ML20093L821
| ML20093L821 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/12/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Bishop T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-30838-WFQ, NUDOCS 8410190212 | |
| Download: ML20093L821 (6) | |
Text
{{#Wiki_filter:_ ^ rinrico I gg 1 Arizona Public Service Company i ? Ei CCI I F l'i " E ? v' ilEG:GN Vi'E e F ANPP-30838-WFQ/TJB October 12, 1984 ~ v U. S. Nuclear Regulatory Commission [ Region V Creekside Oaks Office Park \\ 1450 Maria Lane - Suite 210 I -\\- Walnut Creek, California 94596-5368 [ Attention: Mr. T. W. Bishop, Director W Division of Reactor Saf ety and Projects Reactor Projects and Engineering Programs e gs
Subject:
Responses to Notice of Violation (50-528/84-28-01) and Concern about Proper Equipment Lineups. File: 84-019-026; D.4.33.2 { La
Reference:
(1) Letter f rom T. W. Bishop to E. E. Van Brunt, Jr., dated y p September 14, 1984 y
Dear Sir:
E This letter refers to the inspection conducted by Messrs. R. Zimmerman, G. Fiore111, and C. Bosted on July 2 - August 11, 1984. Our response to the Notice of Violation is enclose'd as Attachment A. t Our response to the concern identified in the referenced letter is enclosed as Attachment B and explicates the corrective actions taken in i response to the incidents identified in paragraphs 6 and 9 of the f_, referenced inspection report, as well as in response to the reactor vessel overfill incident of August 27, 1984. Very truly yours, rm dll O lll E. E. Van Brunt, Jr. APS Vice President r 7 Nuclear Production ANPP Project Director EEVB/TJB/nj g.. k Enclosures c 7 cc: See Page Two l 8410190212 841012 g ( PDR ADOCK 05000520 m g PDR I Ih,-d/ r s u
?[(- V, Mr2 T[ W. Bichop ' ' ~
- Paga Two -
4 ' ' cc: ' Richard DeYoung, Director Office ' of Inspection and Enf orcement' ~ U.. S. Nuclear Regulatory Commission Washington,-D. C. 20555 T.;G. Woods, Jr. D. B..Karner W.'E. Ide ~D. B. Fasnacht J A. - C.'. Rogers L. A..Souza ' D.'E. Fowler T. D. -' Shriver C. N.~- Russo ' J. Vorees : 'J..R. Bynum-s J. M. Allen i A.-C. Gehr-W. J. Stubblefield W..G. Bingham R. L. Patterson' 'R. W. Welcher H. D. Foster 'D.'R. Hawkinson R. P. Zimmerman 'L. Clyde M. Woods T. J. Bloom. J.~ E. Kirby J. D. Houchen : P. Huber-P. Barbour -P. Coffin D. Canady-K. Gross W. F. Quinn - J.~Self b
t Jih :. a w .? f. i j .,o. s. w- -e ,3 '. "( I ', g ' ATTACHMENT A' . Qf- ~ - NOTICE OF VIOLATION-y
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As aTresult of*the inspection conducted on July 2 - August 11, 1984, IV. "and 'in accordance with NRC Enforcement Policy,.10 Part 2, - Appendix C, (47:FR 9937,7the.fo11owing violationLwas' identified. ,e. ~ 10 CFR 50,- Appendix B, criterion XVI, Corrective Action, frequires that for'significant conditions adverse to quality .such as componentLfailuren and malfunctions, measures shall' be established to assure that,the cause of.the' condition.is ~ lde'termined and corrective -action.takenl to preclude repetition, ~ ~ "I yl jAPS Operations Quality Assurance Criteria Manual Revison 0, ' dated September 22,;1982,- Criterion 16, Corrective Action, e9 3 1* If ( requires in part that significant conditions adverse.to quality. ..be evaluated with regard to safety significance in accordance . with written procedures, focusing on the cause of the condition,- and actions that.must be taken to prevent recurrence..
