ML17305A711
| ML17305A711 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/13/1990 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305A710 | List: |
| References | |
| 50-529-90-03, 50-529-90-3, NUDOCS 9004270014 | |
| Download: ML17305A711 (9) | |
Text
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APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Unit 2 l
Docket Number 50'-529 License Number NPF-51 During an NRC inspection conducted on January 21 through March 3, 1990, a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below:
Unit 2 Technical Specifications, Section 6.8. l.c, requires that written procedures be established, implemented, and maintained covering surveillance and test activities of safety related equipment.
Procedure 73AC-92Z04, Surveillance Testing, Revision 7, Paragraph 3.2.4. 1, states that if a particular indicator is not functioning properly it is permissible to utilize the plant computer to obtain the required test data.
Otherwise, if test parameters cannot be obtained from the plant computer, the parameter should be obtained from local
'ndication.
Contrary to the above, on January 25,
- 1990, and on four other occasions, procedure 73AC-9ZZ04 was not implemented in that the Unit 2 "B" Diesel Generator Fuel Oil Storage Tank (FOST) level indicator (2JDFNLI0034) was.
known not to be functioning properly but was used to determine the
-adequacy of FOST level'per Technical Specifications Surveillance Requirement 4.8. 1.1.2.a.
Alternate means of obtaining a valid indication of tank level, such as from the local indicator at the tank or plant
- computer, were not used to provide the basis for satisfactory surveillance test completion.
This is a Severity Level IV violation applicable to Unit 2 (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 of Violation (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 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
0 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.
FOR THE NUCLEAR REGULATORY COMMISSION Dated at Walnut Cr ek alifornia this Q&ay of 1990
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- immerman, grec or Division Reactor Safety and Projects
Document Control Desk Page 1 of 1 102-01689-WFC-TRB/JJN May 11, 1990 APPENDIX A NOTICE OF VIOLATION Arizona Nuclear Power Project Palo Verde Unit 2 Docket Number 50-529 License Number NPF-51 During an NRC inspection conducted January 21 through March 3,
- 1990, a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989),
the violation is listed below:
Unit 2 Technical Specification, Section 6.8.1.c, requires that written procedures be established, implemented, and maintained covering surveillance and test activities of safety related equipment.
Procedure 73AC-9ZZ04, Surveillance Testing, Revision 7, Paragraph 3.2.4.1, states that if a particular indicator is not functioning properly it is permissible to utilize the plant computer to obtain the required test data.
Otherwise, if test parameters cannot be obtained from the plant computer, the parameter should be obtained from local indication.
Contrary to the above, on January 25,
- 1990, and on four other occasions, procedure 73AC-9ZZ04 was not implemented in that the Unit 2 "B" Diesel Generator Fuel Oil Storage Tank (FOST) level indicator (2JDFNLI0034) was known not to be functioning properly but was used to determine the adequacy of FOST level per Technical Specifications Surveillance Requirement 4.8.1.1.2.a.
Alternate means of obtaining a valid indication of tank level, such as from the local indicator at the tank or plant computer, were not used to provide the basis for satisfactory surveillance test completion.
This is a Severity Level IV violation (Supplement I).
If t
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Document Control-Desk Page 1 of 2 102-01689-WFC/TRB/JJN May 11, 1990 ATTACHMENT 1 Re 1
to Notice of Violation 50-529 90-03-01 I.
REASON FO THE VIOLATION The basis for the Notice of Violation is that LI-34 was not functioning properly (i.e., work request tag on LI-34) and that alternate means of obtaining a valid indication were not used to provide the basis for satisfactory Surveillance Test (ST) completion.
The Operators utilized LI-34 in the performance of the ST based on the gauge reading properly and consistent with other indications.
A review of the level indication in the operators'ogs and fuel consumption and replenishment verified that LI-34 was functioning properly at the time of the surveillance test performance.
- However, the reason for the violation is that the operators did not formally document the use of alternative indication (ice ~
, low level alarm).
II'ORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A night order was written on March 5,
- 1990, to provide guidance for the use of instrumentation with a maintenance tag present.
Prior to the use of such instrumentation for the performance of surveillance testing, the Assistant Shift Supervisor shall be notified of the condition requiring
,f
Document Control Desk Page 2 of 2 102-01689-WFC/TRB/JJN May 11, 1990 the maintenance.
t'ag and'n evaluation will be performed and documented to justify the use of the instrument.
APS has revised the diesel generator ST procedures to permit the use of the low level alarm as an alternate means of fulfillingthe fuel oil Surveillance Requirement.
III.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID VIOLATIONS APS believes the actions taken as described above are adequate to prevent recurrence'V.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on March 28, 1990 when the revised Surveillance Tests became effective.
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