IR 05000529/1986033

Insp Repts 50-529/86-33 & 50-530/86-27 on 861201-12. Violations Noted:Failure to Properly Protect Safe Shutdown Cables Through Fire Barriers & Test Breakers Mounted in Train B Essential Switch Gear Room

ML20205E912
Person / Time
Site:	Palo Verde
Issue date:	03/13/1987
From:	Ahmed I, Rebecca Barr, Andrew Hon, Ivey K, Petrosino J, Qualls P, Richards S, Stewart P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20205E799	List: IR 05000529/1986033 ML20205E794 ML20205E819
References
50-529-86-33, 50-530-86-27, NUDOCS 8703310045
Download: ML20205E912 (17)

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U. S. NUCLEAR REGULATORY COMISSION

REGION V

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~ Report No.

50-529/86.-33,50-530/86-27 License No.

.NPF-51 CPPR-143 Licensee:

Arizona Nuclear Power Project P. O. Box 52034 Phoenix, Arizona 85072-2034 Facility Name: Palo Verde Nuclear Generating Station - Units 2 and 3 Inspection of: Palo Verde Site, Wintersburg, Arizona Inspected by:

'$t4 'b2 nt L \\3-W1 r

R. Barr, Team Leader Date Signed L

$~III rat 3 - 13 K1 1. Ahmed. Electrical Engineer Date Signed

$JS b j2 r4 1-\\3-El A. Hon, Project Inspector Date Signed SLA' h[2b WL 3 - 13 -C K. Ivey, Resident Inspector Date Signed R b b ).

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& \\1-K7 P. Qual's, Project Inspector Date Signed

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% \\3.W1 J. Petrosino, quality Assurance Specialist Date Signed Srh 4- {\\Ekb CL

% \\ &~ D P. Stewart, Resident Inspector Date Signe3

$MI DNJ [

3. s3 - WI Approved by:

5. Richards, Chief Date Signed Engineering Section Sunnary:

Inspection on December 1-12, 1986 and February 3 and 6, 1987 (Report No.

50-529/86-33, 50-530/86-27)

Areas Inspected: Annual announced team inspection of PVNGS focused on design changes and modifications originating from operating and maintenance experiences and translation of lessons learned at Units 1 and 2 to Unit 3.

The following activities were examined:

870331004D 870333

{DR ADOCK 05000529 PDR

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2-1)

Design Change Program

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Engineering Evaluation Request Process 3)

-Quality Assurance Program 4)

Fire Protection Program 5)

Technical Specification Surveillance Program 6)

Information Bulletin, Notice and Post Trip Review Report Action Tracking Systems To the maximum extent feasible, the effectiveness of these activities was assessed as they pertained to the electrical discipline.

Results In the areas inspected, three apparent violations of NRC requirements were

identified and 11 open items recorded.

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DETAILS 1.

Persons Contacted

• M. DeMichele, President

• J. Haynes, Vice President Nuclear Production

• E. Van Brunt, Jr., Executive Vice President

• J. Bynum, Plant Manager

• W. Ide, Director, Corporate QA/QC 0. Zeringue, Technical Support Manager

• T. Shriver, Compliance Manager

• R. Baron, Compliance Supervisor G. Sowers, Acting Manager Operations Engineering

• A. Rogers, Manager Nuclear Engineering L. Clyde, STP Supervisor In addition to the individuals identified above, the inspectors met and held discussions with various engineering, maintenance, operations and quality assurance personnel and other members of the Ifcensee's staff.

• Denotes individuals attending the final exit meeting on December 12, 1986.

2.

Design Changes a.

Design Change Program The licensee's Design Change Program was evaluated for control and implementationofdesignchangepackages(DCP). The objectives of the evaluation were to ascertain if the licensee had followed their procedures for design changes, if the design changes conformed with regulatory requirements, FSAR connitments and industry standards and if procedures for Quality Class Q DCP's were of sufficient content and addressed the following areas:

Methods and responsibilities for conducting safety evaluations, Methods for assuring the design change does not involve an unreviewed safety question as described in 10 CFR 50.S9 or does not require a change in the technical specifications, Post-modification acceptance testing and evaluation of the test results.

Incorporation of Design Changes into all three units.

Field changes and actuel installations were properly verified against the as-built drawings and affected drawings were updated and FSAR and/or technical specification changes, if required, due to the design change were properly initiate.

