IR 05000528/1997016
| ML17313A173 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/12/1998 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17313A174 | List: |
| References | |
| 50-528-97-16, 50-529-97-16, 50-530-97-16, EA-98-013, EA-98-13, NUDOCS 9801150085 | |
| Download: ML17313A173 (14) | |
Text
UA.TE(9UKY REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
SUBJECT:
Ack receipt of 971126 ltr,responding to 971029 ltr 6 notice of violation re shutdown cooling flow Unit 2 identified in insp repts 50-528/97-16,50-529/97-16
& 50-530/97-16.Revised notice of violation encl,no response from utility required.
DISTRIBUTION CODE:
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response G
05000528 0500052@
05000530R NOTES: STANDARDIZED PLANT Standardized plant.
Standardized plant.
ACCESSION NBR:9801150085 DOC.DATE: 98/Ol/12 NOTARIZED: NO DOCKET ACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION DYER,J.E.
Region 4 (Post 820201)
RECIP.NAME RECIPIENT AFFILIATION LEVINE,J.M.
Arizona Public Service Co.
(formerly Arizona Nuclear Power C
RECIPIENT ID CODE/NAME PD4-2 PD INTERNAL: ACRS FILE CE PM/PECB NUDOCS-ABSTRACT OGC/HDS2 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL
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1 RECIPIENT ID CODE/NAME CLIFFORD,J AEOD/SPD/RAB DEDRO NRR/DRCH/HHFB NRR/DRPM/PERB OE DIR RGN4 FILE
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SUBJECT:
NRC INSPECTION REPORT 50-528/97-16; 50-529/97-16; 50-530/97-16
Dear Mr. Levine:
Thank you for your letter of November 26, 1997, responding to our October 29 letter and Notice of Violation concerning the shutdown cooling flow in Unit 2 being less than the 3780 gallons per minute (gpm) required by the Palo Verde Technical Specifications.
We found within your response all of the information required by the regulations.
Your response acknowledged that shutdown cooling flowthrough the core was approximately 400 gpm less than the 3780 gpm requirement specified by the LimitingCondition for Operation.
However, you stated that compliance with the Palo Verde Technical Specifications for Mode 5 shutdown cooling flowwas maintained throughout this event, since corrective actions were initiated and adequate flowwas re-established within the allowed outage time of the Action Statement.
Based upon this contention, and as was communicated to you in a subsequent telephone conversation between Ms. A. Krainik, of your staff, and Mr. K. Brockman, Deputy Director, Division of Reactor Projects, your response has been reviewed in accordance with our procedures for a denied violation.
We do not agree with your assertion that you were in compliance with the Technical Specifications throughout this event., he specifications are clear in stating that when the reactor is in MODE 5, shutdown cooling flow shall be maintained greater than 3780 gpm. In this case, for approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, shutdown cooling flowthrough the reactor core was less than 3780 gpm and, therefore, compliance with the Technical Specifications was not met.
The Agency's enforcement guidance for a situation such as this is quite explicit.'..
there has also been a long-standing recognition ofthe need to.also consider potential enforcement based on the total duration that the condition may have existed (i.e., from the time of~cu~n~), where it can be easily determined, and the extent to which the licensee
~sh i~ have identified the condition earlier.
'nforcement Guidance Memorandum 97-013, "Compliance with Technical Specification Limiting Conditions for Operations and Action Statements," July 14, 1997.
980ii50085 980ii2 PDR ADOCK 05000528
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Arizona Public Service Company-2-In order to address the issue ofpotential enforcement fora pre-existing condition, itis necessary to make a clear distinction between compliance with the TS ACTION statement and compliance with the TS LCO....
In other words, the determination ofwhether an ACTIONstatement is metis based on when the condition is discovered.
Once discovered, the question is whether the actions to be completed are completed on time.
Therefore, while a licensee may be in compliance with the ACTIONstatement ofa TS based upon the discovery ofthe violation, a licensee may not bein compliance with the TS LCO based on when the violation occurred.
The followingshould be used forcases where the time ofoccurrence can be established and the licensee should have discovered the condition sooner.
