IR 05000528/1999012

Insp Repts 50-528/99-12,50-529/99-12 & 50-530/99-12 on 990502-0612.Two Violations Occurred & Being Treated as Noncited Violations.Major Areas Inspected:Operations,Maint, Engineering & Plant Support

ML20196K042
Person / Time
Site:	Palo Verde
Issue date:	06/30/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML17300B282	List: IR 05000528/1999012
References
50-528-99-12, 50-529-99-12, 50-530-99-12, NUDOCS 9907080126
Download: ML20196K042 (13)

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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket Nos.: 50-528 50-529 50-530 License Nos.: NPF-41 NPF-51 NPF-74 Report No.: 50-528/99-12 50-529/99-12 50-530/99-12 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Units 1,2, and 3 Location: 5801 S. Wintersburg Road Tonopah, Arizona Dates: May 2 through June 12,1999 Inspectors: J. H. Moorman, Ill, Senior Resident inspector D. R. Carter, Resident inspector N. L. Salgado, Resident inspector Approved By: P. Harrell, Chief, Project Branch D l

i Attachment: Supplemental Information l l

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9907080126 990630 '

gDR ADOCK 05000528 PDR

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EXECUTIVE SUMMARY Palo Verde Nuclear Generating Station, Units 1,2, and 3 NRC Inspection Report No. 50-528/99-12; 50-529/99-12; 50-530/99-12 Operations

Inattention to details was demonstrated by the operations shift manager when he failed to evaluate a Technical Specification limiting condition for operation prior to making a mode change (Section O1.1 ).

A violation of Technical Specification 3.3.1 was identified after shiftly channel checks were not performed over a 2-day period when core protection calculator Channel B was inoperable. This event was reported in Licensee Event Report 50-529/98-002-00. This Severity Level IV violation is being treated as a noncited violation consistent with Appendix C o' the NRC Enforcement Policy. This issue is in the licensee's corrective action program as Condition Report / Disposition Request 2-8-0080 (SectionO8.1).

Maintenance

Knowledgeable technicians used approved procedures to perform routine maintenance activities in a safety-conscious manner. Good work and foreign material control practices were observed (Section M1.1). J

• Knowledgeable technicians used approved procedures to conduct surveillance activities in a safety-conscious manner (Section M1.2).

Observable material condition of the three units was good (Section M2.1).

The failure to properly implement procedures for control of lubricants used in the facility is a violation of Technical Specification 5.4.1. The concerns with the control of lubricants included adding the incorrect oil and grease to safety-related components and not ensuring that the requirements of the program were applied to all appropriate personnel within the maintenance department. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. These issues are in the licensee's corrective action program as Condition Report / Disposition Request 9-9-0443 (Section M4.1).

Plant Suocort

• The radiological protecti e, program was effectively implemented ire those areas reviewed (Section R1.1).

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Reoort Details

) Summarv of Plant Status Units 1 and 3 operated at essentially 100 percent power for the duration of this inspection perio Unit 2 began this inspection period at 20 percent power in the process of starting up ,after the eighth refueling outage. The unit reached 100 percent power on May 5,1999, and operated there for the duration of this inspection perio l. Operations 01 Conduct of Operations 01.1 Mode Chanae Made Without Evaluatina the Effect of Enterina Limitina Condition for Ooeration (LCO) 3.7.3 (Unit 2) Insoection Scope (71707)

During this inspection period, the inspectors reviewed the circumstances of a transition from Modes 2 to 1, when the unit entered Technical Specification (TS) 3.7.3, Condition A, for economizer feedwater isolation Valve 2J-SGB-UV-137 being inoperable. The inspectors reviewed applicable procedures and logs and held

. discussions with operations personne Observations and Findinas The inspectors were prompted to this issue by reading a unit log entry made on May 2, 1999, at 6:30 a.m. that stated, in part, that an inappropriate mode change had occurred while entering Mode 1 because the unit was in LCO 3.7.3, Condition A, for .

