IR 05000528/1999008

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Insp Repts 50-528/99-08,50-529/99-08 & 50-530/99-08 on 990412-16.No Violations Noted.Major Areas Inspected:Maint & Engineering
ML17313A935
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/12/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17313A933 List:
References
50-528-99-08, 50-528-99-8, 50-529-99-08, 50-529-99-8, 50-530-99-08, 50-530-99-8, NUDOCS 9905210173
Download: ML17313A935 (30)


Text

ENCLOSURE U.S. NUCLEAR REGULATORYCOMMISSION

REGION IV

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved By:

50-528; 50-529; 50-530 NPF-41; NPF-51; NPF-74 50-528/99-08; 50-529/99-08; 50-530/99-08 Arizona Public Service Company Palo Verde Nuclear Generating Station, Units 1, 2, and 3 5951 S. Wintersburg Road Tonopah, Arizona April 12-16, 1999 CliffordA. Clark, Reactor Inspector Engineering and Maintenance Branch Lawrence E. Ellershaw, Senior Reactor Inspector Engineering and Maintenance Branch Dr. Dale A. Powers, Chief Engineering and Maintenance Branch Division of Reactor Safety ATIACHMENT:

Supplemental Information 99052iOi73 9905i2 PDR ADQCK 05000529

PDR

-2-EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1, 2, and 3 NRC Inspection Report No. 50-528/99-08; 50-529/99-08; 50-530/99-08 Maintenance The licensee's inservice inspection program implemented the 1992 Edition of the ASME Code, which had not been approved for use by the NRC. While the licensee determined that they had not deviated from the 1989 Edition of the ASME Code, they did however, identify the need for immediate submittal of two requests for relief that dealt with examination of bolted connections and corrective actions associated with detected leaks of bolted connections.

The licensee appeared to have not recognized the differences between the 1980 Edition and Winter 1981 Addenda, the 1989 Edition, and the 1992 Edition and 1992 Addenda.

This was considered by the inspectors as a programmatic weakness (Section M1).

The external material condition of the observed Unit 2 pumps, valves, piping, and component supports was good, in that, no visible oil or water leaks were noted.

The observed equipment was properly labeled (Section M2).

The nondestructive examination procedures used to perform the inspector-observed inservice inspections contained sufficient detail and inspection acceptance criteria to enable the performance of the intended examinations.

The procedures were in compliance with Sections V and XI of the ASME Code (Section M3).

Licensee personnel were effective in their oversight and control of contractor inservice inspection activities. Contractor inservice inspection personnel were properly certified and knowledgeable of applicable nondestructive examination procedures and ASME Code requirements.

Very good performance was demonstrated by contractor inservice inspection personnel during conduct of equipment calibration and examinations (three liquid penetrant, four ultrasonic, and four magnetic particle) observed by the inspectors (Sections M4 and M5).

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The most recent inservice inspection program self-assessment was thorough, objective, and insightful ~ Issues were identified and documented in condition reports/disposition requests, and were being tracked by the licensee's corrective action program (Section M7).

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A noncited violation was identified regarding an inadequate surveillance test procedure (Section E8.5) ~

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A noncited violation was identified for inadequate design control (Section E8.1).

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-3-Re ort Details Summa of Plant Status During this inspection, Unit 2 was in Mode 6, and Units 1 and 3 were in Mode 1.

II. Nlaintenance M1 Conduct of Maintenance M1.1 lnservice Ins ection 73753 a.

Ins ection Sco e 73753 The inspectors performed a thorough review of the licensee's second 10-Year Interval Inservice Inspection Program 2INT-ISI-2, "Inservice Inspection Program Summary Manual - Palo Verde Nuclear Generating Station Unit 2," Revision 0. The inspectors also reviewed applicable requests for relief, ASME code cases, and correspondence between the licensee and the NRC regarding this inservice inspection program.

b.

Observations and Findin s The inspectors noted that the first 10-year interval inservice inspection program had committed to the 1980 Edition through the Winter 1981 Addenda of the ASME Code.