- Palo Verde Nuclear Generating Station Manual Procedure,
' 90GA-0ZZ19, Startup Field Report, Revision B, dated April 2, 1984,! states that Resident Engineering is responsible f or ~ the ^ idisposition of Startup Field ReportsD(SFRs). Contrary to.theiabove, on July;20, 1984 Resident Endineering M L failed to' properly. disposition ~ SFR-1S1-723,. documenting a failure of '. containment sump recirculation valve IJSIAUV675 to
- open remotely from the. Control Room on July 5,1984, in that s
the SFR was incorrectly closed.as'."not valid" without: s . (1) ' adequately evaluatingL the safety: significance of, the failure of ;the Lyalve to :open, (2) determining. the full;cause of the-W ~ _I~ condition which prevented the valve f rom ^ opening, and (3) taking. appropriate corrective action-to preclude repetition. - x. , s g- .-{ L j' 4 y ' C',h L' t e + '..i,
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']' 4ttachment A'(Continued)' Page Two ^ i RESPONSE'TO NOTICE OF VIOLATION LI;l . CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED: ~ L The' physical problem reported. by SFR~ 1-SI-723 has been . 1. ' y. readdressed as SFR 'l-SI-761 and-Deficiency Evaluation - Report (DER) 84-54 2. ' To determine -the scope of the problem with SFRs, Resident . Engineering will review approximately 400. SFRs. The SFRs will b'e reviewed-to determine: a). adequacy of invalidation decisions, b) technical adequacy of disposition, and c) completion of action' prior to closeout. The' results' of tihe review and the evaluation of -the results will be documented in a memorandum to Bechtel quality. a' Asseurance. Based on the results of this review, the-necessity to m review other SFRs will be determined. ~3. Prior to the-NRC $ violation, !APS. Corporate'Qdalit'y A'ssurance had initiated an investigation-(QI-84-006) of the invalidation, technical adequacy of resolution, and completion of closeout) of project documents.' the are used to document problems. Although the review is still. in process; the preliminary results ' indicate the incorrect . invalidation or closure or inadequate technical resolution - 4 of 'these documents is not a generic: problem', although ' isolated problems do exist.. III. ' CORRECTIVE STEPS-TAKEN TO AVOID RECURRENCE: g; Jc ~ t ' A Quality Talk will be presented..Bechtel Resident' Engineering is including this problem into their regularly scheduled: Quality Talk sessions.. The sessions will stress to resident engineers u the importance of continual communication-(feedback and follow-up), affecting thorough efforts' at determining root cause p C. and assuring adequate justification exists to support their. dispositions. D JAdditional actions will be taken as required af ter'the ~ i, ' aforementioned investigations -have been completed and the root cause. identified, p _N. }\\y - s
'f: n .7 l 'l i ' . Attacheent A (continued). e. Page Three A III.- .DATE WHEN FULL COMPLIANCE WILL'BE ACHIEVED .1. - The' Bechtel Resident Engineers review of SFRs is expected 2 - to be completed by October 19,.1984. _2. . Quality Investigation QI-84-006 is expected to be completed ~ by. October 25, 1984. t 13) '.The Bechtel Quality Talks will be completed by October 15, 4 1984.- 4. A supplemental report will-be issued by October 31, 1984, identifying the root cause and' the results of the investigations. r s 4 1 i + 3 1 -k -' (f 5' ~ a y ? w ~ .$ l - r s b 4 i
( ', z ~ a s i.. t f* { ATTACIDENT B ^ s
- Af ter reviewing the.noted incidents for a common or reoccurring trend; we
~ have: identified knowledge of. system' status as the item of most concern .-whether it be' due to improper lineups' being provided to Operations or failure'to adequately. maintain /use system status. To correct this generic. problem; APS has taken the following corrective actions: A.' ? ~. Operating. Department Instruction (ODI) #17; Rev.1, " System Status,". has been issued amplifying and clarifying our methods . for System Status; This document among other things, requires ..t at requests for valve a ignments be of a formal. nature. h l B. When vent / drain valves' are opened within a clearance boundary, g..~ they must be tagged per ODI.#17. k. il Ci, . Requests for valve alignments will be' accompanied by P& ids with intended flow path highlighted at the. shif t supervisor's request. .D; _ ITo ensure'that all. Operations personnel are periodically exposed to ODI #17Lthe Training Department has included ODI #17 in the Requalification Training Program; the Auxiliary Operator
- Training Program, and the Sinalator Training Program.
E. Startup' personnel have been, issued instructions that they are responsible for presenting valve and breaker lineups to . Operations that wi11' safely conduct the t'ests and prove the L
- equipment being tested.
- As' each of the"above incidents has occurred, an Operating Department
~ Experience Repor*:-(ODER) was generated that. indicated the factors which lead up to;the event-and the corrective actions taken in response to the event.'. The ODERs' are disseminated to each operating crew, and along with 10DI~ f17 are required reading f or. new operatiors prior to their assignment ^ i
- in' the field? : InTaddition, individuals involved in the incidents have been counseled;byl Supervision regarding _the seriousness of the event; the importance of good communication, and the-importance of following
~ procedures and written instructions. L As an ' additional measure to increase Management's awareness' of thesc type L ,. Tof' incidents', Ja member of the Transition Team has been reviewing the ~
- daily unit control room lo'gs for unusual events which may' have occurred L
'as a result of inadequate communication or coordination. As'these items ' ~ fare identified,E they are brought (before the daily Transition Team me2 ting 'and:an action is Assigned lto a responsible department to investigrae and . re solve, the problem. These-are documented on a'n Operations /Startup
- Interface Event Form and are maintained by the Transition Team. This practice has been in 'effect since September 6,1984 and is expected to
' continue for Unit 1 until transfer of responsibility to Operations-is complete. This practice will continue for. Unit 2 until such time that it iis no? longer' viewed,as a valuable' tool. i m.s= n m 1 q;s a, _}}