOCUMENTCONTROL DESK, ROOM Pl-37 (EXT. 504-2083 ) TO ELIMINATEYOUR NAMEFROM DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
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Arizona Public Service Company P.O. BOX 53999
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PHOENIX. ARIZONA85012-3999 WILLIAML STEWART EXECUTIVEVICEPRESIDENT NUCLEAR 102-03072-WLS/AKK/PJC August 1, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, D. C. 20555
Reference:
Letter dated June 24, 1994, from A. B. Beach, Director, Division of Reactor Projects, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS 0
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 50-530/94-13-02 and Notice of Deviation 50-528/94-13-01 File: 94-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/94-13 and the Notice of Violation and Notice of Deviation dated June 24, 1994.
Enclosure 1 to this letter is a restatement of the Notice of Violation and the Notice of Deviation. APS'esponses are provided in Enclosure 2.
In a telephone conversation on July 20, 1994, between P. J. Coffin, APS, and B. J. Olson, Region IV, Walnut Creek Field Office, APS was granted an extension until August 1, 1994, for submittal of these responses.
The Inspection Report indicates both the violation and the deviation were the result of weak corrective action.
Corrective action effectiveness has also been an APS concern.
The PVNGS Performance Assessment Team determined that corrective action effectiveness was an area in need of additional management attention during its review of fourth quarter 1993 performance data, and an investigation was conducted.
The incident investigation found that not all PVNGS personnel fully understand the root cause effort. This weakness and contributing factors have had a negative impact on the effectiveness of corrective actions.
t An action plan has been drafted to address the weakness identified by the incident investigation. The plan is divided into three phases, each with specifically recommended 9408100027 940801 PDR ADOCK 05000528 8
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notice of Violation 50-530/94-13-02 and Notice of Deviation 50-528/94-13-01 Page 2 corrective actions.
In Phase I, the corrective action program owner and manager willbe assigned.
These individuals will redefine and revise the program with the objectiv'e of improving the effectiveness of corrective actions at PVNGS.
Phase II includes near-term program enhancements such as improving corrective action tools and simplifying the incident investigation and root cause processes.
Phase III contains longer term actions to continue and sustain program improvements.
The draft action plan is currently being
- reviewed, and action assignments and implementation schedules are being developed.
APS is confident that implementation of the proposed action plan will foster an improved corrective action program.
C Should you have any questions, please call Angela K. Krainik at (602) 393-5421.
Sincerely,
'WLS/AKK/PJC
Enclosures:
1.
Restatement of Notice of Violation and Notice of Deviation 2.
Reply to Notice of Violation and Notice of Deviation cc:
L. J. Callan K. E. Perkins K. E. Johnston B. E. Holian
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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION 50-530/94-1 3-02 AND RESTATEMENT OF NOTICE OF DEVIATION 50-528/94-1 3-01 NRC INSPECTION CONDUCTED MARCH 29 THROUGH MAY7, 1994
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Restatement of Notice of Violation 50-530 94-13-02 During an NRC inspection conducted on March 29 through May 7, 1994, a violation of
,NRC requirements was identified.
ln accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
A.
Unit 3 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix Aof Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A,'requires, in part, that written procedures cover onsite electrical systems.
Procedure 43OP-3PG01, Revision 3, "480V Class 1E Switchgear," Appendix J, Step 6, of the instructions for racking out a breaker states that ifthe closing springs did not discharge as indicated by the "springs charged" indicator on the face of the breaker then lift up the manual close lever and push in the manual trip button to discharge the closing springs.
Contrary to the above, on April 6, 1994, after operators racked out a load center breaker and the closing springs did not discharge as indicated by the "springs charged" indicator, the operators did not liftup the manual close lever and push in the manual trip button to discharge the closing springs.
This is a Severity Level IV violation (Supplement
- 1) applicable to Unit 3.
