ML17300A292

Responds to NRC 860613 Ltr Re Violations Noted in Insp Rept 50-529/86-17.Corrective Actions:Air Lock Seal Leak Test Procedures Revised & Engineers Counseled.Containment Airlock Door Successfully Tested & Closed on 860411

ML17300A292
Person / Time
Site:	Palo Verde
Issue date:	07/07/1986
From:	HAYNES J G ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	MARTIN J B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML17300A291	List: ML17300A292
References
ANPP-00015-JGH, ANPP-15-JGH, NUDOCS 8608040233
Download: ML17300A292 (15)

See also: IR 05000529/1986017

Text

Qi Arizona Nuclear Power Project P.o.BOX 52034~PHOENIX, ARIZONA 85072-2034

RK8~iEO HRI: iS86 JUL lt;PH l: 02 July 7, 1986 ANPP-00015-JGH/TDS/96.03

hkGtON V lKf: 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 Verde Nuclear Generating

Station (PVNGS)Unit 2 Docket No STN 50-529 (License NPF-51)Notice of Violation:

50-529/86-17-02

File: 86-001-493

Reference:

Letter from A.E.Chaffee (NRC)to E.E.Van Brunt, Jr.(ANPP), dated June 13, 1986, NRC Inspection

Reports 50-528/86-16, 50-529/86-17

and 50-530/86-11.

Dear Mr.Martin: This letter is provided in response to the inspection

conducted by Messrs.R.Zimmerman, C.Bosted, G.Fiorelli and J.Ball of the NRC Staff on April 14 through May 26, 1986.Based on the results of the inspection, one (1)violation of NRC requirements

was identified (failure to follow procedure during contain-ment air lock seal leak test).The violation is discussed in Appendix A of the referenced

letter.The violation and ANPP's response is provided in Attach-ment A.The response to the concern of general procedural

adherence as discussed in the referenced

letter is provided in Attachment

B.Very truly yours, 8608040233

860729 PDR ADOCK 05000529 , PDR~J.G.Haynes Vice.President Nuclear Production

JGH/TDS/kj

Attachments

cc: E.E.Van Brunt Jr.L.F.Miller R.P.Zimmerman E.A.Licitria A.C.Gehr (w/attachment)(w/attachment)(w/attachment)(w/attachment)(w/o attachment)

Mr.John B.Martin Palo Verde Nuclear Generating

Station Notice of Violation ANPP-00015-JGH/TDS/96.03

Page 2 bcc: R.M.Butler J.R.Bynum W.E.Ide 0.J.Zeringue T.D.Shriver W.F.Quinn LCTS Coordinator (all w/attachments)

0

ANPP-00015-JGH/TDS/96.03

NOTICE OF VIOLATION Arizona Nuclear Power Project Post Office Box 52034 Phoenix, Arizona 85072-2034

Docket No.50-529 License No.NPF-51 Technical Specification 6.8.1.c requires that written procedures

be estab-lished and implemented

for surveillance

and test activities

of safety-related equipment.

PVNGS Manual Procedure 73ST-9CL03, Containment

Airlock Seal Leak Test, Revision 1 (through procedure change notice number 3), effective February 7, 1986, paragraph 10.0, Contingencies, states that when the inner door fails the seal leak test and requires repair, the outer door shall remain closed until repair and retest have been satisfactorily

completed.

Contrary to the above, on April'll, 1986, the Unit 2 140'ontainment

air-lock inner door failed a seal leak test performed'using procedure 73ST-9CL03, and the outer door was opened prior to satisfactory

repair and retest of the inner door.

~8 ANPP's RESPONSE TO VIOLATION I.THE CORRECTIVE

STEPS MiICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As an immediate corrective

action the engineers involved were counseled on the importance

of procedural

adherence and ANPP's policy concerning

deviations

from that position.Additionally, the Tech-nical Support Department

Manager issued a memorandum

to all personnel in the department

addressing

the importance

of preventing

personnel errors during the performance

of assigned tasks and reiterating

the consequences

of committing

errors through negligence.

The procedure, which was being utilized during the airlock seal I leak test, has been revised to clarify the differences

between Unit I and Unit II's Technical Specifications.

An evaluation

of the overall effectiveness

of these measures is discussed in Attach-ment B.II.THE CORRECTIVE

STEPS WHICH MILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE

An evaluation

was conducted to determine the root cause of the identified

deficiency.

Based upon the results of the evaluation

it was determined

that the event was caused by a conscious decision made by the responsible

personnel to violate the established

pro-cedural controls.Their decision was based on a known difference

between Unit I and Unit II's Technical Specifications.

