IR 05000528/1990026
| ML17305A986 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/26/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305A985 | List: |
| References | |
| 50-528-90-26, 50-529-90-26, 50-530-90-26, NUDOCS 9008100049 | |
| Download: ML17305A986 (13) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report Hos. 50-528/90-26, 50-529/90-26 and 50-530/90-26 Docket Nos. 50-528, 50-529, 50-530 License Nos.
NPF-41, NPF-51, NPF-74 Licensee:
- Arizona Public Service Company Facility Name:
Palo Verde Nuclear Generating Station (PVNGS) Units I, 2 and
Inspection at:
Palo Verde Site, Mintersburg, Arizona Inspection Conducted:
June 4-27, 1990 Inspector:
C. A. Clark, Reactor Inspector-W. J 'eac or Inspector Approved by:
. Huey, C ief Engineering Section Date
>gne Ins ection Summar
Ins ection Durin the Period June 4-27, 1990 (Re ort Nos. 50-528/90-26,, 50-529/
0-an-53 Areas Ins ected:
An unannounced routine inspection by two regional inspectors.
reas inspected include: previously identified items, motor operated valves (MOVs) and check valves.
Inspections Procedures 30703, 73756, 92701 and 92703 were used as guidance for the inspection.
Results:
General Conclusions and S ecific Findin s:
The licensee has initiated a formal check valve program, which appears to be'ddressing the latest industry concerns in this area.
The licensee is following motor operated valve concerns in the industry, and appears to be addressing the latest concerns in a timely manner.
The licensee has acknowledged that their vendor interface program has some weaknesses, and is attempting to resolve the identified concerns.
Si nificant Safet Matters:
None t
Summar of Violations:
None 0 en Items Summar
There were no new open items identified; four items were c ose.
Persons Contacted DETAILS
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Overbeck, Director, Technical Support Bradish, Manager Compliance Webster, Manager, Component/Specialty Engineering Joyce, Manager, Maintenance Shanker, Project Manager, OPIUM Badsgard, Supervisor, Engineering and Construction Waldrep, Supervisor, Mechanical Components Rouse, Compliance Engineer Kawter, Senior Coordinator, Part Services Henry, Site Representative, SRP Summy, Manager, System Engineering Fountain, gA Deficiency Coordinator Karitz, Compliance Engineer Shell, guality Systems Manager Prabhakar, Manager, guality Engineering
.
Wittas, Supervisor, Technical guality Engineering Johnson, Electrical Engineer Pierno, Calibration Test Engineer Cutler, Supervisor, Maintenance Standards Rannells, Supervisor, Protection Chemistry Training 2.
- Attended the Exit Meeting on June',
1990
+Attended the Exit Meeting on June 22, 1990 Previousl Identified Items (92701 a ~
(Closed Unresolved Item No. 528/89-28-02:
Level A Stora e
em erature an urn> st
-
na e uate ro em eso ut1on
\\
.Engineering.Evaluation Report (EER)
No. 84-ZZ-058 pointed out that the Level A storage requirements for temperature and humidity specified for some parts in stock were not being met.
This EER, issued in 1984, was lost and subsequently replaced by EER No.
88-ZZ-037 to address the same environmental concerns.
Because this EER was still pending resolution at the time of the inspection, the NRC inspection team considered the failure to achieve satisfactory resolution to this problem, over a five year period, an example of the failure to effectively implement Procedure No. 73 AC-OEE01.
Procedure No. 73AC.OEEOl, entitled "Engineering Evaluation Request,"
governs the identification and prompt resolution of nonconforming conditions.
The issue regarding improper designation of Level A warehouse storage was identified as NRC Open Item No. 528/89-28-14.
This item was closed based upon vendor confirmation that the original hardware level A storage designation was incorrect; the items actually required level B storage and were found in the level B storage are The prompt resolution, and the size of the backlog, of EERs was also a concern being addressed by licensee management.
Discussions with licensee personnel revealed that the subject of backlogs was being addressed by management prior to the NRC identification of specific issues regarding lost or lengthy resolution and deposition of EERs.
Mr.
W.
Conway, in correspondence ( ID No. 001-00208-WFC) to
"PVNGS Directors and Managers" dated July 31, 1989, established goals for backlogs in key areas such as, Corrective Action Reports, Nonconformance Reports, Monitoring Reports, Warehouse Deficiency Notices, Regulatory Commitments, Operating Experience Reports, Incident Investigating Report Action Items, EERS, Plant Change Requests, Drawing Change Notices, Instruction Change Requests, Preventative Maintenance Requests, Corrective Maintenance Requests and Purchase Requisitions.
