IR 05000528/1993049

Insp Repts 50-528/93-49,50-529/93-49 & 50-530/93-49 on 931115-19.No Violations Noted.Major Areas Inspected:Reviewed Licensee Implementation of Containment LLRT Program & Licensee Actions for Open Items Identified in Insp Rept

ML20059A402
Person / Time
Site:	Palo Verde
Issue date:	12/15/1993
From:	Ang W, Clark C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20059A366	List: IR 05000528/1993049 ML20059A365
References
50-528-93-49, 50-529-93-49, 50-530-93-49, NUDOCS 9312300149
Download: ML20059A402 (16)

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U. S. NUCLEAR REGULATORY COMMISSION REGION V i

Report No.: 50-528/93-49, 50-529/93-49, and 50-530/93-49 Docket No.: 50-528, 50-529, and 50-530  ;

License No.: NPF-41, NPF-51, and NPF-74 Licensee: Arizona Public Service Company ,

Facility Name: Palo Verde Nuclear Generating Station l Units 1, 2, and 3 Inspected at: Palo Verde Nuclear Generating Station, Wintersburg, !

Arizona -l Insoection date: November 15 through November 19, 1993 l

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Inspector: C. Clark, Reactor Inspector

Aporoved by: kl W.'P. Adg, Chief

, o h f b 's Date Signed f

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Engineering Section-

Inspection Summary:

Inspection durina the period November 15 throuah November 19. 1993 (Recort Nos. 50-528/93-49. 50-529/93-49. and 50-530/93-49) l Areas Inspected:

This announced routine inspection reviewed the licensee implementation of thel 'l containment local leak rate test (LLRT) program and the licensee's actions for ;

open items identified in NRC inspection reports. NRC inspection procedures 61720, 92701, and 92702 were used as guidance for this inspectio i Safety Issues Manaaement System (SIMS) Item: i i

None i

Results:

General Conclusions and Specific Findinas:

The inspector concluded that :he licensee's LLRT program was performed in an effective manne ;

i 9312300149 931216 PDR ADOCK 05000528 r G PM ,

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2 i Sionit'icant Safety Matters: 1 Non l l

Summary of Violation or Deviations:

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No violations or deviations of NRC requirements were identified during this inspectio ,

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Open Items Summary:

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Two new unresolved items were identified: ,

• Additional NRC review was required to ensure the inner' door equalizing valves for both the 100' emergency air lock and the 140' containment air

lock in all three units, had been conservatively tested in accordance with NRC requirements. (Section 2. e)

• Additional background information was required to ensure the L

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appropriateness of the licensee's acceptance of a safety related valve (IPSIBV533) for continued operation, after it failed its "As Found" LLRT, without any internal inspection or repair work. (Section 2. e)

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The inspector closed two violation t t

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Details

Persons Contacted ,

Arizona Public Services Company i

• R. Adney, Plant Manager, Unit 3 *

• J. Bergstedt, Senior Quality Monitor, Quality Assurance and Monitoring

• R. Bernier, Supervisor, Nuclear Regulatory Affairs T. Cannon, Supervisor, Plant Inservice Inspection and Testin R. Fountain, Supervisor, Quality Assurance and Monitoring ,

• D. Garchow, Manager, Site Mechanical Engineering Department i

J. Harnden, Supervisory, Independent safety Engineering

• Johnson, Engineer III, Quality Assurance and Monitoring ,

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• D. Kanitz, Senior Engineer, Nuclear Regulatory Affairs W. Lehman, Engineer (Check Valve), Inservice Inspection and Testing i A. Morrow, Primary Discipline Engineer, Inservice Inspection and. Testing

• D. Oakes, Primary Discipline Engineer, Inservice Inspection and Testing-N. Spooner, Senior Engineer (ILRT), Inservice Inspection and Testing

• S. Troisi, Acting Manager, Site Technical Support D. Visco, Senior Engineer, Independent Safety Engineering ,

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U. S. Nuclear Reculatory Commission  ;

