IR 05000528/1985007

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Insp Repts 50-528/85-07,50-529/85-08 & 50-530/85-05 on 850304-08.No Violation or Deviation Noted.Major Areas Inspected:Tmi Action Plan Items,Open Items,Licensee Event Reporting Sys & Independent Walkdowns of Safety Sys
ML17298C129
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/22/1985
From: Andrew Hon, Miller L, Sorensen R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17298C128 List:
References
TASK-2.F.2, TASK-TM 50-528-85-07, 50-528-85-7, 50-529-85-08, 50-529-85-8, 50-530-85-05, 50-530-85-5, NUDOCS 8505170153
Download: ML17298C129 (20)


Text

U.S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos.

50-528/85-07, 50-529/85-08 and 50-530/85-05 Docket Nos.

50-528, 50-529 and 50-530 License No.

NPF-34 Construction Permit Nos.

CPPR 142 and 143 Licensee:

Arizona Public Service Company P.

O. Box 21666 Phoenix, Arizona 85036 Facility Name: Palo Verde Nuclear Generating Station - Units 1, 2 and

Inspection at: Palo Verde Site, Wintersburg, Arizona Inspection conducted.

II Inspectors:

farch 4-8, 1985 R.

. Sorensen, roject Ins ector Date Sig ed Approved:

S~umma a:

A.

on, Pro t

spec or L

. Miller

., Chief Reactor Projects Section

Date igned Date Signed Ins ection on March 4-8 1985 (Re ort Nos. 50-528/85-07 50-529/85-08 and 50-530/85-05 Areas Ins ected:

Routine, unannounced inspection by regional based inspectors of the Licensee Event Re'porting System, TMI Action Plans Items, open items, and independent walkdowns of safety systems.

The inspection focused on Units 1,2, and 3, and involved 68 inspe'ctor hours onsite by two NRC inspectors.

Results:

No violations or deviations were identified.

8505170153 850425 Tl PDR ADOCK 05000528

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DETAILS 1.

Persons Contacted Arizona Public Service Com an (APS)

MD gl L

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M.

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Karner, Assistant Vice-President, Nuclear Production Sousa, Assistant Corporate QA/gC Manager Russo, Manager, equality Audits and Monitoring quinn, Licensing Manager Gross, Compliance Supervisor Hebison, Operations Engineering Supervisor Voboril, Operations Engineer Van Dop, Operations Engineer Meyer, Pire Protection Supervisor

"-Denotes those persons attending exit meeting, March 8, 1985.

The inspectors also interviewed other licensee and contractor personnel during the inspection.

2.

Licensee Event Re orts (LER)

S stem The evaluation assessed the licensee's program for preparing, reporting, tracking, and closing-out LER's.

The following documentation and procedures were inspected:

"Licensee Event Preparation",

79AC-9ZZ02.

"Event Related Reporting",

71AC-9ZZ01.

"Routine and Non-Routine Reporting,"

5N404.04.00.

Potentially Reportable Occurrence (PRO) Tracking System-PRO's were originated either by the control room personnel directly or by others in collabration with the control room personnel.

The immediate consequences of the PRO's were evaluated by the control room personnel when the PRO's were issued.

Samples of LER and closeout packages.

The inspector concluded that the licensee had established an adequate program for handling LER's. It was also evident that this program was being refined by the licensee as the licensee gained experience with using it.

No violations or deviations were identified.

3.

Im lementation of TMI Action Item II.F.2-Inst'.rumentation for Inade uate Core Coolin Detection Closed a

~

Subcoolin Mar in Meter This item was previously inspected for construction adequacy.

This inspection covered pre-operational functional checks.

The inspector reviewed pre-operational report 92PE-1SB19,

"(}SPDS Pre-operational

aj

Test," Section 8':

"RCS and Upper Head Satura'tion Margin Test."

During the period 10/21/84-12/4/85, the subcooling margin meter was verified by simulating an input signal at the Qualified Safety Parameter Display System (QSPDS) cabinet terminals.

Data was recorded for various RCS pressure and temperature conditions.

