ML20199B317

Responds to NRC Re Violations Noted in Insp Rept 50-528/85-43.Corrective Actions:Draft Procedures Proposed, Placing Addl Emphasis on Prompt Attention to Immediate Corrective Actions

ML20199B317
Person / Time
Site:	Palo Verde
Issue date:	05/30/1986
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
ANPP-36729-EEVP, NUDOCS 8606170110
Download: ML20199B317 (5)

Text

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A Arizona Nuclear Power Project ~ D" P.O. BOX $2034 e PHOENIX, ARIZONA 85072-2034 iM *y

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,*. 39 N May 30, 1986 ANPP-36729-EEVB/JYM/98.05 Mr. John B. Martin, Regional Administrator Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5638

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528 (License No. NPF-41)

Notice of Violation, 50-528/85-43-01; 50-528/85-43-03 File : 86-019-026; D.4.33.2; 86-056-026

Reference:

A) NRC Inspection Report Nos. 50-528/85-43; 50-529/85-44, letter from J.B. Martin to E. E. Van Brunt, Jr., dated January 30, 1986.

B) letter to J. B. Martin, NRC, from E. E. Van Brunt, Jr., ANPP, (EEVB-JYM ANPP-35365) dated March 3,1986,

Subject:

Notice of Violation 50-528/85-43-01; 50-528/85-43-03.

Dear Mr. Martin:

Due to continued ANPP management concern over the issues identified in Reference A), evaluations of the entire LER process have been initiated. Bis is an ongoing process. Aspects of this evaluation have included the review of submittal dates and internal processing methods.

During an audit (86-012) of corrective action conducted by ANPP QA/QC, a sample of 14 LERs were reviewed and several LERs were identified as being submitted late. This is not consistent with the information provided in Reference B). The statements "To rectify the circumstances which led to that violation, extremely conservative criteria were imposed for the initial screening of events for reportability, and no similarly caused delays have been experienced to date," and "Since the occurrence of the circumstances described in the Notice of Violation, no further LERs have been submitted late" were based on a review of the Compliance Department records. The subsequent review of Licensing records conducted by ANPP QA/QC disclosed an inconsistency which revealed the late submittal of several LERs. Although this discrepancy has no impact on the overall intent of the response or the corrective actions being implemented, this information is being provided to ensure that concise and accurate communication is maintained. In addition, 8606170110 860530 l PDR ADOCK 05000528 g O PDR r SG-of m

O Mr. John B. Martin Notice of Violation, 50-528/85-43-01; 50-528/85-43-03 ANPP- 36729 Page Two the response has been revised to indicate actiors thi* have been taken since the Reference B) submittal, and the actions ?Mch 02111 need to be taken. includes the Notice of Violdilon provid:s from Reference A), and includes the changes to the Reference B) response to the Notice of Violation indicated by revision bars on the side of the pages.

If you have any questions on this matter, plesse contact Mr. W. F. Quinn of my staff.

Very truly yours, EEl,cSmNl,}

E. E. Van Brunt, Jr.

Executive Vice President Project Director EEVB/JYM/dk At tachments cc: A. C. Gehr (all w/a)

R. P. Zimmerman E. A. Licitra a

a ATTACICIENT 1

,, , , . , . . . APPENDIX A NOTICE OF VIOLATION -- s 3, Arizona Nuclear Power Project Docket No. 50-528 Post Office Box 21666 License No. NPF-41 Phoenix, Arizona 85036 As a result of the inspection conducted on November 13 - December 26, 1985, and in accordance with NRC Enforcement Policy,10 CFR Part 2, Appendix C, the following violations were identified:

a. Technical Specification 3'.6.1.7.b requires, in part, that the 8-inch containment purge supply and exhaust' isolation valves be sealed closed to the maximum extent practicable, but may be

~

, opened for purge system operation for ALARA and respirable air quality considerations for personnel, entry.

