05000528/LER-2007-004, Inadequate Surveillance Test Procedure Resulted in Failure to Meet Surveillance Requirement

Inadequate Surveillance Test Procedure Resulted in Failure to Meet Surveillance Requirement

ML072910226
Person / Time
Site:	Palo Verde
Issue date:	10/10/2007
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05755-DCM/REB LER 07-004-00
Download: ML072910226 (8)

LER-2007-004, Inadequate Surveillance Test Procedure Resulted in Failure to Meet Surveillance Requirement

Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i) 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded 10 CFR 50.73(a)(2)(viii)(A) 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(viii)(B) 10 CFR 50.73(a)(2)(iii) 10 CFR 50.73(a)(2)(ix)(A) 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(x) 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor 10 CFR 50.73(a)(2)(v)(B), Loss of Safety Function - Remove Residual Heat 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown 10 CFR 50.73(a)(2)(v), Loss of Safety Function 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications
5282007004R00 - NRC Website

text

10 CFR 50.73 AL A subsidiary of Pinnacle West Capital Corporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034

,02-05755-DCM/REB October 10, 2007 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529 and 50-530 License No. NPF 41, NPF 51 and NPF-74 Licensee Event Report 2007-004-00 Attached, please find Licensee Event Report (LER) 50-528/2007-004-00 which reports operation in a condition prohibited by Technical Specifications due to an inadequate procedure for Surveillance Testing.

In accordance with 10 CFR 50.4, copies of this LER are being forwarded to the NRC Regional Office, NRC Region IV and the Senior Resident Inspector. If you have questions regarding this submittal, please contact Ray E. Buzard, Section Leader, Regulatory Affairs, at (623) 393-5317.

Arizona Public Service Company makes no commitments in this letter.

Sincerely, DCM/REB/gat Attachment cc:

E. E. Collins Jr.

NRC Region IV Regional Administrator M. T. Markley NRC NRR Project Manager - (send electronic and paper)

G. G. Warnick NRC Senior Resident Inspector for PVNGS A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon Palo Verde 9 South Texas Project

• Wolf Creek

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES: 06/30/2007 (6-2004)

, the NRC may sfor each block) not conduct or sponsor, and a person is not required to respond to, the digits/characters finformation collection.

3. PAGE Palo Verde Nuclear Generating Station (PVNGS) Unit 1 05000528 1 OF 7

4. TITLE Inadequate Surveillance Test Procedure Resulted In Failure To Meet Surveillance Requirement

5. EVENT DATE

6. LER NUMBER

7. REPORT DATE 1

8. OTHER FACILITIES INVOLVED MONTH DAY YEAR ISEQUENTIAL REV M

H DY YR FACILITY NAME DOCKET NUMBER MR YEAR SUMBER R

MONTH DAY YEAR PVNGS Unit 2 05000529 FACILITY NAME DOCKET NUMBER 08 11 2007 2007

- 004 -

00 10 10 2007 PVNGS Unit 3 05000530

9. OPERATING MODE

11. THIS REPORT IS SUBMIITED PURSUANT TO THE REQUIREMENTS OF 10 CFR§: (Check all that apply)

[3 20.2201(b)

[3 20.2203(a)(3)(i)

El 50.73(a)(2)(i)(C)

El 50.73(a)(2)(vii)

E

/ 1 / 1 El 20.2201(d)

El 20.2203(a)(3)(ii)

[I 50.73(a)(2)(ii)(A)

[E 50.73(a)(2)(viii)(A)

El 20.2203(a)(1)

C1 20.2203(a)(4)

El 50.73(a)(2)(ii)(B)

El 50.73(a)(2)(viii)(B)

El 20.2203(a)(2)(i) 0l 50.36(c)(1)(i)(A)

[I 50.73(a)(2)(iii)

El 50.73(a)(2)(ix)(A)

10. POWER LEVEL El 20.2203(a)(2)(ii)

El 50.36(c)(1)(ii)(A)

[I 50.73(a)(2)(iv)(A)

[E 50.73(a)(2)(x)

[I 20.2203(a)(2)(iii)

Cl 50.36(c)(2)

[I 50.73(a)(2)(v)(A)

El 73.71(a)(4)

El 20.2203(a)(2)(iv)

[3 50.46(a)(3)(ii)

El 50.73(a)(2)(v)(B)

El 73.71(a)(5) 100 / 100 / 100 El 20.2203(a)(2)(v)

El 50.73(a)(2)(i)(A)

El 50.73(a)(2)(v)(C)

El OTHER El 20.2203(a)(2)(vi) 0 50.73(a)(2)(i)(B)

El 50.73(a)(2)(v)(D)

Specify in Abstract below or in (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of (If more space is required, use additional copies of NRC Form 366A) headers were full, specific UT was performed on each of the Containment Penetration pipes of each CS Train on September 10, 2007. All CS headers were found to be completely filled except Unit 3 "B", which evidenced a slight void. Operations personnel completed an immediate operability determination and concluded that the "B" train remained operable. The Unit 3 "B" header was filled and then verified to be filled using UT.

On September 13, 2007, a Unit Night Order was entered for all 3 units to inform Operations personnel of the event, and to instruct that all procedural steps with qualifying statements such as "as necessary" or "as needed" shall be reviewed with the Control Room Supervisor (CRS) to ensure that the desired action is understood.

STP 40ST-9SI13 was revised and reissued on September 21, 2007, to require performance of UT analysis of each CS header, between the containment isolation valves, to verify that the header is full. The STP was completed on September 23, 2007, for the "A" train of CS for all three Units and for the "B" train in Units 1 and 2 on October 6 and October 8, 2007, respectively, thereby satisfying SR 3.0.3. Unit 3 entered Operating Mode 5 for its 1 3 th Refueling Outage on September 29, 2007, and therefore the requirements of SR 3.0.3 were no longer applicable. As previously stated, UT had been performed on the "B" train of CS for Unit 3 on September 10, 2007, and performance of the revised STP including UT will be completed prior to restart of Unit 3 following the refueling outage.

Operations Department will establish and implement a program to improve the use of operator fundamentals which will include performance monitoring and trending.

A review of each Surveillance Requirement to verify a system, sub-system or component is filled with water (or other fluid) to a specific criterion will be performed to ensure the Surveillance Test adequately demonstrates the Surveillance Requirement criteria are met.

A review all procedures that affect safety related equipment for steps with conditional phrases such as "as needed", "as necessary", "if required", etc. will be performed to ensure the steps cannot be reasonably misinterpreted to permit an unintended action.

8.

PREVIOUS SIMILAR EVENTS

LER 1-2004-009-01 reported a condition in Units 1, 2 and 3 where there were voids in the Emergency Core Cooling System containment sump piping due to a failure to translate the design intent to have the line filled with water into start-up, surveillance, and operating procedures. The corrective actions for that event would not have prevented this event, as the intent to maintain the CS header full of water was clearly captured in the STPs and operating procedures.