ML17313A715
| ML17313A715 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 12/21/1998 |
| From: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| Shared Package | |
| ML17313A716 | List: |
| References | |
| 50-528-98-14, 50-529-98-14, 50-530-98-14, EA-98-382, NUDOCS 9812300021 | |
| Download: ML17313A715 (12) | |
See also: IR 05000528/1998014
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZADRIVE, SUITE 400
ARLINGTON,TEXAS 76011-6064
December
21,
1998
EA 98-382
James
M. Levine, Senior Vice
President, Nuclear
Arizona Public Service Company
P.O. Box 53999
Phoenix, Arizona 85072-3999
SUBJECT:
NOTICE OF VIOLATIONAND PROPOSED IMPOSITION OF CIVILPENALTY-
$55;000 (NRC Inspection Report No. 50-528/98-14; 50-529/98-14;
50-530/98-14)
Dear Mr. Levine
This refers to the special inspection conducted on May 26 through July 21, 1998, at the Palo
Verde Nuclear Generating Station reactor facilityoperated by Arizona Public Service Company.
The inspection was conducted in response
to the identification of excessive reverse flow
through pump discharge check valves in the high-pressure safety injection (HPSI) systems
(10 CFR 50.72 immediate notifications on May 14 and 15, 1998, and Licensee Event Report
50-528/98006 and Supplement 1). NRC Inspection Report 50-528/98-14; 50-529/98-14;
50-530/98-14, issued August 28, 1998, described the results of that inspection and apparent
violations of NRC requirements.
A predecisional enforcement conference to discuss the
apparent violations was held in the NRC's Arlington, Texas office on September
14, 1998.
Based on the information developed during the inspection and the information that you provided
during the conference and in letters dated September 29 and October 9, 1998, the NRC has
determined that violations of NRC requirements occurred.
These violations are cited in the
enclosed Notice of Violation and Proposed Imposition of Civil Penalty.
The circumstances
surrounding the violations were described in detail in the subject inspection report.
In brief, the violations involve three main issues:
(1) failures to adhere to technical specification
limiling conditions for operation when ECCS subsytems were inoperable; (2) a failure to identify
and correct significant conditions adverse to quality despite numerous indicators; and
(3) inadequate
procedures which caused the problems and prevented timely identification of the
significant conditions adverse to quality.
The NRC considers the potential safety consequences
associated
with these violations to be
significant. During a design basis accident where the pump associated
with the incorrectly
assembled
check valve failed to start, the reverse flow through the valve would have
significantly reduced safety injection flow to the core. This condition existed for approximately
6 years in Unit 1, 5 years in Unit 2, and 1f/~ years in Unit 3.
In addition, the potential for
excessive reverse flow also existed during time periods when the pump associated
with the
incorrectly assembled
check valves was taken out of service for maintenance.
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Arizona Public Service Company
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The degraded performance capability of the HPSI system for certain accident conditions would
have resulted in a decrease
in flow to the reactor vessel significantly below the flowassumed
in
the safety analysis.
Your staff conducted extensive analyses and concluded that no core
damage would have occurred during a toss-of-coolant accident.
However, the method used to
reach this conclusion had not been reviewed or approved by the NRC, and did not conform to
the analysis described in the Final Safety Analysis Report (FSAR), which has been reviewed
and approved by the NRC. At the predecisiorial enforcement conference, your staff
acknowledged that, using the method described in the FSAR, peak fuel cladding temperature
would have exceeded 2,200'F during a toss-of-cooling accident.
This issue was also significant
due to the length of time that the condition existed in each unit and because
the condition could
have resulted in a common-mode failure of the HPSI system.
For the reasons discussed above, these violations are classified in accordance with the
"General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement
Policy) NUREG-1600, as a Severity Level III problem.
In accordance with the Enforcement
Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III
problem.
Because your facility has been the subject of escalated enforcement actions within
the last 2 years', the NRC considered whether credit was warranted for Identification and
Corrective Action in accordance
with the civil penalty assessment
process in Section VI.B.2 of
the Enforcement Policy. Although the performance of a surveillance test led to the discovery of
this problem, the NRC concludes that the problem was identified as a result of an event in
which the misassembly of Valve 1PSIA-V404 caused the shutdown cooling heat exchanger
outlet relief valve to liftand discharge at a rate of approximately 120 gpm to the equipment
drain tank.
In accordance with Enforcement Policy guidance for event-revealed violations, the NRC
considered the ease of discovery, whether the event occurred as the result of a self-monitoring
effort, the degree of initiative in identifying the problem, and whether prior opportunities existed
to identify the problem to determine whether credit was warranted for identification. Any of
these considerations may be overriding if particularly noteworthy or particularly egregious.
The NRC has determined that the facility had numerous prior opportunities to identify the
problem.
Prior to the event, the facility had opportunities to identify the improperly assembled
HPSI check valve in Unit 2 which caused an unexpected level decrease
in a safety injection
tank during two reactor startups conducted in October 1997.
However, the decreases
were not
thoroughly investigated and the startups continued.
On August 31, 1989, NRC Information Notice 89-62 alerted licensees that an essential step for the assembly of the subject valves was
missing and if not implemented, could result in the disc assembly being suspended
too low
inside the body of the valve. And finally, during a review of NRC Information Notice 88-60,
"Check Valve Inservice Testing Program Deficiencies," the facilityidentified that its IST program
did not require reverse-flow testing of the HPSI pump discharge check valves, and on July 26,
1992, a reverse-flow requirement was added to facility testing procedures.
