ML17312B724

Responds to NRC 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)

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 Unit 2i Ari zona Pub li 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:

LITCQ 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/DISP /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

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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

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/mah 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

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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

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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 IVviolation (Supplement 1) 50-529/97-15-03.

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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

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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 willbe 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 willbe 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

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Supervisor's authorization was obtained.

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