ML17306A921
| ML17306A921 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/13/1992 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A920 | List: |
| References | |
| EA-92-119, NUDOCS 9208260085 | |
| Download: ML17306A921 (9) | |
Text
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Arizona Public Service Company Palo Verde Units 1 and 3
Docket Nos.
50-528 and 530 License Nos.
NPF-41 and 74 EA 92-119 During NRC inspections conducted April 4-10, May 8-14, and June 15-19, 1992, 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, the Nuclear Regulatory Commission proposes to impose a civil penalty 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 penalty are set forth below:
A.
Technical Specification 6.8.1 for Palo Verde Unit 3 requires 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,..."
Appendix A of Regulatory Guide 1.33, Revision 2, recommends that "maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.",
Contrary to the above, as of April 10'992i the licensee's maintenance procedures, 32MT-9SB01, Revision 5, "Maintenance of Westinghouse Reactor Trip Switchgear,"
and 32MT-9SB02, Revision 1, "Maintenance of General Electric Reactor Trip Switchgear," for maintenance of reactor trip breakers were not appropriate to the circumstances as evidenced by the following examples:
Since 1983, procedures 32MT-9SB01 and 32MT-9SB02 have specified the use of an improper lubricant, Molykote 321 R, for all reactor trip breakers.
General Electric (GE) informed the li.censee in 1989 that this was an improper lubricant that could affect. the operation of the GE reactor trip breakers.
This information was directly applicable to Westinghouse reactor trip breakers also.
The licensee did not correct the earlier error.
2 ~
3 ~
Procedure 32MT-9SB01 did not incorporate an October 1991 Westinghouse reactor trip breaker inspection bulletin describing an inspection to check whether the Westinghouse reactor trip breakers were adjusted with sufficient opening force to operate properly.
Procedure 32MT-9SB02 did not incorporate the GE recommended maintenance procedures, which had been on 9208260085 920813 PDR ADOCK 05000528 8
PDR V
site since January 1990, for GE reactor trip breakers.
These maintenance procedures included additional undervoltage and shunt device adjustment instructions.
Technical Specification 6.8.1 for Palo Verde Unit 3 requires that "written procedures shall be established, implemented, and maintained covering.-. a.
The applicable procedures
'ecommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978..."
Appendix A of Regulatory Guide 1.33, Revision 2, recommends procedures for equipment control.
Licensee procedure 70DP-OEE01, Revision 1, "Equipment Root Cause of Failure," Section 3.3.1, requires the on-duty Shift Technical Advisor (STA) to initiate formal quarantining of important safety-related equipment for a failure investigation, to preserve the as-found conditions of the incident.
Contrary to the above, on March 31, 1992, the on-duty STA took no action to initiate formal quarantining of the Unit 3 reactor trip breaker, important safety-related equipment, when on March 31, 1992, the STA was informed by the Shift Supervisor that. this breaker,had.failed to open during its surveillance test.
Instead, routine troubleshooting was initiated, which included numerous cycles of opening and closing the breaker, and thereby failed to preserve the as-found conditions of the incident.
Co Technical Specification 3.6.3 for Palo Verde Unit 1 states that "the containment isolation valves specified in Table 3.6-1 shall be operable..." while in Modes 1, 2, 3, and 4.
Valve SIE-V133 is specified as a containment isolation valve in Table 3.6-1.
Technical Specification Action Statement 3.6.3.1 states that "with one or more of the isolation valve(s) specified in Table 3.6-1 inoperable, maintain at least one isolation valve operable in each affected penetration that is open and either:
- a. restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or b. isolate each affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at l~ast one deactivated automatic valve secured in the isolation position, or c. isolate the affected penetration within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one closed manual valve or blind flange, or'. be in at least hot standby within the next 6
hours and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."
Contrary to the above, from April 17, 1990, to February 17, 1992, while Unit 1 was in Modes 1, 2, 3, or'4, Unit 1 containment isolation valve SIE-V133, a containment
Notice af Violation isolation valve specified in Table 3.6-1, was inoperable because the valve internals were installed backwards and the valve could not perform its containment isolation function.
The licensee did not fulfillTechnical Specification Action Statement requirements 3.6.3.1.a d.
D.
Technical Specification 6.8.1 for Palo Verde Unit 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,...>
Appendix A of Regulatory Guide 1.33, Revision 2; recommends that "maintenance that can affect the perfarmance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or dravings appropriate to the circumstances."
procedure 30DP-9MP01, Revision 4, "Conduct of Maintenance,"
Section 3 5'6g states that "necessary precautions shall be taken vhenever work is done, such that the vork activity and any tools/equipment 'used villnot accidentally damage or remove equipment fram service, thus compromising essential plant safety functians."
Contrary to the above, on May 4, 1992, during the performance of Work Order 00521473, licensee personnel failed to take necessary precautions to prevent accidental removal of equipment from service, thus compramising essential plant safety functions, vhen an electrician lost control of a lifted lead inside load center L18,, which contacted a 480 volt bus, causing a loss of control room annunciator circuits.
This resulted in the declaration of an Alert and compromised the ability of the plant operators to monitor the status and conditions of plant parameters and to operate safety-related equipment to assure that.
parameters remained within acceptance limits.
This is a Severity Level XIX problem (Supplement I).
Cumulative Civil Penalty - $100,000 (assessed equally among the violations).
pursuant to the provisions of 10 CFR 2.201, 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 of Violation and Proposed Imposition of Civil Penalty (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 far 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 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'roper should not be taken.
Consideration may be given to extending the xesponse 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 penalty by letter addressed to the'Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission,'ith a check, dxaft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil pena1ty proposed above, or may protest imposition of the civil penalty in whole or in part, by a written answex addressed to the Directox, Office of Enforcement, U.S. Nucleax'egulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil 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 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.
In requesting mitigation of the proposed penalty, the factors addressed in Section V.B of 10 CFR Part 2, Appendix C, 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 fox 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 refexred 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 Noti.ce of Violation, letter with payment of.civil penalty, and Answer to a Notice of
Notice of Violation Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commiss3.on, ATTN:
Document'ontrol Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region V, and a c o the NRC Resident Inspector at the Palo Verde Nuclear neratin Station.
Dated at Walnut Creek, California this ]3 day of August 1992