ML17313A572

From kanterella
Jump to navigation Jump to search
Responds to NRC 980810 Ltr Re Violations Noted in Insp Repts 50-528/98-05,50-529/98-05 & 50-530/98-05,respectively. Corrective Actions:Verified That Letdown Backpressure Cv Was in Correct Position & Properly Locked & Statused in CR
ML17313A572
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 09/06/1998
From: James M. Levine
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-04176-JML-A, 102-4176-JML-A, 50-528-98-05, 50-528-98-5, 50-529-98-05, 50-529-98-5, 50-530-98-05, 50-530-98-5, NUDOCS 9809140249
Download: ML17313A572 (7)


Text

James M. Levine TEL (602)393-5300 Mail Station 7602 Palo Verde Nuclear Senior Vice President FAX (602)393-6077 P.O. Box 52034 Generating Station Nuclear Phoenix, AZ 85072.2034

'02-04176-JML/AKK/DLK September 6, 1998 U. S. Nuclear Regulatory Commission ATI N: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit1 Docket Nos. STN 50-528

. Reply to Notice of Violation 50-528/98-05-001 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/98-05 and the Notice of Violation (NOV) dated August 10, 1998.

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

The NRC Inspection Report 50-528/529/530/98-05 referred to this event as a repeat violation from a June 1997 inspection. APS reviewed the previous violation to determine why the corrective steps taken in 1997 did not prevent the August 10, 1998 violation.'n the 1997 event, an auxiliary operator notified control room personnel that a locking device was going to be broken, broke the locking device, but failed to retuin to the control room to complete the record of change. Additionally, control room personnel failed to promptly document the change in valve status. As such, the corrective action focused on correctly statusing the valve and reminding operations personnel of. their responsibilities associated with locked valve, breaker, and component control The ~

corrective steps focused on co'rrecting attention to detail. The 1998 event differed in that control room personnel were not aware that a locking device was broken., The maintenance technician who broke the lock assumed that because permission was given to disassemble the locked valve, permission was also given to break the locking device. While the maintenance technician was generally familiar with the locked valve, breaker, and component control program, he did not fully understand the individual responsibilities associated with breaking a locking device on a valve that was tagged out and authorized to be disassembled. Because of the different circumstances surrounding the two events, corrective steps taken in 1997 could not have prevented the August 10, 1998 violation.

9809140249 980906 PDR ADGCK 05000528 8 POR

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notic'e of Violation 50-528/98-05-01 Page 2 Should you have any further questions, please contact Ms. Angela K. Krainik at (602) 393-5421..

Sincerely, JML/AKK/DLK/rlh Restatement of Notice of Violation Reply to Notice of Violation cc: E. W. Merschoff M. B. Fields J. H. Moorman

ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION 50-528/98-06-01 NRC INSPECTION CONDUCTED MAY 31 THROUGH JULY 11, 1998 INSPECTION REPORT NO. 60-528/629/530/98-06

RESTATEMENT OF NOTICE OF VIOLATION50-528/98-05-01 During a NRC inspection conducted on May 31 through July 11, 1998, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below.

A. Technical Specification 6.8.1 requires, in part, that written procedures shall be, implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Item 1.c requires that the licensee have written procedures for equipment control.

Procedure 40DP-9OP19, "Locked Valve, Breaker, and Component Tracking," .

Revision 46, Step 3.2, required, in part, that personnel are to complete Appendix C, "Individual Valve/Breaker/Component Change Record," for the valve that had been operated.

Contrary to the above, on June 29, 1998, the inspectors identified that personnel had removed the locking device from Valve CHE-PV-201Q (letdown backpressure control), but had not documented the removal of the locking device in Procedure 40DP-9OP19, Appendix C.

e This is a Severity Level IV violation (Supplement 1) 50-528/98-05-01.

ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION.

50-528/98-06-01 NRC INSPECTION CONDUCTED MAY 31 THROUGH JULY 11, 1998 INSPECTION REPORT NO. 60-528/529/530/98-05

REPLY TO NOTICE OF VIOLATION Reason For the Violation On June 29, 1998, a letdown backpressure control valve in Unit 1 was found with its locking device missing. At the time of discovery, the valve was isolated under an active clearance for maintenance. The letdown backpressure control valve is controlled by the "Locked Valve, Breaker, and Component Control" program and as such, when the locking device is removed a record of.the change in status is required to be maintained in the control room. A record of change in the valve's status was not documented in the control room. Failure to document the change in status is a violation of the "Locked Valve, Breaker, and Component Control" procedure.

An investigation into the event determined that a technician removed the locking device while disassembling the valve for maintenance. Prior to disassembling the valve, a pre-job briefing was conducted with operations personnel; however, details about removing the valve's locking device were not specifically discussed. Permission was granted to disassemble the valve. The maintenance technician assumed that permission to disassemble the valve also included permission to remove the valve's locking device.

After the valve was disassembled, the technician informed Control Room personnel that the valve had been disassembled but did not document a record of change in the valve's status in the control room.

The reason for the violation was cognitive personnel error on the part of the maintenance technician who removed the locking device from the valve but did not document the change in the valve's status in the control room.

Corrective Ste s That Ha've Been Taken and Results Achieved On June 29, 1998, the letdown backpressure control valve was verified to be in the correct position and properly locked and statused in the control room.

The maintenance technician who removed the locking device was coached on the procedural requirements and responsibilities associated with locked valve, breaker, and component control.

An article was published in the "Palo Verde News" that explained the administrative requirements associated with locked valve, breaker, and component control.

Corrective Ste s That Will Be Taken To Avoid Further Violations The details surrounding violation 50-528/98-05-01 and a discussion of the requirements associated with the locked valve, breaker, and component control program will be included in industry events'training for instrumentation and control, and mechanical maintenance technicians. The training will be completed prior to March 31, 1998.

Date when Full Com liance Will Be Achieved Full compliance was achieved on June 29, 1998, when the letdown backpressure control valve was verified to be in the correct position and properly locked and statused in the control room.