IR 05000528/1984056
| ML17298B841 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/07/1985 |
| From: | Clark C, Perez G, Wagner W, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17298B840 | List: |
| References | |
| 50-528-84-56, NUDOCS 8501250618 | |
| Download: ML17298B841 (44) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
50-528/84-56 Docket No.
50-528 License No. CPPR-141 Licensee:
Arizona Public Service Company P. 0. Box 21666 Phoenix, Arizona 85036 Facility Name:
Palo Verde Nuclear Generating Station Unit
Inspection at:
Palo Verde Construction Site, Wintersburg, Arizona Inspection conduc ed:
November 16-December 14, 1984 Inspectors:
W. J.
Wagner, actor n
tor G. Perez, Reac r Inspe t/~ ZH Date Signed y y$'s Date Signed Approved by:
C. Clark, Reactor Inspector T. Young, Jr.,
ief Engineering Sec ion Date Signed l 7ge Date igned
~Summ ar Ins ection on November 26-December 14, 1984 (Re ort No. 50-528/84-56)
Areas Ins ected:
Routine unannounced inspection by regional based inspectors of 50.55(e)
items and licensee programs for verification of quality-related activities.
The inspection involved 198 inspector-hours onsite by three NRC inspectors.
Results:
No violations or deviations were identified.
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DETAILS 1.
Persons Contacted
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Arizona Public Service Com an (APS)
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L. Hamilton, Quality Monitoring Supervisor B. Karner, Assistant Vice President, Nuclear Production E.
Van Brunt Jr., Vice President Nuclear Production I. Gross, Compliance Supervisor A. Souza, Assistant Corporate QA/QC Manager E. Ide, Corporate QA/QC Director J.
Bloom, Licensing Engineer E. Smith, Jr.,
Compliance Engineer M. Allen, Operations Manager M. Russo, Manager, Quality Audits and Monitoring Ozment, Startup Admin. Tech Support Manager Firguson, Lead Startup Engineer Bernier, Operations Support Supervisor G. Papworth, Operations Engineering Manager D. Roman, Lead Operations Engineer C. Sterling, Supervisor Configuration Control B. Fugitt, Lead Quality Investigator A, Tallorin; Quality Investigator W. Iossings, Supervisor Quality Investigations Moring, Quality Investigation Group Engineer M. Eastman, Quality Assurance Engineer Herman, Quality Investigator M. Nelson, Security Manager Daley, QA Engineer Provost, QA Engineer b.
Bechtel Power Cor oration (Bechtel)
N-D. R. Hawkinson, Project QA Manager
"-P. R. Huber, Project Quality Coordinator
$/ H. D. Zoster, Project QC Engineer L. Bowles, Lead Welding QC Engineer A. Harris Jr., Personnel Administrator R. Hegedus, Lead QA Engineer Subcontractors S. Karimi, Quality Assurance Engineer 9 R. E. Vote, Assistant Project QA Manager 0 W. J. Stubblefield, Field Construction Manager fj T. L. Horst, Project Field Engineer-Denotes those individuals attending the exit interview on December 7,
1984.
j/Denotes those individuals attending the exit interview on December 14, 198.
Licensee Action on
CFR 50.55(e) Construction Deficiencies DER The following potential 50.55(e) construction deficiencies were identified by the licensee's representative as closed.
The items were reviewed by the inspector to determine the thoroughness of the licensee's corrective action.
The items marked with an asterisk ('") were judged by the licensee to be reportable under the 50.55(e) criteria; the others were considered not reportable.
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(Closed)
DER No. 80-30 Bor -Warner Motor 0 crated Gate Valve Failed To Close Under 0 eratin Conditions Revision 1 of the final report submitted by the licensee identifies a Borg Warner 3-inch motor operated gate valve, at Duke Power, that failed to close when actuated under operating conditions of 2485 psi at 650 F with a flow rate of 220,000 lbs. per hour of steam.
The potential failure was determined to be inadequate guiding of the valve gate.
This valve is used at Palo Verde as an isolation valve in the safety injection long-term recirculation lines.
The safety function of this valve is to open against differential pressure initiating simultaneous cold-leg and hot-leg injection.
The valve is closed to terminate simultaneous cold-leg and hot-leg injection.
The valve was tested by Borg Warner to demonstrate the valve's operability under the design requirements, at Palo Verde, of 2500 psi differential pressure and 600 gpm flow rate.
The valve successfully passed this operability test opening and closing fully.
b.
The valve operability was verified acceptable in Unit 1 at Palo Verde, during pre-operational testing.
Test results Report 91PE-1S108 (Rev.
1, TCN 9) for Unit 1, received startup manager approval on September 27, 1984.
This item is closed.
(0 en)
DER No. 83-51:"
Turbine-Driven AFW Pum Vibration Unacce table Pum
"Head-Ca acit " and "Desi n Flow" Performance The licensee's final report of September 25, 1984 identified three separate deficiencies on the turbine-driven auxiliary feedwater pump.
These were:
1)
Pump shaft and suction piping vibration; 2)
Unacceptable pump "Head-Capacity" performance; and 3)
Pump Tailed to meet "Design Flow" capacity acceptance criteria.
The first deficiency was subsequently documented in DER 84-49, and its disposition shall be addressed in the report on DER 84-49.
The second and third deficiencies are addressed belo ~ $
t
,
Per FSAR Section 10.4.9.1.G, the auxiliary feedwater (AFW) pump shall be designed to deliver feedwater at a rate of 875 GPM to t e steam generators for removal of decay heat from the reactor coolant system under accident conditions.
The guaranteed performance of the pump, per FSAR Table 10.4-6, is 1010 GPM at 3280 feet TDH (1420 PSIG).
The 1010 GPM allows for 135 GPM minimum recirculation flow to protect the pump with a net design flow of 875 GPM to the steam generator.
