ML20205E819

Notice of Violation from Insp on 861201-12

ML20205E819
Person / Time
Site:	Palo Verde
Issue date:	03/13/1987
From:	Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20205E799	List: IR 05000529/1986033 ML20205E794 ML20205E819
References
50-529-86-33, 50-530-86-27, NUDOCS 8703310022
Download: ML20205E819 (6)

Text

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x APPENDIX A ,

NOTICE OF VIOLATION Arizona Nuclear Power Project- Docket Nos. 50-528 and 50-529 Post Office Box 52034 License Nos. NPF-41 and No. NPF-51

' Phoenix, Arizona 85072-2034 As a result of the inspection conducted December-1-12, 1986, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), the following violations were identified.

A. Paragraph 2.C.7 of the Palo Ve'rde Unit 1 operating license states in part:

"(7) Fire Protection Program (Section 9.5.1, SSER 6, SSER 7 and SSER 8)

(a) APS shall maintain in effect all provisions of the approved- '

fire protection program as described in the Final Safety Analysis Report for the facility through Amendment No. 14, and as provided in the SER through Supplement 8, subject to provisions (b) and (c) below.

Paragraph 2.C.6 of the Palo Verde Unit 2 operating license states in part:

"(6) Fire Protection Program (Section 9.5.1, SSER 6, SSER 7 and SSER 8)

APS shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, as supplemented and amended, and as approved in the SER through Supplement 8, subject to the following provision:

The Palo Verde FSAR covering both Unit 1 and Unit 2 (Amendment 13) section 9.5.1.3 states in part:

"9.5.1.3 Safety Evaluation The primary evaluation of the compliance of the PVNGS design with applicable regulatory and industry standards has been presented in Appendix 9B, " Fire Protection Evaluation Report."

The Palo Verde " Fire Protection Evaluation Report" section IV states in part:

"PVNGS provides a combination of fire barriers, ... to ensure that one train of redundant systems necessary to achieve and maintain cold shutdown is free from fire damage....

...PVNGS utilizes one of the following:

Three-hour rated fire barrier 8703310022 070313 PDR ADOCK 00000529 G PDR

. 2 One-hour rated fire barrier for one division and automatic fire suppression Palo Verde has installed a number of fire barriers, both one and three hours, using TSI thermolag as the barrier material. "TSI Technical Note 20684 Thermo-lag 330 Fire Barrier System, Installation Procedures Manual, Power Generating Plant Application"Section I.D.2 states in part:

"2. To prevent thermal shorts into the fire barrier system, all penetrations (i.e. secondary supports, electrical or seismic) into the fire barrier system, should be fire protected to the same level of fire resistance as the raceway for a distance of 18 inches, minimum, as measured from the outer surface of the fire barrier, covering all continuous paths."

Contrary to the above:

On December 4 and since receiving their operating licenses, Palo Verde Units 1 and 2 operated with both 1 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> thermolag fire barriers which did not protect intruding conduit or steel into the barrier system for a distance of 18 inches, which were required to separate redundant safe shutdown divisions.

Specific conduits with intruding steel not protected include but are not limited to:

2EZC2EARR12 -

The Atmospheric Dump Valve (VPI (2) and the NpSupply Valve Operator Power Supply (2))

2EZCAEARK77 -

Power Supply to the steam supply valve (IN FA 73) to the AFW Turbine 2EZCAEARK79 -

Power Supply to the AFW Turbine Trip (IN FA 73) Throttle Valve; Power Supply to the AFW regulating valve motor 2EZC2EARK05 -

Power Supply to the Steam Supply MOV to (IN FA 73) the AFW Turbine In addition in Fire Area 73, the motor driven auxiliary feed pump room, a hourly fire watch inspection, required by technical specification 3/4.7.12 for Unit 1 & 2 as a compensatory measure for inoperable fire barriers, was not in place.

This is a Severity Level IV Violation (Supplement I).

B. PVNGS Unit-2 Technical Specification 6.8.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, February 1978, Appendix A 1.c., recommends Equipment Control as a procedure to be implemented.