Valve 2J-SGB-UV-137 being inoperable due to low accumulator pressure. The licensee initiated Condition Report /Dispositan Request (CRDR) 2-9-0166 to evaluate this issu The following sequence of events occurred on May 1-2:

11:54 Economizer feedwater isolation Valve 2J-SGB-UV-137 low accumulator pressure annunciator alarmed. Operations personnel entered TS LCO 3.7.3, Condition :03 Unit 2 entered Mode :20 Valve 2J SGB-UV-137 accumulator pressure was restored, and the annunciator alarm cleared. The valve was declared operable, and Operations Personnel exited LCO 3.7.3, Condition The CRDR evaluation concluded that the unit log entry was inaccurate because the shift manager failed to evaluate LCO 3.7.3, Condition A, and apply LCO 3. (

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-2-The inspector independently reviewed the_TS and determined that the exclusion clause of LCO 3.0.4 was applicable in this case; therefore, the mode change was acceptabl However, the inspector assessed that the performance of a mode change without first evaluating the requirements for entry into LCO 3.7.3 demonstrated inattention to details by the shift manage Conclusions Inattention to details was demonstrated by the operations shift manager when he failed to evaluate a TS LCO prior to making a mode chang Miscellaneous Operations issues (92901)

O8.1 (Closed) Licensee Event Report (LER) 50-529/98-002-00: TS Violation Due to Core Protection Calculator (CPC) B Not Being Channel Checke On February 28,1998, at 8 a.m., Unit 2 control room personnel identified that the data link between CPC B and the core monitoring computer had failed. Control room operators determined that the failure occurred on February 26, at 12:05 a.m. and that the required shiftly channel check surveillance had not been performed for four shift The licensee declared CPC B inoperable and entered LCO 3.3.1, Action 2. At 8:38 a.m., the licensee declared CPC B operable and exited the action statement after successful completion of the surveillance requiremen The failure to perform the required channel check surveillance or place ti. .hannel in a tripped or bypassed condition within one hour is a violation of TS 3.3.1. This Severity )

Lovel IV violation is being treated as a noncited violation, consistent with Appendix C of l the NRC Enforcement Policy. This violation is in the licensee's corrective action i I

program as CRDR 2-8-0080 (50-529/9912-01).

Conclusions A violation of TS 3.3.1 was identified after shiftly channel checks were not performed over a 2-day period when CPC Channel B was inoperable. This event was reported in LER 50-529/98-002-00. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This issue is in the licensee's corrective action program as CRDR 2-8-008 r 1

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-3-11. Maintenance M1 Conduct of Maintenance M1.1 General Comments on Maintenance Activities (Units 1 and 2) Inspection Scope (62707)

The inspectors observed all or portions of the fe!!owing activities performed per the listed work document:

885170 " Troubleshoot and Rework / Replace Components on Unit 1 Reactor Protection System Breaker B which inadvertently Opened Following Performance of Procedure 36ST-9SB13" (Unit 1)

882857 " Replace Oil Pressure Safety Valve 2J-CHN-PSV-0054 With New Valve From APN 45000566"(Unit 2) Observations and Findinas The inspecto's r found the work performed under these activities to be properly performed. All work observed was performed with the work package present and in active use. Work and foreign material exclusion practices observed were goo ,

Technicians were experienced and knowledgeable of their assigned task Conclusions Knowledgeable technicians used approved procedures to perform routine maintenance j activities in a safety-conscious manner. Good work and foreign material control I practices were observe l M1.2 General Comments on Surveillance Activities (Units 1 and 2) Inspection Scope (61726)

The inspectors observed all or portions of the following activities performed per the listed surveillance procedures:

32MT-9ZZ56 " Motor Operator Testing Using Movats 3500 System," Revision 20 (Unit 1)

74ST-9PC01 " Spent Fuel Pool Boron Surveillance Test," Revision 5 (Unit 2)

