IR 05000528/1993042
| ML20059A284 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/29/1993 |
| From: | Ang W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20059A278 | List: |
| References | |
| 50-528-93-42, 50-529-93-42, 50-530-93-42, NUDOCS 9310260282 | |
| Download: ML20059A284 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION V
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Report No.:
50-528/93-42, 50-529/93-42, and 50-530/93-42 Docket No.:
50-528, 50-529, and 50-530
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license No.:
NPF-41, NPF-51, and NPF-74 Licensee:
Arizona Public Service Company Facility Name:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Inspected at:
Palo Verde Nuclear Generating Station, Wintersburg, Arizona Inspection date:
August 30 through September 3, 1993 Inspectors:
M. Royack, Reactor Inspector F. Gee, Reactor Inspector b
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't3 Acoroved by:
W. P. Ang, Chief Date Signed Engineering Section Inspection Summary:
Inspection durina the period Auaust 30 throuah September 3.
1993 (Report Nos. 50-528/93-42. 50-529/93-42. and 50-530/93-42)
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Areas Inspected:
The inspectors reviewed examples of licensee design changes and temporary modifications in accordance with Inspection Procedure 37700, " Design Changes and Modifications." The inspectors also performed on-site followup of licensee event report in accordance with Inspection Procedure 92700, "0nsite follow-up of Written Reports of Non-routine Events at Power Reactor Facilities," and performed a review of fire protection enforcement open item in accordance with Inspection Procedure 92702, " Follow-up on Corrective Actions for Violations and Deviations."
Safety Issues Management-System (SIMS) Item:
None 9310260282 931001 PDR ADOCK 05000528 G
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Results:
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General Conclusions and Specific Findinas:
In the review of a design change package (DCP), the inspector
identified a weakness in the 50.59 safety review in which the licensee did not perform a thorough review when the modification was replaced with an unlike part.
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The licensee had incorporated the fire protection program into the-
Quality Assurance (QA) program and had implemented-QA oversight of the fire protection program.
Licensee corrective actions identified in the July 20, 1993 Fire Protection Justification for Continued
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Operation (JCO) have been effective in establishing QA oversight of the fire protection program.
Sianificant Safety Matters:
None.
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Summary of Violation or Deviations:
None.
Open Items Summary:
The inspectors closed one enforcement item (50-528/90-25-02) and one licensee event report (50-528/529/530/93-005-LO).
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Details 1.
Persons Contacted
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Arizona Public Services Company
- J. Auston, Deputy Chief, Administration, Fire Protection
- R. Bouquot, Audit Supervisor, Quality Audits and P.onitoring
- T. Bradish, Manager, Nuclear Regulatory Affairs
- D. Crozier, Supervisor, Fire Protection
- G. D'Aunoy, Principal Engineer, Quality Audits and Monitoring
- C. Day, Supervisor, Instrumentation and Controls (I&C)
- J. Fisher, Manager, Fire Protection Support Services
- R. Fullmer, Manager, Quality Audits and Monitoring
- F. Garrett, Manager, Fire Protection S. Garrett, Supervisor, I&C, Nuclear Engineering
- R. Gouge, Director, Plant Support
- J. Gratza, Senior Technical Specialist, Procurement Quality J. Hesser, Manager, Electrical and I&C, Nuclear Engineering
- J. Irwin, Senior Engineer, Nuclear Regulatory Affairs
- W. Johnson, Monitor, Quality Audits and Monitoring
- D. Kanitz, Senior Engineer, Nuclear Regulatory Affairs
- M. Karbassian, Supervisor, Nuclear Engineering
- W. Lui, Supervisor, Nuclear Engineering
- T. Phillips, Supervisor, Engineering Standards and Training
- G. Overbeck, Director, Site Technical Support
- C. Russo, Manager, Quality Control
- C. Seaman, Director, Quality Assurance
- R. Stevens, Director, Regulatory and Industry Affairs
- T. Sundeen, Auditor, Quality Audits and Monitoring
- S. Troisi, Acting Manager, Operations Computer System
- D. Webb, Technical Advisor, Fire Protection Program Others
- F. Gowers, Site Representative, El Paso Electric
- R. Henry, Site Representative, Salt River Project
- J. Draper, Site Representative, Southern California Edison U. S. Nuclear Reculatorv Commission
- W. Ang, Chief, Engineering Section
- S. Sloan, Senior Resident Inspector The inspectors also held discussions with other licensee and contractor personnel during the course of the inspection.