The inspectors found that the licensee's second 10-year interval inservice inspection program, which was dated February 1, 1998, committed to implement the 1992 Edition including the 1992 Addenda of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Code. The inservice inspection program also included requests for Reliefs 1 through 9.

Section 2.0, "Code Applicability,"of the licensee's program stated, "Based on paragraph 10 CFR 50.55a(b)(2)..

~ the 1989 Edition of ASME Section XI was referenced as the Code to utilize for preparation of this program.

However, this ISI Program is based on the 1992 Edition including Addenda through 1992. This is documented in Request for Relief 1 included in Section 8.0. This request was based on the anticipation of this edition and addenda being referenced in 10 CFR 50.55a; and, its submittal by other utilities." (Note: Currently, the 1989 Edition of the ASME Code is the approved edition incorporated by reference in 10 CFR Part 50.55a, "Codes and Standards.")

The inspectors questioned the licensee's use of the 1992 Edition of the ASME Code and the nine requests for relief with respect to whether or not they had received NRC approval. The licensee provided the inspectors with a copy of a letter to the NRC

(102-04095-WEI/AKK/MLG)dated March 17, 1998, which submitted their updated inservice inspection program.

The letter stated that request for Relief 1 requested approval to use the 1992 Edition including the 1992 Addenda of the ASME Code as the code of record for all three units. The licensee had not received NRC approval to allow use of request for Relief 1, which the licensee implemented during the current Unit 2 outage (U2R8).

As a result of the inspectors'uestions, the licensee performed a detailed review to determine ifthey had deviated from any of the applicable requirements of the 1989 Edition of the ASME Code by having implemented the 1992 Edition and Addenda of the ASME Code during Outage U2R8. The licensee determined that they had not deviated from the 1989 Edition of the ASME Code, and in fact, implementation of the 1992 Edition and Addenda of the ASME Code represented more restrictive requirements.

Their review did, however, identify the need for immediate submittal of two requests for relief that dealt with examination of bolted connections and corrective actions associated with detected leaks of bolted connections.

The licensee's staff appeared to have not recognized the differences between the 1980 Edition and Winter 1981 Addenda, the 1989 Edition, and the 1992 Edition and 1992 Addenda.

Since some examinations and associated actions had been implemented during the current Unit 2 outage, this necessitated the need for requests for relief. The requests for relief were submitted subsequent to the onsite inspection.

The NRC responded to the licensee's submittal and provided approval on April26, 1999.

The inspectors considered the licensee's use of an edition of the ASME Code that had not been incorporated by reference into the Federal Register, and apparently without having performed a sufficiently detailed review, as a programmatic weakness.

Section 3.11, "Code Cases," of the program stated:

"ASME Section Xl Code Case acceptability willbe based on Regulatory Guide 1.147." (Note: Regulatory Guide 1.147,

"Inservice Inspection Code Case Acceptability - ASME Section XI Division 1,"

Revision 11, lists those code cases that are generally acceptable to the NRC staff for implementation in licensees'nservice inspection programs.)

Section 3.11 identified Code Case N416-1 as having been approved specifically for the licensee's use based on NRC Letter dated March 16, 1995, "Authorization to use ASME Section XI Code Case N416-1 for the Palo Verde Nuclear Generating Station Unit 1, 2, 5 3."

The inspectors reviewed the authorization letter and determined that its use was predicated upon the licensee performing additional surface examinations on the root pass of butt and socket welds on the pressure retaining boundary of Class 3 components when the surface examination method is used in accordance with Section III of the ASME Code.

The inspectors requested a list of all work orders pertaining to pressure retaining Class 3 components in which Code Case N416-1 had been used.

From the list, the inspectors selected 14 work orders (identified in the Attachment) and requested the licensee to provide the work order packages and associated welding examination record [

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-5-The inspectors verified that the licensee had performed the additional surface examinations as required in the NRC authorization letter, which allowed the licensee to use Code Case N416-1.