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The design change packages sampled during the inspection were in the electrical discipline and included packages relating to the interface between the offsite power systems and the onsite electrical distribution system. A total of 13 DCP's and their associatedplantchangepackages(PCP's)wereevaluated. The design changes sampled during the inspection were generated by Bechtel and coordinated and approved by ANPP's Change Control in accordance with the applicable revisions of ANPP's " Design Change Package" procedure IP-4.34. Out of the 13 DCP's evaluated, only two DCP's had instructions on the cover sheet which indicated the change was applicable to the other units. ANPP personnel informed the inspector that although the other applicable units were not indicated on the cover sheet, similar design change packages were generated for the other two units. The inspector verified this to be correct.

The DCP's were found to contain all necessary documents such as a DCP information sheet, field change requests, design change notices (DCNs),supplierdocumentchangenotices(SDCNs),andasafety evaluation with reference to 10 CFR 50.59 requirements.

The inspector evaluated drawing revisions and the technical adequacy of the changes. The only discrepancy identified was at Unit 2 where a design change had been made but the drawing had not been updated.

The licensee promptly revised the drawing when infomed of the error. This was considered an isolated incident as all the other drawings reviewed were correctly changed and the same drawing for the other two units did have the change incorporated. The inspector verified equipment installation at Unit 3 to be in accordance with approved drawings.

DCP'swereimplementedbymeansofaplantchangepackage(PCP).

PCP's were initiated by ANPP's Change Control Group (CCG) using forwarded DCP's. The PCP's included the PCP process records, work sumary, plant change request (PCR) evaluation, DCP information sheet, CCG review /coment discipline sheets, unreviewed safety ouestion determination, configuration document checklist, as-built verification, and PCP close out-records. All pertinent documents of the PCP's were reviewed for administrative and technical adequacy.

While these documents were assessed as being technically adequate, in some cases design change documents appeared to lack reference identification. The PCP's included the associated DCP in the PCP package but did not identify the DCP document number. The only identification provided in the PCP was the item change description which did not match the description on the associated DCP. The omission of the DCP document number made it difficult to verify that the change corrected the originally identified deficiency. The inspector observed that referencing the DCP by number in the PCP would aid in ensuring that the original DCP is properly closed out.

No violations or deviations were identifie.

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• b.

Cable Tray Supports Because it appeared that several safety-related seismic cable tray support installations had excessive distances between the cable tray supports, a review of the APS Civil / Structural Design Criteria Manual (DCM), Part II, Revision 12, was performed to ascertain if the design criteria and design basis were correctly translated into appropriate acceptance criteria, and if the design requirements and quality activities had been satisfactorily accomplished.

Part II of the ANP Civil / Structural Design Criteria Manual states,

"all seismic Category I cable tray supports shall be designed per (Bechtel) design guide C2.7". Bechtel Design Guide C2.7 is utilized to establish the criteria for determining the maximum spacing of supports in various buildings at various elevations.

After sampling 15 cable tray spans in the control building and five spans in the auxiliary building, it appeared the maximum allowed support spacing design criteria delineated in part II of ANP's Civil / Structural DCM had not been adhered to in the design of the cable trays because spans were greater than allowed by the design criteria. After researching this concern, the licensee identified that the design criteria had been changed subsequent to the design of the cable trays at PVNGS. The design of the cable tray supports was completed in the period between 1976 and 1979. The criteria that is now in place was added to the APS Civil / Structural Design Criteria Manual on November 19, 1982 to provide guidance to the electrical group for cable tray layout. The design criteria used for the cable tray support design was based on load combinations which is in another section of the APS Civil / Structural Design Criteria Manual and is still applicable to the Palo Verde design.

During the review, the licensee found that all supports did not have a specific calculation. Thedesigngrcup(Bechtel)hadperformed bounding calculations and the design engineers would refer to these bounding calculations when deciding the acceptability of a specific support. However, the bounding calculation used was not recorded.

Also in some cases where a specific parameter exceeded the bounding calculation, engineering judgement was used to justify the design.

For example, if the bounding calculation was for a support which supported four cable trays 12 feet long, the engineer would judge that the same support would be acceptable for two trays, 15 feet long.

To provide additional assurance that the cable tray supports wern acceptable, the licensee performed an initial examination of sev!ral noted deviations to the C2.7 design criteria subsequent to the team raising the concern, and found no safety concerns. The licensee further completed an analysis of 63 cable trays and supports to confirm to a 95/95 confidence level that the engineering judgements of the design engineers were acceptable. All 63 cable trays and supports were in conformance with the cable tray design and all applicable design requirements. The 63 supports selected included approximately 32 cable trays and supports that had a change of direction fitting. These were selected to ensure that a design

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deficiency identified at another nuclear plant was not also present at Palo Verde.

