IR 05000528/1993040
| ML20059A357 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/09/1993 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9312300126 | |
| Download: ML20059A357 (2) | |
Text
$
s
'
.ITEC091993 l Docket Nos. 50-528 50-529 ,
'
50-530 Arizona Public Service Company ,
P.O. Box 53999 &
Phoenix, Arizona 85072-3999 _;
Attention: Mr. William F. Conway Executive Vice President, Nuclear
'
Gentlemen:
Thank you for your letter of November 17, 1993, in response to our Notice of -
Violation and Inspection Report No. 50-528/93-40, 50-529/93-40 and 50-530/93-40, dated October 19, 1993, informing us of the steps you have taken .
to correct the items which we brought to your attention. Your corrective :
actions will be verified during a future inspection. Additionally, we acknowledge your clarification of our statement regarding the methods of main 1 steam safety valve testing. As indicated in the Inspection Report, we will :
review the results of the valve test ,
Your cooperation with us is appreciate '
i
Sincerely,
,
I C. A. VanDenburgh, Chief Reactor Projects Branch ;
cc:
Mr. Steve Olea, Arizona Corporation Commission James A. Beoletto, Esq., Southern California Edison Company Mr. Charles B. Brinkman, Manager, Washington Nuclear Operations Mr. Aubrey Godwin, Director, Arizona Radiation Regulatory Agency Chainnan, Maricopa County Board of Supervisors Jack R. Newman, Esq., Newman & Holtzinger, Mr.'Curtis Hoskins, Executive Vice President and Chief Operating Officer, Palo Verde Services ,
Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld Bradley W. Jones,.Esq., Akin, Gump, Strauss, Hauer and Feld Mr. Ronald J. Stevens, Director, Nuclear Regulatory Affairs, APS bec w/ copy of letter dated November 17, 1993:
Docket File Resident Inspector Project Inspector
'
G. Cook 280035 .)
9312300126 931209 ,
PDR ADOCK 05000528 .
l 0 PDR gg l '
,
. .
. . . .
L:
-- g . ,.
'
-
.
-R. Huey 1 B. Faulkenberry~'
D. Clevenger i
bec w/o' copy of letter dated November 17, 1993:
M. Smith :
Region V/ ann B01 son HWong CVanDenburgh A+
w/s/c w,a o.w s N 9 h> \2. /% / e '
UEST COPY] R EST COPY] EST COPY) S TU DCS] TO PDR]
I / NO 1 / NO 1 YES / NO 1 S / N0 1 _ / ' N0 1
,
[
,
'h
'!
I h
,
% P
,
.
-
... .. .-
+
'-
3 .
. .-
'
l
,
-
Arizona Public Service Compa P O BOX $3999 = PHOENIX. ARIZONA B5072 3999 WILLIAM F CONWAY 102-02731-WFC/ BAG /PJC ~3 M
November 17,1993 mcutiv4vgrsom -
g gg
"t> OsS
- oq ,
m r U. S. Nuclear Regulatory Commission '
- C)
ATTN: Document Control Desk Mail Station P1-37 Washington, D. C. 20555
'
Reference: Letter dated October 19,.1993, from C. A. VanDenburgh, Chief, Reactor Projects Branch, NRC,' to W. F. Conway, Executive Vice President, Nuclear, APS
Dear Sirs:
,
Subject: Palo Verde Nuclear Generating Station (PVNGS) -:
Units 1,2, and 3 Docket Nos. STN 50 528/529/530 Reply to Notice of Violations 50-528/93-40-06, 529/93-40-04, and 529/93-40-08 '
.
File: 93-070-026
.
.
Arizona Public Service Company (APS) has reviewed NRC Inspection Report-50-528/529/530/93-40 and the Notice of Violations dated October 19,1993. Enclosure 1 to this letter is a restatement of the Notice of Violation. APS' responses are provided in :
Enclosure ,
in addition, clarification is needed for a statement a inspection Report 93-40 that refers l
to an APS conclusion with regard to the methods of main steam safety valve testin '
Section 7. " Main Steam Safety Valve (MSSV) Testing - Unit 1 (40500 and 71707)," of the -
inspection report states in pan:
Based on the data collected from these tests, the_ licensee concluded that even though there was an offset between the two test methods, the data from the two--
methods generally correlated and both methods appeared to be acceptabl ,
During the testing of the three MSSVs at the Westinghouse test facility using both the Westinghouse live steam test and the Furmanite "Trevitest," APS made some general observations with respect to the two test methods. However, no conclusions have been . .
i s
- .]
s
'
[. ' '
- ?
' ~
. - . l
-
.. .
