ML17310B469
| ML17310B469 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/24/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17310B468 | List: |
| References | |
| 50-528-94-12, 50-529-94-12, 50-530-94-12, NUDOCS 9407280018 | |
| Download: ML17310B469 (8) | |
Text
APPENDIX A NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating Station Dockets:
50-528; 50-529; 50-530 Licenses:
NPF-41; NPF-51; NPF-74 During an NRC inspection conducted on April 25 through May 27, 1994, 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, the violations are listed below:
A.
B.
Section 3.9.8.2 of the Palo Verde, Unit 3, Technical Specifications states that two independent shutdown cooling loops shall be operable and at least one shutdown cooling loop shall be in operation when the unit is in Mode 6 with the water level less than 23 feet above the top of the reactor pressure vessel flange.
Section
- 1. 19 of the Technical Specification states that a component shall be operable when it is capable of performing its specified
- function, and when electrical power and other necessary auxiliary equipment are capable of performing their related support functions.
Action a of Technical Specification 3.9.8.2 states that, when less than the required shutdown cooling loops are operable, immediate action shall be initiated to return the required loops to operable status, or to establish at least 23 feet of water above the reactor pressure vessel
- flange, as soon as possible.
Contrary to the above, the feeder breaker for the Train A low pressure safety injection pump was racked into the test position on May 12,
- 1994, rendering the associated shutdown cooling loop inoperable, and immediate action was not initiated to restore the shutdown cooling loop to service or to establish at least 23 feet of water above the reactor pressure vessel flange.
, This is a Severity Level IV violation, applicable to Unit 3 (Supplement I) (530/9412-03).
Criterion XI of 10 CFR 50, Appendix B, "Test Control," requires that a
test program be established to assure that required testing is identified and performed in accordance with written procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Contrary to this requirement, test procedures did not incorporate appropriate acceptance criteria as follows:
1.
Post-maintenance or post-modification testing after the following changes in motor-operated valve operator gear ratios was performed 9407280018 940724 PDR ADOCK 05000528 PDR
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using the normal inservice tests, which verified that valve stroke time was still within operational limits, but did not confirm that the desired change in stroke time had actually been accomplished:
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Gear ratio changes to decrease the closing time of Auxiliary Feedwater Discharge Isolation Valves JAFBUV0034 and JAFBUV0035 from 14.5 to 13.5 seconds, performed pursuant to LLDCP 1/2/3LH-AF-102, completed in Unit 3 on Hay 19,
- 1994, respectively.
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Gear ratio changes to increase valve opening time from 3.5 to 4.5 seconds for certain motor-operated valve operators specified in Work Order 00660155, completed on Hay 18, 1994.
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Gear ratio changes for reactor coolant pump controlled bleedoff valves, to increase their closing times from 6.5 to 11 seconds, pursuant to Wor k Orders
- 00653367, 00653513,
- 00653521, and 00653523, completed between Hay 4 and 17, 1994.
As of Hay 12,
- 1994, Procedure 32ST-9ZZ03, "Surveillance Test Procedures for the Class 4160 Bus Undervoltage Relays,"
Revision 5.06, contained inappropriate criteria for verifying and establishing the setpoints for the degraded voltage relays, in that these criteria would have permitted degraded voltage relay setpoints to be left or established at values as low as 3150 volts, although licensee design documents showed that setpoints at or near 3744 volts were required to provide acceptable voltage to safety-related components.
As of April 29, 1994, Surveillance Procedures 43ST-3SP-02, Revision 3, and 43ST-3SW04, Revision 2, which stated as their purpose to verify operability of the essential spray pond pumps and essential cooling water pumps, respectively, included acceptance criteria which monitored for degradation of pump performance from expected
- values, but did not verify the ability of the pumps to satisfy their design or operational performance requirements.
Surveillance Test 73ST-3DG01, Revision 5, performed in Unit 3 on Hay 12,
- 1994, included inappropriate acceptance criteria to perform the 18-month verification required by Technical Specification 4.8. 1. 1.2.d.9 that the auto-connected loads to each diesel generator do not exceed the continuous rating of 5500 KW, in that the acceptance criteria did not account for the operation of several safety-related components at less than their design electrical loading during the test.
The acceptance criteria for post-maintenance testing following preventive maintenance on Unit 1 control room outside air intake Damper 1HHJB-H03, conducted on February 15,
- 1994, were not
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sufficiently specific to verify that the damper actuating linkage had been properly reconnected, with the result that the damper was inoperable until Hay 10, 1994.
This is a Severity Level IV violation, applicable to Units 1, 2, and 3
(Supplement I) (528;529;530/9412-01)
Criterion XI of 10 CFR 50, Appendix B, "Test Control," requires that a
test program be established to assure that required testing is identified and performed in accordance with written test procedures, and that the test program include, as appropriate, operational tests of components during nuclear power plant operation.
Paragraph 3.6. 1.3 of the Palo Verde Nuclear Generating Station Operations guality Assurance Plan states that, "The test program shall cover all required tests including:
. e.
Tests to demonstrate satisfactory performance following plant maintenance Contrary to this requirement, appropriate testing to demonstrate satis-factory performance of the Unit 3 Train A ciesel generator combustion air intake valve was not performed after the completion of preventive maintenance on April 24,
- 1994, in that additional maintenance steps following the specified retest invalidated the retest results.
As a
- result, the valve was left in an inoperable configuration and failed during an integrated engineered safety features test on May 12, 1994.
This is a Severity Level IV violation, applicable to Unit 3 (Supplement I)(530/9412-04).
Section 10 CFR 50.59 of the NRC Regulations, states in (a)(1) that the holder of a license may make changes in the facility as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the Technical Specifications or an
,unreviewed safety question; in (a)(2) that a proposed change shall be deemed to involve an unreviewed safety question "(iii)if the margin of safety as defined in the basis for any technical specification is reduced";
and in (b)(1) that records must include a written safety evaluation which provides the bases for the determination that the change does not involve an unreviewed safety question.
Contrary to these requirements:
1.
The performance requirements for Valves SGA-UV135 and SGA-UV138, motor-operated steam stop valves to the Train A auxiliary feed-water pump turbine in all three units, were changed to require that the valves leak (to keep downstream steam piping warm) in order for the auxiliary feedwater pump to be operable.
Although this represented a change to the facility as described in the Table 6.2.4-1 of the UFSAR, which identifies these valves as con-.
tainment isolation valves, the screening performed on August 23,
- 1993, concluded that no change to the facility as described in the FSAR was involved, and a written safety evaluation was not
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2.
performed to provide the bases for the determination that the change did not involve an unreviewed safety question.
The licensee changed the minimum required spray pond inventory in
- 1993, based on Calculation 13-MC-SP-307, to 26 days from the 27 days specified in the bases for Technical Specification 3/4.7.5.
This represented a decrease.
in the margin of safety as defined in the Technical Specification
- bases, and prior Commission approval of this change was not requested.
This is a Severity Level IV violation, applicable to Units 1, 2, and 3
(Supplement I) (528;529;530/9412-05).
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, Mashington, D.C.
20555 with a copy to the Regional Administrator, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas
- 76011, and a copy to the NRC Resident Inspector at 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, 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 or a Demand for Information 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.
Where good cause is shown, consideration will be given to extending the response time.
Dated at Arlington, Texas this day of 1994
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