ML17306A478
| ML17306A478 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/14/1992 |
| From: | CONWAY W F ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02113-WFC-T, 102-2113-WFC-T, NUDOCS 9202250367 | |
| Download: ML17306A478 (28) | |
See also: IR 05000528/1991044
Text
WILLIAM F.CONWAY EXECU14IEVICEPRESIOENT
NUCLEAR<~~~~liL L I.i 0 0~i'd%F,'r Gl0:I V Arizona Public Service Company P.O.BOX 53999~PHOENIX.ARIZONA 85072-3999
I".-7l FE9 L 0 E 102-02113-WFC/TRB/JRB
February 14;-1992 U.S.Nuclear Regulatory
Commission
Attention:
Document Control Desk Mail Station: P1-37 Washington, DC 20555 Reference:
Letter dated January 16, 1992, from D.F.Kirsch, Chief, Reactor Safety Branch, NRC, to W.F.Conway, Executive Vice President, Nuclear, APS.Gentlemen:
SUBJECT: PALO VERDE NUCLEAR GENERATING
STATION (PVNGS)UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION 50-528/91-44-01
File:.92-070-026
Arizona Public Service Company (APS)has reviewed NRC Inspection
Report 50-528, 529, 530/91-44 and the Notice of Violation dated January 16, 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 Violation.
APS'esponse
is provided in Attachment
1.Should you have any questions regarding this response, please contact me.Very truly yours, WFC/TRB/JRB/nk
Attachments
1.Appendix A-Restatement
of Notice of Violation 2.Attachment
1-Reply to Notice of Violation cc: J.B.Martin D.H.Coe
~,I l F I II i
APPENDIX A RESTATEMENT
OF NOTICE OF VIOLATION 50-528/91-44-01
NRC INSPECTION
CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 INSPECTION
REPORT NOS.50-528, 529, 530/91-44
RESTATEMENT
OF NOTICE OF VIOLATION 50-528 91-44-01 During an NRC inspection
during the weeks of November 4, 18, and December 2, 1991, one violation of NRC requirements
was identified.
In accordance
with the"General Statement of Policy and procedures
for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below: 10 CFR Part 50.Appendix B, Criterion V,"Instructions, Procedures, and Drawings," states in part: "Activities
affecting quality shall be prescribed
by documented
instructions, procedures, or drawings,...
and shall be accomplished
in accordance
with these instructions, procedures, or drawings...." o Palo Verde Nuclear Administrative
and Technical Manual procedure 30 DP-9MPO<, Conduct of Maintenance, Section 3.5.13 states in part,"Personnel
doing maintenance
shall not alter, change or modify plant equipment,,..." Limitorque
Vendor Technical Document Number VTD-L200-0025, states in part,"Li'mitorque
uses commercial
grade 5 or better hardware on all operators.
All external hardware is cadmium plated for corrosion resistance." Contrary to the above, on November 19, 1991, Unit 3 valve 3JSIA-HV-306 limit switch cover plate had two bolts installed, which were not grade 5 or better nor cadmium plated.A o Palo Verde Nuclear Administrative
and Technical Manual.procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part,"Plant equipment shall be restored to proper.design configuration
including all fasteners in place,...." Contrary to the above, Unit 1 valve 1JCHB-HV-255;
Unit 2 valves 2JSGA-UV-0138
and 2JCHE-HV-0536, and Unit 3 valve 3JSIA-UY-617
were missing fasteners on the limit switch cover plates.This'is a Severity Level IV Violation (Supplement
I)Page 1 of 1
k j f
ATTACHMENT
1 REPLY TO NOTICE OF VIOLATION 50-528/91-44-01
NRC INSPECTION
CONDUCTED NOVEMBER 4, 1991-DECEMBER 6)1991 INSPECTION
REPORT NOS.50-528, 529, 530/91-44
REPLY TO NOTICE OF VIOLATION 50-528 91-44-01 Reason for the Violation The reason for the violation was",personnelwrror<by
maintenance
personnel in restoring certain motor operated valve limit switch covers to proper design configuration
following maintenance
activities.
Specifically, one example of two bolts of questionable
material installed in a motor operated valve limit switch cover plate and four examples of a missing fastener on limit switch cover plates on four motor operated valves were identified.
<Corrective
Ste s'That Have Been Taken and the Results Achieved Material<nonconformance
reports were initiated upon identification
of the four missing bolts from the four limit switch covers.The missing fastener in each limit switch cover has been replaced.An engineering
evaluation
request*'was
initiated to document, the bolting being of~indeterminate
origin and material and to evaluate the installation
of these bolts for impact on valve operability.
This engineering
evaluation
determined
that the installation
of these bolts in this application
has no effect on operability
of the motor operated valve.Limit switch covers are installed on the limit switch compartments
of Limitorque
operators for Pageos of 3
0I
cleanliness, personnel safety, and to protect the limit switches from damage.The design incorporates
several bolts with a gasket between the limit switch cover and the limit switch compartment.