The inspectors found these surveillances were performed acceptably and as specified by applicable procedures,

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g-4- Observations and Findinas The inspectors found that knowledgeable personnel performed these surveillances satisfactorily, as specified by applicable procedure Conclusions Knowledgeable technicians used approved procedures to conduct surveillance activities in a safety-conscious manne M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Material Condition Durina Plant Tours (Units 1. 2. and 3) Inspection Scope (62707)

During this inspection period, routine tours of all units were conducted to evaluate plant material conditio Observations and Findinas Observation of plant material condition during this inspection period identified no major observable material condition deficiencies. Minor deficiencies brought to the attention of the licensee were documented with work request Conclusions Observable material condition of the three units was goo M4 Maintenance Staff Knowledge and Performance M4.1 Incorrect Lubricants Added to Safetv-Related Eauioment (Units 1. 2. and 3) Insoection Scope (62707)

On April 13,1999, the licensee identified that oil of improper viscosity had been added to several safety-related and nonsafety-related motor-operated valve actuators. In addition, incorrect grease had been added to both trains of the Unit 1 emergency diesel generator (EDG) building essential exhaust fan motors. The inspectors interviewed

- personnel and reviewed records related to these event Observations and Findinas The licensee initiated CRDR 2-9-0102 to document that a sample of oil from the containment hydrogen recombiner suction Valve 2HPAUV0003 actuator tested at a viscosity of approximately 102. The viscosity of the oil was outside the expected range of 135 to 165 for the required Omala 150 oil. The licensee's investigation revealed that

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5-the wrong viscosity oil, Omala 68, may have been inadvertently added to the valve operator. Omala 150 and 68 oils have the same lubricating properties, but have different viscosities. The licensee performed a transportability review that identified 12 additional valve operators in Units 2 and 3 with similar low viscosity values. Two of the valves were safety-related equipmen The licensee quarantined and analyzed samples from all primary and secondary oil containers containing Omala 150 and 68 oils. Secondary containers are containers used to hold small quantities of lubricants for field use. Sample results indicated that oil i in one secondary container was similar to the oil found in the affected valve actuator !

The licensee determined that, although the secondary container was properly labeled,

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the label was smudged and difficult to read. The licensee concluded that a technician must have inadvertently added Omala 68 oil to the secondary container containing Omala 150 oil. This mixture was then used to add oil to the affected valves. The mixing of two different oils or the same type oil with different viscosities into a secondary container is an example of inattention to detail CRDR 2-9-0102 corrective actions resulted in work requests to remove and replace the i incorrect oil in all effected valve actuators. The inspectors reviewed the !icensee's i operability assessment of the valve actuators containing the mixed oils. It concluded that the lighter viscosity oil did not affect the operability of the valves. The inspectors did not identify any problems during review of the assessmen l Procedure 73DP-9ZZ05," Lubricant Addition," Revision 8, provided direction to personnel to preclude introduction of incorrect lubricants into plant equipment. The procedure stated, in part, that the station information management system (SIMS)

lubrication screen (WMN019) for each plant component that requires a lubricant will identify the required lubricant for that component. The inspectors determined that the SIMS lubrication screen, the preventive maintenance (PM) Task Sheet, and the last work order that directed valve services mechanics to change or add oil to Valve 2HPAUV0003 (Work Order 681097, dated March 1995) all referenced the proper Omala 150 type oi In another related problem, the licensee identified that the incorrect grease was added to the Unit 1 EDG building exhaust fan motors. The licensee initiated CRDR 1-9-0062 to document that Dolium R type grease had been added to the Chevron SRI-2 type grease, which existed in the Unit 1 EDG building essential exhaust fan motors I (1MHDAJ01and 1MHDBJ01). Dolium R grease was not the specified quality-controlled grease referenced by the SIMS lubrication scree The licensee reviewed PM task sheets for the EDG building essential exhaust fan motors for all three units and discovered that the PM Task Sheets for Units 1 and 3 had instructions to use Dolium R type grease. Unit 2 PM Task Sheets did not specify the type of grease to use. The inspectors verified that the SIMS lubrication screen identified Chevron SRI-2 as the correct type of grease for all essential exhaust f an motors. The technicians who last added grease to the essential exhaust fan motor referenced the PM Task Sheet which identified the incorrect Dolium R type greas T