1. Ifthe time between theZgguczg gag ofthe condition and the~m~vg ofthe condition is greater than the AOTforthat condition, then the licensee should be cited fora failure to satisfy the TS LCO. Ifthe licensee otherwise satisfied the TS required action(s) from the time of@m~gy ofthe condition, the citation and enforcement correspondence should acknowledge this....
In this case, Palo Verde had a known design condition which could result in flow being diverted from the shutdown cooling pathway.
It was for this reason that you added a procedural step to hold the handswitch forthe warm-up bypass valve closed for 5 seconds after receiving a closed indication. The operators did not properly perform this procedural step nor did they properly confirm that their intended action (to close the valve) was accomplished.
Even more importantly, however, the design condition which allowed this to occur had been present, and known, since construction.
This establishes conditions which, we believe, are sufficient to meet our decision criterion that
"the licensee should have discovered the condition sooner." And, given these facts, we cannot support the premise that the time between occurrence and the implementation of the corrective action was less than the allowed outage time. Nor can we support the premise that the allowed outage time should have been calculated based on the time of actual discovery (instead of the time of occurrence).
F kp i g h
th I ty~thi significant since the decay heat load at the time was low; however, we do not accept your assertion that this fact should result in a default decision that the event was of minor safety
'f~gce.
First, shutdown cooling flowwas less than that required by the Technical Specification; second, operators were not aware of or attentive to the condition. Finally, the operators should have known of this potential since you had previously instituted a procedural work-around to counteract the operational deficiency associated with the location of the flow transmitter.
This is not a minor issue, and we have determined that it is appropriate for the violation to be, cited.
I i
Arizona Public Service Company It should be noted that the original inspection report which communicated this issue
'ited a violation of Technical Specification 3/4.4.1.4.2, which is applicable when the reactor is in MODE 5 with the reactor coolant loops not filled. Instead, the citation should have been made against Technical Specification 3/4.4.1.4.1, which is applicable when the reactor is in MODE 5 and reactor coolant loops are filled. Additionally, while the original inspection report did acknowledge the fact that corrective actions were initiated immediately upon recognition of the non-compliance with the limiting condition of operation, the citation did not include such a recognition.
Therefore, to establish an appropriate regulatory posture and, as is specified in the previously referenced enforcement guidance, a revised Notice of Violation is attached.
No new information or additional response from Arizona Public Service Company is required.
The NRC has concluded that the information regarding the reason for the violation, the corrective actions taken, and the actions planned to correct the violation and to prevent recurrence are already adequately addressed on the docket in your letter dated November 26, 1997. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position.
In that case, or ifyou choose to provide additional information, you should followthe instructions specified in the enclosed Notice.
We willverify the implementation and effectiveness of your documented corrective actions during a future inspection.
Sincerely, JM m James
. Dyer Deputy Regional Administrator Docket Nos.: 50-528 50-529 50-530 License Nos.:
NPF-41 NPF-51 NPF-74 Enclosure: Notice of Violation CC:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007
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Arizona Public Service Company Douglas K. Porter, Senior Counsel Southern California Edison Company
'Law Department, Generation Resources P.O. Box 800 Rosemead, California 91770 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O. Box 52034 Phoenix, Arizona 85072-2034 John C. Horne, Vice President Power Supply El Paso Electric Company 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills EI Paso, Texas 79901 Mr. Robert Burt Los Angeles Department of Water 8 Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, ¹0604 Albuquerque, New Mexico 87102
W Arizona Public Service Company Mr. Brian Katz SoUthern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251
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Arizona Public Service Company JAN I 2 l998 bcc distrib. by RIV:
Regional Administrator DRP Director Branch Chief (DRP/F, WCFO)
Senior Project Inspector (DRP/F, WCFO)
Branch Chief (DRP/TSS)
WCFO File G. F. Sanborn, EO J. Lieberman, OE, MS: 7-HF OE:EA File, MS: 7-HF Resident Inspector DRS-PSB MIS System RIV File M. Hammond (PAO, WCFO)
DOCUMENT NAME: R:7 PNPV716AK.KEB To receive copy ofdocument, indicate In box: "C" = Copy without enciosures
"E" = Copy with enciosures "N"= No copy RIV:C:DRP/F EO DD:DRP DRA DFKirsch (DFK per telecon)"
GFSanborn" KEBrockmen" JEDyer rTry 1/8/98 1/9/98 1/8/98 01//498
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