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Category:NOTICE OF VIOLATION OF A REGULATION
MONTHYEARML20196D6391998-11-20020 November 1998 Notice of Violation from Insp on 981019-24.Violation Noted: Licensee Submitted Physical Security Plan Rev 40 Which Contained 10 Changes to Physical Security Plan That Decreased Safeguard Effectiveness of Plan ML20236N0381998-07-10010 July 1998 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:On or About 980310, Unit 3 Operators Failed to Demonstrate Operability of Operable Offsite Power Circuits ML20138C1071997-04-22022 April 1997 Notice of Violation from Insp on 970317-21.Violation Noted:Safeguards Documents Discovered Outside Protected Area Unsecured in Terminated Employee Desk ML20059K7021994-01-0505 January 1994 Notice of Violation from Insp on 931102-1206.Violation Noted:On 931103,operators in Unit 1 Failed to Monitor Reactor Coolant Sys Level While Draining for Approx Eight Minutes ML20058D3311993-10-19019 October 1993 Notice of Violation from Insp on 930817-0920.Violation Noted:Between 911225-920113,licensee Engineer Worked More than 72 Hrs in 7 Day Period,Exclusive of Shift Turnover Time W/O Authorization by Manager ML20059C9811993-10-15015 October 1993 Notice of Violation from Insp on 920719-0824 & 1001-1102. Violation Noted:Licensee Determined That Records Required to Be Maintained by NRC Not Complete or Accurate in All Matl Respects ML20057E7301993-09-16016 September 1993 Notice of Violation from Insp on 930713-0816.Violation Noted:Emergency Operating Procedures Used to Identify & Mitigate SG Tube Rupture Were Inadequate ML20057C5941993-09-0909 September 1993 Notice of Violation from Insp on 930621-0709.Violation Noted:Despite Licensee Chemistry Manager Receipt of from Combustion Engineering Identifying Potential for Dilution of Sample,Licensee Failed to Establish Measures ML20056C8451993-07-0101 July 1993 Notice of Violation from Insp on 930426-0514.Violation Noted:Sgtr Event Involving RCS Leakage Greater than 44 Gpm & Previous Condition Involving RCS Leakage Greater than Charging Pump Capacity,Not Classified as SAE ML20056C8501993-07-0101 July 1993 Notice of Violation from Insp on 930427-0531.Violation Noted:Licensee Failed to Meet Surveillance Requirements for Testing Snubbers in Plants ML20127B0961992-12-22022 December 1992 Notice of Violation from Insp on 921026-30 & 1116-20. Violation Noted:On 921110,procedures Were Not Adhered to in That Survey Not Performed or Documented to Illustrate Impact of Cumulative Dose Rates ML20126E0241992-12-0808 December 1992 Notice of Violation from Insp on 921005-09.Violation Noted: Licensee Lost All Meteorological Instrumentation for Approx 7 H But Failed to Declare Unusual Event within 30 Minutes of Loss of Instrumentation on 920822 ML20126B9031992-12-0404 December 1992 Notice of Violation from Insp on Stated Date.Violation Noted:Boric Acid Make Up Pump Discharge Check Valves CHN-V154 & CHN-155 Were Not in Licensee IST Program & Were Not Being Tested Individually ML20128C2671992-11-0303 November 1992 Notice of Violation from Insp on 920825-0930.Violation Noted:On 920903,CR Personnel Inattentive to Plant Instrumentation & Failed to Respond to Abnormal Alarm Indication,Resulting in Flooding of Auxiliary Bldg ML20205E8191987-03-13013 March 1987 Notice of Violation from Insp on 861201-12 ML20199D7451986-06-16016 June 1986 Notice of Violation from Insp on 860113-24 & 0203-14. Violations Noted:Masonry Block Walls Incorrectly Classified as Quality Class & Several Class 1E Components Exhibited Poor Workmanship & Inadequate Vendor Product Quality ML20205M5801986-05-0505 May 1986 Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $100,000 Due to Security Violations IA-86-363, Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $100,000 Due to Security Violations1986-05-0505 May 1986 Partially Deleted Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $100,000 Due to Security Violations ML20138B5661985-10-0808 October 1985 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:Program Not Established to Ensure Capability to Obtain & Analyze post-accident Containment Atmosphere Samples IR 05000801/20090081985-10-0404 October 1985 Notice of Violation from Insp on 850801-0908 IR 05000528/20070071985-08-13013 August 1985 Notice of Violation from Insp on 850528-0707 IR 05000603/20070311985-08-0808 August 1985 Notice of Violation from Insp on 850603-0731 IR 05000530/20070011985-07-30030 July 1985 Notice of Violation from Insp on 850530-0701 ML20132D5381985-07-0808 July 1985 Notice of Violation from Insp on 850429-0503 & 13-17 ML20127K8401985-06-11011 June 1985 Notice of Violation from Insp on 850325-29 ML20058D2881982-07-0909 July 1982 Notice of Violation from Insp on 820420 ML20054N0621982-06-25025 June 1982 Notice of Violation from Insp on 820329-0402 1998-07-10
[Table view] Category:TEXT-INSPECTION & AUDIT & I&E CIRCULARS
MONTHYEARIR 05000528/19990121999-06-30030 June 1999 Insp Repts 50-528/99-12,50-529/99-12 & 50-530/99-12 on 990502-0612.Two Violations Occurred & Being Treated as Noncited Violations.Major Areas Inspected:Operations,Maint, Engineering & Plant Support IR 05000528/19990051999-04-21021 April 1999 Partially Withheld Insp Repts 50-528/99-05,50-529/99-05 & 50-530/99-05 on 990322-26 (Ref 10CFR73.21).No Violations Noted.Major Areas Inspected:Licensee Physical Security Program.Details Withheld IR 05000528/19980131998-11-20020 November 1998 Partially Withheld Insp Repts 50-528/98-13,50-529/98-13 & 50-530/98-13 on 981019-24 (Ref 10CFR73.21).Violations Noted. Major Areas Inspected:Licensee Physical Security Program, Including Mgt Support,Security Audits & Plans & Procedures ML20196D6391998-11-20020 November 1998 Notice of Violation from Insp on 981019-24.Violation Noted: Licensee Submitted Physical Security Plan Rev 40 Which Contained 10 Changes to Physical Security Plan That Decreased Safeguard Effectiveness of Plan ML20236N0381998-07-10010 July 1998 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:On or About 980310, Unit 3 Operators Failed to Demonstrate Operability of Operable Offsite Power Circuits IR 05000528/19970231997-10-20020 October 1997 Partially Deleted Insp Repts 50-528/97-23,50-529/97-23 & 50-530/97-23 Containing Safeguards Info (Ref 10CFR73.21) on 970922-26.No Violations Noted.Major Areas Inspected:Physical Security Program IR 05000528/19970081997-04-22022 April 1997 Partially Withheld Insp Repts 50-528/97-08,50-529/97-08 & 50-530/97-08 on 970317-21.Violations Noted.Major Areas Inspected:Plant Support.Portions Withheld (Ref 10CFR73.21) ML20138C1071997-04-22022 April 1997 Notice of Violation from Insp on 970317-21.Violation Noted:Safeguards Documents Discovered Outside Protected Area Unsecured in Terminated Employee Desk IR 05000528/19960201997-01-31031 January 1997 Partially Deleted Insp Repts 50-528/96-20,50-529/96-20 & 50-530/96-20 on 961007-11 (Ref 10CFR73.21).No Violations Noted.Major Areas Inspected:Licensee Vehicle Barrier Sys Program Utilizing Ti 2515/132,dtd 960118 