~

, . 3 PVNGS Procedure 30AC-9ZZ01, " Work Control," Appendix H requires compressed gas cylinders and equipment stored or located in safety related areas to be enclosed / secured away from safety related equipment.

Contrary to the above, during the NRC inspection conducted on December 1-12, 1986, the following conditions were observed:

Test breakers mounted on casters were stored unsecured in the Train-B Essential Bus Switchgear Room.

Bisco Seal injection unit was stored unsecured in the area of the component cooling water surge tank at the auxiliary building 120' level.

Compressed gas bottles were stored unsecured at the auxiliary building 100' levels in the vicinity of the containment hydrogen monitor panel.

Compressed gas bottles were tied to safety related piping and to the containment hydrogen purge piping.

Compressed gas bottles were tied to safety related raceway supports at the auxiliary building 120' level.

This is a Severity-Level IV violation (Supplement I).

C. 10 CFR 50, Appendix B, Criterion II requires, in part, that the licensee establish a quality assurance program to provide control over activities.

The PVNGS Operations Quality Assurance Criteria Manual requires that the Operations Quality Assurance Program comply with the position set forth in Regulatory Guide 1.33, which endorses ANSI N18.7/ANS 3.2 " Quality Assurance for the Operational Phase of Nuclear Power Plants."

ANSI N18.7/ANS 3.2, Section 5.2.15, states: "Those participating in any activity shall be made aware of, and use, proper and current instructions, procedures, drawings, and engineering requirements for performing the activity."

Contrary to the above, the current procedure revision was not used in the performance of the following Surveillance Tests:

41ST-1HP02, " Containment Hydrogen Analyzer Functional Test" - Performed November 12, 1986 42ST-2RC04, "RCS Vent Path Operability" - Performed January 24, 1986 This is a Severity Level IV violation (Supplement I).

. 4 Pursuant to the provisions of 10 CFR 2.201, Arizona Public Service is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.

MAR 13 Ni gfp[ ~

Dated S. Richards Engineering Section Chief l

l t . - .-_-- _ _ . . - . -. _____ . __- _ - . - . -_ - - .-.. ---

APPENDIX B

SUMMARY

OF TEAM INSPECTION FINDINGS Design Deficiency One and three hour fire barriers using thermolag had not been qualified because the original design criteria for thermolag applications was not supported by a tested configuration (Apparent Violation, 50-529/86-33-09).

Sufficient documentation had not been compiled during the design of cable tray supports to document engineering judgement. An analysis had been performed to confirm with a 95/95 confidence that the undocumented judgements were correct.

(0 pen,50-529/86-33-02) ,

Design Change Process Following the implementation of design changes, Technical Specification Surve111anceshavebeenperformedusingoutdated(unrevised) procedures because appropriate administrative controls had not been implemented to assure procedures were changed subsequent to the facilities incorporation of the design change (Apparent Violation, 50-529/86-33-13).

Procedural, Administrative and Operational deficiencies have not been resolved because the Engineering Evaluation Requests (EERs) system does not have a satisfactory means of dispositioning deficiencies requiring solutions that are not engineering related (0 pen, 50-529/86-33-03).

Operation / Maintenance Adequate controls had not been established to assure large transient equipment is properly secured in areas that contain safety related equipment (Apparent violation, 50-529/86-33-12).

For complex maintenance troubleshooting tasks, procedures lacked sufficient detail to assure corrective maintenance on or around safety related equipment was adequately controlled (0 pen, 50-529/86-11).

System's engineers had not regularly evaluated trends or reviewed surveillances and preventive or corrective maintenance on systems under their cognizance; therefore, comprehensive system performance evaluations had not been performed (0 pen, 50-529/86-33-05).

The documentation of corrective action for post trip reviews and information notices prior to mid 1986 was insufficient.

Quality Assurance The scope of quality assurance reviews for post construction design changes have not been sufficiently defined.

Deficiencies and departures from procedures identified during QA audits had been corrected; however, they had not in all cases been evaluated for impact on operations.

Quality Assurance reviews of the EER system were inadequate in that "for infomation" EER's had not been contained in the scope of the quality review.

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