ML17310A327

Responds to NRC 930505 Ltr Re Violations Noted in Insp Rept 50-529/93-15.C/A:condition Rept Disposition Request 930277 Created

ML17310A327
Person / Time
Site:	Palo Verde
Issue date:	06/08/1993
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02531-WFC-T, 102-2531-WFC-T, NUDOCS 9306150058
Download: ML17310A327 (24)

Text

ACCELERATED DOCUMENT DISTRIBUTION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

'CCESSION NBR:9306150058 DOC.DATE: 93/06/08 NOTARIZED: NO DOCKET FACIL:STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 AUTH. NAME 'AUTHOR AFFILIATION

~VINEiJ.M. Arizona Public Service Co. (formerly Arizona Nuclear Power ECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 930505 ltr re violations noted in insp rept 50-528/93-15,50-529/93-15 & 50-529/93-15.Corrective action:

Condition rept disposition request 930277 created. D DISTRIBUTION CODE: IE01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:Standardized plant. 05000529 /

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV PD 1 1 TRAMMELL,C 1 1 D TRANiL 1 1 D

INTERNAL: ACRS 2 2 AEOD/DEIB 1 1 AEOD/DSP/TPAB 1 1 AEOD/TTC 1 1 DEDRO 1 1 NRR/DRCH/HHFB 1 1 NRR/DRIL/RPEB 1 1 NRR/DRPW/OEAB 1 1 NRR/DRSS/PEPB 1 1 NRR/PMAS/ILPBl 1 1 NRR/PMAS/ILPB2 1 1 NUDOCS-ABSTRACT 1 1 GE DI 1 1 OGC/HDS1 1 1 1 1 RES MORISSEAU,D 1 1 RGN5 FILE 01 1 1 EXTERNAL EGGG/BRYCE i J ~ H ~ 1 1 NRC PDR 1 1 NSIC 1 1 D

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

E Arizona Public Service Company P,O. BOX 53999 ~ PHOENIX, ARIZONA 85072-3999 102-02531-WFC/TRB/DLK WILLIAMF. CONWAY EXECUTIVEVICEPAESIOENT June 8, 1993 NUCLEAR U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Dear Sirs:

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Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notice of Violations 50-529/93-15-01 and 50-529/93-1 5-02 File: 93-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528/529/530/93-15 and the Notice of Violations dated May 5, 1993. Pursuant to the provisions of 10 CFR 2.201, APS'esponses are enclosed. Enclosure 1 to this letter is a restatement of the Notice of Violations. APS'esponses are provided in Enclosure 2.

The due date for this response was extended from June 4, 1993;to June 9, 1993, during a telephone conversation with Mr. L. F. Miller on June 4, 1993, in order to allow adequate time for senior management review.

Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.

Sincerely, IP WFC/TRB/DLK/rv

Enclosures:

1. Restatement of Notice of Violations

2. Reply to Notice of Violations cc: B. H. Faulkenberry J. A. Sloan L4008. P 930bf50058 930b08 05000529 PDR ADOCK 8

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ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATIONS 50-529/93-1 5-0'I AND 50-529/93-'I 5-02 NRC INSPECTION CONDUCTED APRIL 5 THROUGH APRIL 9, 1993 INSPECTION REPORT NOS. 50-528/529/530/93-1 5

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Restatement of Notice of Violations 50-529 93-15-01 and 50-529 93-15-02 During an NRC inspection conducted during the week of April 5 through April 9, 1993, two violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are identified below:

A. Violation 50-529 93-15-01 PROCEDURAL COMPLIANCE Technical Specification 6.8.1 states in part that, 'Written procedures shall be established, implemented, and maintained covering. .applicable procedures

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recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978...." Appendix A of Regulatory Guide 1.33 specifies procedures for procedure adherence in performing tests and inspections.

Palo Verde Nuclear Administrative and Technical Manual (NATM) Procedure 01PR-OAP01, Revision 01.03, "Administrative Controls Program," Section 3.7.3 requires that, "Procedures shall be used, adhered to and enforced."

Palo Verde NATM Procedure 81AC-ODC01, Revision 04.03, "Procedure for Design Changes," Section 3.2.3.d states, "Design...output (e.g., drawings, databases) documents affected by the design modification and the required changes shall be prepared or identified as part of the design change package."

