ML20209B662
| ML20209B662 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/19/1987 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20209B584 | List: |
| References | |
| ANPP-39745-EEVB, NUDOCS 8702040095 | |
| Download: ML20209B662 (10) | |
Text
'
Arizona Nuclear Power Project P o. box 52034 e PHOENIX, ARIZONA 85072-2034 January 19, 1987 ANPP-39745-EEVB/TDS-98.05 is U. S. Nuclear Regulatory Commission
~
Region V m
1450 Maria Iane, Suite 210 E
g
~~
g Walnut Creek, California 94596-5368 g
gT rn Attention:
Mr. John B. Martin U
g Regional Administrator
<A
Subject:
Palo Verde Nuclear Generating Station (PVNGS) co Unit 2 Docket No. STN 50-529 (License NPF-51)
Response to Notice of Violation 50/529/86-32-04 File: 87-070-026; D.4.33.2; 87-056-026
Reference:
(a) Letter from J. B. Martin, NRC to E. E. Van Brunt, Jr., ANPP, dated December 19, 1986.
Subject:
NRC Inspection Report Nos.
50/528/86-23; 50-529/86-32; 50/530/86-26.
Dear Sir:
Referer.ce (a) inclades, as Appendix A, a Notice of Violation, dated December 19,1986 (the " Notice"), a copy of which is attached hereto as Attachment No.
1.
As required by the Notice, a Response to the Notice of Violation is submitted as Attachment No. 2 hereto.
Reference (a) and Section 7a.(2) of the Inspection Report attached thereto express concerns respecting the implementation of the root cause analysis program currently in ef fect at Palo Verde, i.e., that safety-related work orders are not routinely reviewed by the organization responsible for the perforrance of root cause analyses and, as a consequence, may not be aware of the needs to conduct such analyses.
As requested by Reference (a), Attachment No. 3 hereto addresses such concerns and describes the changes to be made in the root cause analysis program and its I
implementation.
l t
~
8702040095 870128 PDR ADOCK 05000529 G
PDR i
l led /
Mr. John B. Eartin Palo Verde Nuclear Generating Station Page 2 of 2 If there are any questions respecting either Attachment No. 2 or Attachment No. 3 or if any additional information respecting the root cause analysis program is desired, we will be pleased to provide the desired answers or information.
Very truly ou C,
Q_LL n LLL E. E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/TDS/c1d Attachments cc:
J. G. Haynes A. C. Gehr R. P. Zimmerman E. A. Licitra S.
Richards
1Mr.' John B. Martin alo Verde' Nuclear Gcnerating Station D
' age 1 of 2 ATTACIMENT NO.1 NOTICE OF VIOLATION Arizona Nuclear Power Project Docket No. 50-529 Post Office Box 52034 License No. NPF-51 Phoenix, Arizona 85072-2GJ4 As a result of the inspection conducted on October 13, 1986 - November 25, 1986 and in accordance with NRC Enforcement Policy,10 CFR 2, Appendix C, the following violation was identified:
10 CFR 50.73.b states that a Licensee Event Report must include the cause of each component failure, if known - following any event or condition that resulted in an. engineered safety feature (ESP) actuation.
i
?
Contrary to the above, Licensee Event Report 2-86-046 submitted on October 17, 1986, -did not-include the known failure mode for a steam generator blowdown 4
containment isolation valve (2JSBUV500Q) which failed to fully close upon receipt of an ESF containment isolation actuation signal on September 22, 1986.
Results of licensee troubleshooting following the event, on September.22, determined that a plugged muffler on the solenoid discharge vent line prevented the containment isolation valve from completing approximately the last 10%
'of its travel.
This is a Severity Level IV Violation (Supplement 1)
Pursuant to the provisions of 10 CFR 2.201, Arizona Public Service Company is I
hereby required to submit-to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including, (1) the corrective steps which have been taken and the results achieved; t
.-.m-a-,m.,.
e.
nn.,,,-e-.,,.w---
+
..-n-,,-.mgg-n n.
g
,--r,--e..,
,,-mpm,-,-.w--,--
I e
,' Mr John B. Martin Palo Verde Nuclear Generating Station Page 2 of 2 (2) corrective steps which will be taken to avoid further items of noncompl4ance; and (3) the date when full compliance will bc achieved. Consideration may be given to extending your response for good cause shown.
l I
l*'
'Mr. John B. Martin Palo. Verde Nuclear Generating Station Page 1 of 2 ATTACIBGDIT NO. 2 ~
RESPONSE *IO NOTICE OF VIOLATION DATED DECEMBER 19, 1986
. -Corrective Steps Which Have Been Taken and The Results Achieved Licensee concedes that the LER did not contain the root cause of the failure of valve V500Q to fully close. The root cause of not including this information in the LER is attributable to the' fact the craf tsmen performing the troubleshooting work did not fully document such work and the observations which they made. A costributing factor was the criteria used for initiating a root cause analysis and a weakness in communication of the failure to the organization responsible for root cause analysis.