The input signal sensors were safety grade and they were used for plant protection.

Since they were covered by routine surveillance required by Technical Specifications, this inspection covered only the circuit from the signal input to the subcooling margin meter display.

The inspector concluded that the licensees'ubcooling margin meters installation met the requirements for this system in TMI Action Item II.F.2.

Reactor Vessel Level Monitor S stem (RVLMS)

The licensee's installation of its Heated Junction Thermocouple RVLMS was done using. Work Order 71473.

The inspector inspected completed work procedure 36MT-9ZZ02, "Installation and Removal of Heated Junction Thermocouple Assemblies."

This procedure included a

Quality Control Inspection Plan.

The system functional check was performed during the filland vent of the reactor coolant system.

According to procedure 410P-1RC02,

"Reactor Coolant System Fill and

'ent",

RVLMS indication was compared with a temporary tygon hose level and data was recorded in Appendix J of this procedure.

Operations Engineering independently recorded the heated junction thermocouple temperature readings taken at the QSPDS.

During this inspection, the Appendix J data were not available, since a

permanent record of the completed procedure '410P-lRC02 was not required.

The licensee initiated an Engineering Evaluation Request, EER No. 85-SB-028, and determined the RVLMS was functional based on the Operations Engineering data.

The inspector reviewed the EER, and concluded that the RVLMS appeared to meet the NUREG 0737 requirement.

Finally, the inspector conducted a walkdown of the reactor upper head and control room to verify the installation of the RVLMS.

The Office of Nuclear Reactor Regulation (NRR) will audit the licensee's experience with the RVLMS during startup.

Final plant specific approval for its usage will be given based on this audit.

Core Exit Thermocou les '(CET)

The licensee installed the CET under Work Order 71471.

The inspector reviewed the following documents related to the installation and functional check of the CET:

Thermocouple properties prior to installation.

36MT9RI01, "Fixed and Movable (In-Core Instrumentation)

ICI Detector Installation." including the QC Inspection Plan and procurement documents.

36MT9RI02, "Fixed ICI Detector Acceptance Test.".

  • 4

92PE-15B19,

"gSPDS Pre-Operational Test.", Section 8.6.2.

No violations or deviations were identified.

This item is closed.

4.

Followu of Previousl Identified Items a

~

(Closed) Deviation 50-528/83-34-09 Acce tance Criteria for Visual Ins ection of Weldin Two aspects remained open from Inspection Report 84-36 regarding this item.

1)

The licensee had submitted an FSAR change (SARCN) 1123 to NRR, which concerned exceptions taken to the AWS Dl.l welding code, to reflect construction practices used during construction of PVNGS.

NRR reviewed this FSAR change and found it acceptable as documented in SSER87.

This aspect is closed.

2)

The licensee submitted another FSAR change (SARCN 1167) to NRR, by letter ANPP-31392-EEVB/WFg, dated December 10, 1984.

This FSAR change revised the FSAR to reflect actual construction practice performed in accordance with field specifications in the following areas:

a)

fabrication of the containment tendon system, equipment hatch, and personnel locks.

b)

fillet weld profiles.

c)

stud welding performed under AWS Dl.l.

NRR has reviewed the proposed changes and found them acceptable as documented in SSERjj7.

This aspect is closed and therefore, this deviation is closed.

b.

(Closed) Followu Item 50-528/84-10-02 Fire Protection S rinkler S stem Pi e Su orts Previous Ins ection As documented in Inspection Report 84-65, the licensee had identified to the inspector 38 fire protection sprinkler system (FPSS) pipe supports that remained to be installed.

The number of pipe supports that remained to be installed was subsequently reduced to 29.

The installation of these supports prior to entering Node

was also imposed as a condition of the operating license for Unit l.

The inspector verified that the 29 FPSS pipe supports had been installed.

The inspector reviewed the applicable Work Order, CWO 69257, that installed the pipe supports in accordance with

applicable Field Change Requests (FCRs).

25 separate FCRs were used in conjunction with this work order to complete this work.

All applicable Field Engineering and equality Control signatures were present and in order on this work order.