• K. Johnston, Project Inspector, Region V The inspector also held discussions with other licensee and contractor !

personnel during the course of the inspectio l

• Denotes those attending the exit meeting on November 19, 1993. Containment local Leak Rate Testina-(61720) Purpose l The purpose of this inspection was to: ,

• Ascertain whether the licensee's containment local leak rate test (LLRT) program was being properly conducte * Independently verify the acceptability of the LLRT result Backaround Section 4.6.1.1 of the Palo Verde Nuclear Generating Station (PVNGS).- -t Units 1, 2, and 3 Technical Specifications (TS) requires that~ :

primary containment integrity shall be demonstrated periodicall *

To meet this commitment the licensee' established a LLRT program to-provide a means of testing to verify actual leakage rates of _

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containment isolation valves and penetrations.- The purpose of the LLRT program was to provide a continually updated evaluation for-the

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integrity of each unit's containment penetrations and of the containment as a whole. Unit I- was completing its fourth refueling outage (IR4) during this inspection. A Unit I containment  ;

integrated leak rate test (CILRT) was initially scheduled to be performed during the IR4 outage,.but was cancelled prior to this inspection. As a result of lengthy past outages, the. licensee was -

preparing a submittal to revise Unit 1 TS to take advantage of the more flexible schedule allowed by Appendix J of 10 CFR Part 5 .

This proposed TS change would reschedule the Unit 1 CILRT to a future outage, c. LtRT Proaram The inspector sampled the licensee's containment LLRT. programs for Units 1, 2, and The requirements for local leak rate testing ^

were outlined in Nuclear Administrative and Technical Manual Procedures 73AC-9ZZ04, Rev. 09.05, " Surveillance Testing" and 73ST-ICL01, Rev. 4, " Containment Leakage Type 'B' and 'C' Testing." ,

Procedure 73ST-lCL01 defined the types of containment penetration testing as follows:

lype "A" Test - A test intended to measure the containment building overall integrated leakage rate; (1) after the containment building has been completed and is ready for operation and (2) at periodic intervals thereafte Tvoe "B" Test - A test intended to detect and measure local leakage across each pressure containing or leakage limiting boundary for the following containment building penetrations:

• Penetrations whose design incorporates resilient seals, .

r gaskets, or sealant compounds, expansion bellows or flexible :

metal seal ,

• Air lock door seals, including door operation mechanism penetrations which are part of the containment pressure boundar * Doors with resilient seals or gaskets (except seal welded). . As ,

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an example, the containment equipment hatc Type "C" Test - A test intended to measure containment isolation valve (CIV) leakage rates. CIV's included were those that:

• Provide direct communication between inside and outside atmospheres of the containment building under normal operatio * Were required to close automatically upon receipt of a -

containment isolation signal intended to effect containment ,

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• Were required to operate intermittently under post accident-condition d. Sample and Criteria The inspector selected the IR4 LLRT procedures and data for review during this inspection. A sample review of local leak rate summary '

test data from the last outages of Units 2 and 3 was also performe '

Procedures

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The inspector reviewed the following licensee procedures:

• 73ST-ICL01, Rev. 4, " Containment Leakage Type "B" and "C" Testing" -

• 73ST-9CLO3, Rev. 04.01, "140' Containment Air lock Seal Leak Test"

• 73ST-9CLO4, Rev. 3, Procedure Change Notice (PCN) 1, "100'

Emergency Air lock Overall Leak Test and Interlock Test" ,

• 73ST-9CLO6, Rev. 3, " Containment Ventilation Purge Isolation Valve (42") - Penetration 56"

• 73ST-9CLO7, Rev. 3, " Containment Ventilation Purge Isolation Valves (8") - Penetration 78' and 79"

• 73ST-9CLO8, Rev. 00.01, "100'- Emergency Air lock Seal Leak

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Test"

• 73ST-9CL10, Rev. O, " Containment Ventilation Purge Isolation Valves (42") - Penetration 57" l Test Data The inspector reviewed approximately 237 associated test data sheets .

completed for the IR4 outage, and surveillance test schedules to ensure: ,

• That all applicable containment penetrations boundaries (CPBs) and CIVs were local leak rate tested at the <

required TS frequency since the previous Type "A" ..