Contrary to the above, Design Change Package (DCP) 2XE-SG-163, "Main Steam Isolation Valve Control Console Power," did not identify that Key drawing 02-E-PKB-001, "Elementary Diagram 125V DC Class 1E Power System," was affected by the design modification and was required to be changed. DCP 2XE-SG-163 was completed in Unit 2 in December 1991 ~

As of April 5, 1993, Key drawing 02-E-PKB-001 had not been updated.

2. Palo Verde NATM Procedure 81AC-ODC01, Section 3.2.6 states that, "Documents, processes, training, etc., affected by the design modiTication...shall be identified, recorded, statused, and updated...."

Contrary to the above, as of April 5, 1993, NATM Procedure 42AL-2RK1A, "Panel B01A Alarm Response," which was affected by DCP 2XE-SG-163, had not been identified, recorded, statused, or updated.

Palo Verde Design Change Package (DCP) 2XE-SG-1 63 and implementing Unit 2 Work Order 519134 [sic] required that the retest for the DCP be performed in accordance with Generic Procedure 70GT-OZZ01, Revision 1, Preliminary Change Notice 1, "Electrical Circuit Test." Section 7.2 of Page 1 of 2

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Procedure 70GT-OZZ01 required that, "Only Operations/Systems Engineers or Maintenance PC [Planning Coordinator] shall place N/A's in data sheets where steps are not applicable for required testing."

Contrary to the above, during performance of 70GT-OZZ01 for Work Order 519134 [sic] in Unit 2, the performing mechanic placed an N/A beside a number of procedure testing steps, including verification of proper wiring, with no evidence of System Engineer/Maintenance PC concurrence. The steps that were "NA'd" or "marked N/A" were not performed. The completed data was inadequate to demonstrate that one of two new 125 volt direct current power sources had been tested to ensure that it would properly supply power to the main steam isolation valves.

This is a Severity Level IV violation (Supplement 1), applicable to Unit 2.

B. Violation 50-529 93-15-02 UPDATED FINAL SAFETY ANALYSIS REPORT CHANGES 10 CFR Part 50.71, Records and Reports, states in Section e(4) that, "Subsequent

[Updated Final Safety Analysis Report (UFSAR)] revisions must be filed annually or 6 months after each refueling outage.... The revisions must reflect all changes up to a maximum of 6 months prior to the date of filing."

Palo Verde NATM Procedure 81AC-ODC01, Section 3.1.7 states, "Licensing document changes shall be prepared during development of the appropriate design change packages...and processed in accordance with the requirements of the associated licensing document change implementing procedure (e.g.,

UFSAR...)."

Contrary to the above, as of April 5, 1993, the UFSAR, Revision 5, dated March 1993, did not include changes to Unit 2 required by DCP 2XE-SG-163, which was completed in Unit 2 in December 1991, during the Unit 2 R3 outage. The Unit 2 R3 outage was completed in January 1992.

This is a Severity Level IV violation (Supplement 1), applicable to Unit 2.

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ENCLOSURE 2 REPLY TO NOTICE OF VIOLATIONS 60-529/93-1 5-01 AND 60-529/93-I 5-02 NRC INSPECTION CONDUCTED APRIL 5 THROUGH APRIL 9, 1993 INSPECTION REPORT NOS. 50-528/529/530/93-15

Re I to Notice of Violation A 50-529 93-15-01 Reason for the Violation Notice of Violation (NOV) 50-529/93-1 5-01 cites three examples where APS failed to follow procedures during the development and implementation of Design Change Package (DCP) 2XE-SG-163. The reason for the Violation in ail three examples was lack of attention to detail on the part of Design Engineering, Work Control Planning, and Plant Engineering. An additional reason, for the third example, was personal error on the part of the maintenance technician.who, contrary, to section 7.2 of 70GT-OZZ01, "Electric Circuit Test," marked several ste'ps "N/A", while performing Work Order (WO) 519034.

During the development of DCP 13XE-SG-163, (of which 2XE-SG-163 is the portion applicable to Unit 2), Design Engineering overlooked the need to revise or reference key drawings 1,2,3-E-PKB-001. At the time DCP 13XE-SG-163'was developed, a manual process was used to identify affected drawings. The manual process was cumbersome and not always effective in identifying all affected drawings. The key drawing information was essential for Operations Standards to identify the operating procedures needing revision. Because drawings 1,2,3-E-PKB-001 were not referenced in the DCP, Operations Standards did not recognize the need to revise the alarm procedure 4(X)AL-(X)RK1A during the DCP impact review.