The circumstances surrounding the evaluation of cable tray support design criteria will be further reviewed during a subsequent inspection. (50-529/86-33-02).

No violations or deviations were identified.

3.

Engineering Evaluation Request (EER) Process The purpose of the EER program is to provide a method for the licensee and its contractors to document technical inquiries made to the station's Technical Support Department and to document the resolution of the inquiries. The EER program pertains to all plant safety and non-safety equipment, a.

EER Procedure Review The following EER program procedures and plant procedures used in the resolution of deficiencies were reviewed:

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73AC-0ZZ29 Engineering Evaluation Requests (Palo Verde Station Procedure)

j 71AC-0ZZ03 Interdepartmental Event Investigation IP-5.27 EngineeringEvaluationRequests(Bechtel Procedure)

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79AC-92207 Nuclear Safety Review and Evaluation QAD 2.0 Quality Assurance Program

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No violations or deviations were identified, b.

EER Review Theinspectorexamined45EERs(andassociatedworkrequests,etc.)

that required resolution by the electrical discipline. The EERs

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examined were associated with deficiencies in the following safety related electrical equipment and systems:

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Plant Protection System Relays Core Protection Calculator Diesel Generator Relays (overcurrent, undervoltage, exciter field flashingandexcitershorting/K-1)

EngineeredSafetyFeatureActuationSystem(ESFAS)

Loss of Power Sequencer for 4.16KV Bus (BOP-ESFAS)

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• 125 Volt DC System (Inverter and DC Motor Control Centers)

4.16KV Switchgear Breakers and Relays 480V MCC Breakers IEControlPowerDistributionSystems(Fuses,TerminalBlocks,etc.)

The inspector made the following observations concerning the EER program.

1)

17 of the 45 EERs were dispositioned as "information only."

The inspector considered that the method of dispositioning EERs, as described in paragraph 5.3.4 of ;'ocedure 73AC-0ZZ29, as "information only" was a weakness in tie licensee's EER program. Several "information only" EERs wei1 resolved by the system engineer with recommendations to revise procedures. The EER program does not provide a method for formally transferring the responsibility to the cognizant department manager for consideration of implementation of this recommended corrective action.

The proble:n is only referred back to the originator for his information. No formal administrative control is in place requiring the initiator to take further action. Based on the review of 45 EERs, it appears the EER Program has evolved into being used for functions for which it was not intended (i.e. a catch all system for dispositioning plant problems).

The lack of a formal method in the EER program to transfer the responsibilityforimplementingrecommendedcorrectiveactions for "information only' EERs is an open item pending review of therevisedEERprogram(50-529/86-33-03).

2)

The inspector identified a technical deficiency in the resolution of EER 86-PB-003. The EER documented the failure of the 4.16KV emergency busses' degraded undervoltage relays to meet the 35 second time requirement of plant technical specifications. The licensee's nuclear engineering department had the response time for the degraded undervoltage relays lowered to 33.5 seconds from the previous settings. The p(36.75 seconds)gswereinerrorbecausetheacceptancecriteria revious settin used for startup testing was greater than the 35 seconds required by technical specifications. The inspector noted that the vendor technical manual on the degraded voltage Agastat relay stated that the accuracy for repeatability was 5%

for nonnal operation of the relay. This accuracy band in conjunction with the present setpoint could result in operation outside Technical Specification limits by 0.18 seconds.

Accordingly, the licensee initiated EER 86-PG-014 to lower the setting of the time response of the 4.16KV degraded voltage relays. The inspector found the licensee's actions acceptable based on the review of the satisfactory surveillance on the subject relays (highest response time was 34.7 seconds)

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currently installed and the licensee's initiation of corrective action.

3)

EER 85-51-190 and 86-ZJ-042, both "information only" EERs, were inadequately dispositioned based upon the remarks made in the engineering response section of the EER. In both instances the licensee agreed that the documented engineering response was inadequate. In both cases the licensee indicated that additional corrective actions had been implemented but not formally documented in the EER program. This demonstrates a lack of an active functional quality assurance role in the EER program. The Quality Assurance Supervisor acknowledged periodic reviews of "information only" EERs are not conducted (50-529/86-33-04).

4)

Ten EERs requiring hardware modifications or which were resolved by " accept as is" in the field were evaluated. No deficiencies were identified.

No violations or deviations were identified.

c.