Conclusions The licensee's second 10-year interval inservice inspection program plan (dated February 1998), which included nine requests for relief, committed to the'1992 Edition of the ASME Code. This program was implemented for the current Unit 2 Refueling Outage U2R8. The latest NRC-approved ASME Code, as referenced in 10 CFR 50.55a, is the 1989 Edition. Neither the inservice inspection program plan nor the requests for relief, submitted to the NRC in March 1998, had been reviewed and approved by the NRC. However, the licensee determined that they had not deviated from the 1989 Edition of the ASME Code, and in fact, implementation of the 1992 Edition and Addenda of the ASME Code represented more restrictive requirements.

Their review did, however, identify the need for immediate submittal of two requests for relief that dealt with examination of bolted connections and corrective actions associated with detected leaks of bolted connections.

The licensee's staff appeared to have not recognized the differences between the 1980 Edition and Winter 1981 Addenda, the 1989 Edition, and the 1992 Edition and 1992 Addenda.

e The inspectors considered the licensee's use of an edition of the ASME Code that had not been incorporated by reference into the Federal Register, and apparently without having performed a sufficiently detailed review, as a programmatic weakness.

M2 Be Maintenance and Material Condition of Facilities and Equipment Ins ection Sco e 73753 While observing performance of nondestructive examinations on Unit 2 safety injection system piping located in the Train A rooms of the low pressure safety injection pump and shutdown cooling heat exchanger, the inspectors noted the external material condition of the system piping, pump, and valves. Walkdowns of equipment, not associated with performance of nondestructive examinations, included both trains of containment spray pumps, low pressure safety injection piping systems, and high pressure safety injection piping systems.

Observations and Findin s The inspectors found that the observed Unit 2 Train A valves, piping, and pump, were in good external material condition, in that, no visible oil or water leaks were noted. This assessment was also applicable to the Train A and B containment spray pumps, low

'ressure safety injection systems and high pressure safety injection systems.

Piping systems and components were identified by tags that corresponded to the applicable piping and instrumentation drawings.

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Conclusions The external material condition of the obseived Unit 2 pumps, valves, piping, and component supports was good, in that, no visible oil or water leaks were noted. The observed equipment was properly labeled.

M3 Maintenance Procedures and Documentation a.

Ins ection Sco e 73753 The inspectors reviewed the following nondestructive examination procedures to determine if they had been developed in accordance with regulatory and applicable ASME code requirements:

Procedure 73TI-'9ZZ07, "Liquid Penetrant Examination," Revision 7 Procedure 73TI-9ZZ09, Ultasonic Examination of Pipe Welds," Revision 10 Procedure 73TI-9ZZ05, "Magnetic Particle Examination," Revision 8 b.

Observations and Findin s The inspectors found that the reviewed nondestructive examination procedures contained sufficient detail and inspection criteria to enable the performance of the intended examinations, and were in compliance with Sections V and XI of the ASME Code and regulatory requirements.

c.

Conclusions The nondestructive examination procedures were in compliance with regulatory and ASME code requirements an&vere sufficient to enable the performance of the intended inservice inspection activities.

M4 Maintenance Staff Knowledge and Performance Ins ection Sco e 73753 The inspectors assessed the knowledge and performance of licensee and contractor personnel by observing liquid penetrant, magnetic particle, and ultasonic examinations.

The inspectors also assessed the effectiveness of the licensee's controls as they related to inservice inspection activities (i.e., scheduling examinations, oversight of inservice inspection contractors, and control of ultrasonic calibration equipment).

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-7-Observations and Findin s b.1 Personnel Knowled e The inspectors determined, through observations and discussions, that contractor inservice inspection personnel were knowledgeable of the nondestructive examination methods, procedures and applicable ASME code requirements.

The inspectors noted that the licensee used the same contractor inservice inspection personnel during previous refueling outages.

b.2 Personnel Performance The inspectors found that the performance of (1) liquid penetrant examinations, (2) magnetic particle examinations, (3) ultrasonic examinations, and (4) equipment calibrations (i.e., magnetic particle ac yoke and ultrasonic examination system), was conducted in accordance with approved procedures.

Examination records reviewed are identified in the Attachment.

b.3 Effectiveness of Licensee Control The inspectors determined through observation, that licensee personnel were effective in the day-to-day oversight and control of contractor inservice inspection activities, through the conduct of inspection prebriefs prior to the scheduling of daily inservice inspections.

