ML17306A730
| ML17306A730 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/14/1992 |
| From: | CONWAY W F ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02147-WFC-T, 102-2147-WFC-T, NUDOCS 9205200206 | |
| Download: ML17306A730 (31) | |
See also: IR 05000528/1992005
Text
ACCELERATED
DISTRIBUTION
DEMONSTPA.TION
SYSTEM REGULATORY
INFORMATION
DISTRIBUTION
SYSTEM (RIDS)ESSION NBR:9205200206
DOC.DATE: 92/05/14 NOTARIZED:
NO'OCKET Lij'IL:STN-50-528
Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 AUTH.NAME AUTHOR AFFILIATION
CONWAY,W.F.
Arizona Public Service Co.(formerly Arizona Nuclear Power RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 920407 ltr re violations
noted in Insp Rept 50-528/92-05
on 920126-0229.Corrective
actions:hydrogen
test bottles, filled by local vendor, removed from svc,quarantined
&returned to vendor&condition rept initiated.
DISTRIBUTION
CODE IEOID COPIES RECEIVED LTR,L ENCL/SIZE'TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response D NOTES:STANDARDIZED
PLANT 05000528 RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M
INTERNAL: ACRS AEOD/DEIIB
DEDRO t NRR/DLPQ/LHFBPT
NRR/DOEA/OEAB
NRR/DST/DIR
8E2 NUDOCS-ABSTRACT
OGC/HDS1 RGN5 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
NSIC 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 RECIPIENT ID CODE/NAME TRAMMELL, C AEOD AEOD/DSP/TPAB
NRR MORISSEAU,D
NRR/DLPQ/LPEB10
NRR/DREP/PEPB9H
NRR/PMAS/ILRB12
O~EG FILE 02 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 D D R D NOTE TO ALL"RIDS" RECIPIENTS:
D D P LEASE HELP US TO REDUCE WASTE!CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAhIE FROM DISTRIBUTION
LISTS FOR DOCUMENTS YOU DON'T NEED!TAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24
WILLIAM F.CONWAY EXECUTNEVICEPRESLDENT
NUCLEAR Arizona Public Service Company P.O.BOX 53999~PHOENIX.ARIZONA 85072-3999
102-02147-WFC/TRB/JRB
May 14, 1992 U.S.Nuclear Regulatory
Commission
Attention:
Document Control Desk Mail Station: P1-37 Washington, DC 20555 Reference:
Letter dated April 7, 1992, from S.A.Richards, Chief, Reactor Projects Branch, NRC, to W.F.Conway, Executive Vice President, Nuclear, Arizona Public Service Company.Gentlemen:
Subject: PALO VERDE NUCLEAR GENERATING
STATION (PVNGS)UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATIONS
50-528/92-05-01, 50-528/92-05-02
AND 50-528/92-05;03
File: 92-070-026
Arizona Public Service Company (APS)has reviewed NRC Inspection
Report 50-528, 529, 530/92-05 and the Notice of Violations
dated April 7, 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 Violations.
APS'esponse
is provided in Attachment
1.Per telephone conversation
on May 6, 1992, between H.J.Wong, NRC, and T.R.Bradish, APS, an extension of the due date for this response from May 7, 1992, to May 15, 1992.This extension was necessary as a result of PVNGS Unit 3 being in an ALERT emergency classification
from May 4, 1992, through May 6, 1992.Should you have any questions regarding this response, please contact me.Sincerely,'0 WFC/TRB/JRB/dmn
Attachments
1.Appendix A-Restatement
2.Attachment
1-Reply to Notice of Violations
cc: J.B.Martin A i-i C'.nn 9205200206
920514 PDR ADDCK 05000528 8 PDR p7p,~)stI r Iiq5
'
APPENDIX A RESTATEMENT
50-528/92-05-02, 50-528/92-05-01
AND 50-528/92-05-03
NRC INSPECTION
CONDUCTED JANUARY 26, 1992-FEBRUARY 29)1992 INSPECTION
REPORT NOS.50-528, 529, AND 530/92-05
i
RESTATEMENT
50-528 92-05-02 50-528 92-0541 AND 50-528 92-05-03 During an NRC inspection
conducted on January 26 through February 29, 1992, three violations
of NRC requirements
were identified.
