IR 05000528/1985019

Insp Repts 50-528/85-19,50-529/85-21 & 50-530/85-15 on 850513-17.No Violation or Deviation Noted.Major Areas Inspected:Activities Associated W/Implementation of Selected TMI Action Items & Routine Followup of Allegations

ML20132A616
Person / Time
Site:	Palo Verde
Issue date:	07/01/1985
From:	Kanow L, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20132A603	List: IR 05000528/1985019 ML20132A598
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-3.D.1.1, TASK-TM 50-528-85-19, 50-529-85-21, 50-530-85-15, IEB-79-06, IEB-79-6, NUDOCS 8507230124
Download: ML20132A616 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

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Report-No /85-19,50-529/8'5-21,.and.50-530/85-15 . ; .

Docket No , 50-529 and 50-530 - ,

License No: NPF-34 -

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' Construction Permit.Nos. CPPR-142 and I43' '

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m Licensee: Arizona Nuclear Power Projec P. O. Box 52034

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Phoenix, Arizona 85072-2034

. Facility Name: Palo Verde Nuclear Generating Station - Units.1, 2'and 3 Inspection at: Palo Verde Site, Wintersburg, Arizona In'spection conducted: May 13-17, 1985

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' Inspector: . {Cd LY'R. Kanow, R'eactor Specialist-7!l!W Date Signed

' Approved By: / Y- b

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T. Young, Jr. , hief, E g i ring Section Date Signed 1-Summary:

' Inspection on May 13-17, 1985 (Report Ncs. 50-528/85-19, 50-529/85-21 and

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50-530/85-15)

Areas Inspected: Routine unannounced inspection by a regional based inspecto of activities associated with implementation of selected TMI Action Items, and routine follow-up of various allegations. The inspection involved 34-

. inspector-hours by one NRC inspecto 'Results: No violations of NRC requirements or deviations were identifie *

8507230124 850701

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1, DETAILS Persons Contacted Arizona Nuclear Power Project (ANPP)

• D. B. Karner,' Assistant Vice President, Nuclear Production

• L. A. Souza, Assistant Corporate QA/QC Hanager

• D. Wootten, Senior Nuclear Safety Engineer

• J. C. Matteson, Transition QA/QC

• T.-J., Bloom, Licensing Engineer

• R. J. Burgess, Field Engineering Supervisor

• J. E. Smith Jr.,. Compliance Engineer

• K. Gross, Supervisor Compliance ,

,. *C. N..Russo, Manager, Quality Audits and Monitoring

• W. Quinn, Manager, Licensing

• J. 01sen, Licensing

• G. Perkins, Manager, Radiological Services

• S. G. Penick, Quality Monitoring' Supervisor D. Wittas, Mechanical Quality Engineer' Supervisor R. Fullmer, Vendor QA Supervisor B. Albert, Licensing Engineer' s -

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M. Jones, Licensing Engineer- ,

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N. W. Lossing, Supervisor, Quality Investigations; ..

A. McClure, QA/QC Investigatof

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f . .BechtelPowerCorporation'(Bechtel{ -

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'*D. R.-Hawkinson, Project QA Manager' , ,

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• T. L. Horst, Project Field Engineer ,

• M. A. Rosen, Quality Control-

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• Denotes those attending the exit' interview on May 17, 198 . Inspection Methodology

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The allegation characterization statements contained in this report are either a paraphrasing of the staff's understanding'of the alleger's concern or statements taken from the allegation source documents. The characterization statements do not represent a staff assessment, conclusion, or positio APS first received the allegations from an alleger. This report refers to these allegations as the "A" list. NRC Region V interviewed the alleger. During this interview on August 23, 1984, the alleger provided a list of allegations (without detailed explanation of their significance or meaning). This list of allegations is referred to as the "B" Lis An Allegation Board meeting was held on November 9, 1984, and summarized the key technical issues, which are referred to as the "C" Lis Subsequent interview with the alleger provided another list of allegations known as the "D" Lis APS originally received most of these allegations, and investigated them extensively. The. staff reviewed APS's findings and conducted independent

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. inspections where.necessary. The staff found that the following allegations were addressed and. resolved by APS,as a. result of.the APS investigation. . This was documented.in APS letter to.NRC dated March 7,

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'1985 and April 15, 1985.- The staff's assessment of the allegations below

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centered primarily on, assessing the completeness andl adequacy of the

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rather extensive APS evaluations. -The staff's position <is that the technical! issues were acceptably addressed byfthe:APS evaluatio.nt and that

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APS management- acted in a - respon"sible manner in the conduct of activities

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s addressed by the allegations below. No further staff action on these'

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. . . allegations'are require /

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- Allegation-N "B" List No. 2, 3','ll,"C" List;No. 6 i , (.