Th lt f the initial AFW hot functional test procedure eresu so APPl) did 91HF-lAFOl indicated that the turbine-driven AFW pump (IMAFAP
) i not meet the above flow/head acceptance criteria.
The pump was run with all flow directed to steam generator Number 1, with the block valves on the minimum recirculation path and the surveillance path l
d and the flow to steam generator Number
.2 isolated.
Both the c ose an e
ow motor-driven and turbine-driven (} class AFW pumps failed oto meet the ed 875 GPM of feedwater acceptable capacity requirements.
The required
o e
flow to the steam generator is based on Combustion Engineering (C-E)
interface requirements.
The root cause identified for failure to meet head flow capacity to the steam generator, was identified as leakage at a surveillance test path block valve (1PAFAVD18), which reduced the flow to the steam generator.
The surveillance test path was provided to perform full flow periodic testing of the pump.
However, there are no requirements for a full flow surveillance test loop in the ASME codes and the technical specifications.
The overall system operability is demonstrated at 18 month intervals by directly pumping to the steam genera r
.
t generators.
Therefore the licensee installed a spectacle blind flange in the surveillance path and removed the block val
valve to eliminate a potential leak path.
Retest of the subject pump zn ica e i d
t d it could deliver the required flow at rated head.
SARCN 1165 was issued to delete reference to the surveil alance flow path from the FSAR.
Durin the initial AFW pump testing, the piping system connected to both the motor-driven and turbine-driven g class pumps experienced hydraulic resonance when operating in the miniflow configuration.
Th l t on of this problem was achieved by increasing the e reso u ion deliver mini ow recircu a i fl
'rculation rate.
This reduced the feedwater e i y
The rate to the steam generator from 875 GPM to 750 GPM.
e DER 84-49.
G-E has documentation of this change is included in comp ete eir a l t d th 'alysis of the reduced AFW system delivery rate (750 SARCN 1272 GPM) to the steam generator, and found it acceptable.
SAR has been initiated to supersede SARCN 1239, to change the delivery I
there existed no deficiency regarding the pumps'bility n summary, from the fact to mee e r t th equired flow rate.
The problem stemmed that, while AFW system was being modified to trouble shooot and resolve vibration pro ems, bl testing was conducted in accordance with
the original test acceptance criteria of 850 GPM flow to the steam generator.
Pending NRR review and approval of SARCN 1165 and SARCN 1272, this item will remain open.
(Closed)
DER No. 83-80 Main Feedwater Isolation Valves Failed to Close in 5 Seconds The final report submitted by the licensee on August 23, 1984 describes the failure of the Main Feedwater Isolation Valve (MFWIV)
to close in 5 seconds as specified in the FSAR.
The nitrogen charge was increased from 3400 psig to 3500 psig and the "G" closed speed control valve was changed from 3/4 open to fully open to shorten the closing time.
An analysis of the mass/energy release during a MSIB inside containment was done to evaluate the consequences of changing the required closing time from 5 seconds to 10 seconds.
A FSAR change (SARCN 1174)
has been submitted for this.
The new required closing time is 10-seconds under operational pressure, temperature, and flow rate.
Anchor Darling has stated if the valve closes in 8-seconds under no flow conditions the valve will meet the 10-second closing time requirement.
The review of the FSAR change and the 8-second maximum closure time under static test conditions, has been submitted to NRR for evaluation.
The same problem identified above on the main feedwater isolation valves (MFWIVs) was encountered with the mainsteam isolation valves (MSIVs) and addressed in DER Number 84-50.
DER Number 84-50 was revised on August 14, 1984 to include the MFWIVs originally addressed in DER Number 83-80.
On November 8, 1984 the licensee was notified by Bechtel that the action performed in accordance with DER Number 83-80 was not sufficient to correct the stated problem with the MFWIVs.
The MFWIV problem will now be addressed and corrected per disposition of DER Number 84-50.
Since the licensee has identified during this inspection, that the final report for DER 83-80 will be revised to show final disposition will be addressed during disposition of DER Number 84-50, this item is closed.
(0 en)
DER No. 83-82-Im ro er Cable Bend Radius The licensee's final report of August 10, 1984 identified that during the NRC inspection of October 31 through November 4, 1983 at PVNGS, it was revealed that some of the cables between the diesel generator and its control cabinet, in Units 1 and 2 violated the minimum bending radius.
These cables have bend radii of 4 to 16 inche f tl "
Installation specification 13-EH-301, Revision 8, requires that these installed cables have a minimum bending radius of 16.08 inches.
This specification is based on ICEA (insulated cable engineers association)
specification S-68-516 which establishes a minimum bending radius of 12 X O.D. for tape shielded cable.
Tests were conducted by Anaconda Wire and Cable Company to evaluate the safety significance of these cables which violate the minimum bending radius.
Based on these tests, Anaconda established a new minimum bending radius criteria of 6 X O.D for 1/C shielded medium voltage cable and 10 X O.D. for 3/C shielded medium voltage cable.
On September 25, 1984 Region V requested NRR to assume lead responsibility for evaluation of the new minimum cable bending radius criteria established by Anaconda.
The cause of this condition was attributed to improper installation and inadequate inspection by quality control due to the lack of bend radius templates.
A cable bend radius inspection program was developed, and performed in Units 1 and 2, Unit 3 inspection could not be verified completed as of the date of this inspection.
Based on the above inspections the licensee has replaced some cable, and dispositioned some "use-as-is" per new minimum bending cable radius criteria established by Anaconda.
Installation specifications have been modified to include permanent training bend radius requirements per new Anaconda criteria noted above.
Bechtel construction has conducted formal training for field engineers and (}C inspectors on bend radius requirements and use of bend radius templates.
Appropriate training is to be provided to all craft personnel involved in cable installation.
Until all inspections are complete on each unit and NRR has completed its evaluation of the new minimum cable bending radius criteria established by Anaconda, this item will remain open for the applicable units.
