IR 05000528/1991031
| ML17306A197 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/16/1991 |
| From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A196 | List: |
| References | |
| 50-528-91-31, 50-529-91-31, 50-530-91-31, NUDOCS 9110140070 | |
| Download: ML17306A197 (17) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Re ort Nos.
Docket Nos.
License Nos.
Licensee:
~Filet N
50-528/91-31,'0-529/91-31, and 50-530/91-31 50-528, 50-529, and 50-530 NPF-41, NPF-51, AND NPF-74 Arizona Public Service Company P.
0.
Box 53999, Station 9012 Phoenix, A2 85072-3999 Palo Verde Nuclear Generating Station Units 1, 2 and
Ins ection Conducted:
July 29 through Auqust 1, 1991 and August 26 through August 30, 1991
~Ins ector:
JAAAd Ins ection Summar
M.
P.
An
, Project Inspector ong, se Reactor ProjectsSection II 0 ic. gl a
e 1gne Ins ection on Jul 29 throu h Au ust 1 1991 and Au ust 26 throu h
u us e or os.
-
-
-
-
an 0/91-31)
Areas Ins ected:
Routine, onsite, regular inspection by one inspector from e
egson s aff.
Areas inspected included:
previously identified items; evaluation of licensee self-assessment capability; and engineered safety feature system walkdowns.
During this inspection the following Inspection Procedures were utilized:
30702, 40500, 71710, and 92701.
Results:
Of the areas inspected, no violations were identified.
General Conclusions and S ecific Findin s
Si nificant Safet Matters:
None Summar of Violations:
None Summar of Deviations:
None 0 en Items Summar
1 item closed, 1 item left open, and 2 new items opened.
9110540070 9'}0925 PDR ADOCV 05000529
I
i~
Stren ths Noted:
-2-The utilization of the Offsite Safety Review Committee (OSRC) for the Palo Verde independent review and audit Technical Specifications (TS)
responsibilities, upon TS change approval and full implementation, appeared to potentially be a significant improvement to the licensee's review and audit program.-
Weaknesses Noted:
No significant weaknesses were observed.
A concern regarding the separation of auxiliary feedwater trains was identifie I 1.
Persons Contacted DETAILS The below listed technical and supervisory personnel were among those contacted:
Arizona Public Service Com an (APS)
R.
Adney, Plant Manager, Unit 3 B. Ballard, equality Assurance, Director
- T. Bradish, Compliance Manager
- R. Flood, Plant Manager, Un)t 2
~R. Fullmer, equality Audits and Monitoring, Manager
"S. Guthrie, Deputy Director, Nuclear Safety and Licensing
"D. Gouge, Plant Support, Manager (Chairman, Plant Review Board)
P.
Hughes, Site Radiation Protection, General Manager M. Ide, Plant Manager, Unit 1 D. Kanltz, Compliance Engineer F. Larkin, Security, Manager
- J. LoCicero, Manager, ISEG
- D. Marks, Manager, Nuclear Safety J.
Levine, Nuclear Power Production, Vice President G. Overbeck, Site Technical Support, Director
- M. Radoccia, Manager, Site Nuclear Engineering Department
"R.
Rouse, Compliance Supervisor
"J.
Summy, Manager, System Engineering M. Hodge, Manager, Mechanical Engineerinq, Nuclear Engineering Department D. Lorenzi, Senior Engineer, Nuclear Engineering Department NRC
~J.
Sloan, Resident Inspector The inspectors also talked with other licensee and contractor personnel during the course of the inspection.
- Attended the Exit Meeting held on August 30, 1991.
2.
Evaluation of Licensee Self-Assessment Ca abilit (40500)
An inspection was performed to evaluate the effectiveness of the licensee's self-assessment programs.
The Technical Specifications (TS)
for the Palo Verde units, section 6.5, contain requirements for review and audit of plant activities.
During the inspection, on August 28, 1991, APS submitted to the NRC a proposed change to TS section 6, to reflect various organizational changes that had occurred and to reflect improvements to its review and audit activities that it had commenced.
A.
Offsite Safet Review Committee (OSRC)
The proposed TS change transfers the independent review and audit responsibility,. previously assigned to the Nuclear Safety Group
(NSG), to the OSRC.
