IR 05000528/1990040
| ML17305B116 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/27/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17305B115 | List: |
| References | |
| 50-528-90-40, 50-529-90-40, 50-530-90-40, IEIN-90-006, IEIN-90-019, IEIN-90-020, IEIN-90-025, IEIN-90-026, IEIN-90-039, IEIN-90-040, IEIN-90-19, IEIN-90-20, IEIN-90-25, IEIN-90-26, IEIN-90-39, IEIN-90-40, IEIN-90-6, NUDOCS 9010170271 | |
| Download: ML17305B116 (18) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos.
50-528/90-40, 50-529/90-40 and 50-530/90-40 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 1, 2 and
Inspection at:
Palo Verde Site, Wintersburg, Arizona Inspection Conducted:
August 27-September 7,
1990 Inspectors:
C.
A. Clark, Reactor Inspector P.
G. Galon, Reactor Inspector Approved by: ~
.
Huey, ie Engineerin Section r<<< /=l"t/
a
>ge Ins ection Summar
Ins ection Durin the Period Au ust 27-Se tember
1990 (Re ort Nos.
-
-
9 -4 an Areas Ins ected:
An unannounced routine inspection by two regional inspectors.
reas inspected include:
previously identified items, and the effectiveness of the licensee's program for handling NRC Bulletins,
, Information Notices and Generic Letters sent to the licensee.
Inspections Procedures 30703, 92701 and 92702 were used as guidance for the inspection.
Results:
General Conclusions and S ecific Findin s:
The licensee Operating Experience Review Programs for NRC Information Notices was not effectively implemented in all cases.
See paragraph 2.A for additional information.
The licensee had identified that they have instituted significant changes in its deficiency identification and root cause analysis programs.
But, recent NRC inspection rep'orts have identified that various licensee procedures contain instructions that would allow bypassing the deficiency identification and root cause'nalysis programs.
See paragraph 2.B.(4)
for additional informatio Si nificant Safet tlatters:
Hone Summar of Violations:
None 0 en Items Summar
There was one open item identified paragraph2.A.;
four
'tems were c osed and one item was left ope DETAILS 1.
Persons Contacted 2.
"G. Overbeck, Director, Technical Support
- T. Bradish, Manager Compliance
~R.
Flood, Unit 2 Plant Manager
~R.
Adney, Unit 3 Plant Manager
"R.
Rouse, Compliance
- J. Baxter, Compliance
"R. Bouquot, equality Audits Supervisor
"L. Henson, APS-Site Nuclear Engineering Electrical Supervisor
~S.
Kanter, Participant Service Coordinator
- J. Draper, Southern California Edison Company Site Representative
"K. Hall, El Paso Electric Company Site Representative B. Ecklund, Technical Data Supervisor R. Bernier, Licensing Supervisor
~F11 t>>7D j A.
Followu of the Effectiveness of the Licensee's Pro ram for and
>n C
u etlns n ormation otlces and Generic etters ent to t e licensee On a sampling basis the licensee performance in this area was verified for the following actions:
Were received NRC documents reviewed for applicability, k
Did NRC documents receive proper distribution to the appropriate personnel at the corporate and site levels, and If applicable, was the scheduling and/or performance of appropriate corrective actions handled satisfactorily.
During this inspection it was identified that prior to January 1,
1990, Nuclear Licensing was responsible for ensuring that NRC issued documents (Bulletins, Information Notices and Generic Letters) were effectively implemented in the Industry Operating Experience Review (OER) Program.
Responsibility for NRC documents issued-after January 1,
1990; was assumed by the Technical Data Department.
The licensee identified that:
Licensee procedure 95PR-ONS01, Revision 1 "Industry Operating Experience Review Program" described the licensee activities, interfaces, and responsibilities for handling the applicable NRC documents.
Licensee Instruction 95DP-ONS01, Revision 1, "Industry Operating Experience Review Program Department Instruction"
described the activities, interfaces and responsibilities for the licensee Technical Data Department handling of the applicable documents.
All NRC documents undergo initial screening by the Technical Data Department.
