ML17311B157

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Forwards Response to NRC Re Violation Noted in Insp Rept 50-528/95-12 on950521-0701.Corrective Actions:Lead Test Performer Counseled & Methodology Used to Perform Surveillance Test Evaluated
ML17311B157
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 08/25/1995
From: Stewart E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-03456-WLS-A, 102-3456-WLS-A, NUDOCS 9509050144
Download: ML17311B157 (14)


Text

RZORZTY 1 CCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) p4 ACCESSION 'NBR:9509050144 DOC.DATE: 95/08/25 NOTARIZED: NO DOCKET g FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 P

AUTH.NAME AUTHOR AFFILIATXON STEWART,E.L.

Arizona Public Service Co.

(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC 950727 ltr re violations noted in insp rept 50-528/95-12-01 on 950521-0701.Corrective actions:

lead test performer was counseled by supervisor on expe'ctations for performing surveillance tests.

DISTRIBUTION CODE:

IE01D COPIES.RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT 05000528 RECIPIENT ID CODE/NAME PD4-2 PD TRAN,L INTERNAL ACRS AEOD/SPD/RAB DEDRO NRR/DISP/PIPB NRR/DRCH/HHFB OEMTH RGN4 FILE~0 EXTERNAL: LITCO BRYCE,J H

NRC PDR COPIES LTTR ENCL 1

1 1

1 2

2 1

1 1

1 1

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1 1

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1 RECIPIENT XD CODE/NAME HOLIAN, B AEOD/DEIB AEOD/TTC FILE CENTER NRR/DORS/OEAB NUDOCS-ABSTRACT OGC/HDS2 NOAC COPIES LTTR ENCL 1

1 1

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NOTE,TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL DESKS ROOM OWFN 5DS (415-2083)

TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED:

LTTR 20 ENCL 20

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Arizona Public Service Company

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BOX 53999

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PHOENIX. ARIZONA85072-3999 WILLIAML. STEWART EXECUTIVEVICEPRESIDENT NUCLEAR U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001 102-03456-WLS/AKK/RAS August 25, 1995

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528 License No. NPF41 Reply to Notice ofViolation 50-528/95-12-01:

Arizona Public Service Company (APS) has reviewed the NRC Inspection Report 50-528/529/530/95-1 2 and Notice ofViolation (NOV) dated July 27, 1995.

Pursuant to the provisions of 10CFR 2.201, APS'esponse is provided in En'closure 2. Enclosure 1 to this letter is a restatement of the NOV.

In response to the inspection report cover letter, APS shares the concern that personnel failed to refer to the procedure prior to performing a surveillance test.

Although the noted deviation did not challenge the test results, it is APS policy and,a management expectation that procedures are followed or changed in accordance with program requirements.

Should you have any further questions, please contact Ms. Angela K Krainik at (602) 393-5421.

Sincerely, WLS/AKK/RAS/pv Enclosures

1. Restatement of Notice of Violation
2. Reply to Notice of Violation cc:

L. J. Callan B. E. Holian K. E. Johnston K. E. Perkins 9509050144 950825 PDR ADQCK 05000528 PDR gr0

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ENCLOSURE 1 RESTATEMENT.OF NOTICE OF VIOLATION50-528/95-12-01 NRC INSPECTION'CONDUCTED MAY21, 1995 THROUGH JULY 1, 1995 INSPECTION REPORT Nos. 50-528/529/530/95-12

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Restatement of Notice ofViolation 60-628/96-12-01 During an NRC inspection conducted on May 21 through July 1, 1995, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 60 FR 34381; June 30, 1995, the violation is listed below:

Unit 1 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering surveillance and test activities of safety related equipment.

Licensee Procedure 73ST-9SI03, Revision 8, "Leak Test of SI/RCS Pressure Isolation Valves," provided instructions for testing safety injection system check valves which serve as reactor coolant system pressure boundaries. Appendix D of the procedure, steps 1.2 and 2.2, required, in part, that the volume of water in the 3-inch header upstream of boundary check Valves SIA-V523 and SIB-V533 be completely drained.

Contrary to the above, during performance of Licensee Procedure 73ST-9SI03 on May 23, 1995, the volume of water in the 3-inch header upstream of boundary check valves SIA-V523 and SIB-V533 was not completely drained.

This is a Severity Level IVviolation (Supplement I) applicable to Unit 1.

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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION50-528/95-12-01 NRC INSPECTION CONDUCTED MAY21, 1995 THROUGH JULY 1, 1995 INSPECTION REPORT Nos. 50-528/529/530/95-12

REPLY TO NOTICE OF VIOLATION50-528/95-12-01 Reasons for the Violation The reason for the violation was personnel error.

The lead test director instructed an Auxiliary Operator to perform steps in a surveillance test in a manner which did not comply with the proceduie requirements.

By doing so, the lead test director failed to I

comply with the surveillance test procedure requirements as well as other programmatic requirements which direct procedure'sers to review, thoroughly understand, and adhere to procedure requirements.

If the procedure cannot be performed as written, the procedure user is responsible for changing the procedure in an approved manner.

Corrective Actions Taken and Results Achieved The lead test performer was counseled by his supervisor on the expectations for performing surveillance tests in accordance with procedure requirements and when appropriate to initiate procedure changes in accordance with approved methods.

System Engineering evaluated the methodology used to perform the surveillance test to determine if the test results were valid. The evaluation concluded the acceptance criteria was not challenged by the procedural deviation.

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I Corrective Actions That WillBe Taken to'Avoid Further Violations An Instruction Change Request has been initiated and is being reviewed to determine if the surveillance test procedure should be revised to incorporate the test methodology used by the test diiector.

Date When Full Com liance WillBe Achieved Compliance was achieved on May 31, 1995, when System Engineering determined the surveillance test results were not affected by the methodology used to perform the test.

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