ML17305B675
| ML17305B675 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/23/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B674 | List: |
| References | |
| 50-528-91-19, 50-529-91-19, 50-530-91-19, NUDOCS 9108130064 | |
| Download: ML17305B675 (4) | |
Text
NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Units 1, 2 and 3
Docket Numbers 50-528, 50-529 and 50-530 License Numbers NPF-41, NPF-51 and NPF-74 During an NRC inspection conducted on May 12 through June 15, 1991; three 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 (1991), the violations are listed below:
A.
Unit 2 and 3 Technical Specifications 6.8. 1 state in part: "Written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1'.33, Revision 2, February, 1978."
1.
Regulatory Guide 1.33, Revision 2, Appendix A, covers maintenance that can affect the performance of safety related equipment.
APS Conduct of Maintenance Procedure, 30DP-9MP01, step 3.5.15 states; "Work group personnel shall verify that station component identification matches the component specified as requiring maintenance in the work document."
Work order 495993 required that the filter cover for 3MCHNF02A be unbolted.
Contrary to the above, on May 24, 1991, Unit 3 Mechanics unbolted 3MCHNF02B, during performance of work order 495993.
2.
Regulatory Guide 1.33, Revision 2, Appendix A covers surveillance tests to meet technical specifications.
Surveillance test procedure 36ST-9SAll, ESFAS Train A High Risk Subgroup Relay Monthly Functional Test, used to satisfy Technical Specification 4.3.2. 1 specifies in steps 8.6.2. 1 and 8.6.2.2 to perform actions at cabinet J-SAA-C01.
Contrary to the above, on May 16,
- 1991, an Instrument and Controls Technician failed to implement procedure 31ST-9SA11, in Unit 3, when steps 8.6.2. 1 and 8.6.2.2 were performed on the B train cabinet J-SAB-C01.
3.
Regulatory Guide 1.33, Revision 2, Appendix A covers the gaseous effluent system.
Procedure 74RM-9EF20, Gaseous Radioactive Release Permits and Offsite Dose Assessment, Step 10.2.2 states that "If RU-34 setpoints were changed, ensure that the ALERT and HIGH alarm set points are restored and documented Contrary to the above, on June 5, 1991, a Unit 2 Chemistry Effluent Technician failed to implement procedure 74RM-9EF20 when the alarm setpoint on RU-38 was reset rather than RU-34 as required.
These examples represent a Severity Level IY Violation applicable to Units 2 and 3 (Supplement I).
9108130064 910723 PDR ADOCK 05000528 G
PDR B.
The Unit 3 Technical Specification 6. 11. 1 requires procedures for personnel radiation protection to be prepared consistent with the requirements of 10 CFR Part 20 and to be approved, maintained,.and adhered to for all operations involving personnel radiation exposure.
Licensee Procedure 75AC-9RP01 requires that "All personnel who enter the Radiological Controlled Area must read the REP (Radiation Exposure Permit) and sign-in on the appropriate REP sign-in sheet.
By signing in they indicate that they have read and understand the REP requirements and will comply."
REP 3-91-0001-B, among other radiation protection measures, requires personnel entering High Radiation Areas to wear an alarming dosimeter.
Contrary to the above, on May 31, 1991, a Unit 3 Radiation Protection Technician failed to comply with REP 3-91-0001-8 which he had signed, when he entered a posted High Radiation Area without an alarming dosimeter.
This is a Severity Level IV Violation applicable to Unit 3 (Supplement Iv).
Unit 1, 2, and 3 Technical Specifications 6.8. 1 state in part:
"Mritten procedures shall be established, implemented, and maintained covering the activities...recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February, 1978."
Regulatory Guide 1.33, Revision 2, Appendix A covers administrative procedures for the plant fire protection program.
Procedure 14AC-OFP04, Revision 2, states in section 2.2.2. 1 that, "Initial Fire Match training shall be given to those employees who will perform fire watch duties,"
and in section 2.2.2.2, "Fire Match CBT retraining and a practical will be given, on an annual
- basis, to those employees who will perform fire watch duties."
Procedure 15AC-OTR09, Revision 1, states in section 3.5.1 that fire watch course NGF16 is required for all personnel who will be involved with fire watch duties.
Contrary to the above, as of January
- February 1991 twelve fire watches failed to implement procedure 14AC-OFP04 when they performed fire watch duties prior to fully completing fire watch course NGF16 or completing annual retraining.
This is a Severity Level IV Violation applicable to Units 1, 2, and 3 (Supplement I).
Pursuant to the provisions of 10 CFR Part 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, Mashington, 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
0
- 0 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'o a
Notice of Violation" and should include for Violations A and C: (1) the reason for the violation or, if contested, the basis for disputing the violation, (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 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.
Mhere good cause is shown,'consideration will be given to extending the response time.
Dated at h'alnut Creek, California this 25+day of Wu~~
1991