ML20058C583
| ML20058C583 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/17/1993 |
| From: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02731-WFC-B, 102-2731-WFC-B, NUDOCS 9312020496 | |
| Download: ML20058C583 (16) | |
Text
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Arimna Public Service Company eo m,
u, mw mm.t. e, m 102-02731-WFC/ BAG /PJC mumimown November 17,1993 j 7-n U. S. Nuclear Regulatory Commission ATTN: Document Contrci Desk Mail Station P1-37 Washington, D. C. 20555
Reference:
Letter dated October 19, 1993, from C. A. VanDenburgh, Chief, Reactor Projects Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGE)
Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notice of Violations 50-528/93-40-06, 529/93-40-04, and 529/93-40-08 File: 93-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/93-40 and the Notice of Violations dated October 19,1993. Enclosure 1 to this letter is a restatement of the Notice of Violation. APS' responses are provided in.
In addition, clarification is needed for a statement in Inspection Report 93-40 that refers to an APS conclusion with regard to the methods of main steam safety valve testing.
Section 7. " Main Steam Safety Valve (MSSV) Testing - Unit 1 (40500 and 71707)," of the inspection report states in part:
Based on the data collected from these tests, the licensee concluded that even though there was an offset between the two test methods, the data from the two methods generally correlated and both methods appeared to be acceptable.
During the testing of the three MSSVs at the Westinghouse test facility using both the Westinghouse live steam test and the Furmanite "Trevitest," APS made some general observations with respect to the two test methods. However, no conclusions have been 9312O20496 931117 PDR ADOCK 0500o528 P
r U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Reply to Notice of Violations 50-528/93-40-06, 50-529/93-40-04, and 50-529/93-40-08 Page 2 reached to date. APS is currently evaluating the test data and formulating conclusions
'in accordance with its problem resolution program.
Should you have any questions, please call Burton A. Grabo at (602) 393-6492.
Sincerely, fJ J.
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fjd (LfG V
WFC/ BAG /PJC
Enclosures:
1.
Restatement of Notice of Violation 2.
Reply to Notice of Violations cc:
B. H. Faulkenberry J. A. Sloan i-1_
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i ENCLOSURE 1 i
RESTATEMENT OF NOTICE OF VIOLATIONS i
50-528/93-40-06, 50-529/93-40-04, and 50-529/93-40-08 j
NRC INSPECTION CONDUCTED AUGUST 17 THROUGH SEPTEMBER 20,1993 4
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Restatement of Notice of Violations 50-528/93-40-06, 50-529/93-40-04, and 50-529/93-40-08 During an NRC inspection conducted on August 17 through September 20,1993, three 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.
Technical Specification 6.2.2.1.b, for Units 1,2, and 3, requires that an individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight nor more that (sic) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, exclusive of shift turnover time. Deviations from this must be authorized by appropriate managers.
Contrary to the above, the licensee determined that: (1) on December 31,1991, l
through January 1,1992, a licensee engineer worked more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, exclusive of shift turnover time, and (2) between December 25,1991, and January 13,1992, a licensee engineer worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period, exclusive of shift turnover time, without authorization by a manager.
This is a Severity Level IV violation (Supplement I) applicable to Units 1, 2, and 3.
I B.
Unit 2 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.
Procedure 73AC-9ZZO4, Revision 9.05, " Surveillance Testing," step 3.9.3, requires that unsatisfactory steps or data be marked "unsat," circled, and initialed. In addition, step 3.10.3, states that a retest shall be documented on blank pages of the surveillance test (ST) procedure, copied from the station manual and inserted as necessary to provide unused steps for the appropriate test sections including prerequisites.
Contrary to the above, on August 27,1993, during the performance of Surveillance 1
Test 42ST-2CH04 in Unit 2, operators noted that the calculated boron injection flow -
was below the minimum acceptance criterion, but failed to mark this step as "unsat." in addition, the retest was not conducted using a blank page from the ST procedure.
This is a Severity Level V violation (Supplement I) applicable to Unit 2.
C.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
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i Procedure 32MT-9ZZ46," Disassembly / Assembly of Limitorque type SMB/SB-0 thru SMB/SB-4 Actuators," includes instructions for the installation of the actuator t
Contrary to the above, on August 4,1993, Revisions 6F and 7G of Work Order 605526 were not appropriate to the circumstances in that they did not include a step referencing procedure 32MT-9ZZ46 for replacing the torque switch for the
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auxiliary feedwater supply isolation valve to Steam Generator 22.
j This is a Severity Level IV violation (Supplement I) app!; cable to Unit 2.