The inspector personally verified the installation of a sample of six of these pipe supports, from FCRs 85542-C, 86011-C and 85513-C.

No violations or deviations were identified.

This item is closed.

(Closed) Violations (50-530/84-24-01 50-528/84-15-12)

Unresolved Item 50-530 84-07-13 Thread En a ement Concerns (Closed)

DER 84-53 Bonnet Nuts and Bolts Loose on Various Safet In ection Valves Previous Ins ection Violation (50-530/84-24-01)

involved insufficient corrective action taken by the licensee in response to Violation 50-528/84-15-12 and Unresolved Item 50-530/84-07-13.

The previous violation, 84-15-12, concerned the failure to include minimum thread engagement criteria for bonnet studs and nuts in applicable procedures and specifications.

The unresolved item, 84-07-13, questioned whether bonnet studs on valve 3PSIEV235 had sufficient thread engagement into the bonnet.

Violation 84-24-01 concerned the need to evaluate the technical acceptability of the as-found conditions of thread engagement problems, and for further inspection and more thorough corrective action.

This Ins ection One of the corrective actions committed to by the licensee was an engineering review for overall technical adequacy of documentation packages for NRC Violations, Deviations and Open Items.

I

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The inspector reviewed a copy of ANPP procedure jf5I406.01.02, which was revised to require ANPP engineering review of NRC 'open items packages.

The revision was.approved and satisfied.this commitment.

The remainder of the corrective actions taken in response to the two violations and one unresolved item were detailed in Revision 1 to DER 84-53.

In summary, the licensee performed two different walkdowns of valves in Units 2 and 3.

One walkdown was conducted in accordance with Special Construction Inspection Plans (SCIP) 569.0 and 570.0. It

l

sampled 250 valves in Units 2 and 3 for full thread engagement of bonnet hex nuts.

Assorted valve types were sampled from 3 different suppliers.

No safety significant deficiencies were identified by the.licensee.

The second walkdown was conducted per SCIPs 617.0 and 618.0.

This walkdown inspected a sample of 260 valves in Units 2 and 3 for proper thread engagement of the bonnet studs into the bonnet.

Again, different types of valves were inspected from different suppliers.

The licensee identified no deficiencies that were safety significant.

Therefore, the licensee concluded, based on these samples, that a high degree of confidence existed that no further thread engagement problems existed at PVNGS.

The inspector observed that the licensee had instituted further corrective actions.

The inspector reviewed Field Change Requests (FCRs) which changed five different field specifications to include acceptable thread engagement criteria.

In addition, the inspector reviewed Procedure Change Notices (PCNs) for 12 MPP/gCIs that now incorporated acceptable thread engagement criteria.

Finally, the licensee held training sessions for field engineers and equality Control Personnel to familiarize them with thread engagement criteria.

The inspector reviewed the lists of attendees to these training sessions, as well as the material for three equality Talks concerning this subject that were given to craft personnel.

The inspector concluded that the licensee's corrective actions were adequate.

These items are closed.

However, the inspector stated that to ensure adequate thread engagement criteria were included in all applicable plant procedures used during operations, thread engagement criteria would be the subject of a followup inspection (open item 50-529/85-08-01).

No violations or deviations were identified.

(Closed) Followu Item (50-528/84-61-01)Inclusion of Valve HPA-UV-024 in Technical S ecifications Previous Ins ection I

The inspector had identified a valve, HPA-UV-024, that shuts on a Containment Isolation Actuation Signal (CIAS), which had not been included in the Technical Specifications as a containment isolation valve.

Licensee management committed to include HPA-UV-024 in Technical Specifications as a containment isolation valve with the associated maximum acceptable stroke time.

The licensee also committed to perform a Local Leak Rate Test (LLRT) of HPA-UV-02 This Ins ection The inspector noted that Table 3.6-1 of the Technical Specifications now includes HPA-UV-024 as a containment isolation valve with a maximum stroke time of 5 seconds.

In addition, the inspector reviewed the applicable data sheet from procedure 73S9C1,01, which

'ocuments the leak rate test of this containment isolation valve.

a No deficiencies were identified This item is closed.

