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Forwards Insp Repts 50-528/93-35,50-529/93-35 & 50-530/93-35 on 930713-0816 & Notice of Violation.Expresses Concern Re Two Instances of Failure to Properly Document Surveillance Test Deficiencies
	ML20058H915
Person / Time
Site:	Palo Verde
Issue date:	12/03/1993
From:	Vandenburgh C; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Conway W; ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML20058H410	List: ML20058H406; ML20058H423; ML20058H915;
References
	NUDOCS 9312130270
	Download: ML20058H915 (2)
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UMITED STATES

Reissued on: DEC 3 7993

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F 'l MUCLEAR REGULATORY COMMISSION '

y n ,E REGION V

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[- 1450 MARIA LANE

WALNUT CREEK, CAUFORNIA 94596-53GB

(EPis1sr

Docket Nos. 50-528, 50-529, and 50-530 '

License Nos. NPF-41, NPF-51, and NPF-74

Arizona Public Service Company

P.O. Box 53999, Station 9082

Phoenix, Arizona 85072-3999 :

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Attention: Mr. W. F. Conway

Executive Vice President, Nuclear

SUBJECT: NOTICE OF VIOLATION -

NRC INSPECTION REPORT NOS. 50-528/529/530/93-35

This refers to the inspection conducted by J. Sloan, H. Freeman,

A. MacDougall, B. Olson, and F. Ringwald of this office, and T. Alley, of the

Department of Energy, on July 13 through August 16, 1993. The inspection

included a review of activities authorized for your Palo Verde facility. At ;

the conclusion of the inspection, the findings were discussed with those

members of your staff identified in the enclosed report.

Areas examined during the inspection are identified in the report. Within

these areas, the inspection consisted of selective examinations of procedures

and representative records, interviews with personnel, and observation of

activities in progress.

Based on the results of this inspection, certain of your activities appeared

to be in violation of NRC requirements, as specified in the enclosed Notice of

Violation (Notice). These violations involved: (1) the failure of the Offsite

Safety Review Committee to review significant operational abnormalities

identified in 1991 in Steam Generator 22 involving abnormal track growth rates ,

in certain steam generator tubes and of a midspan tube crack, and (2) several .

inadequacies in the Emergency Operating Procedures (EOP) identified during the

steam generator tube rupture in Unit 2 in March 1993. We noted that the i

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second violation regarding E0P deficiencies had been corrected and those

actions were reviewed during this inspection. Therefore, no response with

respect to this matter is required.

We also identified two instances of a failure to properly document

surveillance test deficiencies. This is of concern because similar examples !

were previously identified in the Notice of Violation issued with NRC '

Inspection Report 50-528/93-26.

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response to the first i

violation. In your response to Violation A, you should document the specific

actions taken and any additional actions you plan to prevent recurrence. :

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After reviewing your response to this Notice, including your proposed

corrective actions and the results of future inspections, the NRC will

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determine whether further NRC enforcement action is necessary to ensure !

compliance with NRC regulatory requirements. '

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In accordance with 10 CFR Part 2.790 of the NRC's " Rules of Practice," a copy

of this letter and the enclosures will ba placed in the NRC Public Document

Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required i

by the Paperwork Reduction Act of 1980, Pub. L. No.96-511. i

Should you have any questions concerning this inspection, we. xill be glad to l

discuss them with you. ;

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Sincerel

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C. A. VanDenburgh, Chief

Reactor ProjectVBranch i

Enclosures: .

1. Notice of Violation

2. Inspection Report Numbers 50-528/93-35, 50-529/93-35, and 50-530/93-35 ,

cc w/ enclosures: l

Mr. Steve Olea, -Arizona Corporation Commission ,

Mr. James A. Beoletto, Esq., Southern California Edison Company

Mr. Charles B. Brinkman, Manager, Washin'gton Nuclear Operations

Mr. Aubrey Godwin, Director, Arizona Radiation Regulatory Agency (ARRA)

Chairman, Maricopa County Board of Supervisors !

Mr. Jack R. Newman, Esq., Newman & Holtzinger P. C. :

Mr. Curtis L. Hoskins,' Executive Vice President and Chief Operating Officer,

Palo Verde Services '

Mr. Roy P. Lessey, Jr., Esq., Akin, Gump, Strauss, Hauer and Feld

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Mr. Bradley W. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld

Mr. Thomas R. Bradish, Manager, Nuclear Regulatory Affairs, APS

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NOTICE OF VIOLATION i

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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 i

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During an NRC inspection conducted on July 13, through August 16, 1993, two ;

violations of NRC requirements were identified. In accordance with the ,

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 ;,

CFR Part 2, Appendix C, the violations are listed below: ;

A. Unit 2 Technical Specification 6.5.3.4.f requires that the Offsite Safety e

Review Committee (formerly the Nuclear Safety Group) review significant ;

operating abnormalities or deviations from normal and expected l

performance of unit equipment that affect nuclear safety. :

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Contrary to the above, as of March 14, 1993, the Offsite Safety Review '

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Committee / Nuclear Safety Group had'not reviewed abnormal crack growth '

rates in certain tubes in Unit 2 Steam Generator 22 and the

identification of a mid-span crack in another tube also in Steam

Generator 22 (location R117/C54), which were significant abnormalities ,

from normal and expected performance. The cracks had been identified in

the third refueling outage (1991) up to 80% through-wall which had not !

been detected in the previous refueling outage. In addition, one axial :

crack was found to be in the free span area between a horizontal support

and a diagonal support and had grown from being undetectable _to 75% l

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through-wall in one operating cycle. j

This is a Severity Level IV violation (Supplement I) applicable to

Unit 2. f

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B. 10 CFR Part 50, Appendix B, Criterion V, requires that activities :

affecting quality be prescribed by documented instructions, procedures, j

or drawings, of a type appropriate to the circumstances. j

Contrary to the above, as of March 14, 1993, emergency operating )

procedures used to identify and mitigate a steam generator tube rupture !

in Unit 2 were inadequate, in that: ;

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(1) For event diagnosis, the diagnostic logic tree of Emergency l

Procedure 42EP-2E001 relied only on radiation monitors that were ~i

actually in alarm at that time, rather than considering radiation !

monito. trends or alarms received previously. i

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(2) The alert and alarm setpoints for the condenser exhaust and main !

steam line radiation monitors were based on offsite release limits, l

rather than being based on identification of a steam generator tube j

rupture event. .

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(3) The portion of Functional Recovery Procedure 42EP-2R008 for l

mitigation of a steam generator tube rupture event was based on {

evaluation of alarms at the point in time that the step was being j

performed, rather than being continuously applicable, preventing j

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performance of the appropriate guidance in the Functional ' Recovery

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Procedure.

(4) Functional Recovery Procedure 42EP-2R008 did not provide guidance on

the amount of time to allow the steam generator blowdown radiation i

nonitor to respond after steam generator blowdown was restored. I

(5) Functional Recovery Procedure 42EP-2R008, Appendix FQ (Pressure and

Inventory Control), which could be entered during certain steam !

generator tube rupture events, did r>ot establish actions for reactor '

coolant system depressurization.

This is a Severity Level IV violation (Supplement I) 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 V, and a copy to the

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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 violation A: (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. 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 C eek, California

this Mday of f WW,1993

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ML20058H915

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