The inspectors found that the licensee had established and implemented effective controls (administrative procedures and an inventory checklist) in maintaining current status and inventory of ultrasonic calibration blocks for the observed ultrasonic examinations.

Conclusions Contractor inservice inspection personnel were knowledgeable of applicable nondestructive procedures and ASME code requirements.

Examinations were conducted in accordance with approved nondestructive examination procedures.

Licensee personnel were effective in oversight and control of contractor inservice inspection activities through the conduct of job briefings prior to assignment and implementation of daily inservice inspections.

The licensee had established and implemented effective controls (administrative procedures and an inventory checklist) in maintaining current status and inventory of ultrasonic calibration blocks for the observed ultrasonic examination Maintenance Staff Training and Qualification Ins ection Sco e 73753 The inspectors reviewed the licensee's contractor nondestructive examination personnel certification records for Level II examiners.

b.

Observations and Findin s The inspectors noted that personnel certification records were current and contained sufficient documentation (i.e., examination test results for each nondestructive examination method they were certified to perform, work experience, education, and annual visual acuity examinations) to demonstrate personnel qualifications. The inspectors determined that personnel were properly qualified and certified in accordance with the 1984 supplement to SNT-TC-1A, "Requirements for the Qualification of Nondestructive Examination Personnel," as referenced in the ASME code.

Conclusions The contractor nondestructive examination personnel were properly certified in accordance with ASME Code requirements.

Quality Assurance in Maintenance Activities M7.1 Licensee Self-Assessment Activities a.

Ins ection Sco e 73753 The inspectors reviewed the licensee's most recent inservice inspection program self-assessment, dated September 24, 1998.

b.

Observation and Findin s The inservice inspection program self-assessment was conducted over a 10-day period by a team of six individuals, consisting of licensee employees and industry consultants.

The objective of the self-assessment was to assess implementation of the Unit 3 first 10-year interval inservice inspection program utilizing a methodology similar to that contained in the NRC's Inspection Procedure 73753. The inspectors determined that an objective, thorough, and insightful assessment was performed as evidenced by the types of issues identified.

There were 33 issues, nearly all of which caused the initiation of a condition report/disposition request.

The issues were identified as findings (4), unresolved items (7), and recommendations (22) and, generally, were a reflection of poor administrative controls, particularly in the pressure test program. There were, however, some findings that dealt with a failure to conduct required testing, and a failure of testing to comply with all applicable Code requirements.

The inspectors noted that the issues

-9-associated with testing deficiencies dealt with those that could be deferred until the next-10-year interval for Unit 3. The inspectors determined that those conditions had been resolved with respect to the Unit 2 program and, thus, would not have an impact on the current Unit 2 refueling outage inservice inspection activities. The inspectors verified that certain of the actions taken with respect to the administrative control issues had been incorporated into the controlling documents for the Unit 2 refueling outage.

All identified issues had been documented and were being tracked in the corrective action program (i.e., on individual condition report/disposition requests or incorporated into other condition report/disposition requests that identified similar issues.)

Six of the 33 issues remained open; however, the actions for resolving these issues had been completed or had been established but not completed.

c.

Conclusions The most recent self-assessment was thorough, objective, and insightful. Issues were identified and documented in condition reports/disposition requests, and were being tracked by the licensee's correctivy action program.

MS Miscellaneous Maintenance Issues (92902)

NI8.1 Closed Violation 50-529/9722-01:

failure to translate requirements from a design change package to installation work order.

During a previous inspection, the inspector found that Design Change Package DMWO 00793132, Part II, "Other Design Input Considerations,"

Section 1, "Dismantling and Rearranging of Existing Items," contained a requirement that no fuel movement or handling was allowed during the installation of the modification. The inspector noted that the associated work order (WO 00793132) used for implementation of the design change did not contain a requirement prohibiting fuel movement or handling during the installation of the modification.

The licensee issued Condition Report/Disposition Request (CRDR) 9-7-1322 to address this violation, and conducted a root cause investigation.