(Closed)
DER Number 84-24-"
Limitor ue Valve 0 erators Loose on Bor -Warner Valve Bodies The final report submitted by the licensee on October 23, 1984 describes that there have been several instances of limitorque valve operators loosening from their Borg Mourner valve bodies after the bolts securing them had been torqued and inspected.
A majority of these instances were identified after the original motors were replaced with new actuators supplied by C-E.
The vendor instruction manuals specifies either that the valve be in the full open position when installing the limitorque operator or the hand wheel be rotated in the open direction until the operator reaches the valve yoke before the hex bolts are tightened.
Failure to adhere to the instructions described above could cause the valve motor operator hex bolts to be tightened with the force transferred to the valve seat, leaving the operator loose on the
valve yoke.
The probable cause of the loose limitorque operators on Borg Warner valves was failure to properly follow the instruction manuals.
The 3.icensee has issued instructions to properly fasten the initial seven(7)
loose limitorque operators found to their valves.
In addition to the seven (7) valves identified as having loose operator to valve bolts, there are fifty-six (56) additional Borg Marner valves with limitorque operators installed in Unit 1.
The licensee has issued instructions to inspect the fifty-six (56)
additional Borg Warner valves in Unit 1 and to properly fasten any loose limitorque operators found to their valves.
After completion of inspecting the additional fifty-six (56) valves, the licensee stated they would review the inspection results and determine if action is required for Units 2 and 3.
To preclude recurrence of the above problem, supplier document change notices have been issued to instruction manuals to provide additional clarification regarding valve position when tightening the operator bolts.
The importance of attention to details and proper implementation of DCPs have been included in training sessions for craft and (}C personnel, and preventive maintenance procedures are being revised to include additional instructions on inspection for loose parts, especially bolts.
This item is closed.
(Closed)
DER No. 84-26 4.16 KV SMGR Circuit Bracket and Plun er Interlock Bolt Assembl Dama ed The final report submitted September 21, 1984, by the licensee stated that circuit breakers in class IE 4.16 KV switchgear were damaged during functional tests by improper use and/or improper installation of an adjustable test link.
Since adjustable test links are not used in any other class IE distribution centers, this problem is considered to be limited to the class IE 4.16 KV switchgear.
The root cause of bent 'C'lips (or L-shaped CAMS) was due to improper use and adjustments by jobsite personnel, due to inadequate procedures.
The above final report submittal was incomplete since the licensee had not recognized that Unit 1 inspections were still required by startup field report (SFR) No.
1XX-013/NCR SE-4413, or identified that this was an applicable document.
On September 27, 1984, the inspector informed the licensee that the above SFR/NCR was still open with outstanding actions for DER 84-26.
The licensee stated they would reopen the DER.
The licensee committed on November 1,
1984 to issuing a supplement to the final report to include the identification of NCR SE-441 The inspector examined the licensee training procedures, training records and control system for issue of breaker test links.
The inspector noted that the licensee held additional training, revised both training and work procedures to re-emphasize controlled use of test links.
Also controls have been placed on the issue of test links on the job site, to ensure only properly trained and authorized personnel install or use breaker test links.
The inspection and corrective actions addressed in NCR SE-4413, were completed December 3,
1984.
This item is closed.
(0 en)
DER No. 84-48-'m ro er Material for Pi e Plu s on MSIV Limit Switches.
The final report submitted October 18, 1984 by the licensee, identified that the main steam isolation valves (MSIVs) and feedwater isolation valves (FMIVs) have hydraulic actuators provided with NAMCO EA 180 series limit switches.
The switches are mounted on the valve actuator yoke and provide valve position indication in the control room and affect the status of the 4-way hydraulic pilot valves which control the MSIV and FMIV open/close function.
Several NAMCO EA 180 series limit switches on Unit 1 mainsteam bypass and blowdown isolation valves were replaced because their actuating arms could not be tightened.
The switch actuating arm is mounted to the lever shaft by a splined fit, this fit is tightened and secured by an expansion plug threaded into the end of the lever shaft.
Improper plug installation can result in looseness at the splined fit.
This looseness on MSIVs and FWIVs would permit angular displacement between the arm and the lever shaft with the possible result that the switch would not perform its safety function of indicating valve position in the control room and actuating the hydraulic pilot valves which control the MSIVs and FMIVs.
NAMCO, the switch manufacturer, has determined that EA 180 series switches with date codes 1983, 2083, 2183, 2783, 2883, and 2983 (stamped on the conduit hub of the switch housing) might be susceptible to the above condition.
The root cause identified for the above problem is gall.ing of the stainless steel expansion plug threads with the stainless steel internal threads in the lever shaft, which prevent acceptable insertion of the expansion plug.
Installation of an expansion plug that has been silver plated provides dissimilar metals and eliminates the threads galling problem and therefore a looseness at the splined fit.
The licensee identified and inspected all Unit 1 Q class valves with the suspected NAMCO EA 180 limit switches, for acceptable expansion plug installation.
After the above inspection it was directed that the existing expansion plugs in the identified switch/valve assemblies in Units 1, 2 and 3 shall be replaced with silver plated expansion plugs, regardless of original inspection results.
The
>I
0
licensee identified during this inspection, that the above work would be accomplished prior to fuel load.
Pending expansion plug replacement in the identified switch/valve assemblies in Units 1, 2 and 3, this item will remain open for the applicable units.
(0 en)
DER 84-49>"
Auxiliar Feedwater S stem Ex eriences H draulic Resonance The final report submitted September 26, 1984 by the licensee identified that during preoperational testing of the auxiliary feedwater pumps, the piping experienced hydraulic resonance when operating in the normal mini-flow configuration.
During additional testing for DER 83-51 and the above reported condition, it was observed that this unstable condition disappeared when either the mini-flow was increased or the first stage block valve was closed.
CE specifies that auxiliary feedwater be delivered to the steam generators at a minimum rate of 875 gpm.
