ML17312B183

Notice of Violation from Insp on 961117-1228.Violation Noted:On 961125,unit 2 Operations Personnel Disabled Train a High Pressure Safety Injection,Low Pressure Safety Injection & Containment Spray Pumps

ML17312B183
Person / Time
Site:	Palo Verde
Issue date:	01/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17312B182	List: ML17312B181 ML17312B183
References
50-528-96-17, 50-529-96-17, 50-530-96-17, NUDOCS 9701210452
Download: ML17312B183 (8)

Text

ENCLOSURE 1 NOTICE.OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating Station Docket Nos.:

License Nos.:

50-528 50-529 50-530 NPF-41 NPF-51 NPF-74 During an NRC inspection conducted on November 17 through December 28, 1996, several violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A.

Units 1 and 2 Technical. Specifications (TS) 6.8.1 require, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, Appendix A, Section 1.c. requires written procedures for equipment control.

In addition, Section 9e requires general procedures for the control of maintenance, repair, replacement, and modification work.

Procedure 40DP-9OP02, Revision 0, "Conduct of Shift Operations," provides instructions necessary to control system and component status.

Step 6.2.1

. states, in part, when conditions result in disabling a safety-related system for which no automatic input to the safety equipment status system (SESS) panel is provided, a manual bypass/inoperable signal shall be initiated on the SESS panel.

Contrary to the above, on November 25, 1996, Unit 2 operations personnel disabled the Train A high pressure safety injection, low pressure safety injection, and containment spray pumps by closing Valve SIA-UV-660 (the combined miniflow recirculation valve) for which there was no automatic input to the SESS panel, and did not initiate a manual bypass/inoperable signal on the SESS.

2.

Procedure 40DP-9OP30, Revision 8, "Clearance Processing,"

provides instructions for processing station clearances.

Step 2.8.2 requires that if a discipline is working more than one work document under a clearance, each work document shall be listed on the tagout separately and clearance shall be authorized and accepted separately.

Contrary to the above, on October 23, 1996, mechanical maintenance was working more than one work document under Clearance 96-01734 and each work document was not listed nor.was clearance authorized and accepted 970i2f0452 970ii4 PDR ADOCK 05000528 6

PDR

separately.

Work Order (WO) 0756527, which included work to install a temporary restraining device on Unit 1 reactor coolant Pump 2B, was not listed, authorized, nor accepted separately on Clearance 96-01734.'.

Procedure 30DP-9WPO2, Revision 19, "Work Document Development and Control," provides instructions for the development and control of work instructions for maintenance activities.

Appendix 0 of Procedure 30DP-9WP02, requires that a work order be submitted to a work planner, to amend the work instructions, if the work changes involve a scope change as defined by licensee Technical Dictionary 01IG-OAP02, Revision 6.

Included under the definition of scope change is the expansion of tagging boundaries.

Contrary to the above, on October 23, 1996, maintenance allowed a scope change to WO 0756527, in that the installation of a temporary restraining device to Unit 1 reactor coolant Pump 2B required the expansion of tagging boundaries, and the work order was not submitted to a work planner to amend the work instructions.

This is a Severity IV violation (Supplement I) applicable to Units 1 and 2.

10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.

Licensee Specification 13-PN-204, Revision 6, "Installation Specification for Field Fabrication and Installation of Nuclear Piping Systems," Section 8.6.3 provides allowable installation tolerances for pipe supports.

Step 8.6.3.3.1 provides verification requirements for 0-inch/free-to-slide clearances between pipe wall and steel supports.

Verification of this dimension may be demonstrated by either the ability to physically measure a space, insert a standard feeler gauge, or see visible light between the pipewall and supporting structure; or the ability to physically move the pipe by hand within the support.

Contrary to the above, between October 1 and November 22, 1996, the licensee installed piping system modifications to both trains of essential cooling water in Units 1, 2 and 3, in accordance with Specification 13-PN-204, and did not verify a 0-inch/free-to-slide clearance between Train A lines PEWAL-026 and Train A pipe support EW-026-H-27, and Train B lines PEWBL-038 and Train B pipe support EW-038-H-7.

The licensee could not either physically measure a space, insert a standard feeler gauge, or see visible light between the pipe walls and pipe supports; or physically move the pipes by hand within the supports.

2.

WO 0?75357 provided instructions to test and clean out the charging pump well drain line from Unit 3 charging Pump E to the charging pump oil drain tank.

Precaution 2.1.4 of this work order required that operations be contacted to secure seal lube for the duration of the task if one of the other charging pumps had excessive seal lube leakage into the pump well.

Contrary to the above, on November 7, 1996, Unit 3 charging Pump B had excessive seal lube leakage into the pump well, and maintenance personnel performing WO 0775357 did not contact operations to secure seal lube for the duration of the task.

This is a Severity IV violation (Supplement I) applicable to Units 1, 2, and 3.

C.

Unit 2 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, requires, in part, written procedures for security and visitor control ~

Procedure 20AC-OSK04, Revision 17, "Protected/Vital Area Personnel Access Control," step 3.7.6.2 requires that visitors shall remain in the line of sight and in positive control of their escort.

Contrary to the above, on November 22, 1996, a visitor performing work in the Unit 2 Train B emergency diesel generator room, a vital area, was not maintained within the line of sight nor within positive control of the escort, who was in an adjacent room.

This is a Severity Level IV violation (Supplement III) applicable to Unit 2.

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, 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 the facility that is the subject of this Notice, 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.

Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued 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.

Where good cause is shown, consideration will be given to extending the response time.

Because your response will be placed in the NRC Public Document Room {PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction.

However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

Dated at Arlington, Texas this 14th day of January 1997

I 1

1 ll I

I I