ML20046D080

Notice of Violation from Insp on 930601-0712.Violation Noted:During Performance of Surveillance Test 36ST-9SB02 in Unit 1,workers Noted That pre-trip Indication Failed to Illuminate as Required by Procedure,But Failed to Mark Step

ML20046D080
Person / Time
Site:	Palo Verde
Issue date:	07/30/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20046D074	List: IR 05000528/1993026 ML20046D080
References
50-528-93-26, 50-529-93-26, 50-530-93-26, NUDOCS 9308160108
Download: ML20046D080 (3)

Text

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4 NOTICE OF VIOLATION Arizona Public Service Co.

Docket Nos. 50-528, 50-529, and 50-530 Palo Verde Units 1, 2, and 3 License Nos. NPF-41, NPF-51, and NPF-74 During an NRC inspection conducted on June 1 through July 12, 1993, four violations of NRC requirements were identified.

In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appenuix C, the violations are listed below:

1 A.

Unit 1 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented and maintained covering surveillance and test activitier "f safety-related equipment.

Procedure 73AC-9ZZ04, Revisin

.0', " Surveillance Testing," Step 3.9.3, requires that unsatisfactory drar; or data be marked "unsat," circled, and initialed.

In addition, the "as #aund" condition, the corrective action taken, and any maintenEnce work request / work order, TSCCR, CR/DR, or MNCR initiated, shall be documented in the surveillance test Log.

Contrary to the above:

i 1.

On June 23, 1993, during the performance of surveillance test 36ST-9SB02 in Unit 1, workers noted that the pre-trip indication failed to illuminate as required by the procedure, but failed to mark this step as "unsat" and did not document the deficiency in the surveillance test log.

2.

On June 30, 1993, during the performance of surveillance test 41ST-1SP02 in Unit 1, workers lioted that spray pond pump "B" discharge pressure was not within 50-55 psid as required by procedure step 8.2.'., but failed to mark the step "unsat" and failed to adequately describe the corrective action in the surveillance test log. This failure was elso not identified during supervisory review.

This is a Severity Level IV violation (Supplement 1) applicable to Unit 1.

B.

Unit 3 Technical Specification 6.8.1 requires, in part, that written procedures shall be established, implemented and mair.tained covering applicable procedures recommended in Appendix A of Regulatory Guide 1.33, February 1978.

1 Regulatory Guide 1.33, Appendix A requires, in part, that administrative procedures should be developed governing the review and approval of plant procedures.

1 9308160108 930730 PDR ADOCK 05000528 G

PDR

d Procedure 01AC-0AP02, Revision 02.02, " Review and Approval of Nuclear Administrative and Technical Procedures," Step 3.2.3.1, states that a 10 CFR Part 50.59 screening and evaluation shall be performed for any intent change procedure action. Section 4.1.13, Step 5, states that un intent change exists if the change alters the acceptance criteria applicable to Quality Class activities.

Contrary to the above, revisions were implemented to procedure 31ST-9DG02.

on September 12, 1992, and to procedure 31ST-9DG01 on March 5, 1993, that changed the criteria for a satisfactory surveillance test on the Emergency Diesel Generators without a 10 CFR Part 50.59 screening specified by procedure 01AC-0AP02.

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

C.

Units 1, 2, and 3 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, February,1978.

Regulatory Guide 1.33, Appendix A requires, in part, that specific procedures for the control of modification work should be prepared.

Procedure 81DP-0DC03, " Final Engineering," Design Evaluation checklist item 16, requires verification that adequate pre-operational and subsequent periodic test requirements have been appropriately specified.

Contrary to the above, on September 5,1991, verification of checklist item 16 was inadequate in that the pre-operational test requirements were not appropriately specified. The specified pre-operational test only considered the operational mode of the steam bypass control system and did not consider its test modes. This failure resulted in the inadvertent opening of five steam bypass control valves during subsequent testing.

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

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 V, and a copy to the NRC Resident Inspector at the facility that is the sab,iect 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

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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 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 time.

Dated at Walnut Creek, California this 32 day of.dt/W

, 1993 I

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