- Denotes those attending the exit meeting on September 3, 1993.
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2.
Desian Chances and Modifications (37700)
An inspection was conducted to verify that design changes and modifications which had been determined by the licensee to not require approval by the NRC were in conformance with the requirements of the Technical Specifications (TS),10 CFR 50.59, the Safety Analysis R' port, the licensee's Quality Assurance Program and 10 CFR 50, Appendix B, Criterion III, " Design Control," and to selectively verify adequacy of installation and testing of the plant modifications.
The following design change packages (DCPs) were selected for review:
DCP 2XE-PB-024, " Replace Second Level Undervoltage Relays with Solid
State Relays," Revision 0, dated February 15, 1993.
Limited DCP 2LE-PB-025, "4.16 kV Switchgear Undervoltage Relay DC
Control Power Fuse Modification," dated April 16, 1993.
Setpoint Change Request (SPCR) SXX-PG-001, " Class 1E 480 Volt load
Center Transformers," dated February 16, 1993.
The review of the packages included the verification of proper approval authority, interdisciplinary reviews, independent verification, appropriate licensing document update, 50.59 evaluation, post-modification testings, procedural control, as-built drawing control, and field installation.
a.
Backaround Concerns regarding the adequacy of licensee design calculations for various portions of the Palo Verde Electrical Distribution System (EDS) were identified during the NRC electrical distribution system functional team inspection in 1990 (Inspection Report 90-42). The licensee initiated reverification of EDS calculations and identified several issues, documented those issues in eleven Condition Report / Disposition Requests (CRDRs), and initiated design change packages for those issues. Two design change packages and a setpoint change package associated with the licensee identified issues were reviewed during this inspection.
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DCP 2XE-PB-024 replaced all ten second-level electro-mechanical inductive undervoltage (UV) relays with solid state relays. The second level UV relay provides UV protection for a degraded grid voltage resulting in 90% or less of the normal voltage condition sustained for 31.8 seconds or longer. The replacement of the
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secondary UV relays were considered by the licensee to be necessary
te reduce the setpoint tolerance and to provide higher accuracy and repeatability than the existing relays. This design change facilitated UV setpoint adjustment to ensure that adequate voltage was available to operate all engineered safety feature (ESF) loads at all lower distribution levels (4.16 KV and 480 Vac) and to
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minimize inappropriate load shedding.
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During closure review of DCP 2XE-PB-024, the plant engineering staff
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determined that an open 125 Vdc power supply fuse to the new solid state relays would render the relays inoperable, and the condition would not be known to the control room operators.
Limited DCP 2LE-PB-025 was initiated as a supplemental design change to DCP 2XE-PB-024 to modify the arrangement of the 125 Vdc control power circuit to the relays and to provide control room operators with alarms for loss of power to the UV relays.
SPCR SXX-PG-001 implemented a tap setting change on the 480 volt transformers to reduce the potential for UV conditions on supplied loads.
b.
Review of the Desian Chance Control Process and Licensina Document Updates The licensee performed the design changes listed above in accordance with approved procedure AC-00C01, " Procedure for Design Changes,"
Revision 04.04. The design change packages appeared to be performed in accordance with the procedure. The design change packages also appeared to have the proper approval authority, interdisciplinary reviews, and independent verifications.
The design change package for replacing the UV relays included a licensing document change request. The change request included a copy of a revision of Final Safety Analysis Report (FSAR) paragraph 8.3.1.1.3.13.B.7 in the design change package to reflect the change in hardware and to document that the solid state time delay UV relays would commence a maximum 35 second time-out when the bus voltage dropped to less than 90% of design, c.
Review of the 50.59 Evaluation for the Desian Chanaes During the review of the safety evaluation for the design changes, the inspector determined that the li:ensee's staff was aware that the new solid state UV relays required a source of 125 volt de control power to operate and would fail as is on loss of control power. The installation of the new solid state UV relay also included the installation of one control power fuse for each safety train of five UV relays. The old relays did not require a source of power to operate and failed such that ESF loads would be loaded onto the diesel generator and the bus would be energized.
