IR 05000530/2007006

IR 05000530-07-006; 1/1/07 - 1/31/08; Palo Verde Nuclear Generating Station, Unit 3; Integrated Resident and Regional Report of Steam Generator Replacement Activities

ML080700244
Person / Time
Site:	Palo Verde
Issue date:	03/10/2008
From:	Troy Pruett NRC/RGN-IV/DRP/RPB-D
To:	Edington R Arizona Public Service Co
References
IR-07-006
Download: ML080700244 (23)

Text

UNITED STATES NU CLE AR RE GU LATOR Y C O M M I S S I O N rch 10, 2008

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000530/2007006

Dear Mr. Edington:

On January 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Palo Verde Nuclear Generating Station, Unit 3 facility. The enclosed report documents the inspection findings, which were discussed on February 5, 2008, with Mr. Cortopassi and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspection covers steam generator replacement activities at the Palo Verde Nuclear Generating Station. Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Troy W. Pruett, Chief Project Branch D Division of Reactor Projects Docket: 50-530 License: NPF-74

Arizona Public Service Company -2-Enclosure:

NRC Inspection Report 05000530/2007006 w/Attachment: Supplemental Information Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Douglas K. Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Scott Bauer, Director Regulatory Affairs Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Dwight C. Mims Vice President, Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901

Arizona Public Service Company -3-Eric J. Tharp Director of Generation Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255 Los Angeles, CA 90051-5700 John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Geoffrey M. Cook Southern California Edison Company 5000 Pacific Coast Hwy, Bldg. D21 San Clemente, CA 92672 Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Karen O' Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix, AZ 85003 Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Chief, Radiological Emergency Preparedness Section National Preparedness Directorate Technological Hazards Division Department of Homeland Security 1111 Broadway, Suite 1200 Oakland, CA 94607-4052

Arizona Public Service Company -4-Electronic distribution by RIV:

Regional Administrator (EEC)

DRP Director (DDC)

DRS Director (RJC1)

DRS Deputy Director (ACC)

Senior Resident Inspector (GXW2)

Branch Chief, DRP/D (TWP)

Senior Project Engineer, DRP/D (GEW)

Team Leader, DRP/TSS (CJP)

RITS Coordinator (MSH3)

Only inspection reports to the following:

DRS STA (DAP)

V. Dricks, PAO (VLD)

D. Pelton, OEDO RIV Coordinator (DLP)

ROPreports PV Site Secretary (PRC)

SUNSI Review Completed: TWP ADAMS: Yes No Initials: TWP Publicly Available Non-Publicly Available Sensitive Non-Sensitive R:\_REACTORS\_PV\2007\PV2007-006RP-JFM.doc RIV:RI:DRP/D SRI:DRP/D C:DRS/EB2 C:DRS/PSB C:DRS/OB JFMelfi;vlh GGWarnick LJSmith MPShannon RELantz T-TWP T-TWP NOKeefe for /RA/ /RA/

3/7/08 3/7/08 3/6/08 3/6/08 3/6/08 C:DRS/EB1 C:DRP/D RLBywater TWPruett

/RA/ /RA/

3/6/08 3/10/08 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-530 License: NPF-74 Report: 05000530/2007006 Licensee: Arizona Public Service Company Facility: Palo Verde Nuclear Generating Station, Unit 3 Location: 5951 S. Wintersburg Road Tonopah, Arizona Dates: January 1, 2007 through January 31, 2008 Inspectors: J. Bashore, Resident Inspector L. Carson, Senior Health Physics Inspector M. Catts, Resident Inspector B. Henderson, Reactor Inspector, Engineering Branch 1 S. Makor, Reactor Inspector, Engineering Branch 1 J. Melfi, Resident Inspector L. Ricketson, P.E., Senior Health Physics Inspector G. Warnick, Senior Resident Inspector Approved By: Troy W. Pruett, Chief, Project Branch D Division of Reactor Projects-1- Attachment

SUMMARY OF FINDINGS

IR 05000530/2007006; 1/1/07 - 1/31/08; Palo Verde Nuclear Generating Station, Unit 3;

Integrated Resident and Regional Report of Steam Generator Replacement Activities.

This report covered a 13-month period of special inspection by resident and regional inspectors.