The reporting responsibility for the independent review and audit would be changed from the Director of Nuclear Safety and Licensing to the Executive Vice President, Nuclear.
Until the proposed TS change is approved by the NRC, the NSG continues to perform its assigned TS functions.
However, the OSRC had also commenced its review activities and was meeting approximately quarterly.
The propos'ed OSRC is composed of the Chairperson and a minimum of-four members appointed by the Executive VP, Nuclear.
At the time of the inspection, OSRC was chaired by the VP, Nuclear Safety and Licensing, and included the YP, Nuclear Production; YP, Engineering; Director of equality; and three non-APS, industry recognized consultants.
An OSRC meeting was held on July 31, 1991 and was observed by the NRC inspector.
Discussions were held regarding recent LERs, Notices of Violation, gA audits and CARs, and plant operational events.
The OSRC members questioned responsible management personnel, discussed the individual items, provided recommendations and insight, and assigned action items.
The NRC inspector noted that the non-APS committee members provided a
significant contribution to the independent OSRC reviews by drawing from past experience and comparing various situations with a broad industry perspective and thus providing recommendations based on that experience and perspective.
The NRC inspector also noted that'the high APS management level participation in the OSRC gave the OSRC more stature and capability to implement effective action. Similarly, the inclusion of all the high level Palo Yerde management Personnel in the OSRC provided better coordination and focus sn the Iicensee's safety review responsibilities.
The OSRC was formed and commenced its review activities in the later part of 1990.
As previously mentioned, OSRC met approximately quarterly, issued reports for those meetings and documented
. recommendations and assigned actions in those reports.
The recommendations and assigned actions were tracked by the licensee in its Commitment Action Tracking system database.
Past OSRC meeting minutes and in detail the minutes for the May 10, 1991 and July 31, 1991 meetings were reviewed.
The minutes appeared to document substantive and timely plant safety reviews.
The action items identified were reviewed and appeared to be -appropriate, were being tracked, and were being resolved in a timely fashion.
The meeting minutes were distributed to appropriate management personnel including the Executive YP, Nuclear.
Discussions with the licensee indicated that a mechanism for accomplishing the proposed OSRC TS responsibility of reporting and providing advice to the Executive VP, Nuc]ear, other than being on distribution for the meeting minutes, was being considered for implementation when the TS change is approved and implemented.
'Upon approval and full implementation, the utilization of the OSRC for the Palo Verde independent review and audit TS responsibilities appears to be potentially a significant improvement to the licensee's review and audit program.
No violations or deviations were identifie B.
Plant Review Board (PRB)
TS 6.5. 1 lists the requirements for the PRB.
Organizational changes at Palo Verde, however,. resulted in changes to the reporting responsibi lit)es of the PRB.
As noted above, a proposed TS change to Section 6 of the TS was submitted on August 28, 1991.
The proposed
,
TS change revises the reporting relationships of the PRB.
)he TS currently requires the Plant Director to appoint the PRB Chairperson and Vice Chairperson.
The TS currently specifies the function of the PRB to be an advisory function to the Plant Director on all matters related to nuclear safety.
The TS also requires that the VP, Nuclear Production and NSG be notified of any disagreement between the PRB and the Plant Director.
However, the Plant Director position has been vacant, and is unfilled.
The Plant Director functions for the PRB have been assumed by the Vice President, Nuclear Production.
The proposed TS change provides for the new organizational alignment by elevating the notification of disagreement between the PRB and-the VP, Nuclear Production to the Executive VP, Nuclear and the OSRC.
The PRB Chairperson informed the NRC inspector that in the interim, no disagreements between the 'PRB and the YP, Nuclear Production had been experienced that would have necessitated notification of the Executive VP, Nuclear and OSRC.
TS 6.5. 1.4 requires the PRB to be convened at least once per calendar month to perform its review responsibilities.
In the month of August, 1991, the PRB met on at least eight occasions as necessitated by plant events.
The NRC inspector observed the meeting held on August 28, 1991, reviewed available documentation for. the meetings held in August 1991 and discussed PRB functions and requirements with the PRB Chairperson and the PRB Secretary.
The NRC inspector had the following observations.
1.
Improvements to the performance of the PRB functions initiated in the past year appeared to be continuing.