In accordance
with the"General Statement of Policy and Procedure for NRC Enforcement
Action," 10 CFR Part 2, Appendix C, the violations
are listed below: A.Unit 1 Technical Specification 6.8.1 states, in part, that written procedures
shall be established, implemented, and maintained
covering the activities
recommended
in Appendix A of Regulatory
Guide 1.33, Revision 2, February, 1978.Regulatory
Guide 1.33, Revision 2, Appendix A, recommends
surveillance
procedures
and general plant operating procedures.
Surveillance
procedure 36ST-9SB02,"PPS Bistable Trip Units Functional
Test," Step 8.11.6.2, requires the test performer to"ensure LO SG2 PRESS Trip Setpoint (Parameter
12)is at the MAXIMUM VALUE when in Mode 1 or 2.Adjust as necessary." Contrary to the above, on February 4, 1992, when performing
step 8.11.6.2, the test performer failed to ensure the LO SG2 PRESS trip setpoint (parameter
12)was at the maximum value when the unit was in Mode 1, resulting in the setpoint being approximately
50 pounds per square inch less that[sic]the minimum value allowed by Technical Specifications 2.2.1 and 3.3.2.2.General operating procedure 40DP-90P05,"Control Room Data Sheet Instructions," Step 2.3.2, requires that a reactor operator report"any abnormal and/or unusual condition" while filling out the Control Room Data Sheets.Contrary to the above, on February 4, 1992, at 5:00 pm, while filling out the Control Room Data Sheets, the reactor operator failed to note that the 42 steam generator low pressure setpoint was incorrectly
set.This is a Severity Level IV Violation (Supplement
I)applicable
to Unit 1.B.Unit 1 Technical Specification 6.8.1 states, 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.Page 1
Regulatory
Guide 1.33, Appendix A;recommends
procedures
for performing
maintenance
and states that maintenance
that can affect the performance
of safety-related
equipment should be properly preplanned
and performed in accordance
with written procedures, documented
instructions, or drawings appropriate
to the circumstances.
Licensee Procedure 36MT-9RI06,'VNhdrawal
of ICI Cables," Section 8.4.5, requires the control element assembly (CEA)hoist to be used when withdrawing
fixed incore instruments (ICls)for refueling operations.
Contrary to the above, on February 25, 1992, the licensee failed to implement Procedure 36MT-9RI06, in that fixed ICI 455 was manually withdrawn without using the CEA hoist.This is a Severity Level IV violation (Supplement
I)applicable
to Unit 1.C.10 CFR 50, Appendix B, Criterion XII, requires that measures be established
to assure that tools, gages, instruments, and other measuring and testing devices used in activities
affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.Contrary to the above, no measures were established
to assure that calibration
gas used for performance
of containment
hydrogen monitor surveillance
tests, an activity affecting quality, was properly controlled
and calibrated.
Specifically, on February 11, 1992, the Unit 2 Containment
Hydrogen Monitor Channel A surveillance
test (Procedure
was performed using a calibration
gas that was not procured from a QA approved vendor and no other QA controls were provided to assure the proper calibration
of the gas.On February 13, 1992, one containment
hydrogen monitor each in Units 1 and 3, were also determined
to have had surveillance
tests performed with calibration
gas that was not properly controlled
or calibrated.
This is a Severity Level IV violation (Supplement
1)applicable
to Units 1, 2 and 3.Page 2
ATTACHMENT
1 REPLY TO NOTICE OF VIOLATIONS
50-528/92-05-02, 50-528/92-05-0
t AND 50-528/92-05-03
NRC INSPECTION
CONDUCTED JANUARY 26, 1992-FEBRUARY 29, 1992 INSPECTION
REPORT NOS.50-528, 529, 530/92-05
0 REPLY TO NOTICE OF VIOLATION 50-528 92-05-02 Reason For The Violation The reason for both examples of the violation was a cognitive personnel error.During scheduled surveillance
testing of the Unit 1, number 1 steam generator low steam generator pressure trip setpoint on February 4, 1992, the RPS/ESFAS channel'B'ow steam generator pressure trips for both the number 1 and number 2 steam generators
were placed in bypass, as required by 36ST-9SB02,"PPS Bistable Trip Units Functional
Test." During this surveillance, the low steam generator pressure setpoint reset button was depressed, as required, resulting in the channel'B'ow steam generator pressure trip setpoint for both steam generators
being reduced to approximately
200 psia e below the actual steam generator pressures.
