ML17311A256
| ML17311A256 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/29/1994 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-03098-WLS-A, 102-3098-WLS-A, NUDOCS 9409140025 | |
| Download: ML17311A256 (30) | |
Text
P R.IC3H.IWY 1
(ACCELERATED RlDS P ROC ESSIVE G)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ESSION NBR:9409140025 DOC.DATE: 94/08/29 NOTARIZED: NO DOCKET CIL: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 AUTH.NAME AUTHOR AFFILIATION STEWART,W.L.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION R
Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC violations noted in insp rept 50-528/94-20, I
50-529/94-20
& 50-530/94-20.Corrective action:temperature monitoring requirements will be added to procedures in three 0
units which are used to bring plants from MODE 5 to MODE 3.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR L ENCL I
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R TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
05000528 I
05000529 05000530 RECIPIENT ID CODE/NAME PD4-2 PD TRAN,L RNAL ACRS AEOD/SPD/RAB AEOD/TTC NRR/DORS/OEAB NRR/PMAS/IRCB-E O~DIR EG F~
02 RGN4 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
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1 RECIPIENT ZD CODE/NAME HOLIAN, B AEOD/DEIB AEOD/SPD/RRAB DEDRO NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 RES/HFB NOAC COPIES LTTR ENCL 1
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U NOTE TO ALL"RIDS" RE CI PI ENTS:
PLEASE HELP US TO REDUCE iVASTE!CONTACI'THE DOCUilENTCONTROL DESK, ROOKI P I -37 (EXT. 504-2083 ) TO EL IXII.'PATE YOUR NAME FROW!
DISTRIBUTIONLISTS FOR DOCUMENTS YOU DON"I'LED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
Arizona Public Seivice Company P.O. BOX 53999
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PHOENIX, ARIZONA850T2<999 WILLIAML. STEWART EXECUTIVEVICEPRESIDENT NUCLEAR 102-03098-WLS/AKK'/RAB August 29, 1994 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington,DC 20555
Reference:
Letter dated July 29, 1994, from A. B. Beach, USNRC, to W. L. Stewart, APS.
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 60-528/529/630 Reply to Notice of Violations 530/94-20-01 and 528/94-20-05 File: 94-070-026 Arizona Public Service Company (APS) has reviewed NRC inspection Report 50-528/529/530/94-20 and the Notice of Violations dated July 29, 1994. Pursuant to the provisions of 10 CFR 2,201, the APS responses are enclosed.
Enclosure 1 to this letter is a restatement ofthe Notice ofViolations, The APS responses are provided in Enclosure 2.
The referenced letter also noted that APS had committed to reassess its position on diesel generator reliabilitytesting in accordance with Regulatory Guide 1.108 as itpertains to what have. been considered valid and successful tests of the diesel generators at Palo
'erde.
APS has completed this reassessment.
Should you have any questions, please contact Ms. Angela K. Krainik at (602) 393-5421.
WLS/AKK/RAB/dpr
Enclosures:
1.
Restatement of Notice of Violations 2.
Reply to Notice of Violations 9409140025 940829 PDR ADOCK 05000S28 PDR
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U. S. Nuclear Regulatory Commission
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ATTN: Document Control Desk Reply to Notice of Violations 530/94-20-01 8 528/94-20-05 Page 2 cc:
L. J. Callan K. E. Perkins K. E. Johnston B. E. Holian
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ENCLOSURE 1
.,RESTATEMENT OF NOTICE OF VIOLATIONS 630/94-20-01 AND 528/94-20-05 NRC INSPECTION CONDUCTED MAY8s 1994 THRU JUNE 11< 1994 NRC INSPECTION REPORT 60-528/529/530/94-20 V
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Restatement of Notice of Violations 50-530 94-20-01 and 50-528 94-20-05 During an NRC inspection conducted on May 8 through June 11, 1994, two violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
A.
Unit 3 Technical specification 6.8.1 requires, in part, that written procedures be established and implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, dated February 1978.
Regulatory Guide 1.33, Revision 2, Appendix A, requires, in part, written procedures for operation of the auxiliary feedwater system.
Procedure 43ST-3AF02, Revision 7,
"Auxiliary Feedwater Pump AFA-P01 Operability Test 4.7.1.2.a & c," states in prerequisite Step 7.10 to "ensure that the system is aligned for automatic operation per 43OP-3AF01."
