ML17306A478
| ML17306A478 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/14/1992 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02113-WFC-T, 102-2113-WFC-T, NUDOCS 9202250367 | |
| Download: ML17306A478 (28) | |
Text
WILLIAMF. CONWAY EXECU14IEVICEPRESIOENT NUCLEAR
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F,'r Gl0:I V Arizona Public Service Company P.O. BOX 53999
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PHOENIX. ARIZONA85072-3999 I".-7l FE9 L0 E
102-02113-WFC/TRB/JRB February 14;- 1992 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station: P1-37 Washington, DC 20555
Reference:
Letter dated January 16, 1992, from D. F. Kirsch, Chief, Reactor Safety Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS.
Gentlemen:
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION50-528/91-44-01 File:
. 92-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528, 529, 530/91-44 and the Notice of Violation dated January 16, 1992. Pursuant to the provisions of 10 CFR 2.201, APS'esponse is attached.
Appendix A to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Attachment 1.
Should you have any questions regarding this response, please contact me.
Very truly yours, WFC/TRB/JRB/nk Attachments 1.
Appendix A - Restatement of Notice of Violation 2.
Attachment 1 - Reply to Notice of Violation cc:
J. B. Martin D. H. Coe
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APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION50-528/91-44-01 NRC INSPECTION CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 INSPECTION REPORT NOS. 50-528, 529, 530/91-44
RESTATEMENT OF NOTICE OF VIOLATION50-528 91-44-01 During an NRC inspection during the weeks of November 4, 18, and December 2, 1991, one violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below:
10 CFR Part 50. Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
states in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,... and shall be accomplished in accordance with these instructions, procedures, or drawings...."
o Palo Verde Nuclear Administrative and Technical Manual procedure 30 DP-9MPO<, Conduct of Maintenance, Section 3.5.13 states in part, "Personnel doing maintenance shall not alter, change or modify plant equipment,,..."
Limitorque Vendor Technical Document Number VTD-L200-0025, states in part, "Li'mitorque uses commercial grade 5 or better hardware on all operators.
All external hardware is cadmium plated for corrosion resistance."
Contrary to the above, on November 19, 1991, Unit 3 valve 3JSIA-HV-306 limit switch cover plate had two bolts installed, which were not grade 5 or better nor cadmium plated.
A o
Palo Verde Nuclear Administrative and Technical Manual. procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part, "Plant equipment shall be restored to proper. design configuration including all fasteners in place,...."
Contrary to the above, Unit 1 valve 1JCHB-HV-255; Unit 2 valves 2JSGA-UV-0138 and 2JCHE-HV-0536, and Unit 3 valve 3JSIA-UY-617 were missing fasteners on the limit switch cover plates.
This'is a Severity Level IV Violation (Supplement I)
Page 1 of 1
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ATTACHMENT1 REPLY TO NOTICE OF VIOLATION50-528/91-44-01 NRC INSPECTION CONDUCTED NOVEMBER 4, 1991-DECEMBER 6) 1991 INSPECTION REPORT NOS. 50-528, 529, 530/91-44
REPLY TO NOTICE OF VIOLATION50-528 91-44-01 Reason for the Violation The reason for the violation was",personnelwrror<by maintenance personnel in restoring certain motor operated valve limit switch covers to proper design configuration following maintenance activities.
Specifically, one example of two bolts of questionable material installed in a motor operated valve limitswitch cover plate and four examples of a missing fastener on limit switch cover plates on four motor operated valves were identified.
<Corrective Ste s'That Have Been Taken and the Results Achieved Material<nonconformance reports were initiated upon identification of the four missing bolts from the four limit switch covers.
The missing fastener in each limit switch cover has been replaced.
An engineering evaluation request*'was initiated to document, the bolting being of
~ indeterminate origin and material and to evaluate the installation of these bolts for impact on valve operability. This engineering evaluation determined that the installation of these bolts in this application has no effect on operability of the motor operated valve.
Limit switch covers are installed on the limit switch compartments of Limitorque operators for Pageos of 3
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cleanliness, personnel safety, and to protect the limitswitches from damage.
The design incorporates several bolts with a gasket between the limit switch cover and the limit switch compartment.