This corresponds to a
maximum bypass flow of 135 gpm under normal conditions.
CE has proposed increasing bypass flow to 260 gpm which eliminates the hydraulic resonance.
However, this decreased the flow to the steam generators to 750 gpm.
SARCN 1272 was initiated to supersede SARCN 1239, to change the delivery rate to the steam generators in the FSAR document.
The licensee informed NRR of the proposed SAR change, which also effects closure of DER Number 83-51, and stated it was scheduled to be issued December 3,
1984.
Pending NRR review and approval of SARCN 1272, this item will remain open.
(Closed)
DER Number 84-50:
Main Steam and Feedwater Isolation Valves Failed to Close in S ecified Time The final report submitted by the licensee described the failure of the main steam isolation valves (MSIVs) to close in 5 seconds and the main feedwater isolation valves (MFWIVs) to close in 10 seconds (changed from 5 seconds to 10 seconds per SARCN 1174)
as specified in the FSAR.
The MFWIVs failures were originally reported in DER 83-80, and then on November 8, 1984 the licensee was notified by Bechtel that the corrective action for MFWIVs failure would be dispositioned in DER 84-50 along with the corrective actions for the MSIVs failures.
The corrective actions provided in DER 83-80, included increasing the MFWIVs closing time requirements from 5 seconds to 10 seconds per SARCN 1174.
The review of the FSAR change and the 8 second maximum closure time under static test conditions, has been submitted to NRR for evaluation.
The main purpose of the MSIVs and MFWIVs is to protect against a
broken steam line or feedwater line. If one of the lines should break, all of the valves are immediately closed.
The closure time
is important to safety because a steam line break could cause overpressurization of the containment building and possible release of radioactive material to the atmosphere.
The MSIVs and MFWIVs are manufactured by the Anchor/Darling Valve Company (A/DV) and are normally held open with hydraulic pressure supplied by a pump and a nitrogen (N2) filled accumulator.
During the fast close operation, hydraulic oil flows from the accumulator to the valve operator propelled by the nitrogen.
The reason for the valves'ailure to close in the required time was lack of sufficient hydraulic fluid in the accumulator caused by an incorrect "precharge pressure vs temperature" curve used for nitrogen precharging.
The manufacture has attributed the lack of oil to incorrect nitrogen precharge in the accumulator.
If the N2 precharge pressure is too high, full charging will occur before sufficient hydraulic oil volume is pumped into the accumulator.
The actuator is most susceptible to this condition when charging at high ambient temperature when the precharge is near maximum.
The hydraulic accumulator precharge pressures are temperature-related; increased nitrogen temperature increases the nitrogen pressure.
The original "Precharge Pressure vs Temperature" curve provided by the valve manufacturer in the instruction manual did not provide adequate oil reserve in the accumulator over the entire precharge temperature range.
Based upon field testing, this curve was revised and simulated verification of the new curve was conducted.
The mass of nitrogen was adjusted and the valves were operated satisfactorily over the range of the new curve.
Using the revised curve and the new precharge pressure provided by A/DV, all MSIVs and MFWIVs were retested and found to close within the specified 4.2 and 8.0 seconds, respectively.
To preclude recurrence of the above reported valve failures, the licensee has taken the following action:
(1)
The nitrogen precharge pressure-temperature curves for both the MSIVs and MFWIVs have been revised and incorporated in the A/DV instruction manual.
(2)
N2 accumulator low pressure alarm set point for both the MSIVs and MFWIVs has been changed from 4800 psig to 5000 psig in the set point document.
(3)
N accumulator normal operating pressure for both the MSIVs and KRIVs has been changed from 5000 to 5200 psig and incorporated in the A/DV instruction manual.
(4)
Instructions have been issued to implement the N2 accumulator low pressure alarm set point change in Units 2 and 3.
As of the date of this inspection, the following corrective action initiated by DER Number 83-80 will remain the sam f I
(1)
The closing speed control valve "G" in the MFWIV actuator will be set in the fully-open position, as updated in the A/DV instruction manual.
(2)
The 10 second closing time requirement for the MFWIV, initiated
- by SARCN 1174.
NRR review and approval of SARCN 1174 is required.
(3)
The revision to the CE interface document to reflect the
second time requirement.
Based on actions identified above, this item is closed.
Note:
DER 84-84 was issued after the initial issue of DER 84-50, and the corrective action included changing the required closure times for the MSIVs and MFWIVs for reasons unrelated to this DER.
The Unit, 1 MSIVs and MFWIVs tested closing times were within these new recommended time changes and documentation will be updated as described in DER 84-84.
As identified in DER Number 83-80 and DER 84-50 NRR approval of SARCN 1174 and the 8 second maximum closure time under static test condition, is considered a followup item for Units 1, 2 and
(followup Item 528/84-56-01).
(0 en) Der Number 84-51" Turbine Driven AFW Pum Failed to Start from Ambient The licensee's final report of September 26, 1984 identified that the Terry Turbine which drives the auxiliary feedwater (AFW) pump AFA-P01 trips on overspeed when starting from a cold, ambient
'ondition.
The turbine-driven pump is one of the two essential g-class pumps which are required to perform the following.
(1)
To maintain water inventory in the steam generators during emergency operation when the main feedwater system is inoperable.
(2)
To provide feedwater to the steam generators for the removal of decay heat from the reactor coolant system under accident conditions.
In addition, the turbine-driven AFW pump has the unique safety design requirement that it shall be available in the event of a loss of AC power.
During an emergency shutdown condition, following the initiation of an Auxiliary Feedwater Actuation Signal (AFAS), the steam supply valves receive a signal to open in order to start the steam turbine.
Upon receipt of an AFAS signal, the solenoid-operated bypass valves open to bring the turbine up to idle speed prior to full steam admission.
An adjustable Agastat relay provides a time delay prior to opening the supply'valves.
