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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML20206Q3111999-05-18018 May 1999 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML20205T7421999-04-21021 April 1999 Forwards Partially Withheld Insp Repts 50-528/99-05, 50-529/99-05 & 50-530/99-05 on 990322-26.Determined That Security Program Properly Implemented.Insp Repts Details Withheld (Ref 10CFR73.21) ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe ML17313A8241999-02-23023 February 1999 Advises That Kp Jarvis,License OP-50287-1,no Longer Needs to Maintain License as Permanently Assigned to Position Requiring No License ML17313A8111999-02-18018 February 1999 Forwards PVNGS Unit 3 7th Refueling Outage, Which Provides Complete Results of SG Tube Inservice Insp Performed,Per TS 5.6.8 ML17313A8721999-02-16016 February 1999 Discusses Resolution of Generic Safety Issue 171, ESF Failures from Loss-of-Offsite Power Subsequent to Loca. Util Has Low Vulnerability to Loca/Grid Collapse/Loop Scenario ML17313A7611999-01-22022 January 1999 Forwards PVNGS Unit 3 Inservice Insp Rept Seventh Refueling Outage, Per 10CFR50.55a.Ltr Contains No New Commitments 1999-09-08
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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
D D
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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