' Contrary to the above, the 8-inch containment purge supply and

.' exhaust isolation valves were not sealed closed to the maximum extent practicable during the period 10:00 PM on Dece=ber 2, through 12:06 PM on December 3, 1985, in that, the valves remained open without justification following the completion of a containment personnel entry. -

This is a Severity Level IV Violation (Supplement I)

b. Technical Specification 6.6.1.a requires that the Commission be notified of Reportable Events, and a report be submitted pur-suant to the requirements of 10 CFR Part 50.73 3

l'0 CFR Part 50.73 requires, in part, that a Licensee Event I

Report be submitted within 30 days after discovery of any operation or condition prohibited by 'the plant's Technical

. Specifications.

Contrary to the above, the following instances of submittal of late Licensee Event Reports (LERs) were identified:

o LER 85-70, documenting a condition prohibited by Technical Specification 3.2.3.b.3, was submitted to the Commission on October 25, 1985, 31 days after discovery, rather than 30.

o LER 85-72, documenting a condition prohibited by Technical Specification 3.3.3.9, was submitted to the Commission on October 16, 1985, 31 days after discovery, rather than 30.

This is a repeat Severity Level V Violation (Supplement I) .

ATTACHMENT 2 RESPONSE TO NOTICE OF VIOLATION 50-528/85-43-01 (ITEM b)

I. THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED An investigation of the two late submittals of LERs revealed that the root cause was an overly cumbersome review and approval process for LERs, with multiple organizations sharing responsibility for both timeliness and adequacy. This investigation hr.s been under constant scrutiny from the management of ANPP since the initial Notice of Violation which was issued in August of 1985 as a result of the late submittal of LER No. 85-32. At that time, the process used to identify, prepare, review, approve and submit reports was examined, and the conditions which led to the initial violation were corrected. In the case of LER 85-32, a non-conservative assumption related to reportability was made early in the identification and review process, which was not corrected soon enough to allow research and preparation of a timely report. To rectify the circumstances which led to that violation, extremely conservative criteria were imposed for the initial screening of events for reportability. No similarly caused delays have been identified to date, with the exception LER 85-85 which was identified as being late throagh the ANPP QA/QC audit previously mentioned. The event date of LER 85-85 occurred on January 12, 1985, prior to the implementation of the conservative criteria effected by LER 85-32.

As stated above, the management of ANPP recognized at that time that a comprehensive review and corrective measures may have been needed to fully address the overall reporting process. De te '. led evaluation of this area by corporate QA/QC resulted in its issuance of a Management Corrective Action Report on August 13, 1985. Review of the MCAR, and internal discussions at the project management levels, resulted in the assignment of the Assistant Vice President, Nuclear Production, with the primary charter for developing an overall action plan and procedures to address its identified concerns.

During the period of October 1985 through January 1986, the interfaces, responsibilities and procedures used for the reporting of events, interface with regulatory agencies, and associated actions, were studied and an overall project reorganization was proposed and initiated. On February 7, 1986, the first of these changes was implemented with the naming of a Compliance Manager with overall responsibility and control in these areas. This position has been elevated to report to the Plant Manager. The Compliance Manager has implemented the required corporate restructuring and the s taf fing evaluation has been completed.

Associated procedures have been revised and submitted for final approval. Two additional Compliance Supervisors have joined the organization. Each of these individuals is experienced in the Project's controls and procedures, and have previously worked in the reportability area.

ATTACHMENT 2 (continued)

To address the specific issue of late LERs, the proposed draft procedures for the new organization streamline that review and approval process, while placing . additional emphasis on prompt attention to immediate corrective actions, resolution of technical issues and comprehensive actions to prevent recurrence.

II. THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE The additional steps, which will be taken to prevent further items of noncompliance, are detailed above and include the approval of the procedures to implement the overall program.

III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The required modifications to the project organization and the staffing evaluation have been completed. Associated revised procedures have been revised and submitted for final approval. Full compliance will be achieved upon implementation of the procedures which is expected by June 30, 1986. 'Ihere should be an improvement of the overall LER program with the implementation of the procedures.

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