ML17300B017
| ML17300B017 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/21/1987 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 102-00471-EEVB, 102-471-EEVB, NUDOCS 8708260362 | |
| Download: ML17300B017 (30) | |
Text
Arizona Nuclear Power Project P.O. BOX $2034
~
PHOENIX. ARI2ONA85072-2034 102-00471-EEYB/TDS August 21, 1987 NRC Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Palo Verde Huc'lear Generating Station (PVNGS)
Unit 1 and Unit 3
. Docket Ho.
STH 50-528 (License NPF-41)
STH 50-530 (License NPF-65)
Response to Notice of Violation:
50-528/87-17-02
Response
to Notice of Deviation:
50-530/87-19-01 Fi le:
87-001-493
~ ~
~Pl
~M(
C rn
Reference:
Letter from D. F. Kirsch (NRC) to E. E. Van Brunt, Jr.
(ANPP),
dated July 24, 1987.
HRC Inspection Reports 50-528/87-17, 50-529/87-18, and 50-530/87-19 This letter is provided in response-to the inspection conducted by Messrs.
J. Ball, G. Fiorelli, K. Ivey and R. Zimmerman on t1ay 10 - June 20, 1987.
Based on the results of the inspection, one (1) violation and one (1) deviation of NRC requirements were identified.
The violation and deviation are discussed in Appendix A and B respectively, of the referenced letter.
The violation, deviation, and AHPP's response are provided in Attachment l.
Very truly yours, auw EEVB/TDS/kj Attachments cc:
J.
G. Haynes J.
R. Ball E. A. Licitra A. C. Gehr (w/attachme (w/attachment)
(w/attachment)
(w/attachment)
E. E.
Van Brunt, Jr:.
Executive Vice President Project Director
~
NRC Document Control Desk Page 1 of 9 102-00471-EEYB/TDS August 21, 1987 ATTACHMENT I Arizona Nuclear Power Project Post Office Box 52034
- Phoenix, Arizona 85072-2034 NOTICE OF VIOLATION r
Docket No. 50-528 License No. NPF-41 As a result of the NRC inspection conducted on May 10, 1987 - June 20, 1987 a
violation of NRC requirements was identified.
In accordance with the "General Statement. of Policy and Procedure for NRC En,:,rcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI "Corrective Action" states, in part, that measures shall be established to assure that prompt corrective action is taken to preclude repetition of significant conditions adverse to quality.
Contrary to the above, in Unit I on June I, 1987, during the performance of testing on the "B".train containment spray header discharge valve, a related spray line valve specified-to be closed by an approved procedure, was left open resulting in the draining of approximately 100 gallons of water from the refueling water tank (RWT) into the containment building.
Prompt corrective actions to preclude repetition were not implemented as this represents a similar incident as occurred in Unit 2 on flay 19, 1987..-
This is a Severity Level IV Violation (Supplement I).
0 0
NRC Document Control, Desk Page 2 of 9 102-00471-EEVB/TDS August 21, 1987 ATTACS'IENT 1 CONTINUED
RESPONSE
TO NOTICE OF YIOLATION 1.
REASON FOR THE YIOLATION As discussed in the Inspection Report and in ANPP's Special Investigation Report, the cause of the event in Unit 2 on Nay 19,
- 1987, was determined to be a personnel error by the licensed operator who did not adhere to a caution statement contained within a Section XI surveillance testing (ST) procedure.
A contributory cause was the improper inclusion of an action step within a "caution statement" which is contrary to the procedure writers guide.
ANPP' investigation of the Unit 1 event which occurred on June 1, 1987, also determined the cause to be a personnel error contributed to by the improper use of a "caution statement" to include an action step as discussed above.
As with any investigation of an event, the intent is to clearly identify the root cause, formulate necessary corrective actions to prevent r ecurrence, and to disseminate the information to each responsible group or individual.
In the Unit 2 event,
=the initial evaluation was.'completed on Hay 20,
'l987.
However the report and recommendations for corrective action to prevent recurrence did not receive final review and approval until June 2, 1987.
Had the procedural changes recommended in the
NRC Document Control Desk Page 3 of 9 102-00471-EEVB/TDS August 21, 1987 preliminary evaluation of the particular event been immediately implemented, the likelihood of recurrence would have been significantly reduced.
Because of ANPP's concern for ensuring thorough analysis of potential root causes and the subsequent implementation of corrective actions, the event evaluation process is intentionally detailed.
