IR 05000528/2010008: Difference between revisions
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| number = ML110670169 | | number = ML110670169 | ||
| issue date = 02/28/2011 | | issue date = 02/28/2011 | ||
| title = Palo Verde Nuclear Generating Station Units 1, 2 and 3 - NRC Problem Identification and Resolution Inspection Report 05000528-10-008, 05000529-10-008, 05000530-10-008, and Notice of Violation, | | title = Palo Verde Nuclear Generating Station Units 1, 2 and 3 - NRC Problem Identification and Resolution Inspection Report 05000528-10-008, 05000529-10-008, 05000530-10-008, and Notice of Violation, Dated January 28, 2011 | ||
| author name = Mims D C | | author name = Mims D C | ||
| author affiliation = Arizona Public Service Co | | author affiliation = Arizona Public Service Co |
Revision as of 02:03, 19 February 2018
ML110670169 | |
Person / Time | |
---|---|
Site: | Palo Verde ![]() |
Issue date: | 02/28/2011 |
From: | Mims D C Arizona Public Service Co |
To: | Document Control Desk, Office of Nuclear Reactor Regulation |
References | |
102-06326-DCM/DFH, EA-11-006 IR-10-008 | |
Download: ML110670169 (6) | |
Text
10 CFR 2.201EA-11-006A':AO A subsidiary of Pinnacle West Capital CorporationDwight C. Mims Mail Station 7605Palo Verde Nuclear Senior Vice President Tel. 623-393-5403 P.O. Box 52034Generating Station Regulatory Affairs and Oversight Fax 623-393-6077 Phoenix, Arizona 85072-2034102-06326-DCM/DFHFebruary 28, 2011ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001Reference: Palo Verde Nuclear Generating Station Units 1, 2 and 3NRC Problem Identification and Resolution Inspection Report05000528/2010008, 05000529/2010008, 05000530/2010008, and Noticeof Violation, dated January 28, 2011
Dear Sirs:
Subject: Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2 and 3Docket Nos. STN 50-528, 50-529, and 50-530Reply to Notice of Violation EA-11-006In the above referenced letter to Arizona Public Service (APS), the NRC identified thatAPS failed to correct a water intrusion path to the Unit 2 motor termination boxes for theemergency diesel generator fuel oil transfer pumps and implement adequate correctiveactions to preclude repetition.Pursuant to the requirements of 10 CFR 2.201 and Notice of Violation (NOV) EA-1 1-006,attached to the above referenced letter, APS hereby submits its reply to the NOV.Enclosure 1 to this letter contains a restatement of the violation. Enclosure 2 containsthe APS reply to the NOV.No commitments are being made to the NRC by this letter.A member of the STDARS (Strategic Teaming and Resource Sharing) Alliance ZZ7rJII-.Callaway * Comanche Peak * Diablo Canyon -Palo Verde -San Onofre -South Texas -Wolf Creek i ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionReply to Notice of Violation EA-1 1-006Page 2If you have any questions, please contact Marianne Webb, Regulatory Affairs,Compliance Section Leader, at (623) 393-5730.