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containment integrated. leak rate test (CILRT).

That the sum of the current local leak rates for all boundaries and valves subject to LLRTs met the acceptance criteri * That the licensee performed the actions required by the ,

TS, if the combination of the local leak rates was in j

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excess of the acceptance criteri .

• The LLRTs were performed at containment integrated leak rate test (CILRT) peak pressure except where reduced pressure tests had received prior NRR approval in the T ,

• The LLRT program utilized NRC approved methods for testing CPBs and CIVs. NRC approved methods were described in NRC Inspection Procedure 61720, Containment Local Leak Rate Testing."

• Penetration leakage rates were determined using the maximum pathway leakage. Maximum pathway leakage was defined in Inspection Procedure 6172 * Licensee criteria and response for LLRT and combined leakage rate failures were identifie * Licensee criteria and response for the leakage rate failures of components specifically cited in the TS were identifie .

Maintenance Reauest

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The inspector reviewed lists of work orders issued for maintenance work performed on CPBs and CIVs since the last CILRT, for both the Unit I and the Unit 2 fourth refueling outages, along with six completed' work order packages for those outages. This review was performed to verify that the repairs and modifications performed on the penetrations were preceded and followed by LLRTs on the '

applicable penetrations. The tests for the following penetrations were verified:

Unit 1 (a) Penetration 28 - Safety Injection' Tank Drain (b) Penetration 40 - Regenerative Heat Exchanger  ;

(c) Penetration 42A - Pressurizer Surge Sample (d) Penetration 43 - Reactor Coolant Pump Bleedoff (e) Penetration 50 - Refueling Cavity Drain Unit 2 (a) Penetration 09 - Radwaste Drain (b) Penetration 21 - Containment Spray

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(c) Penetration 26 - Shutdown Cooling -B-(d) Penetration 29 - Low Pressure Nitrogen Supply (e) Penetration 59 - Service Air Supply (f) Penetration 61 - Normal Chill Water Return Test Observations The inspector observed LLRTs performed on Penetrations LI (140'

containment air lock) and L2 (equipment hatch) to determine if,they were performed in accordance with regulation and procedural '

commitment Inspector Observations ' Procedures ,

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The inspector reviewed the licensee's LLRT procedures and concluded that the tests described met regulatory requirenent i The inspector verified test acceptance criteria and response for ,

LLRTs and combined leakage rate failures were identified, . in' the i

applicable procedure The inspector verified that, by procedure, each CIV was required.to be closed by normal operation for the LLRT, without any preliminary exercising or adjusting of the valv J Test Data The inspector determined that the Unit 1 CPBs and CIVs reviewed, ,

except for the air lock inner door equalizing valves discussed !

below, had been local leak rate tested at the required frequency i since the previous Type "A" CILR i Specification 4.6.1.1.c. of the TS required the. licensee to .,

establish an acceptance criteria for the combined total maximum ~

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pathway leakage for all mechanical and electrical penetrations and valves subject to the Type "B" and "C" tests in each_ unit. The licensee identified this acceptance criteria as less:than or equal to 134,001 standard cubic centimeters per minute (SCCM) per uni The inspector reviewed the combined total maximum pathway. as-found '

and as-left leakages for 1R4 LLRTs and determined the following:

As-Found leakaae

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The initial Unit I as-found maximum pathway leakage was l unbounded. When performing an as-found LLRT on penetration 67 ~)

(long term recirculation) safety injection check valve i I

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.1PSIBV533, the valve disk seat leakage was so large th'at test .

pressure could not' be obtained. Therefore the licensee .  ;

concluded, in;accordance with procedure 73ST-1CL01,-that.the y maximum penetration leakage was.also unbounded l assuming the '1 other penetration isolation valve was' a . single.' failure. After t

testing of adjacent valves _in the same line:a subsequent' test?