System Trending The EER program was discussed with ten electrical system engineers or their supervisors. From these interviews the inspector determined the station's system engineers are not reviewing trends, surveillances and maintenance activities of the systems for which they have cognizance. It appears that the systems engineers'

function is primarily reactive, responding to problems which cannot be resolved by the maintenance and operation's staff. The inspector also noted that no functional job description currently exists for the system engineers (50-29/86-33-05).

No violations or deviations were identified.

As a result of the progrannatic deficiencies identified with the EER process and the system engineer's )rogram, the licensee should consider re-evaluating these programs for tieir effectiveness. Additionally, QA auditing should be expanded to include "for information only" EERs.

4.

Quality Assurance a.

Quality Program Review Theinspectorsassessedthelicensee'sQualityAssurance(QA) review of the design control process. The licensee has a program that monitors the design change process and a program to periodicall{systemofthemonth".

review the The licensce's formal QA audit of the design change process consists of an audit conducted every two years. The last audit, performed by the licensee, identified problems which are being corrected. The audit program appeared to meet the regulatory reouirement to which the licensee had connitted.

An overall concern is that while the QA Program appears to be effective in identifying deficient conditions and correcting root i

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causes, it has not assured that the identified deficiencies did not impactsafety(50-529/86-33-06). Sub-paragraphs 4.b and 4.c provide examples of this concern.

No violations or deviations were identified.

b.

Quality Assurance Review of Design Changes l

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To provide quality assurance, as required by Appendix B to 10 CFR 50,theANPP'sQAprogram(QAD2.0)isappliedtoallitems classifiet' as quality class Q.

The inspector reviewed a sample of PCP's to t.scertain the degree of QA involvement in the design change process. The inspector found that post construction turnover PCPs did not indicate by QA signature that the ap)11 cable requirements were met in the design, construction and as-)uilt verification of the design change. The QA review of post construction design changes was perfortred during the generation of the design change work order (which is just prior to the implementation of the design change). This represented a change to the review process used during the original Asign.

In reviewing the licensee's instructions on qua. icy, the inspector could not find documentation on what the scope of the QA review for post construction design changes included. Therefore, it was difficult to verify that quality standards and design requirements comensurate with the measures applied to the original design had been incorporated throughout the development of the design change. However, no violations were identified associated with quality in the packages reviewed (50-529/86-33-01).

An example of where the lack of clearly defined QA review criteria could have resulted in a design deficiency is DCPf20M-50-058. This design change added voltage dropping resistors to the Heated Junction Thermocouple (HJTC) circuitry and changed cabinet hardware.

The cabinet is qualified seismically. The modification changed the configuration and size of the resistor's printed circuit board and the fasteners which secure the electronics drawer inside the cabinet. In reviewing the completed design change package neither the inspector nor the licensee could ascertain if the seismic qualification had been altered or reevaluated. Upon contacting the vendor, the licensee verified that a seismic reanalysis had been performed for the component configuration and hardware change.

In addition to the DCP's and PCP's, the inspector reviewed the following items involving interface between the offsite power and onsite electric distribution system for correct design calculations and appropriate quality assurance:

The new set point of degraded grid voltage time delay trip relays.

Design changes to the fast transfer scheme of the reactor coolantpump(RCP) buses.

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RCP coastdown calculation while connected to the de-energized bus.

In general, the review of DCP's and PCP's indicated that the changes were being correctly identified, properly designed, evaluated and implemented. However, although the documentation of the quality reviews may have been complete, the inspector found it difficult to verify that quality standards and design requirements had been incorporated in the design change. A clear definition of the scope of the quality reviews could result in better documentation that the quality standard and design requirements had been properly incorporated in design changes.

No deviations or violations were identified.

c.

Unmarked Bolts While evaluating cable tray supports, many unmarked 1/2" diameter bolts were observed. By A-307/AISC these bolts are required to have the manufacturer's identification on the bolt head. The licensee stated this issue had been previously identified by the Construction Appraisal Team (CAT). To assure safety and alleviate the CAT Team concern, the licensee torcued all the cable tray support bolts to their design value anc also re-performed a sample torquing. These actions were evaluated by)the CAT and considered sufficient to meet bolt strength (design requirements. However, no actions were documented by the licensee to assure unmarked bolts were not used in other applications.

The licensee should evaluate the circumstances that resulted in the procurement of unmarked bolts for the cable tray support application and take actions necessary to obtain the confidence that

)rocurements of unmarked bolts other than the cable tray supports Jolts have not been made. Additionally, the licensee should perform a walkdown of safety systems to assure no unmarked bolts were used insafetysystems(50-529/86-33-07).

No violations or deviations were identified.

d.

