ML17303B044
| ML17303B044 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/13/1988 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17303B045 | List: |
| References | |
| EA-88-062, EA-88-62, NUDOCS 8804200108 | |
| Download: ML17303B044 (6) | |
Text
A,CCZLERATED DISTRIBUTION DEMONSTRATION SYSTEM I
S
't REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
CCESSION NBR:8804200108 DOC.DATE: 88/04/13 NOTARIZED:
NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo.Verde Nuclear Station, Unit 2, Arizona Publi 05000529 AUTH.NAME AUTHOR AFFILIATION MARTIN,J.B.
Region 5, Ofc of the Director RECIP.NAME RECIPIENT AFFILIATION VAN BRUNT,E.E.
Arizona Nuclear Power Project (formerly Arizona Public Serv
SUBJECT:
Discusses insps on 880127-29
& 0117-0305
& forwards notice of violation
& proposed imposition of civil penalty.
DISTRIBUTION,CODE:
IE14D COPIES RECEIVED:LTRj ENCL /
SIZE: 6 ~ 7 TITLE: Enforcement Action Non-2.790-Licensee
Response
NOTES:Standardized plant.
Standardized plant.
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1 INTERNAL: AEOD/DOA DEDRO NRR/DREP/EPB 10 RGN2/DRSS/EPRPB XTERNAL: LPDR NSIC NOTES 1
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k**yq'NITED STATES NUCLEAR REGULATORY COIVIMISSION REGION V 1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 Docket Nos.
50"528 and 50-529 License Nos.
NPF-41 and NPF-51 EA 88-62 APR I 3 lgp~
Arizona Nuclear Power Project ATTN:
Mr.
E.
E.
Van Brunt, Jr.
Executive Vice President Post Office Box 52034
- Phoenix, Arizona 85072-2034 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORT NOS.
50-528/88"02, 50"528/88-07, 50-529/88-02, AND 50-529/88-'07)
This letter refers to (1) a special inspection conducted on January 27-29,
- 1988, and (2) the resident inspector inspection conducted on January 17 through March 5, 1988, at the Palo Verde Nuclear Generating Station.
Several apparent violations of NRC requirements were identified by these inspections.
With the exception of the event involving the High Pressure Safety Injection (HPSI) pump at Unit 1, the apparent violations were discussed with you during the Enforcement Conference/Management Meeting held on February 29, 1988.
The violations of NRC requirements in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties involve:
inoperability of the steam driven auxiliary feedwater pumps in both Units 1 and 2 while operability was required by the technical specifications; inadequate technical review of a modification affecting the automatic initiation capability of the auxiliary feedwater pumps; incomplete testing of the auxiliary feedwater system following modification work; quality control instructions lacking appropriate acceptance criteria; inoperability of an auxiliary feedwater pump at Unit 2, due to the pump discharge valve being incorrectly positioned; entry into plant operational mode 4 at Unit 1 without meeting the technical specification requirement for an operable HPSI pump; and the occurrence of an inadvertent safety injection at Unit 2 due to a failure to follow the applicable procedure.
Several of these viol'ations were identified by you, as reported in Licensee Event Reports 50-528/87-025, 50-529/88-04, 50-529/88-05, and 50-528/88-04.
The focus of the special inspection was to review the circumstances which led to the extended inoperability of the safety related steam driven auxiliary feedwater pumps at Units 1 and 2 with the units operating at power.
Based on this review, we have concluded that the initiating error of this event was the assignment of work to an engineer who was unqualified to perform the electrical engineering evaluation involved in the task, and the failure of the engineer and his supervisors to recognize that the involvement of other engineering disciplines was required to adequately address the work.
In addition, the Engineering Evaluation Request (EER) process, under which the CERTIFIED MAIL r
/
RETURN RECEIPT RE VESTED i'804200108 8804i3 PDR ADOCK 05000528 9
work was done was an inappropriate mechanism with which to do the technical work involved in that your EER program does not require the detailed reviews normally associated with engineering work being done to modify safety related systems.
