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)

See also: IR 05000529/1993015

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.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response D NOTES:Standardized

plant.05000529/RECIPIENT ID CODE/NAME PDV PD TRANiL INTERNAL: ACRS AEOD/DSP/TPAB

DEDRO NRR/DRIL/RPEB

NRR/DRSS/PEPB

NRR/PMAS/ILPB2

GE DI RGN5 FILE 01 EXTERNAL EGGG/BRYCE

i J~H~NSIC COPIES LTTR ENCL 1 1 1" 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME TRAMMELL,C

AEOD/DEIB AEOD/TTC NRR/DRCH/HHFB

NRR/DRPW/OEAB

NRR/PMAS/ILPBl

NUDOCS-ABSTRACT

OGC/HDS1 RES MORISSEAU,D

NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D 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 ELIMINATE YOUR NAME FROM DISTRIBUTION

LISTS FOR DOCUMENTS YOU DON'T NEED!D TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

E

WILLIAM F.CONWAY EXECUTIVEVICE

PAESIOENT NUCLEAR Arizona Public Service Company P,O.BOX 53999~PHOENIX, ARIZONA 85072-3999

102-02531-WFC/TRB/DLK

June 8, 1993 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555 Dear Sirs: Subject: f g 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 PDR ADOCK 05000529 8

i (t

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

(]'

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

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

E j l fl~k I J

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.Page 2 of 2

l i t

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.Page 1 of 6

!'

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 post-modification

testing for 2XE-SG-163

prior to restart.Page 2 of 6

I l

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.

Page 4 of 6

j'

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 AchievedSince 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

(I t

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.Page 6 of 6

i 1