I,nternal D:.ston 'udit Review In conjunction with the DCP/PCP review, internal design audit ANPf86 002(4/14-30/86) was reviewed. As a result of the licensee's audit,sixcorrectiveactionreports(CARS)wereissued. CAR

1. 86 0088 identified that during a 12 month period, 600 field changes, which were not reviewed by QA, had been implemented on design change packages. The CAR appears to have corrected the deficiency of field changes being implemented without QA's concurrences however, consideration was not given as to what potential adverse effects may have resulted from implementation of the field changes without QA concurrence. The licensee should review those field changes that were implemented that required QA approval but did not have it to assure no adverse impact resulted fromthechango(50529/86-33-08).

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No violations or deviations were identified.

e.

During the inspection a sample of fourteen SAE Grade 8.0 bolts were selected from the Palo Verde warehouse. These bolts were independently tested by the NRC to detemine whether the bolts met the specifications.

It was detemined that three of these were SAE Grade 8.2 which is a high strength bolt of similar quality except that SAE Grade 8.2 bolts will degrade at temperatures above 500*F.

On February 3, 1987, the licensee advised that all high temperature applications were reviewed and all specifications for bolts with high temperature applications required ASTM or ASME bolts.

Therefore, since all SAE bolts are used for low temperature applications, the substitution of SAE Grade 8.2 bolts for SAE Grade 8.0 at Palo Verde would be acceptable.

No violations or deviations were identified.

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Fire Protection i

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program Review The inspectors reviewed fire protection program involvement in the design change process and during facility tours observed fire

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barrier installations. To ensure fire protection 3rogram compliance, review of design change packages is necessary to (eep the fire hazards evaluation current. The licensee's required review of

l proposed work activities is accomplished by procedure no.

14AC-0ZZ04, which requires the issuance of a permit to allow large

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amounts of combustible materials into safety related areas and to

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control ignition sources. In QA audit 86-23, the licensee identified

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that fire protection issues were not being consistently reviewed

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during the design change process. The licensee is taking corrective

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No violations or deviations were identified.

b.

Thermolao Installation i

The inspectors observed the apparent improper installation of I

thermolag fire barriers used in the plant. These barriers were installed to separate redundant safe shutdown trains required to l

ensure that the unit could be safely shutdown in the event of any postulated fire in the facility. These barriers were required by the facility's operating license as a license condition.

The manufacturer of the thermolag material reconnends that steel members and conduit which penetrate the thermolag envelope be coated to a distance of 18 inches from the envolose. The requirement is based on fire test results performed by otler utilities and prevents damage to the protected cables due to thermal conductivity. This guidance was first published by the manufacturer in late 1983.

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The thermolag installed in Palo Verde in many cases has no coating on intruding steel or conduits. The design specification in place since about 1981 calls for no coating on the intruding steel.

For a fire barrier to be rated the NRC requires it be installed in a configuration which has been tested at an approved independent testing laboratory and to have passed an ASTM test. It appears the test performed for Palo Verde did not include any intruding steel; however, intruding steel is typical of many of the installations in the plant. The inspectors observed that neither the licensee engineering organization nor the QA organization identified this error in testing.

Licensee staff told the inspector that an analysis performed by the licensee indicated that if the intruding steel were not coated the barrier rating would only be 34 minutes. The plan requires 1 and 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers to be in place in the plant.

violation (properly protect safe shutdown cables is an apparent Failure to 50-529/86-33-09).

Examples of cables not protected in an approved barrier which are required for safe shutdown include:

TheAtmosphericDumpValveVPI(2)

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and the N,, Supply Valve Operator Power Supply (2')

Power Supply to the Steam Supply 2EZCAEARK77

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Valve to the AFW Turbine Power Supply to the AFW Turbine 2EZCAEARK79

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Trip Throttle Valves Power Supply to the AFW Regulating Valve Motor Power Su) ply to the Steam Supply 2EZC2EARK05

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M0V to t1e AFW Turbine The Itcensee has posted fire watches in affected plant areas until this item is resolved.

c.

Vendor Information Program As a result of the Salem ATWS Event, Generic Letter 83-28 was issued. This letter required Itcensees to have a program to ensure that vendor information for safety-related components is complete.

It is not clear that ANPP had the TS! technical note revision, first published in the Spring of 1984, which promulgated the 18 inch installation reconnendation for intruding steel.

This item is open pending further review of the ef fectiveness of the licensee's GenericLetter8328vendorinforrationprogram(00-529/8633-10).

No violations or deviations were identified.

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6.