The surveillance
test subsequently
requires resetting of the channel'B'ow steam generator pressure trip setpoint to verify proper operation.
The channel'B'ow steam generator pressure trip setpoint for the number 1 steam generator was reset in accordance
with the surveillance
test procedure.
While checking the channel'B'ow steam generator pressure trip setpoint for the number 2 steam generator, the maintenance
I&C technician
performing
the surveillance
test did not select the number 2 steam generator low steam generator pressure setpoint on the select switch.This resulted in the maintenance
l&C technician
erroneously
using the previously
verified number 1 steam generator channel'B'ow steam generator pressure trip setpoint to check the numbers 2 steam generator channel'B'ow steam generator pressure trip setpoint.The RPS/ESFAS channel'8'ow steam generator Page 1 of 11
pressure trips for both the number 1 and number 2 steam generators
were taken out of bypass following completion
of the applicable
portion of the surveillance
test.N Approximately'one-half
hour after the channel'B'ow steam generator pressure trips were taken out of bypass, a Unit 1 control room reactor operator checked the low steam generator pressure trip setpoints as part of a scheduled setpoint check.The operations
procedure for control room data sheets (40DP-9OP05,"Control Room Data Sheet Instructions")requires any abnormal and/or unusual conditions
or readings be reported to the Shift Supervisor
or Assistant Shift Supervisor.
The control room reactor operator did not identify that the RPS/ESFAS channel'B'ow steam generator pressure trip setpoint for the number 2 steam generator was below the minimum allowed Technical Specification
value, as required.Corrective
Ste s That Have Been Taken And The Results Achieved Approximately
one hour after the control room reactor operator failed to identify the incorrect RPS/ESFAS channel'B'ow steam generator pressure trip setpoint for the Unit 1, number 2 steam generator, the Assistant Shift Supervisor
discovered
that the setpoint was below the minimum allowed Technical Specification
value.The channel'B'ow steam generator pressure trip for the number 2 steam generator was declared inoperable
and the Unit 1 maintenance
l&C department
was notified.The low steam generator pressure trip setpoint was reset to the required value approximately
one hour later.Page 2 of 11
A Condition Report/Disposition
Request was initiated to conduct an investigation
of this event and subsequently
determined
the cause to be personnel error.The involved control room reactor operator and maintenance
I8 C technician
have been disciplined
in accordance
with the APS Positive Discipline
Program.A control room night order discussing
this event was issued in Units 1, 2, and 3 to reinforce the importance
of attention to detail in performing
routine checks thoroughly.
Briefings have been conducted on this event with Units 1, 2, and 3 maintenance
l&C technicians.
As an enhancement, the surveillance
test procedure (36ST-9SB02)
has been revised to add detailed action steps to direct performers
on how to attain and determine the low steam generator pressure trip setpoints for added assurance that the minimum e allowed value for the trip setpoint is attained prior to removing the low steam generator pressure trip from bypass.The investigation
results were provided to the NRC in a letter from James M.Levine dated March 5, 1992 (Licensee Event Report 528/92-003-00).
Corrective
Ste s That Will Be Taken To Avoid Further Violations
The corrective
actions discussed above are considered
adequate to avoid further violations
and no additional
corrective
actions are planned.Page 3of11
~
Date When Full Com Ilance Will Be Achieved Full compliance
was achieved on February 4, 1992, upon restoring the Unit 1, steam generator number 2 low steam generator pressure trip setpoint.to
the minimum allowed Technical Specification
value.Additional
Information
The inspection
report cover letter requests an assessment
of the need for independent
verification
of the reactor trip setpoints adjusted during surveillance
testing.During the investigation
of this event, APS evaluated the need for independent
verification
of as-left reactor trip setpoints.