Procedul e 43OP-3AF01, Revision 6, "Essential AuxiliaryFeedwater System," states in precautions and limitations Step 3.27.6 that "if AFA-P01 steam supply piping temperature is <193 degrees F as measured using the X21 Micro-logger, then a backup reading shall be performed using the hand-held pyrometer."
Contrary to the above, on June 8, 1994, the steam supply piping temperature read 77 degrees F and a backup reading was not obtained using a hand-held pyrometer prior to operating AuxiliaryFeedwater Pump AFA-P01. As a result, the pump was started in a cold condition and subsequently tripped.
This is a Severity Level IV violation (Supplement I) applicable to Unit 3.
B..
10 CFR Part 50; Appendix B, Criterion V; requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Procedure 93AC-ONS01, "10 CFR 50.59 SCREENING AND EVALUATION,"
provides instructions for performing 10 CFR 50.59 evaluations and indicates that NRC approval is required prior to implementing a proposed change that will require a change to the Technical Specifications.
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Contrary to the above, 10 CFR 50.59 Evaluation 92-0035, dated March 6, 1992, identified that a change to the Technical Specifications was required, and NRC approval was not received prior to implementing the proposed change of November 4, 1993, for Unit 1, July 15, 1993, for Unit 2, and December 21, 1993, for Unit 3.
The design change involved the relocation of condenser exhaust radiation monitors to the plant vent.
This is a Severity Level V violation (supplement I) applicable to Units 1, 2, and 3.
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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATIONS 530/94-20-01 AND 528/94-20-05 NRC INSPECTION REPORT 50-528/529/530/94-20
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Re I to Notice of Violation 50-530 94-20-01 Reason for the Violation The violation occurred because of communication weaknesses among the members of the operating crew. Although the secondary reactor operator(RO) and the assistant shift supervisor were both aware of the need to ensure that steam line temperatures were above the minimum, neither took the action to determine the temperatures.
The auxiliary operator indicated that he reported the low temperatures to the control room, but the communication was ineffective since the control room staff was not aware of the steam line temperatures.
surveillance procedure referred to the normal operating procedure for the essential feedwater system, 4XOP-XAF01, to ensure the system lineup. The precautions about temperature limitations were in a separate section of the normal operating procedure.
Corrective Actions Taken and Results Achieved The control room crew was coached in accordance with the existing PVNGS policies.
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Changes to surveillance procedures 4XST-XAF02, Auxiliary Feedwater Pump AFA-P01 Operability Test, were initiated and completed in the three PVNGS units on June 14, 1994.
These changes modified the procedures to determine steam line temperatures and provided actions if steam line temperatures are below those specified.
There have been no further events of auxiliary feedwater pump overspeed due to low temperatures in the steam lines.
Corrective Actions That Will Be Taken To Avoid Further Violations To further strengthen the formality and completeness of communications at Palo Verde, a common communications standard was implemented on July 1, 1994.
Briefings were conducted on this standard and the Vice President, Nuclear Production issued a
memorandum to Palo Verde employees which reiterated the importance of proper communications practices and the communications standard.
A copy of this memo is enclosed without its attachinent, the standard phonetic alphabet.
The operator requalification training cycle which ended on August 19, 1994, included training on the verbal communications standard and referenced this event as an example of inadequate communications.
During the six week operator requalification training cycle which ends on November 18, 1994, this event will be reviewed with licensed and non-licensed operators in more detail, including the effects of ineffective communication on the event.
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In addition to the procedures noted above, the temperature monitoring requirements will be added to procedures in the three units which are used to bring the plants from MODE 5 to MODE 3. Also, further clarification is being added to procedures 4XST-XAF02 and 4XOP-XAF01 in the three units, which specifies that temperature measurements are to be made at more than one point. These changes will be completed by October 1, 1994.
'I Date When Full Com liance Will Be Achieved Full compliance was achieved later in the day, on June 8, 1994, after troubleshooting and a functional test had been successfully completed.
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To Notice Of Violation 50-528 94-20-05 Reason For The Violation'uring the preparation of design change packages for modification PJ-SQ-065, which rerouted the condenser vacuum exhaust to the plant vent stack, the Engineering Department identified the need to change Technical Specification Figure 5.1-3.