When the full facts were reported on December 4,1986, a formal root cause analysis was performed and completed on December 19, 1986. As a result of such root cause analysis, the following steps have been completed:
-1.
V500Q valves and similar valves equipped with mufflers on Units 1, 2, and 3 have been identified.
2.
Mufflers identified in step 1 for Units 1 and 2 have been examined
. or verified to be free from restriction.
Corrective Steps Which Will Be Taken To Avoid Further Items of Noncompliance
. 1 '.
Craft personnel and their supervisors will receive training emphasizing the need for completeness in describing work performed and observations made. Training of maintenance personnel currently employed will be P
completed by Fbrch 1, 1987, s
. Mr. John B. Martin Palo Verde Nuclear Generating Station Page 2 of 2 2.
In addition, actione will be taken as reported in Attcchment No. 3 to address the concerns stated in Reference (a).
3.
A site modification has been initiated to change the current design of the ef fected valves, identified in step 1 of the preceding section, by removing the mufflers. The modification is expected to be completed during the first refueling outage for each of the three (3) units.
Date When Full Compliance Will Be Achieved A supplement to the LER addressing the cause of the failure of valve V500Q to close will be filed by February 15, 1987.
~
Mr.' John B.' Martin Palo Verde Nuclear Generating Station Page 1 of 4 ATTACIMENT NO. 3 RESPONSE 'It) ADDITIONAL CONCERNS AS REQUESTED IN COVER LETTER In your response to the enclosed violation, we request that you address our additional concerns regarding:
CONCERN 1.
How do you intend to ensure that thorough corrective action, including any generic implications, is initiated for conditions adverse to quality?
RESPONSE
As stated in the inspection report, the ANPP Quality Organization identified a potential weakness in the process for initiating root cause analysis. As a result, Corrective Action Report (CAR)
CA86-0196 was issued to document and obtain resolution for the identified concerns as discussed below. The actions to be taken are extensive, not limited to the specific concern identified, and should provide a positive overall enhancement for the root cause analysis program. The following actions are expected to be fully implemented by April 1, 1987.
An evaluation has been initiated to review the work control program. The intent of this evaluation is to ensure that safety related component failures or anomalies are required i-to be promptly and accurately reported to the responsible organization for further evaluation for conditions adverse J
to quality in accordance with established criteria.
i l
l l
Mr. John B. Martin Palo Verde Nuclear Generating Station Page 2 of 4 An evaluation will be conducted by the responsible organization to determine if the performance trend analysis program is consistent with current regulatory requirements and project needs. This evaluation will specifically address the required review intervals, evaluation criteria and reporting requirements.
Based upon the results of these evaluations, necessary procedural controls will be established or revised as necessary to ensure thorough corrective action is initiated for conditions adverse to quality.
In order to ensure that potential generic implications for performance levels considered adverse to quality are addressed, procedural controls will be established that require a specific evaluation for components which may be subject to similar failure mechanisms.
The actions described above will establish an acceptable component performance level, identification of performance levels considered adverse to quality and ensure thorough corrective actions are initiated as appropriate. ANPP believes that implementation of these actions will resolve the identified concern.
Mr. John B. Martin Palo Verde Nuclear Generating Station Page 3 of 4 CONCERN 2.
How do you plan to correct the apparent weakness in the implemen-tation of your root cause analysis program associated with how significant failures are to be identified for further formal analysis and generic resolution?
RESPONSE
Under the current programmatic controls, significant events which effect plant operations are normally documented as Potentially Reportable Occurrences (PR0's). This was originally designed to ensure that immediate reporting requirements were met and to ensure that each event is evaluated under the require-ments of 1G CFR 50.73.
In order to provide an independent overview and to ensure that significant component failures are adequately evaluated to determine the root cause of the failure, the engineers responsible for the initial review of PRO's have been instructed to ensure a root cause failure analysis request has been initiated for any component failure or anomaly identified.
This includes identified component failures or anomalies associated with plant equipment documented on PRO's regardless of the perceived significance. These actions will provide independent assurance that the evaluations discussed in the response to concern 1 are promptly and effectively implemented.
In addition to the actions described above, Engineering personnel have been instructed to initiate a root cauce failure analysis request for any component failure which requires entry into an
Mr. John B. Martin Palo Verde Nuclear Generating Station Page 4 of 4 action statement required by the Technical Specifications or entry into Technical Specification Section 3.0.3.
The combination of these controls should ensure the prompt identification and evaluation of significant failures associated with plant equipment. As stated in the response to concern 1 procedural controls will be established that require a specific evaluation for components which may be subject to similar failure mechanisms. Full implementation of all actions is expected to be completed by April 1, 1987.
-