ML20057C502
| ML20057C502 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/24/1993 |
| From: | Vandenburgh C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9309290037 | |
| Download: ML20057C502 (3) | |
See also: IR 05000528/1993012
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Docket Nos.:
50-528
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50-529
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50-530
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Arizona Public Service Company
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Post Office Box 53999
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Phoenix, Arizona 85072-3999
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Attention:
Mr. William F. Conway
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Executive Vice President, Nuclear
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Gentlemen:
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Thank you for your. letter of July 29, 1993, in response to our Notice of
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Violation and Inspection Report Nos. 50-528/529/530/93-12, dated July 1, 1993,
informing us of the steps you have taken to correct the items which we brought
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to your attention.
Your corrective actions will be verified during a future
inspection.
Your cooperation with us is appreciated.
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Sincerely,
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C. A. VanDenburgh, Chief
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Reactor Projects Branch
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cc:
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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
Chairman, Maricopa County Board of Supervisors
Jack R. Newman, Esq., Newman & Holtzinger, P.C.
Mr. Curtis Hoskins, Executive Vice President and Chief Operating Officer,
Palo Verde Services
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Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld
Bradley W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld
Thomas R. Bradish, Manager, Nuclear Regulatory Affairs, APS
bec w/ copy of letter dated July 29, 1993:
Docket File
Resident inspector
Project inspector
G. Cook
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R. Huey
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B. Faulkenberry
J. Zollicoffer
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M. Smith
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NUCLEAR REGULATORY COMMISSION
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REGION V
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Docket Nos.:
50-528
50-529
50-530
Arizona Public Service Company
Post Office Box 53999
Phoenix, Arizona 85072-3999
Attention:
Mr. William F. Conway
Executive Vice President, Nuclear
Gentlemen:
Thank you for your letter of July 29, 1993, in response to our Notice of
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Violation and Inspection Report Nos. 50-528/529/530/93-12, dated July 1, 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.
Your cooperation with us is appreciated.
.
Sincerely,
\\
C.A.VanDenburgh,hief
Reactor Projects Branch
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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
Chairman, Maricopa County Board of Supervisors
Jack R. Newman, Esq. , Newman & Holtzinger, P.C.
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Mr. Curtis Hoskins, Executive Vice President and Chief Operating Officer,
Palo Verde Services
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Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld
Bradley W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld
Thomas R. Bradish, Manager, Nuclear Regulatory Affairs, APS
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Arizona Public Service Company
P O BOX 53999 * PHOEN!X. ARIZONA 85072 3999
102-02587-WFC/TRB/RJR
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July 29,1993
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NUCLcAR
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U. S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Mail Station P1-37
Washington, DC 20555
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 Violation 50-528/93-12-04
File: 93-070-026
Arizona Public Service Company (APS) has reviewed NRC Inspection Report
50-528/529/530/93-12, and the Notice of Violation dated July 1,1993. Pursuant to the
provisions of 10 CFR 2.201, APS' response is enclosed. Enclosure 1 to this letter is a
restatement of the Notice of Violation. APS' response is provided in Enclosure 2.
Should you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely,
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WFC/TRB/RJR/bcf
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Enclosures:
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1.
Restatement of Notice of Violation
2.
Reply to Notice of Violation
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cc:
B. H. Faulkenberry
J. A. Sloan
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ENCLOSURE 1
RESTATEMENT OF NOTICE OF VIOLATION
50-528/93-12-04
NRC INSPECTION CONDUCTED APRIL 27-MAY 31,1993
INSPECTION REPORT NOS. 50-528/529/530/93-12
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RESTATEMENT OF NOTICE OF VIOL ATION 50-528/93-12-04
During an NRC inspection conducted on April 27 through May 31,1993, one violation of
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NRC requirements was identified. In accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix C, the violation
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is listed below:
Violation 50-528/93-12-04. Snubber Testina
Technical Specification (TS) Surveillance Requirement (SR) 4.7.9.e.2 states
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that a representative sample of each type of snubber shall be functionally
tested in accordance with Figure 4.7-1 during the first refueling shutdown
and at least once per 18 months thereafter during shutdown. For each
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type of snubber, Figure 4.7-1 requires that the snubbers be tested until the
plot of number of failures versus the total number tested falls in the accept
region (a minimum of 37 snubbers) or until all snubbers have been tested.