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i ENCLOSURE 2 REPLY TO NOTICE OF VIOLATIONS 50 528/93-40-06,50-529/93-40-04, and 50-529/93-40-08 NRC INSPECTION CONDUCTED AUGUST 17 THROUGH SEPTEMBER 20,1993 4
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REPLY TO VIOLATION A (50-528/93-40-06) l Admission Or Denial Of The Alleaed Violation i
l APS admits the violation.
i Reason For The Violation l
r As discussed in its resoonse (
Reference:
Letter No. 102-02361-WFC/RJS/ACR, dated December 1,1992) to the NRC's September 29,1992 request for information, an APS investigation substantiated the concern that a PVNGS engineer exceeded Technical j
Specification and PVNGS procedural overtime limitations. The individual worked more j
than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight on December 31,1991 through January 1,1992 and worked more j
than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period between December 25,1991 and January 13,1992. This violation was attributed to procedural ambiguity regarding the amount of time that should l
be allocated for shift turnover and the individual's misunderstanding of the applicability of the overtime limits to breaks and other time not directly associated with safety-related work. In addition, the APS investigation found that the individual had worked more than 12 consecutive days which also violated PVNGS procedural overtime limitations. This violation was caused by inadequate attention to overtime limitations by the individual and the individual's supervisor.
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Corrective actions included counseling of both engineer and supervisor and revision of PVNGS procedure 02AC-0EM01, " Overtime Limitations," to provide clearer guidelines as to the amount of time that constitutes shift turnover. Guidance was provided to Site Technical Support personnel with regard to how time spent in the work place on non-work activities is to be recorded on time tickets. The violation did not result in any PVNGS unit being operated in a condition prohibited by the Technical Specifications.
Since that response was submitted, the NRC Resident inspectors reviewed PVNGS Quality Assurance (QA) documents associated with overtime limitations and identified discrepancies of minimal safety significance that occurred during 1991 and 1992. During performance of the recent PVNGS QA Maintenance Audit, initiated September 20,1993, the audit team identified severalincidents during 1993 in v.5ich it appeared that personnel had exceeded overtime limitations and/or did not properly comply with exception requirements.
Discrepancies included (1) lack of prior many 3 ment approval, (2) approval from improper management levels, (3) inadequate / incomplete documentation, (4) inadequate justification for exceptions, (5) time activity reporting errors, (6) time activity data entry errors, and (7) errors in the PVNGS Excess Hours Report. These continuing discrepancies indicated a recurring problem for which corrective actions had not been effective in a number of PVNGS departments. Therefore, on November 3,1993, the PVNGS QA Director issued a Stop Work Notice that prohibited the affected PVNGS departments from taking any exceptions to the overtime limitations procedure until those Page 2 of 10
departments provided acceptable corrective action plans. Further, Corrective Action Report (CAR) No. 93-0179 was issued to address the cause(s) of the identified condition, procedure non-compliance, action (s) to prevent recurrence, and the inadequacies of the PVNGS Excess Hours Report. APS immediately initiated an investigation.
Corrective Steps That Have Been Taken And Results Achieved r
1 As discussed above, the OA Director issued a Stop Work Notice prohibiting the affected PVNGS departments from taking exceptions to the Overtime Umitations policy until those organizations implemented acceptable interim corrective actions; a CAR was issued to track and verify corrective actions, and an investigation was initiated.
f Corrective Steps That Will Be Taken To Avoid Further Violations i
The APS investigation is still in progress, and long-term corrective actions have not yet been developed. Through its investigation, APS will determine the extent and i
cause(s) of the problem; the organizations involved; the applicability of the overtime limitations procedure and whether or not changes are needed; and the reliability, distribution, and use of the Excess Hours Report. Based upon the results of the f
1 investigation, appropriate corrective actions will be developed and implemented. APS expects to complete its investigation by December 17,1993.
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Date When Full Compliance Will Be Achieved 1
Full compliance was achieved when interim corrective actions were instituted, and l
l the OA Stop Work Notice was lifted on November 17,1993.
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4 REPLY TO VIOLATION B (50-529/93-40-04) i Admission Or Denial Of The Alleaed Violation APS admit:: the violation. It should be noted that implementation of the corrective actions developed for the violations identified in NRC Inspection Reports 50-528/93-26 and 50-528/93-35 was still in progress when this violation occurred.
t Reason For The Violation As was the case with the similar violations described above, the current violation f
i may be attributed to personnel error. The complexities and inconsistencies of the administrative control procedure 73AC-9ZZO4, " Surveillance Testing," are considered to be contributing factors as they were in the previously mentioned violations.
