IR 05000528/1992004
| ML17306A503 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/11/1992 |
| From: | Narbut P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17306A500 | List: |
| References | |
| 50-528-92-04, 50-528-92-4, 50-529-92-04, 50-529-92-4, 50-530-92-04, 50-530-92-4, NUDOCS 9203060068 | |
| Download: ML17306A503 (12) | |
Text
.Report Nos.
Docket Nos.
License Nos.
Licensee:
Facility Name:
Inspection at:
Inspectors:
Approved by:
U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
50-528/92-04, 50-529/92-04, and 50-530/92-04 50-528, 50-529, 50-530 NPF-41, NPF-51, NPF-74 Arizona Public Service Company P.O.
Box 53999, Station 9012 Phoenix, Arizona 85072-3999 Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2,
Palo Verde Site, Wintersbur g, Arizona M. J.
Wagner, Reactor Inspector, RV H.
A. Freeman, Reactor Inspector, RV 4 fl ar u, c
>
g
>e, sneering e
on e
>gne Ins ection Januar 13 throu h Februar
1992 (Re ort Nos.
50-528/92-04 Areas Ins ected:
An announced routine inspection, by two regional inspectors; o
licensee ac ivities taken to address previously identified items, and an NRC in-office review of documentation on the Unit 1 pressurizer instrument nozzle repair.
Inspection procedures 92700 and 92702 were used as guidance during this inspection.
Results:
General Conclusions:
o Programmatic weaknesses were identified within the system engineering program which undermine the ability of the system engineer to be considered the focal point for system-related problems.
o System engineers are not being involved in problems on a timely basis so that they can identify and/or prevent recurrence of problems (a previously identified concern).
Si nificant Safet Matters; None 92a)agbog~a 9<P<>g PDP, ADuv~ 05000528 A
Summar of Violations or Deviations:
None 0 en Items Summar
One follow-up item was opened, and one open item was close,
Persons Contacted DETAILS
"D. Gouge, General Manager, Plant Support
~R. Flood, Plant Manager, Unit 2
"E. Dotson, Director, Site Nuclear Engineering
"G. Overbeck, Director, Site Technical Support
"J.
Summy, Manager, System Engineering
"D. Garchow, Manager, Fire Protection Support
~F. Garrett, Manager, Fire Protection
- P. Prabhakar, Manager, equality Engineering R. Fountain, Supervisor, equality Audits and Monitoring L. Henson, Electrical Supervisor, Site Nuclear Engineering S.
Penick, Supervisor, equality Engineering
~R.
Rouse, Supervisor, Compliance
"J. Baxter, Engineer, Compliance
"C. Cooper, Engineer, Fire Protection Support
"R. Henry, Site Representative, Salt River Project
"L. Perea, Technical Assistant, Technical Support
+M. Radsprnner, Mechanica1 Eng>neering NSSS Supervisor D. Crozier, Fire Department Supervisor T.Braddish, Compliance Manager The inspectors also interviewed other licensee employees during the course of the inspection.
"Attended Exit Meeting on January 17, 1992.
+Telephone Discussion on February 5, 1992.
2.
Follow-u on Previousl Identified Fire Protection Items (92702)
(Closed) Follow-u Item No. 50-528/91-21-02:
Ali nment Confi ur ation o
ra ozz es an erma e ec ors During a previous NRC inspection, it was identified that water spray nozzles protecting the turbine generator bearings and thermal fire detectors were out of position.
Licensee investigations into this problem concluded that a probable cause of the misalignment of water spray nozzles and thermal fire detectors within this area was improper installation or positioning of rigging for maintenance in the area.
To ensure that the water spray nozzles and thermal fire detectors are correctly positioned during operation, the
~
licensee has revised the fire protection program to include inspections of the water spray nozzles and thermal fire detectors on an eighteen month interval.
The eighteen month inspection intervals are scheduled to coincide with the end of scheduled outages, since outages are when maintenance within these areas is performed.
.
The inspector reviewed the revision to the fire protection program and confirmed that the scheduled inspections were included in the program.
Based on the review of the revised program, and the inclusion of the water spray nozzles and the thermal fire detectors on a scheduled inspection
program, no further actions are required, therefore this item is considered closed.
3.
New 0 en Item (92702)
(0 en) Follow-u Item 50-528/92-04-01:
S stem En ineerin Pro rammatic ea nesses This inspection effort was performed to ensure that appropriate programmatic provisions were in place to provide the System Engineer with the capability to identify and address problems in a timely manner to'revent recurrence of emergency lighting issues or other plant technical problems.