Maintenance The inspection objective was to evaluate the licensee's Maintenance Programtoascertainifcorrectivemaintenance(CM)andpreventive maintenance (PM) activities relative to electrical and I&C disciplines were conducted per approved licensee procedures and that these procedures were adequate for the tasks performed, a.

Program Review The licensee's corrective maintenance activities are controlled by procedure 30AC-9ZZ01, " Work Control". This procedure defines the responsibilities of various supervisors and individuals who perform tasks associated with maintenance related activities. The licensee's policy is that station work should not be performed without proper

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authorization. Maintenance work is performed under Work Orders that provide the authority and instructions to craftmen for task performance. Normally, a Work Request generates a Work Order. A Work Request r:ay be initiated by any PVNGS employee who discovers the need for maintenance and obtains his supervisor's concurrence. The Work Request can also be generated to disposition DCPs, PCPs, EERs, CARS or NCRs.

Typically, after a Work Request is initiated, it is sent to the shift supervisor for inanediate 11 ant impact assessment and reportability determination. T1e Work Request is then sent to the Work Control Group for prioritization and the Maintenance Control Center (MCC) for entry in the Station Information Management Systems (SIMS). Upon review by the Planner Coordinator (PC) in the MCC, a maintenance Work Order is prepared. For safety related equipment the work order is sent to QA for QC inspection hold point insertion.

Appropriate post work retesting is also included in the Work Order.

The Work Order package is then sent to the Work Control Group for scheduling. The actual work is then perfomed by appropriate maintenance disciplines after necessary clearance and precautions are taken. Completed Work Order packages are then forwarded to the Maintenance Control Center for work closure by the cognizant PC.

Quality related Work Control packages are also concurred with by department representatives.

Final closed out packages are stored in the designated storage facility.

The licensco's preventive maintenance activities are controlled by procedure 30AC-9ZZ02 " Preventive Maintenance".

It defines responsibilities of various group supervisors. The process is similar to that of the CM program. The major difference is pre-approved procedures are used in the PM Work Orders since the tasks are periodically performed. The specific PM and frequencies are determined based on vendor technical manuals, equipment qualification reports, NRC Bulletins and Notices, industrial experience and eculpment history. Once the pre-approved PH Work Order is preparoc and performed and the actiodicity is detemined, the PM is put in the SIMS. Thereaf ter, t1e PM Work Order nomally would be generated by the S!MS.

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• The licensee's program appeared to be adequate in controlling preventive and corrective maintenance tasks.

No violations or deviations were identified.

b.

Procedure Review Samples of PM and CM Work Orders were reviewed. The Work Orders included the necessary precautions prior to initiating the work and the necessary retesting after completing the work per 30AC-9ZZ01 and 30AC-9ZZ02. The instructions to perform the actual maintenance appeared to be adequate for the PM Work Orders reviewed; however, the troubleshooting instructions in the CM Work Orders reviewed appeared to lack detail. The instructions were nothing more than a simple statement to troubleshoot.

It is recognized that the complexity of troubleshooting electrical and electronic equipment varies significantly and relies heavily on the capabilities of the technician. However, the simple statement of "go troubleshoot" in most cases is insufficient direction to the worker and does not appear to meet the intent of ANS-3.2/ ANSI N18.7-1976 section 5.3.5.

The simple statement of "go troubleshoot" demonstrates the licensee had not developed a well thought-out troubleshooting action plan prior to performing the work. Of the maintenance tasks observed, the lack of detail in the troubleshooting procedure did not impact the job task; however, the troubleshooting tasks that were observed were considered routine. For complex tasks more detail in troubleshooting procedures would improve the probability of early discovery of root cause and reduce the likelihood of adversely impacting plant operation. The licensee should develop a criteria that clearly defines when detailed troubleshooting procedures are required (50-529/86-33-11).

No violations or deviations were identified, c.

Observation of Maintenance Work in Progress The licensee's maintenance backlog was reviewed and it a >peared that the completed Work Orders had been identified on the bac ciog. The inspector attended the daily Unit 2 Work Control Group meetings.

The meeting appeared to accomplish its intended objective of assuring all plant work activities were identified, understood, properly scoped and scheduled. The inspector witnessed several pMs and cms in progress and found that the licensee's technicians appeared to be competent, adhered to procedures and paid attention to detail.

No violations or deviations were identified.

d.

Control of Matarial Stored After Maintenance Activitiess Procedure 30AC-9ZZ01 " Work Control". Appendix H. establishes the following requirements for material storage following maintenance activities:

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"10. Storage containers, compressed gas cylinders, etc.