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in this particular case, Unit 2 Operations had been experiencing intermittent i
malfunctions of the reactor coolant pump (RCP) seal bleed-off flow indicators for approximately two weeks. On August 25,1993, alternate flow indicators were developed and installed. On August 27,1993, night shift operators were performing 42ST-2CH04 to determine the reliability of the newly installed instruments. The operators found that' F
the new instruments were subject to cycling, and consulted the Operations Supervisor i
who directed them to observe the meters and retake the data.
When conflicting Page 5 of 10
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indications were again received and recorded, the crew discontinued the test. The i
Operations Supervisor did not consider the documentation guidance in the administrative control procedure 73AC-9ZZO4," Surveillance Testing,"to be applicable to the anomalous circumstances of this particular test. The following morning the Operations Manager reviewed the test results and directed operators to perform an alternative method for determining RCP seal bleed-off flow that had been developed for use in the event of further flow meter failures.
A change to procedure 42ST-2CH04 was processed and approved to permit performance of the ST by the alternate method. The test was i
continued and completed successfully.
t Corrective Steps That Have Been Taken And The Results Achieved 5
The test log was updated to explain the circumstances of the test and the actions i
taken. The Operations Supervisor issued a night order advising his staff of the violation i
and pending corrective action.
Corrective Steps That Will Be Taken To Avoid Further Violations l
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As discussed in the APS response to the previous violations (
Reference:
Letter No.
i 102-02623-WFC/TRB/PJC, dated August 30,1993), a Focus Group was established to f
review and revise the ST administrative control to provide clear, concise instructions for ST documentation.
The procedure has been revised and is in the final review cycle.
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F A video tape and briefings are being developed for training on the revised procedure.
l Implementation is expected by the end of the year.
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Date When Full Compliance Will Be Achieved Full compliance was achieved when the test log was updated to explain the circumstances of the test and the actions taken, and the test was successfully completed using the alternate method for RCP bleed-off flow determination.
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REPLY TO VIOLATION C (50-529/93-40-08)
Admission Or Denial Of The Alleaed Violation i
APS admits the violation.
i Reason For The Violation i
Procedure 32MT-9ZZ46, " Disassembly / Assembly of Limitorque Type SMB/SB-0 i
Thru SMB/SB-4 Actuators," which was cited in this violation is intended to provide guidance for the refurbishment of a valve actuator; step 4.45 provides guidance for the f
reinstallation of a torque switch after it has been refurbished. The APS investigation found that the procedure was inconsistently and unnecessarily applied in the development of amendments to work order number 00605526 which was written to perform troubleshooting and maintenance on valve AF-UV-35. The use of the procedure to remove the torque switch for access to the spring-pac was not required. The torque switch is not de-terminated for access to the spring-pac. The mounting screws are removed, and the torque switch is moved aside to gain access to the spring-pac. The torque switch in question was already set, the actuator had been diagnostically tested,-
and the torque switch circuitry functioned. The maintenance on the spring-pac and l
torque switch was performed correctly as the valve passed all the required testing.
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However, since the procedure was used to " remove" the torque switch, it should j
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also have been used to " reinstall" the switch. The need for amendments to the work i
order was identified on backshift, and no planners from the Central Planning I)epartment were available. The planners who developed the amendments and per.brmed the technical review do not normally plan work for the Valve Services technicians. A Unit 2 planner developed the amendments for performance of the troubleshooting needed on 1
the valve so that testing could be resumed, and a Unit 3 planner performed the technical review. The Valve Services work group supervisor reviewed the amendments and
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determined that the steps were adequate to continue troubleshooting. Neither the planner nor the reviewers recognized that there was no reinstallation step for the torque f
switch, and the technicians continued the work without such a step. Inattention to detail was the apparent cause.
l Corrective Steps That Have Been Taken And The Results Achieved The two planners who developed the work order and performed the. technical review were briefed as to management's expectations with regard to the need to ensure all the criteria needed to perform the work are included in the maintenance instructions.
i The Valve Services work group supervisor and technicians were briefed that work is to 1
stop when work orcers or procedures do not specify the needed criteria to complete a
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d Correctivo. Steps That Will Be Taken To Avoid Further Violations
,4 A guideline will be developed to brief Unit and Central planners on the appropiiate l
t use of procedure 32MT-9ZZ46 to ensure it is consistently applied to work instructions.
The briefings will be completed by December 17,1993.
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B Date When Full Compliance Will Be Achieved i
L Full compliance will be achieved when planners have been briefed on the proper application of procedure 32MT-9ZZ46 on December 17,1993.
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