If this screening concludes that a detailed evaluation is required, then they are sent to Licensing for assignment to a licensing engineer for evaluation, then returned to the Technical Data Department to complete the screening activity.
This screening process should be performed within ten working days of logging of receipt of the NRC documents in the Technical Data Department, per licensee instructions in the above procedure and instruction.
A sample review of NRC Bulletins and Generic Letters found that they appeared to have been handled in an appropriate manner.=
During the review of Information Notices, the following discrepancies were identified for some 1990 issued Information Notices:
A review of the current Technical Data Department Commitment Action Tracking System (CATS) Report (I.D.
POER 42-NRC), dated August 29, 1990, identified seven 1990 Information Notices (IN's) that were not entered in the system.
The missing IN's were IN 90-06, 90-19, 90-20, 90-25, 90-26, 90-39, and 90-40.
A review of the Technical Data Department log book and other records identified that all seven IN's had been received by the licensee Technical Data Department and started the initial screening process.
Normally the Technical Data Department assigned'responsible engineer initiates the Appendix A
"operating experience screening/evaluation form."
This was concurred to by the Technical Data supervisor and forwarded to Licensing with a 'cover letter.
This cover letter identifies an evaluation due date, requests identification of a Licensing engineer to perform the required evaluation, and a review signature by the Licensing supervisor.
Once the Licensing supervisor signs off and returns the Operating Experience Screening/Evaluation form to the Technical Data Department, the Operating Experience Secretary is directed to Log the document as returned and enter the information on the OER CATS within 3 working days.
The total screening process should, normally, only take 10 working days.
The log book showed that:
(1)
IN 90-06 had been logged in February 13, 1990, and not logged out to Licensing.
Other Technical Data Department Information identified that this IN had been closed out by a March 15, 1990 letter (ID 8254-00790-BSE/PEF)
and the information had not been entered in the log book and/or OER CATS.
(2)
IN's 90-19 and 20 had been logged in April 12 and 13, 1990, respectively, and both were not logged out to Licensing; but both were logged as returned April 25, 1990.
Other Technical Data Department information
(3)
(4)
(5)
identified that the screening/evaluation forms for both INs had been signed off April 13 and 16, 1990, respectively, as N/A, not requiring any further action.
Again the IH's and close out information were not entered in the OER CATS.
IN 90-25 was logged in May 1, 1990, logged out to Licensing May 10, 1990 and logged returned from Licensing May ll, 1990.
Again the IN and close out information were not entered in the OER CATS.
IN 90-26 was logged in May 2, 1990, logged out to Licensing May 10, 1990, and not logged as, returned.
These dates did not agree with the dates identified on a screening cover sheet, which identified the date received as April 25, 1990 and screening due May 9, 1990.
Section G of the screening/evaluation form had a priority identification of routine:
Evaluation must be completed within 90 days (date:
August 7, 1990).
As of August 30, 1990 the evaluation was not available and the IN was not entered in the OER CATS.
The Licensing Department identified that a followup letter (ID ¹161-03387-RAB/JST)
was issued August 10, 1990 by Licensing, which requested a
summary of the evaluations for IN's 90-26 and 90-39 by September 1, 1990.
IN's 90-39 and 90-40 were logged in June 14, 1990 and logged out to Licensing June 15, 1990 and not logged as returned.
The Technical Data Department did not keep copies of IN Operating Experience Screening/Evaluation packages sent out to Licensing.
Licensing could not locate the package for IN 90-39 during this inspection, to verify the original evaluation due date.
Licensing did identify that the August 10, 1989 licensing follow-up letter (ID 161-03387-RAB/JST)
requested a summary of the evaluation for this IN by September 1, 1990.
The IN Operating Experience Screening/Evaluation package for IN 90-40 identified that an evaluation was required by August 15, 1990.'uring this inspection the licensee located a
July 5, 1990 handwritten memo; which identified that the evaluation date for IN 90-40 had been changed from August 15, 1990 to October 15, 1990.
Again, none of this information was available in the log book or OER CATS.
Based on review of the above information, it appears that the licensee's Operating Experience Review (OER) Program for INs was not effectively implemented in all cases.