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. The inspectors reviewed the engineering evaluation that provided a comparison of the critical parameters for both the Dolium R and Chevron SRI-2 greases. Based on the comparison of grease grado, dropping point, base oil viscosity, and thickener type, the two greases had been determined to be compatible when mixed. The licensee's evaluation and subsequent Operability Determination 223 noted that the use of Dolium R grease mixed with Chevron SRI-2 grease was acceptable. The licensee determined that the EDG building essential exhaust fans were capable of performing the intended support function for EDG operabilit Procedure 73DP-9ZZ05, step 3.1.1, stated, in part, that the type of lubricant to be used is determined prior to each addition by consulting the SIMS lubrication screen or the PM Task Sheet (as appropriate) for the identified equipment. The inspectors determined that this is a procedure weakness, implying that mechanics were allowed the latitude of ;

referencing either the SIMS lubrication screen .ol the PM Task Sheet to determine the proper lubricant, in addition, the inspectors noted that the scope of Procedure 73DP-9ZZ05 did not include valve services personnel. Valve services personnel added lubricants to valve actuators according to specific maintenance instructions and did not always reference the SIMS lubrication screen. Not having all work groups who add lubricants to plant equipment under the scope of Procedure 73DP-9ZZ05 was a programmatic concern. The licensee initiated CRDR 9-9-0443 to address these issue CRDR 9-9-0443 identified an additional instance where incorrect grease was used to lubricate all nine reactor coolant system charging pump motors and reduction gear couplings (three pumps per unit). The SIMS Iubrication screen indicated that Alvania EP LF-0 grease should be used for the charging pump couplings. Technicians who performed the lubrications in accordance with the 6-month PM Task Sheets referenced Maintenance instruction MCH00032 to determine lubrication requirement The PM Task Sheets erroneously indicated that A!vania EP LF-2 type grease should be used. The technicians did not use the SIMS lubrication screen to verify the correct lubricant prior to installing the grease as required by Procedure 73DP-9ZZ0 As discussed above, a number of problems were identified with the control of lubricants used in the facility. These problems involved weak procedures, inattention to details by maintenance personnel, and not ensuring the requirements of the lubrication program included all applicable maintenance personne This failure to implement procedures for a maintenance activity that can affect the performance of safety-related equipment is a violation TS 5.4.1. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as CRDR 9-9-0443 (50-528,-529,-530/9912-02).

The licensee performed an evaluation and determined that the lubrication properties of the two greases were similar with only minor differences. The operability of the pumps was not in questio .

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-7-In addition, CRDR 9-9-0443 identified the following weaknesses with the lubrication program:

. PM Task Sheets did not specify the correct lubrican .

Worker knowledge / training of procedure requirements was lackin . Poor attention to details by maintenance personne . The process to control updates to maintenance instructions, PM Task Sheets, and the SIMS lubrication screen to reflect current lubrication specifications was ineffectiv .

There were weaknesses in the procedure in the handling of secondary containers, specific direction to the controlling engineering document, greasing requirements of plant equipment, and lack of process direction to change lubricant type The inspectors evaluated the corrective actions provided in the CRDR to address these issues and did not identify any issues, c. Conclusions The failure to properly implement procedures for control of lubricants used in the facility )

is a violation of TS 5.4.1. The concerns with the control of lubricants included adding the incorrect oil and grease to safety-related components and not ensuring that the requirements of the program were applied to all appropriate personnel within the maintenance department. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. These issues are l in the licensee's corrective action program as CRDR 9-9-044 )

JII. Enaineering i

Engineering Support of Facilities and Equipment

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E2 E2.1 Year 2000 (Y2K) Review (Units 1. 2. and 3)

The inspectors conducted a review of the licensee's Y2K remediation program using the l checklist contained in Temporary Instruction (TI) 2515/141. The checklist is based on

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the guidance in NEl/NUSMG 97-07," Nuclear Utility Year 2000 Readiness, and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning."