No findings of significance were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

Attachment

REPORT DETAILS

Summary of Plant Status

On September 29, 2007, Unit 3 shutdown to begin Refueling Outage 3R13. The unit returned to essentially full power on January 24, 2008, and remained there for the duration of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R08 Inservice Inspection Activities (71111.08 and 50001)

Performance of Nondestructive Examination Activities on Steam Generator Tube Inspections This inspection focused on the Unit 3 steam generator replacement activities (e.g., nondestructive examinations (NDE) and welding activities), focusing on the following areas:

• Special procedures for welding and NDE, as applicable

• Training and qualifications for personnel performing welding and NDE

• NDE including radiography results and work packages for selected welds

a. Inspection Scope

For each of the welding and NDE activities observed and reviewed, the inspectors verified that the specific welding procedure specifications and NDE procedures met the applicable American Society of Mechanical Engineers (ASME) Code requirements.

The inspectors verified, by review, that the welding procedure specifications and the welders had been properly qualified in accordance with ASME Code,Section IX, requirements. The inspectors also verified, through observation and record review, that essential variables for the gas tungsten arc welding process (machine and manual) and the shielded metal arc welding process had been identified, recorded in the procedure qualification record, and formed the bases for qualification of the welding procedure specifications.

During review of each NDE, the inspectors verified that appropriate NDE procedures were used; that examinations and conditions were as specified in the procedure; and that test instrumentation or equipment were properly calibrated and within the allowable calibration period. The inspectors also verified the NDE certifications of the personnel who performed the observed NDE examinations.

The documents reviewed and the inspection results for the steam generator and other welds are documented in NRC Inspection Report 05000528; 05000529; 05000530/2005005, Section 1R08.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

Risk Assessment and Management of Risk The inspectors reviewed the below listed assessment activities to verify:

(1) performance of risk assessments when required by 10 CFR 50.65(a)(4) and licensee procedures prior to changes in plant configuration for maintenance activities and plant operations;

(2) the accuracy, adequacy, and completeness of the information considered in the risk assessment;

(3) that the licensee recognizes, and/or enters as applicable, the appropriate licensee-established risk category according to the risk assessment results and licensee procedures; and

(4) the licensee identified and corrected problems related to maintenance risk assessments.

• September 10, 2007, evaluated controls and plans to minimize any adverse impact on Units 2 and 3 and common systems Documents reviewed by the inspectors are listed in the attachment.

The inspectors completed one sample.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications

a. Inspection Scope

The steam generator replacement modification has been previously reviewed for Units1 and 2 in NRC Integrated Inspection Reports 05000528/2005002 and 05000529/2003009 respectively. There were no significant changes to the design for the replacement of PVNGS Unit 3 steam generators.

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing

a. Inspection Scope

The inspectors selected the three below listed postmaintenance test activities of risk significant systems or components for the steam generator replacement project (SGRP).

For each item, the inspectors:

(1) reviewed the applicable licensing basis and/or design-basis documents to determine the safety functions;

(2) evaluated the safety functions that may have been affected by the maintenance activity; and

(3) reviewed the test procedure to ensure it adequately tested the safety function that may have been affected. The inspectors either witnessed or reviewed test data to verify that acceptance criteria were met, plant impacts were evaluated, test equipment was calibrated, procedures were followed, jumpers were properly controlled, the test data results were complete and accurate, the test equipment was removed, the system was properly re-aligned, and deficiencies during testing were documented.

• January 4-5, 2008, Unit 3, hot gap measurements as noted in design implementing work order retest per Procedure 40TI-9ZZ05, "SGRP Steady State Vibration Test," Revision 2A

• January 9, 2008, Unit 3, retest per Procedure 73TI-9RC03, "Reactor Coolant System Heat Loss Measurement Following Steam Generator Replacement,"

Revision 4

• January 11-18, 2008, Unit 3, Procedure 40TI-9ZZ01, "SGRP Control Systems Checkout Test," Revision 4 Documents reviewed by the inspectors are included in the attachment.