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Containers, cylinders to be anchored / secured away from safety related equipment, except when being moved.

14. Material Handling and Storage b.

Equipment or material may be stored in a safety related area provided the following criteria is met:

Equipment is anchored / secured away from safety related equipment."

Contrary to the above, the inspector found the following conditions at Unit 2:

Test breakers mounted on casters were stored unsecured in the Train B Essential Switch Gear Room.

A Bisco seal injection unit was stored unsecured in the area of the component cooling water surge tank at the auxiliary building 120'

level.

Compressed gas bottles were stored unsecured at the 100' level auxiliary building in the vicinity of the containment hydrogen monitor panel.

Corpressed gas bottles were tied to safety-related piping and raceway supports in the following locations:

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The 120' level of the auxiliary building, compressed gas bottles were tied to raceway supports b.

The 100' level of the auxiliary building, compressed gas bottles were tied to containment hydrogen piping On February 3, 1987, the inspector identified a similar condition at Unit-1. A compressed gas bottle on the 78 foot level of the auxiliary building was found tied to a safety related raceway.

Thisisanapparentviolation(50-529/86-33-12).

e.

Main Steam and Main Feedwater Isolation Valve Maintenance The licensee's program to upgrade the preventive maintenance program for the Anchor Darling MSIVs and FWIVs was reviewed. No progranciatic deficiencies were identified. The valves had required excessive corrective maintenance during routine plant operations. During the period of 1984-86, 132 corrective maintenance activities were performed on the 8 HSIVs and 8 MFlys of Units 1 and 2.

Of the 132 corrective maintenance actions, 72 were due to nitrogen leakage from the nitrogen accumulator sub-syste,.

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The inspector interviewed the Anchor Darling technical representative concerning the high amount of corrective maintenance required on the MSIVs and FWIVs at Palo Verde and questioned how this compared to other nuclear plants. The Anchor Darling technical l

representative indicated that the corrective maintenance actions

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were high at Palo Verde compared to other plants. The

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Representative also stated that the corrective actions which were in progress are expected to reduce the corrective maintenance. The inspector. determined that the licensee had already completed actions to reduce nitrogen leakage from the nitrogen accumulator sub-system.

All nitrogen tubing fittings (except one per accumulator) had been seal welded to eliminate leakage. The Anchor Darling representative indicated that no other plant had experienced significant leakage from the fittings and that previous failures of the fittings had been due to damaged sealing surfaces due to improper seating techniques used by technicians and maintenance personnel. An inspection of selected MSIV's and MFIV's revealed no additional problems with the nitrogen accumulator sub-system.

The components requiring the second highest frequency of corrective maintenance were the air driven hydraulic pumps (17 maintenance actions). The Anchor Darling representative indicated that the licensee had previously not implemented the recommended changes that corrected air driven hydraulic pump failures due to a lack of lubrication. The licensee has now implemented the recommended preventive maintenance lubrication on the pumps.

The other 43 corrective maintenance activities were associated with various oil leaks and oil leaks by the 0-rings internal to control valves. 0-ring and oil seal leakage are not unexpected as the valves are currently 7 - 8 years old at this time. The licensee is currently implementing a five year preventive maintenance overhaul cycle for the valves. Two Unit 2 valves are planned to be overhauled in January 1987 and all Unit 1 valves in October 1987.

Based upon the licensee's actions and future planned actions to upgrade the MSIVs and FWIVs and these valves' preventive maintenance program, the inspector concluded that the licensee was taking appropriate actions to increase the reliability of the valves.

No violations or deviations were identified.

7.

Surveillance Testing The administrative procedure for surveillance testing was reviewed and discussed with the Surveillance Program Coordinator (SPC). The inspector verified that the licensee's program had provisions that include:

A master schedule for the performance of the tests.

Responsibility to maintain the schedule up to date.

Requirements to conduct tests in accordance with approved procedures.

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Responsibility for review and approval of test results.

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Responsibility to ensure that tests are performed within the Technical Specifications maximum allowable extension.

The Surveillance Procedure Group (SPCG) is responsible for the overall coordination and implementation of the surveillance program. This includes scheduling the performance of the tests, generating the appropriate work orders and test packages and tracking the actual performance dates of the weekly or longer interval periodically scheduled i

surveillance tests. The actual performance date of a test is the responsibility of the assigned performance group in accordance with the applicable scheduling procedures for that group. The performance group supervisor is responsible for reviewing the test package to. ensure the~~

current revision was issued; however, the individual who performs the

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work is not. required to verify the current procedure revision prior to

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beginning work.

i The inspector reviewed eighteen completed surveillance test packages and identified two instances where tests were performed using the wrong procedure revision. 41ST-1HP02, " Containment Hydrogen Analyzer

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Functional Test", Revision 1, was performed on November 12, 1986.

