IR 05000528/1984053

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Insp Rept 50-528/84-53 on 841031-1108,28 & 1219.No Violations or Deviations Noted.Major Areas Inspected:Tech Spec Comparsion to as-built Plant Features & Administrative Controls for Plant Equipment/Configuration
ML17298B845
Person / Time
Site: Palo Verde Arizona Public Service icon.png
Issue date: 01/04/1985
From: Chaffee A, Chaffee A, Crews J, Andrea Johnson, Miller L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17298B844 List:
References
50-528-84-53, NUDOCS 8501290700
Download: ML17298B845 (12)


Text

U. S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report No.

Docket No.

50-528/84-53 50-528 License No.

CPPR-141 Licensee:

Arizona Public Service Company P.

O. Box 21666 Phoenix, Arizona 85036 Facility Name:

Palo Verde Nuclear Generating Station - Unit

Inspection at:

Palo Verde Site, Wintersburg, Arizona Inspection conducted:

October 31 - November 8, 1984, November 28 and December 19, 1984 Inspectors:

. Cr ws, Senior Nuclear Engineer Date igned Pf'.

D. Johnson, Enforcement Officer Date igned Approved By:

A.

.

Cha fee, Chief, Reactor Projects Branch

. Miller, Chief, Reactor Projects Section

3 P5 Date Signed l

/ss Date Signed Summary:

Ins ection on October 31 - November

November 28 and December

1984 Re ort No. 50-528/84-53 I

Areas Ins ected:

Routine unannounced inspection by regional based inspectors of technical specification comparison to as-built plant features and

'dministrative controls for plant equipment/configuration.

The inspection involved 98 inspector-hours onsite by three NRC inspectors.

Results:

No violations or deviations were identified within the areas examined.

8501290700 8SOiii PDR ADOCK 05000528

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DETAILS Persons Contacted

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E. Van Brunt, Jr., Vice President Nuclear Production E. Ide, Director, Corporate Quality Assurance B. Earner, Assistant Vice President, Nuclear Production R. Bynum, Plant Manager/Director, Nuclear Operations M. Allen, Manager Operations J.

Adney, Unit Superintendent (Unit 2)

E. Younger, Unit Superintendent (Unit 1)

A. Bernier, Operations Administrative Supervisor N. Russo, equality Audits and Monitoring Supervisor L. Hamilton, (}uality Monitoring Supervisor S. Karmarkar, Systems Engineer Mechanical Buzard, Assistant Shift Supervisor Callaghan, Shift Supervisor R. Niedermeyer, Shift Supervisor Hopkins, (}uality Engineer Bimson, equality Engineer

-"Attended exit interview on November 6, 1984.

+Attended exit interview on November 8, 1984.

Licensee Develo ment of Technical S ecifications At the time of the current inspection the licensee was in the process of the final review and comment phase of the Technical Specifications for Palo Verde Unit l.

Discussions were held with licensee representatives directly involved in the licensee's effort over the past approximately two years to insure the accuracy and validity of technical specification conformance to the as-built systems, components and design features of the facility.

In general, licensee representatives described the ongoing effort to include reviews and comments by all Arizona Public Service Company (APS)

departments and applicable staff involved in design, construction and operational activities as well as the principal contractual participants in such activities, e.g.,

Bechtel Power Company (Bechtel)

and Combustion Engineering Corporation (CE).

Records of a series of meetings between various intra-company participants as well as Bechtel and CE have been maintained, and were made available for the NRC inspector's examination.

The licensee's effort was to culminate in the written certification by all parties to the preparation and review effort during the week of November 26, 1984, and subsequent certification by the licensee to NRC that same week.

Based upon their examination of records and discussion with licensee representatives it was concluded that the licensee had established and

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implemented a comprehensive effort involving the principal licensee staff as well as contract participants in ensuring the accuracy and validity of the technical specifications for Palo Verde, Unit 1.

3.

Technical S ecification Verification - Conformance to As-Built Plant

~Ss ferns A review was conducted to verify that the as-built systems of the facility were consistent in terms of equipment components and design features with the selected Iimiting Conditions for Operation (LCO) and Surveillance Requirements of the Appendix A Technical Specifications (Proof and Review copy).

The review was accomplished on a sampling basis through a combination of (a) examining official plant drawings, (b)

system walkdowns to verify equipment and component installation, (c)

review of plant procedures including surveillance test procedures and (d)

discussions with licensee personnel.

The following findings resulted:

A.

3.5.2 ECCS SUBSYSTEMS An apparent discrepancy was observed in that the surveillance xequirements indicated that flow balance in the ECCS system would be verified by verification of specified throttle valves being in the proper position.