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- of the check valve measured a LLRT. leakage: rate of 411 'SCCM.- 1 However, no corrective-action.was;taken, other:tnan a retest of; j the check valve. The valve was not opened,: norias- an'  !

examination performed of the. valve internals.; Tholicensee '  :

issued a Condition Report / Disposition. Request (CRDR) 1-3-0584- !

dated October 18,.1993, which identified the following:  ;

• Anoarent Cause of the Condition -' Based on the attached-equipment root cause of failure analysis. (ERCFA), the - j apparent potential causes of the excessive leakage - .

exhibited by check valve 1PSIBV533 were as follows: '

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(1) Debris existing between the valve disk and the sea :j (2) An accumulation of deposits between the ball andlthe' 'I race creating a stiffness that prevented the valve- 1 disk from seating properl (3) The disk coming into contact with the valve' body 5

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The licensee considered that debris existing between the seat and the disk, or. some stiffness between the ball and .

race, or'a combination of the two,;would be the more C credible of the three identified potential causes. A definitive inspection of the valve internals wasnot l performe >

• Facts and Evidence - Borg Warner . issued a 10CFR Part' 21- ,

notification (CFRN-9302) that. identified a concern with- l disc to body contact;in various~models'of:Borg Warner i

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check valves which could result in a disc becoming stuck open. The area of contact is the junction between the j horizontal-and vertical ~ bores:in the valve body. A CRDR l 9-3-0149 identified containment isolation check valve: ;j IPSIBVV533 as a potential candidate that this concern-could apply-t ~

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• ' Corrective Action (si --CRDR'9-3-0149 dated October 28, 1993, ' addressed the concern of the Borg Warner 10CFR_ Part -

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21' notification-and the failure of the LLRT of valve -

IPSIV533 identified in CRDR 1-3-0584..- The corrective action of CRDR 9-3-0149 was.to inspect _ valve IPSIBV533 at the next available opportunity with continued inspections

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as required by the check valve progra No additional -

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L The Part 21 report identified similar conditions that could result in a stuck open valve. The inspector l considered that the licensee actions in response to CRDR 1-3-0584 may have not-sufficiently taken into account the recommendation of the Part 21 report, including examination of the. valve internal Additional NRC review of the licensee's basis for this action is required. This concern is considered an unresolved ite i (Unresolved'50-528/93-49-01).

The inspector discussed this concern with the licensee on December 9, 199 .

The licensee stated they would review the Part 21 report and ;

their previous actions for this ite As-Left Leakaae The final the as-left maximum pathway leakage was identified by i the licensee as 29,918 plus or minus 808 SCCM on November 17, 199 ;

The inspector reviewed the performance of LLRTs to verify licensee actions were in accordance with the required action ;

of TS and licensee procedures. The inspector found that all Unit 1 CPBs and CIVs reviewed, except for the air lock inner-door equalizing valves discussed below, were tested using the acceptable inflow method. The testing reviewed was performed at'a containment integrated leak rate test (CILRT) peak pressure of approximately 51.5-52.0 pounds per square inch gauge (PSIG) except where reduced pressure tests had received prior NRR approval in the TS (e.g., air lock-door seals).

The inspector found that all penetrations listed in the TS were incorporated into the LLRT program. However the' inspector ,

noted that the inner door equalizing valves for both the'140'

containment air lock and the 100' emergency air lock (penetrations L1 and L3) in all three units,- were~ not being individually tested. The inboard door equalizing valves were:

clamped shut to prevent the valves from opening at the 51.5-52.0 PSIG test pressure applied to the entire air lock penetration. Due. to.the design of the equalizing valve it -

cannot be tested at pressure (from the air lock side) greater that the spring force which holds the valve closed.(i.e., -

approximately 10 to 15 PSIG), nor can it be readily tested in-the direction of flow from accident conditions. Therefore clamping was necessary. ' The test as performed only verified '.

that' one of the two o ring seals was sealing. The licensee stated that their existing method of ter+ing of the inner door equalizing valves sa',isfied the testin3 requirements of 10 CFR

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Part 50, Appendix In discussions with the licensee, the inspector noted _that another Regi_on V licensee who had similarly clamped the inner door equalizing valves shut had interpreted that they were not testing their similar equalizing valves in accordance with the requirements of 10 CFR Part 50, Appendix J. That' licensee had taken the following actions:

• Classified their equalizing valve as subject to Type "B" testing requirements in that it was a part of the air lock mechanism (but not part of the door seal).