However, Revision 2 was effective on October 20, 1986. 42ST-2RC04, "RCS l

Vent Path Operability", Revision 0, was performed on January 14, 1986.

However, Revision 1 was effective on January 2, 1986.

Thisisanapparentviolation(50-529/86-33-13).

Unrevised surveillance procedures are apparently used because significant time delays may occur between the issuance of the surveillance test package by the Surveillance Procedure Control Group (SPCG) and the actual performance of the test by staff technicians.

8.

Programs for Operational Event Reports The inspector held discussions with licensee personnel and reviewed program procedures governing the followup and tracking of NRC Bulletins, Information Notices, NRC Inspection Report findings / commitments, and Post Trip Review Report action items. The inspector noted that the tracking of these items had been significantly improved in-the past year. These improvements included changes to individual tracking programs and the LicensingCommitmentTrackingSystem(LCTS). The LCTS provides tracking and periodic management review of comitments made to regulatory agencies. The inspector concluded that these programs should ensure the following:

The review of Bulletins and Information Notices for applicability to the plant.

The resolution of action items resulting from the reviews.

The resolution of NRC inspection report findings / commitments.

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The completion of Posit Trip Review Report action items.

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The tracking of commitments made to regulatory agencies.

After reviewing the program status lists and closecut packages, the

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inspector concluded that items completed under the improved program were

. tracked and documented. However, for items identified. prior to the program changes, the tracking systems did not provide sufficient evidence that items were complete. The inspector reviewed three Post Trip Review Reports issued prior to.the program changes and three issued after the changes and noted one instance where the documentation was incomplete.

The inspector noted that 6 Information Bulletins and 58 Information

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Notices issued from 1979 to 1984 were listed as "open" on the licensee's status list. However, a subsequent licensee review revealed that the Bulletins were. closed and tntions complete. The inspector reviewed the closecut packages for eight Bulletins and six Information Notices and found the actions taken to be appropriate. The licensee committed to review all IN's to verify their correct status (50-529/86-33-14).

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No violations or deviations were identified, s

9.

Management Meetings The inspectors met with licensee management representatives daily during the inspection. On December 12, 1986, the inspectors met'with Corporate Management, the Plant Manager and other staff members to discuss the inspection findings.

.At the exit the licensee committed to the following corrective-actions:

Revising procedures to establish criteria for the scope of review required for each signature on the DCP review package checklist (50-529/86-33-01).

Performing a 95/95 review of cable tray supports to assure codeconformance(50-529/86-33-02).

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Verifying each sample deviation for the design of safety related cable tray supports and notifying the regional.

office of any safety concerns (50-529/86-33-02).

Revising APS and Bechtel design criteria for cable tray supports (50-529/86-33-02).

Revising procedures so that EER non-technical resolutions have the identified corrective actions assigned to the appropriatedepartmentmanager(50-529/86-33-03).

Performing periodic QA reviews of "information only" EERs (50-529/86-33-04).

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Reviewing the System's Engineer Program and developing functional job descriptions that include the engineer's responsibilities for each position (50-529/86-33-05).

Establishing fire watches in all plant areas affected by the improper installation of thermolag (50-529/86-33-09).

Researching records to obtain the APS design specifications for thermolag installation (50-529/86-33-09).

Correcting all thermolag installation deficiencies (50-529/86-33-09).

Establishing and documenting a criteria for when detailed f

troubleshooting is required during a corrective maintenance task (50-529/86-33-11).

Developing a writer's guide using craft personnel and technicians that provides instructions on how to prepare detailed troubleshooting instructions (50-529/86-33-11).

Issuing a memorandum to all employees clearly stating the requirement for securing transient equipment (50-529/86-33-12).

Revising procedures to clarify the requirements for securing transient equipment (50-529/86-33-12).

Removing or restraining all-transient equipment in safety related areas (50-529/86-33-12).

Revising Site Access Training to include an excerpt on the hazards and controls established for transient equipment (50-529/86-33-12).

Revising procedures to clarify the requirement of verifying the procedure is current prior to its use and train staff personnel to the requirement (50-529/86-33-13).

Verifying and documenting the completion of all action items for Post Trip Review Reports and applicable IENs issued prior to 7/1/86 were completed (50-529/86-33-14).

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