The inclusion of the Plant Managers and the Director of Site Technical Support in the PRB continues to result in substantive and appropriate reviews and improved PRB actions.
In addition, the inspector noted that open PRB action assignments had been reduced to five items with only one item that was open for more than six months.
2.
Dunng the August 28, 1991 PRB meeting, the board was briefed by engineering regarding ongoing evaluat)ons for the acceptability of the normal HVAC as a backup to the essential chilled water system.
A representative from the license's PRA group provided a
PRA perspective to the problem being discussed.
The NRC inspector considered the discussion meaningful and the consideration of the PRA aspects of the problem as a sianificant enhancement to the PRB review process.
However, the NR"L inspector also noted that some of the PRA questions asked by some members of the PRB indicated less than full understanding of the PRA data presented.
The PRB Chairperson acknowledged the inspector's comments and agreed that PRA was a relatively complex and new subject.
The Chairperson further agreed to consider for future PRB meetings, (involving similar new or
f
complex topics) training on the subject for the PRB members, providing background material for PRB member preparation, or expanded discussions during the meeting.
This would allow the members to fully grasp the information presented and utilize that information sn the reviews that are accomplished.
3.
The Palo Verde PRB administrative procedural requirements were contained in procedure 02AC-OAP01 revision 0.
As previously noted, organizational changes at I alo Verde necessitated submission of a proposed TS change.
Similarly, the Administrative Procedure was in need of change to reflect the proposed TS change.
Upon review and approval of the TS change for the PRB, the Administrative Procedure will be reviewed for conformance to the TS.
This was identified as Inspector Follow-up Item 528/91-31-01.
.4.
The TS specifies that the Chairperson appoint in writing the alternates.
PRB records indicated that PRB members des>gnated their alternates by means of memorandum to the PRB Chairperson and that the PRB Chairman's appointment and approval was reflected in the PRB meeting minutes.
The alternates appeared to be qualified for the function and appeared t'o typically be the person that was routinely and similarly designated to perform the normal plant functions of the PRB member; i.e., the Assistant Plant Managers were typically the designated alternates for the Plant Managers.
The PRB Chait person agreed to clarify the appointment of alternates.
C.
Inde endent Safet Evaluation Grou (ISEG)
The function, responsibilities and administrative requirements for ISEG are contained in TS 6.2.3.
Similar to OSRC and PRB Palo Verde organizational changes necessitated submission of a proposed TS change to reflect the current Palo Verde orqanization and the inter-relationship with ISEG.
The ISEG administrative procedures and requirements were contained in the following Palo Verde procedures and were reviewed by the inspector.
920G-OZZOl, revision 4, Policy 92AC-ONS01, revision 1, Investigati~on 920P-ONSOl, revision 2, Investigation 920P-ONS02, revision 2, ISE Organization and Responsibility ISE Field Evaluations and Special ISE Field Evaluations and Special ISE Task Administration ISEG evaluations were routinely documented in "Field Evaluations" (FE).
A review of nine recent FEs indicated that ISEG evaluations, observations, conclusions and recommended actions were being documented in the FEs.
Recommended actions were being tracked by the licensee in its commitment action tracking system database.
A sampling of the FEs were discussed with the ISEG personnel that performed the evaluations.
On the basis of the review of the FEs and discussions
i
i with the ISEG personnel, ISEG appeared to be fulfillingits TS review responsibilities, ISEG composition and personnel qualifications wete reviewed by the inspector.
TS 6.2.3.2 requires the ISEG to be composed of at least five dedicated, full time engineers, each with a Bachelor's Degree in engineering or related science and at least two years of professional experience in the field.
The ISEG met these requirements.
No violations or deviations were identified.
3.
En ineered Safet Feature S stem Malkdown. (71710)
An inspection of portions of the Unit 1 Auxiliary Feedwater (AFM) System-was performed to verify system lineup, configuration and equipment condition on a sampling basis.
A representative sample of the AFM system was inspected in the Hain Steam Support Structure, the Condensate Storage Tank area, and control room.
The inspector noted that one of the two steam supply lines for the "A" turbine-driven AFM pump was routed through the room for the "B" motor-driven AFM pump.