The inspectors reviewed the identified corrective and preventive actions, along with the associated documents, and considered these actions satisfactory to resolve the violation.

E8 Miscellaneous Engineering Issues (92903)

E8.1 Closed Unresolved Item 50-528/-529/-530/9814-04:

check valve design control issues.

During a previous inspection, the inspector found that Check Valve 1PSIA-V404 had an additional carbon steel spacer ring added, and longer replacement bonnet studs installed without updating any design documentation.

The inspector was concerned that

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-10-installation of the spacer and replacement of the bonnet studs without updating any design documentation was representative of inadequate design control. The licensee informed the NRC that when a maintenance planner reviewed the maintenance history of a component as part of work package preparation, the maintenance history would reveal that subcomponents had been installed or replaced such as the spacer and studs for Valve 1PSIA-V404. The licensee, upon further evaluation, initiated CRDR 9-8-0893 to address this issue.

The inspectors reviewed CRDR 9-8-0893 and noted that it identified that the spacer was later removed from Valve 1PSIA-V404. Condition Report/Disposition Request 9-8-0893 also requested design services, in accordance with existing site procedure instructions, to document the bolting change in the drawing system via issuance of an engineering design change {EDC). Design services issued EDC 98-00920 to document the bolting change on the applicable drawing. The inspectors reviewed the revised drawing (APS Document 13-N001-1104-30) and verified that as of April 15, 1999, the bolting change for Valve 1PSIA-V404 was documented in a note added to the drawing.

The inspectors noted that the failure to maintain drawings to reflect actual plant configuration was a violation of Criterion III of Appendix B to 10 CFR Part 50 (50-528/-529/-530/9908-01).

Criterion III requires, in part, that measures shall be established to assure that plant configuration is correctly translated into drawings. This Severity Level IVviolation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. The inspectors reviewed the licensee's corrective actions and found them to be appropriate and complete.

0 en Violation 50-528/-529/-530/9814-06:

five examples of a failure to meet Technical Specification 3.5.2 or 3.0.3.

This violation identified five examples where action was not taken to either restore the emergency core cooling system subsystems to an operable status or place the unit in the applicable mode in accordance with Technical Specification 3.5.2 or 3.0.3.

Each subsystem included one operable high pressure safety injection pump, one operable Iow pressure safety injection pump, and an independent operable flow path. These examples where initiallydiscussed in NRC Inspection Report 50-528;-529;-530/98-14, issued August 28, 1998. Condition Report/Disposition Requests 1-8-0317 and 2-8-0128 documented some of the examples discussed in the violation.

On December 21, 1998, a Notice of Violation and Proposed Imposition of Civil Penalty was issued based on apparent violations discussed at a predecisional enforcement conference held in the NRC Region IV office on September 14, 1998 {reference NRC Inspection Report 50-528;-529;-530/98-14).

Violation 50-528;-529;-530/9814-06 was opened in NRC Inspection Report 50-528;-529;-530/98-10 issued March 18, 1999, for administrative purposes, to provide a tracking number for the violatio The inspectors found that the licensee was still reviewing completed corrective actions implemented for this violation. While the licensee's staff noted that they were confident that the immediate and long-term corrective actions taken to correct this violation were sufficient to restore compliance with the regulations and prevent recurrence of the identified condition, all completed actions were not available for review by the inspectors during this inspection.

0 en Violation 50-528/-529/-530/9814-07:

two examples of high pressure safety injection pump discharge check valve conditions adverse to quality.

This violation identified two examples where prompt actions were not taken to identify, correct, and preclude recurrence of significant conditions adverse to quality.

Specifically, a cocked-open check valve caused an unexpected loss of inventory in Unit 2 safety injection tank on October 10 and 28, 1997, and final corrective actions were not completed until May 16, 1998. Additionally, Check Valve 1PSIAV405 was improperly assembled on April 9, 1998, and this condition was not identified and corrected until May 15, 1998. These examples where initiallydiscussed in NRC Inspection Report 50-528;-529;-530/98-14, issued August 28, 1998. Condition Report/Disposition Request 2-7-0420 was issued to document some of the information discussed in the violation.