On May 18-20,1999, a review of the contingency planning portion of the checklist was conducted by the Office of Nuclear Reactor Regulation. This review was conducted as part of a national survey of contingency plans. The results of this review will be combined with the results of reviews from other commercial nuclear facilities and published at a later dat . l

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-8-The results of this review will be combined with the results of reviews of Y2K programs at other commercial nuclear facilities in a summary report to be issued by the NRC by July 31,199 IV. Plant Suncort R1 Radiological Protection arid Chemistry Controls R1.1 General Comments on Radioloaical Protection Controls (Units 1. 2. and 3)

a. Insoection Scope (71750)

The inspectors monitored radiological protection activities during routine site tour b. Observations and Findin.gg The inspectors observed radiatiori protection personnel, including supervisors, routinely touring the radiologically controlled areas. Licensee personnel working in radiologically controlled areas exhibited good radiation work practice Contaminated areas and high radiation areas were properly posted. Area surveys posted outside the room were current. The inspectors checked a sample of doors, required to be locked for the purpose of radiation protection, and all were in accordance with requirement c. Conclusions The radiological protection program was effectively implemented in those areas reviewe I V. Manaaement Meetinas  ;

X1 Exit Meeting Summary I

The inspectors presented the inspectior esults to members of licensee's staff at the l'

conclusion of the inspection on June 16,1099. The licensee acknowledged the findings presente .

The. inspectors informed the licensee that some material examined during the inspection was considered proprietar !

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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee D. Carnes, Unit 1 Department Leader, Operations R. Fullmer, Director, Nuclear Assurance W. Ide, Vice Presidet, Nuclear Engineering D, Kanitz, Engineer, rJuclear Regulatory Affairs J. Levine, Senior Vice President, Nuclear-D. Mauldin, Director, Maintenance D. Marks, Section Leader, Nuclear Regulatory Affairs J. Minnicks, Department Leader, Valve Services Maintenances S. Moyers, Senior Advisor, Maintenance Programs D. Smith, Director, Operations C. Stevens, information Technology Leader, Y2K Program T. Trieckel, Department Leader, Outage and Site Scheduling INSPECTION PROCEDURES USED 61726 Surveillance Observations 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities 92901 Plant Operations Followup Tl 2515/141 Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants

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-2-LTf,MS OPENED. CLOSED. AND DISCUSSED Ooened

'50-529/9912-01 NCV Failure to bypass CPC B, as required by TS 3.3.1 (Section l 08.1)

50-528.- 529,- NCV Violation of TS 5.4.1 with two examples of a failure to follow-530/9912-02 lubrication program procedures (Section M4.1) I Closed 50-529/98-002-00 LER CPC B was not channel checked as required by TS 3. (Section 08.1)

50-529/9912-01 NCV Failure to bypass CPC B, as required by TS 3.3.1 (Section O8.1)

50-528,- 529, NCV Violation of TS 5.4.1 with two examples of a failure to follow-530/9912-02 lubrication program procedures (Section M4.1)

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-3-LIST OF ACRONYMS USED

,- CFR Code of Federal Regulations CPC core protection calculator CRDR condition report / disposition request EDG emergency diesel generator LCO limiting condition for operation LER' licensee event report NCV noncited violation NRC Nuclear Regulatory Commission PDR Public Document Room PM preventive maintenance SIMS . station information management system Tl temporary instruction TS Technical Specification l Y2K Year 2000 l

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