ML20046B872
| ML20046B872 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/29/1993 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02587-WFC-T, 102-2587-WFC-T, NUDOCS 9308060355 | |
| Download: ML20046B872 (7) | |
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1 Arizona Public Service Company e o rww me. vcewr wrona eumm 102-02587-WFC/TRB/RJR wui e conwar July 29,1993 v e m g g e ernr U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555
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 50-528/93-12-04 File: 93-070-026 Arizona Public Service Company (APS) has reviewed NRC inspection Report 50-528/529/530/93-12, and the Notice of Violation dated July 1,1993. Pursuant to the provisions of 10 CFR 2.201, APS' response is enclosed. Enclosure 1 to this letter is a restatement of the Notice of Violation. APS' response is provided in Enclosure 2.
Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, WFC/TRB/RJR/bef
Enclosures:
1.
Restatement of Notice of Violation 2.
Reply to Notice of Violation cc:
B. H. Faulkenberry J. A. Sloan 0600h
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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATION 50-528/93-12-04 NRC INSPECTION CONDUCTED APRIL 27-MAY 31,1993 INSPECTION REPORT NOS. 50-528/529/530/93-12 l
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RESTATEMENT OF NOTICE OF VIOLATION 50-528/93-12-04
- During an NRC inspection conducted on April 27 through May 31,1993, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C, the violation is listed below:
Violation 50-528/93-12-04. Snubber Testirag Technical Specification (TS) Surveillance Requirement (SR) 4.7.9.e.2 states that a representative sample of each type of snubber shall be functionally tested in accordance with Figure 4.7-1 during the first refueling shutdown and at least once per 18 months thereafter during shutdown. For each type of snubber, Figure 4.7-1 requires that the snubbers be tested until the plot of number of failures versus the total number tested falls in the accept region (a minimum of 37 snubbers) or until all snubbers have been tested.
TS SR 4.7.9.e states that the representative sample shall be randomly selected.
Contrary to the above, as of May 12,1993, the licensee failed to meet the surveillance requirements for testing snubbers in Units 1,2, and 3 in that the licensee did not test each type of snubber until the plot of failures versus total tested fell in the accept region or until all snubbers of that type were tested. Additionally, the representative snubber samples were not random.
This is a Severity Level IV violation (Supplement 1) applicable to Units 1,2, and 3.
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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION 50-528/93-12-04 NRC INSPECTION CONDUCTED APRIL 27-MAY 31,1993 INSPECTION REPORT NOS. 50-528/529/530/93-12 l
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BEPLY TO NOTICE OF VIOLATl!ON 50-528/93-12-04 1
Reason For The Violation The reason for the violation was personal error, in that the procedure preparer developed a program which did not meet the committed Technical Specification (TS) surveillance requirements. Further, the technical reviewers and management involved in reviewing the program assumed, based on internal discussions, that the program met the TS requirements and as such, did not perform independent verification and/or validation of the program to the requirements. As a result, the condition has existed since program initiation.
Corrective Actions Taken And Results Achieved An evaluation of the snubber testing program at PVNGS concluded that the test program, as implemented, demonstrated that the snubbers are operable even though the test program was not being conducted in full compliance with the committed TS requirements.
in accordance with TS 4.0.3 failure to perform a surveillance requirement constitutes noncompliance with the OPERABILITY requirements for the Limiting Condition for Operation (LCO) and requires the entry into the associated ACTION statement.
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PNNGS entered the ACTION statement for TS 3.7.9 at approximately 1330 MST on May 12,1993. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ACTION period would have ended at approximately 1330 MST on May 15,1993, when PVNGS Units 1 and 3 would have been required to shutdown in accordance with TS 3.0.3. A Notice of Enforcement Discretion from PVNGS Units 1,2, and 3 TS 3.7.9 ACTION statements was requested from and subsequently granted by the NRC at approximately 1400 MST on May 14,1993.
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A one time only change to TS 3/4.7.9 to document the acceptability of past practices for selecting snubber functional test samples was approved on June 21,1993.
An independent Safety Engineering Assessment of this event was completed on June 21, 1993, to determine what barriers failed, allowing this condition to exist. The assessment determined that the technical review process was inadequate as discussed in the reason for the violation above. The assessment also determined that although Quality Audits and Monitoring had specific requirements in the QA Plan for review of TS and the reviews had been conducted, the snubber testing program procedure and the TS were never reviewed together in their entirety. The assessment determined that other TS have a potential for the same condition and recommended that a separate assessment be conducted.
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Corrective Actions That Will Be Taken To Avoid Further Violations The PVNGS Snubber Testing program will be revised to correctly implement the TS requirements prior to commencing the next testing cycle.
The independent Safety Engineering Assessment provided recommendations for improving the technical review and oversight programs to enhance their ability to identify any similar condition in the future. All recommendations are being tracked in the Commitment Action Tracking System.
Based on interviews and review of the TS, the independent Safety Engineering Assessment team prepared a list of other TS which have the potential for a similar condition. As an immediate action, Quality Audits included 4 of the TS from the list in their periodic audit of TS which started on June 21,1993. If this audit finds conditions similar to that identified with the snubber testing program, additional corrective actions will be in4iated as appropriate.
Date When Full Compliance Will Be Achieved Full compliance was achieved on June 21,1993, when TS amendments 71,57, and 44 for Units 1,2 and 3 respectively, were approved.
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