ML17312B724

Responds to NRC 970912 Ltr Re Violations Noted in Insp Repts 50-528/97-15,50-529/97-15 & 50-530/97-15.Corrective Actions: Responsible Engineer Was Coached on Procedural Use & Adherence

ML17312B724
Person / Time
Site:	Palo Verde
Issue date:	10/10/1997
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-04030-JML-A, 102-4030-JML-A, 50-528-97-15, 50-529-97-15, 50-530-97-15, NUDOCS 9710170031
Download: ML17312B724 (16)

See also: IR 05000528/1997015

Text

REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)CESSION NBR: 9710170031

DOC.DATE: 97/10/10 NOTARIZED:

NO DOCKET FACIL: STN-50-528

Palo Verde Nuclear Stations Unit 1.Arizona Publi 05000528 STN-50-529

Pa l o Verde Nuc lear Sta t i one Uni t 2i Ar i zona Pub l i 05000529 STN 50 530 Palo Verde Nuclear Stations Unit 3.Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION

LEVINE'.M.Arizona Public Service Co.(formerly Arizona Nuclear Pouper RECIP.NAME REC IP IENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 970912 ltr re violations

noted in insp repts 50-528/97-15

50-529/97-15

5 50-530/97-15

respectively.

Corrective

actions: responsible

engineer coached on procedural

use 8.adherence.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED: LTR ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES:STANDARDIZED

PLANT Standardized

plant.Standardi zed plant.05000528 05000529 05000530 RECIPIENT ID CODE/NAME PD4-2 PD TERNAL: ACRS RR/DRCH/HHFB

NRR/DRPM/PERH

OE D IR RGN4 FILE 01 EXTERNAL: L ITCQ BRYCEi J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME THOMAS'AEOD/SPD/RAB

DEDRO NRR/D I SP/P IP 8 NRR/DRPM/PECB

NUDOCS-ABSTRACT

QGC/HDS2 NOAC NUDQCS FULLTEXT COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D 0 C N NOTE TO ALL"RIDS" RECIPlENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION

REMOVED FROM DISTRIBUTION

LISTS OR REDUCE THE NUMBER OF COPIES RECEZVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COP I ES REQUIRED: LTTR, 20 ENCL 20

i I

Commitment.

Innmerfon.

Fneryy.Pa'lo Verde Nuclear Generating

Station James M.Levine Senior Vice President Nuclear TEL (602)393-5300

FAX (602)393-6077

Mail Station 7602 P.O.Box 52034 Phoenix, AZ 65072-2034

102-04030-JML/AKK/DLK

October 10, 1997 U.S.Nuclear Regulatory

Commission

ATTN: Document Control Desk Mail Station: P1-37 Washington, DC 20555-0001

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 50-529/97-15-03

Arizona Public Service Company (APS)has reviewed NRC Inspection

Report 50-528/529/530/97-15

and the Notices of Violation (NOV)dated September 12, 1997.APS agrees that the report accurately

reflects our corrective

actions and position relative to NOV nA" and accepts the option of not responding

to the violation.

Pursuant to the provisions

of 10 CFR 2.201, APS'esponse

to NOV"B" is enclosed.Enclosure 1 to this letter is a restatement

of NOV"B." APS'esponse

is provided in Enclosure 2.Should you have any further questions, please contact Ms.Angela K.Krainik at (602)393-5421.Sincerely, J ML/AKK/DLK/m

ah Enclosures

1.Restatement

of Notice of Violation 2.Reply to Notice of Violation cc: E.W.Merschoff K.E.Perkins K.M.Thomas J.H.Moorman 9710170031

971010 PDR ADOCK 05000528 8 PDR Il!II!IIII!IIIIIIIIIIIIIIIIIIIIIIII

I

Cl

ENCLOSURE 1 RESTATEMENT

OF NOTICE OF VIOLATION"B" 50-529/97-15-03

NRC INSPECTION

CONDUCTED JULY 27 THROUGH SEPTEMBER 6, 1997 INSP ECTION REPORT NO.50-528/529/530/97-15

W1

RESTATEMENT

OF NOTICE OF VIOLATION"B" 50-529/97-15-03

During an NRC inspection

conducted on July 27 through September 6, 1997, two violations

of NRC requirements

were identified.