Some of the reasons for this identified program weakness, were:
Procedure
PR-ONS01 and instruction 95 DP-ONS01 did not appear to provide detailedinstructions on how the NRC documents/IN's were routed from the Technical Data Department, through the Licensing Department and back to
the Technical Data Department during the initial screening process.
There was no formal licensee tracking system within the Technical Data Department for these NRC documents until they were entered on OER CATS via the Technical Data Department, which may have been several months later.
Since Licensing has this shared responsibility to perform the initial screening, which should be performed within 10 working days, there should be some tracking system to ensure they do not get lost within Licensing without some follow up action.
Several of the documents in the OER screening evaluation packages contained signatures without dates, which prevented accurate verification of when various actions were performed in this area.
The licensee acknowledged the above findings during the inspection, and identified that they would review this area for implementation of changes to preclude further discrepancies in this area.
On September 13, 1990 the licensee notified Region V via telecon that while the Technical Data Department OER CATS had not been updated for the seven IN's, Licensing had been tracking the Licensing Department actions taken on the seven IN's.
This information was tracked in the Licensing portion of the CATS RCTS partition.
The licensee identified during this
.
telecon that CATS is under evaluation at this time, to identify what changes wi 11 be required to correct the discrepancies between the OER program CATS reports.
Since there were no problems identified that would effect safety related equipment, this item will be tracked as followup item 50-528/90-40-01.
This item can be 'closed when an inspector reviews the action taken by the licensee to ensure effective implementation of the OER program, for all NRC Information Notices.
B.
Followu of Previousl Identified Items (1)
(Closed 50-55 Re ort Item No. 50-528/89-02-01 Potential Overf ow of rans ormer
etent)on um Pits The initial inspection identified that the licensee did not have a maintenance/surveillance program established for the transformer oil retention sump pits at the time of a transformer fire.
This was identified as an example of the licensee's inattention to detail in the fire protection area.
Followup inspection report No.
90-02 identified that the licensee had established a maintenance/surveillance program for the oil retention sump pits, and that a review of the program identified the following program weaknesses:
(a)
Inspection Procedure 14 FT-9FP01, Revision 1, did not contain:
A clear and effective inspection acceptance criteria.
Effective 'instructions for removal of unacceptable amounts of. water, sand and/or foreign material found in sump pits during inspections.
(b) It appeared that licensee personnel, assigned to perform sump pit inspections, required additional training.
During this inspection the licensee identified that Procedure Change Notice (PCN)
No.
Ol had been signed out August 29, 1990, for inspection procedure No.
14FT-9FPOl, Revision l.
A review of this latest PCN identified that additional instructions had been provided for clarification of the inspection acceptance criteria, and removal of unacceptable amounts of water, sand and/or foreign material found during sump pit inspections.
After reviewing the information identified above, it appears the licensee has addressed the original program weaknesses identified in this area.
This item is closed.
(2)
(Closed)
Re ortable Occurrence No. 50-528/89-15-LO Switch ard lre Voluntary Licensee Event Report (LER) No. 89-015-00 identified the following:
On January 17, 1988 the Dever
"B" phase shunt reactor Failed due to a bushing failure.
This shunt reactor is not safety related.
Southern California Edison (SCE)
repaired the shunt reactor and returned it to Palo Verde on August 5, 1989.
Mhen SCE performed 'the shunt reactor repair work, they could not complete all the routine tests normally performed after a repair.
The closest facility that could perform full testing of the repaired unit was in Toronto, Canada.
Because of the expense of the test, time for transporting the unit to Canada and the risk of damange during the long trip, SCE elected to return the unit to Palo Verde without full testing.
The Salt River Project (Operating Nanager for the Palo Verde Switchyard)
normal way of handling major repairs on this type of equipment, was to include full factory testing as part of the repair.
After several discussions were held with SCE, a compromise was reached to follow certain precautions during reinstallation of the equipment
0
and perform reduced impulse testing with a portable impulse generator.
On August 31, 1989 the Dever line, including the repaired
"B" phase shunt reactor, was energized.
On September 1,
1989 the repaired
"B" phase shunt reactor failed catastrophically.
