ML17303B046
| ML17303B046 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/13/1988 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17303B045 | List: |
| References | |
| EA-88-062, EA-88-62, NUDOCS 8804200112 | |
| Download: ML17303B046 (6) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Arizona Public Service Company Palo Verde Nuclear Generating Station Docket Nos.
50-528 and 50-529 License Nos.
NPF-41 and NPF-51 EA 88-62 During NRC inspections conducted on January 27"29,
- 1988, and January 17 thru March 5, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the Nuclear Regulatory Commission proposes to impose two civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U. S. C.
- 2282, and 10 CFR 2. 205.
The particular violations and associated civil penalties are set forth below:
I.A. Technical Specification 3.7. 1.2, applicable to both Units 1 and 2, requires that at least three independent steam generator auxiliary feedwater pumps shall be operable in modes 1,
2 and 3; in mode 4 the pumps shall be operable until the steam generators are no longer required for heat removal.
The action statement of technical specification 3.7. 1.2 further requires that with one auxiliary feedwater pump inoperable, the inoperable pump shall be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit shall be placed in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Contrary to the above, both Units 1 and 2 operated with only two operable independent steam generator auxiliary feedwater pumps without meeting the technical specification action requirements in that:
1.
'With the turbine driven auxiliary feedwater pump inoperable, Unit 1 operated in modes 1, 2, 3, and 4 from September 23, 1987 until October 5, 1987.
2.
With the turbine driven auxiliary feedwater pump inoperable, Unit 2 operated in mode 1 from October 14, 1987 until November 29, 1987.
B.
Technical S ecification 6.5.2.3 re uires in art that ro osed p
q P
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modifications to the unit's nuclear safety-related systems and components be reviewed by an individual/group other than the individual/group which designed the modification, and that the modification be approved by the Plant Manager or by the Manager Technical Support prior to implementation.
Contrary to the above, during September, October and November,
- 1987, the turbine driven auxiliary feedwater pump steam supply isolation valves (SGAUV0134 and SGAUV0138) at both Units 1 and 2 were modified without the modification being reviewed by an individual/group other than the individaul/group which designed the modification, and without prior approval by the Plant Manager or the Manager Technical Support.
8804200ii2 8804i3 PDR ADOCK 0 000528 9
C.
10 CFR Part 50, Appendix B, Criterion XI, Test Control, as implemented by the licensee's guality Assurance Manual, Criterion 11 and the Palo Verde Final Safety Analysis Report, Section 17.2. 11, requires in part that the licensee's test program assure that required testing be identified and performed to demonstrate that systems will perform satisfactorily in service following modifications.
Contrary to the above, testing in September, October and November
- 1987, of the auxiliary feedwater systems for both Units 1 and 2, following modifications made to the turbine driven pump steam supply isolation valves (SGAUV0134 and SGAUV0138), did not include an integrated test of the pumps and their associated steam supply isolation valves.
D.
10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires in part that instructions and procedures shall include appropriate quantitative acceptance criteria to assure the satisfactory accomplishment of important activities.
Contrary to the above, the instructions contained in the work orders for adjusting the limit switches in the turbine driven auxiliary feedwater pump steam supply isolation valves (SGAUV0134 and SGAUV0138) during September,
- October, and November,
- 1987, on both Units 1 and 2, did not contain appropriate quantitative acceptance criteria for verifying the settings of the limit switches.
Collectively, Violations IA thru D have been classified as a Severity Level III problem.
(Supplement I)
Cumulative Civil Penalty - $50,000 - assessed equally among the violations.
II.A.Technical Specification 3.5.3 provides that when the unit is in mode 4, there shall be operable a minimum of one Emergency Core Cooling System (ECCS) subsystem comprised of a High Pressure Safety Injection (HPSI) pump and flow path.
Technical Specification 3.0.4 requires that the conditions of Limiting Conditions of Operation be met without reliance on the provisions contained in the action requirements when entering into an operational mode.
Contrary to the above, on February 29, 1988, Unit 1 entered mode 4 and operated for approximately one hour and twenty-five minutes without an operable HPSI pump.
B.
Technical Specification 3. 7. 1. 2, requires that at least three independent steam generator auxiliary feedwater pumps shall be operable in modes 1,
2 and 3; in mode 4 the pumps shall be operable until the steam generators are no longer required for heat removal.
The action statement of technical specification 3.7. 1.2 further requires that with one auxiliary feedwater pump inoperable, the inoperable pump shall be restored to an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the unit shall be placed in hot standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
, Contrary to the above, Unit 2 operated in modes 1,
2 and 3 from February 8 to February 20, 1988, with less than three independent steam generator auxiliary feedwater pumps operable due to the discharge valve on pump AFN-POl being closed.
C.
Technical Specification 6.8. 1 states, in part, that the licensee shall establish, maintain and implement written procedures covering activities referenced in Appendix A of Regulatory Guide 1.33, Revision 2 (February 1978).
Regulatory Guide 1.33, Revision 2, Appendix A, Section 2j, refers to a procedure for changing plant modes from Hot Standby to Cold Shutdown.
Procedure 420P-2ZZ10, Revision 2, "Hot Standby to Cold Shutdown Mode 3 to Mode 5", step 4.3. 114.2, requires that the licensee bypass all four channels of pressurizer low pressure protection when the reactor coolant system temperature drops below 200 degrees F and that the step be initialed when completed.
10 CFR 50.9(a) requires, in part, that information required to be maintained by licensees be complete and accurate.in all respects.
Contrary to the above, on February 21, 1988, with the Unit 2 reactor coolant system temperature below 200 degrees F, only one of the four channels of pressurizer low pressure protection was bypassed, and step 4.3. 114.2 was i'nitialed as having been completed.
Collectively, Violations IIA thru C have been classified as a Severity Level III problem.
(Supplement I)
Cumulative Civil Penalty - $50,000 - assessed equally among the violations.
Pursuant to the provisions, of 10 CFR 2.201, the Arizona Public Service Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, within 30 days of the date of this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include, for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, (3) the corrective steps that have been taken and the results
- achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) 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 be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C.
2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above unde~
10 CFR 2.201, the Licensee may pay the civil penalties by letter to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, with a check,
- draft, or money order payable to the Treasurer of the United States in the cumulative amount of the civil penalties proposed above or may protest imposition of the civi 1 penalties in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civi 1 penalty will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2. 205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may:
(1) deny the violation listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed.
Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2. 201 reply by specific refer ence (e. g.,
citing page and paragraph numbers) to avoid repetition.
The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected.by civil action pursuant to Section 234c of the Act, 42 U.S.C.
2282c.
The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region V, 1450 Maria Lane, Suite 210, Walnut Creek, California, and a copy to Timothy Polich, Senior Resident Inspector, at the Palo Verde Nuclear Generating Station.
FOR THE NUCLEAR REGULATORY COMMISSION John B. Martin Regional Administrator Dated at Walnut Creek, California this
/g day of April 1988
DISTRIBUTION:
PDR LPDR SECY CA J. Taylor, DEDRO Resident Inspector Project Inspector D. Persinko, NRR G.
- Cook, RV B. Faulkenberry, RV J. Martin, RV J.
Lieberman, OE J.
- Hayes, OI S.
Connel ly, OIA F.
Ingr am, PA E. Jordan, AEOD EA File ES File OCS Docket file bcc w/o enclosure:
LFMB M. Smith OE JLuehman 4/
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'OGC LChandler 4/
/88 0:OE JLieberman 4/
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/88 REQUEST COPY ] REQUEST COPY ] REQUEST COPY ] REQUEST COPY ] REQUEST COPY ]
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