The current process requires extensive reviews and management evaluations prior to final approval.
However, the Unit 2 event and the subsequent Unit 1 event demonstrated the need to develop a process which would allow for'xpediting interim corrective actions to minimize the probability of recurrence pending final approval of the detailed evaluation.
J Based on the above, ANPP has developed and begun implementation of corrective actions designed to address, not only the specific event of the violation but also, the more generic issue of expediting the implementation of interim corrective measures pending the completion of the formal evaluations.
2.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As stated in the inspection r eport, a Temporarily Approved Procedure Change Notice (TPCN) which changes the closur e of the associated spray line valves from a "caution statement" to a required action step was approved and issued on June 2, 1987 for all three units.
NRC Document Control Desk Page 4 of 9 102-00471-EEVB/TDS August 2", 1987 The Unit 2 and Unit 1 Special Investigative Reports were issued as Operation Department Experience Reports (ODER's) on June 2, and June 18, 1987, respectively.
(The ODER's are required reading for all operations shift crew members.)
3.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Section XI ST procedures will be reviewed, (1) to identify and revise caution statements which contain action steps, (2) to ensure action steps are listed in the proper sequence for performance, and (3) to verify the overall technical accuracy of the procedures.
The purpose of this effort is to incorporate human factor changes which may mitigate or prevent this type of event.
Currently, the program for performing Special Reports and Investigations is being revised.
The revision will include a mechanism for disseminating information 'for a Special Report orInvestigation prior to final approval if it is determined that a similar event has a high probability of recurring in the short term.
In the interim period, events which have a high probabi'lity for recurrence will be identified by the issuance of an Operations Department Experience Report (ODER).
NRC Document Control Desk Page 5 of 9
102-00471-EEYB/TDS August 21, 1987 4.
DATE WHEN FULL COtPLIANCE WILL BE ACHIEYED The review of the Section XI ST procedures and incorporation of identified revisions are expected to be completed by November 1, 1987.
The revision of the program for performing Special Reports and Investigations is currently scheduled for implementation by September 15, 1987.
e NRC Document Control Desk Page 6 of 9
ATTACHt1EHT 1 CONT.
NOTICE OF DEVIATION 102-00471-EEVB/TDS August 21, 1987 Ar izona Nuclear Power Project Post Office Box 52034
- Phoenix, Arizona 85072-2034 Docket No. 50-528 License No. HPF-41 The following deviation was identified during an inspection conducted
.on t1ay 10 - June 20, 1987.
In accordance with the "General Statement of Policy and Procedure for HRC Enforcement Actions, "10 CFR Part 2, Appendix C (1987)," the deviation is 1isted below:
By ANPP letter AHPP-20329 dated i)arch 8; 1982, in response to HRC FSAR questions 410.4 and 410.5, the licensee committed to the installation of redundant, air-operated, automatic isolation valves on the auxiliary steam line upstream of the penetration into safety related areas of the auxiliary building, that would automatically close on high differentia1, pressure as would result from a postulated break in the auxiliary steam line.
Contrary to the above, on Hay 13, 1987," six of twenty installed differential pressure switches located in Unit 3, whose function were to cause the closure of the redundant isolation valves on the auxiliary steam line were found inoperable in the plastic plugs instaIIed-to preclude intrusion of debris. into 4
the sensing lines had not been removed subsequent to construction completion.
NRC Document Control Desk Page 7 of 9
102-00471-EEVB/TDS August 21, 1987 ATTACHMENT 1 CONTINUED
RESPONSE
TO NOTICE OF DEVIATION 1.,
REASON FOR THE DEVIATION.
ANPP has conducted an investigation into the circumstances surrounding the isolation of the differential pressure switches by plastic caps.
The cause of the deviation was not identifying the presence of the caps, as a
discrepancy during the operations acceptance walkdown of the auxiliary steam system at the time of system acceptance.
Further review 'also revealed that the pressure transmitters were not included within the preventive maintenance (PM) program to ensure continued operability of this non-safety related subsystem.
This oversight is attributed to not recognizing the commitment made within the Final Safety Analysis Report (FSAR) for this design modification on a
non-safety'elated system..
The plastic caps were originally installed by Bechtel Construction in accordance with HPP/gCI 302.0, section 5.9.
1 as part of initial construction to maintain cleanliness.