The equipment qualification
report for Limitorque
operators states,'n part, that Limitorque
actuators for nuclear plant application
are designed to permit them to survive normal and accident conditions
without depending on absolute sealing and that the seals are of no importance
for qualification, The questionable
bolts in the limit switch cover have been replaced.A condition report/disposition
request was initiated to determine the root cause of failure for improperly
restoring motor operator valves'imit
switch covers.Previously
completed work orders on the subject valve operators were<eviewedsto
determine if any e missing or questionable
bolting on the limit switch covers had been documented.>
No missing or questionable
bolting had been documented.
Consequently, the investigation
concluded the root cause to be personnel error.+Maintenance
personnel who perform work on motor operated valves were briefed.on the identified
conditions, and the importance
of proper restoration
of motor operated valves was stressed.mLo mo 1<6.)'s Page 2 of 3
J'
~y~.Corrective
Ste s That Will Be Taken To Avoid Further Violations
Based on similar problems recently identified
by APS and NRC, APS will conduct an investigation
of equipment hardware configuration
to determine if there are additional
~useqpf Lese issues.This investigation
is expected to be completed by April 13, 1992, and subsequent
corrective
actions will be implemented
through the APS Incident Investigation
Program.Work orders have been initiated in Units 1, 2, and 3 tomalk down accessible
safety related motor operated.valve operators to verify covers and fasteners are properly installed.
Missing or questionable
fasteners will be documented
and corrected.
Date When Full Com liance Will be Achieved APS achieved full compliance
on February 7, 1992, upon installation
of the proper fasteners in'the motor operated valves'imit
switch covers identified
above.Page 3 of 3
~~I l l l
ACCELERATED
DISTRIBUTION
DEMONSTPWTION
SYSTEM REGULATORY'NFORMATION
DISTRIBUTION
SYSTEM (RIDS)ACCESSION NBR:9202250367
DOC.DATE: 92/02/14 NOTARIZED:
NO DOCKET FACIL:STN-50-528
Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 AUTH.NAME AUTHOR AFFILIATION
ONWAY,W.F.
.Arizona Public Service Co.(formerly Arizona Nuclear Power RECIP.NAME
RECIPIENT AFFILIATION
Document Control Branch (Document Control Desk)SUBJECT: Responds to NRC 920116 ltr re violations
noted in insp rept 50-528/91-44
from 911104 to 911206.Corrective
actions:proper
fasteners installed in motor valves'imit
switch covers as identified
as of 920207.DISTRIBUTION
CODE: IEOID COPIES RECEIVED:LTR
L ENCL I SIKE: TITLE: General (50 Dkt)-Insp Rept/Notice
of Violation Response NOTES:STANDARDIZED
PLANT 05000528 RECIPIENT ID CODE/NAME PD5 PD THOMPSON,M
INTERNAL: ACRS AEOD/DEIIB
DEDRO NRR MORISSEAUSD
NRR/DLPQ/LPEB10
NRR/DREP/PEPB9H
NRR/PMAS/ILRB12
OE DIR REGS-E EXTERNAL EG&G/BRYCEg
J~H NSIC NOTES:~O 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 1 RECIPIENT ID CODE/NAME TRAMMELL,C
AEOD AEOD/DSP/TPAB
NRR HARBUCK,C.
NRR/DLPQ/LHFBPT
NRR/DOEA/OEAB
NRR/DST/DIR
8E2 NUDOCS-ABSTRACT
OGC/HDSl RGN5 FILE 01 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 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE%ASIA CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION
LISIS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26
WILLIAM F.CONWAY EXECUTIVEVICEPRESIDENT
NUCLEAR Arizona Public Service Company P.O.BOX 53999~PHOENIX.ARIZONA 85072-3999
102-02113-WFC/TRB/JRB
February 14, 1992 U.S.Nuclear Regulatory
Commission
Attention:
Document Control Desk Mail Station: P1-37 Washington, DC 20555 Reference:
Letter dated January 16, 1992, from D.F.Kirsch, Chief, Reactor Safety Branch, NRC, to W.F.Conway, Executive Vice President, Nuclear, APS.Gentlemen:
SUBJECT: PALO VERDE NUCLEAR GENERATING
STATION (PVNGS)UNITS 1, 2 AND 3 REPLY TO NOTICE OF VIOLATION 50-528/91~%1
File: 92-070-026
Arizona Public Service Company (APS)has reviewed NRC Inspection
Report 50-528, 529, 530/91-44 and the Notice of Violation dated January 16, 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 Violation.