• Conservatively declared the inner containment air lock doors inoperable due to the untested equalizing valve * Elected to request an exemption to Appendix J, from the NRC, to test the equalizing valves by pressurizing between the valve seals at a reduced pressure (i.e., 5 to 10-

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PSIG). This exemption was issued by the NRC on June 8, 1990, and those valves were tested satisfactorily. .

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The inspector asked the licensee if they could identify if the-inner air lock door equalizing valves in all three units had a -

test port that would allow testing' between the' two o-ring seals installed in the valve disk. On' December 2, 1993, the licensee stated that the drawings for the six valves -(two per unit)

installed in all three units, showed that the valves contained ;

a test port. However the licensee had not been able to verify ,

that each valve actually contained a test port. The' licensee committed to take the following actions:

• Research maintenance and testing history on these valves :

to determine if there had been any identified valve leakage problem * Inspect available valves to verify the presence of a valve body seat test port. Unit 3 was shut down, however, the

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valves in the other units may not be readily available for-inspection until the next scheduled containment entr The licensee stated that they would provide available information on the inner door equalizing valves to the inspector by approximately December 13, 199 On December 14, 1993, additional information on the LLRT of air lock inner door ,

equalizing valves was provided 'to the inspector. A December 10, 1993, memorandum ( No. 315-00397-TCC-WGW) identified that although the licensee maintained'the position that their current testing assured the ' operability of the equalizing :

valves in accordance with TS and their commitments to Appendix J, they planned to examine more rigorous testing of indiv_idual

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operating mechanisms (including the equalizing valve 0-ring seals), as part of their plans to develop a' performance. based

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testing program. This item is considered an unresolved item pending further review of the facts by the NRC. (Unresolved item 50-528,529,530/93-49-02)  :

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The inspector noted that the current air lock testing had ,

verified the acceptable leakage of the air lock outer door and ,

its associated equalizing valve, for penetrations L1 and L3 in :

all three unit The inspector verified the combined local leakage rates wer determined for each penetration using the maximum pathway leakage method identified in NRC Inspection Procedure 6172 The inspector verified the recorded test equipment used for the LLRTs was within its recorded calibration acceptance period for the *

tests reviewe The inspector reviewed a sample of scheduled maintenance work and verified that where maintenance work was performed on CPBs and CIVs since the last CILRT, repairs and modifications were preceded an followed by LLRTs on the applicable penetrations. The penetrations and associated work orders included in the review sample are ,

identified below:

Unit 1 (Fourth Refuelino Outaae)

(a) Penetration 28 - Work Orders 4A1CL2801 and 4A1CL2802 (b) Penetration 40 - Work Orders 4A1CL4001 and 4A1CL4002 (c) Penetration 42A - Work Orders 4A1CL42A1 and 4AICL42A2 (d) Penetration 50 - Work Orders 4A1CL5001.and 4AICL5002 ,

Unit 2 (Fourth Refuelina Outaae)

(a) Penetration 009 - Work Orders 4AICL00901 and 4AICL00902 (b) Penetration 021 - Work Orders 4A1CL2101 and 4AICL2102 (c) Penetration 29 - Work Orders 4AICLO2901 and-4A1CLO2902 t

(d) Penetration 059 - Work Orders 4AICLO5901 and 4A1CLO5902 ,

Test Observations The NRC inspector observed LLRTs performed on the-140' personnel air !

lock and the equipment hatch. These LLRTs were performed.in accordance with regulation and procedural commitments. The .