On December 21, 1998, a Notice of Violation and Propos'ed Imposition of Civil Penalty was issued based on apparent violations discussed at a predecisional enforcement conference held in the NRC Region IVoffice on September 14, 1998 (reference NRC Inspection Report 50-528;-529;-530/98-14).

Violation 50-528;-529;-530/9814-07 w'as opened in NRC Inspection Report 50-528;-529;-530/98-10 issued March 18, 1999, for administrative purposes, to provide a tracking number for the violation.

The inspectors found that the licensee was still reviewing completed corrective actions implemented for this violation. While the licensee's staff noted that they were confident that the immediate and long-term corrective actions taken to correct this violation were sufficient to restore compliance with the regulations and prevent recurrence of the identified condition, all completed actions were not available for review by the inspectors during this inspection.

0 en Violation 50-528/-529/-530/9814-08:

two examples of inadequate high pressure safety injection pump discharge check valve procedures.

This violation identified two examples where Maintenance Procedure 31MT-9ZZ17,

"Disassembly and Reassembly of Borg-Warner Check Valves," was not appropriate to the circumstances, in that the procedure did not ensure correct vertical alignment of check valve disassemblies, and Surveillance Test Procedure 73ST-9XI33, "HPSI Pump and Check Valve Full Flow Test," failed to include appropriate quantitative or qualitative acceptance criteria. These examples where initiallydiscussed in NRC Inspection Report 50-528;-529;-530/98-14, issued August 28, 1998. Condition Report/Disposition Request 1-8-0238 was issued to document some of the information discussed in the violatio On December 21, 1998, a Notice of Violation and Proposed Imposition of Civil Penalty was issued based on apparent violations discussed at a predecisional enforcement conference held in the NRC Region IVoffice on September 14, 1998 (reference NRC Inspection Report 50-528;-529;-530/98-14).

Violation 50-528;-529;-530/9814-08 was opened in NRC Inspection Report 50-528;-529;-530/98-10 issued March 18, 1999, for administrative purposes, to provide a tracking number for the violation.

The inspectors found that the licensee was still reviewing corrective actions implemented for this violation. While the licensee's staff noted that they were confident that the immediate and long-term corrective actions taken to correct this violation were sufficient to restore compliance with the regulations and prevent recurrence of the identified condition, all completed actions were not available for review by the inspectors during this inspection period.

Closed Licensee Event Re ort50-529/98-004-00:

missedTechnical Specification 4.0.5 surveillance required for ASME safety injection pressure safety valve.

This licensee event report identified on June 30, 1998, that engineering personnel discovered that Unit 2 Shutdown Cooling Train A Pressure Safety Valve 2JSIAPSV469 had not received the periodic (every 5 years) set pressure test required by the ASME code for Class 1 pressure safety valves, and as specified by Technical Specification Surveillance Requirement 4.0.5. Unit 2 was operating at approximately 100 percent power. This omission was discovered during a transportability review of a similar condition in Unit 3. The periodic test for this valve was required to be completed by February 18, 1998. On July 1, 1998, pressure testing of this valve was satisfa'ctorily completed.

The cause of the event was attributed to personnel error. The licensee's pump and valve testing program procedure correctly identified this valve as a Class 1 valve, but incorrectly specified the test frequency as 10 years.

The set pressure testing schedules for the remaining pressure safety valves were reviewed for all three units and the licensee concluded that all other testing was performed at the required frequencies.

The licensee initiated Condition Report/Disposition Request 2-8-0198 to document the deficiency for Shutdown Cooling Train A.

The inspectors reviewed Condition Report/Disposition Request 2-8-0198 and noted that the proposed corrective action requested:

(1) that lnservice Testing Program Procedure 73DP-9XI01, "Pump and Valve Inservice Testing Program-Component Tables," be revised to update the required ASME code testing frequencies for Class 1 pressure safety valves, and (2) that other pressure safety valve test scheduling be reviewed. The inspectors reviewed applicable pages of Revision 8 to Procedure 73DP-9XI01, and verified that the 5-year test frequency had been identified for Class 1 pressure safety valves.