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Characterization

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Test equipment specifications were -a'rbitrarily modified (e.g. , rod.

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oven thermometers, micrometers, Holiday' detectors, Ashcroft. pressure

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gauges). ,~ ,

, ~ Implied Significance- - i Arbitrarily modifying equipment specificatioits could have resulted in work that was performed with test equipment <outside the set-forth accuracies,and/or has'not been properly evaluated for acceptabilit This could affect the ability of systems required to achieve an maintain the designed safety function '

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~ Assessment of Safety Significance The'staf'f a'ddressed this allegation by reviewing the licensee's investigation and supporting documentation. The licensee wrote CAR No. C0-85-0061 dated March 20, 1985 to identify and correct:

deficiencies regarding accuracy tolerances. Arizona Nuclear Power

_ProjectL(ANPP) letters' dated March 7,1985 and April- 15,-1985 documenting investigation results were reviewe '

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<ANPP investigation concluded the following:

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Work Plan Procedure WPP 7.0 entitled " Calibration and Control of Construction Measuring and Test Equipment," allows the_ Instrument =

- Calibration' Laboratory Engineer (ICLE) to establish -accuracies - for Meas'uring and Testing Equipment based on project requirements. This

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accuracy may be different'than that specified by the manufacturer, depending on the u'se of.the M&TE.

, , , (1)_ Rod oven-thermometers were found to have an accuracy.specifie'd

'by -the'ICLE different- from that of' the manufacturer's specified accuracy. The licensee found-that based on Bechtels' Material

.and Qualification Services (M&QS) test data, this would not have~an adverse affect on-the quality of the completed weld. A review of, weld rod holding oven temperature monitoring logs revealed that approximately'seven instances out of approximately 10,000 records were less than the required

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temperature. These; instances were recorded on NCR WX-135 '

This' condition was evaluated as having no safety significanc ~

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(2)> Ashcroft' pressure gauges' addressed.in CAR No. CO-85-0061.was .

found to have an ICLE specified accuracy different from that.of Ethe. manufacturers specified accuracy. Bechtel reviewed ,

documented hydrostatic test records including documentation of n pre-test and post-test calibrations and- percent ' accuracy of

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test gauges and calibration equipment.used. 'These records were found to meet required accuracies. Bechtel's evaluation

concluded that there was no case where the ICLE specified accuracy could have-had an adverse affe't c on hydrostatic test ~

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lresult ~(3) ' Holiday detectors require field adjustments but not a rigorous

., ' calibration. .The manufacturer operating instruction and Palo

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-Verde procedure No. 202.4 Rev. 2, " Holiday-Testing", references Project Specifications-13-PM-204 and 13-PM-205. The- ,

specifications define _ field adjustment of the detectors. .The,

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--licensee also held discussions with cognizant personnel'to assure that personnel understood the procedures. No-

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discrepancies were note : (4) ANPP's investigation concerning micrometer specifications revealed that the micrometers are calibrated utilizing gauge

'blo'ck sets traceable to the National Bureau of Standards (NBS).

In ANPP's review of five micrometer sets, one was.found to be-

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accepted although it exceeded the manufacturers tolerance.-

.This~ deficiency was documented on a Defective. Instrument 1

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Report,.DIR-92 dated June 29, 1981, and was found not to affect- 1, any previous' installatio ' '

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' Staff Position *

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The staff. conclude'd'that although ICLE specified a'ccuracies were ,.

_ different from the manufacturer's accuracy as in the~ case of the: rod ioven' thermometers and pressure gauges, this allegation was .