In the original design the idle speed was set at 1300 rpm and the steam supply valves opened five seconds after=the solenoid bypass valves received a signal to ope Evaluations have indicated that the five-second delay is not sufficient to allow for the warming up of the lines and pump casing and to attain the turbine idle speed.
The licensee has identified that the solution to this problem is to'ake the necessary design changes in order to establish the turbine idle speed and place the turbine on governor control prior to the admission of full steam flow.
This objective is being accomplished by the implementation of the following modifications.
(1)
The 5-second delay time has been changed to 10 seconds.
(2)
The discharge piping from the two solenoid bypass valves has been routed to a single orifice with an injection point closer to the turbine.
(3)
The idle speed was reduced from 1300 rpm to 800 rpm.
(4)
The governor ramp start has been delayed until the steam admission valves are full open.
(5)
The condensate drains on both the turbine casing and the steam supply piping are being modified to increase the capacity of the low point drain system to eliminate the condensate generated during the warm-up period prior to a cold start.
The changes described in Items (1) through (4) above have been implemented and the turbine has undergoing five successful cold starts.
The average time required for the turbine to start from cold and reach rated speed has been 19 seconds.
Combustion Engineering has performed an analysis and has accepted a 30-second interface requirement in lieu of the previously established 20 seconds for delivery of the rated feedwater flow to the steam generators following the generation of an AFAS.
Design change packages have been implemented for Unit 1, 2 and 3, to cover items (1) through (5) above.
SARCN 1272 was scheduled to be issued December 3,
1984 to supersede SARCN 1239, to reflect the feedwater delivery time change from 20 seconds to 30 seconds.
Pending completion of items (1) through (5) in Units 1, 2 and 3, and NRR review and approval of SARCN 1272, this item will remain open for each applicable unit.
(0 en)
DER Number 84-52-Resistor Base Flan e for Atmos heric Dum Valve is Overstressed The licensee's final report of September 26, 1984 identified that Bechtel used the base flange of the resistor (diffuser), above the atmospheric dump valve, to support part of the interconnecting piping assembly.
Subsequently the vendor submitted their seismic report to Bechtel.
Bechtel review of this report determined that the actual piping loads on the resistor base flange had not been considered and
4'
that when these loads were considered, the resistor base flange would become overstressed during a seismic event.
In order to meet the loading requirements, the thickness of the resistor base flange must be increased from one inch to approximately two inches.
The root cause of this condition is that the piping load information was not transmitted to the supplier.
The licensee has issued instructions to increase the thickness of the resistor base flange to two inches for the installations in Units 1, 2 and 3.
The licensee committed to complete these flange modifications prior to fuel load in the applicable units.
To preclude recurrence, a training session was held to make all engineering disciplines aware of the need to transmit the load information to other disciplines (or suppliers) for incorporation into other specifications.
Pending completion of the above flange modification. in Units 1, 2, and 3, this item will remain open for each applicable unit.
(Closed Unit 1 onl ) DER Number 84-59 "'able Insulation Dama ed The licensee final report of October 9, 1984 identified that during startup testing activities in Unit 2, it was discovered that some electrical cabinet moisture seals may have caused damage to the associated cables'nsulation and jacket by contact with the metal edge of the seal.
The root cause was the lack of a specification/design requirement for edge protection similar to that used with cable trays.
The licensee issued instructions to replace damaged cables in Unit 2 and to perform an inspection of all fire/moisture penetration seals in Units 1 and
and install edge protectors wherever cable I
jackets were found in contact with the seal s metal edge.
The licensee issued DCN 25 to Drawing 13-A-ZYD-096, to add protectors to sheet metal dam edges on seals.
For Unit 3 installations, metal edge protectors will be installed on any seal that has the potential of damaging the cable.
At this time the seals have not been installed in Unit 3.
The instruction (NCR SE-4884) for Unit 1 inspection and corrective action was signed off complete on December ll, 1984.
This item will remain open for Units 2 and 3 until NCR SH-4857 is closed out for Unit 2 and DCN 25 to drawing 13-A-ZYD-096 is incorporated on the drawing, but is closed for Unit (Close-Unit 1 onl ) DER Number 84-88 Grout Missin Under Downcomer Feedwater Five-Ma Restraints The licensee's final report of November 30, 1984 identified that the downcomer feedwater five-way restraints in the main steam support structure require grout to be placed beneath the 1/2 inch base plates.
The required grout forms had been installed in Unit 1, but the grout was not installed for the two west restraints (SG-200 and SG"203).
The licensee issued instructions to inspect all remaining completed five-way restraints in Units 1 and 2.
The Unit 1 inspections and installation of grout in restraints SG-200 and SG-203 per NCR CC-4915 were closed out October 29, 1984.
Based on inspection results the licensee stated that all other completed five-way restraints inspected were found properly grouted in accordance with the drawings, and that this demonstrated that the reported grout omission was an isolated case.
The inspector could not find documented evidence of inspection/reinspection results for Unit 2, during this inspection.
The root cause was attributed to an oversight on the part of construction and failure to pay attention to the detail requirements contained in work plan procedures.
Project management has reemphasized strict adherence to project procedures and overall quality at weekly quality meetings.
This item will remain open for Unit 2 until documented evidence of the inspection/reinspection results for Unit 2 are provided for review by an inspector.
This item is closed for Unit 1 only.
ations (0 en) Alle ation Number RV-84-A-0097 (Followu Item 50-528/84-52-01)
Characterization:
An anonymous caller expressed concern that resumes of Level III certified contractors were routinely falsified at Palo Verde.
The contractors involved were said to be primarily non-Bechtel, e.g.
CALTEST, VOLT, EI, etc.
The falsification was primarily that individuals would falsely identify the title of their previous work experience, and the duration of that experience.
.This falsification enable them to receive a higher pay, since most contractor pay scales were said to be related to level designation of the individual.
The alleger said that 50/ of the hundred or so Level III's he was familiar with had done this.