Technical Specification 5.4.1 requires, in part, that written procedures shall be established and implemented for the performance of surveillance and test of safety-

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-13-related equipment.

Criterion XI of Appendix B to 10 CFR Part 50 requires, in part, that testing shall be performed using adequate test procedures.

The failure to establish an adequate test procedure by not incorporating ASME code testing frequencies was identified as a violation of Technical Specification 5.4.1 (50-529/9908-02).

This Severity Level IVviolation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. The corrective actions have been completed.

V. Mana ement Meetin s X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 9, 1999. The licensee representatives acknowledged the findings presented.

On May 11, 1999, a telephonic exit was held to inform the licensee of NRC's enforcement decisions concerning the two noncited violations.

The inspectors asked the licensee representatives whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identifie ~

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ATTACHMENT SUPPLEMENTAL INFORMATION Licensee PARTIALLIST OF PERSONS CONTACTED K. Brewer, Senior Consultant, Regulatory Affairs R. Hazlewood, Engineer, Regulatory Affairs W. Ide, Vice President, Nuclear Engineering M. Melton, Section Leader, Inservice Inspection G. Sowers, Section Leader, Probabilistic Risk Assessment Group R. Younger, Department Leader, Nuclear Assurance Engineering NRC D. Carter, Resident inspector INSPECTION PROCEDURES USED 73753 92902 92903 lnservice inspection Followup - Maintenance Followup - Engineering ITEMS OPENED, CLOSED AND DISCUSSED

~Oen 50-528/-529/-530/9908-01 NCV Failure to maintain adequate drawing design control (Section E.8.1).

50-529/9908-02 Closed 50-528/-529/-530/9908-01 50-529/9908-02 50-529/9722-01 NCV Technical Specification 5.4.1 violation for inadequate test procedure (Section E8.5).

NCV Failure to maintain adequate drawing design control (Section E.8.1).

NCV Technical Specification 5A.1 violation for inadequate test procedure (Section E8.5).

VIO Failure to translate requirements from a design change package to installation work order (Section M8.1).

-2-50-528/-529/-530/9814-04 URI 50-529/98-0004-00 LER Discussed and Remains 0 en 50-528/-529/-530/9814-06 VIO 50-528/-529/-530/9814-07 VIO 50-528/-529/-530/9814-08 VIO Check valve design control issues {Section E8.1).

Missed Technical Specification 4.0.5 surveillance required for ASME Safety Injection Pressure Safety Valve (Section E8.5).

Five examples of a failure to meet Technical Specification 3.5.2 or 3.0.3.

Two examples of high pressure safety injection pump discharge check valve conditions adverse to quality.

Two examples of inadequate high pressure safety injection pump discharge check valve procedures.

DOCUMENTS REVIEWED Inservice Ins ection Pro ramDocuments Program No. 2INT-ISI-2, "Inservice Inspection Program Summary Manual, Palo Verde Nuclear Generating Station, Unit 2," Revision 0 Inservice Inspection Program Bases, Revision 0 U2R8 Inservice Inspection Outage Plan Procedures 73DP-9EE02, "lnservice Inspection Examination Activities," Revision 3 73TI-9ZZ05, "Magnetic Particle Examination," Revision 8 73TI-9ZZ07, "Liquid Penetrant Examination," Revision 7 73TI-9ZZ09, "Ultrasonic Examination of Pipe Welds," Revision 10 Self-Assessment Inservice Inspection Program Self Assessment, September 24, 1998 Condition Re ort/Dis osition Re uest CRDR 2-7-0230 2-8-0198 3-8-0101 9-8-0893 9-7-1322

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" Work Orders 766149 766183 698671 728980 796335 786373 766151 802630 842362 858564 802616 802617 802627 800207 Li uid Penetrant Examination Re orts 99-2263 99-2264 Ultrasonic Examination Re orts 99-2265 99-2266 99-2269 Ultrasonic Calibration Re orts 99-JLO-2018 99-JLO-2019