During startup testing the caps were removed for testing of the pressure switches and then reinstalled to maintain system cleanliness.
NRC Document Control Desk Page 8 of 9 102-00471-EEVB/TDS August 21'987 During the acceptance walkdown for non-safety related subsystems by ANPP, the pressure switches were verified to be correctly installed however, the plastic caps were not identified as a discrepancy.
As a result, the caps remained in place rendering portions of the subsystem inoperable.
2.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As immediate corrective action, inspections were conducted in Units 1, 2, and 3 to identify pressure switches which may have plastic caps.
As stated in the Inspection Report, a number of inoperable switches were identified.
The caps were removed and the auxiliary steam actuation system in each of the Units was tested and restored to operability.
A preventive maintenance task has been initiated which will test and verify continued operability of this system on a biannual basis.
3.
THE CORRECTIVE STEPS MHICH'MILL BE TAKEN TO AVOID FURTHER DEVIATIONS The ANPP Compliance Department has initiated a review of the FSAR designed to identify other commitments made for non-safety related systems.
This review will focus on, but not be limited to, commitments made in response to NRC guestions which may not have been entered on the ANPP
0,
~i
~
w~ A NRC Document Control Desk Page 9 of 9 102-00471-EEVB/TDS August 21, 1987 commitment tracking system.
Should other commitments be identified, ANPP will verify that actions have been/or will be initiated to satisfy the commitment.
4.
DATE WHEN FULL COtPLIANCE WILL BE ACHIEVED The review by the Compliance Department is expected to be completed in
- November, 1987.
REGULATORY INFORMATION DISTRIBUTION SYSTEM (R IDS)
ACCESSION NBR:8708260362 DOC. DATE: 87/08/21 NOTARIZED:
NO DOCKET FACIL: STN-50-528 Palo Ver de Nuclear Station>
Uni t
- 1. Arizona Pub li 05000528 STN 50 529 Palo Verde Nuclear Station>
Unit 2> Arizona Publi 0500052'P STN-50-530 Palo Ver de Nuclear Station.
Uni t 3> Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION VAN BRUNT> E. E.
Arizona Nuclear Power ProJect (formerly Arizona Public Serv RECIP. NAME REClPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 870724 ltr re violations noted in Insp Repts 50-528/87-17> 50-529/87-18 b 50-530/87-19 on 870510-0620.
Corrective actions: temporary approved procedure change notice approved h issued on 870602 for all three units.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED: LTR Q ENCL g SIZE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES: Standardized plant. M. Davis> NRR: 1Cg.
Standardized plant. M. Davis> NRR: 1Cg.
Standardized plant. M. Davis. NPR: fCg.
05000528 05000529 05000530 RECIPIENT ID CODE/NAME PD5 PD DAVIS> M TERNAL:
ACRS DEDRO NRR/DOEA DIR NRR/DREP/RPB NR R /P MAS/ILR8 OGC/HDSf RES DEP Y G I COPIES LTTR ENCL f
1 2
2 2
2 1
2 2
1 f
f 1
1 RECIPIENT ID CODE/NAME LICITRA>E AEOD NRR MORISSEAU> D NRR/DREP/EPB NRR/DRlS DIR OE EBERMAN> J EG F RGN5 FILE 01 COPIES LTTR ENCL 2
I 1
1 f
f 1
1 1
EXTERNAL:
1 NOTES:
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
Arizona Nuclear Power Project P.O. BOX 52034
~
PHOENIX, ARIZONA85072-2034 102-00471-EE VB/TDS August 21, 1987 NRC Document Control Desk U.
S. Nuclear Regulatory Commission Washington, D.
C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 and Unit 3 Docket No. STN 50-528 (License NPF-41)
STN 50-530 (License NPF-65)
Response
to Notice of Violation:
50-528/87-17-02
Response
to Notice of Deviation:
50-530/87-19-01 Fi le:
87-001-493
Reference:
Letter from D. F. Kirsch (NRC) to E. E. Van Brunt, Jr.
(ANPP),
dated July 24, 1987.
NRC Inspection Reports 50-528/87-17, 50-529/87-18, and 50-530/87-19 This letter is provided in response to the inspection conducted by Messrs.
J. Ball, G. Fiorelli, K. Ivey and R. Zimmerman on May 10 - June 20, 1987.
Based on the results of the inspection, one ('i) violation and one (1) deviation of NRC requirements were identified.
