ML20056H428

Responds to NRC Re Deviations Noted in Insp Repts 50-528/93-17,50-529/93-17 & 50-530/93-17.C/As:completed in-depth Self Assessment of Svc Water Sys,Including Evaluation of Commitments in GL 89-13

ML20056H428
Person / Time
Site:	Palo Verde
Issue date:	09/03/1993
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02626-WFC-T, 102-2626-WFC-T, GL-89-13, NUDOCS 9309090303
Download: ML20056H428 (18)

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Arizona Public Service Company

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P O. BOX 53999. PHOEN!X. ARIZONA B5072-3999 i

WILLIAM F CONWAY F *! CUUVE VICE PP(S!Di'NT wuctra 102-02626-WFC/TRB/DLK September 3, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Reply to Notice of Deviation 50-528/529/530/93-17-02 File: 93-019-026 Arizona Public Service Company (APS) has reviewed NRC. inspection Report 50-528/529/530/93-17 and the Notice of Deviation, dated July 21,1993. Pursuant to the provisions of 10 CFR Part 2, Appendix C, APS' response is enclosed. Enclosure 1 to this letter is a restatement of the Notice of Deviation.

APS' response is provided in l.

Also provided in Enclosure 2, as requested in the cover letter that transmitted the NRC Inspection Report, are the reasons and corrective actions APS determined were warranted to address _ the inadequate review and verification of commitment implementation. The due date for this response was extended from August 20, 1993 to September 3,1993, during a-telephone conversation 'with Mr. Lewis Miller on August 18,1993.

Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421'.

Sincerely

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Enclosures:

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Restatement of Notice of Deviation j

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Reply to Notice of Deviation ec:

_ B. H. Faulkenberry -

J. A. Sloan -

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ENCLOSURE 1 1

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RESTATEMENT OF NOTICE OF DEVIATION 50-528/529/530/93-17-02 1

i NRC INSPECTION CONDUCTED JUNE 7 THROUGH JUNE 25,1993 l

INSPECTION REPORT NOS.'50-528/529/530/93-17 i

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^ Restatement of Notice of Deviation 50-528/529/530/93-17-02 i

During an NRC inspection conducted from June 7 to June 25,1993 a deviation of your l

commitments made in response to Generic Letter 89-13. " Service Water System Problems l

Affecting Safety-Related Equipment," was identified. In accordance with the " General l

Statement of Policy and Procedure for NRC Enforcement Action" 10 CFR Part 2, Appendix C, the deviation is listed below.

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in response to Generic Letter 89-13, Arizona Public Service Company letters i

161-02801-JNB/JST and 161-04031-WFC/JRP dated. January 26,1990 and l

July 1,1931 respectively stated in part that:

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" Testing to demonstrate thermal performance and heat transfer capability of both 3

open and closed cycle will be performed...

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" Existing preventative maintenance tasks regularly inspect the components l

identified in the Generic Letter." - The Generic Letter identified "... service water _

system piping..." as components applicable to the Generic Letter concern.

Contrary to the above, the NRC inspection identified that as of June 25,1993, j

testing which demonstrated thermal performance and heat exchanger capability.

had not been performed, and the inspection of service water piping had not been

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included in the regular preventative maintenance tesks.

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ENCLOSURE 2 i

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l REPLY TO NOTICE OF DEVIATION 50-528/529/530/93-17-02

-j NRC INSPECTION CONDUCTED JUNE 7 THROUGH JUNE 25,1993 1

i INSPECTION REPORT NOS. 50-528/529/530/93-17 i

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Reply to Notice of Deviation 50-528/529/530/93-17-02 Reason for the Deviation:

Arizona Public Service Company's (APS) response to NRC Generic Letter (GL) 89-13 contained both an omission and an unnecessary commitment that went unrecognized and uncorrected during the GL response development and review cycle. Specifically, the j

response omitted a plan to develop a periodic inspection program for service water i

system pipira and committed to conduct thermal performance testing on closed-cycle l

service water system heat exchangers and small, accessible open-cycle service water system heat exchangers.

