ML17312B530
| ML17312B530 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/19/1997 |
| From: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17312B529 | List: |
| References | |
| 50-528-97-05, 50-528-97-5, 50-529-97-05, 50-529-97-5, 50-530-97-05, 50-530-97-5, NUDOCS 9706300262 | |
| Download: ML17312B530 (22) | |
Text
Jun-19-97 13:39 PVNGS Nuclear Reg Affairs 602-393-5442
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/jeer 4waosiersc,~ faarrrs Pab Verde Nuclear Generatirg Station James M. Levine Senor Vice President Nuclear TEL f602)393-5309 FAX(602)3584077 I'Jlai! Stet ten 7602 P.O. Bm 5203 t Phoenix. AZ 65072-2034 102-03959 - JML/AKK/REB June 19, 1997 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket Nos. STN 60-628/629/530 Reply to Notices of Violation 60-630/97-05-02, and 50-528/529/630/97-05-03 Arizona Public Service Company (APS) has reviewed NRC inspection Report 50-528/529/530/97-05 and the Notices of Violation (NOV) dated May 20, 1997.
Pursuant to the provisions of 10 CFR 2.201, APS'esponse is enclosed.
Enclosure 1
to this letter is a restatement of the NOVs. APS'esponse is provided in Enclosure 2.
Please note that violation "A" is being contested.
The information provided to the NRC inspector responsible for evaluating the facts to support the decision to cite the violation later proved to be incorrect.'he final investigation revealed additional facts which were not available at the time the violation was cited. APS'ecision to contest violation "A'as discussed with NRC Region IV management in a telephone conversation on June 19, 1997.
Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421.
JMUAKK/REB/rlh Enclosures'incerely, I
- 1. Restatement of Notice ofViolation
- 2. Reply to Notice of Violation 9706300262 970627 PDR ADOCK 05000528 8
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Jun-19-97 13:40 PVNGS Nuclear Reg Af'fairs 602-393-5442 P.O3 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notices ofViolation 50-530/97-05-02, and 50-528/529/530/97-05-03 Page 2 cc:
E. W. Merschoff K. E. Perkins D, F. Kirsch J. W. Clifford F. L. Brush
Dun-19-97 13: 40 1
PVNGS Nuclear Reg Af'f'ayers 602-393-5442 P. 04 ENCLOSUREl RESTATEIIENT OF NOTICES OF YIOLATION 50-530/97-05-02 and 50-528/529/530/97-05-D3 NRC INSPECTION CONDUCTED MARCH 23 THROUGH MAY03, 1997 INSPECTION REPORT NO. 50-528/529/530/97-05
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Jun-19-97 13:40 PVNGS Nuclear Reg Af'Fairs 602-393-5442 P.05 RES ATEM NT'OF NOTICE OF VIOLATION"A" 60-530/97-05-02 During an NRC inspection conducted on March 23 through May 3, 1997, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
Technical Specification 6.8.1 requires, in part, that, written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1,33, Appendix A, Revision 2,
Section 9,
requires that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Licensee Specification 13-EN-306, Revision 5, "Installation Specification for Cable Splicing and.Termination of Cable Systems at the Palo Verde Nuclear Generating Station,"
Section 3.1, defines the allowable auxiliary supports fabricated to relieve stress on cable termination or splices due to cable weight and to prevent movement of cable to maintain minimum separation and minimum bend radius requirements.
The allowable support may consist of Nylon TY-WRAP cable ties and bases utilizing either machine or 1/4 inch (maximum) self-tapping mounting screws, or snap-in base type configurations.
Contrary to the above On September 2, 1994, the licensee used Nylon TY-WRAP cable ties to support and maintain minimum separation of cables in the Unit 3 Class 1
E 125-Vdc power Channel C battery charger and did not use bases with rnachine or 1/4 inch self-tapping mounting
- screws, or snap-in base configurations.
Electricai maintenance personnel used an adhesive-backed cable tie base, 2.
On March 22, 1997, the licensee used Nylon TY-WRAP cable ties to support cables in the Unit 3 Class
'I E 125-Vdc power Channel C battery charger and did not use bases with machine or 1 /4 inch self-tapping mounting screws, or snap-in base configurations.
Electrical maintenance personnel used an adhesive-backed cable tie base.
This is a Severity Level IVviolation (Supplement 1) applicable to Unit 3 (50-530/97005-02)
Jun-19-97 13:41 PVNGS Nuclear Reg Af'f'airs 602-393-5442 P,O6 RESTATEMENT OF 0 ICE OF VlOLATfON"B" 50-528/529 530/97-05-03 8,
10 CFR Part 50, Appendix 8, Criterion ill, "Design Control," requires that'easures be established to assure that appropriate quality standards are specified and included in design documents.
Licensee Procedure 81AC-OCCOB, Revisions 2.01 and 2.02, "Classification of Structures, Systems, and Components," established criteria for determining the quality classification for structures, systems and components. Step 3.1.4 requires that design output data for specific equipment identification numbers be entered into the station information management system equipment database.
Step 3.5.12 requires that items which do not perform a safety function but whose structural failure could adversely affect the functions of safety related equipment during or following a design basis event be classified as "quality augmented."
Licensee internal Memorandum 284-00601, dated March 3, 1993, identified that the quality classification of components required for high energy line break mitigation, including auxiliary building penetrations be designated as quality augmented.
Licensee internal Memorandum 281-00937, dated September 30,
- 1992, identified that all penetration seals in flooding barriers which provide separation between safety and nonsafety equipment be upgraded to quality.
augmented and all penetrations in the essential auxiliary building ventilation boundary be upgraded to quality augmented.