The dif-ference, as explained in the inspection

report, permits the operable door to be opened for a cumulative

time not to exceed one hour per year in Unit II.The procedure being used during this activity, 73ST-9CL03"Containment

Airlock Seal Leak Test", was written to

lf 1

address the requirements

of Unit I's Technical Specifications

and does not provide the option to open the operable door.The respon-sible, personnel were aware that performing

the tasks in the manner that they did, had no safety impact and did not violate Unit II's Technical Specification 3.6.1.3.They were also aware that their actions were contrary to the requirements

of the approved procedure.

Therefore, based on ANPP Management's

continued attention to issues such as procedural

adherence, a broad scope plan has been developed.

This plan is discussed in Attachment

B.III.THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

was achieved on April ll, 1986 when the Containment

Airlock Door was successfully

tested and closed.

I

ANPP-00015-JGH/TDS-96.03

ATTACHMENT

B In response to the general issue discussed in the referenced

letter, an evaluation

was conducted to address not only the specific incidents identified

but the generic question of procedural

adherence.

The in-spection report transmittal

letter states that the potential for a more general problem exists based on two previous concerns of procedural

noncompliance

identified

in 1985.The specific incidents described were attributed

to willfull violations

of procedural

controls, committed by knowledgeable

individuals

without ANPP Management's

knowledge.

The incidents cited, when evaluated in the overall context of procedural

adherence, appear to be isolated cases which could only be addressed as they were on a case by case basis.However, during the course of the evaluation, potential areas of weakness I.in procedural

adherence were identified.

These areas have been isolated to individual

departments

and do not appear,,to

represent a generic con-II I cern.ANPP Management's

continued concern in this area is demonstrated

by the implementation

of various corrective

measures whenever a potential problem such as this was identified.

Since 1983, ANPP Management

has implemented

various programs and initi-ated changes to existing programs to reduce both personnel errors and procedural

violations.

These efforts have included: a.Establishment

of a"Quality Improvement

Report" (QIR)program in the IRC Maintenance

area.This program was designed to investigate

various incidents, determine the cause and develop the necessary corrective

action plan.This program was implemented

in IRC Maintenance

initially because of

~~~p~~r specific concerns identified

that appeared unique to that area.b.Expansion of the QIR program to include all areas of the Main-tenance Department.

c.Modifying the existing administrative

controls which specify how approved procedures

may be revised or changed.This was done to expedite the process and enable the user to easily modify an existing procedure whenever an error was discovered

or a potential enhancement

was identified.

d.Establishment

of the"Operations

Department

Experience

Report"\((ODER)program.This program was designed to achieve the same objecti'ves

as the QIR program.In conjunction

with the specific programs described above additional

generic actions were taken.These included: a.The production

of a video tape by the Executive Vice President in which he stressed the criticality

of procedural

adherence.

This video was required to be viewed by all PVNGS personnel and is currently being used during the new employee indoctrina-

tion.b.The topic of procedure adherence was repeatedly

used as a topic in the"Quality Talks" program.c.Including the topic of"Procedural

Adherence" in the"Site Access Training" program (SAT).As described above various approaches

had been taken in the past to address not only the generic issue of procedural

adherence but to speci-fically address identified

weaknesses

and concerns.The individual

successes of these programs varied.However, the implementation

of the QIR and accelerated

disciplinary

programs in the I&C Maintenance

area proved effective.

Based upon the success achieved the decision

~~~0 l l(

area proved effective.

Based upon the success achieved the decision t was made to utilize this approach to address the recently identified

concerns.The basic program is being expanded to include all individuals

reporting to the Plant Manager.The initial implementation

of this program was begun on July 7, 1986, when the Plant Manager issued a memo-randum to all PVNGS personnel stressing the necessity to reduce personnel errors and to comply with all station procedures.

The memorandum

also emphasized

the potential for administering

accelerated

disciplinary

action for any individual

who, through willfull intent or negligence, commits an error or procedural

violation.

The Compliance

Manager has been assigned the responsibility

to develop the remaining portions of the program which includes: a.Expansion of the existing QIR program philosophy

to encompass all departments

reporting to the Plant Manager.This approach will ensure that a comprehensive

review is conducted for all incidents effecting the department, that'the root cause is identified

and that effective corrective

actions are initiated.

I b.Establishment

of a committee, consisting

of the Plant Manager and his direct reports, to review incidents and interview per-sonnel found to have willfully or through negligence

committed an error or procedural

violation.

This committee will evaluate the incidents on a case by case basis and recommend appropriate

disciplinary

actions.ANPP Management

believes that full implementation

of this comprehensive

program, expected by October 1, 1986, will successfully

control and reduce both personnel errors and procedural

violations.

r

P