Some individuals were named as examples of people who received Level III certification based on falsified work experience on their resumes and in one case an unwarranted waiver of Level III requirement U I
i
lm lied Si nificance to Plant Construction or 0 eration:
The startup test group is involved in technical acceptance and testing of the various systems in each unit.
Therefore, acceptance of work and/or systems by improperly certified contractors/
personnel could result in improper testing.
Previous Ins ection (2)
~Summa r Inspection Report 50-528/84-52 identified that the licensee had received a similar allegation through their "Hot Line" program, and had done extensive investigation into test personnel qualifications.
The inspector elected to audit the effectiveness of the licensee's
"Hot Line" program while examining the efforts of the licensee's resolution of the similar allegation.
Thus, the inspector partially utilized the licensee's information to examine the subject allegation.
Staff Position The licensee's actions to investigate their "Hot Line" allegation appeared to adequately cover the scope of the allegation received by the NRC.
The allegation remained open pending review and verification of the work experience on two individuals identified in the NRC allegation, and pending the licensee's completed assessment of deleterious effects on test validity.
Actions Re uired Licensee management.
personnel were informed that their final actions on their Hotline allegation would be considered a
followup item.
Specifically, the NRC would examine in a future inspection:
the final results of the work experience/education verification sampling the APS evaluation of the safety significance, if any, of the one case (to date) of apparent falsification the APS final decision on the need to expand their verification sample size This Ins ection
~Summar m
During this inspection the inspector reviewed available information obtained since the last inspection.
The licensee identified that as of December 10, 1984, they had identified approximately six (6) individuals who have apparent resume
deficiencies.
The licensee stated they are in the process of compl'eting their investigation and will issue a report in the next few weeks.
This report will provide the results of the work experience/education verification sampling, evaluation of safety significance and final decision on need to expand sample size.
(2)
Staff Position This allegation will remain open pending review and verification of the licensee's final report noted above.
The NRC will examine this allegation in a future inspection, as a
followup item from the previous inspection (Followup Item 50-528/84-52-01).
b.
(0 en) Alle ation Number RV-84-A-109 Characterization:
An anonymous caller expressed concern that an individual was certified a level III test engineer in the Unit 2 startup test group, based on incorrect education and work history.
Im lied Si nificance to Plant Construction or 0 eration:
The startup test group is involved in technical acceptance and testing of the various systems in each unit.
Therefore, acceptance of work and/or systems by improperly certified contractors/personnel could result in improper testing.
Assessment of Safet Si nificance:
(1)
Technical A
roach to Resolution Examine licensee's procedures for qualification and certification of startup test personnel and compare these the licensee's commitments for test personnel qualification.
Review identified individual resume for previous work experience, and determine if the licensee's requirements were met.
Determine if the licensee's program to verify the work experience stated in resumes, is adequate.
(2)
Ins ection Performed and Findin s Identified
~Summar a
The inspector examined the licensee's procedures and found that the licensee's procedures met their commitments.
The inspector examined the identified individual records and found the following as of December 13, 1984:
N
The individual was supplied on site by Cal-Test on approximately November, 1983, as an uncertified walkdown worker.
This individual had previously worked onsite for approximately one year with LPL.
The subject individual was identified on the licensee's records as an uncertified lead instrument and control walkdown worker.
On October 1,
1984, a request for the subject individual was submitted by a supervisor to the PVNGS startup training department, requesting evaluation of the individual's certification to a Level II startup engineer.
An undated and unsigned resume of the individual education and work history was attached to the above identified request.
Per inspector review of PVNGS startup training department records there were no previous resumes maintained by the licensee onsite for the subject individual, since the individual was provided under a
Cal-Test contract and was uncertified.
On October 3, 1984, the PVNGS startup training department reviewed the above submitted request and completed a
Certification Evaluation Report for the individual, based on review of submitted resume education and work history.
The Certification Evaluation Report stated the candidate evaluated above appears to have the necessary experience and educational background to meet certification of qualification for Level III.
The individual was certified to level III in the evaluation report based on resume information, even though the request was for level II certification, to preclude having to repeat the evaluation again at a later date for level III certification.
On October 3, 1984, the bottom portion of the October 1,
1984 request for certification of the individual, was completed and signed off that the individual had the necessary experience and educational background to meet Level II.
On December 12, 1984, the PVNGS training department identified to the inspector that the initial request for certification of the subject individual was handled as a
preliminary request in their department, as identified on the form by adding a handwritten underlined letter P to the upper right hand corner of the document.
According to the licensee's existing procedure (QADP 10.0),
an individual can not receive formal certification until they have filled out the licensee's education and experience documents (Form F-QADP-10.0-2 and F-QADP-10.0-3), submitted copies of educational degrees, military training/
lt II
certification, etc.
As of December 12, 1984, the PVNGS startup training department did not have any documentation that the subject individual or a supervisor had made any additional request for formal certification of the individual.
On December 12, 1984, when the inspector requested the licensee's records on the subject individual, the licensee contacted Cal-Test to see what. additional records they had on the subject individual.
Cal-Test had records of a security check performed by Beeler Security, incorporated in December of 1983, that did not agree with the resume submitted along with the October 1,
1984, request for certification of the subject individual.
Once the two documents identified above were compared to each other, it became evident that the resume information used for the Certification Evaluation Report disagreed with the information verified in the security check noted above.
It appears the licensee does not maintain a complete file of all employment records for uncertified contract personnel working onsite.
In this case it appears the subject individual provided one set of education and work history to Cal-Test for a security check in December of 1983, and then a different set of education and work history to the PVNGS startup training department on October 1,
1984, for use in performing a certification evaluation.
Since a complete file of employment records were not onsite, the licensee did not have a way to compare the second set of education and work history to the first set, to identify the incorrect information provided in the second set, The licensee does not normally perform telephone followup checks of employment records provided on site by uncertified personnel, provided under contract.