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Restatement of Notice of Deviation 50-528 94-13-01 During an NRC inspection conducted on March 29 through May 7, 1994, one deviation of your response to Violation 528,529,530/9214-02 dated August 7, 1992, was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the deviation is listed below:
The response to Notice of Violation 528,529,530/9214-02 dated August 7, 1992, stated that "Screening criteria and threshold limits would be developed for use by the work group supervisors to identify which instrument loop components that exceed the specified as-found test acceptance criteria required further evaluation by the engineering organization.
~.. Preventative Maintenance and Surveillance Testing procedures would be revised to require the initiation of a CRDR [Condition Report/Disposition Request]
when instruments exceed the screening criteria threshold limits." The response stated that the actions would be completed by November 30, 1992.
Contrary to the above, on March 8, 1994, the preventive maintenance procedures for emergency diesel generator low lube oil pressure switches were not revised to require the initiation of a CRDR when the instruments exceeded the screening criteria threshold limits.
These instrument loop components, which were the subject of Violation 528,529, 530/9214-02, were calibrated 33 times between November 1992 and March 1994 and the screening criteria threshold limit was exceeded 25 times.
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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION 50-530/94-1 3-02 AND REPLY TO NOTICE OF DEVIATION 50-528/94-'I 3-01 NRC INSPECTION CONDUCTED MARCH 29 THROUGH MAY7, 1994
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REPLY TO NOTICE OF VIOLATIONA 50-530 94-13-02 Reason For The Violation While this violation and the previous non-cited violation identified in Inspection Report No. 94-09 each address problems with breakers, there are two somewhat different issues involved.
The present violation involves a failure to ensure the closing springs were discharged on a breaker racked into the disconnect position; the non-cited violation involved breakers, primarily spares, that were found to be improperly positioned as indicated by open racking shutters.
The corrective actions for the non-cited violation were not fully effective, in part, because only the issue of the mispositioned spare breakers was addressed.
The April 6, 1994, incident cited in the present violation was the result of personnel error due to inattention to detail.
While racking out breakers, Unit 2 personnel (non-licensed auxiliary operators) assisting with the Unit 3 outage failed to observe that the closing springs on one breaker did not discharge, and therefore, omitted the procedural steps for manually discharging the closing springs.
A similar incident involving Unit 3 personnel occurred on February 25, 1994.
That incident, too, was attributable to personnel error.
The APS review of these incidents found that the position of the closing springs 1 of 10
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when breakers are in the disconnected position has no impact or consequence on breaker condition, and there is no safety significance.
APS has determined that the applicable procedures are overly prescriptive and will be revised.
The second breaker issue is the mispositioned 480V spare breakers identified on February 28, 1994, which resulted in the non-cited violation. A similar incident occurred on April 25, 1994, during work in progress in Unit 3.
Operations supervision identified another mispositioned breaker and had.it immediately corrected.
The APS investigation identified a weakness in the Operations/Maintenance interface with regard to positioning the spare breakers following preventive maintenance.
This weakness may have contributed to the problem ofthe mispositioned spare breakers.
The most probable explanation for both the February 28, 1994, and April 25, 1994, incidents involves a manipulation ofthe breakers that was not clearly understood between Operations and Maintenance personnel.
The 480V breakers have three actual positions:
(1) Connected; (2) Test, and (3) Disconnected.
The breakers can be racked out further than the disconnected position to a "fullydrawn out" condition which releases all restraints from the breaker and allows it to be removed from its cubicle.
The breakers under discussion were in the fully drawn out condition.
It is probable that during maintenance some electricians may have left the breakers in the fully drawn out condition rather than in the disconnected position, and operators may not have been cognizant of the fully drawn out condition in which the breakers were left.
The applicable Operations and 2 of 10
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Maintenance procedures did not address the fully drawn out condition versus the disconnected position, and not all AOs and electricians may have understood the difference.
