ML17303B030
| ML17303B030 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/30/1988 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303B029 | List: |
| References | |
| 50-528-88-01, 50-528-88-1, NUDOCS 8804190112 | |
| Download: ML17303B030 (6) | |
Text
APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Palo Verde Nuclear Generating Station Docket No. 50-528 License No.
NPF-41 As a result of the inspection conducted during the period of January 4 through February 12,
- 1988, and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C (1987), the following violations were identified:
A.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions, procedures, or drawings.
1.
American Air Filter Company Drawing No.
MC-134-942G, Revision G,
showed access doors installed on the air handling unit for the motor driven. auxiliary feedwater pump room.
Contrary to the above, on January 7, 1988, an access door was missing for the motor driven auxiliary feedwater pump room air handling unit.
2.
Elgar Corporation Drawing No. 543-201-4, Revision A, showed the vital static inverters with 19 thumb screws installed on the front of the inverter assembly.
Contrary to the above, on January 27, 1988, vital static inverter 1-E-PND-N14 had 9 of the 19 thumb screws missing and on February 10, 1988, vital static inverter 1-E-PKD-N44 had 12 of the 19 thumb screws missing.
3.
Bechtel Drawing No. 13-10407, Revision 2, and Drawing E050-86 depicted the use of plastic spacers between selected battery jars.
Contrary to the above, on January 27, 1988, two spacers were missing from vital battery "A," two spacers were missing from vital battery "D," and three spacers were missing from vital battery "B."
4.
Bechtel calculation isometric Drawing 13-MC-DS-511 provided the main header configuration (up to the work point) for the emergency eyewash stations in the vital battery rooms.
Contrary to the above, on February 6, 1987, the eyewash stations in the vital battery rooms were installed without revising the calculation 'isometric drawing and the existing configuration was not analyzed for its ability to meet seismic category 9 requirements.
This is a Severity Level IV Violation (Supplement 1).
8804190ii2 880330 VDR ADOCK 05000528 9
"2-B.
10.
CFR 50.59 requires holders of a license authorizing operation of a utilization facility that makes change in the facility as described in the safety analysis report to maintain records of changes in the facility.
These records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, TMR No. 1-85-CI-377, Revision 0, dated September 27, 1985, a temporary modification that installed tanks to supply hypochlorite for the emergency spray ponds, was completed with an unacceptable written safety evaluation.
The evaluation did not consider the consequences of a seismic event.
'I This is a Severity Level IV Violation (Supplement 1).
C.
10 CFR 50.55a requires pressurized water-cooled nuclear power reactors to meet the requirements of ASME Boiler and Pressure Vessel Codes.
The Palo Verde Nuclear Generating Station FSAR, Section Three, Table 3.2-1, Item 10, identifies ASME, Boiler and Pressure Vessel Code Section III as the principal Construction Code(s) and Standard(s) for the essential cooling'water and chilled water systems.
Section III of the ASME Boiler and Pressure Vessel Code, Article ND-7412, requires pressure relief valve capacity to include consideration of a fully open pressure reducing device.
Contrary to the above, the licensee had not considered or made calculations to demonstrate that the relief valves provided for the essential chilled water and essential cooling water surge tanks are sized to accommodate flows resulting from the failure of the upstream regulating valves in the fully open position.
This is a Severity Level IV Violation (Supplement 1):
Pursuant to the provisions of 10 CFR 2.201, Arizona Nuclear Power Project is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the 'Regional Administrator, Region V, and a copy to the NRC Resident Inspector, Palo Verde, within 30 days of the date of.the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each'"violation:
(1) the reason for the violation if admitted, (2) the corrective steps which have been taken and the results
- achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an Order may be issued to show cause why the license should not
e "3-be modified, suspended, or revoked or'hy such other actions as may be proper should not be taken.
Consideration may 'be given to extending the response time for good cause shown.
FOR HE NUCLEAR REGULATORY COMMISSION J.
B. Martin Regional Administrator Dated at Walnut Creek, California this 30th day of Harch 1988
APPENDIX 8 Summar of Si nificant Findin s
1.
Desi n Basis Documents "A.
A significant number of design calculations could not be recovered from the records.
There were no calculations for the following listed equipment/designs:
(1)
Sizing the relief valves for surge tanks in the essential chilled and cooling water systems (violation).
(2)
The design pressures and temperatures for the three systems reviewed (unresolved item).
(3) gualifying calculations for SSE electrical cable supports located in vertical cable tray runs (unresolved item).
(4)
Sizing the battery room HVAC system to maintain the 60 F design ambient temperature during a loss of offsite power.
B.
Several inaccurate design calculations/assumptions were found,
- however, none resulted in system functional problems.
The following list'dentifies a few examples:
(1)
Two examples where ANPP changes in diesel generator loading calculations failed to take into account or correct inaccuracies in the earlier calculations.
(2)
Non-conservative assumptions in battery sizing calculations which resulted in a reduction in battery design margin by two-thirds.
(3)
Sizing the surge tank for the essential cooling water system assumed half the size of the Rancho Seco tank.
(4)
Heat exchanger (HX) performance calculations did not adequately evaluate the effects of a clean HX on overall system performance.
(5)
Unverifi.ed and undocumented assumptions were used in chiller sizing calculations.
2.
Plant Im lementation and Maintenance of Desi n Basis A.
Inadequacies were noted in procedures and training for operation of the crosstie between the essential cooling water (safety) system and the nuclear cooling water (non-safety) system.
B.
The 50.59 review by site engineers of the temporary modifications on the essential spray pond hypochlorite supply tank was inadequate insofar as it did not perform a seismic analysis (violation).
C.
An inspection access panel for a safety-related air handling unit was not in place (violation).
D.
The emergency lighting batteries were not properly maintained and were found in a degraded condition.
E.
Several electrical enclosure panels/doors were observed to not contain all of the closure bolts, which could impact the enclosure ability to withstand a sei,smic event and certainly is evidence of poor maintenance/operations work practices (violation).
F.
Alignment spacers were missing from safety related battery banks (violation).
G.
Safety-related heat exchanger performance characteristics were not formally trended or evaluated to assure continued function and maintenance of the assumptions in the design basis.
H.
A potentially unacceptable 50.59 review of a change to the oil operating temperature's effect on chiller operating reliability (unresolved item).-
I'esign Document Discrepancies (1)
There were inaccuracies between design basis documents and P8 IDs with regard to essential chilled water throttle valve positions.
(2)
There were inaccuracies between P8IDs and alignment procedures with regard to positions of essential cooling water system surge tank isolation valves.
(3)
The auxiliary operator's log sheets required verification of the essential chiller oil temperature at different values than those.recommended by the vendor.
J.
- Past actions taken to correct recurring M8TE deficiencies have been inadequate (unresolved item).
3.
Related to Desi n Basis En ineerin Work A.
The findings as they relate to the knowledge and responsibilities of the corporate staff are as follows:
(j.)
The engineering staff's review of calculations during the Technology Transfer Program did not identify missing calculations (unresolved item).
(2)
The engineering staff did not identify inadequate design basis documents or calculations.
(3)
The engineering staff did not appear to have a clear understanding of what was necessary to adequately document the design basis.
Engineering Staff at the Plant Site (1)
Responsibilities were identified and assigned but were not being accomplished, e.g., trending of system performance.
(2)
Training was ill-defined and did not assure a proper knowledge of the design basis.
- Further, system engineers and plant personnel evidently failed to identify or followup on obvious departures from original as-built conditions (e.g.,
missing battery spacers and missing electrical cabinet cover fasteners).