In our most recent SALP evaluation of Palo Verde, we were concerned with a number of examples of weak or untimely engineering work, and with your failure to develop and manage your System Engineer program to the extent we expected.
The pump inoperability problem has heightened our concerns'ith regard to the modification to the auxiliary feedwater
- systems, even though your programs require many of your work groups to perform reviews,
- checks, and tests of the work performed, none uncovered the error which led to the inoperability of the pumps.
Although the undetected loss of operability of the steam driven auxiliary feedwater pumps is unacceptable, our major concerns with the event are the poor management and execution of the technical work and that the personnel who fulfilled the checking and testing requirements failed to identify the engineering error which caused the event.
In view of our discussions of the past several years on the importance of performing quality technical work, and of the assurances we have received from top level ANPP managers that the quality of technical work was being given priority attention, we find the performance of your system engineering group and others associated with this matter to be particularly disappointing.
Our concern is increased by our impression that several of your employees who were involved in the event apparently did not clearly understand the importance of their responsibilities to thoroughly check the work.
The three violations set forth in section II of the enclosed Notice (Violations IIA thru C) involve less than expected operator performance.
These violations are similar to the violations in section I (IA thru 0) in that your programs created opportunities for your staff to prevent the violations, but in each case those opportunities were'issed.
Individually the safety significance of each of these three violations was fortuitously low.
- However, when viewed collectively, the violations are indicative of a significant problem resulting in poor operator performance, and are consistent with our recent observations of a divergence between your management expectations and the performance of your operations staff.
- Further, as indicated by Violation II.C, we are concerned that your operations personnel do not fully understand the meaning and importance of initialing or signing procedural steps.
During both our review and your own review of these
- events, a number of obvious deficiencies were identified. It is our perception that although these deficiencies have existed for some time, you had not previously recognized them.
Additionally, during my tour of Palo Verde in January,
- 1988, it was clear to me that a number of problems existed with regard to plant operation, and I expressed those concerns at that time to senior ANPP management.
We conclude that your senior management staff is. not taking appropriate action to ensure prompt attention when indicators point to a trend of personnel deviating from fundamental principles.
We believe that the weakness is due, in par t, to fai lure of your managers to personally devote significant time to direct observation of plant activities, and failure of your guality Assurance and plant oversight committees to identify and address early signs of
developing problem areas.
Me encourage you to increase management attention in the area of personnel performance to ensure a 'clear understanding by your personnel of the fundamental principles involved with the operation of a nuclear power plant, such as the importance of checking work and the need for attention to detail by all personnel, and in particular, by operations personnel.
To ensure your awareness of our insistence on the proper performance of engineering activities and careful checks of technical
- work, a civil penalty for the violations contained in section I of the Notice of Violation is proposed.
To emphasize the importance of minimizing operator
- errors, and to highlight our expectation that ANPP management must quickly identify and address
- problems, a separate civil penalty is proposed for the violations contained in section II of the Notice of Violation.
In summary, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of One Hundred Thousand Dollars ($100,000) for the violations described in the enclosed Notice.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987)
(Enforcement Policy), the violations described in the enclosed Notice have been categorized as two Severity Level III problems.
The base value of the civil penalty for a Severity Level III violation is
$50,000.
The escalation and mitigation factors in the Enforcement Policy were considered and it is our conclusion that neither mitigation nor escalation is warranted in either case.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your
- response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviewing your response to this Notice, including your proposed corrective actions and the re'suits of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC's "Rules of Practice,"
Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L.
No.96-51l.
Sine
- ely,
~
~
~
John B. Martin Regional Administrator
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalties
cc w/enclosure:
J.
G.
- Haynes, Vice President, Nuclear Production, ANPP W.
F. quinn, Director, Nuclear Safety and Licensing, ANPP L.
G.
Papworth, Director, equality Assurance, ANPP T.
D. Shriver, Compliance
- Manager, ANPP J.
- Morrison, PVIF L. Bernabei, GAP T.
- Hogan, ACC A.
C. Gehr, Snell 8 Wilmer