Performance ofthe evaluation in accordance with procedure 93AC-ONS01, "10 CFR 50.59 Screening and Evaluation," states that in this case, NRC approval is required prior to implementation of the modification. The Engineering Department submitted a License Document Change Request to the Licensing Department as required. The Licensing t
Department determined that the changes to Figure 5.1-3 would delete one gaseous release point, and that the rerouting of the condenser exhaust still provided a monitored release path, which was already shown on Figure 5.1-3. This change was determined to be administrative, and that it would be submitted with other administrative changes.
Corrective Actions Taken and Results Achieved The Licensing Department personnel involved with this violation were coached in accordance with existing PVNGS policies.
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A sample of approved Technical Specification changes indicates that this violation is an isolated incident and does not demonstrate a lack of rigor in the design change process or licensing process.
Corrective Actions That Will Be Taken To Avoid Further Violations A discussion will be held by the Department Leader, Nuclear Regulatory Affairs with personnel who process license amendment requests concerning this violation clarifying management's expectations regarding changes to Tech Spec and the need fortimeliness in processing such requests.
Communication with the requesters, regarding the status of amendments, was also stressed.
This will be completed by September 2, 1994.
Date When Full Com llance Will Be Achieved Arizona Public Service Company willsubmit a license amendment request to the NRC by October 31, 1994. Full compliance will be achieved upon approval by the NRC.
ATTACHMENT Page 5 of 5
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ATTACHMENT VERBALCOMMUNICATIONSTANDARD
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Arizona Public Service Company COMPANY CORRESPONDENCE 204-01194-JML/JWD
..1uly 20, 1.994 A11 PVNGS Employees Variuue VAr.lI)us Ja>>lee M. Levin 7002 82-fi'100 94-014-000 Verbal Coxnmunicatioxx Standard Coxxxmuxxication is axx ixxxportant activity Oxat affects everyday operation at PVNGS.
Clnod coxnmunication practices are an expected activity'hat should occur between all employees. (i.e. betweeu peers, employees and supervisors, and across department bouiidaries) huxdequate communi<<ation has been idexxtifled as a casual or contributing factor in 16%
of all lxunian perforrna>>co related events..Within this group, two-thirds ofthe problems iiiviilveverbal comuiuuication (refINPO 87-018). Principal problem areas include shift t>>I >>over, pre-job briefings and communication during job performance, Use ofgood prac-tices willreduce errors due to assumptioxis, ambiguous directions and misunderstanding between site personuel.
C ood communication include the followingprincipals as applica-ble:
~ The message is lirief.
Be specifi. Use noun names ofcomponents, train identiflcation, the alpha nuxneric identifier and ifreiluired unit number.
Use accepted standard terminology:
t'oxxxmunicatiou shall be clear, comp1ete and unambiguous, NO ASSUMPI'IONS as to what the otlxer person willdo or has done.
The phonetic alphabet should be used when part ofthe message contains a single letter ofthe alpiiabet (e.g. alpha, bravti).
~ Ifcoxxxmunicalioii is not face to l'ace. tiie oxiginator should self identify and ensure tiie Iecipie>>t IifI.hv iutoxxded xxiess>>g~'s identified.
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1~i>>sxire the xxiesslxge coiitains Oie'xiliieI.'tcomponent and the required action.
'1'hI i eceivei Iil'.k>>IIwlellgesrec~.i>>l. >>i>>1>>nderstanding oftlie direction including
- is>> ininii>>ui>> i I 1II.>>ti>>g back Oi~ 1Ib>>i1 coxxiponent to be checked or manipulated
>>>>d its desired Rt>>te.
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AllPVNGS Employees 294-0 1194-JMLfJWD July 20, 1994
~ For multiple instxmctions, use of a written list is recommended.
~ The message slxould contain necessary precautions to achieve the desired results.
Inxplexnenting communication practices not only includes the above principals, but also the followingguidelines:
ldentification ofeach valve or coxnponent to be worked on or operated.
~ The sender ofthe message is responsible to ensure the receiver has understood the message.
Receiver reports status ofthe completed activity.
~ Ifthe message is conversation in nature and has littleor no significance to plant operation, a simple "Iunderstand" is an acceptable response.
~ Pre-job briefings xnay include a think tank discussion where all personnel involved may enter into the discussion before an officialgame plan is decided upon. Ifthe gaxn>> plan is to be used in the plant, a general summary willbe con-ductedd that inc1uxles the use ofform@1 communications including identifying of each individual s responsibilities and rx repeat back ofthose responsibilities.
~ When communicating with other departments, a higher awareness ofcommunica-tion is necessary'because the terminology used may be different.
.1ML/jwd w/ e>>closure
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