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During implementation of DCP 2XE-SG-163, Work Control Planning overlooked the need to include a voltage polarity test, in addition to 70GT-QZZ01, as a retest requirement in WO 519034. When the maintenance technician performed 70GT-OZZ01, as part of WO 519034, he placed an "N/A" next to several steps which, according to the drawings provided in the DCP, were not required to be performed. The absence of a voltage polarity test and the unauthorized changes made to 70GT-OZZ01 were overlooked by Plant Engineering, during the "Inservice Verification" performed upon completion of 2XE-SG-1 63.

Corrective Actions Taken and Results Achieved Condition Report Disposition Request (CRDR) 930277 was written to investigate the three problems identified in NOV 50-529/93-15-01, and to review the adequacy of post-modification testing performed for DCPs 1,2,3XE-SG-163. Post-modification testing performed in Unit 3 was satisfactory; however, the post-modification testing in Units 1 and 2 was not adequate. A clearance has been hung in Unit 1 which prevents switching Main Steam Isolation Valve Control Console Power to the alternate power source until the complete post-modification tests for 1XE-SG-163 can be reperformed (currently scheduled for refueling outage 1R4) Unit 2, presently in a refueling outage, will complete

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post-modification testing for 2XE-SG-163 prior to restart.

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Other corrective actions completed under CRDR 930277 include the following:

~ 4(X)AL-(X)RK1 A, "Panel B01 A Alarm Responses," was revised to include the responses for the new alarms added by DCPs 1,2,3XE-SG-163.

~ Key drawings 1,2,3-E-PKB-001 have been revised to include the alarm contacts added by DCPs 1,2,3XE-SG-163.

~ The maintenance technician, who placed an "NA" next to several steps during the performance of 70GT-OZZ01 for WO 519034, was counseled, by his direct supervisor, for failing to follow procedure.

In conjunction with the corrective actions taken for the NOV, Engineering is reviewing design changes, completed on critical systems and components during the past two years, to verify adequate testing was performed. The review is expected to be completed by June 30, 1993.

Finally, two recent changes have occured at PVNGS that should prevent this from recurring. First, an Area Field Engineer (AFE) Program was implemented in 1992, which provides dedicated engineering oversight during DCP implementation. The AFE program was effective in identifying and correcting the post-modification testing deficiencies during the implementation of 3XE-SG-1 63. Second, the Station Information Management System Page 3 of 6

I (SIMS) was enhanced in 1992, integrating the Drawing Document Registry with the Equipment Document Reference screen. This computerized cross reference readily identifies applicable drawings associated with a specific equipment tag number, thereby reducing the possibility of overlooking a draw'ing that may be affected by a DCP.

Corrective Actions That Will Be Taken To Avoid Further Violations The actions discussed above are adequate to avoid further violations.

Date When Full Com liance Will Be Achieved Full compliance was achieved on June 2, 1993, when key drawings 1,2,3-E-PKB-001 were revised to include the alarm contacts added by DCPs 1,2,3XE-SG-163.

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Re I To Notice Of Violation B 50-52993-15-02 Reason for the Violation APS denies the Violation.

The PVNGS Updated Final Safety Analysis Report (UFSAR) states in the Foreword:

"Descriptions of physical changes to PVNGS are included in the UFSAR after the changes have been approved for use and are operable in all units, unless the changes are unique to a specific unit (or units). For unit-specific changes, the change is identified in the UFSAR upon completion in the affected unit (or units)."

DCPs 1,2,3XE-SG-163 were implemented in all three units. Unit 3 was the last unit to complete the DCP. The "Inservice Verification" for 3XE-SG-163, was signed October 31, 1992, which was within six months of the filing date for Revision 5 to the PVNGS UFSAR (March 12, 1993). APS was in compliance with 10 CFR Part 50.71.

Corrective Actions Taken And Results Achieved Since APS was in compliance with 10 CFR 50.71, no corrective action was required. The Licensing Document Change Request (LDCR) associated with 1,2,3XE-SG-1 63 has been Page 5 of 6

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submitted to the Nuclear Regulatory Affairs Department for inclusion into Revision 6 of the UFSAR. CRDR 930336 was initiated as a result of the identified concern discussed at the NRC exit meeting on April 9, 1993.

The investigation, conducted under CRDR 930336, has recommended additional controls over the UFSAR change initiation process to provide added assurance that descriptions of physical changes to PVNGS are incorporated into the annual UFSAR update, in accordance with 10 CFR 50.71. These recommendations are currently being evaluated.

Corrective Actions That Will Be Taken To Avoid Further Violations None required.

Date When Full Com liance Will Be Achieved Full compliance was achieved at all times.

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