Although no previous examples of improper restoration
of reactor trip setpoints at the conclusion
of surveillance
testing were identified, APS e concluded that an additional
check of as-left reactor trip setpoints would be prudent, if the setpoint was.adjusted outside the acceptance
criteria during the surveillance
test.Surveillance
testing meeting this criteria was identified
for the low steam generator pressure trip and the low pressurizer
pressure trip.Changes to the PPS bistable trip units functional
test procedure (36ST-9SB02)
have been initiated to require a separate check to verify that the low steam generator pressure trip setpoint and the low pressurizer
pressure trip setpoint are within their acceptance
criteria prior to removing the trips from bypass.These changes will be implemented
by June 30, 1992.Page 4 of 11
REPLY TO NOTICE OF VIOLATION 50-528 92-05-01 Reason For The Violation The reason for the violation was an improper procedural
step and subsequent
implementation
of the flexibility
allowed by the step.Prior to February 25, 1992, during Unit 1 refueling activities, sixty incore instruments
,(ICIs)had been withdrawn in accordance
with maintenance
procedure 36MT-9RI06,"Withdrawal
Of The Incore Instruments
For Reactor Refueling Operations," leaving one ICI installed.
On February 25, 1992, scaffolding
had been erected at the entrance to the east end of the refueling canal.This scaffolding
prevented placement of the control element assembly (CEA)/ICI change platform above the ICI holding frame, and consequently
the use of the CEA hoist to withdraw the final ICI, as required by 36MT-9RI06, Step 8.4.5.The a involved Work Group Supervisor
reviewed 36MT-9RI06
for an alternate means to remove the final ICI.Step 7.7 of 36MT-9RI06
states,'This procedure should be considered
a guideline, the I&C technician
and Work Group Supervisor
should have flexibility
in the order of work performance
and should decide the need for some steps depending upon inspection
results, such as cleaning of slip tubes, spacers, etc.".The Work Group Supervisor
interpreted
this step as allowing a manual withdrawal
of an ICI, in lieu of using the CEA hoist, as required by 36MT-9RI06, Step 8.4.5.Following the decision to attempt a manual withdrawal
of the final ICI, a tailboard meeting was conducted, at which the ICI task shift lead was cautioned on the slow lift requirement
and the 500 pound maximum pull requirement
of 36MT-9RI06.
The radiationPage 5 of 11
0 protection
department
was notified of the planned ICI manual withdrawal.
.During the actual ICI withdrawal, a rope was attached to the ICI lift bail and used by a technician
on the 140 foot elevation platform to withdraw the ICI.A second technician, in the accompaniment
of a radiation protection
technician, was located in the refuel cavity to wipe the cable as it was withdrawn.
When the withdrawal
was first attempted, the force was greater than anticipated, so the technicians
stopped the withdrawal
attempt to investigate
the cause.A piece of duct tape was removed from the ICI cable and the ICI was successfully
withdrawn and secured in the ICI holding frame The duct tape had been left following a preceding, unrelated maintenance
activity to replace the ICI seal housing.Corrective
Ste s That Have Been Taken And The Results Achieved A Condition Report/Disposition
Request was initiated to investigate
this activity and determined
the cause discussed above.The B&W Nuclear Services personnel were briefed on the incident and the need for verbatim procedural
compliance
was emphasized.
Changes have been made to maintenance
procedure 36MT-BRI06,'Withdrawal
Of The Incore Instruments
For Reactor Refueling Operations," to delete the phrase,"this procedure should be considered
a guideline," from Step 7.7 (Step renumbered
as 2.1.2.7)and to revise Step 8.4,5 (Step renumbered
as 4.4.12)to allow lifting ICls manually.Page 6 of 11
0 Corrective
Ste s That Will Be Taken To Avoid Further Violations
The corrective
actions discussed above are considered
adequate to avoid further violations
and no additional
corrective
actions are planned.Date When Full Com Ilance Will Be Achieved Full compliance
was achieved on February 25, 1992, upon completion
of the manual withdrawal
of the final Unit 1 ICI.Page 7 of 11
REPLY TO NOTICE OF VIOLATION 50-528 92-05-03 Reason For The Violation The reason for the violation was inadequate
interim corrective
measures upon identification
of a quality deficiency.