.;
,
'
U. S. Nuclear Regulatory Commission I ATTN: Document Control Desk-Reply to Notice of Violations 50-528/93-40-06,
' 50-529/93-40-04, and 50-529/93-40-08 Page 2 i
,
reached to date. APS is currently evaluating the test data and formulating conclusions in accordance with its problem resolution progra !
Should you have any questions, please call Burton A. Grabo at (602) 393-649
Sincerely,
'
,
,.
., ,
'
g-t a:FG WFC/ BAG /PJC !
,
Enclosures: Restatement of Notice of Violation Reply to Notice of Violations
.,
cc: B. H. Faulkenberry J. A. Sloan .
,
i f
I
.
'l
- ,
,
!
,
>
>
l
!
>
n
. .
f"
-
,
, , _
- -
.
. _ . ' ' '
-
4- .
. ., ,
ENCLOSURE 1 RESTATEMENT OF NOTICE OF VIOLATIONS
- 50-528/93-40-06, 50-529/93-40-04, and 50-529/93-40-08
.
NRC INSPECTION CONDUCTED AUGUST 17 THROUGH SEPTEMBER 20,1993
,
>
t F a
,m .
,
. . .;
- '
, ,.
Restatement of Notice of Violations 50-528/93-40-06, 50-529/93-40-04. and 50-529/93-40-08 l
During an NRC inspection conducted on August 17 through September 20,1993, three: ,
violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,.
Appendix C, the violations are listed below:
, Technical Specification 6.2.2.1.b, for Units 1,2, and 3, requires that an individu'al should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight nor more that (sic)
~
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any 7-day period, exclusive of shift tumover time. Deviations from this'
must be authorized by appropriate manag'er l Contrary to the above, the licensee determined that: (1) on December 31,1991, a through January 1,1992, a licensee Engineer worked more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, exclusive of shift turnover time, and (2) between December 25,1991, and January 13,1992, a licensee engineer worked more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period, exclusive of shift turnover time, without authorization by a manage % '
This is a Severity Level IV violation (Supplement 1) applicable to Units 1,2, and Unit 2 Technical Specification 6.8.1 requires, in part, that written procedures'shall '
be established, implemented and maintained covering surveillance and test activities of safety-related equipmen '
Procedure 73AC-9ZZO4, Revision 9.05, " Surveillance Testing," step 3.9.3, requires that unsatisfactory steps or data be marked "unsat," circled, and initialed. In addition, step 3.10.3, states that a retest shall be documented on blank pages of the surveillance test (ST) procedure, copied from the station manual and inserted as necessary to provide unused steps for the appropriate test sections including prerequisite '
'
Contrary to the above, on August 27,1993, during the performance of Surveillance Test 42ST-2CH04 in Unit 2, operators noted that the calculated boron injection flow was below the minimum acceptance criterion, but failed to mark this step as
"unsat." In addition, the retest was not conducted using a blank page from the ST '
procedur This is a Severity Level V violation (Supplement I) applicable to Unit t CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type ,
appropriate to the circumstance .
Page 1 of 2
I
- .
. , ,
.
-
.
. .
.
,
Procedure 32MT-9ZZ46," Disassembly / Assembly of Limitorque type SMB/SB-Othru SMB/SB-4 Actuators," includes instructions for the installation of the-actuator
,
-
torque switc Contrary to the above, on August 4,1993, Revisions GF and 7G of Work Order-605526 were not appropriate to the circumstances in that they did not include a ,
- step referencing' procedure 32MT-9ZZ46 for replacing-the torque switch for the' '
auxiliary feedwater supply isolation valve to Steam Generator 2 ,
This is a Severity Level IV violation (Supplement 1) applicable to Unit .
.., ;
F
'
t i
.
,
,
k a
,
t Page 2 of 2
.
- \; .
p ....~
.
..- . .
. . :
i
,
i
.
'
ENCLOSURE 2 -
!
i REPLY TO NOTICE OF VIOLATIONS
.
50-528/93-40-06, 50-529/93-40-04, and 50-529/93-40-08 -
NRC INSPECTION CONDUCTED AUGUST 17 THROUGH SEPTEMBER 20,1993 ;
,
,,
i
?
e t'
4 .
<.-.
.
.
.' . ;
.
. ..
1. . ,
I REPLY TO VIOLATION A (50-528/93-40-06) )
.
!
.
L Admiscion Or Denial Of The Alleaed Violation l
APS admits the violatio '
, .
a
!
, . Reason For The Violation ;
- 1 As discussed in its response (Reference: Letter No. 102-02361-WFC/RJS/ACR, !
dated December 1,1992) to the NRC's September 29,1992 request for information, an APS investigation substantiated the concern that a PVNGS engineer exceeded Technical -
,
Specification and PVNGS procedural overtime limitations. The individual worked more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight on December 31,1991 through January 1,1992 and worked more - ;
, i than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period between December 25,1991 and January 13,1992. This violation was attributed to procedural ambiguity regarding the amount of time that should '
be allocated for shift turnover and the individual's misunderstanding of the applicability of the overtime limits to breaks and other time not directly associated with safety-related work. In addition, the APS investigation found that the individual had worked more than 12 consecutive days which also violated PVNGS procedural overtime limitations. This
, ,
J violation was caused by inadequate attention to overtime limitations by the individual and the individual's supery;so i
'!