As of December 13, 1984, it appears the subject individual has not been certified a level III test engineer in the Unit 2 startup test group, based on review of available licensee documents.
Incorrect education and work history was provided to and used by the licensee for the preliminary Certification Evaluation Report for the subject individual.
The licensee stated they would investigate how the incorrect education and work history information was submitted and used Xor the above evaluatio (3)
Staff Position:
This allegation was verified accurate in part, since based on submittal of incorrect education and work history information the subject individual had received a preliminary Certification Evaluation Report that stated he was qualified to be a level III test engineer.
As of December 13, 1984 the subject individual has never completed a formal submittal of the required licensee documents for certification to a level III test engineer or received a formal Level III certification which would have required formal verification/comparison of all employee records by both the licensee and Cal-Test.
This item will remain open pending review of the actions the licensee will take on this item and review of the licensee's final report for allegation number RV-84-A-0097.
The above is considered a followup item (followup item 50-528/84-56-02).
4.
Startu Test Personnel Certifications
~Summar The inspector examined the licensee's procedures and found that the licensee's procedures met their commitments.
In the course of this examination the inspector identified that this item is similar to (Open) Allegation Number RV-84-A-0097 (Followup Item 50-528/84-52-01),
which was reviewed.
The above allegation is still open pending review of the licensee's final report on their similar "Hot Line" allegation.
The licensee's procedures and actions to investigate their similar "Hot Line" allegation, appear adequate at this time.
This item remains open pending closing of Allegation Number RV-84-A-0097.
The above is considered a followup item (followup item 50-528/84-56-03).
5.
ualit Assurance/ ualit Control Ins ectors ualifications The licensee has established a program to verify the qualifications and certifications of QA Engineers and QC Inspectors that have or are performing quality-related activities at Palo Verde.
The inspector reviewed this program to evaluate the adequacy of the program to accomplish its objective, and to verify that these activities had been accomplished in accordance with FSAR and regulatory requirements.
The program covers past and present QA/QC personnel employed by APS, Bechtel and subcontractors.
Personnel resume's were reviewed to verify past employment and education.
Certification and inspection records were also reviewed to assure that only certified inspectors performed the required inspection V
The are results of this inspection effort of the various QA/QC organization as follows:
a
~
APS A/
C Personnel The APS effort involves a 100 percent verification of past and current QA and QC personnel qualifications.
The inspector reviewed the methods utilized to obtain resume verification and the responses obtained.
The program has been successful in obtaining the required information with no major discrepancies identified regarding the accuracy of the information contained on the personnel resumes.
APS Security performed the verification of past employment and education for APS contractor Energy, Incorporated (EI).
Security's final report on their audit of IE was in progress during this inspection; however, the Security Manager informed the inspector that no major problems were identified.
The inspector examined the APS effort to assure that no uncertified APS QA/QC inspectors signed off on inspection documents.
Initially 125 quality-related work orders out of approximately 2,500 were reviewed.
Ten minor problems were identified which resulted in increasing the sample size to 100 percent.
This effort is currently in progress; the inspector review of the questionable work orders revealed no significant discrepancies that would affect safety-related work.
b.
Bechtel C En ineers The Bechtel effort for verification of QC Engineers (Inspectors)
personnel qualifications revealed no major problems.
The methods of verification is sufficient in scope to cover current and terminated or transferred personnel to assure experience and education was accomplished as stated in the QC Engineer's employment application.
Bechtel's review of records to assure that inspections were performed by certified inspectors is documented in NRC Report Number 50-528/84-36.
This effort was in response to a NRC:RV violation regarding an unqualified QC Inspector.
The records reviewed included 100 percent of the Mechanical CIP's and randomly selected CIP's from each discipline (electrical, welding, piping)
to verify the inspector of record was qualified for the task.
C.
Bechtel A'En ineers The verification program was limited to Bechtel QA Lead Auditor qualifications.
The inspector reviewed the program, which included all past and presentQA Iead Auditors; for compliance with ANSI N45.2 '3.
No problems were identifie e I
f,,
J
d.
Bechtel Subcontractor C Ins ectors The inspector's effort was directed at reviewing the verification program on quality-related subcontractors who performed their own inspection activities.
There are four active and three inactive subcontractors that fall into this category.
The inspector's review revealed that the subcontractor's response
.for resume verification was not satisfactory.
Only one out of the four active subcontractors had adequately responded in the time requested.
The inspector also noted, that Honeywell Corporation, an active subcontractor to the Waldinger Corporation, was not included in this effort, and that the program did not address inactive subcontractors.
Therefore, during the exit meeting of December 7,
1984, the licensee committed to (a) include Honeywell in the program for verification of past and present QC personnel qualifications, (b) address the inactive subcontractors, and (c) complete the entire verification program effort, prior. to -going beyond 5/ power.
(Followup Item 50-528/84-56-04)
I 6.
Verification of Welders'alifications The: licensee, during a meeting at Region V on June 14, 1984, committed to establish a program for verification of welder qualifications for Unit 1.
This program would provide for a 100 percent review of ASME weld records and associated welder certification documentation.
Special Construction Inspection Planning (SCIP) Number 565.0 was issued to accomplish this work.
In addition identical programs have been approved for Units 2 and 3 under SCIP Numbers 575.0 and 576.0 respectively.
The SCIP requires Quality Control verification of this review by QC stamping of all WR-5's (Field Welding Check List) included in the N-5 Code Data Packages.
The inspector reviewed the welder verification program in order to determine the adequacy of the program to verify post-weld welder qualifications.
The inspector also reviewed evidence for proper implementation of this program, including evaluation of reported weld misassignments, i.e. certified welders welding outside their qualifications.
Bechtel Quality Control reviewed welder qualifications of all ASME Section III welds included in the ASME N-5 Code Data Packages.
This review was evident by the QCE's stamp on the WR-5's indicating that the welder's qualifications have been verified.
