ML17306A446
| ML17306A446 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/03/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A445 | List: |
| References | |
| EA-91-182, NUDOCS 9202110053 | |
| Download: ML17306A446 (15) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Arizona Public Service Company Palo Verde Nuclear Generating Station Wintersburg, Arizona Docket Nos.
50-528, 50-529,
& 50-530 License Nos.
NPF-41, NPF-51, and NPF-74 EA 91-182 During an NRC inspection conducted between October 27, 1991 through December 2, 1991, 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 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:
Violations Assessed a Civil Penalt A
Technical Specification 6.8.1 for Palo Verde Units 1, 2,
and 3 states that "Written procedures shall be established
, implemented, and maintained covering a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February
- 1978,
-and those required for implementing the requirements of NUREG-0737."
Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 9,
recommends procedures for performing maintenance that can affect the performance of safety-related equipment.
Procedure No.
30DP-9MP01, Revision 4, dated August 29,
- 1991, "Conduct of Maintenance,"
Section 3.5.16, states that "necessary precautions shall be taken whenever work is done, such that the activity... will not accidentally damage or remove equipment from service, thus compromising essential plant safety functions."
Section 3.5.9 directs that rigging activities be accomplished in accordance with Procedure No.
30AC-OMP13, Section 3.9.6.1, which requires that "When working with or around cranes that are within a boom's length of any power line, an electrical checker shall be required.
Ensure that a qualified signalman and checker are stationed at all times within view of the operator to warn him when any part of the machine or its load is approaching the minimum safe clearance."
9202110053 920203 PDR ADOCK 05000528 6
Notice of Violation Contrary to the above, on November 15, 1991, while installing a new electrical bushing on the phase A
main transformer, an activity that might compromise the electrical power supply to vital electrical busses, an electrical checker and signalman were not stationed at the work site at all times; other necessary precautions were not taken in that licensee personnel made no allowances for out-of-level conditions, as recommended in the crane vendor's manual; the crew using the crane was required to work without adequate rest and had been awake for approximately 18 of the 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> prior to the incident; the work planners were not familiar with the details of the work being conducted, including the need for a mobile crane; and Amendment A to Work Order No.
526228, controlling the crane job, which designated the Senior Electrician as an independent observer of the job and responsible for the job, was not provided to that individual nor was he otherwise informed of his added responsibilities.
2 ~
Paragraph 5.0 of Procedure No.
30DP-9MP01 references the Palo Verde Accident Prevention Manual.
The Accident Prevention Manual, dated January 4,
1990, requires, in Paragraph 29.9(c),
that cranes used for work in the vicinity of bare conductors energized at voltages of 600 volts or greater be grounded.
This manual further
- requires, in Paragraph 29.7, that at least 2 feet clearance be maintained between the uninsulated boom section and the 13.8 kV power line energized conductor.
Contrary to the above, on November 15, 1991, the crane used to replace the electrical bushing on the phase A main transformer was not grounded, and the two foot clearance between the uninsulated boom section and the 13.8 kV power line energized conductor was not maintained.
3.
Procedure 40AC-P02, "Conduct of Shift Operations,"
Step 3.2.5.1 states that "formality in communications will be emphasized to reduce operating errors due to assumptions, ambiguous directions, and misunderstandings between
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Notice of Violation operations personnel."
Step 3.2.5.2.3 states that "all communications directing or reporting completion of an operating activity must include identification of the originator and intended recipient if other than face to face communication identification of each valve or component
[and] acknowledgement of receipt and understanding of direction including as a minimum repeating back each valve or component Contrary to the above, on November 15,
- 1991, operators failed to identify the originators of calls to the control room, failed to ensure correct identification of the overhead power lines being reported as a problem, and failed to acknowledge receipt and understanding of information passed to the control room via telephone.
These communication errors caused incorrect action to be taken by control room operators, resulting in the loss of forced circulation in the Unit 3 reactor coolant system.
B.
Technical Specification 6.8.1 for Palo Verde Units 1, 2,
and 3 states in part that "Written procedures shall be established, implemented, and maintained covering a.
The applicable procedures... required for implementing the requirements of NUREG-0737."
NUREG-0737,Section I.C.5, states that the licensee "shall prepare procedures to assure that operating information pertinent to plant safety originating both within and outside the utility organization is continually supplied to operators and other personnel and incorporated into training and retraining programs.
These procedures shall clearly identify organizational responsibilities for... the feedback of pertinent information to operators and other personnel, and the incorporation of such information into training and retraining programs;... provide means to assure that affected personnel become aware of and understand information of sufficient importance that should not wait for emphasis through routine training and retraining programs;
...[and] identify the administrative and technical review steps necessary in translating recommendations by the operating experience assessment group into plant actions (e.g.,
changes to procedures; operating orders)."
Procedure No.
95PR-ON01, Revision 3 (Industry Operating Experience Review Program),
dated June 13,
- 1991, paragraph 2.4, prescribes that Unit Plant Managers and Directors are responsible, for ensuring that lessons
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Notice of Violation learned from industry events are effectively incorporated in Palo Verde Nuclear Generating Station (PVNGS) operations.
The NRC advised the licensee of the significant hazards attendant with using mobile lifting equipment in proximity to transmission lines by Information Notice (IN) No. 90-25, dated April 16,
- 1990, and IN 90-25, Supplement I, dated March 11,
- 1991, each titled "Loss of Vital Power with Subsequent Reactor Coolant System Heatup."