Li j i
Page 1 of 10 !
I l
! .
ll l l i
_ _ _
.
,
j
.
.. ,
- *
.. - ;
Corrective actions included counseling of both . engineer and supervisor and revision of PVNGS procedure 02AC-0EM01, " Overtime Limitations," to provide clearer
.
guidelines as.to the amount of time that constitutes shift turnover. Guidance was
.
provided to Site Technical Support personnel with regard to how time spent in the work
,
place on non-work activities is to be recorded on time tickets. The violation did not result in any PVNGS unit being operated in a condition prohibited by the Technical Specification i
- ,
Since that response was submitted, the NRC Resident inspectors reviewed PVNGS
'
Ouality Assurance (OA) documents associated with overtime &nitations and identified
discrepancies of minimal safety significance that occurred during ',991 and 1992. During performance of the recent PVNGS QA Maintenance Audit, initiated September 20,1993, j the audit team identified severalincidents during 1993 in which it appeared that personnel j had exceeded overtime limitations and/or did not properly comply with' exception 1 requirement Discrepancies included (1) lack of prior management approval, (2) ,
approval from improper management levels, (3) inadequate / incomplete documentation, '
(4) inadequate justification for exceptions, (5) time activity reporting errors, (6) time activity data entry errors, and (7) errors in the PVNGS Excess Hours Report. These continuing -
discrepancies indicated a recurring problem for which corrective actions had not been .
effective in a number of PVNGS departments. Therefore, on November 3,1993, the PVNGS OA Director issued a Stop Work Notice that prohibited the affected PVNGS, departments from taking any exceptions to the overtime limitations procedure until those Page 2 of 10
.
. ,
', >
.
.
.. ,
f
,
.
.
,. q
. , .* ,
departments provided acceptable corrective action plans. Further,' Correctivef Action Report (CAR) No. 93-0179 was issued to address the cause(s)'of the identified condition, - !
procedure non-compliance, action (s) to prevent recurrence, and the inadequacies of the -;
'
PVNGS Excess Hours Report. APS immediately initiated an investigatio !
,
i Corrective Steps That Have Been Taken And Results Achieved
!
!
As discussed above, the QA Director issued a Stop Work Notice prohibiting the affected PVNGS departments from taking exceptions to the Overtime Limitations policy until those organizations implemented acceptable interim corrective actions; a CAR was '
issued to track and verify corrective actions, and an investigation was initiate ,
t 4
.
Corrective Steps That Will Be Take'n To Avoid Further Violations
'
,
The APS investigation is stillin progress, and long-term corrective actions have not . J yet been developed. Through its investigation, APS will determine the extent and i cause(s) of the problem; the organizations involved; the applicability of the overtime limitations procedure and whether or not changes.are needed;-and the reliability,; -
distribution, and use of the Excess Hours Report. Based upon the results of the i
>
investigation, appropriate corrective actions will be developed and implemente'd; APS-'
t expects to complete its investigation by December 17,199 :
Page 3 of 10
,
)
T
'
,- - r --k
- y
. . .
l ,
- <
ie'
Date When Full Compliance Will Be Achieved
.
Full compliance was ' achieved when interim corrective actions were instituted, and - .
the OA Stop Work Notice was fifted on November 17,199 ~
.
l t
l
!
t
,
a i
i r
!
,
i
-i F
?
.
Page 4 of 10
,
p .,- -
'c . .
.
. .
..
.. .
, i REPLY TO VIOLATION B (50-529/93-40-04)
.
,
Admission Or Denial Of The Alleoed Violation <
APS admits the violation. It should be noted that implementation of the corrective i
actions developed for the violations identified in NRC Inspection Reports 50-528/93-26 and 50-528/93-35 was stillin progress when this violation occurre '
..
!
Reason For The Violation
,
'i
.
As was the case with the similar violations described above, the current violation may be attributed to personnel error. The complexities and inconsistencies'of the administrative control procedure 73AC-9ZZO4, " Surveillance Testing," are considered to:
be contributing factors as they were in the previously mentioned. violation I
.
In this particular case, Unit 2 Operations had been_ experiencing intermittent malfunctions of the reactor coolant pump (RCP) seal bleed-off flow-indicators for i
approximately two weeks. On August 25,1993, alternate flow indicators were developed i
and installed. On August 27,1993, night shift operators were performing 42ST-2CH04 :
to determine the reliability of the newly installed instruments. The operators found that the new instruments were subject to cycling, and consulted the Operations Supervisor ,
,
who directed them to observe the meters and retake the dat When conflicting j Page 5 of 10
!
i (
- .