In the design implementation, the licensee's design engineers overlooked the fact that an open 125 Vdc fuse, which supplied power to five relays of one safety train, would render the relays inoperable. No annunciation was provided to the operators to inform them of the loss of the UV protection.
The replacement of relays with different operating characteristics resulted in a deficiency in the design modification that was not identified during the initial 10 CFR 50.59 review but was subsequently identified by the licensee
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during the DCP closure review. The inspector informed the licensee that the noted condition appeared to be a weakn,ess in the licensee's initial 10 CFR 50.59 review for the DCP. The licensee acknowledged the weakness and committed to review the 10 CFR 50.59 review process.
d.
Review of Post Modification Testina The inspector reviewed the test procedure and records for the post modification testing to verify that the testing confirmed that the-design requirements of the DCPs were met. The inspector reviewed
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the records of the bench tests and the calibrations of the new solid state relays, the associated work orders, and the relay test data cards. The inspector also reviewed the test records for testing performed in accordance with Procedure 70GT-0ZZ01, " Electrical Circuit Test," Revision 1, and Surveillance Test Procedure 32ST-9ZZO3, " Surveillance Test Procedures for the Class 4160 Bus UV Protective Relays," Revision 05.06. The post modification testing appeared to be adequate.
Review of Operatina and Maintenance Procedures and Trainina Proaram e.
The inspector verified that procedures needed as a result of the design changes had been established, and training that was needed as a result of the design changes had been completed, prior to declaring the affected systems operable.
The licensee had revised the alarm response procedures 42AL-2RK1A and 42AL-2RKIC for the respective annunciations for Unit 2 trains A and B, 4.16 KV switchgear trouble and UV trip, on the main control room vertical boards. The inspector verified the completion of training for the operators and the establishment of surveillance procedure 32ST-9ZZ03 on the modifications. The procedures and training appeared to be adequate.
f.
Review of As-Built Drawinas and Walkdown of the Modifications The inspector sampled some of the as-built drawing changes, work orders, and field change requests. The drawing change control appeared to be adequate.
The inspector also performed a walkdown of the 4.16 KV switchgear and the control room panels to verify the field installations of the test switches and the installation of the UV relays. The inspector also observed the performance of surveillance on the UV relays during the walkdown. The inspector did not observe any equipment abnormality. The installation appeared to be adequate.
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Conclusion The design, installation, testing, procedure changes, training, FSAR changes, required for the modifications appeared to be adequate. A weakness in the 10 CFR 50.59 review of DCP 2XE-PB-024 was noted, but the deficiency in the design had also been identified and corrected by the licensee prior to the inspection.
No violations or deviations of HRC requirements were identified.
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The inspector selecte ' temporary modification 2-93-SQ-006,
" Eliminate Noise on i,onitor Ground Lines to Reduce Detector High Count Rate Indication," for review. The inspector reviewed this modification for program controls, precedure details, approval
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responsibility, formal records of the changes, independent verifications of the changes, functional testing, periodic licensee review and adequacy of the design.
- Temporary modification 2-93-SQ-006 was chosen for review due to the noise problems experienced in the past years in the radiation monitoring system circuits. The temporary modification. attempted to i
obtain an optimum grounding configuration to correct the radiation monitoring system noise problems. The optimum configuration would '
eventually be incorporated into a plant design change.
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The inspector determined that TM 2-93-SQ-006 met the above noted
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review criteria. The inspector also performed a walkdown of the
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equipment and determined that the equipment was adequately installed and controlled.
.i No violations or deviations of NRC requirements were identified.
3.
Onsite Review of Non-Routine Events (92700)
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(Closed) Licensee Event Report (LER) 50-528/529/530/93-005-LO " Loss of
.l Redundant Trains of Safe Shutdown (SSD) Equipment Due to a Sincle Fire"
Backcround Licensee event report (LER) 50-528/529/530/93-005-LO reported that on
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June 22, 1993 the licensee determined that eight of approximately 200-pieces of safe shutdown equipment, powered by 125 voit ungrounded class j
IE DC power, could have been rendered inoperable due to a single fire in the redundant SSD train.