According to the Nuclear Administrative and Technical Hanual procedure 70PR-OAP01 entitled."System Engineer Program,"
the, policy is that the System Engineer will serve as the focal point for technical and'ngineering information for a given system.
Therefore, to obtain ownership for a system, all work activities and problems associated, directly or indirectly, with the system must be made available to the System Engineer.
The inspectors observed what appeared to be a
disconnect between what was required to be implemented by the System Engineer proqram and the associated quality assurance and work process programs.
Discussions with several System Engineers and their management evolved around the following examples of programmatic discrepancies.
(1)
Procedure 70PR-OAP01, Section 3.3.3 states that the System Engineer is responsible for preparation, or assistance with preparation, of Design Changes Packages (DCPs).
The DCP procedure 81AC-ODCOl also addresses System Engineer involvement.
However, 81DP-ODC04 entitled
"Limited DCP," which allows for minor or small design modifications, does not address System Engineer involvement thereby excluding the System Engineer from this portion of the DCP process.
The concern here is the potential that a modification could be put into the system without the System Engineer's awareness.
Licensee management indicated to the inspectors that they were aware of this disconnect/problem and a revision is in process to include System Engineer notification of limited DCPs issued to make the System Engineer aware of any modifications to their system.
(2)
Procedure 70PR-OAPOl, Section 3.3.7 states that the System Engineer is responsible for preparation, or assistance with preparation, of Material Nonconformance Reports (MNCR's) in accordance with 60AC-OQQ01, Material Nonconformance Report.
However, 60AC-OQQOl limits the System Engineer responsibilities by excluding their involvement and awareness of HNCRs dispositioned as "Other,"
"Rework," or "Scrap."
The inspector requested and received a special computer run of HNCRs which were dispositioned as scrap, rework or other (1991 HNCRs only).
This run of 56 pages represented over 700 HNCRs of which 4 per cent were reviewed by the inspector.
From this review, the inspector concluded that 50 per cent of the HNCRs raised questions
regarding root cause determinations and possible affects on system
'vailability.
Although no safety concerns were identified, this review revealed a weakness in the program in that System, Engineers are not consistently being involved in problems with 'their.systems on a timely basis.
This weakness was previously addressed and documented in NRC Inspection Report No. 50-528/89-28.
Licensee management indicated that a recent revision, in draft, to the MNCR process will provide copies of all MNCRs to the responsible System Engineers, and that distribution is currently in process.
Inspector discussion with the site Engineering Control Desk personnel revealed that they do issue MNCRs of the type in question to the System Engineer-when they receive them, but they don't always receive them.
Also, on the subject of distribution for System Engineer awareness, the System Engineers are not, on a consistent basis, receiving copies of Condition Report Disposition Requests (CRDRs) written against their systems that are dispositioned by other organizations.
(3)
Failure Data Trending (FDT) reports are issued to the System Engineer six weeks after the quarterly reporting period.
Since the System Engi,neer is expected to respond proactively to implement preventative measures, it is questionable whether the FDT reports contributes in a positive manner to allow timely corrective actions to be initiated.
Also, timely entry of FDT information is a concern that was addressed at the January 14, 1992 Emergency Lighting Team Meeting.
An Emergency Lighting failure occurred in September of 1991, was reported in January 1992, and may not show up until the 2nd quarter FDT report; 6-9 months after the failure.
(4)
Nine out of ten System Engineers interviewed by the inspector indicated that they were not complying with Sections 3.4. 1 and 3.8. 1 of the system engineering program as described in 70PR-OAPOl.
Section 3.4. 1 states that
'The System Engineer is expected to identify and trend appropriate system parameters to allow timely preventative or corrective actions to be implemented."
Section 3.8. 1 states that "The System Engineer maintains a system-oriented database which contains pertinent information about the assigned system(s) (i.e.,
system history, performance, trends, status, etc. )."
Although there is no regulatory requirement for System Engineers to trend this data, this represents another programmatic weakness requiring management attention.
The above items are examples of programmatic weaknesses in the System
.
Engineer Program which appear to preclude the System Engineer from being the focal point for technical and engineerinq information associated with their respective systems.
Discuss>ons with licensee management revealed that they hav'e previously taken actions to address some of these weaknesses.
Specific actions taken by the licensee will be examined further by Region V as Follow-up Item 528-528/92-04-0.
Follow-u on Unit 1 Pressurizer Instrument Nozzle Re air (92700)
Repair of the pressurizer upper instrument nozzle was performed on January 7, 1992.