.,
, , ,,
-
,
.- ,- 's
.. ..
indications were again received and recorded, the crew discontinued the test. ' The Operations Supervisor did not consider the documentation guidance in the administrative
'
control procedure 73AC-9ZZO4, " Surveillance Testing," to be applicable to the anomalous ,
j
circumstances of this particular test. The following morning the Operations Manager l
,
reviewed the test results and directed operators to perform an alternative method for determining RCP seal bleed-off flow that had been developed for use in the event of-further flow meter failure A change to procedure.42ST-2CH04 was processed and approved to permit perfornmoce of the ST by the alternate method. The test was '
r continued and completed successfull .
Corrective Stoos That Have Been Taaen And The Results Achieved I
,
!
The test log was updated to explain the circumstances of the test and the actions ,
taken. The Operations Supervisor issued a night order advising his staff of the violation and pending corrective actio .
Corrective Steos That Will Be Taken To Avoid Further Violations '
,
l'
-L As discussed in the APS response to the previous violations (Reference: Letter N ,
102-02623-WFC/TRB/PJC, dated August 30,1993), a Focus Group was established to-review and revise the ST administrative control to provide cleari concise instructions for a
ST documentatio The procedure has been revised and is in _the final review cycl a Page 6 of 10 ,
P
~ ,
.,
,
,
,,-,,.. .
-
., =
1 ,
,
.
.
A video tape and briefings are being developed for training on the revised procedur Implementation is expected by the end of the yea Date When Full Comoliance Will Be Achieve Full compliance was achieved when the test log was updated to explain the circumstances of the test and the actions taken, and the test was successfully completed using the alternate method for RCP bleed-off flow determination.
p Page 7 of 10 i: . _ _ - -
+
-
'*
.
.. .
f- .. ,.
'
p
_ REPLY TO VIOLATION C (50 529/93-40-08)
.
Admission Or Dental Of The Alleaed Violation-
APS admits the violatio Reason For The Violation Procedure 32MT-9ZZ46, " Disassembly / Assembly of Limitorque Type SMB/SB-0 Thru SMB/SB-4 Actuators," which was cited in this violation is intended- to provide guidance for the refurbishment of a valve actuator; step 4.45 provides guidance for the reinstallation of a torque switch after it has been refurbished. The APS investigation found-that the procedure was inconsistently and unnecessarily applied in the development of amendments to work order number 00605526 which was written; to perform troubleshooting and maintenance on valve AF-UV-35. The use of the procedure to-remove the torque switch for access to the spring. pac was not required. The torque-switch is not de terminated for access to the spring-pac. The mounting screws are removed, and the torque switch is moved aside to gain access to the spring-pac. The torque switch in question was already set, the actuator had been diagnostically tested, and the torque switch circuitry functioned. The maintenance on the spring-pac and torque switch was performed correctly as the valve passed all the required testin Page 8 of 10
..
.. g .. ,
.
v -
. '. .
However, since the procedure was used to " remove" the torque switch, it should -
also have been used to " reinstall" the switc The need for amendments to the work order was identified on backshift, and no planners from the Central Planning Department were available. The planners who developed the amendments and performed the technical review do not normally plan work for the Valve Services technicians. A Ont 2 planner developed the amendments for performance of the troubleshooting neec.ed on the valve so that testing could be resumed, and a Unit 3 planner performed the trchnical review. The Valve Services work group supervisor reviewed the amendrrents an determined that the steps were adequate to continue troubleshooting. !!either the planner nor the reviewers recognized that there was no reinstallation step for the torque-switch, and the technicians continued the work without such a step. Inattention to detail was the apparent caus Corrective Steos That Have Been Taken And The Results Achieved The two planners who developed the work order and performed the technical review were briefed as to management's expectations with regard to the need to ensure all the criteria needed to perform the work are included in the maintenance instruction The Valve Services work group supervisor and technicians were briefed that work is to -
stop when work orders or procedures do not specify the needed criteria to complete a tas Page 9 of 10
p+ , . .
-
.
m
- ,, -
.
_ , , , ,.
Corrective Steps That Will Be Taken To Avoid Further Violations k
A guideline will be developed to brief Unit and Central planners on the appropriate .
use of procedure 32MT-9ZZ46 to ensure it is consistently applied to work instruction The briefings will be completed by December 17,1993.
'
.Date When Full Compliance Will Be Achieved
.
Full compliance will be achieved when planners have been briefed on the proper application of procedure 32MT-9ZZ46 on December 17,199 i
.
ai
,
F Page 10 of 10
.
&
.
-