(0 en) Deviation (50-528/84-25-03)

ualit Assurance for Fire Protection

~Back round This deviation originally addressed the concern that no Quality Assurance existed for the application of spray-on fireproofing at PVNGS. This subsequently broadened into the issue of whether or not a Quality Assurance program existed for fire protection at PVNGS.

The inspector reviewed the licensee's Quality Assurance Program Description applied to Fire Protection Systems during the construction and startup phases.

This program description was submitted to Region V by letter ANPP-31658-EEVB/WEI/SFQ dated January 9,

1985. It delineated how compliance was achieved with the Quality Assurance guidelines of Appendix A to NRC Branch Technical Position (BTP)9.5-1.

I The licensee covered each of ten aspects of the BTP in the Program Description.

The inspector reviewed documentation that showed implementation of a sample of five of these guidelines.

In addition, the inspector interviewed numerous personnel involved in different areas of fire protection to assess the licensee's implementation of the QA program.

Samples of documentation that the inspector reviewed included fire protection system drawings, test procedures, walkdown procedures, QA audits, QA surveillances, official correspondence, inspection procedures, System Turnover procedures, Master Tracking System lists, and Corrective Action Requests.

The BTP guidelines for Quality Assurance that the inspector examined were:

1)

Instructions Procedures and Drawin s The inspector reviewed a sample of three Fire Protection Sprinkler System drawings prepared by Viking Fire Protection Company, a subcontractor to Bechtel.

Drawing numbers 650-328-2, 650-355-3, 650-356-2 were studied.

Notes in the drawings specified National Fire Protection Association (NFPA)

standards that were referenced for hangers and supports, types of fittings and materials to use,'tolerances, etc.

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The inspector also examined manufacturer's procedures (W.R.

Grace 8 Co.) for application of Monokote spray-on fireproofing.

This work is done at PVNGS by Ora B. Hopper 8 Son.

In addition, the inspector reviewed a letter from W. R. Grace, certifying Hopper as a qualified applicator of Monokote for the past 23 years.

The inspector concluded the licensee had adequately implemented this fire protection QA criteria.

~ine ection The inspector examined correspondence from American Nuclear Insurers (ANI) documenting their role as independent inspectors and witnesses of system acceptance tests.

Also the inspector observed ANI stamps on system installation drawings which denoted ANI approval of individual fire protection systems.

Finally, the inspector reviewed an ANI inspection report for the period December 5-6, 1979, that, showed inspections for compliance with applicable codes and standards.

Recommendations were included in the report and the status of recommendations from previous reports was discussed.

The inspector also reviewed a copy of WPP/QCI 205.0, the inspection procedure for sprinkler piping and pipe supports installed in accordance with drawings originated by Viking.

This inspection was performed by Bechtel field engineers and was used during the construction phase.

In addition, Special Construction Inspection Plan (SCIP) 544.0 performed an inspection of the same type on a 10% sample of sprinkler piping and pipe supports that had been turned over to APS by Bechtel.

The inspector also reviewed a copy of Inspection Procedure (IP) 5.26-04, which was the Fire Protection Design Documentation Walkdown.

This walkdown was done by Bechtel and verified that the system had been installed in accordance with the design requirements.

An extensive list of buildings affected was contained within the procedure.

The inspector reviewed a sample listing of discrepancies generated in Unit

as a result of this walkdown.

In all cases, NCRs or SFRs were generated, and all but one had been resolved as of the date of the inspector's review.

However, a completed copy of IP 5.26-04 was unavailable at the time of the inspection.

The inspector requested a copy for his review during a future inspection.

The licensee agreed.

The licensee's System Completion Group (SCG) also performed walkdowns of all Safety related (Q class)

and important to safety (R class)

systems.

This included fire protection systems and was done for system turnovers from construction to startup and from startup to operations.

The licensee compared the subcontractor's and Bechtel's drawings with the as-built systems to identify any discrepancies prior to system turnove The inspector reviewed a subsystem walkdown for system 2FP-19

,in Unit 2, completed on February 18, 1985.