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traceable to. National Bureau of Standards (NBS) standards. The personnel performing the LLRTs observed were knowledgeable and performed their assigned functions in a professional manne Conclusions .

The inspector concluded that the LLRT program appeared to be t generally effective. Except for the concern that the inner door ,

equalizing valves for the air locks in all three units may not have been properly tested, the IR4 LLRTs were properly conducte No violations or deviations of NRC requirements were identified, j Followup on Corrective Actions for ~Previously Identified Violations (92701) { (Closed) Violation 50-528/92-036-01: Failure to Test Boric Acid Check Valves in accordance with Section XI of the ASME Code ,

Oriainal NRC Violation NRC inspectors identified that the licensee had not included boric acid make-up pump discharge check valves CHN-V154 and CHN-V155 in their IST program. These valves were in the boron injection flow ,

path described in Technical Specification 3.1.2.2.c. This flow path was tested per procedure 41ST-ICH04,' Revision 2.03, " Boron Injection Flow Test 4.1.2.2.1.b". The flow path of this test utilized gravit feed from the refueling water tank through valve CHV-164 (boric acid filter bypass valve) and a charging pump to the reactor coolant system. However, the flow path was paralleled through ' check valves CHN-V154 and CHN-V155, and these valves were not individually teste Since these check valves were required to open, they were active check valves which required individual testing in accordance with Section XI of the ASME Boiler and Pressure Vessel Cod Licensee's Actions In Response To The Violation The licensee, in their December 31, 1992, response to the violation,-

identified the following:

• The violation occurred because a safety function, provided by check valves CHN-V155 and CHN-V155, was not recognized when the IST program was develope * A Condition Report / Disposition Request (CRDR) 920679.wa ;

initiated to determine whether there was adequate assurance that check valves CHN-V154 and CHN-V155 were capable of performing their intended function. This review determined ,

that these valves were capable of performing their safety

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functio In this same response, the licensee committed to perform the following actions:

• Evaluate an alternate gravity feed boron injection flow path that.would satisfy T5 limiting condition for operation (LCO),

Section 3.1.2.2. This alternate path' would not' include the

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boric acid make-up pumps or their associated discharge check valves (CHN-V154 and'CHN-V155).

• If the alternate flow path was determined to be unacceptable, check valves CHN-154 and CHN-155 would be added to the IST progra * All affected programs and surveillance procedures would be revised to incorporate required ASME Section XI testing by June 30, 199 Inspector's Actions Durino The Present Inspection The inspector reviewed the following:

• The licensee's evaluation of CRDR 920679

• Nuclear Administrative and Technical Manual 73PR-1XIOI, Re .07, ".PVNG ASME Section XI Pump and Valve Inservice Testing '

Program, Unit 1."

• Nuclear Administrative and Technical Manual 73PR-2XI01, Re .07, " PVNG ASME Section XI Pump and Valve Inservice Testing Program, Unit 2."  ;

• Nuclear Administrative and Technical Manual 73PR-3XIOl, Re .07, " PVNG ASME Section XI Pump and Valve Inservice Testing '

Program, Unit 3."

• Unit I procedure 41ST-1CH04, Rev. 7, " Boron Injection Flow Test 4.1.2.2.1.b."

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• Unit 2 proceduie 42ST-2CH04, Rev. 03.06, " Boron Injection Flow Test 4.1.2.2. * Unit 3 procedure 43ST-3CH04, Rev. 02.06, " Boron Injection Flow ]

Test 4.1.2.2. Discussion and conclusion .