The equipment qualification report for Limitorque operators states,'n part, that Limitorque actuators for nuclear plant application are designed to permit them to survive normal and accident conditions without depending on absolute sealing and that the seals are of no importance for qualification, The questionable bolts in the limitswitch cover have been replaced.
A condition report/disposition request was initiated to determine the root cause of failure for improperly restoring motor operator valves'imit switch covers.
Previously completed work orders on the subject valve operators were <eviewedsto determine if any e
missing or questionable bolting on the limit switch covers had been documented.>
No missing or questionable bolting had been documented.
Consequently, the investigation concluded the root cause to be personnel error.
+ Maintenance personnel who perform work on motor operated valves were briefed.
on the identified conditions, and the importance of proper restoration of motor operated valves was stressed.
mLo mo 1<6.) 's Page 2 of 3
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. Corrective Ste s That Will Be Taken To Avoid Further Violations Based on similar problems recently identified by APS and NRC, APS willconduct an investigation of equipment hardware configuration to determine if there are additional
~useqpf Lese issues.
This investigation is expected to be completed by April13, 1992, and subsequent corrective actions will be implemented through the APS Incident Investigation Program.
Work orders have been initiated in Units 1, 2, and 3 tomalk down accessible safety related motor operated. valve operators to verify covers and fasteners are properly installed.
Missing or questionable fasteners will be documented and corrected.
Date When Full Com liance Will be Achieved APS achieved full compliance on February 7, 1992, upon installation of the proper fasteners in'the motor operated valves'imit switch covers identified above.
Page 3 of 3
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ACCELERATED DISTRIBUTION DEMONSTPWTION SYSTEM REGULATORY'NFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9202250367 DOC.DATE: 92/02/14 NOTARIZED:
NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 AUTH.NAME AUTHOR AFFILIATION ONWAY,W.F.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 920116 ltr re violations noted in insp rept 50-528/91-44 from 911104 to 911206.Corrective actions:proper fasteners installed in motor valves'imit switch covers as identified as of 920207.
DISTRIBUTION CODE:
IEOID COPIES RECEIVED:LTR L ENCL I
SIKE:
TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:STANDARDIZED PLANT 05000528 RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M INTERNAL: ACRS AEOD/DEIIB DEDRO NRR MORISSEAUSD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 OE DIR REGS
- E EXTERNAL EG&G/BRYCEgJ
~ H NSIC NOTES:
~O 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 1
RECIPIENT ID CODE/NAME TRAMMELL,C AEOD AEOD/DSP/TPAB NRR HARBUCK,C.
NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR 8E2 NUDOCS-ABSTRACT OGC/HDSl RGN5 FILE 01 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 1
1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE %ASIA CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISIS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED:
LTTR 26 ENCL 26
WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR Arizona Public Service Company P.O. BOX 53999
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PHOENIX. ARIZONA85072-3999 102-02113-WFC/TRB/JRB February 14, 1992 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station: P1-37 Washington, DC 20555
Reference:
Letter dated January 16, 1992, from D. F. Kirsch, Chief, Reactor Safety Branch, NRC, to W. F. Conway, Executive Vice President, Nuclear, APS.
Gentlemen:
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION (PVNGS)
UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION50-528/91~%1 File: 92-070-026 Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-528, 529, 530/91-44 and the Notice ofViolation dated January 16, 1992. Pursuant to the provisions of 10 CFR 2.201, APS'esponse is attached.
Appendix A to this letter is a restatement of the Notice of Violation. APS'esponse is provided in Attachment 1.
Should you have any questions regarding this response, please contact me.
Very truly yours, WFC/TRB/JRB/nk Attachments Appendix A - Restatement of Notice of Violation 2.