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unsubstantiated in that the ICLE: specifications.were not' arbitrarily

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modified. The staff assessed'a'nd concur ~ red with:thei licens'ee's

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evaluation discussed abov ,

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ActiontRequired j

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f cv Allegation No. "B" List-No. 13,' "C" Lis't No. [

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The use.of weld. volt-amp monitors7 were arbitrarily suspended and the

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weld monitors were not' calibrated-when they"were'used;

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4 Implied Significance

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Failure to use weld-amp monitors during welding of'Charpy'V-notch (CVN) tested materials could result'in the reduction of notch toughness properties of the material with; increasing heat inpu This could cause materials being welded to not meet design '

toughnes , Assessment of Safety Signifbance'-

The staff addressed this allegation by re' vie'ing w the licensee's investigation and' supporting documentation. The licensee wrote s

Procedure Change Notice.No. 27, dated. July 30, 1979, regarding the deletion of the requirement for a voltage and amperage check for material regarding CVN testing in Procedure WPP/QCI No. 10 Justification for the deletion was established by Bechtel Research and Engineering, Materials and Quality Services Department in the report, " Technical and ASME Code Considerations for Notch Toughness Tested Welding Procedure Qualification," dated May 1978, and a M&QS data report on monitoring welding procedures. Prior to deletion of the voltage-amperage check, the instruments were maintained and calibrated by M&TE lab until decontrolled on February 12, 198 Staff Position Based on the above safety assessment, the staff concluded that this allegation was unsubstantiated in that the suspension of the weld-amp monitors was not arbitrary and therefore does not represent a safety concer Action Required None. This item is close . Allegation N "B" List No. 19, "C" List No. 10

, Characterization Welding oxygen monitors were not properly calibrate Implied Significance Improperly calibrated oxygen monitors could result in root oxidation. This could result in inadequate welds and consequently

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reduced structural integrity of the plan Assessment of Safety Significance The staff addressed this by reviewing the licensee's investigation and supporting documentation. The licensee found that the welding oxygen monitors used requires a field adjustment but not a rigorous calibration. The M&TE cal lab performs a functional check of each unit prior to its leaving the lab. The manufacturer's operating

. procedure is attached to the side of each unit for use by personnel

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performing the field adjustment. 'The licensee

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< complies.with the' manufacturer's instructions. ponclude's that'this , ,

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g pro'cedure are attached to'each unitLfor personnel referenc .a-. _*~ .- m-

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None. 'This item is close . . Allegation'No.~"B" List No. 21, "C" List No. 13 ~ Characterization

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Test equipment vendor calibration standards were not traceable to '

the i;ational' Bureau of Standards (NBS).

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Failure to maintain traceability to NBS could result in improper L ,

= calibration of test equipment. This could affect the ability of ,

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systems required to achieve and maintain'the designed safety ,

function [~ TAssessment of Safety Significance .

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m The licensee conducted a-review of the calibration standards used by' q the Bechtel Metrology Laboratory and found'that two out of

, " approximately 215 vendor calibrated items were not traceable to NB '

Further. investigations revealed one item was traceable to NBS and the second item had not been^used. This item is required to'have 1~

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verification of, traceability to NBS pri,r to use by the license Based on the investigation, the licensee _ concluded that vendo '

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calibrations are traceable to NBS.

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- The. staff concurs with'ANPP.that this-allegation.was unsubstantiated and'does not represent'a significant safety concer . et . Action-Required

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'Non This item is closed.

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7. "' Allegation No.'"C" List:No. 12

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. Micrometer ratcheting torque wrenches were frequently used

' imp roperly.- Implied Significance Improperly. t'orqued bolts may. affect the structural integrity of joints, and consequently the structural integrity of the plan . Assessment of Safety Significance ,

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This allegation' was simi '- to a previous allegation addressed in-Inspection Report 50-528/t i-59, regarding." Improper Use'of Tools."