However,
appropriate acceptance
criteria were not added to this requirement and thus the magnitude of
the leakage and the consequences
caused by vertically misaligned check valves in all three
'he NRC issued a Severity Level III problem with a $50,000 civil penalty on July 10, 1998,
(EA 98-131) for violations involving falsification of records in 1993.
l
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Arizona Public Service Company
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units was not identified. The NRC concludes that the multiple prior opportunities to identify the
problem were overriding and that credit for identification is not warranted.
The NRC has determined that, on the whole, your immediate corrective actions taken were
sufficient to restore compliance with the regulations a'nd the long term action taken should
prevent recurrence of this issue.
Specifically, you corrected the misassembled
valves in Units 1
and 2, tested both trains of valves in all three units, revised the maintenance procedures
governing the subject valves, revised the surveillance test to add acceptance
criteria for reverse
flow through the valves, and reviewed the IST check valve program to ensure that this condition
did not affect other valves at the facility. Therefore, the NRC has determined that credit for
~
corrective actions is warranted.
Accordingly, to emphasize the importance of ECCS subsystem operability, prompt identification
and comprehensive correction of significant conditions adverse to quality, and appropriate
acceptance
criteria and procedures,
I have been authorized, after consultation with the Director,
Office of Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of
Civil Penalty (Notice) in the base amount of $55,000 for the Severity Level III problem described
above and in the Notice.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response.
The NRC willuse your response,
in part, to
determine whether further enforcement action is necessary
to ensure compliance with
regulatory requirements.
As the result of the information provided at the September
14, 1998, predecisional enforcement
conference and our subsequent
deliberations, the following modifications were made to the
apparent violations described in the NRC inspection report and discussed at the conference.
These apparent violations were also handed out at the conference, and listed in Enclosure 3 to
our letter dated September 23, 1998.
In addition, some editorial changes were made for
clarification:
(1)
Apparent Violations 1 and 2, involving failure to meet the requirements of Technical Specification 3.5.2 to have an operable HPSI system flowpath, have been combined as
Violation A in the enclosed Notice. An additional example of the violation was included,
as you identified in Licensee Event Report 50-528/98006, Revision 1, for Unit 3.
(2)
Apparent Violation 2.a., involving failure to meet the 1-hour requirement of Technical Specification 3.0.3 to make preparations to perform an orderly shutdown on May 13,
1998, has been withdrawn on the basis of your position that Operations personnel
considered Valve 1PSIA-V404 operable because
previous surveillance testing data was
considered to provide reasonable
assurance
that the valve would function. The
circumstances surrounding this issue revealed communication weaknesses
between the
operations and engineering organizations and could have, under different
circumstances,
resulted in a situation in which the requirements of your Technical
Specifications would not have been satisfied.
However, in this particular situation, we
agree with your position that a violation did not occur.
(3)
Apparent Violation 3, involving failure to implement the requirements of Technical Specification 6.8.1 to make an entry in the Control Room Log following abnormal
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Arizona Public Service Company
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decreases
in safety injection tank level on October 10 and 28, 1997, is not being cited.
We consider this to be another example of the violation previously cited in NRC
Inspection Report 50-528/98-11; 50-529/98-11; 50-530/98-11.
As discussed during the
predecisional enforcement conference and documented
in your presentation materials,
you are continuing to implement corrective actions to preclude recurrence of these
violations, and your corrective actions should be comprehensive enough to correct the
example identified here.
Accordingly, no additional violation is cited.
(4)
Apparent Violations 4.d and 4.e have been revised to be cited as examples of
inadequate procedures under 10 CFR Part 50, Appendix B, Criterion V, "Instructions,
Procedures,
and Drawings," rather than examples of inadequate corrective actions
under Criterion XVI,"Corrective Action."
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its
enclosure, and your response willbe placed in the NRC Public Document Room.
Sincerely,
Ellis W. Mersch
Regional Admi 'rator
Docket Nos.: 50-528; 50-529; 50-530
License Nos.: NPF-41; NPF-51; NPF-74
Enclosures:
1. Notice of Violation and Proposed
Imposition of Civil Penalty
2. NUREG/BR-0254 Payment Methods (Licensee only)
cc w/Enclosures:
State of Arizona
Mr. Steve Olea
Arizona Corporation Commission
1200 W. Washington Street
Phoenix, Arizona 85007
Douglas K. Porter, Senior Counsel
Southern California Edison Company
Law Department, Generation Resources
P.O. Box 800
Rosemead,
California 91770
I
Arizona Public Service Company
Chairman
Maricopa County Board of Supervisors
301 W. Jefferson, 10th Floor
Phoenix, Arizona 85003
Aubrey V. Godwin, Director
Arizona Radiation Regulatory Agency
4814 South 40 Street
Phoenix, Arizona 85040
Angela K. Krainik, Manager
Nuclear Licensing
Arizona Public Service Company
P.O. Box 52034
Phoenix, Arizona 85072-2034
John C. Horne, Vice President
Power Supply
El Paso Electric Company
2025 N. Third Street, Suite 220
Phoenix, Arizona 85004
Terry Bassham,
Esq.
General Counsel
El Paso Electric Company
123 W. Mills
El Paso, Texas
79901
Mr. Robert Burt
Los Angeles Department of Water & Power
Southern California Public Power Authority
111 North Hope Street, Room 1255-B
Los Angeles, California 90051
Mr. David Summers
Public Service Company of New Mexico
Albuquerque, New Mexico 87102
Mr. Brian Katz
Southern California Edison Company
14300 Mesa Road, Drop D41-SONGS
San Clemente, California 92672
Mr. Robert Henry
Salt River Project
6504 East Thomas Road
Scottsdale, Arizona 85251
Arizona Public Service Company
bcc w/Enclosure(s):
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