Attachment 1 - Reply to Notice of Violation cc:
J. B. Martin D. H. Coe 9202250367 9202i4 PDR ADOCK 05000528 8
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APPENDIX A RESTATEMENT OF NOTICE OF VIOLATION50-528/91%4-01 NRC INSPECTION CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 0
INSPECTION REPORT NOS. 50-528, 529, 530/91%4
1
RESTATEMENT OF NOTICE OF VIOLATION50-528 91%4-01 During an NRC inspection during the weeks of November 4, 18, and December 2, 1991, one violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below:
10 CFR Part 50. Appendix B, Criterion V, "Instructions, Procedures, and Drawings,"
states in part:
"Activitiesaffecting quality shall be prescribed by documented instructions, procedures, or drawings,... and shall be accomplished in accordance with these instructions, procedures, or drawings...."
o Palo Verde Nuclear Administrative and Technical Manual procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part, "Personnel doing maintenance shall not alter, change or modify plant equipment,...." Limitorque Vendor Technical Document Number VTD-L200-0025, states in part, "Limitorque uses commercial grade 5 or better hardware on all operators.
All external hardware is cadmium plated for corrosion resistance."
Contrary to the above, on November 19, 1991, Unit 3 valve 3JSIA-HV-306 limit switch cover plate had two bolts installed, which were not grade 5 or better nor cadmium plated.
o Palo Verde Nuclear Administrative and Technical Manual Procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part, "Plant equipment shall be restored to, proper design configuration including all fasteners in place,...."
Contrary to the above, Unit 1 valve 1JCHB-HV-255; Unit 2 valves 2JSGA-UV-0138 and 2JCHE-HV-0536, and Unit 3 valve 3JSIA-UV-617 were missing fasteners on the limitswitch cover plates.
This is a Severity Level IV Violation (Supplement I)
Page1 of1
ATTACHMENT1 REPLY TO NOTICE OF VIOLATION50-528/91~01 NRC INSPECTION CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 INSPECTION REPORT NOS. 50-528, 529, 530/91~
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t
REPLY TO NOTICE OF VIOLATION50-528 91%441 Reason for h Vlolatl n The reason for the violation was personnel error by maintenance personnel in restoring certain motor operated valve limitswitch covers to proper design configuration following maintenance activities.
Specifically, one example of two bolts of questionable material installed in a motor operated valve limitswitch cover plate and four examples of a missing fastener on limit switch cover plates on four motor operated valves were identiTied.
Corrective S e s Tha Have Been Taken and the Resul Achfeved Material nonconformance reports were initiated upon identification of the four missing bolts from the four limit switch covers.
The missing fastener in each limitswitch cover has been replaced.
An engineering evaluation request was initiated to document the bolting being of indeterminate origin and material and to evaluate the installation of these bolts for impact on valve operability. This engineering evaluation determined that the installation of these bolts in this application has no effect on operability of the motor operated valve.
Limit switch covers are installed on the limitswitch compartments of Limitorque operators for Pageos of 3
V i
t
cleanliness, personnel safety, and to protect the limitswitches from damage.
The design incorporates several bolts with a gasket between the limit switch cover and the limit switch compartment.
The equipment qualification report for Limitorque operators states, in part, that Limitorque actuators for nuclear plant application are designed to permit them to survive normal and accident conditions without depending on absolute sealing and that the seals are of no importance for qualification. The questionable bolts in the limitswitch cover have been replaced.
A condition report/disposition request was initiated to determine the root cause of failure for improperly restoring motor operator valves'imit switch covers.
Previously completed work orders on the subject valve operators were reviewed to determine ifany
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~
missing or questionable bolting on the limit switch covers had been documented.
No missing or questionable bolting had been documented.
Consequently, the investigation concluded the root cause to be personnel error.
Maintenance personnel who perform work on motor operated valves were briefed on the identified conditions, and the importance of proper restoration of motor operated valves was stressed.
Page 2 of 3
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Corre lv s Tha Will Be Taken To Avoid Further Viola I ns Based on similar problems recently identified by APS and NRC, APS willconduct an investigation of equipment hardware configuration to determine ifthere are additional causes of these issues.
This investigation is expected to be completed by April 13, 1992, and subsequent corrective actions will be implemented through the APS Incident Investigation Program, Work orders have been initiated in Units 1, 2, and 3 to walk down accessible safety related motor operated valve operators to verify covers and fasteners are properly installed.
Missing or questionable fasteners will be documented and corrected.
Da e When Full Com lienee Will be Achieved APS achieved full compliance on February 7, 1992, upon installation of the proper fasteners in the motor operated valves'imit switch covers identified above.
Page 3 of 3