The goal regarding EERs was for disposition within 90 days of issuance; all EERs were to be tracked on Commitment Action Tracking System (CATS) by Engineering Evaluations.
Since that letter on backlog goals was issued, EERs are no longer the means for documenting nonconforming conditions; nonconformance on 'safety-related items are currently documented on Material Nonconformance Reports (MNCR).
Approximately 2500 EERs were reviewed by the licensee to determine MNCR applicability; this effort identified 170 EERs as potential MNCRs.
Fifty-eight were subsequently converted to MNCRs; as of this inspection
MNCRs were open in various stages of implementation.
The licensee appears to have been successful in their efforts to reduce the backlog of EERs to ensure prompt resolution of problems.
This item is closed.
Closed)
Unresolved Item No. 528/89-28-10:
Food Consum tion in a )at>on rea This issue concerned a box containing approximately 40 empty soft drink cans found on a cabinet in the Radioactive Liquid Waste Processing Control Room.
The area was posted no eating or drinking.
The inspectors questioned whether the soft drinks had been consumed within the posted work area.
The licensee performed an investigation of this matter and concluded that the 40 empty soda cans were in the Radwaste Control Room because an employee was collecting empty aluminum cans for the purpose of recycling.
This conclusion is documented in licensee correspondence ID No. 203-00339-FCB dated December 14, 1989.
Inspector conversations with licensee personnel indicated that the cans were being stored in this location because that was the employee's assigned work place;-
Based on the information reviewed and discussions with licensee personnel, it appears that no food was consumed in the RCA.
This item is close c ~
(Closed Unresolved Item No. 50-528/89-28-04:
Failure Data Trendin na e uate ro em eso utson This item involved inadequate resolution of problems identified by licensee quality assurance audits.
The audits identified that the system engineers were not consistently reviewing the quarterly FDT reports and preparing.Root Cause Failure (RCF) reports of the components exceeding the established failure threshold, or documenting why such reports were not necessary as required by plant procedures.
The inspector's review of the procedures established to address the FDT program revealed that recent revisions have incorporated adequate provisions to resolve these issues.
If properly implemented, procedural compliance should preclude recurrence of the problems identified by licensee quality assurance audits.
This item is closed.
d.
(Closed)
Unresolved Item No. 528/89-28-12:
Trainin of nstrumentation an ontro I
aintenance ersonne na e uate ro em eso ution Corrective Action Request (CAR) No. 87-0099 addressed the issue of deficient training and qualification of personnel performing ISC maintenance technician activities in 1987 and initiated a training program for fire protection personnel required to perform these activities.
The corrective action for fire protection personnel required the Shift Fire Captain to review each crew member's personnel file to verify that the individual was qualified prior to performance of the maintenance test procedure.
This requirement was incorporated into Department Guideline 22, Appendix A and. B.
To ensure that all personnel are adequately trained and qualified to perform work, the licensee has generated and is implementing procedure 15 AC-0-TR01 entitled,
"Personnel gualification and
.Certification."
This procedure applies to, but is not limited to, RPITs, radwaste technicians, electrical test engineers, and site engineers.
This procedure requires the responsible Managers/
Supervisors to implement the applicable procedural method for certification of employees and contractors to ANSI/ANS 3. 1-1978.
The current Revision 2, effective date of February 9, 1990 included changes to, (a) clarify and provide additional details to the process of hiring non-specialized contract employees and ensuring their qualifications to work independently, and (b) to establish the
. responsibilities for ensuring continuing training requirements are identified and met.
Regarding the generic implications of CAR No. 98-0099, the licensee has revised their corrective action prooram to address the applicability of corrective actions to other personnel performing maintenance or similar activities.
For example, procedure
l
60AC-OQQ02, entitled "Corrective Action," Section 3.3.3.4 requires the Manager, Quality Audits and Monitoring to "Determine if the CAR is potentially generic.
If determined to have potential impact on other units/organization, forward a copy of the CAR to the affected unit/organization manager for evaluation."
Also, the CAR form provides a check off for "Potentially Generic Implications" and space for identifying the affected 'organizations.
In conclusion, although CAR No. 87-0099 did not specifically address RPITs or other personnel performing ISC maintenance activities, there are program changes, developed in 1989, which are currently being implemented that identify the technical requirements to assure that only qualified individuals are certified to perform duties of a specific job.