Sincerely,DCM/MNW/DFH/gat
Enclosures:
1. Restatement of Notice of Violation EA-1 1-0062. Reply to Notice of Violation EA-1 1-006cc: E. E. Collins Jr.J. R. HallL. K. GibsonM. A. BrownNRC Region IV Regional AdministratorNRC NRR Senior Project Manager -(electronic / paper)NRC NRR Project Manager (electronic / paper)NRC Senior Resident Inspector for PVNGS Enclosure 1Restatement of Notice of Violation EA-1 1-006During an NRC inspection conducted on November 29, 2010 through December17, 2010, a violation of NRC requirements was identified. In accordance withNRC enforcement policy, the violation is listed below:10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action" requires, inpart, that measures shall be established to assure that conditions adverseto quality are promptly identified and corrected. In the case of significantconditions adverse to quality, the measures shall assure that the cause ofthe condition is determined and corrective action taken to precluderepetition.Contrary to the above, from April 2009 through September 2010, thelicensee failed to correct a significant condition adverse to quality andimplement adequate corrective actions to preclude repetition. Specifically,the licensee failed to correct a water intrusion path to the Unit 2 motortermination boxes for the emergency diesel generator fuel oil transferpumps, resulting in degraded electrical connections and a pump trip.This Notice of Violation is associated with a Green Significance DeterminationProcess finding.I Enclosure 2Reply to Notice of Violation EA-1 1-006Arizona Public Service (APS) concurs with the violation. The NRC IntegratedInspection Report 05000528/2010008, 05000529/20109008, and05000530/2010008, noted that APS failed to restore compliance of the Unit 2emergency diesel generator fuel oil transfer pumps (DFOTP) within a reasonabletime after the previous violation was identified in NCV 05000529/2009-004-002.The investigation concluded that the previous investigation did not recognize thepossibility for water to flow inside the control cable's outer jacket to cause anelectrical fault inside the motor termination box of the DFOTP.The Reason For The ViolationThe cause for failing to take adequate actions to correct the water intrusion pathto the Unit 2 motor termination box for the emergency diesel generator fuel oiltransfer pump (DFOTP) was that the investigation from the previous event didnot identify an internal water path through a degraded cable outer jacket to themotor termination box. Subsequent investigation determined that the probablecause for the degradation of the cable outer jacket which allowed the water pathto develop was the presence of an unknown chemical contaminant on the cablejacket. Corrective actions from the previous investigation focused on anelectrical short to ground inside the motor termination box as a result of moistureand corrosion inside the motor termination box. The moisture source was thoughtto have been caused by water traveling through the conduit around the cablesinstalled in the conduit. The previous investigation did not recognize thepossibility for water to flow inside of the control cable's outer jacket to the motortermination box.The Corrective Steps That Have Been Taken And The Results AchievedAs an immediate corrective action, the two conductor control cables and threeconductor power cables from the cable pull boxes in the DFOTP vault to themotor termination boxes for the six site DFOTPs were replaced. The control andpower cables were spliced to interrupt the drain path through the cable outerjacket around the cables and prevent possible future water drainage into themotor termination box. Additionally, boroscopic examinations were performed forthe accessible sections of cable between the diesel building and the DFOTP1 Enclosure 2Reply to Notice of Violation EA-1 1-006vault. This section of cable for the Unit 2 train A DFOTP was replaced due to thedegraded condition of its outer jacket. No additional cables in the areasinspected boroscopically needed to be replaced. Finally, the motor terminationboxes for the Unit 2 trains A and B DFOTP were replaced due to corrosion. TheUnits 1 and 3 motor termination boxes were inspected and exhibited no evidenceof corrosion or moisture intrusion.These actions eliminate the potential water flow path to the DFOTP motortermination box through the inside of the cable's outer jacket.The Corrective Steps That Will Be Taken To Avoid Further ViolationsIn addition to the actions described above, the following design modification,specification changes and extent of condition evaluation will be performed." Implement a Design Change Request (DCR) to replace the undergroundduct banks and associated cabling from all three EDG buildings to the sixsite DFOST vaults with direct buried submersible cables." Revise installation specification 13-EN-0300 "Installation Specification forElectrical Cable in Cable Trays" and 13-EN-0301 "InstallationSpecification for Electrical Cables in Conduit and Duct Banks" to identifycompatible chemicals for cleaning cables." Revise installation specification 13-EN-0306 "Installation Specification forCable Splicing and Termination" to add a requirement to install a cablesplice or other means of blocking the flow of water internal to the outerjacket of cables where an electrical component is at a location such that ahydrostatic head may be developed with respect to the cables.* Evaluate the need for cable splices for critical components andcomponents that support key safety or operational functions, that arelocated in areas where water may be transported through the outer jacketof the cables.2 Enclosure 2Reply to Notice of Violation EA-1 1-006Additionally, Palo Verde will continue to monitor the EDG DFOTP cables as partof the Palo Verde preventive maintenance program to ensure the actions takenare effective to prevent water flow to the DFOTP motor termination box.The Date When Full Compliance Will Be AchievedFull compliance was achieved on September 23, 2010, with the replacement ofthe two conductor control cables and three conductor power cables for the Unit 2trains A and B DFOTP. During replacement these cables were spliced tointerrupt the drain path and prevent possible future water drainage into the motortermination box through a path internal to the jackets around the cables.3