The inspector reviewed the welder qualifications of a number of welders selected at random from the N-5 Code Data Packages.
The WR-5 provides traceability for all welds as required by ASME Section III requirements.
Therefore the WR-5, or the WR-5A for 2 inch and less socket welded joints, provides the necessary information for identifying the welder or welders that performed welding on any ASME weld joint, along with the date the weld was made, the welding procedure number, joint thickness, pipe diameter and filler metal used.
The WR-1 (Welder Performance Qualification Test Record)
certifies that, a welder was successfully qualified and provides the necessary details of qualification.
Therefore, by comparing the WR-5
L
with the WR-l, verification of welder qualification at time of fabrication and installations activities can be accomplished as required by SCIP Number 565.0.
The inspector is satisfied that the program is meeting its objective for verification of welder qualifications for 'Unit l.
The results of the licensee effort revealed that deviations in welder qualifications were responsible for 92 nonconforming welds out of a total of 32,190.
The nonconforming conditions were documented on NCR-W-X-1084.
The inspector reviewed the description and disposition of the various nonconformances.
The majority were cases of welders welding outside their qualified thickness range.
In these cases a successful requalification of the welder resulted in a disposition of use-as-is.
If the original welder was no longer available for retest, the disposition called for rework.
There were 3 cases where the welder was not qualified to weld using stainless steel filler material; disposition required the welds to be cut out and rewelded.
The inspector was satisfied that the technical justifications for the dispositions were'ppropriate and in accordance with AS11E Section III requirements.
The inspector performed an evaluation of these nonconforming items for root cause to determine if these items were indicators or "signals" of some underlying problem.
Due to the low deviation rate, less than 1/2 percent of the total weld records reviewed, and the circumstances associated with each item e.g.
time period, type of deviation and disposition, no trend or other gA related concerns were evident.
The welder qualification verification program was initially limited to AS>iE welds.
The reason was that AWS does not required traceability to the weld joint; hence no WR-5 Form to identify a welder with a specific structural weld joint.
However, the licensee did commit in a meeting with the Region V Administrator on October 24, 1984 to include AWS certified welders in a similar program.
Although the plan to perform this work is in progress the licensee did commit during the exit meeting to complete the review and analysis of all AWS weld qualifications by January 15, 1985.
(Followup Item 50-528/84-56-05)
Invalidation of Nonconformin Documentation The inspector reviewed the licensee's program developed to assess the adequacy of justifications used for invalidating nonconformance documents.
The following procedures were reviewed to verify that administrative controls exist for invalidation of noncomformance documents:
60AC-OZZ02, Revision 3 "Control of Nonconforming Items" 90GA-OZZ08, Revision 13 "Prerequisite/Preoperational Startup Work Authorization:
90GA-OZZ19, Revision 98 "Start-up Field Reports" Bechtel Work Plan Procedure/equality Control Instruction 5.0, Revision 2 Each procedure provides means to void or invalidate their respective documents.
Also the procedures include a requirement to provide justification on documents invalidated.
Quality Investigation Report QI-84-0006, discussed the licensee's investigation of nonconformance documents.
The licensee selected a
sampling of all types of nonconformance reports including:
Nonconforming Reports (NCRs), Start Up Work Authorizations (SWAs), Start Up Field Report (SFSs)
and contractors and subcontractor's NCRs.
The sample size was'etermined by using Mil'. Std.
105D; however all APS NCRs were reviewed because of the smaller number of documents involved.
The sample sizes, were as follows:
50 of 419 Bechtel NCRs,
of 47 APS NCRs, 125 of 2,183 SWAs/SWPs, 52 of 803 SFRs, and 15 of 15 subcontractors NCRs.
!
The licensee's review revealed that approximately 10% of the invalidated documents did not provide adequate justification for the invalidation.
However, the licensee was able to provide documents or objective evidence to support these dispositions.
The licensee has issued five corrective action reports, which are still'pen, to assure that the above items have the appropriate written justifications.
The inspector reviewed a sampling of the invalidated documents.
The document were found to have sufficient justification provided, to support the invalidation.
Therefore, it appears that the licensee's program for invalidation of nonconformance reports is adequate to provide proper justification and control of these documents.
Licensed 0 erator Trainin The inspector examined the training records of several licensed operators, selected at random, for compliance with the training commitments set forth in section 13.2 of the facility FSAR.
The examination included a review of resumes transcripts, certificates of completion, attendance records, completed licensee application forms and other records.
Where waivers had been granted for portions of the training, the basis for granting the waiver was reviewed.
The inspector also examined the report of an audit performed by the applicant's Quality Assurance organization during the summer of 1984.
This report, dated August 31, 1984, states that it included a review of the training records of all licensed operators.
The report identified a
number of deficiencies in the applicant's records program.
A review of the applicant's response to this audit report indicated timely corrective action was being or had been implemented.
In addition, the inspector discussed the more significant deficiencies with the applicant's representative and verified the deficiencies had been corrected or resolve I
0
By letter dated May 1, 1984 (E. Van Brunt (APS) to J. Martin (NRC)),
the applicant committed to provide systems qualification training in accordance with facility procedure 40 AC-OZZ13.
The applicant also committed that this training would be completed prior to Unit 1 fuel loading for specified operators.
The archival records examined by the inspector did not include records of this "systems" training.
Discussions with the applicant's representative, however, indicated this information was available but not yet included in the archival records because the bulk of the training had only been recently completed.
The representative indicated the training was being completed on a schedule consistent with management commitments and that they would submit a
letter certifying the timely completion of the training.
Based on the foregoing, the inspector concludes the training of the licensed operators satisfactorily conforms to the commitments set forth in the applicant's CESAR (Chapter 13.2)
and in the letter of May 1, 1984, cited above.
On December 7 and 14, 1984, an exit meeting was conducted with the licensee representatives identified in paragraph 1.
The scope of the inspections and the findings as described in this report were discusse I f
lq 1