The violation and deviation are discussed in Appendix A and B respectively, of the referenced letter.
The violation, deviation, and ANPP's response are provided in Attachment l.
Very truly yours,
~
GU.A 5 UA E. E.
Van Brunt, Jr.
Executive Vice President Project Dit ector EEVB/TDS/kj Attachments cc:
J.
G. Haynes J.
B. Martin J.
R. Ball E. A. Licitra A. C. Gehr (w/attachment)
(w/attachment)
(w/attachment)
(w/attachment)
(w/attachment) 8708260362 870821 PDR ADOCK 05000528 G
NRC Document Control Desk Page 1 of 9 102-00471-EEVB/TDS August 21, 1987 ATTACHMENT 1 NOTICE 'OF VIOLATION Arizona Nuclear Power Project Post Office Box 52034
- Phoenix, Arizona 85072-2034 Docket No. 50-528 License No. NPF-41 As a result of the NRC inspection conducted on May 10, 1987 - June 20, 1987 a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI "Corrective Action" states, in part, that measures shall be established to assure that prompt corrective action is taken to preclude repetition of s ignificant, conditions adverse to quality.
Contrary to the above, in Unit 1 on June 1,
1987, during the performance of testing on the "B" train containment spray header discharge valve, a related spray line valve specified to be closed by an approved procedure, was left open resulting in the draining of approximately 100 gallons of water from the refueling water tank (RWT) into the containment building.
t Prompt corrective actions -to preclude repetition were not implemented as this represents a similar incident as occurred in Unit 2 on May 19, 1987.
This is a Severity Level IV Violation (Supplement 1).
NRC Document Control Desk Page 2 of 9 102-00471-EEVB/TDS August 21, 1987 ATTACHMENT 1 CONTINUED
RESPONSE
TO NOTICE OF VIOLATION 1.
REASON FOR THE VIOLATION As discussed in the Inspection Report and in ANPP's Special Investigation Report', the cause of the event in Unit 2 on May 19,
- 1987, was determined to be a personnel error by the licensed operator who did not adhere to a caution statement contained within a Section XI surveillance testing (ST) procedure.
A contributory cause was the improper inclusion of an action step within a "caution statement" which is contrary to the procedure writers guide.
ANPP's investigation of the Unit 1 event which occurred on June 1,
- 1987, also determined the cause to be a personnel error contributed to by the improper use of a "caution statement" to include an action step as discussed above.
As with any investigation of an event, the intent is to clearly identify the root cause, formulate necessary corrective actions to prevent recurrence, and to disseminate the information to each responsible group or individual.
In the Unit 2 event, the initial evaluation was completed on May 20, 1987.
However the report and recommendations for corrective action to prevent recurrence did not receive final review and approval until June 2, 1987.
Had the procedural changes recommended in the
NRC Document Control Desk Page 3 of 9 102-00471-EE VB/TDS August 21, 1987 preliminary evaluation of the particular event been immediately implemented, the likelihood of recurrence would have, been significantly reduced.
Because of ANPP's concern for ensuring thorough analysis of potential root causes and the subsequent implementation of corrective actions, the event evaluation process is intentionally detailed.
The current process requires extensive reviews and management evaluations prior to final approval.
However, the Unit 2 event and the subsequent Unit 1 event demonstrated the need to develop a process which would allow for expediting interim corrective actions to minimize the probability of recurrence pending final approval of the detailed evaluation.
Based on the above, ANPP has developed and begun implementation of corrective actions designed to address, not only the specific event of the violation but also, the more generic issue of expediting the implementation of interim corrective measures pending the completion of the formal evaluations.
2.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As stated in the inspection report, a Temporarily Approved Procedure Change Notice (TPCN) which changes the closure of the associated spray line valves from a "caution statement" to a required action step was approved and issued on June 2, 1987 for all three units.
NRC Document Control Desk Page 4 of 9 102-00471-E E VB/TDS August 21, 1987 The Unit 2 and Unit 1 Special Investigative Reports were issued as Operation Department Experience Reports (ODER's) on June 2, and June 18, 1987, respectively.
(The ODER's are required reading for all operations shift crew members.)
3.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Section XI ST procedures will be reviewed, (1) to identify and revise caution statements which contain action steps, (2) to ensure action steps are listed in the proper sequence for performance, and (3) to verify the overall technical accuracy of the procedures.