All work activities, such as welding and nondestructive examinations, were performed in accordance with the American Society of Mechanical Engineers (ASME) Code,Section XI, 1980 Edition with 1981 Winter Addendum.
Special Code requirements are addressed in Article IWB-4000 "Repair Procedures."
These Code requirements were incorporated into the repair plan written and approved specifically for the pressurizer nozzle repair by Asea Brown Boveri (ABB) Combustion Engineering Nuclear Power with subsequent approval by Arizona Public Service Company.
The following documents, identified by APS Log Number, associated with the repair activities were reviewed by the inspector:
o 01-N001-6.04-123-'1
"Weld Repair of Pressurizer Upper Instrument Nozzle. "
This is a traveler that documents each sequence of repair activities with witness and inspection hold points.
All activities involve the Authorized Nuclear Inspector (ANI), owner and construction representatives, and equality Control.
o 01-N001-6.04-125-1
"Pressurizer Upper Instrument Repair equality Plan."
o Ol-N001-6.04-126-1
"Procedure for Welding to Prevent Leakage of a Pressurized Upper Instrument Nozzle."
0-01-N001-6.04-129-1
"Shielded Metal Arc Weld Procedure."-
This procedure provided special instructions for preheat, interpass and postweld heat treatment requirements along with specific weld filler metal controls.
o 01-N001-6.04-130-1
"Capacitor Discharge Weld Procedure," for thermocoup le attachment.
o 01-N001-6. 04-131-1 "Capacitor Discharge Weld Procedure," for insulation pin attachment.
o Ol-N001-6.04-24-1 "Ultrasonic Examination Procedure for Weld Build-up and Base Metal on Pressurizer."
The licensee performed a calculation, number V-MPS-CALC-021, to analyze the stress levels of the nozzle and the repair weld pad under normal operation plus Operating Basis Earthquake (OBE) and normal plus Safe Shutdown Earthquake (SSE) loading conditions.
The analysis concluded that the stress levels of the repaired nozzle were within Code allowables and acceptable; also, that sufficient allowable stress cycles could be applied unti1 the next outage when the nozzle will be replaced.
Discussions with licensee engineering management revealed that the repaired nozzle, along with 6 other pressurizer nozzles of concern, will be replaced during the Unit 1 outage scheduled to begin February 15,
1992.
The 7 pressurizer nozzles will be replaced with an alloy 690)
shown to have higher corrosion resistance to primary water stress corrosion crackling (PWSCC) than the existing material (INCONEL-600).
The original stress analysis on the pressurizer and nozzles wi 11 subsequently be amended to take into consideration the replacement material.
No violations or deviations were identified in the areas reviewed.
5.
~Eit M ti The inspectors met with the licensee management representatives denoted in Paragraph 1 on January 17, 1992.
The scope of the inspection and the findings as described in this report were discussed.
Documents addressing the Unit 1 pressurizer instrument nozzle repair were reviewed in the regional-office on February 4-5, 1992 and documented in Section
of this repor P
In accordance with 10 CFR 2.790(a),
a copy of this letter and the enclosure will be placed in the NRC Public Document Room.
Should you have any questions concerning this inspection, we wi'll be pleased to discuss them with you.
Sincerely, e
Dennis F. Kirsch, Chief Reactor Safety Branch Enclosure:
Inspection Report Nos.
50-528/92-04, 50-529/92-04, and 50-530/92-04 cc w/enclosure:
Mr.
O. Mark DeMichele,'PS Mr. James M. Levine, APS Mr. Jack N. Bailey, APS Mr.
E.
C.
Simpson, APS Mr. S. Guthrie, APS Mr. Thomas R. Bradish, APS Mr. Robert M. Page, APS Ms.
Nancy C. Loftin, Esq.
(Snell 8 Milmer)
Mr. Al Gutterman, Newman 8 Holtzinger P.C.
Mr. James A. Boeletto, Esq., Assistant Counsel, SCE Company Mr. Charles B. Brinkman, Combustion Engineering, Inc.
Mr. Milliam A. %right, Acting Director, Arizona Radiation Regulatory Agency Chairman, Maricopa County Board of Supervisors Mr. Steve H. Olea, Chief Engineer, Arizona Corporation Commission Ignacio R. Troncoso, El Paso Electric Company Roy P.
Lessy, Jr.,
Esq., Akin, Gump, Strauss, Hauer and Feld Bradley M. Jones, Esq., Akin, Gump, Strauss, Hauer and Feld Mr. Jack R.
Newman, Esq.
(Newman 8 Holtzinger)