IA-98-273, Partially Deleted Investigation Rept 5-93-023R.No Noncompliance Noted.Investigation Conducted to Determine Whether Technician Vacancy at Plant Had Been Discriminated by Plant1994-05-11011 May 1994 Partially Deleted Investigation Rept 5-93-023R.No Noncompliance Noted.Investigation Conducted to Determine Whether Technician Vacancy at Plant Had Been Discriminated by Plant ML20236U9511994-05-11011 May 1994 Partially Deleted Investigation Rept 5-93-023R.No Noncompliance Noted.Investigation Conducted to Determine Whether Technician Vacancy at Plant Had Been Discriminated by Plant ML20059K7021994-01-0505 January 1994 Notice of Violation from Insp on 931102-1206.Violation Noted:On 931103,operators in Unit 1 Failed to Monitor Reactor Coolant Sys Level While Draining for Approx Eight Minutes IR 05000528/19930481994-01-0404 January 1994 Insp Repts 50-528/93-48,50-529/93-48 & 50-530/93-48 on 931102-1206.Violations Noted.Major Areas Inspected:Plant Activities,Surveillance Testing,Plant Maint,Lifting of Main Steam Safety Valve & mid-loop Operations IR 05000528/19930471993-12-16016 December 1993 Insp Repts 50-528/93-47,50-529/93-47 & 50-530/93-47 on 931108-10.No Violations Noted.Major Areas Inspected:Licensee Preparations for 940101 Implementation of Changes to 10CFR20 as Set Forth in Fr 56FR23377,dtd 910521 IR 05000528/19930491993-12-15015 December 1993 Insp Repts 50-528/93-49,50-529/93-49 & 50-530/93-49 on 931115-19.No Violations Noted.Major Areas Inspected:Reviewed Licensee Implementation of Containment LLRT Program & Licensee Actions for Open Items Identified in Insp Rept IR 05000528/19930501993-12-0202 December 1993 Meeting Repts 50-528/93-50,50-529/93-50 & 50-530/93-50 on 931115.No Violations Noted.Major Areas Discussed:Status & Schedule of EOP Rewrite Program & Assessment of Recent Operator Performance Issues IR 05000528/19930431993-11-19019 November 1993 Insp Repts 50-528/93-43,50-529/93-43 & 50-530/93-43 on 930921-1101.No Violations Noted.Major Areas Inspected:Plant Activities,Engineered Safety Features Walkdowns,Surveillance Testing & Plant Maint IR 05000528/19930461993-11-17017 November 1993 Insp Repts 50-528/93-46,50-529/93-46 & 50-530/93-46 on 930913-1029.No Violations Noted.Major Areas Inspected:Review of ISI of ASME Code Class 1,2 & 3 Welds & Licensee Unit 1 SG Eddy Current Insp Activities IR 05000528/19930321993-11-17017 November 1993 Insp Repts 50-528/93-32,50-529/93-32 & 50-530/93-32 on 931018-22.No Violations Noted.Major Areas Inspected: Implementation of Licensee Program to Meet Commitments to GL 89-10, Safety-Related Motor-Operated Valve.. IR 05000528/19930391993-10-28028 October 1993 Insp Repts 50-528/93-39,50-529/93-39 & 50-530/93-39 on 930823-27.No Violations or Deviations Noted.Major Areas Inspected:Open Items in Emergency Preparedness Program Area ML20058D3311993-10-19019 October 1993 Notice of Violation from Insp on 930817-0920.Violation Noted:Between 911225-920113,licensee Engineer Worked More than 72 Hrs in 7 Day Period,Exclusive of Shift Turnover Time W/O Authorization by Manager ML20058D3571993-10-15015 October 1993 Insp Repts 50-528/93-40,50-529/93-40 & 50-530/93-40 on 930817-0920.Violations Noted.Major Areas Inspected:Review of Plant Activities,Engineered Safety Features Walkdowns, Surveillance Testing & Plant Maint ML20059C9811993-10-15015 October 1993 Notice of Violation from Insp on 920719-0824 & 1001-1102. Violation Noted:Licensee Determined That Records Required to Be Maintained by NRC Not Complete or Accurate in