APS'esponse
is provided in Attachment
1.Should you have any questions regarding this response, please contact me.Very truly yours, WFC/TRB/JRB/nk
Attachments
Appendix A-Restatement
of Notice of Violation 2.Attachment
1-Reply to Notice of Violation cc: J.B.Martin D.H.Coe 9202250367
9202i4 PDR ADOCK 05000528 8 PDR
tI l I
APPENDIX A RESTATEMENT
OF NOTICE OF VIOLATION 50-528/91%4-01
NRC INSPECTION
CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 0 INSPECTION
REPORT NOS.50-528, 529, 530/91%4
1
RESTATEMENT
OF NOTICE OF VIOLATION 50-528 91%4-01 During an NRC inspection
during the weeks of November 4, 18, and December 2, 1991, one violation of NRC requirements
was identified.
In accordance
with the"General Statement of Policy and procedures
for NRC Enforcement
Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below: 10 CFR Part 50.Appendix B, Criterion V,"Instructions, Procedures, and Drawings," states in part: "Activities
affecting quality shall be prescribed
by documented
instructions, procedures, or drawings,...
and shall be accomplished
in accordance
with these instructions, procedures, or drawings...." o Palo Verde Nuclear Administrative
and Technical Manual procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part,"Personnel
doing maintenance
shall not alter, change or modify plant equipment,...." Limitorque
Vendor Technical Document Number VTD-L200-0025, states in part,"Limitorque
uses commercial
grade 5 or better hardware on all operators.
All external hardware is cadmium plated for corrosion resistance." Contrary to the above, on November 19, 1991, Unit 3 valve 3JSIA-HV-306 limit switch cover plate had two bolts installed, which were not grade 5 or better nor cadmium plated.o Palo Verde Nuclear Administrative
and Technical Manual Procedure 30 DP-9MP01, Conduct of Maintenance, Section 3.5.13 states in part,"Plant equipment shall be restored to, proper design configuration
including all fasteners in place,...." Contrary to the above, Unit 1 valve 1JCHB-HV-255;
Unit 2 valves 2JSGA-UV-0138
and 2JCHE-HV-0536, and Unit 3 valve 3JSIA-UV-617
were missing fasteners on the limit switch cover plates.This is a Severity Level IV Violation (Supplement
I)Page1 of1
ATTACHMENT
1 REPLY TO NOTICE OF VIOLATION 50-528/91~01
NRC INSPECTION
CONDUCTED NOVEMBER 4, 1991-DECEMBER 6, 1991 INSPECTION
REPORT NOS.50-528, 529, 530/91~
I I t
REPLY TO NOTICE OF VIOLATION 50-528 91%441 Reason for h Vlolatl n The reason for the violation was personnel error by maintenance
personnel in restoring certain motor operated valve limit switch covers to proper design configuration
following maintenance
activities.
Specifically, one example of two bolts of questionable
material installed in a motor operated valve limit switch cover plate and four examples of a missing fastener on limit switch cover plates on four motor operated valves were identiTied.
Corrective
S e s Tha Have Been Taken and the Resul Achfeved Material nonconformance
reports were initiated upon identification
of the four missing bolts from the four limit switch covers.The missing fastener in each limit switch cover has been replaced.An engineering
evaluation
request was initiated to document the bolting being of indeterminate
origin and material and to evaluate the installation
of these bolts for impact on valve operability.
This engineering
evaluation
determined
that the installation
of these bolts in this application
has no effect on operability
of the motor operated valve.Limit switch covers are installed on the limit switch compartments
of Limitorque
operators for Pageos of 3
Vi t
cleanliness, personnel safety, and to protect the limit switches from damage.The design incorporates
several bolts with a gasket between the limit switch cover and the limit switch compartment.
The equipment qualification
report for Limitorque
operators states, in part, that Limitorque
actuators for nuclear plant application
are designed to permit them to survive normal and accident conditions
without depending on absolute sealing and that the seals are of no importance
for qualification.
The questionable
bolts in the limit switch cover have been replaced.A condition report/disposition
request was initiated to determine the root cause of failure for improperly
restoring motor operator valves'imit
switch covers.Previously
completed work orders on the subject valve operators were reviewed to determine if any~~missing or questionable
bolting on the limit switch covers had been documented.
No missing or questionable
bolting had been documented.
Consequently, the investigation
concluded the root cause to be personnel error.Maintenance
personnel who perform work on motor operated valves were briefed on the identified
conditions, and the importance
of proper restoration
of motor operated valves was stressed.Page 2 of 3
r 4
Corre lv s Tha Will Be Taken To Avoid Further Viola I ns Based on similar problems recently identified
by APS and NRC, APS will conduct an investigation
of equipment hardware configuration
to determine if there are additional
causes of these issues.This investigation
is expected to be completed by April 13, 1992, and subsequent
corrective
actions will be implemented
through the APS Incident Investigation
Program, Work orders have been initiated in Units 1, 2, and 3 to walk down accessible
safety related motor operated valve operators to verify covers and fasteners are properly installed.
Missing or questionable
fasteners will be documented
and corrected.
Da e When Full Com lienee Will be Achieved APS achieved full compliance
on February 7, 1992, upon installation
of the proper fasteners in the motor operated valves'imit
switch covers identified
above.Page 3 of 3