ML17313A352
| ML17313A352 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17313A351 | List: |
| References | |
| 50-528-98-12, 50-529-98-12, 50-530-98-12, NUDOCS 9804210130 | |
| Download: ML17313A352 (6) | |
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I ENCLOSURE 1
NOTICE OF VIOLATION Arizona Public Service Company Palo Verde Nuclear Generating Station Docket Nos.: 50-528: 50-529; 50-530 License Nos.: NPF-41: NPF-51: NPF-74 During an NRC inspection conducted on February 17-27. 1998. with inoffice inspection from February 29 to April 9. 1998. two violations of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG-1600. the violations are listed below:
I 10 CFR Part 50, Appendix 8, Criterion V, "Instructions, Procedures and Drawings," requires that activities affecting quality be accomplished in accordance with instructions, procedures, and drawings.
The approve5 Quality Assurance Program Description PD-OAP01. "PVNGS Administrative Control Program." Chapter 1 0. Revision 2. states.
in part. "Procedures shall be used as appropriate.
Chapter 17.0. Revision 1. states. in part. "... the work control piocess is used to identify and correct hardware deficiencies using Work Request documents,"
Chapter 17.0 also defines an adverse condition as any condition which adversely affects the safe and reliable production of electricity such as failures, malfunctions, deficiencies. deviations. defective material and equipment.
The implementing procedures for these requirements are 90DP-OIP10, "Condition Reporting," Revision 1. and 30DP-PWP02. "Work Document Development and Control ~" Revision 23.
A.
Procedure 90DP-OIP10, Step 3.1.2. states, in part, that if a condition may cause a
degraded or nonconforming condition in a plant system, the identifier of the condition (originator) must promptly notify the shift supervisor of the affected unit.
Procedure 90DP-OIP10. Step 3.1.3. states, in part. that the identifier of a condition will complete a condition report/disposition request and submit the form to his/her lead (supervisor) by the end of the shift.
Procedure 90DP-OIP10. Step 3.6.2, states that, for significant condition reports/disposition requests. "... the CRDR Owner shall complete a Root Cause Investigation. identify the root cause(s).
if possible. and implement corrective actions to prevent recurrence."
Contrary to the above.
I On September
- 19. 1997. when Unit 2 Licensee Event Report 50-529/97-004 was issued. and on October 15, 1997. when significant Condition Report/Disposition Request 270271 was issued. the licensee failed to identify, in accordance with Procedure 90DP-OIP10. Step 3.6.2. the root cause for a procedure writer. a reviewer. and a management representative failing to include the proper acceptance critenon for the power channel check in Surveillance Procedure 40ST-9ZZ34.
Standard Full Power Surveillance."
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On October 28. 1997. licensee engineers failed to identify a degraded condition in accordance with Procedure 90DP-OIP10, Steps 3.1.2 and 3.1.3, to promptly notify the shift supervisor of the affected unit (Unit 2) ~ complete a condition report/disposition request. and provide information to their supervisor, by the end of the shift. involving the discovery of tests. required by ASME Section XI and
,technical specifications, which had not been performed on Unit 2 components for either the first or second inspection period of the first interval.
This is a Severity Level IVviolation (Supplement I) (50-528:-529;-530/9812-01).
B.
Procedure 30DP-PWP02, paragraph 3.2.2.3, requires that work shall be reviewed to determine if evaluations for transportability are potentially required and documented on a condition report/disposition request.
Contrary to the above. from December 19, 1995, through November 18, 1997, the licensee failed to review to determine ifevaluations for transportability were required and initiate a condition report/disposition request for 27 failures (e.g., slow response) of the free air regulators for the instrument air system.
These failures were adverse conditions because a malfunction or defect in the instrument air system could affect the safe and reliable production of power, for example, by loss of auxiliary feedwater, atmospheric dump, and steam generator blowdown systems.
This is a Severity Level IV violation (Supplement I) (50-528;-529;-530/9812-04).
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 or severity level, (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 willbe 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'e proper should not be taken. Where good cause is shownconsideration will be given to extending the response time.
Ifyou contest this enforcement action, you should also provide a copy of your response to the Director. Office of Enforcement. United States Nuclear Regulatory Commission. Washington, DC 20555-0001.
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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.
If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. Ifyou request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.
~ explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas this 16th day of April 1998
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