All other portions of the switchyard remained in service during and following the event.
All three units handled this failure as designed.
The cause of the fai lure of the phase
"B" shunt reactor was believed to be moisture or flaws in the vertical pressboard support or flaws in the insulating tape on the lead; Full testing of the phase
"B" shunt reactor may have identified any insulation problems.
To prevent recurrence of a similar event, the Salt River Project will approve and review the results of switchyard component testing prior to acceptance of equipment for installation in, the switchyard.
Various Salt River Project memo's issued September 27, 1989 by Electrical Engineering, identified as corrective actions after the failure of the Devers B phase line reactor, that:
Any replacement or new 500 KV line reactors obtained
,for installation at Palo Verde, shall require full routine testing.
The performance of this routine testing shall be a
condition for acceptance of this equipment on site.
Any replacement 500 KV line reactors installed in the Palo Verde switchyard shall be test energized from the remote end a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to being energized from Palo Verde.
Based on the information identified above, it appears the cogniza'nt organizations have addressed this item sati s factori ly.
Thi s item i s cl osed.
(3)
(0 en) Fol lowu Item No. 50-528/89-16-02 Inflow Method for oca ea rate estrin ot se s
m se The original inspection identified that:
The LLRT surveillance procedures did not explicitly show that when the outflow method was used, it was equivalent to or more conservative than the inflow method.
This determination prior to using the outflow method is recommended by ANSI/ANS 56.8-1987,
"Containment System Leakage Testing Requirements,"
paragraph 16. For testing done on non-pressurized systems, the outflow method will not detect boundary leakage which escapes through paths other than via the flow detector.
The inflow method, however, conservatively detects non-boundary leakage as well as boundary leakage.
Since the majority of LLRT surveillances performed by the licensee utilized the outflow method, and the licensee's FSAR appeared to implicitly allow the inflow method, it appeared that additional review in this area was required for clarification.
During this inspection, it was identified that the licensee had taken the following actions:,
Reviewed the finding of a report entitled "Final Report Local Leakage Rate Testing Results and Rotameter Evaluation",
issued October 31, 1988'his report was p'repared for the Palo Verde Nuclear Generating Station by the Bechtel Power Corporation.
The subject testing was discussed in section 5, "Review the inflow and outflow testing methodology used at PVNGS", of the report.
Contracted with BCP Technical Services, Inc for a review of Appendix J type C testing methods.
A report entitled
"Final Report on Independent Review of Appendix J type C
Testing methods",
was issued Hay 18, 1990.
The licensee was reviewing the findings and recommendations of this report, and identified that their Commitment Action Tracking System (CATS) has identified this review item as commitment No.
038975 and assigned an administrative due date of December 1, 1990.
W This i tem will remain open until the licensee has completed its review and evaluation, identified what actions will be taken in this area, and a inspector has reviewed the identified licensee actions.
(4)
(Closed)
Enforcement Item No. 50-528/89-28-06.
Diesel Generator Parts ai ure ue o Corrosion The initial inspection identified:
That Diesel, Generator (DG) cooling-subsystem plug and elbow fitting failures occurring September 15, 1989 through April 12, 1989 were not corrected to preclude repetition and potentially significant common mode fai lures.
Although engineering evaluation reports were issued by the licensee on four occasions to resolve the corrosion problems that resulted in repeated and multiple failures of these parts in all three units, effective corrective
actions had not been implemented at the time of the initial inspection.
A November 30, 1989 licensee response (102-01530-WFC/TDS/TRB)
to thi s vio 1 at jon, identified the following:
The initial June 25, 1987 OG cooling elbow failure and replacement did not require an engineering evaluation, as the program in place at that time did not require an engineering analysis for components which were replaced.
The 1988 OG cooling drain plug failures were identified on Engineering Evaluation Requests (EERs).
The drain plug failures were attributed to the same corrosion mechanism.
The licensee's corrective action, was to replace the subject drain plugs in all three units with a new plug and sacrificial anode.
This corrective action was signed off completed April 10, 1990 for the last unit, Unit 1.
Additionally, a preventive maintenance task was requested to monitor/replace the sacrificial anodes installed in the new drain plugs.