Corrective Action Ste s That Have Been Taken And The Results Achieved All of the breakers identified as being out of, position were restored to the proper positions.
A walkdown was conducted in each unit that confirmed the 480V load center breakers are properly positioned.
The walkdowns were documented in the control room logs.
To address the weak interface between Operations and Maintenance with regard to racking out spare breakers, a night order has been issued in each unit to reinforce
-operating crew responsibilities for breaker positioning, and the applicable Operations procedures have been revised to include a description of the fully drawn out breaker condition.
Maintenance electricians in all three units and in the Central Maintenance Department were briefed regarding the improperly positioned breakers.
In addition, a communications standard has been implemented to improve communications among Operations, Maintenance, Radiation Protection, and Chemistry personnel.
Briefings have been conducted with the appropriate personnel in each organization, and the applicable procedures have been revised to include guidelines forspecific communication principles.
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Corrective Action Ste s That Will Be Taken To Avoid Further Violations As a refresher course, Nuclear Training has prepared a "breaker lab" for AOs that will be conducted during the upcoming requalification cycle. The breaker lab willinclude a job performance measure on the proper racking of breakers.
It is expected that training for incumbent AOs will be completed by August 19, 1994.
The Operations procedures that address racking both the class 1E and non-class 480V breakers will be revised to eliminate the requirement to manually discharge the closing springs.
These procedure revisions will be completed by August 15, 1994.
To further address the Operations/Maintenance interface,,a step will be added in the electrical PMs for the 480V breakers to require electricians to call the control rooms and ask Operations for instructions regarding the desired as-left position for a breaker that has been restored to its cubicle following maintenance.
A note will also be added to define the disconnected position for the electricians.
In addition, the incident investigation regarding the breaker concerns identified on February 28, 1994, will be presented in Industry Events Training for both AOs and electricians.
This training is-scheduled for completion by October 30, 1994.
PVNGS Engineering reviewed the incident-investigation discussed above for seismic concerns.'hat review determined that the corrective actions to require the 480V breakers to be maintained in the Connected, Test, or Disconnected positions will also 4of10
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Date When Full Cpm liance Will Be Achieved Full compliance was achieved on April 6, 1994, when the Unit 3 breaker was properly positioned.
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REPLY TO NOTICE OF DEVIATION 50-528-94-13-01 Reason For The Deviation The corrective actions specified in the response to Notice of Violation (NOV) 528/92-14-02 were erroneously limited to plant instruments used to satisfy the technical specifications.
Therefore, the corrective actions were applied only to (1) instrument surveillance tests and (2) preventive maintenance (PM) procedures for the calibration of select additional safety-related and quality augmented instruments used to comply with technical specification Umiting Conditions for Operation.
Atthe time the NOV corrective actions were developed, it was incorrectly assumed the emergency diesel generator (EDG) lube oil low pressure switches were included with the PM procedures in the second category above.
This was not the case, and the EDG lube oil low pressure switches were inadvertently excluded from the corrective actions to resolve the NOV.
The limitation of the corrective action scope to only technical specification-related instruments also resulted in the failure to consider the potential safety significance of out-of-calibration conditions of other safety-related instruments in general.
This error is attributed to the use of overly simplified assumptions in defining the scope of equipment affected by the original deficiency by personnel developing the corrective action plan.
Further, some ofthe corrective actions specified in the NOVresponse were neither well communicated to nor understood by the PVNGS organizations involved in the 6 of 10
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implementation of them.
Responsibilities for performing out-of-calibration evaluations were shifted among PVNGS organizations without adequate assurance that the requirements for performing the evaluations were properly understood.
This resulted in poor corrective action implementation and an inappropriate reliance on related plant programs, such as the Failure Data Trending Program, to identify and trend components found to be out-of-calibration.
This error is attributed to the failure to clearly identify a lead organization responsible for ensuring the corrective actions were effectively implemented.