The inspectors completed three samples.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

The inspectors reviewed the following risk significant refueling items or outage activities to verify defense in depth commensurate with the outage risk control plan, compliance with the Technical Specifications (TS), and adherence to commitments in response to Generic Letter 88-17, Loss of Decay Heat Removal:

(1) the risk control plan; (2)tagging/clearance activities;

(3) reactor coolant system instrumentation;

(4) electrical power;

(5) decay heat removal;

(6) spent fuel pool cooling;

(7) inventory control; (8)reactivity control;

(9) containment closure;

(10) refueling activities;

(11) heatup and cooldown activities;

(12) restart activities; and

(13) licensee identification and implementation of appropriate corrective actions associated with refueling and outage activities. The inspectors containment inspections included observations of the

containment sump for damage and debris; and supports, braces, and snubbers for evidence of excessive stress, water hammer, or aging.

Coverage of the full scope of Inspection Procedure 71111.20 is documented in NRC Inspection Report 05000528; 05000529; 05000530/2007005.

Documents reviewed by the inspectors are included in the attachment.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), procedure requirements, and TSs to ensure that the below listed surveillance activity demonstrated that the structures, systems or components (SSCs) tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the following significant surveillance test attributes were adequate: (1)preconditioning;

(2) evaluation of testing impact on the plant;

(3) acceptance criteria; (4)test equipment;

(5) procedures;

(6) jumper/lifted lead controls;

(7) test data;

(8) testing frequency and method to demonstrate TS operability;

(9) test equipment removal; (10)restoration of plant systems;

(11) fulfillment of ASME Code requirements;

(12) updating of performance indicator data;

(13) engineering evaluations, root causes, and bases for returning tested SSCs not meeting the test acceptance criteria were correct; (14)reference setting data; and

(15) annunciators and alarms setpoints. The inspectors also verified that the licensee identified and implemented any needed corrective actions associated with the surveillance testing.

• December 4, 2007, Unit 3, Procedure 40TI-9ZZ02, "Steam Generator Spillover Test," Revision 4

• January 20, 2008, Unit 3, Procedure 40TI-9ZZ03, "SGRP Unit Load Transient Test," Revision 3

• January 19-21, 2008, Unit 3, Procedure 72PA-9ZZ08, "Reload Power Ascension Testing Following Steam Generator Replacement," Revision 10 Documents reviewed by the inspectors are included in the attachment.

The inspectors completed three samples.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

The inspectors reviewed the UFSAR, plant drawings, procedure requirements, and TSs to ensure that the two below listed temporary modifications were properly implemented.

The inspectors:

(1) verified that the modifications did not have an affect on system operability/availability;

(2) verified that the installation was consistent with modification documents;

(3) ensured that the post-installation test results were satisfactory and that the impact of the temporary modifications on permanently installed SSCs were supported by the test;

(4) verified that the modifications were identified on control room drawings and that appropriate identification tags were placed on the affected drawings; and

(5) verified that appropriate safety evaluations were completed. The inspectors verified that the licensee identified and implemented any needed corrective actions associated with temporary modifications.

• October 5, 2007, Unit 3, Temporary Modification 2743049, "Refueling Water Level Indication System Reroute"

• October 17, 2007, Unit 3, Design Modification 2666103, "Temporary Power to Temporary Lift Device" Documents reviewed by the inspectors are included in the attachment.

The inspectors completed two samples.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety [OS]

2OS1 Access Control To Radiologically Significant Areas (71121.01)

a. Inspection Scope

This area was inspected to assess the licensees performance in implementing physical and administrative controls for airborne radioactivity areas, radiation areas, high radiation areas, and worker adherence to these controls. The inspectors used the requirements in 10 CFR Part 20, the TSs, and the licensees procedures required by TS as criteria for determining compliance. During the inspection, the inspectors interviewed

the radiation protection manager, radiation protection supervisors, and radiation workers. The inspectors performed independent radiation dose rate measurements and reviewed the following items:

• Performance indicator events and associated documentation packages reported by the licensee in the Occupational Radiation Safety Cornerstone

• Controls (surveys, posting, and barricades) of radiation, high radiation, or airborne radioactivity areas

• Radiation exposure permits, procedures, engineering controls, and air sampler locations

• Conformity of electronic personal dosimeter alarm set points with survey indications and plant policy; workers knowledge of required actions when their electronic personnel dosimeter noticeably malfunctions or alarms

• Barrier integrity and performance of engineering controls in airborne radioactivity areas

• Radiation work permit briefings and worker instructions

• Adequacy of radiological controls, such as required surveys, radiation protection job coverage, and contamination control during job performance

• Dosimetry placement in high radiation work areas with significant dose rate gradients

• Posting and locking of entrances to all accessible high dose rate - high radiation areas and very high radiation areas

• Radiation worker and radiation protection technician performance with respect to radiation protection work requirements Documents reviewed by the inspectors are listed in the attachment.