There were 158 open items generated as a result of these walkdowns.

The inspection also examined a sample of ANPP Engineering walkdowns for system acceptance to operations.

This was performed in accordance with procedure 73AC-OZZ04 Walkdowns for Systems FP-38,51,70,71, and 72 were reviewed.

The inspector concluded the licensee had adequately implemented this fire protection gA criteria.

Test and Test Control The inspector reviewed a sample of completed hydrostatic tests, performed by Viking, on portions of the FPS for Units l, 2 and 3.

These tests were witnessed by Bechtel and APS Construction.

APS Construction ver'ified gage calibration, test pressures and inspected for leaks.

The inspector also examined a sample of fire protection system preoperational test procedures that verified the operability of these systems.

The inspector concluded the licensee had adequately implemented this criteria.

Nonconformin Items The inspector reviewed the Master Tracking System (MTS)

printout for Fire Protection, as of July 23, 1984, and noted use of Startup Field Reports (SFRs)

and Nonconformance Reports (NCRs) to document identified deficiencies.

The list was extensive.

Much of it was generated during the above-mentioned walkdowns.

The MTS was the method by which the licensee tracked open items and resolved them.

The inspector concluded the licensee had adequately implemented this criteria.

Audits The inspector reviewed a sample of approximately 30 Bechtel (}A surveillance reports of Viking activities spanning the period 1980-1984. 'he reports covered such subjects as witnessing flow tests of sprinkler'ystems, witnessing hydrostatic tests of sprinkler systems, certification records for pressure gages, receipt inspections, housekeeping and storage in storage areas, installation of piping, adherence to the Viking gC manual, etc.

Where deficiencies were noted, corrective action was taken in every case.

However, the inspector reviewed audit report 84-VFP-S-19, which documented an extensive audit conducted by Bechtel of Viking in the period September 28,'984-November 30, 1984.

The audit verified the implementation of the Viking equality Control Manual and compliance with Vikings'ubcontract specification.

Bechtel assessed Viking's gA program as being weak.

Nine deficiencies were identified as a result of this

lu

audit.

Two were corrected immediately, but the other seven resulted in the issuance of seven Corrective Action Requests (CARs).

The inspector requested these CARs and Viking's responses to them.

The licensee agreed to have these things available for a future inspection.

B The inspector reviewed an audit report 85-ISI-S-2 conduct d b echtel of Insulation Services, Inc. (ISI), the subcontractor or fireproofing systems for electrical raceways.

This audit covered the period January 31-February ll, 1985, and verified implementation of the ISI gA manual and subcontract CARs.

specifications.

The audit resulted in the issuance of three As a result, of the issuance of this deviation, Bechtel audited Ora B. Hopper 8 Son during the period November 2-December 13, 1984.

This audit, 84-VA-S-20, assessed the implementation of the subcontract specification, and only one deficiency was identified. It was corrected during the audit.

In addition, Bechtel measured the thickness of a sample of 280 different applications of Monokote and found none less than the minimum acceptance thickness as defined by the Underwriter's Laboratories Fire Resistance Directory.

Also as a result of this deviation, Bechtel will audit Ora B.

opper again in May, 1985 before the completion of the contract in June, 1985.

The inspector concluded from the Bechtel audits an inspections that, while it was true that no written gA program had existed for spray-on fire proofing at PVNGS, the Monokote was nevertheless applied properly.

In addition, a

high degree of confidence exists that the Monokote will continue to be applied properly based on Hopper's certification by the manufacturer and commitment to future surveillance by Bechtel.

~Summa r The inspector concluded from his sample that the licensee substantially complied with the gA guidelines of BTP9.5-1 Appendix A.

However, additional followup inspection to examine Viking's gC manual, Viking's response to the seven CARs from the most recent (}A audit, and a copy of the completed version of IP5.26-04 will be necessary.

This item will remain open until these aspects have been reviewed.

No violations or deviations were identified.

The inspectors met with licensee representatives denoted in Paragraph

on March 8, 1985.

The scope of the inspection and the inspectors'indings as noted in this report were discusse '