ML17305A376
| ML17305A376 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/25/1989 |
| From: | Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305A375 | List: |
| References | |
| 50-528-89-36, 50-529-89-36, 50-530-89-36, NUDOCS 8911130105 | |
| Download: ML17305A376 (6) | |
Text
0 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Docket Numbers 50-528, 50-529, and 50-530 Palo Verde Units 1, 2, and 3
License Numbers NPF-41, NPF-51 and NPF-74 During an NRC inspection conducted on August 7 through September 10,
- 1989, four violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C (1989), the violations, are listed below:
A.
Technical Specification
- 6. 8. 1 states, in part: "Written procedures shall
.be established, implemented, and maintained covering... the recommendations in Appendix A of Regulatory Guide 1.33, Revision 2,
'ebruary, 1978..."
(RG 1.33)
RG 1.33 recommends administrative procedures for "Authorities and Responsibilities for Safe Operation and Shutdown".
RG 1.33 is implemented, in part, by ANPP Night Orders, which on May 25, 1989, in Unit 1 read, in part:
"When any evolution is planned, sufficient valves which encompass the desired flow path must be actually verified to ensure that the water flows only from/through/to the desired portions of the system."
This Night Order was written. as corrective action for a Spent Fuel Pool valve misalignment event which occurred at Unit 3 on May 22, 1989.
Contrary to the above, on August 2, 1989, in Unit 1 during a planned evolution, valve PCN-V004, which encompassed the desired flow path, was not verified shut, thereby causing an unintended flow path which resulted in lowering Spent Fuel Pool level to less than the Technical Specification minimum required level.
This is a Severity Level IV Violation applicable to Unit 1 (Supplement I).
2.
RG 1.33 recommends administrative procedures for "Authorities and Responsibilities for Safe Operation and Shutdown".
RG 1. 33 is implemented, in part, by ANPP procedure 40AC-90P02, "Conduct of Shift Operations",
Section 3.3.2.2. 1 which states, in part, "...
A step may be resequenced if it is independent of a step which is being delayed...".
891 1 l30i 05 9S'1025 PDR ADOCJ( 0500052S PNU
Contrary to the above, on August 19, 1989, in Unit 3, procedure 430P-3SI02 Step 6.3.6 was resequenced prior to Step 6.3.4, and was not independent of Step 6.3.4 in that it resulted in a temporary loss of control of Reactor Coolant System (RCS) level including spillage of RCS into the refueling cavity.
This is a Severity Level IV Violation applicable to Unit 3 (Supplement I).
B.
10 CFR Part 50, Appendix B, Criterion III, Design Control, states in part:
"Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in 50.2 and as specified in the licensee application, for those structures,
- systems, and components to which this appendix applies are correctly translated into specifications,
- drawings, procedures, and instructions."
Contrary to the above, licensee design calculation 13-MC-ZZ-704, sheet 7,
dated February 18, 1987, required that Emergency Diesel Generator (EDG)
Excess Flow Check Valve (XCV) isolation valves be kept normally closed.
On June 1,
- 1989, XCV isolation valves were open in all three units due to the licensee's failure to include the requirement in the applicable procedure.
This is a Severity Level IV Violation applicable to Units 1, 2, and 3
(Supplement I).
C.
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states in part:
"In the case of significant conditions adverse to quality, the (corrective) measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
Interim corrective action contained in Engineering Evaluation Report (EER) 86-XM-046, and dated July 27,
- 1989, regarding a discrepancy with the alignment of Emergency Diesel Generator (EDG) starting air valves, as cited in paragraph B above, required that EDG excess flow check valve (XCV) isolation valves be kept normally closed.
Contrary to the above, on September 6, 1989, the Unit 3 EDG XCV isolation
'valves were open on both operable EDG's.
This is a Severity Level IV Violation applicable to Unit 3 (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Arizona Public Service Company is hereby required to submit a written statement or explanation to the U.
S. 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 Inspection office at the Palo Verde Nuclear Generating Station, 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 that have been taken and the results achieved; (3) the corrective steps that will be taken to avoid further violat'ions; 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 be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending your response time for good cause shown.
Dated at Walnut Creek, California this +today of October 1989 FOR THE NUCLEAR REGULATORY COMMISSION
( gp(,
A.
E. Chaffee, Deputy Director Division of Reactor Safety and Projects