Also, the corrective action program was strengthened by including provisions for handling potentially generic concerns.
This item is closed.
No violations or deviations were identified in the areas reviewed.
3.
Inservice Testin of Pum s and Valves 73756 A review of licensee performance of Inservice Testing (IST) and maintenance activities for check valves and motor operated valves was accomplished during this inspection.
Based on a sample review of available licensee documents, and discussions with licensee personnel, the inspector identified the following information.
a
~
Check Valves - The licensee has initiated the following actions in (1)
Contracted with Bechtel to prepare check valve study number 13-MS-A24, "Check Valve Evaluation Program for PVNGS".
Revision 1 of this study has been issued at this time.
(2)
Implemented a check valve program, using information from the Bechtel check valve study (number 13-MS-A24) for information and guidance.
(3)
Issued procedure 73AC-OXI03, Revision I, "Preventive Maintenance of Check Valves", to provide administrative guidelines and controls for the disassembly and inspection of check valves.
This procedure was initially issued December 20,.
1989.
(4)
Issued a January 19, 1990 Revision 4 to procedure 73TI-92219,
"Visual Examination of Pump and Valve Internal Surfaces,"
to incorporate Significant Operating Event Report (SOER) 86-03
, check valve inspection requirements.
(5)
The Engineering Evaluation Department Technical Support Engineering Section (EED-T) has designated an EED-T Lead Engineer for check valves, to coordinate licensee actions in this are (6)
The EED-T was monitoring the daily performance of the Unit 2 check valve inspection and work activities during this refueling outage."
The status of this performance is reported daily in a "Check Valve Daily Status Report."
(7)
The EED-T has established communication with other licensees, vendors, etc. to obtain information based on the 'latest industry check valve experience.
After reviewing the above information it appears the licensee has taken appropriate actions to initiate a formal check valve program.
The performance of this check valve program will be the subject of a future inspection.
b.
Motor 0 crated Valves The licensee has initiated the following recent actions in this area:
(1)
A licensee task force reviewed the motor operated valve (MOV)
program, and provided recommendations for improvement, such as item (2) below.
(2)
In response to an MOV task force reconmendation, the technical data department compiled a three volume information report on motor operator valves.
The purpose of this report was to collect all the available MOV information based on NRC documentation, industry operating experience reports, etc. in one document where it would be available for applicable licensee personnel.
These three volumes were issued as uncontrolled documents, for information only, to be updated informally.
During a review of. this.information, the.inspector identified the following weakness regarding the collection of MOV information.
Limitorque Corporation had issued four limitorque maintenance updates (8/88, 88-2, 89-. 1, and 90-1) for their valve operators, however only maintenance update 88-2 was in this report. 'he copy of update 88-2 included in the licensee report had been obtained from the valve motor operator lead engineer.
The lead engineer for the motor operators had a
copy of update 90-1 for review, but did not have copies of updates 8/88 or 89-1.
The inspector provided a copy of update 8/88 to the licensee and they stated they would enter these two updates (8/88 and 90-01) in the HOV report, the drawing and data control (DDC) program, and obtain a copy of update 89-1.
The licensee could not locate any of these four Limitorque maintenance updates in their drawing and data control (DDC)
program.
This item will be addressed later in this report under paragraph 4, vendor interface program.
(3)
Issued a March 29, 1990 PVNGS motor operated valve program executive summary, on the subject of "Unit 2 Status of Testing Motor Operated. Valves to Meet INPO'A1. 1 and NRC Generic Letter 89-10 requirements".
(4)
Issued a Nay 18, 1990 PVNGS MOV project dedicated assignment memorandum, assigning leads for NOV work.
(5)
Issued a June 1,
1990 letter.( ID Ho.: 225-00578-GRO/JSS),
for
"Realignment of Motor Operator Valve Automated Testing System, (NOVATS) Engineering Support".
(6)
Issued a June 6, 1990 letter (ID No: 111-00444-DWS/CJR/HGJ),
to identify "Commercial Operating History of Motor Operator Degraded Conditions for Palo Verde Units 1, 2, 3.
The above actions indicate that additional management attention into the MOV program has identified areas of concern to which the licensee has initiated positive management actions to resolve.
The licensee method of NOV stroke time testing was also reviewed.
The licensee performed NOV stroke time testing with a stop watch, using the switch-to-light technique, (i.e., the interval of time measured from control switch actuation to light indication of position).
There has been a concern at some facilities that this technique does not account for the inaccurate closed position light indication which occurs on limitorque actuators using a
common limit switch rotor for both the closed light position indication and torque switch bypass control.