Contrary to the above, as of May 3, 1997, all auxiliary building penetrations required for high energy line break mitigation, in flooding barriers, which provided separation between safety and nonsafety equipment, and in the essential auxiliary building ventilation boundary, and which did not serve as' fire protection barrier, were not classified as quality augmented in the station information management system database.
This is a Severity Level IVviolation (Supplement 1) applicable to Units 1, 2 and 3 (50-528,529,530/97005-03).
Jun-19-97 13:43 PVNGS Nuclear Reg Affairs 602-393-5442 P.O7 ENCLOSURE 2 REPLY TO NOTICES.OF YIOLATION 60-530/97-06-02, and 50-528/529/530/97-06-03 NRC INSPECTION CONDUCTED MARCH 23 THROUGH IIAY03, 1997 INSPECTION REPORT NO. 50-528/529/530/97-06
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Jun-19-97 13 = 43 PVNGS Nuclear Reg Af'f'airs 602-393-5442 P.O8 REPLY TO NOTICE 0 VIOLATON "A" 50-530/97-05-02 8
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On March 21, 1997, the input breaker for Unit 3 nC" battery charger tripped open during integrated safeguards testing.
The initial investigation suggested a possible cause for the trip was a 480 Vac cable coming in close proximity to the breaker's high voltage shutdown card.
The 480 Vac cable was harnessed away from the high voltage shutdown card in 1994 with an adhesive backed TY-WRAP
. Sometime after.1994, the adhesive on the TY-WRAP backing failed and the 480 Vac cable relaxed and moved back to its original position - close to the high voltage shutdown card. p~fe'ipieted w ss ~si ttti~es tggfiomgooae~e~e co!!gLgtfjLt.ttgnhlfuncgontcg oYra~us~n~t" p.ds~ce:.<Xusadgttisr ibsa~eroMIS niiw5;$80, ac,cttttta,ilg!essynmtmitttno;igteeigK~Ão age%mdtntn p8N~aO.Nlginally;suspected)
Although the physical location of the 480 Vac cable was not a factor in the breaker trip, the cable was re-routed away from the high voltage shutdown card.
An NRC inspector reviewed the circumstances surrounding the breaker trip while the investigation was still in-progress and was told by maintenance engineering that the adhesive back TY-WRAP did not conform to specification 13-EN-306 when used as an auxiliary support. ~eetwause~@~reake&rip had~~t+een<etetnHnedmn4.
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that adhesive backed TY-WRAPs can fail when used in applications similar to the Unit 3 "C" battery charger, their use was not contrary to the applicable vendor specification or specification 13-EN-306.
Regulatory Guide 1.33, requires that maintenance that can affect the performance of safety-related equipment should be performed in accordance with written procedures, documented instructions, or drawings appropriate'o the circumstances.
For these reasons, APS is contesting NOV 50-530/97-05-02.
Corrective Ste s T at Have Been aken and Results Achieved Since no violation of specification 13-EN-306 occurred, no corrective actions were required.
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Jpn-19-97 13:46 PVNGS Nuc1ear Reg Af'f'ayers 602-393-5442 Corrective Ste s That WillBe Taken To Avoid Fu er Violations Since no violation of specification 'i3-EN-306 occurred, no corrective actions to avoid further violations were required.
Date When Full Corn liance WillBe Achieved Full compliance was always maintained since no violation of specification of 13-EN-306 occurred.
Jun-19-97 13: 46 P VNGS Nuc 1ear Reg Af'f'amrs 602-393-5442
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P 11 REPLY TO NOTICE OF VIOLATIO "B" 50%28/529/530/9~7-05-03 Reason For The Violation APS identified the need to change the quality classification from NQR to QAG for non-fire barrier penetrations in September 1992 (for flooding and essential ventilation) and in March 1993 (for high energy line break). Actions were initiated in the corrective action program for the flooding and essential ventilation evaluations; however, the actions wel'B closed without all actions being completed.
At the time, significant attention was applied to penetration upgrades for fire function documentation and the flooding and essential ventilation functions were overlooked.
ln the case ofthe high energy line break evaluation, a design change package was generated for physical modifications to the units and included the penetration upgrade to QAG in the station information management system for high energy line break barriers.
An action was not entered into the corrective action tracking system to track the QAG upgrade portion of the change.
This design change was canceled in 1995 and itwas not recognized that the QAG upgrade would be deleted.
The reason for both of these errors is cognitive personnel error, in that the individuals involved did not recognize and did not verify that the QAG upgrade classification for flooding, essential ventilation, and high energy line break had not been implemented.
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Jpn-19-97 13:47 PVNGS Nuclear Reg Af'f'airs 602-393-5442 I
lt is important to note the design, procurement and installation of penetration seals is the same for seals classified as NQR or QAG.
Therefore the physical plant is not affected by this error.
Additionally many of the affected seals are already classified as QAG because of their fire function.
Corrective Ste s That Have Been Taken and Results Achieved The corrective action tracking system has been updated to track the completion of upgrading the non-fire barrier penetrations to QAG, for flooding, essential ventilation, and high energy line break considerations, in the station information management system by July 30, 1997.
Co rective Ste s
at Wi Be a en To Avoid Further Yiolations Cognitive personnel errors that are the result of mental lapses are not normally corrected with revised procedures or additional training.
Nevertheless, the issues of ensuring completion of all requirements necessary to close an action in the corrective action tracking system and of ensuring corrective actions are entered into the corrective action tracking system will be addressed in industry events training for Engineering Support Personnel.
Date When ull Com lia ce WillBe Achieved Full compliance will be achieved by July 30, 1997 when the station information management system is updated to reflect a QAG classification for penetrations that are required to function in flooding, essential ventilation, and high energy line break events.
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