ML20044E008
| ML20044E008 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/05/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20044E007 | List: |
| References | |
| 50-528-93-15, 50-529-93-15, 50-530-93-15, NUDOCS 9305210184 | |
| Download: ML20044E008 (3) | |
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l NOTICE OF VIOLATION Arizona Public Service Company Docket Nos. 50-528, 50-529, and 50-530 l
Palo Verde Units 1, 2, and 3 License Nos. NPF-41, NPF-51, and NPF-74 During an NRC inspection conducted during the week of April 5 through April
.f 9,1993, two violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are identified below:
A.
Technical Specification 6.8.1 states in part that, " Written procedures shall be established, implemented, and maintained covering... applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978...."
Appendix A of Regulatory Guide 1.33 specifies procedures for procedure adherence in performing tests and inspections.
Palo Verde Nuclear Administrative and Technical Manual (NATM) Procedure OlPR-0AP01, Revision 01.03, " Administrative Controls Program," Section 3.7.3 requires that, " Procedures shall be used, adhered to and en forced. "
1.
Palo Verde NATM Procedure 81AC-0DC01, Revision 04.03, " Procedure for Design Changes," Section 3.2.3.d states, " Design... output l
(e.g., drawings, databases) documents affected by the design modification and the required changes shall be prepared or j
identified as part of the design change package."
Contrary to the above, Design Change Package (DCP) 2XE-SG-163, f
" Main Steam Isolation Valve Control Console Power," did not identify that Key drawing 02-E-PKB-001, " Elementary Diagram 125V DC Class lE Power System," was affected by the design modification
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and was required to be changed. DCP 2XE-SG-163 was completed in Unit 2 in December 1991. As of April 5,1993, Key drawing 02-E-PKB-001 had not been updated.
l 2.
Palo Verde NATM Procedure 81AC-0DC01, Section 3.2.6 states that, i
" Documents, processes, training, etc., affected by the design modification...shall be identified, recorded, statused, and updated...."
Contrary to the above, as of April 5,1993, NATM Procedure 42AL-l 2RKIA, " Panel B01A Alarm Response," which was affected by DCP 2XE-SG-163, had not been identified, recorded, statused, or updated.
3.
Palo Verde Design Change Package (DCP) 2XE-SG-163 and implementing i
Unit 2 Work Order 519134 required that the retest for the DCP be performed in accordance with Generic Procedure 70GT-0ZZ01, Revision 1, Preliminary Change Notice 1, " Electrical Circuit Test." Section 7.2 of Procedure 70GT-0ZZ01 required that, "Only i
Operations / Systems Engineers or Maintenance PC [ Planning j
Coordinator] shall place N/A's in data sheets where steps are not applicable for ' required testing."
9305210184 930505 PDR ADOCK 05000528 G
PDR f
2 Contrary to the above, during performance of 70GT-0ZZ01 for Work I
Order 519134 in Unit 2, the performing mechanic placed an N/A l
beside a number of procedure testing steps, including verification l
of proper wiring, with no evidence of System Engineer / Maintenance l
PC concurrence. The steps that were "NA'd" or " marked N/A" were i
not performed. The completed data was inadequate to demonstrate that one of two new 125 volt direct current power sources had been tested to ensure that it would properly supply power to the main i
steam isolation valves.
This is a Severity Level IV violation (Supplement 1), applicable to Unit 2.
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B.
10 CFR Part 50.71, Records and Reports, states in Section e(4) that,
" Subsequent [ Updated Final Safety Analysis Report (UFSAR)] revisions must be filed annually or 6 months after each refueling outage....
The revisions must reflect all changes up to a maximum of 6 months prior to the date of filing."
1 Palo Verde NATM Procedure 81AC-0DC01, Section 3.1.7 states, " Licensing
[
document changes shall be prepared during development of the appropriate' design change packages...and processed in accordance with the requirements of the associated licensing document change implementing procedui.
'e.g., UFSAR...)."
Contrary to the above, as of April 5,1993, the UFSAR, Revision 5, dated l
March 1993, did not include changes to Unit 2 required by DCP 2XE-SG-163, which was completed in Unit 2 in December 1991, during the Unit 2 l
R3 outage. The Unit 2 R3 outage was completed in January 1992.
r This is a Severity Level IV violation (Supplement 1), applicable to Unit l
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 t ith a copy to the Regional Administrator, Region V, and a copy to the i
NRC Resident Inspector at the Palo Verde Nuclear Generating Station, within 30 t
days of the date of the letter transmitting this Notice of Violation (Notice).
i 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 wi:1 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, the Commission may issue an order or a demand i
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'I for information 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'
-l time.
Dated at Walnut Creek, California i
this 5th day of May 1993 l
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