A quality deficiency
report was initiated in April, 1991, to document that surveillance
test procedure 36ST-9HP03,"Containment
Hydrogen Monitoring
System Calibration
Test, Channel A," was inadequate
in that the test gas used was not traceable to a calibration
standard.An action plan was developed to address this deficiency
which included actions to establish technical specification
and quality requirements
for the test gas and locate an acceptable
vendor.The test gas used in this surveillance
was being purchased on a non-quality
related purchase order used to purchase miscellaneous
gases, without identifying
specific plant applications
for each gas.\Prior to an acceptable
vendor being approved, interim measures were taken to ensure the quality of the test gas used in the performance
of 36ST-9HP03.
A prospective
vendor (Air Products and Chemical)was selected based on their use by another Region V utility as a supplier of safety-related
calibration
gases.The prospective
vendor's quality assurance manual was reviewed and APS concluded that the vendor had adequate processes for ensuring that the required calibration
standards are accurately
represented
in their Certificates
of Analysis (CQA).APS also verified that the test gas being supplied by a local vendor was, in fact, being filled by Air Products and Chemical.Surveillance
test procedures, 36ST-9HP03
and 36ST-9HP04 (Containment
Hydrogen Monitoring
Page 8of11
System Calibration
Test, Channel B)were revised to require the serial number on the test gas bottle to be recorded during performance
of the hydrogen monitoring
system'urveillance
test to provide traceability
of the gas bottle.Following identification
of the critical design attributes
that are essential to the dedication
process of test gas, APS performed a commercial
grade survey of Air Products and Chemical and identified
some minor programmatic
issues, none of which would question the accuracy of the hydrogen concentration.
A randomly selected bottle of test gas filled by this vendor which had been supplied to APS was verified to contain the correct hydrogen concentration
during this survey.On January 9, 1992, due to an urgent need for hydrogen test gas, the system engineer and the Unit 1 l&C maintenance
department
authorized
a purchase of hydrogen e test gas filled by a local vendor using the existing non-quality
related purchase order.No test gas was in stock at APS and approximately
two weeks would have been necessary to obtain the test gas from Air Products and Chemical.Test gas was obtained from the local vendor and used in Unit 1.Although use of hydrogen test gas filled by the local vendor in a hydrogen monitoring
system surveillance
test was inappropriate, involved personnel did comply with interim corrective
measures.During the week of February 10, 1992, an NRC inspector was observing the hydrogen monitoring
system surveillance
test on a Unit 2 hydrogen analyzer and noted that the test gas being used was not traceable to the vendor being evaluated for acceptance
by APS.Based on this observation, all three units were checked for hydrogen test gas bottles which were not traceable to the vendor being evaluated for acceptance.
Three additional
test gas bottles were found, Page 9 of 11
which were not traceable to the vendor being evaluated for acceptance.
These bottles had been purchased under the non-quality
related purchase order for miscellaneous
gases and filled by a local vendor at various times.Corrective
Ste s That Have Been Taken and Results Achieved Hydrogen test gas bottles which were filled by the local vendor were removed from service, quarantined, and subsequently
returned to the vendor.Hydrogen monitoring
system surveillance
tests were performed on the hydrogen analyzers which had been tested using test gas bottles filled by the local vendor using test gas bottles filled by Air Products and Chemical.The tests required no adjustments
to hydrogen analyzers, thus validating
the tests performed using test gas bottles filled by H the local vendor.Air Products and Chemical has been accepted by APS as capable of providing test gases of the required'quality
and placed on the Commercial
Grade Approved Vendor's List.A quality related purchase order has been issued to Air Products and Chemical to establish a new stock level of test gases.The procurement/warehouse
tracking (class and item)numbers for test gas have been input into the Materials Management
Information
System and Station Information
Management
System for inclusion in corrective
maintenance
and surveillance
test work order packages associated
with'hydrogen
analyzers.
Page 10 of 11
r-
Corrective
S e s That Will Be Taken To Avoid Further Violations
The corrective
actions discussed above are considered
adequate to avoid further violations
and no additional
corrective
actions are planned.Date When Full Com liance Will Be Achieve Full compliance
was achieved on February 14, 1992, upon replacement
of the identified
test gas bottles which had been filled by the local vendor with test gas bottles filled by Air Products and Chemical.Page 11 of,11