All Matl Respects IR 05000528/19930371993-10-0101 October 1993 Insp Repts 50-528/93-37,50-529/93-37 & 50-530/93-37 on 930920-24.One Unresolved Item Identified.Major Areas Inspected:Licensee Radiation Protection Program & Followup of Safety Evaluation Rept IR 05000528/19930421993-09-29029 September 1993 Insp Repts 50-528/93-42,50-529/93-42 & 50-530/93-42 on 930830-0903.No Violations Noted.Major Areas Inspected: on-site Followup of LER in Accordance W/Insp Procedure 92700, Onsite Followup of Written Repts.. PNO-V-93-017, on 930922,util Informed NRC That re-review of Eddy Current Test Data Identified Midspan Indications in Two Tubes in Unit 3 SG31.Review Being Performed to Determine If Nonquantifiable Indications Exist.Telcon W/Nrc Scheduled1993-09-22022 September 1993 PNO-V-93-017:on 930922,util Informed NRC That re-review of Eddy Current Test Data Identified Midspan Indications in Two Tubes in Unit 3 SG31.Review Being Performed to Determine If Nonquantifiable Indications Exist.Telcon W/Nrc Scheduled IR 05000528/19930361993-09-22022 September 1993 Insp Repts 50-528/93-36,50-529/93-36 & 50-530/93-36 on 930830-0903.Non-cited Violation Identified.Major Areas Inspected:Review of Licensee Access Authorization Program ML20057E7301993-09-16016 September 1993 Notice of Violation from Insp on 930713-0816.Violation Noted:Emergency Operating Procedures Used to Identify & Mitigate SG Tube Rupture Were Inadequate ML20057E7451993-09-10010 September 1993 Insp Repts 50-528/93-35,50-529/93-35 & 50-530/93-35 on 930713-0816.Violations Noted.Major Areas Inspected:Plant Chemistry,Fire Protection,Security & Outage Operations ML20058H4231993-09-10010 September 1993 Errata to Insp Repts 50-528/93-35,50-529/93-35 & 50-530/93-35 on 930713-0816.Provides Omitted Signature Page & Attachments IR 05000528/19930291993-09-0909 September 1993 Insp Repts 50-528/93-29,50-529/93-29 & 50-530/93-29 on 930621-0709.Violations Noted.Major Areas Inspected:External Exposure Control,Internal Exposure Control,Control of Radioactive Materials & Rms ML20057C5941993-09-0909 September 1993 Notice of Violation from Insp on 930621-0709.Violation Noted:Despite Licensee Chemistry Manager Receipt of from Combustion Engineering Identifying Potential for Dilution of Sample,Licensee Failed to Establish Measures IR 05000528/19930331993-09-0303 September 1993 Insp Repts 50-528/93-33,50-530/93-33 & 50-530/93-33 on 930802-06.No Violations Noted.Major Areas Inspected:Failure Rate of Crews & Operators During Sept 1992 & Mar 1993 Requalification Exams PNO-V-93-016, on 930828,plant Restarted After Refueling Outage That Proceeded Tube Rupture Event on 930314.Cause of Tube Rupture Was Due to Intergranular Attack.Unit 3 Operating at 100% Power1993-08-30030 August 1993 PNO-V-93-016:on 930828,plant Restarted After Refueling Outage That Proceeded Tube Rupture Event on 930314.Cause of Tube Rupture Was Due to Intergranular Attack.Unit 3 Operating at 100% Power IR 05000528/19930271993-08-26026 August 1993 Insp Repts 50-528/93-27,50-529/93-27 & 50-530/93-27 on 930726-30.No Violations Noted.Major Areas Inspected:Water Chemistry & Radiochemistry Programs,Including Water Chemistry & Health Physics Confirmatory Measurements PNO-V-93-014, on 930811,NRC Was Informed That APS Supervisor Declined to Hire Contract Employee Because Employee Raised Safety Concerns at Plant & Elsewhere.Judge Ruled APS Discriminated Against Employee1993-08-11011 August 1993 PNO-V-93-014:on 930811,NRC Was Informed That APS Supervisor Declined to Hire