.l On July 28, 1992, during a licensee 10 CFR 50, Appendix "R" reconstitution effort, fire protection engineering personnel questioned the adequacy of the fuse protection of associated circuits (non-safe shutdown) and identified safe shutdown equipment due to the lack of documentation provided in the Appendix R analysis that was current at l
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that time. The concern was that redundant trains of SSD equipment could be rendered inoperable by a single fire. The single fire could have induced a fault in an associated circuit which could cause current flow in the un-fused circuit leg. The current could have tripped the common power supply breaker causing a loss of power to the safe shutdown load.
The condition was limited to equipment powered from the SSD 125 volt DC ungrounded class IE power supplies where non-safety shutdown equipment (associated circuits) had only one leg electrically protected by coordinated relays, fuses, or circuit breakers, or were powered from the same power supply as SSD equipment, and had not been verified to meet the requirements of 10 CFR 50 Appendix R, section III.G.2 and 3.
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circuit cable routing had not been reviewed as part of the original i
Appendix R analysis.
The licensee initiated a condition report / disposition request (CR/DR) 92-0455 to evaluate the scope of the potential problem. The licensee's initial review, completed on October 22, 1992, identified that there were approximately 200 individual pieces of SSD equipment (150 loads) that might have been impacted by this condition.
In order to determine if a reportable condition existed, for each SSD load, the licensee needed to identify and trace all non-safe shutdown associated circuits.
On June 22, 1993 the licensee concluded that of the 200 individual pieces of SSD equipment reviewed, eight pieces could have been affected by the condition, which was determined to be reportable.
Licensee Corrective Actions The licensee stated in LER 50-528/529/530/93-005-LO that the following corrective actions would be taken.
Fire watches would be established in areas of the plant where 125
volt de grounded Class IE control cabinets and wiring were located.
Licensee pro-fire strategies manual Appendix A would be revised to
indicate that spare fuses were available for returning 125 volt de i
ungrounded Class IE circuits to service during a fire.
The spare fuses would be included in the pre-fire strategies manual until permanent design changes were made to the 125 volt de ungrounded
Class IE power sources.
Control room fire procedures would be revised to provide direction
for isolating faulted 125 volt de ungrounded Class 1E circuits and returning undamaged SSD circuits to service.
A plant change request would developed to provide additional fusing
in SSD circuits with an unprotected leg.
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2 NRC Inspection of Licensee LER Corrective Actions
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Fire Watches The inspector toured the areas where the 125 volt DC ungrounded class IE power cabinets were located in Units 2 and 3.
The inspector observed that fire watches were in the areas. The inspector questioned two fire watches about why they would be concerned about a potential fire in the 125 volt DC ungrounded IE control cabinets. The inspector found that the fire watches interviewed understood the effect of a potential single fire on redundant trains of SSD equipment.
Pre-Fire Strategies Manual The inspector reviewed the licensee's Attachment A to the Pre-Fire Strategies Manual, Amendment 2 to Revision 6, dated August 1993. The inspector found that the licensee had revised Attachment A to the Pre-Fire Strategies Manual to state that fuses were staged for replacement.
The inspector also found that Attachment A to the Pre-Fire Strategies Manual included instructions to replace the fuses to restore power. The inspector also visually verified the staging of the fuses.
Control Room Fire Procedure The inspector reviewed 41A0-1ZZ44, Revision 03.02, 42AO-2ZZ44, Revision 02.02, and 43A0-3ZZ44, Revision 01.02, Control Room Fire, for Units 1, 2, and 3 respectively.
The inspector found that the licensee had revised the procedures to include the replacement of fuses in the 125 volt DC ungrounded class IE circuits. The inspector also visually inspected the fuses in the Emergency Equipment Cabinets on the 100 foot level of the
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control building.
The inspector found that the fuses were in the
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cabinets, that they were correctly referenced in the control room fire procedures, and that proper instructions were provided for the replacement of the fuses.
Actions to Prevent Recurrence i
The inspector reviewed Plant Change Request (PCR) 93-13-ZZ-001, Appendix R - Auxiliary Relay Cabinet Modifications, and Plant Modification
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Committee (PMC) Meeting minutes of June 29, 1993.