Since the only failures documented within engineering were associated with DG cooling drain plug corrosion, the root cause of failure analysis was limited to the drain plug corrosion problem.
On April 12.,
1989, OG Cooling elbow fitting failed, and was documented on an EER to determine the root cause of fitting failure.
A review of maintenance records revealed that this fai lure was similar in nature to the fitting fai lure which had occurred on June 25, 1987.
On April 19, 1989, the root cause of the fitting failures was determined to be the exposure of unprotected carbon steel materials to spray pond water Based on the above information, the reasons for the violation were determined to be:
(1) that the Problem Identification Programs did not require an engineering
'analysis for components which were replaced with like parts, and (2) The Root Cause of Failure Analysis Program did not assure that the analyses gave adequate consideration to components of a system not directly affected by the failure being analyzed.
As a result of the above and other problems, the licensee has instituted significant changes in its Deficiency Identification and Root Cause Analysis Programs.
Specifically, the licensee has implemented a Material Nonconformance Report (MNCR) program which should ensure failures, such as occurred on the OG intercoolers, are evaluated by engineering and a root cause of failure
~-
analysis is performed on the'failed component.
Additionally, System Engineers have received additional training in formal root cause analysis techniques..
The licensee considered that the actions taken above, were sufficient to preclude further violations.
During this inspection the above information and some of the latest NRC inspection reports were reviewed, and the following was identified:
While the licensee identified in the November 30, 1989 response to this violation, that significant changes to specific programs and the implementation of the MNCR program should preclude further violations of this type, the inspector identified the following.
(a)
An NRC inspection report 50-528/90-02 issued April 24, 1990, approximately four months later, identified that licensee personnel were reluctant to initiate an t1NCR or EER, immediately upon identification of a deficiency or nonconformance condition.
Without immediate documentation of these identified conditions, there is no way to ensure adequate operability determination, engineering evaluation and management review of the identified condition.
(b)
An NRC inspection report 50-528/90-22 issued June 6, 1990 identified that existing Inservice Inspection (ISI) and Inservice Testing (IST) procedures contained instructions that stated "the nonconforming process is not required to be initiated when the unacceptable condition can be readily corrected in accordance with 30 AC-(9ZZ01), Work Control."
This statement could result in a lack of engineering review, evaluation and corrective action, for an identified nonconforming condition.
It appears that additional management attention is required in this area to ensure full implementation of the Deficiency/HNCR/Root Cause Analysis Programs.
Based on the above information, it appears the licensee has initiated actions to address this violation.
The implementation of these actions to preclude further similar violations, will be the subject of future NRC inspections.
This item is closed.
(5)
(Closed)
Unresolved Item No. 50-528 529 530/89-34-02.
ant o >>catsons roce ures uest>ons This unresolved item identified a need to further inspect Plant l1odification Review Committee Procedures for clarification of
the implementation priority codes.
A previous inspection identified:
That licensee procedure 02GB-OZZ01, Revision 0, "Plant Modification Committee (PMC)," implemented the planned committee changes for plant modifications.
A priority system was discussed in licensee letters at PMC meetings;,however, at the time of the previous inspections the priority systems had not been incorporated in existing design change and modification procedures.
That planned changes to Plant Modification Procedures-would incorporate the new priority system.
During this inspection licensee procedure 81 DP-ODC01, Revision 0, Procedure Change Notice 01, "Plant Change Request",
effective date July 12, 1990, was reviewed.
Appendix B of this procedure,
"Plant Modification Priority System,'ncorporated the new priority system for plant changes.
The Appendix B
priority system appeared to be similar to the system identified in the December 21, 1989 letter (ID 160-00278-JEA-THC-CRS)
from the NED Director and the EED Director to the PMC Chairman recommending a priority system.
It appears the Licensee has taken action to address this item.
This item is closed.
3.
Exit Meetin (30703)
The inspectors met with the licensee management representatives denoted in paragraph 1,
on August 31, 1990.
The scope of the inspection and the inspector's findings up to 'the time of the meeting were discussed.
At this meeting 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 paragraph 2.