In fact flow orifices were installed for this purpose in some locations.

On December 19, 1984, this discrepancy was observed to have been corrected by a revision to the draft technical specifications.

B.

3.6.1.3 CONTAINMENT AIRIOCKS No discrepancies were identified.

C.

3.7.1.2 AUXILIARYFEEDMATER SYSTEM No discrepancies were identified.

D.

3.7.1.3 CONDENSATE STORAGE TANK No discrepancies were identified.

E.

3.7.3 ESSENTIAL COOLING MATER No discrepancies were identified.

(See paragraph 4, regarding controls over sealed, locked or otherwise secured values)

F.

3.7.4 ESSENTIAL SPRAY POND SYSTEM No discrepancies were identified.

G.

3.7.5 ULTIMATE HEAT SINK No discrepancies were identifie 'J

V H.

3.7.7 CONTROL ROOM ESSENTIAL FILTRATION SYSTEM No discrepancies were identified.

I.

3.7.9 SNUBBERS No discrepancies were identified.

J.

3.8.1 A. C.

SOURCES An apparent discrepancy was observed regarding the surveillance test requirement (4.8.1.1.2.d.6.c)

to verify automatic diesel generator trip bypass.

Whereas the draft technical specifications indicated that non-essential trips were bypassed with concurrent loss of offsite power and safety injection actuation signal, in fact a

design change had been implemented such that each signal by itself would cause the nonessential trip to be bypassed.

A subsequent change in the draft technical specifications was verified by NRC inspectors on December 19, 1984.

This change corrected the discrepancy discussed above.

4.

Confi uration Control An assessment was made of the licensee's administrative controls to insure proper plant configuration (i.e.,

system alignments)

associated with maintenance or operational activities.

The assessment consisted of a review of station procedures and discussions with licensee personnel.

a.

Documents Reviewed The following procedures and related documents were reviewed.

t Procedure 73AC-92204, Surveillance Testin Rev. 0, dated February 15, 1984, 'including PCN 1, dated July 17, 1984.

Proposed Procedure 40AC-92215, Station Ta in and Clearances (0 eratin License)

Rev. 0.

Procedure 410P-12211, Mode Chan e Check-List Rev.

0, dated October 23, 1984.

Procedure 73AC-92205, Tem orar Modification Control Rev, 2, dated October 31, 1984.

Procedure 40AC-92202, Conduct of Shift 0 erations Rev. 2, dated October 19, 1984.

Procedure 40AC-02206, Iocked Valve and Breaker Control Rev. 2, dated October 22, 1984.

0 eratin De artment Instruction

S stem Status Control Rev.

3, dated October 30, 198

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Procedure 30AC-92201, Work Control Rev. 6, dated February 8, 1984, including PCN8 dated October 8, 1984.

b.

~Findin n

Overall the configuration control program, as defined by the procedures reviewed, appeared to reflect considerable effort on the part of the licensee.

Significant, guidance was contained in these procedures.

It was observed by the NRC inspector that many of the procedures in this area are either in the process of being issued or have undergone recent revision.

Licensee representatives stated that operator training on these procedures would be held shortly, and in any event prior to operating license issuance.

With the exception of the following, no significant weaknesses were observed by the NRC inspector.

The licensee has no apparent administrative control over control room key lock valves.

The licensee does not have provisions in administrative procedures for independent verification of the completeness of return to service partial system alignments.

The licensee's current controls may allow the position of certain critical valves (e.g.,

V478, V476 [HPSI pump discharge valves]

and V435, V447 [LPSI pump discharge valves]) to go unverified for as long as 18 months.

In response to the above observations, the licensee representatives committed to the following actions.

An administrative procedure will be developed prior to initial criticality to require Senior Licensed Operator (SRO) approval of key locked valve operation in the Control Room.

P two-party system to verify proper partial system alignments.

This procedure revision will require one individual to prepare a partial system alignment, and an independent SRO to approve the proposed alignment prior to implementation.

This revision will be implemented prior to initial criticality.

Procedures will be developed, prior to initial criticality, to require that a portion of critical locked valves be verified each month, such that all will be verified every 18 months.

In addition, these procedures will be "fine tuned" such that certain high risk valves will be checked first (e.g., valves with no monthly Technical Specification surveillance, valves with no remote indication and no system operability functional check which shows conclusively based, on system flow that the valves are properly positioned).

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The licensee actions appear to be acceptable.

These items are closed.

5, Exit Interview meetings were held with those persons indicated in paragraph 1 at the conclusion of the inspection, during which inspection findings as discussed above were discusse ~ ~