The inspector found that the licensee had identified and scheduled installation of fuses to protect SSD equipment from a single fire scenario which could cause the
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loss of both trains of SSD equipment. The inspector found that the June.
29, 1993 PMC meeting minutes authorized and approved funding for the
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completion of engineering and installation of fuses in the 125 volt DC ungrounded class IE auxiliary relay cabinets E-ZAA-C01, E-ZAB-C01, E-ZBB-C03, and E-ZAB-C03. The installation schedule of the fuses for each plant was as follows: Unit I during Refueling Cycle 5 (IR5) April 1995, Unit 2 during Refueling Cycle 6 (2R6) April 1996, and Unit 3 during Refueling Cycle 5 (3RS) November 199 _ _ _ _ _ _ _ _
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Conclusion
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The inspector concluded that the licensee had established fire watches as a compensatory measure and that the fire watches were aware of the significance of a fire in the associated circuits to the 125 volt DC ungrounded class IE power supplies.
The inspector concluded that the licensee had revised the Pre-Fire Strategies manual and control room fire procedures to identify and
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include instructions for replacement of fuses for specific equipment j
powered by the 125 volt DC ungrounded class IE power supplies, i
The inspector concluded that the licensee had prepared, scheduled, and funded a plant change to install fuses for eight pieces of equipment where a single fire in an associated circuit could render both trains of safe shutdown equipment inoperable.
The inspector concluded that the licensee had initiated and completed the immediate corrective actions and had scheduled and funded actions to
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prevent recurrence of the condition. This item is closed.
l No violations or deviations of NRC requirements were identified.
4.
Previously Identified Violations (92702)
(Closed) 50-528/90-25-02. Failure to Implement Fire Protection Ouality
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Assurance Procram Violation A Notice of Violation and a Proposed Imposition of Civil Penalty (Notice)
was issued for failure to implement an adequate Quality Assurance (QA)
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program for fire protection. The notice of violation and proposed
imposition of civil penalty was issued on October 16, 1990.
The NRC i
I enforcement action (EA) was EA 90-121.
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Licensee Actions During an Enforcement conference held in Region V on July 10, 1990, the licensee committed to submit a Fire Protection Justification for Continued Operation (JCO) regarding the application of the QA program to fire protection equipment. The 71censee's fire protection JC0 was submitted to Region V on July 2J 1990.
i Previous NRC Inspection Follow-up NRC Inspection Report 50-528/529/530/93-24 documented NRC inspector review of the licensee's Fire Protection JC0 commitment to provide adequate QA program coverage for fire protection. The inspector
concluded that the licensee revised their QA program to include all provisions of the fire protection program described in the Updated Final Safety Analysis Report (UFSAR). The inspector did not inspect the i
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implementation of the QA program as it applied to the installed fire protection equipment, therefore the item had remained open.
Inspector Review of Licensee Actions The inspector reviewed licensee procedures, reports, and interviewed personnel to determine if the licensee had implemented Quality Assurance oversight of their fire protection program and equipment. The inspectors review included: QA audits, quality control oversight, licensee management observation reports, procurement procedures and packages, fire protection equipment trending and performance assessments, and material non-cor.formance reports (MNCR's).
Quality Assurance Audits
The inspector reviewed licensee Quality Audits and Monitoring (QAM)
departments triennial, biennial, and annual fire protection audit reports,90-016, 91-014, and 92-018, respectively. The inspector found that the licensee had performed fire protection program audits as required by Technical Specification 6.5.3.5(g) and (f). The inspector's review of the fire protection program QAM audits found that the audits were comprehensive, identified problem areas, documented corrective actions and followed up on corrective actions which required long term action.
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The inspector observed two fire protection surveillance procedures in progress: 14FT-9FP37, Revision 1.0, Weekly Wet Pipe, Deluge and Pre-Action System Inspection, and 36MT-9QK24, Revision 0.01, Fire Detection / Protection System Supervised Circuits Test - Allison Model A888-M135. The inspector noted that QA was performing an audit of 14FT-9FP37. The inspector reviewed the QA audit data and found that the audit was being performed in accordance with licensee procedures 73AC-0FP01, Revision 2.02, Fire Protection Test Program and 73DP-0FP01, Revision 2.02, Fire Protection Test Program Requirements.