In addition, these hazard potentials were reinforced in a letter from Dr. T. Murley (NRC) to Mr.
W. F.
Conway (APS), dated March 21, 1991, titled "Operational Events While Shutdown."
Contrary to the above, as of November 15, 1991, the lessons learned from the above formal NRC communications were not effectively incorporated into PVNGS operations, training and procedures to prevent the occurrence at Palo Verde of the type of event described in the NRC communications.
This is a Severity Level III problem (Supplement I).
Civil Penalty
$112,500 C.
-Unit 2 Technical Specification 6.2.2.d provides that "All'CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation."
Technical Specification 3.9.5, applicable during core alterations, provides that "Direct communication shall be maintained between the control room and personnel at the refueling station."
Contrary to the above, on October 27, 1991, with the reactor in Mode 6 (refueling), at approximately 12:10 PM (MST), a core alteration involving withdrawal of the control element assemblies at least one foot from the core into the upper guide structure was conducted without a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling present and without direct communications established between the control room and personnel at the refueling station.
This is a Severity Level III violation applicable to Unit 2 (Supplement I). Civil Penalty
$50,000
I r,
Notice of Violation II. Violations Not Assessed a Civil Penalt A.
Unit 2 Technical Specification 6.8.1 states in part:
"Written procedures shall be established, implemented, and maintained covering the activities...
recommended in Appendix A of Regulatory Guide 1.33, Revision 2, Februaryg 1978"
("Reg. Guide" ).
Appendix A of Regulatory Guide 1.33 Revision 2
recommends procedures for safe operation and shutdown
("Ops. Procedures" ).
Procedure 40AC-90P02, "Conduct of Shift Operations,"
Step 3.2.1.5, which implements in part the Ops.
Procedures recommendation of the Reg.
Guide, requires that "Onshift personnel shall be aware of and responsible for plant status... They shall be attentive to instrumentation and respond to abnormal indications until corrected or verified to be false by other instrumentation."
Contrary to the above, on October 27, 1991, Unit 2 onshift control room personnel were not attentive to plant instrumentation in that they failed to respond to an abnormal alarm indication caused by the transfer of the PNC-D27 bus power supply.
This is a Severity Level IV violation (Supplement I).
B.
Unit 2 Technical Specification 6.8.1 states 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"
("Reg. Guide" ).
Appendix A of Regulatory Guide 1.33 Revision 2
recommends procedures for preparation for refueling and refueling equipment operation.
Procedure 42OP-2ZZ12, "Mode 6 Operations,"
Step 5.3.15.2, which implements in part the refueling procedures recommendation of the Reg.
Guide, provides that, prior to removing the gate between the fuel canal and the spent fuel pool, the fuel canal and Spent Fuel Pool (SFP) shall be sampled to ensure that adequate boron concentration is maintained.
Notice of Violation Contrary to the above, on October 27, 1991, with the reactor in Mode 6, the licensee failed to obtain boron samples of the SFP and the fuel canal prior to opening the gate.
This is a Severity Level IV violation (Supplement I).
C.
Unit 2 Technical Specification 6.8.1 states in part:
"Nritten procedures shall be established, implemented, and maintained covering the activities...
recommended in Appendix A of Regulatory Guide 1.33, Revision 2,
- February, 1978"
("Reg. Guide" ).
Appendix A of Regulatory Guide 1.33 Revision recommends procedures for preparation for refueling and refueling equipment operation
("Refueling Procedures" ).
Procedure 420P-2ZZ12, "Mode 6 Operations,"
Step 5.3.3, which implements in part the Refueling Procedures recommendation of the Reg.
Guide, requires that the Refueling Pool be filled between elevation 127 feet 6
inches and 128 feet 6 inches prior to Step 5.3.4, which directs the lowering of the Upper Guide Structure (UGS) liftrig working platform to its lower stop.
-Procedure 40AC-90P02, "Conduct of Shift Operations,"
Step 3.3.2.1.2, provides that "Procedures shall be completed in the order identified unless deviations are allowed by the procedure or authorized by an approved Special Variance."
Contrary to the above, on October 27, 1991, the Refueling Pool level was less than 127 feet 6 inches when Step 5.3.4 was accomplished to lower the UGS lift rig working platform and a Special Variance had not been authorized.
This is a Severity Level IV violation (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 Director, Office of Enforcement, U. S.
Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalties.
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, and if denied, the reasons
- why, (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
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Notice of Violation specified in this Notice, the Commission may issue an order or a demand for information as to 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 under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable the Treasurer of the United States in the cumulative amount of the civil penalties proposed
- above, or may protest imposition of the civil 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, and order imposing the civil penalties 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 violations listed in the Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not, be imposed.
In addition to protesting the civil penalty, in whole or in part, such answer may request remission or mitigation of the penalty.
Zn requesting mitigation of the proposed penalties, the factors addressed in Section V.B. of 10 CFR Part 2, Appendix C (1991) 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 reference (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 response noted above (Reply to 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, D.C.
20555 with a copy to the Regional
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Notice of Violation Administrator, U.S. Nuclear Regulatory Commission, Region V, and a copy to the NRC Senior Resident Inspector at Palo Verde Nuclear Generating Station.
Dated at Walnut Cr ek, California this Qj~c, day of I
1992