The response-was based on recommendations from engineering that were not adequately reviewed against the recommendations provided l

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GL 89-13 also required confirmation to the NRC that all the recommended aci6ns (of the 5

l GL) or their justified alternatives had been implemented. The verificat6n performed at

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Palo Verde did not identify any concerns with APS' GL 89-13 prograni er commitment implementation. The verification only confirmed that the procedures to implement the l

program existed. The verification did not evaluate the adequacy of the program to meet l

the recommendations of the GL, nor did the verification confirm that procedures were l

being performed as committed.

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Finally, the management controls placed on the " ongoing" testing to demonstrate heat i

exchanger thermal performance and heat transfer capability, were ineffective in ensuring (nat the testing was scheduled and performed as committed. Heat exchanger thermal 4

l performance testing was not incorporated into a system that automatically placed it into the refueling outage schedules and, as such, was not performed on all heat exchangers 1

as committed.

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Corrective Actions Taken and Results Achieved:

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APS completed an in-depth self assessment of the service water systems, including an -

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evaluation of the original commitments made in response to GL 89-13. As a result, APS is currently revising the original GL 89-13 response. The revised response will include a j

plan to develop maintenance tasks that periodically inspect service water system piping.

l Additionally, the original commitment to conduct thermal performance testing on all open i

and closed-cycle service water system heat exchangers will be revised taking into consideration EPRI guidelines as discussed in the next section.

An operability review was performed on all open and closed-cycle service water system heat exchangers under Condition Report / Disposition Request 9-3-0532. Based on the satisfactory performance of the heat exchangers during Integrated Safeguards Testing,-

Performance Engineering system temperature trend results, high quality system chemistry 2 of 4 i

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control, and the results of visual heat exchanger inspections conducted during refueling l

outages, engineering determined that all open and closed-cycle heat exchangers are capable of performing their intended safety function and are therefore capable of meeting i

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their design basis requirements.

l Nuclear Engineering is reconstituting the design basis calculations for the service water systems. The results of these calculations will be used to determine the type of heat

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exchanger testing to be performed and the accuracy of instrumentation needed to I

adequately verify that design heat transfer rates will be met.

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The manager of Quality Audits and Monitoring (OA&M) has conducted a discussion with the OA&M staff to reinforce management expectations with regards to audit and j

monitoring activities. These expectations include the need to clearly describe the scope i

of Quality Assurance overview activities in audit and monitoring reports in order to provide plant management with accurate indicators of plant performance, l

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l Corrective Action That Will Be Taken To Avoid Further Deviations:

The heat exchanger thermal performance program will be revised taking into i

consideration EPRI guideline NP-7552 (Heat Exchanger Performance Monitoring) dated December 1991. This guideline, developed in response to GL 89-13, provides methods 3 of 4 e

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to test heat exchangers using steady state heat loads, thus potentially eliminating the need for a refueling outage to determine the heat transfer capabilities of safety-related heat exchangers.

Video camera inspections on a portion of the spray pond piping in Units 1 and 3 will be conducted during refueling outages 1 R4 and 3R4, respectively. Engineering will evaluate the inspection results from all three units (Unit 2 has already been inspected and evaluated as satisfactory) and recommend the scope and frequency of spray pond system piping inspections to be included in the preventive maintenance program by June 30,1994.

Quality Assurance management will ensure that future oversight activities involving technical issues are assigned to technically qualified individuals.

Date When Full Compliance Will Be Achieved:

APS expects to begin implementing the revised EW heat exchanger thermal performance and heat exchanger capability testing program by March 31,1994. Full compliance will be achieved by September 30,1995, when the initial testing program is complete (i.e.,

three tests are performed on each EW heat exchanger) and a periodic retest frequency is established.

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