Quality Control Inspections The inspector reviewed licensee procedure 63DP-0QQ06, Revision 05.01, Determination and Implementation of Plant Inspections, and reviewed 35 Quality Control (QC) inspection reports performed since January 1993.
The QC inspection areas covered routine walk-downs, maintenance and repair observations, and surveillance tests for fire protection equipment and emergency lighting.
The inspector found that licensee QC inspections were being conducted in accordance with licensee procedure 63DP-0QQ06, Revision 05.01.
The inspector found that the QC inspection reports had documented.
deficiencies and that corrective action documents (MNCR's or condition report / disposition requests (CR/DR)) were written. The inspector also found that if on the spot corrective actions were taken or if further inspection requirements needed, the actions were documente,
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Licensee Manaaement Observations Licensee procedure 02GB-0M001, Revision 01.02, Management Observation
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Program, provided forni direction and guidelines for management personnel (above first line supervisory personnel) to directly observe personnel performing plant activities and work. This procedure was
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required to ensure that management expectations and standards were understood and implemented, as well as to provide feedback to personnel.
The inspector reviewed licensee procedure 02GB-0M001 and three completed general management observation program reports for fire protection. The
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inspector found that licensee procedure 02GB-0M001 required management personnel to perform in-plant observations on a quarterly basis. The inspector found that the fire department manager was meeting this
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requirement by performing fire protection area and equipment walk-downs.
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The inspector also found that fire protection supervisory personnel performance requirements contained a performance rating factor which required them to perform monthly in plant walk-downs and inspections.
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Procurement of Fire Protection Eouipment The inspector reviewed licensee procedures 87DP-0MC01, Revision 00.07, Item Procurement Specification (IPS) Requirements, 12AC-0MC01, Revision 3.02, Control of Purchased Material Equipment and Services, and 63DP-0QQ04, Revision 02.08, Receipt Inspection, four fire protection, and three 10 CFR 50, Appendix R emergency lighting purchase order packages.
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The inspector found that the licensee had specified, procured, receipt inspected, and stored fire protection equipment and emergency lighting in accordance with licensee procurement specification, inspection and storage procedures.
Testina. Trendina, and Corrective Actions The inspector reviewed fire protection surveillance testing procedures 73AC-0FP01, Revision 2.02 Fire Protection Test Program and 73DP-0FP01, Revision 2.02, Fire Protection Test Program Requirements, and fire protection equipment testing schedules. The inspector reviewed five fire protection equipment surveillance records and observed two fire protection surveillance tests in progress (see QA section above). The inspector found that the licensee had scheduled and performed the surveillance and tests in accordance with their procedures.
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The inspector reviewed licensee procedure 73DP-0ZZO3, Revision 1.0, System Performance Engineering, and 60AC-0QQ20, Revision 01.00, PVNGS Performance Assessment Process and reviewed fire protection group fire protection equipment trending reports and_the PVNGS Performance
Assessment Annunciator Report.
The inspector found that the licensee j
fire protection group was trending fire protection equipment condition and status, and that the licensee QA department performance assessment team was monitoring overall fire protection trend ;
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The inspector reviewed three 10 CFR 50, Appendix R emergency lights which had MNCR's written for test failures. The inspector review found that the licensee had initiated corrective action within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with priority level 2 classification for 10 CFR 50, Appendix R~
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emergency lighting. The inspector limited the review of 10 CFR 50, Appendix R emergency lighting during this inspection.. 10 CFR 50, Appendix R emergency lighting and testing, corrective actions, and trending were previously inspected for the closure of NRC enforcement item 50-528/90-25-01. NRC enforcement item 50-528/90-25-01 was closed in NRC Inspection Report 50-528/529/530/93-24, dated July 30, 1993.
Conclusion The inspector concluded that the licensee had implemented QA oversight of the fire protection program and had completed actions as defined in the July 20, 1990, Fire Protection Justification for Continued Operation
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(JCO). This item is closed.
No new violations or deviations of NRC requirements were identified.
5.
Exit Meetina The inspectors conducted an exit meeting on September 3, 1993, with members of the licensee staff as indicated in Section 1.
During this meeting, the inspectors summarized the scope of the inspection activities i
and reviewed the inspection findings as described in this report.
The licensee acknowledged the concerns identified in the report.
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