The purpose of this effort is to incorporate human factor changes which may mitigate or prevent this type of event.
Currently, the program for performing Special Reports and Investigations is being revised.
, The revision will include a mechanism for disseminating information for a Special Report or Investigation prior.to final approval if it is determined that a similar event has a high probability of recurring in the short term.
In the interim period, events which have a high probability for recurrence will be identified by the issuance of an Operations Department Experience Report (ODER).
NRC Document Control Desk Page 5 of 9
102-00471-EEVB/TDS August 21, 1987 4.
DATE WHEN FULL COt4'LIANCE WILL BE ACHIEVED The review of the Section XI ST procedures and incorporation of identified revisions are expected to be completed by November 1, 1987.
The revision of the program for performing Special Reports and Investigations is currently scheduled for implementation by September 15, 1987.
NRC Document Control Desk Page 6 of 9
102-00471-EEVB/TDS August 21, 1987 ATTACHMENT I CONT.
NOTICE OF DEVIATION Arizona Nuclear Power Project Post Office Box 52034
- Phoenix, Arizona 85072-2034 Docket No. 50-528 L'icense No. NPF-41 The following deviation was identified during an inspection conducted on May 10 - June 20, 1987.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, "10 CFR Part 2, Appendix C (1987)," the deviation is listed below:
By ANPP letter ANPP-20329 dated March 8, 1982, in response to NRC FSAR questions 410.4 and 410.5, the licensee committed to the installation of redundant, air-operated, automatic isolation valves on the auxiliary steam line upstream of the penetration into safety related areas of the auxiliary building, that would automatically close on high differential pressure as would result from a postulated break in the auxiliary steam line.
Contrary to the above, on May 13, 1987, six of twenty installed differential pressure switches located in Unit 3, whose function were to cause the closure of the redundant isolation valves on the auxi'liary steam line were found inoperable in the plastic plugs installed to preclude intrusion of debris into the sensing lines had not been.removed subsequent to construction completion.
NRC Document Control Desk Page 7 of 9
102-00471"EEVB/TDS August 21, 1987 ATTACHMENT 1 CONTINUED t
RESPONSE
TO NOTICE OF DEVIATION 1.
REASON FOR THE DEVIATION=
ANPP has conducted an investigation into the circumstances surrounding the isolation of the differential pressure switches by plastic caps.
The cause of the deviation was not identifying the presence of the caps, as a.
discrepancy during the operations acceptance walkdown of the auxiliary steam system at the time of system acceptance.
Further review also revealed that the pressure transmitters were not included within the preventive maintenance (PM) program to ensure continued operability of this non-safety related subsystem.
This r
oversight is attributed to not recognizing the commitment made within the Final Safety Analysis Report (FSAR) for this design modification on a
non-safety related system.
The plastic caps were originally installed by Bechtel Construction in accordance with WPP/gCI 302.0, section 5.9.
1 as part of initial construction to maintain cleanliness.
During startup testing the caps were removed for testing of the pressure switches and then reinstalled to maintain system cleanliness.
NRC Document Control Desk Page 8 of 9 102-00471-EEVB/TDS August 21, 1987 During the acceptance walkdown for non-safety related subsystems by ANPP, the pressure switches were verified to be correctly installed however, the plastic caps were not identified as a discrepancy.
As a result, the caps remained in place rendering portions of the subsystem inoperable.
2.
THE CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As immediate corrective action, inspections were conducted in Units 1, 2, and 3 to identify pressure switches which may have plastic caps.
As stated in the Inspection Report, a number of inoperable switches were identified.
The caps were removed and the auxiliary steam actuation system in each of the Units was tested and restored to operability.
A preventive maintenance task has been initiated which will test and verify continued operability of this system on a biannual basis.
3.
THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS The ANPP Compliance Department has initiated a review of the FSAR designed to identify other commitments made for non-safety related systems.
This review will focus on, but not be limited to, commitments made in response to NRC guestions which may not have been entered on the ANPP
0
NRC Document Control Desk Page 9 of 9 102-00471-EEYB/TDS August 21, 1987 commitment tracking system.
Should other commitments be identified, ANPP will verify that actions have been/or will be initiated to satisfy the commitment.,
4.
DATE WHEN FULL COHPLIANCE WILL BE ACHIEVED The review by the Compliance Department is expected to be completed in
- November,
'f987.
Cl t