CAR No..CE-84-0298 was generated to correct and' improve' mishandling

. of tools. The licensee monitored.the usage of micrometer type torque wrenches and observed thel raft personnel, clicking theltorque -

wrenches ten times after adjusting,and- prior to. performing bolt

~ # r torquing as recommended by ,the manufacture ,

The inspe'ctor observed the demonstration of the accurac..y ,od'a /

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. micrometer type torque wrench first with clicking -the, wrench ten times and then without clicking the wrench ten times. - Th~e l . >

instrument was;found to produce the' required torque within the"

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allowable tolerance in both case, <

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allegation does not represent a' safety concer = t

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None. This item'is close .

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9'.' L Allegation No. "A List 39

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._, Characterization- '

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Verbal instructionc~which were not reflected in specific written

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) procedures were'being given by the Bechtel-Cal Lab Superviso . Implied Significance-I ~

The-procedures used to calibrate M&TE should be documented

procedures to ensure approved. procedures are used. Using verbal

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-instructions-in lieu of formal written procedures could possibl >>

result in incorrect calibration of M&TE. This could affect the

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4 The' staff addressed the , allegation _by- reviewing 'the licensee' : E investigatio'n and supporting documentation. The licensee discussed

'the concern,with the calibration lab personnel who disclosed that,

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- in fact, the previous Bechtel Cal Lab Supervisor would sometimes

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provide verbal technical direction to cal <1ab personnel.regarding

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h'ow to_ calibrate M&TE which was not reflected in the documented

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would seek' direction.from the cal lab supervisor when the

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manufacturers technical manuals were vague or missing detail. This

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direction would be given verbally. The licensee did not determine

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any situations.that were considered safety significant regarding the

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The licensee issued. CAR No. CP-84-0141,-' dated August 22, 1984', to

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address this issue. ~The corrective action taken as documented in the CAR was to reinstruct the cal lab technicians to follow only-

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< written procedures when performing calibration activities, and when .

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- necessary, to' prepare documented instructions to provide for needed , ,

directio ' In addition,'the licensee monitored the cal lab activities on

- October 9, 23, and 26, 1984. No conditions of procedure violations

,or verbal direction were observed, d '.' ; Staff Position

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The staff has no evidence that the verbal instruction resulted in

any equipment' calibration errors that are considered safety significan .

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10. Allegation "D" List No. 2-

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a., Characterization

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1 Improper calibration of pressure gauges at the site due to M&TE which was calibrated offsite in a different' portion of the: country e

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at a different atmospheric pressur x

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, - Improper calibration.of' pressure gauges could result in systems

.being under - or over pressurized. This could affect'the safe ( '

operationfof_the. plan ~ .

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.. Assessment of Safety Significance

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.ANPP's' investigation revealed that a change in the value of gravity n . between the location.the dead weight tester was calibrated and that (-

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• 8 of PVNGS has a negligible affect on the accuracy of the tester. The local value of gravity is currently being used by the Bechtel M&TE lab. Additionally, a review of the calibration report performed by the Navy Standards Laboratory dated January 19, 1984, determined that corrections for air buoyancy relating to changes in atmospheric pressure had been considered during the calibration of the dead weight teste Staff Position Based on the above assessment, the staff concluded that this allegation did not represent a significant safety concer Action Required None. This item is considered close . TMI Action Plan Requirements (Closed) TMI Item I.C.I "Short-Term Accident and Procedures Review-Inadequate Core Cooling / Transients and Accidents" Summary:

NUREG-0737 requires licensees to perform analyses of transients and accidents, prepare emergency procedure guidelines, upgrade emergency procedures, including procedures for operating with natural circulation conditions, and to conduct operator retrainin Supplement I to NUREG-0737 (Generic Letter No. 82-33), dated December 17, 1982, requires that each applicant; submit a Procedure Generation Package (PGP) at least three months before the date of formal operator training onethe upgraded-procedures. Additional clarification was providedjin NUREG-057 ,

Background:

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The initial C-E Owners Group analysis of Inadequate Core Cooling (ICC) is documented in Report CEN-117,." Inadequate Core Cooling. A Response to NRC IE Bulletin 79-06C, Item 6 for Combustion Engineering Nuclear Steam Supply Systems." This report was submitted to the NRC staff for review on October 31, 197 Subsequently, " Operational Guidance for Inadequate Core Cooling" was prepared by the C-E Owners Group based on the analyses in Report CEN-117. This operational guidance was submitted to the NRC staff

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for review by the C-E Owners Group on December 10, 198 The initial C-E Owners Group analyses of transients and accidents (non-LOCA) are documented in Report CEN-128, " Response of Combustion Engineering Nuclear Steam Supply System to Transients and Accidents." This report was submitted to the NRC staff for. review on April 1, 1980. The analysis in CEN-128 considered a single active failure for each system called upon to function for a particular event passive and multiple failures were not considered.

