ML20206P383
| ML20206P383 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/13/1986 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-37750-EEVB, NUDOCS 8608270191 | |
| Download: ML20206P383 (9) | |
Text
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A RECEIVED t(T.C Arizona Nuclear Power Projects fg g g pg 7.g P o. BOX 52034 e PHOENIX, ARtZoNA 85072-2034 August 13, 1986 ANPP-37750-EEVB/TDS-g,pggg Mr. John B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368
Subject:
Palo 'Jerde Nuclear Generating Station (PVNGS)
Unit 1 Docket No STN.50-528 (License NPF-41)
Notice of Violation:
50/528/86-20-01 File: 86-001-493
Reference:
Letter from D. F. Kirsch (NRC) to E. E. Van Brunt, Jr. (ANPP), dated July 22, 1986, NRC Inspection Reports 50-528/86-20, 50-529/86-20 and 50-530/86-14
Dear Mr. Martin:
This letter is provided in response to the inspection conducted by Messrs, R.
Zimmerman, C. Bosted, G. Fiorelli, J. Ball, and J. Melfi of the NRC Staff on May 27, through June 30, 1986. Based on the results of the inspection, one (1) violation of NRC requirements was identified (failure to establish a fire patrol in accordance with PVNGS Technical Specifications). The violation is discussed in Appendix A of the referenced letter. The violation and ANPP's response is provided in Attachment A.
Additionally, in response to the concern raised by the inspector regarding the time required to complete the patrols, an independent evaluation was conducted.
The evaluation consisted of an experienced nuclear operator, who was not familiar with the specific routes utilized, conducting the required patrol. The results achieved were consistent with the times normally required by the fire protection personnel. However, ANPP will evaluate this issue for implementation of potential enhancements.
Very truly yours, W
n%
E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/TDS/kj Attachments 8608270191 860813 PDR ADOCK 05000528 I '
G PDR,
j
Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-37750-EEVB/TDS-96.03 Page 2 of 9 cc:
J. G. Haynes (w/ attachment)
L. F. Miller (w/ attachment)
R. P. Zimmerman (w/ attachment)
E. A. Licitria (w/ attachment)
A. C. Gehr (w/o attachment) 7 e
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Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP 37750-EEVB/TDS-96'03 Page 3 of 9 4
bec:
R. M. Butler J. R. Bynum W. E. Ide
- 0. J. Zeringue T. D. Shriver W. F. Quinn P. J. Coffin R. W. Meyers J.
Vorees R. K.-Nelsen R. D. Zering LCTS Coordinator l
1 i
9
Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-37750-EEVB/TDS-96.03 Page 4 of 9 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Docket No. 50-528 Post Office Box 52034 License No. NPF-41 Phoenix, Arizona 85072-2034 Technical Specification 3.7 11.2.a requires that an hourly fire watch patrol be established for the "B" Low Pressure Safety Injection Pump Room whenever equipment in the room is required to be operable and the sprinkler system is inoperable.
Contrary to the above, when equipment in the room vas required to be operable and the sprinkler system was inoperable throughout the period of April 28 through June 19, 1986, hourly fire watch patrols of the "B" Low Pressure Safety Injection Pump Room were not established.
Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-37750-EEVB/TDS-96.03 Page 5 of 9 I.
THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On June 19, 1986, ANPP Management was informed that the methods being employed by personnel to implement an hourly fire patrol were inadequate to meet the intent of Technical Specification 3.7.11.2.a.
As discussed in the Inspection Report, the fire patrols were utilizing a video camera to examine the Low Pressure Safety Injection Pump (LPSI) room in lieu of physically entering the area.
Immediately upon the notification that a potential deficiency existed, ANPP Management directed the fire patrols to cease using the camera and commence physical area entry to ensure full compliance with the Technical Specification.
II. THE CORRECTIVE STEPS WHICH WILL BE TAKEN 'IT) AVOID FURTHER ITEMS OF NON-COMPLIANCE The compensatory watch (hourly fire watch patrols) was initially established ~
at 0620 on April 28, 1986, when the sprinkler valves were taken out of service
4 Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP-37750-EEVB/TDS-96.03 Page 6 of 9 o
due to spurious tripping of the deluge valve while decontaminating the Low.
Pressure Safety Injection (LPSI) pump room. At that time the "B" LPSI pump was undergoing corrective maintenance and three (3) video cameras were in-l stalled to permit supervision to monitor the activities without being exposed to a radiologically contaminated area. During this period, entrf to the lower room area required full protective clothing sad a. respirator. A decision was made by fire protection personnel to utilize the cameras as an aid to examine the room for potential fires, thus eliminating the i
possibility of exposing the fire patrols to this type of environment. Upon 1
completion of the pump maintenance, attempts were made to return the sprinkler system to service, however, a hole was discovered in the diaphragm of the deluge valve which prevented the system from being declared operable and necessitating the cantinuation of the compensatory fire patrol. At this time, a decision was made by fire protection personnel'to continue the use of one of the video cameras. Although it is believed that the use of the cameras may be an acceptable alternative, in lieu of physical entry, the
a ~
4 Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP 37750-EEVB/TDS-96.03 Page 7 of 9 method used to authorize the deviation from the normal practice was not in accordance with ANPP. Management philosophy.
Using this sequence of events as a basis, a root cause evaluation was con-ducted. The following conclusions were reached; The Fire Watch personnel did not provide the onshift Operations per-sonnel (Shift Supervisor / Assistant Shift Supervisor) with s'ufficient information for them to make an accurate evaluation of the potential impact on meeting the Technical Specification requirements.
Responsible ALARA personnel were not consulted to determine the camera's capablilities and proper method of operation.
Fire Watch personnel did not utilize the camera properly. The camera that remained installed at the completion of the corrective maintenance
-activity had the capability of examining at-least 90% of the room.
However,_the fire watch patrol personnel did not use this capability, leaving the camera focused on a fixed location.
Neither Health Physics or ALARA. personnel were consulted concerning t_
Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP 37750-EEVB/TDS-96.03 Page 8 of 9 the necessity for the use of the camera.
Fire Protection personnel did not use the methods available (such as a Technical Specification Interpretation) to obtain the necessary reviews and authorization prior to implecenting an alternate method for satisfying a Technical Specification requirement.
As described above there were.several contributory fa.ctors, however, the root cause can be directly attributed to a personnel error in that a decision was made to deviate from the normal methods of conducting fire patrols without obtaining the necessdry review and approval. In order to address the specific deficiency identified, fire protection personnel will be counseled on com-pliance with established guidance.
In addition, the responsible fire protec-tion supervisior. will be instructed on the proper methods of obtaining relief from established controls when circumstances arise which could preclude their safe or responsible implementation. The evaluation conducted also indicated the potential for similar circumstances to arise in other areas not only addressed in Technical Specifications but in the established administrative
Mr. John B. Martin Palo Verde Nuclear Generating Station ANPP 3775C-EEVB/TDS-96.03 Page 9 of 9 controls. To enure that the generic issue is also addressed, tbc methods of how to obtain relief from established commitments, interpretations of commitments, or clarification of established controls will be disseminated to project personnel.
III. TIIE DATE WIIEN FULL COMPLIANL/,WILL BE ACHIEVED Full compliance was achieved on June 19, 1986 when the hourly fire watch begaa to physically enter the LPSI pump room "B".
The additional corrective actions listed in Item 11 will be completed by October 31, 1986
.