The coverage of the full scope of Inspection Procedure 71121.01 is documented in NRC Integrated Inspection Report 05000528; 05000529; 05000530/2007005.

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02)

a. Inspection Scope

The inspectors assessed licensee performance with respect to maintaining individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20 and the licensees procedures required by TS as criteria for determining compliance. The inspectors interviewed licensee personnel and reviewed:

• ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements

• Intended versus actual work activity doses and the reasons for any inconsistencies

• Integration of ALARA requirements into work procedure and radiation exposure permit documents

• Shielding requests and dose/benefit analyses

• Dose rate reduction activities in work planning

• Use of engineering controls to achieve dose reductions and dose reduction benefits afforded by shielding

• Workers use of the low dose waiting areas Documents reviewed by the inspectors are listed in the attachment.

The coverage of the full scope of Inspection Procedure 71121.02 is documented in NRC Integrated Inspection Report 05000528; 05000529; 05000530/2007005.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Steam Generator Replacement Lessons Learned Review - Effectiveness of Corrective

Actions

a. Inspection Scope

The inspectors reviewed corrective action documents associated with the replacement of steam generators from Units 1 and 2. Additionally, the inspectors interviewed plant personnel (craft, supervisors, and managers), attended outage work control meetings, and observed a heavy lift inside the biological shield wall to determine if the corrective actions were incorporated into processes, procedures, and work practices for Unit 3 steam generator replacement activities. The inspectors selected the following seven Condition Report Disposition Requests (CRDRs) and performed a detailed assessment:

CRDRs 2577331, 2826313, 2846706, 2846716, 2847330, 2848062, and 2849202.

b. Findings

No findings of significance were identified.

.2 Steam Generator Replacement Outage Inspection

a. Inspection Scope

The inspectors reviewed the daily condition report summaries and nonconformance reports issued during the replacement project for risk-significant issues to evaluate if the licensee was properly implementing the corrective action program. The inspectors verified that the licensee identified, evaluated, corrected, and trended in accordance with the program requirements in place at the Palo Verde Nuclear Generating Station.

The inspectors also reviewed the licensees actions to identify and correct lessons learned from the Unit 1 steam generator replacement project.

b. Findings

No findings of significance were identified.

.3 Partial Removal of Gusset beyond Work Order Guidance

a. Inspection Scope

The inspectors performed a review of CRDRs 3076549 and 3076613, which documented weld removal on a main steam system pipe support in excess of the work

instructions. The inspectors review of the CRDRs concluded that enough weld material was left on the gusset welds to maintain the seismic qualification.

b. Findings

No findings of significance were identified.

4OA5 Steam Generator Replacement Activities

.1 Design and Planning Inspections

a. Inspection Scope

The inspectors used the guidance in Inspection Procedure 50001 to perform the following steam generator design and planning inspection activities.

Engineering and Technical Support Inspections to review engineering and technical support activities were performed prior to, and during, the steam generator replacement outage by resident and regional office-based specialist inspectors. The results of the inspection are documented in Sections 1R17 and 1R23.

Lifting and Rigging Inspections to review engineering design, modification, and analysis associated with steam generator lifting and rigging activities were performed by resident and regional inspectors.

Security Considerations and Adverse Impact to Other Units Inspectors checked for potential adverse impacts to Units 1 and 2 (the nonoutage units)caused by outage activities, equipment configurations, etc., in accordance with Inspection Procedure 50001. The inspectors made frequent observations of security practices to verify that the licensee provided appropriate support for affected vital and protected area barriers during outage activities.

Documents reviewed by the inspectors are listed in the attachment.

b. Findings

No findings of significance were identified.

.2 Steam Generator Removal and Replacement Inspections

a. Inspection Scope

The inspectors used the guidance in Inspection Procedure 50001 to perform the following steam generator removal and replacement inspection activities.