Finally, corrective action effectiveness was not adequately reviewed. Weaknesses identified in the implementation of the NOV corrective actions wel'e not aggressively pursued to resolution.
This error is attributed to weaknesses in the area of corrective action effectiveness at PVNGS.
Corrective Ste s That Have Been Taken And The Results Achieved The preventive maintenance (PM) calibration procedures for the EDG lube oil low pressure switches have been revised to include a requirement to initiate a request for an engineering evaluation (e.g, Condition Report/Disposition Request) when out-of-calibration test results are identified.
In addition, PM calibration procedures for the essential chiller lube oil low differential pressure switches, as identified in the text of Inspection Report 94-13, have also been revised to include a requirement to initiate a request for an 7of10
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engineering evaluation when out-of-calibration test results are identified. These actions will preclude recurrence of the specific concerns in the Notice of Deviation (NOD).
As discussed in APS'over letter to this response, a plant-wide investigation of corrective action effectiveness at PVNGS has recently been completed.
The recommendations from the investigation will be used to strengthen the overall effectiveness of PVNGS'orrective action program.
Corrective Ste s That Will Be Taken To Avoid Further Deviations A category 3 incident investigation was initiated to investigate the out-of-calibration program and to identify the root cause of the failure to resolve the original deficiencies t
identified in NOV 92-14-02.
The investigation included the following major activities:
(A)
A review of applicable regulatory requirements and industry guidance was conducted to clearly identify the basis for performing evaluations of out-of-calibration test results.
(B)
A comprehensive review of safety-related plant instruments was conducted to ensure that instruments subject to out-of-calibration evaluation requirements are identified and included in the corrective action plan. This review included quality augmented instrumentation and selected non-safety-related instrumentation to ensure no relevant instruments would be inadvertently excluded from the scope of the corrective actions.
From this review a list of l&C components that require out-of-calibration evaluations 8 of 10
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has been compiled.
(C)
A review of the existing out-of-calibration reporting (Failure Data Trending) and evaluation (CRDR) processes was conducted to determine the effectiveness of corrective actions implemented to date.
This review also encompassed the plant work processes involved in performing instrument calibrations, as well as the organizations currently involved in the identification, reporting, and evaluation of out-of-calibration conditions.
The investigation is ongoing. To date, recommendations to prevent recurrence of the deficiencies include:
(1)
Designate a program owner to ensure the requirements for conducting out-of-calibration evaluations are understood and the evaluations are performed in an effective and timely manner.
The Nuclear Engineering
- Division, Electricai/Instrumentation
& Controls (I&C) Department, Setpoints Group, has been designated as the lead organization responsible for implementation ofthe corrective actions specified in this response including a subsequent evaluation of the effectiveness of these corrective actions in resolving the identified deficiencies.
I&C Maintenance Engineering has been designated as the lead organization responsible for conducting the evaluations of out-of-calibration test results. Consolidation ofthe evaluation responsibilities in the maintenance area will ensure calibration failures receive prompt review by engineering personnel and provides for 9of10
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consistency and thoroughness in the evaluations.
The assignment ofthese program owners will establish accountability and continuity.
(2)
Use the list of l&C components subject to out-of-calibration evaluations (Item B above) to ensure the associated calibration procedures are revised to include a requirement to obtain engineering evaluations of out-of-calibration (i.e., as-found) test results.
(3)
Conduct a sample review of the calibration history of selected components that are not calibrated under either the surveillance test or the Operations No Waive PM programs.
This review will provide assurance that safety significant issues are receiving engineering attention, and there are appropriate corrective actions.
(4)
Assess corrective action implementation to ensure corrective actions are complete and effective.
Date When Corrective Action Will Be Com leted Action 1 above is complete.
Revision of the PM calibration procedures discussed in Action 2 will be completed by September 22, 1994, and the sample review in Action 3 will be completed by November 21, 1994.
The corrective action implementation assessment (Action 4) is expected to be completed by February 21, 1995.
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