The inspector inquired about any analysis performed regarding the consequences of a pipe break in the line, downstream of its
'heck valve, that had the potential for disabling all safety-related AFM pumps; ice., the "A" pump would not have steam to run the pump and the "B" pump (and associated instrumentation, controls and electrical connections)
wouid be exposed to a steam environment for which they are not environmentally qualified.
The licensee responded that this was an issue that had been previously identified and evaluated and deemed to be acceptable.
The licensee presented documentation that showed that the piping did not experience full system pressure and temperature more than two percent of the total normal operatinq time and consequently did not have to be evaluated for a high energy leone break or a moderate energy line break.
The licensee also demonstrated that the line was not required for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or more during analyzed postulated accident conditions, and consequently did not have to be considered for a passive failure analysis.
Conversely, the inspector noted that the PVNGS Updated Final Safety Analysis Report (UFSAR), section 10.4.9.3.J, Safety Design Basis,Ten, stated that "The components and piping for each Seismic Category I AFS pump train are separated from each other and are either enclosed by a Seismic Category I structure or are installed underground."
The inspector requested the licensee provide any evaluation that may have been previously performed to demonstrate how the noted condition met the UFSAR safety evaluation for the AFM system.
U During inspection of the observed AFM steam supply piping routing and discussions with Nuclear Engineering Department (NED} personnel, the inspector was shown a copy of a February 21, 1991 memorandum, 0'81-00427-AKKlDJL, that provided "recommended corrective action to resolve recommendation No.
2 of INPO SOER 81-17, "Potential for Steam Line Rupture to Affect Auxiliary Feedwater System."
The memorandum indicated that INPO SOER 81-17 requested that PMR owners ensure that a single steam line break, creating a harsh environment from the discharging steam, cannot result in the loss of all auxiliary feedwater equipment.
The memorandum further indicated that the SOER had been previously evaluated, and at that
time resolved by plans to move the steam supply line check valve, SG-Y044, from the "B" AFM pump room to the "A" AFM pump room.
However, the relocation had not been accomplished and the memorandum documented a
reevaluation of the noted condition.
The reevaluation concluded that relocation of valve SG-Y044 was not necessary since no requirement existed to postulate a pipe break in the steam supply piping that was routed through the "B" AFM pump room.
Pending submitta'I of an evaluation of how separation of trains meets the stated design basis, licensee determination of the acceptability of the existing separation of the AFM trains, and NRC review of the licensee's evaluation, this was identified as Unresolved Item 528/91-31-02.
During the inspection of the AFM system, the inspector noted that the AFM pump B" discharqe check valve, AFB-Y138, was installed in a vertical run of piping.
The inspector asked the licensee for any available vendor and test information that demonstrated the acceptability and proper functioning of the check valve installed in the vertical piping.
The licensee provided the inspector with a memorandum from the vendor and inspection and test data that confirmed that the check valve performed its intended function as installed in the vertical run of piping.
The inspector had no further questions on the subject.
No violations or deviations were identified in the area inspected.
4.
Follow-u of Previousl Identified Items (92701)
A.
(0 en) Follow-u Item 91-04-02 -
H dro en Monitor Test Gas oncen ra ion ccurac The subject item identified that test gas used for the calibration of hydrogen monitors was procured commercial grade and the inspector consequently questioned the accuracy of the concentration data for the gas used in the calibration process.
The inspector reviewed licensee actions regarding the open item and noted that (DR 91-0130 had been issued for this concern.
The licensee has commenced action to upgrade the reliability and traceabi lity of the gas concentration data.
However, the (DR was still open pending final determination of the procurement process for future calibration gas purchases.
Pending final licensee determination and completion of actions to assure the quality of the test gas and accompanying certifications, the item was left open.
B.
(Closed)
Licensee Event Re ort LER) 528/89-05-LO - Atmos heric Dum a ve e >c>enc>es The subject LER revision 1 was closed by NRC Inspection Report 528/
90-38.
Reyisi'on 0 of the LER was inadvertently left open at that time.
Revision 0 of the LER was administratively closed.
5.
~Eit 5 tt An exit meeting was held on August 30, 1991, with licensee management during which the observations and conclusions in this report were
I
discussed.
The licensee did not identify as proprietary any materials provided to or reviewed by the inspector during the inspectio ~i I