Welding and NDE Activities An inspection to review welding and NDE activities was performed during the steam generator replacement outage by regional office-based specialist inspectors. The results of the inspection are documented in Sections 1R08 and 1R23.

Lifting and Rigging Activities (50001 and 71111.23)

The inspectors observed and reviewed several activities throughout the outage associated with lifting and rigging. The inspectors observed and reviewed preparations, procedures, crane and rigging inspections, and lay-down areas associated with the following activities:

• Construction of the outside lift system

• Partial bio-wall and interference removal and replacement

• Temporary handling device construction and removal

• Reactor cavity decking construction and removal

• Old steam generator removal

• Onload of new steam generator

• Transport of old steam generator to storage facility Major Structural Modifications The inspectors observed the implementation and reviewed documentation related to several structural modifications. The inspectors observed and reviewed the removal and reinstallation of the following structural modifications to support removal and replacement of steam generators.

• Containment bio-wall removal as interference

• Structural supports for steam generator and all attached piping during all phases of removal and installation of the steam generator Containment Access and Integrity This was not applicable to PVNGS steam generator replacement. The cutting of the outer containment wall was not necessary.

Outage Operating Conditions The inspectors used Inspection Procedure 71111.20 to verify proper outage conditions.

Section 1R20 records the activities reviewed.

Radiation Protection Controls An inspection to review radiation protection controls was performed during the steam generator replacement outage by regional office-based specialist inspectors. The results of the inspection are documented in Section 2OS1.

Foreign Materials Control The inspectors performed frequent observations of the steam generator replacement activities to verify the licensee was implementing proper foreign materials controls. In particular, the inspectors observed controls related to reactor coolant system and secondary side openings.

Temporary Services The inspectors reviewed the work package and drawings, then observed the installation, use, and removal of temporary services in the containment building during the outage.

Instructions for the use and controls for construction power, acetylene, oxygen, and argon were reviewed; and the actual installation of each system was compared to the approved system sketches.

Storage of Old Steam Generators The inspectors observed the transport and storage of the old steam generator to the onsite storage facility. The radiological safety plans were reviewed.

Documents reviewed by the inspectors are listed in the attachment.

b. Findings

No findings of significance were identified.

.3 Postinstallation Verification and Testing Inspection

The inspectors used the guidance in Inspection Procedure 50001 to perform the following post installation verification and testing inspection activities.

Containment Testing This was not applicable to Palo Verde Nuclear Generating Station steam generator replacement. The cutting of the outer containment wall was not necessary.

Licensees Postinstallation Inspections and Verifications The inspectors observed the implementation and reviewed several post installation surveillance and tests conducted under the licensees return to service program.

Specific items reviewed are documented in Sections 1R19 and 1R22.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings, Including Exit

Exit Meeting Summary

On November 30, 2007, the inspectors presented the occupational radiation safety inspection results to Mr. R. Bement, Vice President, Nuclear Operations, and other members of his staff who acknowledged the findings.

On February 5, 2008, the inspectors presented the results of the inspection to Mr. L.

Cortopassi, Plant Manager, and other members of his staff who acknowledged the findings presented.

The licensee confirmed that the inspectors retained no proprietary information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Andrews, Director, Performance Improvement

S. Bauer, Department Leader, Regulatory Affairs

R. Bement, Vice President, Operations

P. Borchert, Director, Operations

R. Buzzard, Section Leader, Regulatory Affairs

D. Carnes, Assistant Plant Manager

R. Cavalieri, Director, Outages

L. Cortopassi, Plant Manager

D. Coxon, Unit 3 Department Leader, Operations

J. Gaffney, Director, Radiation Protection

T. Gray, Division Leader, Radiation Protection

M. Grigsby, Unit Department Leader, Operations

D. Hautala, Regulatory Affairs

J. Hesser, Vice President, Engineering

M. Karbasian, Director, Engineering

H. Ridenour, Director, Maintenance

D. Straka, Regulatory Affairs

J. Ward, Director, Training

T. Weber, Department Leader, Regulatory Affairs

Other

R. Henry, Site Rep, SRP

E. Shouse, Site Rep, El Paso Electric

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None