TS SR 4.7.9.e states that the representative sample shall be randomly
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selected.
Contrary to the above, as of May 12,1993, the licensee failed to meet the
surveillance requirements for testing snubbers in Units 1,2, and 3 in that
the licensee did not test each type of snubber until the plot of failures
versus total tested fell in the accept region or until all snubbers of that type
were tested. Additionally, the representative snubber samples were not
random.
This is a Severity Level IV violation (Supplement I) applicable to Units 1,2,
and 3.
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ENCLOSURE 2
REPLY TO NOTICE OF VIOLATION
50-528/93-12-04
NRC INSPECTION CONDUCTED APRIL 27-MAY 31,1993
INSPECTION REPORT NOS. 50-528/529/530/93-12
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REPLY TO NOTICE OF VIOLATION 50-528/93-12-04
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Reason For The Violation
The reason for the violation was personal error, in that the procedure preparer developed
a program which did not meet the cotomitted Technical Specification (TS) surveillance
requirements. Further, the technical reviewers and management involved in reviewing the
program assumed, based on internal discussions, that the program met the TS
requirements and as such, did not perform independent verification and/or validation of
the program to the requirements. As a result, the condition has existed since program
initiation.
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Corrective Actions Taken And Results Achieved
An evaluation of the snubber testing program at PVNGS concluded that the test program,
as implemented, demonstrated that the snubbers are operable even though the test
program was not being conducted in full compliance with the committed TS requirements.
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in accordance with TS 4.0.3 failure to perform a surveillance requirement constitutes
noncompliance with the OPERABILITY requirements for the Limiting Condition for
Operation (LCO) and requires the entry into the associated ACTION statement.
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PVNGS entered the ACTION statement for TS 3.7.9 at approximately 1330 MST on May
12,1993. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> ACTION period would have ended at approximately 1330 MST on
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May 15,1993, when PVNGS Units 1 and 3 would have been required to shutdown in
accordance with TS 3.0.3. A Notice of Enforcement Discretion from PVNGS Units 1,2,
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and 3 TS 3.7.9 ACTION statements was requested from and subsequently granted by the
NRC at approximately 1400 MST on May 14,1993.
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A one time only change to TS 3/4.7.9 to document the acceptability of past practices for
selecting snubber functional test samples was approved on June 21,1993.
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An independent Safety Engineering Assessment of this event was completed on June 21,
1993, to determine what barriers failed, allowing this condition to exist. The assessment
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determined that the technical review process was inadequate as discussed in the reason
for the violation above. The assessment also determined that although Quality Audits and
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Monitoring had specific requirements in the QA Plan for review of TS and the reviews had
been conducted, the snubber testing program procedure and the TS were never
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reviewed together in their entirety. The assessment determined that other TS have a
potential for the same condition and recommended that a separate assessment be
conducted.
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Corrective Actions That Will Be Taken To Avoid Further Violations
The PVNGS Snubber Testing program will be revised to correctly implement the TS
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requirements prior to commencing the next testing cycle.
The independent Safety Engineering Assessment provided recommendations for
improving the technical review and oversight programs to enhance their ability to identify
any similar condition in the future. All recommendations are being tracked in the
Commitment Action Tracking System.
Based on interviews and review of the TS, the Independent Safety Engineering
Assessment team prepared a list of other TS which have the potential for a similar
condition. As an immediate action, Quality Audits included 4 of the TS from the list in
their periodic audit of TS which started on June 21,1993. If this audit finds conditions
similar to that identified with the snubber testing program, additional corrective actions
will be initiated as appropriate.
Date When Full Compliance Will Be Achieved
Full compliance was achieved on June 21,1993, when TS amendment 3 71,57, and 44
for Units 1,2 and 3 respectively, were approved.
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