As a result of this dual function design rotor feature used at some facilities, the valve may be still open by as much as 15'A when the closed position is indicated by the lights.
The valve will continue to travel toward the closed position, until the rotor torque switch actuates to complete the cycle.
The. licensee identified that this was not a concern at Palo Verde, since their limitorque actuators do not share a
common limit switch rotor for the closed light position indication and the torque switch bypass control.
It. appears the licensee method of MOV stroke time testing is performed in an acceptable manner.
The licensee actions in the area of MOV spring pack relaxation in some limitorque actuator was reviewed, and it appears the licensee
's closely following this item.
Spring pack relaxation/gap is checked during valve testing and maintenance activities, and spring packs are adjusted or replaced as required.
The licensee has issued a procedure for quantitizing spring pack gap (32NT-9ZZ55).
The procedure establishes specific criteria for evaluating t e acceptability of any detected gap.
Licensee implementation of this procedure and assessment of engineering involvement in spring pack gap evaluation will be reviewed during a future inspection.
This is an open item (528/90-26-01).
violations or deviations were identified in the areas reviewed.
Confirmator Action Letter, and Generic Letter Followu No Bulletin 92703 Generic et er L t 83-28
"Required Actions Based On Generic Implication of stated in art:
Salem ATWS Events" was issued July 8, 1983.
This letter s
'
"F d
t face licensees and applicants shall establish, or ven or in er ensure that vendor implement and maintain a continuing program to ensure
= information for safety-related components is complete, current and
controlled throughout the life of their plants, and is appropriately referenced or incorporated in plant instructions and procedures.
Vendors of safety-related equipment should be contacted and an interface
"
established.
...The program shall include periodic communication with vendors to assure that all applicable information has been received.
The program should use a system of positive feedback with vendors for mailing containing technical information.
This could be accomplished by licensee acknowledgement for receipt of technical mailings.
It shall also define the interface and 'division of responsibilities among the licensee and the nuclear and non-nuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control of and applicable instructions for maintenance work on safety-related equipment are provided."
It appears that the licensee did not establish, implement and maintain a
vendor interface program that met all the requirements of generic letter 83-28.
For background information, the following information is provided.
a.
The NRC has identified concerns with the licensee Vendor Interface program in the following inspection reports.
50-528, 529, 530/89-28, paragraph D., Open Item 528/89-28-03 50-528, 529, 530/89-30, paragraph 14,=- Open Item 529/89-30-04 50-528, 529, 530/90-22, paragraph
b.
Licensee Corrective Action Report (CAR) number CS89-0059 was issued August 30, 1989, to address concerns with the Vendor Interface Program.
c ~
Generic Letter 90-03, "Relaxation of staff position in Generic Letter 83-28, Item 2.2 Part 2 "Vendor Interface for Safety-Related Components" was issued March 20, 1990, to clarify the NRC position on this subject.
The licensee has unti 1 approximately October of 1990 to respond to this generic letter.
As of this inspection the licensee has taken the following initial actions to improve the vendor interface program.
a ~
b.
Issued Revision 2, of the Vendor Technical Manual (YTM) project scope 2 schedule, dated March 19, 1990.
Issued a letter (IDbNo. 285-00283-ECS/DRJ)
dated April 16, 1990, in response to NRC Open Item 528/89-28-03, which,provided a final action plan and schedule required to address this open item.
This action plan identified that the licensee is planning to accomplish the following:
(I)
Provide the correct licensee mailing address to each safety related vendor, for vendor informatio (2)
Provide training, which describes the service information letter evaluati'on and corrective action process, to all Technical Data and Nuclear Engineering Department (NED)
engineers that evaluate Service Information Bulletins.
(3)
Conduct a performance base audit by June 30, 1991 to determine the effectiveness of the vendor interface program after completion of the actions in steps ( I) and (2) above.
After reviewing the above information and documentation, it appears that the licensee is aware of the weaknesses in their vendor interface program, and have initiated corrective actions to address the identified concerns.
No violations or deviations were identified in the areas reviewed.
5.
Exit Meetin (30703)
The inspectors met with the licensee management representatives denoted in paragraph 1,
on June 7 and 22, 1990.
The scope of the inspection and the inspector's findings up to the time of the meetings were discussed.
At these meetings the inspectors identified that additional information had been obtained, that would be reviewed in the NRC regional office.
The information was reviewed and the findings included in paragraphs 2,
and I t
I f
i
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