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The initial C-E Owners Group development of emergency procedure guidelines was completed _in the first quarter of 1980. These emergency procedure guidelines are documented in Report CEN-12 This report was submitted-to the NRC staff for review on April 1, 1980. Early in 1981 workshops were held by the CE Owners Group (CEOG) to provide a formal process by which the emergency procedure guidelines documented in Report CEN-128 would be revised to account for multiple failure considerations. The revised emergency procedure guidelines were submitted to the staff on June 30, 1981 as CEN-15 t As documented in the Palo Verde Safety Evaluation Report (SER) dated November 1981, the CEOG submitted CE Emergency Procedure Guidelines (CEN-152) to the staff for review on June 30, 1981. These guidelines reflected the reanalysis of transients and accidents, and incorporates inadequate core cooling. Based on preliminary staff

[ comments on the revised guidelines, CE and CEOG agreed to incorporate staff comments into a revised guideline (CEN-152, Revision 1).

Findings and Conclusions:

The licensee uses the Emergency Procedure Guidelines to develop the Emergency Procedure Generation Package (PGP). The PGP is.then used to generate the Emergency Operating Pr'ocedures (EOPs). *

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As documented in Palo Verde SSER 6, the staff issued a safety _

evaluation'which approved the CEOG Emergency Procedure Guidelines (CEN-152, Revision 1) on July; 29, 1983. On July.15, 1983, the PGP for PVNGS 1-3 was formally' submitted:for staff review. The submitted PGP was separated into'five parts as'follows:

A plant-specific-technical guidelin *

A plant-specific writer's guide'

A description of the program ~ for E0P' verification

A description of the program for E0P validation ,

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• A description of the program for training operators on th upgraded E0Ps NRR performed a review of each of the five parts and concluded that the licensee's program for preparing and implementing E0Ps was acceptable. This TMI item is considered close The inspector noted that three months following the staffs evaluation of CEN-152 Revision 2, the licensee committed to submit a schedule for revising the PGP to be in conformance with CEN-152 Revision 2 and the E0Ps to be in conformance with the revised PG The Emergency Procedure Guidelines (CEN-152 Revision 2) was accepted by NRR in a letter dated April 16, 1985. A review of the implementation of the above commitment and a review of operator training will be verified during a future inspection (0I-85-19-01).

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(Open) ' Item III.D.I.1', " Primary Coolant: Outside of Containa'ent"

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?NUREG-d737requ_iresaproglramtorreducelleakag~efromsystemsout

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. containment that would or.could cont'ain highlyDradioactive fluids

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during a-serious transient oi-sccide'nt to as'-low?as prict'ical-I ' levels . This program shall Include theifollowin'g: ],.

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N '(1) 1Immediate leak reduction' -

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(a) LImplement all practical-leak reduction measure's for all systems that could carry radioactive fluid outside of -

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(b) ' Measure actual leakage rates with system in operatiion and  ;

report them to the NR .

(2) Continuing Leak Reduction -- Establish and implement a program

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of preventive' maintenance to reduce leakage to

- , as-low-as practical levels. This program shall includ t periodic integrated leak tests at intervals not to exceed each refueling. cycl '

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~NRR reviewed ANPP?s. leak; testing ~and leak preventative maintenance

program and found them acceptable as documented in Palo Verde-SSER ,

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IAt the time of'the inspection, an actual measurement of leakage

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-g- rates had not been performed.-

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N This item will remain open pending a review of ANPP's measurement of

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actual leakage rates and subsequent report to the NR ~

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'1 Management Meeting The ' inspector met w*th the licensee management representatives . denoted in

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paragraph I on.May 17, 1985. The scope of'the inspection and the

inspectors' preliminary findings as noted in this report were discusse ,

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