Contract Employee Because Employee Raised Safety Concerns at Plant & Elsewhere.Judge Ruled APS Discriminated Against Employee IR 05000528/19930241993-08-0606 August 1993 Page 27 Inadvertently Omitted from NRC Inspection Repts 50-528/93-24,50-529/93-24 & 50-530/93-24 ML20056E3691993-07-29029 July 1993 Insp Repts 50-528/93-24,50-529/93-24 & 50-530/93-24 During Wks of 930524,0607 & 28.No Violations Noted.Major Areas Inspected:Corrective Actions for Previously Identified Followup & Enforcement Items & LER Followup ML20056C8501993-07-0101 July 1993 Notice of Violation from Insp on 930427-0531.Violation Noted:Licensee Failed to Meet Surveillance Requirements for Testing Snubbers in Plants ML20056C8451993-07-0101 July 1993 Notice of Violation from Insp on 930426-0514.Violation Noted:Sgtr Event Involving RCS Leakage Greater than 44 Gpm & Previous Condition Involving RCS Leakage Greater than Charging Pump Capacity,Not Classified as SAE ML20056C8511993-06-30030 June 1993 Insp Repts 50-528/93-12,50-529/93-12 & 50-530/93-12 on 930427-0531.Violations Noted.Major Areas Inspected:Review of Plant Activities,Emergency Operating Procedures,Surveillance Testing,Plant Maint,Snubber Testing & Core Reload Analysis IR 05000528/19930281993-06-30030 June 1993 Enforcement Conference Repts 50-528/93-28,50-529/93-28 & 50-530/93-28 on 930603.Violations Noted.Major Areas Inspected:Licensee Analyses of Several Apparent Violations of NRC Requirements Re Emergency Classification PNO-V-93-009D, on 930325,leakage from Reactor Coolant Sys Occurred.Cause of Leak Not Determined1993-03-25025 March 1993 PNO-V-93-009D:on 930325,leakage from Reactor Coolant Sys Occurred.Cause of Leak Not Determined IR 05000528/19920411993-01-13013 January 1993 Insp Repts 50-528/92-41,50-529/92-41 & 50-530/92-41 on 921103-1214.No Violations Noted.Major Areas Inspected: Review of Plant Activities,Surveillance Testing & Plant Maint IR 05000528/19920381992-12-22022 December 1992 Insp Repts 50-528/92-38,50-529/92-38 & 50-530/92-38 on 921026-30 & 1116-20.Violations Noted.Major Areas Inspected: Licensee Radiation Protection Program,Surveys & Occupational Exposure During Unit 3 Refueling Outage ML20127B0961992-12-22022 December 1992 Notice of Violation from Insp on 921026-30 & 1116-20. Violation Noted:On 921110,procedures Were Not Adhered to in That Survey Not Performed or Documented to Illustrate Impact of Cumulative Dose Rates IR 05000528/19920341992-12-0808 December 1992 Insp Repts 50-528/92-34,50-529/92-34 & 50-530/92-34 on 921005-09.Violations Noted.Major Areas Inspected:Status of Emergency Preparedness Program & Followup on Open Items ML20126E0241992-12-0808 December 1992 Notice of Violation from Insp on 921005-09.Violation Noted: Licensee Lost All Meteorological Instrumentation for Approx 7 H But Failed to Declare Unusual Event within 30 Minutes of Loss of Instrumentation on 920822 ML20126B9031992-12-0404 December 1992 Notice of Violation from Insp on Stated Date.Violation Noted:Boric Acid Make Up Pump Discharge Check Valves CHN-V154 & CHN-155 Were Not in Licensee IST Program & Were Not Being Tested Individually IR 05000528/19920361992-12-0404 December 1992 Insp Repts 50-528/92-36,50-529/92-36 & 50-530/92-36 on Stated Dates.Violations Noted.Major Areas Inspected:Ist of Check Valves in safety-related Sys & Performance of Unit 3 ISI 1999-06-30
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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.
4 4
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