In accordance

with the"General Statement of Policy and Procedure for NRC Enforcement

Actions," NUREG-1600, violation"B" is listed below.(Note-'o response to Violation"A" is required.)

Technical Specification 6.8.1 requires, in part, that written procedures

shall be established, implemented, and maintained

covering the applicable

procedures

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Regulatory

Guide 1.33, Revision 2, Appendix A, requires, in part, written procedures

for procedural

adherence.

Procedure 01DP-OAP01,"Procedure

Process," Revision 4, Step 7.2, required, in part, that procedure users are responsible

for adhering to the requirements

of the procedure.

Contrary to the above, on July 23, 1997, licensee personnel failed to adhere to the requirements

of Procedure 70TI-9SP03, Chemical Passivation

Of Spray Pond Piping, Revision 0.Specifically, Step 4.2 which required the control room supervisor/shift

supervisor

to be briefed on the test procedure and that the work group obtain permission

to proceed with the test.These requirements

were not performed.

Also, Step 5.8, which required a pretest briefing to be conducted, was not performed.

.This is a Severity Level IV violation (Supplement

1)50-529/97-15-03.

1 i

ENCLOSURE 2 REPLY TO NOTICE OF VIOLATION"B" 50-529/97-15-03

NRC INSPECTION

CONDUCTED JULY 27 THROUGH SEPTEMBER 6, 1997 INSPECTION

REPORT NO.50-528/529/530/97-15

I

REPLY TO NOTICE OF VIOLATION"B" 50-529/97-15-03

Reason For The Violation On July 23, 1997, temporary piping was installed by divers in the Unit 2 spray pond.The procedure used to install the temporary piping was test and inspection

procedure 70TI-9SP03,"Chemical Passivation

of Spray Pond Piping." The prerequisite

and initial condition sections of 70TI-9SP03

included individual

signoffs for obtaining Shift Supervisor

authorization

and performing

a prejob briefing.The Project Manager discussed the test plan with the Work Control Senior Reactor Operator and afterwards

briefed the diving crew;however, the engineer responsible

for conducting

the test did not contact the Shift Supervisor

and obtain authorization

nor did he conduct and document a thorough prejob briefing with all appropriate

personnel.

Failing to notify the Shift Supervisor

and conduct a thorough prejob briefing resulted in missed opportunities

to prevent events that compromised

the personal safety of the divers.Specifically, a valve that was being used as a safety boundary during installation

of the temporary piping was cycled open while divers were in the spray pond and unmonitored

service air was used by some divers as a breathing air source during diving operations.

Failing to complete the prerequisite

and initial conditions

of 70TI-9SP03

prior to installing

the temporary piping in the spray pond was contrary to approved station procedures

and was a violation of Technical Specification 6.8.1.

Palo Verde's significant

investigations

of the event determined

the reason for the violation was poor work practices on the part of the responsible

engineer.A contributing

factor was poor communications

between operations, engineering, maintenance, and scheduling.

Corrective

Ste s That Have Been Taken and Results Achieved Significant

investigations

were performed in accordance

with Palo Verde's corrective

action program.Based on the results of the investigations, the responsible

engineer was coached on procedural

use and adherence.

Corrective

Ste s That Will Be Taken To Avoid Further Violations

A newsletter

will be issued by strategic communications

on procedure use and adherence and procedure implementation, including responsibilities

for impact reviews C and training for affected personnel by October 30, 1997.Training will be provided to all engineering

support personnel on procedure use and adherence, procedure preparation

and implementation, including responsibilities

for impact reviews and training for affected personnel by January 31, 1998

Date When Full Com liance Will Be Achieved Full compliance

was achieved on July 23, 1997 after the first phase of temporary piping was installed and 70TI-9SP03

suspended.

On September 12, 1997, prior to continuing

work under 70TI-9SP03, a thorough prejob briefing was conducted and the Shift (Supervisor's

authorization

was obtained.

j j