The inspector determined that the alternate flow path was determined i by the licensee to be unacceptable, and check valves CHN-154 and I CHN-155 were added to the IST programs for all three units. The

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latest surveillance procedures reviewed by the inspector had been revised to incorporate the required ASME Section XI testing for check valves CHN-154 and CHN-155. As of December 14, 1993, the- :

licensee identified that the Unit I valves had been satisfactorily tested November 20,1993, Unit 2 valve test results were being evaluated, and Unit 3 valves would be tested at the next scheduled availability. Based on this review, the inspector concluded that the licensee's actions adequately resolved this violation. This item is close :i b. 1 Closed) Violation 50-528/92-013-01: Failure to Report Loose Nut on Snubber Oriainal NRC Violation

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On April 27, 1993, NRC inspectors performed an independent followup examination of steam generator blowndown piping support 2SG-048-H017 and discovered a jam nut could be turned by hand on this componen A contractor for the licensee had performed an ISI examination of this support on April 22, 1993, and evaluated the component i acceptable in Palo Verde Inservice Visual Examination Report 93-2316. Report 93-2316 did not identify the abnormal condition and therefore, the loose jam nut condition was not evaluate Licensee's Actions in Response to this Violation The licensee, in their July 12, 1993, response to the violation . '

identified the following:

• Subsequent to the NRC inspection finding, three licensee >

inspectors independently checked the loose jam nut on pipe ,

support 2SG-048-H017. Two of the licensee's inspectors considered the jam nut tight, the third.however, considered it *

loose. Each inspector had different physical abilities and- '

each positioned himself differently, relative to the pipe ;

support, when performing the inspection * The licensee concluded that the reasons for the' mixed inspection results and the Notice of Violation were the . ,

differences in the physical abilities of the inspectors and the differences in the' positions assumed by the inspectors when-performing these inspection * A material non-conformance report (MNCR) was written against .

2SG-048-H017, the jam nut was tightened, and the support was a satisfactorily reinspecte o

• Approximately 112 pipe supports in Unit 2 were reinspected by a !

new licensee contractor. The new inspectors found two loose -

bolting discrepancies that were not previously identified, and-accepted two loose bolting discrepancies that were previously

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identifi m. MNCRs were written for the rejected supports identified and the discrepancies were correcte In this same response, the licensee committed to perform the '

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following actions:

• To review the violation and their violation response with the Palo Verde ISI engineers by September 1,199 * To develop a btiefing describing the' proper technique to use and the optimum position to take when manually checking accessible boltea connections for tightness. The briefing would also incluoe a discussion on documenting the technique used and limitations encountered when inspecting bolted cor.nections that are not fully accessibl This briefing was scheduled to be provided to Palo Verde ISI engineers by September 1, 1993. Contract ISI inspectors would be briefed ,

during orientatio '

• To revise procedure 73TI-9ZZl8 by September 1,1993, to. include guidance on the proper technique to use and optimum position to take when checking accessible bolted connections for tightnes Inspector's Actions Durino the Present Inspection The inspector reviewed the following:

• The licensee's evaluation of CRDR No. 2-3-030 * Procedure 73TI-9ZZ18, Rev. 5.00, " Visual Examination of Support Components." ,

• Procedure 73DP-9EE02, Rev. 00.03, " Inservice Inspection Examination Activities."

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• Various available training documents and records for the briefing provided on this violatio ,

Discussion and conclusion c

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The inspector determined that the licensee developed a briefing for this violation and their response, and reviewed the briefing with-the Palo Verde ISI engineers. The latest procedures reviewed by the inspector had been revised to incorporate the briefing inspection i guidance. Based on this review, the inspector concluded that the licensee's actions adequately resolved this violation. ' This item is close ;

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14 i Exit Meetina i

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The inspector conducted an exit meetings on November 19, 1993, with .

members of the licensee staff as-indicated in Section 1 of this repor During this meeting, the inspector summarized the scope of.the inspection activities and reviewed the inspection findings as described in this >

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report.- The inspector identified that he had requested. some additional information that would be reviewed in the region. This additional-information was reviewed by the inspector and' included in section 2. e of ;

the report. ' The licensee acknowledged the inspector findings as identified in this repor '

The inspector requested that the licensee identify any proprietary information which needed to be returned to the licensee. The licensee +

did not identify any proprietary information which had to be returned to .

the license :

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